Bureau of Environmental Management 1145 Market Street, 5th Floor San Francisco, CA 94103 T 415.934.5700 F 415.

934-5750

July 18, 2012

Diana Sokolove, Senior Environmental Planner Environmental Planning Division San Francisco Planning Department 1650 Mission Street, Fourth Floor San Francisco, CA 94103 RE: CEQA Exemption Request for the Ocean Beach Sand Maintenance Project SFPUC Index Code: CWWRNRTF47 Planning Department Case:

Dear Diana: The San Francisco Public Utilities Commission (SFPUC) requests review of the proposed Ocean Beach Sand Maintenance Project (project) under the California Environmental Quality Act (CEQA). The purposes of this letter are to: 1) Provide the Environmental Planning Division (EP) with information on the proposed project; and 2) Request EP review and concurrence that the project is categorically exempt under CEQA. CEQA Guidelines Section 15304 provides exemptions for Minor Alterations to Land. Class 4 consists of minor public or private alterations in the condition of land, water and or vegetation which do not involve removal of healthy, mature, scenic trees except for forestry or agricultural purposes. The San Francisco Planning Department has clarified that stabilization of shorelines in areas that are not environmentally sensitive is also included under the Class 4 exemptions in List of Projects that are Generally Categorically Exempt from Review Under the California Environmental Quality Act (CEQA) adopted by the Planning Commission August 17, 2000. The following description of the proposed activities demonstrates the proposed project would not result in any adverse environmental effects, and provides support for our recommendation that the activities are categorically exempt under CEQA. The project would be conducted in compliance with applicable federal, State and local regulations and under contractual provision prohibiting work in violation of applicable regulations and plans. The Project would comply with all of the SFPUC Standard Construction Measures, issued February 7, 2007, which are on file at EP.

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 3

BACKGROUND The purposes of the proposed project are: (1) to remove sand from in front of the OShaughnessy Seawall in order to reduce future sand maintenance efforts; (2) maintain public access on the promenade and stairwells that have been blocked by sand build-up; (3) provide bluff protection in high risk areas that threaten The City of San Franciscos infrastructure; (4) enhance beach access in the erosion hotspot area south of Sloat Boulevard; and (5) reduce the need to implement more engineered bluff protection measures in the short-term. Since the 1970s due to various natural and manmade factors, the beach at the northern end of Ocean Beach has been widening while the southern end has been shrinking. The effects are especially notable during the spring, when shifting winds and currents accumulate sand and create large sand mounds in the north while the beach has recedes by many feet in the south. Sand aggradation at the northern end of Ocean Beach this season has resulted in sand overtopping the OShaughnessy Seawall and accumulating in the parking lot and along the Great Highway, burying stairways and impeding access along the promenade. Currently the sand is in excess of 13 feet deep at the face of the seawall. It has been estimated that over 200,000 cubic yards of excess sand have accumulated within a 4,200-foot long reach of beach. At the same time, the bluffs from Santiago Street to Fort Funston are eroding at an unprecedented rate. The City of San Francisco (City) has placed approximately 1,000 feet of temporary rock revetments in two critical places south of Sloat Boulevard over the past 15 years. However erosion from storms each year requires constant maintenance of the bluffs to protect the Citys wastewater and transportation infrastructure. To address the issues of excess sand and sand deficit at opposite ends of Ocean Beach, the National Park Service (NPS) Golden Gate National Recreation Area (GGNRA) in conjunction with two City departments, the San Francisco Public Utilities Commission (SFPUC) and Department of Public Works (DPW) propose to transport approximately 100,000 cubic yards (cy) of sand annually, over a period of up to five years, (depending on the performance of the newly created sand berms), from the beach west of the OShaughnessy Seawall to the erosion hot spots south of Sloat Boulevard to provide temporary shoreline stabilization and protection for the SFPUC Lake Merced Transport Tunnel, a critical wastewater facility, as well as the Great Highway. NPS and the City are actively participating in the comprehensive planning efforts at Ocean Beach led by San Francisco Planning and Urban Research Association (SPUR), which aim to develop long-term solutions that would address the complicated land

