Big Wave Final EIR Comments

Comments for the
November 17, 2010

Planning Commission
Public Hearing for the Big
Wave EIR & Project
Date: November 15, 2010

Commenter Agency Date
1 Ed Rosiak Calpilots 10/26/10
2 Anthony Garcia FAA 10/26/10
3 Barbara Kossy -- 10/19/10
4 Barry Liftland -- 10/25/10
10/26/10
5 Bill Kehoe -- 10/26/10
6 Bob Kline -- 10/27/10
7 Bonnie Dunham -- 10/26/10
8 Carolyn Maddux -- 10/13/10
9 Chris Porter -- 10/27/10
10 Christine Hanlon CGF 10/11/10
11 Chuck Duffy GSD 10/25/10
12 Clemens Heldmaier MWSD 10/18/10
10/26/10
10/27/10
11/9/10
13 Dana Kimsey League for Coastside 10/26/10
Protection
14 David Schricker MWSD 10/25/10
15 David Skelly -- 10/28/10
16 David Vesprimi -- 10/26/10
17 Denise Aquila -- 10/22/10
18 Donald Freese -- 10/28/10
19 Gary Giovannoni -- 10/25/10
20 Geoffrey Perusse -- 10/27/10
21 Grace Maguire -- 10/19/10
22 Hal Bohner -- 11/9/10
23 Jack and MaryEm Wallace -- 10/27/10
24 Jack Sutton -- 10/26/10
25 James Porter County DPW, 11/2/10
Airports Division
26 Jan Gray -- 10/14/10
27 Jennifer Castner -- 10/24/10
28 Jerry West -- 10/25/10
29 Jim Larimer -- 10/13/10
30 John Collins AOPA 10/26/10
31 Karen Hoexter -- 10/27/10
32 Kathryn Salter Carter MWSD 10/26/10
33 Ken King Sierra Club Loma 11/8/10
Prieta Chapter
Coastal Issues
Committee
34 Kerrie DeMartini -- 10/27/10
35 Kevin Cooke -- 10/26/10
36 Kim Gainza -- 10/28/10
37 Kimberly Clark -- 10/27/10
38 Laurie Goldberg -- 10/25/10
39 Len Erickson -- 10/19/10
10/25/10
40 Lennie Roberts -- 10/15/10
11/10/10
41 Leslie O’Brien -- 10/25/10
42 Lisa Carboni Caltrans 10/20/10
43 Lisa Ketcham Pillar Ridge Home 10/11/10
Owners Association 10/19/10
10/26/10
44 Madeline Cavalieri CA Coastal 10/26/10
Commission
45 Mark Woyshner MWSD 11/10/10
46 Marshall Ketchum -- 10/24/10
47 Mary Larenas -- 10/21/10
48 Mary Lou Williams -- 10/19/10
49 Matthew Clark -- 10/26/10
50 Merrill Bobele Sierra Club Coastal 10/26/10
Issues Committee
Loma Prieta Chapter
51 Mike Ferreira Sierra Club Loma 10/26/10
Prieta Chapter's
Conservation
Committee
52 Mike Hagmaier -- 10/19/10
53 Nancy Horner GGNRA 11/10/10
11/11/10
54 Neil Merrilees MCC 9/29/10
10/26/10
55 Patty Lauritzen -- 10/24/10
56 Paul Perkovic MWSD 11/12/10
57 Peter Grenell San Mateo County 11/8/10
Harbor District
58 Petra Syme -- 10/26/10
59 Robert L. Pilgrim -- 10/25/10
60 Rosabelle and Michael "Arvin" Lynes -- 10/23/10
61 Sandy Gainza -- 10/25/10
62 Sandy Hesnard Caltrans Aeronautics 10/25/10
63 Sara DeSoto -- 10/25/10
64 Sarah Damron Surfrider Foundation 10/19/10
65 Terry Gossett Californians for 10/25/10
Property Rights
66 Vanessa Richter -- 10/25/10
67 Winter King, Shute Mihaly & -- 11/9/10
Weinberger
PO Box 6868, San Carlos, CA 94070-6868
October 26, 2010
County of San Mateo, Planning and Building Department

Attn: Camille Leung
455 County Center, 2nd Floor
Redwood County CA 94063
Subject: Final Environmental Impact Report (FEIR) for the Big Wave Wellness Center and
Office Park
Dear Ms. Leung,
The California Pilots Association’s mission is to promote and preserve the State’s airports.
As a statewide volunteer organization, we work to maintain the State’s airports in the best
possible condition.
Previously, we provided comments to the Notice of Preparation for the Environmental
Impact Report and the Draft Environmental Impact Report. We do not believe that any of
the following concerns have been adequately addressed in the Final Environmental Impact
Report. It should be noted CalPilots concurs with the letter from the FAA dated 7-8-2010.
We also agree with the Letters from CalTrans Div of Aeronautics dated Nov 17 2008 and
Dec 21 2009 as well as comments from AOPA. All express similar very serious concerns
about the placement of housing of any kind this close to Half Moon Bay Airport
1) The California Pilots Association commends the County of San Mateo for this
worthwhile project. However, we are opposed to the project at its current location.
It does a disservice to the low income, developmentally disabled (DD) children and
adults the Big Wave Wellness Center hopes to serve, to be located approximately
300’-(even if moved to 800-1000’ feet) from Half Moon Bay Airport. This site will
subject more than 70 people to the impacts attendant to a location so close to an
airport such as safety and noise, etc. There is not a final depiction of the site plan
available.
2) The FEIR does not address the safety or other impacts of placing this project so
near the Half Moon Bay Airport. The site is inconsistent with the 2002 California
Airport Land Use Handbook airport planning guidelines. These guidelines are a
minimum. It is inconsistent as well with the Deeds and Restrictions that came with
the Federal Government’s allowance of County of San Mateo to operate and protect
the airport from encroachment. It is not advisable to allow housing, or a medical
facility at this location.
Land Use Sensitivity Concerns related to Safety and Noise.
1
a) Highly Risk-Sensitive Uses.
Pg 2 CalPilots FEIR Comments
The California Airport Land Use Planning Handbook, (the CalTrans Handbook) which is
required to be referenced during CEQA analysis for projects within 2-miles of Public Use
Airports, states the following:
“Certain critical types of land uses—particularly schools, hospitals, and other uses in which
the mobility of occupants is effectively limited—should be avoided near the ends of runways
regardless of the number of people involved.”
b) Sensitive Uses. The CalTrans Handbook further states:
This category includes land uses which, because of their special sensitivity, should be
excluded from certain locations near airports even if they meet other quantitative criteria.
Children’s schools, day care centers, hospitals, nursing homes, and other highly risk-sensitive
uses are primary examples.” No matter what you call this project (Sanitarium) it contains a
vulnerable population who should not be placed near the Airport. Sanitarium is an
inappropriate designation.
c) School Site Reviews. Though not specifically a School Site, Two sections of the
Education Code (17215 and 81033) solicit input from the Airport Land Use Commission
(ALUC) for use by the California Department of Transportation (CalTrans) when evaluating
such Sensitive Land Uses for schools “that would be within two miles of an airport runway
or potential runway included in an airport master plan.”
d) Wellness Center Location. The proposed Wellness Center certainly represents the criteria
indicated above and should not be located at the proposed site, or within 2-miles of the
airport.
CalTrans Land Use Safety Zones Around Airports.
a) State Law requires that the CalTrans Airport Land Use Planning Handbook (the
Handbook) be used as a “guide” to protect the Public from new incompatible Safety and
Noise Land Uses within 2-miles of Public Use Airports
b) Beyond the FAA’s Runway Protection Zones illustrated by the Planning Department, the
Handbook also includes Six additional Safety Zones. The following ones appear to also
apply to the proposed development.
i) Inner Turning Zone (3) , which would be further offset 17 Degrees than illustrated in the
Handbook over the proposed site location(s) to reflect the existing “RNAV (GPS) Y RWY
30” instrument approach to the airport. The following limitations are applicable in this area:
* Limit residential uses to very low densities (if not deemed unacceptable because of
2
noise)
* Avoid nonresidential uses having moderate or higher usage intensities (e.g., major
shopping centers, fast food restaurants, theaters, meeting halls, buildings with more than
three aboveground habitable floors are generally unacceptable)
* Prohibit children’s schools, large day care centers, hospitals, nursing homes
* Avoid hazardous uses (e.g. aboveground bulk fuel storage)
* The new SFO CLUP Zone 3 Maximum Density Criteria is 80 to 100 people per acre.
ii) Sideline Zone (5), which parallels the runway:
* Avoid residential uses unless airport related (noise usually also a factor)
* Allow all common aviation-related activities provided that height-limit criteria are met
* Limit other nonresidential uses similarly to Zone 3, but with slightly higher usage
intensities
* Prohibit children’s schools, large day care centers, hospitals, nursing homes
* The new SFO CLUP Zone 5 Density criteria is 100 to 150 people per acre.
c) The proposed Business Park and the Wellness Center both appear to encroach on these
Safety Areas, and should be limited by the above criteria.
d) The appropriate body to make determinations on the above concerns is the Airport Land
Use Commission (ALUC). As stated in former CalTrans correspondence on these projects,
the proposed action should be referred to the ALUC for further review and
a“Determination”.
The Half Moon Bay Airport is a vital link in the National Transportation System. It is
eligible for and has accepted Grants from the Federal Aviation Administration. When the
County of San Mateo last accepted a FAA Grant, the County signed Grant Assurances as part
of the contract with the FAA.
The County thereby agreed to an obligation to maintain compatible land use zoning. This is
Grant Assurance number 21.
http://www.faa.gov/airports_airtraffic/airports/aip/grant_assurances/media/airport_sponsor_a
ssurances.pdf
3
3) 21. Compatible Land Use. It (the County, acting as the sponsor) will take
appropriate action, to the extent reasonable, including the adoption of zoning laws, to
restrict the use of land adjacent to or in the immediate vicinity of the airport to
activities and purposes compatible with normal airport operations, including landing
and takeoff of aircraft. In addition, if the project is for noise compatibility program
implementation, it will not cause or permit any change in land use, within its jurisdiction,
that will reduce its compatibility with respect to the airport, of the noise compatibility
program measures upon which federal funds have been expended.
As we have seen above, in the FAA Grant Assurance, it is incumbent upon the County of San
Mateo to protect the airport with zoning which would prevent the development of a project
which is clearly incompatible to safe operation for Pilots at Half Moon Bay Airport as well
as the residents, particularly low income, developmentally disabled (DD) children and adults
on the ground.
Failure to comply with these Grant Assurances could likely result in the loss of millions of
dollars in future Federal Grants to the County.
NOISE:
Incorrect Noise Measurement Techniques Used by the County Planning Consultant:
When addressing noise concerns in relation to airports and aviation, the appropriate
modeling methodology to be used is the Integrated Noise Model (INM) as addressed in the
Federal Aviation Regulations (FAR) Part 150 “Airport Noise Compatibility Planning
Program” documents and procedures. An appropriate output would be Airport Noise
Exposure Maps (NEM’s) representing the yearly Day-Night-average-sound-Level (DNL)
contours and also Single Event analysis. The procedure used by the County Planning
Consultant did not appear to produce the appropriate Noise Planning information for a
project that would be cited near an airport. No further action should be taken until this
required INM information is provided and discussed in a public Workshop Format at the
Airport Land Use Commission (ALUC).
An example of inadequacy of the FEIR is Section V. General Impact Categories, Page V6

5. NOISE “The proposed project is not located near a private Airfield therefore
Thank you for this opportunity to comment on this important item.
From the DEIR pg IV.G-25: “Full compliance with all applicable Federal, State, Regional
and Local regulations, Programs and Plans related to land uses in proximity to a public
airport would be required” was stated. However, the project has not followed FAA or State
regulations, Programs and Plans related to land uses in proximity to a public airport and thus
results in a very significant impact associated with airport safety hazards to people residing
4
or working in the area of a public airport contrary to the stated intent.
Respectfully submitted,
s/s
Ed Rosiak
President California Pilots Association
800 319 5286
erosiak@comcast.net
5
U.S. Department Western-Pacific Region P. O. Box 92007
of Transportation Airports Division Los Angeles, CA 90009-2007
Federal Aviation
Administration Son Mateo County Afrport$
July 8,2010 JUL 1 2 2010

Mark Larson
Airport Manager
RECEIVED .J
Half Moon Bay Airport
620 Airport Drive
San Carlos, CA 94070
Dear Mr. Larson:

Planned Wellness Center
We are providing comments regarding the proposal to construct a Big Wave Wellness Center
(Center) next to Half Moon Bay Airport (HAF). Based on the information available to us, the
Center will be built approximately 500 feet west of runway 30. The presence of a center for
the developmentally disabled that is so close to the runway represents a use that is not
compatible with normal airport operations. Therefore, it is our determination that the selected
site is not appropriate. An alternative site outside HAF's influence area should be used for the
Center.
San Mateo County is reminded of the requirements of Assurance 21, Compatible Land Use.
Airport sponsors are required to take appropriate action to restrict the use of land adjacent to
the airport to activities that are compatible with normal airport operations. Clearly, a clinical
residential center serving disabled patients would not be considered a compatible use so close
to the airport and its runway.
Even if the center is not inside the noise contours of HAF, aircraft operations will have some
disturbing impact on the Center. Its occupants will surely be aware of normal airport
operations because aircraft over-flight noise will occur. The duration and intensity of the
noise, even if it is intermittent, will likely be deemed to be an undesirable nuisance by
occupants and residents of the center.
From a practical perspective, the consequences of incompatible land uses should not be
taken lightly. The airport's neighbors will surely complain about airport noise.
Incompatible land uses such as the Center will eventually provoke persistent criticism
related to noise, safety, and emissions.
Once incompatible land uses are established, it is the airport that is expected to undertake
remedial action to mitigate the offending irritants. For example, the San Mateo County
General Plan was formulated to "promote and protect the public health, safety, peace, morals,
comfort, convenience and general welfare." Additionally, the "Airport Land Use Plan includes
policies, standards, and criteria to address each of these issues to assist local agencies to
achieve land use compatibility with existing and future airport development and operations."
2
Yet, because of incompatible land uses in the vicinity ofHAF, "the County has implemented
noise abatement procedures at HAF to further reduce aircraft noise impacts in the surrounding
noise sensitive areas."
The above example discloses the land-use incompatibility shortcoming related to the proposed
location of the Wellness Center. The planning and environmental documents proffer that there
will not be any negative environmental impacts related to the proximity of the Center to the
airport. However, experience actually reveals that the opposite is true. Inevitably, the Center's
users will complain about the airport. The unfortunate public policy reaction to the complaints
will inevitably be proposals to impose additional restrictions on normal airport operations.
Historically, case after case shows that incompatible land use becomes a quality of life issue
for the airport's neighbors and, thereafter, a losing proposition for the airport.
For these reasons, we must express our objection to the proposed site of the Wellness Center.
If you have any questions, please call me at 310-725-3634.
on 'a
Airports Compliance Program Manager!
Safety-Certification Inspector
Western-Pacific Region P. O. Box 92007
Airports Division Los Angeles, CA 90009-2007
October 26, 2010
Mark Larson
Airport Manager
620 Airport Drive
Dear Mr. Larson:

Follow-Up Comments
It is our understanding that San Mateo County (County) may remain in favor of the
Wellness Center being built next to Half Moon Bay Airport although it represents an
incompatible land use.
We wish to remind the County that protecting people on the ground from aircraft noise,
emissions, and the potential consequences of near-airport aircraft accidents are fundamental
reasons for establishing good compatible land use practices. People react differently to
noise and the threat of exhaust emissions, but inevitably some will react negatively and
actively seek to extinguish the noise irritant or pollutant. If Center residents do not speak
out, family or advocates may lead the protests. They will incessantly complain to
government officials and demand limitations be placed on the airport and aircraft operations.
The airport will be perceived as the cause of the problem when, in reality, the real cause is
As a substitute for good compatible land use planning, sound insulation and buyer
notification become the typical, less-effective noise mitigation measures to reduce the
negative consequences of incompatible land use development. However, these measures do
not change exterior aircraft noise levels and have no appreciable effect on individual
responses to noise. Furthermore, they become less effective if noise occurrences increase as
a result of increased aircraft operations or the types of aircraft operations. Therefore, noise
mitigation measures are not a substitute for good land use compatibility planning
The protection of airports from incompatible land use encroachment is vital to California’s
economic future and the financial well being of the airport itself. Airports serve the local
and national interest. They facilitate transportation and commerce. They provide for the
national defense and serve the public good in times of calamity and emergency. Airports are
invaluable because they are irreplaceable. By way of comparison, one can replace a house
almost anywhere, but an airport could never be replaced in any of the developed areas of
2
California. Therefore, airports, such as Half Moon Bay, must be preserved and protected.
Compatible land use is an obligation that the County pledged to uphold when it made legal
commitments to the federal government in exchange for financial assistance. Ordinarily,
grant funding is the incentive motivating airport sponsors to comply with the Grant
Assurances. The County may not be concerned with future entitlement to FAA grant
funding, but the County should be concerned with the health, welfare, personal rights, and
the quality of life of the residents who might have to live and work next to an active airport.
The County will be responsible for the reduction in any of these measures of well-being.
The Airport Improvement Program cannot compensate impacted residents for any
diminution of their quality of life. If residents complain about the airport, it will be the
County’s responsibility to compensate them for their perceived harm or loss.
In the future, the airport should not be blamed for the irritation caused by noise and
emissions or the loss caused by an aircraft accident. Furthermore, the airport should not be
penalized in any way or made to suffer a reduction in its utility to serve civil aviation or the
rights of aviators who want to use the airport. The liability for incompatible land use will lie
at the door of the County and not the airport if the County makes a decision to allow
incompatible land use next to Half Moon Bay Airport.
Sincerely,
Original Signed by
Tony Garcia
Tony Garcia
Airports Compliance Program Manager
U.S. Department Western-Pacific Region P. O. Box 92007
of Transportation Airports Division Los Angeles, CA 90009-2007
Federal Aviation
Administration
Son Mateo County Airports

October 26, 2010
OCT 29 2010
Mark Larson
Airport Manager RECEIVED
HalfMoon Bay Airport
620 Airport Drive
Dear Mr. Larson:

Follow-Up Comments
It is our understanding that San Mateo County (County) may remain in favor of the
Wellness Center being built next to HalfMoon Bay Airport although it represents an
We wish to remind the County that protecting people on the ground from aircraft noise,
emissions, and the potential consequences of near-airport aircraft accidents are fundamental
reasons for establishing good compatible land use practices. People react differently to
noise and the threat of exhaust emissions, but inevitably some will react negatively and
actively seek to extinguish the noise irritant or pollutant. If Center residents do not speak
out, family or advocates may lead the protests. They will incessantly complain to
government officials and demand limitations be placed on the airport and aircraft operations.
The airport will be perceived as the cause ofthe problem when, in reality, the real cause is
As a substitute for good compatible land use planning, sound insulation and buyer
notification become the typical, less-effective noise mitigation measures to reduce the
negative consequences of incompatible land use development. However, these measures do
not change exterior aircraft noise levels and have no appreciable effect on individual
responses to noise. Furthermore, they become less effective if noise occurrences increase as
a result of increased aircraft operations or the types of aircraft operations. Therefore, noise
mitigation measures are not a substitute for good land use compatibility planning
The protection of airports from incompatible land use encroachment is vital to California's
economic future and the financial well being of the airport itself. Airports serve the local
and national interest. They facilitate transportation and commerce. They provide for the
national defense and serve the public good in times of calamity and emergency. Airports are
invaluable because they are irreplaceable. By way of comparison, one can replace a house
2
almost anywhere, but an airport could never be replaced in any of the developed areas of
California. Therefore, airports, such as HalfMoon Bay, must be preserved and protected.
Compatible land use is an obligation that the County pledged to uphold when it made legal
commitments to the federal government in exchange for financial assistance. Ordinarily,
grant funding is the incentive motivating airport sponsors to comply with the Grant
Assurances. The County may not be concerned with future entitlement to FAA grant
funding, but the County should be concerned with the health, welfare, personal rights, and
the quality oflife of the residents who might have to live and work next to an active airport.
The County will be responsible for the reduction in any of these measures of well-being.
The Airport Improvement Program cannot compensate impacted residents for any
diminution of their quality of life. If residents complain about the airport, it will be the
County's responsibility to compensate them for their perceived harm or loss.
In the future, the airport should not be blamed for the irritation caused by noise and
emissions or the loss caused by an aircraft accident. Furthermore, the airport should not be
penalized in any way or made to suffer a reduction in its utility to serve civil aviation or the
rights of aviators who want to use the airport. The liability for incompatible land use will lie
at the door of the County and not the airport if the County makes a decision to allow
incompatible land use next to Half Moon Bay Airport.
From: "Barbara Kossy" <bkossy@coastside.net>
To: <plngbldg@co.sanmateo.ca.us>, <planning-
commission@co.sanmateo.ca.us>
CC: "sabrina brennan" <sabrina@dfm.com>, "Lisa Ketcham"
<Lisa.Ketcham@comcas...
Date: 10/19/2010 5:02 PM
Subject: Big Wave Final EIR
Dear Planning Commission,
The Big Way Project, as proposed, remains inappropriate for the proposed location.
The construction will threaten valuable wetlands, and proposes structures too close to
the airport.
It's also in a Tsunami inundation zone. And if that weren't enough, it's oversized and
would have a huge visual impact.
"As proposed, the project would not result in significant short-or long-term impacts to the
overall value of the views from these viewpoints." Totally the opinion of the developers. I
disagree. The project will result in significant short-and long-term impacts to the overall
value of the views..."
Also the impact of increased traffic on Airport road with limited access from Moss Beach
and Princeton is totally unacceptable.
Traffic reports do not decrease traffic, or make a road safer for more enjoyable for
pedestrians and cyclists.
Open space and farmed land are part of the fabric of the Coastside.
To destroy farmland, and pave valuable open space, with it's vistas, and wildlife
corridors, while bringing in unmitigated traffic flow, the damage and disruption of
construction, and a questionable enterprise, well, that's just bad planning.
This is a perfect project for an urban redevelopment zone with infrastructure in place.
Perhaps it could be built in an abandoned shopping mall or big box store. Those already
have huge parking lots, and any wetlands at those sites were destroyed long ago.
There's a big, mostly empty parking lot surrounding Harbor Village. Perhaps it should be
built there, if it must be built on the Coastside.
Barbara Kossy
Moss Beach
Page 1 of 1
- Big Wave requests
From: BARRY <bevbarry@pacbell.net>

To: <Planning-Commission@co.sanmateo.ca.us>
Date: 10/25/2010 1:24 PM
Subject: Big Wave requests
CC: <cleung@co.sanmateo.ca.us>
Greetings San Mateo Planning Commission:
RE: Big Wave
1. Please grant us - the public - at least 60 day to review the FEIR. It is HUGE and difficult reading for
me and other persons I know.
2. Please compel the Big Wave developers to erect full story-poles for each building and top them with
netting. Please require them to have the story-poles in place for the entire review period.
Thank you,
Barry Lifland
750 First Avenue
Half Moon Bay, CA 94019
11/16/2010
Page 1 of 1
I - Big Wave comments
From: BARRY <bevbarry@pacbell.net>

Date: 10/26/2010 4:32 PM
Subject: Big Wave comments
Greetings San Mateo County Planning Commission
RE: Big Wave FEIR
I disagree with certain parts of the proposed FEIR:
1. APPENDIX G MODIFIED ALTERNATIVE C: ALTERNATE OFFICE PARK TRAFFIC

CIRCULATION OPTION is at best wishful thinking. I maintain that all options in Appendix G will
impact to cumulative peak-hour traffic volumes and intersection LOS to a more-than-significant level.
2. Building heights of more than one story will impact the area to a more-than-significant level.
3. Potable water availability and sewage capacity from community sources do not seem to be available
and will impact those services to a more-than-significant level.
4. The Wellness Center occupancy of 70 persons would make a similar demand of all services as would
20 to 25 single family homes. This will impact service and the area to a more-than-significant level.
5. The HMB Airport Overlay does not allow for the high concentrations of people so close to the flight
paths; this will impact the airport and the area to a more-than-significant level.
I am requesting that the San Mateo County Planning Commission deny certification of the DEIR and the
FEIR.
Thank you,
Barry Lifland
750 First Avenue
11/16/2010
To: Planning Commission
County Government Center
455 County Center, MD-PLN122
Redwood City, CA 94063
planning-commission@co.sanmateo.ca.us.
Subject: Big Wave FEIR Comments
Honorable Commissioners,
I apologize for the incompleteness of my comments on the Final EIR. The short
review period does not permit me sufficient time to research the details presented
in the FEIR on all the issues and coherently summarize my concerns. I would like
you to consider and extension to the review period so that the public can
adequately respond to the many remarks, explanations and interpretations the
Planning Staff has added to the FEIR. I would also hope that if you do grant an
extension that you keep in mind of the holiday season that is approaching and
take into account that many of us in this community are not professional planners
or paid consultants and will be responding on our own time with limited
resources.
With that said, here are some preliminary comments which have caused me much
concern about this project.
1. Wellness Center
First and foremost, none of us on the MCC or in this community are against
helping the disabled or disadvantaged in our community. In fact, it is one of the
reasons why so many of us volunteer our time to make this a community worth
living in.
But is this proposal well thought out? Its location, in the Waterfront (Zone W)
and next to Manufacturing (Zone M1) and beside the Airport Overlay (Zone AO)
places them in a warehouse environment and not in a community environment.
Where is the nearest local store for them to get incidentals they may need? Where
can they go during their off hours for social, medical, educational or spiritual
needs? Granted they will be near some of the most scenic trails and have
recreational facilities on site, but don’t we all need more to break up the
monotony of the same limited routine everyday? If the idea of a wellness center,
or sanitarium or what ever they are calling it, is to integrate their charges into
society and afford them independent living environments is this isolated area the
right way to go?
In the online literature on Searching for Appropriate Housing Options (this is just
one example) it states “When determining the best location, consider the
proximity to shopping, your doctor's office, friends and family, etc. If you do not
drive, you must also consider the availability of transportation.”
Is this a plan to warehouse the developmentally disabled and keep them out of
sight and out of mind?
2. Questionable process tactics to usurp the EIR process.
This is probably the most damning display of unprofessional conduct by the

Planning Staff we have seen to date. I will briefly list subject areas that need to be
addressed in the public review process in further detail at a later date.
a. Review period is inadequate. Over 3000 pages to be reviewed in 12 days

and less if you consider that a subsequent package of drawings arrived a
few days after the FEIR was sent.
b. Organization of Materials. Some portions of the documents show
conflicting drawings and descriptions of the project. Is the Office Park 4
buildings or 8? Is the Wellness Center 2 buildings or 7? And why does the
AO drawing still show 7 building? Should the sections, drawings and
materials that are no longer relevant be marked as such with either
strikethrough marks or other such verbiage to indicate it has been
changed?
c. The question becomes is this really a “FEIR” or do the changes warrant
another round of “DEIR”? Some of the “changes” in the FEIR, in response
to the comments, has changed traffic flow, building count, building
location without updating the original supporting documentation to reflect
the new changes. Shouldn’t these changes be certified by the same
organizations and placed in the FEIR so the public and interested parties
can see “an effort at full disclosure”?
d. Is it the practice of the Planning Staff to both write and review FEIR for
projects in the county of San Mateo? Is this service open to all residents
and business in the county? Does this provide the checks and balances
need to “demonstrate to an apprehensive citizenry that the agency has, in
fact, analyzed and considered the ecological implications of its action”.
3. CEQA Guidelines Vol 1 page II-33 Section 15003. Policies.
I would like to remind the Planning Commission of its duty to follow the CEQA
Guidelines and in particular Section 15003 which states (among other things):
(d) The EIR is to demonstrate to an apprehensive citizenry that the agency has, in
fact, analyzed and considered the ecological implications of its action. (People ex
rel. Department of Public Works v. Bosio, 47 Cal. App. 3d 495.)
(f) CEQA was intended to be interpreted in such a manner as to afford the fullest
possible protection to the environment within the reasonable scope of the
statutory language. (Friends of Mammoth v. Board of Supervisors, 8 Cal. 3d 247.)
(h) The lead agency must consider the whole of an action, not simply its
constituent parts, when determining whether it will have a significant
environmental effect. (Citizens Assoc. For Sensible Development of Bishop Area
v. County of Inyo(1985) 172 Cal.App.3d 151)
(i) CEQA does not require technical perfection in an EIR, but rather
adequacy, completeness, and a good-faith effort at full disclosure. A court
does not pass upon the correctness of an EIR's environmental conclusions, but
only determines if the EIR is sufficient as an informational document. (Kings
County Farm Bureau v. City of Hanford(1990) 221 Cal.App.3d 692)
It is this last, highlighted requirement that I feel has been totally ignored by this
committee and I will cite just a one of many of examples:
a. Traffic. To mitigate the objections of the Seal Cove residents concerned

with the backups on Cypress Ave and HWY 1, the proposed solution,
referred to as Alternative C, would “force” the traffic flow south through
Princeton, adding backups at several stop signs as the traffic migrates to
HWY 1. This will impact many small businesses, like restaurants, who
count on local patronage around the evening commute. It also moves the
bottleneck problem of Office Park traffic at Cypress Ave and HWY 1 to
N. Capistrano and HWY 1 where traffic going north will have to enter
HWY 1 without a traffic light and where HWY one transitions from a two
lane road to a four lane road adding to problem. Finally, traffic on HWY 1
is already considered LOS ‘F’ by the California Coastal Commission and
is currently an issue with the adoption of the LCP amendments between
the County and the CCC. Some questions that come to mind:
i. Was this changed looked at and commented on by any of the
organizations that deal with traffic?
ii. Was a trained traffic engineer consulted with for this
alternative?
iii. Since it doesn’t really mitigate the traffic problem is it right
for the Planning Staff to say that the issue was addressed?
4. Project Viability.
a. One of the Planning Commissions duties is to assess the viability of this

project’s success so that it doesn’t fail and leave a blight or negative
impact in the community. There are numerous risks in this project that
have not been mitigated properly to ensure its success. One I would like to
point out here is the reliance on the businesses of the Office Park to
employ the residents of the Wellness Center to help them afford their cost
of living there. But the plan states that the Office Park buildings will be
phased in over time based on the ability to acquire tenants. The occupancy
types permitted in that zoning (M-1) are “administrative, research and
professional offices, excluding doctors and dentists” as a permitted use.
The current plan is for the Office Park includes 40% General Office, 25%
Research and Development, 20% Light Manufacturing, and 15% Storage
uses. But I also noted that they plan to sub-divide the parcels into 8
parcels which hint at the need to maybe sell some off separately if the
economic conditions don’t fall in their favor. This leads to many
questions:
i. Will any change of ownership of the Office Park still support the
Wellness Center residents so that their tenancy and care will not be
jeopardized?
ii. How will the tenants of the Office Park legally be
mandated to employ the residents of the Wellness Center?
iii. What if the tenants can’t find the right job descriptions to
fill with the residents?
b. One question which has not been addressed adequately is the actual need
in this location for any of the proposed office space. There are already
many available spaces here on the coastside which are vacant. Won’t this
glut of new office space drive down the cost of existing vacancies? Won’t
this have a negative impact on the area? And why would research facilities
or office parks locate here when the 101/Cal Train corridor has plenty of
vacancies which are better served?
5. Adherence to the Local Coastal Plan.
The California Coast has been a battle ground for development since the last
century. Numerous public referendums have been voted on and approved by the
citizens of the state, the county and the local community. Let me just remind you
of the history
a. California Proposition 20 - The voters of California, by an 800,000 vote
margin (55%-45%), passed the Coastal Initiative -- Proposition 20 -- in
November 1972.
b. The California Coastal Initiative (Proposition 20), overwhelmingly passed
by the voters in 1972, was made permanent by the California Coastal Act
of 1976.
c. In November 1986, San Mateo County voters enacted Measure A, "The
Coastal Protection Initiative".
All of these in some form stated the following ideals for the California Coast
preservation:
a. Protection and expansion of public access to the shoreline and recreational
opportunities
b. Protection, enhancement and restoration of environmentally sensitive
habitats
c. Protection of productive agricultural lands and commercial fisheries
d. Directing new housing and other development into areas with adequate
services to avoid wasteful urban sprawl and leapfrog development
I know you don’t need a history lesson but I will ask you to consider why either
of these projects should be on the west side of HWY1 when they should be east of
HWY 1 since they are not really necessary to waterfront area or endangering the
salt marsh?
Thank you for your consideration. I will use any time you grant us to investigate
the changes, additions and validity of the assumptions in this FEIR.
Sincerely,
Bill Kehoe
Resident of Moss Beach
Member of the Midcoast Community Council
Page 1 of 1
- Re: Big Wave
From: <Rdkline1@aol.com>
To: <petra_syme@hotmail.com>, <pprice@finexgroupllc.com>, <pfoster222@aol.co...
Date: 10/27/2010 9:48 AM
Subject: Re: Big Wave
CC: <planning-commission@co.sanmateo.ca.us>, <cleung@co.sanmateo.ca.us>
Dear Mr. Syme,

If you read my note to EGNAG closely, you might have noticed that it is possible I might become a MCC.
member. I interviewed for the vacancy last Wednesday At that recent meeting, I first learned about the Big
Wave project.
Since I knew little about the project, I have visited the web site you recommended. I read about Big Wave
on the web site and tried to learn as much as I could. In addition, I decided to get feed back from people in the
community. In my travels around El Granada, Princeton, Half Moon Bay and Montara residents. I asked people
about Big Wave. In addition, I called several EGNAG folks and asked them about Big Wave, too. The 50-60
people I chatted with were people I thought were well informed. These people knew very little about Big Wave
or thought I was talking about the Maverick's event. Although the project has been progressing for 5 years, it
would seem some folks are unaware.
Recent events with the cell tower in El Granada have rekindled my interest in community service. I take the
nomination to MCC very seriously. That is why my note of "Our Attention is Needed" went to our group. Our
attention is needed. Big Wave is an important project. That is why I urged people to the meeting on
Wednesday. I stated in my email that, "Regardless of your position, even if you have one, more information is
needed before this project becomes reality". I would hope, since you have been monitoring my emails, you
have seen other emails to the group urging them to visit the Big Wave web page as well as other information I
have forwarded to EGNAG. Jan Clark's informative email has reached our group.
I am not certain of the purpose of you email to me. If I were in your position, I would encourage and
welcome all citizens to attend this meeting, even first timer uninformed people like me. If the information at the
Big Wave meeting Wednesday appeals to the community, I would expect the community to support Big Wave.
If the information displeases the community, I would not expect the community's support.
I take the MCC vacancy very seriously. Since I have never met you and you know little about me, perhaps
this will help. My approach to the position will be to become as informed as I can about issues, involve the
community in the issues, try to keep emotion to a minimum, evaluate all factors and proceed intelligently. I hope
that meets with your approval.
Thanks for your email.. Look forward to meeting you tonight.
Regards,
Bob Kline
In a message dated 10/26/2010 5:05:10 P.M. Pacific Daylight Time, petra_syme@hotmail.com writes:
Regardless of your position, even if you have one, more information is needed before this project
becomes reality
11/16/2010
San Mateo County Planning Commission
Planning & Building Department
County Office Building
455 County Center
Redwood City, California 94063
October 26, 2010
Dear Commissioners:
With all due respect to the planning process, we request that the
hearing on the agenda for October 27 take place as planned. The Big
Wave Project has been studied for 5 years. The thorough (4,000 page)
EIR was released a year ago showing that the project has no
significant environmental impact. It's time for the Commission to
approve Big Wave, a project that meets the County's planning goals
and zoning requirements. Enough is enough.
If that's not sufficient, step back from the rules, regulations, and
politics and see the value of this proposal to our community. This is
a dazzling project in terms of its premiere design, meeting the highest
standards of sustainable development. And it's even more
remarkable in terms of its humanity. The Wellness Center creates a
new and unique community environment for special needs adults,
which is also sustainable. It's time to see how right this project is.
There is enough information. There has been enough time for study
and discussion. It is time to say "yes" to this truly special project.
Sincerely,
Dale and Bonnie Dunham
513 Ruisseau Francais Avenue

(650) 726-6775
Page 1 of 1
- Big Wave
From: "Carolyn Maddux" <cmaddux@hctc.com>

To: <CLeung@co.sanmateo.ca.us>
Date: 10/13/2010 10:09 PM
Subject: Big Wave

County Planner Camille Leung
Dear Planners,
If the voice of a Washingtonian is worth listening to at all, I urge you to work toward a speedy
review of the Big Wave project before you. We're in an economic phase when there's not going to be public money available to assist the
developmentally disabled, and a privately funded project that needs only governmental approval is one of the best things you can do, not only for
the disabled among you and their families, but for the entire community.
Forty-some years ago, just such a project was started in Shelton, the town where I live and where I was a reporter and managing editor for the
local newspaper. Like Big Wave, our project was established with private funding and the support of the community. While Exceptional Foresters
Inc. has changed over the years (and been somewhat weakened by silly state regulations) it remains one of the best things about our town. I
don't recall ever having to write a negative story involving the organization or its residents, who were beloved here. You have a tremendous
opportunity for good in this proposal. Please make Big Wave a reality.
Best regards,
Carolyn Maddux
706 West Birch Street
Shelton, WA 98584
11/16/2010
Page 1 of 1
- My support for the Big Wave Project
From: "chris porter" <chrisporter8@gmail.com>

Date: 10/27/2010 6:54 PM
Subject: My support for the Big Wave Project
CC: <CLeung@co.sanmateo.ca.us>
Dear Planning Commissioners and County Planner, Ms. Leung,
I support the Big Wave Project and all staff recommendations in the County Staff Report, including to "approve
the project as described in Alternative C and as presented in the Final EIR..."
I believe the Big Wave Project is precedent setting in the way it sincerely cares for our environment, our
economy, and our special needs community. It should be noted that the project applicant has been modifying their
initial proposal to comply with all County issues raised over the past five years, and now the current proposal is in
compliance with all County requirements with no significant environmental impacts.
Please do not further delay this urgently needed project. It is time to develop affordable housing on the Coastside
and to provide for our special needs population.
Vote yes to your staff recommendations. I hope the cancelled meeting will give you extra time to consider our
voice.
Warm regards,
Christopher Porter
Chris Porter
chrisporter8@gmail.com
Mobile: (650) 580-8696
11/16/2010
October 11, 2010
David Bomberger, Chair and

Members of the Planning Commission
nd
455 County Center, 2 Floor
Re: Request for Extension of Time to 60 days for Public Review for Final Environmental
Impact Report (FEIR), Big Wave Project
On behalf of the Committee for Green Foothills (CGF), I am requesting a 60-day public review
period in order to give the public and responsible agencies sufficient time to review the FEIR for
the Big Wave Project.
As you know, the Big Wave Project, as proposed and described in the DEIR, is enormously
complex, and includes residential, office, manufacturing and warehousing uses, as well as an
onsite wastewater treatment plant, onsite wastewater recycling, conversion of an onsite
agricultural well to domestic and industrial use, and solar, wind, and natural gas power
generation.
The DEIR, along with its Technical Appendices and Facilities Plan, was over 2,000 pages long.
It was a daunting task to digest and comment on the DEIR. The public is keenly interested in the
project as evidenced by the 245 written comments on the DEIR.
CGF believes that given the complexity of the proposed project and the high level of
interest/controversy it has raised, it is vitally important for the County to allow sufficient time for
thoughtful review of the responses to comments.
Therefore, CGF respectfully requests that the review period for the FEIR be extended to 60 days.
As a member of CGF and coastside resident, I am deeply troubled by the scale of this project,
and believe there must be adequate time for careful consideration of this report.
Thank you for consideration of this request.
Sincerely,
Christine Hanlon
Member of CGF
Local Artist/Teacher
www.christinehanlon.com
O F S AN M AT E O C O U N T Y
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October 25, 2010
Ms. Camille Leung

Planning and Building Department
County of San Mateo
Re: Big Wave FEIR and Project Permitting
Dear Ms. Leung,
The Granada Sanitary District is in receipt of the revised FEIR for the Big Wave project. Due to
the massive size of the EIR and its related documents, the District believes additional time
should be allowed beyond the 10 days allotted for responses to be able to adequately analyze
the impacts the project will have on our wastewater system. The short response time is
especially problematical since several tables critical to GSD’s review related to the sources and
uses of water were not made available to GSD until seven (7) days before the Planning
Commission’s Public Hearing. Their absence from the FEIR as released has deprived GSD, as
the wastewater agency with jurisdiction over the sewer system for the project, of sufficient time
to review and respond to the FEIR.
Overall, the District’s abbreviated review of the FEIR reveals a document so materially flawed
and lacking in basic project definition and environmental analysis that it makes a mockery of the
CEQA review process. Without a clear project definition, the District cannot delineate adequate
mitigation measures for the impacts the project’s wastewater generation will have on our sewer
system and the environment. At this time, we have, at a minimum, the following critiques of the
Big Wave FEIR.
• The District has not been afforded status as a Responsible Agency in the CEQA
process, which is required because the project now unquestionably includes connection
to the GSD sewer system, which requires the Applicant to obtain a Sewer Connection
Permit from GSD.
• The volume of wastewater which will enter the sewer system is still undefined by the
FEIR, and therefore, GSD cannot adequately analyze the impacts to our system,
including the empirically established potential for wet weather sewage overflows.
• The FEIR states that the project will send wastewater to the District sewer system during
times of wet weather. However, the downstream impacts on the District’s and SAM’s
sewer system during these rain events, including pipe sizing, impacts on pump stations,
and impacts on flow volume, have not been analyzed by any type of engineering report
or model. This is an especially important issue due to the District’s problems with high
flows during wet weather. Because this analysis has not been provided as required by
CEQA, the District is unable to develop adequate mitigation measures to plan for the
increased wastewater flow which will result from the project.
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• The report contains multiple sections in the FEIR where it states that because the project
is not yet defined, additional CEQA analysis will be required. This lack of project
definition and deferred CEQA analysis is not allowable under the CEQA statutes.
• There are numerous instances throughout the report which state that “a total of 8 ERU’s
will be purchased for emergency and excess (wastewater) discharge into the Granada
Sanitary District (GSD) system.” Contrary to that statement, the District has not made
any assessment of the number of ERU’s which will be assessed to the project. If the
Project generates 10,000 GPD of wastewater flow, which is the applicant’s lowest
estimate of wastewater flow, the project will generate wastewater requiring at least 45
ERU’s of capacity.
The general lack of interaction the applicant has had with the District speaks volumes to the
inadequacies of the EIR. Prior to the document’s publication, the District’s sum total of
interaction with the applicant consisted of an hour-long meeting between the District General
Manager and applicant Scott Holmes, and a phone conversation with the District Engineer. I
have had greater interaction discussing the connection of a single family home to the sewer
system, much less a project which could generate 26,000 gallons per day of sewage. The
applicant has conducted no engineering study of the impacts this project will have on the
District’s sewer system, and indeed could not, since he has not requested any of the pertinent
pipe size and pump station specifications necessary to conduct such a study.
GSD also incorporates its prior comment letters by reference because they have not been
adequately addressed in the FEIR. The flaws in the FEIR need to be corrected and the
document recirculated as a Revised Draft EIR for public comment, in accordance with 14 CCR
§15088.5. Only then can GSD and its decision makers have adequate information to make a
responsible evaluation of the project and attempt to develop adequate mitigation measures.
Sincerely,
The Granada Sanitary District
Chuck Duffy, General Manager
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MONTARA WATER & SANITARY DISTRICT
Serving the Communities of Montara and Moss Beach
P.O. Box 370131 Tel: (650) 728-3545
8888 Cabrillo Highway Fax: (650) 728-8556
Montara, CA 94037-0131 E-mail: mwsd@coastside.net
Visit Our Web Site: http://www.mwsd.montoro.com
October 18,2010
Camille Leung, Project Planner

Re: Extension of Public Review Period for Big Wave Final Environmental
Impact Report
Dear Ms. Leung,
As of today, the District has not received complete copies of the Big Wave Final
Environmental Impact Report (FEIR). MWSD received so far only one copy of
Volume 1 of 3. The missing volumes contain all comment letters and respective
anwsers and are crucial for MWSD's review. The review of a several thousand
pages thick document cannot be completed in a review period of 8 working days,
especially if incomplete documents are distributed. We believe that the starting
period does not commence until complete copies have been received.
245 comment letters written as response to the over 2000 page long Draft EIR
show a high level of interest of the public and responsible agencies.
Environmental Impact Reports require decision makers to account for their
decisions in light of detailed environmental studies and public comments on the
potential environmental impacts of the proposal.
In order to give the public and responsible agencies time to review the FEIR, the
Montara Water and Sanitary District is requesting the extension of the public
review period to a 60-day public review period and thus, the rescheduling of the
consideration of the Final EIR and Project by the Board of Supervisors.
Thank you for "ration of this request.
Sincerely. ~ fI/Jr--
Clemens Heldmaier
General Manager
MWSD
Page 1 of 6
Big Wave FEIR Comment Letter
From: "Clemens Heldmaier" <mwsd@coastside.net>
To: "'Camille Leung'" <CLeung@co.sanmateo.ca.us>
Date: 10/26/2010 5:01 PM
Subject: Big Wave FEIR Comment Letter
CC: <kathryn.mwsd@gmail.com>, "'Paul Perkovic'" <paul_perkovic@yahoo.com>, "...
Attachments: oledata.mso
Camille,
Please see the Districts comment letter below. I will send the attachments in a separate email.
Thanks,
Clemens

October 26, 2010

Ms. Camille Leung
County of San Mateo
Redwood City, Ca 94063


Dear Ms. Leung,

At this time we note serious deficiencies in the Big Wave FEIR. Lack of comment on a County
response in the FEIR does not imply acceptance of that comment as accurate or adequate.
MWSD does not waive its right to raise issues from its previous comments in CEQA litigation.
The County has artfully dodged responses to numerous substantive issues.

The FEIR does not adequately analyze the water supply impacts of the project.

It does not address the growth potential of the increase in density of the manufacturing site
and the project provision of water for the project. The LCP calculated the water and sewer
capacity needed for buildout. The sewer and water agencies have planned their infrastructure,
service levels and funding mechanisms based on the county adopted zoning, general plan and
Local Coastal Program. The project supplied water and sewer service will be added to the
already determined capacities. The growth inducing impacts, including probable additional
traffic loads, of additional capacity remains unanalyzed. The EIR is fatally flawed.

The DEIR states that recycled water will be used for all irrigation. MWSD must conclude that
recycled water will be used to irrigate the B/W Farm operation located on the airport. MWSD is
the supplier of water to the airport and has the sole authority to deliver recycled water to
MWSD customers. Big Wave LLC and or Big Wave Farms cannot usurp our recycled water
authority. The environmental impact of the water supply for the farming operation has not
11/16/2010
Page 2 of 6
been analyzed. Montara Water and Sanitary District has not been contacted in this regard.

A number of well known documents and reports about the aquifer have not been consulted. In
the recently released Groundwater Study Phase III has compared groundwater levels in the
2009-2010 with levels in previous droughts without analyzing the amount of water that has
been taken out of the aquifers. Therefore prior studies and associated documents should be
included in the EIR.

MWSD sewer lines and sewer pump facilities are adjacent to the project. Clay pipes are easily
destroyed and MWSD’s sewer system impacted by trees planted on the Big Wave site. This
has not been analyzed in the current EIR.

The following sections comment on the County’s responses in the Final EIR to MWSD
comments on the Draft EIR in the District’s comment letter dated 24, 2009. The District has not
been able finish the review of all comments:

231-2 MWSD respectfully disagrees with the response. The purpose of an EIR is to evaluate
environmental impacts, not to attempt to make conclusions of law that are within the
jurisdiction of the courts. MWSD asserts its right to serve this project and has initiated LAFCo
consolidation proceedings with County Service Area 12 to conform District boundaries to our
acquired Service Area.

Without conceding in any way the County's claim that CCWD has, or in the future might have,
authority to serve the water needs of this project, MWSD continues to assert that it has the
exclusive right to serve within the former Citizens Utilities Company of California Service Area.
However, to prevent the project from being left entirely without access to public water in the
event that MWSD prevails in its position through LAFCo decisions or litigation, MWSD
respectfully requests that Condition of Approval 9 be modified to allow the project to obtain
public water from either MWSD or CCWD, whichever is ultimately determined to have the
authority to serve the project.

This may be accomplished by modifying the last sentence in the condition to read:
In the event that the annexation application to CCWD is denied by LAFCo or overturned by a
court of competent jurisdiction, or that necessary amendments to CCWD's CDPs are
not approved by the Coastal Commission or are approved with conditions that preclude
service within the former Citizens Utilities Company of California (CUCC) Service Area, or that a
court of competent jurisdiction determines that CCWD is attempting duplication of service by
invading the existing MWSD Service Area, the applicant shall actively pursue annexation to the
Montara Water and Sanitary District (MWSD) and shall not object or obstruct an application by
MWSD to consolidate with County Service Area 10 (or is it 12?) defining the Service Area of the
former CUCC. Upon completion of annexation or consolidation into MWSD, the applicant shall
apply for domestic water service connections, private fire protection connections, and any
necessary infrastructure improvements such as mainline extensions necessary to serve the
project, and after those water connections are approved and installed, the existing well shall
be transferred to MWSD for incorporation into the public water supply serving the Montara /
11/16/2010.
Page 3 of 6
Moss Beach community.

According to the General Plan Water Service Area map the project is in the Citizens Utilities
water district. MWSD purchased the Citizens Utilities District and its assets, including its entire
service area. MWSD is on record as to its ability to provide hydrants and service for sprinkler
systems within the structures.

On November 7, 2008, MWSD notified Jeff Peck by email (acknowledged by Mr. Peck also on
Nov. 7) that their project is within our service area, that "MWSD stands ready, today, to provide
public fire hydrants and private fire protection connections to internal sprinkler systems for your
proposed project," and that "We would like to meet with you to get a better idea of the water
needs of your proposed project, and how MWSD might be able to include sufficient capacity in
our plans for new water supply development to meet the needs of your proposed project as
well as the needs of other property owners in our entire Service Area."

Big Wave delayed meeting with MWSD until November 23, 2009 - more than a year later, and
after the DEIR was published.

MWSD was not contacted by the project applicants in regard to it’s ability to provide providers
into the Administrative Record, since clearly the County is stonewalling on this issue.

231-3 MWSD respectfully disagrees with the County's response. See comment on 231-2.

With regard to MWSD's question about septic system drainfields, our concern is not satisfied
by elimination of drainfields from the project. The DEIR does not adequately document the
location, age, or condition of existing septic drainfields that may affect the aquifer providing the
proposed well water supply for the project. The FEIR does not demonstrate that this proposed
water source will be safe from contaminants, especially nitrate, from existing septic systems
that the FEIR acknowledges are in the vicinity.

231-4 MWSD includes the certified LCP maps in the Administrative Record, despite the
County's refusal to do so, as the basis for future litigation. San Mateo County General Plan
Water Suppliers identifies Citizens Utilities Company as the water supplier – MWSD is the
successor water supplier to Citizens Utilities district.

231-5 MWSD finds the County's response inadequate, in that it fails to consider existing
certified maps and depends on a future action, i.e., LAFCo and Coastal Commission
approvals, that are by no means certain.

The FEIR refuses to consider likely future changes to the Half Moon Bay Airport safety zones,
which would preclude this project, and yet depends on hypothetical future approvals for water
service, which is essential to the project.

231-7 MWSD submits its Master Plan and Addendum to the Administrative Record in support
of anticipated litigation.

231-8 MWSD respectfully disagrees with this response.

231-9 MWSD reasserts its readiness to provide fire service to the project.
11/16/2010
Page 4 of 6

231-10 MWSD again raises the service duplication issue and asserts it has exclusive rights to
provide recycled water within its Service Area.

The Waterfront zoning district is subdivided and zoned for residential development at densities
greater than one DU per 5 acres: W zoning has a minimum parcel size of 5000 square feet
and allows caretaker quarters (which are residential) on 20% of the parcels, thus yielding an
allowed density of 8 DU per 5 acres. Thus policies 1.18 abs 1.19 do apply.

231-12 The County completely ignored the point of this comment. The proposed private
wastewater system adds at least 26,000 gallons per day to the regional wastewater treatment
capacity. Existing regional capacity is sufficient, and limited to that necessary to serve, buildout
of the LCP land use plan. Adding 118 equivalent resource units (ERUs) of private capacity to
the existing regional total is thus growth inducing, and no study of these growth inducing
impacts is included in the EIR. Consequently, the EIR is fatally flawed.

321-14 The County does not have an adequate enforcement mechanism to enforce its use
permits or zoning regulations relying instead on citizen complaints to spur action. The use
permit hearing on Sept 8, 2010 for PLN2001-00553 a use permit that expired 9 years ago is a
case in point. The business is reported to be disposing of contaminated waste water into the
Princeton drainage system and has an occupancy far in excess of that allowed in the airport
zone among other violations. Monitoring of hazardous chemicals every two years is not
adequate.

231-15 CEQA requires a full examination of cumulative impacts. The Farallone Vista Project,
Moss Beach Highlands Project and North El Granada Affordable Housing Projects remain as
planning priorities for the county as documented in the Local Coastal Program. The water
needs and traffic impacts of all of these projects need to included as part of the cumulative
impacts. Farallone Vista will require water from MWSD while the remaining two will use
CCWD as the water supplier. The traffic generated by all three should be included in the traffic
analysis.

MWSD anticipates it will have adequate water to serve new development within 20 years, the
anticipated timeframe over which the project would be constructed (see term of DA). The listed
affordable housing projects have priority for new water capacity and would therefore likely be
first in line. Therefore it is "reasonably foreseeable" that projects with a comparable cumulative
impact will be proposed and approved during this 20 year time span. The existing approved
EIRs for previous proposals on these sites provide an excellent basis for performing a
cumulative impact analysis.

If the County is willing to stipulate as a condition of approval or by contract on the DA that it will
not seek any commercial or industrial development at the Half Moon Bay Airport, then we
agree that there is no contribution to cumulative impacts from the airport. Otherwise, the Half
Moon Bay Airport Master Plan, which the County asserts was approved by the Board of
Supervisors in 1996 (?), forms the best guide for anticipating cumulative effects from Master
Plan implementation.

231-20 MWSD reasserts all points and legal authorities cited in David Schricker's letter. Failure
to acknowledge MWSD's claim to rights to serve these parcels is likely to lead to expensive
11/16/2010
Page 5 of 6
and time consuming litigation with resulting significant delays to the project. It is in the interests
of all parties to resolve the water service issue through cooperation, which had been actively
refused by the applicant and the County. (See email correspondence to Jeff Peck dated
November 2008 and 2009.)

231-21 The Phase II of the Kleinfelder report does not contain any long term study of the Pillar
Point Marsh or the specific endangered species or wetland habitats or information to evaluate
the impacts of this project on the Pillar Ridge water supply or the Montara Water and Sanitary
district water wells. The EIR needs to rely on the long term studies contained in the Half Moon
Bay/Pillar Point Marsh Ground-Water Basin Report Phase II by Luhdorff and Scalmanini, Sept
1991 and the 1993.12.02 California Coastal Commssion A-3-SMC-86-155 and 155A
Compliance Report. Given sufficient time to review the response MWSD will request a hydro-
geologist to comment.

231-23 to 231-32 Given sufficient time to review the response MWSD will request an engineer
to comment.

Water Supply

Clemens Heldmaier
11/16/2010
Page 6 of 6
General Manager
Montara Water & Sanitary District
8888 Cabrillo Hwy
Montara, CA 94037
PHONE: 650‐728‐3545
FAX: 650‐728‐8556
mwsd@coastside.net

PRIVILEGED COMMUNICATION:

The information contained in this message is privileged and confidential. It is intended only to be read by the individual
or entity named above or their designee. If the reader of this message is not the intended recipient, you are on notice
that any distribution of this message, in any form, is strictly prohibited. If you have received this message in error, please
immediately notify the sender and delete or destroy any copy of this message.

file://C:\Documents and Settings\balbini.COMMON\Local Settings\Temp\XPgrpwise\4C... 11/16/2010

Page 1 of 1
From: "Clemens Heldmaier" <mwsd@coastside.net>

To: "'Camille Leung'" <CLeung@co.sanmateo.ca.us>
Date: 11/9/2010 1:59 PM
Subject: Big Wave
Attachments: oledata.mso; Resolution 1480 Big Wave0001.pdf
Camille,

On the November 4 meeting the Board of Directors of the Montara Water and Sanitary District
adopted RESOLUTION 1480, RESOLUTION OF THE MONTARA WATER AND SANITARY DISTRICT
CONCERNING PROPOSED “BIG WAVE” OFFICE AND WELLNESS CENTER DEVELOPMENT IN THE VICINITY
OF PILLAR POINT MARSH. Please see the resolution attached. A hardcopy will be send by mail. Please
ensure that the Resolution will be included in the packet the for the next relevant Planning Commission
Meeting concerning Big Wave.

Thank you

Clemens Heldmaier
General Manager
Montara Water & Sanitary District
8888 Cabrillo Hwy
Montara, CA 94037
PHONE: 650‐728‐3545
FAX: 650‐728‐8556
mwsd@coastside.net

PRIVILEGED COMMUNICATION:

The information contained in this message is privileged and confidential. It is intended only to be read by the individual
or entity named above or their designee. If the reader of this message is not the intended recipient, you are on notice
that any distribution of this message, in any form, is strictly prohibited. If you have received this message in error, please
immediately notify the sender and delete or destroy any copy of this message.

11/16/2010...
P.o. Box 370131 Tel: (650) 728-3545
8888 Cabrillo Highway Fax: (650) 728-8556
Montara, CA 94037-0131 E-mail: mwsd @c oastside.net
October 26, 2010
Ms. Cam ille Leung

Plann ing and Bu ilding Department
County of San Mateo
455 County Center, 2 nd Floor
Dear Ms. Leung,
At this time we note serious deficiencies in the Big Wave FEIR. Lack of comment
on a County response in the FEIR does not imply acceptance of that comment as
accurate or adequate. MWSD does not waive its right to raise issues from its
previous comments in CEQA litigation. The County has artfully dodged
responses to numerous substantive issues.
The FEIR does not adequately analyze the water supply impacts of the project.
It does not address the growth potential of the increase in density of the
manufacturing site and the project provision of water for the project. The LCP
calculated the water and sewer capacity needed for buildout. The sewer and
water agencies have planned their infrastructure, service levels and funding
mechanisms based on the county adopted zoning, general plan and Loca l
Coastal Program. The project supplied water and sewer service will be added to
the already determined capacities. The growth inducing impacts, including
probable add itional traffic loads, of add itional capacity remains unanalyzed. The
EIR is fata lly flawed .
The DEIR states that recycled water will be used for all irrigation. MWSD must
conclude that recycled water will be used to irrigate the BMJ Farm operation
located on the airport. MWSD is the supplier of water to the airport and has the
sole authority to deliver recycled water to MWSD customers. Big Wave LLC and
or Big Wave Farms cannot usurp our recycled water authority. The
environmental impact of the water supply for the farming operation has not been
analyzed. Montara Water and Sanitary District has not been contacted in this
regard.
A number of well known documents and reports about the aquifer have not been
consulted. In the recently released Groundwater Study Phase III has compared
groundwater levels in the 2009-2010 with levels in previous droughts without
analyzing the amount of water that has been taken out of the aquifers. Therefore
prior studies and associated documents should be included in the EIR.
MWSD sewer lines and sewer pump facilities are adjacent to the project. Clay
pipes are easily destroyed and MWSD's sewer system impacted by trees planted
on the Big Wave site. This has not been analyzed in the current EIR.
The following sections comment on the County's responses in the Final EIR to
MWSD comments on the Draft EIR in the District's comment letter dated 24,
2009. The District has not been able finish the review of all comments:
231-2 MWSD respectfully disagrees with the response. The purpose of an EIR is
to evaluate environmental impacts, not to attempt to make conclusions of law
that are within the jurisdiction of the courts. MWSD asserts its right to serve this
project and has initiated LAFCo consolidation proceedings with County Service
Area 12 to conform District boundaries to our acquired Service Area.
Without conceding in any way the County's claim that CCWD has, or in the
future might have, authority to serve the water needs of this project,
MWSD continues to assert that it has the exclusive right to serve within the
former Citizens Utilities Company of California Service Area. However, to
prevent the project from being left entirely without access to public water in
the event that MWSO prevails in its position through LAFCo decisions or
litigation, MWSO respectfully requests that Condition of Approval 9 be
modified to allow the project to obtain public water from either MWSO or
CCWD, whichever is ultimately determined to have the authority to serve
the project.
This may be accomplished by modifying the last sentence in the condition

to read:
In the event that the annexation application to CCWD is denied by LAFCo
or overturned by a court of competent jurisdiction, or that necessary
amendments to CCWD's COPs are not approved by the Coastal
Commission or are approved with conditions that preclude service within
the former Citizens Utilities Company of California (CUCC) Service Area,
or that a court of competent jurisdiction determines that CCWD is
attempting duplication of service by invading the existing MWSD Service
Area, the applicant shall actively pursue annexation to the Montara Water
and Sanitary District (MWSD) and shall not object or obstruct an
application by MWSD to consolidate with County Service Area 10 (or is it
12?) defining the Service Area of the former CUCC. Upon completion of
annexation or consolidation into MWSD, the applicant shall apply for
domestic water service connections, private fire protection connections,
and any necessary infrastructure improvements such as mainline
extensions necessary to serve the project, and after those water
connections are approved and installed, the existing well shall be
transferred to MWSD for incorporation into the public water supply serving
the Montara / Moss Beach community.
According to the General Plan Water Service Area map the project is in the
Citizens Utilities water district. MWSD purchased the Citizens Utilities District
and its assets, including its entire service area. MWSD is on record as to its
ability to provide hydrants and service for sprinkler systems within the structures.
On November 7,2008, MWSD notified Jeff Peck by email (acknowledged by Mr.

Peck also on Nov. 7) that their project is within our service area, that "MWSD
stands ready, today, to provide public fire hydrants and private fire protection
connections to internal sprinkler systems for your proposed project," and that
"We would like to meet with you to get a better idea of the water needs of your
proposed project, and how MWSD might be able to include sufficient capacity in
our plans for new water supply development to meet the needs of your proposed
project as well as the needs of other property owners in our entire Service Area."
Big Wave delayed meeting with MWSD until November 23, 2009 - more than a
year later, and after the DEIR was published.
MWSD was not contacted by the project applicants in regard to it's ability to
provide providers into the Administrative Record, since clearly the County is
stonewalling on this issue.
231-3 MWSD respectfully disagrees with the County's response. See comment
on 231-2.
With regard to MWSD's question about septic system drainfields, our concern is not satisfied b)
elimination of drainfields from the project. The DEIR does not adequately document the locatior
age, or condition of existing septic drainfields that may affect the aquifer providing the proposec
well water supply for the project. The FEIR does not demonstrate that this proposed water sour
will be safe from contaminants, especially nitrate, from existing septic systems that the FEIR
acknowledges are in the vicinity.
231-4 MWSD includes the certified LCP maps in the Administrative Record,
despite the County's refusal to do so, as the basis for future litigation. San
Mateo County General Plan Water Suppliers identifies Citizens Utilities Company
as the water supplier .~ MWSD is the successor water supplier to Citizens Utilities
district.
231-5 MWSD finds the County's response inadequate, in that it fails to consider
existing certified maps and depends on a future action, i.e., LAFCo and Coastal
Commission approvals, that are by no means certain.
The FEIR refuses to consider likely future changes to the Half Moon Bay Airport
safety zones, which would preclude this project, and yet depends on hypothetical
future approvals for water service, which is essential to the project.
231-7 MWSD submits its Master Plan and Addendum to the Administrative
Record in support of anticipated litigation.
231-8 MWSD respectfully disagrees with this response.
231-9 MWSD reasserts its readiness to provide fire service to the project.
231-10 MWSD again raises the service duplication issue and asserts it has
exclusive rights to provide recycled water within its Service Area.
The Waterfront zoning district is subdivided and zoned for residential

development at densities greater than one DU per 5 acres: W zoning has a
minimum parcel size of 5000 square feet and allows caretaker quarters (which
are residential) on 20% of the parcels, thus yielding an allowed density of 8 DU
per 5 acres. Thus policies 1.18 abs 1.19 do apply.
231-12 The County completely ignored the point of this comment. The proposed
private wastewater system adds at least 26,000 gallons per day to the regional
wastewater treatment capacity. Existing regional capacity is sufficient, and limited
to that necessary to serve, buildout of the LCP land use plan. Adding 118
equivalent resource units (ERUs) of private capacity to the existing regional total
is thus growth inducing, and no study of these growth inducing impacts is
included in the EIR. Consequently, the EIR is fatally flawed.
321-14 The County does not have an adequate enforcement mechanism to

enforce its use permits or zoning regulations relying instead on citizen complaints
to spur action. The use permit hearing on Sept 8,2010 for PLN2001-00553 a use
permit that expired 9 years ago is a case in point. The business is reported to be
disposing of contaminated waste water into the Princeton drainage system and
has an occupancy far in excess of that allowed in the airport zone among other
violations. Monitoring of hazardous chemicals every two years is not adequate.
231-15 CEQA requires a full examination of cumulative impacts. The Farallone

Vista Project, Moss Beach Highlands Project and North EI Granada Affordable
Housing Projects remain as planning priorities for the county as documented in
the Local Coastal Program. The water needs and traffic impacts of all of these
projects need to included as part of the cumulative impacts. Farallone Vista will
require water from MWSD while the remaining two will use CCWD as the water
supplier. The traffic generated by all three should be included in the traffic
analysis.
MWSD anticipates it will have adequate water to serve new development within
20 years, the anticipated timeframe over which the project would be constructed
(see term of DA). The listed affordable housing projects have priority for new
water capacity and would therefore likely be first in line. Therefore it is
"reasonably foreseeable" that projects with a comparable cumulative impact will
be proposed and approved during this 20 year time span. The existing approved
EIRs for previous proposals on these sites provide an excellent basis for
performing a cumulative impact analysis.
If the County is willing to stipulate as a condition of approval or by contract on the

DA that it will not seek any commercial or industrial development at the Half
Moon Bay Airport, then we agree that there is no contribution to cumulative
impacts from the airport. Otherwise, the Half Moon Bay Airport Master Plan,
which the County asserts was approved by the Board of Supervisors in 1996 (?),
forms the best guide for anticipating cumulative effects from Master Plan
implementation.
231-20 MWSD reasserts all pOints and legal authorities cited in David Schricker's
letter. Failure to acknowledge MWSD's claim to rights to serve these parcels is
likely to lead to expensive and time consuming litigation with resulting significant
delays to the project. It is in the interests of all parties to resolve the water service
issue through cooperation, which had been actively refused by the applicant and
the County. (See email correspondence to Jeff Peck dated November 2008 and
2009.)
231-21 The Phase II of the Kleinfelder report does not contain any long term
study of the Pillar Point Marsh or the specific endangered species or wetland
habitats or information to evaluate the impacts of this project on the Pillar Ridge
water supply or the Montara Water and Sanitary district water wells. The EIR
needs to rely on the long term studies contained in the Half Moon Bay/Pillar Point
Marsh Ground-Water Basin Report Phase II by Luhdorff and Scalmanini, Sept
1991 and the 1993.12.02 California Coastal Commssion A-3-SMC-86-155 and
155A Compliance Report. Given sufficient time to review the response MWSD
will request a hydro-geologist to comment.
231-23 to 231-32 Given sufficient time to review the response MWSD will request
an engineer to comment.
Water Supply
The question is not whether CCWD has enough uninstalled connections today to
serve Big Wave (if allowed by MWSD, LAFCo, and the CCC), but whether
CCWD will have sufficient water in 2080 (end of 50-year economic life of building
constructed at end of 20-year proposed Development Agreement), after all
Crystal Springs connections have been installed.
Note that the growth limits do not necessarily assure CCWD that water
connections will not be needed quickly. This single project requires 118 ERUs of
sewer capacity and might require a similar amount of water. Other non-
residential development, plus priority uses, could quickly place significant
demand on CCWD's system, beyond its existing drought year supply assurance.
There is no environmental analysis of CCWD water supply impacts to serve the

project long term.
Sincerely
/s/
Kathryn Slater-Carter
Attachments
RESOLUTION NO. 1480
RESOLUTION OF THE MONTARA WATER AND SANITARY DISTRICT
CONCERNING PROPOSED "BIG WAVE" OFFICE AND WELLNESS CENTER
DEVELOPMENT IN THE VICINITY OF PILLAR POINT MARSH
(APN 047-311-060, 047-312-040)
WHEREAS, significant improvements to the District's water system have

been made, and additional sources of water have been acquired, by our District
subsequent to acquiring the privately-owned system in 2003; and
WHEREAS, the District's Water Master Plan provides for service
throughout the entire service area acquired by the District including the Project
area; and
WHEREAS, this District has commented upon both the DEIR and FEIR
regarding their omission to acknowledge our authority and duty to provide water
service to the Project and the corresponding deficiencies and inaccuracies in
those documents; and
WHEREAS, this Board desires to set forth its policy and intentions
regarding the provision of water service within the service area currently located
outside District boundaries and to the Project;
NOW, THEREFORE,
BE IT RESOLVED BY THE BOARD OF THE MONTARA WATER AND
SANITARY DISTRICT AS FOLLOWS:
1. The foregoing recitals are incorporated herein by reference.
2. The service area acquired by this District in 2003 is a valuable asset of
the District and of the citizens served by the District, both within and outside our
corporate boundaries.
3. Public policy and the legislative authority conferred upon our District
require that connection to a public water system shall be paramount to, and
preferred over, on-site systems such as that proposed for the Project.
4. Our District currently is capable of providing fire protection service for
the Project and our District likewise is capable of providing commercial and
domestic service for the Project.
5. In accordance with the foregoing, this Board fully intends to provide
service throughout its entire service area acquired by purchase of the water
RESOLUTION NO. 1480
(APN 047-311-060, 047-312-040)
WHEREAS, the Final Environmental Impact Report ("FEIR") for the

development of 19.4 acres of land currently devoted primarily to agricultural use
and including wetlands in the vicinity of Pillar Point Marsh in the mid-coast region
of unincorporated San Mateo County ("County") has been submitted to the
County's Planning Commission for certification under the California
Environmental Quality Act ("CEQA"; Pub. Res. C. §21000 et seq.); and
WHEREAS, the development, named "Big Wave" ("Project"), consists of
an office component and a "well ness center" component with associated
appurtenances and amenities; and
WHEREAS, as proposed by the Project proponent domestic and
commercial water service for the Project would be provided through on-site wells
with fire protection service and "backup" water service from Coastside County
Water District ("CCWD"); and
WHEREAS, the Project is located within the service area acquired by this
District through its purchase in 2003 of the privately-owned water system then
serving our District; and
WHEREAS, the Project is located outside the corporate boundaries of
both CCWD and this District; and
WHEREAS, this District has initiated proceedings through the County
Local Agency Formation Commission ("LAFCo") to reorganize the District's
boundaries to incorporate that portion of the District's service area, including the
Project area, that currently is located outside the District boundaries; and
WHEREAS, this District currently provides water service to the Half Moon
Bay Airport outside our corporate boundaries and to the Pillar Ridge
Manufactured Home Community within our boundaries, both of which service
areas are adjacent to the Project; and
RESOLUTION NO. 1480
(APN 047-311-060, 047-312-040)
system described above, including service to the Project in compliance with the
District's governing statute, all pertinent District regulations, specifications and
related terms and conditions in furtherance of the public health, welfare and
safety.
6. The District Secretary is hereby authorized and directed to transmit a
certified copy of this resolution to the County Planning Commission in
conjunction with its review of the FEIR, to the Project proponent and to the
County Local Agency Formation commis~~~ n. . ij "-
-.p~~
President, Montara Water and Sanitary District
COUNTERSIGNED:
Secretary, Montar Water and Sanitary District
****
I HEREBY CERTIFY that the foregoing Resolution No. 1480 was duly and
regularly adopted and passed by the Board of the Montara Water and Sanitary
District, San Mateo County, California, at a Regular Meeting thereof held on the
4th day of November 2010, by the following vote:
AYES, Directors: Boyd, Harvey, Perkovic, Slater-Carter & Ptacek
NOES, Directors: n/a
ABSENT, Directors: None

Kathr~n 6507281451 p. 1
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LAW OFFICES OF ;'
./
J.
DAVID E. SCHRICKER
A PROFESSIONAL CORPORATION
20370 Town Center Lane, Suite 100
CUPERTINO, CALIFORNIA 95014
(-.\ TELEPHONE (408) 517-9923

: _ _1
FAX (408) 252-5906
~ ... l_j ":" ,-
E-MAIL: dschricker@schrickerlaw.com
'"
... schrickerlaw@aol.com
:~:::.~--
, www.schrickerlaw.com
C",J
Via mail, e-mail and facsimile ([650] 363-4849)
October 25, 2010
Honorable Chair and Commission Members

County of San Mateo
455 County Center, Second Floor
Re: Big Wave Wellness Center and Office Park ("Project") - Proposed
Certification of Final Environmental Impact Report ("FEIR")
Dear Chair Bomberger and Commission Members:
This letter preliminarily responds to the Notice of Availability of the above-

referenced FEIR on behalf of the Montara Water and Sanitary District ("MWSD").
Initially, I must underscore the need for an extended comment period as
requested in the letter dated October 18, 2010 to Camille Leung, Project
Planner, from Clemens Heldmaier, MWSD's General Manager. Aside from the
voluminous bulk of the FEIR, including the Comment Letters and Responses
thereto, the proposed revisions to the Project and its complexity in relation to
environmental and regulatory concerns demand further detailed analysis and
correction, all of which necessarily require additional time for comment beyond
the 12 days referenced in the Notice. Likewise, and in consideration of the
foregoing, the comments contained in this letter must be viewed as preliminary,
made without prejudice to additional comments and without waiving objection to
deficiencies in theFEIR and proposed conditions of approval that may not have
been stated in this letter.
A fundamental flaw in the FEIR, carried forward from the Draft

Environmental Impact Report ("DEIR") is the failure of the Project proponent and
the County, as sponsor of the DEIR and FEIR, to acknowledge MWSD as the
water utility service provider for the Project and, correspondingly, its status as a
Responsible Agency under the California Environmental Quality Act (" CEQA";
Pub. Res. C §21 000 et seq.).1 From that omission flow fatal deficiencies in the
FEIR regarding its failure to consider alternative water sources, failure of the
1 This omission has been brought to the County's attention repeatedly. Please refer to my letters
dated December 4, 2009 and February 19, 2010 to Ms. Camille Leung, enclosed herewith.
Hon. Chair and Planning Commissioners
October 25,2010
Page 2
Project to comply with the Local Coastal Program ("LCP") and the County's
General Plan, among other regulatory requirements.
The purported responses to MWSD's comments regarding MWSD's

status as a Responsible Agency under CEQA and its right and duty to provide
service for the Project are factually and legally incorrect. As the legal basis for
purporting to reject MWSD as the water service provider for the Project and its
exclusion from MWSD's service area, the FEIR relies upon Code of Civil
Procedure Section 1235.170 (Response to Comment 231-2).2 The property that
MWSD acquired through the initiation of eminent domain proceedings consisted
of the on-going business enterprise of the Montara Division of California
American Water Company ("CaIAm"), which had acquired all of the assets of
Citizens Utilities Company California rCUCC"), including its service area
established by the California Public Utilities Commission. 3
It is well settled that a public agency may acquire a privately-owned water

system as an on-going business enterprise, including that portion that lies
outside the boundaries of the acquiring agency (City of North Sacramento v.
Citizens Utilities Company of California [1961] 192 Cal. App. 2 nd 482; 13 Cal
Rptr. 538). That a water utility's service area is an identifiable and purchasable
property interest is clearly established by case law (City of San Jose v. Great
rd
Oaks Water Co. (1987) 192 Cal. App. 3 1005; 237 Cal. Rptr. 845). Aside from
being contrary to the law, the foregoing FEIR Response is specious because a
utility system without the territorial ability to provide service to its customers,
present and future, would be valueless.
Instead of analyzing MWSD's capability of providing water service to the

Project as an appropriate alternative to the proposed on-site source, the FEIR
sets forth arguments without analysis in avoidance of MWSD's service based
upon the erroneous conclusion that MWSD is not a Responsible Agency under
CEQA (Response to Comment 231-3). Rather than analyzing MWSD's capability
as an alternative water supplier, the FEIR indulges in a circular argument
commencing with the conclusion that MWSD is not a Responsible Agency and
then asserting that therefore it should not be the supplier (id.).·
The FEIR avoids analysis by relying upon the Local Agency Formation
Commission's ("LAFCo.") Sphere of Influence designation for CCWD
(Responses to Comments 231-2, 231-5, 231-6, 231-7, 231-8, 31-9, 231-10).
However, a Sphere of Influence is merely an indication of an agency's future
boundary as determined by LAFCo at a given moment in time (Gov. C. §56076).
It is subject to change to reflect changes in the provision of an agency's services.
2 That section defines property for eminent domain purposes as follows: "'Property' includes real
and personal property and any interest therein." (emphasis added).
3 Enclosed herewith, please find copy of CalAm's (formerly CUCC's) service area included as an
exhibit to the acquisition documents. .
October 25, 2010
Page 3
Here, just such a change has occurred by virtue of MWSD's acquisition of

the CUCC/CaIAm service area coupled with MWSD's updated Water Master
Plan that demonstrates MWSD's capability of providing service within its
acquired extraterritorial service area, including the Project. 4 Moreover, MWSD
currently provides service to that portion of the acquired service area through its
service to the Half Moon Bay Airport and to the Pillar Ridge Manufactured Home
Community in close proximity to the Project area, thereby demonstrating its
5
capability of expanding service to the Project. The FEIR simply ignores those
salient facts thereby avoiding analysis of MWSD's role as a Responsible Agency
under CEQA and as an alternative source of water service to that proposed by
the Project proponent. Such an analysis is required under CEQA (Napa Citizens
for Honest Government v. Napa County Board of Supervisors [2001] 91 Cal.
App. 4th 342, 373; 110 Cal. Rptr. 2 nd 579).
The FEIR also avoids analysis of CCWD's capability or lack thereof for
providing service to the Project, notwithstanding that it nominates CCWD as
somewhat of a back-up service provider. In that regard, the County General Plan
notes that, for CCWD, demand exceeds supply (General Plan, Table 10.4).6 By
focusing on and inadequately analyzing the Project's proposed on-site source of
water, the FEIR has omitted analysis of exclusive water service provided by
existing public agencies. In so doing, it purports to exalt an essentially untried
private system over viable existing public systems.
By the same token, the County General Plan includes, through the
designation of CUCC's service area (now MWSD's) that MWSD, as the
successor to CUCC, is the service provider for the area encompassed by the
Project. 7 Likewise, LCP Policy 1.3 defines urban areas, such as that within which
the Project is located, to include lands that are suitable for development
because, among other requirements, they are served by public utilities. Here,
utility service inexplicably would be limited to a private utility. The FEIR fails to
analyze the Project in relation to its inconsistencies with the General Plan and
the LCP. That omission violates the mandates of CEQA.
4 Enclosed herewith please find copy of MWSD Resolution No. 1438, initiating proceedings for
consolidation of County Service Area ("CSA") 12 with Montara Water and Sanitary District. As
stated in the recitals of the resolution, CSA 12's boundaries conform to the former service area of
CUCC/CaIAm. The consolidation will provide for inclusion of the entire service area within the
corporate boundaries of MWSD. A change in the Sphere of Influence may occur concurrently with
the reorganization effectuated by the consolidation. As noted, the Project lies with in that area. By
adoption of a separate resolution, MWSD has also initiated proceedings for annexation of the
extraterritorial area.
5 By avoiding meaningful contact with MWSD, the Project proponent and preparer of the
DEIR/FEIR has precluded informed factual analysis of MWSD's role as the water service provider
and, hence, the determination that MWSD is a Responsible Agency under CEQA.
6 While that Table apparently predates more recent improvements to CCWD's water system,
current information suggests that it is not out of date.
7 Please refer to General Plan designation of Water Suppliers, enclosed herewith.
October 25, 2010
Page 4
In short, for sewage and water utilities, the Project proponent would
establish a private utility fiefdom. That is contrary to public policy, good planning
concepts, existing planning regulations (the LCP and the County General Plan)
and correspondingly, the public health, welfare and safety.
The County's planning staff has recommended, as a condition of approval

of the Project, that the Project applicant actively pursue a water connection from
CCWD for the potable water and fire suppression needs of the Project (General
Project Condition 9). That recommendation is not supported by the FEIR which,
as discussed above, is fatally deficient under CEQA for failure to analyze
alternative water sources and sufficiently to examine the frailties of the proposed
on-site water system. Indeed, the latter represents a curious and undisclosed
rejection of public systems. With regard to MWSD, the FEIR fails in any manner
whatsoever to discuss any alleged inability of MWSD to provide service to the
Project, which is located within MWSD's service area. The FEIR's silence on that
subject follows from the fact that there are no grounds to support such an
allegation.
MWSD respectfully urges your Honorable Commission to deny

certification of the FEIR and deny approval of the Project and accompanying
applications for permits. In conjunction therewith, and if the applicant desires to
pursue the Project further, MWSD respectfully recommends that the applicant be .
directed to provide a thorough analysis and examination of provision of water
and sewerage service solely by public agencies in accordance with existing land-
use regulations and generally accepted concepts of public policies in furtherance
of the public health, welfare and safety.
David E. Schricker, Attorney
DES:hs
Encl.
cc: MWSD Board (via e-mail)

MWSD General Manager (via e-mail)
MWSD Water Engineer (via e-mail)
David J. Byers, Atty. (via facsimile: [650] 697 - 4895)
LAW OFFICES OF
DAVID E. SCHRICKER
TELEPHONE (408) 517 -9923

FAX (408) 252-5906
schrickerlaw@aol.com
www.schrickerlaw.com
December 4, 2009

County of San Mateo
Re: Big Wave Well ness Center and Office Park ("Project") - Draft Environmental
Impact Report ("DEIR")
Dear Ms. Leung:
This letter is a preliminary comment on behalf of the Montara Water and

Sanitary District ("MWSD") responding to the Notice of Availability for the subject
DEIR regarding its coverage of water utility services and systems (DEIR, pp.
IV.N 21 et seq.; page references commencing with "IV.N" hereinafter are to the
DEIR). MWSD exercises water powers pursuant to the County Water District
Law (Wat. C. §30000, et seq.; H. & S. C. §6512.7). For the reasons discussed
below, MWSD is a Responsible Agency (as that term is defined in the California
Environmental Quality Act ["CEQA," Pub. Res. C. §21000 et seq.) for the Project
and should be so listed in the DEIR. Aside from that omission, as also discussed
below, the DEIR's coverage of water service and systems is deficient for failure
adequately to discuss alternative water supplies and service and long-term
effects of the Project on community water supplies.
The Project is located within the water service area established by the
California Public Utilities Commission ("CPUC") for Citizens' Utility Company of
California ("CUCC"). That company was acquired by California American Water
Company ("CaIAm") and in 2003 MWSD acquired the water system from CaiAm.
MWSD thereby succeeded to the property interests of CUCC and CalAm,
including the service area (City of San Jose v. Great Oaks Water Co. (1987) 192
Cal App 3d 1005; 237 Cal Rptr 845).1 Under MWSD's regulations, property
capable of being served by its system must connect to it (MWSD C. §5-3.103).2
1 Although the Project is outside MWSD's corporate boundaries, MWSD is authorized to provide
extraterritorial service (Wat. C. §31023).
2 MWSD's projections for improvement and development of its water system coincide with the.
probable timeline for actual development of the Project. Therefore, the moratorium on new
connections initially established by the CPUC while the system was owned by CUCC and
necessarily continued by MWSD would not be a barrier to MWSD's service to the Project.
December 4, 2009
Page 2
Accordingly, MWSD is a Responsible Agency under CEQA for the Project (Pub.
Res. C. §21069). The DEIR neglects to identify MWSD as such and therefore is
deficient in that regard.
A corresponding defect of the DEIR is its failure to identify MWSD as an

alternative source of water service. Analysis under CEQA requires discussion of
alternative water sources (Napa Citizens for Honest Government v. Napa County
Board of Supervisors (2001) 91 Cal. App. 4th 342, 373; 110 Cal. Rptr. 2 nd 579;
see, also Laurel Heights Imrrovement Ass'n. v. Regents of the University of
r
California [1988], 47 Cal. 3 376; 253 Cal. Rptr. 426, 764 P.2d 278).
Indeed, the DEIR omits discussion of any alternative source of water and
purports to establish an on site well as the sole source (IV.N-36~37; IV.H-42).
Moreover, in relying on purported overlying water rights to serve the
development, the DEIR fails to discuss the long-term effects of drawing on
underground water resources, including the effects on property served, or to be
served, by the same aquifer, with the exception of adjacent agricultural land
(IV.N-33).3 Such effects must be analyzed under CEQA (Vineyard Area Citizens
for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal. 4th 4121;
rd
53 Cal. Rptr. 3re 821, 150 P. 3 709). Specifically, expanded tapping and
extraction of underground water supplies must be analyzed in an EIR (County of
Inyo v. Yorty (1973) 32 Cal. App. 3rd 795; 108 Cal. Rptr. 377).
In sum, the DEIR is significantly deficient in analyzing the water resource

impacts of the Project in an area served by fragile groundwater supplies. That
deficiency must be addressed by including, among the issues mentioned above,
the water resource impacts of the Project vis-a-vis the absence of aground
water management plan for the midcoast region within which the Project is
located.
Very truly yours,
lsI

David J. Byers, Atty.
3 Inexplicably, the DEIR includes no discussion of alternative sources for the agricultural property,
the water supply of which would be depleted by 80% in drought years by the Project's water
consumption (IV.N-33). '. .. ',''; .
LAW OFFICES OF
DAVID E. SCHRICKER
TELEPHONE (408) 517-9923

FAX (408) 252-5906
schricker1aw@aol.com
February 19, 2010

County of San Mateo
Re: Big Wave Wellness Center and Office Park ("Project") - Draft Environmental
Impact Report ("DEIR") Planning Commission Study Session
Dear Ms. Leung:
This letter refers to your Staff Report ("RepOrt") dated January 27,2010
(Subject: Study Session Background Report Regarding the Big Wave Office Park
and Well ness Center Project and Draft Environmental Impact Report (DEIR». I
understand that the Report was presented to and discussed by the County
Planning Commission on that date.
Our office commented on the DEIR on behalf of the Montara Water and
Sanitary District ("MWSD"), a "Responsible Agency" for the project under the
California Environmental Quality Act ("CEQA," Pub. Res. C. §21000 et seq.) with
regard to serious deficiencies of the DEIR's Hydrology & Water Quality and
Utilities & Service Systems sections (DEIR §§ IV.H. and IV.N., respectively).1 As
discussed below, the Report perpetuates gross omissions in the DEIR, which
renders the DEIR legally inadequate under CEQA.
In response to the Planning Commission's question, " ... who is a

Responsible Agency per CEQA and who is not?" (Report, p.7), the Report
purports to identify Coastside County Water District ("CCWD") as the secondary
provider of domestic water and the primary provider of emergency and fire flow
water (id., pp. 7_8).2 However, as stated in our letter dated December 4, 2009,
MWSD is the Responsible Agency for water service because the project is
located within MWSD's service area and MWSD fully intends to serve the
project. Simply put, CCWD has no jurisdictional authority to serve the project and
to suggest otherwise is clearly erroneous and misleading:
1Please refer to copy of letter dated December 4, 2009, enclosed herewith.

2An on site well is identified as the primary domestic water source, corresponding to the DEIR's
description (Report, pp. 7-8).
February 19, 2010
Page 2
With regard to MWSD's authority, MWSD exercises its water powers

under the County Water District Law (Wat. C. §30000 et seq.; H. & S. C.
§6512.7). It has enacted water service regulations pursuant to its statutory
authority (Wat. C. §31024). Those regulations include mandatory connection to
its system for properties located within its service area (MWSD C.§5-3.1 03).
MWSD exercises its community water powers in furtherance of State policy
protecting municipal water rights !' ••• to the fullest extent necessary for existing
and future uses, ... subject to the rights of the municipality to apply such water to
municipal uses as and when necessity therefor exists." (Wat. C. §106.5).
Succinctly stated, at such time as the proposed project is ready to develop, it
3
shall be mandated to connect to MWSD's water system. ,
While the DEIR purports to describe water utility service at odds with
MWSD's service area and authority by omitting any reference to MWSD, it is
incumbent upon the County, in carrying out its Lead Agency duties under CEQA,
candidly to identify MWSD's Responsible Agency status, particularly in light of
the fact that that omission, among other deficiencies of the DEIR, has been
brought to the County's attention. Kindly ensure that a copy of this letter is
included in the administrative record of the CEQA proceedings for the project.
Very truly yours,
lsI
DES:hs
Enel.

3As noted in my letter dated December 4, 2009 (fn. 2), MWSD's projections for improvement and
development of its water system coincide with the probable timeline of the Big Wave development
so as to be capable of serving the latter.
• • •
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SERVICE AREA BOUNDARIES
CI11ZENS UllUllES
COMPANY OF CAUfORNIA
COASTSIDE COUNTY
WATER OISlRlCT
MONTARA SANITAnON
DISlRlCT
PIPE SIZf lEGEND

1 - Inch
1,5 - Inch
1 -Inch
2.5 - Inch
3 - Ineb
4 ··Inch
6 -loch
e - Inch
10 - Inch
12 - Ind!.
500 1000 2000
16 - Inch
SCALE IN FEET
MONTARA
•
Resolution No. 1438
RESOLUTION OF APPLICATION TO THE LOCAL AGENCY FORMATION

COMMISSION OF SAN MATEO COUNTY, CALIFORNIA, INITIATING
PROCEEDINGS FOR CONSOLIDATION OF COUNTY SERVICE AREA 12
WITH THE MONTARA WATER AND SANITARY DISTRICT AND
ESTABLISHING SAID DISTRICT AS SUCCESSOR AGENCY
(Montara Water and Sanitary District)
WHEREAS, pursuant to Resolution No. 50749 entitled, "Resolution

Establishing San Mateo County Service Area No. 12 (Montara-Moss Beach) for
the Water Services and Establishing the Affected Area," adopted August 30,
1988 by the Board of Supervisors, County of San Mateo, County Service Area
No. 12 ("CSA 12") was established; and
WHEREAS, CSA 12 was established to provide water service, including
the acquisition, construction, operation, replacement, maintenance and repair of
water supply and distribution systems, including land, easements and rights of
way and water rights; and
WHEREAS, CSA 12 was established in anticipation of acquiring the water
system then owned by Citizens' Utilities Company of California ("CUCC") serving
residents of the Montara-Moss Beach unincorporated communities in San Mateo
County; and
WHEREAS, CSA 12's boundaries conform to the service area of CUCC
established by the California Public Utilities Commission; and
WHEREAS, CSA 12 did not proceed to acquire CUCC's water system as
originally anticipated; and
WHEREAS, as of August 1, 2003, the Montara Water and Sanitary District
("MWSD") acquired the assets of the aforesaid water system from CUCC's
successor in interest, California American Water Co., including the service area
thereof; and
WHEREAS, MWSD is operating the water system in all respects and has
exclusive ownership and control of, and authority over, said system; and
1
ResAppnConsolCSA 12rr[renLirnbered 1438]
WHEREAS, a portion of the service area acquired by MWSO currently lies
adjacent to and outside of MWSO's southerly boundary; and
WHEREAS, the boundary of CSA 12 includes the aforementioned portion
of the service area acquired by MWSD; and
WHEREAS, in conjunction with the formation of CSA 12, the San Mateo
County Local Agency Formation Commission determined that the boundary of
CSA 12 shall include the entire area served by CUCC; and
WHEREAS, MWSO has fulfilled and is fulfilling the purposes of CSA 12;
and
WHEREAS, in order to carry out the intent evidenced by the formation of
CSA 12 that the water service area for the Montara-Moss Beach communities
shall be identical to the former service area of CUCC and to provide that
MWSD's boundary shall include that area, it is appropriate to consolidate CSA 12
and MWSD with MWSD established as the successor etgency so as to include
the aforesaid portion of the CSA 12 territory currently lying outside of MWSO's
,boundary; and
WHEREAS, the Local Agency Formation Commission of the County of -
San Mateo, California ("LAFCO") exercises the authority granted such
commissions under the Cortese-Knox-Hertzberg Local Government
Reorganization Act of 2000 (Title 5, Division 3 [commencing with §56000] of the
Government Code [the "Act"]) for changes of organization, including
consolidation of districts and county service areas; and
WHEREAS, this Board desires to initiate proceedings under the Act for
consolidation of CSA 12 with MWSO and establishing MWSD as the successor
agency; and
WHEREAS, this Board has determined that the proposed consolidation is
categorically exempt from the reqUirements of the California Environmental
Quality Act ("CEQA;" Pub. Res. C. §21000 et seq.) as a consolidation of two or
more districts having identical powers (14 CCR §15320);
2
ResAppnConsolCSA 12rr[renumbered1438)
NOW THEREFORE, be it resolved by the Soard of the Montara Water and
Sanitary District, a public agency in the County of San Mateo, California, as
follows:
1. Findings. The above recitals are incorporated herein by reference as
true statements of fact.
2. Statutory Matters. Pursuant to the provisions of Section 56654 of the
Act, the following matters are stated with regard to the consolidation proposed
hereby:
(a) The proposed consolidation is made pursuant to Part 3 (commencing
with Section 56650), Division 3, of the Act.
(b) The change of organization proposed hereby consists of the
consolidation of CSA 12 with MWSD and establishing MWSD as the successor
agency,
(c) The boundary of CSA 12 is described in Exhibit"A" and shown on the
plat designated Exhibit "A-1", The boundary of MWSO is desc~ibe~i.n Exhibit "8"
and shown on the plat designated "S-1", The boundary of MWSD as the
successor agency established by the consolidation is described in Exhibit "C"
and shown on the plat designated "C_1", Said exhibits and plats are incorporated
herein by reference.
(d) Proposed terms and conditions, if any, shall be included in the
application submitted pursuant to Section 56652 of the Act.
(e) The purpose of the proposed annexation is to conform MWSO's
boundary to the service area acquired by MWSD from the above-mentioned
privately owned water system and to the boundary of CSA 12, thereby providing
continuity of water service throughout the territory of both agencies.
(f) The consolidated territory is inhabited.
(g) MWSD hereby requests that proceedings be taken for the proposed
consolidation pursuant to Part 3 (commencing with Section 56650), Division 3, of
the Act.
(h) The proposed consolidation is consistent with the Sphere of Influence
of MWSD except as to the portion to be added to MWSD's existing territory. The
3
ResAppnConsolCSA 12rr[renumbered 1438]
proposed consolidation is not consistent with the Sphere of Influence of CSA 12,
which Sphere is "0".
(i) MWSD shall be the successor district and shall operate and conduct
itselfunder its principal act. The herein proposal requires the formation of a new
district and shall include a plan for services prepared pursuant to Section 56653
of the Act.
3. Application. The General Manager is hereby authorized and directed
to complete and submit the application prescribed byLAFCO pursuant to Section
56652 of the Act.
COUNTERSIGNED:
Secretary, Montara Water and Sanitary District
4
***
CERTIFICATION
I HEREBY CERTIFY that the foregoing resolution No. 1438 was duly and
regularly passed and adopted by the Board of the Montara Water and Sanitary District,
San Mateo County, California, at a regular meeting thereof on the 6th day of November
2008 by the following vote:
AYES, Directors: Perkovic, Harvey, Slater-Carter, Ptacek, Boyd
NOES, Directors: None.
ABSENT, Directors: None.
5
Exhibit A
(Boundary description of CSA 12 from Board of Supervisors Resolution 50749)
6
ResAppnConsolCSA 12r - Revised 11/07/08
COUN'I'Y S'E RV I CE Aru'::,1\
MON'I'Al:U\ "'. MOSS BEA.CH VI CINI'TY
..::r].\NUARY 1988
Beginning at the intersection of the shoreline of the Pacific

Ocean cHld t11e NQ)::'t!1\ries'c.erly prolongation of the Nort'heast.erly
linr::: of I\anoff A.venue as said Avenue is shown on t.he map ent it:led
"E'a:r.allone City" 'recorded in Volume 6 of Subdivision tJIaps at ?age
:2 01: Scm Mateo County Recordsi' t.hence sout'he·asterly· along said
prolonq(iI.t.ion and said northeasterly line of: Kanoff Avenue to t.he
Northwesterly line of the lands described in the Grant Deed to
t'he Mont,cu:a School District as recorded in Volume 4060 of Offi-
cial Records at Paqe 290 u San Mateo County Recordsr thence along
said line North 44 6 48' East 100 feet and North 28 0 41' East
74.0000 feet. to Ute Nort,:'v~asterly line of so.id lands: t'i:lence along
sa.id 1:i.ne) and it~; prolongation South 61 0 19 1 East. to the North-,·
westerly li ne of ~I'am3.rind Street. as shown on t'hat certain map
-en ti t,1 e~3. "Amended and Supplemental 1'1ap of Monta:r.a" asT.~corded in
Volume ~5 of Subdivision 1'1aps at Page 35 San t-1ateo County
Q
R(:K!Ords ~ t:henc~ No:ctheasterly along said line p the Nort'hv"esterly'

line of Lot 54 as shown on tbe map entitl~d "Half Moon Bay Col-
onv" recorded in Volume D of Stlbdivision 1-1a1"5 at Page 5, San
:~~(Cl.teCi Count.y Pecor-as and the Northwesterly line of Al to. LomaRoad
dE> s'ho\rJ'n on t'~1e map entitled "Second Addition to Hontara" as
record(.~Cl. in Volume 6 of SubcHvis:i.on Maps at Page 28 f San Mateo
Count.y Reco:cds, an.d Southeasterly along t'he Northeasterly line of
;;"1 15 :Coot Ni de path (a 1so 'be ing the Nor the a s t er J.:y boundary of
said map) to the most Easterly corner.' of the lands of Stat,e of
California as recorded in VolUme 6198 of Dfficial Records at Page
S25 e San lVlat:eo County Records~ ~thencea--long the bot.:mdary of said
lands Sout.h 16 0 ~\·9 i 22" 't'vest 69.80 fe~t, South 3° 03' OBIt \'Jest
81 .7'7 '.1: e(~t and. South 24 ° oi i 44" "Jest 394. 56 feet too. point on
the Southwesterly line of Lot 10 Block 6 as shown on last said
lVlap (said point being Nor·th 6S o 58' 16" ;West 55.43 feet from t,'he
Soutll'2:cly corner of. said Lot 10); thence leaving the boundary of
sa.id lands Sout'heasterly along. the Sout.hwesterly line of Lots 10
a.nd 213" in said B.loc;1,p- and its Southeasterly prolongation to 'c.·he
Southeasterly
. It line of Alta Vis~a Road as shown on said mao: X
t:hence c).long said Road SouJc~h"yesterlyu Southeasterly 'and Nort.h,-
easteJ:'ly 'c.,o the Northeast.erly prolongation of the Southeasterly
line 0::: I..oJcs 33 0 340 35 and 36 in Blocl< 3 as shown on said l1lap~
t:henc::E~ Sout:.h.westel~ly along said prolongation and said Southea.st ....
r-~rly lit.\e of sa.ia loots. Southeasterly along the Northeasterly
line of :L.ot 37 in said Bloc'k 0 Southvvesterly along the SouthE~ast,
erly line of Lots 37 and 38 in said Block. and Northwesterly
along- t:he Southwesterly line 01: said Lot. 38 to the line dividinq
Lot~s 39 and 25 in said Block, thence Southwester.ly along said
Llne c Southerly along the line dividingfots 25 and 24 in. said
Bloc'k and its prolongation to ·the Southerly line of Linda Vista
:Road ell::: sho1;>m on said map" thence Wes\:erly along said :Line to t.he
'No:t"'thE:~';iste:rly line of Lot~ 50 in Block 1 as s'hown. on said ma.p,
t:.b.ence i3Jout:heast.(~rly along said line r SOt.:!th1tleste:clYKidB.~q,Qgdt!f\)
A'~ D ;- at ';.1 " L. sJ;
MWSD Resolution 1438

Exhibit A - Page 1 of 4
Sou'theast.ex:-ly line of. Lots 50,51 0 52.53,.54 and ~j:; 'i'" ..... I.t. ,····.1(';1 ....... ~ ...
..::;l(""' '._
Block and N-este:rly along· the Southerly line of :I:..ot ~)6 in said
Bloc'k to t.he SOlJtl).easterly line of Lot. 36 in said l31oc]!~ 1 tJle:nce
Southwest,=,rly along said linp. and Southeaste:rJ.y 0.10)']<;1 t.':·'H":: No:ct:h ..--
easterly line of Drake Street as ~hown on aforesaid map (5/35) to
the.l'iort'heasteY·ly prolongation of. the Southeaster.:ly l:1.ne 02: Enoch
B as shown on said map~ thence Sot:!thweste:rly alonq sedd p:colonS-F"·'··
tion and said Southeasterly line t~o the Southerly co:tne:l. o:f s<-.'d. d
BloCK; thence crossing Edison Street as shown on sa:1.(·1 map. in. ~'1.
straight line to the most Easterly corner of Blo~k A as ;hown on
said map; t.henc~ Southwester ly along the Southeasterly Li, ne 01".
said Block ano Southeasterly along t:H: Northeasterly i:i.n~: of
Franklin Street as shown on said map to the Northwesterly line of
Montara Boulevard East as shown ont.he map ent:i.t:.led "First A.ddi . ·
tion to t-10ntara 01 as recorded in Volume 6 of Subdivi.sion l'-'japs clt
Page 270 San lVla teo County RecDrds~ thence Nort'heas'l:E::rly ctlcm<:J
said line to the \'1esterly line of Coronado Road a.s 13'1:10\;/11 em 1:>cd.iJ
map (now abandoned) : thence Northerly and'lrJest:erly along t.he
\1esterly and Souther.ly line of said Road to t.lls East:",;:rlv linE~ of.
Lot 1 in Block 14 ass"hown on said Illap; t.hence Sou t.he:l: 1y
aJ.onq
said line, Westerlyi' Northerly, Nort.heastex-ly and Sout:hec1.13tc~i.:·ly·
along the boundaries of said Block. to a point on the South-
westerly boundary of the lands'~escribed in a deed from A. R.
vJagner and Cora vJagner to Public Uti 1 it i e$ Cali :tcnnia COrp01"Cl tion
in Volume 415 of Official Records, Page 39B, San Mateo County
Recordsi' thence along the boundaries of said lands Nocc'h 39°" ~:i:?'
West 138 feet mor.e or less, North 46° 26' East 104 feet, South
39 0 52' East 268 feet and South 50° 08' 'itlest 103 ft:::et. t.o 'c'he mos:t
easterly corner of Lot 9 in saicf Block 14 {erroneously ea lIed th{~:
northeasterly corner) I thence crossing said CorofH:H.':!O Road South·,
easter ly a long the prolongation~ of the Northeaster 1y Ii ne of sa id
Lot to t'he NorthHesterly line of Lo't 3 in Block 12 CIS shown on
sa i d map; thence Nor theaster ly and Sou tlv~aste:r l-.y 1:1.101'19 the b01:!r')(~l·
aries of said Let tot!1e Northvve·st.erly line of L.ot. 1:~~ in said
Block 12 ~ t!'1ence Northeasterly, Easterly and SOI.:lthe:cly alon9 l.he
bound3.ries of sa.i.d Block to the Nort11easterly linE') of ?ar-cel~. ::I
and 4 as shown on Volume 8 LoLuS .. Haps at Page 144, Scm Ho.t.eo
County Recordsi' t,hence Sout"heasterly along said line cmd South·..
westerly along the Southeasterly line of said Parcel 4, the
Sou·theasterly lin.es of Lots 69 and 70 as s'hown on s2d,d map (D/.I:'))
and Park Street as shown on the map of "Wienke Addition. to
Montara" as recorded in Volume 6 of Su·bdivis:i.on l'vlaps at. Page :3::)
to the souther ly Ii ne of J'orda.n S t.~--:·ee t. as shovm on sa:\.d lna,p,
thence Westerly along said Southerly line and t'l"!e Sou·\:'hcr.·1.:Y' J.·.l11(:":
of Lot 64 as 'shmm on said map (D/5) to the SoutI1eastl-?y·ly- cox-W..';,'C
of the lands of the State of California as desr~:c:U::)ed irA '1::.h.o\·:. c~::c·
tai~ tax deed, File No. 84072352 0 San Mateo County Records?
t "'lience-
" a 1 ong t1-.le ,\-,
uoun d '
al~l-es 0 f salu
'.-"! 1 an d s \\'Y
!.'Jor t..,...'') ;-~, 0 ....
I! "".;:1 1 L'") ", ' ) " ) "..::.8.
d • .!. " •
S'\:.
0
30 feet more or less g North 81 16 47 West 256.25 feet. North
0 01
28 0 15' 22" Eas't 12.25 feet p North 61 0 44,' 38" We~~·t 2~lu40 feet.
and Soui:h '28 0 15' 22 VI West to the most EasterlY C J:·Y.1e:C of LO'i:: I.U
as shown on aforesaid map (DJ 5) ~ t::tence Northwes tsr<l..y 211on9 tJ'H'::
Northeaster~y line of said Lot 10 and Lots 11 27, 28. 38 and 4!

and Southwesterly along the Northwesterly line of said Lot 43 and
:c,(jt~, 41;l. ClS f,;;hown' on sa id map to t'he most Nort_llE~J~ ly cor'ner of.. Lot.
12 in Bloc'!<: 38 as s'bo\A!n em the map entitled "Farollon Heights" a,~:;
recc.n:'ded in, Volume 6 of subdivision maps at: Page 710 San j'Jiateo
Coun ty n+~co!'ds ~ tl1E;~nce Southeaster ly along the Nor t.hea ster' l~:{ Ii ne!
of said lot. 30 feet more or less. t6 the Sou~heasterly line of
tJle No:ct.'hwestexly one hal:': of said lot.; t1.tence Southwest.erly
along so.:i.Cl line and Northwesterly a.long the Northeasterly line of
J.6t,h St;:1:'eet as shm'Jn on said map to the Northeaster 1y prolonga,'~'
'(j.an o:f. t:'b.e 'No:t'tl'iwes'terly :Line of Lot 4 in Block, 39' as ShO\>111 on
£,aid map~ t::!1ence Sout'n\.,;est.erly along saie prolongat.ion and said
N'ort'h1,1est.erly linE~ of said Lot 4 q Southeasterly alorl9 tn,e 5 00. t.'):l'"
\!v€:ste:clv line of said Lot and 1. 0t5 3# 2 and 1 a.s shown on said
map o.nc;(·Southweste:r:ly along the Southeaste:C'ly line of Lot 5 as
s'hown on f~aid map and' its South''I1€:sterly prolongation to t'he
I:\lo:rt.'h'We~:;:tf'.!rly prolongation of the Northeasterly line of Lo·ts 6
and 7 in 131oc1t,; 26 as s'hown on t.he map t:!nt.i,tled "f.vloss Beach
Heig1it:.s~· <H,_ ~~ecorC!ed in Volume 6 of subdivision maps,:at Page 8,
Garl )~1c1.t,eo County Records ~ thence Southeasterly along said pro'·"
longation r;;lnd t,'be sCl.id Northeasterly line 0): said lots and ,the
Sout:heas't:,~~:rly prolongation of said line to t'he Southeasterly line (
cd: lVi(')r1t:,2.1.na St :ceet, as s'h,o'l,\Tn on said map I t'hence SOL1t'hwes ter 11' (
(
along sa,id line 'to 1:he general 'Nort'heasterly line of Block 25 as ~
shown on said map~ thence along said line in a general Soutll""
east$rly direction. '1:,0 the Northwesterly line of California
Street, t:hence )~~o:ct.heasterly along said line and the N'ori:hwes··
'c.e·rly line of Lot 15 in Block 20 as shown on said mapF South-
easterly i:tlong t':!€: Northeasterly line of said ):"o't 15 and Lots 14 f
13 u 12. 11 and 10 in said Block a,no Nor.·theasterly along the

Northwesterly line of Lots 5, 4, 3 0 2 and 1 of said Block to a
point. on t11.e Sot.:!trLWesterly line- of Lot'-z5 as S'h01l.rCl on said map
(D/S). ,scd.d line also being~ the Sout'hwesterly line o:E the path
(15 feet ",d,ae) as shown on t,1,)8 map entitled "Nonta:ca Heights"
recorded in Volume f3 of subdivision maps at Page 19 of San Mateo
COlJn ty I~'2COrd s ~ t'bence No:r:tllw8s'ter ly along the so. id Sou th\1e s ter ly
line 0:( said Lot 25 and Northea:;;terly along the Northwesterly
line of said Lot 25 and Lot 26 as shown on said map (D/5) to the
most \'Jest.erly COI".ner: of Lot J as shown on said ma.p (8/19) ~ t.:'lence
Sout:heast:erly along the Southwes)cerly line of said Lo·t to the
Nort'heaster ly prolongation of the cen ter Ii ne of Lorna: Vi s to. St.reet.
ciS s'hO'lrvn on said l!i3.p; t:h,ence Southwes'cerly along said prolongati,on
and said c~enterline to the said Southwesterly line of Lot 25; t'hence
~:;out.l';ec\S'l:.eX."ly along said line to the most. Nort.herly corner: of Lot. 14
a.s shown on aforesaid Xilap (D/5) ~ thence Southeasterly along the
No:r::'''t:hecu:;t.ex'ly line and Southwesterly along the Southeasterly line of
said lot.." Sou,thwesterly along the Northwesterly line and Sout.h,·,
east.erly along the Southwesterly line of Lot 6as shown on said mo.}:}
ano SOL'!1:.hwesterly along t.he Southeasterly. linf.~ of Lot 5 as ShOHH on
sa:id mctp to t.he Nor theast:erly Ii ne of Btl"}.€: Ido:ce Street~ (former' Iy
l3a'lb()c~ Boulevard) as shown 011 ,the xnap of "Resubdivision offvla.r-:in(~ Vi(
'l'e:i':'J:etce ':t':ract" as :recorded in yolume 5 of Subdivision lViaps at. Page ::l~
San t\11ateo County Records~ thence Southeasterly along said l:i,1'1E, a.nd t'l
Nm:."tllea.sterly line of Cabrillo High,way (Stat.e RO}lt,1"RG~,)1r£)~{-~tl1e '
fA\(9) r )1 • ,q!, \ J
I~\r ~~ b ~Q "
Sb\\Nl !m[tWH) r;OUfHY lm~~tt

MWSD Resolution 1438 AGt~C\f IFO~l~~i\1 ;GN G{J~lMESSRm~
..-3 ,~.
Exhibit A - Page 3 of 4 COUNTY t10VHtNWlENl Cf.J~11~
IJUItHf1:100 [)J (; nv, C-fib 9&}06~i
rEt{ ~~ ij 18 ~ 1 IL,,=,,:..~". ~14Gt,,~~,,~~.•
=<c == (W .""§:.~.""'.
N~rtheasterly prolonga~ion of the NorthwesterlY' line of the land~
formerly belonging to Deane & Deane, Inc., as described in the Grant
Deed recorded .in Volume 5727 of Official Records at Page 441. San
Mateo County Recordsr thence Southwesterly along said prolongation ani
salu '..:11
\\'1 "h ltJes\..er.
L'IOre '-·1 y 'j;; C' .... ·h
_ ... 1'1e.. oou't 1,>-0
;.;) ..?Il":l" U OC)" Y.·{ •
.ves'c eCI ·c..,lE-~ Y'
I.' ,.'1,. ,,". 'j
..::.asl:.er._Y' ",
11.l"!(±: u
Capistrano Road. It'hence Southerly along said line t.o the ~;;O'L1t.11,~cu5t.ex::L'
1i ne of said lands.. ther.lce crossing sa i d Capistnui.() r.~o;:J.d in c:i, strcd. ~th·
line to t.he NOY'thE!aster1y corner of Lot 1 in Block 14 as ~1.1.(nvn em th,(i';
map of uPrinceton By The Sea" as recorded in. Voluxn€:! 0.) of SLli:)C1j.\J":l.f.~::. on
lilJaps at Page 3:2 p ~'ar!. lYJa teo County Records.. t'hence i~!(H:'i:.hvves te~~ ly r:ll:'H~J.
South\rJester'ly along t'he boundaries of saie! map t.o tlv~ Southwest.e:clv
line thereof~ 't,hence Southeasterl'y along said IhH:: and. :Lb;; Py.ol<)n."'··
gation to the _hore of the Pacific Ocean: thence along the said shore
Squthwest~rly p Souther lyo Wes terlyv Nort111ivesterly and. N·ol~the(-J.ste:ely
( around ..'t"' e
~l 11 ar '1">'
"Olfl'tt..) . an d con tlnU'lng'" ln a qenens._.,1 N'
... 0:('1:,. '1'Le)~ ,.y
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alongt'!:l.e shore of the Paci:Hc Ocean to t.he Pcd.nt cd: F\e~~jirming¥
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3-88 -·3 --
D-28/Kanoff - Rev. 3/21/88
151 (24)
Exhibit A-1
(Map of CSA 12 from Board of Supervisors Resolution 50749)
7
ResAppnConsolCSA 12r - Revised 11/07/08
·S1' A l (
MONTARA POINT
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SCALE 1".800'
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OOCUlU .. MflUS YO t.ULtR't Htt.onl.X!n'c,
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PROPOSED C:OUNTY SERVICE. ARE,t.
\\IlONTAR!~. _. MOSS BE ACH V1C1N·\Y-Y-----
MARCH
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RECORDER'S MEMO:
POOH HE.CORD \S DUE 10
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\UAUn Of ORIGINAL
Exhibit B
(Boundary description of MWSD from Board of Supervisors Resolution 12987)
8
ResAppnConsolCSA12r- Revised 11/07/08
:';;~iF
DESG1UPTION OF paoPOsED
<f".I"".~; ••"1"=,,,",..':~~..,zr.I~~·4>~~
,"? ;.~;i{<:·i'
tIHON1'[lli,A SAlUTARY, n:r.S"f.'RIGTH

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~\:'I
e:;·:GJ.N}UjlG V:I;, un nngle po:Lnt :til 'the i:feat :yo boundary 01' t.he Granada.
f.:i£tnJ:i~B.T:l Dln td.ct formed bjr H.osolutiOrr No(, 127l .. ,adopt,C!;!d by the Board of .
Sl\pc'lX'·,il.flO)'5 of SaXl i1~:ttO() CO\U1t.y em ~~r:ch lap J.95a~. aa.1d point of boginning
n1flo ho:Lug th~l most~ ,sllar,ar]..,\'· conwr ot\tho S" n owell 63B a.are tra.ct,. a.o
Bh(Mi'l o:nt})o ItOU':.i.c:l.al Map or Ban l~t.cp Cotm"r.yltp opyright 1950Z thoooo from
J3airj PQ~.nt of bf.l~l.:(u-J.:Lng alonB t~he aast;arl,r bounaiir,y of said 638 acre tract)) ann
ml1.d hotmde.Y.';I" of: Gl"n:CHlda Slln~l.tar.Y' Dif3~1?ct9south~e8terlJr51 'W'e/3terlYIl and 6outh=
\·r~.H1t.(Jd,.\, to D. po:l.nt, :i.n th~1 110r.i·,h0aatd~lJf Una of'!i,~t.he. Sta.te H5.ghwnyp Route 56!,
(COIl:B'i. fI:l.gln·w.y) ml sho\'iD. on mdd 1I0rf1ciiaJ. CountY';;.~Maplt ~ thence continm.ng alon.g
~:HJ5_d ::ki1it/r.u~· D533t.t':l.ci; boundar'Y'!> 6out.h'!1ff.lllte:rl~ •. '. 'e. d1:t'ect Una to the moot.
(:l.\u.:ter.-J.;:r (:o:cner oJ,"!,ha"i; ce)'i~I.l.:t);l ·t~. . a.o~S~}t' land by·vidoa. by Map of "Fr.e.ncif3co
Jio:i.ght.n ll • :\'eeordo(l 1.. 1:1 Beok 6 o;f.' HC),pfmp,1.iPagee. ;;;~.tmd6;J San M..t:tteo County R€loorclf.l~
thonce cnnt:trm:Lng DJ.(mg Stl1.1:1.1~f.l.r-y Dist~;l.ctbound~· aouth\!Emtel"ly a.long t.he south"",
c1?Hterly bOlm.dary oJ: t.he landsubc:ti.rldod 'OY aa:t4!.,ma.p and corrc.intd.ng southwesterly
nlr..ml~ i~lw last, menl~:i.onoclbmm.d<J.r.Y' to1.the nhara o~.tha Pacific Ocean; t.nenCl:l
:1.E)o.v:tng tho bonndnT',;If of I3l.11.d Gj?arta.da'?8llnj.taryn1~~rictb inn ganeral. nOr'thwest.er.:~y
D.n.r:J. l.'.!.o):'thOJ.·J.y· direction along the ahore linaQr;:;S~id Pacifio Ooean to the inten;"",
fiOct.:I.on Qf fmlc1 shore :lJ.. n.a1·d.th the northl.reBter~ line of: J.IOt. 5, as /laid lot. j.6
r:;hONl'l on. ~~h:.l'l~ Gert.H:!..n ln9.p ent:t'l:.led p ~.!H)\P OF' THE~SOUTHERL1'RECMN TR/\CT ON SAN
pgmW H.h;;CIlO"r x'ecClrocd :.l.n Vt11ume19'o!' X-!a.pa,l> aKpnge 16» 8nn Mnteo COt1.ntyRe=
c: or dc.; , ';J:~~nc(;) not':,hea.aterly along aai~ line of. ~t, 5 t.t.) the interaect..iot'). 't.hw.eo:f.
1:r:i.th "i;,h0 e!."1tf:!X· l:l.ne of thp,; Ole< COllet. lt1.ghtrro.yp ldi.ol1n a.s County Road No, 1: 0::"
Pedro Ji;ourri;,a:i.n ROB-d.;! nO'll o.bandc·n(3d p au fwld :road'; is shown on eoid Orric:tal ~iji:lP
,-,,f ~.><:'n 1,!;;.tGO COtmt;l"i~ t~henc('l 1.n 1], e;cnarl'.l 6outhaaGter~ direct-ton along t,he Gen:t~c~~
line oj' r:;;,d.d l.~()ad. to tho lnt.c:""Hection i,hereof "1:1.th the 1-1.n6 d:1.viding lot,s 16 and
1'7, (W [w:Ld lot~l al'{:l nho ..m on thn.t ceriia:tn rnnpeh.titled~ "PlIRT OF THE SIIN PEDR.O
FU.JIGHO FUftr-LTNG THE !·l.f.iHONE:'i J.Nl'ER~'STII.!I "l:,ecorded Juno 25,,' 1.8791> in Volume flAil of'
H3.p~l I:).t• .Pi~gC 5(\~ San Hat.on COllnt.v Recot"dG~ t.hence sou.'"he.,asterly alor~g the line
batMeen ::ia·l.d 1..0'1;.13 :1.6 and. 17 ~;o the aout.heastarly,:liue of the ].{c!ntosh e:t aL I>
.3h3.93 ael:'O t.):·HC'l~ (),t' J.unrlns oho',mon said Or£:1.~ia.lMD·Pll thence. l1ortheaat.erl.y
.... long f'iH.id sou.th<-t;:l.r.iJ~eJ'J...Y' :U.11.C to ·~ha'ifltaraect:f.c?n the:roof with the cne~··quarte:r.'
S0(;i:,tOXl 1:i.n8 X'ttnl:1:i.r..tg eU61:. and tlTGnt. through thEl·~pal..t1a1 Section 23, T4S, a6rl,)
i'i( 1)" 13. t~ H,,; t.h(Hl'tC eatltorly along')3uid one...qt¥trter 5&ctionline to the nod;h~·
\'/(;~Ht em'no;:' 0; i~hG f}outhea.st. on!.'), .quartor of. aa~~~{5ecM.on 23~ thence sOl,.t.h alo11g
1:.11::: ,votrt. :U.ne of ~Hl1.d on.er..quD.'l:'tel' GEl<:.t1.on. to t~~fsout,l·l1.'le~Jt corner therElo.f;
thenc{~ OuG't o.long '/;he Houth line ofaaid Sectici~)23 tc t.he northea.st corneX' of
pp.. r-t:lul ;:;eci',:\.on 26 in Bcd..c1 'ro\mab:tp findH.nnge~ ,;~thence ac·uth along the f-~1l5t J...:i.no
~)fn,i:i.<1 ':loct1.ol:l. 26 to 1;.h6 north linltl"of the n.nn~ho Cor~·al. de Tierra (paJ_o }>t-,u"l!ls) 1\
sn:i.d north lim:l beJ.llg tlH~ northe~l.vJ.il1e of. th~),;li:C8.rlo TOrelliu at. at" ft 2ll1 .. 30
tWX'E: !:,:,'U c't. 01.' 10.11<1 8.13 91'\ 0;'111 on ~midO.f1·:tc1.a.l I'lt{P~ thence ~ze3t ulong iSo.id northerly
Jj,);'le t.o t!ho no~othM(,)atorly corne-r ofsald 2111030 acre t1"8.ot; t,hcnce in a general
B(n:ri~hl1(::I,l!['(:I'l'y d:tre(;t,ion p e.J.ong the \'fetitorly li,no o.f enid 21:1.1,,30 aOr'e t, ra ct. '[;0
t.he sm.lUn,',:wterly corrwr t.hereof p said 130ll't,h"laa~er~ corM).'" being in '~he b01mallry
of th,,: S., B., Cmrell 638 acre ·tx-actp &),s eho,."n orr'Jaid O.f."tj.cial l:4flP; thooce
ellf.>'i~orl~r nlong thG :t:.tne he:liwee.m. ~~niC!211l".:30 Ilcl"a tr-act. and am.d 63(;; aoX'e t,ra.c'(,
,',0 t.h0 po:;.nt.. e'er. b$glt111~li'lg",

Exhibit B - Page 1 of 1
Exhibit B-1
(Map of MWSD from Board of Supervisors Resolution 13165)
9
ResAppnConsolCSA 12r - Revised 11/07108
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FC':t''IIl.ed by llElsolut.ion No" 1316;5 p adopted AntSy 5»195
Exhibit 8-1 - Page 1 of 1 b;r the 130ard of Supervisoy's!) County of San Nut-coo
Exhibit C
(Boundary description of consolidated MWSD to be provided upon approval)
10
ResAppnConsolCSA 12r - Revised 11/07108
Exhibit C-1
(Map of consolidated MWSD and amended Sphere of Influence)
11
ResAppnConsolCSA12r- Revised 11/07/08
Exhibit C-1 - Page'1 of 1
l\1l.ap oft' BOUllRllldlarry of cl{)JIllsonnd~lnhed IVlIoJlutan VVaien-' allJl1l(l! §;mnltary JD)n§\tll"nd

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SAN MATEO COUNTY GENERAL PLAN
WATER SUPPLIERS
,. . ..1-
sAN-··· I
FFW\.'ClSCO !
-- BOUNDARY OF WATER SUPPLIERS
BAY
.- - - --
SANl'A CLABA
COUNTY
PACIFIC
OCEAN
·F SANTA CRUZ
COUNTY
LAW OFFICES OF
DAVID E. SCHRICKER
TELEPHONE (408) 517-9923

FAX (408) 252-5906
E-MAIL: dschricker@Schrickerlaw.com
Via mail, e-mail and facsimile ([650] 363-4849)
October 25, 2010
Honorable Chair and Commission Members

County of San Mateo
Re: Big Wave Well ness Center and Office Park ("Project") - Proposed
Certification of Final Environmental Impact Report ("FEIR")
Dear Chair Bomberger and Commission Members:
This letter preliminarily responds to the Notice of Availability of the above-

referenced FEIR on behalf of the Montara Water and Sanitary District ("MWSD").
Initially, I must underscore the need for an extended comment period as
requested in the letter dated October 18, 2010 to Camille Leung, Project
Planner, from Clemens Heldmaier, MWSD's General Manager. Aside from the
voluminous bulk of the FEIR, including the Comment Letters and Responses
thereto, the proposed revisions to the Project and its complexity in relation to
environmental and regulatory concerns demand further detailed analysis and
correction, all of which necessarily require additional time for comment beyond
the 12 days referenced in the Notice. Likewise, and in consideration of the
foregoing, the comments contained in this letter must be viewed as preliminary,
made without prejudice to additional comments and without waiving objection to
deficiencies in the FEI R and proposed conditions of approval that may not have
been stated in this letter.
A fundamental flaw in the FEIR, carried forward from the Draft

Environmental Impact Report ("DEIRn) is the failure of the Project proponent and
the County, as sponsor of the DEIR and FEIR, to acknowledge MWSD as the
water utility service provider for the Project and, correspondingly, its status as a
Responsible Agency under the California Environmental Quality Act CEQA"; r
Pub. Res. C §21000 et seq.).1 From that omission flow fatal deficiencies in the
FEIR regarding its failure to consider alternative water sources, failure of the
1 This omission has been brought to the County's attention repeatedly. Please refer to my letters
dated December 4, 2009 and February 19, 2010 to Ms. Camille Leung, enclosed herewith.
Han. Chair and Planning Commissioners
October 25, 2010
Page 2
Project to comply with the Local Coastal Program ("LCP") and the County's
General Plan, among other regulatory requirements.
The purported responses to MWSD's comments regarding MWSD's

status as a Responsible Agency under CEQA and its right and duty to provide
service for the Project are factually and legally incorrect. As the legal basis for
purporting to reject MWSD as the water service provider for the Project and its
exclusion from MWSD's service area, the FEIR relies upon Code of Civil
Procedure Section 1235.170 (Response to Comment 231-2).2 The property that
MWSD acquired through the initiation of eminent domain proceedings consisted
of the on-going business enterprise of the Montara Division of California
American Water Company (IiCaIAm"), which had acquired all of the assets of
Citizens Utilities Company California ("CUCC"), including its service area
established by the California Public Utilities Commission. 3
It is well settled that a public agency may acquire a privately-owned water

system as an on-going business enterprise, including that portion that lies
outside the boundaries of the acquiring agency (City of North Sacramento v.
nd
Citizens Utilities Company of California [1961] 192 Cal. App. 2 482; 13 Cal
Rptr. 538). That a water utility's service area is an identifiable and purchasable
property interest is clearly established by case law (City of San Jose v. Great
rd
Oaks Water Co. (1987) 192 Cal. App. 3 1005; 237 Cal. Rptr. 845). Aside from
being contrary to the law, the foregoing FEIR Response is specious because a
utility system without the territorial ability to provide service to its customers,
present and future, would be valueless.
Instead of analyzing MWSD's capability of providing water service to the

Project as an appropriate alternative to the proposed on-site source, the FEIR
sets forth arguments without analysis in avoidance of MWSD's service based
upon the erroneous conclusion that MWSD is not a Responsible Agency under
CEQA (Response to Comment 231-3). Rather than analyzing MWSD's capability
as an alternative water supplier, the FEIR indulges in a circular argument
commencing with the conclusion that MWSD is not a Responsible Agency and
then asserting that therefore it should not be the supplier (id.).·
The FEIR avoids analysis by relying upon the Local Agency Formation
Commission's ("LAFCo.") Sphere of Influence designation for CCWD
(Responses to Comments 231-2,231-5,231-6,231-7,231-8,31-9,231-10).
However, a Sphere of Influence is merely an indication of an agency's future
boundary as determined by LAFCo at a given moment in time (Gov. C. §56076).
It is subject to change to reflect changes in the provision of an agency's services.
2 That section defines property for eminent domain purposes as follows: '"Property' includes real
and personal property and any interest therein." (emphasis added).
3 Enclosed herewith, please find copy of CalAm's (formerly CUCC's) service area included as an
exhibit to the acquisition documents.
October 25, 2010
Page 3 .
Here, just such a change has occurred by virtue of MWSO's acquisition of

the CUCC/CalAm service area coupled with MWSO's updated Water Master
Plan that demonstrates MWSO's capability of providing service within its
acquired extraterritorial service area, including the Project. 4 Moreover, MWSO
currently provides service to that portion of the acquired service area through its
service to the Half Moon Bay Airport and to the Pillar Ridge Manufactured Home
Community in close proximity to the Project area, thereby demonstrating its
s
capability of expanding service to the Project. The FEIR simply ignores those
salient facts thereby avoiding analysis of MWSO's role as a Responsible Agency
under CEQA and as an alternative source of water service to that proposed by
the Project proponent. Such an analysis is required under CEQA (Napa Citizens
for Honest Government v. Napa County Board of Supervisors [2001] 91 Cal.
App. 4th 342, 373; 110 Cal. Rptr. 2nd 579).
The FEIR also avoids analysis of CCWD's capability or lack thereof for
providing service to the Project, notwithstanding that it nominates CCWO as
somewhat of a back-up service provider. In that regard, the County General Plan
notes that, for CCWO, demand exceeds supply (General Plan, Table 10.4).6 By
focusing on and inadequately analyzing the Project's proposed on-site source of
water, the FEIR has omitted analysis of exclusive water service provided by
existing public agencies. In so doing, it purports to exalt an essentially untried
private system over viable existing public systems.
By the same token, the County General Plan includes, through the
designation of CUCC's service area (now MWSD's) that MWSO, as the
successor to CUCC, is the service provider for the area encompassed by the
Project. 7 Likewise, LCP Policy 1.3 defines urban areas, such as that within which
the Project is located, to include lands that are suitable for development
because, among other requirements, they are served by public utilities. Here,
utility service inexplicably would be limited to a private utility. The FEIR fails to
analyze the Project in relation to its inconsistencies with the General Plan and
the LCP. That omission violates the mandates of CEQA.
4 Enclosed herewith please find copy of MWSD Resolution No. 1438, initiating proceedings for
consolidation of County Service Area C1CSA") 12 with Montara Water and Sanitary District. As
stated in the recitals of the resolution, CSA 12's boundaries conform to the former service area of
CUCC/CaIAm. The consolidation will provide for inclusion of the entire service area within the
corporate boundaries of MWSD. A change in the Sphere of Influence may occur concurrently with
the reorganization effectuated by the consolidation. As noted, the Project lies with in that area. By
adoption of a separate resolution, MWSD has also initiated proceedings for annexation of the
extraterritorial area.
S By avoiding meaningful contact with MWSD, the Project proponent and preparer of the
DEIRIFEIR has precluded informed factual analysis of MWSD's role as the water service provider
and, hence, the determination that MWSD is a Responsible Agency under CEQA.
6 While that Table apparently predates more recent improvements to CCWD's water system,
current information suggests that it is not out of date.
7 Please refer to General Plan designation of Water Suppliers, enclosed herewith.
October 25, 2010
Page 4
In short, for sewage and water utilities, the Project proponent would
establish a private utility fiefdom. That is contrary to public policy, good planning
concepts, existing planning regulations (the LCP and the County General Plan)
and correspondingly, the public health, welfare and safety.
The County's planning staff has recommended, as a condition of approval

of the Project, that the Project applicant actively pursue a water connection from
CCWD for the potable water and fire suppression needs of the Project (General
Project Condition 9). That recommendation is not supported by the FEIR which,
as discussed above, is fatally deficient under CEQA for failure to analyze
alternative water sources and sufficiently to examine the frailties of the proposed
on-site water system. Indeed, the latter represents a curious and undisclosed
rejection of public systems. With regard to MWSD, the FEIR fails in any manner
whatsoeverto discuss any alleged inability of MWSD to provide service to the
Project, which is located within MWSD's service area. The FEIRls silence on that
subject follows from the fact that there are no grounds to support such an
allegation.
MWSD respectfully urges your Honorable Commission to deny

certification of the FEIR and deny approval of the Project and accompanying
applications for permits. In conjunction therewith, and if the applicant desires to
pursue the Project further, MWSD respectfully recommends that the applicant be
directed to provide a thorough analysis and examination of provision of water
and sewerage service solely by public agencies in accordance with existing land-
use regulations and generally accepted concepts of public policies in furtherance
of the public health, welfare and safety.
DES:hs
Encl.

David J. Byers, Atty. (via facsimile: [650] 697 - 4895)
LA W OFFICES OF
DAVID E. SCHRICKER
TELEPHONE (408) 517-9923

FAX (408) 252-5906
December 4, 2009

County of San Mateo
Impact Report ("DEIR")
Dear Ms. Leung:
This letter is a preliminary comment on behalf of the Montara Water and

Sanitary District ("MWSD") responding to the Notice of Availability for the subject
DEIR regarding its coverage of water utility services and systems (DEIR, pp.
IV.N 21 et seq.; page references commencing with "IV.N" hereinafter are to the
DEIR). MWSD exercises water powers pursuant to the County Water District
Law (Wat. C. §30000, et seq.; H. & S. C. §6512.7). For the reasons discussed
below, MWSD is a Responsible Agency (as that term is defined in the California
Environmental Quality Act ["CEQA," Pub. Res. C. §21000 et seq.) for the Project
and should be so listed in the DEIR. Aside from that omission, as also discussed
below, the DEI R's coverage of water service and systems is deficient for failure
adequately to discuss alternative water supplies and service and long-term
effects of the Project on community water supplies.
The Project is located within the water service area established by the
California Public Utilities Commission ("CPUC") for Citizens' Utility Company of
California ("CUCC"). That company was acquired by California American Water
Company ("CaIAm") and in 2003 MWSD acquired the water system from CaiAm.
MWSD thereby succeeded to the property interests of CUCC and CalAm,
including the service area (City of San Jose v. Great Oaks Water Co. (1987) 192
Cal App 3d 1005; 237 Cal Rptr 845).' Under MWSD's regulations, property
capable of being served by its system must connect to it (MWSD C. §5-3.103).2
1 Although the Project is outside MWSD's corporate boundaries, MWSD is authorized to provide
extraterritorial service (Wat. C. §31023).
2 MWSD's projections for improvement and development of its water system coincide with the
probable timeline for actual development of the Project. Therefore, the moratorium on new
connections initially established by the CPUC while the system was owned by CUCC and
necessarily continued by MWSD would not be a barrier to MWSD's service to the Project.
December 4, 2009
Page 2
Accordingly, MWSD is a Responsible Agency under CEQA for the Project (Pub.
Res. C. §21069). The DEIR neglects to identify MWSD as such and therefore is
deficient in that regard.
A corresponding defect of the DEIR is its failure to identify MWSD as an

alternative source of water service. Analysis under CEQA requires discussion of
alternative water sources (Napa Citizens for Honest Government v. Napa County
Board of Supervisors (2001) 91 Cal. App. 4th 342, 373; 110 Cal. Rptr. 2 nd 579;
see, also Laurel Heights Imrrovement Ass'n. v. Regents of the University of
California [1988], 47 Cal. 3~ 376; 253 Cal.Rptr. 426, 764 P.2d 278).
Indeed, the DEIR omits discussion of any alternative source of water and
purports to establish an on site well as the sole source (IV.N-36-37; IV.H-42).
Moreover, in relying on purported overlying water rights to serve the
development, the DEIR fails to discuss the long-term effects of drawing on
underground water resources, including the effects on property served, or to be
served, by the same aquifer, with the exception of adjacent agricultural land
(IV.N-33).3 Such effects must be analyzed under CEQA (Yineyard Area Citizens
for Responsible Growth. Inc. v. City of Rancho Cordova (2007) 40 Cal. 4th 4121;
rd
53 Cal. Rptr. 3re 821, 150 P. 3 709). Specifically, expanded tapping and
extraction of underground water sup'plies must be analyzed in an EIR (County of
Inyo v. YQlli (1973) 32 Cal. App. 3rd 795; 108 Cal. Rptr. 377).
In sum, the DEIR is Significantly deficient in analyzing the water resource

impacts of the Project in an area served by fragile groundwater supplies. That
deficiency must be addressed by including, among the issues mentioned above,
the water resource impacts of the Project vis-a-vis the absence of a ground
water management plan for the midcoast region within which the Project is
located.
Very truly yours,
lsI

3 Inexplicably, the DEIR includes no discussion of alternative sources for the agricultural property,
the water supply of which would be depleted by 80% in drought years by the Project's water
consumption (IV.N-33). . '"
LAW OFFICES OF
DAVID E. SCHRICKER
TELEPHONE (408) 517-9923

FAX (408) 252-5906
E-MAIL: dschricker@Schrickerlaw.com
February 19, 2010

County of San Mateo
Impact Report ("DEIR") Planning Commission Study Session
Dear Ms. Leung:
This letter refers to your Staff Report ("Report") dated January 27, 2010
(Subject: Study Session Background Report Regarding the Big Wave Office Park
and Wellness Center Project and Draft Environmental Impact Report (DEIR». I
understand that the Report was presented to and discussed by the County
Planning Commission on that date.
Our office commented on the DEIR on behalf of the Montara Water and
Sanitary District ("MWSD"), a "Responsible Agency" for the project under the
California Environmental Quality Act ("CEQA," Pub. Res. C. §21000 et seq.) with
regard to serious deficiencies of the DEIR's Hydrology & Water Quality and
Utilities & Service Systems sections (DEIR §§ IV.H. and IV.N., respectively).1 As
discussed below, the Report perpetuates gross omissions in the DEIR, which
renders the DEIR legally inadequate under CEQA.
In response to the Planning Commission's question, " ... who is a

Responsible Agency per CEQA and who is not?" (Report, p. 7), the Report
purports to identify Coastside County Water District ("CCWD") as the secondary
provider of domestic water and the primary provider of emergency and fire flow
water (id., pp. 7-8).2 However, as stated in our letter dated December 4,2009,
MWSD is the Responsible Agency for water service because the project is
located within MWSD's service area and MWSD fully intends to serve the
project. Simply put, CCWD has no jurisdictional authority to serve the project and
to suggest otherwise is clearly erroneous and misleading.
1Please refer to copy of letter dated December 4,2009, enclosed herewith.