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 4

use, resource protection, public recreation, and shoreline stabilization issues at Ocean Beach. The proposed project would serve as an interim measure until a more permanent solution is developed. NPS owns and manages Ocean Beach as part of the GGNRA, the SFPUC operates the Citys wastewater infrastructure, notably the Lake Merced Transport Tunnel located under the Great Highway, and DPW maintains the Great Highway. The GGNRA has initiated and will complete National Environmental Policy Act (NEPA) compliance for the proposed project and will pursue issuance of necessary permits to implement the proposed project. DESCRIPTION OF THE PROPOSED PROJECT The proposed project involves excavation of sand at the beach along the OShaughnessy Seawall, transporting the sand via 30 cubic yard (cy) dump trucks, and placing the sand west of the bluffs south of Sloat Boulevard for temporary protection from erosion during high wave winter storm events. Excavator, loader, and bulldozers would be used to move and load sand into 30 cubicyard articulated off road dump trucks from the area of excavation indicated on Figure 1. The areas to be excavated would approximately 150-200 feet wide, 4,200 feet long, and to a maximum depth of 13 feet. Equipment would enter and exit through an access point at the south end of the OShaughnessy Seawall near Lincoln Boulevard. The proposed project would place sand on an approximately 0.5 mile stretch of bluff south of Sloat Boulevard. The project would prioritize sand placement at two different locations, the bluffs approximately 600 feet south of Sloat Boulevard, which is known as Reach 3 as identified in the 2011 Lake Merced Tunnel/Great Highway/Ocean Beach Emergency Project Design Report prepared for the SFPUC by Moffat and Nichols, and another area approximately 2,000 feet south of Sloat Boulevard, identified as Reach 2 in the same report, west of the Great Highway from the SFPUCs Oceanside Water Pollution Control Plant. The reach selected for sand placement would depend upon the erosion rate and bluff protection needs in a given year. Reaches 2 and 3 have been identified as the locations where the Lake Merced Transport Tunnel and the Great Highway are most threatened by erosion. If excess sand is available after placement at Reaches 2 and 3, it would be placed in other adjacent shoreline areas. A sacrificial berm (maximum dimensions 60 feet wide by 1,400 feet long, and 30 feet deep) would be established each year to protect the eroding bluffs. The height of the berm would not exceed the elevation of the adjacent parking lot and Great Highway. Sand would be dumped from the top of the bluff and spread by bulldozers and loaders as required. The berm would cover an area of the existing rock revetment and also create sand ladders for beach access. Design of the berm would place approximately 70

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 5

cubic yards of sand per lineal foot of bluff face. In the first year, a sand ladder would also be constructed at the MUNI 23-Monterey bus turn around at Sloat Boulevard west of the Great Highway to facilitate construction equipment access to the beach. Prior to placing the sand on the beach, hazardous rubble such as sharp pieces of metal and asphalt would be removed. Vehicles and equipment that would be used would include 8 30-cubic yard articulated dump trucks, 1 excavator, 1 loader, and a maximum of 4 bulldozers. The proposed project duration is approximately 5 weeks. Staging would occur at the southern end of the parking lot near the OShaughnessy Seawall and the Sloat parking lot at the southern end of the project site. These staging areas would be used to store, refuel and service the construction vehicles at the end of each day. These two staging areas would be partially closed to the public during construction, allowing for as much public parking as possible without affecting the construction operation. To expedite the construction, southbound lanes of the Great Highway would be closed during normal construction hours, Monday through Friday between 7:00 AM and 8:00 PM. No night or weekend work would occur. The dump trucks would move north and southbound on the closed lanes with access to the beach at both ends. The construction contractor would implement a San Francisco Municipal Transportation Agency (SFMTA) approved traffic routing plan. Sand relocation activities would be restricted during western snowy plover (a federally-listed threatened species) overwintering season on Ocean Beach (July 1May 15), such as the first year, as sand excavation would be precluded south of Stairway 21 and construction vehicles would not encroach south of Stairwell 28 to avoid disturbance of the bird species. In subsequent years, if project activities occur outside of the overwintering season, the excavation area could extend as far south as Stairway 28. See the Biological Resources section below for a more detailed discussion of the measures to avoid conflict with the western snowy plover. ENVIRONMENTAL INFORMATION Aesthetics The proposed project would not result in any new above ground structures or vegetation removal. The sand at the north end of Ocean Beach shifts naturally with the seasons, therefore removing the excess sand would not result in any drastic changes in appearance. At the southern end, where sand would be placed over existing riprap, the visual quality would likely improve as areas of the riprap would appear more similar to the surrounding bluffs. Therefore, adverse effects to aesthetics are not anticipated.

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 6

Air Quality Emissions of dust and air pollutants during the project implementation are expected to be minimal given the limited duration of the project. There would be a total of 15 pieces of large construction equipment operating 5 days a week for 5 weeks. A maximum of 3,400 roundtrips by dump trucks would be required to transport the sand. Estimated emissions of criteria pollutants do not exceed Bay Area Air Quality Districts CEQA guideline and are as follows: Chemical PM 10 PM 2.5 NOx ROG Project Emissions (lbs/day) 1.46 1.45 49.91 6.02 Threshold (lbs/day) 82 54 54 54

The contractor would comply with the Citys Clean Construction Ordinance as required by the SFPUC standard contract technical specifications which include the use of biodiesel fuel (B20) and equipment rated Tier 2 or higher. Generation of airborne dust is not anticipated because the only material to be mobilized is sand-sized sediment. Because the project would not generate emissions greater than the thresholds specified in BAAQMD guidelines, and based upon compliance with the Clean Construction Ordinance, and implementation of SFPUC Standard Construction Measure Number 3, Onsite Air and Water Quality Measures, adverse effects on air quality are not expected. Biological Resources The project site is not located within designated critical habitat and does not involve any vegetation removal or any permanent development. Habitat for the western snowy plover (Charadrius alexandrinus nivosus), a federally threatened species, and a California species of special concern is found on Ocean Beach, but it is not designated critical habitat. In 2008 the NPS, through formal rulemaking, established a Snowy Plover Protection Area (SPPA) on Ocean Beach in order to provide a protection zone for western snowy plovers overwintering on Ocean Beach (no known nesting of snowy plover occurs on Ocean Beach). The NPS designated the SPPA to require dogs to be on leash from July 1 until May 15 (period when SNPL have been observed on Ocean Beach) and thereby attempt to minimize this activitys effect on SNPL.

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 7

In relation to the SPPA (see Figure 4), and if the project is being implemented during the snowy plover season, haul activities (no excavation) would be limited to a narrow corridor along the eastern edge of the SPPA, within 50 feet of the OShaughnessy Seawall between Stairwells 21 and 28. This travel corridor was determined by NPS biologist and Golden Gate Audubon Society representative Dan Murphy to be the best location for truck haul traffic to minimize interaction with snowy plovers (and other shorebirds) based on historical monitoring information and habitat preferences. The NPS has concluded that the project would Not Likely Adversely Affect Western Snowy Plovers. The bank swallow (Riparia riparia) is a state-listed threatened species that burrows in beach bluffs. An important nesting colony of bank swallows has been identified at Fort Funston, approximately 2.5 miles south of Reach 2. Active bank swallow burrows have been recorded approximately 300 feet south of Reach 2. There are no active bank swallow burrows in the project area. Dan Murphy of the Golden Gate Audubon Society and an NPS biologist have concluded the proposed project would not affect bank swallows. (Attachment 1) Because the project would not affect the western snowy plover or the bank swallow, adverse effects on biological resources are not anticipated. Cultural Resources Based on the San Francisco Groundwater Supply Projects Historic Context and Archeological Survey Report (ESA December 2010, on file at EP), which include a map of known archeological resources in western San Francisco, there are no known resources located at the excavation site. In addition the proposed project would not excavate sand below the depth of deposition, an average of 13 feet per year. The OShaughnessy Seawall, constructed between 1919 and 1929, is a historic resource. However, the proposed excavation activities would avoid contact with the seawall and would not affect the structure. The NPS has determined that the project would have no adverse effect on cultural resources. Hazards and Hazardous Materials A review of databases maintained by the State of California Water Resources Control Board GeoTracker or Department of Toxic Substances Control Envirostor confirmed no Open hazardous materials sites in the project area. In addition, excavation would not occur below 13 feet, and as such, no underground hazardous materials would be encountered. Adverse effects resulting from construction worker or public exposure to hazardous materials therefore are not anticipated.