2An on site well is identified as the primary domestic water source, corresponding to the DEIR's
description (Report, pp. 7-8).
February 19, 2010
Page 2
With regard to MWSD's authority, MWSD exercises its water powers

under the County Water District Law 0/'Iat. C. §30000 et seq.; H. & S. C.
§6S12.7). It has enacted water service regulations pursuant to its statutory
authority (Wat. C. §31024). Those regulations include mandatory connection to
its system for properties located within its service area (MWSD C. §5-3.103).
MWSD exercises its community water powers in furtherance of State policy
protecting municipal water rights" ... to the fullest extent necessary for existing
and future uses, ... subject to the rights of the municipality to apply such water to
municipal uses as and when necessity therefor exists." (Wat. C. §106.5).
Succinctly stated, at such time as the proposed project is ready to develop, it
shall be mandated to connect to MWSD's water system. 3
While the DEIR purports to describe water utility service at odds with
MWSD's service area and authority by omitting any reference to MWSD, it is
incumbent upon the County, in carrying out its Lead Agency duties under CEQA,
candidly to identify MWSD's Responsible Agency status, particularly in light of
the fact that that omission, among other deficiencies of the DEIR, has been
brought to the County's attention. Kindly ensure that a copy of this letter is
included in the administrative record of the CEQA proceedings for the project.
Very truly yours,
lsI
DES:hs
Encl.

3As noted in my letter dated December 4, 2009 (fn. 2), MWSD's projections for improvement and
development of its water system coincide with the probable timeline of the Big Wave development
so as to be capable of serving the latter.
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SCAU!IHFI!I!T
MONTARA
e
Resolution No. 1438
RESOLUTION OF APPLICATION TO THE LOCAL AGENCY FORMATION

COMMISSION OF SAN MATEO COUNTY, CALIFORNIA, INITIATING
PROCEEDINGS FOR CONSOLIDATION OF COUNTY SERVICE AREA 12
WITH THE MONTARA WATER AND SANITARY DISTRICT AND
ESTABLISHING SAID DISTRICT AS SUCCESSOR AGENCY
(Montara Water and Sanitary District)
WHEREAS, pursuant to Resolution No. 50749 entitled, "Resolution

Establishing San Mateo County Service Area No. 12 (Montara-Moss Beach) for
the Water Services and Establishing the Affected Area," adopted August 30,
1988 by the Board of Supervisors, County of San Mateo, County Service Area
No. 12 ("CSA 12") was established; and
WHEREAS, CSA 12 was established to provide water service, including
the acquisition, construction, operation, replacement, maintenance and repair of
water supply and distribution systems, including land, easements and rights of
way and water rights; and
WHEREAS, CSA 12 was established in anticipation of acquiring the water
system then owned by Citizens' Utilities Company of California ("CUCC") serving
residents of the Montara-Moss Beach unincorporated communities in San Mateo
County; and
WHEREAS, CSA 12's boundaries conform to the service area of CUCC
established by the California Public Utilities Commission; and
WHEREAS, CSA 12 did not proceed to acquire CUCC's water system as
originally anticipated; and
WHEREAS, as of August 1, 2003, the Montara Water and Sanitary District
("MWSD") acquired the assets of the aforesaid water system from CUCC's
successor in interest, California American Water Co., including the service area
thereof; and
WHEREAS, MWSD is operating the water system in all respects and has
exclusive ownership and control of, and authority over, said system; and
1
ResAppnConsolCSA 12rr[renumbered1438]
WHEREAS, a portion of the service area acquired by MWSD currently lies
adjacent to and outside of MWSD's southerly boundary; and
WHEREAS, the boundary of CSA 12 includes the aforementioned portion
of the service area acquired by MWSD; and
WHEREAS, in conjunction with the formation of CSA 12, the San Mateo
County Local Agency Formation Commission determined that the boundary of
CSA 12 shall include the entire area served by CUCC; and
WHEREAS, MWSD has fulfilled and is fulfilling the purposes of CSA 12;
and
WHEREAS, in order to carry out the intent evidenced by the formation of
CSA 12 that the water service area for the Montara-Moss Beach communities
shall be identical to the former service area of CUCC and to provide that
MWSD's boundary shall include that area, it is appropriate to consolidate CSA 12
and MWSD with MWSD established as the successor agency so as to include
the aforesaid portion of the CSA 12 territory currently lying outside of MWSD's
boundary; and
WHEREAS, the Local Agency Formation Commission of the County of
San Mateo, California ("LAFCO") exercises the authority granted such
commissions under the Cortese-Knox-Hertzberg Local Government
Reorganization Act of 2000 (Title 5, Division 3 [commencing with §56000] of the
Government Code [the "Act"]) for changes of organization, including
consolidation of districts and county service areas; and
WHEREAS, this Board desires to initiate proceedings under the Act for
agency; and
WHEREAS, this Board has determined that the proposed consolidation is
categorically exempt from the requirements of the California Environmental
Quality Act ("CEQA;" Pub. Res. C. §21000 et seq.) as a consolidation of two or
more districts having identical powers (14 CCR § 15320);
2
ResAppnConsolCSA12rr(renumbered 1438]
NOW THEREFORE, be it resolved by the Board of the Montara Water and
Sanitary District, a public agency in the County of San Mateo, California, as
follows:
1. Findings. The above recitals are incorporated herein by reference as
true statements of fact.
2. Statutory Matters. Pursuant to the provisions of Section 56654 of the
Act, the following matters are stated with regard to the consolidation proposed
hereby:
(a) The proposed consolidation is made pursuant to Part 3 (commencing
with Section 56650), Division 3, of the Act.
(b) The change of organization proposed hereby consists of the
agency.
(c) The boundary of CSA 12 is described in Exhibit uA" and shown on the
plat designated Exhibit "A-1". The boundary of MWSD is described in Exhibit "B"
and shown on the plat designated "B-1". The boundary of MWSD as the
successor agency established by the consolidation is described in Exhibit "c"
and shown on the plat designated "C-1". Said exhibits and plats are incorporated
herein by reference.
(d) Proposed terms and conditions, if any, shall be included in the
application submitted pursuant to Section 56652 of the Act.
(e) The purpose of the proposed annexation is to conform MWSD's
boundary to the service area acquired by MWSD from the above-mentioned
privately owned water system and to the boundary of CSA 12, thereby providing
continuity of water service throughout the territory of both agencies.
(f) The consolidated territory is inhabited.
(g) MWSD hereby requests that proceedings be taken for the proposed
consolidation pursuant to Part 3 (commencing with Section 56650), Division 3, of
the Act.
(h) The proposed consolidation is consistent with the Sphere of Influence
of MWSD except as to the portion to be added to MWSD's existing territory. The
3
ResAppnConsolCSA 12rr[renumbered1438]
proposed consolidation is not consistent with the Sphere of Influence of CSA 12,
which Sphere is "0".
(i) MWSD shall be the successor district and shall operate and conduct
itself under its principal act. The herein proposal requires the formation of a new
district and shall include a plan for services prepared pursuant to Section 56653
of the Act.
3. Application. The General Manager is hereby authorized and directed
to complete and submit the application prescribed by LAFCO pursuant to Section
56652 of the Act.
COUNTERSIGNED:
~~j
Secretary, Montara ater an dS ani"tary O't't
IS riC
4
***
CERTIFICATION
I HEREBY CERTIFY that the foregoing resolution No. 1438 was duly and
regularly passed and adopted by the Board of the Montara Water and Sanitary District,
San Mateo County, California, at a regular meeting thereof on the 6 th day of November
2008 by the following vote:
AYES, Directors: Perkovic, Harvey, Slater-Carter, Ptacek, Boyd
NOES, Directors: None.
ABSENT, Directors: None.
at and Sanitary District
5
ResAppnConsolCSA12rr[renumbered 14381
Exhibit A
(Boundary description of CSA 12 from Board of Supervisors Resolution 50749)
6
ResAppnConsolCSA12r - Revised 11/07/08
COUNTY SERVICE A~~
MONTARA - MOSS BEACH VICINITY
JANUARY 1988
Beginning at t~e intersection of the shoreline of the Pacific

Ocean and the Northwesterly prolongation of the Northeasterly
line of Kanoff Avenue as said Avenue is shown on the map entitled
"Faral1one City" 'recorded in Volume 6 of Subdivision 11aps at Page
2 of San Mateo County Records~ thence sout"he,asterly· along said
prolongation and said northeasterly line of Kanoff Avenue to the
Northwesterly lin€ of the lands described in t~e Grant De~d to
the Men·tara Schoel District as recorded in Volume 4060 of Offi-
cial Records at Paqe 290, San Mateo County Records: thence along
said line North 44° 48 1 East 100 feet and North 28 0 411 East
740000 :::eet to the Nort'h'?!asterly line of said lands: thence along
said line and its prolongation South 61 0 19' East to the North-
westerly line of Tamarind Street as shown on t~at certain map
-antit.led "Amended and Supplemental t-1ap of Montara" as
rt:;corded ii:l
Volume 5 of Subdivision 1'1aps at Page 35, San Mateo County
Records: thenc~ Northeasterly along said line, the Nortnwesterlv
line of: Lot 54 as s'!-lown on the map entitled "Half Moon Bay Col--
ony" recorded in Volume D of SUbdivision Haps at Page 5, San
Mateo County Records and th~ Northwesterly line of Alta Lorna Road
as ShOVlrl on 't~e map entitled "Second Addition to Hontara" as
recorded in Volume 6 of Subdivision Maps at Page 28, San Mateo
County Records, and Southeasterly along the Northeasterly line of
a 15 foot Nide path (also being the NortheasterJ.:y boundary of
said map) to the most Easterly corner of the lands of State of
California as recorded in Volume 6198 of Official Records at Page
525, SO.n Mateo County Records ~ ... thence a~ong the boundary of said
lands South 16° 49 22" \'Jest 69080 £e,=t: South 3° 03' 08" \'lest
1
81 .. 77 :!:e~t and Sou"ch 24° oil 44 11 \vest 394056 feet to a point on

'the Sou·thwester ly Ii ne of Lot 10 Block 6 as shown on last said
J.Vlap (said point being North 65 0 58· 16" West 55043 feet from "the
Soutlv:rly corner of said Lot 10); thence leaving the bound3ry of
said lands Southeasterly along. the Southwesterly line of Lots 10
and 28 c in said ~locl~ u ancl its Southeasterly prolongation to the
Southeasterly line of Alta Vista Road as shown on said map:
thence along said Road Southwesterly, SoutheasterlY'and North-
easterly to the Northeasterly prolongation of the Southeasterly
line of Lots 33 q 34, 35 and 36 in Block 3 as shown on said map;
t.hence SouthtoJesterly along said prolongation and said Southea.st··-
~rly lil1e of said lots, Southeasterly along the Northeasterly
line of Lot 37 in said Block, Southwesterly along the Southeast-
erly line of Lots 37 and 38 in said Block f and Northwesterly
along ~he Southwesterly line of said Lot 38 to the line dividing
Lots 39 and 25 in said Block; thence Southwesterly along said .
line, Southerly along the line dividing iots 25 and 24 in said
Block and its prolongation to ,the Southerly line of Linda Vista
Road as shown on said map; thence Westerly along said line t.o the
Northeasterly line of Lot 50 i~ Block 1 as shown on said map,
·thence Southeasterly along said line, Southwesterly; A~onQ'tf..:tbD
tfi ..., 1.- '-q: f' .; ~
1~3 • ~ -. v , _
SAW ~~ATtO
COUNTY lOCAL
fO-
IlI'lc:nlCV¥ -I'"~ C··\-AIl.IISSIO Il
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1.x.\U1_ril'~_::I"il vf... 1Y1 II
MWSD Resolution 1438 -1 ..··
COUNTY GOVERi~MH~T CENTER
REIJWOOD CITY. CA 9~063
Southeasterly line of Lots 50, 51, 52" 53; 54 a'nd 55 in said
Block and \~-esterly along· the Southerly line of Lot 56 in said
Block to the Southeasterly lin~ of Lot 36 in said Block: thence
Southwest~rly along said lint=: and Southeasterly alon9 t"~le Nort.h·-
easterly line of Drake Street as shown on aforesaid map (5/35) to
the .. Northeasterly prolongation of the Southeasterly line of Block
B as shown on said map: thence SouthVo'estgrly along said pl:-olonga,-
ticn a~d said Southeasterly line to the Southerly corner of said
Block~ thence crossing Edison Street as shown on.said 11lap, in. a
straight line to t"he most Easterly corner of Block A ;:\s SnOlrJD on
said r.\ap: thenc~ Southwesterly along the Southeasterly line ot
said Block and Southeasterly along t~e Northeasterly line of
Franklin Street as shown on said map to the Northwesterly line of
Montara Boulevard East as shown on the map entitled "Pirst. Addi-
tion to ~1ontara" as recorded in Volume 6 of Subdivision IV1aps at
Page 27, San Mateo County Records~ thence Northeasterly alortt;)
said line to the '\'1esterly line of Coronado Road as SllO\vn on said
map (now abandoned) j thence Northerly and v~esterly along the
Westerly and Southerly line of said Road to the East~rly line of
Lot 1 in Block 14 as shown on said map; thence Southerly along
said line, Westerly, Northerly, Northeasterly and Southeasterly
along the boundaries of said Block, to a point on the South-
westerly boundary of the lands"~escribed in a deed from Au Ry
Wagner and Cora Wagner to Public Utilities California Corpo~ation
in Volume 415 of Official Records, Page 398, San Mateo County
Records; thence along the boundaries of said lands Nort.h 39°"' '52'
West 138 feet more or less, North 46° 26' East 104 feet, South
39 0 52' East 268 feet and South 50 0 08' \'lest 103 :f:eet to t'~le most
easterly corner of Lot 9 in sai6 Block 14 (erroneously called th~
northeasterly corner): thence crossi ng said Coronado Eoad South--
easterly along the prolongation~ of the Northeaste)~ly line of said
Lot to t~e North\y,=sterly line of Lot 3 in Block 12 as shown on
said map; thence Northeasterly and South~asterly alon<;} the bound-
aries of said Let to t~e Northwe·ster1y line of Lot. 12 in said
Block 12: t~ence Northeasterly, Easterly and Southerly along the
bound=tries of said Block to the Northeasterly line of Parcels 3
and 4 as shown on Volume 8 LoLoSo Maps at Page 144, San Mateo
County Records: thence Sout"':1easterly along said line and South-'
westerly along the Southeasterly line of said Parcel ~, the
Sou·theasterly lines of Lots 69 and 70 as shown on sa"id map (D/ 5)
and Park Str,=et as shown on the map of "Wienke Addition to
Montara" as recorded in Volume 6 of Subdivision Maps at Page 3J
to th·e souther ly line of Jordan Street as shown on said map;,
thence Westerly along said Southerly line and the Sou·tht:.r"ly line
of Lot 64 as . shown on said map (DIS) to the Southeasterly cornel:
of the lands of th~ State of California as des~r'il::)ed in that. ce:c-
tai~ tax de,=d, File Nao 84072352, San Mateo County Recordsr
thence along the boundaries of said lands North 28° 15 t :';~2" East
30 feet more or less I North 81 0 16 0 4711 TJ.Jest 256 .. 25 ~:eel~_ I' Not"t.1L
28 0 15 I 22 It Ea s t 12 2 5 fee t " Nor th 61 0 44 D 38 If We s"i: 2 3 .. 4 0 f: e e t
0
and South 28 0 15' 22 II West to the most Easterly c J~neL of Lot 1U

as shown on aforesaid map (DIS); t~tence Northwest'?):-ly along the
Nartheast~rly line of said Lot 10 and Lots 11 27 v 28,. 38 Clnd tL:;
r:
k\\ ~ ;:'! ~~ Y·ll[-:' IT))
/Xo,o • ;l~dj '4 L ~::;y
SAN PJLi\TEO r.;OUf{fV lOeJ:\[.
MWSD Resolution 1438 -2 ..- AGENCY rOr.:!~~(:l i ;C.d C0MM~$S~O\~
Exhibit A - Page 2 of 4 COUNTY GOVi:R:\{M£l~T CE?dlf~
R£Dt1l000 CUll. C/~ 940~):1
fE h\ Hij ~ ~ '1f . _. ;)--_. __. ~.i I.H.~ I:" •. ': d (: ,::,
and Sout.l1,\-Jesterly along the Northwesterly line of said Lot 43 and
Lot. 44 as shown'on said map to the most Northerly corner of Lot
12 in Blocl< 38 as shown on the map entitled "Farollon Heights" as
recorded in Volume 6 of subdivision maps at Page 71a San Hateo
COl1nty records: t'hence Southeasterly along the Northeasterly line
of said lot, 30 feet more or less o to the Southeasterly line of
the Nortl-1Nesterly one half of said lot; tryence Southwesterly
along said line and Northwest~rly along the Northeasterly line of
16t.h Street as sho\tJn on said map to the Northeasterly prolonga-
tion of 'the Northwesterly line of Lot 4 in Block 39· as sho\""n on
said map: thence Southwesterly along saic prolongation and said
Northwesterly line of said Lot 4, Southeasterly along the South-
westexlv line of said Lot and Lots 3, 2 and 1 as shown on said
map :lnd- Southwesterly along the Southeasterly Ii ne of Lot 5 as
s"hown on said map and' its Southwesterly prolongation to the
Northwest.erly prolongation of the Northeasterly line of Lots 6
and 7 in' Block 26 as shown on the map enti tled "fvioss Beach
Height,sU a.s recorded in Volume 6 of subdi vision maps :at Page 8 t
San Mateo County Records: thence Southeasterly aiong" said pro-
longation and 'the said Northeasterly line of said lots and the
Soutbeas-c.e:cly prolongation of said line to the Southeasterly line (
of Montana Street as s1&o\~n on said map, thence Southwesterly (

(
along sa.id line to the general 'Northeasterly line of Block 25 as (
shown on said map, thence along said line in a general South-
easterly direction to the Northwesterly line of California
Stre,=t; t"hence r~ortheasterly along said line and the Northwes-
terly line of Lot 15 in Block 20 as shown on said map, South-
easterly along t"he Northeasterly line of said Lo·t 15 and Lots 14,.
13, 12, 11 and 10 in said Block and Northeasterly along the
Northwesterly line of Lots 5, 48 3, 2 and 1 of said Block to a
point on the Southwesterly line' of Lot·-25 as s"hot""n on said map
(DIS), said line also being~ the Southwesterly lint: of the path
(15 feet v/ide) as shown on the map entitled "Montara Heights"
recorded in Volum~ 8 of subdivision maps at Page 19 of San Mateo
County H.ecords~ tnence Northwesterly along the said Southwesterly
line of said Lot 25 and Northeasterly along the Northwesterly
line of said Lot 25 and Lot 26 as shown on said map (D/S) to the
most \'lesterly cor.ner of Lot J as shown on said map (8/19): t!-ience
Sout·heas·terly along the Southwesterly line of said Lot to the
Northeast".erly prolongation of the cen terline of Lorna' Vista Street
as shown on said map: thence Southwesterly along said prolongati,on
and ~aid centerline to the said Southwesterly line of Lot 25j thence
S6utheas·i:.erly along said line to the most. Northerly corner of Lot 14
as shown on aforesaid map (D/5): thence Southeasterly along the
Nortl·1ea.sterly line and Southwesterly along the Southeasterly line of
said 10·t~ Southwesterly along the Northwesterly line and South-
easterly along the Southwesterly line of Lot 6 as shown on said map
and Southwesterly along the Soutneasterly. line of Lot 5 as sho\'itl on
said map to the Northeasterly line of Etheldore Street (formerly
Balboa Bou.levard) as shown on ·the map of "Resubdivision of Marine ViE
Terrace '.rract" as recorded in yolume 5 of Subdivision Maps at Page 3~
San Mateo County Records: thence Southeasterly along said line and t'l
Northeasterly 1i ne of Cabri 110 High.way (Sta te Ro~t~J.l:'~lf\\the .
~\?r: KU b ~ ¥Jf
S~n\
fMlA1EO C01H~TY lOCAL
MWSD Resolution 1438 AGENCV fO~ll:~;Yi ;Gr~ GOMMISSIOru
Exhibit A - Page 3 of 4 -3--
COUN1"V GOVEfHiMENT CENTE~
~EOWOOO cnv~ CA 94063
[E}{ ~ ~ B~ 1,__11_,........ PAGL~y~Of .f,- ~. .
c.
North~asterlY prolonga,tion of the Nort'hwesterl,:};' li~le of the lands
formerly belonging to Deane & Deane q Inc., as described in the Grant
Deed recorded .in Volume 5727 of Official Records at. Page ,(1-41 San D
Hateo County Records: thence Sout.hwesterly along said prolongatiol~! ~Ull

said North"lesterly line South 13° 24' 00" \oJest to 'cne East.erly linE: L)
Capistrano Road; thence Southerly along said line \:0 the SOl.lt.heasterl'
line of said lands: thence crossing said Capistrano l~(jad in a st:ccd.g1j·
line to the Northeasterly corner of Lot 1 in Block III as ~;ho"·Jn on t.11<:::
map of "Princeton By The Sea" as recorded in Volume 6 of Sllbdivis~~on
Maps at Page 32, San Mateo County Records: thence Nort.hwesterly and
Southwest~rly along the boundaries of saiCl map to -(:11(-2: Southwest r:1:cly
line thereof; thence Southeasterly along said line and i ts prolon'~
gation to the shore of the Pacific Ocean; thence along the said sho}':e
Southwest~rly, Southerly, Westerly, Northwesterly and Northeasterlv
(~round Pillar Point) and continuing in a general Northerly direction
along t'he shore of the Pacific Ocean to the Point of 13eginn:b"lg ..
(
L
l
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Ii
t:
(
t

Exhibit A - Page 4 of 4 Af?l?~O~~E[»
SAN MATEO COUNTY LOCAt
AGENCV fOR~/U\T i Gr~ COM ruJ ISS!O~
3-88 -3- COUNTY GO\fERNMEruT CENT~r<
D-28/Kanoff - Rev~ 3/21/88 REDWOOD CITY. CA 94063
151 (24 )
tEX~~B~1 Ll.-
" "'........""...
PAGf: 6--' L' \S;-
''1 L ~"""""... lJg c."""..;--.-,-,-
ExhibitA-1
(Map of eSA 12 from Board of Supervisors Resolution 50749)
7
ResAppnConsolCSA12r - Revised 11107108
61S83
stA',
MONTARA POINT
-._--- -
..
SCALE .-. 600'
==
f IL C .,,'''OCg.
oOtO OA. 100 - A(PtA' 10 Offl,.AL ",eOAOS.
ot .. O"I G.,"UCI ooua",,,:n.
MAP OE-.
PROPOSED COUNTY SERVICE A~~~_.
MONTARA - MOSS BEACH V1CINITY
MARCH 1988
- RECORDER'S MEMO,.
POOR RECORD IS DUE 10
QUAU1V Of ORIGlNAl DOCUMENT ~
Exhibit B
(Boundary description of MWSD from Board of Supervisors Resolution 12987)
8
ResAppnConsotCSA12r - Revised 11/07/08
.....:
.' '.~
DEScurPrION OFes PROPOSED

......~~~ """ ..
• ( I ~:~,~ •• '.
UHONTARA SAUIT/\ltX
...,'. a::uo.a
, ::w:;
DISTRICTu
\~ ~~~..
.; : { ; ", ': '~~';:n:-~'.I'.~ ',: .·:~
J~·:G:r.NNIUG a'~, un nngle point ~:
the l1eat;jy boundary or the Grane.da
fianita,,...:.'" Din tr:l.(:t fo'):med by Rosolution No", 1271>2~~~; .adopt,ed by the Board or .
of San H,~teo County on ~fu.rch lap 195,8 6 said point. of beginning
Sl).pO:C1J.!10l~5
nlAo hn:lug t,ho most G8st,ar1.y· corner or' tho 50 1I';::,Cowell 638 acre tra.ct p as
5ho\\rn on t,he tlOr..ric1.al Hap of: San l.fatco Countyrt 9~[;COPyr1g)1t 1950; thencEl from
!,;mid point of bec9.nn:lng along the easterly boundary' of said 638 acre tract" alJQ
~Hl:t d boundary of Gl.-'anada Snnitary Distl1.ctD sout~we8terl,.S) weat.erly fJ and south-
\'((-3ol;.c1"J.y to ~ point 5.11 tho northE)aatd~ly line ot,:~~the State Iligh'WnYJ) Route 56 r
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(if ~)(:':.n l'!:li'.CO County; t,henc,~ in a. BanarHl 60uthaasterly direction along the center
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343.·€J3 acrc t.X'Hct of lann as aho',m on said Orr1cisl Map; thence northeasterly
.. 1m~g r:mid sQuthaa,str:c'ly line to the intersection theroof with the one-·,quarter
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From: "David Skelly" <dskelly@geosoilsinc.com>
To: "Camille Leung" <CLeung@co.sanmateo.ca.us>, "Nicole DeMartini"
<NDeMarti...
Date: 10/28/2010 7:22 AM
Subject: Recent Tsunami Info
To All,
I thought I would pass on what I have learned about the Tsunami eraly
this week in Indonesia. The earthquake epiccenter was very near the
impacted island of Pagai Utara. The tsunami wave was about 10 feet high
and went about 600 yards inland (relatively flat topography). There was
only 1 or 2 waves (the witness account varies).
The fact that this relatively large Tsunami only propagated about 600
yards into relatively dense vegetation illustrates my point about the
propagation of a tsunami, and energy loss from friction, to the Big Wave
wellness center.
What occurred at Pagai is consistent with my analysis at Half Moon Bay

wellness center.
David W. Skelly
(760) 438-3155
www.geosoilsinc.com
October 26, 2010
Jim Eggemeyer
Planning Director
San Mateo County Planning Department
400 County Center
With all of the negative comments made in connection with the Big Wave project
proposal, I can see why both county planning officials and members of the public could
feel overwhelmed and at their respective wits end.
For the public, it is difficult to know where to start with a 3,000+ page FEIR and a long
list of existing complaints, concerns, and potential red flags with just 12 days to review
the finished document to check and see whether these were adequately addressed. The
planners and applicant appear to be equally overwhelmed responding to the numerous
letters, emails, charts and graphs submitted both in response to the DEIR and FEIR. I
too am opposed to the Big Wave Project and like many members of my community that
took the time to submit comments during the DEIR stage, believe that most, if not all, of
the areas of concern we expressed in our DEIR comments are also applicable to the
FEIR - especially in light of the mutually exclusive alternative development scenarios
set forth therein. For this reason, until I have more time to read and digest the FEIR, I
hereby incorporate by reference my previously submitted DEIR comment letter.
There is good news, however. Moving forward, things can go more smoothly for future
development proposals and maybe, just maybe even Big Wave can be salvaged. But
there are important lessons to be learned from this failed process and some big
changes needed for that to happen.
The Seven Deadly Sins of the Big Wave EIR Process and How To Avoid Them
(1) Both the County and the Developer Need to Be Open and Transparent
Trust in the process and err on the side over over-sharing information with the public as
opposed to going dark and remaining silent on potential key areas of concern. This is
basic human psychology 101. The more people trust in the process and feel like they
are being treated as intelligent members of the community, and the more opportunities
they have to engage in a meaningful dialog at the feasibility analysis stage of a
contemplated new development – before a project proposal ever becomes an EIR – the
better the likelihood that the project proposal will find broad community acceptance.
Here, there were countless examples of missed opportunities. From a lack of coastal
workshops, to a lack of meaningful engagement with the elected Midcoast Community
Council, to a lack of story poles, to a lack of opening the books on the projects financial
structure, there was a sense of a shell game being played throughout. The impression
that this project proposal made was one of being sneaky rather than honest,
1 of 1
underhanded rather than above board, pushed on the community rather than pulled
towards it.
The solution is obvious. Embrace openness with the community and engage with
residents and the MCC as early and as often as possible.
(2) Make Everyone Play By The Same Rules
Related to point number 1 above, the majority of us have had the experience of either
building a home, or doing a remodel or renovation on the coast. We have experienced
the frustrations of asking for, and being denied, special treatment from the building and
planning department and/or the department of public works. If variances and special use
permits are as rare as hen’s teeth for the average resident, it should be no different for
developers, and this includes simple requirements like the courtesy of notifying
neighbors and erecting story poles.
When the community sees developers receiving special treatment, especially when that
special treatment appears to be occurring behind closed doors and out of the realm of
public meetings (see point number one above) the chasm between community support
and the interests of the county and the developer with which it is aligned widens.
Big Wave may be a wonderful, viable project but the only way we would ever know is if
the county said, in essence, “Our vision for the Princeton Harbor over the next 20-30
years is as follows. [Outline of how the harbor might change in that time]. A key part of
planning for that future is a incorporating the facilities presented by a development like
Big Wave. In order to make that future a reality, we are going to need to revisit the
Master Plan for the area, the applicable zoning, the airport overlay, and even propose
some LCP amendments. Once we have done those things, it will be clear that Big Wave
is a perfect fit for our forward-looking vision for Princeton Harbor.” – And then do exactly
that.
Revisit the Master Plan. Does it need updating? How about the zoning? If the Big Wave
Wellness Center is needed and doesn’t comport with W zoning, consider initiating a
rezone for the area. Maybe more W zoning can be incorporated elsewhere in the harbor
district? If there is a conflict with the LCP, work to propose an update that the
community can get behind. Playing sleight of hand with a “Sanatorium” designation for
the Wellness Center is offensive and belittles our intelligence. Follow the procedures
and keep the playing field level, and there will be no need for engineering loopholes and
escape hatches into the EIR process to get around obvious regulatory conflicts.
(3) Have a Vision
At a recent Midcoast Community Council meeting, Jim Eggemyer, Planning Director,

was repeatedly asked to share his vision for the Midcoast and what he saw were the
potential opportunities and stumbling blocks towards achieving it. Although this question
was rephrased for him a number of times, we never got an answer.
2 of 1
The same question is now being asked of the candidates for the Board of Supervisors
and has been a central theme in debate over district vs. at large elections. People want
to feel that San Mateo County planning staff has an understanding of what makes the
Midcoast such a special place to live and visit – not just relative to other communities in
San Mateo, but for the entire state. When residents feel like San Mateo County officials
appreciate what the Midcoast is all about, and have a vision for preserving and
enriching that experience, projects come to the table in a more favorable light.
Many people looked at, and continue to see, The Big Wave commercial office complex
as not being very coastal. How is this different from an office complex in Foster City,
San Bruno or South San Francisco? When county planning staff can anticipate those
kinds of concerns and clearly show why this office complex has to be on the Midcoast
and isn’t appropriate anywhere else (a CEQA requirement, incidentally), because it
comports with a broader vision for the Midcoast, the public will better be able to
embrace it as perhaps a bitter pill to swallow on its own merits, but as a necessary step
towards achieving a broader vision that we are all on board with.
(4) Avoid the Trap of All or Nothing and Discourage the Trojan Horse
The Big Wave project proposal could, and probably should, have been presented as a
phased proposal (PEIR) as opposed to an (EIR). There is no reason the county
planning staff couldn’t have said, for example, that the project should move forward in
baby steps. Did the Wellness Center need to be right next door to the commercial office
complex? Did the buildings of the commercial office complex needed to be sited in a
cluster, or could they have been spread through the community in spoke-and-hub
orientation? What if the businesses were geared towards meeting LCP visions for
promoting aquaculture and agriculture?
The County could and probably should have requested that the developer come back to
the table with an approach that merges the desired functions within the context of the
existing working harbor – and guess what, if this developer couldn’t or wouldn’t do it –
another one gladly would have.
Add the Trojan Horse element into the mix (“to get this, you have to accept that”) and
residents on the coastside know to be on the lookout. Time and again projects are
brought in with a catch – a developer wants to help veterans, the children, the disabled,
or some other perfectly deserving group with something just for them – but there is a
catch. To get this, you have to also take that.
This song and dance has worn thin on the coastside and is long overdue for being
retired.
(5) You Don’t Always Have to Do Business With the Usual Suspects
The land use attorneys associated with the Big Wave project proposal brag about their
deep insider ties with San Mateo County building and planning officials right on their
website. Not only is this unseemly, but when the same group of characters have been at
3 of 1
odds with the residents over ill conceived and ill advised development proposals for
decades, maybe it is time to start talking to different people.
There are innovative and progressive approaches to urban design that have been
happening all over the globe, including in neighboring counties right in our home state.
Maybe if we gave some new faces a chance to help set forth development proposals for
the Coastside, including not just the direct stakeholders, but the back-room expediters
that set up shop to help them see a project through – we would begin to see some
change in the types of projects that are proposed and the tactics for seeing them
through the public vetting process.
In some cases, the hardened, seasoned insiders that roam the halls of San Mateo
County Building and Planning like it is their second home aren’t the right people to be
talking to when it comes to big, potentially controversial projects like Big Wave – at least
not if the project is to get any semblance of community support.
(6) You Have to Have Infrastructure for Development – No Excuses
It stands to reason that for development to occur, cars need to move, water needs to
flow, and waste needs to go somewhere. Yet with Big Wave, the very sore points that
residents experience day in and day out with roads consistently rated “F” for traffic flow,
a long waiting list on water connections with a decades old moratorium, and a waste
system consistently at or beyond capacity are left as big question marks. Add to this
PG&E power lines that have yet to be put underground to prevent neighborhood wide
outages and ancient communications infrastructure, and you have a recipe for a sleepy
shut-in style coastal township for the foreseeable future.
Want to see that change (and there are many who don’t) – then deal with the obvious
infrastructure problems first, or at a minimum, in parallel with any sizable new
development proposal.
Traffic and trails meetings that look to lower speed limits and introduce traffic calming
roundabouts are at odds with major new commercial developments. Fix what needs
fixing and at least commit to deploying the first steps of some long range planning
against those infrastructure shortcomings, and you’ll be amazed at how much more
open the community is to new developments (given that points 1-5 above are also taken
to heart).
(7) Listen, Listen, Listen.
Listen not to developers. Not to their legal counsel. Certainly not to paid consultants.
Listen to your voters and tax base.
Good urban planning starts with talking to people and hearing about what they love
about their community, what they hold dear, and what they think needs some attention.
Before even initiating the planning towards development in steps 1-3 takes place, take
the time to conduct some polling and workshops without any specific agenda in mind –
4 of 1
just to get a feel for what it is people want. Then use this in helping to evaluate the
feasibility and desirability of any and every new project that walks in the door.
Incidentally, if the right project doesn’t walk in the door, go out and find it. Ask for
competitive bids. When you have taken the time to listen and engage the community,
you’ll be pleasantly surprised how easy it is to find the developers, funding, and support
to make those projects a reality that is both profitable for its backers and embraced by
the majority of the residents.
I hope this helps.
[SIGNED]
David Vespremi
Cc:
San Mateo Board of Supervisors
5 of 1
Page 1 of 1
- Big Wave
From: "Denise Aquila" <denise@deniseaquila.com>

Date: 10/22/2010 1:52 PM
Subject: Big Wave
Unfortunately I can’t be at the meeting but I want to let you know I feel very strongly that it is in the best
interests of the community to build this project as soon as possible. There are people who desperately deserve
the opportunity to be self‐sufficient and to live a life as they see fit. There are so many other regulations and
mandates due to the ADA that not approving this project seems to be counterproductive.

I have lived on the coast for 36 years and a project of this positive magnitude has never been built. It is terribly
overdue. The project will provide much needed affordable housing and jobs to the coast which is something the
Board of Supervisors and the general public on the coast has been asking for.

No more delays. Delays hurt the people waiting for their new home to be built, the economy because new jobs
mean people can be gainfully employed, sales tax will flow to the county coffers and the beauty of the coast can
be enjoyed by others.

Thank you in advance for your vote to move immediately forward with this project.

Denise Aquila
70 Patrick Way
Half Moon Bay, Ca 94019

11/16/2010
Donald L. Freese
1 Creekside Drive
Half Moon Bay
CA 94019-2373
(650) 726-6893
October 28, 2010

Planning Divison
San Mateo County
455 County Center
Re: Big Wave Project
The enclosed materials are self explantory. Please see that my October 27, 2010
presenrtation text is placed on the official record for the Big Wave Project.
Thank you
Respectfully,
~J~7c!~
DONALD L. FREESE
DLF/nd
Enclosures:
Donald L. Freese
1 Creekside Drive
Half Moon Bay
CA 94019-2373
(650) 726-6893
October 28, 2010
Mr. David Bomberger, Chairman

Re: Big Wave Group Project, October 27. 2010 meeting
Dear Chairman Bomberger:
Prior to the October 27, 2010, planned Big Wave Project meeting, I place
several telephone calls to the Big Wave Group (560-9588) in an attempt to get some
information. Unfortunately I receive no response to my many messages. Having
received an invitation, I proceeded to the El Grenada Elementary School site, only to
find that the meeting had been cancelled. It was more than an inconvenience, as I
have an important statement that I want to be placed "on the record".
The enclosed copy of my intended 10/27/10 presentation is self explanatory. I

would request a written confirmation that the text of my intended presentation has
been placed "on-the-record". And, I hope you will keep me informed of any actions
planned for the Big wave Project.
Respectfull y,
p;~(aL//~
DONALD L. FREESE
DLF/nd
Enclosure:
cc: Richard S. Gordon, County Supervisor, District 3

cc: .Camille Leung, Project Planner
//~
BIG WAVE GROUP
October 27, 2010
EI Grenada Meeting
I'm Don Freese from Half Moon Bay.
Years ago, I was affiliated with the founding Unit of the California State
Department of Rehabilitation that was established and funded to assist the
Developmentally Disabled. So. I very much support your project goals
and intentions. However, I strongly question your choice of LOCATION!
The Half Moon Bay Airport is a tremendously important asset to all the
San Mateo County Coastal Communities:
The annual "DREAM MACHINES" alone attracts tens of thousands of

participants and provides much needed income for the budgets of our
many Charity Organizations. Some could not exist with out it!
Professionals from the U.S. Geological Society (USGS) have stated that
flhtere is more than a 60% chance of a damaging earthquake striking the
regior4" And, it is not a matter IF but WHEN it will happen! When
that EARTHQUAKE DISASTER occurs, we all know Highways 1, 92
and even 84 will be PARKING LOTS! NO ONE will be able to get IN
or OUT of the area on these roads!
WE WILL BE TOTALLY ISOLATED!
The AIRPORT will be our ONLY means of access for FOOD, WATER,
SHELTER, A1EDICAL / HEALTH and SECURITY services that will be
required!
Remember how important the AIRPORT was for Haiti!
I actually READ the draft EIR and was STUNNED to find no mention
about the effects of our Half Moon Bay Airport's much needed
operations and activities on the Big Wave Developmentally Disabled
clients and staff.
OUR AIRPORT MUST BE PROTECTED, AT ALL COSTS!
I recommend that for the HEALTH AND WELL BEING of the Big
Wave Developmentally Disabled and staff, that they locate their project
closer to downtown Half Moon Bay. Perhaps to the City's Beachwood
property and the adjacent land recently donated to the City.
Thank you.
Sincerely,
;tL dd ? .Aee4e -
DONALD L. FREESE
Page 1 of 1
- Fwd: Big Wave Project Approval
From: Camille Leung

To: Bryan ALBINI
Date: 11/15/2010 12:41 PM
Subject: Fwd: Big Wave Project Approval
Attachments: Big Wave Project Approval; Big Wave Development; Big Wave Project Review; Big
Wave; HMB resident input on Big Wave proposal; Big Wave project; Big Wave
Project; Big Wave Project; Big Wave Project; comments FEIR big wave jack sutton;
Comments on Big Wave; Big Wave Project; Support for the Big Wave Projecct; RE:
Big Wave; 1991.05.14 CCC SMC LCP Major 2-90 Staff Report.pdf, 1993.12.02 CCC
A-3-SMC-86-155 and 155A Condition Compliance.pdf + 2 more items
To whom it may Concern:
I am a lifelong resident of the Coastside and have never seen a project better suited for the community
as a whole. I hope that the County of San Mateo will approve this project as soon as possible for all of
the people involved. Since it seems like the Owner's of this project have accepted all of the conditions
for approval this should be a done deal. Please get this project approved now. Big Wave is a win win!!!
Sincerely,
Cynthia Giovannoni
1780 Higgins Canyon Road
Half Moon Bay, Ca. 94019
11/16/2010..
Page 1 of 1
- Big Wave Development
From: "Geoffrey Perusse" <gperusse14@yahoo.com>

Date: 10/27/2010 4:06 PM
Subject: Big Wave Development
I am writing to remind you that you serve voters and tax payers on the coast, not private
developers, and the public has spoken out overwhelmingly against Big Wave. Please do
not permit this development to occur in our backyard. We love the way the coast is now
– there is NO need for this type of commercial development. Please don't build another
downtown in this area. The traffic is ALREADY horrible! This project is way, way too big.

Best regards,
Geoff

390 9th St. Montara, CA
11/16/2010..
Page 1 of 1
- Big Wave Project Review
From: "Grace Maguire" <gmaguire@biocodexusa.com>

To: "CLeung@co.sanmateo.ca.us" <CLeung@co.sanmateo.ca.us>
Date: 10/19/2010 3:28 PM
Subject: Big Wave Project Review
Dear Camille,

Please place the Big Wave project in a high priority list of projects for final review. So many building project are
simply commercial ventures without a real heart and soul. The Big Wave project is certainly the exception. Our
community has a heart and soul and many developmentally disabled members are pinning much hope for a
fulfilling future on the completion of this project. I met you at the first meeting in El Granada. The need in the
community is great. The time frame for completion has been very long. If you can do anything to move this
along the correct channels for completion, it would be a great service to the community. Developmentally
disabled people need the opportunity to thrive. This project gives them the opportunity to thrive in a
community built with them in mind.

Warm regards,

Grace Maguire

Grace Maguire
Training Manager

1250 Bayhill Drive
Tel : 650-243-5324
Suite 200
Cell : 650-580-4878
San Bruno, CA 94066
Fax : (650) 589-1196
www.biocodexusa.com gmaguire@biocodexusa.com
WARNING: The information in this e-mail and in any attachments is intended for the above-referenced addressees only. It may contain
privileged or confidential information the review, dissemination or disclosure of which is strictly prohibited. If you have received this email in
error, please destroy it. If you are not the above-referenced addressees, you are not authorized to disclose copy, distribute, or retain this
message or any part of it. Any unauthorized disclosure is prohibited. Thank you.

11/16/2010...
HAL BOHNER - ATTORNEY
115 Angelita Avenue
Pacifica, CA 94044
(650) 359-4257
hbohner@earthlink.net
Sent by email to cleung@co.sanmateo.ca.us
November 7, 2010
Camille Leung, Planner

San Mateo County Planning and Building Department
455 County Center, 2nd floor
Re: Big Wave Wellness Center and Office Park Final Environmental Impact Report /
SCH No. 2008102109 / October 2010
Dear Ms. Leung:
I am submitting the following comments concerning the Big Wave Wellness Center and
Office Park Final Environmental Impact Report / Sch No. 2008102109 / October 2010 and
related Draft EIR and other related documents. Please include my comments in the file and
consider them in the environmental evaluation of the project. Also, please provide a copy of my
comments to the Planning Commissioners for their meeting to discuss this EIR, which is
scheduled for November 17 .
To summarize my position, I feel strongly that the DEIR and the final EIR are not legally
adequate. I have read the comments of many others concerning the DEIR and agree with many
of the comments which explain why the DEIR is legally inadequate. And I have read the
responses to comments, which for the most part do not adequately address or resolve the issues
the commenters raised. For the sake of brevity I will direct my comments in this letter to only a
few issues and not discuss many of the flaws in the EIR which others have highlighted.
I. The project site is habitat for special status species, contrary to repeated denials in
the DEIR. Failure to admit this fact has lead to many incorrect statements and conclusions
in the EIR.
Ia. The DEIR repeatedly states that the project site is not habitat for special status
species.
The following are some examples.

1
“No direct impact or take of special-status species is expected as a result
of the proposed project due to the lack of habitat suitable on site to support
those species with a potential to occur or known to occur in the project
vicinity.” Pg IV.D-94
“Proposed project construction activities will not result in impacts to

project area wetlands and/or habitat for special-status species known to
occur in the vicinity of the site.” Pg IV.D-97
“No wildlife corridors or sensitive habitats will be affected as a result of

the proposed project. Impacts would be less than significant.” Pg IV.D-98
Ib. It is obvious that the project site is habitat
Ib1. The definition of “habitat” includes upland dispersal habitat, and the project site is
plainly upland dispersal habitat, at least for the CRLF and probably for other species as well.
The US Fish and Wildlife Service Recovery Plan for the CRLF Recovery Plan for the California
Red-legged Frog (Rana aurora draytonii) – May 28, 2002
(http://ecos.fws.gov/docs/recovery_plan/020528.pdf ) (copy attached) identifies two types of
habitat, breeding habitat and upland dispersal habitat. The Plan states:
Habitat Requirements: The California red-legged frog requires a variety of

habitat elements with aquatic breeding areas embedded within a matrix of
riparian and upland dispersal habitats. (Recovery Plan pg iv)
The Plan further states:
Dispersal and Use of Uplands and Riparian Areas. During periods of wet
weather, starting with the first rains of fall, some individuals may make
overland excursions through upland habitats. (Recovery Plan pg 12)
The EPA has recently made it clear that agricultural fields can be upland dispersal habitat. A
recent EPA report states:
“Dispersal habitat includes natural and altered habitats such as agricultural

fields that do not act as barriers to dispersal.” Pg 4 of Attachment 1: Status
and Life History of California Red-Legged Frog (copy attached hereto)
(http://www.epa.gov/espp/litstatus/effects/redleg-frog/attachment1.pdf),
which is an attachment to Risks of Dimethoate Use to the Federally-
Listed California Red Legged Frog, USEPA, January 32, 2008
(http://www.epa.gov/espp/
litstatus/effects/redleg-frog/dimethoate/analysis.pdf) (copy attached).
Ib2. The DEIR said that the CRLF is “likely” to occur on the project site. (DEIR pg
IV.D-63) This was changed to “moderately”. (III. Corrections And Additions To The Draft EIR
- B. Revisions To Draft EIR pg III.B-7. ) Also it says that the potential for occurrence for the
SFGS is “likely” (DEIR pg IV.D-64), but this was not changed to “moderately” in the FEIR.
2
Whether the potential for occurrence is “likely” or “moderately”, in either case if the animal lives
on the site then the site is clearly “habitat” within the common understanding of the meaning of
the word “habitat”.
Ib3. The Mitigation Measures focus heavily on monitoring procedures and

contingency measures if species of special concern are found on the project site. Obviously
such procedures would not be necessary if it were not likely for the special status animals to
occur on the site. It takes little imagination to understand that these mitigation measures were
required by scientific experts, probably with the US Fish and Wildlife Service, who expect that
special status animals will be on the site.
Ib4. A recent report studied land in Pacific, California which is quite similar to the
project site. It is not an agricultural field but it is an upland area which has been significantly
disturbed by quarrying in the past, and it is near breeding habitat for the CRLF. The report
concludes that Red Legged frogs are present on the site.
Status Of The San Francisco Garter Snake (Thamnophis Sirtalis Tetrataenia) At Pacifica Quarry,
San Mateo, California by Swaim Biological , Inc, February 27, 2007 (copy attached)
Ib5. The DEIR itself admits that there is habitat on the site. The DEIR states:
“Measures recommended in Mitigation Measures BIO-1a through BIO-1d would serve to protect
important natural habitat on the site for wildlife, . . .”.Pg IV.D-98 concerning Mitigation
Measure BIO-4a Wildlife Movement and Habitat Connectivity
Ib6. The DEIR fails to explain why it states that the site is not habitat for special status
species. It may be based on the implicit assumption that because the project site consists of
agricultural fields it cannot be habitat. However, the DEIR itself contradicts this assumption.
“Agricultural fields provide habitat for a number of insects, reptiles, birds and small mammals,
which in turn serve as important prey for predatory birds and mammals.” DEIR pg IV.D-22
Ic. Failure to recognize that the site is habitat has lead to many serious incorrect
statements can conclusions.
The following are some examples.
The DEIR states: “In general the proposed project would conform to local policies and
ordinances related to protection of vegetative, water, fish and wildlife resources.” Impact BIO-5
Conformance with Local Policies and Ordinances. Pg IV.D-99. This is not correct. For
example, local policies and ordinances require many protections for habitat , e.g. Local Coastal
Program Policies 7.1 through 7.20 and 7.32 through 7.36.
The DEIR states: “Potential impacts to special-status species, sensitive natural

communities, wetlands, and wildlife habitat and movement opportunities would be less than
significant with implementation of the above mitigation.” Pg IV.D-99. This is not correct. For
example constructing large structures and parking lots on the habitat of California Red legged
frogs obviously would have significant impact.
3
II. Wetlands Restoration
IIa. It is not clear whether wetlands restoration is in fact part of the project and
whether it will in fact be done.
The EIR is confusing and misleading. On the one hand the DEIR indicates in many
places that restoration will occur at specific locations and that it will comprise a specific
percentage of the land of the project. However, it is not at all clear whether wetlands restoration
will in fact be done and if done the exact nature of the restoration.
A document titled, “Draft (90%) Basis of Design Report, Riparian & Waters/Wetlands
Ecosystem Restoration for Big Wave Wellness Center and Office Park San Mateo County,
California – August 4, 2008” is included in the Final EIR, III.B., Revisions to Draft EIR.
(Hereinafter “Draft Design Report.”) The Draft Design Report is just that – a draft. It is clearly
not a final document. Furthermore the title “Draft (90%)” is unclear and misleading. Does 90%
mean that it is almost complete? If so, what more needs to be done to complete it? What may
change when it is completed? Also, the Draft Design Report states, “Wetland boundaries under
California Coastal Commission jurisdiction have not received formal approval.” (pg i). What is
the meaning and significance of this statement? If the Coastal Commission disapproves of the
wetland boundaries then will the restoration not be done? Has the developer met with the
Coastal Commission to discuss the Draft Design Report? If so what were the results of the
meeting?
It is plain from the DEIR that ostensibly one of the main environmental benefits of the
project is wetlands restoration. However, since it is not clear that the developer would even need
to do wetlands restoration or to what extent, it is absurd to approve the EIR and the project at this
time.
IIb. Monitoring and maintenance of the restoration area is not adequately addressed
The Draft Design Report makes it clear that after the restoration is done there must be
ongoing monitoring and maintenance. For example, the Draft Design Report states,
“In case project standards and/or success criteria are not met, an adaptive
management strategy with contingency measures will be included as part
of the monitoring plan. In the event of failure to achieve a project
standard, recommended contingency measure(s) will be outlined (e.g.,
weeding, grading, planting) and implemented as soon as possible.” (pg 8,
emphasis added)
The key here is the future tense – “will be included . . .” At present there is no
monitoring plan. This is ridiculous. The law requires an EIR to include a detailed monitoring
program for mitigation measures. If wetlands restoration were called “mitigation” then a
monitoring and reporting program would be required as part of the EIR. By simply failing to
classify the wetlands restoration as mitigation, the need to provide a monitoring program cannot
be avoided.
4
Additionally, the Draft Design Report states, “Assume a ten year monitoring interval with
monitoring reports completed at Year 0 (baseline), 1, 2, 5, and 10.” To limit to monitoring
program to 10 years is ridiculous. One of the purposes of restoration is to provide habitat for
special status species. If the animals colonize the restoration site during the 10 year period what
will become of them if monitoring is discontinued and the site reverts to a condition in which it
is no longer satisfactory as habitat? Quite likely this would constitute an illegal take under the
Endangered Species Act. To be adequate a monitoring program must continue for as long as
necessary to be sure that the site is self-sustaining as habitat.
IIc. The restoration is a significant impact not recognized as such in the EIR
The DEIR states,
Sensitive wildlife habitats are located south of the project site within the
adjacent Pillar Point Marsh. Due to the continuous and ongoing
agricultural activities on the project site, special-status and common
wildlife species movement across the site is limited. The drainage that
bisects the project parcels contains the only sensitive habitat onsite. This
area will be restored and protected by a 100-foot buffer on either side,
enhancing its habitat value and availability for use as a protected
movement corridor through the site. No wildlife corridors or sensitive
habitats will be affected as a result of the proposed project. Impacts would
be less than significant. Pg IV.D-98
This paragraph raises significant issues.
1) The statement, “Due to the continuous and ongoing agricultural activities on the
project site, special-status and common wildlife species movement across the site is limited.” is
an admission that the farmed portion of the site in its current condition provides a route for
wildlife movement. Whether it is “limited” or unlimited is merely a matter of degree.
Furthermore, the nature and magnitude of the alleged limitation is not addressed in the DEIR and
it must be addressed.
2) The paragraph implies that the restored wetland would have less adverse impact on
movement of wildlife across the site than the present agricultural activities. However, there are
two problems with this conclusion. First, as discussed above, it is not clear whether the wetlands
will be restored or if restored what the nature of the restoration will be. Moreover, it is not at all
obvious that constructing large buildings and parking lots on the site coupled with some habitat
restoration, would not impede wildlife movement more than an undeveloped field in agricultural
use. At a minimum, the EIR must provide scientific evidence as the basis for these
unsubstantiated opinions in the EIR.
3) The statement, “No wildlife corridors or sensitive habitats will be affected as a result
of the proposed project,” is plainly incorrect. The paragraph states that the restored wetland will
provide a “protected movement corridor.” This is obviously an effect.. Furthermore, the
construction of large buildings and parking lots will affect wildlife movement.
5
III. The Mitigation Measures are not adequate
IIIa. Mitigation Measure BIO-1a Item 1 Special-Status Species
The DEIR states that at the beginning of construction, a monitor shall survey the site and,
“If any life stage of the WPT, SFGS or CRLF is found during these
surveys or excavations, the Department of Fish and Game and the US Fish
and Wildlife Service shall be contacted immediately, and activities that
could result in take shall be postponed until appropriate actions are taken
to allow project activities to continue.” Pg IV.D-95
There are a number of problems with this procedure.
1) What “appropriate actions”? They must be described in the EIR

2) What does it mean to say that, “activities that could result in take shall be
postponed?” The clear implication is that the animals would simply be removed from the site
and construction would continue. If this is the intent then it should be so stated.
IIIb. Mitigation Measure BIO-1a Item 2 Special-Status Species
IIIb1. The DEIR states:
During installation of construction zone exclusion fencing, the biological

monitor shall be present and will oversee the installation of all
construction fencing. The exclusionary fencing shall be installed on one
parcel site first so that if any animals are within the construction zone,
they will have the opportunity to move out of the area freely. Pg Pg IV.D-
95
1) In other words, if special status species are on the site they will be driven off. That
constitutes a “take” which is unlawful under the Endangered Species Act.
2) If they are on the site then it is undeniably habitat and the basic assumption of the
DEIR has been proven incorrect.
IIIb2.. The DEIR states:
“If any life stage of the SFGS or CRLF is found during these surveys, the
Department of Fish and Game and the U.S. Fish and Wildlife Service shall
be contacted immediately, and activities that could result in take shall be
postponed until appropriate actions are taken to allow project activities to
continue.” Pg IV.D-95
6
What are the “appropriate actions”. The only logical thing would be to stop all further
construction and abandon the project. However, that, of course, would never occur. It would be
too late. At that time a take will have already occurred.
IIIb3. The DEIR states:
Prior to the removal of the buffer area/restoration area fencing, permanent

exclusionary measures shall be put in place to prevent special-status
species movement beyond the buffer areas. Wildlife movement through
the site shall be facilitated via a buffer zone on either side of the drainage
that bisects the parcels. Pg IV.D-95-96
A fndamental problem with this procedure.is that it provides no protection for animals
which may travel from the east onto the project site.
IIIc. Mitigation Measure BIO-1c Special-Status Species
The DEIR states: “The applicant’s biologist has obtained a verified wetland delineation
and has consulted with the regulatory agencies regarding special-status species.” Pg IV.D-97.
This leads to the obvious question – what did those agencies say? The substance of these
negotiations must be included in the EIR. It is obviously pertinent to the EIR and should not be a
secret. Moreover, as mentioned above, the Coastal Commission apparently has not “verified”
the wetlands delineation.
IIId. Impact BIO-4 Wildlife Movement and Habitat Connectivity
The DEIR states: “No wildlife corridors or sensitive habitats will be affected as a result
of the proposed project. Impacts would be less than significant.” Pg IV.D-98. This is not
correct. In fact the whole of the project site is a wildlife corridor. To the north and south of the
site animals cannot travel east and west but animals are able to move east and west across the
whole project site. Common parlance would call the site a corridor. However, the development
of the project would constitute an impassable barrier across most of the site, with the possible
exception of the drainage swale
.
IV. Tidelands
In a letter Dated December 23, 2009 concerning the DEIR the Coastal Commission staff
stated, “The proposed project is located on two parcels that appear to contain historic tidelands
that are in the Coastal Commission’s original permit jurisdiction.” Volume III of III - Final
Environmental Impact Report - comment letter No. 21
The County’s response to this comment (Comment 213-2) stated:
“ . . . . the County has added recommended Mitigation Measure LU-2 to

the Land Use and Planning Section of the DEIR/FEIR to require the
property owner to work with the Coastal Commission to identify and
delineate the CCC’s jurisdiction over the project site and obtain all
7
necessary approvals from the Coastal Commission prior to the initiation of
any development within areas of CCC jurisdiction.”
The extent of historic tidelands on a project site can be a major consideration in the
planning of the development of the project. Whether and to what extent the Coastal Commission
will have original jurisdiction is one issue. Moreover, development on certain historic tidelands
may be legally prohibited. Generally speaking, land which is historic tidelands is subject to the
Tidelands Trust which can place severe restrictions on development. For example, a recent EIR
for a development on Treasure Island in San Francisco Bay states, “The Tidelands Trust
generally prohibits residential, general office, non-maritime industrial, and certain recreational
uses on lands that are subject to the Trust.” Pg. II-14 of Project Description for Redevelopment
Plan for the Treasure Island / Yerba Buena Island Redevelopment Project (“Redevelopment
Plan”). (http://www.sf-planning.org/ftp/files/MEA/2007.0903E_TI_DEIR_05_ChapterII.pdf)
(copy of page II-14 attached)
Thus the answer to whether some or all of the project site is historic tidelands must not be
delayed to a future date. Instead it must be resolved before the EIR is completed and the results
reported in the EIR.
Thank you for your consideration.
Sincerely
Hal Bohner
Attachments:
1) Recovery Plan for the California Red-legged Frog (Rana aurora draytonii) – May
28, 2002
2) Attachment 1: Status and Life History of California Red-Legged Frog
3) Risks of Dimethoate Use to the Federally-Listed California Red Legged Frog,
USEPA, January 32, 2008
4) Status Of The San Francisco Garter Snake (Thamnophis Sirtalis Tetrataenia) At
Pacifica Quarry, San Mateo
5) Pg. II-14 of Project Description for Redevelopment Plan for the Treasure Island /
Yerba Buena Island Redevelopment Project
8
Recovery Plan
for the
California Red-legged Frog
(Rana aurora draytonii)
Region 1
U.S. Fish and Wildlife Service
Portland, Oregon
ii
Disclaimer
Recovery plans delineate reasonable actions that are believed to be required to recover and/or
protect listed species. Plans are published by the U.S. Fish and Wildlife Service, and
sometimes are prepared with the assistance of recovery teams, contractors, State agencies, and
others. Objectives will be attained and any necessary funds made available subject to
budgetary and other constraints affecting the parties involved, as well as the need to address
other priorities. Recovery plans do not necessarily represent the views nor the official positions
or approval of any individuals or agencies involved in the plan formulation, other than the U.S.
Fish and Wildlife Service. They represent the official position of the U.S. Fish and Wildlife
Service only after they have been signed by the Director, Regional Director, or Manager as
approved. Approved recovery plans are subject to modification as dictated by new findings,
changes in species status, and the completion of recovery tasks.
Literature Citation Should Read As Follows:
U.S. Fish and Wildlife Service. 2002. Recovery Plan for the California Red-legged Frog (Rana
aurora draytonii). U.S. Fish and Wildlife Service, Portland, Oregon. viii + 173 pp.
Additional copies may be purchased from:
Fish and Wildlife Reference Service

5430 Grosvenor Lane, Suite 110
Bethesda, Maryland 20814-2158
301-492-6403 or 1-800-582-3421
FAX: 301-564-4059
E-mail: fwrs@mail.fws.gov
http://fa.r9.fws.gov/r9fwrs/
The fee for the plan varies depending on the number of pages of the plan.
An electronic version of this recovery plan will also be made available at

http://www.r1.fws.gov/ecoservices/endangered/recovery/default.htm
iii
Acknowledgements
Primary Authors
Ina Pisani of the Sacramento Fish and Wildlife Office, U.S. Fish and Wildlife Service,
Sacramento, California acted as the Recovery Team Manager and prepared this recovery
plan. Recovery plan preparation was supervised and edited by Karen Miller, Diane Elam,
and Carmen Thomas, Sacramento Fish and Wildlife Office.
Acknowledgements
Grace McLaughlin of the Ventura Fish and Wildlife Office provided technical input on
many aspects of this recovery plan. In particular, Ms. McLaughlin provided assistance in
the delineation of recovery units and core areas and compiled Appendix B which
addresses the potential effects of contaminants on the California red-legged frog.
Each member of the California red-legged frog recovery team contributed valuable
information and assistance. In particular, we gratefully acknowledge the efforts of
Norman Scott and Galen Rathbun of the U.S. Geological Survey, Biological Resources
Division, Western Ecological Research Center, Piedras Blancas Field Station and Mark
Jennings for preparing the appendices that address pond management and
reestablishment of California red-legged frogs, and for being generous with their
technical assistance and time throughout the development of this recovery plan. We
thank them also for their thorough editorial review. In addition, we wish to thank
William Cunningham of the Natural Resources Conservation Service and Amy Lind of
the U.S. Forest Service for preparing the appendix that lists existing incentive programs.
The following individuals contributed significant information/assistance during recovery

plan preparation (California red-legged frog recovery team members are italicized):
Paul Barrett Michael Jani Steven Morey

Steven Bobzien Mark Jennings Dave Pereksta
Maria Boroja Douglas Krofta Galen Rathbun
Patricia Bratcher Sheila Larsen Mark Rentz
Sara Lee Chubb Amy Lind Lisa Roberts
David Cook Laurie Litman Tamara Sasaki
William W. Cunningham Ivette Loredo Norman Scott
Joseph Didonato Ed Lorentzen William Shook
Gary Fellers Sheila Massey John Steuber
Darren Fong Curt McCasland Terry Strange
Catherine Hibbard Tony McKinney Kate Symonds
Joshua Hoffman Grace McLaughlin Brad Valentine
Steve Holzman Meri Moore Phil Zentner
Illustrations are courtesy of the California Department of Fish and Game.

iv
Executive Summary
Current Species Status: The California red-legged frog (Rana aurora draytonii) is federally
listed as threatened. This subspecies of red-legged frog occurs from sea level to elevations of
about 1,500 meters (5,200 feet). It has been extirpated from 70 percent of its former range and
now is found primarily in coastal drainages of central California, from Marin County,
California, south to northern Baja California, Mexico. Potential threats to the species include
elimination or degradation of habitat from land development and land use activities and habitat
invasion by non-native aquatic species.
Habitat Requirements: The California red-legged frog requires a variety of habitat elements
with aquatic breeding areas embedded within a matrix of riparian and upland dispersal
habitats. Breeding sites of the California red-legged frog are in aquatic habitats including pools
and backwaters within streams and creeks, ponds, marshes, springs, sag ponds, dune ponds and
lagoons. Additionally, California red-legged frogs frequently breed in artificial impoundments
such as stock ponds.
Recovery Objective: The objective of this plan is to reduce threats and improve the
population status of the California red-legged frog sufficiently to warrant delisting.
Recovery Priority Number: 6C, per criteria published by Federal Register Notice (48 FR
43098; September 21, 1983). This number indicates a subspecies with high threats and low
recovery potential, in conflict with development projects.
Recovery Criteria: This subspecies will be considered for delisting when:
1) Suitable habitats within all core areas (described in Section II of this recovery plan) are
protected and/or managed for California red-legged frogs in perpetuity, and the ecological
integrity of these areas is not threatened by adverse anthropogenic habitat modification
(including indirect effects of upstream/downstream land uses);
2) Existing populations, throughout the range, are stable (i.e., reproductive rates allow for long
term viability without human intervention). Population status will be documented through
establishment and implementation of a scientifically acceptable population monitoring
program for at least a 15-year period, which is approximately 4 to 5 generations of the
California red-legged frog. This 15-year period will preferably include an average
precipitation cycle. An average precipitation cycle is a period when annual rainfall includes
average to 35 percent above-average through greater than 35 percent below-average and
back to average or greater. The direction of change is unimportant in this criterion.
3) Populations are geographically distributed in a manner that allows for the continued
existence of viable metapopulations despite fluctuations in the status of individual
populations (i.e. when populations are stable or increasing at each core area);
4) The subspecies is successfully reestablished in portions of its historic range such that at
least one reestablished population is stable/increasing at each core area where frogs are
currently absent; and
Recovery Plan for the California Red-legged Frog v
5) The amount of additional habitat needed for population connectivity, recolonization, and
dispersal has been determined, protected, and managed for California red-legged frogs.
Actions Needed:
1. Protect known populations and reestablish populations.
2. Protect suitable habitat, corridors, and core areas.
3. Develop and implement management plans for preserved habitat, occupied watersheds, and
core areas.
4. Develop land use guidelines.
5. Gather biological and ecological data necessary for conservation of the species.
6. Monitor existing populations and conduct surveys for new populations.
7. Establish an outreach program.
Estimated Cost of Recovery: $10,031,500 plus costs that are not yet determined.
Date of Recovery: Delisting could occur by 2025 if recovery criteria have been met.
vi Recovery Plan for the California Red-legged Frog
“Smiley was monstrous proud of his

frog, and well he might be, for
fellers that had traveled and been
everywheres all said he laid over
any frog that they ever see.”
—Mark Twain, Celebrated Jumping Frog of
Calaveras County
(Most historians and scientists believe that the

California red-legged frog inspired Mark Twain
to write his short story.)
vii
Table of Contents
Executive Summary.. .............................................................................................................. iv
I. Introduction ...................................................................................................................... 1
A. Brief Overview .............................................................................................................. 1
B. Species Description ....................................................................................................... 2
C. Historic and Current Distribution. ................................................................................. 2
D. Habitat ......................................................................................................................... 12
E. Life History and Ecology ............................................................................................. 15
F. Reasons for Decline and Threats to Survival ............................................................... 17
G. Regulatory Protection and Conservation Measures .................................................... 30
H. Associated Species ...................................................................................................... 38
II. Recovery .......................................................................................................................... 45

A. Recovery Objectives and Strategies ............................................................................ 45
B. Recovery Criteria. ........................................................................................................ 46
C. Recovery Units ............................................................................................................ 47
D. Core Areas for Focused Recovery Efforts ................................................................... 50
E. Effects of the Recovery Strategy on Associated Species ............................................. 57
III. Outline of Recovery Actions .......................................................................................... 61

A. Guidance for Development of Watershed Management Plans and
Implementation of Recovery Tasks ........................................................................... 61
B. Recovery Tasks ......................................................................................................... 73
IV. Implementation Schedule .............................................................................................. 89
V. References ..................................................................................................................... 103

A. Literature Cited .......................................................................................................... 103
B. Personal Communications ......................................................................................... 113
C. In litt. References ....................................................................................................... 114
VI. Appendices ..................................................................................................................... 117

Appendix A. Glossary of Technical Terms ..................................................................... 117
Appendix B. Potential Contaminants Associated with California Red-legged Frog
Habitat ....................................................................................................... 120
Appendix C. Maps of Core Areas Per County ............................................................... 130
Appendix D.Guidelines for Voluntary Pond Management for the Benefit of
California Red-legged Frogs ..................................................................... 151
Appendix E. Private Landowner Incentives for Implementation of Conservation
Measures ................................................................................................... 154
Appendix F. Code of Practice to Reduce Spread of Disease and Parasites .................... 162
Appendix G. General Guidelines for Reestablishment of California Red-legged
Frog Populations ....................................................................................... 163
Appendix H. Summary of the Agency and Public Comment on the Draft Recovery
Plan for the California Red-legged Frog .................................................. 166
viii Recovery Plan for the California Red-legged Frog
List of Tables
Table 1. Number of streams per county where California red-legged frogs are present,
post-1985 ................................................................................................................. 1
Table 2. Sensitive fish and wildlife species associated with the California
red-legged frog ...................................................................................................... 37
Table 3. Threats to California red-legged frogs and recovery potential per recovery unit . 45
Table 4. Recovery goals and tasks aimed at eliminating threats ......................................... 48
Table 5. Selection criteria for core areas and importance of core areas for recovery ......... 54
Table 6. Core areas targeted for development and implementation of management and
protection plans for the California red-legged frog. .............................................. 74
List of Figures
Figure 1. Adult California red-legged frog ............................................................................. 2
Figure 2. California red-legged frog egg mass, tadpole, and new metamorph ....................... 3
Figure 3. Historic range of the California red-legged frog by county .................................... 4
Figure 4. Current range of the California red-legged frog by county ..................................... 5
Figure 5. California red-legged frog recovery units ............................................................... 6
Figure 6. Aerial view of breeding areas ................................................................................ 13
Figure 7. Breeding habitat at Ledson Marsh, Sonoma County ............................................. 14
Figure 8. Breeding pool and streamside vegetation in Round Valley Creek,

Contra Costa County ............................................................................................. 14
Figure 9. Dune swale breeding pond on Vandenberg Air Force Base, Santa Barbara
County and breeding habitat in a stockpond on Camp Ohlone Regional Park,
Alameda County .................................................................................................... 15
Figure 10. Comparison of the California red-legged frog and bullfrog .................................. 25
Figure 11. Predation by a bullfrog .......................................................................................... 26
Figure 12. California red-legged frog core area distribution .................................................. 51

1
I. Introduction
A. BRIEF OVERVIEW Service 1992) with substantial information

indicating the requested action may be
The California red-legged frog (Rana aurora warranted. On July 19, 1993, we published a
draytonii) is endemic to California and Baja 12-month finding on the petitioned action
California, Mexico, and its known elevational (U.S. Fish and Wildlife Service 1993)
range extends from near sea level to indicating that listing of the California red-
elevations of about 1,500 meters (5,200 feet). legged frog was warranted and that a
Nearly all sightings have occurred below proposed rule would be published promptly.
1,050 meters (3,500 feet) (Natural Diversity On February 2, 1994, we published a
Database 2001). The species has been proposal to list the California red-legged frog
extirpated from 70 percent of its former range as an endangered species (U.S. Fish and
and now is found primarily in coastal Wildlife Service 1994a). Based on
drainages of central California, from Marin information received during the comment
County, California, south to northern Baja period on the proposed rule, we determined
California, Mexico, and in isolated drainages the California red-legged frog to be a
in the Sierra Nevada, northern Coast, and threatened species; the listing was effective
northern Transverse Ranges (U.S. Fish and on June 24, 1996 (U.S. Fish and Wildlife
Wildlife Service 1996a). Populations remain Service 1996a). The recovery priority number
in approximately 256 streams or drainages in of the California red-legged frog is 6C,
28 counties (Table 1). indicating a subspecies with a high degree of
threat and low recovery potential. Recovery
The California red-legged frog is threatened
within its remaining range, by a wide variety
of human impacts to its habitat, including Table 1. Number of streams per county (north to south) where
urban encroachment, construction of California red-legged frogs are present, post-1985 (Natural Diversity
reservoirs and water diversions, Database 2001, M. Jennings in litt. 1993).
contaminants, agriculture, and livestock
grazing. These activities can destroy, degrade, County Number of Streams County Number of Streams
and fragment habitat. The introduction of
non-native predators and competitors also El Dorado 2 San Mateo 22
continues to threaten the viability of many
California red-legged frog populations. Plumas 1 Santa Clara 21
Butte 1 Santa Cruz 17
The California red-legged frog was included Yuba 1 Stanislaus 2
as a Category 1 candidate species in our (U.S. Placer 1 Fresno 1
Fish and Wildlife Service) November 21,
1991, Animal Notice of Review (U.S. Fish Tehama 1 Merced 5
and Wildlife Service 1991). On January 29, Napa 5 San Benito 5
1992, we received a petition from Dr. Mark Sonoma 3 Monterey 32
R. Jennings, Dr. Marc P. Hayes, and Mr. Dan Solano 6 Kern 1
Holland to list the California red-legged frog.
On October 5, 1992, we published a 90-day Marin 19 San Luis Obispo 30
petition finding (U.S. Fish and Wildlife Contra Costa 21 Santa Barbara 35
San Joaquin 2 Ventura 6
Alameda 12 Los Angeles 2
NOTE: In this document the term “frog” San Francisco 1 Riverside 1
refers to the California red-legged frog unless
otherwise indicated.
2 Recovery Plan for the California Red-legged Frog
priority numbers are based on criteria pink; the back is characterized by small black
published by Federal Register Notice (48 FR flecks and larger irregular dark blotches with
43098; September 21, 1983). indistinct outlines on a brown, gray, olive, or
reddish-brown background color. Dorsal
spots usually have light centers (Stebbins
B. SPECIES DESCRIPTION 1985). Dorsolateral folds (the ridges of skin
along the back) are prominent (Figure 1).
Class - Amphibia Larvae (tadpoles) range from 14 to 80
Order - Anura millimeters (0.6 to 3.1 inches) in length, and
Family - Ranidae the background color of the body is dark
Genus - Rana brown or olive with darker spots (Figure 2)
Species - Rana aurora (Storer 1925). A line of very small, indistinct
Subspecies - Rana aurora draytonii gold-colored spots becomes the dorsolateral
fold (G. Rathbun in litt. 1998).
The California red-legged frog (Rana aurora
draytonii) is one of two subspecies of the red- Several morphological and behavioral
legged frog (Rana aurora). The other characteristics differentiate the two
subspecies is the northern red-legged frog (R. subspecies of red-legged frogs. Adult
a. aurora). The northern red-legged frog California red-legged frogs are larger than
ranges from Vancouver Island, British northern red-legged frogs by 35 to 40
Columbia, Canada, south along the Pacific millimeters (1.4 to 1.6 inches) (Hayes and
coast, west of the Cascade ranges to northern Miyamoto 1984). Dorsal spots of northern
California. Some red-legged frogs found in red-legged frogs usually lack the light centers
the intervening areas (southern Del Norte to that are common to California red-legged
northern Marin County along the Coast frogs (Stebbins 1985). The southern
Range), exhibit intergrade characteristics of subspecies (California red-legged frog) has
both subspecies (Hayes and Krempels 1986). paired vocal sacs and calls in air, whereas the
The two subspecies, and intergrades of the northern subspecies (northern red-legged
subspecies, may frog) lacks vocal sacs and calls under water
occur together in (Hayes and Krempels 1986, Licht 1969).
some areas such as Female California red-legged frogs deposit
the vicinity of Point egg masses (Figure 2) on emergent vegetation
Reyes National so that the masses float on the surface of the
Seashore in Marin water (Hayes and Miyamoto 1984) although
County, and portions biologists from the East Bay Regional Park
of Sonoma County. District have seen submerged egg masses
throughout the egg development stage on
The California red- numerous occasions (J. DiDonato in litt.
legged frog is the 2000). Northern red-legged frogs also attach
largest native frog in their eggs to emergent vegetation, but the
the western United mass is submerged (Licht 1969). California
States (Wright and red-legged frogs breed from November
Wright 1949). Adult through early April (Storer 1925) and
females attain a northern red-legged frogs breed from January
significantly longer through March (Nussbaum et al. 1983).
body length than
males (138
millimeters [5.4 C. HISTORIC AND CURRENT DISTRIBUTION
inches] versus 116
Figure 1. Adult millimeters [4.5 It is believed that before the arrival of
California red- inches] snout-urostyle length) (Hayes and Europeans on the west coast of North
legged frog. Miyamoto 1984). The posterior abdomen and America, the California red-legged frog was
Photo © Steven Bobzien hind legs of adults are often red or salmon common in coastal habitats from the vicinity
Recovery Plan for the California Red-legged Frog 3
of Point Reyes National Seashore, Marin

County, California, and inland from the
vicinity of Redding, Shasta County,
California, southward to northwestern Baja
California, Mexico (Jennings and Hayes
1985, Hayes and Krempels 1986).
Historically, the California red-legged frog
was known from 46 counties (Figure 3) but
the taxon is now extirpated from 24 of these
(U.S. Fish and Wildlife Service 1996a).
The California red-legged frog is now known

only from isolated localities in the Sierra
Nevada, northern Coast, and northern
Transverse Ranges. It is believed to be nearly
extirpated from the southern Transverse and
Peninsular ranges. This species is still
common in the San Francisco Bay area
(including Marin County) and along the
central coast (Figure 4) ( Natural Diversity
Data Base 2001, Jennings in litt. 1998a). It is
still present in Baja California, Mexico, but
this recovery plan does not address
populations in Mexico.
The following paragraphs discuss, in general,

the status of the California red-legged frog in
each of the recovery units (north to south). Figure 2. California
Briefly, there are eight recovery units (Figure red-legged frog egg
5). These include the following regions: mass (top)
Photo © David Cook
Sierra Nevada Foothills and Central Valley;
Tadpole (center)
North Coast Range Foothills and Western Photo © Steven Bobzien
Sacramento River Valley; North Coast and New metamorph
North San Francisco Bay; South and East San (bottom)
Francisco Bay; Central Coast; Diablo Range Photo © Robert Snow
and Salinas Valley; Northern Transverse
Ranges and Tehachapi Mountains; and
Southern Transverse and Peninsular Ranges.
Recovery units are identified and described in
more detail below and in the Recovery
chapter (Section II.C). Detailed locality
information is available through the
California Department of Fish and Game’s
Natural Diversity Database (Natural Diversity
Database 2001).
Under the discussion of each recovery unit,

watersheds occupied by the California red-
legged frog are listed; a watershed is
considered occupied when the presence of the
species is confirmed. Watersheds are used
here because California red-legged frogs can
be found in a range of habitats within a
watershed (e.g., stock ponds, creeks) and “locality” is used (e.g., the Pescadero Marsh
because they may be known from a single locality or the Spivey Pond locality versus the
location or numerous locations within a broader Scott Creek drainage).
watershed. Thus, an occupied watershed
refers to an assumed network of habitat areas, Because populations of frogs may be
populations, and site-specific localities. extirpated with some frequency, occurrence
Occupied drainages or watersheds include all data may not adequately describe the status of
of the bodies of water that support frogs (i.e., the species in a region. This limitation may be
streams, creeks, tributaries, associated natural the result of a lack of long term survey data, a
and artificial ponds, and adjacent drainages), lack of complete survey data (due to
and habitats through which frogs can move restricted access to private lands), and
(i.e., riparian vegetation, uplands). Where fluctuations in population numbers. The
frogs are known from a particular location numbers at a site or series of sites can vary
within a drainage, the more specific term widely from year to year. When conditions
are favorable, California red-legged frogs can
experience extremely high rates of
reproduction and produce large numbers of
dispersing young and a concomitant increase
in number of occupied sites. Conversely,
frogs may temporarily disappear from a
normally occupied area. At sites where frogs
seem absent, long-term monitoring is
necessary to determine if these sites are
recolonized or “rescued” by dispersers from
nearby subpopulations. Therefore, the
information on distribution and status should
be understood within the context of the larger
metapopulation scale (Scott and Rathbun in
litt. 1998). In this plan, metapopulations are
considered collections of populations that are
Figure 3. Historic
range of the
California red-
legged frog in the
United States by
county.
linked by migrants (i.e., dispersers), allowing (Jennings et al. in litt. 1992). Elimination of
for recolonization of unoccupied habitat the frog from the floor of the valley was
patches after local extinction events. particularly significant in that it isolated
Sierra-Nevada foothill populations that may
Sierra Nevada Foothills and Central Valley. have depended on immigrants from the valley
The California red-legged frog was probably floor (Jennings et al. in litt. 1992). However,
extirpated from the floor of the Central Valley California red-legged frogs may never have
before 1960 (U.S. Fish and Wildlife Service been widespread on the valley floor as
1996a). The last verifiable record of this specimen-based records are scarce north of
species on the valley floor was a sighting in the Kern River drainage.
Lodi (San Joaquin County) in 1957, and the
last record of a reproducing population on the California red-legged frogs historically
valley floor is from the vicinity of Gray occupied portions of the western slope of the
Lodge Wildlife Area (Butte County) around Sierra Nevada from Shasta County south to
1947, although this record is unverified Tulare County, but these populations have
been fragmented and nearly eliminated. In
1960, isolated populations were known from
at least 30 Sierra Nevada foothill drainages
bordering the Central Valley. Records show
that the lower elevations of some National
Forests and Yosemite National Park were
once occupied by California red-legged frogs
(M. Jennings et al. in litt. 1992). Adjacent to
and in the vicinity of the Plumas National
Forest (Butte, Yuba, and Plumas Counties),
many sightings of California red-legged frogs
were reported in the early 1960s near Lake
Oroville. Specifically, frogs were verified
from the North Fork Feather River and the
Figure 4. Current
range of the
California red-
legged frog in the
United States by
county.
Recovery Units
1. Sierra Nevada Foothills and Central Valley
2. North Coast Range Foothills and
Western Sacramento River Valley
3. North Coast and North San Francisco Bay
4. South and East San Francisco Bay
5. Central Coast
6. Diablo Range and Salinas Valley
7. Northern Transverse Ranges and Tehachapi
Mountains
8. Southern Transverse and Peninsular Ranges
Figure 5. California
red-legged frog
recovery units.
South Fork Feather River in 1961. In El reproduction appears to be highly successful

Dorado County, records exist for Rock Creek at this site (S. Barry in litt. 2000). California
in 1974 and Traverse Creek in 1975. Within red-legged frogs have been observed on
the vicinity of the Stanislaus National Forest, Indian Creek, near the town of Woodleaf
California red-legged frogs were seen in San from 1973 to 1983 (Jennings et al. in litt.
Antonio Creek (Calaveras County) in 1975, 1992). Each of these Butte County
in Jordon Creek in 1967, and in Piney Creek populations is located on private lands,
from 1972 to 1984 (Mariposa County). adjacent to the Plumas National Forest. An
Within the vicinity of the Tuolumne River, additional site in Butte County was located in
many historic sites exist. For example, a 2000, on the Feather River Ranger District of
collection from the Mather vicinity was taken the Plumas National Forest on a tributary to
in 1922, and again in 1945. Within Yosemite the North Fork Yuba River west of New
National Park, collections were made from Bullards Bar Reservoir (C. Roberts pers.
Gravel Pit Lake (about 1,500 meters [5,000 comm. 2000, Barry 2000). In El Dorado
feet]) in 1940, Swamp Lake (1,500 meters County near Placerville, a confirmed
[5,000 feet]) from 1938 to 1941, and Miguel population of California red-legged frog was
Meadows (1,600 meters [5,200 feet]) in 1939 discovered in an impoundment (Spivey Pond)
(M. Jennings et al. in litt. 1992). These in the North Fork of Weber Creek. In 2 years
collections represent the highest elevation of surveys at this site (1997 and 1998), adults,
records for the California red-legged frog in egg masses, and tadpoles have been observed.
the Sierra Nevada. No confirmed sightings In 2001, a California red-legged frog was
have been observed or collected in the documented near the confluence of Rubicon
Tuolumne River drainage for several decades. River and the Middle Fork of the American
In the southernmost Sierran foothills, frogs River in Placer County (G. Fellers in litt.
were historically located within Kern County, 2001). This locality is on U.S. Forest Service
particularly in streams and irrigation ditches land. Much of the Sierra Nevada range is
near Bakersfield (Natural Diversity Data Base unsurveyed, particularly on private lands, and
2001, Jennings in litt. 1998a). therefore the true status in this region is
largely unknown.
Currently, only a few drainages in the
foothills of the Sierra Nevada are known to North Coast Range Foothills and Western
support California red-legged frogs, Sacramento River Valley. Historically, the
compared to over 60 known historic localities California red-legged frog was found in
and 18 historic sites where specimens were several counties in this region. In the 1960s,
collected (Jennings and Hayes 1992, Barry frogs were found in Glenn County east of Elk
1999). In 1991, California red-legged frogs Creek and in many drainages in Colusa
were observed at Pinkard Creek in Butte County. In 1986 and 1987, California red-
County (1,200 meters [3,500 feet]) (Hayes legged frogs were reported in Sunflower
1991). However, intensive surveys in Gulch and Cottonwood Creek, west of Red
subsequent years have failed to reveal Bluff (Tehama County), but subsequent
additional observations of this species. In surveys documented only bullfrogs (Rana
recent surveys a population of mountain catesbeiana) (M. Jennings pers. comm.
yellow-legged frogs (Rana muscosa) was 1998). Within the vicinity of Clear Lake
observed, suggesting that the original (Lake County), records exist from 1961 near
observation may have been a mountain the town of Hobergs, on Cold Creek. Barry
yellow-legged frog misidentified as a (in litt. 2000) observed California red-legged
California red-legged frog. Additional frogs along Pope Creek and several
locations in Butte County include French and tributaries near Pope Valley in the Putah
Indian Creeks. The French Creek population, Creek drainage throughout the 1970s and
also referred to as the Swayne Hill/Chino 1980s, and the habitat in this area remains
Creek population, was discovered in 1997; at unaltered. There are three confirmed sightings
least a few hundred adults plus tadpoles and of this species in upper Napa County: from
juveniles have been observed and 1983, along Highway 128 between Highway
121 and Wragg Canyon Road, and from 1992 San Francisco County including Lake
and 1997, along nearby Steele Creek which is Merced, Golden Gate Park, and the Presidio.
a tributary to Lake Berryessa (S. Barry in litt. The most recent sighting was in 1993, near
2000). Recently, unverified sightings have Strybing Arboretum in Golden Gate Park.
been reported in the vicinity of the Stebbins These populations may have been introduced
Cold Canyon Ecological Reserve, Cache for commercial harvesting or may be relics of
Creek, and tributaries to Clear Lake (Lake a larger metapopulation. Currently, it is likely
County) (M. Jennings pers. comm. 1998). that these populations face such severe
California red-legged frogs were also barriers that dispersal between populations
documented in 1998 in a tributary to may be precluded. Canals within the West of
American Canyon Creek in lower Napa Bayshore parcel, near the San Francisco
County (Natural Diversity Database 2001). International Airport in San Mateo County,
currently support California red-legged frogs.
North Coast and North San Francisco Bay. This population experienced a decline over
Significant numbers of California red-legged the past several years due to site management
frogs occur in small coastal drainages, ponds, activities and tidal influences (U.S. Fish and
and man-made stockponds in the vicinity of Wildlife Service 1996b). However, data
Point Reyes, including Point Reyes National collected at the site since 1996 indicate that
Seashore and Golden Gate National the localized population contained more
Recreation Area (Marin County). For individuals than previously thought.
example, large numbers of frogs occur in Numerous individuals of all size classes have
Olema Marsh and the general vicinity of been observed and few bullfrogs are present.
Drakes Estero (Point Reyes National Breeding has been confirmed in some
Seashore). Many areas within the vicinity of seasonal impoundments and within the canal
Mount Tamalpais and the Tiburon peninsula system. The population, however, is isolated
(Marin County) also support California red- by residential development (M. Allaback in
legged frogs, including Tennessee Valley litt. 2000).
(Natural Diversity Database 2001, D. Fong in
litt. 1998). Contra Costa and Alameda Counties contain
the majority of known California red-legged
A large breeding population is located at frog localities within the San Francisco Bay
Ledson Marsh in Annadel State Park area, although they seem to have been nearly
(Sonoma County). Also in Sonoma County, eliminated from the western lowland portions
two sightings of California red-legged frogs of these counties (west of Highway 80 and
have been verified near Sears Point at the Highway 580), particularly near urbanization.
junction of Highway 37 and Lakeville Road California red-legged frogs still occur in
and the junction of Highway 37 and Highway small isolated populations in the East Bay
121 (Natural Diversity Database 2001). foothills (between Highway 580 and
Highway 680), and are thriving in several
In Solano County, there are three known areas in the eastern portions of Alameda and
occurrences of California red-legged frogs Contra Costa Counties. Numerous ponds and
near Suisun Marsh (e.g., Sulphur Springs creeks in Simas Valley (Contra Costa County)
Creek). Several localities are recorded near support California red-legged frogs (Dunne
the cities of Fairfield, Cordelia, American 1995). This area, owned and managed in part
Canyon, and Vallejo (Natural Diversity by East Bay Municipal Utility District,
Database 2001). Most remaining known includes Rodeo and Pinole Creeks, and is
occurrences in the vicinity of southern Solano connected with Briones and Wildcat Canyon
County are threatened by proposed Regional Parks (East Bay Regional Park
development (C. McCasland in litt. 1998a). District). On East Bay Regional Park lands,
sizeable breeding populations are found at
South and East San Francisco Bay. In the Pine Creek (Diablo Foothills Regional Park/
late 1800s and early 1900s, California red- Castle Rock Regional Recreation Area), Sand
legged frogs were reported in various areas of Creek (Black Diamond Mines Regional
Park), and Round Valley Creek (Round Larson pers. comm. 1998). Pescadero Marsh
Valley Regional Preserve) (S. Bobzien in litt. and Año Nuevo State Reserve (San Mateo
1998). Recently, frogs have been sighted in County) support large numbers of California
small ponds and seeps in the foothills of red-legged frogs; Pescadero Marsh is
Mount Diablo (M. Westphal pers. comm. considered one of the few places, throughout
1998). California red-legged frogs are present the range, to support more than 350 adult
in Kellogg Creek watershed and its tributaries frogs. Almost all coastal drainages from the
upstream of Los Vaqueros Reservoir and Santa Cruz/San Mateo County line south to
downstream to Vasco Road in eastern Contra the city of Santa Cruz are occupied by
Costa County. Here, 87 of 91 stockponds and California red-legged frogs. Wilder Ranch
mitigation wetlands have reproducing State Park (Santa Cruz County) also supports
populations. Recent surveys (September this species. The frogs occur in the Carmel
2000) recorded nearly 3,000 individuals. River watershed and most of its tributaries
Conservative estimates for the total (Natural Diversity Database 2001, EIP
population range from 7,000 to as high as Associates 1993); Rancho San Carlos, a
10,000 post-metamorph frogs (J. Alvarez in private ranch on the upper portion of the
litt. 2000). Many localities occur in Corral Carmel River Valley is another locality where
Hollow Creek, in San Joaquin County, and more than 350 adults have been observed (M.
near the San Joaquin/Alameda County border. Jennings et al. in litt. 1992).
In the Corral Hollow watershed, frogs are
found in the California Department of Fish This species is widespread in Monterey
and Game’s Corral Hollow State Ecological County; nearly all coastal drainages from
Reserve, although this Reserve is currently Garrapata Creek south to Salmon Creek,
threatened by siltation possibly caused and/or including the Little and Big Sur drainages and
exacerbated by an off-road vehicle park, the vicinity of Pfeiffer Beach, support frogs.
livestock grazing, and urban development up- In San Luis Obispo County, California red-
and downstream (M. Jennings in litt. 1993, legged frogs are found in many streams, stock
Jennings and Hayes 1994). Adult frogs have ponds, dune ponds, and springs on the coastal
been observed in Upper Alameda Creek plain and western slopes of the Santa Lucia
(Sunol Regional Wilderness) and also in Range from San Carpoforo Creek in the north
many of the creeks from this area, south to to the Santa Maria River in the south. Sites
Henry W. Coe State Park (e.g., Arroyo Hondo include Pico, Little Pico, and Toro Creeks;
and Sulphur, Smith, Isabel, and San Felipe Pico Pond; and San Simeon, Santa Rosa,
Creeks) (Santa Clara County). California red- Chorro, and Arroyo Grande Creeks. On Camp
legged frogs currently occupy many ponds San Luis Obispo of the California National
and creeks within Henry W. Coe State Park in Guard, frogs occur in Whiskey Spring,
Santa Clara County (M. Jennings et al. in litt. tributaries to Chorro Creek and Chorro
1992, K. Freel in litt. 1998) and are abundant Reservoir, and other sites (Jennings et al. in
in many ponds in the Palassou Ridge area litt. 1992, U.S. Fish and Wildlife Service
south of Henry W. Coe State Park (L. Serpa 1996a).
in litt. 2000).
Diablo Range and Salinas Valley. California
Central Coast. The central coast from San red-legged frogs were once widespread and
Francisco to Santa Barbara County supports abundant in the inner Coast ranges between
the greatest number of currently occupied the Salinas River system and the San Joaquin
drainages. South of San Francisco, many Valley. Currently, no more than 10 percent of
California red-legged frogs occur in the historic localities within the Salinas River
tributaries to Crystal Springs Reservoir and hydrographic basin and inner Coast ranges
adjacent lands (San Mateo County) (Natural (between the Salinas basin and the San
Diversity Database 2001). Most coastal Joaquin River south of Pacheco Creek
streams and ponds (natural and artificial) drainage) still support this species (Jennings
from Pacifica south to Half Moon Bay (San and Hayes 1994).
Mateo County) support this species (S.
On the eastern side of the Diablo Range, there the most productive areas for red-legged
are several occurrences of red-legged frogs frogs in Santa Barbara County (Christopher
including Mine Creek in Fresno and Merced 1996). Most of this area occurs on
Counties; and Piedra Azul Creek and North Vandenberg Air Force Base. In this area,
Los Banos Creek in Merced County. Large California red-legged frogs are found in dune
populations have been recently reported on swale ponds; this habitat type has remained
Romero Ranch, and potential habitat exists on essentially undisturbed, and the conditions
the Simon Newman Ranch. These ranches are seem to be less suitable for introduced fishes,
located between Henry W. Coe State Park and crayfish, and bullfrogs because they dry
San Luis Reservoir. The Nature Conservancy completely in drought years. Jalama Lagoon
purchased these sites; it has since sold the also supports a relatively large population of
Romero Ranch and soon will sell Simon the California red-legged frog (Christopher
Newman Ranch with rare species protection 1996).
assured through conservation easements.
South of Henry W. Coe State Park and San The largest known populations in the northern
Luis Reservoir, California red-legged frogs Transverse Range are on upper Alamo Creek
are found in Quien Sabe and Tres Pinos (a tributary to Cuyama River), a northern
creeks, the Pajaro and San Benito rivers, and tributary to the Sisquoc River, and La Brea
the general vicinity of Hollister (San Benito Creek and its southern tributary Manzana
County) such as Santa Ana Creek, Creek (S. Sweet in litt. 2000).
Tequisquita Slough, and the Hollister Hills
State Vehicular Recreation Area. Numerous Populations of California red-legged frogs in
populations exist in Pinnacles National the lower Santa Ynez River Basin (Santa
Monument, particularly in Chalome and Bear Barbara County) are smaller and patchily
Gulch Creeks. (Natural Diversity Data Base distributed. In this basin, deep pools with
2001, M. Jennings in litt. 1998a). dense marginal vegetation are rare and
introduced aquatic predators are abundant and
The Elkhorn Slough watershed (Monterey diverse (Christopher 1996). California red-
County) currently supports this species. legged frogs are also found in fairly high
Within this area, adult California red-legged numbers in the upper Santa Ynez River basin,
frogs were observed at McClusky Slough in up to Lake Cachuma and its tributaries (S.
1996; this is a site where restoration efforts Christopher pers. comm. 1998); tributaries to
for the endangered Santa Cruz long-toed the Santa Ynez River (e.g., Salispuedes
salamander (Ambystoma macrodactylum Creek) also support California red-legged
croceum) are ongoing. Several adult frogs. The small coastal drainages between
California red-legged frogs have been Gaviota and Goleta also support California
observed in the Salinas River drainage (M. red-legged frogs (M. Jennings et al. in litt.
Jennings in litt. 1998). On Fort Hunter 1992, S. Christopher pers. comm. 1998, D.
Liggett Military Reserve, no current or Pereksta pers. comm. 1998) as do areas west
historic records of California red-legged frogs to Point Conception (P. Bloom in litt. 2000).
exist, but surveys are being conducted in this
area which includes the Nacimiento and San Drainages on the southern portion of the Los
Antonio Rivers (G. McLaughlin pers. comm. Padres National Forest such as Upper Santa
1998). Ynez, (in and above Jameson Reservoir),
Agua Caliente, Juncal, Indian, and Mono
Northern Transverse Ranges and Tehachapi Creeks still support California red-legged
Mountains. On the Santa Maria River, frogs. They were depleted significantly from
California red-legged frogs occur up- and the mainstem of Sespe Creek following a
downstream of Twitchell Reservoir (Natural 1979-1981 bullfrog invasion. However, they
Diversity Database 2001). To the south, the have persisted in low numbers in several of
lower drainage basin of San Antonio Creek, the tributaries. The species is also in decline
the adjacent San Antonio Terrace, and San in Piru Creek due to changes in flow regimes
Antonio Lagoon are considered to be among since the construction of Pyramid Dam in
1973 and the introduction of many predatory the Santa Monica mountains (Los Angeles
fish via the California aqueduct (P. Bloom in County); the last record was from 1976 (M.
litt. 2000). In the Santa Clara River Jennings in litt. 1998a). A recent discovery of
watershed, California red-legged frogs may California red-legged frogs was made in East
be found in the headwaters and tributaries of Las Virgenes Creek (Ventura County) in the
the Santa Clara River (Jennings et al. in Simi Hills, adjacent to the Santa Monica
litt.1992). To the east, in the Tehachapi Mountains National Recreation Area. No
Mountains, historic records (mid-1800s) of frogs were found in nearby streams (Las
California red-legged frogs exist in Kern Virgenes Creek, Palo Comado, Cheeseboro,
County in El Paso Creek and near Fort Tejon. and Liberty canyons) (Sapphos
In the 1980s, this species was observed in Environmental 1999). Current survey
Cedar Creek near Glennville and near the information suggests that this breeding
Kern and San Luis Obispo County line (M. population contains 20 to 25 adults, 10 to 15
Jennings et al. in litt. 1992). juveniles, and several hundred tadpoles (R.
Smith in litt. 2001).
Sweet and Leviton (1983 as cited in Jennings
1988a) reported the natural occurrence of the Today, in southern
Rangewide, and even within local
California red-legged frog on Santa Cruz California, south of
Island (Santa Barbara County). According to the Tehachapi
Jennings (1988a), it is likely that they were Mountains, populations, there is much variation in
introduced by Basque or French workers for California red-legged
consumption. Based on recent reports, the frogs are currently how frogs use their environment; in
frogs still exist on Santa Cruz Island (M. known from only a
Jennings in litt. 1998b). few locations,
some cases, they may complete their
compared to over 80
Southern Transverse Range and Peninsular historic records from
Ranges. The California red-legged frog was a this region. Former entire life cycle in a particular
common native frog in parts of Los Angeles, populations in the
San Bernardino, Orange, Riverside, and San Whitewater River habitat....and in other cases, they may
Diego Counties (Jennings et al. in litt. 1992). canyon (Riverside
Numerous records of California red-legged County), the eastern
seek multiple habitat types.
frogs exist from the 1930s, along the Mojave San Bernadino
River near Victorville (San Bernardino mountains, and
County), as well as along the San Luis Rey Sentenac Canyon in
River in San Diego County. The frog the San Felipe Creek system of the Southern
historically occurred in the San Gabriel Peninsular Ranges (San Diego County) have
Wilderness Area of the Angeles National not been observed since the 1960s (Jennings
Forest (Los Angeles County); until 1999, and Hayes 1994). The existing locations
there were no post-1970 observations in this include Amargosa Creek near Palmdale (Los
area or nearby parts of Angeles National Angeles County) and Cole Creek on The
Forest (Jennings 1993). In 1999, a population Nature Conservancy’s Santa Rosa Plateau
of California red-legged frogs was located on Ecological Reserve (Riverside County).
the Angeles National Forest in the San Current survey data suggest that the effective
Francisquito drainage. Current population population size has been severely reduced
estimates suggest that there are between 15 primarily due to predation by bullfrogs.
and 25 adults (R. Fischer pers. comm 2001). While this population contained greater than
However, this population is threatened by 10 breeding adults in the late 1980s to early
non-native predators (bullfrogs, crayfish, and 1990s, recent survey data suggests that only 2
non-native fish species), disease, and males remain. This area is the focus of
parasites. augmentation and reestablishment project
being pioneered by the U.S. Fish and Wildlife
Until a recent sighting, California red-legged Service, the Los Angeles Zoo, The Nature
frogs were considered to be extirpated from Conservancy, and the Mexican government.
D. HABITAT Scott and G. Rathbun in litt. 1998). The

following descriptions describe the range of
General Habitat. While nearly all of the habitat types used by the frog.
known California red-legged frog populations
have been documented below 1,050 meters Breeding Habitat. Breeding sites of the
(3,500 feet), some historical sightings were California red-legged frog are in a variety of
noted at elevations up to 1,500 meters (5,200 aquatic habitats; larvae, tadpoles, and
feet). Suitable habitat above 1,050 meters metamorphs have been collected from
(3,500 feet) may be more specific and may streams, deep pools, backwaters within
include such requirements as: quiet water streams and creeks, ponds, marshes, sag
refugia within 0.5 ponds, dune ponds, and lagoons. Breeding
kilometers (0.25 adults are often associated with deep (greater
Overall, populations are most likely to miles) during high than 0.7 meter [2 feet]) still or slow moving
water flows, water and dense, shrubby riparian or
emergent vegetation emergent vegetation (Hayes and Jennings
persist where multiple breeding areas present on a 1988), but frogs have been observed in
minimum of 25 shallow sections of streams that are not
are embedded within a matrix of percent of a pool or cloaked in riparian vegetation. Reis (1999)
pond margin, and found the greatest number of tadpoles
habitats used for dispersal. standing water that is occurring in study plots with water depths of
retained into late July 0.26 to 0.5 meters (10 to 20 inches). While
(S. Chubb in litt. frogs successfully breed in streams, high
1999). Expanded flows and cold temperatures in streams
surveys will provide information necessary to during the spring often make these sites risky
determine the elevational range limits of the environments for eggs and tadpoles.
California red-legged frog. California red-legged frogs also frequently
breed in artificial impoundments such as
California red-legged frogs live in a stock ponds. It is assumed, however, that
Mediterranean climate, which is characterized these ponds must have proper management of
by temporal and spatial changes in habitat hydroperiod, pond structure, vegetative cover,
quality. In addition to climatic fluctuations, and control of non-native predators, although
the habitats used by this species typically some stock ponds support frogs despite a lack
change in extent and suitability in response to of emergent vegetation cover and the
the dynamic nature of floodplain and fluvial presence of non-native predators (N. Scott
processes (i.e., natural water flow and and G. Rathbun in litt. 1998). Additional
sedimentation regimes that, in flux, create, research on the habitat requirements of the
modify, and eliminate deep pools, backwater California red-legged frog in artificial ponds
areas, ponds, marshes, and other aquatic may clarify this issue.
habitats) (N. Scott and G. Rathbun in litt.
1998). Therefore, the frog uses a variety of Dispersal and Use of Uplands and Riparian
areas, including various aquatic, riparian, and Areas. During periods of wet weather,
upland habitats (Figures 6, 7, 8, 9). starting with the first rains of fall, some
individuals may make overland excursions
Rangewide, and even within local through upland habitats. Most of these
populations, there is much variation in how overland movements occur at night. Evidence
frogs use their environment; in some cases, from marked and radio-tagged frogs on the
they may complete their entire life cycle in a San Luis Obispo County coast suggests that
particular habitat (i.e., a pond is suitable for frog movements, via upland habitats, of about
all life stages), and in other cases, they may 1.6 kilometers (1 mile) are possible over the
seek multiple habitat types. Overall, course of a wet season. Frogs have been
populations are most likely to persist where observed to make long-distance movements
multiple breeding areas are embedded within that are straight-line, point to point migrations
a matrix of habitats used for dispersal (N. rather than using corridors for moving in
Figure 6.
Aerial view of
between habitats (N. Scott and G. Rathbun in the amount of time California red-legged breeding areas
litt. 1998). Dispersing frogs in northern Santa frogs spend in upland habitats, patterns of surrounded by
Cruz County traveled distances from 0.40 use, and whether there is differential use of upland dispersal
kilometer (0.25 mile) to more than 3 uplands by juveniles, subadults, and adults. habitat.
kilometers (2 miles) without apparent regard Dispersal distances are considered to be Photo © Curt McCasland,
to topography, vegetation type, or riparian dependent on habitat availability and USFWS.
corridors (Bulger in litt.1998). environmental conditions (N. Scott and G.
Rathbun in litt. 1998).
During dry periods, the California red-legged
frog is rarely encountered far from water Frogs spend considerable time resting and
(Jennings et al. in litt. 1992). However, feeding in riparian
California red-legged frogs will sometimes vegetation when it is
disperse in response to receding water which present. It is believed
often occurs during the driest time of the year. that the moisture and
Frogs have been observed to make
For example, between September 20 and cover of the riparian
October 20 in 1999, 7 adults were observed plant community long-distance movements that are
moving through nearby uplands on the provide good
University of Santa Cruz campus as the foraging habitat and straight-line, point to point migrations
breeding pond dried (M. Allaback in litt. may facilitate
2000). dispersal in addition
to providing pools
rather than using corridors for moving
The manner in which California red-legged and backwater
frogs use upland habitats is not well aquatic areas for in between habitats.
understood; studies are currently examining breeding. California
red-legged frogs can

Breeding sites of the CLRF are in a be encountered
living within streams
at distances
variety of aquatic habitats: exceeding 3
kilometers (2 miles)
Stream from the breeding
site, and have been
Deep pools found up to 30
meters (100 feet)
Backwater areas from water in
adjacent dense
Ponds riparian vegetation,
for up to 77 days
Marshes (Rathbun et al.
1993).
Sag ponds
Summer Habitat.
Dune ponds California red-
legged frogs often
Lagoons disperse from their
breeding habitat to
forage and seek
summer habitat if water is not available. This
Figure 8. Breeding
summer habitat could include spaces under
pool and streamside
boulders or rocks and organic debris, such as
vegetation in Round
downed trees or logs; industrial debris; and
Valley Creek, Contra
agricultural features, such as drains, watering
Costa County.
troughs, abandoned sheds, or hay-ricks. Photo © Steven Bobzien
Figure 7. California red-legged frogs use small

Breeding habitat in mammal burrows and moist leaf litter
Ledson Marsh, (Jennings and Hayes 1994); incised stream
Sonoma County. channels with portions narrower and deeper
Photo © David Cook than 46 centimeters (18 inches) may also
provide habitat (U.S. Fish and Wildlife
Service 1996a). This depth may no longer be
an accurate estimate of preferred depth for
this species as individuals have been found
using channels and pools of various depths.
Most observations are associated with depths
greater than 25 cm (10 inches). For example,
M. Allaback (in litt. 2000) has observed
numerous red-legged frogs inhabiting stream
channels with pools that are less than 46
centimeters (18 inches) deep, particularly in
north coastal Santa Cruz County and
generally from late spring to the fall. Some of
the observations have been along tributaries
where there are no pools that are 46 centi-
meters (18 inches deep) for several thousand
feet. At one site, along a tributary to Liddell
Creek (Santa Cruz County), the same indivi-

duals were seen at the same streamside loca-
tions for several weeks in late summer during
a monitoring project. Pool depth averaged
approximately 30 centimeters (12 inches). In
2000, an adult red-legged frog was observed
in shallow, 5 centimeter (2 inch) deep riffle
habitat in a disturbed drainage in lower Little
Bull Valley (Contra Costa County). Here, no
pool or pond habitat was present within
approximately 300 meters (1,000 feet).
California red-legged frogs use large cracks

in the bottom of dried ponds as refugia.
Approximately 25 red-legged frogs were
observed using open cracks in the bottom of
three separate dried ponds. At least one pond
was dry for more than 2 months when adult
frogs were found deep in the cracks of the
pond bottom. Many cracks within which
frogs were found were damp at a depth of 46
centimeters (18 inches). These cracks may
have provided moisture for frogs that were
also avoiding predation and solar exposure (J.
Alvarez in litt. 2000). Dispersal and habitat
use, however, is not observed in all studied
red-legged frogs and is most likely dependent
upon climatic conditions, habitat suitability,
and varying requisites of each life stage.
Water Quality. California red-legged frogs

are sensitive to high salinity, which often
occurs in coastal lagoon habitats. When eggs
Figure 9. Dune swale
are exposed to salinity levels greater than 4.5
breeding pond on
parts per thousand, 100 percent mortality 1998) indicated that California red-legged Vandenberg Air
occurs (Jennings and Hayes 1990). Larvae die frogs were absent when temperatures exceed Force Base, Santa
when exposed to salinity levels greater than 22 degrees Celsius (70 degrees Fahrenheit), Barbara County
7.0 parts per thousand (M. Jennings in litt. particularly when the temperature throughout (top).
1993). Reis (1999) found that the proportion a pool was this high and there are no cool, Photo © Ina Pisani
of study plots without tadpoles was greatest deep portions.
among plots with salinity levels greater than Breeding habitat in a
6.6 parts per thousand. stockpond on Ohlone
E. LIFE HISTORY AND ECOLOGY Regional Wilderness,
Early embryos of northern red-legged frogs Alameda County
are tolerant of temperatures only between 9 Reproduction. California red-legged frogs (bottom).
and 21 degrees Celsius (48 and 70 degrees breed from November through April (Storer Photo © Steven Bobzien
Fahrenheit) (Nussbaum et al. 1983). Study 1925). Males appear at breeding sites from 2
plots at Pescadero Marsh (San Mateo County) to 4 weeks before females (Storer 1925). At
with the greatest number of California red- these sites, males frequently call in small
legged frog tadpoles had mean water groups of two to seven individuals, although
temperatures between 15.0 and 24.9 degrees in some instances they may call individually
Celsius (60 to 75 degrees Fahrenheit). (Jennings et al. in litt. 1992). Females are
Observations by S. Bobzien (pers.comm. attracted to the calling males. A pair in
amplexus (breeding position) moves to an Sexual maturity can be attained at 2 years of

oviposition site (the location where eggs are age by males and 3 years of age by females
laid) and the eggs are fertilized while being (Jennings and Hayes 1985); adults may live 8
attached to a brace. Braces include emergent to 10 years (Jennings et al. in litt. 1992),
vegetation such as bulrushes (Scirpus spp.) although the average life span is probably
and cattails (Typha spp.) or roots and twigs; much lower (N. Scott pers. comm. 1998).
the egg masses float on the surface of the Schmieder and Nauman (1994) reported that
water (Hayes and Miyamoto 1984). Each California red-legged frog larvae are highly
mass contains about 2,000 to 5,000 eggs that vulnerable to fish predation, especially
are each about 2.0 to 2.8 millimeter (0.08 to immediately after hatching, when the
0.11 inches) in diameter (Figure 8). The eggs nonfeeding larvae are relatively immobile.
are dark reddish brown (Storer 1925).
Activity Patterns and Movements. Hayes and
Growth and Development. Eggs hatch in 6 to Tennant (1985) found juvenile frogs to be
14 days depending on water temperatures active diurnally and nocturnally, whereas
(Jennings 1988b). Egg predation is infrequent adult frogs were largely nocturnal. The
and most mortality probably occurs during season of activity for the California red-
the tadpole stage (Licht 1974), although eggs legged frog seems to vary with the local
are susceptible to being washed away by high climate (Storer 1925); individuals from
stream flows. Schmeider and Nauman (1994) coastal populations, which rarely experience
report that California red-legged frog eggs low temperature extremes because of the
have a defense against predation which is moderating maritime effect, are rarely
possibly related to the physical nature of the inactive. Individuals from inland sites, where
egg mass jelly, although Rathbun (1998) has temperatures are lower, may become inactive
documented newt predation on eggs and for long intervals (Jennings et al. in litt. 1992)
suggested that this predation may be an and no information is available on the activity
important factor in the population dynamics levels of California red-legged frogs at higher
of the California red-legged frog. elevations.
Typically, most adult frogs lay their eggs in Feeding. The diet of California red-legged
March. Eggs require approximately 20-22 frogs is highly variable. The foraging ecology
days to develop into tadpoles, and tadpoles of larvae has not been studied, but they are
require 11 to 20 weeks to develop into thought to be algal grazers (Jennings et al. in
terrestrial frogs. (Bobzien et. al. 2000, Storer litt. 1992). Hayes and Tennant (1985) found
1925, Wright and Wright 1949). Several invertebrates to be the most common food
researchers, however, have observed items of adult frogs. Vertebrates, such as
overwintering tadpoles (i.e., tadpoles that did Pacific tree frogs (Hyla regilla) and
not metamorphose within their first breeding California mice (Peromyscus californicus),
season) in recent surveys. In Round Valley represented over half of the prey mass eaten
Creek (Contra Costa County) on East Bay by larger frogs, although invertebrates were
Regional Park District land, overwintering the most numerous food items. Feeding
tadpoles were documented in 1997, 1998, typically occurs along the shoreline and on
1999, and 2000. In these cases, metamorphs the surface of the water; juveniles appear to
were observed in March and April from forage during both daytime and nighttime,
previous breeding seasons. These frogs were whereas subadults and adults appear to feed
relatively small in size and still had posterior at night (Hayes and Tennant 1985). Radio-
scar tissue where their tails were located. tracking studies suggest that frogs also forage
Further, numerous tadpoles were seen in late several meters into dense riparian areas (G.
fall (October and November) and several in Rathbun pers. comm 1993, as cited in U.S.
December and January. The majority of these Fish and Wildlife Service 1996a).
individuals had rudimentary or developed
hind limbs and appeared to have
overwintered in this stage. (Bobzien et al.
2000).
F. REASONS FOR DECLINE AND THREATS TO 1987). Further, dispersal between fragments
SURVIVAL exposes frogs to increased risk of predation
(G. Rathbun in litt. 1998).
The California red-legged frog is threatened
by human activities, many of which operate In addition to the isolation of populations, the
synergistically and cumulatively with each range of the California red-legged frog has
other and with natural disturbances (i.e., been severely reduced. While numerous
droughts or floods). Factors associated with localities exist along the Pacific coast from
declining populations of the frog include Point Reyes south through Santa Barbara
degradation and loss of its habitat through County, few localities exist in the Sierras and
agriculture, urbanization, mining, southern California.
overgrazing, recreation, timber harvesting,
non-native plants, impoundments, water Urbanization. Current and future
diversions, degraded water quality, use of urbanization poses a significant threat to the
pesticides, and introduced predators. The California red-legged frog. In 1995,
reason for decline and degree of threats vary approximately 27 percent of the known
by geographic location. California red-legged occurrences were associated with
frog populations are threatened by more than urbanization threats and many areas within
one factor in most streams. The following the range of the frog were slated for
discussion is organized according to the five development (U.S. Fish and Wildlife Service
listing criteria under section 4(a)(1) of the 1996a). Urban and suburban developments
Endangered Species Act. often leave isolated habitat fragments and
create barriers to frog dispersal. Numerous
1. The Present or Threatened Destruction, studies, as discussed below, have
Modification, or Curtailment of Habitat or demonstrated the impacts of fragmentation on
Range. other frog and toad species. Urban
populations of common frogs (Rana
Curtailment of Range and Alteration, temporaria) were more genetically distinct
Fragmentation, Degradation, and Loss of than rural populations (Hitchings and Beebee
Habitat. Habitat loss and alteration are the 1997). Based on genetic analysis, Reh and
primary factors that have affected the Seitz (1990) found that highways effectively
California red-legged frog negatively isolated common frog populations. Kuhn
throughout its range. For example, in the (1987, in Reh and Seitz 1990) estimated that
Central Valley of California, over 90 percent 24 to 40 cars per hour killed 50 percent of
of historic wetlands have been diked, drained, common toad (Bufo bufo) individuals
or filled for agricultural and urban migrating across a road, while Heine (1987,
development (U.S. Fish and Wildlife Service in Reh and Seitz 1990) found that 26 cars per
1978, Dahl 1990). This has resulted in a large hour could reduce the survival rate of toads
loss of frog habitat throughout this species’ crossing roads to zero. Fahrig et al. (1995)
range. found a significant negative correlation
between traffic density and the density of
California red-legged frog habitat has become anuran (frog and toad) populations. Thus,
isolated and fragmented along many stream roads are an important human-caused
courses. Patches of suitable habitat represent landscape component hindering amphibian
remnants of a much larger historical habitat, movement and thereby fragmenting
which once covered entire drainages. With amphibian populations.
habitat fragmentation, dispersal opportunities
are reduced and interactions between sub- Because urbanization typically results in
populations can be precluded, jeopardizing additional water sources into wetlands and
the viability of metapopulations. Isolated stream courses, due to irrigation and home
populations are vulnerable to extinction use activities, another consequence of
through random adverse environmental urbanization is the change in hydroperiod of
events and human-caused impacts (Soulé historically ephemeral drainages to perennial
streams (often due to wastewater outflows). fertilizers and pesticides including herbicides
This change allows the proliferation of non- and fungicides, that may pose contamination
native predators (M. Moore and M. Westphal threats to the frog. Impacts include
in litt. 1997). Richter and Azous (1997) deformities, abnormal immune system
observed wetlands adjacent to undeveloped functions, diseases, injury, and death (see
upland areas were more likely to have richer Appendix B) (K. Woodburn in litt. 1996,
populations of native amphibians. The Schneeweiss and Schneeweiss 1997). An
reduced richness of amphibians in wetlands important factor in the decline of the
with highly urbanized watersheds is likely California red-legged frog may be exposure
due, in part, in part, to differences in to wind-borne agrochemicals. A number of
hydrologic patterns related to land use. studies have documented transport and
deposition of pesticides from the Central
In addition to the modification of Valley to the Sierra Nevada mountain range
hydroperiod, development within the (Zabik and Seiber, 1993, Aston and Seiber
watershed can also affect water and habitat 1997, Datta 1997, McConnell et al 1998 as
quality. As watersheds are developed, the cited in Davidson et al. 2001). There is a
amount of impervious surface increases, strong relationship between increasing levels
resulting in an increase of sediments of upwind agriculture and the percentage of
containing organic matter, pesticides, and extirpated California red-legged frog
fertilizers, heavy metals such as population sites; this relationship is
hydrocarbons, and other debris into streams particularly pronounced within the Sierra
and wetlands (Environmental Protection Nevada-Central Valley region where
Agency 1993). Skinner et al. (1999) found agriculture is the greatest (Davidson et al.
developed watersheds had greater 2001). In this region, the percentage of
concentrations of toxic effluents than less upwind land in agriculture for sites where the
developed areas with more open space. The California red-legged frog has disappeared is
decrease in water quality can have profound 6.5 times greater than for sites where they
impacts on native amphibians and other persist (Davidson et al. 2001). Similarly,
wetland vertebrates. Other consequences Sparling et al. (2001) noted that the most
include channelization of creeks (which severe declines of amphibians, including
reduces or eliminates breeding sites) and California red-legged frogs, are in the Sierra
increased suitability for predators such as Nevada mountains east of the central valley
non-native fish, bullfrogs, and raccoons, all of and downwind of the intensely agricultural
which thrive in disturbed conditions (Harris San Joaquin valley. In contrast, coastal and
1998). more northern populations across from the
less agrarian Sacramento valley are stable or
Agriculture. Agricultural practices pose a declining less precipitously.
threat to the California red-legged frog
populations due to loss or modification of Water diversion and impoundment for
frog habitats. Many crops (e.g., row crops) irrigation, can reduce the flows necessary to
are stands of monotypic vegetation, which support adequate aquatic habitat for frogs and
replace varied natural habitats. Fisher and other species. The California coast supports
Shaffer (1996) studied historic records and several agricultural activities including
conducted surveys for amphibians in the artichoke production, flower nurseries, and
Sacramento Valley, San Joaquin Valley, and other irrigated crops that require the use of
Coast range. In the San Joaquin Valley, irrigation ponds. Water is collected during the
drastic declines of both native and non-native winter months from rainfall and is also
amphibians were noted. The authors suggest pumped out of coastal drainages into ponds.
that the declines may be due to intense These ponds typically grow shoreline
farming rendering the few remaining ponds vegetation such as cattails, tules (Scirpus
and pools on the valley floor uninhabitable spp.), and horsetails (Equisetum spp.), and
even for introduced species. Agricultural with proper water management can provide
practices typically include the use of high quality breeding habitat. However,
farmers often start irrigating crops during the Lind et al. (1996) studied the effects of a dam
late spring, and continue through summer. As on the foothill yellow-legged frog (Rana
water is drawn down, egg masses can be boylii) in the Trinity River (Trinity County).
exposed and desiccate. Although the outlets Unlike the California red-legged frog, this
may be screened, the pumps used are species is typically associated with stream
powerful enough to suck tadpoles and riffles. Here, dams reduced breeding habitat
juveniles against the screen and can crush due to changes in channel morphology and
individuals. Depending upon their size, ponds eliminated entire cohorts due to unseasonable
also may be drawn down to such an extent high flow releases. Other dam-related factors
that they completely dry out or are shallow that may have influenced the breeding
enough to allow significant predation of frogs ecology of the foothill yellow-legged frog are
(particularly tadpoles that have not fully water temperature, exotic species, and
metamorphosed) by waterbirds. Ponds that changes in prey base. Hayes and Jennings
are not drawn down all the way often support (1988) found that California red-legged frogs
predatory sunfish (Lepomis spp.), largemouth generally were extirpated from downstream
bass (Micropterus spp.), and bullfrogs (S. portions of a drainage 1 to 5 years after filling
Larsen in litt. 1998). Some agricultural of a reservoir, depending on the size of the
activities (e.g., nurseries) provide a large drainage. However, in some larger drainages,
flush of pesticides into stream systems during isolated populations have been observed to
rain events and may pose a threat to frogs (C. persist upstream of a reservoir.
McCasland in litt. 1998b). The effects of
agricultural activities are especially intense in Some populations of frogs are known to use
the Central Valley, Salinas Valley, the coastal reservoirs at least in the adult stage (e.g.,
plain of Monterey County, and parts of San Jamieson Reservoir on the Santa Ynez River).
Luis Obispo and Santa Barbara Counties. On Los Padres National Forest, plunge pools
and seepage pools that occur at the base of
Impoundments and Water Management. In most dams are prime California red-legged
the Central Valley and surrounding foothills frog habitat, and viable populations have
the construction and filling of large persisted despite dams (S. Chubb in litt.
reservoirs, which are typically situated at or 1999). It is not clear if these reservoirs are a
just below the juncture of several tributaries, source or sink to the overall California red-
either directly eliminated, fragmented, or legged frog population in these areas; the
isolated populations of the California red- suitability may depend on the presence of
legged frog. Examples include the non-native species and/or other land-use
construction of Lake Oroville (Butte County), disturbances such as recreation. Reservoirs
Whiskeytown Reservoir (Shasta County), are typically stocked with non-native
Folsom Reservoir (Placer, El Dorado predatory fishes. Bullfrogs were stocked in
Counties), Lake Berryessa (Napa County), the past and continue to spread. These species
and San Luis Reservoir (Merced County) often disperse upstream and downstream into
within the Central Valley hydrologic basin California red-legged frog habitat and disrupt
(Jennings et al. in litt. 1992). At least 40 natural community dynamics.
percent of the historically suitable California
red-legged frog habitat on the Los Padres Many small impoundments are situated on
National Forest has been fragmented by the private and public lands. For example, on Los
placement of dams on streams. The major Padres National Forest, there are 150 small
existing dams include San Clemente and Los impoundments, over 500 small water
Padres Dams on the Carmel River; Twitchell diversions exist, and approximately 190
Dam and Reservoir on the Cuyama and springs are diverted. Most of these diversions
Alamo watersheds; Bradbury, Gibraltar, and and impoundments are operated as temporary
Juncal Dams on the Santa Ynez River; storage of surface water run-off in ephemeral
Matilija Dam on Matilija Creek; and Santa drainages for livestock and/or wildlife
Felicia and Pyramid Dams on Piru Creek (S. watering. Impoundments can structurally
Chubb in litt. 1998). block or hinder dispersal. Further, they can
eliminate the high flows needed to maintain reaches by interrupting the supply of sand and
moderately deep holes in stream channels (G. gravel, which is needed for localized shallow,
Rathbun in litt. 1998). Stock ponds and small braided channels (Collins and Dunne 1990).
reservoirs also typically support populations Long-term gravel mining on point bars
of non-native fishes and bullfrogs (G. retards the development of appropriate soil
Rathbun and M. Jennings in litt. 1993). In conditions for riparian vegetation. Continued
contrast, California red-legged frogs instream gravel mining activities without
frequently use small reservoirs as breeding adequate safeguards may preclude favorable
habitat, and these sites may be good habitat conditions for the California red-
producers of California red-legged frogs with legged frog. California red-legged frogs have
the proper management of water and non- colonized active and inactive sediment basins
native predators. at two quarries in Santa Cruz County (Bonny
Doon Quarry and Wilder Ranch Quarry) and
Channelization and Flood Control. Routine it is possible that frogs inhabit other sediment
flood control maintenance, which typically basins associated with quarries throughout the
includes vegetation removal, herbicide species’ range (M. Allaback in litt. 2000).
spraying, shaping and riprapping of banks to Effluent from mercury mines has created high
control erosion, and dredging of creeks and levels of mercury in the upper Nacimiento
rivers, can result in degradation of California River basin (Salinas River drainage), and
red-legged frog habitat. Widespread probably other streams in the Santa Lucia
channelization of watercourses for flood Mountains (N. Scott in litt. 1998).
control and water diversion has eliminated
habitat along small to medium-sized Within Los Padres National Forest, oil and
watercourses (Harding 1960), and has gas development occupies approximately 73
allowed the proliferation of non-native hectares (200 acres) within Sespe and Hopper
aquatic species. Management of water flows creeks. There has been one documented oil
for flood control also has the potential to spill which extended 3 kilometers (2 miles)
adversely impact California red-legged frogs. down Sespe Creek. Los Padres National
For example, in San Mateo County, poorly Forest has since worked with the lessees to
timed releases of storm water flows from establish and implement Best Management
Horse Stable Pond at Sharp Park in February Practices and properly cap old wells and
1992, resulted in exposure and desiccation of remove storage tanks. Oil and gas pipelines
62 California red-legged frog egg masses (T. also extend across a number of drainages
Steiner in litt. 1994). within San Luis Obispo, Santa Barbara, and
Ventura Counties. There is always a risk of
Mining. Suction dredge mining may threaten leakage or breakage near stream crossings (S.
California red-legged frog habitat. Jennings et Chubb in litt. 1999).
al. (in litt. 1992) reported heavy siltation in
late spring and summer in portions of Piru Livestock Grazing and Dairy Farming.
Creek (Santa Barbara County), which is Livestock grazing is another form of habitat
known to support California red-legged frogs. alteration that may be both (1) contributing to
The siltation resulted from upstream gold declines in the California red-legged frog by
mining. Extremely deep holes in streams decreasing suitability of riparian and aquatic
created by instream suction dredge mining habitat and (2) in many instances, providing
may also provide habitat for non-native frog habitats.
predatory fish (U.S. Fish and Wildlife Service
1996a). Creeks, streams, and rivers are open In many cases, California red-legged frogs
to suction dredging throughout the year in co-exist with managed livestock grazing.
many counties within the range of the High numbers of frogs are found in areas
California red-legged frog. such as Point Reyes National Seashore, many
East Bay Regional Parks, and private land
Sand and gravel mining practices can alter holdings where stock ponds and cattle are
natural channel morphology in downstream prevalent. In many of these areas, California
red-legged frogs may be present only because Unmanaged cattle trample and eat emergent
livestock operators have artificially created and riparian vegetation, often eliminating or
ponds for livestock water where there were severely reducing plant cover (Gunderson
none before and therefore, created frog 1968, Duff 1979). Loss of riparian vegetation
habitats. In such ponded habitat, grazing may results in increased water temperatures (Van
help maintain habitat suitability by keeping Velson 1979), which
ponds clear where they might otherwise fill in decreases suitability
with cattails, bulrushes, and other emergent for California red-
vegetation (S. Bobzien in litt. 1998, G. Fellers legged frogs and Livestock grazing is another form of
in litt. 1998, N. Scott and G. Rathbun in litt. encourages
1998). reproduction of habitat alteration that may be both
bullfrog and non-
In other areas, however, observations suggest native warm water contributing to declines of the
that grazing activities pose a serious threat to fishes. Effects on
the suitability of aquatic habitats for riparian vegetation
California red-legged frogs. For example, due to cattle grazing California red-legged frog by
exclusion of cattle grazing from the Simas include the loss of
Valley (Contra Costa County) resulted in willows (Duff 1979), decreasing suitability of riparian and
reestablishment of native trees and native which are associated
wetland herbs, re-establishment of creek with the highest aquatic habitat and, in many
pools, and expansion of frog populations into densities of
streams and ungrazed stock ponds (Dunne California red-legged
1995). Further research is necessary to frogs (Hayes and instances, providing frog habitats.
determine the role of drought and population Jennings 1988,
size in this observed expansion of red-legged Jennings 1988b).
frogs into streams, because the exclusion of Loss of streamside vegetation also reduces
cattle coincided with the end of a prolonged habitat for insects and small mammals, which
drought. Other biologists have noted that are important dietary components for aquatic
when cattle drink from small ponds and and riparian associated species, including the
streams they can draw down water levels, red-legged frog (Cordone and Kelley 1961).
leaving egg masses above the water level and
subjecting them to desiccation and/or disease Cattle overgrazing also results in increased
(e.g., fungal infections) (S. Chubb in litt. erosion in the watershed (Lusby 1970,
1998). Grazing cattle can also cause direct Winegar 1977), which accelerates the
impacts to frogs by crushing and/or sedimentation of deep pools (Gunderson
disturbing egg masses (S. Chubb in litt. 1968) used by California red-legged frogs.
1998), larvae, and metamorphosing frogs. High levels of sediment introduced into
streams can alter primary productivity and fill
Numerous studies, summarized by Behnke interstitial spaces in streambed materials with
and Raleigh (1978) and Kauffman and fine particulates, which impede water flow,
Krueger (1984), have shown that livestock reduce dissolved oxygen levels, and restrict
grazing can negatively affect riparian habitat, waste removal (Chapman 1988). The
marshes, and ponds. Cattle have an adverse populations of California red-legged frogs in
effect on riparian and other wetland habitats the Corral Hollow Ecological Reserve and
because they tend to concentrate in these Frank Raines Regional Park are threatened, in
areas, particularly during the dry season part, by sedimentation of aquatic habitats
(Marlow and Pogacnik 1985). Poorly either directly or indirectly caused by grazing
managed grazing in riparian areas often (M. Jennings et al. in litt. 1992). Livestock
results in downcutting and loss of plunge grazing can cause a nutrient loading problem
ponds, which in turn, decreases pool habitats due to urination and defecation in areas where
for California red-legged frogs. The cattle are concentrated near the water (Doran
consequences of these changes in riparian et al. 1981). The primary contaminant in the
conditions and the effect on the frog are tributaries to Tomales Bay (Marin County) is
largely unknown.
waste from cattle ranches and dairies (San Mountain bikes may also pose a threat to
Francisco Chronicle 1998). California red-legged frogs. Wilder Ranch
(Santa Cruz County) is used by a high
Overall, grazing may both enhance California number of mountain bikers daily. In 1996, a
red-legged frog populations and be a sub-adult red-legged frog was observed on a
detriment to habitat suitability; the effects bike trail along Baldwin Creek. Where bike
probably depend on the grazing practices, paths are regularly used at night on the
watershed integrity, and conditions of a University of California Santa Cruz campus,
particular site. For example, the East Bay there have been reported deaths of California
Regional Park District uses livestock grazing red-legged frogs due to bike strike (M.
for vegetation management and habitat Allaback in litt. 2000).
enhancement. The vast majority of California
red-legged frogs observed on Park District Recreational activities such as angling often
lands are in artificial ponds or in streams that result in the introduction of non-native
are exposed to livestock grazing (Bobzien et species either through the artificial stocking
al. 2000). While safeguards may be needed to of streams, lakes, and ponds or the use of
protect riparian and aquatic habitats, with non-native species as bait. These non-native
proper management of artificial ponds and species, such as bass and sunfish, can prey
appropriate grazing regimes, this land use upon and ultimately eliminate native species.
may prove to be a benefit to this species as Mechanical disturbances of habitats, such as
witnessed in Alameda, Contra Costa, Marin, trampling of vegetation, can increase the
Sonoma, Santa Cruz, and San Luis Obispo proliferation of non-native vegetation.
Counties (N. Scott in litt. 1999). Littering associated with recreational
activities can also introduce toxic substances
Recreation and Off-Road Vehicles. Routine such as motor oil, antifreeze, and other
road maintenance, trail development, and substances or items that are harmful to the
facilities construction associated with parks aquatic and riparian community (S. Chubb in
and other public lands, in or adjacent to litt. 1998).
California red-legged frog habitat can
degrade habitat quality (U.S. Fish and Timber Harvesting. Timber operations and
Wildlife Service 1996a). Heavy recreational related practices occurring on commercial,
use of parks (e.g., fishing, hiking, use of private, and public timberlands within
developed sites, dispersed camping) can also watersheds inhabited by the California red-
degrade habitat for the California red-legged legged frog may contribute to the degradation
frog. People tend to congregate around of instream and riparian habitat and the
aquatic areas and can trample vegetation, decline of California red-legged frog and
trample frog eggs and young, increase noise other aquatic species. The effects that degrade
levels, and change the environment. At Big habitat include increased sedimentation of
Basin Redwoods State Park in Santa Cruz gravels and pools, removal of trees that
County, heavy recreational use may have provide instream and streamside habitat
contributed to the disappearance of California structure and shade, and changed patterns of
red-legged frogs from Opal Creek (U.S. Fish runoff (U.S. Fish and Wildlife Service 1996a,
and Wildlife Service 1996a). 1996b). Access roads, haul roads, skid trails,
and ground based (tractor) yarding systems
Unmanaged off-road vehicles can damage have great impacts related to sedimentation
riparian vegetation, increase siltation in pools, and compaction. Wet weather operations also
compact soils, disturb the water in stream have more potential for impacts. Timber
channels, and crush frogs. California red- harvesting in upland habitat can also impact
legged frogs were eliminated, in part by off- California red-legged frogs by causing direct
road vehicle activities, at the Mojave River harm or injury to frogs that may be dispersing
above Victorville, and at Rincon Station on or sheltering.
the West Fork of the San Gabriel River (U.S.
Fish and Wildlife Service 1996a). Within the current range of the California red-
legged frog, timber harvest activities are most studies. Short term impacts of these activities
likely to occur in the following areas: (1) the may include harassment and possible
Sierra Nevada foothills; (2) along the coast in accidental injury or death of a limited number
Santa Cruz County; and (3) in certain of individual frogs. The long-term impacts
watersheds in Sonoma, Napa, and Lake will be to benefit recovery of the species by
Counties. Timber harvest activities occur in facilitating development of more precise
many areas within the California red-legged scientific information on status, life history,
frog’s historic range, but outside the known and ecology.
current range. These areas include Glenn,
Tehama, Shasta, Lassen, and Plumas 3. Disease and Predation
Counties, and the counties on the west slope
of the Sierra Nevada south to Tulare County. Disease. Pathogens and parasites have been
South of Santa Cruz County, the majority of implicated in the decline of other frog
timber harvest activities relate to fuelwood species, but there has not been an extensive
gathering, and pose a minimal threat to examination of how disease may adversely
watersheds (S. Chubb in litt. 1999) although affect California red-legged frog populations.
this practice may remove cover and refugia Currently, the San Francisquito drainage
that frogs may rely upon. population in Los Angeles County is being
monitored for disease and parasites which are
2. Overutilization for Commercial, the suspected cause of this population’s
Recreational, Scientific, or Education decline (R. Fischer pers. comm 2001). It has
Purposes been suggested that increased levels of UV-B
radiation or air pollutants cause a weakening
Exploitation. Exploitation of California red- of the immune system which could increase
legged frogs for food began during the period the susceptibility of frogs to natural diseases
following the gold rush of 1849 (Jennings and (Blaustein and Wake 1995, P. Montague in
Hayes 1984, 1985). By the mid-1870s, it was litt. 1998). Another hypothesis, supported by
recognized that their numbers were observations, is that disease carried by
diminishing in the vicinity of San Francisco planted trout may attack and kill amphibian
(Lockington 1879). Overharvest, driven by a eggs and larvae (Blaustein et al. 1994).
significant commercial demand, was Lefcort and Blaustein (1995) documented the
indicated by a sharp reduction in frog harvest effects of the yeast Candida humicola, which
size in the late 1880s, and by the attempt to is a naturally occurring pathogen, on northern
compensate for depleted wild stocks of the red-legged frogs. Infected frogs were more
California red-legged frog, by introducing susceptible to predation due to changes in
bullfrogs (Jennings and Hayes 1984, 1985). their ability to detect predators and changes in
Commercial exploitation reduced lowland their thermoregulatory behavior. Little
populations, particularly those on the floor of information exists concerning the distribution
the Central Valley, to low levels (Jennings of this pathogen. A high incidence of
1988b). This past exploitation is not a factor parasites has been observed in bullfrogs that
that is causing current declines, as commer- coexist with California red-legged frogs (>90
cial harvesting of California red-legged frogs percent of sampled population with evidence
has not occurred for a number of years. of infection) in southern California. Data
have not yet been collected to determine if
Scientific Take. Qualified individuals may California red-legged frogs are also
obtain permits to conduct scientific research contaminated in these areas; however, adult
activities on California red-legged frogs red-legged frogs appear to be in poor
under section 10(a)(1)(A) of the Endangered condition with low body weight.
Species Act. Specific activities that may be
authorized include: capturing, handling, Chytrid fungus has been found in a number of
weighing, measuring, radiotracking studies, amphibian populations that are known to be
genetic studies, contaminant studies, and declining. Signs of amphibian
behavioral, ecological, and life history chytridiomycosis include deformed
mouthparts in tadpoles; most individuals that in the decline of California red-legged frogs,
are infected as tadpoles die when they it is appropriate to take some precautions
metamorphose. Infected boreal toads (Bufo against spreading fungus between sites (U.S.
boreas boreas) found in Rocky Mountain Geological Survey 2000). The disease is now
National Park, Colorado, showed few clinical being studied in detail to understand its
signs of the disease but many appeared weak origin, incidence, distribution and control
or lethargic, exhibited excessive shedding of methods.
skin and were reluctant to flee at the approach
of humans (U.S. Geological Service 2000). Predation by Introduced Species. Introduced
Chytrids are widespread in the environment bullfrogs, crayfish, and species of fish have
where they act as decomposers of keratin, been a significant factor in the decline of the
chitin, cellulose, and other plant material. California red-legged frog. All of these
Chytrids are also known parasites of fungi, species were introduced into California in the
algae, higher plants, protozoa, and late 1800s and early 1900s, and through range
invertebrates, but none were known to infect expansions and transplants have become
vertebrates until recently. Chytrid fungi established throughout most of the State
reproduce asexually by means of minute, (Riegel 1959, Bury and Luckenbach 1976,
fragile, motile spores, and are probably Moyle 1976). Introduced aquatic vertebrates
spread directly from amphibian to amphibian and invertebrates are predators on one or
in water. Chytrids probably move from one more of the life stages of California red-
water source to another on migrating legged frogs. These include bullfrogs, African
amphibian, or on waterbirds or flying insects clawed frogs (Xenopus laevis), red swamp
(Daszak et al. 1999). crayfish (Procambarus clarkii), signal
crayfish (Pacifastacus leniusculus), and
Chytrid fungus in amphibians was first various species of fishes, especially bass,
identified in 1998 by an international team of catfish (Ictalurus spp.), sunfish, and
scientists from Australia, the United States, mosquitofish (Gambusia affinis) (Hayes and
and Great Britain. This team discovered that Jennings 1986).
the fungus had most likely been responsible
for large amphibian die-offs in pristine areas Several researchers in central California have
of Panama and Australia. It also was a factor noted the decline and eventual disappearance
and probable cause of recent die-offs in of California red-legged frogs once bullfrogs
remaining populations of the endangered become established at the same site (Moyle
boreal toad (Bufo boreas boreas) in the 1976, S. Barry in litt. 1992, L. Hunt in litt.
southern Rocky Mountains. Dead and dying 1993, Fisher and Schaffer 1996). Changes in
Chiricahua leopard frogs (Rana habitat that are unfavorable to California red-
chiricahuensis) at study sites in Arizona were legged frogs tend to be favorable to a suite of
diagnosed with a chytrid fungal skin infection introduced non-native aquatic predators, mak-
(Colorado Herpetological Society 2000). ing it difficult to identify detrimental effects
Here, entire populations have been lost or of specific introduced species on California
reduced to very low numbers by an outbreak red-legged frogs. Bullfrogs prey on California
of chytrid fungus. Furthermore, two red-legged frogs (Twedt 1993), and may have
amphibian species in the Sierra Nevada (i.e., a competitive advantage over California red-
mountain yellow-legged frog (Rana muscosa) legged frogs because of their larger size
and the Yosemite toad (Bufo canoris)) have (Figures 10 and 11), generalized food habits
been observed to be infected by a chytrid (Bury and Whelan 1984), extended breeding
fungus (G. Fellers pers. comm. 1999). A season (Storer 1933) that allows for
California red-legged frog tadpole was production of two clutches of up to 20,000
collected with a chytrid fungus infection in eggs during a breeding season (Emlen 1977),
Calabasas Pond on the Ellicott Slough and the unpalatability of their larvae to
National Wildlife Refuge in Santa Cruz predatory fish (Kruse and Francis 1977).
County (G. McLaughlin in litt. 2000). While Lawler et al. (1999) found that fewer than 5
it is not yet clear what role the fungus plays percent of California red-legged frogs
survived in ponds with bullfrog tadpoles, and frogs in dune ponds with both non-native fish
the presence of bullfrogs delayed frog and bullfrogs was nearly eliminated; in ponds
metamorphosis. with bullfrogs but no fish, reproduction of
California red-legged frogs was evident,
Hayes and Jennings (1986, 1988) found a though low. Reproductive rates were very
negative correlation between the abundance high in ponds with neither non-native fish nor
of introduced fish species and California red- bullfrogs (S. Christopher in litt. 1998).
legged frogs. Jennings (1988b) suspected that
native frogs do poorly where introduced Mosquito abatement efforts in California
fishes are abundant because the placement of include stocking water bodies with
native ranid eggs and activities of tadpoles in mosquitofish. Mosquitofish (Gambusia
shallow near-shore habitats may predispose affinis) are native to the eastern United States
them to predation. However, this may be and have been introduced to wetlands
unlikely given that introduced fish are not worldwide as biological control agents for
typically associated with shallow, near-shore mosquito larvae. This practice is a concern to
habitat (G. Rathbun, in litt. 1999). The conservationists because introduced
interaction between tadpoles and predatory mosquitofish can harm amphibians.
fish may be exacerbated when they are Mosquitofish are considered opportunistic
crowded into small pools lacking habitat feeders foraging on over 50 recorded types of
complexity (Hews 1995). Bradford (1989) plant and animal life, including micro- and
also reported a lack of co-occurrence of macro-invertebrates (Graf 1993).
native frogs and non-native fish in the same
habitat areas, which may be due to predation Several studies have attempted to
by introduced fish. Many sites, particularly in demonstrate the relationship between
the Sierra Nevada, are now unsuitable for mosquitofish and amphibians. Studies have
California red-legged frogs because of the also been conducted in Australia on the
presence of non-native fish. On Vandenberg effects of a closely related species, Gambusia
Air Force Base (Santa Barbara County), the holbrooki, on frog tadpoles (Crinia glauerti,
reproductive success of California red-legged C. insignifera, and Heleioporus eyrei) under
Figure 10.
Comparison of
California red-
legged frog (smaller)
and bullfrog
Photo © Galen Rathbun
experimental conditions and on frog species effects of mosquitofish have been

richness and abundance in the field. These demonstrated and may provide reason enough
studies (Blyth 1994, Webb and Joss 1997) to consider other mosquito-control methods
showed direct predation on tadpoles, injuries in amphibian habitat and surrounding
to tadpoles in tanks or ponds with Gambusia, watersheds. Effects of mosquitofish may be
and reduced survival and recruitment. greater than experimentally demonstrated if
Analysis of field data from Australia (Webb mosquitofish are more abundant in natural
and Joss 1997) demonstrated a significant ponds when tadpoles are small. Overall, this
drop in the abundance of frogs when evidence that mosquitofish may play a role in
Gambusia were present. Results of a study in the decline of the red-legged frog is
artificial ponds showed that mosquitofish and inconclusive because it is based on
bluegill (Lepomis machrochirus) were correlations between species distributions,
significant predators of California red-legged predation trials in arenas where habitat and
frog larvae (Schmieder and Nauman 1994). community structure were simplified, and, in
Mosquitofish may also compete with some cases, similar Gambusia species rather
California red-legged frogs by consuming than Gambusia affinis, specifically.
aquatic insects that are potential food sources
for postmetamorphic frogs. Lawler et al. California red-legged frog larvae have been
(1999) observed that mosquitofish did not found with mosquitofish in Corral Hollow
affect the recruitment of red-legged frogs Creek (Alameda and San Joaquin Counties)
from natural, spatially complex ponds. (T. Strange pers. comm. 1994) and in some
However, although mosquitofish did not waterbodies in Contra Costa County (K.
affect red-legged frog survival, juveniles Swaim in litt. 1994, Malamud-Roam in litt.
emerging from ponds with mosquitofish 1994). California red-legged frogs may be
metamorphosed later and weighed an average coexisting successfully with mosquitofish in
of one-third less than those raised without these cases because winter rains may flush
Figure 11. Predation fish. Laboratory trials showed that young mosquitofish out of creeks, thus eliminating
of a California red- tadpoles were less active (i.e., exhibited lower or reducing the physical, sublethal effects
legged frog by a foraging levels) in the presence of fish. noted by Lawler et al. (1999) in pond
bullfrog (larger frog) Lowered activity levels could have caused a environments.
Photos © David Cook
decrease in their
initial growth rate; Overall, while California red-legged frogs are
injuries are also occasionally known to persist in the presence
known to decrease of either bullfrogs or mosquitofish (and other
the growth of non-native species), the combined effects of
tadpoles (Lawler et both non-native frogs and non-native fish
al. 1999). As has often leads to extirpation of red-legged frogs
been noted with (Kiesecker and Blaustein 1998, Lawler et al.
other amphibians, 2000, S. Christopher in litt. 1998).
smaller metamorphs
mature later and lay In addition to non-native animals, a number
fewer eggs; of non-native plants may threaten the
California red- integrity of aquatic systems by out-competing
legged frogs may be and replacing native plants and thus
vulnerable to this decreasing plant diversity. For example,
problem if they species such as tamarisk (Tamarix sp.), giant
cannot grow quickly reed also called arundo (Arundo donax), and
enough in the cape ivy (Delaria odorata) have made
terrestrial sizeable inroads into native willow-
environment to cottonwood-sycamore communities in
compensate for their California. These species not only change the
initially smaller size. structure and function of a riparian corridor,
Thus, sublethal but also can result in losses of surface water
due to their increased transpiration rates (S. study plots at Pescadero Marsh (San Mateo
Chubb in litt. 1998). Biologists have noted County) when predaceous invertebrates were
that California red-legged frogs may be present. These invertebrates include diving
avoiding creeks and stream pools dominated beetles (family Dytiscidae), dragonflies
by eucalyptus (Eucalyptus spp.). The (order Odonata), and backswimmers (family
aromatic leaves of eucalyptus trees may Notonectidae).
secrete toxic chemicals into the water, which
may decrease the suitability of the area for 4. The Inadequacy of Existing Regulatory
frogs (Bobzien in litt. 1998). Some biologists, Mechanisms
however, have also reported high numbers of
frogs in areas with poor water quality due to a Although the California red-legged frog is
dominance of eucalyptus (e.g., West of classified as a species of special concern by
Bayshore property at San Francisco Airport, the State of California and may not be taken
Pescadero Marsh) (M. Allaback in litt. 2000, without an approved scientific collecting
S. Orlorff in litt. 2000). The relationship permit, this designation provides no special,
between the presence of non-native plants legally mandated protection of the species
and habitat suitability for California red- and its habitat.
legged frogs, however, is currently unknown.
The Endangered Species Act is the primary
Predation by Native Species. Several native Federal law that provides protection for the
predators, including raccoons (Procyon California red-legged frog since its listing as
lotor), great blue herons (Ardea herodias), a threatened species in 1996. Since this
American bitterns (Botaurus lentiginosus), designation, many projects have undergone
black-crowned night herons (Nycticorax section 7(a)(2) consultation. Section 7(a)(2)
nycticorax), red-shouldered hawks (Buteo of the Endangered Species Act requires
lineatus), and garter snakes (Thamnophis Federal agencies to consult with us prior to
spp.) eat adult frogs (Jennings and Hayes authorizing, funding, or carrying out activities
1990, Rathbun and Murphy 1996). Other that may affect listed species. The section
potential predators include opossums 7(a)(2) consultation process provides
(Didelphis virginiana), striped skunks protection for California red-legged frogs
(Mephitis mephitis), and spotted skunks through reasonable and prudent measures that
(Spilogale putorius) (Fitch 1940, Fox 1952, minimize the amount or extent of incidental
Jennings and Hayes 1990). take of the species due to project impacts.
While projects that are likely to result in
It has been noted that the release of adverse effects include such minimization
translocated predators, which is a common measures, we are limited to requesting minor
practice of municipal animal control districts, modifications to the project description, as
may threaten California red-legged frogs. For proposed. Reasonable and prudent measures,
example, in Los Padres National Forest, a along with the terms and conditions that
high number of raccoons and opossums were implement them, cannot alter the basic
observed in riparian areas where they were design, location, scope, duration, or timing of
preying upon arroyo southwestern toads the action and may involve only minor
(Bufo microscaphus californicus) and changes. The minimization measures
preventing successful reproduction of pond typically include: (1) pre-construction
turtles. The high number of raccoons and surveys, (2) capture of frogs from the
opossums were due to county and city construction site and relocation into Service-
districts practice of releasing trapped urban approved on-site watercourses, and (3)
wildlife into the riparian areas of the National protection, enhancement, and/or creation of
Forest (S. Sweet in litt. 2000). habitat. The later recommendation includes
protection of California red-legged frog
Some native fish may also eat tadpoles (N. habitat that already exists or creation of new
Scott in litt. 1998). Reis (1999) found that habitat which in most cases has not been
tadpoles were more likely to be absent from proven to be successful (i.e., California red-
legged frogs have, for the most part, not Decreased surface flows in some coastal
colonized or survived in newly created streams [e.g., Pescadero Creek (San Mateo
wetlands usually due to the proximity of the County), San Simeon Creek (San Luis Obispo
created ponds to development). Therefore, County)] during drought years, coupled with
there is typically a net loss of California red- agricultural, industrial, and residential ground
legged frog individuals and habitat with each water demands can result in desiccation or
authorized project. Most of these conserva- increased salinity of water sufficient to kill
tion measures have not been thoroughly most if not all of 1 year’s reproduction.
studied for effectiveness and therefore, may Drought conditions have the potential to
not fully mitigate the effects of the proposed eliminate a high proportion of the
project. Monitoring to determine the reproductive effort of California red-legged
effectiveness of these actions is required of frogs in the coastal region where the largest
permit holders; however, in general neither populations of the species remain (Jennings
we nor the permit holders have fully and Hayes 1989). On the other hand, since
implemented such monitoring. California red-legged frogs metamorphose in
1 year and bullfrog larvae require at least 2
Section 404 of the Clean Water Act is another years (Jennings 1988), occasional droughts
Federal law that potentially provides some can benefit California red-legged frogs by
protection for aquatic habitats of the reducing the numbers of exotic fish and
California red-legged frog, if the habitats are bullfrogs. For example, this benefit has been
determined to be jurisdictional areas (i.e., noted in the lower reaches of Brush Creek
waters of the United States) by the U.S. Army (Contra Costa County) which dries roughly
Corps of Engineers. Upland habitats adjacent every 3 to 5 years (M. Allaback in litt. 2000).
to riparian zones and other wetlands are not
provided any protection by section 404 of the Contaminants. Amphibians, in general,
Clean Water Act. Upland areas provide typically have complex life cycles and thus
important dispersal, estivation and summer more opportunities for exposure to chemicals
habitat for this species. and more potential routes of exposure than
other vertebrates. The California red-legged
5. Other Natural, or Manmade Factors frog continues to be exposed to a variety of
Affecting Their Continued Existence toxins throughout its range. The sensitivity of
this species to pesticides, heavy metals, air
Drought. Populations of most species are pollutants, and other contaminants is largely
cyclic in nature or fluctuate in response to unknown. Studies using other species of
natural factors such as weather events, amphibians, however, provide toxicity data
disease, fire, and predation. Natural events, that are relevant to the potential vulnerability
including long-term drought or extreme of the California red-legged frog, as cited
rainfall, have a less negative overall effect on below.
a species when the species is widely and
continuously distributed. Small, fragmented, As mentioned above, agricultural practices
or isolated populations of a species are more typically use pesticides including herbicides.
vulnerable to extirpation by random events. While some amphibian larvae (e.g., anuran
As water demands increase in California due tadpoles) are resistant to some cholinesterase
to increasing human populations, the inhibitors (the class of pesticides used most
interactions of those demands with natural often), some results indicate that this
drought cycles may further reduce the extent resistance does not apply to all amphibian
and quality of California red-legged frog species and chemicals (Sanders 1970, Cook
habitat and the size of remaining populations. 1981). According to Berrill et al. (1993),
ranid tadpoles are likely to be killed or
Decreased rain and snowfall can lead to paralyzed by some herbicides (e.g., triclopyr)
premature drying of streams and ponds and and insecticides (e.g., fenitrothion). Some
subsequent death of frog eggs and larvae, and pesticides mimic estrogen in vertebrates and
reduced survival of subadults and adults. this has been proposed as a hypothesis for
amphibian declines (Jennings 1996). There noticed (S. Chubb in litt. 1999).
are approximately 150 pesticides or
herbicides used in the same 2.6 square Airborne pollutants are considered to be a
kilometers (1-square mile) surveyed section likely cause of decline of amphibians in the
as known California red-legged frog sites or Central Valley and Sierra Nevada range. For
their habitat (California Department of example, basins that face the Central Valley
Pesticide Regulation 1997). The chemicals of are nearly devoid of mountain yellow-legged
greatest concern that are used within the frogs and the California red-legged frog is
range of the frog are listed and described in found in only a few locations in the western
Appendix B. slope of the Sierra Nevada range. The most
drastic declines of amphibians are found in
In addition to pesticides and herbicides, the Sierra Nevada mountains lying east of the
mineral fertilizers are used throughout the San Joaquin Valley; in the San Joaquin Valley
range of the California red-legged frog on agriculture is intense and vast quantities of
crops, household lawns, and golf courses. In a pesticides are applied. For example, in 1998,
study by Schneeweiss and Schneeweiss 60 percent of all active ingredient pesticides
(1997) in Germany, up to 100 percent of used in the State of California were applied in
amphibians were dead in pitfall traps located the San Joaquin Valley (Sparling et al. 2001).
on fields that were mineral fertilized. In Particulate matter, ozone, nitrogen oxides,
contrast, no dead or injured amphibians were herbicides, pesticides, and other air pollutants
found during simultaneous monitoring of are transported from the Central Valley into
non-fertilized fields. Marco et al. (1999) the Sierra Nevada. Some sources of air
found increased mortality of northern red- pollution are generated within the Sierra
legged frog larvae when exposed to nitrite Nevada, such as particulate matter generated
below the levels allowed for drinking water. by smoke from forest fires and nutrient loads
Additionally, Marco and Blaustein (1999) and gases produced by urban areas (i.e., use
found that Cascades frog (Rana cascadae) of fertilizers, traffic) (Cahill et al. 1996).
larvae exposed to sublethal concentrations of Further, the pattern of recent frog extinctions
nitrite exhibited changed morphology in the southern Sierra Nevada appear to
(delayed metamorphosis) and changed correspond with the pattern of highest
behavior (shallow water occupancy) that concentrations of air pollutants from
increased their vulnerability to predation. automobile exhaust (Jennings 1996).
Mercury mines have contaminated several Researchers measured the contaminants

areas within the range of the frog (e.g., Lake levels in frog and fish tissue in the Sierra
Nacimiento, Cache Creek), and chlorine has Nevada range to determine the extent of
been introduced to breeding sites via spills transport and absorption. Results showed that
and flushing of pipes used for wastewater and the concentrations and frequency of
drinking water treatments (e.g., Chorro detections for pesticides in amphibian tissue
Creek). Industrial chemicals, such as these, follow north-south and west-east patterns
that are released into the environment may consistent with intensified agriculture upwind
damage the immune systems of frogs. For of the areas with the most serious amphibian
example, one class of chemicals, known as declines (Sparling et al. 2001). Some of the
retinoids, causes severe defects in young pesticides are reducing cholinesterase activity
frogs; exposure to retinoids can also make in tadpoles of the Pacific treefrog. Depressed
frogs more susceptible to infectious diseases cholinesterase has been associated with
(Montague in litt. 1998). Oil seeps (either due reduced activity, uncoordinated swimming,
to natural leaks or by accidents at oil increased vulnerability to predators,
extraction facilities) contaminate California depressed growth rates, and greater mortality
red-legged frog habitats. For example, in tadpoles (Sparling et al. 2001). Rana
possible damage to red-legged frog tadpoles species such as the California red-legged frog
could occur in Tar Creek, a tributary of Sespe may be more at risk from aqueous pesticides
Creek, where an obvious oil sheen was than the Pacific treefrog because they are
more reliant on aquatic environments and use will take to minimize and mitigate the
aquatic habitat in more life stages (i.e., impacts. There are several habitat
Pacific treefrogs use aquatic habitat only conservation plans currently being developed
during breeding whereas Rana species use that will include measures to protect the
aquatic habitat as tadpoles and adults). California red-legged frog.
As previously described in section F. Threats

G. REGULATORY PROTECTION AND and Reasons for Decline, section 7(a)(2) of
CONSERVATION MEASURES the Endangered Species Act requires Federal
agencies, including us, to ensure that actions
Since the 1996 listing of the California red- they fund, authorize, or carry out do not
legged frog, several conservation efforts have destroy or adversely modify critical habitat to
been undertaken by various Federal, State, the extent that the action appreciably
and local agencies and private organizations. diminishes the value of the critical habitat for
The following briefly describes some the survival and recovery of the species.
regulatory protection and conservation Individuals, organizations, states, local
measures accomplished to date. governments, and other non-Federal entities
are affected by the designation of critical
Federal Regulatory Protection. Section 9 of habitat only if their actions occur on Federal
the Endangered Species Act of 1973, as lands, require a Federal permit, license, or
amended, prohibits any person subject to the other authorization or involve Federal
jurisdiction of the United States from taking funding.
(i.e., harassing, harming, pursuing, hunting,
shooting, wounding, killing, trapping, Since the listing, we have entered into section
capturing, or collecting) listed wildlife 7(a)(2) consultations with other Federal
species. It is also unlawful to attempt such agencies on numerous project proposals per
acts, solicit another to commit such acts, or the requirements of the Endangered Species
cause such acts to be committed. Regulations Act. Examples include interagency section
implementing the Endangered Species Act 7(a)(2) consultations on proposed road
(50 Federal Register 17.3) define “harm” to construction and maintenance, housing
include significant habitat modification or developments and golf courses that involve
degradation that results in the killing or injury wetland fill, timber harvest activities,
of wildlife, and intentional or negligent livestock grazing practices, and other
“harassment” as acts that significantly impair activities within the current and historic range
essential behavioral patterns (i.e., breeding, of the species.
feeding).
On March 13, 2001, we finalized the
Section 10(a)(1)(A) of the Endangered designation of critical habitat for the
Species Act and related regulations provide California red-legged frog (U.S. Fish and
for permits that may be granted to authorize Wildlife Service 2001). Critical habitat is
activities otherwise prohibited under section defined as specific areas that have been found
9, for scientific purposes or to enhance the to be essential to the conservation of the
propagation or survival of a listed species. species and which may require special
Section 10(a)(1)(B) of the Endangered management considerations or protection.
Species Act allows permits to be issued for The primary constituent elements for
take that is “incidental to, and not the purpose California red-legged frogs are aquatic and
of, carrying out an otherwise lawful activity” upland areas where suitable breeding and
if we determine that certain conditions have nonbreeding habitat is interspersed
been met that will minimize the impacts to throughout the landscape and is
the listed species. Under this section, an interconnected by unfragmented dispersal
applicant must prepare a habitat conservation habitat. Specifically, to be considered to have
plan (HCP) that specifies the impacts of the the primary constituent elements an area must
proposed project and the steps the applicant include two (or more) suitable breeding
locations, a permanent water source, activities which have been conducted on this
associated uplands surrounding these water Forest include non-native species removal
bodies up to 91 meters (300 feet) from the (e.g., bullfrogs and green sunfish),
water’s edge, all within 2 kilometers (1.25 streambank stabilization and revegetation,
miles) of one another and connected by road closures, modifications to permitted
barrier-free dispersal habitat that is at least 91 water diversions (e.g., Upper Santa Ynez
meters (300 feet) in width. When these River), restrictions on recreational activities,
elements are all present, all other essential educational programs, and assessment and
aquatic habitat within 2 kilometers (1.25 monitoring of California red-legged frog
miles), and free of dispersal barriers, will be abundances and habitat use. In this region,
afforded some protection under section Vandenberg Air Force Base has also been
7(a)(2) of the Endangered Species Act. protecting California red-legged frogs and
their habitats.
Federal Conservation Measures. Section
7(a)(1) of the Endangered Species Act The Cleveland National Forest has completed
requires that Federal agencies use their extensive surveys of historic and potential
authorities to further the conservation of habitat for California red-legged frogs, but no
listed species. Section 7(a)(1) obligations frogs were located. However, the Forest has
have caused Federal land management management direction, such as livestock
agencies to implement California red-legged grazing guidelines and management practices,
frog protection measures that go beyond to maintain suitability of riparian corridors.
those required to avoid take. Some of these The Cleveland National Forest has excluded
conservation measures are described below. grazing from most perennial riparian habitats
on the forest. Where exclusion is not feasible,
Los Padres National Forest has completed a the Forest has changed the season of use to
forest-wide Riparian Conservation Strategy winter; presumably cattle graze to a lesser
that augments and amends the Forest Land degree in breeding habitats during the winter
and Resource Management Plan (U.S. Forest because forage is available in the uplands
Service 1988). This management plan (with during the moist winter season. Further, the
the added riparian conservation strategy) Forest is removing non-native species (e.g.,
provides management guidelines for the arundo, tamarisk, bullfrogs) and redesigning
conservation of riparian habitats and road crossings on Pine, Morena, and Santa
associated species. Conservation actions Ysabel Creeks (S. Chubb in litt. 1998).
include: riparian management guidelines,
administration of water flow and use, The Cleveland, San Bernardino, Angeles, and
management of non-native species, Los Padres National Forests have completed
reintroduction of native species, recreational a Southern California Mountain and Foothills
guidelines, livestock grazing guidelines, Assessment, which has added standards,
mining and prospecting guidelines, road guidelines, and conservation measures to
maintenance guidelines, land exchanges, protect and recover wetland and upland
acquisition and sales programs, management habitats of importance to California red-
of watershed activities, and species and legged frogs and associated species (S. Chubb
habitat inventories. Pursuant to the Los in litt. 1998). This program has gone through
Padres National Forest Plan Riparian our section 7 consultation process.
Conservation Strategy and anadromous
steelhead recovery efforts, landscape-based The Sierra National Forest is currently
watershed analyses of the Sespe, Santa Paula, surveying for California red-legged frogs.
Ventura, Santa Ynez, and Arroyo Seco This Forest is also implementing our
watersheds have been conducted. These recommendations related to timber sales, and
efforts are likely to benefit the California red- is developing a management plan for off-
legged frog through more effective and highway vehicles that should minimize
efficient protection measures and coordinated impacts to California red-legged frogs.
restoration projects. Other beneficial Similarly, the Tahoe National Forest is
conducting forest-wide surveys for California Management developed a Riparian-Wetland

red-legged frogs and other amphibians. In Initiative that established national goals and
addition to following the Forest’s general objectives for managing riparian-wetland
guidelines, which include management and resources on public lands. One of the chief
protection of riparian habitats and protection goals of this initiative is to restore and
of threatened and endangered species, the maintain riparian-wetland areas so that at
Tahoe National Forest has proposed projects least 75 percent or more are in proper
to plant riparian vegetation along streams and functioning condition. Riparian areas that
fences with potential California red-legged meet the proper functioning condition, or are
frog habitat and to exclude recreational restored to such condition, may provide the
activities. habitat quality necessary for successful
colonization and/or reintroduction of
The Eldorado National Forest, with assistance California red-legged frogs (E. Lorentzen in
from the Biological Resources Division of the litt. 1998).
U.S. Geological Survey, has conducted
surveys for California red-legged frogs in The National Resource Conservation Service
streams that have potential habitat. No red- has carried out the Elkhorn Slough Watershed
legged frogs have been observed during any Project. This program was established with
of the surveys, and the habitat suitability is farmers within the watershed to implement
poor. Near Eldorado National Forest, the measures to reduce sedimentation and runoff
American River Conservancy has taken the and to restore habitat.
lead in facilitating the purchase of 20 hectares
(55 acres) of land that encompasses Spivey The Golden Gate National Recreation Area
Pond on the North Fork of Weber Creek, the (National Park Service) has developed several
location of a breeding California red-legged programs that provide benefits to the
frog population. A memorandum of California red-legged frog. Several site
understanding was signed by the U.S. Bureau management plans have been developed that
of Land Management American River will provide protection for California red-
Conservancy, California Department Water legged frogs. For example, the Milagra Ridge
Resources, U.S. Forest Service, U.S. Fish and and Wolfback Ridge Management Plans
Wildlife Service, U.S. Bureau of include plans for removal of non-native plant
Reclamation, and El Dorado Irrigation species from riparian corridors, revegetation
District to support a management plan for the with native riparian plants, maintenance of
property and the frog population (S. Chubb in water-diversion structures to improve water
litt. 1999). This management plan is currently flow, soil erosion control, and outreach/
being crafted and the U.S. Bureau of Land environmental education (National Park
Management is now the property owner. Service 1995, 1996). Further, the Golden
Gate National Recreation Area has initiated a
The Bureau of Land Management has tiered, volunteer-based monitoring program
developed, and is implementing, national for surveying for frogs during the winter in
standards and guidelines for livestock three watersheds (Tennessee, Lower
grazing. The standards and guidelines relate Redwood/Big Lagoon, and Rodeo Valley).
to vegetative ground cover, riparian-wetland The Golden Gate National Recreation Area
function, stream morphology, water quality, has also developed plans to restore several
and threatened and endangered species areas within its jurisdiction, such as Mountain
recovery. Several of the guidelines should Lake in the Presidio in coordination with the
indirectly help maintain California red-legged City of San Francisco, and Big Lagoon in
frog habitat quality. Assessments of whether Marin County. The Golden Gate National
grazing allotments are meeting these Recreation Area is also implementing non-
guidelines are expected to be completed native aquatic animal control programs in
within 5 years; allotments not meeting the Tennessee and Oakwood valleys to protect
standards will be subject to additional California red-legged frogs and western pond
management. In 1991, the Bureau of Land turtles (Shinomoto and Fong 1997, D. Fong,
in litt. 1998).
The CALFED Program is a comprehensive, Section 1600 of the California Fish and Game
30-year plan to restore ecosystems and Code authorizes the Department of Fish and
improve water management for beneficial Game to enter into agreements with parties
uses of the San Francisco Bay and seeking to perform activities within the bed,
Sacramento-San Joaquin River Delta. The bank, or channel of any stream, lake or river.
CALFED Program is managed cooperatively Section 1603 of the California Fish and Game
by 14 Federal and State agencies with Code authorizes the Department of Fish and
management responsibilities in the Bay-Delta Game to regulate streambed alteration for
region. The CALFED Program vision for the private entities or individuals. The
California red-legged frog is to maintain Department must be notified, and approve
populations. The CALFED Program is any work that substantially diverts, alters, or
expected to restore aquatic, wetland, and obstructs the natural flow or substantially
riparian habitats in the Sacramento-San changes the bed, channel or banks of any
Joaquin Delta Ecological Management Zone river, stream, or lake. If an existing fish or
and other ecological management zones wildlife resource may be substantially
which will help in the recovery of the frog by adversely affected by a project, the
increasing habitat quality, connectivity, and Department must submit proposals to protect
area (CALFED Bay-Delta Program 2000). the species within 30 days; this regulatory
Specifically, the CALFED Program included procedure should provide some protection for
in the Multi-Species Conservation Strategy California red-legged frog populations and
goals to enhance or restore suitable habitats habitat.
near occupied habitat and to avoid or
minimize CALFED actions that could In 1996, the California Department of
increase or attract non-native predator Forestry and Fire Protection requested our
populations to occupied habitat (CALFED assistance in determining protective measures
Bay-Delta Program 2000). for timber harvest plans and non-industrial
timber management plans to avoid take of the
Measures Implemented by California State California red-legged frog. Through this
Resource Agencies. The California red- process, we developed guidelines that can be
legged frog is classified as a “Species of applied, by California Department of Forestry
Special Concern” by the State of California and Fire Protection inspectors or other forest
(Steinhart 1990). This designation provides professionals, to any timber harvest plan or
no special, legally mandated protection of the non-industrial timber management plans
species and its habitat, but does mandate that within the range of the frog. In addition to
the species not be taken without an approved providing a dichotomous key to assessing
scientific collecting permit. In 1972, the potential impacts to the California red-legged
California Fish and Game Commission frog, the guidelines also recommend
amended its sport fishing regulations to avoidance measures, which reduce the
prohibit take or possession of California red- likelihood of incidental take of the species
legged frogs (Bury and Stewart 1973). The (U.S. Fish and Wildlife Service 1996c).
designation of species of special concern can
confer additional protection to species via California Department of Forestry and Fire
section 15380 of the California Protection enforces the California Forest
Environmental Quality Act guidelines. This Practice Rules (California Department of
section requires lead agencies under the Forestry and Fire Protection 1999), which
California Environmental Quality Act to treat provide prescriptive and procedural rules that
species as de facto State threatened or protect watercourses and lakes, and provide
endangered if they appear to meet listing some protection for California red-legged
requirements. For many unlisted species frog against timber harvest and related
which are currently species of special activities. Conservation measures were
concern, this designation can afford developed by the California Department of
additional consideration under California Forestry and Fire Protection and the
Environmental Quality Act review. California Department of Fish and Game
pursuant to the California Endangered program in Pescadero Marsh (T. Sasaki in litt.
Species Act consultation process, for 1999). Año Nuevo State Reserve has
Registered Professional Foresters. These are undertaken intensive bullfrog removal efforts
to be applied in areas immediately adjacent to in ponds inhabited by California red-legged
coho salmon (Oncorhynchus kisutch) habitat frogs (I. Loredo in litt. 1998). The Santa Cruz
south of San Francisco Bay. The protection District completed a 7 hectare (20 acre)
measures for coho salmon will benefit restoration project at Wilder Creek Natural
California red-legged frogs occurring in Preserve, converting 3.5 hectares (10 acres)
Pescadero, Gazos, San Gregario, and Butano of lowland and streamside agricultural fields
Creeks in San Mateo County; and Aptos, to willow and wetlands, allowing Wilder
Scott, Soquel, San Vincente, and Waddell Creek to escape the dredged channel during
Creeks and the San Lorenzo and Pajaro high water events. California red-legged frogs
Rivers in Santa Cruz County (B. Valentine in appeared and reproduced in high numbers
litt. 1998). shortly after the project began, and the frogs
continue to use the area (T. Sasaki in litt.
The California Department of Parks and 1999). M. Allaback (in litt. 2000) observed
Recreation has programs that benefit the numerous frogs before the restoration in the
California red-legged frog. Special park early 1990s suggesting that a significant
designations (i.e., Natural Preserves and State population was already present. The San
Reserves), provide increased protection of the Simeon District is currently restoring
land and for resident sensitive species, wetlands adjacent to San Simeon Creek, and
including the California red-legged frog. is in the process of requesting funds to
Development of general plans, resource purchase a small, unnamed drainage used by
management plans, site management plans, red-legged frogs during periods of high
and resource inventories are ongoing within salinity in the lagoon. This district also
the Department and allow planning for conducts biannual surveys to monitor
special status species. Other planning efforts California red-legged frogs and bullfrogs,
include developing habitat conservation plans removes non-native plant species, removes
with us. Currently, a regional habitat predators such as raccoons and feral cats, and
conservation plan is being developed for San monitors water quality (G. Smith pers. comm.
Luis Obispo Coast and Oceano Dunes 1998).
districts, and another is being developed for
Carnegie State Vehicular Recreation Area. The California Army National Guard has
Both will benefit the California red-legged sponsored California red-legged frog surveys
frog. at Camp Roberts (San Luis Obispo and
Monterey Counties) and at Camp San Luis
Restoration and enhancement efforts in many Obispo (San Luis Obispo County) (N. Scott
State park areas include riparian and wetland in litt. 1999). These surveys are used to
habitats. The following are some examples of monitor red-legged frog numbers at known
park wetland restoration projects that and potential sites, status of habitat,
benefitted the California red-legged frog. At reproduction and occurrence of red-legged
Pescadero Marsh Natural Preserve, within frog predators. In 1994, the California Army
Pescadero State Beach, the California National Guard fenced a section of riparian
Department of Parks and Recreation habitat along Chorro Creek at Camp San Luis
developed and implemented a wetland Obispo to eliminate cattle grazing;
restoration project to enhance habitat approximately 4,500 native plants were
suitability for the California red-legged frog. planted within the exclosure to restore
Restoration actions include enlargement of riparian habitat. This exclosure has enhanced
existing breaches in the levees, and habitat for the California red-legged frog. The
connection of remnant channels, removal of a California Army National Guard also began a
tide gate, excavation of channels, bullfrog eradication program and a giant reed
management of the Nunziatti trout ponds, and and invasive plant removal program in 1999,
a one-season experimental bullfrog control at known and potential red-legged frog sites
at Camp San Luis Obispo. In this area, the water levels in ponds, removing predatory
National Guard has also repaired roads and fishes, reducing grazing impacts, minimizing
trails, eroded areas and reduced sedimenta- human disturbances, planting wetland and
tion into creeks, ponds, and reservoirs, and riparian vegetation, offering public education
has planted willows; all of these actions have programs and developing guidelines for fire
increased habitat suitability by enhancing management practices to decrease incidental
aquatic and riparian habitats. impacts to California red-legged frogs. These
activities have contributed to the expansion of
Section 6(d) of the Federal Endangered the range of the frog within the watershed and
Species Act allows us to provide financial have helped to increase breeding success (J.
assistance to the State to assist in Alvarez in litt. 2000).
development of programs for the
conservation of endangered and threatened Protection on Private Lands. Private
species or to assist in monitoring the status of landowners interested in conservation efforts
candidate species. Through this program we, for riparian habitats have made important
along with the California Department of Fish contributions to recover the California red-
and Game, have funded several projects that legged frog. Since 1990, our Partners for Fish
have benefitted the California red-legged and Wildlife program has provided cost-share
frog. For example, surveying and monitoring monies and technical assistance to private
of the Sierra Nevada foothills have been landowners throughout the state who
funded through section 6(d), as were undertake fish and wildlife habitat restoration
restoration activities at Calabasas Pond (Santa projects. To date, the Partners for Fish and
Cruz County). Wildlife program has helped fund six projects
to improve habitat in creeks that support
Municipal Protection Measures. Regional, California red-legged frogs. In 1997, three
county, and city park districts and regional projects were carried out in Toro Creek in San
water and municipal utility districts have Luis Obispo County. Restoration activities
played a role in conserving habitat for the included stabilization of eroding streambanks
California red-legged frog. Some counties are and planting of riparian vegetation. In
preparing county-wide habitat conservation Sonoma County, eroding streambanks were
plans that will benefit the California red- stabilized and riparian vegetation was planted
legged frog (e.g., San Benito County, Contra in 1996 and 1997 in Stemple Creek (D. Strait
Costa County). The East Bay Regional Park in litt. 1998).
District encompasses 59 regional parks,
recreation and wilderness areas, shorelines, In 1995, the livestock industry agreed to
preserves and other land bank areas in Contra become involved in developing a cooperative
Costa and Alameda Counties, covering over approach to meet the regulatory requirements
33,000 hectares (91,000 acres). The East Bay in place for nonpoint source pollution
Regional Park District has surveyed ponds associated with rangeland practices by
and streams within its jurisdiction, has allowing land owners to voluntarily develop
restored several ponds and streams, and plans and implement California Rangeland Water
to restore additional areas, to benefit Quality Management Plans. The plans are
California red-legged frogs. Biologists from limited to non-Federal rangelands, pasture
the Santa Clara Valley Water District and East and other grazed lands of California (G.
Bay Municipal Utility District have surveyed Humiston in litt. 1995).
many areas within the districts for California
red-legged frogs; the Santa Clara Valley Interagency and Private Cooperative
Water District has plans to expand the survey Efforts. Throughout the range of the
program in upcoming years (D. Padley pers. California red-legged frog there are many
comm. 1998). The Contra Costa Water cooperative efforts aimed at restoring and
District actively manages the Los Vaqueros preserving wetland ecosystems and
watershed (Upper Kellogg Creek drainage) maintaining or increasing biodiversity. These
for California red-legged frogs by adjusting groups or projects are typically comprised of
some combination of Federal, State, and Research Center of the Biological Resources
municipal agencies as well as non- Division (part of the U.S. Geological Survey)
government organizations and private has several ongoing research projects. The
citizens. They demonstrate the commitment Piedras Blancas Field Station of the Western
that the private sector exhibits regarding Ecological Research Center has a research
conservation as well as the productivity that program in progress that is focused on radio-
can result when multiple groups collaborate. tracking the movements of adult California
One example includes the project named red-legged frogs in pastures and forested
Biodiversity in the Santa Cruz Mountains. habitats in both San Luis Obispo and Santa
This project is involved in an inventory of Cruz Counties. Another project, which
biodiversity in the Santa Cruz mountains as involves monitoring population dynamics and
well as a threats assessment. Cooperators ecology of California red-legged frogs in
include us, the California Department of Fish coastal streams in San Luis Obispo County, is
and Game, and the Santa Cruz Mountains contributing data on population fluctuations
Bioregional Council. Another example is the and turnover, movements, and reproductive
Carmel River Watershed Management Plan, behavior. This research group is also
which aims to assess conditions in the examining the effects of non-native frogs and
watershed and recommend a water fishes on California red-legged frogs on
management plan that will restore the river to Vandenberg Air Force Base, Santa Barbara
a level of productivity while benefitting County. The Western Ecological Research
wildlife species including the California red- Center field station at Point Reyes National
legged frog. Cooperators involved in this Seashore is conducting surveys for California
effort include the California Department of red-legged frogs in the Sierra Nevada
Fish and Game, the U.S. Forest Service, and foothills. In addition, they are investigating
the Monterey Peninsula Water Management the interactions between California red-
District. The Watsonville Slough’s Water legged frogs and livestock in pond sites at
Resources Management Plan is being Point Reyes National Seashore, Marin
developed to improve water quality in County, and are tracking frogs to determine
Watsonville Sloughs freshwater marsh habitat use at breeding sites and to monitor
system. This effort involves Federal, State, dispersal habits in the Olema Valley.
and municipal agencies as well as the Research groups associated with many
University of California, and Watsonville universities (e.g., University of California at
Wetland Watch. The Elkhorn Slough Davis, Sonoma State University, San Jose
Watershed Project’s purpose is to reduce State University) are investigating the
sediment and pesticide delivery to wetlands genetics and life history of California red-
by working cooperatively with private legged frogs and providing valuable
landowners and tenants to reduce agricultural information regarding distribution,
erosion and runoff. Similarly, the Pajaro systematics, habitat requirements, and life
River Management Plan is being developed history (Cook 1997).
by a large group of collaborators to address
flood control and environmental preservation We have been actively working with multiple
of this river. Many other examples exist as conservation partners in southern California
listed by the Information Center for the on developing a captive rearing and
Environment, which maintains a website that propagation program to augment existing
includes the California Watershed Projects populations of red- legged frogs and re-
Inventory (http://ice.ucdavis.edu). establish frogs into historic localities. These
partners include the Los Angeles Zoological
Surveys and Research. In addition to the Society, The Nature Conservancy, The Las
efforts of Federal, State, local, and private Virgenes Institute, and Center for Scientific
entities, status surveys for California red- Research and Higher Education in Ensenada,
legged frogs and research on the ecology of Baja California, Mexico. These efforts have
this species have been conducted by several concentrated on two separate programs.
research groups. The Western Ecological
The first program is the augmentation and re- The second program consists of a cooperative
establishment of the red-legged frog at the effort between us, the Los Angeles Zoo, and
Santa Rosa Plateau Ecological Reserve in the Las Virgenes Institute to monitor an
southwestern Riverside County. This effort extant breeding population in the Los Angeles
has concentrated on a cooperative effort with basin and develop a captive rearing,
The Los Angeles Zoo, The Nature propagation, and release protocol. After
Conservancy, and the Center for Scientific monitoring the population for several years to
Research and Higher Education in Ensenada, establish the size and breeding success,
Baja California, Mexico, to collect frogs from several metamorphs were brought into
an apparently genetically similar (genetics to captivity to develop a captive rearing protocol
be verified) breeding population in Baja and head-start program. This effort was
California to re-establish a breeding expanded to include tadpoles and will be
population at the Reserve. Once re- further expanded to include captive rearing
established and stabilized, this population and breeding ponds. Frogs from these ponds
will be used as a source population to re- will eventually be used to re-establish frogs
establish frogs into appropriate habits in into historic localities in the norther portion
southern California. of the Los Angeles basin.
Table 2. Sensitive fish species and wildlife associated with the California red-legged frog.
Taxa (Scientific name) Federal Status/State Status

California freshwater shrimp (Syncaris pacifica) endangered/endangered
Tomales asellid (Caecidotea tomalensis) species of concern/no status
California tiger salamander (Ambystoma californiense) candidate/species of special concern
Distinct Population Segment in Santa Barbara County endangered/species of special concern
Santa Cruz long-toed salamander (Ambystoma macrodactylum croceum) endangered/endangered
foothill yellow-legged frog (Rana boylii) species of concern/species of special concern
mountain yellow-legged frog (Rana muscosa) species of concern/species of special concern
arroyo southwestern toad (Bufo microscaphus californicus) endangered/species of special concern
western spadefoot toad (Scaphiopus hamondii) species of concern/species of special concern
Alameda whipsnake (Masticophis lateralis euryxanthus) threatened/threatened
two-striped garter snake (Thamnophis hammondii) species of concern/no status
San Francisco garter snake (Thamnophis sirtalis tetrataenia) endangered/endangered
western pond turtle (Clemmys marmorata) species of concern/species of special concern
tidewater goby (Eucyclogobius newberryi) endangered/species of special concern
unarmored threespine stickleback (Gasterosteus aculeatus williamsoni) endangered/endangered
coho salmon (Oncorhynchus kisutch) varies by evolutionarily significant unit
steelhead trout (Oncorhynchus mykiss) varies by evolutionarily significant unit
tricolored blackbird (Agelaius tricolor) species of concern/species of special concern
little willow flycatcher (Empidonax traillii brewsteri) species of concern/endangered
southwestern willow flycatcher (Empidonax traillii extimus) endangered/endangered
saltmarsh common yellowthroat (Geothlypis trichas sinuosa) species of concern/species of special concern
least Bell’s vireo (Vireo bellii pusillus) endangered/endangered
marsh sandwort (Arenaria paludicola) endangered/endangered
Gambel’s watercress (Rorippa Gambellii) endangered/threatened
The knowledge learned through both of these sharing of resources and decision making
programs will facilitate the development of on recovery actions for wide ranging
standardized protocols for rearing, breeding, species.
and re-establishment efforts for the red-
legged frog that can be used throughout the The current emphasis on multiple species
species’ range in California and possibly protection and management reflects a
Mexico. recognition of the way organisms interact
with each other and their environments. By
developing and implementing conservation
H. ASSOCIATED SPECIES measures aimed at restoring and protecting
the processes that maintain healthy ecosys-
We are committed to applying an ecosystem tems, future listings may be prevented. There
approach to conservation to promote efficient are several listed, proposed, or candidate fish,
and effective conservation of our Nation’s wildlife and plant species that occur in, or
biological diversity (U. S. Fish and Wildlife near, streams and wetlands that either histor-
Service 1994b). In recovery plans, it is our ically supported, or currently support
policy to incorporate ecosystem California red-legged frog populations (Table
considerations by: 2). Some of these species are included in
existing or developing recovery plans. In
1) Developing and implementing recovery these cases, actions taken to recover the
plans for communities or ecosystems California red-legged frog will also contribute
where multiple listed species and species to implementation of these recovery plans
of concern occur; (e.g., California freshwater shrimp,
southwestern willow flycatcher, least Bell’s
2) Developing and implementing recovery vireo, arroyo southwestern toad). Other
plans for threatened and endangered spe- species that are not covered by regulatory
cies in a manner that processes or existing recovery planning
restores, reconstructs, efforts (e.g., foothill yellow-legged frog,
or rehabilitates the mountain yellow-legged frog, western pond
Recovery plans shall be developed structure, distri- turtle, California tiger salamander, neotropi-
bution, connectivity, cal migratory songbirds), should also benefit
and implemented in a manner that and function upon from implementation of the California red-
which those listed legged frog recovery plan through improve-
conserves the biotic diversity of the species depend. In ments in wetland habitats where the ranges
particular, these overlap with California red-legged frogs.
recovery plans shall
ecosystem upon which the listed be developed and California freshwater shrimp. The California
implemented in a freshwater shrimp (Syncaris pacifica) is
species depend. manner that con- endemic to perennial streams in Marin, Napa,
serves the biotic and Sonoma Counties, California, and is the
diversity of the only existing species in the genus Syncaris.
ecosystems upon which the listed species The species is adapted to freshwater
depend; environments and has not been found in
brackish or estuarine environments. The
3) Expanding the scope of recovery plans to shrimp is found in low elevation (less than 16
address ecosystem conservation by meters [52 feet]) and low gradient (less than 1
enlisting local jurisdictions, private percent) streams where banks are structurally
organizations, and affected individuals in
recovery plan development and
implementation; and
4) Developing and implementing agreements

among multiple agencies that allow for
diverse with undercut banks, exposed roots, Most of the remaining range of the California
overhanging woody debris, or overhanging tiger salamander is threatened by urban
vegetation (Eng 1981, Serpa 1986, 1991). development, conversion of natural habitat
The shrimp is threatened by several types of and grazing lands to seasonal crops,
human activities (e.g., urbanization, in-stream vineyards, and orchards, introduction of non-
gravel mining, overgrazing, agricultural native predatory animals, construction of
development and activities, impoundments, reservoirs, poisoning campaigns to destroy
water diversions, water pollution, and rodents, environmental pollution, and other
introduced predators). Many of these threats anthropogenic factors (U.S. Fish and Wildlife
operate synergistically and cumulatively with Service 1994c, Stebbins and Cohen 1995).
each other and with natural disturbances such
as floods and droughts (U.S. Fish and Santa Cruz long-toed salamander. The Santa
Wildlife Service 1997a). Cruz long-toed salamander (Ambystoma
macrodactylum croceum)
Tomales asellid. The asellid (Caecidotea spends most of its life
tomalensis), an aquatic sowbug, inhabits underground in small
moist soils or water bodies with perennial mammal burrows and along the
flows although it has been found in seasonal root systems of plants in upland
wetlands (Shinomoto and Fong 1997). In chaparral and woodland areas of coast live
general, freshwater isopods, such as the oak (Quercus agrifolia) or Monterey pine
Tomales asellid, are associated with shallow (Pinus radiata) as well as in riparian strips of
waters less than 1 meter (3 feet) deep, and are arroyo willows (Salix lasiolepis). The
found under rocks, vegetation, and debris breeding ponds are usually shallow,
(Serpa 1991). The Tomales asellid is known ephemeral, freshwater ponds or quiet, marshy
from just 11 sites within California, from areas of sloughs. Adult Santa Cruz long-toed
Mendocino County to San Mateo County salamanders leave their upland chaparral and
(Serpa 1991). woodland summer retreats with the onset of
the rainy season in mid- to late-November or
California tiger salamander. The historic December, and begin their annual nocturnal
distribution of the California tiger salamander migration to the breeding pond (Anderson
(Ambystoma californiense) apparently 1960).
included large portions of the Central Valley
of California, from the southern Sacramento Breeding of Santa Cruz long-toed
Valley north of the Sacramento River delta salamanders has been documented at Valencia
into the southern San Joaquin Valley. The Lagoon, Ellicott, Seascape, Calabasas, Buena
salamander also was found in the lower Vista, Green, and Rancho Road ponds in
foothills along the eastern side of the Central Santa Cruz County and at McClusky, Moro
Valley and in the foothills of the Coast Cojo, and Bennett sloughs, and McClusky
Ranges (U.S. Fish and Wildlife Service vernal pool in Monterey County. However,
1994c). many of these sites have not been surveyed
recently and may no longer support breeding
The salamander occurs in grasslands and populations. Juvenile Santa Cruz long-toed
open oak woodlands. Necessary habitat salamanders have also been found at several
components include rodent burrows for other sites in Santa Cruz and Monterey
underground retreats and breeding ponds, Counties (Natural Diversity Database 2001).
such as artificial stockponds, seasonal
wetlands, vernal pools, or slow-moving The extremely restricted and disjunct
streams, that do not support fish. Because the distribution of the Santa Cruz long-toed
salamander may migrate up to a mile salamander has made the species particularly
(approximately 1.5 kilometers) from its susceptible to population declines resulting
underground retreats to breeding ponds, from both human-associated and natural
unobstructed migration corridors are also factors, including habitat loss and
required (U.S. Fish and Wildlife Service degradation, predation by introduced and
1994c).
native organisms, and weather conditions. Arroyo southwestern toad. The arroyo
Highway construction, urban and agricultural southwestern toad (Bufo microscaphus
development, siltation, off-highway vehicles, californicus) is restricted to rivers that have
non-native fish and vegetation, and saltwater shallow, sandy to gravelly pools adjacent to
intrusion are some of the perturbations sandy terraces. Breeding occurs on small to
affecting Santa Cruz long-toed salamander medium streams and rivers with persistent
habitat. water from late March until mid-June (Sweet
1989). Historically, arroyo southwestern
Foothill yellow-legged frog. Within the range toads were found in coastal drainages in
of the California red-legged frog, the foothill southern California from San Luis Obispo
yellow-legged frog (Rana boylii) occurs County to San Diego County and in Baja
along the central coast and in the Sierra California, Mexico (US Fish & Wildlife
Nevada (Leonard et al. 1993). The foothill Service 1999). In Orange and San Diego
yellow-legged frog is confined to the Counties, the species occurred in low gradient
immediate vicinity of permanent streams, stream reaches. Arroyo southwestern toads
including those that may be reduced to water now survive primarily in the headwaters of
holes connected by trickles during the dry coastal streams as small isolated populations.
season. The frogs are most common along In 1996, they were discovered on Fort Hunter
streams having rocky, gravelly, or sandy Liggett in Monterey County. Urbanization
bottoms, but they may occur in those having and dam construction beginning in the early
muddy bottoms (Nussbaum et al. 1983). 1900s in southern California caused most of
Introduced predators, habitat fragmentation, the extensive habitat degradation. Mining,
and disease seem to be important factors in livestock grazing, and recreational activities
the decline of this species (Jennings 1996). in riparian areas have also degraded habitat
(U.S. Fish and Wildlife Service 1994d).
Mountain yellow-legged frog. Before the late Arroyo southwestern toads historically
1960s, mountain yellow-legged frogs (Rana occurred with California red-legged frogs in
muscosa) were abundant in southern the Transverse and Peninsular ranges. They
California stream drainages. The mountain still occur in the same streams on the Los
yellow-legged frog originally inhabited Padres National Forest.
riverbanks, meadow streams, isolated pools,
and lake borders in the Sierra Nevada above Western spadefoot toad. Spadefoot toads are
1,370 meters (4,500 feet) from Butte Creek, olive-brown or gray, with dark blotches and
Plumas County, south to Taylor Meadow, little red bumps. Adults have a light-colored,
Tulare County, California and also occurred hourglass pattern on their back. In adult
in streams in the Palomar, San Bernardino, males, the smooth skin of the throat is
San Gabriel, and San Jacinto mountain ranges charcoal-gray. The young are nearly the same
in southern California between 400 meters color as adults, but they do not have the
(1,300 feet) and 2,300 meters (7,500 feet) hourglass pattern on their backs. They have a
(Jennings and Hayes 1994). The southern tiny black shovel (spade) on each hind foot.
California population of mountain yellow-
legged frogs has probably been extirpated Spadefoot toads use grasslands and breed in
from more than 99 percent of its historic natural vernal pools and man-made stock
range (U.S. Fish and Wildlife Service 1997b). ponds. Western Spadefoots have now largely
This species is threatened by non-native disappeared in lowland southern California,
aquatic predators, changes in streamflows, although populations remain in other parts of
land use practices, loss of habitat, possibly a the State. Western spadefoot toads occur in
sensitivity to ultraviolet radiation and urban the same areas as California red-legged frogs
atmospheric pollution, and various other in several areas including the Corral Hollow
natural and human caused factors throughout watershed (Alameda and San Joaquin
its range (U.S. Fish and Wildlife Service Counties), Sunol Regional Wilderness
1997c). (Alameda County), and Simon Newman
Ranch (Santa Clara County).
Alameda whipsnake. The Alameda San Francisco garter snake. The San
whipsnake (Masticophis lateralis Francisco garter snake’s (Thamnophis sirtalis
euryxanthus) occurs in northern coastal scrub, tetrataenia) preferred habitat is densely
chaparral, and adjacent habitats in the inner vegetated ponds that are located near open
coast ranges of western and central Contra hillsides or levees. Hillsides and levees are
Costa and Alameda Counties. Five also used by the snake for basking, feeding,
populations of the whipsnake are centered in and cover (e.g., rodent burrows). Threats to
the (1) Sobrante Ridge, Tilden/Wildcat the San Francisco garter snake include loss of
Regional Parks area to the Briones Hills, in habitat from agricultural, commercial, and
Contra Costa urban development. The decline of the
County, (2) California red-legged frog (an important prey
Oakland Hills, species of the San Francisco garter snake) and
Anthony Chabot the introduction of bullfrogs into San
area to Las Trampas Ridge, in Francisco garter snake habitat are additional
Contra Costa County; (3) Hayward Hills, threats (S. Larsen pers. comm. 1998).
Palomares area to Pleasanton Ridge, in Currently, this species is found in only a few
Alameda County; (4) Mount Diablo vicinity localities in San Francisco and San Mateo
and the Black Hills, in Contra Costa County; Counties.
and (5) Wauhab Ridge, Del Valle area to the
Cedar Mountain Ridge, in Alameda County. Western pond turtle. The western pond turtle
The Alameda whipsnake and its habitat are (Clemmys marmorata) is currently divided
threatened by commercial and residential into two subspecies: the northwestern pond
development, fire suppression, turtle (Clemmys marmorata marmorata),
overcollecting, competition from alien plants, which occurs from the vicinity of the
inappropriate grazing levels, off-road vehicle American River in California northward to
use, and random chance events by virtue of the lower Columbia River (Oregon-
their small numbers and small, fragmented Washington), and the southwestern pond
population sizes (U.S. Fish and Wildlife turtle (Clemmys marmorata pallida), found in
Service 1996d). coastal drainages from the vicinity of
Monterey, California south to northwestern
Two-striped garter snake. The two-striped Baja California, Mexico. There is an
garter snake (Thamnophis hammondii) lacks a intergrade zone south of the American River
middorsal stripe, having pale to indistinct and north of Monterey ( Stebbins 1985).
lateral stripes on an olive, brown, or
brownish-gray background color. Individuals Western pond turtles are habitat generalists
usually have dark spots dorsal to the lateral and occur in a wide variety of permanent and
stripes, but no red on the sides. The species intermittent aquatic habitats (Holland 1991).
occurs in or near permanent fresh water In streams and rivers, turtles generally avoid
streams in coastal, transverse, and peninsular fast-moving and shallow waters and are
ranges from Monterey County, California, to concentrated in pools and backwater areas.
northwestern Baja California. Two-striped Turtles are uncommon in heavily shaded
garter snakes forage on all life stages of toads areas and prefer openings in the streamside
and frogs (including California red-legged canopy that provide sufficient sunlight for
frogs), fish, fish eggs, and earthworms. The basking.
species’ range has been greatly reduced by
housing and urban development, and by water Threats to the turtles include introduced and
control projects that reduce summer flows. native predators, habitat alteration,
The introduction of non-native predators such urbanization, poaching, historic commercial
as bullfrogs and crayfish may have had exploitation, water pollution, and disease.
additional impacts. Excessive grazing activities in riparian areas
adversely impact turtle populations by
collapsing undercut banks used as shelter, and
by consuming emergent vegetation used as

habitat by hatchling and first-year turtles an
(Holland 1991). anadromous
species; coho salmon
Tidewater goby. Tidewater gobies generally return to their natal streams to
(Eucyclogobius newberryi) inhabit sandy and spawn after spending 2 years in the ocean.
silty bottoms of lagoons, shallow bays, and The spawning migrations begin after heavy
estuaries. The tidewater goby ranged from late-fall or winter rains breach the sandbars at
Lake Earl, Del Norte County south to Agua the mouth of coastal streams, allowing the
Hedionda Creek, Carlsbad, San Diego County fish to move into them. Spawning occurs in
(Irwin and Soltz 1984). They are common in small to medium-sized gravel at well-aerated
San Luis Obispo and Santa Barbara County sites, typically near the head of a riffle
streams (Moyle 1976, Swift et al. 1989) (Moyle 1976). These streams have summer
where California red-legged frogs are also temperatures seldom exceeding 21 degrees
abundant. Threats include coastal Celsius (70 degrees Fahrenheit). Emergent fry
development, dredging of coastal waterways, use shallow near-shore areas, whereas
coastal road construction, and upstream optimal habitat conditions for juveniles and
diversions (U.S. Fish and Wildlife Service sub-adults seem to be deep pools created by
1994e). rootwads and boulders in heavily shaded
stream sections (U.S. Fish and Wildlife
Unarmored threespine stickleback. Service 1996a). The distribution and habitat
Unarmored threespine sticklebacks of coho juveniles partially overlaps with that
(Gasterosteus aculeatus williamsoni) are of the California red-legged frog.
small fish measuring up to 60 millimeters (2
inches). They inhabit slow moving reaches or Because of dramatic declines in population
quiet water microhabitats of streams and numbers, the National Marine Fisheries
rivers. Favorable habitats usually are shaded Service was petitioned to list this species
by dense and abundant vegetation, but in coast-wide. Several runs were listed along the
more open reaches, algal mats may provide central California coast and include regions
refuge for the species. Unarmored threespine occupied by California red-legged frogs.
sticklebacks reproduce throughout the year Causes of coho salmon declines in California
with a minimum of breeding activity occur- include incompatible land-use practices such
ring from October to January. Historically, as logging and urbanization, loss of wild
they were distributed throughout southern stocks, introduced diseases, over harvesting,
California but are now restricted to San and climatic changes.
Antonio and Cañada Honda Creeks on
Vandenberg Air Force Base, in Santa Barbara Steelhead trout. Steelhead trout
County, the upper Santa Clara River and its (Oncorhynchus mykiss) are anadromous
tributaries in Los Angeles and Ventura rainbow trout; adult steelhead typically spawn
Counties, Shay Creek in San Bernardino in gravel riffles in the spring, from February
County, and San Felipe Creek in San Diego to June. Optimum temperatures for growth
County. The range overlaps with California range from 13 to 21 degrees Celsius (55 to 70
red-legged frogs in the central coast, particu- degrees Fahrenheit) (Moyle 1976). Steelhead
larly in Santa Barbara County. Competition fry reside in near-shore areas. Steelhead
with non-native fish, interbreeding with other juveniles tend to use riffles and pool margins,
subspecies of sticklebacks, and loss of habitat potentially overlapping with California red-
to urbanization are factors associated with its legged frog tadpoles.
decline.
The National Marine Fisheries Service was
Coho salmon. The general biology of coho petitioned to list this species coast-wide.
salmon (Oncorhynchus kisutch) is described Steelhead trout is federally listed as
in detail in McMahon (1983), Hassler (1987), threatened, along the northern, central, and
and Sandercock (1991). The coho salmon is south-central California coast, and listed as
endangered in southern California and the Southwestern willow flycatcher. The

Central Valley. southwestern willow flycatcher (Empidonax
traillii extimus) is a small bird, with a
Tricolored blackbird. Tricolored blackbirds grayish-green back and wings, whitish throat,
(Agelaius tricolor) are colonial passerines light grey-olive breast, and pale yellowish
that require several habitat components for belly. The range includes southern California,
suitable breeding colony sites. These include Arizona, New Mexico, and portions of
open accessible water, a protected nesting Nevada, Utah, and western Texas (Unitt
substrate, and suitable foraging space within a 1987, Tibbitts et al. 1994). It occurs in
few kilometers (approximately 2 miles) of the riparian habitats along rivers, streams or other
nesting colony (Beedy and Hamilton 1997). wetlands, where dense growth of willows,
Most breeding colonies are in freshwater tamarisk, or other riparian plants are present,
marshes dominated by tules (Scirpus sp.) and often with a scattered overstory of
cattails, some use willows (Salix spp.), cottonwood (Populus spp.). The southwestern
blackberries (Rubus sp.), thistles (Cirsium willow flycatcher has experienced extensive
and Centaurea spp.), or nettles (Urtica sp.) loss and modification of habitat (in both
(Neff 1937). Results from a statewide 1997 breeding habitat in North America and
survey for tricolored blackbirds, coordinated wintering habitat in Mexico and Central
by the California Department of Fish and America) and is also endangered by brood
Game, indicate that the population numbers parasitism by the brown-headed cowbird
of tricolored blackbirds declined by about 37 (Molothrus ater). Several populations occur
percent compared to results of a 1994 survey. within the current and historic range of the
The greatest declines occurred in Sacramento, California red-legged frog including
Fresno, Kern, and Merced Counties (Beedy populations located on the Santa Margarita,
and Hamilton 1997). Threats to the tricolored Santa Ynez, Santa Ana, San Luis Rey, and
blackbird include nest failure due to Kern Rivers (U.S. Fish and Wildlife Service
predation, habitat loss and alteration, 1995).
contaminants, and pollution. The current
ranges of the tricolored blackbird and the Saltmarsh common yellowthroat. The
California red-legged frog overlap in saltmarsh common yellowthroat (Geothlypis
Alameda, Santa Clara, Monterey, San Luis trichas sinuosa) is a small marsh dwelling
Obispo, and Merced Counties. warbler of the subfamily Parulinae. It is also
referred to as the San Francisco common
Little willow flycatcher. This subspecies yellowthroat. Saltmarsh yellowthroats nest in
(Empidonax traillii brewsteri) is a variety of habitats. In a study conducted by
distinguished from the southwestern willow the San Francisco Bird Observatory (Hobson
flycatcher (Empidonax traillii extimus) et al. 1986), yellowthroat nesting territories
primarily by subtle differences in color, were observed in five habitat types including
morphology and song (Unitt 1987). The brackish marsh, salt marsh, riparian woodland
breeding range of the little willow flycatcher or swamp, freshwater marsh, and upland/or
extends from central/coastal California north grassland. Yellowthroats frequently use
through western Oregon and Washington to borders between various plant communities
Vancouver Island, Canada. The range of the and territories often straddle the interface of
little willow flycatcher overlaps with portions riparian corridors and ecotones between
of the current and historic range of the freshwater or tidal marsh and the upland
California red-legged frog (i.e., Coast range vegetation of weedy fields or grassland
and Sierra Nevada foothills). The little willow (Hobson et al. 1986). Extensive changes have
flycatcher uses similar habitat components of occurred in San Francisco Bay since the turn
the riparian corridor as the southwestern of the century that have resulted in reductions
willow flycatcher and is threatened by similar in the extent and suitability of habitat for the
factors including brood parasitism, grazing, yellowthroat. The remaining habitat is under
and loss of riparian habitat. threat from a number of sources which range
from land development to flood control
actions. Surveys conducted in 1977, 1985 Marsh sandwort. The marsh sandwort
(Hobson et al. 1986), and 1996 (Nur et al. (Arenaria paludicola) is a herbaceous green
1997) for the saltmarsh common perennial often supported by surrounding
yellowthroat, indicate that the species is vegetation, with angled or grooved stems.
present in the following counties: Sonoma, The species blooms from May to August.
Napa, Solano, Marin, San Francisco, Contra Flowers are small, white, and borne singly on
Costa, Alameda, San Mateo, and Santa Clara. long stalks. Only two of California’s seven
Saltmarsh common yellowthroat occurrences historical populations of marsh sandwort are
overlap with the California red-legged frog in know to exist today, near the southern San
riparian and freshwater marsh habitats. Luis Obispo County coast at Black Lake
Canyon on the Nipomo Mesa and at Oso
Least Bell’s vireo. The least Bell’s vireo Flaco Lake further south. Recently, another
(Vireo bellii pusillus) is a small gray, occurrence of the Arenaria paludicola was
migratory passerine. It was once widespread found in MacKerricher State Park,
and abundant as a nesting species throughout Mendocino County. Marsh sandwort is found
the Central Valley and other low-elevation in freshwater marshes. Immediate threats to
riverine valleys. Its historic range extended its survival include habitat degradation or
from interior northern California (near Red destruction and competition with exotic
Bluff, Tehama County) to northwestern Baja species for light, water, nutrients, and space.
California, Mexico. It is assumed to be Other threats to the survival of the species
extirpated from the Sacramento and San may be related to biological and genetic
Joaquin valleys, and its breeding range seems factors and the occurrence of sudden
to be restricted to Inyo, Santa Barbara, disastrous events.
Ventura, Los Angeles, San Bernardino, San
Diego, and Riverside Counties (Goldwasser Gambel’s watercress. The Gambel’s
1978). Recent evidence of breeding has been watercress (Rorippa gambellii) is a member
documented in San Benito and Monterey of the mustard family (Brassicaceae) and is
Counties (L. Hays pers. comm. 1998) and an herbaceous perennial that produces dense
Santa Clara County (D. Padley pers. comm. white flowers from April to June. This plant
1998). The vireo’s range overlaps with the is found in freshwater or brackish marsh
California red-legged frog in Santa Barbara habitats at the margins of lakes or along slow-
County (e.g., Santa Ynez River), Ventura flowing streams. Three known populations
County (e.g., Santa Clara River near Lake occur in San Luis Obispo County at Black
Piru), and San Benito, Monterey, and Santa Lake Canyon, Oso Flaco Lake, and lands
Clara Counties. The vireo primarily inhabits owned by the California Department of Parks
dense, willow-dominated riparian habitats and Recreation (Pismo Beach State Vehicle
with lush understory vegetation. It is Recreation Area). This species faces threats
threatened by loss of habitat, grazing of from alteration of hydrology, competition
riparian corridors, and brood parasitism by with encroaching eucalyptus trees
the brown-headed cowbird (U.S. Fish and (Eucalyptus globulus), urban
Wildlife Service 1998). development, and stochastic
extinction due to the small
number of individuals and
populations that remain.
45
II. Recovery
A. RECOVERY OBJECTIVES AND STRATEGIES will be focused within suitable habitat in each
recovery unit. Recovery unit boundaries and a
The objective of this recovery plan is to delist detailed description of recovery units follows
the California red-legged frog. Eight recovery in section C of this Recovery section (Figure
units have been established for the California 11).
red-legged frog. Because of the varied status
of this subspecies and differing levels of Overall, the strategy for recovery of the
threats throughout its range (Table 3), California red-legged frog will involve: 1)
recovery strategies differ per recovery unit to protecting existing populations by reducing
best meet the goal of delisting the species. threats; 2) restoring and creating habitat that
For example, in areas where California red- will be protected and managed in perpetuity;
legged frog populations appear to be stable, 3) surveying and monitoring populations and
recovery strategies will be to protect existing conducting research on the biology of and
population numbers, whereas in areas where threats to the subspecies; and 4) reestablish-
frogs have been extirpated or are declining, ing populations of the subspecies within its
strategies will be to stabilize, increase, historic range.
augment, or reestablish populations.
Differences within recovery units are also Protection of existing populations will occur
evident. Thus, recovery actions such as through preservation (e.g., fee title acquisi-
implementing land use guidelines are not tion, conservation easements, conservation
expected to be applied across-the-board agreements) and management of occupied
within each recovery unit or throughout the drainages and cor areas. Reduction of threats
range of the frog; recovery implementation will focus on reversing the apparent loss and
Table 3. Threats to California red-legged frogs and their recovery status per recovery unit.
Recovery
Recovery Unit Threats Status
1. Sierra Nevada Foothills and Central Valley Ag, Li, Mi, Nn, Re, Ti, Ur,Wa Low
2. North Coast Range Foothills and Western Sacramento River Valley Ag, Li, Nn, Ti, Ur Low
3. North Coast and North San Francisco Bay Li, Nn, Ur, Wa High
4. South and East San Francisco Bay Li, Nn, Ur, Wa, High
5. Central Coast Ag, Li, Mi, Nn, Re, Ti, Ur, Wa High
6. Diablo Range and Salinas Valley Ag, Li, Mi, Nn, Re, Ur, Wa Med
7. Northern Transverse Range and Tehachapi Mountains Ag, Mi, Nn, Re, Wa, High
8. Southern Transverse and Peninsular Ranges Ag, Li, Mi, Nn, Re, Ur,Wa Low
Threats: Ag=Agriculture, Nn=Non-native species, Li=Livestock (cattle grazing and/or dairies), Mining=Mi,
Re=Recreation, Ti=Timber, Ur=Urbanization, Wa=Water Management/Diversions/Reservoirs
Recovery Status:
Low: Few existing populations, high levels of threats and, in general, medium habitat suitability
Med: Numerous existing populations, some areas of medium habitat suitability, high levels of threats
High: Many existing populations, many areas of high habitat suitability, low to high levels of threats
degradation of habitat by improving the Upon completion of the tasks aimed at

quality and connectivity of aquatic and removing threats and increasing habitat
upland habitats within core watersheds. protection, recovery is expected to occur
Efforts are needed to decrease the impacts of through natural recolonization and population
urbanization and the conditions that allow the expansion. This may be highly unlikely,
proliferation of non-native aquatic predators. however, in portions of the historic range
In addition, research is necessary to develop where frogs are absent or nearly absent. In
solutions to the pollution which may be these areas, determining the reasons for local
detrimental to all life stages of the California or regional extirpation will be necessary
red-legged frog. followed by implementation of the
appropriate recovery tasks to increase
Habitat needed by the California red-legged suitability and reduce threats. Upon
frog for reproduction, development, and achieving the necessary habitat conditions,
survival is dependent on the dynamic nature pilot re-establishment programs may help to
of aquatic systems (riparian, sag ponds, increase the current range and recover the
springs, lagoons, marshes, vernal pools, etc.). red-legged frog. Re-establishment is not
Therefore, recovery will be achieved when expected to be implemented in recovery units
breeding habitats are created and maintained where California red-legged frog populations
naturally by fluctuating hydrological, are numerous unless large distances occur
geological, and ecological processes. In between populations and natural dispersal/
regulated bodies of water where natural expansion is unlikely to occur. In largely
processes are interrupted, water management unoccupied areas where isolated, unstable
regimes and land use practices appropriate to populations exist, population augmentation
maintain habitat suitability must be (i.e. adding individuals to the population)
demonstrated over the long term, prior to may be appropriate.
delisting. Habitat protection and restoration
will be achieved by controlling non-native
predators, managing flows in ways that are B. RECOVERY CRITERIA
beneficial for frogs, controlling erosion and
sedimentation, replanting wetland vegetation, Delisting of this species will be considered
and increasing connectivity of habitat when:
between known breeding areas. One
component of the recovery strategy will be to 1) Suitable habitats within all core areas
encourage private landowners and public land (described in section D below) are protected
managers that have existing man-made ponds and/or managed for the California red-legged
(e.g., stock ponds) to modify pond structure frog in perpetuity, and the ecological integrity
and management such that they best provide (e.g., water quality, uplands condition,
breeding habitat for frogs. While the focus of hydrology) of these areas is not threatened by
recovery is on natural, dynamic aquatic adverse anthropogenic habitat modification
systems and healthy uplands, in some (including indirect effects of upstream/
recovery units (e.g., south and east San downstream land uses);
Francisco Bay, Diablo Range), the
importance of artificial pond management is 2) Existing populations, throughout the
expected to be high. These artificial ponds range, are stable (i.e., reproductive rates
may prove to be critical in years where allow for long term viability without human
conditions in natural aquatic systems are intervention). Because population numbers
unsuitable by providing alternative habitat for do not necessarily indicate stability (i.e., a
dispersing juveniles and adults. In both population may have large numbers of
natural and artificial habitats, protection via individuals one year then decline
conservation easements, acquisition, or other precipitously as documented at the Santa
mechanisms is expected to provide long-term Rosa Plateau locality), long term evidence of
benefits to the species. successful reproduction (e.g., presence of
juveniles) and survivorship into different age
classes provides a better indication of The five listing criteria under section 4(a)(1)
stability, persistence, and population describe the reasons for decline and threats
resilience. Therefore, population status will that led to the listing of the California red-
be documented through establishment and legged frog. These are described, in detail, in
implementation of a scientifically acceptable Section F, Reasons for Decline and Threats to
population monitoring program for at least a Survival in Section I, Introduction. The above
15-year period (four to five generations) that recovery criteria relate to these listing factors
includes an average precipitation cycle (a in that they will reverse the negative effects of
period when annual rainfall includes average these threats and result in recovery of this
to 35 percent above-average through greater species. Each recovery criterion (delisting
than 35 percent below-average and back to criterion) can be met via implementation of
average or greater; the direction of change is the recommended recovery tasks as described
unimportant in this criterion). in the Outline of Recovery Actions in Section
III (see Table 4). Land use guidelines are
3) Populations are geographically distributed provided in the Outline of Recovery Actions
in a manner that allows for the continued that should be used when developing
existence of viable metapopulations despite watershed management and protection plans
fluctuations in the status of individual that are required of Tasks 1.0, 2.0, and 3.0;
subpopulations (i.e., when populations are these guidelines will also be useful in
stable at each core area); implementing many other tasks. General
recovery goals that address metapopulation
4) The subspecies is successfully viability, dispersal, and reestablishment
reestablished in portions of its historic range within the historic range will provide the
such that at least one reestablished population California red-legged frog with the stability
is stable/increasing in each core area where needed to survive fluctuating environmental
frogs are currently absent; and conditions and thus reduce susceptibility to
manmade and natural effects (e.g., drought,
5) The amount of additional habitat needed invasions of predators).
for population connectivity, recolonization,
and dispersal has been determined, protected,
and managed for the California red-legged C. RECOVERY UNITS
frog. There will be varying scales of
connectivity needed including at the level of a Initial Recovery Units. In the May 23, 1996,
local population (i.e., connectivity of habitat Final Rule listing the California red-legged
within a drainage) up to the needs of a frog as federally threatened, the following
metapopulation (many linked drainages over recovery units were established:
large regions such as recovery units). This
will provide dispersal opportunities for 1. The western foothills and Sierra Nevada
population viability, genetic exchange, and foothills to approximately 1,500 meters
recolonization. (5,000 feet) in elevation in the Central Valley
hydrographic basin.
Criteria for delisting will be revised and
quantified as additional information is 2. The Central Coast ranges from San Mateo
provided by research projects and monitoring and Santa Clara Counties south to Ventura
programs. If it is determined through research and Los Angeles Counties.
that distinct vertebrate population segments
exist, delisting may be considered 3. The San Francisco Bay/Suisun Bay
independently for each distinct vertebrate hydrologic basin.
population (see section C below). If recovery
criteria are met, rangewide delisting of the 4. Southern California, south of the Tehachapi
California red-legged frog could occur by Mountains.
2025.
5. The northern coast range in Marin and
Sonoma Counties.
Based on conservation needs, ecology, and recovery units as opposed to the statewide
distribution, the recovery units as described in range, and therefore, will benefit from a
the final rule (U.S. Fish and Wildlife Service region-specific approach to conservation. As
1996a) were revised, to facilitate recovery of the recovery units reflect areas with similar
the California red-legged frog (Figure 11). conservation needs and population statuses,
The eight recovery units are essential to the appropriate means of implementation and
recovery of this subspecies; throughout monitoring of the recovery plan will be
implementation of this recovery plan and in facilitated. Individual recovery units of the
other planning efforts (e.g., section 7 California red-legged frog may be considered
consultations pursuant to the Endangered for delisting if research shows that they may
Species Act), the status of the frog will be be regarded as distinct vertebrate population
considered within the smaller scale of segments. Distinct population segments are
Table 4. Recovery Goals and Tasks Aimed at Reducing or Eliminating Threats
Listing Criterion Recovery Criterion Tasks Within Recovery Plan

and Threats (Delisting Criterion) that Address Threat Reduction
or Elimination
1. Present or threatened destruction, modification, or curtailment of habitat or range

Curtailment of Range 4 10.1, 10.2, 10.2.1, 10.3.2, 10.3.3
Urbanization 1 1.0, 2.0, 3.0, 4.0, 5.0, 6.1
Agriculture 1 1.0, 2.0, 4.0, 11.7
Water Management 1 1.0, 2.0, 3.0, 4.0, 7.0
Flood Control 1 1.0, 2.0, 3.0, 4.0, 5.0
Mining 1 1.0, 7.0
Grazing 1 1.0, 11.13, 11.13.2
Recreation 1 1.0, 4.0
Timber 1 1.0
2. Overutilization for commercial, recreational, scientific, or education purposes

Exploitation 2 12.1
Scientific Take 2 9.1, 9.2, 11.1
3. Disease and Predation

Disease 3 9.1, 9.2
Predation by Introduced Species 1,3 1.0, 11.8, 11.9, 11.15
Predation by Native Species 1,3 1.0, 1.3
4. Inadaquacy of existing regulatory mechanisms

Section 7(a)(2) of ESA 1,3,5 6.1, 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, 6.8, 6.9
5. Other natural or manmade factors

Drought 3,4 4.0, 11.3.2, 11.3.3, 11.5, 11.6
Contaminants 1 1.0, 4.0, 5.0, 7.0, 8.0, 11.7
defined by us for the purposes of listing, Stanislaus, Upper Calaveras, Lower

delisting and reclassification of vertebrate Cosumnes-Lower Mokelumne, Lower
fish or wildlife taxa. To be determined a Calaveras-Mormon Slough, Upper
distinct population segment, the portion of the Mokelumne, and Upper Cosumnes.
taxon under consideration must be ‘discrete’
and ‘significant’ in relation to the remainder 2. North Coast Range Foothills and Western
of the taxon. A portion of a taxon may be Sacramento River Valley. Watersheds
considered discrete if it is separated from include: Lower Cottonwood, Sacramento-
other portions of the taxon by geographic, Lower Thomes, Lower Sacramento, Lower
genetic, physiological, behavioral, or Cache, Sacramento-Upper Clear, Cottonwood
ecological factors. The portion of the taxon is Headwaters, Upper Elder-Upper Thomes,
considered ‘significant’ if it occupies a setting Upper Stony, Sacramento-Stone Corral,
that is unusual or unique for the taxon, if its Upper Cache, and Upper Putah.
loss would result in an appreciable gap in the
range of the taxon, or if it is substantially 3. North Coast and North San Francisco
different genetically from the rest of the Bay. Watersheds include: Tomales-Drakes
taxon. If a population segment is both discrete Bays, San Pablo Bay (partial), and Suisun
and significant, then it qualifies as a distinct Bay (partial).
population segment, and it may be considered
independently for listing or delisting (U.S. 4. South and East San Francisco Bay.
Fish and Wildlife Service 1996e). The eight Watersheds include: Suisun Bay (partial), San
recovery units identified in this plan are Pablo Bay (partial), San Francisco Coastal
delineated by watershed boundaries as South (partial), San Francisco Bay, Coyote,
defined by U.S. Geological Survey and San Joaquin Delta.
hydrologic units and the limits of the range of
the California red-legged frog (i.e., 1,500- 5. Central Coast. Watersheds include: San
meter [5,000-foot] elevation). The following Francisco Coastal South (partial), San
lists the U.S. Geological Survey hydrologic Lorenzo-Soquel, Central Coastal, and
units included in each recovery unit. Carmel.
Revised Recovery Units. 6. Diablo Range and Salinas Valley.

Watersheds include: Panoche-San Luis
1. Sierra Nevada Foothills and Central Reservoir, Pajaro, Upper Gatos, Estrella,
Valley. The eastern boundary is the 1,500- Tulare-Buena Vista Lakes (partial), Carrizo
meter (5,000-foot) elevation. Watersheds Plain, Alisal-Elkhorn Sloughs, and Salinas.
include: Sacramento Headwaters, McCloud,
Lower Pit, Sacramento-Lower Cow-Lower 7. Northern Transverse Ranges and
Clear, Upper Cow-Battle, Mill-Big Chico, Tehachapi Mountains. Watersheds include:
Upper Butte, North Fork Feather, East Branch Middle Kern-Upper Tehachapi-Grapevine,
North Fork Feather, Middle Fork Feather, Santa Maria, Santa Ynez, Cuyama, San
Honcut Headwaters, Upper Yuba, Upper Antonio, Santa Barbara, Ventura, Santa
Bear, Upper Coon-Upper Auburn, North Fork Clara, and Antelope-Fremont Valleys
American, South Fork American, Lower (partial).
Butte, Lower Feather, Lower Yuba, Lower
Bear, Lower American, Upper Kern, South 8. Southern Transverse and Peninsular
Fork Kern, Upper Poso, Upper Deer-Upper Ranges. Watersheds include: Calleguas,
White, Upper Tule, Upper Kaweah, Mill, Santa Monica Bay, Los Angeles, San Gabriel,
Upper Dry, Upper King, Tulare-Buena Vista Antelope-Fremont Valleys (partial), Santa
Lakes, Middle San Joaquin-Lower Ana, San Jacinto, Seal Beach, Newport Bay,
Chowchilla, Middle San Joaquin-Lower Aliso-San Onofre, Santa Margarita, San Luis
Merced-Lower Stanislaus, Upper San Rey, San Diego, Cottonwood-Tijuana,
Joaquin, Upper Chowchilla-Upper Fresno, Whitewater River, San Felipe Creek, and
Upper Merced, Upper Tuolumne, Upper Salton Sea (partial).
D. CORE AREAS AND PRIORITY ecosystems used by the California red-legged

WATERSHEDS FOR FOCUSED RECOVERY frog (i.e., inclusion of non-coastal
EFFORTS ecosystems). These unoccupied areas will
require varying degrees of rehabilitation with
Core Areas: the expectation of future recolonization or
While a goal of the recovery plan is to protect reestablishment efforts when habitat
the long-term viability of all existing popula- suitability has been restored.
tions within each recovery unit, several areas
have been identified as core areas where While core areas are mapped in Figure 12, the
recovery actions will be focused (Figure 12 entire area described as a core area may not
and Appendix C). The core areas, which are represent suitable California red-legged frog
distributed throughout portions of the historic habitat. Habitats within core areas should be
and current range, represent a system of areas assessed for suitability. This is especially
that, when protected and managed for important in areas between the elevations of
California red-legged frogs, will allow for 1,050 and 1,500 meters (3,500 and 5,000
long-term viability of existing populations feet). At these elevations, known localities are
and reestablishment of populations within the rare and suitable habitat appears to be less
historic range. The core areas were chosen for abundant. In addition to elevational
focused recovery either because they repre- constraints, many portions of the mapped
sent viable populations (possibly even source core areas are agricultural lands and urban
populations for larger metapopulations), or developments which, in most cases, will be
because the locations will contribute to the considered unsuitable and excluded from the
connectivity of habitat and thus increase recovery efforts. Recovery goals should be
dispersal opportunities between populations. implemented only where suitable or
Preservation and enhancement of each core potentially suitable habitat is present.
area is important to maintain and expand the
distribution of California red-legged frog Results of monitoring and habitat
populations rangewide. Core areas will management will reveal, in time, whether
require long-term protection and management core areas will provide suitable habitat. If
so that existing and reestablished populations selected drainages are unlikely to support
remain viable. Recovery and delisting will be frogs, alternative core areas will be identified.
facilitated by meeting recovery criteria in all In recovery units where the status of the
core areas. California red-legged frog is largely unknown
(e.g., Sierra Nevada foothills, North Coast
In many recovery units, core areas represent Range), additional or replacement core areas
areas of high California red-legged frog may be identified to best protect existing
densities (e.g., Pescadero Marsh); some core populations and focus recovery efforts after
areas, however, do not currently support the survey results are obtained. This will provide
California red-legged frog (e.g., most Sierra flexibility in implementing the recovery plan
Nevada and southern California watersheds). by adjusting the locations and numbers of
Core areas located in the historic range core areas if they are not providing suitable
represent areas where restoration of habitat is habitat after restoration attempts.
most feasible, where pilot reestablishment
efforts are most likely to be successful, and Because core areas typically include entire
where natural recolonization is expected. watersheds and thus include both public and
Inclusion of the core areas in the historic private lands, cooperative agreements among
range will prevent further range collapse (i.e., public land managers, local planning
prevent the California red-legged frog from departments, resource conservation districts,
becoming merely a distinct vertebrate and private landowners will be relied upon to
population segment along the coast from ensure that these areas are managed to
Point Reyes south to Santa Barbara County). support the California red-legged frog.
The core areas in the historic range also
represent important elements of the historic Core areas include many watersheds within
1 Feather River 19 Watsonville Slough-Elkhorn Slough
2 Yuba River -S. Fork Feather River 20 Carmel River - Santa lucia
S Traverse Creek I Middle Fork American R I Rubicon 2 1 Gablan Range
4 Cosu mnes River 22 Estero Bay
5 South Fork Calaveras River 23 Arroyo Grande Creek
6 Tu olurme Ri ver 24 Santa Maria Ri ver _Santa Ynez River
7 Piney Creek 25 Sisquoc River
e Cottonwood Crook 26 Ven tur a River - Santa Clara River
9 Pu tah Creek -Cache Creek 27 Santa Monica Bay - Ventura Coastal Streams
10 Lake Berryessa Tributaries 28 Estrella River
11 Upper Sonoma Creek 29 San Gabriel Mountain
12 Petatuma Creek - Sonoma Creek 30 Forks 01 the Mojave
t 3 Pt. Reyes Peflinsula 3 1 Santa Ana Mountain
14 Belvedere Lagoon 32 Santa Rosa Plateau
15 Jameson Canyon - Lower Napa River 33 San Luis Rey
16 East San Francisco Bay 34 Sweetwater
17 Santa Oara Valley 35 Laguna Mountain
1S South San Francisco Bay
Legend
D Recovery Unit Boundaries
-
D
Core Areas
County Boundaries
o
-==--==---
37.5 75 150 Miles
Figure 12. California red-legged frog core area distribution.
51
the boundaries. They were mapped by

selecting the appropriate Hydrologic Sub- Selection Criteria for Core Areas
Areas per the California Watershed Map
(CALWATER version 2.2). Occupied. Some core areas were selected because they had one or
more occupied drainages. Drainages are considered currently
Core areas were selected based on several occupied if there are frog sightings from 1985 or later. Historic and
criteria as described below. Table 5 lists current distribution information for watersheds that are included in
which selection criteria applies to each core core areas can be found in Section C. Historic and Current
area and demonstrates the importance of each Distribution and by referring to the Natural Diversity Database
core area to recovery of the California red- which is maintained by the California Department of Fish and
legged frog. Game (Natural Diversity Database 2001). Extant populations found
on the periphery of the current range were included as core areas.
The delineation of core areas, however, will
not limit the scope of recovery plan Historically occupied. Many watersheds are currently unoccupied
implementation. Areas of suitable or but appear to be important to recovery due to the numerous historic
potentially suitable habitat outside designated records that exist for these areas. Restoring habitat in historically
core areas (particularly priority 2 and 3 occupied watersheds and possibly reestablishing California red-
watersheds) are also expected to be examined legged frogs in the appropriate, restored areas is important to
for possible recovery plan implementation recovery as this will restore the distribution of the species to the
and managed according to appropriate land- historic range and reverse the observed range collapse and
use guidelines. concentration of populations along the Pacific coast.
Priority 2 Watersheds: Source populations. Based on discussions with California red-

Many watersheds that are not listed as core legged frog experts and analyses of survey data, watersheds were
areas currently support the California red- chosen as core areas if data suggested that the watershed harbored a
legged frog. These watersheds are in need of source population which provide colonizers to nearby areas,
conservation and appropriate management showed reproductive success over an extended period of time (i.e.,
(conservation needs vary per watershed) and frogs and young present since 1985 or longer) and appeared to be
are considered priority 2 watersheds. The stable in population size or growing.
number of priority 2 watersheds will most
likely change according to the status of the Potential for Reestablishment. As mentioned before, some core
frog; as more localities are identified, these areas are unoccupied but appear to be restorable and/or represent
should be included as priority 2 watersheds important segments of the historic range. Some unoccupied
and managed according to the appropriate watersheds that are listed as core areas represent areas in which
recovery strategies for this species. Protection reestablishment efforts are considered most likely to succeed.
of priority 2 watersheds will provide the
necessary habitat connectivity between core Connectivity. Some core areas, whether occupied or unoccupied,
areas and is an important contribution to the provide the necessary connectivity between known populations.
recovery of the California red-legged frog Connectivity is important in maintaining viable metapopulations
throughout its range. throughout the range of the species.
Priority 3 Watersheds: Other. As noted above, some core areas were chosen despite being
Priority 3 watersheds are areas that historic- currently unoccupied. In some of these cases, particular watersheds
ally harbored California red-legged frogs. appear to be highly restorable. For example, some watersheds have
These areas will need (in most cases) been listed as having high ecological integrity and are classified as
extensive rehabilitation prior to recoloniza- an Aquatic Diversity Management Area by Moyle et al. (1996).
tion or reestablishment. These are considered Aquatic Diversity Management Areas represent watersheds that
as priority 3 because in these watersheds, the have, among other characteristics, high values for aquatic
likelihood of successful recovery is less than biodiversity, are dominated by native aquatic species, and have
in core areas and priority 2 watersheds. terrestrial and riparian ecosystems that are in fairly good condition.
However, with intensive efforts and public Extant and extirpated areas were included if they represent the
support, conservation of habitat in these historic distribution of the species.
watersheds is possible and may contribute to
Table 5. Selection criteria for core areas and importance of core areas for recovery.
Core Area Selection Criteria

Currently Historically Source Potential for Connectivity Other
Occupied Occupied Population Reestablish-
(post-1985) ment or
Augmentation
Feather River x x x
Yuba River - South x Indian Creek listed as Aquatic
Fork Feather Diversity Management Area
because it contains nearly
pristine habitat, threatened
amphibians, and dominated by
native fish
Middle Fork American x x x
Cosumnes River-South x x x Rock Creek listed as an Aquatic
Fork American River Diversity Management Area
because native frogs and fish are
present, Cosumnes River is
focus of restoration effort led by
The Nature Conservancy
South Fork Calaveras x x Extirpated but represents
historic range
Tuolumne River x x Extirpated but represents
historic range
Piney Creek x x Extirpated but represents
historic range
Cottonwood Creek x x Extant on periphery of range
Putah Creek-Cache x x x
Creek
Tributaries to Lake x x x Extant on periphery of range
Berryessa
Upper Sonoma Creek x x
Petaluma Creek-Sonoma x x x
Creek
Point Reyes Peninsula x x
Belvedere Lagoon x x x
Fagan-Jameson Canyon- x x x
Lower Napa River
East San Francisco Bay x x x
Santa Clara Valley x x x

South San Francisco x x x
Bay
Table 5 (continued). Selection criteria for core areas and importance of core areas for recovery.
Core Area Selection Criteria

Currently Historically Source Potential for Connectivity Other
Occupied Occupied Population Reestablish-
(post-1985) ment or
Augmentation
Salinas River-Pajaro x x x
River
Carmel River-Santa x x x
Lucia l
Gablan Range x x x
Estero Bay x x x
Arroyo Grande Creek x x
Santa Maria - Santa x x x
Ynez River
Sisquoc River x x x
Ventura River - Santa x x
Clara River
Santa Monica Bay- x x x Extant on periphery of range
Ventura Coastal Streams
Estrella River x x
San Gabriel Mountains x x
Mojave River x x Extirpated but represents
historic range
Santa Ana Mountain x x Extirpated but represents
historic range
Santa Rosa Plateau x x Extant on periphery of range
San Luis Rey x x x Extirpated but represents

historic range
Sweetwater River x x x Extirpated but represents
historic range
Laguna Mountain x x x Extirpated but represents
historic range
the overall distribution and recovery of this ecological significance. For the selection of
species. core areas, areas of ecological significance
include: watersheds that represent the limits
Critical Habitat. On March 13, 2001, a final of the current and historic range and/or that
designation of critical habitat was made for appear to be restorable and thus good sites
the California red-legged frog. The critical for reestablishment projects. Unlike the
habitat designation has been challenged in selection of core areas, it is a requirement
court; the status of the case has not been that primary constituent elements be defined
resolved as this plan goes to press. The legal for critical habitat. These primary constituent
ramifications of critical habitat designations elements are described in this recovery plan
are described below. Approximately in Section I, part G. Regulatory Protection
1,674,582 hectares (4,140,440 acres) of land and Conservation Measures and are present
fall within the critical habitat designation. in all critical habitat areas and core areas.
Specifically, aquatic and upland areas where
suitable breeding and nonbreeding habitat is The core areas and critical habitat areas differ
interspersed throughout the landscape and is in several ways. Unlike core areas which
interconnected by unfragmented dispersal have no legal mandate for protection under
habitat is critical habitat. the Endangered Species Act and solely rely
upon voluntary implementation, the
Core areas and critical habitat areas were designation of critical habitat requires
selected based on similar criteria. The main Federal agencies to consult with us regarding
criteria used for both were to capture areas: 1) any action that could destroy or adversely
that are occupied by California red-legged modify critical habitat. Adverse modification
frogs, 2) where populations of California red- of critical habitat is defined as any direct or
legged frogs appear to be source populations, indirect alteration that appreciably
3) that provide connectivity between source diminishes the value of the habitat for both
populations, and 4) that represent areas of the survival and recovery of the species.
Critical Habitat
Critical habitat affects Federal agencies by requiring them to evaluate the effects that any
activities they fund, authorize, or carry out may have on listed species. Agencies are
required to ensure that such activities are not likely to jeopardize the survival of a listed
species or adversely modify (e.g., damage or destroy) its critical habitat. By consulting
with us, Federal agencies can usually minimize or avoid any potential conflicts; activities
have almost always been allowed to proceed in some form. It should be noted that critical
habitat designation does not create a wilderness area, preserve, or wildlife refuge. It
applies only to activities sponsored at least in part by Federal agencies. Such federally-
permitted land uses as grazing and recreation may take place if they do not adversely
modify critical habitat. Designation of critical habitat does not constitute a land
management plan nor does it signal any intent of the government to acquire or control the
land. Therefore, if there is no Federal involvement (e.g., Federal permit, funding, or
license), activities of a private landowner, such a farming, grazing or constructing a home,
generally are not affected by a critical habitat designation, even if the landowners’
property is within the geographical boundaries of critical habitat. Without a Federal
connection to a proposed action, designation of critical habitat does not require that
landowners of State or other non-Federal lands do anything more than they would
otherwise do to avoid take under provisions of section 9 and 10 of the Endangered
Species Act.
E. EFFECTS OF THE RECOVERY STRATEGY ON salamanders and decrease the suitability of

ASSOCIATED SPECIES these ponds for non-native aquatic predators.
Because California tiger salamanders often
Many of the threats facing the California red- estivate by using small mammal burrows
legged frog have also resulted in declines of adjacent to waterways, care must be taken to
other native, coexisting species. Therefore, avoid trapping salamanders in burrows while
improved habitat conditions for co-occurring managing ponds for California red-legged
species are expected to occur through frogs.
attainment of the recovery objectives.
Monitoring of co-occurring species is Santa Cruz long-toed salamander. Removal
recommended as a task of this plan, and of non-native aquatic predators for the
California red-legged frog recovery actions California red-legged frog will benefit the
that may have adverse effects on associated salamander where the two species overlap.
sensitive species should be adjusted to reduce Restoration of flows to coastal sloughs will
impacts. However, the net effect on native slow saltwater intrusion and benefit this
species of implementing this plan is expected species. In addition, management of shallow,
to be predominantly positive. The following ephemeral, freshwater ponds will increase the
describes potential effects of recovery tasks suitability of habitat for this species, while
on specific taxa. decreasing the proliferation of non-native
aquatic predators.
California freshwater shrimp. Protection
and improvement of riparian habitat will Foothill yellow-legged frog and mountain
increase vegetative cover required for yellow-legged frog. Both of these species
protection from predators. Control of non- have experienced population declines due to
native fish and crayfish may also decrease the the presence of non-native aquatic species,
occurrences of predation and thus increase particularly in the Sierra Nevada and Coast
survivorship of California freshwater shrimp. Range foothills. Predator control and reduced
stocking of non-native fish should increase
Tomales asellid. The Tomales asellid relies the breeding success and survival of these
upon the presence of dense mats of marsh species. Further, restoration of streams and
pennywort (Hydrocotyle spp.) and submerged creeks should result in water flow regimes
decaying leaves; California red-legged frogs and vegetative cover that provide suitable
have been observed utilizing marsh habitat for these species.
pennywort as a substrate for egg mass
attachment (S. Christopher in litt. 1998). Arroyo southwestern toad. Protection and
Restoration or protection of habitat enhancement of stream systems for the
conditions for the California red-legged frog California red-legged frog should also
will result in increased streamside vegetation provide the necessary components of arroyo
and thus a source of fallen, decaying leaves, toad breeding habitat, such as shallow pools
and in some areas, mats of marsh pennywort. in streams and dense riparian vegetation.
Benefits for Tomales asellid are expected in Many of the land uses that threaten the
the Golden Gate National Recreation Area California red-legged frog also threaten
and Point Reyes National Seashore where the arroyo toads. Thus, implementation of
ranges of the species overlap. appropriate land use guidelines and best
management practices will benefit both
California tiger salamander. California tiger species. This is particularly true if guidelines
salamanders and California red-legged frogs for off-road vehicles, mining, and grazing are
are often found coexisting in stock ponds and implemented. Control of non-native aquatic
other artificial impoundments in the San predators will also benefit both species.
Francisco Bay region. Improved management
of artificial ponds for the benefit of the Western spadefoot toad. A large portion of
California red-legged frog is expected to habitat restoration for California red-legged
increase suitability of these habitats for tiger frog recovery will involve the creation of-
and management of- artificial ponds such as of natural flow regimes will help to maintain
stock ponds. Because western spadefoot toads suitability for turtles. Control of bullfrogs and
are associated with stockponds they may predatory non-native fish will also benefit the
benefit from the increased availability and western pond turtle.
suitability of such habitat. Many areas that
are listed as core areas for protection and Tidewater goby. Implementation of tasks to
management will also benefit the western recover frog populations in lagoons and
spadefoot toad. Such areas include large coastal streams should also improve habitat
portions of the south and east San Francisco conditions for gobies. Reduction of sediments
Bay and the vicinity of San Luis Reservoir. in creek channels from bank erosion,
livestock grazing, timber harvesting, and
Alameda whipsnake. Protection of large recreation will benefit the tidewater goby.
tracts of land including uplands that connect
breeding areas for the California red-legged Unarmored threespine stickleback. Removal
frog should provide protected areas of coastal of non-native aquatic predators for the
scrub and chaparral required by the Alameda California red-legged frog will benefit the
whipsnake. Benefits to the Alameda stickleback where the two species overlap.
whipsnake will particularly be high in Restoration of habitat in slow moving stream
Alameda and Contra Costa Counties, where reaches will also benefit this species.
protection and management of core areas for
the California red-legged frog should result in Salmonids. Removal of threats in streams
fairly well connected reserves of uplands and supporting the California red-legged frog is
aquatic habitats. expected to improve aquatic habitat
conditions for threatened runs of coho salmon
Two-striped garter snake and San Francisco and steelhead where geographic ranges
garter snake. One of the goals of this overlap. Protection and restoration of riparian
recovery plan is to maintain long-term conditions in core watersheds and drainages
viability and increased reproductive success harboring frog populations will moderate
of California red-legged frogs despite natural extreme temperature fluctuations, reduce
sources of mortality (i.e., predation by native sediment transport to streams, provide
predators). The decline of the California red- terrestrial insects for food, eventually provide
legged frog, which is a prey species of the in-stream woody debris and undercut banks
both the two-striped garter snake and the San for cover, and create habitat conditions less
Francisco garter snake, and the introduction favorable to introduced predators.
of bullfrogs into aquatic habitats are both
threats to these species. Therefore, with Tricolored blackbird. The preservation of
implementation of this recovery plan, it is ponded habitat for the California red-legged
expected that increased numbers of California frog with emergent vegetation and protective
red-legged frogs will subsequently increase buffers from urban predators (e.g., raccoons)
the prey base for garter snakes. Habitat should greatly benefit the tricolored
restoration and predator control (e.g., the blackbird, which primarily relies upon
continued control of bullfrogs at Pescadero emergent marsh habitat for breeding.
Marsh) will benefit both species as well as the
California red-legged frog. Further, any Southwestern willow flycatcher, little willow
measures that reduce the impacts of flycatcher, and least Bell’s vireo. Care must
urbanization (i.e., water management and be taken to avoid disturbing breeding sites of
protection of undeveloped habitat areas) will the flycatcher where tamarisk is present.
be beneficial. Removal of tamarisk for the benefit of the
California red-legged frog must be weighed
Western pond turtle. Management of streams, against any potential losses of breeding
creeks, and natural and artificial ponds should habitat for the flycatcher. Monitoring of avian
provide habitat enhancements for western use of tamarisk at a targeted site should
pond turtles. In regulated streams, restoration decrease the chances that negative impacts
may result. Overall, increased streamside enhance or protect riparian corridors and
habitat and decreased disturbance by marshes where they interface with salt
recreationists and livestock in stream systems marshes, should also provide nesting,
should benefit all of the above avian species. foraging, and dispersal habitat for the
Increased connectivity between drainages will saltmarsh common yellowthroat. These areas
facilitate population expansion of each will particularly provide suitable habitat for
species as fragmented habitat is one of the the yellowthroat during high tides when
factors contributing to declines. refuge is required for survival.
Saltmarsh common yellowthroat. The Marsh sandwort and Gambel’s watercress.

saltmarsh common yellowthroat utilizes a Recovery efforts that protect habitat areas in
range of aquatic habitats in the San Francisco San Luis Obispo County will benefit these
Bay area. Because the ranges of the plant species as well as the California red-
yellowthroat and California red-legged frog legged frog. Further, mitigation of altered
overlap in the periphery of San Pablo Bay and hydrology and elimination of non-native
its tributaries, in wetlands in Marin County plant species (such as eucalyptus where it is
(e.g., Olema Marsh), in southern San deemed a threat to water quality and riparian
Francisco Bay streams (e.g., Coyote Creek), habitat quality) will restore habitat for each
and at Pescadero Marsh, protective measures species.
for the California red-legged frog that
61
III. Outline of Recovery Actions
A. GUIDANCE FOR DEVELOPMENT OF WATERSHED MANAGEMENT PLANS

AND IMPLEMENTATION OF RECOVERY TASKS
The following guidelines should be used when implementing the recovery tasks as outlined in
Section B. They provide specific recommendations for minimizing the effects of various land
and water uses, predation, and air and water contamination and provide recommendations for
habitat preservation. These guidelines will be valuable when developing watershed
management and protection plans (see Task #1), developing mitigation measures for
development projects, during section 7 consultations under the Endangered Species Act, and
for regional conservation planning for the California red-legged frog.
1) Protect suitable habitats and buffers in perpetuity.
a. Encourage and assist counties and owners of large tracts of natural lands to
develop preserves, conservation banks, and/or mitigation banks.
Owners of large tracts of natural land (public and private) should be encouraged to
participate in conservation planning by establishing preserves or mitigation banks.
b. Purchase conservation easements or parcels from willing sellers where

acquisitions may protect existing populations, allow for expansion of
metapopulations, and increase the quantity of protected suitable habitat within
the range of the species.
Expanding the acreage of protected high quality habitat within core areas and high
priority watersheds will contribute to recovery of the California red-legged frog by
increasing opportunities for dispersal, population expansion, and recolonization. The
delineation of core areas (Figure 12, Table 4, and Appendix C) provides direction on
where habitat suitability and connectivity are considered important for long-term
recovery of the California red-legged frog and where land acquisition or protection is
necessary. In addition to expanding protection within designated core areas,
increasing the connectivity between core areas and occupied watersheds may also
increase recovery potential. Therefore, lands that are not designated as core areas
should also be evaluated using a landscape approach to determine their possible
importance to species recovery.
Several areas have been noted as being very important to the ecological function of
adjacent sites that currently support the California red-legged frog. For example,
protection of lands upstream from the Corral Hollow Ecological Reserve will increase
and maintain suitability of this Reserve for frogs. Protection of coastal areas owned
by the Hearst Corporation will allow for protection of frogs in the San Simeon
vicinity by maintaining contiguous habitat necessary for dispersal and population
expansion. Long-term protection of parcels in these, and other areas, should be
pursued via conservation easements or other means of permanent protection.
Isolated sites such as stock ponds, which currently support frogs in the Sierra Nevada
foothills, are also in need of protection. Protection of at least a 3-kilometer (2-mile)
radius from these isolated ponds may contribute to range expansion in the Sierras.
Opportunities to acquire inholdings within National forests should be pursued and

vehicles for achieving this may include land swaps. Again, protection of the
watershed, including stream reaches up- and downstream of known populations and
adjacent uplands, will increase the potential for long term suitability of such sites for
the California red-legged frog.
c. Establish appropriate buffers within urban and agricultural areas on a site-by-

site basis.
Buffers should be established and preserved through the same mechanisms used to
secure habitat. Incorporation of research on dispersal habits of the California red-
legged frog, and influences of habitat type and gradient, should increase the
understanding of appropriate buffers by site. Dispersal habits and habitat needs of the
frog should be provided to planning agencies so that appropriately sized buffers,
habitat areas, and corridors (i.e., dependent on site-specific conditions, topography,
etc.) can be built into project plans.
2) Develop and implement guidelines for maintaining adequate water flow regimes,
particularly in California red-legged frog habitats downstream of impoundments,
water diversions, and residential or industrial developments.
Altered water regimes can result in a multitude of direct and indirect impacts to the
California red-legged frog and its habitat, ranging from unseasonable flows that disturb
egg masses to loss of aquatic habitat by excessive groundwater withdrawals or stream
diversions. Data should be collected to identify the in-stream flow needs necessary to
restore natural, seasonal flow cycles and thus maintain optimal habitat for protection and
recovery of the California red-legged frog and co-occurring species. Care must be taken to
consider the varying needs of co-occurring species and accommodate potential conflicts.
While water flows will vary with weather conditions and thus may not be consistently
maintained, particularly in drought conditions, measures should be proposed and
agreements implemented to secure the needed flows when diversions, impoundments, or
urban wastewater flows threaten the integrity of the hydrologic regime.
a. Provide water budgets to county planners and water districts that identify needs
for the California red-legged frog.
Work with authorities to secure appropriate flows, limit the amount of water pumped
from wells during late summer months and drought periods, and/or manage small
impoundments in a manner that increases suitability of habitat in reaches up- and
downstream of dams. Sites that are in need of water budgets include coastal streams,
particularly those in the Central Coast Recovery Unit (i.e., San Simeon Creek and
Santa Rosa Creek in San Luis Obispo County).
b. Manage dams and reservoirs that affect populations of the California red-legged
frog.
Water suppliers and reservoir operators should consider operational changes that
result in environmental enhancements while preserving water quality and quantity to
the extent consistent with environmental goals. Management actions may include
seasonally drawing down water levels to remove non-native aquatic predators or
release of flows to create and/or maintain breeding habitat for the California red-
legged frog downstream of dams. Goals should include restoring natural hydrographs
and minimizing unseasonable flows.
Diversions on the Los Padres National Forest and other public and private lands (i.e.,
other National Forests, Bureau of Land Management, State Parks) that have not
undergone environmental review should be analyzed for impacts to the California red-
legged frog and associated species and managed for habitat suitability. Because small
impoundments can also create habitat for the California red-legged frog, site-specific
determinations of benefits and/or impacts are necessary.
c. Where feasible, remove dams that have eliminated or reduced populations of the
California red-legged frog on National Forest lands and other public lands.
Managers of public lands should consider removal of dams and diversions

(particularly those that divert springs) that are negatively affecting the extent and
suitability of California red-legged frog habitat. In particular, removal should be
considered when such facilities no longer serve their useful purpose and when they
could feasibly be replaced by other, less environmentally damaging facilities capable
of supplying water of equal or better quality compared to the facility proposed for
removal.
For example, the Matilija Dam on the Los Padres National Forest has been identified
as an obstacle to the flows necessary for suitable breeding habitat for the California
red-legged frog in Matilija Creek on the Los Padres National Forest land. Further,
careful review of the 190 spring diversions on the Los Padres National Forest, and
removal of these diversions where appropriate, is recommended. Where dam removal
is not feasible, modification of the structures and systems should be completed to
provide suitable habitat for the California red-legged frog.
Other locations where careful review and possible elimination of impoundments is

necessary include the tributaries to Año Nuevo State Park. Impoundments here are a
source of non-native predators (i.e., warm water fish and bullfrogs) (M. Westphal
pers. comm. 1998). Restoration via impoundment removal may be the best long-term
solution to the threat of non-native predation on the California red-legged frog at this
location.
In some cases, dams provide the requisite impoundment of water that is required for
California red-legged frog habitat where none existed before (e.g., stock ponds) so
surveys and suitability analyses must be carried out prior to removal.
3) Develop and implement best management practices to prevent or minimize adverse

impacts to the California red-legged frog from in-stream and stream bank activities
associated with mining operations.
Activities such as gravel mining and suction dredging can degrade California red-legged
frog habitat in streams and creeks by altering the morphology and hydrology of these
aquatic systems, facilitating the proliferation of non-native aquatic species and increasing
sedimentation. Identification of watersheds with this problem is needed for recovery with
subsequent development and implementation of measures that reduce effects.
a. Identify streams for which in-stream and stream bank activities associated with
mining threaten habitat suitability for the California red-legged frog.
A survey of streams which are subject to gravel mining operations is necessary. Placer
mining and gravel extraction impacts may be greatest in the Sierra Nevada foothills.
b. Determine the effects of suction mine dredging, gravel extraction, and placer
mining on the California red-legged frog.
An analysis that evaluates the effects of suction mine dredging and placer mining on
the California red-legged frog and its aquatic habitat is necessary. While many water
quality impacts have been identified (e.g., increased sedimentation), determining the
relationship between degraded water quality and frog reproduction and survival will
aid development of management guidelines and minimization measures to protect the
subspecies.
c. Develop gravel mining guidelines for streams where gravel mining is identified
as a threat to the suitability of habitat for the California red-legged frog.
Upon identification of streams for which these activities are a threat to the suitability
of habitat for the frog, measures may be necessary to minimize the impacts to aquatic
habitat. Minimization measures or guidelines should be applied in suitable habitat for
the frog. Management guidelines may include such measures as: removal of artificial
pools that have been created by suction dredging and now harbor non-native aquatic
species (or may in the future), bank stabilization, reduction and containment of
sediments, reduction of highbanking, and removal of gravels and soils above the high
water mark and on adjacent terraces.
Appropriate sites for doing impact analyses and applying guidelines include portions
of the Los Padres National Forest (portions of the Santa Ynez, Ventura-Matijila, and
Piru watersheds), watersheds in the Sierran foothills, and other problem areas as they
are identified.
d. Eliminate mining activities in drainages with known California red-legged frog

populations.
In identified high use areas, elimination of mining activities within 1.5 kilometers (1
mile) up and downstream of known frog populations will contribute to recovery by
eliminating potential negative effects on frog reproduction and survival. Sediment
loads should be monitored for mining activities conducted greater than 1.5 kilometers
(1 mile) upstream to evaluate whether California red-legged frogs are negatively
impacted. If so, minimization measures should be enacted to reduce degradation of
water quality. Elimination of mining activities is recommended on all public lands
and in core watersheds where California red-legged frogs are threatened by such
activities. Where elimination is infeasible due to valid patented claims, and where
mining operations are already permitted under the state Surface Mining and
Reclamation Act, guidelines should be implemented to avoid impacts.
e. Identify areas where acid mine drainage may be affecting California red-legged
frog populations, and identify measures to reduce or eliminate the effects.
Acid mine drainage is associated with the extraction of many metals. High acidity can
have direct effects on the frog and their prey base, or indirect effects by interactions
with other actual and potential contaminants. Some elimination or reduction of
contaminant exposure might be accomplished through zoning regulations. This may
entail working with county planning departments and agricultural commission offices
to define areas where certain activities are not permitted or certain chemicals are
restricted.
4) Control/eliminate non-native species/predators (plants, vertebrates, invertebrates)

using methods that are determined to be the most effective.
A large component of the threats to California red-legged frogs involves the presence of
non-native predators, particularly warm water fish, crayfish, and bullfrogs. In addition,
some regions in southern California may benefit from control of African clawed frogs.
Although introduced predators can be considered ubiquitous in many watersheds within
the current and historic range of the frog, areas of high concentrations should be identified
and the numbers of non-native predators reduced. As a short-term method, physical
removal of non-native predators may be most beneficial. However, pro-active means of
reducing the conditions in which non-native predators thrive is a long-term priority.
Sustainable land uses that maintain high suitability for the California red-legged frog
rather than degraded conditions where non-natives have a competitive advantage should
be encouraged.
a. Identify sites that require control or elimination of non-native predators.
Through implementation of this recovery plan, many sites needing non-native

predator control are expected to be identified. However, based on current information,
the following sites have been identified as areas which may benefit from non-native
predator removal: Garin Dry Creek and ponds/drainages in Pleasanton Ridge
Regional Park (Alameda County), Arroyo Del Valle (Alameda County), upper
Alameda Creek and other drainages in the Sunol Regional Wilderness (Alameda
County), Bollinger and Brushy drainages (Contra Costa County), Kellogg Creek,
Castro Creek and drainages in the Black Diamond Mines Regional Preserve (Contra
Costa County), Diablo Foothills Regional Park (Contra Costa County), portions of the
Golden Gate National Recreation Area including Tennessee Valley and bordering
drainages (Marin County), Mountain Lake in the Presidio, (San Francisco County),
Crystal Springs Reservoir and Pilarcitos Lake on San Francisco Water District lands
(San Mateo County), the Corral Hollow watershed (San Joaquin County), Oristemba
and Garzas Creeks (Stanislaus County), Año Nuevo State Park and Reserve (Santa
Cruz County), ponds and lakes in Henry W. Coe State Park (Santa Clara County),
ponds and lakes on Palassou Ridge ( Santa Clara County), Romero Creek and ponds
on Romero Ranch (Santa Clara and Merced Counties) Fort Hunter Ligget (San
Antonio and Nacimiento drainages, Monterey County), Little Oso Flaco Lake (San
Luis Obispo County), and areas within the Los Padres National Forest, Yosemite
National Park, Eldorado National Forest, and Plumas National Forest.
b. Eliminate predators utilizing various methods to determine the most effective

means.
Many methods for controlling/eliminating non-native predators exist and yield

differing results (i.e., pond drainage, physical removal, rotenone). Various methods
should be tested to determine which are the most successful and cost effective.
c. Eliminate breeding habitat of non-native predators.
In identified problem areas, potential and known breeding sites of non-native aquatic
predators (e.g., stock ponds, small reservoirs) should be eliminated near known or
potential California red-legged frog habitat. Physical removal (i.e., filling in a stock
pond known to be infested with non-native species) may be necessary; this may be
more cost effective and productive over the long-term than removing individuals.
Surveys should be conducted prior to such actions to ensure that the California red-
legged frog is not breeding in these areas.
d. Maintain watersheds that are free from non-native predators.
Some ponds (e.g., Mud Dam Pond on San Francisco Public Utility Commission
Lands and some ponds on East Bay Regional Park District lands) support the
California red-legged frog and are not infested with non-native predators. Careful
monitoring and preventative management should be carried out to avoid invasions.
e. Use appropriate animal control measures to reduce impacts of raccoons and

other predators associated with urbanization.
Preventative and reactive measures taken within urbanized areas may decrease the
proliferation of predators. Such measures may include waste management in public
parks and housing developments, control of feral pets, discouraging the public from
accidentally or intentionally feeding wild predators such as raccoons, and animal
removal if predator populations appear to be significantly detrimental to the
California red-legged frog breeding success and survival.
f. Remove arundo, tamarisk, cape ivy, and other non-native plant species if they
are threatening habitat suitability.
In addition to non-native animals, a number of non-native plants threaten the integrity

of the frog’s habitat in aquatic systems. These non-native plants can out-compete, and
ultimately replace, native plants resulting in the loss of plant species diversity and
wildlife habitat. The relationship between the presence of non-native plants and
habitat suitability for the frog should be investigated. If these plants threaten habitat
suitability, they should be removed. In the case of non-native plant removal, the
effectiveness of eradication should be verified and post-treatment revegetation efforts
should be conducted promptly to ensure adequate vegetative cover in treated areas.
Areas identified thus far as having an intense invasion of non-native plants include
the following aquatic systems: Santa Ynez, Ventura-Matilija, Santa Paula, Sespe, and
Piru watersheds on the Los Padres National Forest, San Simeon and Santa Rosa
Creeks in San Luis Obispo County, areas in the San Gabriel Mountains and most
southern California sites. More sites are expected to be identified in the future.
g. Decrease the extent of and/or cease artificial stocking of non-native fish.
Stocking of non-native fish should occur only in aquatic systems that have been
surveyed for sensitive native aquatic species and where these sensitive species are
deemed absent. Surveys should be conducted upstream and downstream from a
stocking site prior to stocking. Watersheds that support the California red-legged frog
should be allowed to revert to either a fishless system or a community of native
aquatic species, depending on the historic conditions. Stocking of non-native fish
should be discontinued in National Park waters, State and Regional Parks,
Vandenberg Air Force Base, and core watersheds.
h. Remove restrictions on the take of feral pigs and encourage their removal from
red-legged frog habitat including associated uplands.
i. Eliminate practice of releasing translocated urban predators such as raccoons,

skunks, and opossums into California red-legged frog habitat areas.
5) Reduce the detrimental effects of livestock grazing and increase incidental benefits
associated with livestock grazing on public and private lands.
Although research is necessary to understand the interactions between livestock grazing

and the frog, and to determine the optimum grazing regimes for California red-legged frog
habitat suitability and survival (see task 10.12 below), opportunities currently exist to
manage grazed lands in a manner that reduces impacts to or enhances frog habitats.
a. Implement guidelines for construction, maintenance, and management of

artificial ponds.
Because of the variability of aquatic systems from either natural climatic changes or
anthropogenic effects, the survival of populations in all aquatic habitats may depend
on the continued presence of ponds, springs, or pools that are disjunct from streams.
In many California red-legged frog metapopulations, artificial ponds maintained for
watering livestock are the principal sources of the young frogs that annually
repopulate the watershed. Appendix D provides guidelines that may be used to create
and manage artificial ponds for the benefit of California red-legged frogs and/or
enhance existing ponds to increase suitability. Private landowners should be
encouraged to implement the recommended pond guidelines on a voluntary basis, and
public managers should implement these guidelines where California red-legged
productivity is low due to poor breeding habitat conditions in natural aquatic systems.
Areas where pond construction and maintenance are expected to benefit California
red-legged frogs include cattle ranches, dairy farms, and nurseries (particularly
nurseries along the central coast south of Half Moon Bay). At existing and future
nurseries, supplemental irrigation ponds can be constructed for use by frogs when
irrigation ponds are drawn down. Cost sharing incentives and safe harbor agreements
may be appropriate for landowners who choose to participate in habitat enhancements
such as pond creation (see Appendix E).
b. Increase the number of private landowners who develop and implement

California Rangeland Water Quality Management Plans.
Landowners should be encouraged to develop California Rangeland Water Quality

Management Plans. Because the primary goals of these plans are to maintain and
improve the quality of surface water, implementation of such self-initiated plans will
improve habitat conditions for the California red-legged frog.
c. Test grazing strategies to determine grazing regimes that are most compatible
with California red-legged frog breeding and survival and habitat suitability.
Several grazing strategies and guidelines may minimize impacts to the frog. Strategies
that should be analyzed include rest-rotation and deferred utilization, varied livestock
types (i.e., change from cow-calf operation to steers or breeds which utilize dry
habitats), and/or lowered stocking rates for lighter utilization levels to limit forage
removal.
d. Develop and implement grazing guidelines or enhance existing guidelines for

public lands which have been identified as having habitat quality concerns due to
livestock grazing.
Guidelines must be site-specific and could include actions such as: fencing, relocation
of water and salting sites away from wetlands, maintenance of stream bank stability
(i.e., no more than 10 percent of natural stream bank stability altered by livestock
trampling, chiseling, and sloughing), management of upland herbaceous vegetation
such that utilization does not exceed 50 percent of annual growth (depending on the
site conditions), and monitoring of utilization and subsequent habitat suitability for
frogs.
Areas needing grazing guidelines to reduce impacts to frogs and increase suitability of
habitat include the following: portions of the East Bay Regional Park District (i.e.,
Garin Dry Creek Regional Park), areas of high levels of grazing on National forests
(i.e., portions of the Carmel, Cuyama, Sisquoc, and Piru watersheds on the Los Padres
National Forest), State parks, and publicly owned portions of core areas. Additional
areas should be included if overgrazing is negatively affecting the California red-
legged frog.
e. Reduce water quality degradation associated with livestock grazing and horse
corrals.
Areas in which livestock and horses congregate typically experience high levels of
nutrients due to urination and defecation by these animals. This has been identified as
a problem on the Golden Gate National Recreation Area and Point Reyes National
Seashore, and it is likely that this problem exists in other areas throughout the range
of the frog. Measures should be implemented to alleviate water quality degradation.
Suggestions include limiting the extent of time that livestock/horses are allowed to
congregate in watersheds harboring the California red-legged frog. If a demonstrated
threat to California red-legged frogs exists, horse corrals should be moved to at least a
150-meter (500-foot) distance from known and potential breeding sites until
appropriate buffers are determined through experimental research.
6) Reduce the effects of timber harvest activities on the California red-legged frog and
its habitat.
Timber harvest activities are considered a threat to watershed integrity when guidelines
are not in place to reduce adverse impacts. This is a particularly important issue in the
North Coast foothills and the Sierra Nevada foothills.
a. Develop and implement timber harvest guidelines to reduce impacts to the

California red-legged frog and their habitat.
Guidelines for minimizing impacts associated with timber harvest activities should be
developed for each timber region within the current and historic range of the frog.
Implementation of guidelines should be refined for individual sites (i.e., based on
topography, watershed conditions).
b. Develop regional dichotomous keys for assessing potential effects of proposed

timber harvest plans.
As described in section I, part G of the Introduction (Regulatory Protection and

Conservation Measures), a dichotomous key exists to assist land managers and timber
harvesters in the analysis of potential project impacts. This key has been successfully
used by foresters, and is viewed as a means for harvesters to actively take part in the
analysis with a full understanding of the rationale for assessing impacts. This
dichotomous key should be refined for each recovery unit so that the key is more
specific to regional habitat conditions and harvest practices. Specifically, a refined
key should be developed for the Sierra Nevada foothills, North Coast foothills, and
the Northern Transverse and Tehachapi ranges recovery units.
c. Design and maintain roads in a manner that reduces impacts.
Erosion control features should be established on skid trails and tractor roads
immediately upon completion of yarding on them in wet weather conditions. Road
surfaces should maintain a hard surface (e.g., rock hardness) during periods of road
use. Roads should be designed with the minimum width necessary to support the
proposed use, roads on steep slopes (greater than 50 percent) should be full-bench
design, and spoils should be disposed on grounds that are less than 30 percent slope
and remote from watercourses. New roads and those requiring reconstruction should
be out-sloped with rolling lips. The California Forest Practice Rules should be
consulted for additional measures to reduce impacts and sedimentation.
7) Develop site-specific guidelines for recreational activities to reduce or eliminate

impacts to the California red-legged frog where these activities pose an on-going
threat to habitat quality.
Hiking, fishing, horseback riding, and back country camping occur over large areas on
public lands such as National Forest, Bureau of Land Management, State, and regional
park lands. Habitat impacts associated with use of trails and roads, use of developed
recreation sites, and dispersed use include wetland vegetation trampling, soil compaction,
sedimentation, bank destruction, dammed pools, vegetation clearing, introduction of
contaminants, and introduction of non-native fish and wildlife species. Impacts to the
California red-legged frog may include direct loss of egg masses and tadpoles due to
trampling and decreased suitability of aquatic habitats due to the proliferation of non-
native predators, sedimentation of pools, vegetation clearing or trampling, and decreased
water quality.
a. Reduce the impacts of trail and road use on California red-legged frog habitat
within public lands.
Again, depending on the site-specific needs for California red-legged frogs, trails and
roads may need to be rerouted to avoid stream crossings and rerouted a distance of at
least 150 meters (500 feet) from wetlands (i.e., springs, wet meadows, ponds,
marshes). Where stream crossings are absolutely necessary, measures that ensure that
crossings do not degrade frog habitat should be implemented. Vehicular activities
should be excluded from riparian and other wetland areas unless adequate stream
crossings exist to prevent sedimentation. Roads near known source populations of the
California red-legged frog should be closed annually, if feasible, during the late
winter and spring to prevent the killing of subadult and adult frogs on roads. With
each of these actions, care must be taken to avoid impacting other species.
Management plans should include impact minimization actions such as: (1) closure or
reroutes of trails or trail segments that cause degradation of aquatic systems, (2)
development of trails and overlooks which provide the public opportunities to view
unique resources without impacting those resources, (3) closure and relocation of
campgrounds and other developments to areas that are within a 150-meter (500-foot)
distance from wetlands, (4) development of interpretive trails and signs to educate the
public about sensitive resources and habitats, (5) restoration of aquatic and upland
areas that have been heavily degraded by recreational activities, and (6) installation of
space barriers installed as appropriate to protect sensitive habitat areas. Existing
guidelines for road development, maintenance, drainage, and surfacing should be

followed to decrease impacts to the California red-legged frog habitats.
b. Minimize off-highway vehicle impacts.
A high priority is to develop management guidelines for off-road vehicle uses where
recreation activities have resulted in sedimentation of streams and ponds and the
degradation of upland habitats. Off-road vehicle activities upstream of the Corral
Hollow Ecological Reserve are decreasing the suitability of the ecological reserve due
to high rates of sedimentation during peak stream flows. In addition, many areas in
National forests need management of off-road vehicle use in suitable and occupied
habitats to decrease impacts to the California red-legged frog and other sensitive
species. Sediment monitoring guidelines, permanent or seasonal closures, and
development and maintenance of siltation ponds are needed in these areas.
c. Reduce impacts on the California red-legged frog from developed recreation

sites and dispersed recreational use on public lands.
Developed sites, including day use areas and campgrounds, often attract
congregations of people around water. Management plans for developed recreational
sites on National Forest, State park, and Regional park lands are needed to minimize
impacts to the frog. Developed recreational sites in need of management include areas
along Arroyo Seco, Santa Ynez, Ventura-Matilija, Sespe, and Piru drainages on the
Los Padres National Forest. On the Los Padres National Forest, areas with greatest
concentrations of dispersed use include portions of the Carmel, Arroyo Seco, Big Sur,
Sisquoc, Santa Ynez, Ventura-Matilija, Santa Paula, Sespe, and Piru drainages. Other
areas of high priority that need management plans include State and Regional parks
that currently support populations of the California red-legged frog.
8) Decrease the exposure of the California red-legged frog and their habitat to
contaminants.
Currently, the sensitivity of the California red-legged frog to pesticides, herbicides, heavy
metals, air pollutants, and other contaminants is largely unknown. Research on the
relationship between the frog and pollutants is necessary and will contribute to the
knowledge base required for development of management guidelines with respect to
contaminants. Several contaminated areas have been identified (e.g., Vandenberg Air
Force Base) where the California red-legged frog may be exposed to toxins; at these sites,
contaminants should be removed and other measures that decrease exposure of the frog
should be undertaken.
a. Use habitat-based measures to prevent contamination of California red-legged

frog habitat.
Habitat-based recovery actions that prevent the movement of pesticides into the
aquatic environment should be used to reach this goal. For example, well-vegetated
riparian areas and/or vegetation buffers around natural and artificial ponds should be
protected and/or enhanced in agricultural, urban, and suburban areas to prevent aerial
drift and overland flow of chemicals into wetlands. Intensive farming should be
avoided within a 500-meter (1,500-foot) buffer from wetlands.
b. Develop contingency guidelines for hazardous material spills.
Measures to avoid contact with hazardous material will preserve the integrity of
aquatic systems and habitats needed by the frog. Having contingency plans in place
will reduce the likelihood that unexpected spills will negatively affect the California
red-legged frog and associated species.
c. Identify point and non-point source pollution and develop guidelines to reduce
impacts.
Identification of pollution sources will provide the focus for implementation of

appropriate guidelines and impact minimization measures. Some point-sources have
been identified and include Las Tables Creek in the Lake Nacimiento drainage
(Monterey County) which receives acid mine drainage from the Buena Vista and Klau
Mercury mines, Chorro Creek (San Luis Obispo County) which received high levels
of chlorinated water (50 parts per million) in 1997, the Guadalupe Oil Field (San Luis
Obispo County), San Justo Reservoir (San Benito County) which has high selenium
levels, the Goleta vicinity (Santa Barbara County) where sediment and water samples
show high levels of benzene, arsenic, and selenium from past oil industry activities,
and ponds on Vandenberg Air Force Base (Santa Barbara County). Identification of
non-point sources should include waste water discharges and areas in which use of
agricultural chemicals is concentrated.
d. Clean aquatic habitats that support the California red-legged frog and are
known to be contaminated.
As noted above, several areas within the current range of the California red-legged
frog are known to support the subspecies despite high levels of contaminants. Clean
up and remediation are necessary at each site. For example, some ponds on the
Vandenberg Air Force Base are contaminated but support the frog. Researchers have
noted physical deformities and research is necessary to determine the causes.
California red-legged frogs should be removed from the site while clean up occurs
and either relocated or allowed to disperse back into ponds once water quality has
been improved.
e. Substitute strongly caustic fertilizers or their components with less dangerous

substances.
Amphibian mortality, skin lesions, and burns have been associated with the caustic
materials found in mineral fertilizers (Schneeweiss and Schneeweiss 1997). Less
dangerous substances should be used in place of these chemicals.
f. Stop contamination of riparian areas from the direct application of herbicides

and pesticides by road crews (e.g., county departments of transportation,
Caltrans)
The use of materials known to be toxic to aquatic and riparian species are routinely
applied for control of roadside weeds and other unwanted vegetation. This is
particularly important where ditches, riparian areas, and springs occur at roadsides.
9) Develop guidelines for fire management practices (i.e., prescribed burns, emergency
fire suppression, emergency water use) to decrease incidental impacts to the
California red-legged frog.
Many public lands do not currently have specific guidelines for fire management
activities. Routine and emergency plans should be modified to include protective measures
for the frog while maintaining fire fighter safety and protecting life and property.
Prescribed burning should be used when doing so will enhance ecosystem health (e.g.,
reduce fuels, control non-native plants) and decrease chances of catastrophic fires.
However, prescribed burning should be carried out in upland habitats during seasons when
frogs are not likely to be dispersing or estivating in uplands, if ecologically appropriate.
Guidelines for emergency fire suppression could include such actions as: restricting the
use of fire retardant drops in wetland habitat areas; avoiding breeding pool habitat for
water supply sites; avoiding establishment of staging areas within a minimum of 150
meters (500 feet) from California red-legged frog habitat; prohibiting solid and sanitary
waste facilities in the vicinity of aquatic habitats; signing, fencing, or closing areas of
California red-legged frog breeding habitat; developing inspection and monitoring
requirements for operating plans; and briefing hand crews on locations and types of frog
habitats.
The current fire management guidelines used by State parks should be evaluated for
compatibility with the California red-legged frog and revised in a manner that enhances
the ecosystem and watersheds upon which the frog relies. This should also be done for
National forests and lands managed by the Bureau of Land Management where the
California red-legged frog is present. A priority is the implementation of best management
practices by California State Park staff in implementation of the State-wide burn program.
10) Develop and implement best management practices to prevent or minimize adverse
impacts to the California red-legged frog from in-stream and stream bank activities
associated with flood control actions.
Guidelines on flood control measures should be developed and implemented on public

lands. Guidelines could include actions such as: maintenance of appropriate levels of
down woody material in riparian zones and within a 150-meter (500-foot) distance from
ponds, marshes, and other aquatic habitats; avoidance of seeding/revegetating treated
areas with non-native species (including using mulch that may contain non-native seed
species); contour felling of trees within or just outside riparian zones to help reduce runoff
and sedimentation of streams; and monitoring to verify effectiveness of actions.
Guidelines should address impacts of flood control activities carried out upstream of
California red-legged frog habitat.
11) Implement watershed management and protection plans using cooperative

agreements and existing incentive programs.
Traditional fee title acquisition by government or private resource interests is an effective,

but expensive, way of protecting resources. Other mechanisms to protect habitat on
private lands include: 1) local zoning restrictions that prevent incompatible uses, 2)
transfer of development rights, 3) fee title donations, 4) sale or donation of conservation
easements, 5) land swaps, 6) sale and back lease or resale programs with restrictive
covenants, and 7) use of existing incentive programs (described in Appendix E). Support
and assistance of private landowners in conserving and recovering the frog may be gained
by developing economic and other incentive programs (relief from taxes, tax credits, tax
deductible habitat management expenses, safe harbor agreements).
B. RECOVERY TASKS
1.0 Develop and implement watershed management and protection plans for core
areas.
While the California red-legged frog uses streams, ponds, and other wetlands to varying
degrees, an assumption of this recovery plan is that a varied landscape with multiple
opportunities for breeding within a watershed is optimum. For example, these frogs may
rely on artificial ponds for the majority of reproductive output but move into streams in
wet years or when suitability is increased via restoration. Thus, having both habitat
types in optimum condition within the landscape/watershed will provide the variety of
available habitats on which California red-legged frogs typically rely. Watershed
improvements are expected to increase habitat for the California red-legged frog by
providing suitable aquatic sites for breeding that are maintained by hydrological balance
and located within a matrix of adjacent uplands that are managed appropriately (i.e.,
have stabilized soils and are not fragmented).
Management and protection plans should be developed for each core area as listed in
Table 6. Watershed assessments will be necessary to determine restoration and land
management needs for each watershed. Methods to enhance habitat and minimize or
eliminate identified threats should be included in the management and protection plan.
Each plan should include proposals to incrementally protect, via conservation
easements, fee title, acquisitions, or other mechanisms, important breeding and dispersal
habitats. The Guidance for Development of Watershed Management Plans and
Implementation of Recovery Tasks (section III.A) should be used to assess the needs
within a particular drainage and to develop appropriate land use guidelines, threat
minimization measures, and/or land protection and restoration measures.
Because ownership within targeted watersheds is likely to encompass multiple land

owners, multi-entity cooperative watershed management plans will be necessary to
secure appropriate flows, control predators that may disperse into frog breeding habitats
from within or outside a watershed, combine restoration and enhancement efforts, and
manage use of uplands to allow for maintenance of suitable wetlands.
2.0. Develop and implement watershed management and protection plans for each
watershed that currently supports populations of the California red-legged frog
(priority 2 watersheds).
Within priority 2 watersheds, known or potential California red-legged frog habitat

should be managed in a manner which maintains or enhances the suitability for this
species. Land use guidelines should be implemented, as appropriate, to minimize
impacts to California red-legged frog populations (see Guidance for Development of
Watershed Management Plans and Implementation of Recovery Tasks). Preservation of
habitat, via acquisition or easements, may further protect the species in priority 2
watersheds.
3.0 Develop and implement watershed management and protection plans for each
watershed that was historically occupied by the California red-legged frog (priority
3 watersheds).
Priority 3 watersheds are areas that historically harbored California red-legged frogs. In
priority 3 watersheds, the likelihood of successful recovery is less than in core areas and
priority 2 watersheds. These areas will need (in most cases) extensive rehabilitation
Table 6. Core areas targeted for development and implementation of management and protection plans for the
Recovery Core Area Conservation Needs