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 8

Noise Construction noise levels would not exceed normal traffic noise on the Great Highway. Moreover, construction would be limited to the hours between 7:00 AM to 8:00 PM to comply with the San Francisco Noise Ordinance, as required in the SFPUCs Standard Construction Measure Number 6. Therefore, adverse noise effects are not anticipated. Recreation The proposed project would be located on public beaches with the overall aim of improving public access by removing the sand currently burying the staircases at the OShaughnessy Seawall and placing sand over existing rock revetment to improve access down to the beach south of Sloat Boulevard. Areas affected near the seawall would be limited to the area shown on Figure 2. At the south end the sand placement area is limited primarily to the existing rock revetment or bluff faces, and would have minimal effects on the flat beach areas where most of the recreation activities occur. Sand relocation activity would be completed in five weeks and would not occur during the weekends when the beaches experience greater usage. Due to the short duration of the construction period and the limited beach area occupied by the proposed project, adverse effects to recreation are not anticipated. Transportation The proposed project would not result in any permanent increases in traffic or use of on-street parking spaces. The proposed project would require 5 week closure of the two southbound lanes of the Great Highway between Lincoln as far south as the Oceanside Water Pollution Control Plant. However, the closure would be limited to Mondays through Fridays from 7:00 AM to 8:00 PM and would not occur evenings or weekends. Southbound traffic during construction hours would be rerouted to Sunset Boulevard, although southbound drivers could elect to use a number of other streets between the Great Highway and Sunset Boulevard. The contractor would develop a traffic control plan (including the use of cones, signs and flagmen) to ensure traffic is safely routed during the lane closures. Signs would clearly identify the detour route. Signs would also be placed at crosswalks to ensure pedestrian safety. The traffic control plan would be reviewed and approved by the SFMTA. The proposed lane closures would be temporary and would not occur during the evenings or weekends. The Great Highway is not designated as a Street of Major Traffic Importance by the SFMTA, which means it is not subject to restrictions on lane

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 9

closures or when construction activities in streets can occur. With implementation of the traffic control plan, adverse effects to traffic are not anticipated. The western terminus and turnaround for the 23-Monterey bus route is located at the Sloat Boulevard parking lot. The proposed project would not disrupt bus route service. The bus route would not be affected except the bus stop at the terminus would be moved temporarily to Sloat Boulevard, approximately 300 feet east of the existing bus stop for the duration of the construction period, including weekends. Signs would be erected to clearly indicate the location of the temporary stop. A plan would be developed and approved by the SFMTA for the temporary re-routing of the 23 bus line. Because the temporary stop would only be approximately 300 feet away from the original bus stop, and there would no disruption of services on the bus line, adverse effects to public transportation are not anticipated Staging and equipment access would affect about 20 parking spots at the OShaughnessy Sewall. However, there are a total of 600 parking spots available; therefore, construction would occupy approximately 3 percent of total parking for a period of 5 weeks. The parking lot at Sloat would be partially closed during construction hours. However, there is ample parking nearby on the sides and medians of Sloat Boulevard that could be used by visitors during the week. The majority of the parking lot at Sloat Boulevard would remain open during the weekend when it experiences heavier usage. Due to the temporary nature of the project, availability of the parking lots on the weekends as well as parking near the Sloat Boulevard parking lot, the proposed project would not result in adverse effects to parking availability. Water Quality The proposed project would be constructed during the dry season and equipment would not be used below the mean high tide line. All vehicle staging and fueling would be located in the parking lots adjacent to the beach. The proposed project aims to maintain the original grade of the beach, therefore, under State Water Resources Control Board Order No. 2009-0009-DWQ (NPDES NO. CAS000002) coverage under the State Water Resources Control Boards general construction stormwater permit would not be required. No effects to water quality or other waters are anticipated due to activities occurring only during the dry season and no vehicle or equipment operating below the mean high tide line.

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 10

CEQA Compliance/Recommendation Based on the above description, the SFPUC recommends EP determine the proposed Project is categorically exempt under CEQA Guidelines Section 15304. The Planning Department provides that stabilization of shorelines in areas that are not environmental sensitive are included in the "List of Projects that are Generally Categorically Exempt from Review Under the California Environmental Quality Act (CEQA)" adopted by the Planning Commission August 17, 2000. If you have any questions, please contact YinLan Zhang, Environmental Project Manager, Bureau of Environmental Management, at 487-5201. Thank you for your cooperation.

Irina P. Torrey, A.I.( p., Manager ireau of Enviroi intal Management

Cc:

Maria Jurosek, SFPUC Wastewater Enterprise Joseph Ortiz, SFPUC Project Management Bureau Frank Filice, SFDPW Steve Ortega, NPS

Attachment A . Project Figures Attachment B. Letter from Dan Murphy of Golden Gate Audubon Society Attachment C. Letter from NPS Concerning Western Snowy Plover

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 11

Attachment A
Figure 1. Project Area

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 12

Figure 2. General Area of Excavation

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 13

Figure 3. General Sand Placement Area

Reach 3

Reach 2

Diana Sokolove, Senior Environmental Planner San Francisco Planning Department

CEQA Exemption Request for the Ocean Beach Sand Maintenance Project July 18, 2012 Page 14

Figure 4. Project Area Adjacent to Stairwell 21

Attachment B

July 6, 2012 2945 Ulloa St. San Francisco, CA 94116 Frank Dean, Superintendent Golden Gate National Recreation Area Building 210, Fort Mason San Francisco, CA 94123-0022 RE: Sand Removal at Ocean Beach Mr. Dean: As a representative of the Golden Gate Audubon Society I had the opportunity to visit the Ocean Beach project sites with members of your staff, led by Steve Garcia, San Francisco PUC staff and the contractors staff on July 3, between 10 am and 11:30 am. We met at Stairwell 28 on Ocean Beach just north of Lincoln Way. From there we visited two sites where sand will be deposited south of Sloat Blvd. My comments refer only to the potential impacts on Western Snowy Plover and to Bank Swallows. Western Snowy Plover As one who has monitored the Ocean Beach population of snowy plovers about weekly for several years it is my conclusion it is very unlikely the project will pose any adverse impacts. The area between Stairwell 21 and 28 is in the designated Snowy Plover Protection Area. The work plan is to access the beach north of Stairwell 21 from the end of the seawall near Stairwell 28 and drive heavy equipment north to the project site. Since the project will take place in July and August, it is set for a time when plover numbers will be low on the beach. The site itself is little used by plovers. I did not observe plovers there during the 2011-2012 season. They were in the area in at least 1 prior year, but usually out near the water line. The only occasion I observed plovers within the project site was during heavy winter storms that accompanied very high tides. I think it is highly unlikely there will be any plovers in the project site during the period of time the project is conducted. Therefore my conclusion is the project should move forward. There is very little chance of any adverse impacts on the plovers. Bank Swallow I have surveyed the Bank Swallow colony at Fort Funston for many years. During the past 3 years the colony has relocated north of their previous preferred site to a section of sheer sand bluff with a rock revetment below and roadbed above. Bank Swallows arrived at the site in early April, have established nests (no fewer than 110 burrows) and are now fledging young. Assuming their usual pattern continues this year, they will have finished nesting by mid to late July. By August 1 they should all be gone from the colony. One thing to keep in mind is that the population of Bank Swallows that comprises the Fort Funston colony leave the site almost immediately after the young

fledge. Some birds have already started to migrate south to their wintering grounds in Columbia and Ecuador. As the young fledge other family groups will follow them. In my experience they do not linger at the colony or even at nearby Lake Merced. The project proposal for this area is to dump sand removed from the OShaughnessy Seawall along 3 sites: Reach 3, from Sloat to the Emergency Quarry Revetment (EQR); onto the EQR; and Reach 2, the area from the EQR to the Westside Treatment Plan outflow. Reach 3 and the EQR are well north of the Bank Swallow colony site, so they are not at issue. Reach 2 is adjacent to the Bank Swallow colony site and is of concern. I made certain to inform NPS, PUC and contractor staff that the colony site is just south of the end of Reach 2. Everyone concurred there was no plan to place sand south of that point. In addition, sand will be placed in Reach 2 only after it has been deposited in Reach 3. That places it 2 or 3 weeks into August. In my experience the swallows will hve migrated south by then. So there should be no impact on this years swallow population. I have never observed Bank Swallow burrows in Reach 2 or in the EQR. Deposting sand in either area, even up to the level of the parking lot, should not impact Bank Swallows when they return in April, 2013. I have not observed Bank Swallow burrows in Reach 3, but it is adjacent to the present colony site. Considering there is a rock revetment between the deposition site and the colony site there should be no problem. Given the information I have, there does not seem to be any potential impact on the Bank Swallows or their colony site from this project. Very truly yours, Dan Murphy Golden Gate Audubon Society Conservation Committee Cc: Steve Garcia Mark Weltner David Anderson Mike Lynes