Task #
1.1 Feather River Protect existing populations, remove non-native predators, protect and restore
wetlands within watershed, reestablish populations within this watershed and/
or augment existing populations with additional individuals.
1.2 Yuba River-South Fork Feather Protect existing populations, remove non-native predators, protect and restore
wetlands within watershed, reestablish populations within this watershed and/
or augment existing populations with additional individuals.
1.3 Middle Fork American River Control bullfrogs, reestablish populations within this watershed.
1.4 Cosumnes River-South Fork Protect existing populations, restore additional habitat, protect
American River connectivity, reestablish populations and/or augment existing population.
1.5 South Fork Calaveras Control bullfrogs, minimize effects of off-road vehicle use by eliminating
vehicle trails in California red-legged frog habitat, reestablish populations.
1.6 Tuolumne River Control non-native fish and amphibians, reestablish populations (e.g., at
Swamp Lake, Miguel Meadows).
1.7 Piney Creek Control bullfrogs, reestablish populations.
1.8 Cottonwood Creek Control bullfrogs.
1.9 Putah Creek-Cache Creek Reduce impacts of land uses, protect and restore wetland habitats, reestablish
populations.
1.10 Tributaries to Lake Berryessa Protect existing populations, reduce impacts of recreation, augment existing
populations.
1.11 Upper Sonoma Creek Protect existing populations, conduct subwatershed assessments and
management, control bullfrogs, maintain dams.
1.12 Petaluma Creek-Sonoma Creek Protect existing populations; reduce impacts of urban development; protect,
restore, and/or create breeding and dispersal habitat.
1.13 Point Reyes Peninsula Protect existing populations, control bullfrogs, continue genetics research on
R.a. aurora and R.a. draytonii, manage livestock and horse corrals to prevent
nutrient loading problems.
1.14 Belvedere Lagoon Encourage voluntary creation and/or management of habitat on private lands.
1.15 Fagan-Jameson Canyon- Protect existing populations from current and future urbanization, create and
Lower Napa River manage alternative breeding habitats, protect dispersal corridors.
1.16 East San Francisco Bay Protect existing populations; control non-native predators; study effects of
grazing in riparian corridors, ponds and uplands (e.g., on East Bay Regional
Park District lands); reduce impacts associated with livestock grazing; protect
habitat connectivity; minimize effects of recreation and off-road vehicle use
(e.g., Corral Hollow watershed); avoid and reduce impacts of urbanization;
protect habitat buffers from nearby urbanization.
1.17 Santa Clara Valley Protect existing populations, control non-native predators.
1.18 South San Francisco Bay Protect existing populations, control non-native predators, increase
connectivity between populations, reduce erosion, implement guidelines for
recreation activities to reduce impacts, implement forest practice guidelines,
reduce impacts of urbanization.
1.19 Watsonville Slough-Elkhorn Protect existing populations, protect habitat connectivity, reduce impacts of
Slough agriculture, improve water quality, reduce impacts of urbanization .
1.20 Carmel River-Santa Lucia Protect existing populations, restore Carmel River watershed.
1.21 Gablan Range Protect existing populations, protect habitat connectivity, restore and create
habitat.
1.22 Estero Bay Protect existing populations, protect habitat connectivity, control non-native
predators, reduce water diversions to ensure adequate flows (e.g., Villa Creek,
Ellysly Creek).
1.23 Arroyo Grande Restore habitat, protect habitat connectivity.
1.24 Santa Maria-Santa Ynez River Protect existing populations; reduce contamination of habitat (e.g., clean
contaminated ponds on Vandenberg Air Force Base); control non-native
predators; implement management guidelines for recreation; cease stocking
dune ponds with non-native, warm water fish; manage flows to decrease
impacts of water diversions; implement guidelines for channel maintenance
activities; preserve buffers from agriculture (e.g., in lower reaches of Santa
Ynez River and San Antonio Creek).
1.25 Sisquoc River Restore habitat, control non-native predators, maintain Mono Debris Dam to
prevent the spread of bullfrogs, implement recreation guidelines, eliminate off-
road vehicle use of habitat areas, implement guidelines for placer mining and
suction dredging.
1.26 Ventura River-Santa Clara River Restore habitat, control non-native predators and non-native plants, remove
Matilija Dam.
1.27 Santa Monica Bay- Protect existing populations (e.g. East Las Virgenes Creek), restore
Ventura Coastal Streams habitat, reestablish populations, augment existing population.
1.28 Estrella River Restore habitat.
1.29 San Gabriel Mountains Restore habitat, eliminate non-native predators, assess suitability for
reestablishment of populations, reestablish populations where appropriate.
1.30 Mojave River Restore habitat, assess suitability for reestablishment of populations,
reestablish populations where appropriate.
1.31 Santa Ana Mountain Restore habitat, assess suitability for reestablishment of populations,
1.32 Santa Rosa Plateau Protect existing population, augment existing population with individuals,
remove non-native predators.
1.33 San Luis Rey Restore habitat, assess suitability for reestablishment of populations;
reestablish populations where appropriate
1.34 Sweetwater River Restore habitat, assess suitability for reestablishment of populations,
1.35 Laguna Mountain Restore habitat, assess suitability for reestablishment of populations,
prior to recolonization or reestablishment. However, with intensive efforts and public

support, conservation of habitat in these watersheds is possible and may contribute to
the overall distribution and recovery of this species. Priority 3 watersheds include
unoccupied watersheds within the historic range including watersheds in the southern
Sierra Nevada and wetlands within the Central Valley (particularly wetlands that are on
U.S. National Wildlife Refuges).
4.0 Develop and implement conservation plans (e.g., Habitat Conservation Plans) for
the California red-legged frog on all State and regional parks and water/utility
district lands within the historic and current range.
Many State parks occur within the range of the frog and are key to providing habitat and
protective measures necessary for recovery of the frog. Parks that provide important
frog habitat include: Henry W. Coe State Park, Big Basin Redwoods State Park, Butano
State Park, Wilder Ranch State Park, and numerous others. Regional Park districts and
water and municipal utility districts that harbor frogs should also develop and
implement conservation plans, if existing land management plans are inadequately
protecting the California red-legged frog or have not yet been developed.
5.0 Work with county planners and local water districts to minimize the effects of
urban and suburban development and associated activities by developing regional
plans and/or habitat conservation plans.
City and county governments, as the primary agencies making land use decisions, need
to be involved in recovery planning. Cooperative programs and regional plans are
needed to coordinate local, public, and private land use planning with State and Federal
land use and recovery efforts for the California red-legged frog. Regional plans and/or
habitat conservation plans should incorporate recovery goals by including dispersal
opportunities between California red-legged frog populations, protecting large areas of
habitat (both breeding and dispersal) without fragmentation and edge effects, by
controlling exotic predators, and by implementing land use guidelines. Cooperative
programs should encourage and promote development of regional plans for cities and
counties in the area covered by this recovery plan. Development of cooperative
programs based on counties or at the watershed level may be most feasible.
6.0 Implement regional ecosystem strategies via existing regulatory processes to

minimize the effects of incidental take resulting from land uses and development
activities, and optimize benefits to the California red-legged frog derived from
mitigation and compensation actions.
Use of local, State, and Federal laws, regulations, and policies to protect the California
red-legged frog and its habitat provide existing, in-place conservation mechanisms. To
ensure that projects subject to these regulations do not preclude, but rather facilitate
recovery, project planning, and mitigation planning should utilize an ecosystem and/or
regional approach and include adaptive management.
6.1 Emphasize the connectivity of affected habitat areas or populations by

analyzing impacts and developing mitigation recommendations at the
regional level.
Numerous developments in a region are likely to result in intense cumulative

impacts such as large areas of habitat loss and fragmentation. Thus, a landscape
approach to impact analysis and mitigation planning is necessary. Conservation
measures should enhance connectivity between habitat areas and should enhance
the effectiveness of mitigation sites or measures associated with adjacent
(perhaps already permitted) projects.
6.2 Design mitigation plans to enhance the viability of an entire known

metapopulation or group of populations.
Analysis of the status of California red-legged frog population distribution is

necessary to best manage populations and metapopulations while providing
flexibility in planning and mitigation development. Mitigation actions should
focus on protecting and enhancing source populations and maintaining
connectivity with other subpopulations or suitable habitat. If the impact analysis
indicates that a small portion of a known metapopulation (or group of populations
if the status of a metapopulation is undocumented or unknown) may be impacted
(approximately 10 percent or less of known subpopulations or breeding sites),
metapopulation viability may not be precluded with proper protection of the
source population(s). If a larger portion of the metapopulation (or group of
populations) will be negatively impacted, an emphasis on avoidance of impacts
will be necessary as well as appropriate habitat enhancement and preservation to
ensure long term viability of the metapopulation. Where dispersal between
populations is unclear, connectivity of habitats between known populations
should be maintained so that opportunities for interactions between populations
are not precluded.
6.3 Analyze project impacts by considering the variable breeding status of the
California red-legged frog in response to varying weather conditions.
Project and mitigation planning should include an analysis of the status of the
affected population(s) and/or metapopulation(s) to determine the importance of
the breeding habitat or subpopulations from one year to another. A historical
perspective on habitat use of the area is necessary when sufficient data are
available. If a project will negatively affect a number of breeding sites in an area
that includes all or part of a known population or group of populations, care
should be taken to ensure that despite varying current and future weather
conditions (i.e., extremely wet or dry years) there are sufficient breeding sites
available, over the long term, to allow for at least an average of 75 percent of
subpopulations to be reproductively successful in any given year.
6.4 Implement off-site mitigation when on-site conditions are not likely to be
beneficial for the frog.
Many proposed developments lead to unsuitable conditions for the California

red-legged frog. For example, housing developments typically result in increased
presence of non-native predators, altered flow regimes, and increased human use
of aquatic and upland habitats. In these cases, alternative sites for mitigation
should be considered to offset the effects of an action. Core areas as identified in
each recovery unit should be the focus of off-site mitigation or compensation.
Consolidation of mitigation actions may be achieved by development and
implementation of cooperative agreements with local and regional agencies.
Mitigation banks may be another appropriate vehicle for achieving this goal in
some areas.
6.5 Include management and monitoring plans for mitigation measures that rely
on habitat construction, enhancement, or preservation.
Acreage that is set aside for frogs may not be adequate without proper
management. A management plan and an endowment or other funding
mechanism should be included with land preservation to maintain habitat
suitability in perpetuity. Management may include predator removal,
maintenance of created habitat, maintenance of adequate hydrology, and
monitoring.
6.6 Analyze past and future mitigation measures against clearly defined success
criteria to determine effectiveness.
While little is known about the optimum reproductive rates required for long-
term population viability of the California red-legged frog, post-project surveys
should be conducted to document the reproductive status of the frog on
mitigation areas. Contingency measures should be implemented if/when it is
apparent that the California red-legged frog is not successfully reproducing.
6.7 Establish and maintain a database that tracks the amount of incidental take
authorized and the effectiveness of mitigation measures.
This database should be maintained by a central agency, updated and distributed

to project planners and reviewers on a regular basis (i.e., yearly), and referred to
by project planners and regulators during the project planning and review stage.
Incidental take and the effectiveness of mitigation measures should be quantified
by recovery unit and tracked for cumulative effects.
6.8 Summarize extent of incidental take previously authorized in biological

opinions pursuant to section 7(a)(2) of the Endangered Species Act and
describe the status of the species in relation to recovery goals per recovery
unit.
Each biological opinion that addresses take of the California red-legged frog and
its habitat should provide a summary of the extent of take previously authorized
per recovery unit.
6.9 Cease the use of frog barriers as a mitigation measure.
Mortality of the California red-legged frog due to frog barriers has been
documented at several locations (Rathbun et al. 1997, Rathbun and Scott, in litt.
1999). This measure should be discontinued until the design and installation of
frog barriers have been refined, tested, and proven safe.
7.0 Develop and implement guidelines for improving water quality within the range of
the California red-legged frog.
In the absence of data specific to the California red-legged frog, water quality standards
should be developed based on existing data from related species or from standard
toxicity tests. The standards can then be used to develop and implement appropriate
guidelines for use of chemicals and management of water quality.
8.0 Implement air quality standards where poor quality is contributing to degraded
conditions for the California red-legged frog.
The Central Valley is the primary source of ozone and particulate air pollution in the
Sierra Nevada foothills (Cahill et al. 1996). Summer ozone is transported from the
Central Valley resulting in ozone levels in the Sierras that are as severe as those on the
valley floor. The proposed Federal standard of 8 parts per million should be met for the
Central Valley floor and Sierran foothills, particularly in the summer months when
transport is strongest.
9.0 Prevent the spread of disease and parasites in the California red-legged frog.
Observations of diseased and parasite-infected amphibians are now frequent. Amphibian

pathogens and parasites can be carried on the hands, footwear, or equipment of field
workers. These pathogens and parasites can spread to localities containing species with
little or no prior contact. Therefore, it is important for those involved in research in
wetland/pond habitats (including research on fish, invertebrates, and plants as well as
amphibians) to take steps to minimize the spread of disease agents and parasites.
9.1 Refine guidelines to minimize the spread of disease and parasites.
A Code of Practice, prepared by the Declining Amphibian Populations Task

Force of the International Union for the Conservation of Nature and Natural
Resources, provides guidelines for use by anyone conducting fieldwork at
amphibian breeding sites or other aquatic habitats. The Code is included as
Appendix F. Refinement of these guidelines may be necessary to ensure that the
most appropriate measures are implemented for research activities affecting the
California red-legged frog and its habitats.
9.2 Minimize chances of spreading disease and parasites when conducting field
surveys and research activities.
Upon development of disease and parasite minimization guidelines for the

California red-legged frog, the guidelines should be adhered to by all researchers
and surveyors. The guidelines should be listed as a term and condition for
scientific take permits.
10.0 Restore habitat conditions for the California red-legged frog at or near historical
localities, and where feasible, reestablish populations at extirpated localities (i.e.
unoccupied core areas).
The absence of the California red-legged frog in many areas within their historic range
indicates that habitat suitability must be enhanced. In many areas, however, even with
improved habitat conditions, natural recolonization is unlikely due to habitat
fragmentation and the large distances between known populations. Active augmentation
of populations and reestablishments following the guidelines in Appendix G, will be
necessary, upon completion of habitat restoration, to facilitate recovery.
Reestablishments are not necessary in each recovery unit but will be an important tool
to recovering the frog in recovery units 1, 2, and 8. The level of regulatory protection
for re-established populations is outlined in section 10(j) of the Endangered Species Act
(see Appendix G). Where mixed land ownership occurs, reestablishment efforts should
occur on public lands and only on private lands when landowners willingly volunteer
their lands for reestablishment efforts.
10.1 Implement site assessments and restoration programs prior to

reestablishment of the California red-legged frog.
The following steps may be necessary prior to reestablishment of California red-

legged frog populations:
■ Comprehensive watershed surveys in areas previously unsurveyed are

necessary to determine absence/presence and current habitat suitability.
■ Where the frog is absent, analyses of its habitat conditions are necessary to
determine reason for its absence.
■ Enhancement of habitat suitability, to the extent feasible, may be necessary in

areas where the frog is no longer present and habitat appears unsuitable.
Construction of breeding ponds and/or enhancement of existing breeding habitat
may also be necessary.
■ Analysis of the genetic differentiation of California red-legged frogs within

regions and between regions (particularly in the Sierra Nevada foothills and
southern California).
10.2 Conduct pilot captive rearing and reestablishment efforts to test the
effectiveness of methods, and modify protocol as necessary to improve the
effectiveness of reestablishments.
Appendix G provides initial guidelines for reestablishment efforts. These

guidelines will be refined as necessary. Reestablishment attempts should
continue using and testing various methods until at least one population in each
currently unoccupied core area is viable.
10.3 Reestablishment efforts should be carried out at each core area that does
not currently support the California red-legged frog.
10.3.1 Reestablish the frog in unoccupied core areas in Recovery Unit #1.
Unoccupied core areas in Recovery Unit #1 are: Yuba-South Fork

Feather River, South Fork Calaveras River, Tuolumne River, and Piney
Creek.
10.3.2 Reestablish the frog in unoccupied core areas in Recovery Unit #2.
The unoccupied core area in Recovery Unit # 2 is the Putah Creek-

Cache Creek core area.
10.3.3 Reestablish the frog in unoccupied core areas in Recovery Unit # 8.
Unoccupied core areas in Recovery Unit #8 are: San Gabriel

Mountains, Mojave River, Santa Ana Mountain, San Luis Rey River,
Sweetwater River, and Laguna Mountain.
11.0 Conduct research on the biology of the California red-legged frog and its habitat
requirements.
Much of the current status, general ecology, habitat requirements, and population trends
of this subspecies is unknown. Research is necessary in many areas to fully understand
the California red-legged frog, its relationship to its environment and its response to
various threats. Completion of recommended research projects will provide additional
information needed to refine recovery criteria and actions, and assist in determining if
and when delisting is appropriate. Data will also provide important guidance for
adaptive management.
11.1 Develop a California red-legged frog survey protocol.
A standardized protocol approved by us is necessary for this subspecies.
11.2 Identify areas for which no surveys of the California red-legged frog have
been carried out or where data are out-dated; conduct surveys in these
areas, obtaining private landowner permission to survey where necessary.
A better understanding of the distribution of the California red-legged frog is

needed. Many areas throughout the historic and current range of the frog have not
recently been surveyed and in some cases, never been surveyed. Most private
lands throughout the range of the California red-legged frog have not been
currently surveyed and represent a large gap in the understanding of this
subspecies. When potential California red-legged frog habitats are identified and
appropriate permissions have been obtained from private landowners, permitted
researchers should survey for the frog using the approved survey protocol.
Participation with willing landowners is essential to expand the scope of surveys

to private lands. One means may be to develop cooperative arrangements with
private landowners and managers of municipal lands. In addition, a joint United
States and Mexico effort to survey and protect California red-legged frog
populations and their habitat in Mexico is needed.
The following regions have been identified as areas which need current surveys.
Additional areas will inevitably be identified throughout implementation of the
recovery plan.
11.2.1 Conduct surveys in the Tehachapi Mountains.
11.2.2 Conduct surveys in the Santa Monica Mountains.
11.2.3 Conduct surveys in the Sisquoc River.
11.2.4 Conduct surveys in the upper Salinas River drainage including the
Estrella-San Jose system in San Luis Obispo County.
11.2.5 Conduct surveys in the Carrizo Plain and San Juan Creek.
11.2.6 Conduct surveys on Bureau of Land Management lands

(particularly in Recovery Unit # 6).
11.2.7 Conduct surveys within the historic and current range in the Sierra
Nevada.
11.2.8 Conduct surveys on all other lands identified as unsurveyed or

where survey data is not recent (within the last 5 years).
11.3 Monitor known California red-legged frog populations.
A better understanding of the demographics and distribution will give a fuller

picture of population viability and threats to California red-legged frog
populations. These data are necessary to assess the species’ status over time.
Identification of source and sink populations should be included under this
recovery action.
11.3.1 Develop a population monitoring program.
Protocols for the collection and analysis of qualitative and quantitative

monitoring data should be developed. One approach may be to monitor
representative populations such that the viability of a group of
populations or a known metapopulation can be estimated.
11.3.2 Conduct qualitative assessments of all known populations.
Each population should be monitored to determine its status. Parameters

to be noted include presence/absence of suitable habitat, habitat
modification, disturbance, threats, and other factors.
11.3.3 Conduct quantitative assessments of representative populations.
Representative populations, in each recovery unit, will be chosen to be

monitored in greater detail using a protocol as defined under Task
11.3.1. Quantitative data needs include, but are not limited to, numbers
of individuals per age class, reproductive rates, survival, recruitment
rates, immigration and emigration rates. This information should allow
for the identification of source and sink populations.
11.3.4 Researchers and surveyors should, as a term and condition for

holding a section 10(a)(1)(A) scientific take permit, provide survey
and monitoring information to us and the California Department of
Fish and Game for input into appropriate databases.
Survey data should be provided to the California Department of Fish and

Game’s Natural Heritage Program for input into their Natural Diversity
Database on a yearly basis. In addition, population monitoring data and
habitat condition information should be consolidated into a database,
and maintained by our Sacramento, Ventura, and Carlsbad Fish and
Wildlife offices. This database should be accessible to all interested
parties including planning agencies, researchers, and the general public.
11.3.5 Use the results obtained from the monitoring of the California red-
legged frog populations to determine where recovery efforts need to
be focused and to change prioritization of actions and locations if
necessary.
A contingency plan should be developed and implemented to best

respond to success and/or failure of previously implemented recovery
methods. For example, if bullfrog eradication programs have resulted in

expenditure of funds with little success, alternatives should be
investigated and implemented. Further, if surveys reveal areas of source
populations that are not identified as core areas, the delineations of core
areas should be re-defined or expanded as appropriate.
11.3.6 Track status and recovery of California red-legged frog populations

per recovery unit and propose delisting where appropriate.
Monitoring of frog population trends, habitat conditions, and status of

threats may indicate that delisting is appropriate. It is likely, however,
that recovery will occur at different rates per region; recovery units with
lower recovery potential will require extensive management and
monitoring. If distinct vertebrate population segments are identified,
these may be delisted independently when appropriate.
11.3.6.1 Track status and recovery in Recovery Unit # 1.
11.4 Conduct population viability analyses for California red-legged frog

metapopulations throughout the range as appropriate.
Population viability analyses are tools that can identify populations in need of
recovery actions, as opposed to those that may be viable over the long-term
without intervention. Population viability analyses also may help identify the best
sites for reestablishment (i.e., identify metapopulations that may require
additional subpopulations for long-term viability), determine the effectiveness of
recovery actions (i.e., determine whether population growth rates are sufficient to
ensure long term viability), determine whether recovery criteria are appropriate or
need revision (i.e., whether the recovery goals are adequate to ensure long-term
viability of the subspecies), determine minimum population sizes required for
long-term viability, determine the anticipated time when recovery goals can be
reached, and provide many other answers related to population trends.
11.5 Study metapopulation dynamics, particularly the California red-legged frog

movements, among subpopulations.
This information will be used to determine whether active reestablishment efforts

are necessary following habitat restoration. Information on metapopulation
dynamics, in conjunction with frog monitoring data, will also help define isolated
populations that are at risk of local extirpation, and identify source and sink
subpopulations.
11.6 Conduct research to better understand the ecology of the California red-
legged frog including the use of uplands, dispersal habits, and overland
movements.
Environmental factors and habitat characteristics that hinder or facilitate

movement of various life stages should be determined. This will assist in the
development of best management practices, appropriate buffers from
disturbances, and optimum preserve design and size.
11.7 Investigate the effects of contaminants issues including ozone, pesticides,

herbicides, heavy metals, salinity, selenium, agricultural chemicals,
hydrocarbons, chlorine, ultraviolet radiation, estrogen mimics, airborne
contaminants, methoprene and other chemicals used to control mosquitoes,
and others as appropriate (e.g., detergents).
The effects of contaminants on the California red-legged frog have not been
widely studied and this is an area where research is needed. As noted above,
toxicity tests are needed to determine the effects of contaminants, the levels at
which detrimental effects occur, and measures required to minimize the effects
of chemicals. Further, the transport of contaminants from primary sources (e.g.,
Central Valley) to distant areas (e.g., the Sierran foothills) should be investigated.
Research on the effects and transport of contaminants will provide information
necessary for establishing sound air and water quality standards. In addition, risk
assessments of pesticides typically fail to evaluate the breakdown by-products.
Recent research suggests these by-products may pose a threat to amphibians (La
Clair 1998) although these experiments used 15,000 times the label rate and still
found low levels of deformity or mortality (P. Bindings in litt. 2000). Therefore,
the effects of breakdown by-products of pesticidal chemicals should also be
evaluated
11.8 Conduct research on the effects of mosquitofish including the development

of alternatives to mosquitofish use.
Mosquitofish are considered to be a predator of the California red-legged frog

although there are some sites where the species coexist. Additional research is
needed to better understand how these two species interact. Alternatives to the
use of mosquitofish as a means of mosquito abatement should be investigated to
decrease this practice if it does indeed pose a threat to the frog. Alternatives
include other biological control methods such as the application of several
species of bacteria (Bacillus sp.) and a fungus (Lagenidium giganteum) which
attacks and kills only mosquitoes. The implications of introductions of these
other control agents, however, may require extensive research. To implement this
task, we should work with mosquito and vector control districts to minimize
conflicts between public health and the California red-legged frog, and look for
sources of funding for necessary research.
11.9 Conduct research on the ecology of non-native species.
To better understand the interactions with and effects on the California red-
legged frog and gain an understanding on the best management of habitats (i.e,
management that favors red-legged frogs over non-native predators), more

information on the distribution, life histories, and habitat needs of non-native
predators is needed. An important component of this task is to gather such
information on bullfrogs. Bullfrogs should be studied at a minimum of three
northern coastal sites, three northern non-coastal sites, three southern coastal
sites, and three southern non-coastal sites, to consider variations in the bullfrog’s
life history within the range of the California red-legged frog. Another research
need is to determine effects of non-native species including crayfish, non-native
fish, and African clawed frogs.
11.10 Determine the genetic and ecological relationships between Rana aurora
draytonii and R. a. aurora.
Red-legged frogs in the intergrade zone from northern Marin County to southern
Del Norte County have not been assigned to either subspecies (northern red-
legged frog or California red-legged frog). Based on morphological and
behavioral differences, researchers have suggested that the two subspecies may
actually be distinct species and that the frogs in the intergrade zone may represent
a zone of hybridization between the two species (G. Fellers pers. comm. 1999).
Genetic research is needed to clarify systematic relationships and allow a more
precise identification of the northern limits of the geographic distribution of the
11.11 Determine whether distinct vertebrate population segments are identifiable

Portions of the range of the California red-legged frog may be delisted

incrementally, provided the delisted portions qualify as distinct population
segments (defined in U.S. Fish and Wildlife Service 1996e). Research is needed
to determine whether particular recovery units, combinations of recovery units, or
other portions of the range of the frog meet the definition of distinct population
segments. Such research would address whether portions of the range are
‘discrete’ and ‘significant’ in relation to the remainder of the species (as described
in Section II-c and in U.S. Fish and Wildlife Service 1996e).
11.12 Conduct experimental manipulations of habitat to determine habitat

requirements of the frog, and subsequently, develop habitat creation and
restoration.
One of the most fruitful ways to investigate the habitat requirements of California
red-legged frogs is through creation and manipulation of habitats. These
investigations will serve two needs: to better understand habitat requirements of
the frog, and refine the methods for creation, improvement, and management of
habitat (natural and artificial). Experiments could include examination of the
optimum structure (i.e., depth, size) of artificial ponds and the optimum
hydroperiod for maintaining suitability for the California red-legged frog, while
decreasing the chances of non-native predator proliferation. Responses of the red-
legged frog to habitat experiments need to be carefully monitored over a period
of 5 years minimum.
11.13 Conduct studies on the interactions of cattle grazing and California red-
legged frogs.
Experimental manipulations with habitat controls will best assist land managers
in the development of appropriate grazing regimes. In particular, to determine

the effects of various grazing regimes, it will be extremely beneficial to
experimentally fence portions of riparian zones, ponds, springs, and other
aquatic bodies to exclude livestock to varying degrees and over differing time
periods.
11.13.1 Determine the effects of livestock waste on frogs, particularly larval

development.
Congregation of livestock and horses (i.e., watering troughs, corrals)

may be a source of concentrated waste. Research is necessary to fully
understand the effects on all life stages of the California red-legged frog
and to determine the appropriate avoidance buffer needed to minimize
impacts to the frog.
11.13.2 Determine grazing thresholds, on a site by site basis, that ensure

optimum habitat suitability for the California red-legged frog.
Areas that need further research include determination of appropriate

stocking densities, seasonality of grazing, and residual dry matter levels
for California red-legged frog habitat suitability.
11.14 Develop and/or refine a protocol for a captive rearing and propagation
program.
California red-legged frogs from captive rearing and propagation efforts may be
required for reestablishment efforts or as an insurance measure to forestall
extinction of wild populations in the event of catastrophic population declines.
Propagation techniques should be designed to minimize both the loss of genetic
diversity and the introduction and spread of non-native diseases. Laboratory
experiments should only use frogs from captive propagation efforts.
11.15 Investigate the effects of eucalyptus on water quality and habitat suitability
for California red-legged frogs.
Stream reaches which are dominated by eucalyptus may not be suitable for the
California red-legged frog. The relationship of eucalyptus and habitat suitability
for the frog should be examined.
12.0 Increase public awareness and involvement in the protection of the California red-
legged frog and native, co-occurring species.
Implementation of recovery actions may depend on the level of awareness of public

landowners, private landowners, conservation groups, planning interests, and
stakeholders. Outreach plans and educational programs explaining the life history and
habitat needs of the species and the goals of recovery will be an important part of
implementation.
12.1 Develop and implement outreach plans.
Plans should focus on providing information to interested and affected

landowners about: (1) the California red-legged frog, (2) what is meant by
recovery, and (3) how recovery can be achieved. Private landowners should
become familiar with the frog and/or frog habitat that occur on their land, with
the significance of the populations, and with available conservation measures,
including incentive programs. For private lands with potential occurrences of the
California red-legged frog (i.e., lands with historic occurrences or otherwise
within the range of the subspecies), permission should be sought from
landowners to conduct surveys (task 11.2). If populations of the California red-
legged frog are identified, landowners should be informed of their significance
and should be encouraged to follow land uses guidelines that protect the species
and its habitat.
We should offer periodic updates to the press and general public regarding the
status of the California red-legged frog and recovery efforts. Creation of exhibits
containing live frogs in natural frog habitat should be encouraged if exhibits are
also used to gather pertinent research information such as captive propagation
techniques. The National Wildlife refuges, Point Reyes National Seashore,
Golden Gate National Recreation Area, Año Nuevo and/or other State parks,
National Forests, and regional park districts should be excellent locations for
providing such educational opportunities to the public.
12.2 Develop and implement participation plans.
Participation plans will assist in the realization of recovery goals by getting

commitments from participating agencies and stakeholders to implement
recovery actions where feasible. Implementation of recovery tasks will require
cooperative efforts on the part of resource and regulatory agencies, regional,
county, and city park districts, local landowners, conservation groups, and
planning interests. Development and implementation of separate participation
plans in each recovery unit is necessary.
12.2.1 Develop a participation plan for Recovery Unit # 1.
12.3. Provide technical assistance to private landowners who wish to voluntarily

improve conditions for the California red-legged frog.
A significant portion of recovery can be achieved through landowners who may

voluntarily improve habitat conditions for the California red-legged frog.
Landowners should be provided technical guidance such as guidelines for
wetland/pond management when requested (see Appendix D).
13.0 Assess effects of various conservation efforts on co-occurring, native species.
Population data on listed and non-listed sensitive, co-occurring native species (Table 2)
will aid in their preservation. Improved habitat conditions may lead to increased
populations of species of concern and thus may forestall the need to list these species in
the future. Although it is assumed that enhancement of habitat conditions for the
California red-legged frog will benefit other native species, the impacts of enhancement
efforts on co-occurring, native species should be assessed.
13.1 Monitor co-occurring, native species.
There must be sufficient monitoring of populations and reproduction to detect

any detrimental effects that may arise from habitat improvements directed at
improving conditions for the California red-legged frog. Species-specific habitat
information should be collected on an as needed basis. This task can be achieved
through coordination with ongoing recovery efforts for associated listed species.
13.2 Implement remediation, where appropriate.
If conservation efforts cause declines in populations of listed or non-listed co-

occurring species, remediation efforts should be developed and implemented.
89
IV. Implementation Schedule
This implementation schedule outlines actions and estimated costs for this recovery plan. It is a
guide for meeting the objectives discussed in this recovery plan. This schedule describes and
prioritizes tasks, provides an estimated time table for performance of tasks, indicates
responsible agencies, and estimates costs of performing tasks. These actions, when
accomplished, should recover the California red-legged frog and co-occurring species.
KEY TO ACRONYMS USED IN THE IMPLEMENTATION SCHEDULE
Definition of task priorities:
Priority 1 An action that must be taken to prevent extinction or prevent the species from
declining irreversibly in the foreseeable future.
Priority 2 An action that must be taken to prevent a significant decline in the species’
population or habitat quality, or some other significant negative impact short of
extinction.
Priority 3 All other actions necessary to meet recovery or conservation objectives.
Definition of task durations and costs:
Continual A task that will be implemented on a routine basis once begun.
Ongoing A task that is currently being implemented and will continue until action is no
longer necessary.
TBD To be determined.
* Continued implementation of task expected to be necessary after delisting.
† Task expected to be necessary until delisting of species (possible by 2025).
Responsible parties are those agencies who may voluntarily participate in any aspect of
implementation of particular tasks listed within this recovery plan. Responsible parties may
willingly participate in project planning, funding, provide technical assistance, staff time, or
any other means of implementation.
Costs of some recovery tasks cannot be estimated at this time. Costs of developing and
implementing watershed management and protection plans will vary with local circumstances
and details of individual plans. Sites for reestablishment of California red-legged frogs have
not yet been determined, so costs of assessment and restoration cannot be estimated. The
scope of necessary contaminants studies depends on results of ongoing research.
Responsible parties:
ACE Army Corps of Engineers
ADC Animal Damage Control
BLM Bureau of Land Management
BOR Bureau of Reclamation
BRD Biological Resources Division, U.S. Geological Survey
CDFG California Department of Fish and Game
CDPR California Department of Parks and Recreation
CDF California Department of Forestry and Fire Protection
COUN County
DOD Department of Defense
DWR California Department of Water Resources
EBRPD East Bay Regional Park District
EPA Environmental Protection Agency
FWS U.S. Fish and Wildlife Service
FS U.S. Forest Service
MUD Municipal Utility District
MULTI Multiple public land agencies
MVCD Mosquito Vector Control District
NPS National Park Service
TNC The Nature Conservancy
Tribe Local Native American tribe(s)
UCNRS University of California Natural Reserve System
UNIV University or academic researchers
WMD Local Water Management Districts
Potential lead responsible parties are designatd in bold.

Implementation Schedule for the California Red-legged Frog Recovery Plan
Cost Estimate (in $1,000 units)
Task Task Task Description Task Duration Responsible Parties Total FY1 FY2 FY3 FY4 FY5
Priority Number Costs
1 1.1 Develop and implement a management continual* Plumas National TBD

and protection plan for Core Area #1 Forest, Lassen
(Feather River). National Forest,
FWS
1 1.2 Develop and implement a watershed continual* Plumas National TBD
management and protection plan for Forest, FWS,
Core Area #2 (Yuba River-South Fork private
Feather)
Recovery Plan for the California Red-legged Frog
1 1.3 Develop and implement a management continual* Eldorado National TBD

and protection plan for Core Area #3 Forest, FWS,
(Middle Fork American River) private
1 1.4 Develop and implement a management continual* Plumas National TBD
and protection plan for Core Area #4 Forest, FWS, BLM,
(Cosumnes River-South Fork American DWR, USFS, FWS,
River) El Dorado County, El
Dorado Irrigation
District, American
River Conservancy
private
1 1.5 Develop and implement a management continual* FWS, TBD
and protection plan for Core Area #5 USFS–Calaveras
(South Fork Calaveras River) Ranger District,
private
1 1.6 Develop and implement a watershed continual* Yosemite TBD
management and protection plan for National Park,
Core Area #6 (Tuolumne River) FWS
1 1.7 Develop and implement a watershed continual* Stanislaus TBD
management and protection plan for National Forest,
Core Area #7 (Piney Creek) FWS
Potential lead agencies are designated in bold.

91
92

1 1.8 Develop and implement a watershed continual* MULTI TBD

management and protection plan for
Core Area #8 (Cottonwood Creek)
1 1.9 Develop and implement a management continual* BLM, FWS, private TBD
and protection plan for Core Area #9
(Putah Creek-Cache Creek)
1 1.10 Develop and implement a management continual* FWS, BLM, USBR, TBD
plan for Core Area #10 (Tributaries to CDFG, UCNRS,
Lake Berryessa) Quail Ridge
Wilderness
Conservancy
1 1.11 Develop and implement a watershed continual* CDPR, FWS TBD
Core Area #11 (Upper Sonoma Creek)
1 1.12 Develop and implement a watershed continual* FWS, Sonoma Land TBD
management and protection plan for Trust, private
Core Area #12 (Petaluma Creek-
Sonoma Creek)
1 1.13 Develop and implement a watershed continual* NPS, CDPR, Marin TBD
management and protection plan for Municipal Water
Core Area #13 (Point Reyes Peninsula) District, FWS
1 1.14 Develop and implement a watershed continual* FWS, private TBD
Core Area #14 (Belvedere Lagoon)
1 1.15 Develop and implement a management continual* FWS, Land Trust TBD
and protection plan for Core Area #15 of Napa County,
(Fagan-Jameson Canyon-Lower Napa City of American
River) Canyon

1 1.16 Develop and implement a management continual* EBRPD, FWS, TBD

and protection plan for Core Area #16 CDFG, CDPR,
(East San Francisco Bay) EBMUD, Lawrence
Livermore
Laboratory, DWR,
USBR, TNC, private
1 1.17 Develop and implement a watershed continual* MULTI TBD
Core Area #17 (Santa Clara Valley)

1 1.18 Develop and implement a management continual* CDPR, CDFG, TBD
and protection plan for Core Area #18 FWS. private
(South San Francisco Bay)
1 1.19 Develop and implement a management continual* Elkhorn Slough TBD
and protection plan for Core Area #19 National Estuarine
(Watsonville Slough–Elkhorn Slough) Research Institute,
CDPR, FWS,
private
1 1.20 Develop and implement a management continual* C D P R , Los TBD
and protection plan for Core Area #20 Padres National
(Carmel River-Santa Lucia) Forest, FWS,
private
1 1.21 Develop and implement a management continual* FWS, Pinnacles TBD
and protection plan for the Core Area National
#21 (Gablan Range) Monument, private
1 1.22 Develop and implement a management continual* CDPR, FWS, TBD
and protection plan for the Core Area private
#22 (Estero Bay)

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94

1 1.23 Develop and implement a management continual* CDPR, FWS, TBD

and protection plan for Core Area #23 private
(Arroyo Grande)
1 1.24 Develop and implement a management continual* Los Padres National TBD
and protection plan for Core Area #24 Forest, Vandenberg
(Santa Maria-Santa Ynez River) Air Force Base
(DOD), CDPR,
FWS, private
1 1.25 Develop a management and protection continual* FWS, Los Padres TBD
plan for Core Area #25 (Sisquoc River) National Forest
1 1.26 Develop a watershed management and continual* Los Padres TBD
protection plan for Core Area #26 National Forest,
(Ventura River-Santa Clara River) FWS, private
1 1.27 Develop and implement a watershed continual* CDPR, Santa TBD
management and protection plan for Monica National
Core Area #27 (Santa Monica Bay- Recreation Area,
Ventura Coastal Streams) Las Virgenes
Institute, FWS,
private
1 1.28 Develop a watershed management and continual* FWS, private TBD
protection plan for Core Area #28
(Estrella River)
1 1.29 Develop a watershed management and continual* Angeles National TBD
protection plan for Core Area #29 (San Forest, FWS
Gabriel Mountains)
1 1.30 Develop and implement a management continual* San Bernadino TBD
and plan for Core Area #30 (Mojave National Forest,
River) FWS

1 1.31 Develop and implement a watershed continual* Cleveland TBD

Core Area #31 (Santa Ana Mountain) FWS
1 1.32 Develop and implement a watershed continual* TNC, CDFG, FWS, TBD
management and protection plan for Cleveland National
Core Area #32 (Santa Rosa Plateau) Forest, private
1 1.33 Develop and implement a watershed continual* Tribe, FWS, WMD, TBD
management plan for Core Area #33 private,
(San Luis Rey)

1 1.34 Develop and implement a watershed continual* FWS, CDFG, TBD
management plan for Core Area #34 Sweetwater Authority
(Sweetwater River) (WMD)
1 1.35 Develop and implement a watershed continual* Cleveland TBD
Core Area #35 (Laguna Mountain) FWS, private
1 4 Develop and implement conservation continual* C D P R , Regional TBD
plans for the California red-legged frog Parks, MUDs, FWS
for all State and regional parks and
water/utility districts within the
historic and current range
1 5 Work with county planners and local ongoing* FWS, local 12 0.5 0.5 0.5 0.5 0.5
water districts to minimize effects of governments and
urban and suburban development by water districts
creating regional plans or habitat
conservation plans
1 6.1 Emphasize connectivity of affected ongoing* FWS 18 0.75 0.75 0.75 0.75 0.75
habitat areas or populations by
analyzing impacts and developing
mitigation recommendations at the
metapopulation and regional level
95

96

1 6.2 Design mitigation plans to enhance the ongoing† FWS 12 0.5 0.5 0.5 0.5 0.5
viability of an entire metapopulation
1 6.3 Analyze project impacts by considering ongoing† FWS 12 0.5 0.5 0.5 0.5 0.5
the variable breeding status of frogs in
response to varying weather conditions
1 6.4 Implement off-site mitigation when on- ongoing† FWS 18 0.75 0.75 0.75 0.75 0.75
site conditions are not likely to be
beneficial for the frog
1 6.5 Include management and monitoring ongoing† FWS 18 0.75 0.75 0.75 0.75 0.75
plans for mitigation measures that rely
on habitat construction, enhancement or
preservation
1 7 Develop and implement guidelines for continual* EPA, DWR, FWS 180 40 30 5 5 5
improving water quality within the
range of the California red-legged frog
1 8 Implement air quality standards where ongoing* EPA, FWS 270 80 80 5 5 5
poor quality is contributing to degraded
conditions
1 9.1 Refine guidelines to minimize the 1 year BRD, FWS 1.5 1.5
spread of disease and parasites
1 9.2 Minimize chances of spread of disease ongoing* MULTI 12 0.5 0.5 0.5 0.5 0.5
when conducting field surveys and
research
1 10.1 Implement site assessments and 2 years Los Angeles Zoo, TBD
restoration programs prior to BRD, Univ, FWS
reestablishment of the frog
1 10.2 Conduct pilot captive rearing and 2 years Los Angeles Zoo, 500 250 250
reestablishment programs to test BRD, Univ, FWS,
methods Las Virgenes Institute

1 10.3.1 Reestablish the frog in unoccupied core 5 years FWS, BRD, Univ 500 100 100 100 100 100
areas in Recovery unit # 1
1 10.3.2 Reestablish the frog in unoccupied core 5 years FWS, BRD, Univ 500 100 100 100 100 100
areas in Recovery Unit # 2
1 10.3.3 Reestablish the frog in unoccupied core 5 years Los Angeles Zoo, 500 100 100 100 100 100
areas in Recovery Unit # 8 FWS, Univ, Las
Virgenes Institute
2 2 Develop and implement management continual* MULTI TBD
and protection plans for all Priority 2

watersheds
2 6.6 Analyze past and future mitigation ongoing† FWS 18 0.75 0.75 0.75 0.75 0.75
measures against clearly defined success
criteria to determine effectiveness
2 6.7 Establish and maintain a database that ongoing† FWS 3.6 0.15 0.15 0.15 0.15 0.15
tracks the amount of incidental take
authorized and the effectiveness of
mitigation measures
2 6.8 Summarize extent of incidental take ongoing† FWS 2.4 0.1 0.1 0.1 0.1 0.1
previously authorized
2 6.9 Cease the use of frog barriers as a continual† MULTI 2 2
mitigation measure
2 11.1 Develop a California red-legged frog 1 year MULTI 40 40
survey and monitoring protocol
2 11.2.1 Conduct surveys in the Tehachapi 5 years MULTI 25 5 5 5 5 5
Mountains
2 11.2.2 Conduct surveys in the Santa Monica 5 years MULTI 25 5 5 5 5 5
Mountains

97
98

2 11.2.3 Conduct surveys in the Sisquoc River 5 years MULTI 25 5 5 5 5 5

Watershed
2 11.2.4 Conduct surveys in the upper Salinas 5 years MULTI 25 5 5 5 5 5
River Drainage
2 11.2.5 Conduct surveys in the Carrizo Plain 5 years MULTI 25 5 5 5 5 5
vicinity
2 11.2.6 Conduct surveys on Bureau of Land 5 years BLM, FWS 50 10 10 10 10 10
Management lands
2 11.2.7 Conduct surveys within the historic and 5 years MULTI 50 10 10 10 10 10
current range in the Sierra Nevada.
2 11.2.8 Conduct surveys on all other lands 20 years MULTI 1790
identified as unsurveyed
2 11.3.1 Develop a population monitoring 1 year BRD, FWS, Univ 40 40
program
2 11.3.2 Conduct qualitative assessments of 4 years FWS, BRD, CDPR 320 80 80 80 80
known populations
2 11.3.3 Conduct quantitative assessments of 10 years MULTI 1500 150 150 150 150 150
representative populations
2 11.3.4 Researchers should provide survey data ongoing† MULTI 12 0.5 0.5 0.5 0.5 0.5
to California Department of Fish and
Game and FWS
2 11.3.5 Utilize monitoring results to determine 25 years FWS 120 10 10
where recovery should be focused
2 11.3.6.1 Track status and recovery in Recovery ongoing† FWS 120 5 5 5 5 5

Unit # 1


Unit # 2
Unit # 3
Unit # 4
Unit # 5
Unit # 6
Unit # 7
Unit # 8
2 11.4 Conduct population viability analyses 5 years BRD, Univ, FWS 25 5 5 5
for metapopulations
2 11.5 Research metapopulation dynamics 10 years BRD, Univ, FWS 250 25 25 25
2 11.6 Conduct research to better understand 10 years BRD, Univ, Los 400 40 40 40 40 40
the ecology of this species including Angeles Zoo,
use of uplands, dispersal habits, and EBRPD, EBMUD,
overland movements FWS
2 11.7 Investigate contaminants issues ongoing† FWS, EPA, BRD TBD
2 11.8 Conduct research on the effects of 5 years BRD, Univ, 400 80 80 80 80 80
mosquitofish and determine alternatives MVCD, FWS
to mosquitofish use
2 11.9 Conduct research on the ecology of 5 years BRD, Univ, FWS 100 20 20 20 20 20
exotic species
99

100

2 11.10 Determine genetic and ecological 3 years Univ, BRD, FWS 90 30 30 30

relationships between R. aurora
draytonii and R.a.aurora
2 11.11 Determine whether distinct vertebrate 5 years BRD, FWS, Univ 150 30 30 30 30 30
population segments are identifiable for
the California red-legged frog
2 11.12 Conduct experimental manipulations of 5 years BRD, Los Angeles 100 20 20 20 20 20
habitat to determine requirements for Zoo, Univ, FWS,
creation and restoration Las Virgnes Institute,
TNC
2 11.13.1 Determine the effects of livestock waste 2 years BRD, NPS, FWS 40 20 20
2 11.13.2 Determine grazing thresholds that 5 years MULTI 100 20 20 20 20 20
ensure optimum habitat suitability
2 11.14 Develop a protocol for a captive 2 years Los Angeles Zoo, 50 25 25
propagation program BRD, Univ, FWS,
Las Virgenes Institute
2 12.1 Develop and implement outreach plans 1 year FWS 40 40
2 12.2.1 Develop and implement participation 1 year FWS 40 40
plan for Recovery Unit # 1


plan for Recovery Unit #8
2 12.3 Provide technical assistance to continual† FWS 120 5 5 5 5 5
landowners
3 3 Develop and implement a watershed continual* MULTI TBD

Priority 3 watersheds
3 11.15 Investigate the effects of eucalyptus on 1 year NPS, GGNRA, 20 20
water quality EBRPD, BRD,
FWS
3 13.1 Monitor cohabiting, native species continual† MULTI 240 10 10 10 10 10
3 13.2 Implement remediation, where continual† MULTI TBD
appropriate
Total estimated cost 10,031.5+
TBD costs

101
103
V. References
A. LITERATURE CITED
Anderson, J.D. 1960. A comparative study of coastal and montane populations of Ambystoma
macrodactylum. Unpublished Ph.D. Dissertation, University of California, Berkeley. 261
pp.
Barry, S. J. 1999. A study of the California red-legged frog (Rana aurora draytonii) of Butte
County, California. Sacramento, California, PAR Environmental Services.
Barry, S. J. 2000. Results of a survey for California red-legged frogs (Rana aurora draytonii)
near Little Oregon Creek, Yuba County, Plumas National Forest, California. Sacramento,
California, PAR Environmental Services.
Beedy, E.C. and W.J. Hamilton III. 1997. Tricolored blackbird status update management
guidelines. Prepared for Migratory Birds and Habitat Programs, U.S. Fish and Wildlife
Service, and Bird and Mammal Conservation Program, California Department of Fish and
Game. September 1997.
Behnke, R.J. and R. F. Raleigh. 1978. Grazing and the riparian zone: Impact and management
perspectives. Pp. 184-189. In Strategies for protection and management of floodplain
wetlands and other riparian ecosystems. R.D. Johnson and J. F. McCormick, (technical
coordinators). USDA, Forest Service, General Technical Report WO-12, Washington,
D.C.
Berrill, M., S. Bertram, L. McGillivray, M. Kolohon, and B. Pauli. 1993. Effects of low
concentrations of forest-use pesticides on frog embryos and tadpoles. Environmental
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Barry, S. 2000. Letter to U.S. Fish and Wildlife Service providing comments on the Draft
Barry, S. 1992. Letter to Marvin L. Plenert, Regional Director, U.S. Fish and Wildlife Service,
Portland, Oregon, regarding proposed listing.
Bindings, P. 2000. Letter to Wayne S. White, Field Supervisor, Sacramento Fish and Wildlife
Office, Sacramento, California, providing comments on the Draft California Red-legged
Frog Recovery Plan.
Bloom, P. 2000. Letter to U.S. Fish and Wildlife Service providing comments on the Draft
Bobzien, S. 1998. Letter to Wayne S. White, U.S. Fish and Wildlife Service, Sacramento,
California, responding to January 13, 1998, news release requesting input on recovery
needs of California red-legged frog.
Bulger, J. 1998. Wet season dispersal and habitat use by juvenile California red-legged frogs
(Rana aurora draytonii) in forest and rangeland habitats of the Santa Cruz Mountains. A
research proposal submitted to the U.S. Fish and Wildlife Service, Sacramento, California.
Christopher, S.V. 1998. Information provided to Ina Pisani regarding the status of California
red-legged frogs on Vandenberg Air Force Base, Lompoc, California.
Chubb, S. 1998. Letter to Grace McLaughlin, U.S. Fish and Wildlife Service, providing U.S.
Forest Service input for recovery plan.
Chubb, S. 1999. Letter to Ina Pisani, providing U.S. Forest Service comments on working draft
of recovery plan.
DiDonato, J. 2000. Comments to the U.S. Fish and Wildlife Service on the Draft California
Red-legged Frog Recovery Plan.
Fellers, G. 2001. Documentation of California red-legged frog in Placer County.
Fellers, G. 1998. Comments provided to Ina Pisani on a working draft of California red-legged
frog recovery plan.
Fong, D. 1998. Information on Tennessee Valley exotic predator control project conducted by
the Golden Gate National Recreation Area, National Park Service, San Francisco,
California.
Freel, K. 1998. Letter to Ina Pisani, U.S. Fish and Wildlife Service, Sacramento, California,
providing survey results from Henry Coe State Park.
Humiston, G. 1995. California Rangeland Water Quality Management Plan.
Hunt, L. 1993. Letter to Marvin L. Plenert, Regional Director, U.S. Fish and Wildlife Service,
Portland, Oregon regarding proposed listing.
Jennings, M. 1993. Letter to Peter C. Sorensen, U.S. Fish and Wildlife Service, Sacramento,
California.
Jennings, M. 1998a. Electronic database of California red-legged frog occurrences.
Jennings, M. 1998b. Electronic message to Ina Pisani regarding the status of California red-
legged frogs on Santa Cruz Island.
Jennings, M.R., M.P. Hayes, and D.C. Holland. 1992. A petition to the U.S. Fish and Wildlife
Service to place the California red-legged frog (Rana aurora draytonii) and the western
pond turtle (Clemmys marmorata) on the list of endangered and threatened wildlife and
plants. 21 pp.
Loredo, I. 1998. Electronic message to Ina Pisani regarding the status of California red-legged
frogs on National Wildlife Refuges.
Lorentzen, E. 1998. Letter to Ina Pisani providing comments on a working draft of the
California red-legged frog recovery plan.
Larsen, S. 1998. Electronic message to Ina Pisani regarding effects of coastal nurseries.
Malamud-Roam, K. 1994. Letter to Field Supervisor, Sacramento Field Office regarding the
proposed listing of the California red-legged frog as an endangered species.
McCasland, C. 1998a. Electronic message to Ina Pisani regarding the status of California red-
legged frogs in Solano County.
McCasland, C. 1998b. Electronic message to Ina Pisani regarding the effects of coastal
nurseries on California red-legged frogs.
McLaughlin, G. 2000. Electronic message to Ina Pisani regarding chytrid fungus in California
red-legged frog tadpole.
Montague, P. 1998. Electronic version of Rachel’s Environment and Health Weekly.

Environmental Research Foundation.
Moore, M. and M. Westphal. 1997. Memo to Cay Goude, Chief, Endangered Species Division,
Sacramento Fish and Wildlife Office, regarding conservation strategy for the California
red-legged frog in Contra Costa and Alameda Counties.
Orlorff, S. 2000. Letter to U.S. Fish and Wildlife Service providing comments on the Draft
Rathbun, G. 1998. Comments provided to Ina Pisani on working draft of California red-legged
frog recovery plan.
_____. 1999. Comments provided to Ina Pisani on working draft of California red-legged frog
recovery plan.
Rathbun, G. and M. Jennings. 1993. Letter to Naomi Mitchell, U.S. Fish and Wildlife Service,
Ventura Fish and Wildlife Office, Ventura, California, regarding Environmental Impact
Statement for the C.T. Ranch development.
Rathbun, G. and N. Scott. 1999. Letter to Ina Pisani regarding frog barriers.
Sasaki, T. 1999. Letter to Ina Pisani providing comments on working draft of California red-
legged frog recovery plan.
Scott, N. 1998. Comments on working draft of California red-legged frog recovery plan.
Scott, N. 1999. Letter to Ina Pisani in response to a draft California red-legged frog recovery
plan.
Scott, N. and G. Rathbun. 1998. Essays provided to Ina Pisani in response to a working draft of
California red-legged frog recovery plan.
Serpa, L. 2000. Letter to U.S. Fish and Wildlife Service providing comments on the Draft
Smith, R. 2000. Electronic message to Douglas Krofta regarding status of California red-
legged frogs on the Santa Rosa Plateau Reserve.
Smith, R. 2001. Electronic message to Douglas Krofta regarding status of California red-
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listing of California red-legged frog as an endangered species.
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Wildlife Program.
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frogs.
117
V. Appendices
APPENDIX A. GLOSSARY OF TECHNICAL TERMS
amplexus from Latin, an embracing; the breeding position of frogs, where the
male is on the female’s back and clasping her directly behind the front
legs or directly in front of the hind legs.
anadromous describes fish that are born in fresh water, migrate to sea, and return to
fresh water to spawn (e.g., salmon, sturgeon).
Anura the Order of tailless amphibians; frogs and toads.
aquatic of or in water; streams, lakes, rivers, ponds, and marshes are aquatic
habitats.
candidate species for which the U.S. Fish and Wildlife Service believes there is
enough information on status and threats to support a proposal for
listing.
colonization the act or process of establishing a new colony or population.
contour a practice of leaving felled trees parallel to the contour line felling
of a hillside to stabilize soils and prevent erosion.
core areas watersheds, or portions thereof, that have been determined to be

essential to the recovery of the California red-legged frog.
dispersers individual frogs, usually juveniles or subadults, that move away from
the site where they hatched and metamorphosed and settle at another
site.
diurnal active during the day.
dorsal of or pertaining to the upper surface; top or back.
dorsolateral folds ridge of skin along the region between the center of the back and the
sides.
ecotone a zone where vegetation types (such as riparian and upland) adjoin
each other and often mix.
effluent an outflow, such as waste from a sewer, or water off of agricultural

fields or streets and other developed areas.
ephemeral lasting only a short time, temporary; for aquatic habitats, water present
only part of the year.
exotic not native to the area, introduced from another region or country.
extinct no longer existing. Can refer to a species in its entirety, or in a

particular part of the range.
extirpated extinct in a particular area.
habitat the environment in which a species or population lives and grows.

Different types of habitats may be used for different life stages.
habitat breaking up continuous habitat into smaller, isolated pieces.

fragmentation
intergrade having representative characteristics of two or more distinct groups,

such as hybrid frogs with characteristics of two subspecies or species.
interstitial the spaces between sand grains or gravel.
juvenile a newly metamorphosed frog; sometimes called froglets up to sexual

maturity at 2 to 3 years.
listed species recognized by Federal or State governments as endangered or

threatened.
maritime adjacent to the ocean, influenced by the ocean.
metamorph immature life stage with characteristics of both tadpoles and adult
frogs.
metamorphosis the process of changing from a larvae (tadpole) to an adult (frog).
metapopulation several to many subpopulations of frogs that are close enough to one
another that dispersing individuals could be exchanged.
microhabitat the smallest unit of a habitat, such as a clump of reeds that provides
cover for tadpoles, or the vegetation to which eggs are attached, or a
basking site for a frog.
morphological pertaining to body shape or structure.
nocturnal active during the night.
oviposition the act of egg-laying and/or the location where eggs are laid.
perennial for aquatic habitats, persisting all year; for plants, living more than 1
year.
point bar the inside portion of a bend in a stream or river where sand and gravel
accumulate.
population in the wider sense, all California red-legged frogs throughout their
range. In the narrower sense, used to refer to the frogs in one particular
locality or watershed; a collection of individuals that share a common
gene pool.
posterior toward the rear or tail.
proposed species for which a proposal to list the species as threatened or

endangered has been published in the Federal Register.
Ranidae the Family of true frogs.
recovery units regions of the species’ distribution that are distinct from one another
based on ecological characteristics, status of the species, threats to the
continued existence of the species, or recovery actions needed within
the area.
riparian terrestrial areas adjacent to aquatic habitats; on the bank of a stream,

river, pond, marsh, or lake.
sink population a population whose average reproductive rate is less than its average
rate of mortality.
snout-urostyle “nose-to-tail”, the length measured from the anterior tip of the nose to
the length posterior end of the urostyle.
source population an actively breeding population that has an average birth rate that
exceeds its average death rate, and thus produces an excess of
juveniles that may disperse to other areas.
spatial of or relating to space or distribution in space, such as how ponds and

streams are distributed in a landscape.
subpopulation a group of frogs using a particular breeding site or area; several to

many subpopulations constitute a metapopulation.
taxon a level in the classification system, such as species, genus, family, or

order.
temporal of or relating to time; can be on a daily, seasonal, annual, or longer

basis.
upland terrestrial habitats not included in riparian zones, the higher elevations.
urostyle a rodlike bone composed of fused tail vertebrae present in frogs and
toads.
viability capability or capacity to survive; for populations, the ability to survive

into the foreseeable future.
vocal sac an inflatable pouch on the throat or at the sides of the neck in male
frogs.
APPENDIX B. POTENTIAL CONTAMINANTS ASSOCIATED WITH CALIFORNIA RED-LEGGED

FROG HABITAT
The chemicals of greatest concern for which data on amphibians, fish, or their food supply
could be found are:
acephate
azinphos-methyl
carbaryl
chlorpyrifos
diazinon
dicofol
disulfoton
endosulfan
esfenvalerate
fenamiphos
glyphosate
malathion
mancozeb
methamidophos
methoprene
naled
paraquat
permethrin
phosmet
polycyclic aromatic hydrocarbons
pyrethrins
rotenone
strychnine
triclopyr
trifluralin
Units Glossary
LC50-lethal concentration to 50 percent of test organisms

mg/kg-milligrams per kilograms
mg/L-milligrams per liter
ng/L-nanongrams per liter
µg/L-micrograms per liter
PAH-Polycyclic Aromatic Hydrocarbons
Toxicity Analysis for These Chemicals
The information below, unless cited specifically, was obtained from Briggs (1992) and Moses
(1997).
Acephate is an organophosphate insecticide (classified in some sources as a carbamate) that

generally is applied as a foliar spray to control aphids. It is used on broccoli, cabbage, brussels
sprouts, cauliflower, celery, kale, leeks, lettuce, and greenhouse plants. Studies on the toxicity
of acephate to amphibians have shown effects to occur at relatively high concentrations when
compared to other organophosphates. Studies by Geen et al. (1984) determined a lethal
concentration to 50 percent of test organisms (LC50) of 8,816,000 micrograms/liter (µg/L)

during a 4 day exposure period for the northwestern salamander (Ambystoma gracile). Studies
on the green frog (Rana clamitans) reported a LC50 of 6,433 milligrams per liter (mg)/L (U.S.
Environmental Protection Agency (1995)). Most other toxicity information on amphibians
report LC50 values above 40,000 µg/L. However, accidental spills of acephate into habitat of
the California red-legged frog could expose this species or its food base to lethal doses.
Azinphos-methyl (AZM) is an organophosphate insecticide and miticide used on fruits, nuts,

vegetables, field crops, ornamentals, and forest and shade trees. The U.S. Environmental
Protection Agency (1995) classifies this pesticide as class I, indicating high toxicity. Harris et
al. (1998) reported a green frog (Rana clamitans) 16-day LC50 of >5.0 mg/L for Guthion WP, a
preparation of 50 percent AZM. Dolah et al. (1997) reported that, in South Carolina streams,
measured concentrations of AZM at greater than 17 µg/L have coincided with documented fish
kills. They reported that at a concentration of 20 µg/L, 100 percent mortality occurs within a
short time. The use of AZM in the vicinity of the California red-legged frog could affect
recruitment and survival directly, or by affecting the food supply.
Carbaryl is a wide-spectrum carbamate insecticide, acaricide, and molluscicide used on citrus,

fruit, cotton, forests, forage crops, rangelands, lawns, nuts, ornamentals, shade trees, and other
crops, as well as on poultry, livestock, and pets. Studies on the toxicity of carbaryl to bullfrogs
have shown effects to occur at relatively high concentrations (LC50 greater than 4,000 mg/kg)
(Hudson 1984). Bioaccumulation of carbaryl can occur in catfish, crawfish, and snails, as well
as in algae and duckweed. Residue levels in fish were 140-fold greater than the concentration of
carbaryl in water. In general, due to its rapid metabolism and rapid degradation, carbaryl should
not pose a significant bioaccumulation risk in alkaline waters. However, under conditions below
neutrality, bioaccumulation may be significant (Baron 1991).
Chlorpyrifos, an organophosphate pesticide, is used in the vicinity of California red-legged

frog populations and habitats on oats, greenhouse plants, broccoli, cabbage, brussels sprouts,
cucumbers, cauliflower, kale, leeks, lettuce, parsley, radish, and berries. It is primarily a contact
poison and is available as granules, wettable powder, dustable powder, and emulsifiable
concentrate. There is insufficient information on the toxicity of chlorpyrifos to amphibians to
fully evaluate the potential effects to the species. However, studies on the toxicity of
chlorpyrifos to invertebrates have shown that relatively minor applications of the pesticide can
have dramatic lethal and sublethal effects (Delpuech et al. 1998, Odenkirchen and Eisler 1988).
Direct toxic effects to the California red-legged frog or its prey base from the application of this
pesticide are possible with standard application rates and agricultural runoff.
Diazinon is a phosphorothioate used on fruits, vegetables, forage, field crops, pasture,

rangelands, turf, and ornamentals to control soil insects and nematodes. It is also used for
household insects and fly control. Harris et al. (1998) reported a diazinon 16-day LC50 for
green frogs of 0.005±0.0001 mg/L active ingredient (a.i.). Harris also reported that Basudin®
500EC, a diazinon based pesticide, had a similar 16-day LC50 of 0.0028±0.0003 mg/L a.i. It is
apparent that diazinon is extremely toxic to amphibians, and its use should be restricted in the
vicinity of the California red-legged frog.
Dicofol is an organochlorine miticide manufactured from DDT and used on a wide variety of
fruit crops, cotton, and ornamentals. In 1986, use of dicofol was temporarily canceled by the
U.S. Environmental Protection Agency because of concerns raised by high levels of DDT
contamination. However, it was reinstated when it was shown that modern manufacturing
processes could produce technical grade dicofol containing less than 0.1 percent DDT. Dicofol
is highly toxic to fish, aquatic invertebrates, and algae (Rohm and Haas Company 1991). It
could pose a significant risk to the California red-legged frog and its prey base.
Disulfoton is a phosphorothioate insecticide and acaricide used on cotton, sugar beets,

cabbage family crops, corn, wheat, ornamentals, cereal grains, and potatoes. It is a selective,
systemic pesticide that is especially effective against sucking insects. Disulfoton is considered
highly toxic to cold- and warm-water fish, crab, and shrimp. The LC50 values for the
compound are 0.038 mg/L in bluegill sunfish, 0.25 mg/L in guppies, 1.85 mg/L in rainbow
trout, and 6.5 mg/L in goldfish. According to the U.S. Environmental Protection Agency, the
use of disulfoton on certain crops may pose a risk to some aquatic and terrestrial endangered
species (U.S. Environmental Protection Agency 1984).
Endosulfan is a sulfur-containing organochlorine used for the control of aphids, thrips,

beetles, mites, borers, cutworms, bollworms, bugs, whiteflies, and leafhoppers on citrus, small
fruits, fiber crops, forage crops, forests, grains, nuts, oil crops, ornamentals, and vegetables.
Studies by Berrill et al. (1998) reported severe toxicity to amphibians from exposure to
endosulfan, including extensive paralysis to three different species of anuran tadpoles and high
post-exposure mortality. Two-week old tadpoles suffered greater than 50 percent mortality 4 to
19 days after exposure to a range of 0.041-0.364 mg/L endosulfan. At an exposure of 0.307
mg/L, American toad (Bufo americanus) tadpoles exhibited discoloration, swelling, and death
within 24 hours, or experienced delayed metamorphosis. Harris et al. (1998) reported that
green frogs exposed to Thiodan ® (a 47 percent mixture of endosulfan) had a 16-d LC50 of
greater than 5.0 mg/L. It is apparent that endosulfan is extremely toxic at low concentrations
to amphibians, and its use should be restricted in the vicinity of the California red-legged frog.
Esfenvalerate, a class of isomers of fenvalerate, a synthetic pyrethroid (see pyrethrin), is

used as a broad spectrum insecticide on fruits, nuts, artichokes, cabbage family crops, many
other vegetables, forests, Christmas tree farms, and recreational areas. Eisler (1992) reported
that at 4 degrees Celsius all northern leopard frogs exposed to a dose of 3 µg/L were dead
within 72 hours. These isomers of fenvalerate are reported to be the most toxic technical
mixtures, and their use in the vicinity of the California red-legged frog could have serious
negative effects.
Fenamiphos, a phosphorothioate, is used on a variety of plants including turf, citrus and other
fruit crops, some vegetables, and grains to control a wide variety of nematodes (roundworms).
The compound is absorbed by roots and is then translocated throughout the plant. The toxicity
of fenamiphos to aquatic species varies from moderate to high. Bluegill are extremely
sensitive to fenamiphos; the LC50 is 9.6 mg/L in this species. Other species tested include the
rainbow trout (LC50 is 0.11 mg/L) and goldfish (LC50 is 3.2 mg/L) (University of California
at Davis 1997a). Fenamiphos has been linked to fish and bird kills and is known to have a high
potential of leaching into the groundwater. The compound is not expected to bioaccumulate
appreciably in aquatic organisms (Smith 1993).
Glyphosate is used for control of annual and perennial plants including grasses, sedges,
broad-leaved weeds, and woody plants. It is used on range and pasture, as well as on over 150
crops. Glyphosate is also used for control of exotic species such as giant cane (Arundo donax),
and thus has a role in the rehabilitation of habitat for several native species, including the
California red-legged frog. Glyphosate does have the potential to contaminate surface waters
due to its use patterns and through erosion, as it adsorbs to soil particles suspended in runoff.
If glyphosate reached surface water, it would not be broken down readily by water or sunlight.
Toxicity tests performed under standard conditions at the Columbia National Fisheries
Laboratory indicated that this compound is “moderately toxic” to rainbow trout (U.S.
Environmental Protection Agency 1993). Some formulations may be more toxic to aquatic
species due to the different surfactants used in formulation. Although the herbicide glyphosate
appears to have limited effects on amphibians, other components of the most commonly used
formulations (e.g., Roundup®), particularly the surfactants, have severe negative effects on
amphibians. Formulations of glyphosate must be used carefully in and near California red-
legged frog habitat.
Malathion is a nonsystemic, wide-spectrum organophosphate insecticide used for the control

of mosquitos, sucking and chewing insects on fruits and vegetables, flies, household insects,
animal parasites (ectoparasites), and head and body lice. Malathion is used in formulations
with many other pesticides. It is highly toxic to aquatic invertebrates with EC50 values from 1
µg/L to 1 mg/L (Johnson and Finley 1980), and to the aquatic stages of amphibians (U.S.
Environmental Protection Agency 1992). Malathion has a wide range of toxicities in fish, from
very highly toxic in walleye (96-hour LC50 of 0.06 mg/L) to slightly toxic in goldfish (10.7
mg/L) (Johnson and Finley 1980). Malathion could affect California red-legged frog
populations through direct mortality and by reducing the prey base.
Mancozeb is a carbamate fungicide used on field crops, fruits, vegetables, nuts, and
commercial sod farms. Harris et al. (1998) reported that green frog embryos exposed to
Dithane DG® (76 to 80 percent mancozeb) had zero percent hatching success at approximately
1.0 to 20 mg/L. Adult frogs exhibited a 16-day LC50 of 0.20±0.04 mg(a.i.)/L. Mancozeb
appears to be quite toxic to amphibians. Its use should be restricted in the vicinity of the
Methamidophos is a highly active, systemic, residual, organophosphate insecticide and

acaricide used to control aphids, flea beetles, whiteflies, thrips, cabbage loopers, Colorado
potato beetles, potato tubeworms, armyworms, mites, leafhoppers, and many others. Crop uses
include broccoli, brussels sprouts, cauliflower, grapes, celery, sugar beets, cotton, and potatoes.
This compound is considered to be highly toxic to mammals, birds, and bees (U.S.
Environmental Protection Agency 1997a) and is also toxic to aquatic organisms. The LC50
ranges from 25 to 100 mg/l in 96-hour tests with rainbow trout, guppies, carp, and goldfish.
Freshwater, estuarine, and marine crustaceans are extremely sensitive to methamidophos.
Concentrations as low as 0.22 ng/L (nanograms/liter) (0.00000022 mg/l) were lethal to larval
crustaceans in 96-hour toxicity tests.
Methoprene is an insect growth regulator. It is considered a biochemical pesticide because,

rather than controlling target pests through direct toxicity, methoprene interferes with an
insect’s life cycle and prevents it from reaching maturity or reproducing. Methoprene is used in
the production of a number of foods including meat, milk, eggs, mushrooms, peanuts, rice, and
cereals. It is also used in aquatic areas to control mosquitos and several types of flies, moths,
beetles, and fleas. Studies on other amphibians suggest that use of this chemical may pose a
threat. Although methoprene did not cause increased mortality of gray treefrog tadpoles (Hyla
versicolor), it has been implicated in reduced survival rates and malformations in the
development of northern leopard frogs (Rana pipiens) (Ankley et al. 1998). According to the
U.S. Environmental Protection Agency (1991), methoprene is highly and acutely toxic to
estuarine invertebrates, and ecological effects studies suggest that use of the briquette or slow-
release formulation in estuarine areas may cause disruption of normal ecological processes. In
addition, the U.S. Environmental Protection Agency states in their fact sheets that methoprene
is moderately toxic to warm water, freshwater fish, and is slightly toxic to cold water,
freshwater fish. Mosquito and Vector Control Districts typically use dosages far below those
found to cause developmental problems and mortality (P. Bindings in litt. 2000).
Naled, an organophosphate pesticide, is used on greenhouse plants, broccoli, cabbage, brussels

sprouts, kale, leeks, lettuce, and radishes. It is used to control aphids, mites, mosquitos, and
flies. As an organophosphate pesticide it is assumed naled is toxic to aquatic organisms and
caution should be exercised when using it in the vicinity of California red-legged frog habitats.
Paraquat is a herbicide widely used for broadleaf weed control. It has been employed for
killing marijuana in the U.S. and in Mexico. It is also used as a crop desiccant and defoliant,
and as an aquatic herbicide. Paraquat is considered to be slightly to moderately toxic to many
species of aquatic life, including rainbow trout, bluegill, and channel catfish (U.S.
Environmental Protection Agency 1997b). Eisler (1990) reported that concentrations as low as
0.5 mg/kg had an adverse effect on northern leopard frog tadpoles. These effects included a
high number of tail abnormalities, reduced growth rate, abnormal swimming behavior, and
increased mortality. In 15-day old northern leopard frog tadpoles, 95 percent of the test
organisms were dead after 6 days when exposed to 2 mg/kg paraquat. In addition to potential
adverse effects on tadpoles, there may be an adverse effect on the California red-legged frog by
reduction of plant cover.
Permethrin, a pyrethroid pesticide, is used on berries, broccoli, cabbage, brussels sprouts,

greenhouse plants, kale, leeks, lettuce, and radishes. It is also used to control animal
ectoparasites, biting flies, and cockroaches. It is available in dusts, emulsifiable concentrates,
smokes, ultra-low volume sprays, and wettable powder formulations. There is insufficient
information on toxicity of permethrin to amphibians. Toxicity studies on invertebrates have
shown that permethrin contaminated sediments are toxic to chironomid larvae (Fleming et al.
1998). Studies conducted on adult desert pupfish (Cyprinodon macularius) have shown a 48-
hour LC50 of 0.005 mg/L of permethrin (Mulla et al. 1978). Standard applications of
permethrin and agricultural runoff may cause direct acute effects to the California red-legged
frog or its prey base.
Phosmet is a non-systemic, organophosphate insecticide used on both plants and animals. It is

mainly used on apple trees for control of codling moths; it is also used on a wide range of fruit
crops, ornamentals, and vines for the control of aphids, mites, and fruit flies. The reported 96-
hour LC50 values for phosmet are less than 1 mg/L in bluegill, small- and largemouth bass,
rainbow trout, and chinook salmon, and are less than 10 mg/L in fathead minnow and channel
catfish (Johnson and Finley 1980). The compound is also very highly toxic to aquatic
invertebrates (Johnson and Finley 1980). Phosmet has little potential for accumulation in
aquatic organisms. Phosmet could have direct toxic effects on the California red-legged frog
and indirect effects through reduction of the prey base.
Polycyclic Aromatic Hydrocarbons, or PAHs, are among the most potent carcinogens known
to exist. However, amphibians are considered to be quite resistant to PAH carcinogens when
compared to mammals. PAHs are widely distributed in the environment and have been detected
in plant and animal tissues, sediments, soils, air, surface water, and groundwater (Eisler 1987).
PAHs may enter the aquatic environment through industrial and domestic discharge, surface
runoff, and releases of petroleum products into water bodies. PAHs can cause a wide variety of
adverse biological effects, including effects on survival, growth, metabolism, and tumor
formation (Eisler 1987). Eisler (1987) reports that 85 percent of adult African clawed frogs
exposed to 1.5 mg benzo(a)pyrene, a PAH, developed lymphosarcomas (cancer of connective
tissues associated with the lymphatic system) in 85 to 288 days. When leopard frogs were
exposed to a single dose of 3-methylcholanthrene, another PAH, at 40 mg/kg body weight,
cellular function and blood and tissue oxygen levels were abnormal for several weeks. Hatch
and Burton (1998) suggested that low levels of PAHs may act with other environmental factors
to cause adverse effects to larval amphibians.
Pyrethrins are natural insecticides produced by certain species of chrysanthemums; synthetic

pyrethrins also are manufactured. The compounds may be used in grain storage and in poultry
pens, and on dogs and cats to control lice and fleas. Both natural and synthetic compounds are
extremely toxic to aquatic life, such as bluegill and lake trout, and slightly toxic to bird
species, such as mallards. Toxicity increases with higher water temperatures and acidity.
Natural pyrethrins are highly fat soluble, but are easily degraded and thus do not accumulate
in the body. Although no information regarding the toxicity of natural pyrethrins to
amphibians was found, effects may be similar (see esfenvalerate).
Rotenone is the dried and ground root of various plants, or extracts thereof. It is used for fish
eradications as part of water body management, in home gardens for insect control, and for
lice and tick control on pets. Rotenone interferes with normal cell functions and nerve
transmission and is highly toxic to fish and amphibians. Reported 96-hour LC50s were 0.031
mg/L in rainbow trout, 0.0026 mg/L in channel catfish, and 0.023 mg/L in bluegill for the 44
percent pure formulation (Johnson and Finley 1980). Aquatic invertebrates have a wide range
of sensitivity to rotenone with 48-hour EC50 values ranging from 0.002 to 100 mg/L (Johnson
and Finley 1980). The compound is not expected to accumulate appreciably in aquatic
organisms as its highly toxic nature allows little survival of the organisms in which it would
accumulate. Contamination of breeding ponds with rotenone could cause the loss of an entire
year’s production of California red-legged frog larvae.
Strychnine is currently registered for use only below-ground as a bait application to control
pocket gophers, but was used in the U.S. to control vertebrate animals for many years before
1947. Strychnine ranges from moderately to highly toxic to freshwater fish and is moderately
toxic to aquatic invertebrates (Environmental Protection Agency 1998). The U.S.
Environmental Protection Agency believes that the risks to non-target terrestrial animals are
minimal when strychnine is used below-ground and that below-ground use of strychnine does
not constitute a risk to non-target or endangered species. However, this does not take into
account any burrowing species or those that may use small mammal burrows as temporary
refuges.
Triclopyr, a pyridine, is a selective systemic herbicide used for control of woody and
broadleaf plants along rights-of-way, in forests, on industrial lands, and on grasslands and
parklands. Studies on the toxicity of triclopyr to aquatic organisms have shown that the parent
compound of this pesticide is practically nontoxic to fish, with a LC50 (96-hour) of 117 mg/L
in rainbow trout and 148 mg/L in bluegill sunfish (University of California at Davis 1997b).
The compound has little if any potential to accumulate in aquatic organisms. In addition to the
potential direct effects of the ester formulation of this herbicide on amphibians, there may be
an adverse effect on the California red-legged frog by reduction of plant cover.
Trifluralin is a selective, pre-emergence dinitroaniline herbicide used to control many annual

grasses and broadleaf weeds in lawns and in a large variety of fruit, nut, vegetable, and grain
crops, including soybeans, sunflowers, cotton, and alfalfa. Trifluralin is highly toxic to fish,
amphibians, and other aquatic organisms. The 96-hour LC50 is 0.02 to 0.07 mg/L in rainbow
trout and bluegill (Johnson et al. 1980). Variables such as temperature, pH, life stage, and size
may affect the toxicity of the compound. Trifluralin is highly toxic to Daphnia, with a 48-hour
LC50 of 0.5 to 0.6 mg/L. The compound shows a moderate tendency to accumulate in aquatic
organisms (U.S. Environmental Protection Agency 1996).
Other contaminants
Ammonia: Harris et al. (1998) reported that elevated levels of ammonia could act as an
environmental stressor to amphibians and could lead to decreased hatching success, survival,
or growth rates.
CONTAMINANTS GLOSSARY
acaricide compound used to kill ticks and mites.
acute toxicity the ability to cause a poisonous effect or death as a result of a short-
term or single exposure. Common acute effects are skin or eye
irritation, vomiting, tremors.
bioaccumulate increase in concentration in living organisms as they breathe

contaminated air, drink contaminated water, or eat contaminated food.
carbamate organic compounds based on carbamic acid (CO2NH3); cholinesterase

inhibitors, they interfere with nerve function, cause malformations in
developing embryos, and are suspected carcinogens.
carcinogen cancer-causing agent.
cholinesterase a neurotransmitter; cholinesterase inhibitors interfere with the

transmission of nerve impulses. Symptoms of cholinesterase inhibition
include nausea, vomiting, cramps, increased heart rate, and death.
chronic toxicity the ability to cause a poisonous effect or death as a result of long-term
exposure. Liver or kidney damage, impaired reproduction, and cancers
are common chronic effects.
dinitroaniline herbicides; in animals, they interfere with cell function, cause skin and
eye irritation, and are carcinogenic and teratogenic.
fungicide compound used to kill fungi.
herbicide compound used to kill plants.
insecticide compound used to kill insects.
miticide compound used to kill mites.
molluscicide a compound used to kill molluscs (snails, slugs, clams, etc.).
organochlorine chlorinated hydrocarbons; compounds that contain, carbon, hydrogen,

and chlorine, such as DDT; interfere with transmission of nerve
impulses primarily in the central nervous system (brain and spinal
cord); bioaccumulate, carcinogens, suspected teratogens and
mutagens; can travel long distances through air and groundwater.
organophosphate compounds that contain, carbon, hydrogen, and phosphorus;

cholinesterase inhibitors, they interfere with nerve function, cause
malformations in developing embryos, and are suspected carcinogens.
pesticide a general term for compounds used to kill organisms considered pests,
including slugs, nematodes, insects, mites, rodents, birds, and plants.
phosphorothioate a class of organophosphates that also contain sulfur.

pyrethroids natural compounds derived from chrysanthemums, or synthetic

compounds that mimic their structure and function. Pyrethroids block
nerve impulse transmission, affect hormone metabolism, and affect the
immune system. They are suspected carcinogens, mutagens, and
teratogens.
pyridine herbicide; limited information available.
systemic absorbed by the leaves or roots and then translocated throughout the
plant. Systemic pesticides are particularly effective against sucking
insects and mites.
teratogen a substance that causes malformations in developing embryos.

LITERATURE CITED FOR APPENDIX B
Ankley, G.T., J.E. Tietge, D.L. DeFoe, K.M. Jensen, G.W. Holcombe, E.J. Durhan, S. A.
Diamond, and P.K. Schoff. 1998. Effects of methoprene and UV light on survival and
development of Rana pipiens. http:// www.mpm.edu/collect/vertzo/herp/Daptf/
Mwabst.html
Baron, R. L. 1991. Carbamate insecticides. Pp. 3-6. In Handbook of pesticide toxicology.

Hayes, W. J., Jr. and E. R., Laws, Jr., (eds). Academic Press, New York, NY.
Berrill, M., D. Coulson, L. McGillivray, and B. Pauli. 1998. Toxicity of endosulfan to aquatic
stages of anuran amphibians. Environmental Toxicology and Chemistry 17:1738-1744.
Bindings, P. 2000. Letter from Santa Cruz Mosquito and Vector Control District to U.S. Fish
and Wildlife Service.
Briggs, S. 1992. Basic guide to pesticides: their characteristics and hazards. The Rachel Carson
Council, Taylor and Francis, Washington, D.C. 283 pp.
Delpuech, J. M., B. Froment, P. Fouillet, F. Pompanon, S. Janillon, and M. Bouletreau. 1998.

Inhibition of sex pheromone communications of Trichogramma brassicae (Hymenoptera)
by the insecticide chlorpyrifos. Environmental Toxicology and Chemistry 17:1107-1113.
Dolah, R. F. Van, P. P. Maier, M. H. Fulton, and G. I. Scott. 1997. Comparison of

azinphosmethyl toxicity to juvenile red drum (Sciaenops ocellatus) and the mummichog
(Fundulus heteroclitus). Environmental Toxicology and Chemistry 16:1488-1493.
Eisler, R. 1987. Polycyclic aromatic hydrocarbon hazards to fish, wildlife, and invertebrates: A
synoptic review. Contaminant Hazard Reviews Report No. 11. Patuxent Wildlife Research
Center, U.S. Fish and Wildlife Service. 81 pp.
_____. 1990. Paraquat hazards to fish, wildlife, and invertebrates: A synoptic review.
Contaminant Hazard Reviews Report No. 22. Patuxent Wildlife Research Center, U.S.
Fish and Wildlife Service. 28 pp.
_____. 1992. Fenvalerate hazards to fish, wildlife, and invertebrates: a synoptic review.
Contaminant Hazard Reviews Report No. 24. Patuxent Wildlife Research Center, U.S.
Fish and Wildlife Service. 43pp.
Fleming, R. J., D. Holmes, and S. J. Nixon. 1998. Toxicity of permethrin to Chironomus

riparius in artificial and natural sediments. Environmental Toxicology and Chemistry
17:1332-1337.
Geen, G. H., B. A. McKeown, T. A. Watson, and D. B. Parker. 1984. Effects of acephate

(Orthene) on development and survival of the salamander, Ambystoma gracile (Baird).
Journal of Environmental Science and Health B19(2):157-170.
Harris, M. L., C. S. Bishop, J. Struger, B. Ripley, and J. P. Bogart. 1998. The functional
integrity of northern leopard frog (Rana pipiens) and green frog (Rana clamitans)
populations in orchard wetlands. II. Effects of pesticides and eutrophic conditions on early
life stage development. Environmental Toxicology and Chemistry 17(7): 1351-1363.
Hatch, A. C. and G. A. Burton, Jr. 1998. Effects of photoinduced toxicity of fluoranthene an

amphibian embryos and larvae. Environmental Toxicology and Chemistry 17: 1777-1785.
Hudson, R. H. 1984. Handbook of toxicity of pesticides to wildlife. U.S. Fish and Wildlife
Service Resource Publication Number 153.
Johnson, W.W. and M.T. Finley. 1980. Handbook of acute toxicity of chemicals to fish and
aquatic invertebrates. Resource Publication 137. U.S. Department of Interior, Fish and
Wildlife Service, Washington, DC.
Moses, L., editor. 1997. Farm chemicals handbook ‘97. Meister Publishing Company,
Willoughby, Ohio. 943 pp.
Mulla, M.S., H.A. Navvab-Gojrati, and J.A. Darwazeh. 1978. Toxicity of mosquito larvicidal
pyrethroids to four species of freshwater fishes. Environmental Entomology 7:428-430.
Odenkirchen, E.W. and R. Eisler. 1988. Chlorpyrifos hazards to fish, wildlife, and
invertebrates: A synoptic review. Contaminant Hazard Reviews Report No. 13. Patuxent
Wildlife Research Center, U.S. Fish and Wildlife Service. 34 pp.
Rohm and Haas Company. 1991. Material safety data sheet for Kelthane Technical B Miticide.
Philadelphia, PA.
Smith, G. J. 1993. Toxicology and pesticide use in relation to wildlife: Organophosphorus and
carbamate compounds. C. K. Smoley, Boca Raton, FL.
U.S. Environmental Protection Agency, Office of Pesticides and Toxic Substances. 1984.
Pesticide fact sheet number 43: Disulfoton. Washington, D.C.
_____. 1991. Pesticide reregistration fact sheets: Methoprene. Washington D.C.
_____. 1992. Pesticide reregistration fact sheets: Malathion. Washington D.C.
_____. 1993. Pesticide reregistration fact sheets: Glyphosate. Washington D.C.
_____. 1995. Environmental effects database. Washington, D.C.
_____. 1996. Pesticide reregistration fact sheets: Trifluralin. Washington D.C.
_____. 1997a. Pesticide reregistration fact sheets: Methamidophos. Washington D.C.
_____. 1997b. Pesticide reregistration fact sheets: Paraquat. Washington D.C.
_____. 1998. Pesticide reregistration fact sheets: Strychnine. Washington D.C.
University of California, Davis. 1997a. Pesticide Use Profiles: Fenamiphos. Davis, California.
_____. 1997b. Pesticide Use Profiles: Trifluralin. Davis, California.

Appendix C. Maps of Core Areas Per County
APPENDIX C. MAPS OF CORE AREAS PER COUNTY
The following core are maps were developed using the California Watershed Map (Calwater
Version 2.2). This is a set of standardized watershed boundaries meeting standardized
delineation critera. The hierachy of watershed designations consists of six levels of increasing
specificity: Hydrologic Region, Hydrologic Unit, Hydrologic Area, Hydrologic Sub-Area,
Super Planning Watershed, and Planning Watershed. Core area maps were delineated at the
Hydrologic Sub-Area level. Following each core area map is a list of Hydrologic Sub-Areas
that are included in each map per core area.
Figure 13. Map of core areas in Butte, Plumas, and Yuba Counties ..................................... 131
Figure 14. Map of core areas in Calaveras County .............................................................. .132
Figure 15. Map of core areas in Sacramento, El Dorado, and Amador Counties ................. 133
Figure 16. Map of core areas in Tuolumne and Mariposa Counties ..................................... 134
Figure 17. Map of core areas in Shasta and Tehama Counties .............................................. 135
Figure 18. Map of core areas in Lake and Colusa Counties .................................................. 136
Figure 19. Map of core areas in Napa, Solano, and Yolo Counties ....................................... 137
Figure 20. Map of core areas in Marin and Sonoma Counties .............................................. 138
Figure 21. Map of core areas in Alameda, San Joaquin and Contra Costa Counties ............ 139
Figure 22. Map of core areas in Santa Clara and Stanislaus Counties .................................. 140
Figure 23. Map of core areas in San Mateo County .............................................................. 141
Figure 24. Map of core areas in Santa Cruz County ............................................................. 142
Figure 25. Map of core areas in Monterey, San Benito, and Fresno Counties ...................... 143
Figure 26. Map of core areas in San Luis Obispo and Kern Counties .................................. 144
Figure 27. Map of core areas in Merced County ................................................................... 145
Figure 28. Map of core areas in Santa Barbara County ........................................................ 146
Figure 29. Map of core areas in Los Angeles, Ventura, and Orange Counties ...................... 147
Figure 30. Map of core areas in San Bernardino County ...................................................... 149
Figure 31. Map of core areas in San Diego and Riverside Counties ..................................... 150
Figure 13. Map of

core areas in Butte,
Plumas, and Yuba
Counties.
Butte County
Core Area:
Feather River
Hydrologic Sub-Area:
Bucks Lake
Reservoir Drain
Core Area:
Yuba River–S. Fork
Feather River
Bullards Bar
Lumpkin
Plumas County
Core Area:
Feather River
Bucks Lake
Butt Valley
Reservoir Drain
Core Area:
Feather River
Lumpkin
Yuba County
Core Area:
Feather River
Bullards Bar
Lumpkin
Figure 14. Map of

core areas in
Calaveras County
Calaveras County
Core Area:
South Fork Calaveras
River
HSA:
South Fork Calaveras
Figure 15. Map of

core areas in
Sacramento, El
Dorado, and
Amador Counties
Sacramento
County
Core Area:
Cosumnes River
Big Canyon Creek
Upper Deer Creek
El Dorado County
Core Area:
Cosumnes River
Big Canyon Creek
North Fork Cosumnes
Omo Ranch
Upper Deer Creek
Weber Creek
Core Area:
Traverse Crek
HSA:
Coloma
Amador County
Core Area:
Cosumnes River
Big Canyon Creek
North Fork Cosumnes
Omo Ranch
Figure 16. Map of

core areas in
Tuolumne and
Mariposa Counties
Tuolumne County
Core Area:
Piney Creek
HSA:
Coulterville
Core Area:
Tuolumne River
Cherry Lake
Clavey River
Hetch Hetchy
Lake Eleanor
Mercut Peak
North Fork Merced
Mariposa County
Core Area:
Piney Creek
HSA:
Coulterville
Core Area:
Tuolumne River
Clavey River
North Fork MErced
Figure 17. Map of

core areas in Shasta
and Tehama
Counties
Shasta County
Core Area:
Cottonwood Creek
HSA:
Lower Cottonwood
Tehama County
Core Area:
Cottonwood Creek
Elder Creek
Lower Cottonwood
Red Bank Creek
South Fork
Wells Creek
Figure 18. Map of I'll ' >

(1)-
core areas in Lake ::::I I:
and Colusa Counties -::::I
Lake County
Core Area:
Putah Creek–Cache
88 I -
"'
~8
>
-
s:::
0.::::1
Creek -'
HSAs
Lakeport
Lower Lake
Pope Creek
Upper Putah Creek
Wilson Valley
Colusa County
Core Area:
Putah Creek–Cache
Creek
East Blue Ridge
Rumsey
Wilson Valley
~
.
~
III
"I!:
::l ~
/ ~ I!!
2;-
t:
.c
~
\. !!! ~
'"C
c
0
u "'"
if u I
~
ell
••
(
Cl
ell
..I 11 • I
•• '"
•I ••
.•• 1-- •••
0
81
:;
I ~ .f) -..."'-
Figure 19. Map of

core areas in Napa,
Solano, and Yolo
Counties
Napa County
Core Area:
Jameson Canyon–
Lower Napa River
Benicia
Napa River
Core Area:
Lake Berryessa
Tributaries
Capell Creek
East Rocky Ridge
Core Area:
Putah Creek–Cache
Creek
East Blue Ridge
Eticuera Creek
Pope Creek
Rumsey
Upper Puah Creek
Wilson Valley
Solano County
Core Area:
Jameson Canyon–
Lower Napa River
Benicia
Napa River
Core Area:
Lake Berryessa
Tributaries
Capell Creek
East Rocky Ridge
Yolo County
Core Area:
Lake Berryessa
Tributaries
HSA:
East Rocky Ridge
Core Area:
Putah Creek–Cache
Creek
East Blue Ridge
Eticuera Creek
Rumsey
Upper Putah Crek
Wilson Valley
Figure 20. Map of

core areas in Marin
and Sonoma
Counties
Marin County
Core Area:
Belvedere Lagoon
HSA:
San Rafael
Core Area:
Petaluma Creek–
Sonoma Creek
HSA:
Petaluma River
Core Area:
Pt. Reyes Peninsula
Bolinas
Inverness
Lagunitas Creek
Point Reyes
Walker Creek
Sonoma County
Core Area:
Petaluma Creek–
Sonoma Creek
Petaluma River
Sonoma Creek
Core Area:
Pt. Reyes Peninsula
HSA:
Walker Creek
Core Area:
Putah Creek–Cache
Creek
Lakeport
Upper Putah Creek
Core Area:
Upper Sonoma Creek
HSA:
Sonoma Creek
Figure 21. Map of

core areas in
Alameda, San
Joaquin and Contra
Costa Counties
Alameda County
Core Area:
East San Francisco
Bay
Alameda Creek
East Bay Cities
North Diablo Range
Contra Costa
County
Core Area:
East San Francisco
Bay
Alameda Creek
East Bay Cities
North Diablo Range
Pittsburg
Walnut Creek
Figure 22. Map of

core areas in Santa
Clara and Stanislaus
Counties
Santa Clara County

Core Area:
East San Francisco Bay
Alameda Creek
Coyote Creek
Orestimba Creek
Pacheco-Santa Ana
Creek
Romero Creek
Core Area:
Salinas River–Pajaro
River
Aptos–Soquel
Santa Cruz Mountains
Core Area:
Santa Clara Valley
South Santa Clara
Valley
Core Area:
South San Francisco
Bay
Palo Alto
Pescadero Creek
Stanislaus County
Core Area:
Alameda Creek
Coyote Creek
Orestimba Creek
Pacheco–Santa Ana
Creek
Romero Creek
Figure 23. Map of

core areas in San
Mateo County
San Mateo County

Core Area:
South San Francisco
Bay
Ano Nuevo
Davenport
Half Moon Bay
Pacfica
Palo Alto
Pescadero Creek
San Gregorio Creek
San Mateo Bayside
Tunitas Crek
Figure 24. Map of

core areas in Santa
Cruz County
Santa Cruz County

Core Area:
Watsonville Slough–
Elkhorn Slough
Aptos–Soquel
Watsonville
Core Area:
South San Francisco
Bay
Ano Nuevo
Davenport
Pescadero Creek
Monterey County
Core Area:
Carmel River–Santa
Lucia
Carmel River
Santa Lucia
Core Area:
Estrella River
HSA: Estrella River
Core Area:
Gabilan Range
Gabilan Range
Core Area:
Watsonville Slough–
Elkhorn Slough
Bolsa Neuva
Chualar
Moro Cojo
Neponset
Watsonville
San Benito County

Core Area:
Pacheco–Santa Ana
Creek
Panoche
San Benito River
Core Area:
Gabilan Range
Gabilan Range
Core Area:
Salinas River–Pajaro
River
Bolsa Neuva
Watsonville
Core Area:
Santa Clara Valley
S. Santa Clara Valley
Fresno County
Core Area:
Panoche
Core Area:
Figure 25. Map of core areas in Monterey, San Benito, Estrella River
and Fresno Counties HSA: Estrella River
Figure 26. Map of

core areas in San
Luis Obispo and
Kern Counties
San Luis Obispo

County
Core Area:
Arroyo Grande Creek
HSA:
Oceano
Core Area:
Estero Bay
Arroyo De La Cruz
Cayucos
Chorro
Los Osos
Morro
Old
San Luis Obispo Creek
San Simeon
Santa Rosa
Toro
Villa
Core Area:
Estrella River
Estrella River
Temblor
Core Area:
Santa Maria River–
Santa Ynez River
HSA:
Guadalupe
Core Area:
Sisquoc River
HSA:
Sisquoc
Kern County
Core Area:
Estrella River
Estrella River
Temblor
Figure 27. Map of

core areas in Merced
County
Merced County
Core Area:
East San Francisco
Bay
Pacheco–Santa Ana
Creek
Romero Creek
San Benito River
San Luis Reservoir
Legend
Imi ~-
'" • • o
-
.... ""'"' .~-.-".
"i· ... 1
Figure 28. Map of
,
core areas in Santa

()~\-, ~
Barbara County
Santa Barbara
County
Core Area:
, ?
Santa Maria River–

Santa Ynez River
Arguello
Buellton
Guadalupe
Lake Cachuma
Lompoc
Los Olivos
San Antonio
~
Santa Cruz Creek

Santa Rita
Core Area:
10
Sisquoc River
HSA:
Sisquoc
Core Area:
Ventura River–Santa
Miles
Clara River
o
Topa Topa
Upper Ventura River
5
10
Coun~Boundariee
~ Gore A""'6
HIgt1way
Riv8f'&
Legend
- ••
-
Figure 29 . Map of
core areas in Los
Angeles, Ventura,
and Orange Counties
(see next page for Core

Areas and HSAs)
Los Angeles Lindero Canon Ventura County Lindero Canyon Orange County
County Little Sycamore Canyon Core Area: Little Sycamore Canyon Core Area:
Los Alisos Canyon Santa Maria River– Russell Valley Santa Ana Mountain
Core Area: Monte Nido Sherwood
San Gabriel Mountain Santa Ynez River HSA:
Nicholas Canyon HSA: Core Area: Santiago
Hydrologic Sub-Area: Pena Canyon
Santa Anita Santa Cruz Creek Ventura River–Santa Core Area:
Piedra Gorda Canyon Clara River
Tujunga Ramera Canyon Core Area: Santa Rosa Plateau
Upper Canyon Santa Monica Bay– Hydrologic Sub-Area: HSA:
Russell Valley Lower Ventura River
Core Area: Sherwood Ventura Coastal Upper San Juan
Hydrologic Sub-Area: Ojai Valley
Santa Monica Boy– Solstice Canyon Sisar Topa Topa
Ventura Coastal Topanga Canyon Arroyo Senuit
Big Sycamore Canyon Upper Ojai
Hydrologic Sub-Area: Trancas Canyon Upper Piru
Arroyo Senuit Triunfo Canyon Deer Canyon
La Jolla Valley Upper Ventura River
Carbon Canyon Tuna Canyon
CorralCanyon Zuma Canyon La Virgenes Canyon
Encinal Canyon Core Area:
Escondido Canyon Ventura River–Santa
La Virgenes Canyon Clara River
Las Flores Canyon HSA:
Latigo Canyon Upper Piru
H~ri. ) r~-

\
1,. ~Fo<'.
./ the Mojave
01 "-
"
1
~.-:
d
I)
I
Legend
/' S·n,
San Bernardino
County
~.
~
• • • counry 6olJnl1anQs.
.....
-----
~
--~ Rive,s
·I m Care Aress ~~--------

4 2 0 4 • ...
Mil YU_:'-Hpa
......,.. ...
,.".
> I
•
I
Upper Mojave
HSA:
Forks of the Mojave
Core Area:
County
San Bernardino
Bernardino County
core areas in San
Figure 30. Map of
149
Figure 31. Map of

core areas in San
Diego and Riverside
Counties
San Diego County

Core Area:
Laguna Mountain
Cottonwood
Pine
Core Area:
San Luis Rey
Guejito
Pala
Pauma
Core Area:
Santa Rosa Plateau
Deluz Creek
Gavilan
San Mateo Canyon
Core Area:
Sweetwater
Jamacha
Loveland
Riverside County
Core Area:
San Luis Rey
HSA:
Pala
Core Area:
Santa Ana Mountain
HSA:
Santiago
Core Area:
Santa rosa Plateau
Deluz Creek
Gavilan
Murrieta
San Mateo Canyon
Upper San Juan
APPENDIX D. GUIDELINES FOR VOLUNTARY POND MANAGEMENT

FOR THE BENEFIT OF THE CALIFORNIA RED-LEGGED FROG
In many California red-legged frog metapopulations, artificial ponds maintained for watering
livestock are the principal sources of the young frogs that annually repopulate the system. In
dry areas, a pond can represent a longer-lasting water source, providing for complete tadpole
development and adult escape cover. At wetter sites, ponds are often the only quiet water
refuges for egg-laying and tadpole development outside of the swiftly flowing streams. In both
cases, ponds can give a stability and predictability to the habitats that would not otherwise be
present.
However, in some cases, ponds can be extremely detrimental to the California red-legged frog.
Perhaps the most common nuisance pond is one that attracts and provides habitat for bullfrogs
and predatory fish. In many instances, these predators eliminate the California red-legged frog.
Another type of detrimental pond is one that fills and is attractive breeding habitat in late
winter and early spring, but dries up before tadpoles can undergo metamorphosis. These ponds
can trap many California red-legged frog egg masses and larvae and eliminate reproductive
output.
California red-legged frogs have evolved in California’s Mediterranean climate with wet
winters and springs and dry summers and falls, but most of their introduced predators have not.
In most cases, pond management that mimics the natural water cycle will be most beneficial
Red-legged Frog Biology
Ponds that successfully enhance California red-legged frog populations must complement their
biology. The frogs breed from December to April in ponds and streams. They seem to choose
the sites that have the warmest water available, as long as it is at least 20 centimeters (8 inches)
deep. Tadpoles hatch in a few days, depending on temperature, and develop through the spring.
They start to transform into froglets in June or July, and by late August most have completed
the process.
Outside of the breeding season, adult frogs seek out water greater than 1 meter (3 feet) deep for
escape from predators. In some areas, late summer water can be very scarce, and frogs will
travel to congregate in old dug wells, in deep holes in drying streams, or in and around springs.
With the first soaking rains of fall, frogs tend to move away from their summer refuges.
During a rainy winter, they may establish a temporary residence quite a distance from any
body of water. At this time they often gradually move towards the late winter breeding site.
Choosing a Site
At the present time, stock ponds are useful for rehabilitation and enhancement of California
red-legged frog populations only if the frogs can get to them. We must approve the transport
and reestablishment of the California red-legged frog into areas where they do not now occur.
Reestablishment is only considered after intensive studies of both the donor and recipient sites,
with guarantees that the donor population will not be damaged. Given this, ponds for the
benefit of California red-legged frogs should be limited to areas that already contain at least a
remnant population. In such areas, if the ponds are suitable, the frogs will find them on their
own and will not need to be moved.
Ponds should be located as far as possible from predator source-areas. Bullfrogs from a pond
with a large population will quickly invade a new pond up to a few hundred meters (about
1,000 feet) away, but it should take them longer to build up to damaging population levels if
the ponds are separated by a kilometer (0.6 mile) or more. Raccoons are also a serious
California red-legged frog predator in many places. They build up to many times the normal
population density in urban areas and campgrounds with a plentiful supply of garbage, and dog
and cat food.
Pond Design
Suggestions for pond design are based on observations of frogs in many habitats, but they have
not been experimentally tested for efficacy. Further research will surely modify or eliminate
some of these suggestions. The final design depends on a number of considerations such as the
terrain, the use of the pond, and the adequacy and timing of the water supply. From a
biological point of view, pond design is most tightly restricted when bullfrogs are present in
the area.
The ideal pond probably has two main components: a deep-water escape portion and a shallow
tadpole- and juvenile-rearing section. The former should have areas that are deeper than 1
meter (3 feet). It may not matter if this part is clogged with aquatic vegetation. Mats of floating
submerged vegetation in deep water seem to be ideal for the adult frog in the non-breeding
season. Predators such as raccoons and herons, and even large bullfrogs, probably find it
difficult to reach California red-legged frogs on floating mats.
The tadpole-rearing portion should be unshaded and shallow enough to warm quickly in the
winter sun. Submerged aquatic vegetation seems to be tolerated, but emergents such as willows
(Salix), cattails (Typha), or bulrushes (Scirpus) shade the water and keep it cool. The pond
must contain water for tadpole development during the entire rearing season (minimally March
through July in most areas), but it can be allowed to dry at other times of the year.
If the main pond dries regularly, adult frogs will use a restricted summer refuge. In places with
a high water table, these can be dug wells if they have deep, perennial water and protecting
vegetation and are designed so frogs can get out (i.e., not too deep and steep sided). Springs
can also be easily modified as summer refuges.
Discouraging Predators
Perhaps the most important factor in discouraging aquatic vertebrate predators of the
California red-legged frog is the installation of a pond drain. If the pond can be regularly and
completely drained, even once every 3 or 4 years, bullfrog and fish populations will be greatly
reduced or eliminated. Bullfrog eggs are laid in the early summer (April through July), and the
majority of tadpoles do not transform until the following year. If the pond is completely
drained in the fall or winter, bullfrog (and fish) life cycles will be broken.
Bullfrog tadpoles and adults are usually associated with deep water, and extensive shallow,
marshy areas may favor the California red-legged frog. Also, small isolated ponds a few meters
(several yards) across, such as dug out spring heads, may harbor the California red-legged
frog, but may not be attractive to bullfrogs.
Chemical means of bullfrog tadpole and fish control are possible (e.g., use of rotenone), but
their use requires the permission of the California Department of Fish and Game and the U.S.
Fish and Wildlife Service to ensure that the California red-legged frog and other native wildlife
will not be harmed.
The Role of Grazing
Pond management usually needs to be integrated with the local livestock grazing program.
Grazing can be an important tool to help keep the shallower, tadpole-rearing portions of the
pond free of emergent vegetation that shades the water. The shallows should be deep enough
so that livestock do not churn them into a mucky mire, but shallow enough so that the animals
can graze comfortably. Ponds with fluctuating levels where the shallow portions dry each year,
facilitate this type of grazing management.
Many ponds used by cattle gradually become shallow mud holes as cattle trample the banks.
To prevent this, the deepest portion of the pond should be fenced so that cattle cannot enter.
This can be done so that the primary function of the pond, which is to provide livestock water,
is not compromised, but deep escape water is preserved for frogs.
The critical periods for livestock water on many California ranges is late summer and early
fall. Draining of ponds for bullfrog and fish control can usually be postponed until after the
first fall rains, when livestock water is less critical. Alternatively, a temporary catch basin
below the drained pond could provide livestock water. Water in the catch basin could be
maintained until the main pond refills, then the catch basin could be drained. A catch basin
should also be used if there is danger of releasing unwanted predators into a downstream body
of water.
APPENDIX E. PRIVATE LANDOWNER INCENTIVES FOR IMPLEMENTATION

OF CONSERVATION MEASURES
A. NATIONAL RESOURCE CONSERVATION SERVICE PROGRAMS
The 1996 Farm Bill authorized $2.2 billion nationally in funding for conservation programs,
extended the Conservation Reserve Program and Wetland Reserve Program, and created new
initiatives to improve natural resources on America’s private lands. To qualify for market
transition payments under basic commodity programs which replace traditional farm subsidies,
farm operators must agree to abide by Conservation Compliance and Wetlands Conservation
(Swampbuster) provisions in the 1996 Farm Bill. As of October 2001, some of these programs
have ceased to be funded but due to the overwhelming support for Farm Bill programs, future
reauthorization and funding is expected.
1. Conservation Reserve Program
The Conservation Reserve Program encourages farmers to convert highly erodible cropland
or other environmentally sensitive acreage to vegetative cover, such as non-native and
native grasses, wildlife plantings, trees, filter strips, or riparian buffers. Farmers receive an
annual rental payment for the term of the multi-year contract. Cost sharing is provided to
establish the vegetative cover practices. This program allows up to 34.4 million acres,
nationally, to be enrolled at any one time. New enrollments can replace expired or
terminated contracts.
2. Wetland Reserve Program
The Wetland Reserve Program is a voluntary easement program that offers financial
incentives to help landowners restore and protect wetlands. The program targets farmed
wetlands and farmland that once was wetland. A priority is given to areas offering the most
wetland benefits (lands adjacent to restorable wetlands that contribute significantly to
wetland functions and values, previously restored wetlands that need long-term protections,
upland areas needed to provide an adequate ecological buffer or otherwise contribute to
defining a management boundary, existing or restorable riparian habitat corridors that
connect protected wetlands and lands substantially altered by flooding where there is a
likelihood of successful wetland restoration at a reasonable cost). The program offers three
options to protect, restore, and enhance wetlands and associated uplands: permanent
easements, 30-year easements, or 10-year restoration cost share agreements.
3. Wetland Conservation (Swampbuster)
The Wetland Conservation provision allows landowners to comply with wetland

conservation requirements while protecting natural resources under the 1996 Farm Bill. It
provides more options for mitigation by including restoration, enhancement, or creation as
long as wetland functions and values are maintained. The program stipulates that wetland
conservation activities, authorized by permits issued under section 404 of the Clean Water
Act, which make agriculture production possible, will be accepted for Farm Bill purposes if
they were adequately mitigated. It requires wetland determinations to be certified by the
National Resource Conservation Service. It also establishes a pilot program for wetland
mitigation to allow the U.S. Department of Agriculture to assess how well mitigation
banking works for agriculture.
4. Environmental Quality Incentives Program (EQIP)
The Environmental Quality Incentives Program was established in the 1996 Farm Bill to
provide a single, voluntary conservation program for farmers and ranchers to address
significant natural resource needs and objectives. Nationally, this program provides
technical, financial, and educational assistance, half of it targeted to livestock-related
natural resource problems and the other half to more general conservation priorities.
The program works in priority areas where there are serious and critical environmental
needs and concerns. These critical needs areas are determined and prioritized by the
National Resource Conservation Service, other U.S. Department of Agriculture agencies,
and local work groups. High priority is given to areas where State or other local
governments offer financial or technical assistance and where agricultural improvements
will help meet water quality and other environmental objectives. All Environmental
Quality Incentives Program activities must be carried out according to a conservation plan.
The program offers 5 to 10-year contracts that provide incentive payments and cost sharing
for conservation practices needed at the site. Cost sharing may pay up to 75 percent of the
costs of certain practices important to improving and maintaining the health of the natural
resources of the area. Incentive payments can be made to encourage producers to perform
land management practices including wildlife habitat management. Incentive payments can
be up to 100 percent of the producer’s cost.
The program funding comes from commodity credit corporations. The budget is $200
million per year, nationally, through the year 2002. Conservation practices for natural
resource concerns related to livestock production will receive 50 percent of the funding.
Total cost share and incentive payments are limited to $10,000 per person per year and
$50,000 over the length of the contract.
5. Wildlife Habitat Incentives Program
The Wildlife Habitat Incentives Program is a voluntary program for people who want to
develop or improve fish and wildlife habitat primarily on private lands. It provides both
technical assistance and cost share payments to help establish and improve fish and
wildlife habitat. The National Resource Conservation Service helps participants prepare a
wildlife habitat development plan in consultation with the local conservation district. The
plan describes the landowner’s goals for improving wildlife habitat, includes a list of
practices and a schedule for installing them, and details the steps necessary to maintain the
habitat for the life of the agreement. This plan may or may not be part of a larger
conservation plan that addresses other resource needs, such as water quality and erosion.
Cost share assistance includes an agreement for wildlife habitat development and usually
lasts 5 to 10 years.
Under the agreement:
1. The landowner agrees to install and maintain the program practices and allow the
National Resource Conservation Service or its agent access to monitor the effectiveness
of the practices.
2. The U.S. Department of Agriculture agrees to provide technical assistance and pay up
to 75 percent of the costs of installing the wildlife habitat practices.
Wildlife Habitat Incentives Program funds are distributed to States based on state wildlife
habitat priorities which may include: a) wildlife habitat areas; b) targeted species and their
habitats; and c) specific practices.
The program may be implemented in cooperation with other Federal, State, or local
agencies; conservation districts; or private conservation groups. State priorities in
California for the Wildlife Habitat Incentives Program are the following:
1. Riparian area and stream habitat restoration or enhancement.
2. Federal or State threatened or endangered species habitat restoration or enhancement.
3. Treatment or improvement of habitats in uplands (rangeland, woodland, and forest

land).
4. Wetland area creation, restoration, enhancement, and management.
5. “Farmland compatible” habitat development (odd areas, ditches, field borders, rights-of-
way, and other areas in or adjacent to farmland fields).
6. Cold water fisheries habitat restoration and enhancement (including salmon, steelhead,
and trout).
7. Restoration or enhancement of critical habitat related to endangered species.
8. Habitat restoration and enhancement for game species and other species.
6. Forestry Incentives Program (FIP)
The Forestry Incentives Program supports good forest management practices on privately
owned, nonindustrial forest lands. This program is intended to assure the Nation’s ability to
meet future demand for saw timber, pulp wood, and quality hardwoods by planting more
trees and placing more forest land under good forest management. The program provides
65 percent of the cost of tree planting, timber stand improvements, and related practices on
nonindustrial private forest land. The Federal cost share limit is $10,000 per person per
year. The Forest Incentives Program’s forest maintenance and reforestation provide
numerous natural resource benefits, including reduced wind and soil erosion and enhanced
water quality and wildlife habitat. The program is administered by the Natural Resource
Conservation Service and the U.S. Forest Service.
7. California Stewardship Incentives Program
The California Stewardship Incentives Program is similar to the Forest Incentives Program.
Whereas the Forest Incentives Program requires that the total private acreage be timbered
acreage potentially suitable for timber production, the Stewardship Incentives Program only
requires that 10 percent of the land have tree canopy or be planted to trees. Cost share rates
and benefits to natural resources are the same as the Forest Incentives Program.
8. Emergency Conservation Program
The Emergency Conservation Program provides emergency funds for sharing with farmers
and ranchers the cost of restoring to productive use farmland seriously damaged by natural
disasters. This program is available only to solve new conservation problems caused by
natural disasters that impair and endanger the land or materially affect the productive
capacity of the land. The damage must be unusual (except for wind erosion) and not likely
to recur frequently in the same area. Conservation problems existing prior to the disaster
are not eligible for program assistance. Emergency practices to rehabilitate damaged
farmland may include: 1) rehabilitating stream banks, channels, levees, and dikes affected
by the natural disaster; 2) removing debris deposited by a natural disaster (e.g. flood debris)
that interfere with normal farming operations; and 3) restoring land between any levee and
the stream.
9. Emergency Watershed Protection Program
The Emergency Watershed Protection Program, administered by the Natural Resource

Conservation Service, provides technical and financial assistance to communities for
restoring watersheds ravaged by natural disasters such as, floods, fires, wind storms,
earthquakes, and drought. Through the Emergency Watershed Protection Program, the
Natural Resource Conservation Service provides assistance to prevent damage from
flooding, runoff, and erosion, reducing the threat to life and property. The Natural Resource
Conservation Service helps repair over-topped levees, dikes, and other flood retarding
structures. Assistance is also available to help clear water courses clogged by sediment and
debris to prevent future flooding. Other available measures include establishing vegetative
cover, controlling gullies, and protecting stream banks.
This assistance protects homes, businesses, and other properties from further damage in the
event of subsequent storms. The Natural Resource Conservation Service also provides
financial assistance covering up to 75 percent of construction costs of eligible emergency
treatments. Local sponsors of program projects are responsible for obtaining the necessary
permits, providing 25 percent cost share, and providing for the operation and maintenance
of completed emergency measures.
10.Resource Conservation and Development Program
The Resource Conservation and Development Program was initiated in 1962 to help people
care for and protect their natural resources and to improve an area’s economy, environment,
and living standards. The program provides a way for local residents to work together and
plan how they can actively solve environmental, economic, and social problems facing
their communities. Assistance is available from the Natural Resource Conservation Service
for planning and installation of approved projects specified in Resource Conservation and
Development area plans, for land conservation, water management, community
development, and environmental enhancement. The program provides for multi-county
planning coordination. Groups of landowners, communities, nonprofit organizations, and
local government agencies are eligible to participate in this program, as well as Native
American landowners and Tribal trust lands meeting the requirement that land is located in
a Resources Conservation and Development area.
Land must be in a United States Department of Agriculture-recognized Resource

Conservation and Development area. Currently these areas are: OreCal Resource
Conservation and Development area in Siskiyou and western Modoc Counties in
California, and Klamath/Lake Counties in Oregon; North Cal Neva Resource Conservation
and Development area in Lassen, Plumas, and western Modoc Counties in California and
Washoe County, Nevada; Trinity County Resource Conservation and Development area in
Trinity County, California; High Sierra Resource Conservation and Development area in
Nevada, Placer, El Dorado, Sierra, and Amador Counties in California; Central Coast
Resource Conservation and Development area in Santa Cruz, Monterey, San Benito, and
San Luis Obispo Counties in California.
Assistance is provided in the form of: 1) technical assistance and 2) grants (as funding
allows) up to 25 percent of the total cost, not to exceed $50,000. Local or State
governments must provide 10 percent of the total cost and they are responsible for the
operation and maintenance.
11. Other Programs
Several other programs administered by the Natural Resource Conservation Service are
designed to protect natural resources on a watershed basis. These include River Basin
Studies and Water Project Plans. River Basin Studies identify water and land resource
problems, and analyze the economic base and environmental setting. Alternative plans for
solving problems and improving the economy and the environment are offered. Watershed
Project Plans and Environmental Impact Statements provide plans that assist urban and
rural communities to protect, improve, and develop water and land resources in watersheds
up to 92,000 hectares (250,000 acres). The Natural Resource Conservation Service may
provide both technical and financial assistance in the planning and implementation of
watershed projects. The local sponsors may have major obligations in these projects,
including obtaining 25 percent of the funding to implement the projects and the
responsibility for insuring the operation and maintenance of the installed practices which
make up the project. Wetland restoration, creation, or enhancement is often used to mitigate
wildlife habitat losses caused by project actions.
B. U.S. FISH AND WILDLIFE SERVICE PROGRAMS
1. Partners for Fish and Wildlife
Partners for Fish and Wildlife is our habitat restoration cost-sharing program for private
landowners. The program was established to offer technical and financial assistance to
landowners who wish to restore wildlife habitat on their property. On-the-ground habitat
improvement projects that benefit Federal trust species include restoration of wildlife
habitat on degraded or converted wetlands, riparian areas, native grasslands, and streams.
The assistance we provide can range from giving informal advice on the design and
location of a potential restoration project, to designing a project and funding up to 50
percent of the implementation costs under a formal cooperative agreement with the
landowner. Projects with the highest priorities are those that reestablish the natural
historical communities and provide benefits to migratory birds, anadromous fish, and
threatened and endangered species. Projects include efforts such as, but not limited to:
creating shallow water areas, revegetating native plants, erecting fences along riparian areas
to exclude livestock, grazing plans to benefit livestock and wildlife, pesticide use reduction,
water level management, and soil and water quality improvements.
The process is as follows:
We meet with the landowner and any representative from other cooperating agencies or
organizations on the property to discuss the landowner’s goals and objectives. We provide
technical advice on project design, material, and engineering as appropriate. Cost sharing is
proposed. A habitat restoration proposal, developed by the landowner and our staff, is
submitted to one of our State offices to compete for funds. After funding is approved, the
Wildlife Extension Agreement is signed. Upon project completion, we will reimburse the
landowner after receipts and other documents are submitted according to the agreement.
2. Safe Harbor Programs
Many public and private interests have suggested that there be an incentive for private
landowners and/or public land managers to voluntarily enhance habitat for California red-
legged frogs or to participate in reestablishment efforts for this species in historically
occupied areas. Many have concerns that doing so, without proper incentive programs in
place, will pose a long-term regulatory threat. This is particularly a concern for those
landowners who may be situated adjacent to areas undergoing reestablishment. For this
reason, a safe harbor program may be the best vehicle to encourage voluntary
reestablishment programs and alleviate the concerns of neighboring landowners. A Safe
Harbor Agreement is a voluntary agreement between us and one or more private or non-
Federal landowners to restore, enhance, or maintain habitats for listed species, candidates,
or other species of concern. Under the Agreement, we provide the landowner with
assurances that additional land use actions would not be imposed. If the Agreement
provides a net conservation benefit to the covered species and the landowner meets all the
terms of the Agreement, we would authorize the incidental taking of covered species to
enable the landowner to return the enrolled lands to agreed upon conditions.
The California red-legged frog appears to be a good candidate for application of a safe
harbor program. Because recovery planning emphasizes the importance of maintaining
viable metapopulations and protecting a network of connected habitats, it is reasonable to
assume that any conservation measure that is enacted (albeit with the understanding that it
is implemented under a potentially limited time frame via a safe harbor agreement) will
provide potential short term benefits to an individual population but lasting benefits to the
overall metapopulation. For example, if habitat is created via enhancements of a stockpond
such that the stockpond is colonized by California red-legged frogs or if a stockpond is
stocked with translocated individuals, this restoration action will presumably provide some
number of years of suitable habitat for successful breeding. This will in turn, provide
dispersers into adjacent habitats. If a landowner decides to remove this habitat at some
future point in time, the overall metapopulation will still have gained by the potential
increase in subpopulations. Provided that adjacent landowners are party to the agreement,
all colonized habitats could be covered under the agreement, perhaps with staggered time
periods/endpoints. Opportunities for enhancement of habitat exist rangewide and the use of
safe harbor programs may substantially facilitate implementation of recovery actions.
There are several steps to develop a Safe Harbor Agreement and obtain the appropriate
permits. An interested landowner should contact the nearest Fish and Wildlife Service Field
Office and speak to someone about the program. The landowner, with our the aid, must
provide some background information including the location and of the property, the
proposed management actions, and the species that will benefit. We (or appropriate
cooperators as approved by the landowner) will describe the baseline conditions for the
enrolled property in terms appropriate for the listed species. Baseline conditions include the
number and location of individuals, if it can be determined, and also includes an assessment
of habitat extent and quality. Both parties will discuss land use objectives, assess habitat
quality, and identify any other information needed to develop an Agreement. After this, a
Safe Harbor Agreement is developed; it should include a monitoring program to assess the
success of the management practices. Assurances are provided through a “enhancement of
survival” permit once the Agreement is developed. We complete an internal section 7
review and a public comment period, issue a 10(a)(1)(A) permit, and finalize the
agreement. This permit allows the landowner to return the property to the baseline
conditions at the end of the Agreement. Safe Harbor Agreements will be honored after the
sale of the enrolled property if the new owner willingly signs the original Agreement;
agreements can also be renewed.
C. STATE OF CALIFORNIA PROGRAMS
1. California Resource Conservation Districts
Conservation Districts emerged during the 1930s as a way to prevent the soil erosion
problems of the Dust Bowl from recurring. Formed as independent local liaisons between
the Federal government and landowners, conservation districts have always worked closely
with the USDA Natural Resources Conservation Service. Resource Conservation Districts
address a wide variety of conservation issues such as forest fuel management, water and air
quality, wildlife habitat restoration, soil erosion control, conservation education, and much
more.
Resource Conservation Districts render assistance to private landowners wishing to

conserve soil and water and manage their resources on a sustainable basis. But Resource
Conservation Districts also act as a focal point for local conservation efforts, and Resource
Conservation Districts throughout the State now function as leaders in the conservation
community, including a large number of watershed groups such as Coordinated Resource
Management Planning (CRMP) groups throughout the State. Resource Conservation
Districts continue to sponsor educational efforts to teach children and adults alike of the
importance of conserving resources.
California now has 103 Resource Conservation Districts, most of which are funded largely
through grants. A few receive limited funds through county property tax revenues. The
Department of Conservation and the Natural Resources Conservation Service provide
training and in-kind support, as well as a watershed grant program for districts.
2. California Forestry Incentives Program (CFIP)
The purpose of the California Forest Improvement Program is to encourage private and
public investment in, and improved management of, California forest lands and resources.
This focus is to ensure adequate high quality timber supplies, related employment and other
economic benefits, and the protection, maintenance, and enhancement of a productive and
stable forest resource system for the benefit of present and future generations.
The program scope includes the improvement of all forest resources, including fish and
wildlife habitat, soil, and water quality. The program provides technical assistance to private
forest landowners, forest operators, wood processors, and public agencies. Cost share
assistance is provided to private forest landowners, Resource Conservation Districts, and
non-profit watershed groups. Cost-shared activities include management planning, site
preparation, tree purchase and planting, timber stand improvement, fish and wildlife habitat
improvement, and land conservation practices for ownerships containing up to 5,000 acres
of forest land.
D. GREEN CERTIFICATION PROGRAMS
Green Certification programs have recently been developed to bring environmental

concerns to the marketplace. Products that are generated using environmentally sensitive
methods are offered as alternatives to traditionally produced items. There is a double
incentive for these types of programs that leads to reduced environmental effects. Producers
are encouraged by the potential for higher income, and consumers are stimulated by the
prospect of owning higher-valued specialty items. Both are motivated by personal desires to
contribute to good land stewardship and sustainable environments. These programs
typically involve certification of the producer by an independent party using criteria
generated through ecological and economic research. Certification can be done to verify
lowered impacts to a species or group of species (e.g., Dolphin-Safe Tuna) or to verify that
land management practices in general meet sustainability criteria (e.g., the Smart Wood
Program).
There are a number of programs that could be considered as models for setting up criteria
and a labeling program for the California red-legged frog. “Dolphin-Safe Tuna” labeling
was one of the first such programs. This program uses independent monitors that have
unrestricted access to fishing boats and manufacturing facilities to document the minimal
effects of tuna fishing on dolphins. There are numerous large companies that now use the
Dolphin-Safe label. Another species-specific program is “Bird-Friendly Coffee.” Recent
changes in the way coffee is grown (from under forest canopies that provide shade to open-
field, sun grown) have had significant negative impacts to native birds in the tropics and
neotropical migrants. This program uses criteria developed by the Smithsonian Migratory
Bird Center, as applied by independent evaluators, to certify coffee as shade-grown and
“Bird Friendly.” There is at least one coffee company now that produces and sells this
certified coffee.
Several other programs provide certification to landowners that use ecologically sustainable
land management practices. Two examples of these types of programs are “Smart Wood”
and “Salmon Safe.” Both are overseen by independent non-profit entities that have
developed specific criteria for their local area. In the case of “Salmon Safe,” small
agricultural landowners in California and Oregon are currently the main focus. Expert
evaluators use criteria and scoring guidelines developed by the Pacific Rivers Council
(Eugene, Oregon) to certify that farmland management uses with best management
practices to avoid harm to stream ecosystems. These practices may result in restoration of
currently degraded areas. The following four criteria guide this process: 1) quality of
management of riparian and wetland areas; 2) quality of management of water use and
irrigation; 3) approaches to uses of pesticides, herbicides, and fertilizers; and 4) erosion and
sediment control measures. More specific sub-criteria are used to do actual scoring. The
“Smart Wood” program, developed by the Rainforest Alliance (New York City, New York)
is probably the largest wood products certification program. The program certifies wood
products, resource managers, and manufacturing companies that produce and handle wood
that has been generated using ecologically sustainable practices. Local organizations
typically develop region-specific criteria that are then approved by the “Smart Wood”
program. An example are the certification criteria used by the Institute for Sustainable
Forestry in Redway, California. Their approach includes evaluation of: 1) the overall forest
and watershed management plan, 2) silvicultural techniques, 3) the monitoring plan, 4) road
management and sediment production, 5) stream and riparian management, 6) wildlife and
biodiversity management, 7) fire and fuels management, 8) wildlife habitat, 9) roads and
trails, 10) yarding, 11) special resources, 12) restoration, 13) community and economic
stewardship, 14) use of local workforce, and 15) documentation of the “chain of custody”
(how the wood is tracked through to a final product).
Developing a program to encourage private landowners and businesses to practice land

management activities that are sensitive to the needs of the California red-legged frog could
be based on a combination of the approaches used by the “Salmon Safe” and “Smart Wood”
programs. These two programs cover the main impacts to the California red-legged frog in
many areas of its current range. Agriculture, livestock grazing, and forestry practices could
be certified as “frog friendly” by independent evaluators based on criteria developed by the
recovery plan technical team or another science-based group. These criteria might include:
1) management of ponds, wetlands, and streams; 2) management of adjacent upland areas;
3) lack of exotic vertebrate species and/or a program for reduction of exotic species on the
property; and/or 4) minimal use of chemical pesticides, herbicides, and fertilizers.
APPENDIX F. CODE OF PRACTICE TO REDUCE SPREAD OF DISEASE AND PARASITES
A Code of Practice was prepared by a group of scientists within the Declining Amphibian
Populations Task Force to provide guidelines for use by anyone conducting fieldwork at
amphibian breeding sites or in other aquatic habitats. While this protocol has not been
reviewed and endorsed by the task force at large, the Code of Practice serves as a starting point
for the development and adoption of measures that reduce the spread of disease and parasites
(see task 7 in the Stepdown Narrative Outline).
Observations of diseased and parasite-infected amphibians are now being frequently reported
from sites all over the world. This has given rise to concerns that releasing amphibians
following a period of captivity, during which time they can pick up infections of novel disease
agents, may cause an increased risk of mortality in wild populations. Amphibian pathogens and
parasites can also be carried in a variety of ways between habitats on the hands, footwear, or
equipment of fieldworkers, which can spread them to novel localities containing species which
have had little or no prior contact with such pathogens or parasites. Such occurrences may be
implicated in some instances where amphibian populations have declined. Therefore, it is
extremely important for those involved in amphibian research and other types of wetland/pond
studies (such as those on fish, invertebrates, and plants) to take steps to minimize the spread of
disease agents and parasites between study sites.
The Declining Amphibian Populations Task Force Fieldwork Code of Practice:
1. Remove mud, snails, algae, and other debris from nets, traps, boots, vehicle tires, and all
other surfaces. Rinse cleaned items with sterilized (eg., boiled or treated) water before
leaving each study site.
2. Boots, nets, traps, etc. should then be scrubbed with 70 percent ethanol solution and rinsed
clean with sterilized water between study sites. Avoid cleaning equipment in the immediate
vicinity of a pond or wetland.
3. In remote locations, clean all equipment with 70 percent ethanol or a bleach solution, and
rinse with sterile water upon return to the lab or a “base camp.” Elsewhere, when washing-
machine facilities are available, remove nets from poles and wash (in a protective mesh
laundry bag) with bleach on a “delicates” cycle.
4. When working at sites with known or suspected disease problems, or when sampling
populations of rare or isolated species, wear disposable gloves and change them between
handling each animal. Dedicate sets of nets, boots, traps, and other equipment to each site
being visited. Clean and store them separately at the end of each field day.
5. When amphibians are collected, ensure the separation of animals from different sites and
take great care to avoid indirect contact between them (e.g., via handling, reuse of
containers) or with other captive animals. Isolation from unsterilized plants or soils which
have been taken from other sites is also essential. Always use disinfected and disposable
husbandry equipment.
6. Examine collected amphibians for the presence of diseases and parasites soon after capture.
Prior to their release or the release of any progeny, amphibians should be quarantined for a
period and thoroughly screened for the presence of any potential disease agents.
7. Used cleaning materials (liquids etc.) should be disposed of safely and, if necessary, taken
back to the lab for proper disposal. Used disposable gloves should be retained for safe
disposal in sealed bags.
APPENDIX G. GENERAL GUIDELINES FOR REESTABLISHMENT

OF CALIFORNIA RED-LEGGED FROG POPULATIONS
General Guidelines
The successful reestablishment of frog populations as a conservation measure is largely

unproven. However, reestablishment could be an important tool for repopulating large areas,
especially in southern California, the foothills of the Sierra Nevada, and North Coast Range
foothills that have lost their California red-legged frog populations. Reestablishment can also
be used for the occupation of newly created habitats that cannot be easily reached from
existing populations. Programs of reestablishment should not be entered upon lightly as they
are expensive, and a long-term commitment of time and funds is imperative.
Attempts to reestablish the California red-legged frog should be made only if the following list
of criteria are met. Detailed explanations of these criteria follow the list:
1) The California red-legged frog formerly occupied the general area;

2) The habitat appears to be suitable, is under long-term protection, and predators (especially
exotic fishes and frogs) can be eliminated or kept to manageable levels;
3) The reasons for the species’ absence have been determined and eliminated or minimized;
4) No reproducing populations of the California red-legged frog remain in the area, and it is
not likely to be reinvaded from surrounding populations in the near future;
5) The effort can commit to:
a) Releases of propagules at each site through at least 5 consecutive years, preferably at
several sites within the area; and
b) Monitoring for at least 10 years after the last release.
Explanations:
1) The historic range of the California red-legged frog encompassed the Central Valley of
California, the Coast and Transverse ranges south of Mendocino County, southern
California west of the deserts, and northern Baja California west of the Sierra San Pedro
Mártir (see page 6 of the Introduction). Reestablishment can be considered in areas,
including those with newly created habitats, that are currently unoccupied by the
California red-legged frog, as long as the other criteria are fulfilled. Augmentation of any
California red-legged frog populations is not recommended.
2) Habitat quality is defined in Section I. A favorable mix of breeding, rearing, and summer
habitats relatively free of predators is the key element of habitat quality. At least three
potential breeding/rearing sites should be identified within each habitat block. Single
ponds, unsupported by a network of other ponds or streams, should not be considered for
reestablishment programs.
Sites must be protected from threats and incompatible uses in the foreseeable future.
Biologists must be assured of access to the entire metapopulation habitat block for
monitoring purposes. Top priorities for reestablishment should be those sites that have
high quality habitat and that are most remote in distance from existing populations.
3) The reasons for the original disappearance or absence of the California red-legged frog
must be identified and corrected.
4) Usually reestablishment will not be considered if there are populations present in the
same recovery unit, unless the sites are isolated by habitats that are not easily crossed by
the California red-legged frog. Exceptions may also be made for newly created habitats
that do not have an existing population nearby. Propagules should ideally be taken from
the populations that are geographically closest to the reestablishment sites.
5) Reestablishment can be expensive, and unless the parties involved are dedicated to
spending the necessary funds over a suitable time period, it is better not to embark on a
program. This commitment must include the monitoring phase.
a) Releases of about 1,000 eggs should be made at each breeding site within the habitat
block for each of 5 years. If these goals cannot be achieved, the project should not be
considered. In an emergency (extreme drought, flooding), a year might be skipped. In
that case, the intended releases should be made in the sixth year instead. If more than
1,000 eggs are available, other sites should be considered for reestablishment. Each
site should receive at least 500, but not more than 1,000, eggs each year.
b) The cheapest and most efficient way to secure propagules for reestablishment is to
collect as many whole or partial egg masses as necessary to provide 1,000 eggs for
each reestablishment site. In different years, rotate the take of eggs among several
subpopulations if at all possible.
c) Monitoring reestablished populations is critical. If the fate of the population is not

known, the effort is wasted. Much can be learned by monitoring even a failed
reestablishment effort. Detailed monitoring is especially important during the first
reestablishment program; the lessons learned will be used to guide all future efforts.
Implementation
Reestablishment as a recovery strategy should be considered in the following areas: Recovery

Unit #1, the Sierra Nevada; Recovery Unit #2, the Coast Range foothills and western
Sacramento River Valley; and Recovery Unit #8, the Southern Transverse and Peninsular
ranges.
The steps to be taken are:
1. Survey the areas and determine their suitability, based on the above criteria. Choose suitable
breeding/rearing sites.
2. Locate source metapopulations. Determine that enough adult females are present in each
population to provide the necessary egg masses. As a rule of thumb, no more than 10
percent of the egg masses should be taken from a given site.
3. Collect either freshly laid eggs or those that are hatching. The intermediate stages are
delicate and should not be disturbed. Keep the water cool and move the intact egg mass as
quickly as possible to the release site. Divide the egg mass as necessary when you get to
the release sites.
4. Monitoring should consist of annual survey sessions wherein all California red-legged frogs
captured are sexed, weighed, measured, and examined for passive integrated transponder
(PIT) tags. Tags should be inserted in those that lack them. The data should be
immediately analyzed to examine the survival of each cohort. At the same time, the entire
habitat block should be examined to document the rate of spread from the original release
sites.
Summary of Section 10(j) of the Endangered Species Act of 1973: Experimental

Populations
Reintroduction of the California red-legged frog is consistent with the goals of the Endangered
Species Act. Guidelines for such activities are provided under section 10(j). This section
allows the release (and the related transportation) of any population (including eggs,
propagules, or individuals) of an endangered species or a threatened species outside the current
range of such species if the Secretary of the Department of Interior determines that such
release will further the conservation of a species.
Before authorizing the release of any population, the reintroduced population should be
identified, on the basis of the best available information, as an essential population (i.e, the
population is essential to the continued existence of an endangered species or a threatened
species) or as a nonessential population. This section also provides the Secretaries of the
Departments of Interior and Commerce with the power to designate certain populations of
listed species as experimental populations. The term experimental population means any
population (including any offspring arising solely therefrom) authorized for release that are
wholly separate geographically from nonexperimental populations of the same species.
Each member of an experimental population shall be treated as a threatened species unless the
experimental population is considered to be nonessential to the continued existence of a
species. If it is nonessential, it is treated as a species proposed to be listed under section 4 of
the Act. If the nonessential population occurs in an area within the National Wildlife Refuge
System or the National Park System however, it is treated as threatened with either
designation.
The best known cases in which the status “experimental/nonessential” has been used are the
reintroductions of the endangered red wolf in North Carolina and the threatened gray wolf in
Idaho and in Yellowstone National Park. Ordinarily, private landowners cannot chase an
endangered species such as the red wolf off of their land or away from their livestock because
section 9 of the Endangered Species Act prohibits “harassing” of listed animals. However, in
both the red and gray wolf cases, the animals that were released were designated experimental/
nonessential, allowing landowners to kill individual wolves caught preying upon livestock.
This designation helped reduce public opposition to wolf reintroductions by giving landowners
some control over problem animals. While this designation reduces Endangered Species Act
protections, it can be an invaluable tool in gaining public support. This strategy can facilitate
species recovery in appropriate circumstances.
Reestablished populations of the California red-legged frog may not be critical to the
continued existence of the species and therefore will be considered as nonessential
populations. Because recovery goals hinge on connectivity of habitat and maintenance of
metapopulations of California red-legged frogs, whereby there is dispersal of individuals
between populations and colonization and/or recolonization of habitats, most reestablished
populations are not likely to be geographically isolated from existing populations and thus will
not qualify as an experimental population. In some core areas, reestablished populations will
be geographically isolated initially; in these cases, the experimental approach may be judged
appropriate and should be considered on a site by site basis. Formal designation of
nonessential/experimental status will be required.
APPENDIX H: SUMMARY OF AGENCY AND PUBLIC COMMENTS ON THE DRAFT RECOVERY

PLAN FOR THE CALIFORNIA RED-LEGGED FROG
In May, 2000, we released the Draft Recovery Plan for the California Red-legged Frog (Draft
Plan) for a 90-day comment period. This comment period was extended for an additional 90
days and the entire public comment period ended on November 7, 2000. During this open
comment period, comments for Federal agencies, State and local governments, and members
of the public were collected. Marc Hayes, John Bolger, Samuel Sweet, and Jerry Smith were
asked to provide peer review of the draft plan. Comments were received from one peer
reviewer.
This section provides a summary of general demographic information including the total
number of letters received from various affiliations and States. It also provides a summary of
the major comments. All letters of comment on the draft plan are kept on file in the
Sacramento Fish and Wildlife Office at 2800 Cottage Way, Room 2605, Sacramento,
California 95825-1846.
The following is a breakdown of the number of letters received from various affiliations:
Federal agencies—11
State agencies—3
local governments—25
environmental/conservation organizations—21
academia/professional—8
business/industry—18
individual citizens—159
This section summarizes the content of significant comments on the draft plan. A total of 245
letters were received, each containing varying numbers of comments. Many specific comments
re-occurred in letters. Most letters provided new information or suggestions for clarity. In these
cases, the information was incorporated into the final version of the recovery plan directly.
Some letters requested an explanation of various points made in the draft plan or their
scientific basis. In these cases, the final recovery plan was revised to include an expansion or
clarification of the particular section. Most comments resulted in revisions to the draft
recovery plan. Many commenters simply provided their voice of support or opposition to the
recovery plan. Information and comments not incorporated into the final version of the
recovery plan were considered, noted, and are on file with the entire package of agency and
public comments; these may become useful in the future. Major comments that were not
incorporated or that require clarification in addition to their incorporation are addressed below.
Summary of Comments and Our Responses
Introduction
Comment: One commenter suggested that the information used in the life history sections of
the introduction is mostly outdated and speculative.
Response: The best available information was used to write the life history sections in the
introduction. Most researchers agree that more information is needed to better understand the
ecology of the California red-legged frog. Nevertheless, published research was used for most
sections. Specific references mentioned in comments were re-evaluated and some sections
were updated using new information. In some cases, anecdotal information provided by field
biologists and/or land managers was used in the recovery plan. Many of these references refer
to distribution and status information that has been collected in the field as part of ongoing
survey and monitoring efforts. While this information is not peer reviewed and published, we
feel that it provides valuable information related to the California red-legged frog. Where non-
published information was used, we cited the biologists via personal communications or “in
litt” references. These are listed in the bibliography and are in the administrative record which
is available for review in the Sacramento Fish and Wildlife Office.
Comment: The scientific literature used in the discussion of mosquitofish and their predation
on California red-legged frogs appears to be biased.
Response: This recovery plan acknowledges that more information is needed regarding the
complex relationship between mosquitofish and California red-legged frogs; the plan
recommends such research in the list of recovery actions. The recovery plan states that there
are indeed several sites where mosquitofish and California red-legged frogs coexist.
Nevertheless, the literature that is available at this time overwhelmingly suggests that there are
some negative impacts on California red-legged frogs.
Comment: Address catastrophic fire and reduction of fuel buildup.
Response: We are aware of the need to control fuel buildup and thus preclude catastrophic
fires. Recovery team members representing the U.S. Forest Service provided guidelines for
activities related to fire control. These guidelines are included in the recovery plan in the
Guidance for Development of Watershed Management Plans
and Implementation of Recovery Tasks.
Comment: Several commenters suggested that the recovery plan address the threat of
expansion of the University of California Santa Cruz Campus and how it may destroy frog
habitat on Moore and Jordan Gulch drainages.
Response: There are many development projects impacting California red-legged frogs
throughout its range. The recovery plan attempts to capture the nature and effects of threats to
this species in a general manner, using some specific examples where appropriate. Urban
development and expansion is indeed a threat that is contributing to the decline of the
California red-legged frog. The effects of urban development is discussed in the Threats and
Reasons for Decline section, in the Introduction.
The California red-legged frog habitat in Moore and Jordan Gulch drainages are included in
Core Area # 19 which is called Salinas River-Pajaro River and includes the these drainages. As
a result of this comment, the need for alternatives to, or mitigation for, the expansion of UC
Santa Cruz has been added to the specific management and protection recommendations for
this core area (Table 6). It is the goal of the recovery plan that watershed management plans
will be developed for watersheds that harbor California red-legged frogs. As these plans are
developed site specific impacts, such as the expansion of Santa Cruz campus, can be addressed
and remedied.
Any such development proposal would be required to undergo extensive public review and
authorization, including our review of likely effects on threatened and endangered species and
wetlands.
Comment: Address the off-road vehicle interface issues in Calaveras County as a threat to the
Response: As mentioned above, the threats to California red-legged frogs are described in a
general manner in the recovery plan. Off-road vehicle use of frog habitat is a serious concern
and land management recommendations related to this threat are included in the recovery plan.
Regarding this specific area, the off-road vehicle interface area is included in the recovery plan
as a portion of a core area in Calaveras County. This land use is inconsistent with the goals of
core areas, which are to restore and protect habitat and management for California red-legged
frogs. Therefore, minimization of these impacts should be included in the site-specific
watershed management plan.
Comment: A substantial number of non-indigenous animals are being purchased in live-food

markets and then released into local waters and thereby is a means of introducing non-natives
into the ecosystem. Suggest a ban on their importation.
Response: While non-native predators that have been introduced to the ecosystem are clearly
a major reason for the decline of the California red-legged frog, the source of the majority of
non-native species is not live-food markets. In fact, given the practice of stocking lakes for
sport-fishing, using mosquitofish for mosquito abatement, and the degradation of habitat that
has allowed the rampant proliferation of non-native species that have nearly naturalized in
California, this source is relatively insignificant.
Recovery
Comment: Discuss the relationship between core areas for recovery and critical habitat.
Response: A section discussing this relationship has been added to the recovery plan in
Section II. Core areas and critical habitat areas were selected based on similar criteria. The
main criteria used for both were to capture areas: 1) that are occupied by California red-legged
frogs, 2) where populations of California red-legged frogs appear to be source populations,
3) that provide connectivity between source populations, and 4) that represent areas of
ecological significance. For the selection of core areas, areas of ecological significance
include: watersheds that represent the limits of the current and historic range and/or that appear
to be restorable and thus good sites for reestablishment projects. Unlike the selection of core
areas, it is a requirement that primary constituent elements be defined for critical habitat. These
primary constituent elements are described in the recovery plan and are present in all critical
habitat areas and core areas.
The core areas and critical habitat areas differ in several ways. Unlike core areas which have
no legal mandate for protection under the Endangered Species Act and solely rely upon
voluntary implementation, the designation of critical habitat requires Federal agencies to
consult with us regarding any action that could destroy or adversely modify critical habitat.
Adverse modification of critical habitat is defined as any direct or indirect alteration that
appreciably diminishes the value of the habitat for both the survival and recovery of the
species.
Comment: Provide a better justification for identification of core areas that are currently not
occupied.
Response: Restoration of populations in core areas within the historic range, where California
red-legged frogs are currently not present, will prevent range collapse. If the goals of the
recovery plan do not include the historic range, but rather focus on currently occupied areas,
the result will be a vastly smaller range for this species; this limitation would preclude
recovery of the California red-legged frog.
Comment: Remove from core area maps all urbanized areas.
Response: The Sacramento Fish and Wildlife Office has maps on file that were developed
during the recovery planning process that exclude urban areas. The size of maps used in the
recovery plan however, did not allow such a level of detail without compromising the visibility
of core areas and geographic markers. The recovery plan discloses the fact that many areas
within core areas are expected to remain unsuitable due to land uses such as agriculture and
urban development, and are unlikely to be areas where recovery efforts will be implemented. If
readers wish to view the urban areas within core areas, they may do so at the Sacramento Fish
and Wildlife Office.
Comment: Be more specific, in terms of numbers, in defining the recovery criteria.
Response: Discussion of recovery criteria is given in Section II. Recovery strategies and other
recommendations are based upon the best scientific information available. Current
conservation biology and/or life history data were used to develop the standards. Most
recommendations are preliminary because: 1) available data on the covered species are limited
and 2) conservation biology has yet to resolve the details of how endangered species recovery
is best achieved for any species. Recovery strategies and other recommendations may need to
be altered as more data become available and as conservation science develops. We will review
such information periodically.
In the meantime, the recovery plan uses an approach that focuses on ecological integrity,
habitat availability, and metapopulation viability, rather than specific numbers of habitat acres,
individuals, or populations. When the five recovery criteria are met, the result will be a series
of populations that are linked by suitable, connected habitat.
Comment: Recovery goals are unrealistic and introduction of frogs is not necessary in all core
areas.
Response: We agree that introduction of California red-legged frogs in all core areas that
currently do not harbor the species may be challenging. However, given that most core areas
are already occupied, reestablishment efforts are only recommended in several core areas. This
effort may be achieved given adequate time and funding.
When comparing the historic range and number of populations, the core areas represent a
comparatively low number of watersheds. Distribution of California red-legged frogs in all
core areas, with adequate habitat protection in priority 2 watersheds, are necessary to spread
the risk of extinction across the landscape rather than concentrating genetic diversity and
habitat suitability where frogs currently exist or in a smaller number of watersheds.
Maintaining (and establishing where necessary) frog populations in all core areas may
optimize the chances for genetic diversity, habitat connectivity, and ultimately may allow the
species to occupy its former range. These goals cannot be met unless there is an attempt to
recover the frog in each core area.
Comment: Identify public support for recovery and potential resources for implementation.
Response: In Section I, Federal, State, local and private actions are listed that have
contributed to conservation of the California red-legged frog. This section has been expanded
to include more efforts by non-government organizations which are staffed by concerned,
private citizens. Appendix E. lists potential funding sources for implementation; many of these
programs provide financial assistance to willing participants.
Comment: Include recovery goals for the southern Sierra Nevada range, the Central Valley,
and the National Wildlife Refuges.
Response: Aside from the core areas and priority 2 watershed, all other areas within the range
of the species are listed as priority 3 watersheds. Here, the goals are to restore habitat, where
feasible, and allow for recolonization. The recovery plan specifically identifies the southern
Sierra Nevada, Central Valley, and wetlands on National Wildlife Refuges as priority 3
watersheds.
Comment: Eliminate the recommendation for commercial take of bullfrogs as it may pose an
incidental threat to the California red-legged frogs.
Response: Initially, the recovery team agreed that this would be a great contribution to
bullfrog eradication efforts. Several commenters, however, have suggested that the confusion
between California red-legged frog and bullfrog appearances may lead to take of the California
red-legged frog. This task has been removed as a result of these public comments.
Comment: Use consistent methods to define recovery units.
Response: Overall, the method used to delineate revised recovery units was by watershed
boundaries using U.S. Geological Survey hydrologic units. Along the Sierra Nevada mountain
range, the 1,500-meter (5,000-foot) elevation line was used because it is the general range limit
of the California red-legged frog. This method has not changed in the final recovery plan.
Comment: Include East Las Virgenes Creek as a core area for recovery and address the threat
of development at this site.
Response: This area is included in the Santa Monica Bay - Ventura Coastal Streams core area
(core area #50, Figures 39-40 in draft plan; core area #27, Figure 29 in final plan).
Comment: The recovery plan should include a socio-economic impact analysis, particularly in
regards to the potential economic impacts to agriculture.
Response: Because implementation of recovery plans is voluntary and not a legal mandate,
there is no requirement for an economic impact analysis.
Comment: Eliminate certain core areas (e.g. Traverse Creek, Tejon/El Paso).
Response: While developing the final recovery plan, all core areas were re-evaluated to
determine whether they fit the selection criteria. The selection criteria used were to include
areas that: 1) are occupied by California red-legged frogs, 2) where populations of California
red-legged frogs appear to be source populations, 3) that provide connectivity between source
populations, and 4) that represent areas of ecological significance. Areas of ecological
significance include watersheds that represent the limits of the current and historic range and/
or that appear to be restorable and thus good sites for reestablishment projects. Based on these
criteria, some proposed core areas were expanded, some were omitted, and new areas were
added.
In 2001, a new population of California red-legged frogs was located in a watershed adjacent
to Traverse Creek. This highlights the need for additional surveys and the opportunities for
recovery implementation in all core areas listed in the recovery plan. In light of this new
sighting, we feel that it is important to keep selected core areas until adequate surveys and
habitat suitability assessments are conducted.
Outline of Recovery Actions
Comment: Three commenters suggested that recovery actions should focus on controlling
predation rather than increasing habitat and protecting habitat.
Response: The recovery plan emphasizes the need to control predation as a means of
recovering the California red-legged frog. At the same time, emphasis is put on the
development of watershed management plans to meet the recovery needs at the watershed
level and thus allow for customized, site-by-site management. It is in these watershed
management plans that predator control can be focused and implemented, where appropriate.
Where the preparers were aware of heavy predation, these watersheds were included in the
stepdown narrative of recovery tasks and specified in the Guidance for Development of
Watershed Management Plans and Implementation of Recovery Tasks. We urge land
management agencies to manage non-native predatory species on their lands and is willing and
eager to provide technical assistance and will consider funding any proposal regarding removal
of non-native, predatory species.
Comment: Include as a recovery task the control, research, and monitoring of native
predators.
Response: The recovery team did not wish to list removal of native predators as a task needed
for recovery. Some recovery actions, however, will reduce the impacts of predation. For
example, relocating picnic grounds and campsites farther away from known California red-
legged frog habitat will reduce the proliferation and concentration of native predators such as
raccoons. Further, when the ecosystems in which California red-legged frogs live are restored
to ecological health, a balanced species composition is likely to be restored and will thus
reduce the extent and effects of predation by native species.
Comment: Emphasize the need for research on the role of contaminants and the decline of
California red-legged frogs.
Response: There is an extensive list of research needs and land management recommendations
described in the stepdown narrative of the recovery plan and the Guidance for Development of
Watershed Management Plans and Implementation of Recovery Tasks. A large portion of these
outstanding needs and recommendations deal specifically with contaminants.
Implementation Schedule
Comment: Several commenters suggested that the costs for recovery are underestimated.
Response: These estimates represent best available information from various analyses that
estimate costs for implementing recovery actions. As the recovery plan is implemented, the
exact costs will become more apparent.
Comment: Many commenters expressed concern about actions proposed in the recovery
plans that could affect private landowners.
Response: A recovery plan is not a regulatory document and does not provide for agreement to
or implementation of any of the recovery tasks proposed. A recovery plan is a reference
document that identifies actions that, if implemented, are expected to recover the species. Any
actions that are implemented must follow appropriate State, local, or Federal laws and
regulations. Any cooperation from private landowners is voluntary. Specific arrangements for
accomplishing recovery actions would be worked out at the time of planning and
implementing the action and should include all appropriate stakeholders.
Appendices
Comment: Include safe harbor provisions.
Response: A Safe Harbor Agreement is a voluntary agreement between us and one or more
private or nonfederal landowners to restore, enhance, or maintain habitats for listed species,
candidates, or other species of concern. Under the Agreement, the landowner would be
provided assurances that we would not impose additional land use actions. If the Agreement
provides a net conservation benefit to the covered species and the landowner meets all the
terms of the Agreement, we would authorize the incidental taking of covered species to enable
the landowner to return the enrolled lands to agreed upon conditions.
The recovery plan recommends the use of Safe Harbor Agreements for the conservation of the
California red-legged frog. Such agreements are seen as a valuable tool that can be used to
implement the recovery plan. Discussion of Safe Harbor Agreements has been added to the
plan in Appendix E. which addresses incentives for recovery implementation.
Comment: Include a section on 10(J) for reintroduction.
Response: Because reestablishment of California red-legged frogs in portions of its range is

recommended in the recovery plan, a description of section 10(J) of the Endangered Species
Act has been added to Appendix G. which provides information on reestablishment
opportunities and methods.
Comment: The boundaries of core areas should be refined and the maps of core areas should
be clearer.
Response: Revised maps are included in Appendix C. Due to budget limitations, color maps
and large maps are kept to a minimum in the recovery plan. Because of this, the maps are not
as clear and refined as we would like. If any member of the public is interested in seeing maps
of better clarity, they may visit the Sacramento Field Office to view the maps on file.
You never see a frog so modest and straightfor'ard

as he was, for all he was so gifted. And when it come
to fair and square jumping on a dead level, he could
get over more ground at one straddle than
any animal of his breed you ever see.
—Mark Twain, Celebrated Jumping Frog of Calaveras
County
Attachment 1: Status and Life History of California Red-Legged Frog
1.1 Species Listing Status
The California red-legged frog (CRLF) was listed as threatened throughout its entire range on
May 23, 1996 (61 FR 101 25813-25824) by the U.S. Fish and Wildlife Service (USFWS). A
recovery plan addressing the CRLF was approved by the USFWS on May 28, 2002 (USFWS
2002).
On April 13, 2006, a Federal Register notice designating critical habitat for this species was
published (71 FR 19243-19346). This critical habitat designation also included a special rule,
under section 4(d) of the Endangered Species Act (ESA), exempting routine ranching activities
from critical habitat protection. More information on critical habitat, including the special
exemption rule, is included in Section 1.3.3.
1.2 Description and Taxonomy
The CRLF (see Figure 1.1) is one of two subspecies of the red-legged frog (Rana aurora) and is
the largest native frog in the western United States (USFWS 2002). Baird and Girard first
described this species after discovering it near San Francisco in 1852 (Storer 1925).
Figure 1.1. California red-legged frog. Image courtesy Marc P. Hayes, USFWS
© Marc P. Hayes/U. S. Fish and Wildlife Service
Adult CRLFs are between 85-138 mm in length, from the tip of the snout to the rear of the vent.
Juvenile CRLFs are between 40-84 mm in length and are similar in coloration, although
somewhat lighter, than adults. Larval CRLFs are 14-80 mm in length and are generally blackish
in color, gradually changing to brown with spots (Jennings et al. 1997). A Marin County study
indicates that adult male CRLF body weight ranges from 59.0-94.0 g (Fellers and Guscio 2004).
At Point Reyes National Seashore, Fellers (personal communication 2007) collected over 250
CRLFs (adults and juveniles) and determined that a direct correlation exists between CRLF
length and body weight, described by the equation below:
BW = 0.7291 + 0.0981*L3, where BW = body weight (g) and L= length (mm).
1
The range for male CRLFs (n=158) was 52-118 mm in length and 12.75-163 g in weight. The
range for female CRLFs (n=91) was 50-131 mm in length and 8.7-238 g in weight.
1.3 Population Status and Distribution within California
The CRLF is endemic to California and Baja California (Mexico) and historically inhabited 46
counties in California, including the Central Valley and both coastal and interior mountain
ranges (USFWS 1996). Its range has been reduced by about 70%, and the species currently
resides in 22 counties in California (USFWS 1996). The species has an elevational range of near
sea level to 1,500 meters (5,200 feet) (Jennings and Hayes 1994); however, nearly all of the
known CRLF populations have been documented below 1,050 meters (3,500 feet) (USFWS
2002).
Populations currently exist along the northern California coast, northern Transverse Ranges
(USFWS 2002), foothills of the Sierra Nevada (5-6 populations), and in southern California
south of Santa Barbara (2 populations) (Fellers 2005a). CRLF populations located between
Marin and Santa Barbara Counties are somewhat larger than most other populations (Jennings
and Hayes 1994). A total of 243 streams or drainages are believed to be currently occupied by
the species, with the greatest numbers in Monterey, San Luis Obispo, and Santa Barbara counties
(USFWS 1996). Occupied drainages or watersheds that support CRLFs include all bodies of
water (i.e., streams, creeks, tributaries, associated natural and artificial ponds, and adjacent
drainages), and habitats through which CRLFs can move (i.e., riparian vegetation, uplands)
(USFWS 2002).
The distribution of CRLFs within California can be addressed by considering four categories of
location including recovery units, currently occupied core areas, designated critical habitat, and
known occurrences of the CRLF reported in the California Natural Diversity Database (CNDBB)
that are not included within core areas and/or designated critical habitat. A description of these
areas is provided in Sections 1.3.1 through 1.3.4, and maps of CRLF distribution within each of
the eight recovery units are presented in Section 1.3.5.
1.3.1. Recovery Units
Eight recovery units have been established by the USFWS for the CRLF. Recovery units reflect
areas with similar conservation needs and population statuses, and therefore, similar recovery
goals. The recovery unit is primarily an administrative designation, and land area within the
recovery unit boundary is not exclusively CRLF habitat. These areas are considered essential to
the recovery of the species, and the status of the CRLF “may be considered within the smaller
scale of the recovery units, as opposed to the statewide range” (USFWS 2002). The eight units
described for the CRLF are delineated by watershed boundaries defined by U.S. Geological
Survey (USGS) hydrologic units and are limited to the elevational maximum for the species of
1,500 m above sea level. Additional detail on specific recovery units, including maps, is
provided in Section 1.3.5.
1.3.2. Core Areas
2
Core areas are smaller areas within the recovery units that comprise portions of the species’
historic and current range and have been determined by USFWS to be important in the
preservation of the species. USFWS has designated 35 core areas across the eight recovery units
to focus their recovery efforts for the CRLF. The core areas, which are distributed throughout
portions of the historic and current range of the species, represent areas that allow for long-term
viability of existing populations and reestablishment of populations within historic range. These
areas were selected because they contain existing viable populations or they contribute to the
connectivity of other habitat areas (USFWS 2002). Core area protection and enhancement are
vital to the CRLF population and distribution throughout its range. While core areas are
considered essential for recovery of the CRLF, core areas are not federally-designated critical
habitat, although designated critical habitat is generally contained within these core recovery
areas. It should be noted, however, that several critical habitat units are located outside of the
core areas, but within the recovery units. For the purposes of this assessment, only currently
occupied (post-1985) core areas are considered. Historically occupied sections of the core areas
are not evaluated as part of this assessment because the USFWS Recovery Plan (USFWS 2002)
indicates that CRLFs are extirpated from these areas.
The locations of all currently occupied core areas within each of the eight recovery units are
depicted in Section 1.3.5 in Figures 1.2 through 1.10.
1.3.3. Critical Habitat
Critical habitat was designated for the CRLF on April 13, 2006 (USFWS 2006; 71 FR 19244-
19346). Critical habitat was selected for the species based on areas: 1) that are occupied by
CRLFs; 2) where source populations of CRLFs occur; 3) that provide connectivity between
source populations; and 4) that are ecologically significant. Designation of critical habitat is
based on habitat areas that provide essential life cycle needs of the species or areas that contain
primary constituent elements (PCEs) (as defined in 50 CFR 414.12(b)). PCEs include, but are
not limited to, space for individual and population growth and for normal behavior; food, water,
air, light, minerals, or other nutritional or physiological requirements; cover or shelter; sites for
breeding, reproduction, rearing (or development) of offspring; and habitats that are protected
from disturbance or are representative of the historic geographical and ecological distributions of
a species. The designated critical habitat areas for the CRLF are considered to have the
following PCEs that justify critical habitat designation (USFWS 2006):
1. Aquatic breeding habitat: standing bodies of fresh water (salinity < 7.0 parts per
thousand) including: natural and manmade (stock) ponds, slow moving streams or pools
within streams, other ephemeral or permanent water bodies that typically become
inundated during winter rains and hold water for a minimum of 20 weeks in all but the
driest years.
2. Non-breeding aquatic habitat: fresh water habitats (as described in “aquatic breeding
habitat”) that may or may not hold water long enough for the frog to complete its
lifecycle but provide for shelter, foraging, predator avoidance, and aquatic dispersal.
Wetland habitats that meet these elements include, but are not limited to: plunge pools
3
within intermittent creeks, seeps, quiet water refugia during high water flows, and springs
of sufficient flow to withstand summer dry period.
3. Upland habitat: upland areas within 200 ft of edge of riparian vegetation or dripline
surrounding aquatic and riparian habitat and comprised of: grasslands, woodlands and/or
wetland/riparian plant species providing shelter, forage, and predator avoidance for the
frog. Upland areas may include structural features such as boulders, rocks, organic
debris, small mammal burrows, and moist leaf litter.
4. Dispersal habitat: accessible upland or riparian dispersal habitat within designated units
and between occupied locations within 0.7 mi of each other that allows for movement
between such sites. Dispersal habitat includes natural and altered habitats such as
agricultural fields that do not act as barriers to dispersal. Dispersal habitat does not
include moderate to high density urban or industrial developments with large expanses of
concrete or asphalt, nor reservoirs over 50 acres, nor other areas that do not contain
features defined in “aquatic breeding habitat,” “non-breeding aquatic habitat,” or “upland
habitat.”
Critical habitat is defined in the ESA as the geographic area occupied by the species at the time
of the listing where the physical and biological features necessary for the conservation of the
species exist, and there is a need for special management to protect the listed species. Critical
habitat may also include areas outside the occupied area at the time of listing if such areas are
‘essential to the conservation of the species.’ Critical habitat does not include certain areas
where existing management is sufficient for CRLF protection. For the CRLF, all designated
critical habitat units contain all four PCEs and were occupied by the CRLF at the time of listing.
USFWS has established adverse modification standards for designated critical habitat (USFWS
2006). Activities that may destroy or adversely modify critical habitat are those that alter the
PCEs and jeopardize the continued existence of the species. For the CRLF specifically, these
include, but are not limited to, the following:
(1) Significant alteration of water chemistry or temperature to levels beyond the tolerances
of the CRLF that result in direct or cumulative adverse effects to individuals and their
life-cycles.
(2) Significant increase in sediment deposition within the stream channel or pond or
disturbance of upland foraging and dispersal habitat that could result in elimination or
reduction of habitat necessary for the growth and reproduction of the CRLF by
increasing the sediment deposition to levels that would adversely affect their ability to
complete their life cycles.
(3) Significant alteration of channel/pond morphology or geometry that may lead to changes
to the hydrologic functioning of the stream or pond and alter the timing, duration, water
flows, and levels that would degrade or eliminate the CRLF and/or its habitat. Such an
effect could also lead to increased sedimentation and degradation in water quality to
levels that are beyond the CRLF’s tolerances.
(4) Elimination of upland foraging and/or aestivating habitat or dispersal habitat.
4
(5) Introduction, spread, or augmentation of non-native aquatic species in stream segments
or ponds used by the CRLF.
(6) Alteration or elimination of the CRLF’s food sources or prey base (also evaluated as
indirect effects to the CRLF).
The critical habitat designation includes a special rule exempting routine ranching activities
associated with livestock ranching from incidental take prohibitions. The purpose of this
exemption is to promote the conservation of rangelands, which could be beneficial to the CRLF,
and to reduce the rate of conversion to other land uses that are incompatible with CRLF
conservation.
1.3.3.1 Critical Habitat Special Exemption Rule
As part of the CRLF critical habitat designation, USFWS promulgated a special rule exempting
routine ranching activities from take prohibitions under section 9 of the ESA. (USFWS 2006, 71
FR 19285-19290). USFWS reasoned that this exemption is of net benefit to the CRLF, overall,
despite the potential for effects to a few individual CRLFs. Managed livestock activities,
especially the creation of stock ponds, provide habitat for the CRLF. Maintenance of these areas
as rangelands, rather than urban/suburban development or conversion to other uses, should
ranching prove to be economically infeasible, is beneficial to CRLF populations.
Several of the specific exempted activities include situations where pesticides may be used in
accordance with labeled instructions. Specific exemptions for rodent control and stock pond
management/maintenance, and the reasoning behind each of the exemptions are provided below.
The rule provides recommended best management practices, but does not require adherence to
these practices by the landowner.
With respect to stock pond management and maintenance, chemical control of aquatic vegetation
is allowed primarily because “it is unlikely that vegetation control would be needed during the
breeding period, as the primary time for explosive vegetation control is during the warm summer
months.” USFWS recommends chemical control measures be used only “outside of the general
breeding season (November through April) and juvenile stage (April through September) of the
CRLF.” Mechanical means are the preferred method of control. Pesticide applications for
mosquito control are also allowed because of concerns associated with human and livestock
health. Alternative mosquito control methods, primarily introduction of nonnative fish species,
are deemed potentially more detrimental to the CRLF than chemical or bacterial larvicides.
USFWS believes “it unlikely that [mosquito] control would be necessary during much of the
CRLF breeding season,” and that a combination of management methods, such as manipulation
of water levels, and/or use of a bacterial larvicide will prevent or minimize incidental take.
The special exemption rule also applies to rodent control. According to USFWS, the use of
rodenticides presents a low risk to CRLF conservation because the extent to which small
mammal burrows are essential for the conservation of CRLF is unknown. No data are available
to evaluate the potential effects of toxicant-treated grains (primarily anti-coagulants) on the
CRLF. Grain is not a typical food item for the CRLF, but individuals may be indirectly exposed
by consuming invertebrates which have ingested treated grain. In addition, there is a possibility
5
of dermal contact, especially when the grain is placed in the burrows. Athough placement of
treated grain into the burrows is not prohibited for rodent control, USFWS recommends bait-
station or broadcast application methods to reduce the probability of exposure. Use of burrow
fumigants is also not prohibited, but the Service recommends “not using burrow fumigants
within 0.7 mi (1.2 km) in any direction from a water body” suitable as CRLF habitat.
1.3.4 Other Known Occurrences from the California Natural Diversity Database (CNDDB)
The CNDDB provides location and natural history information on species found in California.
The CNDDB serves as a repository for historical and current species location sightings.
Information regarding known occurrences of CRLFs outside of the currently occupied core areas
and designated critical habitat is considered in defining the current range of the CRLF. See:
http://www.dfg.ca.gov/bdb/html/cnddb_info.html for additional information on the CNDDB.
1.3.5 CRLF Distribution Maps by Recovery Unit
The distribution of the CRLF, including currently occupied core areas (post-1985), designated
critical habitat, and known occurrences reported in the CNDDB that are not included within
occupied core areas and/or designated critical habitat, is depicted for all eight recovery units in
Figure 1.2. Additional maps depicting the CRLF distribution within each of the eight recovery
units are provided in Figures 1.3 through 1.10.
A summary of the currently occupied core areas and critical habitats that are included in each of
the eight recovery units is provided in Sections 1.3.5.1 through 1.3.5.8.
6
Figure 1.2. CRLF Recovery Units
1. Sierra Nevada Foothills and Central Valley

2. North Coast Range Foothills and Western
Sacramento River Valley
3. North Coast and North San Francisco Bay
5. Central Coast
7. Northern Transverse Ranges and Tehachapi
Mountains
8. Southern Transverse and Peninsular Ranges
Figure 1.2. CRLF Distribution within Recovery Units

Core Areas
1. Feather River 19. Watsonville Slough-Elkhorn Slough
2. Yuba River- S. Fork Feather River 20. Carmel River – Santa Lucia
3. Traverse Creek/ Middle Fork/ American R. Rubicon 21. Gablan Range
4. Cosumnes River 22. Estero Bay
5. South Fork Calaveras River* 23. Arroyo Grange River
6. Tuolumne River* 24. Santa Maria River – Santa Ynez River
7. Piney Creek* 25. Sisquoc River
8. Cottonwood Creek 26. Ventura River – Santa Clara River
9. Putah Creek – Cache Creek* 27. Santa Monica Bay – Venura Coastal Streams
10. Lake Berryessa Tributaries 28. Estrella River
11. Upper Sonoma Creek 29. San Gabriel Mountain*
12. Petaluma Creek – Sonoma Creek 30. Forks of the Mojave*
13. Pt. Reyes Peninsula 31. Santa Ana Mountain*
14. Belvedere Lagoon 32. Santa Rosa Plateau
15. Jameson Canyon – Lower Napa River 33. San Luis Ray*
16. East San Francisco Bay 34. Sweetwater*
17. Santa Clara Valley 35. Laguna Mountain
18. South San Francisco Bay
* Only currently occupied core areas are included in the map
7
1.3.5.1. Recovery Unit 1: Sierra Nevada Foothills and Central Valley
Recovery Unit 1 includes the western foothills and Sierra Nevada foothills to approximately
1,500 meters (5,000 feet) in elevation in the Central Valley hydrogeographic basin. As shown in
Table 1.1 and depicted in Figure 1.3, there are five currently occupied core areas and four critical
habitat units for the CRLF within Recovery Unit 1. Known occurrences of the CRLF have also
been reported in the CNDBB in Butte, Calaveras, El Dorado, Nevada, Placer, Plumas, Stanislaus,
and Yuba Counties.
Table 1.1. Currently Occupied Core Areas and Critical Habitat Units Within Recovery
Unit 1: Sierra Nevada Foothills and Central Valley
Currently Occupied Core Areas (Core Area Number) Critical Habitat Units
Feather River (1) BUT-1A-B
Yuba River-S. Fork Feather River (2) YUB-1
-- NEV-1*
Traverse Creek/Middle Fork American River/Rubicon (3) --
Consumnes River (4) ELD-1
East San Francisco Bay (partial)(16) --
*
Critical habitat units that are outside of core areas, but within recovery units.
8
Recovery Unit 1:
Sierra Nevada Foothills and Central Valley
Legend
D Recovery Unit 1
_ Curren~y O:rupied Core areas
_ Critical habitat
_ CN CO B Occurence Sections
D County boundaries
Note Labels indicate Occupied Core

Areas (by Unit Name) and o-itical
Habitat (by Unit Number)
1::lJ Miles
Rec ov ery Unit Map
Figure 1.3. CRLF Distribution Within Recovery Unit 1: Sierra Nevada Foothills and
Central Valley
9
1.3.5.2 . Recovery Unit 2: North Coast Range Foothills and Western Sacramento
River Valley
Recovery Unit 2 includes the North Coast Range Foothills and Western Sacramento River
Valley. As shown in Table 1.2 and depicted in Figure 1.4, there are four currently occupied core
areas and no critical habitat units for the CRLF within Recovery Unit 2. Known occurrences of
the CRLF have also been reported in the CNDBB in Marin and Tehama Counties.
Unit 2: North Coast Range Foothills and Western Sacramento River Valley
Cottonwood Creek (8) --
Jameson Canyon – Lower Napa Valley (partial) (15) --
Belvedere Lagoon (partial) (14) --
Pt. Reyes Peninsula (partial) (13) --
10
Recovery Unit 2: North Coast Range Foothills and
I
Legend
c:J Recovery Unit 2
_ Currently Occupied Core Areas
_ Critical Habitat
_ CNDDB Occurence Sections
County Boundary
c:J Recovery_zones selection
Note: Labels indicate Occupied
Core Areas
o 10 20 40 Miles
I I I I I I I
Pt. Reyes Peninsula
Figure 1.4. CRLF Distribution Within Recovery Unit 2: North Coast Range
Foothills and Western Sacramento River Valley
11
1.3.5.3 . Recovery Unit 3: North Coast and North San Francisco Bay
Recovery Unit 3 includes the North Coast and North San Francisco Bay. As shown in Table 1.3
and depicted in Figure 1.5, there are six currently occupied core areas and four critical habitat
units for the CRLF within Recovery Unit 3. Known occurrences of the CRLF have also been
reported in the CNDBB in Marin, Napa, Solano, and Sonoma Counties.
Significant numbers of CRLFs occur in small coastal drainages, ponds, and man-made stock
ponds near Point Reyes, and many areas near Mount Tamalpais and the Tiburon peninsula in
Marin County support CRLF populations. Sonoma County supports breeding populations and
occurrences have been reported in Solano County. However, most of the remaining known
occurrences in Solano County are threatened by proposed land development. (USFWS 2002)
Unit 3: North Coast and North San Francisco Bay
Lake Berryessa Tributaries (10) NAP-1
Upper Sonoma Creek (11) --
Petaluma Creek-Sonoma Creek (12) --
Pt. Reyes Peninsula (13) MRN-1, MRN-2
Belvedere Lagoon (14) --
Jameson Canyon-Lower Napa River (15) SOL-1
12
Recovery Unit 3: North Coast and
North San Francisco Bay
•
Lak e
Sonoma
Pt.
Rec overy Unit Map
Legend
c:J Rewvery Unit 3 ,,
_ CUlTen~y Occupied Core Neas
_ Critical Habitat
_ CNDDB Occurence Sections Note Labels indicate Occupied Core Areas

(by Unit Name) m d Critical H ooi tat (by Unit Number)
County Boundary
Figure 1.5. CRLF Distribution Within Recovery Unit 3: North Coast and North San
Francisco Bay
13
1.3.5.4. Recovery Unit 4: South and East San Francisco Bay
Recovery Unit 4 includes South and East San Francisco Bay. As shown in Table 1.4 and
depicted in Figure 1.6, there are two currently occupied core areas and six critical habitat units
for the CRLF within Recovery Unit 4. Known occurrences of the CRLF have also been reported
in the CNDBB in Alameda, Contra Costa, San Francisco, San Joaquin, San Mateo, Santa Clara,
and Stanislaus Counties.
The majority of CRLF localities within Recovery Unit 4 are in Contra Costa and Alameda
Counties; however, certain populations near urban areas seem to have been eliminated. Ponds
and creeks in Simas Valley support CRLFs and sizeable breeding populations are found at Pine
Creak, Sand Creek and Round Valley Creek. In eastern Contra Costa County, stockponds and
mitigation wetlands have reproducing populations of CRLFs, with recent surveys recording
nearly 3,000 individuals. (USFWS 2002)
Unit 4: South and East San Francisco Bay
-- CCS-1A*
East San Francisco Bay (partial) (16) ALA-1A, ALA-1B, STC-1B
-- STC-1A*
South San Francisco Bay (partial) (18) SNM-1A
*
14
Recovery Unit 4: South and East San Francisco Bay
East San
f
Rec overy Unit Map
Legend
D Recovery Unit 4
_ Curren~ y O:cupied Core Areas
_ o-itical Habitat
_ CN CO B O:curence Sections
County Boundaries
Note Labels indicate Occupied Core Areas (by Unit Nmcell
md o-itical Habitat (by Unit Number) ~ _ _ _ _ _ _ _ _ _~
Figure 1.6. CRLF Distribution Within Recovery Unit 4:

South and East San Francisco Bay
15
1.3.5.5. Recovery Unit 5: Central Coast
Recovery Unit 5 includes the central coast from San Francisco to Santa Barbara County. This
area supports the greatest number of currently occupied drainages (USFWS 2002). As shown in
Table 1.5 and depicted in Figure 1.7, there are six currently occupied core areas and six critical
been reported in the CNDBB in Monterey, San Luis Obispo, San Mateo, Santa Clara, and Santa
Cruz Counties.
Many coastal streams, ponds and tributaries, as well as State Reserves, in San Mateo County
support CRLFs. Almost all coastal drainages from the Santa Cruz/San Mateo County line south
to Santa Cruz are occupied by CRLFs. CRLFs are widespread in Monterey County. This
species is found in streams, stock ponds, dune ponds, and springs in San Luis Obispo County.
(USFWS 2002)
Table 1.5. Currently Occupied Core Areas and Critical Habitat Units within Recovery
Unit 5: Central Coast
South San Francisco Bay (partial) (18) SNM-1A, SNM-2C, SCZ-1
Watsonville Slough- Elkhorn Slough (partial) (19) SCZ-2
Carmel River-Santa Lucia (20) MNT-2
Estero Bay (22) --
-- SLO-8*
Arroyo Grande Creek (23) --
Santa Maria River-Santa Ynez River (24) --
*
16
Recovery Unit 5: Central Coast
Legend
D Recovery Unit 5
South San _ Current~ Occupied Core Area
Francisco
_ Critical Habitat
_ CN CO B Occurooce Sections
County BJundary
Note Labels indicate Occupied Core Ar eas
(by Unit Name) and Cri ti ca Habitat
(by Unit Number)
Wats onvill e Slough - 60 Miles
Elkho rn Slough
(S alina s Ri ver - Pajaro R;; '" '"
Re covery Unit Map
Carmel Ri ver
Santa Lu cia
,,
Arroyo Grande Creek
Santa Maria Ri ver - Santa Ynez - l
Figure 1.7. CRLF Distribution Within Recovery Unit 5: Central Coast
17
1.3.5.6. Recovery Unit 6: Diablo Range and Salinas Valley
Recovery Unit 6 includes the Diablo Range and Salinas Valley between the Salinas River system
and the San Joaquin Valley. As shown in Table 1.6 and depicted in Figure 1.8, there are six
currently occupied core areas and seven critical habitat units for the CRLF within Recovery Unit
6. Known occurrences of the CRLF have also been reported in the CNDBB in Fresno, Merced,
Monterey, San Benito, San Luis Obispo, and Santa Clara Counties. CRLFs were once
widespread in this region; however, no more than 10% of historic localities currently support this
species (USFWS 2002).
Table 1.6. Currently Occupied Core Areas and Critical Habitat Units within Recovery
Unit 6: Diablo Range and Salinas Valley
East San Francisco Bay (partial) (16) MER-1A-B, STC-1B
-- SNB-1*, SNB-2*
Santa Clara Valley (17) --
Watsonville Slough- Elkhorn Slough (partial)(19) MNT-1
Carmel River-Santa Lucia (partial)(20) --
Gablan Range (21) SNB-3
Estrella River (28) SLO-1A-B
*
18
Recovery Unit 6: Diablo Range and Salinas Valley
Legend
D Recovery Uni t 6
_ Currently O: cupi ed Core A reas
_ Critical Habi tat
_ CNCElS O:curence Sections

County Boundary
Note Labels indicate Occupied Core

Ar eas (by Unit Name) and Critical
Habit at (by Unit Number)
60 Miles
r
, ~ .~/(
I "'
/
Rec ov ery Unit Map
,,
Figure 1.8. CRLF Distribution Within Recovery Unit 6: Diablo Range and Salinas Valley
19
1.3.5.7. Recovery Unit 7: Northern Transverse Ranges and Tehachapi Mountains
Recovery Unit 7 includes the Northern Transverse Ranges and Tehachapi Mountains. As shown
in Table 1.7 and depicted in Figure 1.9, there are three currently occupied core areas and ten
critical habitat units for the CRLF within Recovery Unit 7. Known occurrences of the CRLF
have been reported in the CNDBB in Los Angeles, San Luis Obispo, Santa Barbara, and Ventura
Counties.
Within Santa Barbara County, CRLFs are found on the Santa Maria River and in the lower
drainage basin of San Antonio Creek, San Antonio Terrace, and San Antonio Lagoon. Much of
this area is occupied by an Air Force base where CRLFs are found in dune swale ponds. The
largest populations in this region are on upper Alamo Creek. In the lower Santa Ynez River
Basin, populations are smaller and patchily distributed. While populations have declined in
southern portions of the Los Padres National Forest, low numbers of CRLFs have persisted.
CRLFs still exist on Santa Cruz Island, though it is not certain whether they are naturally-
occurring or introduced. (USFWS 2002)
Unit 7: Northern Transverse Ranges and Tehachapi Mountains
-- SLO-8*
Santa Maria River-Santa Ynez River (24) STB-4, STB-5, STB-7
Sisquoc River (25) STB-1, STB-3
Ventura River-Santa Clara River (26) VEN-1, VEN-2, VEN-3
-- LOS-1*
*
20
Recovery Unit 7: Northern Transverse Range
and Tehachapi Mountains
Santa M aria ~:~:"!:...:::~

Santa Ynez-Ri ver
Rec ov ery Unit Map
60 Miles
Legend
D Recovery Unit 7
_ Currently O:rupied Core Areas
7
_ Critical Habitat
_ CN CO B o.xurence Sections
D County Boundary
Note Labels indicate Occupied Core Areas ,,
(by Unit Name) m d Crit ical Hooitat (by Unit Ne,cec"'1
Figure 1.9. CRLF Distribution Within Recovery Unit 7: Northern Transverse

Ranges and Tehachapi Mountains
21
1.3.5.8. Southern Transverse and Peninsular Ranges
Recovery Unit 8 includes the Southern Transverse and Peninsular Ranges. As shown in Table
1.8 and depicted in Figure 1.10, there are two currently occupied core areas and no critical
been reported in the CNDBB in Los Angeles, Riverside, San Bernardino, and Ventura Counties.
Historically, the CRLF was a common native frog in Los Angeles, San Bernadino, Orange,
Riverside, and San Diego Counties. Populations have drastically declined in these areas. Until a
sighting in 1999, CRLFs were considered extirpated from the Santa Monica Mountains. This
population is estimated at 20-25 breeding adults. South of the Tehachapi Mountains, CRLFs are
known in only a few locations, though historically, there were over 80 records from this region.
Populations in Riverside and San Diego Counties have not been observed since the 1960s.
Bullfrog introduction is blamed for population decline in Los Angeles and Riverside Counties.
(USFWS 2002)
Unit 8: Southern Transverse and Peninsular Ranges
Santa Monica Bay-Ventura Coastal Streams (27) --
Santa Rosa Plateau (32) --
22
Recovery Unit 8: Southern Transverse
and Peninsular Ranges
,~..." '{ Santa Monica Bay-

Ve ntura Coastal
•
Santa Ros a Plateau
Re cov ery Unit Map

00 Miles
Legend
D Recovery Unit 8
_ Critical Habitat
_ Currently Ocrupied Core Areas

_ CN COB Oxurence Sections
D County Boundary
Note Labels indicate Occupied

Core Areas (by Unit Name)
Figure 1.10. CRLF Distribution Within Recovery Unit 8:

Southern Transverse and Peninsular Ranges
23
1.4 Habitat
Most CRLF populations have been documented below 1,050 m, although there are some
historical sightings documented up to 1,500 m. CRLFs require aquatic habitat for breeding, but
also use other habitat types, including riparian and upland areas, throughout their life cycle.
CRLF use of their environment varies; they may complete their entire life cycle in a particular
habitat or they may utilize multiple habitat types. Overall, populations are most likely to exist
where multiple breeding areas are embedded within varying habitats used for dispersal (USFWS
2002). Generally, CRLFs utilize habitat with perennial or near-perennial water (Jennings et al.
1997), and dense vegetation close to water and shading water of moderate depth are habitat
features that appear especially important for CRLF (Hayes and Jennings 1988).
Hayes and Jennings (1988) recorded occurrences from two sites in California, and found that
CRLFs were primarily located in aquatic habitats with intermittent streams, which included some
area with water at least 0.7 meters deep, had emergent or shoreline vegetation, and lacked
introduced bullfrogs. Emergent vegetation consisted mainly of cattails (Typha spp.) and tules
(Scirpus spp.), while shoreline vegetation was primarily composed of willows (Salix spp.). They
report more findings of CRLFs at sites with native fish than those with introduced fish species.
CRLFs were also more frequently recorded at sites influenced by a small drainage area (< 40
km2), having a low slope, and with low-order streams (4th or below).
Breeding sites include streams, deep pools, backwaters within streams and creeks, ponds,
marshes, sag ponds (land depressions between fault zones that have filled with water), dune
ponds, and lagoons. Breeding adults have been found near deep (0.7 m) still or slow moving
water surrounded by dense vegetation (USFWS 2002). There is a long larval period and
subsequent to hatching, larvae inhabit shallow (0.26-0.5 m) water adjacent to the main pond
(Storer 1925). CRLFs are also found and breed in manmade waters, such as stock ponds, sewage
treatment ponds, and artificial (concrete) pools without vegetation (Jennings, et al 1997). Data
indicate that CRLFs do not frequently inhabit vernal pools, as conditions in these habitats
generally are not suitable (Hayes and Jennings 1988).
CRLFs are more often found in habitats without introduced predators, such as centrarchid fish
(e.g., largemouth bass), green sunfish, bluegill, crayfish, and bullfrogs (Jennings et al. 1997;
Hayes and Jennings 1988). CRLFs are largely restricted to freshwater or slightly brackish water
(< 9.0% salinity). Juvenile CRLFs are active during the day and night, and may be found sunning
themselves on floating vegetation, while adults are mainly nocturnal (Jennings et al. 1997).
In general, dispersal and habitat use depends on climatic conditions, habitat suitability, and life
stage. Adults rely on riparian vegetation for resting, feeding, and dispersal. The foraging quality
of the riparian habitat depends on moisture, composition of the plant community, and presence of
pools and backwater aquatic areas for breeding. During wet periods, adults can be found to
move long distances (1.6 km) between aquatic habitats (Jennings et al. 1997). Winter habitats
vary with locality, but generally, CRLFs seek habitat where ponds do not freeze, and dispersal
seems limited and rare (Storer 1925).
24
During dry periods, the CRLF is rarely found far from water, although it will sometimes disperse
from its breeding habitat to forage and seek other suitable habitat under downed trees or logs,
industrial debris, and agricultural features (UWFWS 2002). According to Jennings and Hayes
(1994), CRLFs also use small mammal burrows and moist leaf litter as habitat. In addition,
CRLFs may also use large cracks in the bottom of dried ponds as refugia; these cracks may
provide moisture for individuals avoiding predation and solar exposure (Alvarez 2000).
1.5. Life History and Ecology
Information on the life history and ecology of the CRLF, including diet, reproduction, diseases,
predators, and threats, is provided in Sections 1.5.1 through 1.5.5.
1.5.1. Diet
In general, larvae may graze on algae but they are rarely observed in the field; post-metamorphic
CRLFs feed on a variety of invertebrates and grow rapidly; and adults feed on invertebrates,
small fish, frogs, and small mammals (Jennings, et al 1997). Juveniles eat day and night, while
sub-adults and adults feed primarily at night, corresponding to periods of activity (Hayes and
Tennant 1985). Although the diet of CRLF aquatic-phase larvae (tadpoles) has not been
specifically studied, it is assumed that their diet is similar to that of other frog species, with the
aquatic-phase feeding exclusively in water and consuming diatoms, algae, and detritus (USFWS
2002).
Juvenile and adult CRLFs forage in aquatic and terrestrial habitats. The main food source for
juvenile aquatic- and terrestrial-phase CRLFs is thought to be aquatic and terrestrial invertebrates
found along the shoreline and on the water surface. Hayes and Tennant (1985) report, based on a
study examining the gut content of 35 juvenile and adult CRLFs, that the species feeds on as
many as 42 different invertebrate taxa. Most frequently encountered were: carabid (11) and
tenebrionid (9) beetles; water striders (9); lycosid spiders (7); larval neuropterans (e.g.,
alderflies) (7). Only large CRLFs ate large prey, suggesting that a greater range of prey sizes are
available to larger frogs. For larger CRLFs, over 50% of the prey mass may consists of
vertebrates such as mice, frogs, and fish, although aquatic and terrestrial invertebrates were the
most numerous food items. This study reported no observations of attempts to capture prey
underwater, suggesting that CRLFs forage primarily above water, although the authors note other
data reporting that adults also feed under water. In addition, there is no information on the
relative percentage of various food items in the diet of aquatic- and terrestrial-phase CRLFs.
1.5.2. Reproduction
CRLFs breed primarily in ponds; however, they may also breed in quiescent streams, marshes,
and lagoons (Fellers 2005a). According to the Recovery Plan (USFWS 2002), CRLFs breed
from November through late April. Spawning generally occurs at night (Storer 1925). Peaks in
spawning activity vary geographically; Fellers (2005b) reports peak spawning as early as January
in parts of coastal central California. Male frogs call in small mobile groups of 3-7 individuals
and females move towards males to initiate amplexus (copulatory position during which males
fertilize eggs released by a female). After amplexus, females move to oviposition sites (Jennings
25
et al. 1997), where eggs are attached to emergent vegetation, such as bulrushes (Scirpus spp.)
and cattails (Typha spp.) or roots and twigs, and float on or near the surface of the water (Hayes
and Miyamoto 1984). Egg masses contain approximately 2000 to 6000 eggs ranging in size
between 2 and 2.8 mm (Jennings and Hayes 1994). After oviposition, females move
immediately to foraging sites, while males typically remain near the breeding site for a few
weeks before moving to foraging areas (Jennings et al. 1997).
Embryos hatch 10 to 14 days after fertilization (Fellers 2005a) depending on water temperature.
Egg predation is reported to be infrequent and most mortality is associated with the larval stage
(particularly through predation by fish); however, predation on eggs by newts has also been
reported (Rathburn 1998). Tadpoles require 11 to 28 weeks to metamorphose into juveniles
(terrestrial-phase), typically between May and September (Jennings and Hayes 1994; USFWS
2002); tadpoles have been observed to over-winter (delay metamorphosis until the following
year) (Fellers 2005b; USFWS 2002). Males reach sexual maturity at 2 years, and females reach
sexual maturity at 3 years of age, depending on resource availability (Jennings et al. 1997);
adults have been reported to live 8 to 10 years (USFWS 2002). Figure 1.11 depicts CRLF
annual reproductive timing.
Figure 1.11. CRLF Reproductive Events by Month
J F M A M J J A S O N D
Light Blue = Breeding/Egg Masses

Green = Tadpoles (except those that over-winter)
Orange = Young Juveniles (sub-adults)
Adults and juveniles can be present all year
1.5.3. Diseases
While pathogens and parasites have been linked to population declines in other frog species,
there is limited research on how disease may affect the CRLF. It has been hypothesized that
environmental factors, including radiation and air pollutants can cause a weakening of the CRLF
immune system, making them more susceptible to disease. It is also hypothesized that
introduced trout may carry diseases that attack and kill amphibian eggs and larvae. There is a
noted high incidence of parasites in bullfrogs that coexist with the CRLF, though the parasites
have not been documented in the CRLF.
Chytrid fungus (Batrachochytrium dendrobatidis) is found in numerous amphibian species

whose populations are declining. Symptoms include deformed mouthparts in tadpoles, and most
infected tadpoles die when they metamorphose. Chytrids are naturally occurring and widespread
in the environment. They reproduce asexually by spores, and are likely spread in amphibian
populations through water. Chytrid fungus was first identified in 1998 as the cause of boreal
toad and other amphibian die-offs. In the Sierra Nevadas, the yellow-legged frog and the
Yosemite toad have both been observed to be infected by a chytrid fungus. There are reports of
CRLFs with chytrid fungus; however, the effect the chytrid fungus has on CRLF population
26
decline is unclear. The chytrid fungus has been suggested as key cause in the decline of
amphibian populations worldwide (USFWS 2002).
1.5.4. Predators
Introduced bullfrogs, crayfish, and certain centrarchid fish species (e.g., largemouth bass) have
been a significant factor in the decline of the CRLF (Jennings et al. 1997). Habitat changes that
are favorable for bullfrogs are generally unfavorable to CRLF, and researchers have noted
declines in CRLF populations when bullfrogs coexist (Hayes and Jennings 1988). Bullfrogs also
prey on CRLF and may have a competitive advantage because of larger size, more generalized
food habits, an extended breeding season, and less predation on their larvae (unpalatable).
Delayed metamorphasis has been observed in ponds with bullfrog tadpoles present (Hayes and
Jennings 1988).
Native predators to the CRLF include: raccoons, great blue herons, American bitterns, black-
crowned night herons, red-shouldered hawks, and garter snakes (Jennings et al. 1997). Natural
predation could be exacerbated by the release of these species into riparian areas after capture
from urban environments. Some native fish eat tadpoles. Rathbun (1998) has also noted newt
predation on CRLF eggs and tadpoles.
1.5.5. Threats
The USFWS Recovery Plan (2002) lists the following threats to CRLF populations:
(1) The present or threatened destruction, modification, or curtailment of habitat or range
a. curtailment of range and alteration, fragmentation, degradation, and loss of habitat
b. urbanization
c. agriculture
d. impoundments and water management
e. channelization and flood control
f. mining
g. livestock grazing and dairy farming
h. recreation and off-road vehicles
i. timber harvesting
(2) Overutilization for commercial, recreational, scientific, or education purposes
a. exploitation
b. scientific take
(3) Diseases and predation
a. disease
b. predation by introduced species
c. predation by native species
(4) The inadequacy of existing regulatory mechanisms
(5) Other natural, or manmade factors affecting their continued existence
a. drought
b. contaminants
27
In summary, threats to the CRLF include: habitat loss or modification (e.g., agriculture,
urbanization, grazing, mining), disease and predation, and predation and competition from
nonnative species. Disease and predation have been discussed specifically above (Sections
1.5.3-1.5.4). Table 1.9 (below) lists the major threats to the CRLF by recovery unit (USFWS
2002). It should be noted, however, that threats to the CRLF associated with disease and fungal
pathogens such as the chytrid fungus are not addressed in this table.
Table 1.9. Threats to and recovery status of CRLF per Recovery Unit
Recovery Unit Threat Recovery

Status
1. Sierra Nevada Foothills and Central Valley Ag, Li, Mi, Nn, Re, Ti, Ur, Low
Wa
2. North Coast Range Foothills and Western Ag, Li, Nn, Ti, Ur Low
Sacremento River Valley
3. North Coast and North Francisco Bay Li, Nn, Ur, Wa High
4. South and East San Francisco Bay Li, Nn, Ur, Wa High
5. Central Coast Ag, Li, Mi, Nn, Re, Ti, Ur, High
Wa
6. Diablo Range and Salinas Valley Ag. Li, Mi, Nn, Re, Ur, Wa Med
7. Northern Transverse Range and Tehachapi Ag, Mi, Nn, Re, Wa High
Mountains
8. Southern Transverse and Peninsular Ranges Ag, Li, Mi, Nn, Re, Ur, Wa Low
Threats: Ag = Agriculture, Nn = Non-native species, Li = Livestock (cattle grazing and/or dairies), Mining
= Mi, Re = Recreation, Ti = Timber, Ur = Urbanization, Wa = Water Management/Diversions/Reservoirs
Recovery Status:
Low: Few existing populations, high levels of threats and, in general, medium habitat suitability
Med: Numerous existing populations, some areas of medium habitat suitability, high levels of threats
High: Many existing populations, many areas of high habitat suitability, low to high levels of threats
28
References
California Natural Diversity Data Base (CNDDB). 2001. Natural Heritage Division. California
Department of Fish and Game. Natural Heritage Division, Sacramento, California.
http://www.dfg.ca.gov/bdb/html/cnddb_info.html
Fellers, Gary M. 2007. Personal communication. Biological Resources Division, U.S. Geological
Survey.
Fellers, Gary M. 2005a. Rana draytonii Baird and Girard 1852. California Red-legged Frog.
Pages 552-554. In M. Lannoo (ed.) Amphibian Declines: The Conservation Status of
United States Species, Vol. 2: Species Accounts. University of California Press,
Berkeley, California. xxi+1094 pp. (http://www.werc.usgs.gov/pt-
reyes/pdfs/Rana%20draytonii.PDF)
Fellers, Gary M. 2005b. California red-legged frog, Rana draytonii Baird and Girard. Pages 198-
201. In L.L.C. Jones, et al (eds.) Amphibians of the Pacific Northwest. xxi+227.
Fellers, G.M. and G. Guscio. 2004. California red-legged frog surveys of lower Redwood Creek,
Golden Gate National Recreation Area. Prepared for the National Park Service. 65pp.
(http://www.werc.usgs.gov/pt-reyes/pdfs/Redwood%20Creek%20Report.pdf)
Hayes, M.P. and M.R. Jennings. 1988. Habitat correlates of distribution of the California red-
legged frog (Rana aurora draytonii) and the foothill yellow-legged frog (Rana boylii):
Implications for management. Pp. 144-158. In Proceedings of the symposium on the
management of amphibians, reptiles, and small mammals in North America. R. Sarzo,
K.E. Severson, and D.R. Patton, (technical coordinators). USDA Forest Service General
Technical Report RM-166.
Hayes, M.P. and M.M. Miyamoto. 1984. Biochemical, behavioral and body size difference
between Rana aurora aurora and R.a. draytonii. Copeia 1984(4):1018-1022.
Hayes, M.P. and M.R. Tennant. 1985. Diet and feeding behavior of the California red-legged
frog. The Southwestern Naturalist 30(4): 601-605.
Jennings, Mark R. 1988. Natural history and decline of native ranids in California. Pp. 61-72. In
Proceedings of the conference on California herpetology. H.F. DeLisle, P.R. Brown, B.
Kaufman, and H.M. McGurty (eds). Southwestern Herpetologists Society Special
Publication (4): 1-143.
Jennings, M.R. and M.P. Hayes. 1994. Amphibian and reptile species of special concern in
California. Report prepared for the California Department of Fish and Game, Inland
Fisheries Division, Rancho Cordova, California. 255 pp.
29
Jennings, M.R., S. Townsend, and R.R. Duke. 1997. Santa Clara Valley Water District
California red-legged frog distribution and status – 1997. Final Report prepared by H.T.
Harvey & Associates, Alviso, California. 22 pp.
Rathburn, G.B. 1998. Rana aurora draytonii egg predation. Herpetological Review, 29(3): 165.
Storer, T.I. 1925. A synopsis of the amphibia of California. University of California Publications
in Zoology 27:1-342.
U.S. Fish and Wildlife Service (USFWS). 1996. Endangered and threatened wildlife and plants:
determination of threatened status for the California red-legged frog. Federal Register
61(101):25813-25833.
U.S. Fish and Wildlife Service (USFWS). 2002. Recovery Plan for the California Red-legged
Frog (Rana aurora draytonii). USFWS, Region 1. Portland, Oregon. viii + 173 pp.
(http://ecos.fws.gov/doc/recovery_plans/2002/020528.pdf)
determination of critical habitat for the California red-legged frog. 71 FR 19243-19346.
30
Risks of Dimethoate Use to the Federally-Listed
California Red Legged Frog
(Rana aurora draytonii)
Pesticide Effects Determination
Environmental Fate and Effects Division

Office of Pesticide Programs
Washington, D.C. 20460
January 31, 2008
Page 1 of 137
Primary Authors
Kristina Garber, Biologist
Thomas Steeger, Ph.D., Senior Biologist
Reviewers
Anita Pease
Senior Biologist, Environmental Risk Branch 4
Elizabeth Behl
Branch Chief, Environmental Risk Branch 4
Page 2 of 137
Acknowledgement
The dimethoate chemical team would like to acknowledge the contribution of the California red-
legged frog Steering Committee in compiling detailed information on the threatened species.
Additionally, the Steering Committee has provided invaluable guidance toward achieving greater
consistency in format and content between chemicals being assessed. We acknowledge Dr. R.
David Jones’ work modeling exposures due to spray drift. We acknowledge the contribution of
Ms. Michelle Thawley, Mr. Kurt Pluntke and Ms. Megan Thynge in providing the Geographic
Information System analysis used to define the potential overlap between the California red-
legged frog and its designated critical habitat within the action area.
Page 3 of 137
Table of Contents
ACKNOWLEDGEMENT.............................................................................................................................................3
TABLE OF CONTENTS ..............................................................................................................................................4
APPENDICES...............................................................................................................................................................5
ATTACHMENTS .........................................................................................................................................................5
LIST OF FIGURES .......................................................................................................................................................5
LIST OF TABLES.........................................................................................................................................................6
1. EXECUTIVE SUMMARY..................................................................................................................................9
1. EXECUTIVE SUMMARY..................................................................................................................................9
2. PROBLEM FORMULATION...........................................................................................................................15
2.1 PURPOSE....................................................................................................................................................15
2.2 SCOPE........................................................................................................................................................17
2.3 PREVIOUS ASSESSMENTS...........................................................................................................................18
2.4 STRESSOR SOURCE AND DISTRIBUTION .....................................................................................................19
2.4.1 Environmental Fate and Transport Assessment ..................................................................................19
2.4.2 Mechanism of Action ...........................................................................................................................22
2.4.3 Use Characterization...........................................................................................................................22
2.5 ASSESSED SPECIES ....................................................................................................................................25
2.5.1 Distribution ...........................................................................................................................................26
2.5.2 Reproduction........................................................................................................................................31
2.5.3 Diet ......................................................................................................................................................32
2.5.4 Habitat .................................................................................................................................................32
2.6 DESIGNATED CRITICAL HABITAT ..................................................................................................................33
2.7 ACTION AREA ...........................................................................................................................................35
2.8 ASSESSMENT ENDPOINTS AND MEASURES OF ECOLOGICAL EFFECT .........................................................39
2.8.1 Assessment Endpoints for the CRLF ......................................................................................................39
2.8.2. Assessment Endpoints for Designated Critical Habitat.......................................................................40
2.9 CONCEPTUAL MODEL................................................................................................................................42
2.9.1 Risk Hypotheses ...................................................................................................................................42
2.9.2 Diagram...............................................................................................................................................43
2.10 ANALYSIS PLAN ..............................................................................................................................................46
2.10.1. Measures to Evaluate the Risk Hypothesis and Conceptual Model .......................................................47
3. EXPOSURE ASSESSMENT .................................................................................................................................51
3.1 AQUATIC EXPOSURE ASSESSMENT ...................................................................................................................51
3.1.1 Existing Water Monitoring Data for California......................................................................................51
3.1.2. Modeling Approach..................................................................................................................................53
3.1.3. Aquatic Modeling Results.........................................................................................................................61
3.2. TERRESTRIAL EXPOSURE ASSESSMENT ............................................................................................................63
3.2.1. Modeling Approach..................................................................................................................................63
3.2.2. Terrestrial Animal Exposure Modeling Results .......................................................................................65
3.2.3. Spray Drift Modeling ...............................................................................................................................67
4. EFFECTS ASSESSMENT.................................................................................................................................70
4.1. EVALUATION OF AQUATIC FRESHWATER ECOTOXICITY STUDIES FOR DIMETHOATE .......................................71
4.1.1. Toxicity to Freshwater Fish .....................................................................................................................73
4.1.2. Toxicity to Aquatic-phase Amphibians.....................................................................................................73
4.1.3. Toxicity to Freshwater Invertebrates .......................................................................................................73
Page 4 of 137
4.1.4. Toxicity to Aquatic Plants ........................................................................................................................73
4.2. EVALUATION OF TERRESTRIAL ECOTOXICITY STUDIES FOR DIMETHOATE .......................................................74
4.2.1. Toxicity to Birds .......................................................................................................................................77
4.2.2. Toxicity to Terrestrial-phase Amphibians................................................................................................77
4.2.3. Toxicity to Mammals ................................................................................................................................77
4.2.4. Toxicity to Terrestrial Invertebrates ........................................................................................................77
4.2.5. Toxicity to Terrestrial Plants ...................................................................................................................77
4.3. COMPARISON OF TOXICITIES OF DIMETHOATE AND OMETHOATE ......................................................................78
4.3.1. Aquatic organisms....................................................................................................................................78
4.3.2. Terrestrial organisms...............................................................................................................................78
5.1. RISK ESTIMATION .............................................................................................................................................80
5.1.1. Exposures in the Aquatic Habitat.............................................................................................................80
5.1.2. Exposures in the Terrestrial Habitat........................................................................................................84
5.2. RISK DESCRIPTION ............................................................................................................................................88
5.2.1. Direct Effects............................................................................................................................................89
5.2.2. Indirect Effects (through effects to prey)................................................................................................101
5.2.3. Indirect Effects (through effects to habitat) ...........................................................................................112
5.2.4. Primary Constituent Elements of Designated Critical Habitat..............................................................113
5.2.5. Action Area ............................................................................................................................................114
5.2.6. Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps..............................122
5.2.7. Addressing the Risk Hypotheses.............................................................................................................127
6. CONCLUSIONS ...................................................................................................................................................128
7. REFERENCES ......................................................................................................................................................130
Appendices
Appendix A. Use Closure Memo for Dimethoate

Appendix B. Analysis of dimethoate use in California over 2001-2005
Appendix C. Detailed analysis of final dimethoate action area and overlap of action area with CRLF core areas and
critical habitat
Appendix D. Output files from PRZM/EXAMS modeling
Appendix E. Example output from T-REX v.1.3.1 model
Appendix F. List of citations accepted and rejected by ECOTOX criteria
Appendix G. The Risk Quotient Method and Levels of Concern
Appendix H. Ecological incidents associated with dimethoate
Appendix I. Output from T-HERPS v.1.0 model
Appendix J. Individual Effect Analysis
Appendix K. Review of ECOTOX database for dimethoate and omethoate
Attachments
Attachment 1: Status and Life History of California Red-legged Frog

Attachment 2: Baseline Status and Cumulative Effects for the California Red-legged Frog
List of Figures
Figure 1. Historical Extent (2002) of dimethoate usage. ............................................................................ 25

Figure 2. Recovery Unit, Core Area, Critical Habitat, and Occurrence Designations for CRLF. .............. 30
Figure 3. CRLF Reproductive Events by Month. ....................................................................................... 31
Page 5 of 137
Figure 4. Initial area of concern for crops described by agricultural landcover which corresponds to
potential dimethoate use sites. This map represents the area potentially directly affected by the federal
action........................................................................................................................................................... 37
Figure 5. Initial area of concern for crops described by orchard, vineyard and forestry landcover which
corresponds to potential dimethoate use sites. This map represents the area potentially directly affected by
the federal action......................................................................................................................................... 38
Figure 6. Conceptual model for potential effects of dimethoate on the aquatic phase of the California red-
legged frog. ................................................................................................................................................. 43
Figure 7. Conceptual model for the potential effects of dimethoate on the terrestrial phase of the
California red-legged frog........................................................................................................................... 44
Figure 8. Conceptual model for the potential effects of dimethoate on aquatic components of the
California red-legged frog critical habitat................................................................................................... 45
Figure 9. Conceptual model for the potential effects of dimethoate on terrestrial components of the
California red-legged frog critical habitat................................................................................................... 46
Figure 10. CDPR reported concentrations of dimethoate in surface waters in CA (includes detections and
non-detections, which are represented as 0). .............................................................................................. 53
Figure 11. Chance of individual mortality to terrestrial-phase CRLF when considering acute dose-based
RQs. ............................................................................................................................................................ 97
Figure 12. Chance of individual mortality to terrestrial-phase CRLF when considering acute dietary-based
RQs. ............................................................................................................................................................ 98
Figure 13. Final action area for crops described by agricultural landcover which corresponds to potential
dimethoate use sites. This map represents the area potentially directly and indirectly affected by the
federal action............................................................................................................................................. 117
Figure 14. Final action area for crops described by orchard, vineyard and forest landcover which
corresponds to potential dimethoate use sites. This map represents the area potentially directly and
indirectly affected by the federal action. *Within recovery units. ............................................................ 118
List of Tables
Table 1. Dimethoate Effects Determination Summary for the California Red-legged Frog. ..................... 12
Table 2. Potential risks directly to prey of CRLF due to dimethoate exposures from specific uses (yes or
no).* ............................................................................................................................................................ 13
Table 3. Environmental fate and transport data for dimethoate.................................................................. 19
Table 4. Foliar dissipation data for dimethoate........................................................................................... 21
Table 5. Methods and rates of application of currently registered used of dimethoate in California. ........ 24
Table 6. California Red-legged Frog Recovery Units with Overlapping Core Areas and Designated
Critical Habitat............................................................................................................................................ 28
Table 7. Dimethoate uses and their respective GIS landcovers used to depict the initial dimethoate area of
concern for this assessment......................................................................................................................... 36
Table 8. Summary of Assessment Endpoints and Measures of Ecological Effects for Direct and Indirect
Effects of Dimethoate on the California Red-legged Frog. ........................................................................ 40
Table 9. Summary of Assessment Endpoints and Measures of Ecological Effect for Primary Constituent
Elements of Designated Critical Habitat..................................................................................................... 41
Table 10. Agency risk quotient (RQ) metrics and levels of concern (LOC) per risk class......................... 50
Table 11. PRZM scenario assignments according to uses of dimethoate. .................................................. 54
Table 12. PRZM/EXAMS input parameters............................................................................................... 57
Table 13. Use specific parameters used to model aquatic EECs using PRZM/EXAMS............................ 58
Table 14. Application dates for PRZM/EXAMS simulations for modeling associated with dimethoate
uses.............................................................................................................................................................. 59
Page 6 of 137
Table 15. One-in-ten-year dimethoate EECs for aquatic environments from the application of dimethoate
to uses in California. ................................................................................................................................... 62
Table 16. Input parameters for foliar applications used to derive terrestrial EECs for dimethoate with T-
REX. ........................................................................................................................................................... 64
Table 17. Upper-bound Kenaga nomogram EECs for dietary- and dose-based exposures of the CRLF and
its prey to dimethoate.................................................................................................................................. 66
Table 18. Scenario and standard management input parameters for simulation of dimethoate in spray drift
using AgDisp with Gaussian far-field extension. ....................................................................................... 68
Table 19. AgDrift Input parameters that vary with crop and formulation are used for estimating drift from
one application of dimethoate. .................................................................................................................... 68
Table 20. Distance from the edge of the treated field to get below LOC for crops with aerial spray
application of dimethoate............................................................................................................................ 69
Table 21. Summary of most sensitive toxicity endpoint for assessing direct and indirect effects of
dimethoate to CRLF in aquatic habitats. Study classifications based on EFED’s ecotoxicity database. ... 72
Table 22. Categories of Acute Toxicity for Aquatic Organisms. ............................................................... 72
Table 23. Summary of most sensitive toxicity for assessing direct and indirect effects of dimethoate to
CRLF in terrestrial habitats. Study classifications based on EFED’s ecotoxicity database........................ 75
Table 24. Categories for mammalian acute toxicity based on median lethal dose in mg per kilogram body
weight (parts per million)............................................................................................................................ 76
Table 25. Categories of avian acute oral toxicity based on median lethal dose in milligrams per kilogram
body weight (parts per million)................................................................................................................... 76
Table 26. Categories of avian subacute dietary toxicity based on median lethal concentration in
milligrams per kilogram diet per day (parts per million)............................................................................ 76
Table 27. Comparison of toxicities of technical dimethoate and omethoate to aquatic organisms (units in
mg/L). ......................................................................................................................................................... 78
Table 28. Comparison of acute oral toxicities (LD50, units in mg/kg) of technical dimethoate and
omethoate to birds....................................................................................................................................... 79
Table 29. Risk Quotient values for acute and chronic exposures directly to the CRLF in aquatic habitats.
.................................................................................................................................................................... 81
Table 30. Risk Quotient values for indirect effects to aquatic-phase CRLF due to effects to its prey. ...... 83
Table 31. Acute and chronic, dietary-based RQs and dose-based RQs for direct effects to the terrestrial-
phase CRLF. RQs calculated using T-REX................................................................................................ 85
Table 32. RQs for determining indirect effects to the terrestrial-phase CRLF through effects to potential
prey items, specifically terrestrial invertebrates.......................................................................................... 86
prey items, specifically terrestrial mammals............................................................................................... 87
Table 34. Revised dose-based RQs1 for 1.4 g CRLF consuming different food items. EECs calculated
using T-HERPS........................................................................................................................................... 91
Table 35. Revised dose-based RQs1 for 37 g CRLF consuming different food items. EECs calculated
using T-HERPS........................................................................................................................................ 92
Table 36. Revised dose-based RQs1 for 238 g CRLF consuming different food items. EECs calculated
using T-HERPS........................................................................................................................................... 93
Table 37. Revised acute dietary-based RQs1 for CRLF consuming different food items. EECs calculated
using T-HERPS........................................................................................................................................... 94
Table 38. Single aerial application rate not exceeding acute LOC for dietary- and dose-based exposures of
the CRLF to dimethoate.............................................................................................................................. 95
Table 39. Single ground application rate not exceeding acute LOC for dietary- and dose-based exposures
of the CRLF to dimethoate. ........................................................................................................................ 96
Table 40. Revised chronic dietary-based RQs1 for CRLF consuming different food items. EECs calculated
using T-HERPS......................................................................................................................................... 100
Page 7 of 137
Table 41. RQs and associated likelihood of individual effects to aquatic invertebrates due to dimethoate
exposures. ................................................................................................................................................. 102
Table 42. Acute dose-based RQs and associated likelihood of individual effects to terrestrial mammals
due to dimethoate exposures. .................................................................................................................... 105
Table 43. Acute dose-based RQs and associated likelihood of individual effects to terrestrial-phase frogs
(prey) due to dimethoate exposures. ......................................................................................................... 107
Table 44. Acute dietary-based RQs and associated likelihood of individual effects to terrestrial-phase
frogs (prey) due to dimethoate exposures. ................................................................................................ 109
Table 45. Potential for risk to prey of CRLF due to dimethoate exposures from specific uses (yes or no).
This information is used to determine whether effects of dimethoate on these prey will indirectly affect
the CRLF................................................................................................................................................... 111
Table 46. Down stream dilution factors used to determine extent of lotic action area for uses of
dimethoate................................................................................................................................................. 114
Table 47. Quantitative results of spatial analysis of lotic aquatic action area relevant to dimethoate uses
(in km)....................................................................................................................................................... 115
Table 48. Spray drift distances used to determine extent of action area for uses of dimethoate. ............ 115
Table 49. Overlap between CRLF habitat (core areas and critical habitat) and agricultural action area by
recovery unit (RU#). ................................................................................................................................. 119
Table 50. Overlap between CRLF habitat (core areas and critical habitat) and orchard, vineyard and
forestry action area by recovery unit (RU#). ............................................................................................ 119
Table 51. Reported county level uses of dimethoate in California during 2002-2005 and their relation to
presence or absence of CRLF critical habitat or core areas within the county. ........................................ 120
Table 52. 1-in-10 year peak estimates of dimethoate concentrations in aquatic and terrestrial habitats
resulting from deposition of dimethoate at 0.102 µg/L dimethoate in rain. ............................................. 125
Page 8 of 137
1. Executive Summary
The purpose of this assessment is to evaluate potential direct and indirect effects on the
California red-legged frog (Rana aurora draytonii) (CRLF) arising from FIFRA regulatory
actions regarding use of dimethoate on agricultural and non-agricultural sites. In addition, this
assessment evaluates whether these actions can be expected to result in the destruction or
modification of the species’ designated critical habitat. This assessment was completed in
accordance with the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries
Service (NMFS) Endangered Species Consultation Handbook (USFWS/NMFS 1998) and
procedures outlined in the Agency’s (i.e. the EPA) Overview Document (U.S. EPA 2004).
The CRLF was listed as a threatened species by USFWS in 1996. The species is endemic to
California and Baja California (Mexico) and inhabits both coastal and interior mountain ranges.
A total of 243 streams or drainages are believed to be currently occupied by the species, with the
greatest numbers in Monterey, San Luis Obispo, and Santa Barbara counties (USFWS 1996) in
California.
Dimethoate is nationally registered for over 40 uses in agriculture and ornamental production.
Aerial applications are allowed for all uses, with the exception of citrus, Brussels sprouts, and
outdoor nursery. From 2001-2005, the percentage of total dimethoate use in California was
highest on alfalfa (19.7% of total use), tomato (13.5%), beans (11.3%), broccoli (10.6%), corn
(9.3%), citrus (8.4%), lettuce (7.5%) and cotton (7.1%). Use data from 2001-2005 for California
indicate that dimethoate is applied throughout the year, with the majority of applications
occurring during the summer months (June-August). The overall annual average for reported
uses in California over this three year period was 249,405 lbs.
The environmental fate properties of dimethoate along with monitoring data identifying its
presence in surface waters in California indicate that dimethoate has the potential to be
transported to non-target areas. In this assessment, transport of dimethoate from initial
application sites via runoff and spray drift are considered in deriving quantitative estimates of
dimethoate exposure to CRLF, its prey and its habitats.
Since CRLFs exist within aquatic and terrestrial habitats, exposure of the CRLF, its prey and its
habitats to dimethoate are assessed separately for the two habitats. Tier-II exposure models
(PRZM and EXAMS) are used to estimate high-end exposures to aquatic habitats resulting from
runoff and spray drift from different uses. Peak model-estimated aquatic environmental
concentrations, resulting from different dimethoate uses, range from 0.1 to 20.3 µg/L. These
estimates are supplemented with analysis of available California surface water monitoring data
from U. S. Geological Survey’s National Water Quality Assessment (NAWQA) program and the
California Department of Pesticide Regulation. The maximum concentration of dimethoate
reported by NAWQA from 2001-2006 for California surface waters is 0.158 µg/L. This value is
two orders of magnitude less than the maximum model-estimated environmental concentration
(which corresponds to use on cottonwoods), but is within the range of environmental
concentrations estimated for different uses. The maximum concentration of dimethoate reported
by the California Department of Pesticide Regulation surface water database from 1991-2005
Page 9 of 137
(11.31 µg/L) is on the same order of magnitude when compared to the highest peak model-
estimated environmental concentration.
The T-REX model is used to estimate dimethoate exposures to terrestrial-phase CRLF, its
potential prey and its habitat resulting from uses involving foliar applications. T-HERPS is used
to further characterize exposures of terrestrial-phase CRLF to dietary and dose-based exposures
of dimethoate resulting from foliar applications. AgDRIFT and AGDISP are also used to
estimate deposition of dimethoate on terrestrial and aquatic habitats from spray drift.
The assessment endpoints for the CRLF include direct toxic effects on the survival, reproduction,
and growth of the CRLF itself, as well as indirect effects, such as reduction of the prey base
and/or modification of its habitat. Direct effects to the CRLF in the aquatic habitat are based on
toxicity information for freshwater fish, which are generally used as a surrogate for aquatic-
phase amphibians. In the terrestrial habitat, direct effects are based on toxicity information for
birds, which are used as a surrogate for terrestrial-phase amphibians. Given that the CRLF’s prey
items and designated critical habitat requirements in the aquatic habitat are dependant on the
availability of freshwater aquatic invertebrates and aquatic plants, toxicity information for these
taxonomic groups is also discussed. In the terrestrial habitat, indirect effects due to depletion of
prey are assessed by considering effects to terrestrial insects, small terrestrial mammals and
frogs. Indirect effects due to modification of the riparian and terrestrial habitats could not be
quantitatively characterized since measurement endpoints were unavailable for terrestrial
monocotyledenous and dicotyledonous plants; however, indirect effects to the terrestrial habitat
are qualitatively characterized.
Dimethoate’s primary mode of action as an insecticide is through inhibition of acetylcholine

esterase. Dimethoate is moderately toxic to freshwater fish and very highly toxic to freshwater
invertebrates on an acute exposure basis. Toxicity categories for aquatic plants have not been
defined; however, if classification for animals were applied to aquatic plants, dimethoate would
be classified as very highly toxic to unicellular aquatic plants. The no observed adverse effect
concentration (NOAEC) for chronic effects to the rainbow trout is 0.43 mg/L, with a lowest
observed adverse affect concentration (LOAEC) of 0.84 mg/L for a reduction in growth.
Available chronic toxicity data for aquatic invertebrates (waterfleas) indicate effects to
reproduction, survival and growth at 0.1 mg/L. In order to adjust this chronic endpoint for the
most sensitive aquatic invertebrate species under acute exposure conditions, the acute-to-chronic
ratio (ACR) is used to determine an adjusted NOAEC for stonefly of 0.0005 mg/L. Dimethoate
is very highly toxic to birds on an acute oral exposure basis, moderately toxic on a subacute
dietary exposure basis and highly toxic to mammals on an acute oral exposure basis. Dimethoate
is also very highly toxic to honey bees on an acute contact exposure basis. Chronic exposures of
Northern bobwhite quail to dimethoate indicate reproductive effects with a NOAEC of 4 ppm
and a LOAEC of 10.1 ppm. Chronic exposures of rats to dimethoate in a developmental
neurotoxicity study indicate a NOAEL of 0.1 mg/kg-bw/day corresponding to a LOAEL of 0.5
mg/kg-bw/day for pup death and brain cholinesterase inhibition.
Dimethoate degrades into one notable degradate, omethoate (also known as dimethoxon).
Omethoate was not detected in any of the laboratory studies examining the environmental fate of
dimethoate but was detected in terrestrial field and foliar dissipation studies. Since laboratory
Page 10 of 137
studies did not provide data with which to estimate the formation and decline of the omethoate,
no half-lives are available with which to populate PRZM/EXAMS to estimate aquatic exposure.
Exposure to omethoate residues on terrestrial forage items are discussed qualitatively in this
assessment. Toxicity data for omethoate indicate that this oxon is more toxic than the parent
dimethoate on an acute exposure basis to aquatic invertebrates and mammals, but of similar
toxicity to fish and birds, which represent the surrogates of the CRLF. Given that acute and
chronic risk quotients are exceeded for the parent compound alone, any contribution in toxicity
from omethoate would increase the risk estimates.
Risk quotients (RQs) are derived as quantitative estimates of potential high-end risk. Acute and
chronic RQs are compared to the Agency’s Levels of Concern (LOCs) for Federally-listed
threatened (listed) species to identify if dimethoate use within the action area has any direct or
indirect effect on the CRLF and its designated critical habitat. Based on terrestrial estimated
environmental concentrations for the currently registered uses of dimethoate, RQ values exceed
the Agency’s LOC for direct acute and chronic risk to the CRLF; this represents a “may affect”
determination. RQs exceed the LOC for acute and chronic risks to aquatic invertebrates and for
acute risks to terrestrial invertebrates. Therefore, there is a potential to indirectly affect juvenile
and adult CRLFs due to effects on the invertebrate prey base in aquatic and terrestrial habitats.
The effects determination for indirect effects to the CRLF due to effects on its prey base is “may
affect.” When considering the prey of larger CRLFs in aquatic and terrestrial habitats (e.g. frogs,
fish and small mammals), RQs for terrestrial-phase frogs and small mammals also exceed the
LOC for acute and chronic risks, resulting in a “may affect” determination. RQ values for
unicellular plants in aquatic habitats do not exceed the LOC. Risk of dimethoate use on riparian
and terrestrial vegetation cannot be discounted given the lack of terrestrial plant toxicity data.
Therefore, the determination for indirect effects to the CRLF through effects to its habitat is
“may affect.”
All “may affect” determinations are further refined using available evidence to determine
whether dimethoate is “not likely to adversely affect” (NLAA) or “likely to adversely affect”
(LAA) the CRLF. Additional evidence employed to distinguish between NLAA and LAA
determinations includes available monitoring data, reports of ecological incidents and likelihood
of individual mortality analysis.
Refinement of all “may affect” determinations results in: a “LAA” determination based on direct
effects to the terrestrial-phase CRLF, a “LAA” determination for indirect effects to the CRLF
based on effects to its prey and a “LAA” determination for indirect effects to the CRLF based on
effects to its habitat (Table 1). Table 2 includes information on whether specific uses of
dimethoate pose risks to specific taxa of CRLF prey. Consideration of CRLF critical habitat
indicates a determination of “habitat modification” for aquatic and terrestrial designated critical
habitats. The overall CRLF effects determination for dimethoate use is “LAA.”
Page 11 of 137
Table 1. Dimethoate Effects Determination Summary for the California Red-legged Frog.
Assessment Effects Basis for Determination
Endpoint Determination1
Direct effects to LAA -Based on a lack of LOC exceedances by acute and chronic RQs, direct effects to the CRLF in aquatic habitats are not expected for any use of dimethoate.
CRLF -Refined acute and chronic RQs for the terrestrial-phase CRLF exceed the LOC for all uses of dimethoate.
-Analysis of individual effects (considering acute dose-based exposures) indicates that the chance of individual mortality to terrestrial-phase CRLF ranges from 1 in 180
individuals to 1 in 1 individuals.
-EECs resulting from spray drift exposures are sufficient to exceed the acute LOC for terrestrial-phase CRLF at distances >990 feet.
-Refined chronic EECs (estimated using T-HERPS) are sufficient to exceed the LOAEC for reproductive effects.
-For all uses of dimethoate, the effects determination is LAA based on acute and chronic exposures of dimethoate to the terrestrial-phase CRLF.
Indirect effects to NE -RQs do not exceed the LOC for algae. Therefore, applications of dimethoate are not expected to affect this food source.
tadpole CRLF via
reduction of prey
(i.e., algae)
Indirect effects to LAA -Table 2 includes information on whether specific uses of dimethoate pose risks to specific taxa of CRLF prey.
juvenile CRLF via -Acute and chronic RQs for aquatic invertebrates and acute RQs for terrestrial invertebrates exceed the LOCs.
reduction of prey -Estimates of individual chance of effects to aquatic invertebrates indicate that acute exposures of dimethoate result in ≤1.1% chance of mortality to aquatic invertebrate
(i.e., invertebrates) individuals. Based on this analysis, acute effects to aquatic invertebrates are insignificant to CRLF.
- Comparison of chronic aquatic EECs to the LOAEC for aquatic invertebrates indicates that the majority of EECs are sufficient to exceed the LOAEC.
-Estimates of individual chance of effects to terrestrial invertebrates indicate that acute exposures of dimethoate result in approximately 100% chance of mortality to terrestrial
invertebrate individuals.
-Chronic effects to aquatic invertebrates and acute effects to terrestrial invertebrates have the potential to result in indirect effects to the CRLF.
Indirect effects to - Table 2 includes information on whether specific uses of dimethoate pose risks to specific taxa of CRLF prey.
adult CRLF via LAA - Chronic effects to aquatic invertebrates and acute effects to terrestrial invertebrates have the potential to result in indirect effects to the CRLF (see specific explanation in row
reduction of prey above).
(i.e., invertebrates, - Based on a lack of LOC exceedances by acute and chronic RQs, direct effects to fish and aquatic-phase frogs are not expected.
fish, frogs, mice) - There is potential for acute and chronic effects to terrestrial-phase frogs representing prey based on:
- LOC exceedances by refined acute RQs for terrestrial-phase frogs;
- individual effects analysis the majority of uses of dimethoate have the potential to result in mortality to individual frogs;
- LOC exceedances by chronic RQs;
- Refined chronic EECs are sufficient to exceed the LOAEC for reproductive effects.
- Although acute RQs for mice exceed the LOC, individual effects analysis indicates that acute exposures of mice would only result in mortality that would be significant to the
CRLF only for applications of dimethoate to citrus and non-cropland areas adjacent to vineyards. The effects of all other uses are insignificant to the CLRF. RQs exceed the
LOC by factors ranging 30X to 2082X. Comparisons of chronic EECs to the LOAEC indicate that EECs are sufficient to exceed the LOAEC for all uses of dimethoate.
- Overall, exposures of dimethoate have the potential to decrease populations of several types of prey of the CRLF, indicating that it is likely that uses of dimethoate can
adversely affect the CRLF through indirect effects to its prey.
Indirect effects to LAA -Based on RQs for unicellular plants inhabiting aquatic habitats, applications of dimethoate are not expected to affect these plants.
CRLF via reduction -Available data from the literature combined with spray drift deposition modeling suggest that dimethoate could affect plant biomass as far as 390 feet from the edge of the
of habitat and/or treatment site.
primary productivity -There are two reported incidents involving effects of dimethoate to plants.
(i.e., plants) - Several dimethoate product labels indicate that use of dimethoate at label rates could result in phytotoxicity to several types of plants.
-Risks of dimethoate to riparian and terrestrial plants cannot be quantified or discounted.
1
LAA = likely to adversely affect; NLAA = not likely to adversely affect; NE = no effect
Page 12 of 137
Table 2. Potential risks directly to prey of CRLF due to dimethoate exposures from specific uses (yes or no).*
Aquatic Terrestrial Aquatic-phase Terrestrial-phase
Small Mammals
Use Algae Invertebrates Invertebrates frogs and fish frogs
Acute Chronic (Acute) Acute Chronic Acute Chronic Acute Chronic
Alfalfa No No Yes Yes No No Yes Yes No Yes
beans No No Yes Yes No No Yes Yes No Yes
broccoli No No Yes Yes No No Yes Yes No Yes
Brussels sprouts No No Yes Yes No No Yes Yes No Yes
cauliflower No No Yes Yes No No Yes Yes No Yes
celery No No Yes Yes No No Yes Yes No Yes
Chinese cabbage No No Yes Yes No No Yes Yes No Yes
citrus No No Yes Yes No No Yes Yes Yes Yes
conifer 1 No No Yes Yes No No Yes Yes No Yes
cotton No No Yes Yes No No Yes Yes No Yes
Cottonwood 2 No No Yes Yes No No Yes Yes No Yes
Endive (escarole) No No Yes Yes No No No Yes No Yes
field corn No No Yes Yes No No Yes Yes No Yes
garbanzo beans No No Yes Yes No No Yes Yes No Yes
grass for seed No No Yes Yes No No Yes Yes No Yes
ornamentals No No No Yes No No No Yes No Yes
honeydew No No Yes Yes No No Yes Yes No Yes
kale No No Yes Yes No No No Yes No Yes
Kohlrabi No No Yes Yes No No Yes Yes No Yes
lentils No No Yes Yes No No Yes Yes No Yes
lettuce (leaf) No No Yes Yes No No No Yes No Yes
Lupine No No Yes Yes No No Yes Yes No Yes
melon No No Yes Yes No No Yes Yes No Yes
mustard greens No No Yes Yes No No No Yes No Yes
Non-cropland3 No No Yes Yes No No Yes Yes Yes Yes
pears No No Yes Yes No No Yes Yes No Yes
peas (succulent) No No Yes Yes No No Yes Yes No Yes
pecans No No Yes Yes No No No Yes No Yes
peppers No No Yes Yes No No Yes Yes No Yes
popcorn No No Yes Yes No No Yes Yes No Yes
potatoes No No Yes Yes No No Yes Yes No Yes
Safflower No No Yes Yes No No Yes Yes No Yes
sainfoin No No Yes Yes No No Yes Yes No Yes
sorghum No No Yes Yes No No Yes Yes No Yes
Swiss chard No No Yes Yes No No No Yes No Yes
tomatoes No No Yes Yes No No Yes Yes No Yes
triticale No No Yes Yes No No Yes Yes No Yes
turnips No No Yes Yes No No Yes Yes No Yes
Wheat No No Yes Yes No No Yes Yes No Yes
*This information is used to determine whether or not effects of dimethoate on prey will indirectly affect the CRLF.
1 2 3
seed orchards For pulp Areas adjacent to vineyards
Page 13 of 137
When evaluating the significance of this risk assessment’s direct/indirect and habitat
modification effects determinations, it is important to note that pesticide exposures and predicted
risks to the species and its resources (i.e., food and habitat) are not expected to be uniform across
the action area. In fact, given the assumptions of drift and downstream transport (i.e., attenuation
with distance), pesticide exposure and associated risks to the species and its resources are
expected to decrease with increasing distance away from the treated field or site of application.
Characterizing the implication of this non-uniform distribution of risk to the species would
require information and assessment techniques that are not currently available. Examples of
such information and methodology required for this type of analysis would include the
following:
• Enhanced information on the density and distribution of CRLF life stages within specific
recovery units and/or designated critical habitat within the action area. This information
would allow for quantitative extrapolation of the present risk assessment’s predictions of
individual effects to the proportion of the population extant within geographical areas where
those effects are predicted. Furthermore, such population information would allow for a
more comprehensive evaluation of the significance of potential resource impairment to
individuals of the species.
• Quantitative information on prey base requirements for individual aquatic- and terrestrial-
phase frogs. While existing information provides a preliminary picture of the types of food
sources utilized by the frog, it does not establish minimal requirements to sustain healthy
individuals at varying life stages. Such information could be used to establish biologically
relevant thresholds of effects on the prey base, and ultimately establish geographical limits to
those effects. This information could be used together with the density data discussed above
to characterize the likelihood of effects to individuals.
• Information on population responses of prey base organisms to the pesticide. Currently,
methodologies are limited to predicting exposures and likely levels of direct mortality,
growth or reproductive impairment immediately following exposure to the pesticide. The
degree to which repeated exposure events and the inherent demographic characteristics of the
prey population influence the recovery of prey resources is not predictable. An enhanced
understanding of long-term prey responses to pesticide exposure would allow for a more
refined determination of the magnitude and duration of resource impairment, and together
with the information described above, a more complete prediction of effects to individual
frogs and potential modification to critical habitat.
Page 14 of 137
2. Problem Formulation
Problem formulation provides a strategic framework for the risk assessment. By identifying the
important components of the problem, it focuses the assessment on the most relevant life history
stages, habitat components, chemical properties, exposure routes, and endpoints. The structure
of this risk assessment is based on guidance contained in U.S. EPA’s Guidance for Ecological
Risk Assessment (U.S. EPA 1998), the Services’ Endangered Species Consultation Handbook
(USFWS/NMFS 1998) and procedures outlined in the Overview Document (U.S. EPA 2004).
2.1 Purpose
The purpose of this endangered species assessment is to evaluate potential direct and indirect
effects on individuals of the federally threatened California red-legged frog (Rana aurora
draytonii) (CRLF) arising from FIFRA regulatory actions regarding use of the insecticide
dimethoate on vegetable crops, fruit, tree nuts, citrus, forage crops, forests and outdoor nurseries.
In addition, this assessment evaluates whether these actions can be expected to result in the
modification of the species’ critical habitat. Key biological information for the CRLF is
included in Section 2.5, and designated critical habitat information for the species is provided in
Section 2.6 of this assessment. This ecological risk assessment has been prepared as part of the
Center for Biological Diversity (CBD) vs. EPA et al. (Case No. 02-1580-JSW(JL)) settlement
agreement entered in the Federal District Court for the Northern District of California on October
20, 2006.
In this endangered species assessment, direct and indirect effects to the CRLF and potential
modification to its critical habitat are evaluated in accordance with the methods (both screening
level and species-specific refinements, when appropriate) described in the Agency’s Overview
Document (U.S. EPA 2004) and evaluated by the U. S. Fish and Wildlife Service
(USFWS/NMFS 2004).
In accordance with the Overview Document, provisions of the Endangered Species Act (ESA),
and the Services’ Endangered Species Consultation Handbook, the assessment of effects
associated with registrations of dimethoate are based on an action area. The action area is
considered to be the area directly or indirectly affected by the federal action, as indicated by the
exceedance of Agency Levels of Concern (LOCs) used to evaluate direct or indirect effects. It is
acknowledged that the action area for a national-level FIFRA regulatory decision associated with
a use of dimethoate may potentially involve numerous areas throughout the United States and its
Territories. However, for the purposes of this assessment, attention will be focused on relevant
sections of the action area including those geographic areas associated with locations of the
CRLF and its designated critical habitat within the state of California.
As part of the “effects determination,” one of the following three conclusions will be reached
regarding the potential for registration of dimethoate at the use sites described in this document
to affect CRLF individuals and/or result in the modification of designated CRLF critical habitat:
Page 15 of 137
• “No effect”;
• “May affect, but not likely to adversely affect”; or
• “May affect and likely to adversely affect”.
Designated critical habitat identifies specific areas that have the physical and biological features,
(known as primary constituent elements or PCEs) essential to the conservation of listed species.
The PCEs for CRLFs are aquatic and upland areas where suitable breeding and non-breeding
aquatic habitat is located, interspersed with upland foraging and dispersal habitat (Section 2.6).
If the results of initial screening-level assessment methods show no direct or indirect effects (no
LOC exceedances) upon individual CRLFs or upon the PCEs of the species’ designated critical
habitat, a “no effect” determination is made for the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA) regulatory action regarding dimethoate as it relates to this species and
its designated critical habitat. If, however, direct or indirect effects to individual CRLFs are
anticipated and/or effects may impact the PCEs of the CRLF’s designated critical habitat, a
preliminary “may affect” determination is made for the FIFRA regulatory action regarding
dimethoate.
If a determination is made that use of dimethoate within the action area(s) associated with the
CRLF “may affect” this species and/or its designated critical habitat, additional information is
considered to refine the potential for exposure and for effects to the CRLF and other taxonomic
groups upon which this species depend (e.g., aquatic and terrestrial vertebrates and invertebrates,
aquatic plants, riparian vegetation, etc.). Additional information, including spatial analysis (to
determine the overlay of CRLF habitat with dimethoate use) and further evaluation of the
potential impact of dimethoate on the PCEs is also used to determine whether modification to
designated critical habitat may occur. Based on the refined information, the Agency uses the
best available information to distinguish those actions that “may affect, but are not likely to
adversely affect” from those actions that “may affect and are likely to adversely affect” the
CRLF and/or the PCEs of its designated critical habitat. This information is presented as part of
the Risk Characterization in Section 5 of this document.
The Agency believes that the analysis of direct and indirect effects to listed species provides the
basis for an analysis of potential effects on the designated critical habitat. Because dimethoate is
expected to directly impact living organisms within the action area (defined in Section 2.7),
critical habitat analysis for dimethoate is limited in a practical sense to those PCEs of critical
habitat that are biological or that can be reasonably linked to biologically mediated processes
(i.e., the biological resource requirements for the listed species associated with the critical habitat
or important physical aspects of the habitat that may be reasonably influenced through biological
processes). Activities that may modify critical habitat are those that alter the PCEs and
jeopardize the continued existence of the species. Evaluation of actions related to use of
dimethoate that may alter the PCEs of the CRLF’s critical habitat form the basis of the critical
habitat impact analysis. Actions that may affect the CRLF’s designated critical habitat have been
identified by the Services and are discussed further in Section 2.6.
Page 16 of 137
2.2 Scope
Dimethoate is an organophosphate insecticide used to kill mites and insects systemically and on
contact. Its mode of action is through inhibition of acetylcholinesterase. It is used against mites
and a wide range of insects, including, but not limited to scale insects, thrips, aphids, leaf miners,
leaf hoppers, flea hoppers, plant bugs, corn rootworms, lygus bugs, loopers, grasshoppers, alfalfa
weevils, planthoppers, fir cone midges, loblolly pine sawflies and whiteflies. Dimethoate is
registered for use on 39 crops relevant to California.
The end result of the EPA pesticide registration process (the FIFRA regulatory action) is an
approved product label. The label is a legal document that stipulates how and where a given
pesticide may be used. Product labels (also known as end-use labels) describe the formulation
type (e.g., liquid or granular), acceptable methods of application, approved use sites, and any
restrictions on how applications may be conducted. Thus, the use or potential use of dimethoate
in accordance with the approved product labels for California is “the action” being assessed.
This endangered species assessment is for currently registered uses of dimethoate in portions of
the action area that are reasonably assumed to be biologically relevant to the CRLF and its
designated critical habitat. Further discussion of the action area for the CRLF and its critical
habitat is provided in Section 2.7.
This assessment quantitatively considers effects of exposures to dimethoate only. Dimethoate

degrades into one notable degradate, omethoate (also known as dimethoxon). Omethoate was not
detected in any of the laboratory studies examining the environmental fate of dimethoate but was
detected in terrestrial field and foliar dissipation studies. Since laboratory studies did not provide
data with which to estimate the formation and decline of the omethoate, no half-lives are
available with which to populate PRZM/EXAMS to estimate aquatic exposure. Exposure to
omethoate residues on terrestrial forage items are discussed qualitatively in this assessment.
Toxicity data for omethoate indicate that the oxon is more toxic than the parent on an acute
exposure basis to aquatic invertebrates and mammals, but of similar toxicity to fish and birds,
which represent the surrogates for the CRLF. Given that acute and chronic risk quotients are
exceeded for the parent compound alone, any contribution in toxicity from omethoate would
increase the risk estimates.
This assessment considers only the single active ingredient of dimethoate. However, the assessed
species and their environments may be exposed to multiple pesticides simultaneously.
Interactions of other toxic agents with dimethoate could result in additive effects, synergistic
effects or antagonistic effects. Evaluation of pesticide mixtures is beyond the scope of this
assessment because of the myriad factors that cannot be quantified based on the available data.
Those factors include identification of other possible co-contaminants and their concentrations,
differences in the pattern and duration of exposure among contaminants, and the differential
effects of other physical/chemical characteristics of the receiving waters (e.g. organic matter
present in sediment and suspended water). Evaluation of factors that could influence
additivity/synergism is beyond the scope of this assessment and is beyond the capabilities of the
available data to allow for an evaluation. However, it is acknowledged that not considering
Page 17 of 137
mixtures could over- or under-estimate risks depending on the type of interaction and factors
discussed above.
The Agency does not routinely include, in its risk assessments, an evaluation of mixtures of
active ingredients, either those mixtures of multiple active ingredients in product formulations or
those in the applicator’s tank. In the case of the product formulations of active ingredients (that
is, a registered product containing more than one active ingredient), each active ingredient is
subject to an individual risk assessment for regulatory decision regarding the active ingredient on
a particular use site. If effects data are available for a formulated product containing more than
one active ingredient, they may be used qualitatively or quantitatively in accordance with the
Agency’s Overview Document and the Services’ Evaluation Memorandum (U.S., EPA 2004;
USFWS/NMFS 2004). Dimethoate does not have any registered products that contain multiple
active ingredients.
2.3 Previous Assessments
In January 2004, a revised environmental fate and ecological risk assessment was published in
support of the interim reregistration eligibility decision on dimethoate (USEPA 2006). This was
a national-level assessment of the risks of dimethoate to aquatic and terrestrial organisms and
was intended to update an earlier science chapter (USEPA 1998). The updated assessment
concluded that risk to non-listed terrestrial animals from exposure to dimethoate could not be
discounted. RQs for non-listed aquatic animals were below the LOC, indicating that risk from
dimethoate to these organisms was low. Due to a lack of terrestrial plant and aquatic vascular
plant effects data and due to reports of terrestrial plant incidents, risk to plants was presumed.
Because the Agency had determined that dimethoate shares a common mechanism of toxicity
with the structurally-related organophosphates insecticides, a cumulative human health risk
assessment for the organophosphate pesticides was necessary before the Agency could make a
final determination of reregistration eligibility of dimethoate. At this time, a cumulative
ecological risk assessment for the organophosphate pesticides has not been completed.
EPA consulted with the U. S. Fish and Wildlife Service in 1989 regarding dimethoate impacts on
some endangered species (USFWS 1989). As a result, the U.S. Fish and Wildlife Service issued
a formal Biological Opinion which identified reasonable and prudent measures and alternatives
to mitigate effects of dimethoate use on endangered species.
EPA also consulted with the National Marine Fisheries Service concerning dimethoate effects on
endangered salmon and steelhead. In its assessment, the Agency determined that the use of
dimethoate may affect 19 salmon and steelhead evolutionarily significant units (ESUs), may
affect but is not likely to adversely affect two ESUs and will have no effect on four ESUs
(Williams 2004).
Page 18 of 137
2.4 Stressor Source and Distribution
2.4.1 Environmental Fate and Transport Assessment
As described in the supplement to the environmental fate and ecological risk assessment chapter
(U. S. EPA 2004) dimethoate is a highly mobile, generally non-persistent organophosphate
insecticide. The primary route of dissipation is microbially-mediated degradation in aerobic soil.
Dissipation studies indicate that dimethoate rapidly dissipates from soil and foliar surfaces
(Table 3). Omethoate was not reported in laboratory fate studies involving degradation of
dimethoate. It was, however, observed in terrestrial field dissipation and foliar dissipation
studies. Results of fate and transport studies associated with dimethoate are briefly described
below.
Table 3. Environmental fate and transport data for dimethoate.

Study Value Source
Aerobic Soil Metabolism Half-life 2.4 d MRID 42843201
Anaerobic Soil Metabolism Half-life 22 d MRID 42884402
Hydrolysis Half-life pH 5: 156 d MRID 00159761

pH 7: 68 d
pH 9: 4.4 d
Aqueous Photolysis Half-life 353 d MRID 00159762
Soil Photolysis Half -life no significant degradation MRID 43276401
Soil Water Partition Coefficient (Kd) sand 0.06 L (kg-soil)-1 MRID 00164959
sandy loam: 0.30 L (kg-soil)-1
silt loam: 0.57 L (kg-soil)-1
clay loam: 0.66 L (kg-soil)-1
Field Dissipation DT50 CA loamy sand: 11 d MRID 42884403

CA sandy loam ~ 9 d MRID 42884403
CA sandy loam: ~16 d MRID 42884403
TX silt loam ~ 9 d MRID 43388001
Chenango gravelly silt loam: < 5 d MRID 43388002
Foliar Dissipation Half-life mean value: 2.8 d See Table 5
Microbial degradation
In an aerobic soil metabolism study, dimethoate degraded rapidly, with a half-life of 2.4 days.
The majority of dimethoate residues were composed of carbon dioxide, accounting for >50% of
total residues by day 7 of the test and approximately 75% by day 181. Two non-volatile
degradates, desmethyl dimethoate and dimethylthiophosphoric acid, were identified but were
present at levels less than 2% during the aerobic soil metabolism study.
Under anaerobic soil conditions, dimethoate degrades, with a half-life of approximately 22 days.
The major non-volatile degradate was desmethyl dimethoate.
Page 19 of 137
Hydrolysis
Dimethoate hydrolyzes slowly in sterile buffered solutions under acidic (pH 5) conditions, with
an observed half life of 156 days. Desmethyl dimethoate was the only degradate observed at this
pH (12.2% of total dimethoate residues).
Dimethoate also hydrolyzes slowly in sterile buffered solutions under neutral (pH 7) conditions,
with an observed half life of 68 days. Desmethyl dimethoate was the only major degradate
observed, comprising 22.1% of the residues at the end of the 30-day observation period.
Throughout this study, dimethoate and desmethyl dimethoate comprised <96% of the original
dimethoate residues. Dimethoylphosphorothioc acid was also identified as a degradate,
comprising 1.9% of dimethoate residues at 30 days.
Under alkaline conditions (pH 9), dimethoate degrades to desmethyl dimethoate and
dimethylthiophosphoric acid with a half-life of 4.4 days. One day after test initiation, both
degradates were observed. At day 30, desmethyl dimethoate and dimethoylphosphorothioc acid
composed 62.1 and 36.0%, respectively, of the total dimethoate residues.
Photolysis
Dimethoate photodegrades slowly in water (T1/2 = 353 days). No significant photodegradation

occurred in the soil photolysis study.
Mobility
Dimethoate is highly mobile in soil. In a soil column leaching study, 72-100% of applied
radioactivity was eluted from the columns (loam, silt loam, sandy loam, and sand). Calculated
Kd values based on these column studies ranged from 0.06 L kg-1 for sand to 0.66 L kg -1 for clay
loam. Degradate mobility has not been well defined; however, based on the aged leaching data
as well as the metabolism data, degradates are not expected to persist and move through the soil
profile.
Volatility
A study measuring the volatility of dimethoate from the soil surface showed this not to be a
significant route of dissipation. After 30 days, only 2.7% of the applied radioactivity had
volatilized, 0.7% of which was CO2. The majority of the radioactivity (83%) was extracted from
the soil and most of this (93.2%) was dimethoate.
Field Dissipation
The results of five terrestrial field studies indicate that dimethoate dissipates with half-lives
ranging 5 and 15 days when applied post-emergence to green beans, grapes, and bare ground in
California, grain sorghum in Texas, and bare ground in New York (MRIDs 433880-02, 433880-
01 and 428844-03). These results are reasonably consistent with those that might be expected
from the laboratory studies although the persistence is somewhat longer in the field studies.
Page 20 of 137
When detected, dimethoate was mostly in the top layer of soil (0-6”), with some detections
below 6”. Omethoate was detected in the top layer of soil in all five studies. In the California
bare ground study, omethoate was found through day 159 of the study.
Foliar Dissipation
Foliar dissipation was assessed using data compiled by Willis and McDowell, 1987. This paper
is a summary of data on the persistence of pesticides on foliage. In this document, 28
measurements of dimethoate dissipation on foliage were identified on whole plant or on foliage.
Of these, four were completed in Egypt, and it could not be determined whether they were
appropriate for assessing foliar dissipation in the United States, so they were not used. For the
remaining 24 (Table 4), the mean foliar dissipation half-life was 2.8 days, and the upper 90%
confidence bound on the mean was 2.9 days. Note that these were all field studies, and that these
are dissipation rather than degradation half-lives. In some cases, the author of the study noted
when rain occurred during the trial. However, absence of that information in Table 4 is an
indication that the author did not note whether precipitation occurred rather than the absence of
precipitation.
Table 4. Foliar dissipation data for dimethoate.

Crop Author1 Comment T½ (days)
apple Pree et al. 1976 5.4
alfalfa Shaw and Ziener, 1964 1.4
apple Pree et al. 1976 7.2
apple Pree et al. 1976 rained 80 mm 2.6
apple Pree et al. 1976 rained 11 mm 4.1
birdsfoot trefoil Shaw and Ziener, 1966 2.1
sorghum Dorough et al. 1966 4
ladino clover Shaw and Ziener, 1966 1.8
lemon Bellows et al., 1985 2.2
coastal bermuda grass Beck et al., 1966 22.6 mm rain 3.1
corn Beck et al., 1966 90.2 mm rain 2.7
soybeans Beck et al., 1966 0 mm rain 0.9
beet Vail et al., 1967 0 mm rain 2.5
broccoli Nelson et al., 1966 3
cabbage Nelson et al., 1966 1.7
chard Vail et al., 1967 5.1 mm rain 2.6
collards Nelson et al., 1966 2.5
leaf lettuce Vail et al., 1967 5.1 mm rain 2.8
lima beans Nelson et al., 1966 2.2
snap beans Nelson et al., 1966 2.6
soybeans Nelson et al., 1966 1.2
turnip Vail et al., 1967 83.8 mm rain 3.1
turnip Nelson et al., 1966 3.2
wheat Lee and Westcott, 1981 2.5
1
As cited in Willis and McDowell 1987.
In addition to the literature studies, a registrant-submitted study (MRID 464864-01) provided

information on the degradation of dimethoate, and the formation and decline of omethoate on
ground-level vegetation and canopy arthropods in a mandarin orchard in Spain. The dissipation
half-life values for plants and insects were 2.56 and 4.84 days, respectively, for dimethoate. For
Page 21 of 137
omethoate the dissipation half-life values for plants and insects were 3.94 and 5.13 days,
respectively. This study indicates that omethoate forms in nontarget animal forage items and that
at peak levels, these residues were as high as 41% of the parent.
Estimates of foliar dissipation half-lives for total dimethoate residues (which include omethoate)
are available from several registrant-submitted studies involving several crops, including wheat
(MRIDs 466780-01, 466780-05 and 466780-10) and lettuce (MRID 466780-07). For wheat,
foliar dissipation half-lives ranged 3.1 to 7.4 days. For lettuce, the estimated foliar dissipation
half-life was 0.98 days. The upper 95% confidence limit for these values is 5.48 days (mean =
3.56, stdev = 2.23). For more information, see Jones and Steeger 2006.
In a dimethoate magnitude of residue study conducted with olives, omethoate residues ranged
from 1.1 to 17% of total residues (dimethoate and omethoate) measured on the day of
application. After 7 days, omethoate comprised up to 96% of total residues measured on olives
(MRID 466780-09).
2.4.2 Mechanism of Action
Dimethoate is an organophosphate insecticide used to kill mites and insects systemically and on
contact. Its mode of action is through inhibition of acetylcholinesterase. Organophosphate
toxicity is based on the inhibition of the enzyme acetylcholinesterase which cleaves the
neurotransmitter acetylcholine. Inhibition of acetylcholinesterase by organophosphate
insecticides, such as dimethoate, interferes with proper neurotransmission in cholinergic
synapses and neuromuscular junctions.
As a phosphorodithioate organophosphate, the chemical is subject to bioactivation into its oxon

form (omethoate) similar to other members of this class. Certain taxonomic groups, such as
birds, have been demonstrated to be more sensitive to the oxon compared to the parent
compound (Walker 1982). The enhanced sensitivity of birds to this group of bioactivated
organophosphate insecticides is potentially due to physiological and biochemical differences
among or between birds and other animals (Walker 1982; Chambers and Carr 1995; Brealey et
al. 1980). Thus, the rate at which a phosphorodithioate pesticide is transformed to its oxon and
the rate at which the oxon is subsequently detoxified can influence toxicity. However, the oxon
is potentially orders of magnitude more toxic than the parent compound. It is not possible,
however, to gauge the toxicity of the oxon from looking at the parent alone since available
studies do not indicate how much of the parent is converted to the oxon.
2.4.3 Use Characterization
Dimethoate is nationally registered for over 40 uses in agriculture and ornamental production.
The specific uses and their maximum application rates are identified in Table 5. Specific
registration numbers associated with dimethoate are available in Appendix A. Aerial
applications are allowed for all uses, with the exception of citrus, Brussels sprouts, non-cropland
areas adjacent to vineyards and outdoor nursery. Dimethoate use on non-cropland areas adjacent
to vineyards is permitted according to a special local needs label (SLN # CA-970003) and is
relevant only to Napa, Sonoma, Mendocino and Lake counties in northern California.
Page 22 of 137
Pesticide use information from the California Department of Pesticide Regulation (CDPR
2007a), include county-level data for various dimethoate uses from 2002-2005. Past uses of
dimethoate include the majority of the uses identified in Table 5, as well as uses that are no
longer permitted. Analysis of the mass of dimethoate applied with consideration of the
application area indicates that applications have been made at or above the maximum application
rates identified in Table 5. In situations were the use data indicate higher than maximum label
application rates, the discrepancy is considered to be most likely due to misreporting.
As of 2002, over 1.4 million pounds of dimethoate were applied annually in the United States;
the highest poundage (487,270 lbs) was applied to corn. Alfalfa hay (181,652 lbs) and wheat
(122,051 lbs) represented the second and third highest total pounds of dimethoate applied.
Figure 1 depicts the extent of estimated annual dimethoate use nationally as of 2002.
From 2001-2005, the percentage of total dimethoate use in California was highest on alfalfa
(19.7% of total use), tomato (13.5%), beans (11.3%), broccoli (10.6%), corn (9.3%), citrus
(8.4%), lettuce (7.5%) and cotton (7.1%) (CDPR 2007a). The total annual average for reported
uses over this three year period was 249,405 lbs. Use data from 2001-2005 for California
indicate that dimethoate is applied throughout the year, with the majority of applications
occurring during the summer months (June-August). A more thorough analysis of the 2001-2005
data for applications of dimethoate in California is provided in Appendix B.
Analysis of labeled use information is the critical first step in evaluating the federal action. The
current labels for dimethoate represent the FIFRA regulatory action; therefore, labeled use and
application rates specified on the label form the basis of this assessment. The assessment of use
information is critical to the development of the action area and selection of appropriate
modeling scenarios and inputs. Specific uses and their application practices are in Table 5.
The uses considered in this risk assessment represent all currently registered uses in California
according to a review of all current labels. No other uses are relevant to this assessment. Any
reported use not represented on current labels, such as may be seen in the CDPR PUR database,
represent either historic uses that have been cancelled, misreported uses, or misuse. Historical
uses, misreported uses, and misuse are not considered part of the federal action and, therefore,
are not considered in this assessment.
Page 23 of 137
Table 5. Methods and rates of application of currently registered used of dimethoate in California.
Use Max. App. Rate Max. No. Application

(lb a.i./acre) of Apps. Intervals (days)
Alfalfa1 0.5 1 NA
beans2 0.5 2 14
broccoli 0.5 3 7
Brussels sprouts 1 6 7
cauliflower 0.5 3 7
celery 0.5 3 7
Chinese cabbage 0.5 3 7
Citrus 2 unknown NA
conifer seed orchards 1 1 NA
cotton2 0.5 2 14
cottonwood (for pulp) 1 3 unknown
Endive (escarole) 0.25 3 7
field corn 0.5 1 NA
garbanzo beans 0.5 1 NA
grass for seed 0.5 2 90
herbaceous ornamentals 0.25 1 NA
honeydew 0.5 2 7
kale 0.25 2 15
kohlrabi 0.5 3 7
lentils 0.5 2 7
lettuce (leaf) 0.25 3 7
Lupine 0.5 2 unknown
melon 0.5 2 7
mustard greens 0.25 2 9
Non-cropland areas adjacent to vineyards 2 2 unknown
pears 0.5 1 NA
peas (succulent) 0.5 1 NA
pecans 0.33 1 NA
peppers 0.33 5 7
popcorn 0.5 1 NA
potatoes 0.5 2 7
Safflower1 0.5 1 NA
sainfoin 0.5 1 NA
sorghum 0.5 2 7
Swiss chard 0.25 3 7
tomatoes 0.5 2 6
triticale 0.5 2 unknown
turnips 0.25 7 3
Wheat1 0.5 1 NA
1
per crop/cutting
2
per season
NA = not applicable
Page 24 of 137
Figure 1. Historical Extent (2002) of dimethoate usage.
(Source http://ca.water.usgs.gov/pnsp/pesticide_use_maps/show_map.php?year=02&map=m6006 ).
2.5 Assessed Species
The CRLF was federally listed as a threatened species by USFWS effective June 24, 1996
(USFWS 1996). It is one of two subspecies of the red-legged frog and is the largest native frog
in the western United States (USFWS 2002). A brief summary of information regarding CRLF
distribution, reproduction, diet, and habitat requirements is provided in Sections 2.5.1 through
2.5.4, respectively. Further information on the status, distribution, and life history of and
specific threats to the CRLF is provided in Attachment 1.
Final critical habitat for the CRLF was designated by USFWS on April 13, 2006 (USFWS 2006;
71 FR 19244-19346). Further information on designated critical habitat for the CRLF is
provided in Section 2.6.
Page 25 of 137
2.5.1 Distribution
The CRLF is endemic to California and Baja California (Mexico) and historically inhabited 46
counties in California including the Central Valley and both coastal and interior mountain ranges
(USFWS 1996). Its range has been reduced by about 70%, and the species currently resides in
22 counties in California (USFWS 1996). The species has an elevation range of near sea level to
1,500 meters (5,200 feet) (Jennings and Hayes 1994); however, nearly all of the known CRLF
populations have been documented below 1,050 meters (3,500 feet) (USFWS 2002).
Populations currently exist along the northern California coast, northern Transverse Ranges
(USFWS 2002), foothills of the Sierra Nevada (5-6 populations), and in southern California
south of Santa Barbara (two populations) (Fellers 2005a). Relatively larger numbers of CRLFs
are located between Marin and Santa Barbara Counties (Jennings and Hayes 1994). A total of
243 streams or drainages are believed to be currently occupied by the species, with the greatest
numbers in Monterey, San Luis Obispo, and Santa Barbara counties (USFWS 1996). Occupied
drainages or watersheds include all bodies of water that support CRLFs (i.e., streams, creeks,
tributaries, associated natural and artificial ponds, and adjacent drainages), and habitats through
which CRLFs can move (i.e., riparian vegetation, uplands) (USFWS 2002).
The distribution of CRLFs within California is addressed in this assessment using four categories
of location including recovery units, core areas, designated critical habitat, and known
occurrences of the CRLF reported in the California Natural Diversity Database (CNDDB) that
are not included within core areas and/or designated critical habitat (see Figure 2). Recovery
units, core areas, and other known occurrences of the CRLF from the CNDDB are described in
further detail in this section, and designated critical habitat is addressed in Section 2.6. Recovery
units are large areas defined at the watershed level that have similar conservation needs and
management strategies. The recovery unit is primarily an administrative designation, and land
area within the recovery unit boundary is not exclusively CRLF habitat. Core areas are smaller
areas within the recovery units that comprise portions of the species’ historic and current range
and have been determined by USFWS to be important in the preservation of the species.
Designated critical habitat is generally contained within the core areas, although a number of
critical habitat units are outside the boundaries of core areas, but within the boundaries of the
recovery units. Additional information on CRLF occurrences from the CNDDB is used to cover
the current range of the species not included in core areas and/or designated critical habitat, but
within the recovery units.
Recovery Units
Eight recovery units have been established by USFWS for the CRLF. These areas are
considered essential to the recovery of the species, and the status of the CRLF “may be
considered within the smaller scale of the recovery units, as opposed to the statewide range”
(USFWS 2002). Recovery units reflect areas with similar conservation needs and population
statuses, and therefore, similar recovery goals. The eight units described for the CRLF are
delineated by watershed boundaries defined by US Geological Survey hydrologic units and are
Page 26 of 137
limited to the elevation maximum for the species of 1,500 m above sea level. The eight recovery
units for the CRLF are listed in Table 6 and shown in Figure 2.
Core Areas
USFWS has designated 35 core areas across the eight recovery units to focus their recovery
efforts for the CRLF (see Figure 2). Table 6 summarizes the geographical relationship among
recovery units, core areas, and designated critical habitat. The core areas, which are distributed
throughout portions of the historic and current range of the species, represent areas that allow for
long-term viability of existing populations and reestablishment of populations within historic
range. These areas were selected because they: 1) contain existing viable populations; or 2) they
contribute to the connectivity of other habitat areas (USFWS 2002). Core area protection and
enhancement are vital for maintenance and expansion of the CRLF’s distribution and population
throughout its range.
For purposes of this assessment, designated critical habitat, currently occupied (post-1985) core
areas, and additional known occurrences of the CRLF from the CNDDB are considered. Each
type of location information is evaluated within the broader context of recovery units. For
example, if no labeled uses of dimethoate occur (or if labeled uses occur at predicted exposures
less than the Agency’s LOCs) within an entire recovery unit, that particular recovery unit would
not be included in the action area and a “no effect” determination would be made for all
designated critical habitat, currently occupied core areas, and other known CNDDB occurrences
within that recovery unit. Historically occupied sections of the core areas are not evaluated as
part of this assessment because the USFWS Recovery Plan (USFWS 2002) indicates that CRLFs
are extirpated from these areas. A summary of currently and historically occupied core areas is
provided in Table 6 (currently occupied core areas are bolded). While core areas are considered
essential for recovery of the CRLF, core areas are not federally-designated critical habitat,
although designated critical habitat is generally contained within these core recovery areas. It
should be noted, however, that several critical habitat units are located outside of the core areas,
but within the recovery units. The focus of this assessment is currently occupied core areas,
designated critical habitat, and other known CNDDB CRLF occurrences within the recovery
units. Federally-designated critical habitat for the CRLF is further explained in Section 2.6.
Other Known Occurrences from the CNDBB
The CNDDB provides location and natural history information on species found in California.
The CNDDB serves as a repository for historical and current species location sightings.
Information regarding known occurrences of CRLFs outside of the currently occupied core areas
and designated critical habitat is considered in defining the current range of the CRLF. See:
http://www.dfg.ca.gov/bdb/html/cnddb_info.html for additional information on the CNDDB.
Page 27 of 137
Table 6. California Red-legged Frog Recovery Units with Overlapping Core Areas and Designated Critical
Habitat.
Currently
Recovery Unit 1 Critical Habitat Historically
Core Areas 2,7 (Figure 2) Occupied
(Figure 2) Units 3 Occupied 4
(post-1985) 4
Cottonwood Creek (partial) (8) -- 9
Feather River (1) BUT-1A-B 9
Yuba River-S. Fork Feather River
YUB-1 9
(2)
6
Sierra Nevada Foothills -- NEV-1
and Central Valley Traverse Creek/Middle Fork
-- 9
(RU#1) American River/Rubicon (3)
(eastern boundary is the Consumnes River (4) ELD-1 9
1,500m elevation line) S. Fork Calaveras River (5) -- 9
Tuolumne River (6) -- 9
Piney Creek (7) -- 9
-- 9
(partial)(16)
Cottonwood Creek (8) -- 9
Putah Creek-Cache Creek (9) -- 9
North Coast Range Jameson Canyon – Lower Napa
Foothills and Western -- 9
Valley (partial) (15)
Sacramento River Valley
(RU#2) Belvedere Lagoon (partial) (14) -- 9
Pt. Reyes Peninsula (partial) (13) -- 9
Putah Creek-Cache Creek (partial) (9) -- 9

Lake Berryessa Tributaries (10) NAP-1 9
Upper Sonoma Creek (11) -- 9
North Coast and North Petaluma Creek-Sonoma Creek
-- 9
San Francisco Bay (12)
(RU#3) Pt. Reyes Peninsula (13) MRN-1, MRN-2 9
Belvedere Lagoon (14) -- 9
Jameson Canyon-Lower Napa
SOL-1 9
River (15)
-- CCS-1A6
East San Francisco Bay (partial) ALA-1A, ALA-1B,
9
South and East San (16) STC-1B
Francisco Bay (RU#4) -- STC-1A6
South San Francisco Bay (partial)
SNM-1A 9
(18)
South San Francisco Bay (partial) SNM-1A, SNM-2C,
9
(18) SCZ-1
Watsonville Slough- Elkhorn
SCZ-2 5 9
Slough (partial) (19)
Carmel River-Santa Lucia (20) MNT-2 9
Central Coast (RU#5)
Estero Bay (22) -- 9
-- SLO-86
Arroyo Grande Creek (23) -- 9
Santa Maria River-Santa Ynez
-- 9
River (24)
Diablo Range and Salinas East San Francisco Bay (partial) MER-1A-B, STC-
9
Valley (RU#6) (16) 1B
-- SNB-16, SNB-26
Santa Clara Valley (17) -- 9
Page 28 of 137
Watsonville Slough- Elkhorn
MNT-1 9
Slough (partial)(19)
Carmel River-Santa Lucia
-- 9
(partial)(20)
Gablan Range (21) SNB-3 9
Estrella River (28) SLO-1A-B 9
-- SLO-86
Santa Maria River-Santa Ynez STB-4, STB-5,
9
Northern Transverse River (24) STB-7
Ranges and Tehachapi Sisquoc River (25) STB-1, STB-3 9
Mountains (RU#7) Ventura River-Santa Clara River VEN-1, VEN-2,
9
(26) VEN-3
-- LOS-16
Santa Monica Bay-Ventura Coastal
-- 9
Streams (27)
San Gabriel Mountain (29) -- 9
Southern Transverse and Forks of the Mojave (30) -- 9
Peninsular Ranges Santa Ana Mountain (31) -- 9
(RU#8) Santa Rosa Plateau (32) -- 9
San Luis Rey (33) -- 9
Sweetwater (34) -- 9
Laguna Mountain (35) -- 9
1
Recovery units designated by the USFWS (USFWS 2000, pg 49).
2
Core areas designated by the USFWS (USFWS 2000, pg 51).
3
Critical habitat units designated by the USFWS on April 13, 2006 (USFWS 2006, 71 FR 19244-19346).
4
Currently occupied (post-1985) and historically occupied core areas as designated by the USFWS (USFWS 2002, pg 54).
5
Critical habitat unit where identified threats specifically included pesticides or agricultural runoff (USFWS 2002).
6
7
Currently occupied core areas that are included in this effects determination are bolded.
Page 29 of 137
Recovery Units
1. Sierra Nevada Foothills and

Central Valley
2. North Coast Range Foothills and
Western Sacramento River Valley
3. North Coast and North San
Francisco Bay
5. Central Coast
7. Northern Transverse Ranges and
Tehachapi Mountains
8. Southern Transverse and
Peninsular Ranges
Core Areas
1. Feather River 19. Watsonville Slough-Elkhorn Slough

2. Yuba River- S. Fork Feather River 20. Carmel River – Santa Lucia
3. Traverse Creek/ Middle Fork/ American R. Rubicon 21. Gablan Range
4. Cosumnes River 22. Estero Bay
5. South Fork Calaveras River* 23. Arroyo Grange River
6. Tuolumne River* 24. Santa Maria River – Santa Ynez River
7. Piney Creek* 25. Sisquoc River
8. Cottonwood Creek 26. Ventura River – Santa Clara River
9. Putah Creek – Cache Creek* 27. Santa Monica Bay – Venura Coastal Streams
10. Lake Berryessa Tributaries 28. Estrella River
11. Upper Sonoma Creek 29. San Gabriel Mountain*
12. Petaluma Creek – Sonoma Creek 30. Forks of the Mojave*
13. Pt. Reyes Peninsula 31. Santa Ana Mountain*
14. Belvedere Lagoon 32. Santa Rosa Plateau
15. Jameson Canyon – Lower Napa River 33. San Luis Ray*
16. East San Francisco Bay 34. Sweetwater*
17. Santa Clara Valley 35. Laguna_Mountain
18. South San Francisco Bay
* Core areas that were historically occupied by the California red-

legged frog are not included in the map
Figure 2. Recovery Unit, Core Area, Critical