Golden Gate Audubon Society Page 2 of 2

Attachment C

United States Department of the Interior

NATIONAL PARK SERVICE
Golden Gate National Recreation Area Fort Mason, San Francisco, California 94123
IN REPLY REFER TO:

A7627 (GOGA-PLAN)

Ms. Susan K. Moore Field Supervisor, Sacramento Office 2800 Cottage Way, Rm W-2605 Sacramento, CA 95825 Re: Request for Concurrence on Sand Management Action to Not Likely to Adversely Affect Western Snowy Plover (Charadrius alexandrinus nivosus) on Ocean Beach, SF, CA Dear Ms. Moore: The National Park Service (NPS) requests your agencys concurrence that the herein described project Sand Backpass Project on Ocean Beach would be Not Likely to Adversely Affect Western Snowy Plover (SNPL), a species listed as threatened under the Endangered Species Act. The project is a cooperative effort with the City and County of San Francisco (CCSF) to manage excess sand that has built up along the OShaunessy Seawall. The excess sand built up along the OShaunessy seawall is overflowing into the stairwells, promenade, parking lots, Great Highway, and adjacent neighborhoods. The sand levels at the north end of Ocean Beach are at historic high levels and there is an urgent need to manage the excess sand. Without removal of this excess sand, NPS and City and County of San Francisco (CCSF) maintenance crews will need to expend an extraordinary amount of resource effort to manage the overflow of sand. Project Description - The proposed project involves excavation of approximately 100-150 thousand cubic yards of sand from in front of the OShaunessy seawall from Stairwell 1 to 21, and transporting sand with dump trucks along the Great Highway to the erosion hotspot south of Sloat Blvd. The sand placed south of Sloat Blvd will be monitored to understand how long it will remain in place, how well it functions as bluff protection, and where it moves in the nearshore environment. Based on monitoring, excess sand from in front of OShaunessy seawall may be placed south of Sloat Blvd in successive years. It is hopeful that the placement of sand would reduce the need to implement more engineered bluff protection measures in the short-term. The public will be safely directed around areas where active project activities are occurring. Project staging will require short-term closures of some parking areas. Staging for excavation operations will occur in a portion of the parking area at Stairwell 28, and staging for the sand placement operations will occur at the parking lot located at Sloat Blvd. Operations and staging in the area south of Sloat Blvd would be done to maintain as much parking as possible. To ensure safe transport of sand, the south-bound lanes of the Great Highway will be closed during construction hours: Monday through Friday between 8:00 AM and 7:00 PM. No night or weekend

work will occur. The dump trucks will move north and south on the closed lanes and access the beach at both ends. There will be an Municipal Transportation Agency approved traffic routing program in place. The project is estimated to be completed within 5 weeks from the start of project. Effects of Project to Western Snowy Plover Ocean Beach is not designated critical habitat for the Western Snowy Plover, so the project will not occur in critical habitat. In 2008 the NPS, through formal rulemaking, established a Snowy Plover Protection Area (SPPA) on Ocean Beach in order to provide a protection zone for Western Snowy Plovers overwintering on Ocean Beach (no known nesting of Snowy Plover occurs on Ocean Beach). The NPS designated the SPPA to require dogs to be on leash from July 1 until May 15 (period when SNPL have been observed on Ocean Beach) and thereby attempt to minimize this activitys impact to SNPL. In relation to the SPPA (see Enclosure A), the project would conduct haul activities (no excavation) in only a small corridor along the eastern edge of the SPPA, within 50 feet of the OShaunessy seawall from Stairwell 21 to 28. This travel corridor was determined by NPS ecologist Bill Merkle and Golden Gate Audubon representative Dan Murphy to be the best location for truck haul traffic to minimize interaction with Snowy Plovers (and other shorebirds) based on historical monitoring information and habitat preferences. Historical Observations. - Historical observations of Snowy Plover in the area where truck haul traffic is proposed (eastern edge of SPPA from Stairwell 21-28), indicate that Snowy Plovers are infrequent in this area both because of the time of year the project is proposed, and the distance away from areas where SNPL are observed (habitat quality). Based on GGNRA monitoring (see enclosed NPS summary of SNPL occurrence data), Snowy Plovers are at the lowest detection levels during July, August, and September when the proposed project would be conducted. Golden Gate Audubon (GGA) monitoring information confirms the NPS monitoring, stating Since the project will take place in July and August, it is set for a time when plover numbers will be low on the beach. The site itself is little used by plovers. I did not observe plovers there during the 2011-2012 season. (Dan Murphy Golden Gate Audubon 7/6/12). GGNRA also conducts occurrence monitoring by sector within the SPPA. The sector where truck haul traffic is proposed has the lowest occurrences of Snowy Plovers in the entire SPPA. This is likely due to the number of people and dogs on the beach in this area, and lower quality preferred foraging areas within this sector. When plovers are observed in this area during the summer they are near the shoreline (rackline) foraging. According to GGA, Snowy Plovers only go into the area closest the seawall when they are seeking shelter during winter storm events. In summary, based on the proposed project being conducted: in an area not designated as critical habitat; in part of the SPPA that has low occurrence of SNPL; in the time of year when SNPL are at their lowest numbers; and sand truck haul activity is the furthest distance from where SNPL have been observed. The NPS concludes that the project would Not Likely Adversely Affect Western Snowy Plovers. NPS requests your concurrence either via e-mail or letter. If you have any questions on this project or potential project impacts to SNPL, please contact Bill Merkle (Wildlife Ecologist) at (415) 289-1843.