Habitat, and Occurrence Designations for CRLF.
Page 30 of 137
2.5.2 Reproduction
CRLFs breed primarily in ponds; however, they may also breed in quiescent streams, marshes,
and lagoons (Fellers 2005a). According to the Recovery Plan (USFWS 2002), CRLFs breed
from November through late April. Peaks in spawning activity vary geographically; Fellers
(2005b) reports peak spawning as early as January in parts of coastal central California. Eggs
are fertilized as they are being laid. Egg masses are typically attached to emergent vegetation,
such as bulrushes (Scirpus spp.) and cattails (Typha spp.) or roots and twigs, and float on or near
the surface of the water (Hayes and Miyamoto 1984). Egg masses contain approximately 2000
to 6000 eggs ranging in size between 2 and 2.8 mm (Jennings and Hayes 1994). Embryos hatch
10 to 14 days after fertilization (Fellers 2005a) depending on water temperature. Egg predation
is reported to be infrequent and most mortality is associated with the larval stage (particularly
through predation by fish); however, predation on eggs by newts has also been reported
(Rathburn 1998). Tadpoles require 11 to 28 weeks to metamorphose into juveniles (terrestrial-
phase), typically between May and September (Jennings and Hayes 1994, USFWS 2002);
tadpoles have been observed to over-winter (delay metamorphosis until the following year)
(Fellers 2005b, USFWS 2002). Males reach sexual maturity at 2 years, and females reach sexual
maturity at 3 years of age; adults have been reported to live 8 to 10 years (USFWS 2002).
Figure 3 depicts CRLF annual reproductive timing.
Month J F M A M J J A S O N D
Young
Juveniles:
Tadpoles*
Breeding/Egg
Masses
Adults and
Juveniles
Figure 3. CRLF Reproductive Events by Month.
Page 31 of 137
2.5.3 Diet
Although the diet of CRLF aquatic-phase larvae (tadpoles) has not been studied specifically, it is
assumed that their diet is similar to that of other frog species, with the aquatic phase feeding
exclusively in water and consuming diatoms, algae, and detritus (USFWS 2002). Tadpoles filter
and entrap suspended algae (Seale and Beckvar, 1980) via mouthparts designed for effective
grazing of periphyton (Wassersug, 1984, Kupferberg et al.; 1994; Kupferberg, 1997; Altig and
McDiarmid, 1999).
Juvenile and adult CRLFs forage in aquatic and terrestrial habitats, and their diet differs greatly
from that of larvae. The main food source for juvenile aquatic- and terrestrial-phase CRLFs is
thought to be aquatic and terrestrial invertebrates found along the shoreline and on the water
surface. Hayes and Tennant (1985) report, based on a study examining the gut content of 35
juvenile and adult CRLFs, that the species feeds on as many as 42 different invertebrate taxa,
including Arachnida, Amphipoda, Isopoda, Insecta, and Mollusca. The most commonly observed
prey species were larval alderflies (Sialis cf. californica), pillbugs (Armadilliadrium vulgare),
and water striders (Gerris sp). The preferred prey species, however, was the sowbug (Hayes and
Tennant, 1985). This study suggests that CRLFs forage primarily above water, although the
authors note other data reporting that adults also feed under water, are cannibalistic, and
consume fish. For larger CRLFs, over 50% of the prey mass may consists of vertebrates such as
mice, frogs, and fish, although aquatic and terrestrial invertebrates were the most numerous food
items (Hayes and Tennant 1985). For adults, feeding activity takes place primarily at night; for
juveniles feeding occurs during the day and at night (Hayes and Tennant 1985).
2.5.4 Habitat
CRLFs require aquatic habitat for breeding, but also use other habitat types including riparian
and upland areas throughout their life cycle. CRLF use of their environment varies; they may
complete their entire life cycle in a particular habitat or they may utilize multiple habitat types.
Overall, populations are most likely to exist where multiple breeding areas are embedded within
varying habitats used for dispersal (USFWS 2002). Generally, CRLFs utilize habitat with
perennial or near-perennial water (Jennings et al. 1997), and dense vegetation close to water and
shading water of moderate depth are habitat features that appear especially important for CRLF
(Hayes and Jennings 1988).
Breeding sites include streams, deep pools, backwaters within streams and creeks, ponds,
marshes, sag ponds (land depressions between fault zones that have filled with water), dune
ponds, and lagoons. Breeding adults have been found near deep (0.7 m) still or slow moving
water surrounded by dense vegetation (USFWS 2002); however, the largest number of tadpoles
have been found in shallower pools (0.26 – 0.5 m) (Reis, 1999). Data indicate that CRLFs do
not frequently inhabit vernal pools, as conditions in these habitats generally are not suitable
(Hayes and Jennings 1988).
CRLFs also frequently breed in artificial impoundments such as stock ponds, although additional
research is needed to identify habitat requirements within artificial ponds (USFWS 2002). Adult
CRLFs use dense, shrubby, or emergent vegetation closely associated with deep-water pools
Page 32 of 137
bordered with cattails and dense stands of overhanging vegetation
(http://www.fws.gov/endangered/features/rl_frog/rlfrog.html#where).
In general, dispersal and habitat use depends on climatic conditions, habitat suitability, and life
stage. Adults rely on riparian vegetation for resting, feeding, and dispersal. The foraging quality
of the riparian habitat depends on moisture, composition of the plant community, and presence of
pools and backwater aquatic areas for breeding. CRLFs can be found living within streams at
distances up to 3 km (2 miles) from their breeding site and have been found up to 30 m (100 feet)
from water in dense riparian vegetation for up to 77 days (USFWS 2002).
During dry periods, the CRLF is rarely found far from water, although it will sometimes disperse
from its breeding habitat to forage and seek other suitable habitat under downed trees or logs,
industrial debris, and agricultural features (UWFWS 2002). According to Jennings and Hayes
(1994), CRLFs also use small mammal burrows and moist leaf litter as habitat. In addition,
CRLFs may also use large cracks in the bottom of dried ponds as refugia; these cracks may
provide moisture for individuals avoiding predation and solar exposure (Alvarez 2000).
2.6 Designated Critical Habitat
In a final rule published on April 13, 2006, 34 separate units of critical habitat were designated
for the CRLF by USFWS (USFWS 2006; FR 51 19244-19346). A summary of the 34 critical
habitat units relative to USFWS-designated recovery units and core areas (previously discussed
in Section 2.5.1) is provided in Table 6.
‘Critical habitat’ is defined in the ESA as the geographic area occupied by the species at the time
of the listing where the physical and biological features necessary for the conservation of the
species exist, and there is a need for special management to protect the listed species. It may
also include areas outside the occupied area at the time of listing if such areas are ‘essential to
the conservation of the species.’ All designated critical habitat for the CRLF was occupied at the
time of listing. Critical habitat receives protection under Section 7 of the ESA through
prohibition against destruction or adverse modification with regard to actions carried out, funded,
or authorized by a federal Agency. Section 7 requires consultation on federal actions that are
likely to result in the modification of critical habitat.
To be included in a critical habitat designation, the habitat must be ‘essential to the conservation
of the species.’ Critical habitat designations identify, to the extent known using the best
scientific and commercial data available, habitat areas that provide essential life cycle needs of
the species or areas that contain certain primary constituent elements (PCEs) (as defined in 50
CFR 414.12(b)). PCEs include, but are not limited to, space for individual and population
growth and for normal behavior; food, water, air, light, minerals, or other nutritional or
physiological requirements; cover or shelter; sites for breeding, reproduction, rearing (or
development) of offspring; and habitats that are protected from disturbance or are representative
of the historic geographical and ecological distributions of a species. The designated critical
habitat areas for the CRLF are considered to have the following PCEs that justify critical habitat
designation:
Page 33 of 137
• Breeding aquatic habitat;
• Non-breeding aquatic habitat;
• Upland habitat; and
• Dispersal habitat.
Please note that a more complete description of these habitat types is provided in Attachment 1.
Occupied habitat may be included in the critical habitat only if essential features within the
habitat may require special management or protection. Therefore, USFWS does not include
areas where existing management is sufficient to conserve the species. Critical habitat is
designated outside the geographic area presently occupied by the species only when a
designation limited to its present range would be inadequate to ensure the conservation of the
species. For the CRLF, all designated critical habitat units contain all four of the PCEs, and were
occupied by the CRLF at the time of FR listing notice in April 2006. The FR notice designating
critical habitat for the CRLF includes a special rule exempting routine ranching activities
associated with livestock ranching from incidental take prohibitions. The purpose of this
exemption is to promote the conservation of rangelands, which could be beneficial to the CRLF,
and to reduce the rate of conversion to other land uses that are incompatible with CRLF
conservation. Please see Attachment 1 for a full explanation on this special rule.
USFWS has established modification standards for designated critical habitat (USFWS 2006).
Activities that may modify critical habitat are those that alter the PCEs and jeopardize the
continued existence of the species. Evaluation of actions related to use of dimethoate that may
alter the PCEs of the CRLF’s critical habitat form the basis of the critical habitat impact analysis.
According to USFWS (2006), activities that may affect critical habitat and therefore result in
effects to the CRLF include, but are not limited to the following:
(1) Significant alteration of water chemistry or temperature to levels beyond the tolerances
of the CRLF that result in direct or cumulative effects to individuals and their life-
cycles.
(2) Significant increase in sediment deposition within the stream channel or pond or
disturbance of upland foraging and dispersal habitat that could result in elimination or
reduction of habitat necessary for the growth and reproduction of the CRLF by
increasing the sediment deposition to levels that would affect their ability to complete
their life cycles.
(3) Significant alteration of channel/pond morphology or geometry that may lead to changes
to the hydrologic functioning of the stream or pond and alter the timing, duration, water
flows, and levels that would degrade or eliminate the CRLF and/or its habitat. Such an
effect could also lead to increased sedimentation and degradation in water quality to
levels that are beyond the CRLF’s tolerances.
(4) Elimination of upland foraging and/or aestivating habitat or dispersal habitat.
(5) Introduction, spread, or augmentation of non-native aquatic species in stream segments
or ponds used by the CRLF.
(6) Alteration or elimination of the CRLF’s food sources or prey base (also evaluated as
indirect effects to the CRLF).
Page 34 of 137
As previously noted in Section 2.1, the Agency believes that the analysis of direct and indirect
effects to listed species provides the basis for an analysis of potential effects on the designated
critical habitat. Because dimethoate is expected to directly impact living organisms within the
action area, critical habitat analysis for dimethoate is limited in a practical sense to those PCEs of
critical habitat that are biological or that can be reasonably linked to biologically mediated
processes.
2.7 Action Area
For listed species assessment purposes, the action area is considered to be the area affected
directly or indirectly by the federal action and not merely the immediate area involved in the
action (50 CFR 402.02). It is recognized that the overall action area for the national registration
of dimethoate is likely to encompass considerable portions of the United States based on its uses.
However, the scope of this assessment limits consideration of the overall action area to those
portions that may be applicable to the protection of the CRLF and its designated critical habitat
within the state of California. Deriving the geographical extent of this portion of the action area
is the product of consideration of the types of effects that dimethoate may be expected to have on
the environment, the exposure levels to dimethoate that are associated with those effects, and the
best available information concerning the use of dimethoate and its fate and transport within the
state of California.
The definition of action area requires a stepwise approach that begins with an understanding of
the federal action. The federal action is defined by the currently labeled uses for dimethoate. An
analysis of labeled uses and review of available product labels was completed. This analysis
indicates that the following uses are considered as part of the federal action evaluated in this
assessment: alfalfa, beans, broccoli, Brussels sprouts, cauliflower, celery, Chinese cabbage,
cotton, endive (escarole), field corn, garbanzo beans, grass for seed, herbaceous ornamentals,
honeydew, kale, kohlrabi, lentils, lettuce, lupine, melon, mustard greens, peas, peppers, popcorn,
potatoes, safflower, sainfoin, sorghum, soybeans, Swiss chard, tomatoes, triticale, turnips, wheat,
conifer seed orchards, cottonwood, pears, pecans and citrus.
After determination of which uses will be assessed, an evaluation of the potential “footprint” of
the use pattern is determined. This “footprint” represents the initial area of concern and is
typically based on available land cover data. Local land cover data available for the state of
California were analyzed to refine the understanding of potential dimethoate uses. The initial
area of concern is defined as all land cover types that represent the labeled uses described above.
The initial area of concern is represented by 1) agricultural landcovers, which are assumed to
represent vegetable and non-orchard fruit crops as well as ornamental crops; 2) orchard,
vineyard and forestry landcovers. The specific uses which correspond to each of these landcovers
are depicted in Table 7. Maps representing the land cover types that make up the initial areas of
concern for these separate uses are depicted in Figures 4 and 5. These maps represent the areas
that may be directly affected by the federal action.
Page 35 of 137
Table 7. Dimethoate uses and their respective GIS landcovers used to depict the initial dimethoate area of
concern for this assessment.
GIS layer Uses
agriculture alfalfa, beans, broccoli, Brussels sprouts, cauliflower, celery, Chinese
cabbage, cotton, endive (escarole), field corn, garbanzo beans, grass for seed,
herbaceous ornamentals, honeydew, kale, kohlrabi, lentils, lettuce, lupine,
melon, mustard greens, peas, peppers, popcorn, potatoes, safflower, sainfoin,
sorghum, soybeans, Swiss chard, tomatoes, triticale, turnips, wheat
Orchard, vineyard and pears, pecans, citrus, conifer seed orchards, cottonwood, non-cropland areas
forestry adjacent to vineyards
Once the initial area of concern is defined, the next step is to compare the extent of that area with
the results of the screening level risk assessment. In this assessment, transport of dimethoate
through runoff and spray drift is considered in deriving quantitative estimates of dimethoate
exposure to CRLF, its prey and its habitats.
Since this screening level risk assessment defines taxa that are predicted to be exposed through
runoff and drift to dimethoate at concentrations above the Agency’s Levels of Concern (LOC),
the action area is expanded to include areas that are affected indirectly by this federal action.
Two methods are employed to define the areas indirectly affected by the federal action, and thus
the total action area. These are the down stream dilution assessment for determining the extent of
the affected lotic aquatic habitats (flowing water) and the spray drift assessment for determining
the extent of the affected terrestrial and lentic aquatic (standing water) habitats. In order to define
the final action areas relevant to uses of dimethoate, it is necessary to combine areas directly
affected, as well as aquatic and terrestrial habitats indirectly affected by the federal action. It is
assumed that lentic aquatic habitats (e.g. ponds, pools, marshes) overlapping with the terrestrial
areas are also indirectly affected by the federal action. The analysis of areas indirectly affected
by the federal action, as well as the determination of the final action area for dimethoate is
described in the risk discussion (Section 5.2.5). Additional analysis related to the intersection
of the dimethoate action area and CRLF habitat used in determining the final action area is
described in Appendix C.
Page 36 of 137
'.
Legend
_ Ag ricultur al La ndco ve r
D Count y Boun da ry
-- ~M il e s
Co mpil ed from Californ ia Count y bo un da nes (ESRI, 21)] 2) ,

US DA Na tion al Agll cultur e Stati st ic al Serv ice (NASS, 20 02)
Map created by U. S. Environm ent al Prot e ction Agency,
Offic e of Pe stici de s Progr ams, Enmonm ent a l Fa te and
Effects Dr,. ision. Ap ril ll , 2007
Gap ;\na lysls Progr am Orch ard/ Vin eya rd Landcove r (G AP)
Na tlo nal Land Co ve r Da taba se (NLC D) (MR LC , 20 01) Pr oj e ction: AJb ers Equ al he a Coni c USG S,
Nort h Ame "c an Datum of 1983 (NAO 1~ 3)
Figure 4. Initial area of concern for crops described by agricultural landcover which corresponds to potential
dimethoate use sites. This map represents the area potentially directly affected by the federal action.
Page 37 of 137
Legend
D Count y Bound ary
For est
Orch a rdNin e ya rd
-- ~M il e s
Co mpil ed from C aliforn ia Count y bo un daries (ESRI, 21)] 2) , Map created by U.S. Environm ent al Prot ect ion Age ncy,
Offic e of Pe sticid e s Prog rams, Environm ent a l Fa te and
USD A Na tio nal Ag ricultur e Stati st ic al Se tv ic e (NASS, 2002)
Effects Dr,.ision. Ap rill1, 2007
Gap ;\na lysis Progr am Orch ard/Vin eya rd Landcover (G AP)
Na tio nal Land Co ve r Databa se (NLC D) (MR LC , 2001 ) Pr oj e ction: AJb ers Equ al he a Conic USG S,
North Ame ric an Datum of 1983 (NAO 1~3)
Figure 5. Initial area of concern for crops described by orchard, vineyard and forestry landcover which
corresponds to potential dimethoate use sites. This map represents the area potentially directly affected by
the federal action.
Page 38 of 137
2.8 Assessment Endpoints and Measures of Ecological Effect
Assessment endpoints are defined as “explicit expressions of the actual environmental value that
is to be protected” (USEPA 1992). Selection of the assessment endpoints is based on valued
entities (e.g., CRLF, organisms important in the life cycle of the CRLF, and the PCEs of its
designated critical habitat), the ecosystems potentially at risk (e.g,. water bodies, riparian
vegetation, and upland and dispersal habitats), the migration pathways of dimethoate (e.g.,
runoff, spray drift, etc.), and the routes by which ecological receptors are exposed to the
pesticide (e.g., direct contact, etc).
2.8.1 Assessment Endpoints for the CRLF
Assessment endpoints for the CRLF include direct toxic effects on the survival, reproduction,
and growth of the CRLF, as well as indirect effects, such as reduction of the prey base and/or
modification of its habitat. In addition, potential modification of critical habitat is assessed by
evaluating potential effects to PCEs, which are components of the habitat areas that provide
essential life cycle needs of the CRLF. Each assessment endpoint requires one or more
“measures of ecological effect,” defined as changes in the attributes of an assessment endpoint or
changes in a surrogate entity or attribute in response to exposure to a pesticide. Specific
measures of ecological effect are generally evaluated based on acute and chronic toxicity
information from registrant-submitted guideline tests that are performed on a limited number of
organisms. Additional ecological effects data from the open literature are also considered.
A complete discussion of all the toxicity data available for this risk assessment, including
resulting measures of ecological effect selected for each taxonomic group of concern, is included
in Section 4 of this document. A summary of the assessment endpoints and measures of
ecological effect selected to characterize potential assessed direct and indirect CRLF risks
associated with exposure to dimethoate is provided in Table 8.
Page 39 of 137
Table 8. Summary of Assessment Endpoints and Measures of Ecological Effects for Direct and Indirect
Effects of Dimethoate on the California Red-legged Frog.
Assessment Endpoint Measures of Ecological Effects
Aquatic Phase
(eggs, larvae, tadpoles, juveniles, and adults)a
1. Survival, growth, and reproduction of CRLF 1a. Rainbow Trout LC50
individuals via direct effects on aquatic phases 1b. Rainbow Trout NOAEC
2. Survival, growth, and reproduction of CRLF 2a. Stonefly acute EC50
individuals via effects to food supply (i.e., freshwater 2b. Stonefly chronic NOAECc
invertebrates, non-vascular plants) 2c. Algae EC50
3. Survival, growth, and reproduction of CRLF
individuals via indirect effects on habitat, cover, and/or 3a. Algae EC50
primary productivity (i.e., aquatic plant community)
individuals via effects to riparian vegetation, required to
4a. no data are available for deriving RQs
maintain acceptable water quality and habitat in ponds
and streams comprising the species’ current range.
Terrestrial Phase
(Juveniles and adults)
5. Survival, growth, and reproduction of CRLF 5a. Red winged blackbird acute LD50 b
individuals via direct effects on terrestrial phase adults 5b. Ring-necked pheasant subacute LC50 b
and juveniles 5b. Northern bobwhite quail chronic NOAEC b
6a. Honeybee acute contact LD50
6. Survival, growth, and reproduction of CRLF 6b. Laboratory rat LD50
individuals via effects on prey (i.e., terrestrial 6c. Laboratory rat chronic NOAEC
invertebrates, small terrestrial vertebrates, including 6d. Red winged blackbird acute LD50 b
mammals and terrestrial phase amphibians) 6e. Ring-necked pheasant subacute LC50 b
6f. Northern bobwhite quail chronic NOAEC b
individuals via indirect effects on habitat (i.e., riparian 7a. no data are available for deriving RQs
vegetation)
a
Adult frogs are no longer in the “aquatic phase” of the amphibian life cycle; however, submerged adult frogs are considered
“aquatic” for the purposes of this assessment because exposure pathways in the water are considerably different that exposure
pathways on land.
b
Birds are used as surrogates for terrestrial phase amphibians.
c
Estimated using acute-to-chronic ratio.
2.8.2. Assessment Endpoints for Designated Critical Habitat
As previously discussed, designated critical habitat is assessed to evaluate actions related to the
use of dimethoate that may alter the PCEs of the CRLF’s critical habitat. PCEs for the CRLF
were previously described in Section 2.6. Actions that may modify critical habitat are those that
alter the PCEs and may jeopardize the continued existence of the CRLF. Therefore, these
actions are identified as assessment endpoints. It should be noted that evaluation of PCEs as
assessment endpoints is limited to those of a biological nature (i.e., the biological resource
requirements for the listed species associated with the critical habitat) and those for which
dimethoate effects data are available.
Assessment endpoints and measures of ecological effect selected to characterize potential

modification to designated critical habitat associated with exposure to dimethoate are provided in
Table 9. Adverse modification to the critical habitat of the CRLF includes the following, as
specified by USFWS (2006) and previously discussed in Section 2.6:
1. Alteration of water chemistry/quality including temperature, turbidity, and oxygen

content necessary for normal growth and viability of juvenile and adult CRLFs.
Page 40 of 137
2. Alteration of chemical characteristics necessary for normal growth and viability of
juvenile and adult CRLFs.
3. Significant increase in sediment deposition within the stream channel or pond or
disturbance of upland foraging and dispersal habitat.
4. Significant alteration of channel/pond morphology or geometry.
5. Elimination of upland foraging and/or aestivating habitat, as well as dispersal habitat.
6. Introduction, spread, or augmentation of non-native aquatic species in stream
segments or ponds used by the CRLF.
7. Alteration or elimination of the CRLF’s food sources or prey base.
Measures of such possible effects by labeled use of dimethoate on critical habitat of the CRLF
are described in Table 9. Some components of these PCEs are associated with physical abiotic
features (e.g., presence and/or depth of a water body, or distance between two sites), which are
not expected to be measurably altered by use of pesticides. Assessment endpoints used for the
analysis of designated critical habitat are based on the modification standard established by
USFWS (2006).
Table 9. Summary of Assessment Endpoints and Measures of Ecological Effect for Primary Constituent
Elements of Designated Critical Habitat.
Assessment Endpoint Measures of Ecological Effect
Aquatic-Phase PCEs
(Aquatic Breeding Habitat and Aquatic Non-Breeding Habitat)
Alteration of channel/pond morphology or geometry and/or increase in sediment
deposition within the stream channel or pond: aquatic habitat (including riparian
Algae EC50
vegetation) provides for shelter, foraging, predator avoidance, and aquatic dispersal for
Alteration in water chemistry/quality including temperature, turbidity, and oxygen
Algae EC50
content necessary for normal growth and viability of juvenile and adult CRLFs and their
food source.*
Rainbow Trout LC50
Rainbow Trout NOAEC
Alteration of other chemical characteristics necessary for normal growth and viability of
Stonefly acute EC50
CRLFs and their food source.
Stonefly chronic NOAEC
Algae EC50
Reduction and/or modification of aquatic-based food sources for pre-metamorphs (e.g.,
Algae EC50
algae)
Terrestrial-Phase PCEs
(Upland Habitat and Dispersal Habitat)
Elimination and/or disturbance of upland habitat; ability of habitat to support food
source of CRLFs: Upland areas within 200 ft of the edge of the riparian vegetation or
dripline surrounding aquatic and riparian habitat that are comprised of grasslands,
woodlands, and/or wetland/riparian plant species that provides the CRLF shelter,
forage, and predator avoidance
Elimination and/or disturbance of dispersal habitat: Upland or riparian dispersal habitat
no data are available for deriving RQs
within designated units and between occupied locations within 0.7 mi of each other that
allow for movement between sites including both natural and altered sites which do not
contain barriers to dispersal
Reduction and/or modification of food sources for terrestrial phase juveniles and adults
Alteration of chemical characteristics necessary for normal growth and viability of
juvenile and adult CRLFs and their food source.
*Physico-chemical water quality parameters such as salinity, pH, and hardness are not evaluated because these processes are not
biologically mediated and, therefore, are not relevant to the endpoints included in this assessment.
Page 41 of 137
2.9 Conceptual Model
2.9.1 Risk Hypotheses
Risk hypotheses are specific assumptions about potential effects (i.e., changes in assessment
endpoints) and may be based on theory and logic, empirical data, mathematical models, or
probability models (U.S. EPA, 1998). For this assessment, the risk is stressor-linked, where the
stressor is the release of dimethoate to the environment. The following risk hypotheses are
presumed for this endangered species assessment:
• Labeled uses of dimethoate within the action area may directly affect the CRLF by
causing mortality or by affecting growth or fecundity;
• Labeled uses of dimethoate within the action area may indirectly affect the CRLF by
reducing or changing the composition of food supply;
• Labeled uses of dimethoate within the action area may indirectly affect the CRLF and/or
modify designated critical habitat by reducing or changing the composition of the aquatic
plant community in the ponds and streams comprising the species’ current range and
designated critical habitat, thus affecting primary productivity and/or cover;
• Labeled uses of dimethoate within the action area may indirectly affect the CRLF and/or
modify designated critical habitat by reducing or changing the composition of the
terrestrial plant community (i.e., riparian habitat) required to maintain acceptable water
quality and habitat in the ponds and streams comprising the species’ current range and
designated critical habitat;
• Labeled uses of dimethoate within the action area may modify the designated critical
habitat of the CRLF by reducing or changing breeding and non-breeding aquatic habitat
(via modification of water quality parameters, habitat morphology, and/or
sedimentation);
habitat of the CRLF by reducing the food supply required for normal growth and viability
of juvenile and adult CRLFs;
habitat of the CRLF by reducing or changing upland habitat within 200 ft of the edge of
the riparian vegetation necessary for shelter, foraging, and predator avoidance.
habitat of the CRLF by reducing or changing dispersal habitat within designated units
and between occupied locations within 0.7 mi of each other that allow for movement
between sites including both natural and altered sites which do not contain barriers to
dispersal.
habitat of the CRLF by altering chemical characteristics necessary for normal growth and
viability of juvenile and adult CRLFs.
Page 42 of 137
2.9.2 Diagram
The conceptual model is a graphic representation of the structure of the risk assessment. It
specifies the stressor (dimethoate), release mechanisms, biological receptor types, and effects
endpoints of potential concern. The conceptual models for aquatic and terrestrial phases of the
CRLF are shown in Figures 6 and 7, and the conceptual models for the aquatic and terrestrial
PCE components of critical habitat are shown in Figures 8 and 9. Exposure routes shown in
dashed lines are not quantitatively considered because the resulting exposures are expected to be
so low as not to cause effects to the CRLF.
presence in surface waters and precipitation in California indicate that runoff, spray drift,
volatilization and limited atmospheric transport and deposition represent potential transport
mechanisms of dimethoate to the aquatic and terrestrial habitats of the CRLF. These transport
properties (e.g. sources) are depicted in the conceptual models below (Figures 6-9) along with
the receptors of concern and the potential attribute changes in the receptors due to exposures to
dimethoate. Based on available fate and transport data for dimethoate, field dissipation studies
and lack of detections of dimethoate in ground water samples, dimethoate is not expected to
reach ground water at levels sufficient to be of concern to the CRLF.
Dimethoate applied to use site

Stressor
Source Spray drift Runoff Soil Groundwater Long range

atmospheric
transport
Exposure Surface water/

Sediment Wet/dry deposition
Media
Uptake/gills Uptake/cell,
Riparian plant
or integument roots, leaves
terrestrial
Uptake/gills exposure
or integument Aquatic Animals Aquatic Plants
pathways see
Invertebrates Non-vascular
Figure 7
Vertebrates Vascular
Ingestion Ingestion
Receptors Red-legged Frog
Eggs Juveniles
Larvae Adult
Tadpoles
Attribute Individual organisms Habitat integrity

Reduced survival Food chain Reduction in primary productivity
Change Reduced growth Reduced cover
Reduction in algae
Reduced reproduction Reduction in prey Community change
Figure 6. Conceptual model for potential effects of dimethoate on the aquatic phase of the California red-
legged frog.
Page 43 of 137
Stressor
Direct Spray drift Runoff Long range

Source application atmospheric
transport
Exposure Dermal uptake/Ingestion Soil
Media Root uptake
Terrestrial Terrestrial/riparian plants Wet/dry deposition
insects grasses/forbs, fruit, seeds
(trees, shrubs)
Ingestion
Ingestion
Ingestion
Amphibians
Ingestion Mammals
Ingestion
Receptors Red-legged Frog

Juvenile
Adult
Attribute Individual organisms Habitat integrity

Reduced survival Food chain Reduction in primary productivity
Change Reduced growth Reduced cover
Reduction in prey
Reduced reproduction Community change
Figure 7. Conceptual model for the potential effects of dimethoate on the terrestrial phase of the California
red-legged frog.
Page 44 of 137
Stressor
Soil Groundwater Long range

Source Spray drift Runoff
atmospheric
Surface water/ transport
Exposure
Sediment Wet/dry deposition
Media
Uptake/gills Uptake/cell, Uptake/cell,
or integument roots, leaves roots, leaves
Uptake/gills
Receptors or integument Aquatic Animals Aquatic Plants
Invertebrates Non-vascular Riparian and
Vertebrates Vascular Upland plants
Red-legged Frog terrestrial exposure
Eggs Juveniles pathways and PCEs
Ingestion Ingestion
Larvae Adult see Figure 9
Tadpoles
Individual organisms Individual organisms Population Community

Attribute Reduced survival Reduced survival Yield Reduced seedling
Change Reduced growth Reduced growth Reduced yield emergence or vegetative
Reduced reproduction Reduced reproduction vigor (Distribution)
Habitat quality and channel/pond

Habitat Other chemical Food sources morphology or geometry
PCEs characteristics Reduction in algae Adverse water quality changes
Adversely modified Reduction in prey Increased sedimentation
chemical characteristics Reduced shelter
Figure 8. Conceptual model for the potential effects of dimethoate on aquatic components of the California
red-legged frog critical habitat.
Page 45 of 137
Stressor
Direct Long range

Source application
Spray drift Runoff
atmospheric
transport
Dermal uptake/Ingestion Soil
Exposure
Media and Root uptake
Terrestrial Terrestrial plants Wet/dry deposition
Receptors insects grasses/forbs, fruit, seeds
(trees, shrubs)
Ingestion
Ingestion Ingestion
Red-legged Frog Ingestion Mammals

Juvenile
Adult
Community
Attribute Individual organisms Population Reduced seedling emergence or
Reduced survival Reduced survival vegetative vigor (Distribution)
Change Reduced growth Reduced growth
Reduced reproduction Reduced reproduction
Elimination and/or disturbance of

Habitat Other chemical upland or dispersal habitat
PCEs characteristics Food resources Reduction in primary productivity
Adversely modified Reduction in food Reduced shelter
chemical characteristics sources Restrict movement
Figure 9. Conceptual model for the potential effects of dimethoate on terrestrial components of the California
red-legged frog critical habitat.
2.10 Analysis Plan
In order to address the risk hypothesis, the potential for effects on the CRLF, its prey and its
habitat is estimated. In the following sections, the use, environmental fate, and ecological effects
of dimethoate are characterized and integrated to assess the risks. This was accomplished using
a risk quotient (ratio of exposure concentration to effects concentration) approach. Although risk
is often defined as the likelihood and magnitude of ecological effects, the risk quotient-based
approach does not provide a quantitative estimate of likelihood and/or magnitude of an effect.
However, as outlined in the Overview Document (USEPA 2004), the likelihood of effects to
individual organisms from particular uses of dimethoate is estimated using the probit dose-
response slope and either the level of concern (discussed below) or actual calculated risk quotient
value.
Page 46 of 137
2.10.1. Measures to Evaluate the Risk Hypothesis and Conceptual Model
2.10.1.1. Measures of Exposure
presence in surface water, in air and in precipitation in California indicate that spray drift,
volatilization, atmospheric transport and subsequent deposition represent potential transport
mechanisms of dimethoate to the aquatic and terrestrial habitats of the CRLF. In this assessment,
transport of dimethoate through runoff and spray drift is considered in deriving quantitative
estimates of dimethoate exposure to CRLF, its prey and its habitats. Although volatilization of
dimethoate from treated areas resulting in atmospheric transport and deposition represent
relevant transport pathways leading to exposure of the CRLF and its habitats, adequate tools are
unavailable at this time to quantify exposures through these pathways. Therefore, volatilization,
atmospheric transport and wet and dry deposition from the atmosphere are discussed only
qualitatively in this assessment.
Measures of exposure are based on aquatic and terrestrial models that predict estimated
environmental concentrations (EECs) of dimethoate using maximum labeled application rates
and methods. The models used to predict aquatic EECs are the Pesticide Root Zone Model
coupled with the Exposure Analysis Model System (PRZM/EXAMS). The model used to
predict terrestrial EECs on food items was T-REX. These models were parameterized using
relevant reviewed registrant-submitted environmental fate data.
PRZM (v3.12.2, May 2005) and EXAMS (v2.98.4.6, April 2005) are screening simulation
models coupled with the input shell pe5.pl (Aug 2007) to generate daily exposures and 1-in-10
year EECs of dimethoate that may occur in surface water bodies adjacent to application sites
receiving dimethoate through runoff and spray drift. PRZM simulates pesticide application,
movement and transformation on an agricultural field and the resultant pesticide loadings to a
receiving water body via runoff, erosion and spray drift. EXAMS simulates the fate of the
pesticide and resulting concentrations in the water body. The standard scenario used for
ecological pesticide assessments assumes application to a 10-hectare agricultural field that drains
into an adjacent 1-hectare water body, 2-meters deep (20,000 m3 volume) with no outlet.
PRZM/EXAMS was used to estimate screening-level exposure of aquatic organisms to
dimethoate. The measure of exposure for aquatic species is the 1-in-10 year return peak or
rolling mean concentration. The 1-in-10 year peak is used for estimating acute exposures of
direct effects to the CRLF, as well as indirect effects to the CRLF through effects to potential
prey items, including: algae, aquatic invertebrates, fish and frogs. The 1-in-10-year 60-day mean
is used for assessing chronic exposure to the CRLF and fish and frogs serving as prey items; the
1-in-10-year 21-day mean is used for assessing chronic exposure for aquatic invertebrates, which
are also potential prey items.
Exposure estimates for terrestrial-phase CRLF and terrestrial invertebrates and mammals
(serving as potential prey) assumed to be in the target area or in an area exposed to spray drift are
derived using the T-REX model (version 1.3.1, 12/07/2006). This model incorporates the
Kenega nomograph, as modified by Fletcher et al. (1994), which is based on a large set of actual
field residue data. The upper limit values from the nomograph represented the 95th percentile of
Page 47 of 137
residue values from actual field measurements (Hoerger and Kenega, 1972). The Fletcher et al.
(1994) modifications to the Kenega nomograph are based on measured field residues from 249
published research papers, including information on 118 species of plants, 121 pesticides, and 17
chemical classes. These modifications represent the upper bound of the expanded data set. For
modeling purposes, direct exposures of the CRLF to dimethoate through contaminated food are
estimated using the EECs for the small bird (20 g) which consumes small insects. Dietary-based
and dose-based exposures of potential prey (small mammals) are assessed using the small
mammal (15 g) which consumes short grass. The small bird (20g) consuming small insects and
the small mammal (15g) consuming short grass were used because these categories represent the
largest RQs of the size and dietary categories in T-REX that are appropriate surrogates for the
CRLF and one of its prey items. Estimated exposures of terrestrial insects to dimethoate are
bound by using the dietary-based EECs for small insects and large insects.
Birds are currently used as surrogates for terrestrial-phase CRLF. However, amphibians are
poikilotherms (body temperature varies with environmental temperature) while birds are
homeotherms (temperature is regulated, constant, and largely independent of environmental
temperatures). Therefore, amphibians tend to have much lower metabolic rates and lower caloric
intake requirements than birds or mammals. As a consequence, birds are likely to consume more
food than amphibians on a daily dietary intake basis, assuming similar caloric content of the food
items. Therefore, the use of avian food intake allometric equation as a surrogate for amphibians
is likely to result in an over-estimation of exposure and risk for reptiles and terrestrial-phase
amphibians. Therefore, T-REX (version 1.3.1) has been refined to the T-HERPS model (v. 1.0),
which allows for an estimation of food intake for poikilotherms using the same basic procedure
as T-REX to estimate avian food intake.
Two spray drift models, AGDISP and AgDRIFT were used to assess exposures of terrestrial-
phase CRLF and its prey to dimethoate deposited in spray drift. AGDisp (version 8.13; dated
12/14/2004) (Teske and Curbishley, 2003) is used to simulate aerial and ground applications
using the Gaussian far-field extension. AgDrift (version 2.01; dated 5/24/2001) is used to
simulate spray blast applications to orchard crops.
2.10.1.2. Measures of Effect
Data identified in Section 2.8 are used as measures of effect for direct and indirect effects to the
CRLF. Data were obtained from registrant submitted studies or from literature studies identified
by ECOTOX. The ECOTOXicology database (ECOTOX) was searched in order to provide more
ecological effects data and in an attempt to bridge existing data gaps. ECOTOX is a source for
locating single chemical toxicity data for aquatic life, terrestrial plants, and wildlife. ECOTOX
was created and is maintained by the USEPA, Office of Research and Development, and the
National Health and Environmental Effects Research Laboratory’s Mid-Continent Ecology
Division (ECOTOX, 2007).
The assessment of risk for direct effects to the CRLF makes the assumption that avian toxicity is
similar to terrestrial-phase CRLF. The same assumption is made for fish and aquatic-phase
CRLF. Aquatic invertebrates and algae represent potential prey of the CRLF in the aquatic
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habitat. Aquatic plants and semi-aquatic plants represent habitat of CRLF. Terrestrial
invertebrates and small mammals represent potential prey of the CRLF in the terrestrial habitat.
The acute measures of effect used for animals in this assessment are the LD50, LC50 and EC50.
The acronym “LD” stands for “Lethal Dose” and LD50 is the amount of a material, given all at
once, that is estimated to cause the death of 50% of the test organisms. The acronym “LC” stands
for “Lethal Concentration” and LC50 is the concentration of a chemical that is estimated to kill
50% of the test organisms. The acronym “EC” stands for “Effective Concentration” and the
EC50 is the concentration of a chemical that is estimated to produce a specific effect in 50% of
the test organisms. Endpoints for chronic measures of exposure for listed and non-listed animals
are the NOAEL/NOAEC and NOEC. The acronym “NOAEL” stands for “No Observed-
Adverse-Effect-Level” and refers to the highest tested dose of a substance that has been reported
to have no harmful (adverse) effects on test organisms. The NOAEC (i.e., “No-Observed-
Adverse-Effect-Concentration”) is the highest test concentration at which none of the observed
effects were statistically different from the control. The NOEC is the No-Observed-Effects-
Concentration. For non-listed plants, only acute exposures are assessed (i.e., EC25 for terrestrial
plants and EC50 for aquatic plants).
2.10.1.3. Integration of Exposure and Effects
Risk characterization is the integration of exposure and ecological effects characterization to

determine the potential ecological risk from the use of dimethoate on fruits, nuts, vegetables and
ornamentals, and the likelihood of direct and indirect effects to CRLF in aquatic and terrestrial
habitats. The exposure and toxicity effects data are integrated in order to evaluate the risks of
ecological effects on non-target species. For the assessment of dimethoate risks, the risk quotient
(RQ) method is used to compare exposure and measured toxicity values. EECs are divided by
acute and chronic toxicity values. The resulting RQs are then compared to the Agency’s Levels
of Concern (LOCs) (USEPA, 2004) (see Table 10). These criteria are used to indicate when
dimethoate’s uses, as directed on the label, have the potential to cause direct or indirect effects to
the CRLF.
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Table 10. Agency risk quotient (RQ) metrics and levels of concern (LOC) per risk class.
Risk Class Description RQ LOC
Aquatic Habitats
Acute Listed
CRLF may be potentially affected by use via direct or indirect effects. Peak EEC/EC501 0.05
Species
60-day EEC/NOEC
Chronic Listed Potential for chronic risk to CRLF through direct or indirect effects. Indirect (CRLF)
1
Species effects represented by effects to invertebrates, which represent potential prey. 21-day EEC/NOEC
(invertebrates)
Non-Listed Potential for effects in non-listed plants. Peak EEC/ EC50 1
Terrestrial Habitats
Dietary EEC 2/LC50
Acute Listed
CRLF may be potentially affected by use via direct or indirect effects. Or 0.1
Species
Dose EEC 2/LD50
Acute Listed Potential effects to terrestrial invertebrates. CRLF may be potentially
EEC 2/LD50 0.05
Species affected by use via direct or indirect effects.
Potential for chronic risk to CRLF through direct or indirect effects. Indirect
Chronic Listed
effects represented by effects to small mammals, which represent potential EEC 2/NOAEC 1
Species
prey.
Non-Listed Potential for effects in non-listed plants. Peak EEC/ EC25 1
1
LC50 or EC50.
2
Based on upper-bound Kenaga values.
2.10.1.4. Data Gaps
No data are available for assessing the effects of exposures of dimethoate to freshwater, vascular
plants. Generally, data for duckweed (Lemna gibba) are used to assess these effects. In addition,
no data are available for deriving RQs to assess the effects of exposures of dimethoate to riparian
and terrestrial vegetation, which are generally represented by effects data for terrestrial
agricultural crop species.
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3. Exposure Assessment
3.1 Aquatic Exposure Assessment
3.1.1 Existing Water Monitoring Data for California
EFED finalized the Environmental Fate and Ecological Risk assessment for dimethoate in 2006
(USEPA 2006). That assessment contained a surface water exposure assessment as well as an
ecological risk assessment. The data included in that risk assessment and the conclusions
associated with monitoring data are briefly described below. For more detailed information, see
USEPA 2006. California specific monitoring data for dimethoate are summarized below. These
data include United States Geological Survey’s (USGS) National Water Quality Assessment
(NAWQA) and the CDPR Surface Water Database. Available monitoring data are not
necessarily targeted to detect maximum environmental concentrations of dimethoate, and
therefore are not necessarily representative of peak concentrations of dimethoate that may be
observed in the field.
3.1.1.1. Previous Assessment
A number of National and California-specific surface water monitoring studies are discussed in
the Environmental Fate and Ecological Risk Assessment supporting the Interim Reregistration
Eligibility Decision (IRED) for dimethoate (USEPA 2006). Sources of monitoring data used in
that assessment included: STORET (Storage and Retrieval) database (USEPA 2007), several
USGS surveys (Coupe et al. 1995; Kimbrough and Litke 1996), the Pilot Reservoir Monitoring
Study (Blomquist et al. 2001) the Washington State Pesticide Monitoring Program (Davis 1996
and 2000), and the California Department of Pesticide Regulation (CDPR) investigations in the
San Joaquin Watershed (Ross et al 1996, 1999 and 2000).
Dimethoate was detected in surface waters included in 3 of the 6 studies cited above (the Pilot
Reservoir Monitoring Study, the Washington State Monitoring Program and the CDPR San
Joaquin Basin Study). The highest detection of dimethoate in California was 2.4 µg/L, which
was from a sample collected in the main stem of the San Joaquin River. The results of the San
Joaquin Basin Study indicate that dimethoate was present all summer long in the main stem of
the San Joaquin River during 1991-1992. For more detailed information, see USEPA 2006.
3.1.1.2. NAWQA Data for California
NAWQA monitoring data are available for dimethoate from California surface waters and
ground waters (USGS 2007). No monitoring data are available for the degradate omethoate.
Dimethoate was detected in 8.7% of 265 surface water samples from 2001-2006, with a
maximum concentration of 0.158 µg/L. The level of quantification for these analyses was 0.0061
µg/L. During this time period, 270 ground water samples contained no detectable levels of
dimethoate.
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NAQWA data are defined by the landcover composition of the watershed of the surface waters
from which samples were taken. Of the available surface water samples, dimethoate was
detected in waters from agricultural (9 of 33 samples), mixed (12 of 120 samples) and other (2 of
82 samples) land cover types. As would be expected from its use patterns, dimethoate was not
detected in surface waters from urban watersheds (30 total samples).
3.1.1.3. California Department of Pesticide Regulation Surface Water

Database
CDPR maintains a database of monitoring data of pesticides in CA surface waters. Data are
available from 1990-2005 for 27 counties for several pesticides and their degradates. The
sampled water bodies include rivers, creeks, urban streams, agricultural drains, the San Francisco
Bay delta region and storm water runoff from urban areas. The database contains data from 51
different studies by federal, state and local agencies as well as groups from private industry and
environmental interests. Some data reported in this database are also reported by USGS in
NAWQA; therefore, there is some overlap between these two data sets. Unlike NAWQA data,
the land use (e.g. agriculture, urban) associated with the watershed of the sampled surface waters
is not defined in the CDPR database; therefore, the available data do not allow for a link of the
general use pattern and the individual data. Data for dimethoate are included in this database.
Data are not included for omethoate (CDPR 2007b).
Dimethoate was detected in 11.3% of 2061 surface water samples from 1991-2005, with a
maximum concentration of 11.31 µg/L (Figure 10). The level of quantification for these
analyses ranged 0.04-0.1 µg/L.
Page 52 of 137
12
10
concentration (ug/L)
0
Jun-91 Mar-94 Dec-96 Aug-99 May-02 Feb-05
date
Figure 10. CDPR reported concentrations of dimethoate in surface waters in CA (includes detections and
non-detections, which are represented as 0).
3.1.2. Modeling Approach
As stated above, the Tier II models used to calculate aquatic EECs are PRZM and EXAMS. For
this modeling effort, PRZM scenarios designed to represent different crops and geographic areas
of CA are used in conjunction with the standard pond environment in EXAMS. Use-specific and
chemical-specific parameters for the Pe5 shell as well as PRZM scenarios are described below.
An example of an output file from PRZM/EXAMS is in Appendix D.
3.1.2.1. PRZM scenarios
Several standard PRZM scenarios already exist for California, including: CA almond, CA citrus,
CA cotton, CA fruit, CA nursery, CA tomato. In addition, several scenarios that were developed
for the cumulative organophosphate assessment are available, two of which are useful for this
assessment: CA alfalfa and CA corn. Scenarios were developed for CRLF assessments, including
several that are relevant to this assessment: CA cole crop, CA forestry, CA melon, CA potato,
CA row crop, CA turf, CA wheat and CA wine grapes. PRZM scenarios used to model aquatic
exposures resulting from applications of specific uses are identified in Table 11. In cases where
a scenario does not exist for a specific use, it is necessary to assign a surrogate scenario. Those
surrogates are assigned to be most representative of the use being considered. Justifications for
assignments of surrogates are defined below.
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Table 11. PRZM scenario assignments according to uses of dimethoate.
PRZM scenario Uses
CA alfalfa Alfalfa, lupine, sainfoin
CA almond Pecans
CA citrus Citrus
CA cole crop Broccoli, cauliflower, Chinese cabbage, kohlrabi, kale, mustard greens
CA corn Field corn, popcorn
CA cotton Cotton
CA forestry Conifer seed orchards, cottonwood (for pulp)
CA fruit Pears
CA lettuce Endive (escarole), lettuce, Swiss chard
CA melon Honeydew, melon
CA nursery Herbaceous ornamentals
CA potato Potatoes, turnips
CA row crop Beans, celery, garbanzo beans, lentils, peas, peppers
CA tomato Tomatoes
CA turf Grass for seed
CA wheat Safflower, sorghum, wheat, triticale
CA wine grapes Non-cropland areas adjacent to vineyards
Alfalfa scenario
This scenario is intended to represent alfalfa production in CA and is therefore, directly relevant
to this use. It is used as a surrogate for lupine and sainfoin, which are legumes grown as forage.
Since alfalfa is also a perennial legume, it is assumed that it would have similar cultivation
requirements as lupine and sainfoin. No data have been identified to indicate where in CA lupine
and sainfoin are grown.
Almond scenario
This scenario is intended to represent almond production in CA. Pecan is a nut tree with similar
cultural practices as almonds. Primary California producing areas are located in the same areas
as other nut crops, from Chico-Orland area in the north to Bakersfield in the south.
Citrus scenario
This scenario is intended to represent citrus production in CA, including cultivation of oranges,
grapefruit, lemon, tangelo and tangerines. Therefore, this scenario is directly relevant to
modeling dimethoate applications to citrus.
Cole crop scenario
This scenario is intended to represent cole crop production, specifically broccoli, in the Central
California coast and Coastal Valley Mountain range. Therefore, exposures resulting from
applications of dimethoate to broccoli, Brussels sprouts, Chinese cabbage, cauliflower, kohlrabi,
kale and mustard greens, all of which are classified as “cole crops,” are modeled using this
scenario.
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Corn scenario
This scenario is intended to represent corn production in CA therefore, this scenario is directly
relevant to this use.
Cotton scenario
This scenario is intended to represent cotton production in CA therefore, this scenario is directly
relevant to this use.
Forestry scenario
This scenario is intended to represent cultivation of trees used for forestry purposes. It is
assumed that this scenario would be representative of trees grown for pulp (specifically
cottonwood trees) and seeds.
Fruit scenario
The CA fruit scenario represents an orchard in Fresno County, which is located in the Central
Valley of California. This scenario is intended to represent non-citrus fruit, including peaches,
plums, prunes, pears and apples. Therefore, this scenario is used to represent applications of
dimethoate to pears.
Lettuce scenario
This scenario is intended to represent lettuce, which is a leafy vegetable. It is assumed that this
scenario is representative of other leafy vegetables, including Swiss chard and endive.
Melon scenario
This scenario is intended to represent applications of pesticides to melons in CA and is therefore,

directly relevant to this use.
Nursery scenario
This scenario is intended to represent applications of pesticides on ornamentals in outdoor

nurseries in CA and is therefore, directly relevant to this use.
Potato scenario
The CA potato scenario is representative of a field in Kern County. According to the 2002
census of agriculture (USDA 2007), the majority of turnips grown in California were from Kern
County. Therefore, it is assumed that this crop would grow under similar conditions as the
potato.
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Row crop scenario
This scenario is intended to represent production of carrots, beans, peppers and other crops in
CA, and is therefore, directly relevant to these uses. Peas and celery are considered row crops
and are classified in this category. Therefore, this scenario is used to represent fields growing
beans, garbanzo beans, lentils, celery, peppers and peas.
Tomato scenario
This scenario is intended to represent applications of pesticides to tomatoes in CA and is

therefore, directly relevant to this use.
Turf scenario
This scenario is intended to represent applications of pesticides to turf in CA. Classifications of

turf include sod farms, parks, recreational fields, golf courses and grass grown for seed.
Therefore, this scenario is relevant to modeling applications of dimethoate to grass grown for
seed.
Wheat scenario
This scenario is intended to represent wheat, barley and oats production in CA. Triticale is a
hybrid of rye and wheat. It is assumed that this scenario is representative of cultivation of other
grain crops in CA, including sorghum, safflower and triticale.
Wine grape scenario
This scenario is intended to represent cultivation of grapes in northern coastal CA, specifically in
Sonoma, Napa, Lake and Mendocino Counties. This scenario is used as a surrogate for the non-
cropland areas adjacent to vineyards in Napa, Sonoma, Mendocino and Lake Counties. It is
assumed that the land adjacent to grape vineyards has similar soil and meteorological properties
as the vineyards themselves.
3.1.2.2. Input Parameters
Chemical-specific parameters
The appropriate chemical-specific PRZM input parameters are selected from reviewed
environmental fate data submitted by the registrant (Table 3) and in accordance with EFED
water model input parameter selection guidance (U.S. EPA 2002). The input parameters selected
are similar to those used in the 2006 dimethoate IRED (U.S. EPA, 2006). No new environmental
fate data were incorporated into this assessment. A summary of the chemical specific model
inputs used in this assessment are provided in Table 12.
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Use-specific parameters
Use-specific parameters include application methods and rates (Table 5). Maximum rates per
application and maximum number of applications per year are based on current label directions
(Table 13).
Table 12. PRZM/EXAMS input parameters.

Input Parameter Value Justification
Molecular Wt. (g/mol) 229.25 Measured value
Solubility in water (mg/L) 32,000 Measured value
Henry’s Law Constant (atm-m3/mol) 8.0e-11 Estimated from solubility and vapor pressure
Lowest non-sand value
Kd (L/kg) 0.3
(MRID 00164959)
3 times a single study value
Aerobic Soil Metabolism Half-life (days) 6.202
(MRID 42843201)
Aerobic Aquatic Metabolism Half-life 2 times the aerobic soil metabolism value and
16.4
(days) adjusted for hydrolysis
Anaerobic Aquatic Metabolism Half-life 2 times anaerobic soil metabolism half-life (22d)
40.9
(days) and adjusted for hydrolysis
Upper 90% confidence bound on 24 measured
Foliar Degradation Rate (d-1) (PLDKRT) 0.24
values (Table 4)
Foliar Washoff Coefficient 0.5 Default value
pH 5: 156 Measured values (MRID 00159761)

Hydrolysis Half-life (days) pH 7: 68
pH 9: 4.4
Aqueous Photolysis Half-life (days) 353 Measured value (MRID 00159762)
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Table 13. Use specific parameters used to model aquatic EECs using PRZM/EXAMS.
Use Maximum single application Maximum number of Minimum application
rate (kg/ha) applications per year interval (days)
Alfalfa 0.56 9* 40*
beans*** 0.56 2 14
broccoli 0.56 3 7
Brussels sprouts 1.12 6 7
cauliflower 0.56 3 7
celery 0.56 3 7
citrus 2.24 Not specified** Not specified
(model 1 application)
conifer seed orchards 1.12 1 NA
cotton++ 0.56 2 14
cottonwood (for pulp) 1.12 3 Not specified (assume 7 d)
field corn 0.56 1 NA
honeydew 0.56 2 7
kale 0.28 2 15
kohlrabi 0.56 3 7
lentils 0.56 2 7
Lupine 0.56 2 Not specified (assume 7 d)
melon 0.56 2 7
Non-cropland areas adjacent to vineyards 2.24 2 Not specified (assume 7 d)
pears 0.56 1 NA
pecans 0.37 1 NA
peppers 0.37 5 7
popcorn 0.56 1 NA
potatoes 0.56 2 7
Safflower+++ 0.56 1 NA
sainfoin 0.56 1 NA
sorghum 0.56 2 7
tomatoes 0.56 2 6
triticale 0.56 2 Not specified (assume 7 d)
turnips 0.28 7 3
Wheat+++ 0.56 1 NA
NA = not applicable
*There is one application allowed per cutting. Since alfalfa can have 2-9 cuttings per year (Kaul 2007), there is a maximum of 9 applications
per year. Based on this, it is assumed that there are cuttings throughout the year and there are equal intervals between cuttings. Therefore, there
would be 40 d intervals between cuttings and between pesticide applications.
**Label directions indicate that applications to citrus should be repeated as necessary.
***Labels indicate that rates for beans are relevant to season. It is assumed that beans have one crop per year (Kaul 2007).
++Labels indicate that rates for cotton are relevant to each season of growth. Due to limitations of current PRZM scenarios, it is assumed that in
CA, only one season of cotton is grown per year.
+++Labels indicate that rates for wheat and safflower are relevant to crop. According to Kaul 2007, only one crop of wheat is grown per year.
Since safflower is grouped with wheat, it is assumed that one crop of safflower is also grown per year.
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Application dates are not specified on product labels. For this assessment, application dates are
generally estimated using available use data for dimethoate applications in California during
2001-2005. The month where the most dimethoate was applied during this time period is used as
the application month for modeling purposes (see Appendix B for more information on the crop
specific analyses). The specific application date is defined as the 15th, to represent the middle of
the month. Crop emergence, maturity and harvest dates of each PRZM scenario are considered
to verify that the chosen application date and subsequent applications (if there is more than one
application per year) fall at a time when the crop is present during the simulation of the PRZM
scenario. In some cases, insufficient data were available for defining the historical timing of
dimethoate applications to a use. In those instances, surrogate crops, which are defined according
to the PRZM scenario groups, are used to define the timing of the dimethoate application. In
other cases, the PRZM scenario itself is used to define the appropriate date of the first
dimethoate application. For each dimethoate use, the selected application date and its
justification are defined in Table 14.
Table 14. Application dates for PRZM/EXAMS simulations for modeling associated with dimethoate uses.
PRZM Application
Use Application date comments
scenario date
Alfalfa CA 2-Jan There is one application allowed per cutting. Since alfalfa can have 2-9 cuttings per year (Kaul
alfalfa 2007), there is a maximum of 9 applications per year. Based on this, it is assumed that there are
cuttings throughout the year and there are equal intervals between cuttings. Therefore, there
would be 40 d intervals between cuttings and between pesticide applications. In order to
accommodate that many applications, the initial application date was selected as January 2.
beans CA 1-Mar The emergence date of the PRZM scenario is Jan 1, the maturity date is April 1 and the harvest
rowcrop date is April 8. It is assumed that there is insect pressure on this crop when it is close to maturity.
Therefore, the first application date is chosen as one month before the maturity date.
broccoli CA cole 1-Feb The date of crop emergence in PRZM scenario is Jan 1 and the harvest date is Mar 1. An
crop application date of Feb 1 is selected to allow for all applications to be made to the crop before
harvest.
Brussels sprouts CA 12-Aug See CAPUR data
lettuce
cauliflower CA cole 1-Feb See broccoli explanation
crop
celery CA 1-Mar Consistent with beans
rowcrop
Chinese cabbage CA cole 1-Feb See broccoli explanation
crop
citrus CA citrus 15-May See CAPUR data
conifer seed CA 15-Jan There are no CAPUR data for past applications of dimethoate to this use. The PRZM scenario
orchards forestry indicates that the crop is mature throughout the year. An application date during the rainy period
of the year was chosen to derive conservative EECs.
cotton CA cotton 15-Aug See CAPUR data
cottonwood CA 15-Jan There are no CAPUR data for past applications of dimethoate to this use. The PRZM scenario
(for pulp) forestry indicates that the crop is mature throughout the year. An application date during the rainy period
of the year is chosen to derive conservative EECs.
Endive (escarole) CA 15-Oct consistent with lettuce
lettuce
field corn CA corn 15-Jul See CAPUR data
garbanzo beans CA 1-Mar Consistent with beans
rowcrop
grass for seed CA turf 15-Jan There are no CAPUR data for past applications of dimethoate to this use. The PRZM scenario
indicates that the crop is mature throughout the year. An application date during the rainy period
of the year was chosen to derive conservative EECs.
herbaceous CA 15-Aug See CAPUR data
ornamentals nursery
honeydew CA 1-Jul According to the CAPUR data, the majority of dimethoate use is in August, with use during June
melons to September. The harvest date of the PRZM scenario is August 2. In order to be consistent with
the CAPUR data and the PRZM scenario, an application date of July 1 is selected.
kale CA cole 1-Feb See broccoli explanation
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crop
kohlrabi CA cole 1-Feb See broccoli explanation
crop
lentils CA 1-Mar Consistent with beans
rowcrop
lettuce (leaf) CA 15-Oct See CAPUR data
lettuce
Lupine CA 15-Mar Data are unavailable to define the specific application month for this use. Therefore, alfalfa is
alfalfa used as a surrogate. According to CAPUR use data for alfalfa, the majority of use is in March.
melon CA 1-Jul According to the CAPUR data, the majority of dimethoate use on melons is in august, with use
melons June-September. The harvest date of the PRZM scenario is August 2. In order to be consistent
with the CAPUR data and the PRZM scenario, an application date of July 1 is selected.
mustard greens CA cole 1-Feb See broccoli explanation
crop
Non-cropland CA wine 15-Jul Date set to middle of July, which corresponds to peak use month of dimethoate in California,
areas adjacent to grape according to CA PUR data for 2001-2005.
vineyards
pears CA fruit 15-Jun CAPUR data (note: this is a limited data set, only 3 applications were reported in CAPUR over
2001-2005, 2/3 were in June)
peas CA 1-Mar See CAPUR data
rowcrop
pecans CA 15-Jun See CAPUR data
almond
peppers CA 1-Mar See CAPUR data
rowcrop
popcorn CA corn 15-Jul See CAPUR data
potatoes CA potato 25-May According to the CAPUR data, the majority of dimethoate use is in August, with use during June
to August. The harvest date of the PRZM scenario is June 15. In order to be consistent with the
CAPUR data and the PRZM scenario, an application date of May 25 is selected.
Safflower CA wheat 15-Mar consistent with wheat
sainfoin CA 15-Mar Data are unavailable to define the specific application date for this use. Therefore, the value for
alfalfa lupine is used as a surrogate.
sorghum CA wheat 15-Mar Consistent with wheat
Swiss chard CA 15-Oct Consistent with lettuce
lettuce
tomatoes CA 15-Jul See CAPUR data
tomato
triticale CA wheat 15-Mar Consistent with wheat
turnips CA potato 15-May There are insufficient data from CAPUR to define the period of application of dimethoate to
turnips. In the PRZM scenario, the emergence date is Feb 16 and the harvest date is June 15. All
7 applications must be between this date range. The maturity date is May 15. It is assumed that
there will be insect pest pressure when the crop is mature, but before it is harvested. Therefore,
the maturity date was selected as the first application date.
Wheat CA wheat 15-Mar See CAPUR data
According to labels, aerial applications are permitted for all dimethoate uses, with the exception
of applications to citrus, Brussels sprouts, non-cropland areas adjacent to vineyards and
herbaceous ornamentals. For aerial applications, efficiency and spray drift were chosen as 0.95
and 0.05, respectively, according to input parameter guidance (USEPA 2002). For ground
applications, input parameter guidance is also used to define efficiency and spray drift as 0.99
and 0.01, respectively (USEPA 2002).
In PRZM, application methods are defined by the Chemical Application Method (CAM) values.
A CAM of 1 represents applications to soil with no incorporation. A CAM of 2 is used to
represent foliar applications. For the registered uses of dimethoate, with the exception of citrus, it
is assumed that applications are made directly to the crop. For these uses, a CAM of 2 is
selected. For use of dimethoate on citrus, labels indicate that applications should be made to the
soil. For this, a CAM of 1 is selected.
Page 60 of 137
When CAM 2 is selected, it is necessary to identify an IPSCND value, which represents the
deposition of dimethoate in the post-season. For this modeling effort, an IPSCND of 1 is chosen
to accompany CAM 2 selections. This value represents conversion of dimethoate remaining on
foliage to surface application to the top soil layer.
3.1.3. Aquatic Modeling Results
PRZM/EXAMS EECs representing 1-in-10 year peak, 21-day, and 60-day concentrations of
dimethoate in the aquatic environment are located in Table 15.
Page 61 of 137
Table 15. One-in-ten-year dimethoate EECs for aquatic environments from the application of dimethoate to
uses in California.
Use* peak (µg/L) 21-d (µg/L) 60-d (µg/L)
Alfalfa 6.7 5.5 4.0
beans 5.8 4.5 3.1
broccoli 16.5 13.7 9.4
Brussels sprouts 9.2 6.7 4.2
cauliflower 16.5 13.7 9.4
celery 8.4 6.6 4.5
Chinese cabbage 16.5 13.7 9.4
citrus 1.3 0.9 0.4
conifer seed orchards 7.3 5.8 4.0
cotton 2.5 1.7 1.1
cottonwood (for pulp) 20.3 18.7 13.9
endive (escarole) 5.6 4.4 3.0
field corn 1.4 0.9 0.5
garbanzo beans 2.2 1.7 1.1
grass for seed 4.8 3.7 2.5
herbaceous ornamentals 0.1 0.1 0.1
honeydew 2.3 1.5 0.8
kale 4.2 3.3 2.2
kohlrabi 16.5 13.7 9.4
lentils 4.1 3.2 2.2
lettuce (leaf) 5.6 4.4 3.0
Lupine 4.2 3.1 2.0
melon 2.3 1.5 0.8
mustard greens 6.1 4.8 3.1
Non-cropland areas adjacent to vineyards 3.2 2.5 1.6
pears 1.4 0.9 0.4
peas (succulent) 2.2 1.7 1.1
pecans 1.1 0.8 0.4
peppers 8.2 6.7 5.0
popcorn 1.4 0.9 0.5
potatoes 3.0 2.0 1.1
Safflower 3.9 3.2 2.0
sainfoin 2.7 2.1 1.3
sorghum 8.0 6.8 4.5
Swiss chard 5.6 4.4 3.0
tomatoes 2.4 1.5 0.8
triticale 8.0 6.8 4.5
turnips 4.3 3.3 2.0
Wheat 3.9 3.2 2.0
*All EECs correspond to aerial applications except for ground applications to citrus, Brussels sprouts,
non-cropland areas adjacent to vineyards and herbaceous ornamentals.
Page 62 of 137
3.2. Terrestrial Exposure Assessment
3.2.1. Modeling Approach
T-REX (version 1.3.1) is used to calculate dietary and dose-based EECs of dimethoate for the
terrestrial-phase CRLF and its potential prey (e.g. terrestrial invertebrates, small mammals)
inhabiting terrestrial areas. T-REX simulates a 1-year time period. A foliar dissipation half-life
of 2.88 days is used based on data cited in USEPA 2006. The default Mineau scaling factor of
1.15 is used (Mineau et al. 1996). T-REX incorporates set weights for dose-based or dietary-
based exposure data involving either mallard ducks or Northern bobwhite quail. Since the most
sensitive toxicity data for acute dose-based and dietary-based exposures of dimethoate to birds
involved two species (red-winged blackbird and ring-necked pheasant) that were not mallard
duck or bobwhite quail, body weight data for these two species were entered into T-REX. For the
red-winged blackbird, the body weight is assumed to be 53 g based on the mean of male and
female mean weights for this species as cited in Dunning 1984. For the ring-necked pheasant, the
body weight is assumed to be 1135 g based on the mean of male and female mean weights for
this species as cited in Dunning 1984. Specific input values, including number of applications,
application rate and application interval used in the analyses are located in Table 16. An
example output from T-REX v.1.3.1 is available in Appendix E.
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Table 16. Input parameters for foliar applications used to derive terrestrial EECs for dimethoate with T-
REX.
Use Max single ap. Rate Max # of apps per year Application interval
(lbs a.i./A) (days)
Alfalfa 0.5 9* 40*
beans*** 0.5 2 14
broccoli 0.5 3 7
Brussels sprouts 1 6 7
cauliflower 0.5 3 7
celery 0.5 3 7
citrus 2 Not specified (assume 1) Not specified
conifer seed orchards 1 1 NA
cotton++ 0.5 2 14
cottonwood (for pulp) 1 3 Not specified (assume 7)
field corn 0.5 1 NA
honeydew 0.5 2 7
kale 0.25 2 15
kohlrabi 0.5 3 7
lentils 0.5 2 7
Lupine 0.5 2 Not specified (assume 7)
melon 0.5 2 7
Non-cropland areas adjacent to vineyards 2 2 Not specified (assume 7)
pears 0.5 1 NA
pecans 0.33 1 NA
peppers 0.33 5 7
popcorn 0.5 1 NA
potatoes 0.5 2 7
Safflower+++ 0.5 1 NA
sainfoin 0.5 1 NA
sorghum 0.5 2 7
tomatoes 0.5 2 6
triticale 0.5 2 Not specified (assume 7)
turnips 0.25 7 3
Wheat+++ 0.5 1 NA
NA=not applicable
*There is one application allowed per cutting. Since alfalfa can have 2-9 cuttings per year (Kaul 2007), there is a maximum of 9 applications per
year. Based on this, it is assumed that there are cuttings throughout the year and there are equal intervals between cuttings. Therefore, there
would be 40 d intervals between cuttings and between pesticide applications.
***Labels indicate that rates for beans are per season. It is assumed that beans have one crop per year (Kaul 2007).
+++Labels indicate that rates for wheat and safflower are relevant to crop. According to Kaul 2007, only one crop of wheat is grown per year.
Since safflower is grouped with wheat, it is assumed that one crop of safflower is also grown per year.
Page 64 of 137
3.2.2. Terrestrial Animal Exposure Modeling Results
For modeling purposes, exposures of the CRLF to dimethoate through contaminated food are
estimated using the EECs for the small bird (20 g) which consumes small insects. EECs used to
represent exposure to CRLF are also used to represent exposure values for frogs serving as
potential prey of terrestrial-phase CRLF adults. Dietary-based and dose-based exposures of
potential prey are assessed using the small mammal (15 g) which consumes short grass. Upper-
bound Kenaga nomogram values reported by T-REX for these two organism types are used for
derivation of EECs for the terrestrial-phase CRLF and its potential prey (Table 17). T-REX
reported dietary-based EECs used for small and large insects are available in Table 17.
Page 65 of 137
Table 17. Upper-bound Kenaga nomogram EECs for dietary- and dose-based exposures of the CRLF and its
prey to dimethoate.
Use Dietary-based EECs for specific food items (ppm) Dose-based EECs (mg/kg-bw)
1 2, 3 4
Short Grass Small insect Large Insect CRLF5 Small mammal6
(20 g consuming (15 g consuming
sm. Insects) short grass)
Alfalfa 120 68 8 77 114
beans 124 70 8 80 118
broccoli 146 82 9 94 140
Brussels sprouts 295 166 18 189 281
cauliflower 146 82 9 94 140
celery 146 82 9 94 140
Chinese cabbage 146 82 9 94 140
citrus 480 270 30 308 458
conifer seed orchards 240 135 15 154 229
cotton 124 70 8 80 118
cottonwood (for pulp) 293 165 18 188 279
Endive (escarole) 73 41 5 47 70
field corn 120 68 8 77 114
garbanzo beans 120 68 8 77 114
grass for seed 120 68 8 77 114
herbaceous ornamentals 60 34 4 38 57
honeydew 142 80 9 91 136
kale 62 35 4 39 59
kohlrabi 146 82 9 94 140
lentils 142 80 9 91 136
lettuce (leaf) 73 41 5 47 70
Lupine 142 80 9 91 136
melon 142 80 9 91 136
mustard greens 67 38 4 43 64
Non-cropland areas adjacent to vineyards 569 320 36 366 543
pears 120 68 8 77 114
peas (succulent) 120 68 8 77 114
pecans 79 45 5 51 76
peppers 97 55 6 62 93
popcorn 120 68 8 77 114
potatoes 142 80 9 91 136
Safflower 120 68 8 77 114
sainfoin 120 68 8 77 114
sorghum 142 80 9 91 136
Swiss chard 73 41 5 47 70
tomatoes 148 83 9 95 141
triticale 142 80 9 91 136
turnips 116 65 7 74 111
Wheat 120 68 8 77 114
1
Used for dietary-based EECs for deriving RQs for small mammals representing CRLF prey.
2
Used for dietary-based EECs for deriving RQs for direct exposures to the CRLF.
3
Used for EECs for deriving RQs for small terrestrial invertebrates representing CRLF prey.
4
Used for EECs for deriving RQs for large terrestrial invertebrates representing CRLF prey.
5
Used for dose-based EECs for deriving RQs for direct exposures to the CRLF.
6
Used for dose-based EECs for deriving RQs for small mammals representing CRLF prey.
Page 66 of 137
3.2.3. Spray Drift Modeling
In order to determine terrestrial habitats of concern due to dimethoate exposures through spray
drift, it is necessary to estimate the distance spray applications can drift from the treated field and
still be greater than the level of concern. For this assessment, the level of concern for the most
sensitive endpoint (acute exposures to terrestrial invertebrates) and exposure duration is used.
When this is expressed as an equivalent rate per unit area, it is 2 x 10-4 lb a.i./A. This assessment
used the AgDisp model. AgDisp (version 8.13; dated 12/14/2004) (Teske and Curbishley, 2003)
was used to simulate both aerial and ground applications. For simulation requiring estimates of
drift beyond 2400 ft, the Gaussian far field extension mode in AgDisp was used.
Scenario and management practice input parameters for AgDisp fall into three categories. First
are parameters for which there is current guidance (from labels). In all cases, there was no
information from dimethoate labels relevant to these parameters so they have been set to the
default values recommended by the current draft EFED Guidance for AgDisp (EFED 2005).
Second are the default input values for AgDisp that do not affect the results of these calculations,
or are reference variables whose value would only be changed under special circumstances.
“Wind speed” is an example of the former and “height for wind speed measurement” is an
example of the latter. These parameters have ‘NA’ for not applicable in the quality column.
Third are the parameters for which no current guidance is available and the default value for
AgDisp was used for the input parameter for this set of simulations. The justification for these
parameters is “program default” in Table 18.
The quality column in Table 18 provides some qualitative characterization regarding the
confidence in the accuracy of that input parameter. When little or no information is available to
support the value of a particular input parameter, the characterization in the quality column is
poor. In many cases, when this occurs, the variable is set to a value that will produce drift values
greater than those that would actually occur, so the results will likely be conservative and
protective. When the amount of information supporting a parameter value is typical, the
characterization is ‘good’ and the characterization is ‘very good’ or ‘excellent’ when several
measurements of high quality support the value for the parameter.
Page 67 of 137
Table 18. Scenario and standard management input parameters for simulation of dimethoate in spray drift
using AgDisp with Gaussian far-field extension.
Parameter Value Justification Quality
Nozzle type1 Flat fan Program default Poor
Boom Pressure1 60 lb Program default Poor
Spray lines 20 Program default Poor
Nozzles 42 None available Poor
Droplet Size Distribution (DSD) Fine to very fine Default; draft guidance NA
Swath Width 60 ft Program default Good
Wind Speed 15 mph Default; draft guidance Good
Wind direction - 90° Default NA
Air temperature 65° F Program default Poor
Relative Humidity 50% Program default Poor
Spray Material Water Program default Good
Fraction of active solution that is non- 0.1 Program default Poor
volatile
Fraction of additive solution that is 0.1 Program default Poor
non-volatile
Stability Overcast Program default Poor
Upslope angle 0° Assume flat surface Good
Side slope angle 0° Assume flat surface Good
Canopy type none Default from guidance Poor
Surface roughness 0.0246 ft Program default, none provided Poor
Transport 0 ft Program default Poor
Height for wind peed measurement 6.56 ft Program default Good
Maximum comp. Time 600 sec Program default NA
Maximum downwind distance 2608.24 ft Program default NA
Vortex decay rate OGE 0.03355 Program default NA
Vortex decay rate IGE 1.25 Program default NA
Aircraft drag coefficient 0.1 Program default NA
Propeller efficiency 0.8 Program default NA
Ambient pressure 29.91 Program default NA
Ground reference 0 ft Program default NA
Evaporation rate 84.76 μg·(K·s)-1 Program default NA
Specific Gravity (non-volatile) 1.0 Program default Poor
1
parameter for ground spray only
AgDrift input parameters that vary with the crop and application type are in Table 19. The
default release height of 15 ft is used for aerial applications in the absence of other label
directions. Spray volumes are the minimum spray volumes from dimethoate labels for each crop.
The non-volatile fraction, active fraction and specific gravity were calculated from label
information according to current guidance (EFED 2005). The default ½ swath displacement was
used as it is standard practice for aerial sprays.
Table 19. AgDrift Input parameters that vary with crop and formulation are used for estimating drift from
one application of dimethoate.
Specific
Spray Non-
Release Swath Active Gravity of
Crop Grouping App method Volume volatile
Height Displacement Fraction Non-
(gal) Fraction
volatile
Garbanzos
aerial 15 ft ½ 5 0.025 0.086 1.10
(0.5 lb acre-1)
Cottonwood
aerial 15 ft ½ 10 0.025 0.0112 1.07
(1 lb acre-1)
Page 68 of 137
Table 20 presents the results of the AGDISP modeling and shows the minimum distances for a
single maximum application of dimethoate to cottonwood (1 lb a.i./A) and a single maximum
application of dimethoate to garbanzo beans (0.5 lbs a.i./A), where the resulting area-based
concentration of dimethoate is below the LOC of 2 x10-4 lb/A. This value was estimated using T-
REX as the lowest deposition rate that would not exceed any LOC values for terrestrial-phase
organisms of interest to this assessment.
Cottonwood and garbanzo beans were the only uses modeled because they represent the highest
application rates for uses classified in the action areas of “orchard, vineyard and forestry” and
“agriculture,” respectively. The distances cited in Table 20 for these uses are used to define their
respective action areas.
The distances estimated for aerial applications are considerably larger than for ground sprays.
Although ground spray may be the typical practice for most uses of dimethoate, aerial
application is allowed on the label and that practice is assessed when it is allowed because it has
greater drift potential. Most drift events would be expected to have shorter distances due to lower
wind speed. In addition, a fine to very-fine spray has been assumed for the ground sprays and
ground equipment generally produces a coarser spray. However, there is no language restricting
the spray droplet size on the dimethoate labels; therefore, the very fine spray was used as it is the
default in the absence of label instructions.
Table 20. Distance from the edge of the treated field to get below LOC for crops with aerial spray application
of dimethoate.
Use Pattern Representative Action App Rate (lb/A) Distance, 15 mph wind speed
Area
cottonwood Orchard, vineyard and 1 10,797 ft
forestry
garbanzos agriculture 0.5 10,524 ft
The AGDISP calculations used in this assessment are modeled under spray drift conditions in a
flat area without barriers (e.g., trees, structures, hills) with a constant wind speed and using
standard application equipment. Several factors could potentially reduce spray drift deposition
(e.g., wind barriers, spray drift buffers, and the use of drift-reducing technology); however,
potential reductions cannot currently be quantified using available Agency methodologies.
Page 69 of 137
4. Effects Assessment
This assessment evaluates the potential for dimethoate to affect the CRLF. As previously
discussed in Section 2.7, assessment endpoints for the CRLF include direct toxic effects on the
survival, reproduction, and growth of the CRLF itself, as well as indirect effects, such as
reduction of the prey base and/or modification of its habitat leading to effects on survival, growth
or reproduction. Direct effects to the CRLF in aquatic habitats are based on toxicity information
for freshwater vertebrates, including fish, which are generally used as a surrogate for
amphibians, as well as available amphibian toxicity data from the open literature. Direct effects
to the CRLF in terrestrial habitats are based on toxicity information for birds, which are
generally used as a surrogate for terrestrial-phase amphibians. Given that the CRLF’s prey items
and habitat requirements are dependent on the availability of freshwater aquatic invertebrates and
aquatic plants, fish, frogs, terrestrial invertebrates and terrestrial mammals, toxicity information
for these organisms is also discussed. Acute (short-term) and chronic (long-term) toxicity
information is characterized based on registrant-submitted studies and a comprehensive review
of the open literature on dimethoate. A summary of the available freshwater ecotoxicity
information for dimethoate are provided in Section 4.1.
Toxicity endpoints are established based on data generated from guideline studies submitted by
the registrant, and from open literature studies that meet the criteria for inclusion into the
ECOTOX database maintained by EPA/Office of Research and Development (ORD) (U.S. EPA,
2004). Open literature data presented in this assessment were obtained from the 2006
dimethoate supplemental chapter in support of the IRED (U.S. EPA, 2004) as well as
information obtained from ECOTOX on September, 2007. The September 2007 ECOTOX
search included all open literature data for dimethoate and omethoate (i.e., pre- and post-IRED).
In order to be included in the ECOTOX database, papers must meet the following minimum
criteria:
• the toxic effects are related to single chemical exposure;

• the toxic effects are on an aquatic or terrestrial plant or animal species;
• there is a biological effect on live, whole organisms;
• a concurrent environmental chemical concentration/dose or application rate is reported;
and
• there is an explicit duration of exposure.
Data that pass the ECOTOX screen are evaluated along with the registrant-submitted data, and
may be incorporated qualitatively or quantitatively into this endangered species assessment. In
general, open literature effects data that are more conservative than the registrant-submitted data
are considered. Studies relevant to dimethoate that were accepted by ECOTOX and/or OPPTS
are identified in Appendix F, as well as dimethoate studies that were rejected by ECOTOX
and/or OPPTS. Reviews of studies cited in ECOTOX as containing data that were more sensitive
than registrant submitted endpoints relevant to this assessment are included in Appendix K.
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Toxicity testing reported in this section does not represent all species of bird, mammal, or
aquatic organism. Only a few surrogate species for both freshwater fish and birds are used to
represent all freshwater fish (2000+) and bird (680+) species in the United States. For
mammals, acute studies are usually limited to Norway rat or the house mouse. The assessment
of risk or hazard makes the assumption that avian and reptilian toxicities are similar. The same
assumption is used for fish and amphibians.
4.1. Evaluation of Aquatic Freshwater Ecotoxicity Studies for Dimethoate
As described in the Agency’s Overview Document (U.S. EPA, 2004), the most sensitive
endpoint for each taxon is evaluated. For this assessment, evaluated taxa relevant to the aquatic
habitat of the CRLF include freshwater fish, freshwater aquatic invertebrates, and freshwater
aquatic plants. Currently, no guideline tests exist for frogs. Therefore, surrogate species are
used as described in the Overview Document (U.S. EPA, 2004). In addition, aquatic-phase
amphibian ecotoxicity data from the open literature are qualitatively discussed. Table 21
summarizes the most sensitive ecological toxicity endpoints for the CRLF, its prey and its
habitat, based on an evaluation of both the submitted studies and the open literature, as
previously discussed. A brief summary of submitted and open literature data considered relevant
to this ecological risk assessment for the CRLF is presented below.
Page 71 of 137
Table 21. Summary of most sensitive toxicity endpoint for assessing direct and indirect effects of dimethoate
to CRLF in aquatic habitats. Study classifications based on EFED’s ecotoxicity database.
Species Mean
Assessment Endpoint End-point concentration Ref. (MRID)
(common name) (mg/L)
Measures of Direct Effects
Oncorhyncus mykiss
Acute toxicity to CRLF LC50 6.2 40094602
(Rainbow Trout)
Oncorhyncus mykiss
Chronic toxicity to CRLF NOAEC1 0.43 43106303
(Rainbow Trout)
Measures of Indirect Effects
Toxicity to novascular plants

composing aquatic habitat and Anabaena variabilis Das and
EC50 0.084
representing prey for tadpole (blue-green algae) Adhikary 1996
CRLF
Toxicity to vascular plants No data are available at this time
composing aquatic habitat
Acute toxicity to invertebrates EC50 0.043 00003503
(prey) Pteronarcys californica
Chronic toxicity to invertebrates (Stonefly) 0.0005
NOAEC2 NA
(prey)
Acute toxicity to fish and frogs Oncorhyncus mykiss
LC50 6.2 40094602
representing prey (Rainbow Trout)
Chronic toxicity to fish and Oncorhyncus mykiss

NOAEC1 0.43 43106303
other species of frogs (prey)
(Rainbow Trout)
1
LOAEC = 0.84 mg/L. Affected endpoint: reduced growth.
2
Estimated using acute to chronic ratio with Daphnia magna data.
Acute toxicity to aquatic fish and invertebrates is categorized using the system shown in Table
22 (U.S. EPA, 2004). Toxicity categories for aquatic plants have not been defined. Based on
these categories, at most, dimethoate is classified moderately toxic to freshwater fish and very
highly toxic to invertebrates on an acute exposure basis.
Table 22. Categories of Acute Toxicity for Aquatic Organisms.

LC50 (mg/L) Toxicity Category
< 0.1 Very highly toxic
> 0.1 – 1.0 Highly toxic
> 1.0 – 10 Moderately toxic
> 10 – 100 Slightly toxic
> 100 Practically nontoxic
Page 72 of 137
4.1.1. Toxicity to Freshwater Fish
As described in the original ecological risk assessment in support of the reregistration eligibility
decision on dimethoate, the compound is considered moderately toxic to freshwater fish and
aquatic-phase amphibians on an acute exposure basis with 96-hr LC50 values ranging between
6.2 to 7.5 mg a.i./L. Rainbow trout (Oncorhynchus mykiss) were the most sensitive species
(LC50=6.2 mg a.i./L) and this endpoint is used to evaluate acute risks to both fish and aquatic-
phase amphibians. On a chronic exposure basis, growth was impaired in rainbow trout in a 96-
day study (NOAEC=0.43 mg a.i./L).
4.1.2. Toxicity to Aquatic-phase Amphibians
No registrant-submitted data were available on the toxicity of dimethoate to aquatic-phase

amphibians; however, two studies were reported in ECOTOX. Both of these studies reported on
the toxicity of Rogor® (30% dimethoate) to the Indian bull frog (Rana tigerina) (Mohanty-
Hejmadi and Dutta 1981) and to R. hexadactyla (Khangarot et al. 1985). Only one of the studies
(Khangarot et al. 1985) provided a 96-hr LC50 (7.82 μg/L) suggesting that the formulated
endproduct is 3 orders of magnitude more toxic than the technical grade active ingredient [to
fish]. Both of these studies have limitations which are discussed further in Appendix K. The
major limitation associated with each of these studies is that they measure the effects of a
dimethoate formulation that is not registered for use in the United States. Therefore it is
uncertain whether the enhanced toxicity of Rogor® is due to dimethoate or some constituent
(inert) of the formulated product.
4.1.3. Toxicity to Freshwater Invertebrates
Based on 48-hr EC50 values ranging from 0.043 to 5.04 mg a.i./L, dimethoate ranged from being
classified as very highly to moderately toxic to freshwater invertebrates on an acute exposure
basis. The most acute sensitive endpoint, i.e., stonefly (Pteronarcys californica) 48-hr
EC50=0.043 mg a.i./L, is used in this assessment to evaluate risk to nontarget aquatic
invertebrates.
On a chronic exposure basis, waterfleas (Daphnia magna) were the most sensitive species tested
(21-day NOAEC=0.04 mg a.i./L). In order to determine the equivalent chronic toxicity endpoint
for stoneflies, the acute-to-chronic ratio for D. magna is determined. The acute EC50 and chronic
NOAEC for D. magna are 3.32 mg/L and 0.04 mg/L, respectively and the acute-to-chronic ratio
is 83. Based on the acute-to-chronic ratio, the chronic toxicity value is estimated by dividing the
48-hr EC50 (0.043 mg/L) by 83. The resulting estimated NOAEC is 0.0005 mg/L.
4.1.4. Toxicity to Aquatic Plants
No registrant-submitted data are available to assess the toxicity of dimethoate to aquatic plants;
however, a total 11 entries on aquatic nonvascular plants were reported in ECOTOX. The most
sensitive blue-green algae is Anabaena variabilis (15-day EC50=0.084 mg/L; Das and Adhikary
Page 73 of 137
1996) while the most sensitive green algae (Pseudokirchneriella subcapitata) had a 96-hr EC50
of 36 mg/L (Abdel-Hamid 1996).
4.2. Evaluation of Terrestrial Ecotoxicity Studies for Dimethoate
As described in the Agency’s Overview Document (U.S. EPA 2004), the most sensitive endpoint
for each taxon is evaluated. For this assessment, evaluated taxa include birds, mammals,
terrestrial invertebrates and terrestrial plants. Currently, no guideline tests exist for frogs and
thus, no toxicity data are currently required on amphibians. Therefore, surrogate taxa (birds)
were used as described in the Overview Document (U.S. EPA 2004). Table 23 summarizes the
most sensitive ecological toxicity endpoints for terrestrial-phase CRLF, based on an evaluation
of both the submitted studies and the open literature, as previously discussed. A brief summary
of submitted and open literature data considered relevant to this ecological risk assessment for
the CRLF are presented below.
Similar to toxicity categories for aquatic organisms, categories of acute toxicity ranging from
“practically nontoxic” to “very highly toxic” have been established for terrestrial organisms
based on LD50 values (Table 24), and avian species based on LD50 values (Table 25). Subacute
dietary toxicity for avian species is based on the LC50 values (Table 26). Based on these
categories, dimethoate is very highly toxic to birds on an acute oral exposure basis, highly toxic
to birds on a subacute dietary exposure basis and moderately toxic to mammals on an acute oral
exposure basis.
Page 74 of 137
Table 23. Summary of most sensitive toxicity for assessing direct and indirect effects of dimethoate to CRLF
in terrestrial habitats. Study classifications based on EFED’s ecotoxicity database.
Species Mean
Assessment Endpoint End-point Ref. (MRID)
(common name) concentration
Measures of Direct Effects
Acute toxicity to CRLF Agelaius phoeniceus 5.4 mg/kg

LD50 00020560
(red-winged blackbird)
Sub-acute toxicity to CRLF Phasianus colchicus 332 mg/kg-diet

LC50 00022923
(ring-necked pheasant)
Chronic toxicity to CRLF Colinus virginianus 4.0 ppm

NOAEC1 44049001
(Northern bobwhite quail)
Measures of Indirect Effects
Apis mellifera 0.05

Acute toxicity to LD50 00026489
invertebrates (prey) (Honey bee) µg a.i./ bee
Acute toxicity to mammals Rattus norvegicus

LD50 358 mg/kg 00164220
(prey) (laboratory rat)
Chronic toxicity to Rattus norvegicus 45529702

NOAEL2 0.1 mg/kg-bw
mammals (prey) (laboratory rat) 45529703
Acute toxicity to frogs Agelaius phoeniceus
LD50 5.4 mg/kg 00020560
representing prey
(red-winged blackbird)
Sub-acute toxicity to frogs Phasianus colchicus
LC50 332 mg/kg-diet 00022923
representing prey
(ring-necked pheasant)
Chronic toxicity to other Colinus virginianus
NOAEC1 4.0 ppm 44049001
species of frogs (prey) (Northern bobwhite quail)
Toxicity to monocot plants

composing wetland and
terrestrial habitat
No data are available at this time
Toxicity to dicot plants
composing wetland and
terrestrial habitat
1
LOAEC = 10.1 ppm. Affected endpoints included: reduced egg production, viable embryos, 3-week old embryos, normal hatchlings, 14-day old
survivor weight, adult male and female body weight, egg shell thickness.
2
LOAEL = 0.5 mg/kg-bw/day. Affected endpoints included: brain/blood acetylcholinesterase inhibition, decreased weight, and increased pup death.
Page 75 of 137
Table 24. Categories for mammalian acute toxicity based on median lethal dose in mg per kilogram body
weight (parts per million).
LD50 (mg a.i./kg) Toxicity Category
<10 Very highly toxic
10–50 Highly toxic
51–500 Moderately toxic
501–2000 Slightly toxic
>2000 Practically non-toxic
Table 25. Categories of avian acute oral toxicity based on median lethal dose in milligrams per kilogram body
weight (parts per million).
LD50 (ppm) Toxicity Category
10-50 Highly toxic
51-500 Moderately toxic
501-2000 Slightly toxic
Table 26. Categories of avian subacute dietary toxicity based on median lethal concentration in milligrams
per kilogram diet per day (parts per million).
LC50 (ppm) Toxicity Category
50–500 Highly toxic
501–1000 Moderately toxic
1001–5000 Slightly toxic
Page 76 of 137
4.2.1. Toxicity to Birds
As described in the previous ecological risk assessment (USEPA 2004), dimethoate ranges from
moderately to very highly toxic to birds on an acute oral exposure basis (LD50 range 5.4 – 63.5
mg/kg). The compound ranged from highly to slightly toxic on a subacute dietary exposure basis
(LC50 range 332 – 1011 mg/kg diet). The most sensitive endpoints are the acute oral toxicity
value for the red-winged blackbird (Aeglaius phoeniceous) (LD50=5.4 mg/kg) ) and the sub-acute
dietary toxicity value for the ring-necked pheasant (Phasianus colchicus) (LC50 = 332 mg/kg
diet).
Chronic avian toxicity estimates (NOAEC values) for dimethoate range from 4 to 152 mg/kg diet
and consistently resulted in reduced egg production and decreased survival of young. The most
sensitive endpoint is for the northern Bobwhite quail (Colinus virginianus) (NOAEC=4 mg/kg
diet).
4.2.2. Toxicity to Terrestrial-phase Amphibians
No terrestrial-phase amphibian toxicity data are available for dimethoate.
4.2.3. Toxicity to Mammals
The most sensitive acute oral toxicity value available for mammals is a LD50 = 358 (95% CI:
311-411) mg/kg for exposure of male laboratory rats to dimethoate. Acute oral exposures of
female rats to dimethoate resulted in a LD50 = 414 (95% C.I.: 363-463) mg/kg (MRID 164220).
As noted in the supplemental risk assessment in support of the interim reregistration eligibility
decision, the chronic toxicity estimate for dimethoate is based on a developmental neurotoxicity
study (MRID 45529703) reviewed by the Agency’s Health Effects Division. The chronic
NOAEL of 0.1 mg/kg was established based on observed decrease in pup deaths and brain
cholinesterase in rats treated with 0.5 mg/kg-bw/day dimethoate.
4.2.4. Toxicity to Terrestrial Invertebrates
Dimethoate is characterized as highly toxic to terrestrial insects (honeybee acute contact

LD50=0.05 µg/bee). For the purpose of this assessment, the honey bee endpoint is used to derive
RQs. This toxicity value is converted to units of µg a.i./g (of bee) by multiplying by 1 bee/0.128
g thereby resulting in an LD50 = 0.39 µg a.i./g.
4.2.5. Toxicity to Terrestrial Plants
No registrant-submitted data were submitted on the toxicity of dimethoate to terrestrial plants;

however, two studies were reported in ECOTOX that are useful for qualitatively describing the
phytotoxicity of dimethoate. In a study conducted in Europe, six species of “weeds” were
exposed to dimethoate at a rate of 0.02 lb a.i./A. After 28 days, mean dry weight was
significantly affected in two species (Agrostemma githago and Urtica urens), both of which were
Page 77 of 137
dicots (Hanley and Whiting 2004). In another study involving exposures of wheat to 0.5 lb a.i./A,
chlorosis and necrosis were observed, with mass and overall yield (bushels/acre) unaffected
(Chapin an Thomas 1999).
4.3. Comparison of toxicities of dimethoate and omethoate
No data were submitted for exposures of animals to omethoate. Also, ECOTOX did not contain
useful data. Data are available from an evaluation conducted by the United Kingdom (UK) for
the purpose of evaluating omethoate’s use as a pesticide (DEFRA 1993). Information from
omethoate studies discussed in section 4.3 was obtained from the UK’s report. Because the EPA
has not conducted an independent review of these studies, the data relevant to omethoate are
used qualitatively for comparison purposes. These data are not used in this risk assessment for
derivation of risk quotients.
4.3.1. Aquatic organisms
Acute toxicity data are available for rainbow trout and D. magna to compare the toxicities of
dimethoate and omethoate. Chronic toxicity data are also available for exposures of D. magna to
dimethoate and omethoate. Comparison of LC50 values for rainbow trout indicate that the
toxicity of omethoate is similar to that of dimethoate. Although chronic toxicity data for D.
magna indicate a similar response to the two chemicals, acute toxicity data indicate that
omethoate is significantly more toxic to D. magna than dimethoate (Table 27).
Table 27. Comparison of toxicities of technical dimethoate and omethoate to aquatic organisms (units in
mg/L).
Species Endpoint Dimethoate Omethoate* Dimethoate source
(MRID)
Rainbow trout 96-h LC50 6.2 9.1 40094602
7.5 - 40919000
Waterflea (D. magna) 48-h EC50 3.32 0.022 Song et al. 1997
21-d NOAEC 0.04 0.042 42864701
21-d LOAEC 0.1 0.14 42864701
*Source: DEFRA 1993
4.3.2. Terrestrial organisms
Acute oral toxicity data are available to compare the toxicities of dimethoate and omethoate to
birds. Toxicity data are not available for any species exposed (separately) to dimethoate and
omethoate. Available data indicate that dimethoate can be classified as very highly toxic to
highly toxic to birds, while omethoate can be classified as highly toxic to birds (Table 26).
Comparison of LD50 values indicate that the toxicity of omethoate to birds is similar to that of
dimethoate (Table 28). These data indicate that the LD50 for dimethoate used in this assessment
is the most conservative value available for acute oral exposures of birds to either dimethoate or
omethoate.
Page 78 of 137
Table 28. Comparison of acute oral toxicities (LD50, units in mg/kg) of technical dimethoate and omethoate to
birds.
Species Dimethoate Omethoate Source (MRID)
Red-winged blackbird 5.4 NA 00020560
Canary NA 10 to 20 DEFRA 1993
Ring-necked pheasant 20 NA 00160000
Starling 32 NA 00020560
Mallard duck 41.6 NA 115198
Japanese quail NA 49 DEFRA 1993
Japanese quail NA 79.7 DEFRA 1993
Mallard duck 63.5 NA 00160000
NA = not available
Acute toxicity data for honeybees also indicates a similar toxicity of the two chemicals. In an
acute contact study, the reported LD50 was 0.048 µg/bee for honey bees exposed to technical
omethoate (DEFRA 1993). As discussed above, the most conservative acute contact honey bee
LD50 for dimethoate is 0.05 µg/bee.
Acute toxicity data for rats indicates that omethoate is more toxic to mammals on an acute and
chronic basis. Available acute oral toxicity studies for rats exposed to omethoate include LD50
values ranging 22-64 mg/kg (DEFRA 1993). This range indicates that omethoate is an order of
magnitude more toxic to rats than dimethoate, for which the documented LD50 is 358 mg/kg. In
a chronic toxicity study with rats exposed to technical omethoate, the NOAEL was 0.3 ppm
(0.015 mg/kg-bw), with a LOAEL of 1 ppm (0.05 mg/kg-bw) resulting from 20% inhibition of
cholinesterase relative to controls. In a reproductive study involving exposures of rats to
omethoate, decreases in pup viability were observed as low as 3 ppm (0.15 mg/kg-bw), with a
study NOAEL of 1 ppm (0.05 mg/kg-bw) (DEFRA 1993). In a chronic toxicity study with
dimethoate, the LOAEL was 0.5 mg/kg-bw for 10% decrease in brain cholinesterase relative to
controls as well as a decrease in pup viability (NOAEL of 0.1 mg/kg-bw). These data suggest
that 1) on an acute exposure basis, omethoate is significantly more toxic to rats than dimethoate,
2) dimethoate and omethoate affect pup viability at similar levels and 3) omethoate affected rat
cholinesterase at lower doses than where effects were observed after dimethoate exposures.
Page 79 of 137
5. Risk Characterization
Risk characterization is the integration of the exposure and effects characterizations to determine
the potential ecological risk from varying dimethoate use scenarios within the action area and
likelihood of direct and indirect effects on the CRLF, as well as consideration of modification to
designated critical habitat. The risk characterization provides an estimation and description of the
likelihood of effects; it articulates risk assessment assumptions, limitations, and uncertainties;
and synthesizes an overall conclusion regarding the effects determination (i.e., “no effect,”
“likely to adversely affect,” or “may affect, but not likely to adversely affect”) for the CRLF.
5.1. Risk Estimation
Risk is estimated by calculating the ratio of exposure to toxicity. This ratio is the risk quotient
(RQ), which is then compared to established acute and chronic levels of concern (LOCs) for each
category evaluated (Appendix G). For acute exposures to the CRLF and its animal prey in
aquatic habitats, as well as terrestrial invertebrates, the LOC is 0.05. For acute exposures to the
CRLF and mammals, the LOC is 0.1. The LOC for chronic exposures to CRLF and its prey, as
well as acute exposures to aquatic plants is 1.0.
Screening-level RQs are based on the most sensitive toxicity endpoints and modeled EECs in
aquatic and terrestrial systems from dimethoate uses defined in Table 5.
5.1.1. Exposures in the Aquatic Habitat
5.1.1.1. Direct Effects to CRLF
For assessing acute risks of direct effects to the CRLF, 1-in-10 year peak EECs in the standard
pond are used with the lowest acute toxicity value for fish. For chronic risks, 1-in-10 year peak
60-day EECs and the lowest chronic toxicity value for fish are used. Resulting acute and chronic
RQs do not exceed the acute listed species LOC (0.05) or chronic listed species LOC (1.0) for
any use of dimethoate (Table 29).
Page 80 of 137
Table 29. Risk Quotient values for acute and chronic exposures directly to the CRLF in aquatic habitats.
Use peak (µg/L) 60-d (µg/L) Acute RQ1 Chronic RQ2
Alfalfa 6.7 4.0 0.001 0.009
beans 5.8 3.1 0.001 0.007
broccoli 16.5 9.4 0.003 0.022
Brussels sprouts 9.2 4.2 0.001 0.010
cauliflower 16.5 9.4 0.003 0.022
celery 8.4 4.5 0.001 0.010
Chinese cabbage 16.5 9.4 0.003 0.022
citrus 1.3 0.4 0.000 0.001
conifer seed orchards 7.3 4.0 0.001 0.009
cotton 2.5 1.1 <0.001 0.003
cottonwood (for pulp) 20.3 13.9 0.003 0.032
endive (escarole) 5.6 3.0 0.001 0.007
field corn 1.4 0.5 <0.001 0.001
garbanzo beans 2.2 1.1 <0.001 0.003
grass for seed 4.8 2.5 0.001 0.006
herbaceous ornamentals 0.1 0.1 <0.001 0.000
honeydew 2.3 0.8 <0.001 0.002
kale 4.2 2.2 0.001 0.005
kohlrabi 16.5 9.4 0.003 0.022
lentils 4.1 2.2 0.001 0.005
lettuce (leaf) 5.6 3.0 0.001 0.007
Lupine 4.2 2.0 0.001 0.005
melon 2.3 0.8 <0.001 0.002
mustard greens 6.1 3.1 0.001 0.007
Non-cropland areas adjacent to vineyards 6.1 1.6 0.001 0.004
pears 1.4 0.4 <0.001 0.001
peas (succulent) 2.2 1.1 <0.001 0.003
pecans 1.1 0.4 <0.001 0.001
peppers 8.2 5.0 0.001 0.012
popcorn 1.4 0.5 <0.001 0.001
potatoes 3.0 1.1 <0.001 0.003
Safflower 3.9 2.0 0.001 0.005
sainfoin 2.7 1.3 <0.001 0.003
sorghum 8.0 4.5 0.001 0.011
Swiss chard 5.6 3.0 0.001 0.007
tomatoes 2.4 0.8 <0.001 0.002
triticale 8.0 4.5 0.001 0.011
turnips 4.3 2.0 0.001 0.005
Wheat 3.9 2.0 0.001 0.005
1
Based on LC50 value for fish = 6.2 mg/L.
2
Based on chronic NOAEC for fish = 0.43 mg/L.
Page 81 of 137
5.1.1.2 Indirect Effects to CRLF through effects to prey
For assessing risks of indirect effects of dimethoate to the aquatic-phase CRLF (tadpoles)
through effects to its diet, 1-in-10 year peak EECs from the standard pond are used with the
lowest acute toxicity value for aquatic unicellular plants to derive RQs. Resulting RQs do not
exceed the acute risk LOC (RQ>1.0) for any uses of dimethoate (Table 30).
For assessing risks of indirect acute effects to the aquatic-phase CRLF through effects to prey
(invertebrates) in aquatic habitats, 1-in-10 year peak EECs in the standard pond are used with the
lowest acute toxicity value for invertebrates. For chronic risks, 1-in-10 year peak 21-day EECs
and the lowest chronic toxicity value for invertebrates are used to derive RQs. Resulting acute
RQs exceed the acute risk to listed species LOC (RQ≥0.05) for the majority of dimethoate uses.
Chronic RQs exceed the chronic risk LOC (RQ>1.0) for all uses of dimethoate, with the
exception of use on herbaceous ornamentals (Table 30).
5.1.2.3. Indirect Effects to CRLF through effects to habitat (plants)
As noted above, RQs representing unicellular aquatic plants do not exceed the LOC (1.0) (Table
30). No data are available to assess the risks of dimethoate to vascular aquatic plants. Given the
lack of data, RQ values could not be derived to represent the risks of dimethoate exposure to
vascular aquatic plants.
Page 82 of 137
Table 30. Risk Quotient values for indirect effects to aquatic-phase CRLF due to effects to its prey.
Use peak (µg/L) 21-d Algae RQ1 Acute Chronic
(µg/L) Invertebrate Invertebrate
RQ2 RQ3
Alfalfa 6.7 5.5 0.08 0.16 10.9
beans 5.8 4.5 0.07 0.14 8.9
broccoli 16.5 13.7 0.20 0.38 27.3
Brussels sprouts 9.2 6.7 0.11 0.21 13.5
cauliflower 16.5 13.7 0.20 0.38 27.3
celery 8.4 6.6 0.10 0.19 13.2
Chinese cabbage 16.5 13.7 0.20 0.38 27.3
citrus 1.3 0.9 0.02 0.03 1.8
conifer seed orchards 7.3 5.8 0.09 0.17 11.7
cotton 2.5 1.7 0.03 0.06 3.3
cottonwood (for pulp) 20.3 18.7 0.24 0.47 37.3
endive (escarole) 5.6 4.4 0.07 0.13 8.9
field corn 1.4 0.9 0.02 0.03 1.8
garbanzo beans 2.2 1.7 0.03 0.05 3.4
grass for seed 4.8 3.7 0.06 0.11 7.5
herbaceous ornamentals 0.1 0.1 <0.01 <0.01 0.2
honeydew 2.3 1.5 0.03 0.05 3.0
kale 4.2 3.3 0.05 0.10 6.6
kohlrabi 16.5 13.7 0.20 0.38 27.3
lentils 4.1 3.2 0.05 0.10 6.3
lettuce (leaf) 5.6 4.4 0.07 0.13 8.9
Lupine 4.2 3.1 0.05 0.10 6.1
melon 2.3 1.5 0.03 0.05 3.0
mustard greens 6.1 4.8 0.07 0.14 9.6
Non-cropland areas adjacent to vineyards 6.1 4.8 0.07 0.14 9.6
pears 1.4 0.9 0.02 0.03 1.8
peas (succulent) 2.2 1.7 0.03 0.05 3.4
pecans 1.1 0.8 0.01 0.03 1.5
peppers 8.2 6.7 0.10 0.19 13.5
popcorn 1.4 0.9 0.02 0.03 1.8
potatoes 3.0 2.0 0.04 0.07 3.9
Safflower 3.9 3.2 0.05 0.09 6.4
sainfoin 2.7 2.1 0.03 0.06 4.2
sorghum 8.0 6.8 0.09 0.19 13.7
Swiss chard 5.6 4.4 0.07 0.13 8.9
tomatoes 2.4 1.5 0.03 0.06 3.0
triticale 8.0 6.8 0.09 0.19 13.7
turnips 4.3 3.3 0.05 0.10 6.7
Wheat 3.9 3.2 0.05 0.09 6.4
1
Based on algae EC50 = 84 µg/L.
2
Based on invertebrate EC50 = 43 µg/L
3
Based on chronic invertebrate NOAEC = 0.5 µg/L.
Page 83 of 137
5.1.2. Exposures in the Terrestrial Habitat
5.1.2.1. Direct Effects to CRLF
As described above, dietary-based and dose-based exposures modeled in T-REX for a small bird
(20g) consuming small invertebrates are used to assess risks of dimethoate to the terrestrial-
phase CRLF. Acute, subacute and chronic effects are estimated using the lowest available
toxicity data for birds. EECs are divided by toxicity values to estimate acute and chronic dietary-
based RQs as well as dose-based RQs. Acute dose-based RQs exceed the LOC (0.1) for all uses
of dimethoate, with RQs exceeding the LOC by factors ranging between 80 to 781X. Acute
dietary-based RQs are equivalent to or exceed the LOC (0.1) for all uses. Acute dietary based
RQs range 1X to 9.6X of the LOC. Chronic dietary-based RQs exceed the LOC (1.0) for all uses
of dimethoate, by factors ranging 8.4X to 80X (Table 31).
5.1.2.2. Indirect Effects to CRLF through effects to prey
In order to assess the risks of applications of dimethoate to terrestrial invertebrates, which are
considered prey of CRLF in terrestrial habitats, the honey bee is used as a surrogate for terrestrial
invertebrates. EECs (µg a.i./g of bee) calculated by T-REX for small and large insects are
divided by the calculated toxicity value for terrestrial invertebrates, which is 0.39 µg a.i./g of
bee. The resulting RQ values for large insect and small insect exposures bound the potential
range of exposures for terrestrial insects to dimethoate. For all uses, RQ values exceed the acute
risk LOC (RQ>0.05) for both large and small terrestrial insects (Table 32).
As described above, to assess risks of dimethoate to prey (small mammals) of larger terrestrial-
phase CRLF, dietary-based and dose-based exposures modeled in T-REX for a small mammal
(15g) consuming short grass are used. Subacute and chronic effects are estimated using the most
sensitive mammalian toxicity data. EECs are divided by the toxicity value to estimate acute and
chronic dietary-based RQs as well as acute dose-based RQs. Acute dose-based RQ values
exceed the listed species acute risk LOC for the majority of dimethoate uses. Across all uses,
chronic dose-based and dietary-based RQs exceed the LOC (Table 33).
An additional prey item of the adult CRLF is other species of frogs. In order to assess risks to
these organisms, dietary-based and dose-based exposures modeled in T-REX for a small bird
(20g) consuming small invertebrates are used. These are the same EECs, toxicity values and RQs
used to assess direct effects to the CRLF. Acute, dietary-based RQ values are equivalent to or
exceed the LOC for all uses of dimethoate; dietary-based chronic RQ values and dose-based RQ
values exceed the LOC for listed species for all uses (Table 29).
5.1.2.3. Indirect Effects to CRLF through effects to habitat (plants)
No data are available to assess the risks of dimethoate to riparian and terrestrial plants. Given the
lack of data, RQ values could not be derived to represent the risks of dimethoate exposure to the
riparian and terrestrial habitat of the CRLF.
Page 84 of 137
Table 31. Acute and chronic, dietary-based RQs and dose-based RQs for direct effects to the terrestrial-phase
CRLF. RQs calculated using T-REX.
Acute, Chronic, Acute,
Use
dietary- based1,2 dietary-based3,4 dose-based5,6
Alfalfa 0.2 16.88 16.48
beans 0.21 17.46 17.04
broccoli 0.25 20.59 20.1
cauliflower 0.25 20.59 20.1
celery 0.25 20.59 20.1
citrus 0.81 67.5 65.91
conifer seed orchards 0.41 33.75 32.95
cotton 0.21 17.46 17.04
Endive (escarole) 0.12 10.29 10.05
field corn 0.2 16.88 16.48
garbanzo beans 0.2 16.88 16.48
grass for seed 0.2 16.88 16.48
herbaceous ornamentals 0.1 8.44 8.24
honeydew 0.24 20.01 19.53
kale 0.1 8.67 8.46
kohlrabi 0.25 20.59 20.1
lentils 0.24 20.01 19.53
lettuce (leaf) 0.12 10.29 10.05
Lupine 0.24 20.01 19.53
melon 0.24 20.01 19.53
pears 0.2 16.88 16.48
peas (succulent) 0.2 16.88 16.48
pecans 0.13 11.14 10.87
peppers 0.16 13.67 13.35
popcorn 0.2 16.88 16.48
potatoes 0.24 20.01 19.53
Safflower 0.2 16.88 16.48
sainfoin 0.2 16.88 16.48
sorghum 0.24 20.01 19.53
Swiss chard 0.12 10.29 10.05
tomatoes 0.25 20.86 20.37
triticale 0.24 20.01 19.53
turnips 0.2 16.3 15.92
Wheat 0.2 16.88 16.48
1
Based on LC50 for ring-necked pheasant = 332 mg/kg-diet
2
All RQs are equivalent to or exceed the acute listed species LOC of 0.1.
3
Based on chronic NOAEC of 4.0 ppm for northern bobwhite quail.
4
All RQs exceed the chronic listed species LOC of 1.0.
5
Based on LD50 for red-winged blackbird = 5.4 mg/kg.
6
All RQs exceed the acute listed species LOC of 0.1.
Page 85 of 137
prey items, specifically terrestrial invertebrates.
Use Small
invertebrate1,2 Large Invertebrate1,2
Alfalfa 173.1 19.2
beans 179.0 19.9
broccoli 211.1 23.5
Brussels sprouts 425.0 47.2
cauliflower 211.1 23.5
celery 211.1 23.5
Chinese cabbage 211.1 23.5
citrus 692.3 76.9
conifer seed orchards 346.2 38.5
cotton 179.0 19.9
cottonwood (for pulp) 422.3 46.9
Endive (escarole) 105.6 11.7
field corn 173.1 19.2
garbanzo beans 173.1 19.2
grass for seed 173.1 19.2
herbaceous ornamentals 86.5 9.6
honeydew 205.2 22.8
kale 88.9 9.9
kohlrabi 211.1 23.5
lentils 205.2 22.8
lettuce (leaf) 105.6 11.7
Lupine 205.2 22.8
melon 205.2 22.8
mustard greens 96.5 10.7
Non-cropland areas adjacent to vineyards 820.7 91.2
pears 173.1 19.2
peas (succulent) 173.1 19.2
pecans 114.2 12.7
peppers 140.2 15.6
popcorn 173.1 19.2
potatoes 205.2 22.8
Safflower 173.1 19.2
sainfoin 173.1 19.2
sorghum 205.2 22.8
Swiss chard 105.6 11.7
tomatoes 213.9 23.8
triticale 205.2 22.8
turnips 167.2 18.6
Wheat 173.1 19.2
1
Based on LD50 = 0.05 µg a.i./bee (equivalent to 0.39 µg a.i./g).
2
All RQ values exceed the LOC of 0.05.
Page 86 of 137
Table 33. RQs for determining indirect effects to the terrestrial-phase CRLF through effects to potential prey
items, specifically terrestrial mammals.
Acute, Chronic, Chronic,
Use
dose-based1,2 dose-based3,4 dietary-based3,4
Alfalfa 0.15 520.6 60
beans 0.15 538.47 62.06
broccoli 0.18 635.04 73.19
cauliflower 0.18 635.04 73.19
celery 0.18 635.04 73.19
citrus 0.58 2082.25 240
conifer seed orchards 0.29 1041.12 120
cotton 0.15 538.47 62.06
Endive (escarole) 0.09 317.52 36.6
field corn 0.15 520.56 60
garbanzo beans 0.15 520.56 60
grass for seed 0.15 520.56 60
herbaceous ornamentals 0.07 260.28 30
honeydew 0.17 617.12 71.13
kale 0.07 267.32 30.81
kohlrabi 0.18 635.04 73.19
lentils 0.17 617.12 71.13
lettuce (leaf) 0.09 317.52 36.6
Lupine 0.17 617.12 71.13
melon 0.17 617.12 71.13
pears 0.15 520.56 60
peas (succulent) 0.15 520.56 60
pecans 0.1 343.57 39.6
peppers 0.12 421.72 48.61
popcorn 0.15 520.56 60
potatoes 0.17 617.12 71.13
Safflower 0.15 520.56 60
sainfoin 0.15 520.56 60
sorghum 0.17 617.12 71.13
Swiss chard 0.09 317.52 36.6
tomatoes 0.18 643.4 74.16
triticale 0.17 617.12 71.13
turnips 0.14 502.92 57.97
Wheat 0.15 520.56 60
1
Based on LD50 for laboratory rat = 358 mg/kg.
2
Several RQ values exceed the acute listed species LOC of 0.1.
3
Based on chronic NOAEC for laboratory rat = 0.1 mg/kg-bw.
4
All RQ values exceed the chronic listed species LOC of 1.0.
Page 87 of 137
5.2. Risk Description
The risk description synthesizes an overall conclusion regarding the likelihood of impacts
leading to an effects determination (i.e., “no effect,” “may affect, but not likely to adversely
affect,” or “likely to adversely affect”) for the CRLF and its designated critical habitat (i.e.,
modification or no modification).
If the RQs presented in the Risk Estimation (Section 5.1) show no indirect effects and LOCs for
the CRLF are not exceeded for direct effects, a “no effect” determination is made, based on use
of dimethoate within the action area. If, however, indirect effects are anticipated and/or
exposure exceeds the LOCs for direct effects, the Agency concludes a preliminary “may affect”
determination for the CRLF. Following a “may affect” determination, additional information is
considered to refine the potential for exposure at the predicted levels based on the life history
characteristics (i.e., habitat range, feeding preferences, etc.) of the CRLF and potential
community-level effects to aquatic plants. Based on the best available information, the Agency
uses the refined evaluation to distinguish those actions that “may affect, but are not likely to
adversely affect” from those actions that are “likely to adversely affect” the CRLF.
The criteria used to make determinations that the effects of an action are “not likely to adversely
affect” the CRLF include the following:
• Significance of Effect: Insignificant effects are those that cannot be meaningfully

measured, detected, or evaluated in the context of a level of effect where “take” occurs
for even a single individual. “Take” in this context means to harass or harm, defined as
the following:
o Harm includes significant habitat modification or degradation that results in death

or injury to listed species by significantly impairing behavioral patterns such as
breeding, feeding, or sheltering.
o Harass is defined as actions that create the likelihood of injury to listed species to
such an extent as to significantly disrupt normal behavior patterns which include,
but are not limited to, breeding, feeding, or sheltering.
• Likelihood of the Effect Occurring: Discountable effects are those that are extremely
unlikely to occur. For example, use of dose-response information to estimate the
likelihood of effects can inform the evaluation of some discountable effects.
• Adverse Nature of Effect: Effects that are wholly beneficial without any adverse effects
are not considered adverse.
A description of the risk and effects determination for each of the established assessment
endpoints for the CRLF is provided below.
Page 88 of 137
5.2.1. Direct Effects
5.2.1.1. Aquatic-phase
Acute and chronic RQ values representing all uses of dimethoate do not exceed the LOCs for
direct effects to the CRLF in aquatic habitats. EECs would have to be 1-2 orders of magnitude
larger to be of concern for direct effects to the aquatic-phase CRLF. Therefore, the determination
for direct effects to the CRLF in aquatic habitats is “No Effect” for uses of dimethoate.
Of the 25 ecological incidents associated with dimethoate exposures, 4 involved fish kills. Since
fish are used as surrogates for the aquatic-phase CRLF, incidents involving fish are considered
relevant to this assessment. Mortalities of fish were reported for several different species,
including bass, sunfish, and many unnamed fish. Two of the incidents were associated with
applications that were classified as “misuse,” one incident was associated with a registered use of
dimethoate and the remaining incident was unclassified. All incidents were associated with
dimethoate and other pesticide exposures to the fish, including 2,4-D, aldicarb, diazinon,
disulfoton, chlorpyrifos, malathion, methyl parathion, parathion and thiodan. The certainty of the
incidents was defined as possible to probable. Since other pesticides were associated with these
incidents, dimethoate’s specific contribution to the observed fish mortalities is uncertain. For
more details associated with these incidents, see Appendix H.
5.2.1.2. Terrestrial-phase
T-REX calculated acute dose-based RQs, acute dietary-based RQs and chronic dietary-based
RQs exceed their respective LOCs, resulting in a “may affect” determination for all uses. In
order to explore influences of amphibian-specific food intake equations on potential dose-based
and dietary-based exposures of the terrestrial phase CRLF to dimethoate, T-HERPS is used.
Modeling with T-HERPS incorporates the same application rates, intervals and number of
applications for each use as defined for modeling using T-REX (Table 16). Since applications of
dimethoate for all uses result in exposures sufficient to exceed the LOC for direct effects to the
CRLF, the T-HERPS model was used to estimate EECs and subsequent risks to the CRLF based
on amphibian-specific equations. These refined EECs and RQs were used to distinguish
“NLAA” and “LAA” determinations. An example output from T-HERPS is available in
Appendix I.
RQs are calculated for the terrestrial-phase CRLF on the basis of dose and diet. It should be
noted that although dietary-based RQ values are considerably lower than dose-based RQ values,
the former do not take into account that different-sized animals consume differing amounts of
food and that depending on the forage item, an animal has to consume varying amounts due to
differing nutrition levels in the food item. If dietary-based RQ values are adjusted to account for
differential food consumption, the adjusted RQ value would likely approximate the dose-based
RQ value.
Page 89 of 137
Acute exposures
Refined dose-based RQs for small sized (1.4 g) CRLF consuming small insects exceed the acute
listed species LOC (0.1) for all uses of dimethoate. RQs representing dimethoate exposures to
small CRLF consuming large invertebrates are lower than RQs representing exposures of small
CRLF to dimethoate through consumption of small invertebrates. The acute listed species LOC
is exceeded for small CRLF consuming large insects for some uses of dimethoate (Table 34).
This indicates that small CRLF could potentially be affected by acute exposures to dimethoate.
Refined dose-based RQs for medium sized (37 g) and large sized (238 g) CRLF consuming
small insects and mammals exceed the acute listed species LOC (0.1) for all uses of dimethoate.
The acute listed species LOC is exceeded for medium and large CRLF consuming large insects
for some uses of dimethoate. The LOC is not exceeded for medium or large CRLF consuming
small-terrestrial phase amphibians (Tables 35 and 36). This indicates that medium and large
sized CRLF could potentially be affected by acute exposures to dimethoate.
Although dietary-based RQs are generally lower than dose-based RQs, they follow a similar
trend when compared to dose-based RQs. Refined acute dietary-based RQs for CRLFs
consuming small insects and herbivorous mammals meet or exceed the acute listed species LOC
(0.1) for all uses of dimethoate. The acute listed species LOC is exceeded for medium and large
CRLF consuming large insects for only the highest use of dimethoate. For CRLFs consuming
terrestrial-phase amphibians and small insectivorous mammals, the acute LOC is not exceeded
for any use (Table 37). This indicates that CRLF could potentially be affected by acute
exposures to dimethoate.
Page 90 of 137
Table 34. Revised dose-based RQs1 for 1.4 g CRLF consuming different food items. EECs calculated using T-
HERPS.
Use Small Insects Large Insects
Alfalfa 0.49 0.05
beans 0.50 0.06
broccoli 0.59 0.07
celery 0.59 0.07
citrus 1.94 0.22
cotton 0.50 0.06
endive (escarole) 0.30 0.03
herbaceous ornamentals 0.24 0.03
honeydew 0.58 0.06
kale 0.25 0.03
kohlrabi 0.59 0.07
lentils 0.58 0.06
lettuce (leaf) 0.30 0.03
Lupine 0.58 0.06
melon 0.58 0.06
mustard greens 0.27 0.03
pears 0.49 0.05
pecans 0.32 0.04
peppers 0.39 0.04
popcorn 0.49 0.05
potatoes 0.58 0.06
Safflower 0.49 0.05
sainfoin 0.49 0.05
sorghum 0.58 0.06
Swiss chard 0.30 0.03
tomatoes 0.60 0.07
triticale 0.58 0.06
turnips 0.47 0.05
Wheat 0.49 0.05
1
RQ values >0.1 exceed the acute listed species LOC.
Page 91 of 137
Table 35. Revised dose-based RQs1 for 37 g CRLF consuming different food items. EECs calculated using
T-HERPS.
Use Small Large Small Small Small
Insects Insects Herbivore Insectivore Terrestrial-
Mammals Mammals phase
Amphibians
Alfalfa 0.48 0.05 13.85 0.87 0.02
beans 0.49 0.05 14.33 0.90 0.02
broccoli 0.58 0.06 16.90 1.06 0.02
cauliflower 0.58 0.06 16.90 1.06 0.02
celery 0.58 0.06 16.90 1.06 0.02
Chinese cabbage 0.58 0.06 16.90 1.06 0.02
citrus 1.91 0.21 55.41 3.46 0.07
cotton 0.49 0.05 14.33 0.90 0.02
endive (escarole) 0.29 0.03 8.45 0.53 0.01
field corn 0.48 0.05 13.85 0.87 0.02
garbanzo beans 0.48 0.05 13.85 0.87 0.02
grass for seed 0.48 0.05 13.85 0.87 0.02
herbaceous ornamentals 0.24 0.03 6.93 0.43 0.01
honeydew 0.57 0.06 16.42 1.03 0.02
kale 0.25 0.03 7.11 0.44 0.01
kohlrabi 0.58 0.06 16.90 1.06 0.02
lentils 0.57 0.06 16.42 1.03 0.02
lettuce (leaf) 0.29 0.03 8.45 0.53 0.01
Lupine 0.57 0.06 16.42 1.03 0.02
melon 0.57 0.06 16.42 1.03 0.02
mustard greens 0.27 0.03 7.72 0.48 0.01
pears 0.48 0.05 13.85 0.87 0.02
peas (succulent) 0.48 0.05 13.85 0.87 0.02
pecans 0.32 0.04 9.14 0.57 0.01
peppers 0.39 0.04 11.22 0.70 0.01
popcorn 0.48 0.05 13.85 0.87 0.02
potatoes 0.57 0.06 16.42 1.03 0.02
Safflower 0.48 0.05 13.85 0.87 0.02
sainfoin 0.48 0.05 13.85 0.87 0.02
sorghum 0.57 0.06 16.42 1.03 0.02
Swiss chard 0.29 0.03 8.45 0.53 0.01
tomatoes 0.59 0.07 17.12 1.07 0.02
triticale 0.57 0.06 16.42 1.03 0.02
turnips 0.46 0.05 13.38 0.84 0.02
Wheat 0.48 0.05 13.85 0.87 0.02
1
Page 92 of 137
Table 36. Revised dose-based RQs1 for 238 g CRLF consuming different food items. EECs calculated using T-
HERPS.
Use Small Large Small Herbivore Small Small
Insects Insects Mammals Insectivore Terrestrial-
Mammals phase
Amphibians
Alfalfa 0.31 0.03 2.15 0.13 0.01
beans 0.32 0.04 2.23 0.14 0.01
broccoli 0.38 0.04 2.63 0.16 0.01
cauliflower 0.38 0.04 2.63 0.16 0.01
celery 0.38 0.04 2.63 0.16 0.01
Chinese cabbage 0.38 0.04 2.63 0.16 0.01
citrus 1.25 0.14 8.61 0.54 0.04
cotton 0.32 0.04 2.23 0.14 0.01
endive (escarole) 0.19 0.02 1.31 0.08 0.01
field corn 0.31 0.03 2.15 0.13 0.01
garbanzo beans 0.31 0.03 2.15 0.13 0.01
grass for seed 0.31 0.03 2.15 0.13 0.01
honeydew 0.37 0.04 2.55 0.16 0.01
kale 0.16 0.02 1.11 0.07 0.01
kohlrabi 0.38 0.04 2.63 0.16 0.01
lentils 0.37 0.04 2.55 0.16 0.01
lettuce (leaf) 0.19 0.02 1.31 0.08 0.01
Lupine 0.37 0.04 2.55 0.16 0.01
melon 0.37 0.04 2.55 0.16 0.01
mustard greens 0.17 0.02 1.20 0.08 0.01
pears 0.31 0.03 2.15 0.13 0.01
peas (succulent) 0.31 0.03 2.15 0.13 0.01
pecans 0.21 0.02 1.42 0.09 0.01
peppers 0.25 0.03 1.74 0.11 0.01
popcorn 0.31 0.03 2.15 0.13 0.01
potatoes 0.37 0.04 2.55 0.16 0.01
Safflower 0.31 0.03 2.15 0.13 0.01
sainfoin 0.31 0.03 2.15 0.13 0.01
sorghum 0.37 0.04 2.55 0.16 0.01
Swiss chard 0.19 0.02 1.31 0.08 0.01
tomatoes 0.39 0.04 2.66 0.17 0.01
triticale 0.37 0.04 2.55 0.16 0.01
turnips 0.30 0.03 2.08 0.13 0.01
Wheat 0.31 0.03 2.15 0.13 0.01
1
Page 93 of 137
Table 37. Revised acute dietary-based RQs1 for CRLF consuming different food items. EECs calculated using
T-HERPS.
Use Small Insects Large Small Small Small
Insects Herbivore Insectivore Terrestrial-
Amphibians
Alfalfa 0.20 0.02 0.24 0.01 0.01
beans 0.21 0.02 0.25 0.02 0.01
broccoli 0.25 0.03 0.29 0.02 0.01
cauliflower 0.25 0.03 0.29 0.02 0.01
celery 0.25 0.03 0.29 0.02 0.01
Chinese cabbage 0.25 0.03 0.29 0.02 0.01
citrus 0.81 0.09 0.95 0.06 0.03
cotton 0.21 0.02 0.25 0.02 0.01
endive (escarole) 0.12 0.01 0.15 0.01 <0.01
field corn 0.20 0.02 0.24 0.01 0.01
garbanzo beans 0.20 0.02 0.24 0.01 0.01
grass for seed 0.20 0.02 0.24 0.01 0.01
herbaceous ornamentals 0.10 0.01 0.12 0.01 <0.01
honeydew 0.24 0.03 0.28 0.02 0.01
kale 0.10 0.01 0.12 0.01 <0.01
kohlrabi 0.25 0.03 0.29 0.02 0.01
lentils 0.24 0.03 0.28 0.02 0.01
lettuce (leaf) 0.12 0.01 0.15 0.01 <0.01
Lupine 0.24 0.03 0.28 0.02 0.01
melon 0.24 0.03 0.28 0.02 0.01
mustard greens 0.11 0.01 0.13 0.01 <0.01
pears 0.20 0.02 0.24 0.01 0.01
peas (succulent) 0.20 0.02 0.24 0.01 0.01
pecans 0.13 0.01 0.16 0.01 <0.01
peppers 0.16 0.02 0.19 0.01 0.01
popcorn 0.20 0.02 0.24 0.01 0.01
potatoes 0.24 0.03 0.28 0.02 0.01
Safflower 0.20 0.02 0.24 0.01 0.01
sainfoin 0.20 0.02 0.24 0.01 0.01
sorghum 0.24 0.03 0.28 0.02 0.01
Swiss chard 0.12 0.01 0.15 0.01 <0.01
tomatoes 0.25 0.03 0.29 0.02 0.01
triticale 0.24 0.03 0.28 0.02 0.01
turnips 0.20 0.02 0.23 0.01 0.01
Wheat 0.20 0.02 0.24 0.01 0.01
1
Page 94 of 137
EECs and relevant RQs (Tables 34-37) calculated by T-HERPS apply to sites where dimethoate
is directly applied. Since dimethoate can be transported through spray drift to non-target areas
beyond the treatment site, CLRF outside of direct treatment areas can still be exposed to
dimethoate in non-target areas. Exposure and associated risks to the CRLF are expected to
decrease with increasing distance away from the treated field or site of application. Based on
acute effects data, spray drift deposition of dimethoate as low as 0.0036 lbs a.i./A would be
sufficient to exceed the acute listed species LOC for the CRLF. For the majority of dimethoate
uses (all uses with a single maximum application rate ≥0.33 lbs a.i./A; see Table 5 for specific
uses), this distance is estimated to extend more than 990 feet beyond the edge of the application
site (Table 38). Four dimethoate uses (citrus, Brussels sprouts, herbaceous ornamentals and non-
cropland areas adjacent to vineyards) allow applications only by ground methods. For maximum
single applications to citrus and non-cropland areas (2 lbs a.i./A), deposition is sufficient to
exceed the LOC for direct acute effects to the CRLF extending as far as 869 feet from the edge
of the application site. For Brussels sprouts and herbaceous ornamentals, deposition from a
maximum single application (1 and 0.25 lbs a.i./A, respectively) is sufficient to exceed the LOC
extending as far as 545 and 174 feet, respectively from the edge of the application sites (Table
39).
Table 38. Single aerial application rate not exceeding acute LOC for dietary- and dose-based exposures of the
CRLF to dimethoate.
CRLF Based Feeding Category Highest Distance from edge of field where LOC
size* on dose application rate is not exceeded (in feet) for single
or diet? not exceeding application rate**
LOC (lbs a.i./A) 1 0.5 0.33 0.25
lb a.i./A lb a.i./A lb a.i./A lb a.i./A
medium Dose small herbivore mammals 0.0035 >990 >990 >990 741
large Dose small herbivore mammals 0.024 390 194 131 102
medium Dose small insectivore mammals 0.055 174 89 56 26
Small Dose small insects 0.1 98 33 13 7
medium Dose small insects 0.1 98 33 13 7
large Dose small insects 0.16 59 13 3 0
all Diet Small herbivore mammals 0.2 33 7 0 0
all Diet Small insects 0.25 23 0 0 0
large Dose small insectivore mammals 0.36 10 0 0 0
Small Dose large insects 0.9 0 0 0 0
medium Dose large insects 0.9 0 0 0 0
large Dose large insects >1*** 0 0 0 0
all Diet large insects >1*** 0 0 0 0
medium Dose terrestrial-phase amphibians >1*** 0 0 0 0
all Diet Small insectivore mammals >1*** 0 0 0 0
all Diet Terrestrial-phase amphibians >1*** 0 0 0 0
large Dose terrestrial-phase amphibians >1*** 0 0 0 0
*Small is defined as 1.4 g. Medium is defined as 37 g. Large is defined as 238 g.
**Estimated using the terrestrial assessment of the Tier 1 version of AgDRIFT. Modeling assumed that applications were done using aerial methods,
and assuming that the droplet size distribution was "ASAE fine to medium."
***1 lb a.i./A represents the highest single application rate made by aerial methods for dimethoate.
Page 95 of 137
Table 39. Single ground application rate not exceeding acute LOC for dietary- and dose-based exposures of
the CRLF to dimethoate.
CRLF Based Feeding Category Highest distance from edge of field where LOC
size* on dose application rate is not exceeded (in feet) for single
or diet? not exceeding application rate**
LOC (lbs a.i./A) 2 1 0.5 0.25
lb a.i./A lb a.i./A lb a.i./A lb a.i./A
medium Dose small herbivore mammals 0.0035 869 545 322 174
large Dose small herbivore mammals 0.024 200 105 52 30
medium Dose small insectivore mammals 0.055 92 46 26 13
Small Dose small insects 0.1 52 26 16 7
medium Dose small insects 0.1 52 26 16 7
large Dose small insects 0.16 33 20 10 3
all Diet Small herbivore mammals 0.2 26 16 7 3
all Diet Small insects 0.25 23 13 7 3
large Dose small insectivore mammals 0.36 16 10 3 0
Small Dose large insects 0.9 7 3 0 0
medium Dose large insects 0.9 7 3 0 0
large Dose large insects 1.5 3 0 0 0
all Diet large insects >2*** 0 0 0 0
medium Dose terrestrial-phase amphibians >2*** 0 0 0 0
all Diet Small insectivore mammals >2*** 0 0 0 0
all Diet Terrestrial-phase amphibians >2*** 0 0 0 0
large Dose terrestrial-phase amphibians >2*** 0 0 0 0
*Small is defined as 1.4 g. Medium is defined as 37 g. Large is defined as 238 g.
**Estimated using the terrestrial assessment of the Tier 1 version of AgDRIFT. Modeling assumed that applications were done using ground methods,
using a high boom and assuming that the droplet size distribution was "ASAE very fine to fine."
***2 lb a.i./A represents the highest single application rate made by ground methods for dimethoate.
Based on an analysis of the likelihood of individual mortality considering the range of acute
dose-based RQs for terrestrial-phase CRLFs (Tables 34-36) and a probit dose-response of 2.54
(MRID 00020560), the chance of mortality for RQs which exceed the LOC (0.1) range from 1
in 180 individuals to 1 in 1 individuals (Figure 11). This range is relevant to all sizes of CRLF
consuming small invertebrates. For medium sized frogs consuming small herbivorous mammals,
the chance of individual mortality is approximately 1 in 1 individual for all uses of dimethoate.
Essentially, this indicates that if a medium sized CRLF consumes a mouse that was present on a
dimethoate treatment site, it would be expected to die due to dimethoate exposure. For large
sized CRLF consuming small herbivorous mammals, the chance of individual mortality ranges 1
in 2 individuals to 1 in 1 individual. For CRLF (medium and large sized) consuming small
insectivore mammals, the chance of individual mortality ranges from 1 in 180 individuals to 1 in
1 individual.
Page 96 of 137
200
180
160
Chance of individual effect (1 in ...)
140
120
100
80
60
40
20
0
0.1 1 10 100
RQ
Figure 11. Chance of individual mortality to terrestrial-phase CRLF when considering acute dose-based RQs.
Considering acute dietary-based RQs for the terrestrial phase CRLF (Table 37) and a probit
dose-response of 10.1 (MRID 00022923), the chance for mortality of RQs exceeding the LOC
(0.1) range from 1 in 3.62e23 to 1 in 1.4 individuals (Figure 12).
Page 97 of 137
1.00E+24
1.00E+21
1.00E+18
Chance of individual effect (1 in ...)
1.00E+15
1.00E+12
1.00E+09
1.00E+06
1.00E+03
1.00E+00
0 0.2 0.4 0.6 0.8 1 1.2 1.4
RQs
Figure 12. Chance of individual mortality to terrestrial-phase CRLF when considering acute dietary-based
RQs.
An analysis of ecological incidents results in no reported effects to terrestrial-phase amphibians

involving dimethoate exposures. Since birds are used as surrogates for the terrestrial-phase
CRLF, incidents involving birds are considered relevant to this assessment. Of the 25 reported
incidents associated with dimethoate, 9 were associated with bird mortalities. These mortalities
were associated with Canadian geese, cedar waxwings, a rock dove and turkeys. The incidents
were associated with pesticide applications that were classified as “misuse” (3 of 9) and
“registered use” (6 of 9). The certainty index indicated that it was possible to highly probable
that dimethoate contributed to these mortalities. In 6 of the 9 incidents, other pesticides were
associated with the incidents, including pesticides with high avian toxicity. For more details
associated with these incidents, see Appendix H.
Based on the information in this section, for all uses of dimethoate, the effects determination for
acute effects to the terrestrial phase CRLF is “LAA” based on potential mortality through
consumption of dimethoate-contaminated food items.
Page 98 of 137
Chronic exposures
Refined chronic dietary-based RQs for CRLFs consuming insects and mammals exceed the
chronic listed species LOC (1.0) for all uses of dimethoate. The chronic listed species LOC is
exceeded for CRLF consuming terrestrial-phase amphibians for some uses of dimethoate (Table
40).
In the available chronic study where Northern bobwhite quail were exposed to dimethoate, the
NOAEC was 4 ppm, and the LOAEC was 10.1 ppm, based on reproductive effects. Comparison
of the LOAEC directly to chronic dietary-based EECs for CRLF consuming small insects and
small mammals indicate that EECs for all uses are sufficient to exceed the concentration where
reproductive effects were observed in the laboratory. For CRLFs consuming large invertebrates
and terrestrial-phase amphibians, the majority of dimethoate uses have EECs which are
insufficient to exceed the LOAEC. Therefore, for some CRLF feeding categories, dimethoate
EECs are at levels where reproductive effects were observed in birds, which serve as surrogates
for the CRLF.
Based on the information in this section, for all uses of dimethoate, the effects determination for
chronic effects to the terrestrial-phase CRLF is “LAA” based on potential reproductive effects.
Page 99 of 137
Table 40. Revised chronic dietary-based RQs1 for CRLF consuming different food items. EECs calculated
using T-HERPS.
Use Small Large Small Small Small
Insects Insects Herbivore Insectivore Terrestrial-
Amphibians
Alfalfa 16.88 1.88 19.77 1.24 0.59
beans 17.46 1.94 20.45 1.28 0.61
broccoli 20.59 2.29 24.12 1.51 0.71
cauliflower 20.59 2.29 24.12 1.51 0.71
celery 20.59 2.29 24.12 1.51 0.71
Chinese cabbage 20.59 2.29 24.12 1.51 0.71
citrus 67.50 7.50 79.07 4.94 2.34
cotton 17.46 1.94 20.45 1.28 0.61
endive (escarole) 10.29 1.14 12.06 0.75 0.36
field corn 16.88 1.88 19.77 1.24 0.59
garbanzo beans 16.88 1.88 19.77 1.24 0.59
grass for seed 16.88 1.88 19.77 1.24 0.59
honeydew 20.01 2.22 23.44 1.46 0.69
kale 8.67 0.96 10.15 0.63 0.30
kohlrabi 20.59 2.29 24.12 1.51 0.71
lentils 20.01 2.22 23.44 1.46 0.69
lettuce (leaf) 10.29 1.14 12.06 0.75 0.36
Lupine 20.01 2.22 23.44 1.46 0.69
melon 20.01 2.22 23.44 1.46 0.69
mustard greens 9.40 1.04 11.02 0.69 0.33
pears 16.88 1.88 19.77 1.24 0.59
peas (succulent) 16.88 1.88 19.77 1.24 0.59
pecans 11.14 1.24 13.05 0.82 0.39
peppers 13.67 1.52 16.01 1.00 0.47
popcorn 16.88 1.88 19.77 1.24 0.59
potatoes 20.01 2.22 23.44 1.46 0.69
Safflower 16.88 1.88 19.77 1.24 0.59
sainfoin 16.88 1.88 19.77 1.24 0.59
sorghum 20.01 2.22 23.44 1.46 0.69
Swiss chard 10.29 1.14 12.06 0.75 0.36
tomatoes 20.86 2.32 24.43 1.53 0.72
triticale 20.01 2.22 23.44 1.46 0.69
turnips 16.30 1.81 19.10 1.19 0.57
Wheat 16.88 1.88 19.77 1.24 0.59
1
RQ values >1.0 exceed the chronic listed species LOC.
Page 100 of 137

5.2.2. Indirect Effects (through effects to prey)
As discussed in Section 2.5.3, the diet of tadpole CRLF is composed primarily of unicellular
nonvascular aquatic plants and detritus. Juvenile CRLF consume primarily aquatic and
terrestrial invertebrates. The diet of adult CRLF is composed of aquatic and terrestrial
invertebrates, fish, frogs and mice. These prey groups are considered in determining indirect
effects to the CRLF caused by direct effects to its prey.
Nonvascular plants
Based on RQs for algae (Table 30), applications of dimethoate are not expected to affect this
food source. Therefore, indirect effects of dimethoate to CRLF tadpoles by reductions in
phytoplankton are not expected based on the animal’s diet during this life stage for all uses of
dimethoate. Therefore, it is unlikely that there will be affects to algae from aquatic exposures
arising from any use of dimethoate. Therefore, all uses of dimethoate, are expected to have no
indirect effect on the CRLF via adverse effects to algae.
Aquatic invertebrates
RQ values representing acute exposures to aquatic invertebrates indicate that the majority of uses
of dimethoate can potentially result in effects to invertebrates (Table 30). Therefore, indirect
effects are possible to CRLF juveniles and adults, through decreases in prey.
Based on an analysis of the likelihood of individual mortality using acute RQs for aquatic
invertebrates and a probit dose-response of 6.96 (MRID 00003503), the likelihood of individual
mortality for each use is available in Table 41 (see also Appendix J). Based on this analysis the
majority of uses of dimethoate result in <0.01% chance of effects to an individual aquatic
invertebrate, with the highest EECs (from cottonwood) resulting in 1.12% chance of individual
effects. Therefore, although it is possible for acute dimethoate exposures to result in individual
effects to aquatic invertebrates, the impact of these effects on the CRLF is insignificant for all
uses.
Page 101 of 137

Table 41. RQs and associated likelihood of individual effects to aquatic invertebrates due to dimethoate
exposures.
Use Acute Likelihood of
Invertebrate individual acute
RQ effect (%)
Alfalfa 0.16 <0.01

beans 0.14 <0.01
broccoli 0.38 0.17
Brussels sprouts 0.21 <0.01
celery 0.19 <0.01
citrus 0.03 <0.01
conifer seed orchards 0.17 <0.01
cotton 0.06 <0.01
endive (escarole) 0.13 <0.01
field corn 0.03 <0.01
garbanzo beans 0.05 <0.01
grass for seed 0.11 <0.01
herbaceous ornamentals <0.01 <0.01
honeydew 0.05 <0.01
kale 0.10 <0.01
kohlrabi 0.38 0.17
lentils 0.10 <0.01
lettuce (leaf) 0.13 <0.01
Lupine 0.10 <0.01
melon 0.05 <0.01
mustard greens 0.14 <0.01
Non-cropland areas adjacent to vineyards 0.07 <0.01
pears 0.03 <0.01
peas (succulent) 0.05 <0.01
pecans 0.03 <0.01
peppers 0.19 <0.01
popcorn 0.03 <0.01
potatoes 0.07 <0.01
Safflower 0.09 <0.01
sainfoin 0.06 <0.01
sorghum 0.19 <0.01
Swiss chard 0.13 <0.01
tomatoes 0.06 <0.01
triticale 0.19 <0.01
turnips 0.10 <0.01
Wheat 0.09 <0.01
Page 102 of 137

Chronic RQ values representing exposures to aquatic invertebrates indicate that all but one of the
uses of dimethoate (herbaceous ornamentals) can potentially result in effects to invertebrates
(Table 30). Therefore, indirect effects are possible to CRLF juveniles and adults, through
decreases in prey. Chronic EECs exceed the LOC by factors of 1.5X to 37.3X.
RQs for chronic exposures are based on the level where no effects were observed (the NOAEC)
in laboratory exposure tests. As discussed in Section 4.1.3, chronic toxicity data are unavailable
for the most sensitive species (stonefly) used to assess acute risk. Therefore, an acute-to-chronic
ratio was used to estimate the NOAEC for dimethoate exposure to the stonefly. This same
approach can be applied to approximate the lowest concentration where effects (LOAEC) would
be expected to be observed. Based on the information contained in the dimethoate IRED
(USEPA 2006), the 96-hr acute LC50value for waterflea is 3.32 mg/L. With an acute LC50 of
3.32 mg/L and a chronic LOAEC of 0.1, the acute to chronic ratio (ACR) for waterflea is 33.2
(3.32÷0.1). When the ACR is applied to the stonefly data, the resulting estimated LOAEC is
0.0013 mg/L.
Direct comparison of 21-d EECs to this estimated LOAEC for the stonefly indicates that EECs
are sufficient to exceed this LOAEC for all dimethoate uses except citrus, field corn, herbaceous
ornamentals, pears, pecans and popcorn. EECs for all other uses exceed the estimated LOAEC
by factors of 1.2X to 14.4X.
It is assumed that the actual exposure concentration where effects are exhibited lies somewhere
between the NOAEC and the LOAEC. Given the uncertainty associated with the actual level
where effects occur, risks of chronic dimethoate exposures to aquatic invertebrates are based on
RQs derived using the NOAEC. Based on chronic LOC exceedances for aquatic invertebrates,
all uses of dimethoate, except herbaceous ornamentals, are likely to indirectly affect the CRLF
via adverse effects to aquatic invertebrates.
Terrestrial invertebrates
RQ values representing acute exposures to terrestrial invertebrates indicate that all uses of
dimethoate can potentially result in effects to invertebrates. Therefore, indirect effects are
possible to CRLF juveniles and adults, through decreases in prey. When considering the level
where dimethoate causes 50% mortality in honey bees, EECs are sufficient to exceed this level
by factors of 9.6X-692X (Table 32).
Based on an analysis of the likelihood of individual mortality using the lowest RQ value for
terrestrial invertebrates (RQ=9.6 for dimethoate applications to herbaceous ornamentals) and a
probit dose-response of 4.5 (default value), the likelihood of individual mortality is 100%. Using
a range of 2-9 for probit dose response results in an estimate of 97-100% likelihood of individual
mortality. All other RQ values result in an estimation of 100% likelihood of individual mortality
in terrestrial invertebrates (see Appendix J).
Several terrestrial invertebrate data values are available in the EFED ecotoxicity database
relevant to exposures of honeybees to dimethoate (TGAI). Available LD50 values are 0.056,
Page 103 of 137
0.083, 0.16, 0.17 and 0.19 µg a.i./bee (MRIDs 00026489, 00059971, 00026489, 00059971 and
00036935, respectively). The highest LD50 (0.19 µg a.i./bee) is equivalent to 1.48 µg a.i./g (of
bee). Comparison of this value to EECs for small and large terrestrial invertebrates indicates that
EECs are 2.5X to 216X times greater than the highest available LD50 for honeybees.
A review of the ecological incident database for dimethoate indicates that there are 10 reported
incidents of effects to bees. Affected species include honey bees and leaf cutter bees. The
legality of the uses was reported as “undetermined” and as “registered uses”. In 8 of the 10
incidents, other pesticides, including insecticides, were also associated with the effects to bees.
The certainty of the incidents ranged from possible to highly probable. For more details
associated with these incidents, see Appendix H.
Based on this information, there is potential for indirect effects to the CRLF via direct effects to
terrestrial invertebrates due to dimethoate exposures from all uses.
Fish and aquatic-phase amphibians
Based on RQs for used for direct effects to the aquatic-phase CRLF (Table 29), applications of
dimethoate are not expected to affect fish and aquatic-phase amphibians. Therefore, indirect
effects of dimethoate to CRLF tadpoles by reductions in this food source of the adult CRLF are
not expected based on the animal’s diet during this life stage for all uses of dimethoate.
Therefore, it is unlikely that there will be indirect effects to aquatic-phase CRLFs via effects on
fish and aquatic-phase amphibians from aquatic exposures arising from any use of dimethoate.
Small terrestrial mammals
RQ values representing acute exposures to terrestrial mammals exceed the LOC (0.1) for all uses
of dimethoate except: endive (escarole), herbaceous ornamentals, kale, lettuce, mustard greens,
pecans and Swiss chard (Table 33). Therefore, there is potential for acute effects of dimethoate
to terrestrial mammals.
Based on an analysis of the likelihood of individual mortality using acute dose-based RQs for
terrestrial mammals and a probit dose-response of 4.5 (default value), the likelihood of
individual mortality for each use is available in Table 42 (see also Appendix J). Based on this
analysis, the majority of dimethoate uses result in <0.1% chance of effects to an individual
terrestrial mammal representing prey of the CRLF. Only the highest two RQs (from citrus and
non-cropland areas adjacent to vineyards) result in estimations of likelihood of individual effects
which represents a significant effect to the CRLF (14.4% and 23.4%, respectively). Therefore,
the impact of the indirect dietary effects to terrestrial-phase CRLFs via acute effects on small
mammals is insignificant for all uses of dimethoate, except citrus and non-cropland areas
adjacent to vineyards.
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Table 42. Acute dose-based RQs and associated likelihood of individual effects to terrestrial mammals due to
dimethoate exposures.
Likelihood of
Acute
individual
Use dose-based
acute effect
RQ
(%)
Alfalfa 0.15 0.01
beans 0.15 0.01
broccoli 0.18 0.04
celery 0.18 0.04
citrus 0.58 14.4
cotton 0.15 0.01
Endive (escarole) 0.09 <0.01
herbaceous ornamentals 0.07 <0.01
honeydew 0.17 0.03
kale 0.07 <0.01
kohlrabi 0.18 0.04
lentils 0.17 0.03
Lupine 0.17 0.03
melon 0.17 0.03
pears 0.15 0.01
pecans 0.1 <0.01
peppers 0.12 <0.01
popcorn 0.15 0.01
potatoes 0.17 0.03
Safflower 0.15 0.01
sainfoin 0.15 0.01
sorghum 0.17 0.03
tomatoes 0.18 0.04
triticale 0.17 0.03
turnips 0.14 0.01
Wheat 0.15 0.01
Page 105 of 137

Dose-based and dietary-based chronic RQs for terrestrial mammals exceed the LOC (1.0) by
factors of 30X to 2468X, depending upon the use (Table 33). EECs are sufficient to exceed the
LOAEC (0.5 mg/kg-bw/day, based on increased pup death and brain ChE inhibition) for all uses
by factors of 6X or greater. Based on this information, chronic exposures of dimethoate from all
uses have the potential to indirectly affect the CRLF via impacts to terrestrial mammals serving
as potential prey items.
Small terrestrial-phase amphibians
In order to explore influences of amphibian-specific food intake equations on potential dose-

based and dietary-based exposures of amphibians (prey of CRLF) to dimethoate, the T-HERPS
model is used. The Pacific tree frog is used to represent the amphibian prey species. The weight
of the animal is assumed to be 2.3 g, and its diet is assumed to be composed of small and large
insects. For frogs consuming small insects, the acute LOC (0.1) is exceeded for all uses of
dimethoate. For frogs consuming large insects, the acute LOC is exceeded for dimethoate use on
Brussels sprouts, citrus and cottonwood (Table 43).
Based on an analysis of the likelihood of individual mortality using acute dose-based RQs for
terrestrial phase frogs and a probit dose-response of 2.54 (MRID 00020560), the likelihood of
individual mortality for each use is available in Table 43 (see also Appendix J). Based on this
analysis the majority of uses of dimethoate result in >10% chance of effects to an individual
terrestrial phase frog consuming small insects. The exceptions include: endive (escarole),
herbaceous ornamentals, kale, lettuce, mustard greens, pecans and Swiss chard. All of the uses of
dimethoate have RQs for frogs consuming large insects which result in <5% chance of acute
effects to individual frogs. Based on acute dose-based RQs and individual effects chance for
terrestrial-phase frogs (prey of CRLF) which consume small insects, there is potential for effects
to this taxa due to dimethoate exposures from all uses, except: endive (escarole), herbaceous
ornamentals, kale, lettuce, mustard greens, pecans and Swiss chard.
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Table 43. Acute dose-based RQs and associated likelihood of individual effects to terrestrial-phase frogs
(prey) due to dimethoate exposures.
Frogs consuming Frogs consuming
Small Insects Large Insects
Use RQ Likelihood of RQ Likelihood of
individual individual acute
acute effect (%) effect (%)
Alfalfa 0.43 17.6 0.05 0.05
beans 0.45 18.9 0.05 0.05
broccoli 0.53 24.2 0.06 0.10
Brussels sprouts 1.07 53.0 0.12 1.0
cauliflower 0.53 24.2 0.06 0.10
celery 0.53 24.2 0.06 0.10
Chinese cabbage 0.53 24.2 0.06 0.10
citrus 1.94 76.8 0.22 4.7
conifer seed orchards 0.87 43.9 0.1 0.55
cotton 0.45 18.9 0.05 0.05
cottonwood (for pulp) 1.06 52.6 0.12 1.0
endive (escarole) 0.26 6.9 0.03 0.01
field corn 0.43 17.6 0.05 0.05
garbanzo beans 0.43 17.6 0.05 0.05
grass for seed 0.43 17.6 0.05 0.05
herbaceous ornamentals 0.22 4.7 0.02 <0.01
honeydew 0.51 22.9 0.06 0.10
kale 0.22 4.7 0.02 <0.01
kohlrabi 0.53 24.2 0.06 0.10
lentils 0.51 22.9 0.06 0.10
lettuce (leaf) 0.26 6.9 0.03 0.01
Lupine 0.51 22.9 0.06 0.10
melon 0.51 22.9 0.06 0.10
mustard greens 0.24 5.8 0.03 0.01
Non-cropland areas adjacent to vineyards 2.06 78.7 0.23 5.3
pears 0.43 17.6 0.05 0.05
peas (succulent) 0.43 17.6 0.05 0.05
pecans 0.29 8.6 0.03 0.01
peppers 0.35 12.3 0.04 0.02
popcorn 0.43 17.6 0.05 0.05
potatoes 0.51 22.9 0.06 0.10
Safflower 0.43 17.6 0.05 0.05
sainfoin 0.43 17.6 0.05 0.05
sorghum 0.51 22.9 0.06 0.10
Swiss chard 0.26 6.9 0.03 0.01
tomatoes 0.54 24.8 0.06 0.10
triticale 0.51 22.9 0.06 0.10
turnips 0.42 16.9 0.05 0.05
Wheat 0.43 17.6 0.05 0.05
Page 107 of 137

Acute dietary-based RQs for the CRLF, which do not account for the weight of the animal being
assessed, can also be used to assess risks to the terrestrial frog prey (Table 37). For frogs which
consume small insects, RQs meet or exceed the acute LOC (0.1) for all dimethoate uses. For
frogs which consume large insects, the acute LOC is not exceeded for any use of dimethoate,
with the exception of non-cropland areas adjacent to vineyards
Based on an analysis of the likelihood of individual mortality using acute dietary-based RQs for
terrestrial phase frogs and a probit dose-response of 10.1 (MRID 00022923), the likelihood of
individual mortality for each use is available in Table 44. Based on this analysis the majority of
uses of dimethoate result in <0.01% chance of effects to an individual terrestrial phase frog
representing prey of the CRLF. Only the two highest RQs (from citrus and non-cropland areas
adjacent to vineyards) result in estimates that represent the likelihood of individual effects being
a potential significant effect to the CRLF itself (17.8% and 42.9%, respectively). Therefore, the
impact of indirect dietary effects to the CRLF via acute effects on small insects is insignificant
for all uses of dimethoate except citrus and non-cropland areas adjacent to vineyards.
Page 108 of 137

Table 44. Acute dietary-based RQs and associated likelihood of individual effects to terrestrial-phase frogs
(prey) due to dimethoate exposures.
Likelihood of
Small individual
Use acute effect
Insects
(%)
Alfalfa 0.20 <0.01
beans 0.21 <0.01
broccoli 0.25 <0.01
cauliflower 0.25 <0.01
celery 0.25 <0.01
Chinese cabbage 0.25 <0.01
citrus 0.81 17.8
conifer seed orchards 0.41 <0.01
cotton 0.21 <0.01
endive (escarole) 0.12 <0.01
field corn 0.20 <0.01
garbanzo beans 0.20 <0.01
grass for seed 0.20 <0.01
herbaceous ornamentals 0.10 <0.01
honeydew 0.24 <0.01
kale 0.10 <0.01
kohlrabi 0.25 <0.01
lentils 0.24 <0.01
Lupine 0.24 <0.01
melon 0.24 <0.01
pears 0.20 <0.01
peas (succulent) 0.20 <0.01
pecans 0.13 <0.01
peppers 0.16 <0.01
popcorn 0.20 <0.01
potatoes 0.24 <0.01
Safflower 0.20 <0.01
sainfoin 0.20 <0.01
sorghum 0.24 <0.01
tomatoes 0.25 <0.01
triticale 0.24 <0.01
turnips 0.20 <0.01
Wheat 0.20 <0.01
Page 109 of 137

Chronic dietary-based RQs for the CRLF, which do not account for the weight of the animal
being assessed, can also be used to assess risks to the terrestrial frog prey (Table 40). Refined
dietary-based RQs indicate that, for all dimethoate uses, there is potential for chronic effects to
terrestrial frogs feeding on small and large insects. Chronic RQs are exceeded by factors ranging
1.14X to 80X.
In the available chronic study where Northern bobwhite quail were exposed to dimethoate, the
NOAEC was 4 ppm, and the LOAEC was 10.1 ppm, based on reproductive effects. Comparison
of the LOAEC directly to chronic dietary-based EECs for terrestrial frogs consuming small
insects and small mammals indicate that EECs for all uses are sufficient to exceed the
concentration were reproductive effects were observed in the laboratory. For CRLFs consuming
large invertebrates and terrestrial-phase amphibians, the majority of dimethoate uses have EECs
which are insufficient to exceed the LOAEC. Therefore, for terrestrial phase frogs, dimethoate
EECs are at levels where reproductive effects were observed in birds, which serve as surrogates
for frogs.
Summary of indirect effects to the CRLF based on effects to prey
When considering indirect effects to the CRLF through effects to its prey, estimates of exposure
are sufficient to be of concern for effects based on decreased prey for several taxa of the CRLFs
prey for all dimethoate uses. Although effects to the prey of the tadpole life stage (i.e. algae) are
not expected for dimethoate uses, effects to the prey of the juvenile and adult life stages of the
CRLF are of concern (aquatic and terrestrial invertebrates). Table 45 includes a summary of
dimethoate uses that are expected to have significant (when considering the CRLF), direct effects
on the prey of the CRLF. The overall effects determination for the CRLF based on indirect
effects due to effects due to prey is “LAA” for all uses of dimethoate.
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Table 45. Potential for risk to prey of CRLF due to dimethoate exposures from specific uses (yes or no). This
information is used to determine whether effects of dimethoate on these prey will indirectly affect the CRLF.
Aquatic Terrestrial Aquatic-phase Terrestrial-phase
Small Mammals
Use Algae Invertebrates Invertebrates frogs and fish frogs
Acute Chronic (Acute) Acute Chronic Acute Chronic Acute Chronic
Alfalfa No No Yes Yes No No Yes Yes No Yes
beans No No Yes Yes No No Yes Yes No Yes
broccoli No No Yes Yes No No Yes Yes No Yes
Brussels sprouts No No Yes Yes No No Yes Yes No Yes
cauliflower No No Yes Yes No No Yes Yes No Yes
celery No No Yes Yes No No Yes Yes No Yes
Chinese cabbage No No Yes Yes No No Yes Yes No Yes
citrus No No Yes Yes No No Yes Yes Yes Yes
conifer 1 No No Yes Yes No No Yes Yes No Yes
cotton No No Yes Yes No No Yes Yes No Yes
Cottonwood 2 No No Yes Yes No No Yes Yes No Yes
Endive (escarole) No No Yes Yes No No No Yes No Yes
field corn No No Yes Yes No No Yes Yes No Yes
garbanzo beans No No Yes Yes No No Yes Yes No Yes
grass for seed No No Yes Yes No No Yes Yes No Yes
ornamentals No No No Yes No No No Yes No Yes
honeydew No No Yes Yes No No Yes Yes No Yes
kale No No Yes Yes No No No Yes No Yes
Kohlrabi No No Yes Yes No No Yes Yes No Yes
lentils No No Yes Yes No No Yes Yes No Yes
lettuce (leaf) No No Yes Yes No No No Yes No Yes
Lupine No No Yes Yes No No Yes Yes No Yes
melon No No Yes Yes No No Yes Yes No Yes
mustard greens No No Yes Yes No No No Yes No Yes
Non-cropland3 No No Yes Yes No No Yes Yes Yes Yes
pears No No Yes Yes No No Yes Yes No Yes
peas (succulent) No No Yes Yes No No Yes Yes No Yes
pecans No No Yes Yes No No No Yes No Yes
peppers No No Yes Yes No No Yes Yes No Yes
popcorn No No Yes Yes No No Yes Yes No Yes
potatoes No No Yes Yes No No Yes Yes No Yes
Safflower No No Yes Yes No No Yes Yes No Yes
sainfoin No No Yes Yes No No Yes Yes No Yes
sorghum No No Yes Yes No No Yes Yes No Yes
Swiss chard No No Yes Yes No No No Yes No Yes
tomatoes No No Yes Yes No No Yes Yes No Yes
triticale No No Yes Yes No No Yes Yes No Yes
turnips No No Yes Yes No No Yes Yes No Yes
Wheat No No Yes Yes No No Yes Yes No Yes
1 2 3
seed orchards For pulp Areas adjacent to vineyards
Page 111 of 137

5.2.3. Indirect Effects (through effects to habitat)
As discussed in Section 2.5.4, the habitat of the CRLF varies during its life cycle, with the CRLF
surviving in aquatic, riparian and upland areas. Adults rely on riparian vegetation for resting,
feeding, and dispersal. Egg masses are typically attached to emergent vegetation, such as
bulrushes (Scirpus spp.) and cattails (Typha spp.) or roots and twigs, and float on or near the
surface of the water (Hayes and Miyamoto 1984).
Based on RQs for novascular plants inhabiting aquatic habitats (Table 30), applications of
dimethoate are not expected to affect these plants. However, data are unavailable for assessing
potential risks of dimethoate exposures to vascular aquatic plants and terrestrial plants in the
aquatic, riparian and terrestrial habitats of the CRLF. Although dimethoate is an insecticide,
there is reason for concern for effects to plants.
Although there are no data available for quantifying RQs for plants inhabiting terrestrial and
riparian areas, effects data are available for discussion of potential risks of dimethoate exposures
to plants. In a study reported in the literature, two species of dicots were affected (decreased
biomass) by single applications of 0.02 lb a.i./A (Hanley and Whiting 2004). This rate is 1-2
orders of magnitude lower than the maximum single application rates of dimethoate (0.25-2.0 lbs
a.i./A). Spray drift modeling suggests that for ground applications ranging 0.25-2 lbs a.i./A,
deposition of dimethoate is at least 0.02 lb a.i./A for 30-200 feet beyond the edge of the
application site (Table 39). For aerial applications ranging 0.25-1 lb a.i./A, deposition of
dimethoate is at least 0.02 lb a.i./A for 102-390 feet beyond the edge of the application site
(Table 38). This suggests that maximum single applications of dimethoate have the potential to
decrease plant biomass in areas adjacent to treatment sites, as far as 390 feet away from the edge
of the treatment site.
In addition, there are two reported ecological incidents involving effects to plants following
dimethoate exposures. Both incidents were associated with misuse of the pesticide. One involved
effects (burn symptoms) of dimethoate to corn following a discharge of the pesticide onto a 30
acre field. Cyfluthrin was also applied to this field. The certainty index associated with this
incident was “highly probable” for both pesticides. The other incident involved drift of
dimethoate from an application site to lentil plants (a type of legume) and pastureland. No other
pesticides were associated with this incident. The certainty index associated with this incident
was “probable.” In both incidents involving dimethoate exposures to plants, residues of
dimethoate were measured on the foliage of the affected plants. See Appendix H for more
information associated with these incidents.
Also, some product labels for dimethoate indicate that use of the product could result in
phytotoxicity to select species of ornamental plants (including: river birch, ornamental cherry,
Prunus sp., hawthorn, Japanese lace maple and aspens) (registrations 19713-231, 66330-223,
66330-245, 34704-207, 5905-497, 5905-493).
Page 112 of 137

Due to a lack of effects data the extent of risk from dimethoate to plants cannot be quantified.
However, available data suggest the potential for effects to plants extending beyond the site of
application. Therefore, the determination for indirect effects to the CRLF caused by effects to
riparian and terrestrial plants resulting from use of dimethoate is “likely to adversely affect.”
5.2.4. Primary Constituent Elements of Designated Critical Habitat
5.2.4.1. Aquatic-Phase (Aquatic breeding habitat and aquatic non-breeding

habitat)
Two of the four assessment endpoints for the aquatic-phase primary constituent elements (PCEs)
of designated critical habitat for the CRLF are related to potential effects to aquatic and/or
riparian plants:
• Alteration of channel/pond morphology or geometry and/or increase in sediment

deposition within the stream channel or pond: aquatic habitat (including riparian
vegetation) provides for shelter, foraging, predator avoidance, and aquatic dispersal for
• Alteration in water chemistry/quality including temperature, turbidity, and oxygen
content necessary for normal growth and viability of juvenile and adult CRLFs and their
food source.
Since potential effects to riparian vegetation caused by use of dimethoate cannot be discounted,
the determination is “habitat modification.”
The third aquatic-phase PCE is “alteration of other chemical characteristics necessary for normal
growth and viability of CRLFs and their food source.” Dimethoate is not expected to alter the
chemical characteristics of the water such that growth and viability of the CRLF; however, there
is potential for effects to aquatic invertebrates which represent prey of CRLF. Therefore, effects
to CRLF habitat defined by this PCE are of concern.
Another of the aquatic-phase PCE is: reduction and/or modification of aquatic-based food
sources for pre-metamorphs (e.g., algae). RQs do not exceed the LOC for algae for uses of
dimethoate. Therefore, for all dimethoate uses, this PCE is not of concern.
5.2.4.2. Terrestrial-Phase (upland habitat and dispersal habitat)
Three of the four assessment endpoints for the terrestrial-phase PCEs of designated critical
habitat for the CRLF are related to potential effects to terrestrial plants:
• Elimination and/or disturbance of upland habitat; ability of habitat to support food source
of CRLFs: Upland areas within 200 ft of the edge of the riparian vegetation or drip line
surrounding aquatic and riparian habitat that are comprised of grasslands, woodlands,
and/or wetland/riparian plant species that provides the CRLF shelter, forage, and predator
avoidance
• Elimination and/or disturbance of dispersal habitat: Upland or riparian dispersal habitat
within designated units and between occupied locations within 0.7 mi of each other that
Page 113 of 137

allow for movement between sites including both natural and altered sites which do not
contain barriers to dispersal
• Alteration of chemical characteristics necessary for normal growth and viability of
juvenile and adult CRLFs and their food source.
Since potential effects to terrestrial vegetation caused by use of dimethoate cannot be discounted,
the determination is “habitat modification.”
The remaining terrestrial-phase PCE is “reduction and/or modification of food sources for
terrestrial phase juveniles and adults.” RQs exceed LOCs for terrestrial invertebrates, terrestrial
mammals and terrestrial frogs which represent a food source for terrestrial phase CRLF.
Therefore, the determination for this endpoint is “habitat modification.”
5.2.5. Action Area
5.2.5.1. Areas indirectly affected by the federal action
The initial area of concern for dimethoate was previously discussed in Section 2.7 and depicted
in Figures 4 and 5 of the problem formulation. In order to determine the extent of the action
area in lotic (flowing) aquatic habitats, the greatest ratio of the RQ to the LOC for any endpoint
for aquatic organisms for each use category is used to determine the distance downstream for
concentrations to be diluted below levels that would be of concern (i.e. result in RQs less than
the LOC). For this assessment, this applies to RQs for acute exposures of dimethoate to aquatic
invertebrates. For all uses in a landcover category, the highest RQ/LOC ratio is used to define the
action area for that group of uses (Table 46). The total stream kilometers within the action area
that are estimated to be at levels of concern are defined in Table 47.
Table 46. Down stream dilution factors used to determine extent of lotic action area for uses of dimethoate.
Specific use
Down stream
group defining
Action area title Uses dilution factor
down stream
(RQ/LOC ratio)
dilution factor
agricultural lands alfalfa, beans, broccoli, Brussels sprouts, 27.3 Broccoli,
cauliflower, celery, Chinese cabbage, cotton, kohlrabi,
endive (escarole), field corn, garbanzo beans, cauliflower,
grass for seed, herbaceous ornamentals, Chinese cabbage
honeydew, kale, kohlrabi, lentils, lettuce,
lupine, melon, mustard greens, peas, peppers,
popcorn, potatoes, safflower, sainfoin,
sorghum, soybeans, Swiss chard, tomatoes,
triticale, turnips, wheat
Orchard, vineyard pears, pecans, citrus, conifer seed orchards, 37.3 cottonwood
and forests cottonwood, non-cropland areas adjacent to
vineyards
Page 114 of 137

Table 47. Quantitative results of spatial analysis of lotic aquatic action area relevant to dimethoate uses (in
km).
Measure Agriculture Orchard, Vineyard and Forest
Total Streams in CA 332,962

Streams within initial area of concern 56,589 153,902
Downstream distance added 4,508 24,530
Streams in aquatic action area 61,097 178,432
When considering the terrestrial and lentic (non-flowing) aquatic habitats of the CRLF, spray
drift from dimethoate use sites onto non-target areas could potentially result in exposures of the
CRLF, its prey, and its habitat. Therefore, it is necessary to estimate the distance from the
application site where spray drift exposures do not result in LOC exceedances for organisms
within the terrestrial and aquatic lentic habitats. To account for this, first, the dimethoate
application rate which does not result in an LOC exceedance is calculated for each terrestrial
taxa of concern. AgDISP was then used to determine the distance required to reach EECs not
exceeding any LOCs. These values are defined for each use in Table 48.
Table 48. Spray drift distances used to determine extent of action area for uses of dimethoate.
Spray drift distance
Action Specific use group defining
Uses not exceeding LOC
area title spray drift distance
(in feet)
agricultural alfalfa, beans, broccoli, Brussels 10,524 Alfalfa, beans, broccoli,
lands sprouts, cauliflower, celery, Chinese cauliflower, celery, Chinese
cabbage, cotton, endive (escarole), field cabbage, cotton, corn, garbanzo
corn, garbanzo beans, grass for seed, beans, grass for seed, melons,
herbaceous ornamentals, honeydew, kohlrabi, lentils, lupine, pears,
kale, kohlrabi, lentils, lettuce, lupine, peas, potatoes, safflower,
melon, mustard greens, peas, peppers, sainfoin, sorghum, soybeans,
popcorn, potatoes, safflower, sainfoin, tomatoes, triticale, wheat
sorghum, soybeans, Swiss chard,
tomatoes, triticale, turnips, wheat
Orchard, pears, pecans, citrus, conifer seed 10,797 cottonwood
vineyard orchards, cottonwood, non-cropland
and forests areas adjacent to vineyards
To understand the area indirectly affected by the federal action due to spray drift from
application areas of dimethoate, landcovers are considered as potential application areas. These
areas are “buffered” using ArcGIS 9.2. In this process, the original landcover is modified by
expanding the border of each polygon representing a field out to a designated distance, which in
this case, is the distance estimated where dimethoate in spray drift does not exceed any LOCs.
This effectively expands the action area relevant to terrestrial and aquatic lentic habitats so that it
includes the area directly affected by the federal action, and the area indirectly affected by the
federal action.
Page 115 of 137

5.2.5.2. Final action area
In order to define the final action areas relevant to uses of dimethoate, it is necessary to combine
areas directly affected, as well as aquatic and terrestrial habitats indirectly affected by the federal
action. This is done separately for the 2 categories of action areas (i.e. agricultural and orchard,
vineyard, and forests) using ArcGIS 9.2. Landcovers representing areas directly affected by
dimethoate applications are overlapped with indirectly affected aquatic lotic habitats (determined
by down stream dilution modeling) and with indirectly affected terrestrial and aquatic lentic
habitats (determined by spray drift modeling). It is assumed that lentic (standing water) aquatic
habitats (e.g. ponds, pools, marshes) overlapping with the terrestrial areas are also indirectly
affected by the federal action. The result is the final action area for dimethoate uses (Figures 13-
14).
Page 116 of 137

•
Legend
D Count y Bound ary
- - - o ti c area s
_ Te rre stri al and lentic area s
-- ~M il e s
Co mpil ed from C aliforn ia Count y bo un dari"s (ESRI, 21)] 2) ,

Map created by U.S. Environm ent al Prot ect ion Age ncy,
Offic e of Pe sticid e s Prog rams, Environm ent a l Fa te and
USD A Na tio nal Ag ric"I!"r . Stati st ic al Se tv ic e (NASS, 2002)
Effects Dr.;s;on. Ap rill1, 2007
Gap ;\na lysis Progr am Orch ard/Vin eya rd Landeov"r (G AP)
Na tio nal Land C oye r Databa se (N LC DJ (MR LC , 2001 )
Pr oj e c1ion: AJb ers Equ"1he a Conic USG S,
North Am" ric " n Datum of 1983 (NAO 1~3)
Figure 13. Final action area for crops described by agricultural landcover which corresponds to potential
dimethoate use sites. This map represents the area potentially directly and indirectly affected by the federal
action.
Page 117 of 137

Legend
•
D Count y Bound ary
_ Te rre stri al and lenti c area s
- - - o tic area s
-- ~M il e s
Co mpil ed from C aliforn ia Count y bo un danes (ESRI, 21)] 2) , Map created by U.S. Environm ent al Prot ect ion Age ncy
Offic e of Pe sticid e s Prog rams, Enmonm ent a l Fa te and'
USD A Na tion al Ag llcultur e Stati st ic al Serv ic e (NASS, 2002)
Effects Dr,.ision. Ap rilll, 2007
Gap ;\na lysls Progr am Orch ard/Vin eya rd Landcover (G AP)
Na tlo nal Land Co ve r Databa se (NLC D) (MR LC , 2001 ) Pr oj e ction: AJb ers Equ al he a Conic USG S,
North Ame "c an Datum of 1983 (NAO 1~3)
Figure 14. Final action area for crops described by orchard, vineyard and forest landcover which
corresponds to potential dimethoate use sites. This map represents the area potentially directly and indirectly
affected by the federal action. *Within recovery units.
Page 118 of 137

5.2.5.3. Overlap between CRLF habitat and final action area
In order to confirm that uses of dimethoate have the potential to affect CRLF through direct
applications to target areas and runoff and spray drift to non-target areas, it is necessary to
determine whether the final action areas for dimethoate uses overlap with CRLF habitats. Spatial
analysis using ArcGIS 9.2 indicates that lotic aquatic habitats within the CRLF core areas and
critical habitats potentially contain concentrations of dimethoate sufficient to result in RQ values
that exceed LOCs. In addition, terrestrial habitats (and potentially lentic aquatic habitats) of the
final action areas overlap with the core areas and critical habitat of each recovery unit (see Table
7) and available occurrence data for CRLF (Tables 49 and 50). Thus, uses of dimethoate could
result in exposures of dimethoate to CRLF in aquatic and terrestrial habitats. Additional analysis
related to the intersection of the dimethoate action areas and CRLF habitat is described in
Appendix C.
Table 49. Overlap between CRLF habitat (core areas and critical habitat) and agricultural action area by
recovery unit (RU#).
Measure RU1 RU2 RU3 RU4 RU5 RU6 RU7 RU8 Total
CRLF habitat (km2)* 3654 2742 1323 3279 3650 5306 4917 3326 28,197
Overlapping area of CRLF habitat
and terrestrial/lentic aquatic action 930 59 239 1609 2250 1921 2407 393 9811
area (km2)
% CRLF habitat overlapping with
32% 5% 19% 50% 61% 39% 50% 29% 42%
terrestrial/lentic aquatic Action Area
# Occurrences overlapping with
3 0 29 210 243 84 80 27 679
terrestrial/lentic aquatic action area
(of 13) (of 3) (of 70) (of 328) (of 281) (of 122) (of 92) (of 33) (of 942)
(total per area)
*Area occupied by core areas and/or critical habitat.
Table 50. Overlap between CRLF habitat (core areas and critical habitat) and orchard, vineyard and forestry
action area by recovery unit (RU#).
Measure RU1 RU2 RU3 RU4 RU5 RU6 RU7 RU8 Total
CRLF habitat (km2)* 3654 2742 1323 3279 3650 5306 4917 3326 28,197
Overlapping area of CRLF habitat
and terrestrial/lentic aquatic action 2817 1186 1238 3132 3668 4297 4801 1374 22,520
area (km2)
% CRLF habitat overlapping with
97% 97% 100% 97% 99% 87% 99% 100% 96%
terrestrial/lentic aquatic Action Area
# Occurrences overlapping with
13 3 70 325 281 121 92 33 942
terrestrial/lentic aquatic action area
(of 13) (of 3) (of 70) (of 328) (of 281) (of 122) (of 92) (of 33) (of 942)
(total per area)
*Area occupied by core areas and/or critical habitat.
Available pesticide use data from California indicate that dimethoate has been used in counties
which contain CRLF habitat. Out of 58 counties in California, 33 contain some portion of CRLF
critical habitat or core areas. According to use data for 2002-2005, 29 of the 33 counties
containing CRLF areas have reported past uses of dimethoate. In these counties, an annual
average of 214,765 lbs of dimethoate were applied. This represents 69% of the average annual
application of dimethoate in the state of California over 2002-2005. Reported county level uses
Page 119 of 137

of dimethoate for each county and their relation to the presence or absence of CRLF critical
habitat or core areas is available in Table 51. In this table, counties which contain CRLF critical
habitat or core areas are highlighted.
Table 51. Reported county level uses of dimethoate in California during 2002-2005 and their relation to
presence or absence of CRLF critical habitat or core areas within the county.
Average
Are CRLF % of total
annual lbs
habitat/core annual
County Reported uses of dimethoate in county during 2002-2005 applied
areas applied lbs in
(over 2002-
present? CA*
2005)
alfalfa, bean, bok choy, broccoli, Brussels sprouts, cabbage cauliflower,
celery, chervil, Chinese cabbage, collard, endive (escarole), grape, kale,
Monterey yes lettuce, melon, greenhouse, outdoor ornamental, peas, pepper, pimento, 40,711 13.1%
research commodity, rights-of-way, spinach, strawberry, Swiss chard,
tomato, uncultivated
alfalfa, bean, broccoli, cabbage, melon, cauliflower, celery, corn, cotton,
Imperial no endive (escarole), citrus, kale, lettuce, mustard, potato, tomato, turnip, 38,156 12.3%
wheat
alfalfa, bean, Christmas tree, citrus, corn, cotton, grape, lettuce, outdoor
Tulare no ornamental, pecan, pepper, safflower, sorghum, spinach, tangelo, 37,384 12.0%
tangerine, wheat
alfalfa, bean, broccoli, cabbage, melon, cauliflower, citrus, collard,
corn, cotton, grape, kohlrabi, landscape maintenance, lettuce, mustard,
Fresno yes 29,474 9.5%
greenhouse, peas, pecan, peppers, safflower, sorghum, spinach, Swiss
chard, tomato, turnip, wheat
alfalfa, beans, melons, citrus, corn, cotton, grape, landscape
Kern yes maintenance, lettuce, greenhouse, outdoor ornamental, pepper, potato, 27,248 8.8%
rights-of-way, safflower, sorghum, tomato, vertebrate control, wheat
alfalfa, animal premise, apple, bean, broccoli, cabbage, melon,
cauliflower, celery, collard, corn, kale, landscape maintenance, lettuce,
Stanislaus yes 24,464 7.9%
mustard, pecan, pepper, poultry, spinach, structural pest control, Swiss
chard, tomato, turnip, wheat
alfalfa, apple, beans, broccoli, cabbage, Christmas tree, corn, cotton,
San Joaquin yes grape, landscape maintenance, lettuce, greenhouse, pear, pepper, potato, 23,083 7.4%
safflower, sorghum, structural pest control, tomato, melon, wheat
alfalfa, animal premise, beans, broccoli, cabbage, melons, Chinese
greens, Christmas trees, citrus, corn, cotton, date, grape, landscape
Riverside yes 13,932 4.5%
maintenance, lettuce, greenhouse, outdoor ornamental, pepper,
sorghum, tomato, watermelon
alfalfa, apple, beans, bok choy, broccoli, Brussels sprout, cabbage,
cauliflower, celery, Chinese cabbage, endive (escarole), grape, kale,
Santa Barbara yes 13,489 4.3%
landscape maintenance, lettuce, outdoor ornamental, peas, pepper,
potato, spinach, tomato, uncultivated, vertebrate control
alfalfa, animal premise, beans, broccoli, cabbage, cauliflower, corn,
Merced yes cotton, grape, greenhouse, outdoor ornamental, safflower, tomato, 12,278 3.9%
melon, wheat
alfalfa, beans, collard, corn, cotton, grape, lettuce, safflower, sorghum,
Kings yes 9,625 3.1%
tomato, melons, wheat
alfalfa, bean, broccoli, melon, corn, grape, pepper, research commodity,
Yolo no 6,603 2.1%
sorghum, tomato, uncultivated, wheat
alfalfa, bean, bok choy, broccoli, Brussels sprouts, cabbage, cauliflower,
celery, Chinese cabbage, endive (escarole), grape, kale, landscape
San Luis Obispo yes 4,287 1.4%
maintenance, lettuce, greenhouse, outdoor ornamental, peas, pepper,
potato, spinach, squash, tomatillo, tomato
alfalfa, beans, melons, corn, grape, landscape maintenance, outdoor
Solano yes ornamentals, pear, pepper, safflower, sorghum, soybean, tomato, 3,953 1.3%
uncultivated, wheat
beans, cabbage, corn, cotton, landscape maintenance, melon, pear,
Sutter no 3,871 1.2%
sorghum, tomato, uncultivated, wheat
alfalfa, animal premise, beans, corn, cotton, forage hay/silage, grape,
Madera no 2,769 0.9%
greenhouse, citrus, safflower, tomato, wheat
alfalfa, animal premise, forage hay/silage, pastureland, peas, potato,
Modoc no 2,483 0.8%
structural pest control, wheat
bean, broccoli, cabbage, cauliflower, celery, corn, endive (escarole),
San Benito yes 2,409 0.8%
grape, kale, lettuce, mustard, pepper, research commodity, spinach,
Page 120 of 137

Average
Are CRLF % of total
annual lbs
habitat/core annual
County Reported uses of dimethoate in county during 2002-2005 applied
areas applied lbs in
(over 2002-
present? CA*
2005)
tomato
alfalfa, barley, bean, corn, pear, pepper, sorghum, squash, sudangrass,

Sacramento yes 1,897 0.6%
tomato, uncultivated, wheat
broccoli, Brussels sprouts, cabbage, cauliflower, celery, endive
Santa Cruz yes (escarole), lettuce, greenhouse, outdoor ornamental, spinach, Swiss 1,728 0.6%
chard, tomato
bean, broccoli, cabbage, cauliflower, celery, collard, kale, landscape
Ventura yes maintenance, lettuce, melon, mustard greenhouse, outdoor ornamentals, 1,526 0.5%
pepper, rights-of-way, Swiss chard, tomato
beans, cotton, landscape maintenance, melons, rights-of-way, safflower,
Colusa no 1,153 0.4%
sorghum, tomato, wheat
Lassen no alfalfa, uncultivated 1,094 0.4%
alfalfa, animal premise, Christmas tree, landscape maintenance,
San Bernardino no 1,029 0.3%
greenhouse, outdoor ornamental, citrus, public health
apple, beans, broccoli, cabbage, cauliflower, Chinese cabbage, Chinese
greens, corn, grape, landscape maintenance, lettuce, greenhouse,
Santa Clara yes 816 0.3%
outdoor ornamental, peas, pepper, research commodity, spinach,
structural pest control, tomato, melon
Siskiyou no alfalfa, potato, research commodity, structural pest control, wheat 793 0.3%
alfalfa, bean, corn, landscape maintenance, greenhouse plants, tomato,
Contra Costa yes 739 0.2%
wheat
alfalfa, cucumber, fumigation, herb/spice, landscape maintenance,
Los Angeles yes 703 0.2%
greenhouse, outdoor ornamentals, rights-of-way
beans, Christmas tree, landscape maintenance greenhouse, outdoor
Orange yes 679 0.2%
ornamental, pepper
Glenn no alfalfa, beans, melons, corn, cotton, citrus, peas, wheat 619 0.2%
Sonoma yes apple, grape, greenhouse, rights-of-way, uncultivated 607 0.2%
apple, beans, Brussels sprout, chicken, grape, citrus, landscape
San Diego yes maintenance, lemon, greenhouse, outdoor ornamental, pear, pepper, 401 0.1%
poultry, structural pest control, tomato, watermelon
bean, Brussels sprouts, landscape maintenance, greenhouse, peas,
San Mateo yes 347 0.1%
vertebrate control
Mendocino no grape 207 0.1%
Napa yes grape, landscape maintenance, rights-of-way 132 <0.1%
Yuba yes landscape maintenance, melon, pear, structural pest control 103 <0.1%
Butte yes alfalfa, bean, melons, cucumber, wheat 51 <0.1%
Tehama yes alfalfa, bean, corn 49 <0.1%
Alameda yes alfalfa, beans, landscape maintenance, structural pest control 31 <0.1%
Shasta yes apple, pear, structural pest control 3 <0.1%
El Dorado yes grape, structural pest control <1 <0.1%
Amador yes none 0 <0.1%
Marin yes none 0 <0.1%
Nevada yes none 0 <0.1%
Plumas yes none 0 <0.1%
Mono no alfalfa, pastureland, structural pest control 140 <0.1%
Del Norte no outdoor ornamental 100 <0.1%
Lake no apple, grape, pear 31 <0.1%
Tuolumne no rights-of-way 13 <0.1%
Placer no landscape maintenance, structural pest control 2 <0.1%
Humboldt no apple, grape 1 <0.1%
San Francisco no landscape maintenance <1 <0.1%
Trinity no none 0 0.0%
Alpine no none 0 0.0%
Calaveras no none 0 0.0%
Inyo no none 0 0.0%
Mariposa no none 0 0.0%
Sierra no none 0 0.0%
*Total annual average pounds of dimethoate applied in CA during 2002-2005 = 311,213.
Page 121 of 137

5.2.6. Description of Assumptions, Limitations, Uncertainties, Strengths and Data
Gaps
5.2.6.1. Exposure Assessment
Aquatic exposure modeling of dimethoate
The standard ecological water body scenario (EXAMS pond) used to calculate potential aquatic
exposure to pesticides is intended to represent conservative estimates, and to avoid
underestimations of the actual exposure. The standard scenario consists of application to a 10-
hectare field bordering a 1-hectare, 2-meter deep (20,000 m3) pond with no outlet. Exposure
estimates generated using the EXAMS pond are intended to represent a wide variety of
vulnerable water bodies that occur at the top of watersheds including prairie pot holes, playa
lakes, wetlands, vernal pools, man-made and natural ponds, and intermittent and lower order
streams. As a group, there are factors that make these water bodies more or less vulnerable than
the EXAMS pond. Static water bodies that have larger ratios of pesticide-treated drainage area
to water body volume would be expected to have higher peak EECs than the EXAMS pond.
These water bodies will be either smaller in size or have larger drainage areas. Smaller water
bodies have limited storage capacity and thus may overflow and carry pesticide in the discharge,
whereas the EXAMS pond has no discharge. As watershed size increases beyond 10-hectares, it
becomes increasingly unlikely that the entire watershed is planted with a single crop that is all
treated simultaneously with the pesticide. Headwater streams can also have peak concentrations
higher than the EXAMS pond, but they likely persist for only short periods of time and are then
carried and dissipated downstream (assuming that contributing waters to the downstream areas
do not contribute pesticide mass).
The Agency acknowledges that there are some unique aquatic habitats that are not accurately
captured by this modeling scenario and modeling results may, therefore, under- or over-estimate
exposure, depending on a number of variables. For example, aquatic-phase CRLFs may inhabit
water bodies of different size and depth and/or are located adjacent to larger or smaller drainage
areas than the EXAMS pond. The Agency does not currently have sufficient information
regarding the hydrology of these aquatic habitats to develop a specific alternate scenario for the
CRLF. As previously discussed in Section 2 and in Attachment 1, CRLFs prefer habitat with
perennial (present year-round) or near-perennial water and do not frequently inhabit vernal
(temporary) pools because conditions in these habitats are generally not suitable (Hayes and
Jennings 1988). Therefore, the EXAMS pond is assumed to be representative of exposure to
aquatic-phase CRLFs. In addition, the Services agree that the existing EXAMS pond represents
the best currently available approach for estimating aquatic exposure to pesticides
(USFWS/NMFS 2004a).
In order to account for this uncertainty, available monitoring data were compared to
PRZM/EXAMS estimates of peak EECs for the different uses. As discussed above, several data
values were available from NAWQA for dimethoate concentrations measured in surface waters
receiving runoff from agricultural areas. The specific use patterns (e.g. application rates and
timing, crops) associated with the agricultural areas are unknown, however, they are assumed to
be representative of potential dimethoate use areas. Peak model-estimated aquatic environmental
concentrations, resulting from different dimethoate uses, range from 0.1 to 20.3 µg/L. The
Page 122 of 137

maximum concentration of dimethoate reported by NAWQA from 2001-2006 for California
surface waters is 0.158 µg/L. This value is two orders of magnitude less than the maximum
model-estimated environmental concentration, but is within the range of environmental
concentrations estimated for different uses. The maximum concentration of dimethoate reported
by the California Department of Pesticide Regulation surface water database from 1991-2005
was 11.31 µg/L, which is on the same order of magnitude when compared to the highest peak
model-estimated environmental concentration.
Differences between modeled EECs and monitoring results are generally attributable to three
sources: 1) simulation modeling estimates are made using maximum label rates, monitoring data
reflects typical use, 2) modeled values represent a small static water body, the vast majority of
monitoring data is for streams and rivers which tend to be less vulnerable as high concentration
tend to be of short duration as they pesticide is carried downstream more rapidly; 3) simulation
modeling represents a small watershed near the area of application; 4) monitoring data usually
represents higher order streams with large basins and multiple land uses; 5: modeled values are 1
in 10 year exceedance values. Since most monitoring data is from one or two year studies at any
one site, it represents 1 in 2 year values.
There is uncertainty in the PRZM/EXAMS application timing relative to rainfall/runoff events.

Label instructions do not cite specific application dates. Consideration of the meteorological data
associated with the California PRZM scenarios indicates that the largest rainfall events occur in
January. In general, the greater amount of rainfall in a single event, the greater the EEC in the
receiving aquatic habitat. In order to select application dates that are relevant to times when
dimethoate is actually applied, pesticide use data were considered (Appendix B). Selection of
application dates during high rainfall periods would result in higher estimates of exposure of
aquatic habitats to dimethoate. Since EECs are already sufficient to exceed acute and chronic
LOCs for aquatic invertebrates, higher EECs would not alter the overall conclusion that potential
effects to aquatic invertebrates is likely to adversely affect the CRLF through indirect effects.
For direct effects to the aquatic-phase CRLF, current EECs result in the conclusion that
dimethoate exposures in the aquatic environment have “no effect” on the CRLF. In order to be of
concern for direct exposures to the CRLF, EECs would have to be at least one order of
magnitude larger. Even EECs which correspond to application timing which corresponds to the
rainy period (e.g. cottonwood, cauliflower, Chinese cabbage, kohlrabi, kale, mustard greens, and
broccoli) are insufficient to result in RQs which would exceed LOCs for direct effects to the
aquatic-phase CRLF.
Labels do not define a maximum number of applications allowed per year for use of dimethoate
on citrus. For the purposes of this assessment, only one application per year was modeled. This
single application is sufficient to exceed the LOC for several taxonomic groups of interest to this
assessment, including LOCs for direct effects to the terrestrial-phase CRLF. Any additional
applications of dimethoate to citrus would be expected to increase EECs and related RQs;
however, additional applications would not be expected to alter the overall conclusions of the
“LAA” determinations for direct and indirect effects to the CRLF resulting from dimethoate
applications to citrus.
Page 123 of 137

Deposition of dimethoate in precipitation
Dimethoate has been detected in precipitation samples in California. According to Majewski et

al. 2006, dimethoate was detected in 5% of rainfall samples (n=136) at a maximum concentration
of 0.102 µg/L. Based on these data, it is possible that dimethoate can be deposited on land in
precipitation. Estimates of exposure of the CRLF, its prey and its habitat to dimethoate included
in this assessment are based only on transport of dimethoate through runoff and spray drift from
application sites. Current estimates of exposures of CRLF and its prey to dimethoate through
runoff and spray drift, which are already sufficient to exceed the LOC, would be only be greater
if consideration is given to deposition in precipitation.
In an attempt to estimate the amount of dimethoate deposited into aquatic and terrestrial habitats,
the maximum measured dimethoate concentration measured in rain samples taken in California
(0.102 µg/L; Majewski et al. 2006) was considered in combination with California specific
precipitation data and runoff estimates from PRZM. Precipitation and runoff data associated with
the PRZM scenarios used to model aquatic EECs were used to determine relevant 1-in-10 year
peak runoff and rain events. The scenarios included were: CA almond, CA lettuce, CA wine
grape, CA row crop, CA fruit, CA nursery, and CA onion. The corresponding meteorological
data were from the following locations: Sacramento, Santa Maria, San Francisco, Monterey
County, Fresno, San Diego, and Bakersfield, respectively.
To estimate concentrations of dimethoate in the aquatic habitat resulting from deposition in rain,
the daily PRZM-simulated volume of runoff from a 10 ha field is combined with an estimate of
daily precipitation volumes over the 1 ha farm pond relevant to the EXAMS environment. This
volume is multiplied by the maximum concentration of dimethoate in precipitation reported in
monitoring data (0.102 µg/L). The result is a daily mass load of dimethoate into the farm pond.
This mass is then divided by the volume of water in the farm pond (2.0 x107 L) to achieve a daily
estimate of dimethoate concentration in the farm pond, which represents the aquatic habitat.
From the daily values, the 1-in-10 year peak estimate of the concentration of dimethoate in the
aquatic habitat is determined for each PRZM scenario (Table 52). There are several
assumptions associated with this approach, including: 1) the concentration of dimethoate in the
rain event is spatially and temporally homogeneous (e.g. constant over the 10 ha field and 1 ha
pond for the entire rain event); 2) the entire mass of dimethoate contained in the precipitation
runs off to the pond or is deposited directly into the pond; 3) there is no degradation of
dimethoate between the time it leaves the air and the time it reaches the pond.
To estimate deposition of dimethoate on the terrestrial habitat resulting from deposition in rain,
the daily volume of water deposited in precipitation on 1 acre of land is estimated. This volume
is multiplied by the maximum concentration of dimethoate in precipitation reported in
monitoring data, which is 0.102 µg/L. The result is a mass load of dimethoate per acre
(converted to units of lbs a.i./A). From the daily values, the 1-in-10 year peak estimate of the
deposition of dimethoate on the terrestrial habitat is estimated for each PRZM scenario (Table
52). In this approach, it is assumed that the concentration of dimethoate in the rain event is
spatially and temporally homogeneous (e.g. constant over the 1 A of terrestrial habitat for the
entire rain event).
Page 124 of 137

Table 52. 1-in-10 year peak estimates of dimethoate concentrations in aquatic and terrestrial habitats
resulting from deposition of dimethoate at 0.102 µg/L dimethoate in rain.
Met Station Scenario(s) Concentration in Deposition on
aquatic habitat (µg/L) terrestrial habitat
(lbs a.i./A)
Sacramento CA almond 0.019 0.0001
Santa Maria CA lettuce, CA colecrop, CA strawberry 0.020 0.0001
San Francisco CA winegrape 0.018 0.0001
Monterey Co. CA row crop 0.016 0.0001
Fresno CA fruit, CA tomato, CA melon 0.007 <0.0001
San Diego CA nursery 0.014 <0.0001
Bakersfield CA onion, CA potato 0.005 <0.0001
Degradates
Dimethoate degrades into omethoate, which is as toxic or more toxic to non-target animals when
compared to the parent. As discussed in section 2.4.1, omethoate was not detected as a degradate
in available laboratory fate studies, but was detected in terrestrial field dissipation and foliar
residue studies. Registrant submitted studies indicate that omethoate can comprise significant
portions (up to 96%) of applied dimethoate residues detected on foliar surfaces (MRID 466780-
09). Based on this information, potential exposures of animals to omethoate in terrestrial
environments are of concern.
In estimating EECs on food items of terrestrial phase CRLF and its prey, a foliar degradation
half-life of 2.88 days is used in T-REX and T-HERPS to represent degradation of dimethoate. As
noted above, this foliar degradation half-life represents an analysis of data from Willis and
McDowell (1987) (Table 4). While the selection of this half life value does not affect estimates
of acute EECs, it can affect estimates of chronic exposures, with longer half-lives resulting in
greater EECs and greater risks. The selected half-life relies upon data measuring the
disappearance of dimethoate from leaf surfaces, without regard for the formation of omethoate.
The use of 2.88 days as a foliar dissipation half-life represents an uncertainty, since the half-life
could result in an underestimation of chronic exposure and effects resulting from the formation
of omethoate.
Registrant submitted studies which included dissipation of dimethoate and omethoate from foliar
surfaces indicated that foliar dissipation half-lives of the sum of the two chemicals ranged 0.98-
7.4 days. These values fall within the range of data cited in Willis and McDowell (0.9-7.2 days)
for dimethoate. If the foliar dissipation half-life were extended to account for formation of
omethoate, estimates of chronic exposure to terrestrial-phase CRLF and its amphibian and
mammalian prey would increase, resulting in higher RQs. Since RQs already exceed the chronic
LOCs for exposures to these organisms resulting from all uses of dimethoate, this will not
influence the LAA effects determinations for direct and indirect effects of dimethoate to the
CRLF and its prey in terrestrial habitats.
Since the action area for dimethoate is derived using acute exposures to terrestrial invertebrates,
inclusion of omethoate will not alter the action area described above. As noted in Section 4.3, the
toxicities of omethoate and dimethoate to honey bees are roughly equivalent. The action area is
Page 125 of 137

derived using estimates of acute exposures to honey bees, therefore, the use of the foliar
dissipation half life that considers only dimethoate will not affect estimates of acute exposures to
terrestrial invertebrates. Terrestrial invertebrate RQs and the extent of the area indirectly affected
by spray drift from treatment sites will be the same with or without consideration of omethoate.
Mixture Effects
This assessment considers only the single active ingredient of dimethoate. However, the
assessed species and its environments may be exposed to multiple pesticides simultaneously.
Interactions of other toxic agents with dimethoate could result in additive effects, synergistic
effects or antagonistic effects. Evaluation of pesticide mixtures is beyond the scope of this
assessment because of the myriad factors that cannot be quantified based on the available data.
Those factors include identification of other possible co-contaminants and their concentrations,
differences in the pattern and duration of exposure among contaminants, and the differential
effects of other physical/chemical characteristics of the receiving waters (e.g. organic matter
present in sediment and suspended water). Evaluation of factors that could influence
additivity/synergism is beyond the scope of this assessment and is beyond the capabilities of the
available data to allow for an evaluation. However, it is acknowledged that not considering
mixtures could over- or under-estimate risks depending on the type of interaction and factors
discussed above.
5.2.6.2. Effects Assessment
Direct Effects
Toxicity data for aquatic-phase and terrestrial-phase amphibians is not available for use in this
assessment. Therefore, fish and avian toxicity data are used as a surrogates for CRLF. There is
uncertainty regarding the relative sensitivity of amphibians and their surrogates to dimethoate. If
the surrogates are substantially more or less sensitive than the CRLF, then risk would be over or
under estimated, respectively.
Sublethal Effects
Open literature is useful in identifying sublethal effects associated with exposure to dimethoate.
However, no data are available to link the sublethal measurement endpoints to direct mortality or
diminished reproduction, growth and survival that are used by OPP as assessment endpoints.
OPP acknowledges that a number of sublethal effects have been associated with diemthaote
exposure; however, at this point there are insufficient data to definitively link the measurement
endpoints to assessment endpoints.
Indirect Effects
Indirect effects on the aquatic-phase CRLF are estimated based on the most sensitive
invertebrate tested, i.e. stonefly. Other, less sensitive, aquatic invertebrates may be part of the
diet of the aquatic-phase CRLF. Therefore, risk to stonefly, may not be equivalent to risk to
Page 126 of 137

organisms comprising the diet of the CRLF and its use in this assessment may result in an
overestimation of risk.
5.2.7. Addressing the Risk Hypotheses
In order to conclude this risk assessment, it is necessary to address the risk hypotheses defined in
section 2.9.1. Based on the conclusions of this assessment, none of the hypotheses can be
rejected, meaning that the stated hypotheses represent concerns in terms of direct and indirect
effects of dimethoate on the CRLF and its designated critical habitat.
Page 127 of 137

6. Conclusions
Based on terrestrial estimated environmental concentrations for the currently registered uses of
dimethoate, RQ values exceed the Agency’s LOC for direct acute and chronic effects on the
CRLF; this represents a “may affect” determination. RQs exceed the LOC for acute and chronic
exposures to aquatic invertebrates and for acute exposures to terrestrial invertebrates. Therefore,
there is a potential to indirectly affect juvenile and adult CRLF due to effects to the invertebrate
prey base in aquatic and terrestrial habitats. The effects determination for indirect effects to the
CRLF due to effects to its prey base is “may affect.” When considering the prey of larger CRLF
in aquatic and terrestrial habitats (e.g. frogs, fish and small mammals), RQs for terrestrial-phase
frogs and small mammals also exceed the LOC for acute and chronic exposures, resulting in a
“may affect” determination. RQ values for unicellular plants in aquatic habitats do not exceed
the LOC. Risk of dimethoate use on riparian and terrestrial vegetation cannot be discounted.
Therefore, the determination for indirect effects to the CRLF through effects to its habitat is
“may affect.”
Refinement of all “may affect” determinations results in: a “LAA” determination based on direct
effects to the terrestrial-phase CRLF, a “LAA” determination for indirect effects to the CRLF
based on effects to its prey and an “LAA” determination for indirect effects to the CRLF based
on effects to its habitat. Consideration of CRLF critical habitat indicates a determination of
“habitat modification” for aquatic and terrestrial habitats. The overall CRLF effects
determination for dimethoate use is “LAA.”
Based on the conclusions of this assessment, a formal consultation with the U. S. Fish and
Wildlife Service under Section 7 of the Endangered Species Act should be initiated. Attachment
2, which includes information on the baseline status and cumulative effects for the CRLF, can be
used during this consultation to provide background information on past US Fish and Wildlife
Services biological opinions associated with the CRLF.
When evaluating the significance of this risk assessment’s direct/indirect and habitat
modification effects determinations, it is important to note that pesticide exposures and predicted
risks to the species and its resources (i.e., food and habitat) are not expected to be uniform across
the action area. In fact, given the assumptions of drift and downstream transport (i.e., attenuation
with distance), pesticide exposure and associated risks to the species and its resources are
expected to decrease with increasing distance away from the treated field or site of application.
Evaluation of the implication of this non-uniform distribution of risk to the species would require
information and assessment techniques that are not currently available. Examples of such
information and methodology required for this type of analysis would include the following:
• Enhanced information on the density and distribution of CRLF life stages within specific
recovery units and/or designated critical habitat within the action area. This information
would allow for quantitative extrapolation of the present risk assessment’s predictions of
individual effects to the proportion of the population extant within geographical areas where
those effects are predicted. Furthermore, such population information would allow for a
more comprehensive evaluation of the significance of potential resource impairment to
individuals of the species.
Page 128 of 137

• Quantitative information on prey base requirements for individual aquatic- and terrestrial-
phase frogs. While existing information provides a preliminary picture of the types of food
sources utilized by the frog, it does not establish minimal requirements to sustain healthy
individuals at varying life stages. Such information could be used to establish biologically
relevant thresholds of effects on the prey base, and ultimately establish geographical limits to
those effects. This information could be used together with the density data discussed above
to characterize the likelihood of effects to individuals.
• Information on population responses of prey base organisms to the pesticide. Currently,
methodologies are limited to predicting exposures and likely levels of direct mortality,
growth or reproductive impairment immediately following exposure to the pesticide. The
degree to which repeated exposure events and the inherent demographic characteristics of the
prey population play into the extent to which prey resources may recover is not predictable.
An enhanced understanding of long-term prey responses to pesticide exposure would allow
for a more refined determination of the magnitude and duration of resource impairment, and
together with the information described above, a more complete prediction of effects to
individual frogs and potential modification to critical habitat.
Page 129 of 137

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Sources for Wild Birds After Application of an EC Formulation Containing 400 g/L Dimethoate,
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Laboratorium fuer and Huntingdon Life Sciences, Ltd. 238 p.
Page 136 of 137

MRID 46678001. Wilson, A. (2001) Residue Study (Decline Curve) with an EC Formulation
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Containing 400 g/L Dimethoate Applied to Wheat in Spain and Italy in 2002. Project Number:
SCI/037. Unpublished study prepared by Huntingdon Life Sciences, Ltd. 144 p.
Page 137 of 137

II. Project Description
EXISTING ZONING AND THE TIDELANDS TRUST EXCHANGE
The entire Redevelopment Plan Project Area is within the P (Public) Use District on the San
Francisco Planning Code Zoning Map. According to the San Francisco Zoning Map and
Section 105(f) of the San Francisco Planning Code, the Redevelopment Plan Project Area is
within a 40-X height and bulk district.
In addition, any portion of the Redevelopment Plan Area that consists of tidelands and submerged
lands, or former tidelands and submerged lands that have been filled, will become subject to the
use restrictions imposed under the California Tidelands Trust Doctrine and the statutory trust
imposed by the 1997 Treasure Island Conversion Act13 (collectively, the “Tidelands Trust”) upon
their conveyance from the Navy to TIDA.14 These areas include all of Treasure Island,
approximately 2 acres of land on Yerba Buena Island, and all of the tidal and submerged lands
within the Redevelopment Plan Project Area. The approximately 37-acre Job Corps campus
would not be subject to the Tidelands Trust as long as it remains in Federal ownership.
The Tidelands Trust generally prohibits residential, general office, non-maritime industrial, and
certain recreational uses on lands that are subject to the Trust. Under the 1997 Treasure Island
Conversion Act,15 existing uses on Treasure Island that are inconsistent with the Tidelands Trust,
such as the existing residential buildings, are permitted to continue for their remaining useful life,
defined as no less than 25 years or no more than 40 years from the date of the Act.
To facilitate proposed residential and other non-trust uses on the areas of Treasure Island that
would be subject to the Tidelands Trust upon conveyance to TIDA, the State legislature
authorized a Tidelands Trust exchange.16 Under the authorized exchange, the Tidelands Trust
restrictions would be removed from the portions of Treasure Island that are planned for
residential and other non-Trust uses and transferred to portions of Yerba Buena Island that would
be used for Trust purposes (see Figure II.3: Tidelands Trust Land Exchange). The proposed
Tidelands Trust exchange authorized by Senate Bill 1873 would be implemented through an
Exchange Agreement entered into between the State Lands Commission and TIDA.
13
California Health & Safety Code Section 33492.5.
14
The 1943 legislation that authorized the State to convey the property to the Federal Government removed
the Tidelands Trust use restrictions from the property. However, the California Attorney General has
opined that the Tidelands Trust will apply to the property once conveyed out of Federal ownership.
15
California Health & Safety Code Section 33492.5.
16
Chapter 543, Statutes of 2004, as amended in 2007 and 2009 (SB 1873).
July 12, 2010 II.14 Treasure Island / Yerba Buena Island

Case No. 2007.0903E Redevelopment Project Draft EIR
STATUS OF THE SAN FRANCISCO GARTER SNAKE (THAMNOPHIS
SIRTALIS TETRATAENIA) AT PACIFICA QUARRY, SAN MATEO,
CALIFORNIA
Prepared for:
PBS&J EIP Associates

353 Sacramento Street, Suite 1000
San Francisco, CA 94111
Prepared by:
Swaim Biological , Inc.

4435 1st Street, PMB #312
Livermore, CA, 94550
925.455.8770
February 27, 2007

Revised
TABLE OF CONTENTS
1.0 INTRODUCTION................................................................................................................... 1
1.1 Purpose and Scope of Report................................................................................................ 1
1.2 Project Site Location and Regional Study Area ................................................................... 1
1.3 Regulatory Context ............................................................................................................... 1
1.4 San Francisco Garter Snake .................................................................................................. 3
2.0 MATERIALS AND METHODS ........................................................................................... 5
2.1 Trapping and Visual Surveys................................................................................................ 5
2.2 Regional Distribution and Habitat Analysis ......................................................................... 9
3.0 RESULTS AND DISCUSSION ........................................................................................... 12
3.1 Trapping and Visual Surveys.............................................................................................. 12
3.2 Regional Distribution and Habitat Analysis ....................................................................... 20
3.2.1 Mori Point/Sharp Park ................................................................................................. 20
3.2.2 Calera Creek Corridor and City of Pacifica Uplands................................................... 20
4.0 CONCLUSIONS ................................................................................................................... 26
6.0 LITERATURE CITED ........................................................................................................ 27
7.0 PERSONAL COMMUNICATIONS................................................................................... 29
LIST OF FIGURES
Figure 1. Site location. ................................................................................................................... 2

Figure 2. Project site location in relation to Coastal Zone............................................................. 4
Figure 3. Trapline locations. ........................................................................................................... 6
Figure 4. Trapline schematic and photo......................................................................................... 7
Figure 5. Marking system for snakes (upper photo) and PIT tag (lower photo). .......................... 8
Figure 6. Regional analysis study area. ....................................................................................... 10
Figure 7. Habitat analysis area (west of Highway 1)................................................................... 11
Figure 8. Listed Species Capture and Observation Sites - Current, Recent and Historic............ 14
Figure 9. 1989 air photo of site showing location of filled ponds and SFGS captures. .............. 22
ii
LIST OF TABLES
Table 1. California Red-legged Frog captures per trap, the percentage of total captures at each
trap, and the associated habitat type. ............................................................................................ 16
Table 2. Total Captures from Calera Creek trap lines. ............................................................... 17
Table 3. Total captures from upland trap lines west of Calera Creek.......................................... 18
Table 4. Total captures from trap lines east of Calera Creek in the “flats”. ................................. 19
ii
1.0 INTRODUCTION
1.1 Purpose and Scope of Report
This report presents results of a regional analysis of the status of the San Francisco garter snake
(Thamnophis sirtalis tetrataenia). The analysis included a review of existing information on the
SFGS in the region and trapping surveys for the SFGS at the site. The trapping and visual
surveys were conducted under the authority of a 10 (A) 1(a) Federal recovery permit (PRT-
815537) issued by the U.S. Fish and Wildlife Service (FWS), a Memorandum of Understanding
issued by the California Department of Fish and Game, (CDFG), and individual Scientific
Collecting Permits, held by individuals working on the study.
The purpose of this survey was to assess the condition of the project site habitats and to
document the current status of the SFGS on the 85-acre Pacifica Quarry Site, which is proposed
for development. This survey cannot determine negative finding for SFGS or indicate that the
snakes are absent from the site; SFGS are known to occur on the site from past studies and
suitable habitat is present. This stipulation was made in the research proposal submitted to the
FWS and DFG which was required to allow the surveys to proceed (Swaim Biological 2006a).
This language was reviewed and approved by the applicants’ consultant, EIP Associates, prior to
submission to the FWS and DFG. The applicant is interested in conducting the survey for
informational purposes in conjunction with identifying, if possible, a development proposal and
mitigation package that assists with the recovery of the SFGS.
1.2 Project Site Location and Regional Study Area
The 85 acre Pacifica Quarry site is in the town of Pacifica approximately 10 miles southwest of
San Francisco (Figure 1). This proposed project area is within the range of the SFGS in San
Mateo County and SFGS are known to have occupied the site in the past (McGinnis 1990, Barry,
1994). The site lies within the Calera Creek watershed. Pacifica Quarry is bordered by the
Rockaway Beach development on the southwest along San Marlo Drive and scattered
commercial developments on the south and southeast along Highway 1. Highway 1 is a four
lane road with a K-Rail median along the length of Highway 1 to the south and southeast of the
project site (Figure 1). The western boundary is the Pacific Ocean and significant areas of the
southern and eastern boundary are still bordered by undeveloped land and open space, although
it is separated from these undeveloped open space areas by the existing Highway 1. The entire
northern border of the site is contiguous with permanent protected open space (Golden Gate
National Recreation Area) and City of Pacifica Property along Calera Creek.
1.3 Regulatory Context

The San Francisco garter snake (SFGS) is a state and federally endangered species as well as a
state fully protected species. The California red-legged frog (CRF) is a federally listed
threatened species and considered a species of special concern by the state. California law (Fish
and Game Code Sections 3511, 4700, 5050, and 5515) allows the designation of a species as
1
Figure 1. Site location.
2
fully protected. This is a greater level of protection than is afforded by CESA, since such a
designation means the listed species cannot be taken at any time.
The project site is also within the jurisdiction of the California Coastal Commission (Figure 2).
The California Coastal Commission (CCC) oversees the implementation of the federal Coastal
Zone Management Act of 1990, which required coastal states to develop certified Coastal Zone
Management Programs.
1.4 San Francisco Garter Snake
The SFGS was one of the first species to be designated federally endangered in 1967: state
listing followed in 1971. SFGS populations have severely declined over the past century. This
species has suffered from habitat loss due to urbanization, collection by the black-market pet
trade, and decline of its main prey species, the California red-legged frog. The introduction of
non-native bullfrogs (Rana catesbiana), which eat both the snake and the CRF, may have added
to the snake’s decline.
SFGS have a yellowish-green dorsal stripe, edged with black, bordered by a red stripe, then
black again on both sides. The belly is blue-green and the top of the head is red (Stebbins,
2003). Hatchlings and juveniles have the same coloration as adults.
Historically, SFGS occurred in scattered wetlands and the associated matrix of uplands along the
San Francisco Peninsula, from just south of the San Francisco County line south to Waddell
Creek, Santa Cruz County, and along the base of the Santa Cruz Mountains to at least Upper
Crystal Springs Reservoir (U.S. Fish and Wildlife Service, 1985). SFGS enter into a zone of
intergradation with conspecific California red-sided garter snake (T. sirtalis infernalis) just south
of the Pulgas water temple (Crystal Springs Reservoir, San Mateo Co.) into extreme northern
Santa Clara County around Stanford University campus (Barry, 1994).
Currently, Mori Point and Sharp Park (west of Highway 1) are occupied by a breeding
population of the SFGS (Swaim Biological 2004, 2006b) and it is the northern most population
of the subspecies remaining on the coast. The Mori Point and Sharp Park area are within the
Sanchez Creek watershed.
3
Figure 2. Project site location in relation to Coastal Zone.
4
2.0 MATERIALS AND METHODS
2.1 Trapping and Visual Surveys
Trapping surveys consisted of a 90 day spring and 45 day late summer/fall survey period.
A trapline consists of approximately twenty-five feet of drift fence and the four associated traps.
The drift fence is constructed from 16-inch high pieces of 1/8th –inch thick, flexible hardboard,
of which two inches are buried in the ground for stability and to keep animals from passing
under the fence. Traplines were distributed throughout all the habitats of the project area
resulting in twelve in willow riparian, eight in non-native grassland, six in a wetland, and
fourteen in pampas grass (Figure 3). Traps placed in the willow riparian and wetland were in
close proximity to creeks.
Two traps are positioned at each end, for a total of four traps per drift fence (Figure 4). The traps
are wooden framed with a wire mesh funnel and large panels of wire mesh to allow light and air
circulation into the trap (Figure 4). To prevent animals from exiting, circular one-way Mylar
flaps are affixed internally to the entrance hole of each funnel. Traps were checked daily in the
late afternoon to ensure captive reptiles were not likely to be in the traps overnight. To prevent
the desiccation of captured animals, Soilmoist was placed in a small well approximately 3.5
inches wide and 1 inch deep at the end of the trap opposite from the funnel. This is particularly
important for preventing the mortality of threatened species such as the CRLF. The traps were
covered with plywood covers to shade the interior.
Thirty-seven traplines were placed around Pacifica Quarry property and activated on March 21st,
2006 (Figure 3). On March 31, three more traplines were added for a total of forty traplines.
Traplines 1- 22 and 26-40 were straight-line fences, and 23-25 were constructed as an array
(Figure 3). Traplines 21-25 were deactivated on June 13, due to safety concerns of the trap
checkers and the traps. Once school was out for summer, the frequency of persons throwing
rocks from the bluffs increased. Though rocks were not intentionally thrown at trap checkers,
they were not visible from the bluffs above. The remaining traplines were deactivated on June
29, ending the spring component. The late summer/fall survey began on September 5 and went
through October 23. Trap days were calculated for the survey effort. A trap day equals one
trapline in the field for 24 hours. Accounting for the schedule above the total number of trapdays
was 3,313 spring trap days and 1,200 late summer/fall trap days.
All vertebrates captured were identified to species, with the exception of deer mice (Peromyscus
sp.), which were identified to genus. Snakes were sexed and marked for future identification by
clipping specific ventral scales and inserting a PIT (Passive Integrated Transponder) tag (Figure
5)., PIT tagging was discontinued for the for coast garter snakes and they were given ventral
scale marks only, after 300 were processed. Morphometrics, including snout-vent length (mm),
total length (mm), weight (g), and sex were collected for the first ten coast garter snakes
captured, as well as a 3 mm tail clip for genetic analysis, and photos to document color patterns.
Lizards were marked with unique toe clips for future identification (Enge, 1997).
5
o
H!storlcal Calera Creek a !JglUllc'l! (USGS)

D ProJ~ct OOumlmy
D OONRA
I'~cific a QU:lrry Wetlands (I'BS&J)
\\~lJow
Willow Rlparnn
_ Sea0;0nal Pond (E:-:~a\'ated)
~ Wetland (Corps JunooiclJollal)
Figure 3. Trapline locations.
6
Trapline Schematic (plane view)
I• 18 · •I I• 18· •I
T
8· Trap Trap
T
8·
1 """'-- 25'
• 1
Trap /
Drill Fence
Trap
Trapline Schematic (oblique view)

Snake Trap Des ign and Dimensions
I.. 25' ..\ Solid wood
i
/'
2' slakes
,., ,
- , r
2" (burried)
1/8" Hardware Cloth
Figure 4. Trapline schematic and photo.
7
E."alllpie of a scale mark on a juvcnik: SFGS. (S FGS 1129) .
. ~ :.
PIT lag
•
prr lag.
Figure 5. Marking system for snakes (upper photo) and PIT tag (lower photo).
8
Visual surveys were conducted in the course of checking traplines and on specific dates at the
quarry pond. However, because traps are checked very late in the day to avoid having snakes in
the traps overnight, their usefulness in detecting SFGS is somewhat limited. Visual surveys were
conducted along the perimeter of the pond on at least three occasions (January 20, mid April, and
May 24) and seining of the pond on one occasion (May 24).
2.2 Regional Distribution and Habitat Analysis
The regional analysis study area was defined by SBI as the region including Pacifica, Sharp Park
region, Milargra Ridge, Mori Point, the Quarry Area, and east to Highway 35 (GGNRA Lands,
portions of the San Francisco Watershed lands associated with San Andreas Lake (Figure 6).
Within that area we compiled SFGS and CRF occurrences by reviewing all accessible
environmental documents, published documents, museum collection databases, and contacts with
biologists who have done survey work in the area.
The habitat analysis area was smaller in scope and included the project site, the City of Pacifica
Property which bisects the quarry site (Calera Creek area), GGNRA’s Mori Point, and Sharp
Park west of Highway 1 (Figure 7). EIP Associates mapped jurisdictional wetlands and
vegetation types on the site. Swaim Biological mapped the remaining area with a more
simplified vegetation layer and general wetland boundaries base on field inspections. Upland
areas were also mapped using a general classification: aquatic, grassland, pampas grass, and
scrub. SBI then inspected each of these habitats to determine their suitability for target species
(SFGS and CRF).
9
,
ldon POlO!
.... _ K1I0'"''''''
"""'~_"",~ _ _ _J
""' _ _ ."... .... """""" """!tAW>
Figure 6. Regional analysis study area.
10
o 100 200 400
..... _ _ OO>IU ...... _
Meters
.... _ _ ... _ "",,.ADO'
N
His lori~ a l Cal .:ra CI'.:ek ali gllllH::nl (USGS)
c::::J Projed bouudary

D CNNRA
Figure 7. Habitat analysis area (west of Highway 1).
11
3.0 RESULTS AND DISCUSSION
3.1 Trapping and Visual Surveys
No SFGS were captured or observed on the site, indicating that the current population of SFGS
on the site is not large enough to detect. As was acknowledged in the required application to
conduct the survey, SFGS cannot be determine to be absent from the site. In this survey CRF,
were found to be present and distributed throughout project site in wetlands (permanent and semi
permanent) and in the upland habitats (Figure 8, Tables 1-4). CRF breed in the mitigation ponds
on the north side of Calera Creek (City of Pacifica Property) and were the second most abundant
amphibian trapped on the site.
One adult CRF was captured in the center of the “flats” area south of Calera Creek. In addition
several unconfirmed observations of CRF were made in a wetland along Highway 1 on the
southern boundary of the Quarry property (Figure 8). These observations were the audible
“plops” or splashes of larger frogs jumping into the water as a trap checker went by the margin
of the pool. Because the bullfrog is not present on the site, and the splashes were too big for
treefrog, it is assumed these were CRF. Confirmation was attempted by biologists, but the
habitat there has many roots, branches and mud for CRF to escape into, evading direct
observation. Night surveys for eye-shine would be more effective at this location, however this
method was not in the scope and is unnecessary since CRF have been documented there in the
past (H.T. Harvey 2002). A total 30 + juveniles were observed at this pool in February. Given
the sufficient hydro-period in this pool (sufficient water through October), the presence of
suitable cover, this wetland is potentially suitable CRF breeding habitat. Additional adult and
juvenile CRF were found under nearly every available surface object in the Quarry flats and
upland from the quarry pond during the February site visit conducted by H.T. Harvey (Personal
Communication Jeff Wilkinson, November 15, 2006).
Other amphibians, all prey species of the SFGS, were distributed throughout the site and were
abundant in not only the wetlands, and willow riparian area, but also throughout the upland
habitats, including non-native grassland and pampas grass (Figure 8, Tables 2-4).
The most commonly captured prey species were the California slender salamander
(Batrochoseps attenuatus) and the Arboreal Salamander (Aneides lugubris)
Other vertebrates captured include other reptiles and mammals. Three other snake species are
present on the site including coast garter snake (Thamnophis elegans terrestris), western yellow-
bellied racer (Coluber constrictor mormon) and Pacifica gopher snake (Pituophis catenifer).
Coast garter snakes were the most abundant with a total of 1200 captures. No aquatic garter
snakes (Thamnophis atratus couchii) were captured. The total captures include recaptures of
individuals over the course of the survey. Captures of each species consisted of both adults and
juveniles, with adult captures far exceeding juvenile captures. Both males and females of each
species were captured with male captures exceeding female captures.
During a portion of the spring survey at Pacifica Quarry, Swaim Biological was also trapping at
the Mori Point property to the north of the site. The trapping there was part of a pond creation
12
- - 0 .",," Colon (.' r<d: . 10""".. ",
n 'pl.,. I"",,,,,,..
- • - , \\'01ers1 .. d l>ou,"laoy
• C1U.F ()bs"f'~!i""" (SIlt CNDDB)
'"**
.... CRF.~ "' ... (!lIP lOO6)
~FOS Obo.......IIOIlS (/1 « 0 ,.",,- 1m)

~fGS Ob~...,'lI"OI" W.., ) , 1918)
D OONRA
c::J 1'10)«' Ix<" "b,y
>
I'adlic" Q u;on) ' \\'~II J "'I .( P8S&J)
~ FI."h"'"I<. hl:u(t,
Willow SPGS
R<",(r<>dU<IIM
mll~w tt'I' ."'''' ZOO L<
_ S<iISQO,,( P""d !E.w,nled)
_ \\'.lI."d (COI ps J\"lsdr<II01IOI)

_ SFGS "'111~" '''' pond, (SJ'GS '<oU l'Il<IIoc!lOn z"".)
A
N
• •.__ SBI..
o 100
ldctCfll
k _ _ oMHU . . . . .. -
..... _ ............ , _ \1Tl.I1WlO.
Figure 8. Listed Species Capture and Observation Sites - Current, Recent and Historic.
14
project carried out in a joint effort by United States Fish and Wildlife Service (USFWS), Golden
Gate National Recreation Area (GGNRA), and Golden Gate National Park Conservancy. That
project satisfies recommendations detailed in recovery task 252 of the San Francisco Garter
Snake Recovery Plan (USFWS, 1985). During the study, one coast garter snake that was
originally captured in the Pacifica Quarry study (PQ trapline # 16), was recaptured at Mori Point
During the period from April 29 through May 2, 2006 (3 days), this female, juvenile coast garter
snake (THEL 165b) was documented to have moved a linear distance of 550 meters with and
elevation gain of approximately 30 meters, assuming it traveled over the “saddle”, to the trapline
on the Mori Point site.
The most commonly captured mammal species was the California meadow vole (Microtus
californicus), followed by the western harvest Mouse (Reithrodontomys megalotis) , shrew
(Sorex sp.), Botta pocket gopher (Thomomys bottae), Deer Mouse (Peromyscus sp) broad-handed
mole (Scapanus latimanus), dusky-footed wood rat (Neotoma fuscipes), and black rat (Rattus
rattus).
Table 1. California Red-legged Frog captures per trap, the percentage of total captures at
each trap, and the associated habitat type.
Trap Number Total # of Captures % of Total Captures Habitat Type

1 9 15.52 Willow Riparian
40 1 1.72 Pampas Grass
16
Table 2. Total Captures from Calera Creek trap lines.
Calera Creek Trap Lines (lines 1-12)
Trap Line
Species 1 2 3 4 5 6 7 8 9 10 11 12 Total captures
ANLU 0
BAAT 2 1 2 1 6
ENES 0
PSRE 1 1 3 1 6 12
RAAU 9 2 1 2 1 4 29 17 1 66
COCO 2 14 4 12 32
PICA 1 1 2
THEL 7 15 23 14 93 31 64 31 58 17 43 21 417
ELCO 0
ELMU 1 1 2
SCOC 1 1
MICA 2 5 9 5 1 9 9 8 21 6 3 3 81
NEFU 0
PERS 1 1 1 1 1 5
RARA 0
REME 1 1 2 3 4 3 1 2 1 18
SCLA 1 1 2 4
SORE 1 3 4 4 4 10 6 9 9 1 4 55
THBO 1 1
ANLU - Arboreal Salamander (Aneides lugubris)

BAAT - California Slender Salamander (Batrachoseps attenuatus)
ENES - Yellow-eyed Salamander (Ensatina eschscholtzii)
PSRE - Pacific Chorus Frog (Pseudacris regilla)
RAAU - California Red-legged Frog (Rana aurora draytonii)
COCO - Western Yellow-bellied Racer (Coluber constrictor mormon)
PICA - Pacific Gopher Snake (Pituophis catenifer catenifer)
THEL - Coast Garter Snake (Thamnophis elegans terrestris)
ELCO - San Francisco Alligator Lizard (Elgaria coerulea coerulea)
ELMU - California Alligator Lizard (Elgaria multicarinata)
MICA - California Meadow Vole (Microtus californicus)
NEFU - Dusky-footed Wood Rat (Neotoma fuscipes)
PERS - Deer Mouse (Peromyscus sp.)
RARA - Black Rat (Rattus rattus)
REME - Western Harvest Mouse (Reithrodontomys megalotis)
SCLA - Broad-handed Mole (Scapanus latimanus)
SCOC - Western Fence Lizard (Sceloporus occidentalis)
SORE - Shrew (Sorex sp.)
THBO - Botta Pocket Gopher (Thomomys bottae)
San Francisco Garter Snake Prey Species
17
Table 3. Total captures from upland trap lines west of Calera Creek.
Upland Trap Lines (lines 13-25)

(Trap lines west of Calera Creek)*
Trap Line
Species 13 14 15 16 17 18 19 20 21 22 23 24 25 Total captures
ANLU 2 2 4 4 1 5 1 2 5 26
BAAT 3 25 52 17 37 24 33 46 4 3 17 26 22 309
ENES 2 1 1 4
PSRE 1 6 1 1 6 2 5 22
RAAU 0
COCO 13 16 14 10 24 14 1 11 8 3 5 2 4 125
PICA 1 4 1 1 1 8
THEL 41 26 12 23 48 14 8 23 26 18 18 19 13 289
ELCO 1 1 3 1 2 3 2 13
ELMU 5 2 2 3 8 3 2 25
SCOC 1 1 3 3 14 2 1 1 26
MICA 3 11 28 7 18 8 7 20 10 1 1 4 3 121
NEFU 0
PERS 1 1 2 1 1 6
RARA 0
REME 10 14 9 4 3 2 4 5 7 3 3 1 3 68
SCLA 0
SORE 1 2 2 6 1 1 1 1 15
THBO 1 3 3 7
* lines 21-25, lines near the quarry pond, were removed in
June due to safety concerns
San Francisco Garter Snake Prey Species
18
Table 4. Total captures from trap lines east of Calera Creek in the “flats”.
Trap Lines East of Calera Creek (lines 26-40)
Trap Line
Species 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Total captures
ANLU 1 1
BAAT 76 40 51 44 20 12 27 24 17 23 1 1 2 338
ENES 0
PSRE 1 1 11 4 1 2 3 2 25
RAAU 1 1
COCO 1 1 1 6 1 1 1 2 1 2 17
PICA 0
THEL 13 19 33 26 7 23 29 40 34 43 26 9 16 47 29 394
ELCO 1 1 1 3
ELMU 0
SCOC 1 1 2
MICA 3 15 9 17 15 7 15 10 11 14 12 4 31 21 28 212
NEFU 1 1
PERS 1 2 1 1 1 6
RARA 1 1
REME 2 5 9 2 5 6 1 1 6 3 3 5 5 53
SCLA 0
SORE 2 4 1 3 1 1 2 2 4 4 24
THBO 2 1 1 1 5

San Francisco Garter Snake Prey Items
19
3.2 Regional Distribution and Habitat Analysis
3.2.1 Mori Point/Sharp Park
A breeding population of SFGS is currently present at Mori Point and Sharp Park (City and
County of San Francisco). SFGS and CRF population sizes are increasing and expanding their
use of the site due to recovery actions being implemented by the GGNRA (Swaim Biological
2004, 2006). The recovery actions completed so far include enhancement of one pond and
creation of a second pond in fall of 2004. CRF bred in both ponds in the first winter after
creation and SFGS abundance increased accordingly.
Sixty-one days of trapping with 15 traplines in 2005 resulted in a total of 9 captures of 6

individual SFGS. In 2006, a 67 day trapping effort with the same 15 traplines, resulted in 30
captures of 13 individual SFGS. None of the SFGS captured in 2004 were recaptured in 2006.
The closest recent observations of SFGS to the project site, were a foraging individual in
February 2006 at a newly created pond approximately 1,250 feet (<1/4 mile) to the north of the
boundary of the Pacifica Quarry site and an individual SFGS observed in April on the dirt road
adjacent to the created pond (Personal Communication, Susie Bennet, the Parks Conservancy).
However, it should be noted that the focus of the Mori Point surveys was to detect the level of
use in newly created wetland habitats, not to determine the full distribution on the site. No
effort was made either by trapping or visual surveys, to detect SFGS in upland habitats. Due to
the sensitive nature of the species, specific locations on Mori Point are not included here. Point
data will be included in reports to the USFWS and CDFG and will be available during any
project planning exercises with the agencies.
Historically, SFGS have been observed in relatively large numbers at Sharp Park. Hundreds were
collected in the 1950s-1960s, and Barry (1978) made over 40 captures of SFGS from just north
of the site boundary down the face of the ridge at the saddle, and into the “bowl” of the Mori
Point property (Figure 9). The condition of that upland SFGS habitat is the same now and equal
in quality as it was in 1978 when the observations were made. Upland habitat is crucial for
SFGS populations as it provides winter retreats. The clusters of upland observations by Barry
(1978) were as far as 1800 feet from the nearest wetland habitat. Barry found SFGS near the
saddle as late as 1990 (Barry in USFWS 2006). The 1990 observation is not mapped, as the
specific site was not determined. Many other researchers have documented SFGS making use of
habitat a great distance from the wetlands (McGinnis et al 1991, Larsen 1994, Swaim Biological
2004, California Academy of Sciences, 2006). All known SFGS and CRF point observations in
the habitat analysis area are shown below (Figure 8).
3.2.2 Calera Creek Corridor and City of Pacifica Uplands
A breeding population of CRF is present on the site. Breeding habitat for CRF includes the
mitigation ponds just north of Calera Creek (City of Pacifica Property). These ponds were
specifically created for SFGS and CRF as a condition of that project. CRF occupy the entire
Calera Creek Corridor, including both mitigation ponds. The CRF population which breeds at
20
the two mitigation ponds north of the creek and the CRF that breed in the marsh portions of the
creek rely on foraging in the habitat on the Pacifica Quarry site. Individuals from the Calera
Creek Corridor also move into the Quarry Pond (see below).
The Biological Opinion for the Calera Creek Restoration and Wastewater Treatment plant states
the intention to reintroduce SFGS and CRF to the mitigation ponds and Calera Creek Riparian
areas. As indicated, CRF have already colonized and do not need reintroduction
3.2.3 Pacifica Quarry Property
Prior to August of 1989, at least two ponds occupied by SFGS existed on the Quarry property
(Figure 9). These ponds were filled and much of the uplands bulldozed in 1989 (McGinnis,
1990). Since then there have been no confirmed observations on the site.
It is doubtful that the large number of coast garter snakes present at the site contributed to the
decline of SFGS. Although these two species do sometimes prey on the same food, coast garter
snakes show a preference for slugs and SFGS prey on small frogs (both CRF and treefrog) and
other amphibians. One coast garter snake captured in this study, regurgitated approximately
fifteen slugs and a caterpillar, but both coast garter snake and SFGS have regurgitated slender
salamanders in prior studies. One THEL was also observed foraging on a meadow vole during a
site visit.
No real limiting factors for SFGS were found during the survey. Prey is not a limiting factor,
cover is not a limiting factor, suitable retreat sites (mammal burrows, rocks, vole runways etc.),
are not limiting factors. Human disturbance and dog activity at Mori, where SFGS have a
population, is nearly as high as at the quarry. The only difference is bicycle use. Mori Point has
less use by bicycles, but it is not likely a significant factor. Each area of the quarry property is
discussed below.
The Quarry Pond
The Quarry pond (Figure 8) is used by CRF and they may be breeding there nearly every winter
(i.e. deposit egg masses). A total of three CRF were observed at the pond on January 20, 2006
and at least 8 adult CRF were observed on a single site visit and inspection of the perimeter of
the pond by Karen Swaim in mid spring. However, it is unlikely to support significant
successful metamorphosis of CRF tadpoles. The hydro-period is probably not sufficient to allow
tadpoles to develop to the stage where metamorphose into juveniles would occur. The quarry
pond was dry by early June of 2006, a wet year. Thorough and complete seining of the pond on
May 24 revealed only treefrog tadpoles. The water depth was less than one foot. No CRF
tadpoles were detected.
CRF tadpoles may be present in late winter and early spring (February, March, April) and
treefrog are present. Garter snakes are active and foraging during this period and could take
advantage of the source of food. Pacific treefrog are able to breed successfully and the shallow
21
C urrcn! projc~ ! bounda'!' (a ppro.~imal c)
Figure 9. 1989 air photo of site showing location of filled ponds and SFGS captures.
22
water combined with tadpoles is suitable foraging habitat for SFGS. Disturbance factors may
limit the potential for successful reproduction of CRF at the Quarry pond. The pond is
frequented by swimming dogs, even during the winter months. The combination of the small
size and depth of the pond may lead to dislodging of egg masses and poor water quality for eggs
and/or tadpoles. The only potential situation in which CRF could have successful breeding
would be in years where there were significant early rains filling the pond in November
combined with rains that kept the pond retaining water for at least six months.
Other Wetlands
Other wetlands on the site include the areas of inundation along San Marlo Drive and Highway
1. Based on the observations of 30 + juvenile CRF at the pooled areas adjacent to Highway 1
(Personal Communication Jeff Wilkinson, November 15, 2006), the presence of suitable
vegetative cover, and adequate hydro-period of the pool, CRF are very likely to breed there. The
wetlands along Highway 1 are currently the highest quality and most valuable foraging habitat
on the Pacifica Quarry site. This pool receives runoff from the uplands southeast of Highway 1
through a culvert under Highway 1. Water was present and at least 6-8 inches deep in early
October. The wetlands along Highway 1 have been confirmed to be aquatic habitat for CRF
(H.T. Harvey 2002 and Personal Communication, Jeff Wilkonson, November 15, 2006) and
PTF, both critical components of SFGS prey base. Although this wetland is close to Highway 1
and it is not the ideal placement, CRF are known to survive in such situations. These wetlands
also have direct hydrological connection to Calera Creek via the wetlands along San Marlo. The
wetland along San Marlo are connected to Calera Creek via a culvert that extends under the
bike/pedestrian pathway just east of the Rockaway Beach parking lot (Figure 8).
CRF would be expected to take cover in these wetlands anytime standing water is present or the
soil remains moist. Two CRF (small adults) were found under two different pampas grass
clumps, in a narrow drainage on the Mori Point site on January 17, 2007 by John Kunna, a
Swaim Biological Herpetologist. These observations were made during efforts underway at
Mori Point to remove invasive non-native plants.
Upland Habitat
The upland of the Pacifica Quarry site still retains significant structural diversity and dense cover
in all areas except the bare areas of the quarry. Rodent burrows are also abundant and small
mammal populations thriving in the uplands (Tables 2-4). The upland habitat on the site
(including the flats) provides foraging habitat for the local CRF population. We had a trap
capture of an adult CRF in the center of the flats (Figure 8) and the H.T Harvey observations
made in February of juvenile and adult CRLF under many cover items such as rocks (Personal
communication, Jeff Wilkonson, November 15, 2006) and H.T Harvey (2002). CRF would be
expected to make use of the uplands primarily during the rainy season, November- March.
During the remainder of the year, April – October, CRF use primarily the riparian corridor, but
are still present in lower numbers in uplands greater than 300 feet from wetlands. Our trapping
period in the flats did not overlap with the time when high numbers of CRF would be expected to
23
use the area. In contrast, we did capture many CRF in the traps in the riparian corridor during
the survey period.
SFGS forage in the upland habitats in the vicinity of wetlands because of the adequate fog and
moisture that allows the SFGS prey species to be present in the uplands. The climate allows
dispersion of the CRF and pacific treefrog throughout the upland habitat and residency of the
slender salamander (Tables 1-4). Trapping indicated the slender salamander is abundant on the
site, especially in the upland habitats. Treefrogs and juvenile CRF are especially important prey
items of SFGS, as adult CRF can only be eaten by the largest of SFGS (Larsen 1994).
Although there are several disturbance factors and areas of ruderal vegetation on the site, these
factors do not preclude use of the uplands by SFGS or their prey. There is still very adequate
contiguous cover throughout the site in the form of non-native grassland, brush, willow riparian
woodland, and even the areas dominated by pampas grass. The only area SFGS would possibly
avoid, once they are reintroduced into the Calera Creek Mitigation Ponds and creek corridor, is
the barest areas of the quarry that lack any vegetation.
In addition, the lack of SFGS captures on the immediate project site is not due to lack of suitable
habitat or absence of the species. Factors influencing the lack of SFGS detection include the
unlawful filling of ponds where SFGS were documented to be present in 1989 (McGinnis 1990)
and bulldozing of the uplands surrounding the ponds (McGinnis 1990a and b). Once these
ponds were filled and much of the uplands disked, SFGS likely discontinued detectable use of
the area or limited use to seasonal foraging at the creek. The timing of the filling of the ponds, in
later summer, was extremely detrimental because it occurred at a time when the SFGS would
have been concentrating activity in the immediate vicinity of the ponds (McGinnis 1990). Other
wildlife species would have been able to survive this action because they are widely distributed
in the habitat and other vegetation cover.
The habitat disturbance associated with the construction and realignment of Calera Creek in
1999, 2000 have also contributed to keeping the SFGS population numbers at undetectable
numbers on the site. It has been less than six years since the creation of the Ponds on the city of
Pacifica property were completed. They are suitable for CRF, but need some management to
make them more suitable for SFGS. The mitigation ponds need to have more open sunny habitat
at least on the upland side. Currently, tall weedy species have overtaken the edge leaving no
good basking habitat adjacent to the pond.
Another factor that has reduced the likelihood of a breeding population becoming reestablished
in the Calera Creek Corridor is that the population of SFGS is only slowly and very recently
recovering at the adjacent Mori Point. Documented presence of the SFGS in the Mori Point area
(Laguna Salada) dates back to 1946 when Wade Fox, a graduate student at the Museum of
Vertebrate Zoology, University of California, Berkeley, conducted field work in the area (Barry
1978). Fox later published the data (Fox 1951). The area was subject to heavy collecting
pressure in the 1950s, but was recovering well in the late 1970s (Barry 1978) after the scientific
community began to recognize the impacts to the species (McGinnis 1988). Barry (1978)
recorded over 40 hand captures of SFGS at Mori Point (Figure 8). Many of these observations
were of individuals near the ridgeline separating Mori Point from the Calera Creek Corridor,
24
where SFGS were documented in 1989 at two quarry ponds (Figure 8). Barry also observed
SFGS on this ridge in 1990 (Barry 2006 in USFWS 2006). These observations combined with
the known highly mobile nature of SFGS imply movement of the species between the two
watersheds (Calera Creek watershed and Sanchez Creek watershed).
Between 1980 and the late 1990’s, salt water intrusion from the sea wall west of Laguna Salada
resulted in a severe reduction of the SFGS population due to loss of breeding habitat for
amphibian prey, CRF and Pacific treefrog at Horse Stable Pond and Laguna Salada (McGinnis
1997). Over the next twenty years, trapping and visual surveys of the Mori Point and Sharp Park
area produced no SFGS (McGinnis 1986a, McGinnis 1988) one SFGS capture (McGinnis 1997)
or two SFGS (one capture on observation) during the surveys (McGinnis 1986b).
The Sharp Park and Laguna Salada populations also experienced drastic declines in the 1980’s
over the population levels of the 1950s - 1970s (Barry 1978, McGinnis 1986a, 1986b, 1987,
1997). Barry made over 40 SFGS captures on that site). The Sharp Park Population experienced
a decline, starting around 1980 due to salt water intrusion into all of the previously freshwater
marsh areas of Laguna Salada and the associated wetlands. This occurred due to the breaching
of the seawall. With the Sharp Park population drastically reduced, SFGS were not able to
readily recolonize the Quarry Site. Sea wall breaches and saltwater intrusions continued into the
late 1980s effectively eliminating CRF and treefrog from breeding in Sharp Park, except for the
upper reaches of Sanchez Creek. Salinity measurements taken during the spring of 1986 in
Laguna Salada and Horse Stable Pond ranged between 5 and 9 ppt (McGinnis 1986a). One
hundred percent mortality occurs in eggs exposed to salinity levels greater than 4.5 parts per
thousand (Jennings and Hayes 1990). In coastal lagoons, the most significant mortality factor in
the pre-hatching state is water salinity (Jennings et al. 1992). Larvae die when exposed to
salinities greater than 7.0 parts per thousand (Mark Jennings, National Biological Service, in litt.,
1994 ).
No surveys were conducted between 1997 and 2004. In 2004 a small population of SFGS was
detected (Swaim Biological 2006) was conducted during baseline survey for a recovery project
investigating the effects of wetland enhancement and creation for the CRLF and SFGS. Follow
up surveys in 2006 have shown that the Mori Point population appears to be increasing
dramatically. This is based on comparison of previous McGinnis surveys (McGinnis 1986a,
1986b, 1987, 1997) and the recent Swaim Biological surveys (Swaim Biological 2006b).
Introduction of SFGS into the Mitigation Ponds north of Calera Creek will facilitate recovery of
the SFGS in the region and the site. It is expected to increase the local SFGS population
numbers and reestablish a breeding SFGS population at the ponds, wetlands and surrounding
uplands within the contiguous undeveloped areas. Recovery efforts being implemented by NPS
GGNRA, is also expected to increase the local SFGS populations at Mori Point and increase the
amount of dispersal from the Sanchez Creek watershed into the Calera Creek watershed over
time.
Existing data on SFGS use of uplands indicates that once SFGS are reintroduced they will use
the available wetland and upland habitats. This type of movement was demonstrated by the one
coast garter snake that moved from Pacifica Quarry to Mori Point and shows it is possible for an
25
SFGS at Mori Point to move to Pacifica Quarry. Additional movement data on SFGS gathered
at Mori Point showed multiple SFGS going back and forth between separated seasonal and
permanent aquatic habitats (Swaim Biological 2006b).
4.0 CONCLUSIONS
At this time, a specific development is not proposed. However, based on distribution of suitable
habitat conditions and distribution of the California red-legged frog on the project site,
development of the property is expected to have significant and unavoidable impacts to the CRF
and SFGS dispersal habitat. After analyzing the data on the distribution of special status species
habitat, especially the current distribution of CRF, we are unable to determine a development
footprint that would avoid significant impacts. In addition, we are unable to recommend
mitigation for impacts because of the projects sites location in the Coastal Zone. In the course of
conducting the regional analysis for the project it was found that the Coastal Commission
requires completed avoidance of significant impacts and that mitigation is not an acceptable
planning tool (California Coastal Commission 2002, 2006).
The presence of a breeding population of SFGS in the Calera Creek Corridor is crucial to the
long term survival of the Mori Point SFGS population. A viable population at Calera Creek
watershed will be needed if catastrophic events occur in the Mori Point –Sharp Park area. For
example those that have happened in the past (i.e. breaching of the sea wall resulting in salt
water intrusion), could occur and severely reduce or extirpate the Mori Point- Sharp Park
Population.
26
6.0 LITERATURE CITED
Barry, S. J. (1975). Status of the San Francisco garter snake. Inland fisheries endangered
species program special publication 78-2. 21 pp.
Barry, S. J. (1978). Status of the San Francisco garter snake. California Department of Fish and
Game. IFB Species Publication 78-2. 21 pp.
Barry, S.J. (1979). Investigations on the occurrence of the San Francisco garter snake at Mori
Point, San Mateo County. Unpublished report prepared for Environmental Science
Associates.
Barry, S. J. (1996). The San Francisco garter snake (Thamnophus sirtalis tetrataenia) on the San
Francisco watershed. Unpublished technical report of 5 year study.
California Coastal Commission. May 15, 2004. Letter to Ms. Allison Knapp Wollam, City of
Pacifica Regarding DEIR for Pacifica Village Center, Pacifica Quarry Site. 13 pp.
California Coastal Commision. May 12, 2006. Letter to Daniel Grimm, Peebles Corporation,
Re: Pacifica Quarry Development. 7 pp.
California Natural Diversity Data Base. 2006. Natural Heritage Division. California
Department of Fish and Game, State of California.
H.T. Harvey & Associates (2002). Pacifica Village Center Draft Environmental Impact Report,
Biological Resources Section. Prepared for Patricia Jeffery, Placemakers. Emeryville,
CA.
Keel, P., S. M. McGinnis, and L. Smith. (1991). Habitat Requirements and Population Estimate
for the San Francisco Garter Snake (Thamnophis sirtalis tetrataenia) at Año Nuevo
State Reserve, San Mateo County, California. Conducted for the Department of Parks
and Recreation State of California. 8pp.
Larsen, S. S. (1994). Life history aspect of the San Francisco garter snake at the Millbrae habitat
site. Master’s Thesis. California State University, Hayward, California. 105 pp.
McGinnis, S. M. (1984). The Current distribution and habitat requirements of the San Francisco
garter snake (Thamnophis sirtalis tetrataenia) in coastal San Mateo County.
McGinnis, S. M. (1986). The status of the San Francisco garter snake (Thamnophis sirtalis
tetrataenia) at the Sharp Park Golf Course, Pacifica California. Prepared for
Geomatrix Consultants, Inc.
McGinnis, S. M. (1987). The distribution and feeding habitat requirements of the San Francisco
garter snake (Thamnophis sirtalis tetrataenia). Final report for California Department
of Fish and Game Interagency Agreements C-673 and C-1376.
27
McGinnis, S., P. Keel, and E. Burko. (1987). The Use of Upland Habitats by Snake Species at
Año Nuevo State Reserve. Prepared for the Department of Parks and Recreation State
of California. 14 pp.
McGinnis, S.M. 1988. A review of the status of the (Thamnophis sirtalis tetrataenia) in the
Mori Point- Laguna Salada Area, with emphasis on potential upland retreat habitat.
Prepared for The Mori Point Development Company. Unpublished report. 11 pages.
tetrataenia) on the California Department of Transportation property west side of Hwy
1 at the Calara Creek/Reina Del Mar intersection, Pacifica, California. Unpublished
report, submitted to: Environmental Analysis Branch, California Department of
Transportation. San Francisco, California.
McGinnis, S. M. (1991). Habitat requirements and population estimate for the San Francisco
garter snake (Thamnophis sirtalis tetrataenia) at Año Nuevo State Reserve, San Mateo,
California. Unpublished report, submitted to: The Department of Parks and Recreation.
Sacramento, California.
tetrataenia) and the California red-legged frog (Rana aurora draytonii) at Mori Point,
Pacifica, California, with an emphasis on the areas proposed for a conference center
and road. Prepared for National Investors Financial, Inc. Unpublished report. 15 pages.
Stebbins, R. C. (1985). A Field Guide to Western Reptiles and Amphibians. Houghton Mifflin
Book Co., Boston, Massachusetts and New Youk, New York. 335 pp.
Swaim Biological (2006a). Proposal to conduct surveys for the Alameda whipsnake, San
Francisco Garter Snake, and California Red-legged Frog under Permit 815537. March
13, 2006. 17 pp.
Swaim Biological (2006b). San Francisco Garter Snake Foraging Habitat Improvement Project,
at Mori Point Pacifica, CA 2004-2006.
Swaim Biological. (2006c). Results of 2005 surveys for the San Francisco garter snake
(Thamnophis sirtalis tetrataenia) at Año Nuevo State Reserve, San Mateo County,
California, draft. 16 pp.
Swaim Biological. (2006d). Survey Results for the Alameda Whipsnake (Masticophis lateralis
euryxanthus) at the Former Naval Medical Center in Oakland. Prepared for WRA. 30
pp.
USFWS. 1985. Recovery Plan for the San Francisco Garter Snake (Thamnophis sirtalis
tetrataenia). U.S. Fish and Wildlife Service, Portland, OR. 77 pp.
28
USFWS. 1996. Section 7 Formal Consultation on the Calera Creek Water Recycling Plant and
Wetland Resotration on the Lower Calaera Creek, San Mateo County, CA. 18 pages +
figures and appendices.
USFWS. 2004. Section 7 Formal Consultation on the Proposed Enhancement of San Francisco
Garter Snake Foraging Habitat at Mori Point in Pacifica, San Mateo County, California.
U.S. Fish and Wildlife Service, Sacramento, CA. 34 pp. + figures.
USFWS. 2006. San Francisco Garter Snake (Thamnophis sirtalis tetrataenia) 5-Year Review:
Summary and Evaluation. Sacramento Field Office. September 2006. 44 pp.
7.0 PERSONAL COMMUNICATIONS
Bennet, Susie, Biology Intern. Parks Conservancy, GGNRA. December 19, 2006.
Wilkonson, Jeff, PhD Herpetologist, H.T. Harvey and Associates. November 15, 2006.
29
Page 1 of 1
Re: Big Wave
From: <mandjwallace@comcast.net>
Date: 10/27/2010 7:14 AM
Subject: Re: Big Wave
CC: <cgroom@co.sanmateo.ca.us>, "Richard Gordon" <rgorden@co.sanmateo.ca.us>...
Dear Ms Leung,
We are writing to support the Big Wave project. We have lived in the area since 1967 and
1976, and have no doubt that this project will benefit the community. We hope that the County
will complete the permit process and allow this project to go forward. It represents untold
hours of volunteer effort. We are heartened that in addition to being a resource for the
developmentally disabled community, an outlet for local employment, it has changed it's focus
to be a green showcase.
We trust that the Planning Commission will make decisions carefully, support this process,
vote now for the project, and not let the opportunity pass by.
Sincerely,
Jack and MaryEm Wallace

522 Sonora Avenue
El Granada, CA
94018
(650)726-5427

San Mateo Co. Planning Dept.
Attn: Camille Leung, Planner
cleung@co.sanmateo.ca.us
fax 650-363-4849
RE: Final Big Wave EIR
My name is Jack Sutton and J'm a resident of Pillar Ridge Mobile Home Park The
following are some comments and observations about the EIR and the Big Wave Project.
A public review time of 12 days on a project of this magnitude is grossly inadequate. The
final EIR had 295 days of preparation time and the public review time amounts to 4% of
that time.
The story poles are a shoddy piece of work that in no way give a true representation of
the magnitude and visual impact of this project. Most story poles have orange netting to
help visualize the magnitude of the physical structures. Why was this not required of the
Big Wave Projecf7 It appears to me to be another underhanded way to distOli the true
impact of this project, just as the half size artists renditions in the original EIR were
Granada Sanitary District Conce .... s:

According to the recent comments letter sent to you by the Granada Sanitary District
most of their concerns have not been met. Considering this utility is key to the successful
management of water and waste water from the big wave project, they should have the
highest priority in final approval. They have unanswered concerns, no approval should be
considered until they are satisfied they can handle the requirements of the big wave
project and all their concerns are addressed
Local Area Concerns:

As a resident of this community, a main concern has been the direct impact of this project
on the quality of my life as well as my neighbors residing in Princeton, Pillar Ridge, and
Moss Beach Looking at the size and scope as well as the time duration of this project one
can only conclude that the quality of life for the people of this area will be adversely
atTected in the following ways
A ten fold increase in traffic and carbon emissions.
Years of construction noise and the dirt and the air pmiiculates associated with that
construction
Traffic congestion and delays due to ingress and egress of construction equipment.
A negative visual impact on the entire area as well blocked views from existing homes in
the area.
The above concerns and related concerns are not addressed by the EIR and are basically
swept under the carpet. The following paragraph appearing in the FEIR notice sent by the
Planning Office demonstrates this
"Signiticant environmental effects in the following areas are anticipated as a result of the
project Aesthetics, Air Quality, Biological Resources, Cultural Resources, Geology and
Soils, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, Public
Services, Transportation and Traffic, and Utilities and Service Systems. With the
implementation of proposed mitigation measures, all project-related environmental
impacts would be mitigated to a level that is less than signiticant"
Less than signiticant is very insulting to me as well as my neighbors. This statement

shows the total lack of concern of the Big Wave Project for the residents of this area.
The proposed mitigation measures insure that nothing will be addressed until the project
is complete and the damage is done. This is not acceptable and all these issues should be
addressed before this project gets any green lights.
Finally I would like to say I fully support and agree with the comments submitted by the
Pillar Ridge Homeowners association and the Granada Sanitary District.
Jack Sutton
150 Barranca Lane
Moss Beach, C A
o COUNTY
P 0 R T s
SAN MAT E 0 CO U N T Y, DE PAR T MEN T 0 F PUB L I CWO R K S, A I R P 0 R T S D I V I S ION
620 Airport Drive, San Carlos, CA 94070 (650) 573-3700, FAX (650) 593-3762
," ")
-. .. )
Memo ( \ \ i
....
<" ':'
"
~\
Ld . I
To: Camille Leung, Planning and Building Department
From: James C. Porter, Director of Public works&~ '.~

Subject: Final Environmental Impact Report for the Big Wave Wellness Center
Date: November 2,2010
Thank you for the opportunity to comment on the Final Environmental Impact Report (FEIR) for
the Big Wave Wellness Center. We are concerned that the FEIR does not adequately address the
land-use compatibility concerns described in the Federal Aviation Administration's (FAA) letters
to the County dated July 8,2010 and October 26,2010, and the California Department of
Transportation letter dated October 25,2010, all of which are attached.
Specifically, we are concerned that approval of this project could jeopardize past, present, and
future FAA Airport Improvement Program (AlP) grant funding for San Mateo County-operated
airports. If the FAA withholds AlP grants, the County could no longer finance vital safety,
infrastructure and maintenance projects at the HalfMoon Bay Airport absent an equal
appropriation of County funds to offset the loss of FAA funds. There are no other funding
sources available from the Department of Public Works for airport safety and maintenance
project purposes. The most likely source to make up the loss in grant funding is the County's
General Fund.
In the FAA's July 8,2010 letter regarding the Big Wave Wellness Center, Tony Garcia, the
FAA's Airport Compliance Program Manager, states his view that "a clinical residential center
serving disabled patients would not be considered a compatible use so close to the airport and its
runway." Mr. Garcia also cites the County's contractual undertaking to comply with FAA Grant
Assurance No. 21, which is set forth in the various agreements between the County and the FAA,
pursuant to which the County has received FAA airport grant funds.
The FAA's Airport Compliance Manual- Order 5190.6B states that "the federal obligations a
sponsor assumes in accepting FAA administered development assistance are mandated by federal
statute" and that "upon acceptance of an AlP grant, the assurances become a binding contractual
obligation between the airport sponsor and the federal government".
Camille Leung, Planning and Building Department
Subject: Final Environmental Impact Report for the Big Wave Wellness Center
Date: November 2,2010
Page 2
Grant Assurance No. 21 requires that the County ensure compatible land use in the vicinity of the
Airport and "take appropriate action, to the extent reasonable, including the adoption of zoning
laws, to restrict the use ofland adjacent to or in the immediate vicinity of the airport to activities
and purposes compatible with normal airport operations including landing and takeoff of
aircraft. "
I am concerned that neither the FEIR nor other information of which I am aware suggests that the
FAA's concerns have been adequately addressed, notwithstanding the additional proposed
mitigation measures in the FEIR. Likewise, I am concerned that there is nothing to indicate any
change in the position of the FAA, as stated by Mr. Garcia, that the residential component of the
Big Wave project located "so close to the runway represents a use that is not compatible with
normal airport operations."
As part of the National Plan of Integrated Airports, the HalfMoon Bay Airport provides a vital
transportation link for business and personal travel. The County has been awarded just under
$9 Million in federal AIP grant funding since 2007. Failure to comply with the FAA's grant
assurances could jeopardize millions of dollars in federal grant funding for future safety and
infrastructure improvements at the HalfMoon Bay Airport, along with the associated economic
benefit those projects would bring to the community.
JCP:MCL:sdd
F:lusersladminlAIRPORTSIHMBl201OlMemo to Planning - Big Wave FEIR 10-26-10 JCP.doc
Attachments: Federal Aviation Administration letter dated July 8, 2010

Federal Aviation Administration letter dated October 26,2010
California Department of Transportation letter dated October 25,2010
Page 1 of 1
- Fwd: Big Wave Project Approval
From: Camille Leung

To: Bryan ALBINI
Date: 11/15/2010 12:41 PM
Subject: Fwd: Big Wave Project Approval
Attachments: Big Wave Project Approval; Big Wave Development; Big Wave Project Review; Big
Wave; HMB resident input on Big Wave proposal; Big Wave project; Big Wave
Project; Big Wave Project; Big Wave Project; comments FEIR big wave jack sutton;
Comments on Big Wave; Big Wave Project; Support for the Big Wave Projecct; RE:
Big Wave; 1991.05.14 CCC SMC LCP Major 2-90 Staff Report.pdf, 1993.12.02 CCC
A-3-SMC-86-155 and 155A Condition Compliance.pdf + 2 more items
Please do what you can to get a quick turnaround on the review…..the Coast has a big heart and needs Big
Wave…

___________________________________________________________________
Barbara LaVey & Jan Gray
Coldwell Banker │ 1415 Main Street │ Montara, CA 94037

Barbara 650-728-4503 direct/cell │ DRE #01361161
Jan 650-728-4506 direct/cell │ DRE #00478786

11/16/2010
From: "Jennifer Castner" <pennifer@gmail.com>
To: <Planning-Commission@co.sanmateo.ca.us>, <cleung@co.sanmateo.ca.us>
Date: 10/24/2010 9:30 PM
Subject: Comments on Big Wave
I'm sure others will have more comprehensive and educated

commentaries, but here are mine, as a concerned resident of Moss Beach.
1. Calling the housing a "sanatarium" is misleading and clearly an

attempt to avoid local regulations and building and safety coded -
this is indisputably long-term housing for the developmentally disabled.
2. Allowing a 20-yr construction period creates all sorts of problems,

including long-term traffic impacts that cannot be resolved until the
project is complete. Not to mention a 20 year eyesore of ongoing
construction and construction traffic.
3. We already have a lot of commercial and light industrial space that

is under-utilized. Adding to 100s of thousands of square feet to the
Coastside in such an inappropriate location is economically ill-
advised. Additionally such relatively HUGE buildings in a large
complex are extremely out of place in such a minimally developed area.
4. Section 6326.2 of the San Mateo County code specifically prohibits

“buildings or development used primarily by children or physically or
mentally infirm persons in a tsunami inundation hazard area.” That
seems a pretty clear reason that there should NOT BE any housing here
for the developmentally disabled. This is, after all, designated as a
tsunami flood zone.
5. This site is mostly a wetlands. We should not be converting it to

250K+ sq ft of parking and buildings. There would be a tremendous
impact to local visual aesthetics.
6. Putting housing for the developmentally disabled and other business

purposes this close to a small airport is a bad idea. I'm sure there
are laws and regulations that make that clear. That and residents of
the Wellness Center will likely not be pleased by all the airport noise.
7. Permitting subdivision of the property allows the developer an easy

out rather than taking responsibility for developing the property as
promised and possibly risking an EVEN MORE inappropriate use of the
land. How will that subdivision process be managed? Will the
subdivisions be able to evade this rigorous assessment process as a
result?
8. Housing the developmentally disabled in such an isolated location

makes little sense, when a more urban area with access to local
services and shopping would be much more appropriate. Public transit
along Airport Road is already quite limited, particularly on weekends.
9. I am concerned about the ethics of how the final EIR was completed
and even more concerned that the final review period was only 2 weeks
long. How can ANYONE possible effectively conduct a complete
evaluation of the document
10. It is my understanding that this project lacks water or sewage

permits. The absence of such permits should be a significant stumbling
block for the project's inception. The county has no business
approving a project of this size in an area with such limited water
and sewage resources as the Coastside, where even residential
developers have difficulties getting hookups approved.
Unfortunately, I cannot attend the public hearing on Wednesday,

October 27.
I STRONGLY and respectfully encourage the Planning Commission to put a

stop to this project now.
Jennifer Castner
882 Etheldore Street
PO Box 824
Moss Beach, CA 94038
Jennifer Castner
pennifer@gmail.com
650-563-9098
Page 1 of 1
- Big Wave Project
From: "Jerry West" <jerwest@pacbell.net>

To: <Planning-Commission@co.sanmateo.ca.us>, <CLeung@co.sanmateo.ca.us>
Date: 10/25/2010 1:31 PM
Subject: Big Wave Project
To members of the San Mateo County Planning Commission and County Planner:
We are writing in support of the coastal project known as "The Big Wave". As residents of Half Moon Bay since
early 1988, we are aware of all the dynamics and politics associated with any development on the coast. We
believe this project will be a benefit to the coast side by serving those who's lives are affected by developmental
disabilities, providing them well-being and self-determination, while also providing much needed office space on
the coast, and consequently easing the commute traffic on Highway 92.
We understand that with the current configuration of roads in the area near Airport Street, this project could
impact the traffic. It seems to us that this is not a deal-breaking problem since a simple road modification could
be made to alleviate this issue. For instance, it would be physically very easy to add a shunt road from
Capistrano Rd. to California Ave which would allow for bypassing the main congestion in that area.
We strongly urge a quick approval of this project, which has been constantly blocked and delayed by a vocal
activist minority.
Sincerely,
Jerrold P. West and Susan C. West

10 Seascape Dr.
jerwest@pacbell.net
scwest@pacbell.net
11/16/2010..
Page 1 of 1
- Support for the Big Wave Projecct
From: "Jim Larimer" <jim@imagemetrics.com>

Date: 10/13/2010 5:46 PM
Subject: Support for the Big Wave Projecct
Dear Ms Leung-
I am a resident of the Coastside and an elected member of my community. I serve on the Board of
CCWD. My family and I support the Big Wave Project.
Big Wave uses private funds on private property to satisfy a public purpose in serving the
developmentally disabled community. It also provides needed infrastructure, commercial business
space, that is sadly lacking today. The coastside is currently a bedroom community with highways
clogged with commuters during rush hours every day. This situation will only worsen if suitable
commercial space is not allowed to develop on the coastside.
The location on which the Big Wave project will be built is zoned for this kind of development, so one
project serves two very important and needed functions in our coastal community. Big Wave is a very
important project that I hope will move swiftly through the permitting process.
Thank you,
James Larimer, Ph.D.

ImageMetrics, LLC
569 Alto Avenue
650-678-0658 direct
650-560-0153 fax
jim@imagemetrics.com
www.imagemetrics.com
11/16/2010
421 Aviation Way
Frederick, Maryland 21701
T. 301·695-2000
F. 301--695-2375
www.aopa.org
October 26, 2010
County of San Mateo Planning and Building Department

Attention: Camille Leung, Project Planner
nd
Re: Big Wave Wellness Center and Office Park Project Final Environmental Impact Report
Dear Ms. Leung:
The Aircraft Owners and Pilots Association (AOPA) respectfully continues to maintain our
opposition to the above referenced project adjacent to the HalfMoon Bay Airport as a prime
example of non-compatible land use adjacent to an airport. In the Federal Aviation
Administration's (FAA) letter of July 8, 2010 they point out the potential issues with locating the
project so close to the airport. We concur with that assessment.
While we applaud the wording of the avigation easement outlined in Mitigation Measure HAZ-3
and the applicant's proposed modifications to the Wellness Center (building the residential units
as far away from the airport as possib ) e ~ facing them west and away from the airport with no
windows that open towards the airport; and constructing a buffer of storage units and athletic
facilities between the residential spaces and the airport), you are still mitigating something that
shouldn't be there in the first place. From our perspective it is a far better application of public
policy to not allow a bad use than to have to mitigate it. It is a disservice to the developmentally
disabled adults and caretaker staff to locate them so close to the airport. Only time will tell if the
FAA's predictions come about.
Thank you again for your consideration of our views on this issue.
Sincerely,
John L. Collins
Manager
Airport Policy
AIRCRAFT OWNERS AND PILOTS ASSOCIATION

Kathr~n 6507281451 p.4
il.ttachment 1
United States Department of the Interior

r----
FISH AND '.vILDLlFE SERVICE
Sacramento Fi$h and \ViidHfe Office
28CO Cotus~ Way, Room W-260S
Sacnmcn<o, California 95825-1&46
Ie Reply Reft'r To: FEB 21 ZOOS

8i420-1009-TA·0452
Ms. Carnu!e Leung

San Mateo COtHlt"j Planning anc Buiiding Dcpartm~nt
455 County Center, 2nd floor
ReawOCld City, California 94063
Subject: Corr.mcnts on the Big "Vave Project near the City of Half lvfoon Bay. in
San Mateo County, California
D~a;' Ms. Leung:
This letter contains the U.S. fish and Wildlife Service's (Service) comments on the Big Wave
Project near t.l,c City ofHalrMoon Bay, San Nfateo County, California. The Service receive:d
the proj~ct infomlation and Facilities Plan: Draji 2, Big Wave Property on January 21, 2009,
Our C0IT117lCnts are provided under the authority of the Endangered Speeics Act of 1973, as
amended (16 U.S.C, 1531 et seq.) (Act).
it is our understanding the proposed project consists of the construction of fom' three-story
blJildiI,gs and associated pa..---king lots, 70 re:::idential U.!llts, ~ storage building, a s<;ruIl.rning 1'001,
and associated illfi:'astrudure which includes parking lOiS, ,)n-site trails and v..ra1kways, a water
treatment facility, and seawater desaliniz.ation fucillt';. The proposed project also includes 75
acres cf row-crop agriculturcl areas, a Dative plant nur5cry, and livestock farrr.ing and dairy
operation. The proposed Pl'Oject incllldes wetlands restoration, a ground\VZter infiltration
system, and the cX'!en5ion of the coastal trail to the Pillar Point Biuffs. Dle proposed proje,ct is
lo-cated adjacent to and v,-ithin the Half Moon Bay Airport property on Airport Street.
The Senke is concerned abOl.t the po1ential adver.>c effects ur the project on the threatent:d
California red-legged frog (RaYJtl aumr-u draYlOnii) (red-kg,g~ frog) and the endangered San
Francisco garter snake (Thamnophis sirtalis telralaenia) (garter snake). The Service is also
coacemt.'<f !hal portions of the proposed project may adversely affect the ilircat(;ned marbled
murrelet (Brar.chyramphus marmoratus), thr~tened pacitle Coast l=.-opuJation of the western
Kathr:jn 6507281451 p.5
Ms. Camille Leung 2
SIlO";'Y plover (Charaarius alexandrinus nil'oS'«s), threatened Southern sea otter (EnlTJ'dra IU!ris
(Iercis). aTld possibly the endangered Myrtle's si1verspot /}uti.t;:nly (Speyeria zerene myrtleae;.
Section 9 of the ACI prohibits the take of any looera1ly listed animal specie-s by any person
subject to the jurisdi ction of the Unired States. As defmed in the Act, take is defined as " ...to
hara'{5, harm, pursue, hunt, shoot, wound, kill, trap, capture. or collect, or attt.mpt to engage in
MY such conduct" "'Hrum has been further deflned to inci'Jde habitat d~truetion when it
injures or kills a listed species by interteri;]g with essential behavioral patterns, such as
brc.;:ding, foraging. or resting. Thus, not only arc the red-legged frog. garter snake, mal'bled
ID1.l.r!"cl",i:, and Southern sea oner protected from such aC'j"ities as collecting and hunting, but
also from actions that cause th~ir death or injury thrNlgh damage or destruCtion oftneir habitat,
The tem1 ''person'' is defined as '-... an individual, corporation, partneriliip, rrust, associa.tion, or
a ..,y other private entity; or a.l'Jy officer, employee, agent, departmenl or instrumentality ofthe
Federal govemrnf:ut, of ony State, municipality, or political subdivision of a State, or any other
entity :mhject to the jnrisdiction. oft.'le United States."
Take incidental to an otherwise lawful activity may be authorized by one of two procedures. 1f
a Federal agency is involved 'with the pcrmltting, funding, or carrying out of the project and a
listed species is going to be adve...rsely affected, then ioitialion of fom1l.l1 consultation ~tween
th."lt agency and the Service pursuanr to section 7 of the Act is required. Such CO!1Suiriltinn
would n:;:;ult in a l'iologicai op-inion addressing the anticipatt:u effect", ofth" projtXt to the listed
species and may authorize a iimited level of incidental take. If a federal agency .is nol involved
in the project, a"d federally Ii.ste.a spec.ies may be ral{en as part of the proj~t, then an incidental
take per:m.it pursuant to section 1O(a)(1 )(13) of the Act should be obtained. The Service may
issue such a permit upon completion of a satisfactory conservation pl2Il for the listed spl!cies
thz!t would be taken by' the project.
The propo;;e,d project area is lo~~too adjacent to and 'within suitable habitat for me red-legged
frog and ga.'1er snake, a...d is iocllted adjacent to environmentally sensitive areas, such as the
Pillar Point Marsh and the mO!.fth of Den..'1iston Creek, which provides habitat for the garter
SruLl(C and red-legged frog. Observat.ions of both red-legged frogs and garter snakes have been
made upstrea..."l1 within Denni;;[on Creek (CDFG 2009). This waterway provides dispers.:'li c.no
foraging hahitat. as ",,-ell as possible. br~eding habitat for both of these listed species. jljong
with various i1J1ruUned drainages, Denni5.1on Creek provides oontinuhy for dispersai ofthese
spedes 10 the pmrAlsed projee~ are:!!. Tn i 999, adult and juvenile red-legged frogs were
documented jus. south of the adj-acem We~i't Point Road withi."'l the drainage that flows through
the propvsed project area (CDFG 2009). In C!ddition, red·legged frogs and Pacific tree frogs,
the prey oftne garter snake, Lave 'been observed in the Denniston. Creek watershed, Pillar P01ni
Marsh. a.'1d t;>rithin former stock ponds near the proposed project are,L
Research has shown t..'1ar agriculturally disturbed Ia.'lds do not preclude the presence of red·
legged frogs. Dispersing frogs in northern Santa Cruz County were r-::cord.ed traveling distances
frorn 0.25 miles io more than 2 miles without apparent regard to topogiaphy, vegetrttion type, or
riparian corridors (Bulger et al. 20(3). Fellers and Kleeman (2007) and Bulger et al. (2003)
03J.tiW NtiS .:f0 AlNflOJ

Kathr!;jn 6507281451 F·6
Ms. Camille Leung 3
found that uuifomia red-legged frog mi,brrarion corridors (an be less "'pristint:'" (e.g., closdy
grazed fields, plowed agricul:urallands) than breeding or non-breeding habitats. But~r et al.
(2003) observed that this listed ranid did not avoid or prefer any landscape feature or vegetation
type. TIleY tracked individuals that crossed agnculturalland, including recently tiHed fields and
areas with mature crops. Due to the presenc.e of suitabh: habitat aJld cQ})nedivity between
OOcumeruoo sigbtings, nearby observations oired-Iegged frogs, gart:':r makes,. and its prey. the
Pacific tree frog at or near the site, and the hioiogy a,1d ecology of these two lis led species, the
SeTvice believes ilia! the garter snake and red-legged frog !Lore reasonahly certain to occur at the
proposed project area.
The proposed project includes the exte-asion of the exis!ir.'g coa.~.a1l!ail to the Pl1lar POi11i
BJuih and the addition of desalination and bri..nc return pipcli."1es from the proposed project area
to the ocea"l. The Service believes thai the proposed extension cfthe coastal tr"cil would
increase human presenc-e and recreational activities to the adjacent Pnlar Point Harbor Be2ch,
thereby degrading the quality of a .kno~n roosting and foraging site for v:intering Wes.tern
snowy plovers through increased human presence, unleashed dogs, kites, and other disturbing
activitit::s. Garter sIlakes and red-ieggeu frogs may he hara.';sed, h~llJ:red or killed by pedestrian
and bi.cycle traffic on the trail. Garter sna\es are often attracted to trails for basking a11d are
likely to be crushed or harassed by pedestrian and bicycle traffic on the trail.
The construction and main£en.snce of the desalination im::ikc and brim: return pipelines and
associated infrastmcrure would also !1dv,--rsely affect garter snakes <L.'1d red-legged frog!: through
entrapment in trenches ,md injury or death through crushing by equlpment. The, proposed
desalination ir.take 2nd brine return may also adversely affect marbled murreiets and Southern
sea oners. \1a.'"hled murrelets have been documented utilizing the Pillar Point harbor and
surrounding a.reas for foraging with sightings ranging from 2 birds to 66 (CDFG 2009).
Southem sea otters nmgc from B..alfMoon Bay to Point Conception 0:1 the central a....d southern
Caliiomia coasts, but individuals may wander 8S far Mrth as Marin County and south into
Mexic~.
!\lfyr-Je'5 silverspot butterfly was described from spe\:imt."11s conected in coastal San Ivfateo
County. It has not recently been observed in this area, however,11o surveys have b;::cn
c.onducted for the nnimal. The larvae feed on the blue violet (Viola adunca). I...iyrtk's
silvcrspot butterfly is knO\1,"!l from saad dune and coustal g...'"llSslaod habitats.
We rcc..ommend that adequilte assessments for the six listed species be.{:ompleted and provided
to US and the CaJifomic Depal'lment of~ish and Game for review and comment. If appropriate,
8.umorua(io!l for incidental take via sections 7 or lO(a)(l)(13) oftlw Act should be obtained for
t~ Califomit red-legged frog, San Francisco garter :make, Pacific Qra')( population of the
w:::stem snow), ployer, marbled murrdet., southern sea otter, and Myrtie' s si lverspot butterfly
prior to certifkation of the en,ironmental documents prepared for the Californi.a Environmental
Quality Act. .
Kathr~n 6507281451 p.7
Ms. Carnine Leung 4
Please note that iliis letter does not authori~ take for Ollifornia red-tegged frog, &;n Francisco
garter snake, Western snowy ~lover, marbled murrelet, souh~m sea otter. and/or Myrtle's
sHver;;pot butterfly.
This <-:oncludes our C0l11ments on the Facililies Plan: Draft. 2, Big Wave Property. We are
interested in working "'ith the County of San Mateo <4"1d/or the applicant ill the resolution of
these issues to listed species and wildlife. [{you have any questions regarding our comments,
pie.ase ~')ntact Ryan Olah or me at the letterhead address, teiephone 91614 t4-6625, or via
electronlc mail {Ryan...ol.ah@f.vs.gov; Ch;!$_N~gano(!P/fws.gov).
Sincerely,
~0U;~~~~
ChristopUn. Nagant \
Deputy Assistant Fiel~pel'visor
Endangered Species PrOgr'd;"l1
c:c:
Scott Wilso~ Richa.'l:I Fitzgerald, Dave lol-.nston. Suzanne DeLeon, California Department of
Flsh and Game, Yountville, California
Ruby Pap, Cn!ifOli'jc:. Coastal Commission, San Francisco, California
-----.-~--.------~-------,-~-.-~---
Kathr~n 6507281451 1".8
Ms. Camille Leung 5
Literature .Cited .
Bulger, J. E., N. J. Scott Jr., and R. B. Se)moW". 2003. Tr:;rre$hiai activity and conservation of
adujt California red-legged frcg.<; Rana aurora drayUmii in coostal forests and
grasslands. Biological Conserva.tion 110:85-95.
California Department ofFish and Game. 2009. RAREF1ND. Natural Heritage Division,
Sacramento, Californu.
Fdlers. G. M. and P. M. Kleeman. 2007. California Red-Legged Frog (Rant! dtaytonil)

Movement and Habitat Use: Implications for Con..~ation. Journal ofHerpcto1ogy
41(2): 271-281.
D3.1.tJ'..J NtiS =lO )"lMlOJ

Page 1 of 1
1991.05.14 CCC SMC LCP Major 2-90 Staff Report.pdf, 1993.12.02 CCC A-3-SMC-86-155 and 155A Condition Compliance.pdf + 2 more items
From: <kathryn.mwsd@gmail.com>
To: <cleung@co.sanmateo.ca.us>
Date: 10/26/2010 4:50 PM
Subject: 1991.05.14 CCC SMC LCP Major 2-90 Staff Report.pdf, 1993.12.02 CCC A-3-SMC-86-155 and 155A Condition Compliance.pdf + 2 more items
I've shared some items with you
Message from kathryn.mwsd@gmail.com:
Hi Camille,
I would love to make more in-depth comments to the FEIR the short review period prevents this. If the time is extended I will go into more detail. In the mean time, please include that attached Coastal Commission Staff report and other docum
I am concerned that the 11 afy that the County is considering allowing Big Wave to extract will reduce the 23 afy the Coastal Commission allowed Citizens Utilities (now MWSD) to add to our allowed extraction limits from this aquifer. As a MW
Any ag well conversion must follow the Coastal Commission conditions imposed on MWSD, if this is indeed a properly permitted well.
Please add at least 60 days additional time for comment.
Click to open:
 1991.05.14 CCC SMC LCP Major 2-90 Staff Report.pdf

 1993.12.02 CCC A-3-SMC-86-155 and 155A Condition Compliance.pdf
 1991.10.28 CUCC Pillar Point Marsh Groundwater Basin Report, Phase II.pdf
 1991.05.00 CCWD Report on Biological Monitoring Pillar Point Marsh.pdf
Google Docs makes it easy to create, store and share online documents, spreadsheets and presentations.
Logo for Google Docs
11/16/2010
October 26, 2010
San Mateo Co. Planning Dept.