Thank you in advance for your prompt attention to this urgent project. If at all possible, we would like your concurrence no later than July 20, 2012, as the NPS wants to complete the project prior to SNPL arriving in greater numbers.

Frank Dean General Superintendent Enclosures (2): Western Snowy Plover info in relation to Sand Backpass Project, GGA Sand Removal Letter to NPS cc: Ryan Olah

Attachment A. Western Snowy Plover information in relation to Sand Backpass Project on Ocean Beach Background: Western Snowy Plovers (Charadrius alexandrinus nivosus, SNPL) are a federally threatened species that inhabit Ocean Beach of the Golden Gate National Recreation Area (GOGA) in the non-breeding season, from July through mid-April or May (Page et al. 1986, NPS 2006). Snowy plovers seen on Ocean Beach and Crissy Field represent about 1% of the snowy plovers recorded on the USFWS window winter season counts of snowy plover seen on the U.S. Pacific coast (USFWS 2008). Ocean Beach in San Francisco is the longest stretch of dune-backed beach between Point Reyes and Half Moon Bay on the outer California coast, providing important habitat for migratory and non-breeding shorebirds (Stenzel et al. 1995, GOGA 1998). During 19942008, maximum counts of non-breeding snowy plovers at Ocean Beach have ranged from 18 to 85, with winter season averages ranging from 12 to 54 plovers observed per survey. The GOGA snowy plover populations are accessible to a large urban population, providing viewing, education and outreach, and opportunities for engagement in stewardship. There are no recent or historical nesting records for snowy plovers on GOGA beaches, although they breed on nearby beaches within about 25 miles to the north and south of GOGA, and on salt ponds in South San Francisco Bay at Don Edwards San Francisco Bay National Wildlife Refuge. Since the mid-1990s, the park has defined a Snowy Plover Protection Area (SPPA) along Ocean Beach from Stairwell 21 in the north to Sloat Blvd. in the south (Figure 1 and 2). The park restricts maintenance actions and special use permits in the SPPA during the times SNPL may be on the beach (July 1-May 15). The park also requires pets to be on leash during this same time period within the SPPA. The park has authorized year round maintenance activities including sand movement and beach cleaning for the area north of Stairwell 21, out of the SPPA. Project Actions All excavation will occur outside the SPPA, north of Stairwell 21 (Figure 2), and within about 100 feet of the OShaughnessy Seawall. Vehicles and equipment will enter the beach at Lincoln Ave and then drive adjacent to the seawall, within 50 feet of the seawall, to access the excavation areas. It has been estimated that about 5,000 truckloads of sand will need to be transported to meet project objectives. All sand deposition will occur to the south of the SPPA, south of Sloat Blvd. These deposition areas have only had a few snowy plover observations, with these sections of beach now so narrow that they do not provide SNPL habitat. Protection measures for Western Snowy Plovers Conduct regular monitoring surveys for snowy plovers starting in early July. Administer required contractor sensitivity training prior to commencement of work. Vehicle and equipment access zone would be demarcated by fencing.

No staging or maintenance of equipment or refueling on beach. No night work.

Snowy plover monitoring in relation to Sand Backpass Project Consistent monitoring of snowy plovers began on Ocean Beach in December 1994. Snowy plover numbers begin arriving at Ocean Beach in early to mid-July July. Plover numbers are lower in July and August than in subsequent Fall and winter months, meaning it is less likely to encounter large flocks of birds (Figure 3). In addition, we have had only 19 observations of plovers north of Stairwell 21 on the beach, and 237 plovers observed in Sector 4, which would be part of the haul zone (Lincoln Ave. to Stairwell 21, Figure 1 and 4). This is based on 13,736 observations of individual plovers over this time period. Based on recent monitoring, snowy plovers in the work zone are extremely rare during the months of proposed for work. If we just look at the months of July and August when work is proposed, one plover has been observed in sector 2 (outside the SPPA) in July 2008, four plovers were observed in Sector 4 in August 1996, and three plovers were observed in Sector 4 in August 1995. These plover observations were not up by the seawall, but closer to old high tide lines nearer the shoreline. It seems that plover observations north of the SPPA, and even in Sector 4, are rare occurrences, with the plovers not observed again in these same areas in subsequent surveys. Sectors 1-4 do not provide high quality habitat for overwintering snowy plovers due to high levels of use by people and dogs (note that dogs are allowed to be off-leash all year long north of Stairwell 21 and south of Sloat Blvd), and possibly due the lack of dunes backing the beach. South of Sloat Blvd. also has high visitor use from the parking lot at Sloat Blvd, as well as an extremely narrow beach heading south, often just rock protected bluff at most tides. Vehicles will not be accessing the beach for deposition, just dumping the sand from the roadways above. Snowy Plover Impact Assessment This project is Not Likely to Adversely Affect Western Snowy Plovers. Plovers begin showing up, but not in large numbers during the months of July and August when the project will occur. Based on monitoring data, it is very unlikely that plovers will occur in the project area. High levels of visitor use and project vehicle activity would be deterrents to plovers utilizing these areas. In addition, even if in the rare chance they do happen to be within the project area (Sectors 1-4), these birds would most likely be closer to the shoreline and well outside work areas. Sand deposition areas south of Sloat Blvd, Sectors 13 and 14 do not have recent plover observations and have become so narrow in terms of beach width that they do not currently provide suitable plover habitat.

Figure 1. Snowy plover census area at Ocean Beach, San Francisco. The Snowy Plover Protection Area extends from Stairwell 21 in the north to Sloat Blvd. in the south (Sectors 4 12).

Figure 2. Project Area adjacent to Stairwell 21 on Ocean Beach.

30 Average snowy plover count 1994-2010

Average number of snpowy plovers

25

20

15

10

Month

Figure 3. Average number of snowy plovers per survey by month.

60 Percentage of all snowy plover observations 50 40 30 20 10 0 1 2 3 4 5 6 7 8 9 Ocean Beach Sector 10 11 12 13 14

1994-2010

Figure 4. Cumulative percentage of snowy plovers observed by sector.

Literature Cited: Golden Gate National Recreation Area (GOGA). 1998. Draft snowy plover management plan for Ocean Beach, San Francisco. Golden Gate National Recreation Area Unpublished Report, San Francisco, California. National Park Service (NPS). 2006. Status report: Western snowy plovers and recent changes in human and dog use within the Snowy Plover Management Area at Ocean Beach and the Wildlife Protection Area at Crissy Field. Golden Gate National Recreation Area Unpublished Report, San Francisco, California. Page, G. W., F. C. Bidstrup, R. J. Ramer, and L. E. Stenzel. 1986. Distribution of wintering snowy plovers in California and adjacent states. Western Birds 17:145170. Stenzel, L. E., G. W. Page, and D. Hatch. 1995. Snowy plover monitoring program volunteer handbook (includes minor revisions made in 1999). Point Reyes Bird Observatory Unpublished Report, Stinson Beach, California. U.S. Fish and Wildlife Service (USFWS). 2008. Winter window survey data 20032007. Available from http://www.fws.gov/arcata/es/birds/WSP/plover.html (accessed 15 March 2010).