Subject: Big Wave Project Final Environmental Impact Report (FEIR)
I am writing with regard to my concerns over the traffic impact which clearly will be created by
the Big Wave project as it is currently proposed. Anyone familiar with the area around Princeton
Harbor can easily see the roads cannot accommodate the additional automobile traffic projected
by the Office Park plan. Residents of the area are quite familiar with the traffic jams in Princeton
that occur with every harbor or airport event, and these will become a daily phenomenon. The
mitigations cited in the FEIR are quite vague, such as the proposed fifty car offset by means of
shuttle service (itself an insignificant number compared to the 700 + projected autos). Further,
the report refers to future traffic studies as a means of alleviation, as though traffic studies after
the fact will reduce the number of cars when the plant is fully operational. Finally there is a
statement to the effect that if all else fails, the number of cars will be reduced, without saying how
this will be mandated or accomplished. It appears that this major defect in the plan is being
papered over with generalities.
The traffic issue however, is more than a matter of inconvenience to the local residents, when one
considers the eventuality of a tsunami. The report addresses this matter, citing the two most
recent events, both of which occurred within this writer's lifetime, with mitigations including to
raising floors to 20 feet, 6 feet above the level of the highest wave recorded in the area. The
consulting engineer has called these measures "reasonably safe." It should be noted that pipeline
experts charged with monitoring the San Bruno gas pipeline that recently exploded, also judged it
reasonably safe.
In considering tsunamis, one must consider that while 14 feet (approx.) was the highest recorded
locally, the highest recorded in California was 21 feet, in Crescent City in 1964. By way of
illustration, the 2004 Indonesian tsunami, the devastation of which we have all seen on the News,
was 30 feet. The highest wave ever recorded was 1720 feet, in Alaska in 1958. The point is, in
the event of a tsunami, nothing can be judged "reasonably safe," and the only thing one can do is
evacuate the area as quickly as possible. For this reason, a tsunami warning and evacuation
system has been installed on the Coastside.
When a tsunami occurs, there will be a mass evacuation, with Highway 1 and all the local roads
quickly becoming congested to the point of impassability. If the seismic occurrence is in
Indonesia or Alaska, possibly there will be time for everyone of safely escape. If it occurs off the
California coast, there will be very little time. The residents of the Wellness Center will have to
be assembled and put on transports, by which time they will be stuck behind the 700 cars
attempting to flee the Office park, and possibly be swept away by the ensuing wave. This would
be similar to what happened in the 1991 Oakland hills fire, with people trapped in their cars on
the bottlenecked roads and overrun by the blaze. While the consulting engineer has qualified his
judgment with the phrase "reasonably safe," those who approve this project without sufficient
mitigations for such a catastrophe will be in an unfortunate position similar to those charged with
overseeing the San Bruno pipeline.
1 of 2
This is one issue. There are many other issues in connection with this project, including those
raised by the airport and the local sanitation district, regarding the lack of sufficient mitigations
for problems raised within the EIR. If the project is deemed by the county to be sufficiently
important that such details are not considered crucial, then at the least a matter of life and death
must hold sway. The residents of the Wellness Center must be deemed particularly vulnerable. If
the project is to be approved, it is incumbent upon the County to mandate the civil engineering
and construction (including the inevitable matters of eminent domain) of sufficient access through
the area to permit an emergency evacuation. Failure to do so would be irresponsible.
As a postscript, it should be noted that a day prior to this writing, there was another tsunami in
Indonesia that killed over 100 people.
Sincerely,
Kevin L. Cooke
111 Derecho Ln.
2 of 2
I support Big Wave Project and all staff recommendations in the County Staff Report, including to
approve the project as described in Alternative C and as presented in the final EIR
For the last 15 years I have worked with individuals, from ages 4 to 80, with developmental
disabilities all over the state. Nowhere in this state is there an opportunity like this for individuals
with disabilities. A place where they have the chance to live on their own, as independently as
possible, in housing that they own and can afford. The Big Wave Project will put San Mateo
County, and the Coastside, on the map. Just as surf enthusiasts around the world know about
our little town because of Mavericks, professionals who work with people with disabilities and
families of those individuals around the country will be interested in a project like Big Wave!
Please do not further delay this urgently needed project. It is time to develop affordable housing
on the Coastside and to provide for our special needs population.
VOTE YES to your staff recommendations. If you are unable to vote at the meeting tonight, please
hold a special meeting the first week of November to vote YES on this project.
Thank You!
Sincerely,
Kerrie DeMartini
Half Moon Bay High School Special Education Teacher
Page 1 of 3
- RE: Big Wave
From: "Karen Hoexter" <khoexter@comcast.net>

To: "'Petra Syme'" <petra_syme@hotmail.com>, <pprice@finexgroupllc.com>, <rd...
Date: 10/27/2010 1:06 PM
Subject: RE: Big Wave
Dear Ms. Syme,
I was a bit surprised at your reply to Bob Kline although I understand that you have been working on this for
several years so you are quite invested in the completion of the project. Perception is everything. My
interpretation of Bob’s email was that he was asking EGNAG to attend to learn about the project – not to outright
object to it. Our group is very interested in learning the pros and cons of this project, not blatantly objecting to any
growth on the coastside. I have lived in El Granada for only 5 years but this is the first time I have heard anything
about this project. I also thought “Big Wave” referred to something with the Mavericks Surf competition as the
only time I saw anything in the HMB Review was last year. This was at the same time the surfing competition was
going through their change of leadership. My immediate neighbors, who have lived here for well over 20 years
have not heard anything about the project either.
This is not to say that I or my neighbors would object – but transparency in the project would be welcome. I would
be interested in seeing what the requirements are to develop the project, the governmental deadlines, the results
of any studies, and a spreadsheet of which requirements have been satisfied and which have not. Frankly, each
citizen in the coastside is not going to read a 3,000 page impact study or purchase their own copy to. It would
help if you could publicize the findings – both pro and con.
What I object to (and this is not specifically referring to this project but to any project anywhere and to
corporations in general), is that government and corporations have been making a lot of decisions that affect the
general population but for which we had no real input. And by this statement I am referring to the Wall Street
meltdown, mortgage crisis, bank closures, and other events that have caught Americans by surprise. We thought
our leaders where making decisions in our best interest – but we have all learned that this is not necessarily true.
I’ll only speak for myself and my family – yes, I am very sensitive about any project being constructed in the
community of which we have had inadequate prior knowledge. Placing a small 1” x 2” ad in the HMB Review (as
was done with the cell tower issue) is not adequate. It does not mean that I am objecting to the project – I just
want to learn more before a final decision is made.
So, I do take offense at your statement that “This project is not a surprise, it has been over 5 years in the making
and plans have been made available all along. “ I do not routinely spend time at the county offices scouring over
plans that have been filed. Unless the HMB review, the San Mateo County times, The SJ Merc, and/or the SF
Chronicle do in-depth coverage about the project, I will not know anything about it. Maybe there was more press
5 years ago but there are many newcomers to the coastside and it seems that most of us have no knowledge of
“Big Wave”. The younger generation is adept at blogging, searching for information on the internet and reading
their news on-line, but many members of the older generation prefer an actual newspaper. So unless you have
held public meetings that have been widely publicized in the print media, it is unlikely that I will know anything
about the project. It could be one of the best things for our community – providing a home for those in need,
creating local jobs which we desperately need and perhaps sustaining an environmentally fragile ecosystem.
But it is obvious to me that the project has not been well publicized. Right now I feel as if the project has been
thrust upon the communtiy. For a project this size I am amazed that there have not been weekly articles about it
in local papers. This is what gives me pause and nothing else. You could be surprised and find that our little
local action group might very well support the project – if we know enough about it.
I would like to attend a meeting to learn about the project, but I work on Wednesday evenings. Perhaps there
could be a series of informational meetings on different days so those who work in the evenings can attend? Has
this been done or have the meetings been advertised only to the direct stakeholders? I have not seen anything
advertised in the HMB Review and while I don’t always read the entire paper, my neighbors do. No one has ever
11/16/2010
Page 2 of 3
mentioned anything about “Big Wave” until the story poles went up.
EGNAG is very interested in learning about the project so each individual can make their own decision on whether
or not to support the project. Can you help inform us better? I am willing to listen and I have no doubt that my
fellow EGNAGers are also willing to listen. That has been the attitude that I have seen in the emails going back
and forth. People want to attend the MCC meeting to learn and not object.
Very sincerely,
Karen Hoexter
From: Petra Syme [mailto:petra_syme@hotmail.com]

Sent: Tuesday, October 26, 2010 5:05 PM
To: pprice@finexgroupllc.com; rdkline1@aol.com; pfoster222@aol.com; spasero@sugoagency.com;
dpasero@sugoagency.com; gened422@hotmail.com; jameswpeterson@gmail.com; maggiereynard@yahoo.com;
michaelctc@coastside.net; moco.s@sbcglobal.net; jpowellace@yahoo.com; robcello@yahoo.com;
tom@sfdreams.com; terri.eckert@comcast.net; coastside2001@yahoo.com; skline4910@aol.com;
luis@luisrojas.com; cherismail@comcast.net; sperinde@comcast.net; skaman@stanfordalumni.org;
rm_cooke@yahoo.com; chrisnikola@me.com; cnicola@ea.com; kristenob@gmail.com; dhob@yahoo.com;
walter.usinowicz@opco.com; allenolivo@comcast.net; ruthdoell@comcast.net; barbaranorman02@yahoo.com;
khoexter@comcast.net; southernrick@yahoo.com; kschoendorf@sbcglobal.net; gbauthor@hotmail.com;
roarkinhmb@yahoo.com; g@art-affects.us; kawataworks@yahoo.com; wendyandary@hotmail.com;
gburke9372@comcast.net; bluenote.ted@gmail.com; www.mariansbennett.com@aol.com; mskuehn@msn.com;
len.erickson@earthlink.net
Cc: planning-commission@co.sanmateo.ca.us; cleung@co.sanmateo.ca.us
Subject: Big Wave
Mr. Kline
I am disappointed that so little is understood, yet so much ignorant rhetoric is broadcast to such a large group as
in the email below which found its way into my hands.
If you bothered to actually read the Environmental Impact Report for Big Wave you would see why it is over 3000
pages long. It does answer many questions about the environmental impact, the social and economic impact of
the Big Wave project. The so-called 'developer' is a dad of a special needs young adult who is donating his land
to create an independent living and working environment for his daughter and other special needs youth/adults
on the coastside. This avoids them having to leave the coastside to go to other states, and other parts of
California to get such assistance - other places that actually give a damn about special needs people.....
This is NOT a shopping mall, or a hotel, or some major For Profit development - this is specifically to fill a huge
gap on the coastside. This needs careful, considerate, compassionate thought and input, not a 'No Growth -last
one in shuts the gate' knee-jerk reaction.
Please do not encourage others to blindly follow a vocal minority who believe that their right (not sure who
bestowed it) to a 'view', or that shell mounds, or frogs, or anything else like that is more important than a
disenfranchised group of people on this very coastside - children of friends of some of yours no doubt - who
desperately need a place to call home, some independence, some dignity, some skills, and the ability to add value
to the coastside through working and creating jobs, rather than being dependent on the county, the coastside
and others.
This project is not a surprise, it has been over 5 years in the making and plans have been made available all
along. There is no 'sneakiness' here and the developer and the others working on putting this together are
receiving no funds and will receive no funds for their efforts here. This is not something that should be opposed
just for the sake of opposing something. If you want to attend the meeting please do so in an effort to actually
understand the intent, and ask honest questions and expect honest answers, but do not go with the agenda to
11/16/2010
Page 3 of 3
'slow down' something that needs to happen sooner rather than later.
Go to the website and see what it is all about if you don't know:
http://www.bigwaveproject.org/
There has actually been a lot of thought and effort gone into create an economic sustainable environment for
special needs, and mitigating environmental impact, and in fact creating some valuable environmental impact.
Are you really that scared or bigoted towards special needs individuals that you must stop this project just to
make another notch in your belt? Seriously?
I am cc:ing the planning commission and ms leung as I had emailed them earlier today on this issue.
I want them to see the rationale behind the type of opposition to Big Wave - ignorance, and No Growth and a
selfish desire to maintain some desired standard of living at the expense of others just because some of you
happen to live on the coast and don't want anyone else to enjoy that privilege (notice, not a right but a privilege
that you abuse with this kind of selfish behavior). The special needs residents of this proposed project also live
on the coast and want to enjoy the 'splendid Coastside living' you mention in your email below. Do they not have
the same 'rights' as you? or because they need some more infrastructure to support them, they don't have the
same rights as you? Very sad....very sad.
Yours sincerely,
Petra Syme
Subject: OUR ATTENTIOIN IS NEEDED !!!!!!!

Hello!!!! EGNAG ,
At our celebration party, someone let it slip that I was applying for the open seat at MCC. The cell tower
issue revitalized my community spirit and thanks to all of you and your outstanding efforts during the Cell
Tower fight, I applied. There was a MCC meeting last Wednesday. I was interviewed and accepted by
the Council. I need to be interviewed by two persons from the Board of Supervisors. Depending on how
quickly they act, I could be installed by the middle or end of November.
After I was accepted,I stayed for the rest of the meeting, The Big Wave project was discussed. I knew
very little about Big Wave and thought they were going to discuss the Maverick's event. It is not.
This project is a proposed 250,000 square foot facility with 600 parking spaces. I am attaching
information from Len Erickson on the project. There is additional info at the MCC website.
The situation is this. The developer is pushing this through with code and environmental issues not
resolved. MCC is tasked to answer these and other issues found in a 3,000 page document created by
the developer and the Planning Commission.
The Board of Supervisors is holding a meeting this Wednesday, October 27 at 6:00 PM. The place is El
Granada Elementary School.
MCC needs our help and support to slow this process down. This project infringes on our coastal
community.as much or even more so than the cell tower did .The developer seems to be as sneaky as
was AT&T. There are code, environmental, water , traffic and other issues not answered.
A show of community support is essential in order to slow down Big Wave. EGNAG can make a big
impact here. Regardless of your position, even if you have one, more information is needed before this
project becomes reality. So, please try and attend this meeting on October 27 at 6:00 PM at El Granada
School
I believe EGNAG can lead by example. If believe EG NAG reaches out to other Coastside Communities
we can take an active, effective part in protecting and maintaining our splendid Coastside living.
Regards,
Bob Kline
11/16/2010
Page 1 of 1
October 27th Big Wave Planning Commission meeting
From: <kimgainza@comcast.net>
To: "." <Planning-Commission@co.sanmateo.ca.us>
Date: 10/28/2010 11:44 AM
Subject: October 27th Big Wave Planning Commission meeting
CC: <rgordon@co.sanmateo.ca.us>, "Carol Groom" <cgroom@co.sanmateo.ca.us>, "...
I am writing to you to express my frustration and anger at the canceling of last night's Planning
Commission meeting re: the Big Wave project.
I sincerely hope the cancellation had nothing to do with the World Series, which would show an
incredible lack of respect and consideration for those involved with and in favor of the project.
A number of people who planned to attend the meeting had taken time off from work to do so.
My husband and son had been invited to go to the baseball game, which they turned down
because they both planned to speak at the meeting. Many, many hours of planning and
preparation had gone into last night. Plus the expense of sending out postcards to keep the
supporters informed about the 27th date, all of which now has to be done again with the new
date.
Regardless of the reason, it is hard to believe that more notice of the cancellation couldn't have
been given.
The continual delays of this project are inexcusible. According to the final EIR and your own
staff report, there is no reason why it should not be approved. I am asking you to please
expedite the process and do the right thing for the Coastside in general and the
developmentally disabled population specifically.
Sincerely,
Kim Gainza

Page 1 of 1
From: "Laurie Goldberg" <vallemar58@yahoo.com>

Date: 10/25/2010 7:06 PM
I am a citizen of San Mateo County and I'm tired of private investors and big money trying to
ruin every bit of the coast. Stop the Big Wave, we don't need it, and the big money can go
somewhere else, how about Florida and ruin another area. I love the beauty of the coast and I
want it to stay beautiful. I can go anywhere and see shopping centers on every corner, houses
and condos on every corner, and I can go anywhere and see millions of people. I want to see
nature, and the ocean. Keep San Mateo County a beautiful area that it is.
STOP BIG DEVELOPMENT AND GREED NOW AND

FOREVER!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
Laurie Goldberg a concerned citizen of San Mateo County and the coast

Page 1 of 1
Bryan ALBINI - Big wave
From: "kimberly clark" <clarkkp@hotmail.com>

Date: 10/27/2010 1:53 AM
Subject: Big wave
Good Morning:
I am writing to encourage you to support the Big Wave project. As a parent living in Texas with my adult
special needs daughter living in New Mexico in order for her needs met, I am acutely aware of the need for a
model and beacon of hope for the special needs community. I am also very interested in the environment and am
a participant in supporting Greenpeace and the Sierra Club. I am hopeful that with the help of the non-violent
communication model a solution can be found that will meet everyones needs.
Sincerely,
Kimberly Clark

Se, ;ALTRANS TRANSPOATATIO PLANNING; 510 286 5560; Oct-20-10 9:51AM; Page 1/1
STATE OiCAl.!POlNIA BUSIN~ llW!SPOR~ AND fJ,lUllNG AGENCY
DEPARTMENT OF TRANSPORTATION
111 GRAND AVENUE
P. O. BOX 2JfitiO
OAKLAND, CA 94623-0660
PHONE (510) 622··5491 Flex. yo •.,. p()~rl
FAX (510) 286-5559 Be elterl!Y f!jJicient'
TTY 711
October 20,2010
SM001376
SCH# 20081 021Q9
SM-OOl-34.885 .
Ms. Camille Leung
Planning and Building Division
County of San Mateo
455 County Center
Dear Ms. Leung:
BIG WAVE WELLNESS CENT.ER AND OFFICE PARK - RESPONSE TO

COMMENTS
Thank you for continuing to include the California Department ofTrat1Sportation (Department)
in the environmental review process for the Big Wave Well ness Center and Office Park
project. The following comments are based on the Response to Comments. .
High way Operlllions

Response to Comment 2444:
1. We do not agree with the rationale that was presented. Based on the added traffic from the
proposed swrounding projecb of the BackgtOlUld, Project, and Cumulative conditions,
theoretically. existing traffic willaJso increase within the project site area_ Therefore, the
Average Delays for those study intersections and facilities will also increase not decrease.
2. Please explain what is meant byibe statement., ..... due to the use of weighted averages,
average delay can actually decrease with the addition of Background Traffic to Exi~ing
Traffic or with the addition of Project Traffic ifthe traffic is added to a movement With
low delay (i.e., off peak direction)_"
Please feel free to call or troail Sandra Finegan of my staff at (510) 622~ 1644 or
sandra finegan@dot.ca.gQvwithanyquestions regarding this letter.
Sincerely,
~~~~
LISA CARBONI
District Branch Chief
Local Development - Intergovernmental Review
c: State Clearinghouse
"Calera..., Impruvr:.J mebilll)' across california"

Big Wave Store Poles Page 1 of 1
- Big Wave Store Poles
From: "Len Erickson" <lenericksonmcc@gmail.com>

To: "Camille Leung" <cleung@co.sanmateo.ca.us>
Date: 10/19/2010 8:36 AM
Subject: Big Wave Store Poles
CC: "Jim Eggemeyer" <JEggemeyer@co.sanmateo.ca.us>, "Neil Merrilees" <mermad...
Attachments: IMG_4358.jpg; IMG_4359.jpg; IMG_4364.jpg; IMG_4371.jpg; IMG_4372.jpg
Hi Camille,

I’m sending this to clarify the FEIR statement concerning story poles:

The applicant declined, but has stated that story poles will be installed and maintained during the
public notification period prior to any County public hearing considering the project and the certification
of the FEIR. The public notification period is 10 days prior to a public hearing date. (BW FEIR II‐32)

Attached are five photos:
IMG_4358/4359/4364 are of the connected six pole structure on the south parcel shown from airport
(4358,4359) and the supplementary Pillar Point parking lot (4364).

IMG_4371/4372 are of two sets of four connected poles on the north parcel from Airport St. There is also a
tractor in one of these photos and additional additional materials which it appears could be used for poles.

All Photos were taken on Oct. 18, 2010. Can you answer the following questions:
 Which structures these sets of poles represent?
 Is this the full extent of story poles construction?
 When will these story poles be removed?

Thanks you. I will be in the planning office this afternoon at 1:30pm and available to clarify any questions you
have.
Regards,
Len Erickson
Midcoast Community Council
Vice-Chair
(650) 400-3175
WEB: http://mcc.sanmateo.org

,
L:; .'
•
Big Wave: LCP Concern - Community Planning Concern Page 1 of 2
Big Wave: LCP Concern - Community Planning Concern
From: "Len Erickson" <lenericksonmcc@gmail.com>

To: "Jim Eggemeyer" <JEggemeyer@co.sanmateo.ca.us>
Date: 10/25/2010 4:26 PM
Subject: Big Wave: LCP Concern - Community Planning Concern
CC: "Neil Merrilees" <mermade4@yahoo.com>, "Rich Gordon" <rgordon@co.sanmate...
Jim,

I also have been deeply involved in the MCC’s review of the Big Wave project and I have concerns touching on
the process involved in formulating the Big Wave staff report.

The first concern involves county’s efforts to resubmit the Midcoast LCP. When I reviewed the County’s LCP
policy sections and the Big Wave staff report LCP Compliance sections, I found the same well ordered list of
elements in both with one exception: there is no Big Wave LCP Compliance discussion of Public Works
(Transportation, Water, Waste). A few public works elements are listed tangentially in other sections, but there
is no systematic presentation. Since this topic is central to the ongoing effort of San Mateo County and the
Coastal Commission to reach agreement on the LCP update, I can only infer that this is an intentional omission.

A second concern is with process in the Big Wave staff reports recommendation. The first paragraph states
(p.3):

RECOMMENDATION
That the Planning Commission approve the project as described in Alternative C and as
presented in the Final EIR (hereafter referred to as the “project”)1. Under this alternative, the
total proposed square footage of the Office Park (225,000 sq. ft.) is distributed among eight
Office Park buildings, rather than four. As discussed in detail in Section II.C.6 of this staff
report, the recommendation for the approval of Modified Alternative C of the FEIR is based on
staff’s review of project compliance with the Visual Resource Component of County’s Local
Coastal Program (LCP). Staff also recommends approval of the alternate traffic circulation
proposal, which would re-route project traffic away from residential streets (e.g., Cypress
Avenue and Cabrillo Highway) and through the non-residential streets of Princeton, under
Alternative C.

The bolded final sentence is a major new approach the area of Transportation (100% project circulation through
Princeton). Furthermore only five pages later, the Traffic and Parking section of the environmental review is
discusses the Cypress intersection and does not deal with the noted bolded sentence in the recommendation. I
have serious concerns about the reasoning and support for taking this new approach, but have asked for
clarification in this matter in a separate email to Jim Porter, the director of DPW (you are copied on this
communication).

Third is a concern about a planning process that would consider a serious impact on the Princeton community to
support the Big Wave project traffic without some level of independent public vetting. This is all the more true,
because these new projects are not a part of the current fabric of the Princeton Community.

The MCC, as is every other group and individual, extremely pressed for time in this matter. I do not want spend
time on points that are procedural errors when preparing my testimony, so I would like confirmation on the
following points:

1. The alternate traffic circulation proposal, which would re‐route project traffic away from residential

Big Wave: LCP Concern - Community Planning Concern Page 2 of 2
streets (e.g., Cypress Avenue and Cabrillo Highway) and through the non‐residential streets of Princeton,
under Alternative C. is the recommended traffic approach for addressing Traffic and Parking for the Big
Wave project.
2. The LCP compliance discussion of the staff report does not require reference to the Public Works section
of the LCP.
3. The Planning and Building department has no near term plans to vet their major traffic change proposal
for Princeton with the Midcoast community.

Thank you for your consideration.
Regards,
Len Erickson
Vice-Chair
(650) 400-3175
WEB: http://mcc.sanmateo.org

October 10, 2010

Re: Request for Extension of Time to 60 days for Public Review for Final Environmental
Impact Report (FEIR), Big Wave Project
Dear Chair Bomberger and Members of the Planning Commission
On behalf of Committee for Green Foothills (CGF), I am requesting a 60-day public review period
in order to give the public and responsible agencies sufficient time to review the FEIR for the Big
Wave Project.
As you know, the Big Wave Project, as proposed and described in the DEIR, is enormously
complex, and includes residential, office, manufacturing and warehousing uses, as well as an onsite
wastewater treatment plant, onsite wastewater recycling, conversion of an onsite agricultural well to
domestic and industrial use, and solar, wind, and natural gas power generation.
The DEIR, along with its Technical Appendices and Facilities Plan, was over 2,000 pages long. It
was a daunting task to digest and comment on the DEIR. The public is keenly interested in the
project as evidenced by the 245 written comments on the DEIR.
CGF believes that given the complexity of the proposed project and the high level of
interest/controversy it has raised, it is vitally important for the County to allow sufficient time for
thoughtful review of the responses to comments.
Therefore, CGF respectfully requests that the review period for the FEIR be extended to 60 days.
Sincerely,
Lennie Roberts, Legislative Advocate

Committee for Green Foothills
cc: Jim Eggemeyer, Director, Planning and Building Department

3921 E. Bayshore Road 650.968.7243 PHONE info@GreenFoothills.org

Palo Alto, CA 94303 650.968.8431 FAX www.GreenFoothills.org
Page 1
November 10, 2010

Re: Consideration of Approval of EIR, Use Permit, Vesting Tentative Maps for Major Subdivision
and Minor Subdivision, Coastal Development Permit, Design Review Permit, Off-Street Parking
Exception, Grading Permit, and a Development Agreement for the Big Wave Wellness Center and
Office Park, on Airport Street, in the unincorporated Princeton/Moss Beach area of the Midcoast.
PLN 2005-00481 and 2005-00482
Dear Chair Bomberger and Members of the Planning Commission,
Thank you for extending the public comment period for comments and consideration of the Final EIR for the
Big Wave project. On behalf of the over 1,000 family members of Committee for Green Foothills, I am
submitting comments on the Final EIR and Staff Report for the proposed Big Wave project. These
comments supplement those submitted by Shute, Mihaly and Weinberger on behalf of Committee for Green
Foothills and Surfrider Foundation.
Your Commission will be considering eight separate actions in order to approve this controversial project.
CGF respectfully urges you NOT to approve the Final EIR, as it does not adequately respond to comments
from agencies, organizations, and members of the public. Additionally, due to major revisions to the project,
there is significant new information that has not been available to the public or analyzed in the EIR.
Significant changes in the Project Description since the DEIR require full disclosure to the public and
additional review/analysis under CEQA
The project, as described in the Staff Report, has been significantly revised, yet there is inadequate
information to determine whether these revisions may cause significant adverse environmental impacts, and
if so, whether these impacts can be reduced to a level of insignificance by adopting mitigation measures.
Some examples of inadequate information, and possible impacts thereof, resulting from changes to the
project include:
Wellness Center Revisions: The applicant has revised the site plan for the Wellness Center Site to
avoid the cultural/archaeological site. The initial seven buildings that were analyzed in the DEIR
have been consolidated into two buildings, and moved closer to Airport Street. This location is also
closer to the airport runway and increases the hazard to residents from airport operations, and visual
impacts. The revised project’s three-story, 36-foot high and approximately 300-foot long Building A
is a massive structure that is completely out-of-scale with the surrounding neighborhood in Princeton,
as well as with the adjacent one-story Building B. Yet it is not possible to adequately understand and
evaluate its visual impacts. The skimpy story poles and thin sagging tape that attempt to show the
3921 E. Bayshore Road 650.968.7243 PHONE info@GreenFoothills.org

Palo Alto, CA 94303 650.968.8431 FAX www.GreenFoothills.org
(11/15/2010) Bryan ALBINI - Big Wave.PC.11=10=10.doc Page 2

November 10, 2010
Page 2 of 10
exterior walls and height of Building A do not include the portion of the building that extends
northeast to within approximately 20 feet of Airport Street. There are no views or elevations of
Buildings A and B, as revised, included in the Staff Report or Final EIR, so the public is left with
outdated and inaccurate views of the original proposal in Attachment X. The public and decision-
makers are therefore unable to fully understand and evaluate the visual impacts of the Wellness
Center, as revised. Conditions 49, 50, and 57 require further revisions to Buildings A and B. These
conditions would only require Design Review by Planning Staff, rather than review by your
Commission and the public. Additionally, Condition 57 a, b, and c, requires further revisions to the
location and design of Buildings A and B, to reduce the impacts on Project residents from airport
noise, with review only by Planning staff, outside the purview of your Commission and the public.
CGF objects to delegation of review of these major changes to staff. How can your Commission and
the public understand the visual impacts of the Wellness Center, when there are as yet undisclosed,
significant new revisions? The three story, 36 foot high Building A is inconsistent with LCP Policy
3.13 that states: “Require that new development providing significant housing opportunities for
low and moderate income persons contribute to maintaining a sense of community character by
being of compatible scale, size, and design. Limit the height to two stories to mitigate the impact of
this development on the surrounding neighborhoods…” The Final EIR acknowledged this clear
inconsistency, but swept it away by stating that the three story building was “in substantial
compliance” with this policy.
Office Park Revisions: Staff has proposed revisions to the Office Park Alternative C and is
recommending this Alternative as the Environmentally Superior Alternative. The Office Park, as
revised by Staff, proposes eight buildings instead of four but the same square footage would be
maintained overall. Four of the eight buildings would be two stories, (36 feet high), and four would
be three stories, (46 feet high). The Community Design Manual requires that structures relate in size
and scale to adjacent buildings and to the neighborhood in which they are located. . The only
neighborhood of the Office Park is the Pillar Ridge Community, which consists of one-story homes.
Beyond Pillar Ridge to the north, existing buildings on Airport Road in the M-1 zone are no taller
than two-stories, 24 feet high. The skimpy story poles and single sagging tape connecting them that
address only four of the eight buildings are wholly inadequate for decision-makers and the public to
evaluate visual impacts, as were the depictions of views in the Draft EIR. Additional revisions to the
design of buildings in the Office Park are deferred to Planning Staff (Condition 48). How can the
Commission and the public evaluate the mass, bulk, design, and overall appearance of the revised
Office Park?
Traffic and Circulation/Access to Site: Staff has proposed an “Alternate Office Park Traffic
Circulation Option” under Modified Alternative C, which would prohibit all project related traffic
from using Cypress Avenue to the north, and instead would require all traffic to access the site from
the south, through the working waterfront and visitor serving commercial area of Princeton. CGF
believes this alternative routing is unenforceable. The Hexagon Traffic Report assumed that 50% of
the traffic for the Office Park would come from the north, which would require these vehicles to go
beyond the project site to the south, and then backtrack through the narrow substandard streets in
Princeton and the chokepoint block of Prospect between Capistrano and Broadway/Cornell. Drivers
coming from the north will most likely seek creative ways to defeat the “No Right Turn” into the
project site rather than take a more circuitous route. The Staff Report, in Attachment L, concludes
that with the addition of an off-site parking agreement and shuttle for a minimum of 50 cars, the

November 10, 2010
Page 3 of 10
intersections in Princeton would not exceed LOS “C”. There is no information as to where this
parking and shuttle would be located, the frequency of shuttle service, and how such alternative
shuttles would be managed to be convenient for office workers to use. Therefore, this conclusion is
entirely speculative. Princeton is an important visitor serving/recreation and marine related
commercial destination. Additional traffic directed through this area from a non-priority (commercial
office park) land use could potentially impact the ability of the public to access the coast, contrary to
the Public Access Policies of the Coastal Act.
Membrane Bio Reactor (MBR) Plant: The single wastewater treatment plant has been replaced by
three separate smaller plants, which are proposed to be located in separate below-ground areas of the
project sites to allow for project phasing. There is no information in the EIR or Staff Report as to
where these below ground MBR plants would be located. Would they be within the buildings?
Under the parking lots? Within the 100 foot wetlands buffer zone? Nor is there information as to
how odors would be controlled, where any chemicals used in the treatment of wastewater would be
located, and how potential risks to public health and air quality and odor impacts would be addressed.
Use of recycled water for landscaping; landscape species are not suitable for climate, soil, and
ecological characteristics of the site. Table 7, page 58 of the Staff Report (taken from Appendix K
of the DEIR, and revised in the FEIR in “Addition to Appendix K of the DEIR”) claims that the
winter irrigation demand for Uplands Landscaping trees and shrubs would be double (11,000 gpd) the
summer demand (5,500 gpd). Winter demand for Uplands Landscaping irrigation should be zero. In
our California Mediterranean climate, Uplands species are drought adapted, and certainly do not need
irrigation during the winter rainy season. As CGF previously has commented on the DEIR, which has
not changed the Planting Plan, the two Uplands tree species specified for the Palustrine Forest II –
Live Oak Riparian Forest in the WSP “Draft Planting Plan” are Coast Live Oak and California
Buckeye. These trees occur naturally in hot, dry inland locations. Coast Live Oak is highly
susceptible to Sudden Oak Death and Armillaria root rot, and as such is not appropriate for this site
that is underlain by an impermeable clay layer, saturated soils and a high water table. Coast Live
Oaks, Madrone, and California Buckeye are shown on the Planting Plans as perimeter landscaping in
Attachment Q of the Staff Report – which does not reflect the revised Wellness Center Site Plan. The
Draft Planting Plan (Revised Figure III-23 of the DEIR) for the Office Park shows Western
Sycamore, Madrone, and California Buckeye as perimeter landscaping. California Live Oak,
Madrone, Big Leaf Maple and California Buckeye are not appropriate species for landscaping of the
perimeter and parking lots. Madrone is difficult to grow, does not tolerate irrigation, and is
susceptible to Sudden Oak Death and several fungus diseases including crown rot and root rot.
Western Sycamore and Big Leaf Maple achieve heights of 75 feet or more, and would thus be
inappropriate for location near the airport, and adjacent to the Pillar Ridge community. The selected
tree and shrub species are inconsistent with LCP Policy 8.10 which requires that vegetation removed
during construction is replaced with plant materials that are compatible with surrounding vegetation
and are suitable to the climate, soil, and ecological characteristics of the site. These unsuitable tree
species need to be replaced. The calculations of wet season demand by landscaping of the recycled
wastewater need to be re-analyzed. It appears that the project will necessitate much greater
wastewater capacity than estimated in order for the GSD to handle wet weather flows.
Stormwater Drainage Facilities: The Staff Report, page 12, discusses the changes to the
stormwater drainage facilities. Instead of directing roof drainage into “rain gardens”, this runoff
would instead be directed into perforated pipes and an infiltration system in trenches beneath the

November 10, 2010
Page 4 of 10
parking lots. All surface water from parking lots would also be infiltrated into the same underground
system. According to Appendix K, page 1, “the project site is underlain by an impermeable layer of
clay that is eighteen to thirty six inches thick that allows virtually no infiltration.” According to the
BAGG Preliminary Geotechnical Investigations dated June 13, 2000 and May 7, 2002, based on
borings on the two sites, the clay layer may be several feet thick, and is generally beneath one foot of
topsoil. There appears to be inadequate filtration capacity within the topsoil area above the clay layer
to fully absorb and store the rainwater runoff in order to achieve the stated “gradual infiltration
providing biological treatment”, particularly if the landscaping around the buildings and parking lots
is receiving recycled irrigation water during the winter (rainy) season. This lack of capacity to absorb
and store the rainwater runoff could create adverse environmental impacts.
Phasing of Project: The stated intent for the project overall is for the Office Park to support the
Wellness Center, so that the residential units will be affordable. In order for this to happen, the
Office Park would have to be built first. Instead, the Development Agreement shows the Wellness
Center would be built in Phase 1 and 2, and Office Park phased development would be subject to
economic conditions. The initial three-year buildout period has been extended to 20 years. The
assumptions as to affordability of the housing units are thus merely speculative. Discussion of project
compliance with LCP Policy 3.1 (Staff Report, page 28) does not provide any supporting data for the
conclusion that if there is no demand for office space, the Wellness Center would still be affordable to
all but the “extremely low income” category. Phasing of construction proposes to rough grade and
install utilities on both sites, then construct the each of the office park buildings, and associated
parking areas and other infrastructure in phases, according to demand. It is not clear how the
underground stormwater infiltration system would operate if constructed in segments, and how a
partially completed system would be able to retain and slowly release the stormwater runoff from
roofs and parking lots without causing adverse impacts or adding to runoff from the rough graded but
uncompleted Project areas.
Wetland Restoration Areas: The project proposes restoration of wetlands within the Riparian
Area/Wetlands 100 foot buffer zone. The Draft Planting Plans have not been revised to reflect the
changes in Site Plans and building locations. There is conflicting information as to how the wetland
restoration would be accomplished. The Draft #2 Facilities Plan (1/1/09) states (page 79) that the
majority of surface soils are organic clayey silts with low levels of permeability and high levels of
expansion, which are “ideal for the proposed wetlands restoration but will not function for the parking
lot and building foundations”. The Facilities Plan proposes to remove these soils from the parking lot
and rainwater infiltration areas and “all surface soils due to their high organic concentrations will be
utilized in the restored wetlands…” The August 4, 2008 “Draft 90% Basis of Design Report” by
WSP (page 8) prescribes mass grading in the wetlands restoration areas to remove all existing weeds
and seed source in the upper six inches of soil. There is no information as to where and how this top
six inches of soil and its seed bank would be disposed of. Is this removal included in the grading
quantities? Would the aforementioned surface soils, which also presumably harbor a seed bank of
weedy species, replace the soil removed from the wetland restoration areas? There is no information
in the WSP report as to whether, where and how the organic clayey material (which is generally a
foot beneath the top soil) from the parking lot areas would be stockpiled and used in the wetlands
restoration. Completion of the Office Park has been extended to up to 20 years per the proposed
Development Agreement. Condition 28 (Staff Report, page 96) defers any specific plan for the
implementation of the wetland restoration, including grading, stockpiling, and disposal of topsoil until

November 10, 2010
Page 5 of 10
after the first buildings on each site are completed (at the Certificate of Occupancy). This deferral of
submittal of the restoration plan that includes milestones for implementation, monitoring, and
reporting, is impermissible under CEQA. The Development Agreement (Attachment S of Staff
Report) does not even mention any restoration of wetlands on the Office Park, nor is there any
Condition of Approval that requires restoration of wetlands with enforceable triggers and/or
milestones. The WSP report (page 9) specifies a ten-year monitoring program that includes
maintenance and adaptive management. There is no requirement for bonding to ensure the wetland
restoration, maintenance, and monitoring, which was estimated to cost $1.2 million in the Facilities
Plan Draft #2, will actually be carried out.
This list of deficiencies is not exhaustive, but rather illustrative of some of the significant issues that the
revisions to the project have raised.
The necessary Findings for Approval of the Coastal Development Permit (CDP) and Use Permit
cannot be made for the following reasons:
1. Major revisions to the project require analysis of its compliance with the Coastal
Development District requirements. At a minimum, a Revised Site Plan must be prepared for
your Commission’s review and approval, with copies available to the public. The Revised Site Plan
must include the revised locations of all proposed structures, roads, utility lines, signs, fences, and
other improvements, and revised building elevations showing existing and proposed finish grades,
all exterior walls for both the proposed Wellness Center, as revised by the Applicant, and the Staff
Recommended Modified Alternative C for the Office Park, per Zoning Regulations Section 6328.7,
Application Requirements. The square footage for the Wellness Center buildings is missing and is
incorrect for the Office Park Modified Alternative C. The public and decision makers cannot
properly evaluate the project’s impacts without this information.
2. The Wellness Center is not a permitted use by right, or a conditionally permitted use under
the General Plan, LCP, and Zoning Regulations. Most of the site is designated as General
Industrial in the General Plan and LCP Land Use Plan, and is zoned Waterfront/Design
Review/Coastal Development District. A small area comprised of wetlands is designated Open
Space and zoned Resource Management. The Waterfront (W) District’s purpose is to provide a
“working waterfront” area intended primarily for the location of marine related trades and services
and manufacturing land uses that support commercial fishing and recreational boating activities.
The only residential uses allowed in the W District are single unit “caretakers quarters” on no more
than 20% of the developed parcels.
3. The Wellness Center is not a Sanitarium. In order to avoid amending the County General Plan,
LCP, and Zoning Regulations, the applicants have attempted to characterize the Wellness Center as
a “Sanitarium”. Section 6500 of the Zoning Regulations allows a Use Permit to be issued for
certain specified medical institutions - Hospitals, Rest Homes, or Sanitaria - in any zoning district
within the Urban Area when found to be “necessary for the public health, safety, convenience, or
welfare”. A Sanitarium is generally defined as an institution intended for short-term rest,
recuperation, treatment of the chronically ill, or therapy for rehabilitation. As such, a Sanitarium has
an essential medical purpose, as do Hospitals and Rest Homes. In contrast, the Big Wave Wellness
Center is a “community development that provides housing and employment opportunities for low-
income developmentally disabled adults…” (Project Description, DEIR page III-18). Big Wave is

November 10, 2010
Page 6 of 10
not intended for “short-term rest,” but rather long-term residence. Moreover, the residents are not
“chronically ill,” nor will they be receiving treatment. Unlike Sanitaria, which are typically located
in quiet, rural or mountain settings, where clean air and peaceful surroundings can help speed
recuperation, Big Wave would be located adjacent to the Half Moon Bay Airport and within the
Waterfront Industrial District where all but the most extremely hazardous chemicals are allowed to
be stored and used - indoors or outdoors. Noise, dust, odors, vibrations, and other hazards
associated with manufacturing, fish processing, boat building, and other industrial uses, are typical
impacts from land uses and activities in the Waterfront District. Thus, it is clear that the Big Wave
Wellness Center is not a sanitarium, and this particular site is not an appropriate location for a
medical institution, if it were. The Findings for the Use Permit therefore cannot be made.
4. The Wellness Center’s height is not in compliance with LCP Policy 3.13 which is intended to
ensure the maintenance of community character. Even if the Wellness Center were an allowable
use in the Waterfront zoning district, the revised project’s Building A – at three stories and 36 feet
of height - is not in compliance with LCP Policy 3.13 which requires that new development
providing significant housing opportunities for low and moderate income persons must maintain
community character by being of compatible scale, size, and design, and the height shall be limited
to two stories to mitigate impacts on the surrounding neighborhoods. As previously stated, the
project’s compliance with other Visual Resource policies of the LCP, including with the
Community Design Manual, cannot be completely evaluated, due to lack of complete story poles
and netting to outline the buildings, incorrect visual depictions, and inappropriate exterior colors,
particularly bright orange, for the Wellness Center.
5. All use(s) within the 125 foot wide Airport Overlay (AO) on the Wellness Center site require a
Use Permit. The proposed uses within the Airport Overlay include commercial storage, parking
lots, and a nursery and/or farming, although the location of these latter two uses have not been
specifically depicted on the Tentative Subdivision Map. Per the AO Overlay Zone Regulations
(Section 6288.2), no residential uses nor more than three persons may occupy the site at any one
time, and permitted uses shall require a Use Permit, in order to provide an extra margin of safety
for airport operations. The Staff Report lumps the commercial storage area together with the Use
Permit for the “sanitarium”, and does not include the other uses proposed in the AO zone, including
parking, nursery/farming, and possible recreation/sports facilities such as basketball courts. The
Use Permit Findings do not address the required limits on the number of people who would occupy
the site within the AO zone. The Use Permit makes unsupported and/or erroneous Findings
regarding the Wellness Center’s compliance with the Visual Resources, Housing, Hazards,
Sensitive Habitats, and Shoreline Access components of the LCP.
6. Grading for the Wellness Center revised plan would impermissibly allow grading and
placement of fill within the 100’ wetlands buffer zone. The 5/17/10 Preliminary Grading Plans
(Attachment P of the Staff Report, Figure J of FEIR) for the revised Wellness Center show the
buildings have a finished floor elevation of 20 feet. The existing grade elevation beneath Buildings
A and B is 12 to 15 feet. In order to raise the grade beneath the buildings to 18 feet, as shown in the
Grading Plan, the fill would extend well into the 100-foot wetlands buffer zone. It is likely that the
Fire Regulations will require a fire road beyond the buildings, which is not currently in the revised
site plan. LCP Policies 7.16 and 7.19 do not allow filling of wetlands and buffer areas to
accommodate buildings and their associated parking areas, driveways, and fire access roads. LCP
Policy 7.3 requires development adjacent to sensitive habitats to be sited and designed to prevent

November 10, 2010
Page 7 of 10
significant adverse impacts to and maintain the biologic productivity of sensitive habitats. Policy
8.6.d. requires: “Retain wetlands intact except for public accessways designed to respect the visual
and ecological fragility of the area and adjacent land.” The “restoration” of wetlands is not
necessary, as the wetlands and buffer areas would naturally recover and reestablish wetlands
vegetation including cattails, rushes, and horsetail that were destroyed by agricultural activities if
left alone (see item 8 below).
7. Grading for the Office Park Modified Alternative C would impermissibly allow grading and
placement of fill within the 100’ wetlands buffer zone. The Preliminary Grading Plan
(Attachment I of the Staff Report, Figure J of FEIR) for the Office Park Modified Alternative C
shows finished floor elevations of the eight buildings range from 21.5 to 23 feet. The existing grade
elevation beneath the buildings is 17 to 22 feet. In order to raise the grade beneath the buildings
and the fire road to 20 feet as shown on the Grading Plan, up to three feet of fill is necessary along
the south and west side of the Office Park buildings, fire road and parking area. This fill would
extend into the 100’ wetlands buffer zone, which would similarly be out of compliance with LCP
Policies 7.16, 7.19 and 7.3.
8. Wetlands as delineated and mapped on June 20, 1994 by the Army Corps of Engineers on the
proposed Wellness Center site, would be permanently destroyed, contrary to LCP and
Coastal Act resource protection policies. Please see CGF’s letter of March 9, 2009 (attached)
and presentation at the Planning Commission’s November 18, 2009 meeting regarding disking and
filling of wetlands on the southern parcel. Some of the impacted wetlands may be within the
Coastal Commission’s area of retained jurisdiction, yet the jurisdictional determination is left to the
Applicant to work out separately with the Coastal Commission (Condition 5z). The Coastal
Commission has an open violation file on the disking and filling of wetlands. The wetlands and 100
foot buffer delineated by the Army Corps on the southern parcel should be restored rather than
paved over. Agricultural use of the southern parcel has been sporadic; no crops were planted this
year, yet the land has continued to be plowed and disked. This activity is likely designed to prevent
the reestablishment of wetland plants in the areas previously delineated by the Army Corps. LCP
housing policies do not override resource protection policies of the LCP and Coastal Act. More
specifically, affordable housing law does not supersede the requirements of the Coastal Act, and
nothing in the LCP housing policies supersede or overrule its resource protection policies.
9. The project would impermissibly convert prime agricultural soils on both parcels to to non-
agricultural uses. While the LCP does not designate or zone the two sites as prime agricultural
lands due to their location within an urban area, Coastal Act Section 30241 requires that the
maximum amount of prime agricultural land shall be protected as a resource and maintained in
agricultural production. Wetlands and other Environmentally Sensitive Habitat Areas (ESHAs)
within the urban area are similarly protected as a resource. LCP Policy 1.3.b. recognizes that in
order to make a logical urban rural boundary, some land, specifically prime agricultural soils and
sensitive habitats, has been included within the urban boundary which should be restricted to open
spaces uses. All of both sites are mapped as prime soils; a portion of both sites comprises wetlands
as well.
10. The project proposes to locate new development in areas of geologic hazard, which includes
very strong to very violent shaking during an earthquake due to the close proximity to the Seal
Cove/San Gregorio fault, seismic hazards, including the potential for liquefaction, sand boils, and
cyclic densification, and the presence of expansive near-surface soil. The EIR identified possible

November 10, 2010
Page 8 of 10
mitigation measures, but impermissibly deferred specific mitigation measures to future studies.
Without this information, it is not possible to adequately evaluate either the adequacy of measures
or whether they would create additional impacts. Therefore, the County cannot make the findings
necessary that the project complies with the Hazards component of the LCP.
11. Buildings or development that are used primarily by “physically or mentally infirm persons”,
as well as hospitals, nursing homes, and schools are not allowed in a Tsunami Inundation
Hazard Area per Section 6326.2 of the County’s Zoning Regulations and LCP Policy 9.3. This
Zoning Regulation is clearly for protection of these special needs people, as well as persons in
schools and medical facilities and is not discrimination against them. The Wellness Center, whether
a housing site or a Sanitarium, is prohibited from locating in the tsunami inundation hazard area.
12. The Wellness Center and Office Park do not comply with the Visual Resource Policies of the
LCP. LCP Policy 8.5 requires that new development be located where it is least visible from State
and County scenic roads to reduce impacts on views from public viewpoints, and to best preserve
the visual and open space qualities of the parcel overall. Policy 8.6 requires new development to
retain the open space natural qualities of streams, wetlands, riparian habitats, and estuaries, such as
Pillar Point Marsh and adjacent wetlands and riparian areas. Massive three-story buildings up to 46
feet high, adjacent to these biologically and visually sensitive areas are inconsistent with the visual
resource policies, and are in direct conflict with LCP Policy 3.13 addressed in #4 above.
The necessary Findings that the use of an on-site well, water treatment system, and onsite sewage
treatment plant are in compliance with the General Plan and LCP cannot be made.
General Plan Policy 10.10 discourages the use of wells to serve urban uses; and Policy 11.5 considers
sewerage systems to be the appropriate method of wastewater treatment in urban areas. LCP Policy 1.3
defines urban areas as “served by sewer and water utilities” and Policy 1.18 directs new development to
urban areas to (2) “maximize the efficiency of public facilities, services, and utilities.” The on-site water
and sewer systems duplicate existing public community water and sewer systems that serve the area. The
project is within the General Plan and LCP-mapped service areas of the Montara Water and Sanitary
District, (MWSD) and the Granada Sanitary District (GSD). The project proposes to connect to GSD but
only pay for eight ERU’s (1,768 gallons per day) which is wholly inadequate considering the Project
proposes that the GSD provide for emergency backup wastewater treatment and disposal of 26,000 gallons
per day. The MWSD serves the adjacent Pillar Ridge Mobile Home community, and has stated its interest
in serving this project. Duplication of public services is redundant and does not “maximize the efficiency
of public facilities, services, and utilities” as required by LCP Policy 1.18. Approval of on-site water and
sewage treatment systems for this project could become an unwise precedent for approval of other on-site
plants within the service areas of the Midcoast’s sewer and water agencies. This would place an unfair
burden on public agency customers, who would end up paying an excessive share of the capital and
operational costs of the public systems.
The necessary Findings for Approval of the Vesting Tentative Maps for both parcels cannot be made
under the County Subdivision Regulations.
The Subdivision Regulations, Chapter 3, Article 7, Section 7027 “Requirements for Sewage Disposal
(GSD) states that for subdivisions in urban areas, connection to an existing sanitary sewer system shall be

November 10, 2010
Page 9 of 10
required. (Section 7027.2.a.(1) ) Exceptions to this requirement may only be granted by the Planning
Commission if all of the following Findings can be made: (Chapter 5, Article 3, Section 7096)
1. That there are special circumstances or conditions affecting the property, or the exception is necessary
for the preservation and enjoyment of substantial property rights of the owner/subdivision;
2. That the exception is appropriate for the proper design and/or function of the subdivision; and
3. That the granting of the exception will not be detrimental to the public health, safety, or welfare or
injurious to other property or uses in the area in which the property is located.
Finding #1 above cannot be made. There are no special circumstances affecting the property, nor is the
exception necessary for the enjoyment of substantial property rights. The project proposes to build up to
three Membrane Bio Reactor (MBR) on-site sewage treatment plants, direct any excess recycled
wastewater into the GSD system, and rely on the GSD for emergency backup wastewater treatment of up to
26,000 gallons per day, while only paying for 8 ERU’s (221 gallons per ERU which equals 1,768 gallons).
Presumably the requirement for connection to the sanitary system carries an obligation to fully pay for the
service, which in this case is not being adhered to. Granting an exception that allows a duplicative on-site
sewage treatment system would place an unfair burden on GSD customers, as stated above.
Similarly, the Subdivision Regulations, Chapter 3, Article 3, Section 7024 “Requirements for Water
Supply” requires an adequate and safe supply of water to all parcels in the subdivision. In urban areas
domestic water shall be supplied by connection to an existing water supply system, unless infeasible. The
Staff Report allows formation of a mutual water system and conversion of an agricultural well to domestic
use unless and until connection to CCWD (which is not the correct provider under the LCP – see previous
comments). Once the project installs expensive water supply, treatment, and distribution systems under a
mutual water company, there will be no incentive to connect to the public system.
The Subdivision Regulations require that the subdivider provide all facilities needed to provide water
supply of sufficient volume and pressure for fire protection in conformance with the Fire District’s
requirements. The Fire Marshall has commented on the DEIR stating that swimming pools and
underground cisterns shall not be considered as a primary water storage source for fire protection.
Appendix K of the Final EIR proposes using the indoor swimming pool as the water storage source.
The necessary Findings regarding the Project’s compatibility with the Airport Land Use Plan and
California Land Use Planning Handbook cannot be made; approval of the Wellness Center would
jeopardize federal funding for the Airport
The Staff Report does not include any Findings regarding project compatibility with the County Airport
Land Use Plan. The ALUC staff has deferred any review by ALUC to the Planning Commission regarding
compatibility. The Wellness Center’s location is incompatible with the safe operation of the Half Moon
Bay Airport; County approval could jeopardize federal funding for the airport. Both the FAA and Caltrans
Division of Aeronautics have objected to placing housing for developmentally disabled individuals so close
to the airport, and further cite the County’s acceptance of the FAA grant assurances which could
jeopardize future FAA funding for airport improvements if the County approves this project. Ms.
Sandy Hesnard of the Caltrans Division of Aeronautics also points out that the developmentally disabled
individuals who would reside in the units are considered a “sensitive use” according to the California
Airport Land Use Planning Handbook, which states: “certain types of land uses are also regarded as
requiring special protection from hazards such as potential aircraft accidents”. The Handbook recognizes

November 10, 2010
Page 10 of 10
that “society normally seeks a high degree of protection for certain groups of people, especially children
and the infirm.” Ms. Hesnard further states: “a common characteristic among these groups is the inability
to move out of harm’s way, either due to inexperience or physical limitations.” The FAA and Caltrans
Division of Aeronautics comments regarding the incompatibility of the Wellness Center with the Half
Moon Bay Airport are compelling.
In summary, CGF believes that the EIR is fundamentally incomplete and inadequate, is nonresponsive to
numerous comments and questions from the public and responsible agencies, and must be revised and
recirculated. Unless the Project is substantially revised, and a complete and accurate revised EIR is prepared
and recirculated, your Commission cannot make the necessary Findings that the Project complies with the
General Plan, the Local Coastal Program and the Zoning Regulations, including Design Review.
Furthermore, the Findings for approval of the Use Permit and Vesting Tentative Maps cannot be made.
Finally, the project is fundamentally incompatible with airport safety and operations, and would place a
vulnerable population at risk of both manmade and natural hazards.
Therefore, CGF urges you NOT to approve the Project as currently proposed.
Thank you for your careful attention and consideration of our comments.
Sincerely,
Lennie Roberts, Legislative Advocate

Home Office: 339 La Cuesta, Portola Valley, CA 94028
Phone: 650-854-0449
FEIR - Big Wave Page 1 of 1
FEIR - Big Wave
From: "Lennie Roberts" <lennie@darwin.ptvy.ca.us>

Date: 10/15/2010 7:57 AM
Subject: FEIR - Big Wave
CC: "Winter King" <king@smwlaw.com>, "Laurel Impett" <Impett@smwlaw.com>
Hi Camille,
I received the Notice of Availability of Final EIR for the Big Wave Project yesterday by mail.
I'm stunned to see that the Planning Department is now allowing only eight working days for review of
the FEIR (12 calendar days if you count today when the document will presumably be put up on the
County web site). This is extremely disappointing, and will not give the interested public, affected
agencies, and the Planning Commission members adequate time to review the document.
As I said in my letter of October 10, the Big Wave project is enormously complex, and proposes many
different land uses in an environmentally sensitive area. The DEIR was over 2,000 pages long, and
elicited 245 comments from members of the public and relevant agencies.
You had previously talked about a 20 day review period. What is the rationale for truncating that?
I would like to pick up a hard copy of the FEIR today, if possible. Could you please let me know if that
is possible?
Thank you.
Lennie

Page 1
From: "Leslie OBrien" <leslieob@sbcglobal.net>

Date: 10/25/2010 1:37 PM
Subject: Big Wave Development Proposal
As a resident of the Seal Cove area of Moss Beach, I wish to request several items for the proposed Big
Wave development:
- No less than 60 days to review the Final EIR. There is not enough time to read and analyze the volume
of material presented to be sufficiently informed on the issues and proposals in this document.
- Story Poles be erected for all the buildings — with orange netting
and left up during the entire public review period.
-Leslie O'Brien
75 Precita Ave.

October 11, 2010


Re: Big Wave Project FEIR: Request for 60‐day Public Review & Story Poles


On behalf of the Pillar Ridge Homeowners Association, I am requesting a 60‐day public review
period for the Big Wave Project FEIR in order to give concerned citizens and public agencies
sufficient time to review and comment on this large and complex project.

We very much appreciate the efforts to hold the Planning Commission hearing on the Coastside.

We would also like to stress the importance of story poles during the review period for all
proposed structures. We note that this year’s crops have been harvested and the tenant farmer
has never grown a winter cash crop on these parcels.

Thank you for your consideration of our request.

Sincerely,

Lisa Ketcham, President
Pillar Ridge Homeowners Association
175 Culebra Ln.


Page 1 of 1
Re: Big Wave Final EIR - Now Available at the County's Planning & Building
Website
From: "Lisa Ketcham" <lisa.ketcham@comcast.net>

To: "Camille Leung" <CLeung@co.sanmateo.ca.us>
Date: 10/19/2010 1:15 PM
Subject: Re: Big Wave Final EIR - Now Available at the County's Planning & Building Website
Camille,
The final EIR NOA states, "The Office Park property (northern parcel) would consist of four, three-
story buildings..." whereas the 10/27 public hearing agenda asks for consideration of a 10-lot
subdivision and CDP for 8 buildings.
Do you know if the story poles on the Office Park parcel are meant to represent two of the modified
Alternative C buildings, or one of the 4 larger project buildings? Looking at them, I am unable to figure
it out as they are very hard to see and give no sense of volume. Do you know how tall the Office Park
story poles are meant to be if they are Alternative C?
Thank you,
Lisa Ketcham

Pillar Ridge Homeowners Association 1
Big Wave Project FEIR comment

October 26, 2010
455 County Center

Re: Big Wave Project FEIR

On behalf of the Pillar Ridge Homeowners Association, I submit the following comments on the Big
Wave Project Final EIR and the staff report for the 10/27/10 public hearing. Due to the extremely short
public comment period for such lengthy complex documents, our comments are necessarily rushed and
incomplete. Please extend the public comment period to a minimum of 60 days to allow a more
complete review. Please require complete story poles with the standard visible orange mesh during the
entire review period.

Visual Impacts
Story poles were constructed only 5 days before the final EIR hearing with only half the buildings
represented, and strung with thin sagging tape that is not visible from scenic viewpoints except for
Airport St. Three days later some of the tape has already fallen down. After going to the trouble of
raising the tall corner poles, one wonders why the standard visible orange mesh was not used, unless it
was to avoid increased public awareness of the out‐of‐scale size and visual impacts of the project.

The following 3 photos were taken 10/21 ‐ 25 and the story poles/tape have been enhanced so you can
see them. Although the story poles only represent half the proposed buildings, they demonstrate some
of the scenic vistas that are blocked and the large out‐of‐scale mass of the buildings.


How tall are the story poles and do they represent raised grade and roof structures? We are told the 2‐
story office buildings will be 36 ft tall, and 3‐story buildings 46 ft tall, which is much taller than normal
for that number of stories. Visual (and other) impacts would be reduced by shorter buildings. The
inadequate EIR response is to leave this mitigation to the Design Review officer.


Important scenic viewpoints were ignored in the EIR evaluation and responses to our comments (185‐
19, 185‐21), incorrectly state that our suggestions were similar to those analyzed. The inadequate story
poles make it impossible to fully assess distant significant visual impacts caused by the project. The
views below represent open space from shoreline to mountain top and demonstrate the fallacy of
referring to this project as “infill”.

Buildings over 28 ft tall would be out of scale and view‐blocking at this site. Existing Coastside M‐1 zone
buildings are no taller than 2‐story, 24 feet, otherwise surrounded by preserved open space and open
airport fields. FEIR response references 3‐story buildings on the far side of Princeton, out of sight of the
project. Even those 3‐story buildings are no more than 36 ft tall. (comment 185‐25)

Impacts of blocked scenic views are not mitigated by planting tall trees which themselves block views.
Most of the tall perimeter trees in the plan are deciduous so would only hide the buildings half the year.

Landscaping
EIR Response to our comment 185‐13 ignores our stated concerns about project perimeter tree species
not being adapted to our local heavy fog and strong salt‐laden winds. Sycamore is very susceptible to
anthracnose which would be greatly exacerbated by our moist foggy conditions. Our local strong salt‐
laden winds will cause leaf burn, twig dieback and reduced growth in the project‐specified coastal
species which are naturally found in more protected forest locations.

The response does not adequately address our stated concerns that trees planted as proposed along the
property line with Pillar Ridge will impact our sewer and power lines at that location and will shade and
endanger our homes if they blow over. It is costly, impractical, unattractive, and unenforceable for trees
which naturally grow tall to “be maintained so as to not block the sun to the single‐story homes on the
northern side.” It makes more sense to plant appropriately from the start. The EIR response incorrectly
states that our sewer pipeline is PVC which is more impervious to root intrusion, whereas, in fact, this
last largest section carrying all sewage exiting our community is clay, dating from 1963. Water‐loving
trees in the project plan, such as alder, sycamore, maple, should be located 100 feet from Pillar Ridge,
near the office buildings.

The “90% Basis of Design – Riparian & Water/Wetlands Ecosystem Restoration” report makes no
mention of the straight row of tall perimeter trees along the Pillar Ridge and Airport St. boundaries
other than their depiction on the site plan and the take‐off list of plants, but it is our understanding that
their purpose is to mitigate visual impacts by concealing the buildings. Therefore, they would still fill
their purpose if planted in a more natural arrangement closer to the buildings. That would also fit better
with the Local Coastal Plan which calls for tree and plant material native to the area, informal character,
smooth transition (not a straight narrow row with abrupt transition).

New Table IV.N‐3 (Vol. 1, p.III.B‐37) “Plant Recycled Water Demand” shows upland plants require twice
as much irrigation water in the wet season (11,000 gpd) as in the dry season which doesn’t make any
sense at all except that the project sponsors need to dispose of the recycled water.

Wetland Restoration There is no requirement as to when wetlands restoration will occur. Revegetation
is the best form of erosion control. Wetlands restoration should be required at completion of rough
grading and wildlife barriers moved back closer to the buildings enabling the long process of recovery to
begin. (comments 185‐9, 10, 28 – not answered)

Expansive Soil/ Water Infiltration Systems/ Grading
There are project inconsistencies in grading estimates and soil import/export requirements. Geology
studies identify the approximately 2‐feet‐deep surface soil layer as expansive and impermeable and thus
unsuitable for building pads and parking lots. If removed as recommended, we asked where it would go
on site (in wetlands/buffer?), and how would building pads achieve their raised grade without importing
suitable fill? (comment 185‐29) The EIR response confirmed the soil would be put in the
wetlands/buffer, claiming this is for creating “micro‐topography” per the Wetlands Ecosystem
Restoration report. Given the relative areas of parking lot and wetlands/buffer, that’s an awful lot of
“micro‐topography”. The phasing of the project outlined in the Development Agreement indicates both
Wellness Center and Office Park sites would be rough graded in Phase I, but there is no phasing
indicated as to when the wetlands on the Office Park would be restored. Placing grading spoils in
wetlands and their buffers is not an allowable use under the LCP.

Conflicting information in new Table III‐9 (Vol. 1, p. III.A‐28) “Grading Estimates” makes no mention of
wetlands/buffer zone, but shows Wellness Center parking & building pads have no cuts, leaving all
impermeable expansive clay in place, and piling on more of the same (11,000 cy) from the northern
parcel. The northern parcel as well appears to keep most of its impermeable clay on its parking and
building pads. This is contrary to the stated goal of removing this unsuitable soil from building pads and
permeable parking lots.

Changes to Project Description, Summary, D. Stormwater Drainage (p.III.A‐5) describes eliminating “rain
gardens” and adding roof runoff to parking lot infiltration system. In describing the adequacy of this
system, it is stated that the “underlying soil ha(s) a permeability of one‐half inch to 1 inch per hour.”
This is a crucial figure upon which the whole system depends and which has not yet been determined by
any permeability tests. (comment 185‐30 – inadequate response)

Drainage/Flooding
We have reiterated our concern about the Pillar Ridge Community’s vulnerability to massive flooding if
Big Wave northwest culvert should fail or become blocked since the natural drainage at that location is
blocked by the raised roadbed which Big Wave calls their North Trail. We supplied pictures of the badly
corroded culvert and past flooding that occurred when the Big Wave North Trail was cleared in
December 2005 and the mud/debris dumped in the culvert outfall. The EIR never mentions the
significant watershed drainage west of Airport St. and north of Big Wave which must drain through this
culvert. The EIR response was that this culvert on Big Wave property has nothing to do with the project.
With all that the residents of Pillar Ridge will have to endure with the construction of this project, it is
disappointing that there is no effort to address this relatively small issue for Big Wave (but important to
us). (comment 185‐34)

Reflected Noise
As a whole, our community is fairly stoic about airport noise. We recognize the importance of the
airport and knew what we were getting into when we moved here. However, adding in the
amplification and new direction of reflected noise off tall Office Park buildings seems like cruel and
unusual punishment.

The EIR does not address impacts of single‐event aircraft take‐off noise reflecting off tall office buildings
toward the residences at Pillar Ridge. Without studies or references, the EIR response makes the
assumption that this effect would only be directed at the propane service yard at one corner of our
community. (comment 185‐36)

Following is a quote and figure from www.acousticalsurfaces.com.

“When a sound wave travels outward in all directions and encounters an obstacle such as a wall, floor or
ceiling surface the direction of the sound will be changed or reflected. The direction of travel of the
reflected sound will be at the same angle as the original sound striking the surface as shown in (FIGURE
10). The immediate effect of multiple reflections is an increase in the sound intensity caused by the
reflections. A listener will hear the direct sound arriving at the ear along with all of the multiple
reflections. Thus the combined loudness of the direct sound and the reflected sound will be greater than
the direct sound alone.”


Since airplane take‐off noise is not a single location but travels along the runway, and the Pillar Ridge
homes lie over a 22‐acre area, the increased airport noise from reflection would cover a large area and
be a significant impact for us. To say that some future trees may grow 50 feet tall, or that our 6‐foot
perimeter chain link fence will buffer any noise reflected off 46‐foot‐tall buildings to our single‐story
homes is grossly inadequate. Trees generally do not attenuate sound.

Traffic
Inadequate indirect access roads for a project of this size cannot be mitigated by cramming a left‐turn
lane into already narrow Prospect Way, future traffic studies, and potential offsite parking outside the
bottlenecks of Cypress and Prospect. Where would this offsite 50‐car lot be? Using public parking at
the visitor‐serving harbor? For this idea to attract users the shuttle bus would need to run continuously
and would itself add to the traffic. It’s as though this project were in the heart of a city and offsite
parking in out‐lying areas were needed to support the prime location. The Project proposes to flood the
prime visitor‐serving harbor area with office park traffic totally unrelated to Coastal Act priority uses.

Due to traffic impacts, Big Wave promises to limit Wellness Center retail services to project occupants.
This will limit their potential for success, is contrary to their project goals, and is unenforceable – more
evidence that this site is inappropriate for the project. The parking is further reduced, and allots no
space for visitors to the residents (revised Table IV.M‐10 (Vol 1, p.III.B‐28).

Transportation Hazards
Greatly increased traffic in Princeton where streets are narrow and there are no sidewalks will increase
danger, noise and fumes for Coastal Trail bike riders, and for pedestrians and bicyclists from Pillar Ridge
as they walk and bike to work, school and shop. The proposed trail mitigation along Airport St. helps
only in that location, and needs its own bridge across the creek that drains the airport land. There is not
enough room to squeeze it into the roadway and protect it with K‐rail, even though the EIR response
calls this a potential “traffic calming” device. Traffic calming is generally not done with lethal concrete
barriers. (comment 185‐49)


The EIR does not adequately weigh the Project impacts on the narrow congested road segments for
disaster evacuation. It is unrealistic to assume that everyone in Princeton and the Office Park will
evacuate in an orderly manner on foot. (comment 185‐44)

Parking
The Project has already dramatically reduced its parking requirement by calling office buildings mixed
use. Conditions in Princeton, where there are many violations of zoning and planning laws, suggest that
the County does not have the will or resources to monitor the proportion of uses. Parking restrictions
for Office Park parking lots in an effort to promote car pooling or transit use will also impact local streets
with more on‐street parking. Any further reduction in parking requirements via a parking exemption
should not be allowed. (comments 185‐46, 50 inadequate response)

Alternatives
Most of the impacts of the Office Park could be reasonably solved by significantly downsizing the
buildings, but this solution is always rejected due to claims of economic infeasibility. However, this
project has been in the works since 2005. Well into studies and planning, as recently as 11/24/08, the
Office Park was 156,000 sq.ft. (per building permit application). It wasn’t until January 2009, with Draft
2 that the office park grew to 3‐stories, 225,000 sq.ft. Now we are told the 156,000 sq.ft. office park is
not economically feasible as an alternative. That assertion strains credibility.

The 10/27/10 Planning Dept. staff report, p.28, under Housing Component states (emphasis added),
"The revenue from the 225,000 sq.ft. Office Park would allow a portion of the Wellness Center units to
be affordable to disabled persons living below the poverty line. The applicant estimates that, in the
instance where there is no demand for office space and none of the office buildings are built, the
Wellness Center would continue to provide housing to disabled adults, but the units would not be
affordable to disabled adults in the "extremely low" income category or those living below the poverty
line. However, the Wellness Center would still be affordable to the "low" or "very low" income
populations" (thus meeting County requirements for affordability). If the Wellness Center is built first
as proposed, the units would presumably fill with very‐low to moderate‐income residents and there
would be no over‐riding need for such a massively‐sized office park.

Please do not approve this project as currently proposed. Thank you for the opportunity to comment.

Sincerely,

Lisa Ketcham, President
Pillar Ridge Homeowners Association
175 Culebra Ln.
Page 1
From: "Lennie Roberts" <lennie@darwin.ptvy.ca.us>

CC: "Winter King" <king@smwlaw.com>, "Laurel L. Impett" <Impett@smwlaw.com>,...
Date: 11/10/2010 3:09 PM
Subject: CGF Comments on Big Wave
Attachments: Big Wave.PC.11=10=10.doc
Dear Camille, Attached are my comments on the Big Wave project,

which focus on primarily on the Staff Report, but also include some
specific comments on the Final EIR. Please forward these to the
Planning Commission.
You should have already received comments on the EIR from Winter
King, of Shute, Mihaly and Weinberger. As always, I will be happy
to discuss any questions you may have.
Thanks,
Lennie
From: "Merrill Bobele" <MLBobele@comcast.net>
To: "Camille Leung" <CLeung@co.sanmateo.ca.us>, <Planning-Commission@co.sanm...
Date: 10/26/2010 12:00 PM
Subject: SIERRA CLUB Comments: FEIR BIG WAVE
Re: PLN2005-00481 and PLN2005-00482/ Assessor's Parcel Nos. :

047-311-060, 047-312-040
Dear Camille Leung and Planning Commission:
The Coastal Issues Committee of the Loma Prieta Chapter, Sierra Club
requests an extension of the comment period which ends today. Ten days
is too short a period of time to respond to the sheer volume of the FEIR
and number of changes. It seems a rather small request in view of the
amount of time spent on all the hearings, public meetings and documents
that are the previous record. The approval process is designed to be
slow in order to satisfy many legal requirements. It makes no sense to
now put the proposed project on fast track, when the applicant could
have saved a lot of time and money in submitting a more acceptable
DEIR. To assist the public in preparing comments, again we request that
story poles for the entire properties be constructed and left up during
the extended comment period.
Sincerely,
Merrill Bobele, Co-Chair

Coastal Issues Committee Loma Prieta Chapter, Sierra Club
650-726-6429
-------------------------
STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY ARNOLD GOVERNOR
CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST IJISTRICT
45 FREMONT, SUITE 2000
SAN FRANCISCO, CA 94105-2219
VOICE AND TOO (415) 904-5260
FAX (4 15) 904-5400
October 26, 2010
Camille Leung
County of San Mateo
RE: Final Environmental Impact Report (FEIR) for Big Wave Wellness Center and
Office Park (SCH No. 2008102109; PLN 2005-00481 and PLN 2005-00482)
Dear Ms. Leung:
Thank you for the opportunity to comment on the Big Wave FEIR. The FEIR includes additional
information and several project modifications that address some of our comments on the Draft
EIR. However, we still have significant concerns about the proposed project and have identified
several potential inconsistencies with the certified Local Coastal Program (LCP) and the public
access and recreation policies of the Coastal Act. In addition, the FEIR does not include all of the
information necessary to evaluate the project for consistency with the aforementioned policies.
The following is a brief summary of our primary concerns. We urge the County to address these
issues before acting on the coastal development permit (CDP) application.
Zoning Regulations
The project site is located in the Waterfront zoning district. The purpose of this district is to
provide for a working waterfront area that serves marine related industries, and to accommodate
compatible recreational and resource management uses. The proposed Wellness Center would be
a residential facility for developmentally disabled adults, which would provide its residents with
on-site caregivers and social and employment opportunities, in addition to connecting its
residents to support and medical services. Although the Wellness Center is not specifically
allowed in the Waterfront district, it could be allowed pursuant to Section 6500(d) of the zoning
regulations, if it is considered to be a "sanitarium." However, Section 6326.2 of the County's
zoning regulations, which is part of the certified LCP, prohibits the development of facilities that
are used primarily by "physically or mentally infirm persons" within tsunami inundation areas.
The Wellness Center would house and provide services, including residential aides, for 57
developmentally disabled adults, and, as shown in the DEIR, is located within a tsunami
inundation area. Therefore, although we understand the importance of such a facility to the
community, the proposed location is inconsistent with Section 6326.2 of the zoning regulations.
Water Supply
The proposed project is located within the County's urban/rural boundary and therefore, must be
served by public water utilities. LUP policies 1.3, 1.4, 1.16, and 1.18 direct new development to
existing urban areas to maximize the efficiency of public utilities. LUP policy 1.18 specifically
Camille Leung
Big Wave FEIR
October 26, 2010
Page 2
requires new development to be concentrated in urban areas by requiring infill development, and
LUP policy 1.19 goes on to define infill as development of vacant land in urban areas that is
served by sewer and water utilities. Moreover, LUP policy 2.14 clearly intends for urban services
to be provided in urban areas and not within rural areas. To be consistent with these policies,
development within the urban/rural boundary, including the project site, should be served by
public utilities. The County staffs recommendation for approval of the project addresses this
issue through recommended special condition 9, which requires the applicant to pursue a water
connection from Coastside Community Water District (CCWD). However, this condition would
allow for the permanent use of the private on-site well for potable water needs if a connection to
CCWD is not obtained. Therefore, the recommended project appears to be inconsistent with the
LCP policies sited above. We recommend that the County require that the proposed project be
served by public utilities, including a public water supply, prior to issuance of the CDP.
In addition, the County staffs recommended approval would allow the project to be served by
CCWD for fire protection purposes. This fire protection service would constitute an extension of
water services outside of the CCWD service boundary as defined on January 1,2003 and would
require amendments to Coastal Development Permits A-I-HMB-99-20 and A-2-SMC-99-63.
Sewer Service
The FEIR indicates that the on-site sewage disposal system has been eliminated. In the currently
proposed project, a portion of the wastewater generated by the project would be recycled and
reused on site, and the remainder would be disposed of through the public sewer system. The
project is served by an 8-inch sewer line and would obtain eight equivalent dwelling units of
sewer capacity from the Granada Sanitary District (GSD), which amounts to approximately
1,800 gallons of wastewater per day. In addition, GSD would provide emergency sewer service
to the project, in the event that the project's water recycling and/or reuse capacity is interrupted.
The DEIR states that it is unclear if the 8-inch line could physically accommodate the 26,000
gpd of wastewater that would need to be disposed of if the recycling and/or reuse capacity were
disrupted. I In addition, the DEIR states that the EI Granada pump station, which would need to
be used to transport the wastewater to the sewage treatment plant, may not be adequate to
accommodate the 26,000 gpd flow.
The policies of the LCP, including policies 2.8 and 2.21, require public works and sewage
capacity to be reserved for Coastal Act priority uses, such as marine related industrial uses and
commercial recreation. The proposed office park would accommodate general industrial
development and therefore, is not considered a priority use. Because wastewater generated by the
project may exceed the capacity of the sewer infrastructure, including the sewer lines and the EI
Granada pump station, it would not be consistent with these LCP policies.
I As discussed in the DEIR, Title 22 requires recycled water facilities to have the capacity to store or dispose of20
days worth of wastewater discharge. It is unclear if the GSD emergency hookup would provide sufficient treatment
capacity to accommodate this requirement.
Camille Leung
Big Wave FEIR
October 26,2010
Page 3
Traffic Capacity and Public Access
The project site is located between the first public road and the sea, and therefore, must be
consistent with the public access and recreation policies of the Coastal Act. Coastal Act sections
30210 through 30213 protect the public's right to access the coast and require maximum public
access to the coast to be provided and maintained.
The proposed office park would include a subdivision to create ten parcels in order to
accommodate the construction of225,000 square feet of office space in eight new office
buildings. The project would nearly double the existing office space in the Midcoast and would
add approximately 2,123 peak-hour vehicle trips to the road. All of these vehicle trips would
utilize Highway 1, and many would also utilize Highway 92. Both of these highways are at
capacity during peak commute and recreational times, which interferes with the public's right to
access the coast. Traffic congestion on Highways 1 and 92 significantly interferes with the
public's ability to access the area's substantial public beaches and other visitor serving coastal
resources in conflict with these policies. Therefore, any additional traffic on these roadways
would cause significant adverse impacts on the public's ability to access the coast, which is
protected under the public access and recreation policies of the Coastal Act. To determine the
consistency of the proposed project with these policies, as well as the policies ofthe LCP, we
recommend that the County fully analyze the impacts of the project on existing and future traffic
conditions on Highways 1 and 92. Such analysis should include an evaluation of impacts on the
level of service (LOS) for road segments on Highways 1 and 92, as required by LUP policy 2.49,
in addition to impacts on intersection LOS. Any impacts that degrade the traffic LOS below the
requirements ofthe LCP should be avoided through project modifications or conditions of
approval.
Aesthetics
The Visual Resources component of the LCP regulates development to protect the visual
resources of the County's coastal zone. LCP policy 8.5 requires new development to be located
to be least visible from State and County scenic roads, to reduce impacts on views from public
viewpoints, and to preserve the visual and open space qualities of the parcel. In addition, LCP
policy 8.6 protects the visual resources of streams, wetlands and estuaries.
The project site is located adjacent to Pillar Point Marsh and would be visible from the harbor,
Airport Road, Highway 1, several hiking trails, and other viewpoints. The project has the
potential to obstruct views of ridgelines and significant open space areas, including Pillar Point
Marsh. The proposed two and three story project appears to be oversized for the area and its
mass and scale could cause significant visual impacts, inconsistent with the visual resources
policies of the LCP, including those policies sited above. We recommend that the County
consider reducing the footprint and height of the development to avoid impacts to these
important coastal resources.
Camille Leung
Big Wave FEIR
October 26,2010
Page 4
Wetlands
Portions of the project site appear to contain tidelands and public trust lands, which are subject to
the Commissions retained permit jurisdiction authority. There are also wetland areas that are
located in the County's permit jurisdiction. The applicant must obtain a coastal development
permit approval from the Commission prior to any development in the Commission's original
permit jurisdiction. Development in the wetlands and wetland buffers in the County's
jurisdiction is restricted by the Sensitive Habitat component of the LCP. LCP policy 7.14 defines
wetlands; LCP policy 7.16 limits the uses allowed in wetlands; LCP policies 7.18 and 7.19
establish wetlands buffer zones and limit the uses allowed in them; and LCP policy 7.20 provides
specific protections for the Pillar Point Marsh. Our comments on the DEIR, dated December 23,
2009, identified several concerns about the wetland delineations and biological studies.
Unfortunately, given the short period allotted to review the FEIR, we have not had an
opportunity to carefully review the response to our comments. However, after a brief review, it
appears that not all of our concerns have been addressed. We urge the County and the applicants
to continue to work with us to ensure the wetlands delineations and biological reports are
adequate for the purposes of the Commission's review of the project. Further, we note that the
native plant nursery proposed to be located within the wetlands buffer appears to be prohibited
by LCP policy 7.19 ifit would have any impacts on the adjacent wetlands.
Conclusion
In summary, we urge the County to delay action on the proposed project until all of the
information necessary to evaluate the project for consistency with the LCP and the public access
and recreation policies of the Coastal Act is available. After this evaluation is completed, any
inconsistencies with the standards of the LCP or the Coastal Act should be addressed through
project modifications or conditions of approval so that the project avoids significant adverse
environmental impacts and conforms to LCP and Coastal Act requirements.
If we are provided with additional time to review the changes to the project, we may be able to
provide more detailed comments regarding the proposed project's impacts on coastal resources,
including biological resources and flooding and geological hazards. If you have any questions, or
wish to discuss this project further, please feel free to contact me at (831) 427-4863 or
mcavalieri@coastal.ca.gov.
Sincerely,
~,;;;;;;) (for') .' '
Madeline Cavalieri , 0/,-1
Coastal Planner
North Central Coast District
cc: Scott Holmes

Nicole DeMartini
Page 1 of 2
- Big Wave FEIR
From: "Matthew Clark" <mrccrm@comcast.net>

To: <Planning-Commission@co.sanmateo.ca.us>, <cleung@co.sanmateo.ca.us>
Date: 10/26/2010 10:46 AM
Subject: Big Wave FEIR
Dear Commissioners and Ms. Leung,
I see that the concerned public, other government agencies, and environmental groups have been given a
nominal 12 days to read, absorb, review, and respond to the THREE VOLUME Final EIR for the
proposed Big Wave Project in Princeton/Moss Beach. Nominal because when I received notice of the
FEIR availability, it was not in fact on the Planning website as stated in the NOA. How can anyone be
expected to knowledgeably respond to such a massive document in such a short time?
I think Planning should have given at least 30 days and even better twice that for review of this
document. Beyond that, it appears, not having had time to truly peruse the FEIR but having glanced at
specific portions, that the FEIR presents so much information and so many changes--or maybe not
"changes" as in many cases it is difficult to tell whether new wording actually constitutes real changes--
that the FEIR should have been completely recirculated as a Revised DEIR, precedence for which under
CEQA procedures is abundant. The entire supposedly CEQA-compliant procedures for this problematic
proposed development have given the unfortunate impression that the County is actively pushing the
project rather than providing the neutral analysis mandated by CEQA, so Planning appears to be "doing
favors" rather than serving the public interest.
From a necessarily very quick review, two comments I believe are typical of many more that could be
made with enough time:
The FEIR in at least several places essentially kicks analysis and mitigation measures down the road, to
be specified, analyzed, and implemented at later times. This is simply not allowable under CEQA, as
the writers and County surely know. EIRs cannot say "we don't know what the project actually is, nor
what the potential impacts are, nor do we propose mitigation for those unknown impacts, but certify the
environmental documents and start giving us permits and THEN we'll start to reveal the actual projects
and come up with mitigation, maybe..." The County must therefore reject the FEIR and not certify it.
Again, on quickly going through the FEIR, one finds an appended comment letter from Western-Pacific
Region of the DOT Federal Aviation Administration (July 8, 2010), which states:
"The presence of a center for the developmentally disabled that is so close to the runway [of Half Moon
Bay Airport] represents a use that is not compatible with normal airport operations. Therefore, it is our
determination that the selected site is not appropriate. An alternative site outside HAF's influence area
should be used for the Center.
San Mateo County is reminded of the requirements of Assurance 21, Compatible Land Use. Airport
sponsors are required to take appropriate action to restrict the use of land adjacent to the airport to
activities that are compatible with normal airport operations. Clearly a clinical residential center serving
disabled patients would not be considered a compatible use so close to the airport and its runway."
Topical Response 14, on the airport concerns, states that the County acknowledges that Runway
Page 2 of 2
Protection Zone 2 has not been defined and gives an example of how RPZ 2 could be defined as not
covering the project parcels. But no authoritative agency is cited as concurring with use of the
designation example the County uses for that definition; the County does say the Airport Land Use
Commission would have the final say in determining the dimensions of RPZ 2, but not that the County
will actually implement that process before, during, or after certification of the FEIR or actual
construction of a project that could put developmentally disabled people in a potentially dangerous
runway zone. The Topical Response then goes on to equate the FAA stating that the project is not
compatible with normal airport operations with potential problems with excessive noise, which the EIRs
claim is adequately mitigated, while a close reading of the FAA letter shows that the noise question is
another, separate concern expressed by the FAA after flatly stating the project is not a compatible use.
These are but two examples of why the Big Wave FEIR should not be certified by the County. Again,
thorough analysis of the thousands of pages of CEQA documents for the project would, as with the
DEIR, reveal many such problems and inadequacies. I ask that the time allotted for analysis and
response to the FEIR be extended and that more than one public meeting be held to consider those
analyses and hear from concerned parties.
Cordially yours,
Matthew R. Clark
PO Box 652
El Granada, CA 94018
11/16/20
Page 1 of 1
"Big Wave" EIR Commentary
From: "Mike Ferreira" <michaeljferreira@gmail.com>

Date: 10/26/2010 4:57 PM
Subject: "Big Wave" EIR Commentary
CC: <planning-commission@co.sanmateo.ca.us>
Dear Ms. Leung,
At its regularly scheduled monthly meeting on Monday, October 25, 2010, the Sierra Club Loma Prieta
Chapter's Conservation Committee (consisting of 14 separate conservation issue committees) discussed
the current Big Wave EIR document package and came to the unanimous consensus that there just hasn't
been enough time to formulate a considered response to this rather large document. Accordingly, I have
been asked to submit a request to your department and to the Planning Commission for a more
reasonable amount of time in which to thoughtfully respond and hereby do make that request.
Thank you for what we trust will be your cooperative response to this entreaty.
Mike Ferreira
Chair - Sierra Club Loma Prieta Chapter Conservation Committee
Page 1 of 1
- HMB resident input on Big Wave proposal
From: "Hagmaier, Mike" <Mike.Hagmaier@lifetech.com>

To: "commission@co.sanmateo.ca.us" <commission@co.sanmateo.ca.us>, "cleung@c...
Date: 10/19/2010 5:40 PM
Subject: HMB resident input on Big Wave proposal
Hello,

I am writing once again to voice my opposition to the proposed Big Wave project.

There are so many reasons why this project should not be approved, including the negative visual impact of the
structures (they will make the coast look like Oyster Point), the lack of local businesses to occupy all the business
space (there is already so much available business space in Half Moon Bay, and no one is moving in), and most
importantly; that the residential building for the disabled would be the last thing to be built.

I've browsed the EIR reports, which include a bunch of fine‐sounding promises, though often without details on
how or when they will be delivered on, but these are just words. I can live with empty words, but the San Mateo
coast cannot, and should not, have to live with a bunch of large, ugly, empty buildings blocking the natural
beauty of our coastline.

I don't believe a word the Big Wave developers are saying any more than I believe politicians or criminals who
say they're "cured". This comes down to a simple gut‐check. And my gut tells me it's a sham.

Sincerely,
Mike Hagmaier
Half Moon Bay, CA.
11/16/2010
- Stop Big Wave - deny approval and kill this project
From: "Marshall Ketchum" <marshallketchum@gmail.com>

To: <planning-commission@co.sanmateo.ca.us>, <cleung@co.sanmateo.ca.us>
Date: 10/24/2010 7:59 PM
Subject: Stop Big Wave - deny approval and kill this project
I've taken quite a bit of time to read through the EIR. It is simply amazing what people will do and say to get their way.
From 'Topical Responses' to the EIR
Web Link
Wetlands
Parts of the Big Pave site are still considered ‘wetlands’ and are supposed to be protected under their plan. The 'Wellness
Center' is sandwiched between the wetland buffer and the Airport Overlay (more on that later), tucked into the only part of
that lot they consider 'buildable'. Old maps show more wetlands on 'a large portion' of the Big Pave properties that are
currently slated for development. Page 43 of 'Topical Responses' details that apparently, if you are a 'farmer', you can fill in all
the wetlands on your property that you want with the County's approval, then convert your farmland into commercial real
estate. Conversely, if you are the City of Half Moon Bay and you fill in wetlands on private property, you loose $18M
judgments.
The impact of Big Pave on visual character and scenic resources would be heartbreaking
On page 2 of 'Topical Reponses', Big Pave indicates even though it was not required to, it 'has agreed to install story poles for
all Wellness Center buildings and for one of the Office Park buildings.' Mighty nice of them. Hope that didn't break the bank.
On page 17, they detail that in three of the four alternatives discussed, some or all office park buildings will be three stories
high. Back on page 2, Big Pave concludes "the impact of the project on visual character and scenic resources would be less than
significant". Yes, replacing a wetland on the Coast adjoining a marsh with a quarter million square feet of office space and 640
parking spaces may be 'less than significant' on scenic resources to anyone in San Mateo or Redwood City. To Coastsiders, the
impacts on 'visual character and scenic resources' are devastating. On page 39, they detail that the '20-year office park
completion timeframe' ... 'scenario, which appears the most likely based on current conditions...' This is just fantastic. We'll all
be treated to 20 years of on and off construction that will have ‘no significant scenic impacts’. Perhaps our grandchildren see
the completion of this project. Perhaps by then there will actually be a need for more commercial real estate, something anyone
who reads a newspaper realizes we have far too much of now already.
Tsunamis
Section 6326.2 of the San Mateo County code specifically prohibits "buildings or development used primarily by children or
physically or mentally infirm persons in a tsunami inundation hazard area." (page 32, 'Topical Reponses'). On page 29, Big
Pave admits that "the Big [Pave] project remains in the [tsunami] hazard zone." They then detail the tsunami response: "As a
response to a possible local source tsunami following a power local earthquake, staff and residents of the center should walk up
Airport Street towards Cypress Avenue immediately following the earthquake, as a tsunami could arrive in a matter of just a
few minutes. According to the latest inundation maps, the area north of the mobile home park and [sic]will be safe ground."
Page 30 details that this walk would be "approximately 2500 feet"
Airport Overlay
The California Airport Land Use Planning Handbook 'recommends ... prohibiting residential uses except on large, agricultural
parcels and limiting nonresidential uses to activities which attract few people' (page 45, 'Topical Reponses'). Pages 44-45 read
'although the project does propose structures within the airport overlay (AO) zoning district, the structures do not include
residential uses or uses with three or more persons occupying the use at onetime, as consistent with the AO setback
requirements.' The fact is no one has mapped the exact boundaries for Zone 2 of the airport overlay for this airport (page 45).
Big Pave has placed some airport boundaries on their plans as submitted. Big Pave has placed the Wellness Center residences
and Office Park buildings just a few feet outside the airport overlay on their property – the parking lots for both Big Pave
facilities are in the airport overlay. Page 49 reads 'based on past cases, the FAA representative believes that the wellness center
residents will complain about noise associated with the airport. Also based on past experience, the FAA representative states
that the public policy reaction to the complaints will be proposals to impose additional restrictions on normal airport
operations'
From 'Introduction' to the EIR
11/16/2010.
Web Link
Wind turbines and carbonate fuel cells
'Proposed utilities and service systems [at Big Pave] include.... solar cells for heating / energy; carbonate fuel cells...wind
turbines and generators; geothermal cooling systems.' Big Pave gives no details about the size of the wind turbines but the
diagrams do place their locations toward the back of the property. I could find no details about the 'carbonate fuel cells' at Big
Pave which isn't surprising because there are apparently zero commercial installations of 'carbonate fuel cells' worldwide -
these devices are so far at the 'science fair' or 'Avatar' stage of deployment. They might as well have proposed cold fusion
reactors.
Web Link
Web Link
From 'Changes to the Project Description' to the EIR
Shuttle Service
page 19: 'Prior to occupancy of any office park building, [Big Pave] will implement ... an off-site parking agreement and shuttle
services to the Office Park (to accommodate a minimum of 50 cars and their drivers).' 'BW transportation would require one
full time bus driver and 3 full time employees'.
How many office parks can afford their own shuttle service and off-site parking lot? Companies such as Google and Genentech
can afford luxuries such as employee shuttle service because they are very large and very profitable. We're lead to believe that
even with 640 parking spaces, some of the imaginary employees of this unneeded and unwanted office park would park
somewhere else and prefer to be shuttled to work. Exactly where will this single shuttle bus be shuttling to and from? Half
Moon Bay? San Mateo? San Jose? The reality is Big Pave would get the shuttle bus operational in order to get their occupancy
permit, then after not a single rider used the shuttle bus, a few weeks later they would terminate this service without penalty.
But if they put this work of creative writing into the EIR and it gets them their approvals and occupancy permits, that's clearly
all that matters to them.
Lastly I should point out that Big Pave will require both Sewer and Water permits that they do not yet have.
Summary
Big Pave has the nerve to tell us that "the impact of the project on visual character and scenic resources would be less than
significant". Nothing could be further from the truth. 'The impact of the project on visual character and scenic resources’ would
be devastating. The last thing the Coastside needs it a quarter million square feet of commercial real estate and 640 parking
spaces built in wetlands next to the ocean.
Big Pave is building a "development used primarily by children or physically or mentally infirm persons in a tsunami
inundation hazard area", which is clearly prohibited by County code. In response, they tell us it is reasonable to expect Big Pave
residents - developmentally disabled adults and their caregivers - to run or walk half a mile after a major earthquake to avoid
being killed in a tsunami. Seeing plans like this, one might infer that the people behind this project would literally say anything
to get it approved.
Big Pave is building in the Airport Overlay zoning district, which 'recommends ... prohibiting residential uses except on large,
agricultural parcels and limiting nonresidential uses to activities which attract few people'. Another clear zoning violation. The
FAA is already anticipating '[Big Pave] residents will complain about noise associated with the airport' and 'reaction to [noise]
complaints [from Big Pave residents] will be proposals to impose additional restrictions on normal airport operations'
Big Pave has demonstrated many times on multiple levels that they will say literally anything, no matter how unrealistic or
fictional, to get this unwanted and unnecessary project approved.
Telling Coastsiders that "the impact of the project on visual character and scenic resources would be less than significant" is
nothing short of insulting. It makes me very sad to think someone may start a 20 year construction project to build a quarter of
a million square feet of commercial real estate and 640 parking spaces in the middle of the wetlands next to the ocean.
Stop Big Pave - deny approval and kill this project.
I urge you to go out to Airport Boulevard and see the story poles they erected for Big Pave.
Thanks,
Marshall Ketchum
El Granada
\XPgr
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11/16/2010ing
Page 1 of 1
I - Opposition to Big Wave project
From: "Mary Larenas" <mnlarenas@gmail.com>

To: "Camille Leung" <CLeung@co.sanmateo.ca.us>
Date: 10/21/2010 4:12 PM
Subject: Opposition to Big Wave project
Dear Ms. Leung,
I realize that you are probably being bombarded with emails and phone calls re Big Wave. But I would
like to ask you to please EXTEND THE REVIEW PERIOD - 12 DAYS IS NOT AN ADEQUATE
AMOUNT OF TIME FOR SUCH A MONSTROUS PROJECT THAT WILL HAVE A HUGE
IMPACT HERE ON THE COAST. ALSO THE STORY POLES ARE TOTALLY INADEQUATE.
USING CAUTION TAPE INSTEAD OF THE ORANGE WEBBING DOES NOT GIVE A TRUE
VISUAL. Please on behalf of those of us who are going to be directly affected by this project, I ask you
to extend the review period and demand adequate story poles.
Thank you,
Dr. Mary Larenas
301 Nevada Ave.
650-728-5067
11/16/2010
Page 1 of 2
- Big Wave
From: "marylou9@earthlink.net" <marylou9@earthlink.net>

Date: 10/19/2010 5:33 PM
Subject: Big Wave
CC: <cgroom@co.sanmateo.ca.us>, "Richard Gordon" <rgorden@co.sanmateo.ca.us>...
Dear Ms. Leung,

I am distressed to see that the Midcoast Community Council wishes more time to review
Big Wave's Final EIR. They have had adequate time to find the loopholes they seek to
delay this project. In the meantime, it has been 10 years since the first discussion of
this project. My son, who has cerebral palsy, is visually impaired, and is in an electric
wheelchair, is now 27 years old and still living at home, because there are no viable
alternatives here on the Coastside to keep him integrated in the community he has come
to love, and be loved. He is fully immersed in the community in Half Moon Bay. People
don't know me- but I am now known as "Mark's Mother", and am greeted on the street as
such. Comments such as "what a great kid" warm my heart, and make my hard work
worthwhile.

Because there are no viable alternatives for disabled adults on the Coast, I am requesting
that you not delay for one more second the public hearing. October 27th is fine with me.

Mark weighs 210 lbs. and is non-ambulatory. He has developed seizures in the last four
years, which are now under control. I weigh around 140 lbs., and am still turning him
constantly at night, making sure he is adequately fed, and that his psycho-social needs
are being met. My shoulders have been frozen a few times from too much lifting. l
physically cannot keep my son at home much longer and do a good job. I am aging- just like
the rest of the parents who have children at home. I have been intimately involved in the
caregiver and provider side of the Big Wave Project, and am satisfied that Mark's
immense needs will be met, given adequate support. We have worked through many of the
provider issues, and I feel Mark will thrive in the environment with his friends and a
really good supportive living services worker.

In the course of researching the caregiver models for the last 8 years, we have seen
multiple examples of how adults like Mark can be well cared for, once their parents die.
And I am going to die. We, as supporters of Big Wave, have traveled throughout the
11/16/2010..
Page 2 of 2
United States seeking models of excellence. These young adults can thrive. We have the
knowledge among us to make sure these young adults will be well cared for, and are
totally dedicated to that cause. Every young adult that becomes part of Big Wave already
knows all the other young adults, and their very supportive parents. We are a very large
family, and resent the insinuations from the MCC that we don't know what we are doing.
We're going into this project with our eyes wide open, knowing there will be problems and
glitches,and having the faith that we as a group, will work through each and every
problem to the benefit of the kids living at Big Wave. We have a proven history through
C-Pals, and a proven history of Big Wave events for the last 10 to 13 years.

The more this project is delayed, the older I get. Do I have to wait until I'm 72 to finally
have an alternative?

Please- no more delays to the hearings.

Thank you so much for all your hard work and attention to details. You have done an
admirable job.

Respectfully,
Mary Lou Williams
470 Furtado Lane
Half Moon Bay, Ca. 94019
650-726-6754
marylou9@earthlink.net

11/16/2010...
800 Bancroft Way • Suite 101 • Berkeley, CA 94710-2227 • (510) 704-1000
www.balancehydro.com • email: office@balancehydro.com
Berkeley • Auburn • Santa Cruz • San Rafael • Truckee
November 10, 2010
County of San Mateo, Planning and Building Department

RE: Big Wave Wellness Center and Office Park Project DEIR Response to Comments
Dear Ms. Leung:
We would like to thank the San Mateo County Planning and Building Department for responding to our
comment letter dated December 24, 2009 regarding the Draft Environmental Impact Report (DEIR) for
the Big Wave Wellness Center and Office Park Project (Project). Our comments, submitted on behalf of
the Montara Water and Sanitary District (MWSD), identified significant concerns regarding the
inadequate reporting and analysis of potential impacts to water supply wells and the groundwater source
upon which the District relies.1 Our disagreement with the DEIR, and also with the responses to our
comment letter, involves three issues:
1. We provided comments clarifying: a) the range of groundwater fluctuations in the Airport

Aquifer experienced during the annual wet-season to the dry-season cycle, during multi-year
droughts, and especially near water supply wells; and b) how these fluctuations might impact the
supply of water to the proposed Project well. We also addressed the potential impacts of
pumping the Project well on other local wells in the Project area, such as the water supply wells
for the Pillar Ridge Manufactured Home Community (PRMHC). MWSD is especially
concerned about the cumulative impacts to these water supplies during multi-year droughts.
The response to our comments referenced the Phase II Midcoast Groundwater Report
(Kleinfelder, 2008), which concluded that “the Airport Subarea is in long-term equilibrium”. We
view this response as unacceptable and deficient in its understanding of the meaning of ‘long-
term equilibrium’. Balance Hydrologics closely reviewed the Phase II report and associated
project files, and we conducted the follow-up Phase III study in collaboration with the Resource
Conservation District and County Planning and Building. The Phase II study used a water
balance method to assess the long-term equilibrium of specific subareas. However, the study did
not perform the same ‘detailed water balance’ for the Airport Subarea that it did for the El
Granada Subarea, the Miramar Subarea, and the Moss Beach Subarea, which were based on an
annual water budget derived from a 55-year rainfall record (water years 1951 to 2005). Instead,
the water balance analysis for the Airport Subarea was simply based on annual averages (Phase II
report: Table 6), a method which did not assess year-to-year fluctuations and thus did not include
a drought analysis. Furthermore, the Phase II ‘long-term equilibrium’ water balance assessment
for the Airport Subarea was based on a basin-wide average, rendering it meaningless for
assessing drawdown impacts at the project scale.
2. We received no response to our request that a well-capture zone analysis be conducted to assess
the zone of impact from pumping the Project well throughout the dry season. The PRMHC is
connected to the MWSD distribution system and receives MWSD water when the PRMHC’s
1 Montara Water and Sanitary District (MWSD) operates water supply wells in the same aquifer from which the Big Wave Project
proposes to draw water, as does the Pillar Ridge Manufactured Home Community (PRMHC), located adjacent to the proposed
Project location, to the north. MWSD supplies treated potable water to the PRMHC when their water storage runs low.
Integrated Surface and Ground Water Hydrology • Wetland and Channel Restoration • Water Quality • Erosion and Sedimentation • Storm Water and Floodplain Management
Balance Hydrologics, Inc.
November 10, 2010
Ms. Camille Leung, Planner, County of San Mateo, Planning and Building Department
Page 2
own supplies are deficient. MWSD would be concerned if Project well pumping were to
interfere with the PRMHC water supply wells, and subsequently with MWSD sources,
particularly during droughts. As this analysis is a standard first-level approach to assessing
pumping impacts of wells on neighboring water supplies, we feel that our request is reasonable
and should be honored.
3. The responses to our comments referred to a description of the water supply well contained on
page IV.N-23 of the DEIR. This section includes Impact UTIL-9, Adequacy of Onsite Water
Well, which states:
“The applicant proposes to extend the existing 20-foot well seal to 50 feet to meet
requirements for a community water well, which will alter the hydraulic characteristics
of the well. Specifically, half of the existing well screen (from 20 to 50 feet) will be sealed
off, leaving the screened sections only between 50 to 60 feet, and from 80 to 100 feet.
This will materially alter the production capacity of the well, such that the results of the
recently completed pumping test are no longer valid. The production capacity of the
existing onsite well would be expected to decline. Consequently, the EIR assumes that a
repeat pumping test will be required by the County for the modified well to document its
adequacy to meet project water demands. It is not possible to determine whether or not
the modified well will have sufficient production capacity to meet project demands.
However, if the modified well is found to be insufficient, the capacity could be
supplemented with an additional well to meet the project demands. Review of the well log
indicates suitable aquifer conditions to support the water demands for the project. The
water quality for the existing onsite well is satisfactory and would not be expected to
change with the proposed modification of the well seal. Provision of potable water from
the onsite well represents a less-than-significant impact.”
In other words, the DEIR finding of a less-than-significant impact was based on the success of
drilling and permitting a new water well, which would require the approval of the California
Coastal Commission (CCC). However, the DEIR does not report results of any consultations
with the CCC regarding this Project, and it has been the MWSD’s experience that it is extremely
difficult to obtain approval of a new water well in the Airport Aquifer, particularly considering
the CCC-adopted (1994) limit of 459 acre-feet per year for groundwater extractions within the
subbasin. Based on this understanding, and in the absence of any evidence of prior consultation
with the CCC regarding their likely approval to drill a new well, we must strongly disagree with
the DEIR finding of a less-than-significant impact.
Sincerely,
BALANCE HYDROLOGICS, INC.
Mark Woyshner, M.Sc.Eng.

Principal Hydrologist/Hydrogeologist
cc. Clemens Heldmaier, General Manager, Montara Water & Sanitary District
205040.20 Big Wave hydrology section RTC reply 11-10-10.doc

Dear Ms. Leung:
These are GGNRA comments on the Big Wave Project FEIR for consideration by the San Mateo County
Planning Commission at the November 17 meeting:
Visual
The Final EIS did not address visual impacts of this proposed project from Rancho Corral de Tierra. A
new development of this scale with a multi‐story building will be visible from future National Park Land
(NPS) at Rancho Corral de Tierra, approximately 4,000 acres west of Highway 1 in the Montara/Moss
Beach/Princeton area, with numerous trails currently used by the public. Rancho Corral de Tierra is
within the boundary of the Golden Gate National Recreation Area and is anticipated to be acquired by
the National Park Service in early 2011.
The proposed development is of a scale that is considerably larger than other development in the
surrounding area and will be a new visual element in an otherwise rural coastal setting.
We request a reconsideration of the building height, massing, and exterior material and color to
improve compatibility with this rural coastal context and reduce the visual impact and visibility from
Rancho Corral de Tierra.
Landscape
We request that vegetation appropriate to the project's coastal setting be used in landscaping and
screening of the project, and that invasive plant species that could escape from the project site and
impact adjacent natural areas be avoided.
Traffic
The requested parking exemption for this project (that would allow a lower number of parking spaces
than would normally be required) could result in spillover impacts that could affect public recreational
parking resources in the area.
The EIR should evaluate the traffic impacts of this project over the project lifetime and how that project
traffic and congestion could impact public access to national park lands in the area as well as other
public recreational destinations in the area.
The GGNRA is in the process of completing a draft General Management Plan and Draft Environmental
Statement that addresses zoning and broad concepts for future use of these lands. We anticipate that
the Draft Plan and EIS will begin public review in Spring 2011.
Water Availability
The NPS is concerned that over time, the project may become dependent on the Coastside County
Water District (CCWD) for its entire water needs, rather than just any back‐up or emergency needs. This
would increase demand, through CCWD, up into the San Vicente and Denniston watersheds where the
water district draws a portion of its water supply. The NPS will soon hold parcels of land through which
these two coastal streams flow, and is concerned about maintaining water quality and quantity within
these stream corridors to ensure a healthy and proper functioning riparian ecosystem. The CCWD holds
rights to draw water from these streams.
Although the Big Wave Project proposes to receive only emergency domestic water supply and fire
protection supply through CCWD, it is conceivable that the Project may seek, over the longer term, to
receive primary service through the CCWD. In that event, the Project would increase water demand,
through CCWD, on these two coastal streams. Though the Project appears to reduce demand through
changing the well use from agriculture to domestic, the Project may also effectively transfer demand,
through CCWD, into the coastal watersheds, potentially affecting the health and function of these
stream and riparian areas on national park lands of the Golden Gate National Recreation Area..
Please let me know if I can provide additional information.
Nancy Hornor
Planning Division Chief
Golden Gate National Recreation Area
(415)561‐4937
Nancy Hornor
To: cleung@co.sanmateo.ca.us
11/10/2010 05:22 cc:
PM PST Subject: Big Wave Comments
Dear Ms. Leung:
These are GGNRA comments on the Big Wave Project FEIR for consideration by the San Mateo County Planning Commission at the
November 17 meeting:
Visual
The Final EIS did not address visual impacts of this proposed project from Rancho Corral de Tierra. A new development of this
scale with a multi-story building will be visible from future National Park Land (NPS) at Rancho Corral de Tierra, approximately
4,000 acres east of Highway 1 in the Montara/Moss Beach/Princeton area, with numerous trails currently used by the public.
Rancho Corral de Tierra is within the boundary of the Golden Gate National Recreation Area and is anticipated to be acquired by the
National Park Service in early 2011.
The proposed development is of a scale that is considerably larger than other development in the surrounding area and will be a
new visual element in an otherwise rural coastal setting.
We request a reconsideration of the building height, massing, and exterior material and color to improve compatibility with this rural
coastal context and reduce the visual impact and visibility from Rancho Corral de Tierra.
Landscape
We request that vegetation appropriate to the project's coastal setting be used in landscaping and screening of the project, and that
invasive plant species that could escape from the project site and impact adjacent natural areas be avoided.
Traffic
The requested parking exemption for this project (that would allow a lower number of parking spaces than would normally be
required) could result in spillover impacts that could affect public recreational parking resources in the area.
The EIR should evaluate the traffic impacts of this project over the project lifetime and how that project traffic and congestion could
impact public access to national park lands in the area as well as other public recreational destinations in the area.
The GGNRA is in the process of completing a draft General Management Plan and Draft Environmental Statement that addresses
zoning and broad concepts for future use of these lands. We anticipate that the Draft Plan and EIS will begin public review in
Spring 2011.
Water Availability
The NPS is concerned that over time, the project may become dependent on the Coastside County Water District (CCWD) for its
entire water needs, rather than just any back-up or emergency needs. This would increase demand, through CCWD, up into the
San Vicente and Denniston watersheds where the water district draws a portion of its water supply. The NPS will soon hold parcels
of land through which these two coastal streams flow, and is concerned about maintaining water quality and quantity within these
stream corridors to ensure a healthy and proper functioning riparian ecosystem. The CCWD holds rights to draw water from these
streams.
Although the Big Wave Project proposes to receive only emergency domestic water supply and fire protection supply through
CCWD, it is conceivable that the Project may seek, over the longer term, to receive primary service through the CCWD. In that
event, the Project would increase water demand, through CCWD, on these two coastal streams. Though the Project appears to
reduce demand through changing the well use from agriculture to domestic, the Project may also effectively transfer demand,
through CCWD, into the coastal watersheds, potentially affecting the health and function of these stream and riparian areas on
national park lands of the Golden Gate National Recreation Area..
Please let me know if I can provide additional information.
Nancy Hornor
Planning Division Chief
Golden Gate National Recreation Area
(415)561-4937

An elected Municipal Advisory Council to the San Mateo County Board of Supervisors
Serving 12,000 coastal residents
Post Office Box 248, Moss Beach, CA 94038-0064
http://mcc.sanmateo.org
Neil Merrilees Len Erickson Leonard Woren Deborah Lardie

Chair Vice-Chair Secretary Treasurer
David Vespremi Bill Kehoe
October 26, 2010
Jim Eggemeyer
Planning Director
San Mateo County Planning Department
400 County Center
Re: Big Wave FEIR
Due to the size of the document, and the significant changes to the project, the
Midcoast council is asking for more time to review, digest and comment. We
request a 60 day period from the release of the FEIR to complete this review.
The FEIR and the Staff Report are poorly organized, inaccurate and incomplete.
There is information from the DEIR that is no longer relevant and there is missing
information (both site plans are shown interchangeably, ex. The latest traffic proposal
shows the old site plan). The lack of page numbers makes it difficult to reference the
document.
There are still many vague and unresolved issues.
Water source
Waste water management
Tsunami evacuation
Airport noise/ danger
Wetlands impacts/ changing delineation
Traffic directions/ impacts on visitors (LCP)
Parking (off site?)
Many of the unprecedented number of public comments stated that the scope and scale
of the project was too large and did not fit with the character of the community. In
the FEIR responses, this was largely dismissed as “opinion”, but many believe that an
office park of unprecedented size is by definition significant, and must be addressed.
A Wellness Center on the coast is a good idea but it should be considered
1 of 2
separately from the Office Park Project and its location is problematic. The
Wellness Center proposal by itself could be reviewed faster, approved faster, and could
be up and running. Using a good a good cause to push through an overly large
commercial development project is bad policy.
This location is zoned M1 or light industrial, not commercial. While appropriate

for some offices it not suitable for a large office park. The M-1 zoning makes
sense due to the remote location. Light industrial uses do not generate as much
traffic, and are suitable in locations with noise (airport).
The building height has been reduced, which is good, but the footprint increased to
keep the square footage at 225,000 sq ft. There are more buildings, but they are closer
together.
Many of the proposal in this project represent deviations from current County
development policy, starting with:
The brand new policy, in which planning staff is directed to create the EIR, and
then reviews the EIR. Available for future projects? This looks bad to everyone.
Revising parking requirements in favor of the applicant. It seems that since the
cars didn’t fit, they changed the requirements. Page III.A-19
Recommending approval without an actual water source. This is new policy.
Recommending approval without an actual sewer hookup.
A 20-year development agreement. Groundbreaking.
All of these items represent new development policy. They need to be discussed at
public outreach meetings and vetted at the Board of Supervisors.
Good planning is a balance between the rights of the developer and the needs of the
community. Good planning policy strives to keep that balance. In general, the FEIR as
released, seems to be out of balance.
Sincerely,
[SIGNED]
Neil Merrilees
Chair, Midcoast Community Council
Cc:
San Mateo Board of Supervisors
2 of 2
An elected Municipal Advisory Council to the San Mateo County Board of Supervisors
Serving 12,000 coastal residents
Post Office Box 248, Moss Beach, CA 94038-0064
http://mcc.sanmateo.org
Neil Merrilees Len Erickson Leonard Woren Deborah Lardie

Chair Vice-Chair Secretary Treasurer
David Vespremi Bill Kehoe
September 23, 2010
San Mateo County Board of Supervisors

Hall of Justice, 400 County Center
Honorable. Board of Supervisors,
The Midcoast Community Council (MCC) has received the attached Big Wave
Roadmap for a review of the Big Wave Final EIR (FEIR).
At the September 22, 2010 meeting of the MCC, the council voted 5-0 to request the
following changes to the roadmap (attached):
Provide a public review period of two months between the release of the
FEIR document and the planning commission hearing. Due to the
complexity of the project, and the unprecedented number of responses to
the DEIR, we feel the proposed 10 day comment period is inadequate.
Within two weeks of the FEIR release, conduct an evening public
information session on the FEIR, with specific emphasis on key changes
incorporated into the Draft EIR.
Ensure that there is a noticed public tour of the site when story poles are
in place.
State explicitly which structures at big Wave will be represented by story
poles.
Thank you for your support in this matter.
Sincerely,
[SIGNED]
Neil Merrilees
Chair, Midcoast Community Council
Cc:
Jim Eggemeyer
1 of 2
Camille Leung
2 of 2
Big Wave - Environmental Impact Report
Roadmap Update
Conversation between
Len Erickson and Jim Eggemeyer – Director, San Mateo County Planning and Building
Department
September 22, 2010
The Big Wave Final EIR (FEIR) is being produced by an internal team. Scott Holmes
provides support information as needed. The internal team has determined that there
have not been requirements for significant new information, consequently there is not a
need to re-circulate the EIR.
The FEIR draft is being reviewed by planning and legal management. When it passes
this internal review it will be presented to the public. A review was conducted early this
week and the draft did not pass review, so the Big Wave FEIR will not be released this
Friday, Sept. 24.
The review for release will continue on a week by week basis until the FEIR is approved
for release.
When Jim determines that the document is ready for release, Neil Merrilees will be
informed of the release plan by Camille Leung, planner for the project.
Following approval for release:

The FEIR will be published with the goal to provide the public with more than ten
days for review prior to the planning commission hearing.
Story poles will be in place at least ten days before the hearing.
The planning commission will conduct an onsite tour after the story poles are in
place.
The hearing before the planning commission will be conducted in an evening
meeting on the coast at an appropriate venue.
3 of 2
San Mateo County Harbor District
I (-( o~l 0 Board ?f ~arbor
r
fiO ~
I
PI u/
~
Commissioners
Sally Campbell, President
Pietro Parravano, Vice President
James Tucker, Treasurer
Ken Lundie, Secretary
Leo Padreddii, Commissioner
10'( cr: ~ "''''G'~Il, G_l """'g~

November 8, 2010
San Mateo County Planning Commission ---;.. ~,
..,__1...)
County Office Building /""'""1'"""
! I I
455 County Center r-'
'- j
Redwood City, CA 94063 .~ j " .
n-j
~-<~. c:5 ):> ~c.:
R~f: Planning Commission A!eeti~g No. 151~, Wednesday, November 1 'tJ;f!!1 0, l!fm
Big Wave Group, LLC, ConsideratIOn of Environmental Impact Report anil;!Jth1r
{S
Documents and Proposed Actions: DEIR Section III-49 Parking Options, and Sii,ff
Report Conditions ofApproval #68 Traffic Limits
Dear Honorable Planning Commissioners:
As General Manager of the San Mateo County Harbor District, I write you to provide
important information on the above-referenced Item 4 and to express our serious concern
with two specific aspects of the proposed project. Unfortunately, our Board of Harbor
Commissioners meets on the evening of November 17, so this letter must suffice to
articulate our concerns, which are:
1. In DEIR Section III-49, one method proposed to be used to reduce impacts from
the applicant's requested parking exception is to "Provide Shuttle Bus Service to
the Office Park location from the Park and Ride located in Pacifica, Princeton,
and HalfMoon Bay." If by Princeton is meant any location within Pillar Point
Harbor, please be advised that there is no Park and Ride site in the Harbor. For
your information, when Devil's Slide was closed for a brief period previously, the
Harbor District allowed a temporary Park and Ride site at the Harbor as an
emergency response. That is no longer operative and will not be in future. The
applicant should not consider the Harbor as an option, as none is available.
2. Second, the parking area being considered by applicant is restricted for use by
boaters as required by the state grant contract that funded the area's construction.
It cannot be used for the applicant's proposed purpose. Further, this site and any
other Harbor parking area exist for users and visitors to the Harbor, consistent
with the Coastal Act and the County Local Coastal Program. Parking for an off-
site office park with no Harbor connection conflicts with the Harbor's purposes
with respect to state and local requirements, as well as the Harbor District's state
tidelands grant that enabled the Harbor's existence.
400 Oyster Point Blvd., Suite 300, South San Francisco, CA 94080
(650) 583-4400 T
(650) 583-4611 F
San Mateo County Harbor District
Board of Harbor
Commissioners
Sally Campbell, President
Pietro Parravano, Vice President
James Tucker, Treasurer
Ken Lundie, Secretary
Leo Padreddii, Commissioner
Peter Grenell, General Manager
3. Regarding routing of traffic to non-residential streets in Princeton as stated in the

Staff Report Conditions of Approval #68, this clearly implies routing traffic along
Capistrano Ave. to Highway 1. We foresee a significant traffic congestion issue
if this occurs, as well as a serious associated pedestrian safety concern. Further,
such traffic issues would be a concern as well for visitor-serving businesses in the
Harbor and along Capistrano Ave. We urge that this question be given serious
consideration in your deliberations.
Thank you for your attention to our concerns.
cc: Board of Harbor Commissioners
400 Oyster Point Blvd., Suite 300, South San Francisco, CA 94080
(650) 583-4400 T
(650) 583-4611 F
From: "Patty O'Connor Lauritzen" <plauritzn@gmail.com>
CC: <cleung@co.sanmateo.ca.us>, "sabrina brennan" <sabrina@dfm.com>
Date: 10/24/2010 5:29 PM
Subject: Letter in Opposition to Big Wave
I would like to express my opposition to the building of the Big Wave project proposed on Airport Blvd.
As a resident living near the proposed project site, I am very uncomfortable with the increased amount of
traffic to this area, the environmental impact of the facility and the lack of interest from potential
businesses to occupy the proposed business offices.
I am also very concerned about the broad definition of the developmentally disabled community this
project is proposed to serve.
I have done community service with developmentally disabled populations in the past and am currently
working as a content writer for a major metropolitan homeless shelter. Developmentally disabled
individuals have a higher than average incidence of co-occurring mental health or behavioral issues which
can make this population potentially unpredictable or irrational.
What type of security or supervision is proposed for Big Wave while its disabled residents are both on and
off campus? Will all the residents be at a high functioning level? What percentage of this population will
have co-occurring mental health disorders? What types of mental health disorders and behavioral
challenges will Big Wave allow among the population that will live on its campus?
There are many young families in our community with small children and I am concerned that this needy
population will be underserved by the healthcare community. This is a small, remote harbor town. There
are no shopping or recreational destinations in this immediate area - only a trail system that leads to
private residences or the harbor. What assurance do we have that our families will not be impacted by
people with mental health or behavioral disorders knocking on our doors or approaching our children?
I recommend that an alternate metropolitan location be selected that is close to healthcare facilities,
transportation, stores, a library, and recreational parks. This type of project should not be located in a
remote seaside neighborhood.
Please stop the Big Wave Project. Ask yourself if Big Wave is truly designed to meet the needs of this
vulnerable population or if it is really designed just to meet the needs of the developer. The community
does not want this project and cannot logistically support it.
Thank you for reading.
Sincerely,
Patricia Lauritzen
Moss Beach
NDU-15-2010 10:47q FRDM:~~SD 6507288556 TO: 3634849 P.l
MONTARA WATER
AND SANITARY DISTRICT
Serving Montara and Moss Beach
Post Office Box 370131 Tel: (650)728-3545
8888 Cabrillo Highway Fax: (650)728-8556
Montara, CA 94037-0131
To: David Bomberger, Chair, and From: Paul Perkovic, President
Members of the Planning Commission MWSD Board of Directors
Fax: 650-363-4849 Date: November 15,2010
PhD ",a: Pages: 25 w/cover
Re: Big Wave Final Environmental cc:

Impact Report ("FEIR") and Related
Permits
X Urgent X For Review o Please Comment 0 Please Reply X Plea"e Recycle

NOU-15-2010 10:4ER ~ROM:MWSD
6507288556 TO:]6]Q849 P.2

P.o. Box 370131 Tel: (650) 728-3545
SBBa Cabr:llo Highway Fax: (650) 728-8556
Montara, CA 94037-0131 E-mail: mwsd@coastside.net
November 12. 2010
David Bomberger, Chair, and

County Government Center
County of San Mateo
nd
Re: Big Wave Final Environmental Impoct Report ("FEIR") and Related Permits
Dear Chair Bomberger and Members of the Planning Commission:
Wc submit this letter from the Montara Water and Sanitary District ("MWSD" or "District")
commenting on the County's responses in the FEIR for the Big Wave Wellness Center and
Office Park Project ("Big Wave" or "Project") as augmentation and revision to the District's
necessarily rushed initial response dated October 26, 20 10, addressed to Ms. Camille Leung
in the Planning and Building Department. This letter supersedes our previous letter, while
still retaining Attachments A through F from that letter as part of the Administrative Record.
Those documents are incorporated herein by reference and cited as appropriate in these
revised comments on the County's FEIR responses. New attachments providing further
support for the District's comments are included with this revised letter to become part of the
Administrative Record for the California Environmental Quality Act ("CEQA") process.
We note serious deficiencies in the Dig Wave FEIR that preclude certification by the
Planning Commission at this time. Lack of comment on a County response in the FETR
docs not imply acceptance of that comment as accurate or adequate, MWSD does not waive
its right to raise issues from its previous comments in CEQA litigation. The County has
artfully dodged responses to numerous substantive issues, some of which we explore below.
The Board of Directors of the Montara Water and Sanitary District also unanimously adopted
a resolution regarding the Big Wave Project at our regular meeting on November 4,20 I O.
Our General Manager, Clemens Heldmaier. transmitted a certified copy of this resolution by
email toCamilleLeungonNovember9.2010.This resolution is also included with this letter
as Attachment L I.
I Resolution No, 1480, ·'Resolution of the Montara Water and Sanitary District Concerning Proposed 'Big
Wave' Office and Wellness Center Development in the Vicinity of Pillar Point Marsh", adopted
unanimously on November 4, 2010.
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MWSD to San Mateo County Planning Commission - November 12,2010 Page 2 of 12

Comments on Big Wave Final Environmental Impact Report and Related Permits
Major Reasons the FErn Cannot Be Certified
o The FEIR does not adequately analyze the water supply impacts of the Project.
The FEIR still does not recognize MWSD as a "Responsible Agency" under
CEQA requirements. This is a flltal deficiency in the FEIR.
There is absolutely no discussion ofMWSD's water supply capacity, which as the

appropriate public water agency should have been included in the analysis, and - even taking
as a hypothetical the applicant's evident desire for public water service from Coastside
County Water District ("CCWD") - there is no analysis of the existing and long~term
capability of that district to serve the proposed Project and absolutely no consideration ofthe
environmental impacts of water service from that district. This is a fatal flaw in the EIR.
As background, the County itself recognized severe problems with Citizens Utilities
Company of California ("CUCC"), the former operator of the Montara I Moss Beach water
system, many years ago, when it established County Service Area 12 ("CSA 12") defining
the boundaries of the CUCC authorized Service Area with the expectation that CUCC's
water system would be acquired by a public agency and improved to meet current ~tandards.
Montara Water and Sanitary District flllfil1ed the expectations under which CSA 12 was
formed. The District acquired all of the Montara District assets of the former Citizens
Utilities Company of California (by then owned by California American Water Company) on
August 1,2003. The D.istrict has all of the powers of a county water district, and has
exercised those powers even prior to acquiring the former CUCC assets in furtherance ofthe
District's goal of providing assured long-term safe and reliable water supplies to meet the
current and future needs of the Montara I Moss Beach community. Attachment A2
enumerates much of the background of the water shortage situation in our community and
MWSD's successful efforts to ameliorate those shortcomings.
After acquiring the fomler CUCC water system, including its authorized Service Area, the
District initiated consolidation ofCSA 12 (which defines that Service Area as approved by
San Mateo County Local Agency Fonnation Commission ("LAFCo")) with the Montara
Water and Sanitary District to confonn the boundary of the District to include all ofth!..:
District's service areas (sewer, water, and solid waste disposal) within the District's
boundary. See Attachment B3 , which clearly indicates the District's intent to serve the entire
former CUCC Service Area, including the parcels proposed for the Big Wave Project.
The letter from the District's attorney, David E. Schricker, to the Planning Commission dated
October 25,2010 provides the detailed legal background for MWSD's necessity to be a
Responsible Agency under CEQA and the resulting fatal flaws in the FEIR as a consequence
of the County's repeated and consistent refusal to acknowledge MWSD's essential role in
providing water service to this proposed Project.
2 Resolution No. 1376, "Resolution of the Montara Water and Sanitary District Recounting All of the
Actions the Board of Dlrecto,·s Has Taken to Increase Water Supply for the Community", adopted
November 2,2006 (transmitted to County with October 26, 2010 letter to Camille Leung).
3 Resolution No. 1438, "Resoilltion of Application to the Local Agency FormatIon Commission of San
Matco County, California, Initiating Proceedings for ConsulidaLion of County Service Area 12 with the
Montara Water and Sanitary District and Establishing Said District as Successor Agency", adopted
November 6, 2008 (transmitted to County with October 26, 2010 letter to Camille Le"Jng).
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MWSD to San Mateo County Planning Commission - November 12,20 10 Page 3 of 12

Comments on Big Wave Final Environmental Impllct Report and Related Permits
In an effort to initiate communication with the Big Wave Project proponents, the District set
up an ad hoc committee consisting of two members of our Board of Directors, Bob Ptacek
(Treasurer) and Paul Perkovic (president), to work with the Project applicants on water
supply issues. By email dated November 7, 2008, from Paul Perkovic to Jeff Peck (and
others), acknowledged by Mr. Peck latcr that same day, MWSD notified Jeff Peck that their
proposed Project is within our Service Area, that "MWSD stands ready, today, to provide
public fire hydrants and private fire protection connections to internal sprinkler systems for
your proposed project," and that "We would like to meet with you to get a better idea of the
water needs of your proposed project, and how MWSD might be able to include sufficient
capacity in our plans for new water supply development to mcet the needs of your proposed
project as well as the needs of other property owners in our entire Service Area."
Big Wave representatives delayed meeting with MWSD until November 23,2009 - more
than n year later, and after the Draft Environmental Impact Report ("DEIR") was published.
4
Attachment C includes emuils showing MWSD's initiative in offering to meet with the
Project proponents, a surnIlli:lry of our meeting on November 23, 2009, and brief summaries
of subsequent discussions that focused more on recycled water technology and avoided
substantive discussion of how MWSD could serve the Project. The OEIR and FEIR never
consider water supply from MWSD, instead depending on hypothetical future discretionary
approvals by LAFCo and the California Coastal Commission, contrary to CEQA rules.
o Unexamined Growth-Inducing Impacts of Proposed Project
The FEIR docs not address !he growth potential of the increase in density of the
manufacturing site and the Project's proposed provision of water independent of existing
public utilities for the proposed Project. The Local Coastal Program ("LCP") calculated the
water and sewer capacity needed for buildout of the certified Land Use Plan. The responsible
sewer and WEller agencies have planned their infrastructure, service levels, and funding
mechanisms hased on the County's adopted zoning, General Plan and Local Coastal Program
policies. The proposed Project-supplied water and sewer service will be added to the already
determined capacities. The growth inducing impacts of additional water and sewer capacity
remains unanalyzed. This is another serious deficiency in the FEIR.
o Proposed Invasion ofMWSD Service Arca
The Draft Environmental Impact Report states that recycled water will be used for aU
irrigation. MWSD must conclude that recycled water will be used to irrigate the Big Wave
farm operation located on the HalfMoon Bay Airport and any yet-to-be-identified
operations on the Big Wnw parcels. MWSD is the supplier of water to the airport and has the
sole authority to deliver recycled water to MWSD customers. Big Wave LLC and/or Big
Wave Farms cannot usurp the District's recycled water authority. The environmental impact
of the water supply for the farming operation has not been analyzed. Montara Water and
Sanitary District has not been contacted in this regard.
4Email from Paul Perkovic to Jeff Peck dated November 7, 2008 with follow-ups; email from Paul
Perkovic to Scon Holmes dated November 24,2009 summarizing the first meeting with Big Wave
proponents on November 23.2009; email from Scott Holmes dated Aprll14. 2010; email from Scott
Holmes dated May 2B, 2010 (transmitted to County with October 26.2010 letter to Camille Leung).
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Comments on Big Wave Final Environmental Impact Report and Related Penn its
o InadequDte AnDlysis ofHnlf Moon Buy Airport / Pillar Point M.arsh Aquifer
A number of well-known documents and reports about the aquifer have not been consulted.
See, in particular, the reports prepared for the California Coastal Commission ("CCC")
regarding the aquifer, including biological monitoring, as part ofCUCC's request to
constrl1ct additional wells at the Half Moon Bay Airport and increase extraction from that
aquifer, incorporated into the administrative record as Attachments DS, E 6, and F7.
San Mateo County's recently released Groundwater Study Phose III has compared
groundwater levels in the 2009-2010 drought period with levels in previous droughts without
analyzing the amount of water that has been taken out oftbe aquifers during those periods.
Therefore prior stlldies and associated documents should be included in the FEIR. A major
flaw in the Phase III analysis ignores the fact that total water diversions from Denniston
Creek (which replenishes tht: aquifer) and groundwater extraction by CCWD and MWSD
were near historic low levels during the period analyzed, thus leading to faulty conclusions
regarding the sustainability and now rate through this aquifer.
Furthermore, CCWD asserts that it has water rights to divert 2 cubic feet per second ("cfs"),
or approximately 725 acre-feet per year, from Denniston Creek, which it is apparently
pursuing as part of that district's proposed rehabilitation and upgrade of their Dcnniston
Water Treatment Plant, and it has also asserted that it has water rights to divert an additional
2 efs from San Vicente Creek (which :llso partially replenishes the subject aquifer via
diversions to agricultural ponds), for a total of 1450 acre-feet per year. See Table 3 on page
M
23 of Attachment G • A revised and recirculated DEIR is required to analyze the cumulative
impact of the proposed Project when considered togethcr with other increased extraction
from the aquifer as it affects the Pillar Point Marsh and associated riparian and wetland areas.
If the FEIR had examined the totality of water use - both existing and proposed - drawing on
the limited resources of the aquifer, as required by CEQA, then these impacts would already
have been documented for consideration by the public and the relevant decision makers.
Instead, the County failed to do a complete environmental analysis and the FEfR is deficient
in this regard, as well.
MWSD sewer lines and sewer pump facilities are adjacent to the proposed Project. Clay
pipes arc casily destroyed and MWSD's sewer system impacted by trees planted on the Big
Wave site. This has not been analyzed in the current FETR.
5 California Coastal Commission staff report dated December 2, 1993, "Condition Compliance for Permit
A·3-SMC-86·155 and Permit A-3-SMC-B6-1SSA, Citizens Utilities Company", with Exhibits A through N
(transmitted to County with Ocroher 26. 2010 letter to Camille Leung).
~ California Coastal Commission staff report dated May 14, 1991, "San Mateo County Local Coastal
Program. M~jor Amendment 2-90", with Exhibit.. A and B (transmitted to County with October 26, 2010
letter to Camille Leung).
7 "Report on Biological Monitoring, Pillar Point Marsh. Half Moon Bay", prepared for Coastside County
Water District by Questa Engineering Corporation. May 1991 (transmitted to County with October 26,
2010 lener to Camille Leung).
B "Montara Water Supply Study for Montara Sanitary District", prepared by the California Department of
Water Resources. June 1999.
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MWSD to SAn Mateo County Planning Commission - November 12, 2010 Page 5 of 12
Specific Comments on FEIR Responses to Prior MWSD Comments
The District, and our Counsel, submitted several letters to the Planning and Building
Department during the comment period for the DElR. Contrary to CEQA requirements, the
County has not furnished the District with a complete set of responses to the District's
comments, apparently expecting the District to search through the electronic version posted
on the County's web site to find the missing County responses. This is unacceptable.
Comment Lettcr 101, from thc District to the Planning Commission dated November 17,
2009 (presented at the Planning Commission hearing on November 18, 2009) was generally
responded to by forward references to the District's more complete letter dated December 24,
2009 (Comment Letter 23 I) and the relevant responses are discussed below.
Comment Letter 121, from David E. Schricker datcd December 4,2009, was included with
the District's December 24, 2009 Jetter and the County's response to our District Counsel's
letter is response number 231-20, discussed below.
Comment Letter 231 is the main DEIR comment letter from the District, including
att.achments substantiating the District's major findings of inadequacies in the DEIR. Those
attachments include an August 18, 2003 Jetter from our District Counsel to Martha Poyatos,
Executive Officer of the San Mateo County Local Agency Fonnation Commission,
indicating the District's intent to oppose any attempt to annex the Lands of Big Wave LLC to
CCWD and citing the legal basis therefore; a December 4, 2009 letter from our District
Counsel to Camille Leung indicating the County's failure to treat MWSD as a Responsible
Agency and our District's requirement that the proposed Project must connect to our public
water system; a December 24, 2009 letter from the District's consulting hydrogcologist,
Balance Hydrologies, Inc., providing technical evaluation of the hydrological analysis in the
DETR; an April 10, 2006 letter from the California Coastal Commission to David Byers,
regarding Big Wave's attempt to annex to CCWD; and a letter from our District Water
Engineer, SRT Consultants, dated December 22, 2009. The FEIR responds to all of this
material under the Comment Letter 231 umbrella. However, some responses refer to text
contained in the responses to other comment letters and those were not furnished to us.
Summary of MWSD Comment 231-2: Consultant failed to lise certified Local Coastal
Program ("LCP") maps and policies to determine correct utility service providers.
MWSD Comment on Response 231-2: MWSD respectfully disagrees with the County's
response and the continued failure to include requested excerpts from the certified LCP into
the Administrative Record.
The purpose of an EIR is to evaluate environmental impacts, not to attempt to make

conclusions of law that arc within the jurisdiction of the courts. MWSD asserts its right to
serve this proposed Project and has initiated LAFCo consolidation proceedings with County
Service Area 12 to confonn District boundaries to our acquired Service Area, as documented
earlier in this letter. The legal basis for MWSO's contention that it has the right to serve the
Big Wave LLC parcels, and is thus a Responsible Agency under CEQA. is elaborated once
again in great detail in the letter dated Octoher 25, 2010 from our District Counsel David E.
Schricker to the San Mateo County Planning Commission.
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MWSD to San Mateo County PIllllning Commission - November 12,2010 Page 6 of J2

Condition of Approvlll 9 must be deleted from the proposed Conditions of Approval.
According to the General Plan Water Service Area map the proposed Project is in the
Citizens Utilities Montara District. MWSD purchased the Citizens Utilities Montara District
and its assets, including its entire Service Area. MWSD is on record as to its ability to
provide hydrants and service for sprinkler systems within the structures.
Summary of MWSD Comment 231-3: Applicant, County, and Consultant failed to confer
with MWSD and other responsible agencies.
MWSD Conuncnt on Response 23] -3: MWSD respectfully disagrees with the County's
response. See MWSD comment on Response 231-2 above.
With regard to MWSD's question about septic system drainfields, our concern is not satisfied
by the elimination of drainfields from the proposed Project The DElR does not adequately
document the location, age, or condition of existing septic drainfieJds that may affect the
aquifer providing the proposed well water supply for the Project. The rEIR does not
demonstmte that this proposed water source will be safe from contaminants, especially
nitrate, from existing septic systems that the FEIR acknowledges are in the vicinity. MWSD
monitors contaminants in the aquifer upgradient from the proposed water supply well for this
Project and has documented increasing nitrate levels in that aquifer.
Summary of MWSD Comment 231-4: Certified LCP maps clearly show the Pro.iect is
within Citizens Utilities Company of California ("CUCC") water service area.
MWSD Comment on Response 231-4: The District is compelled to include in the

Administrative Record the relevant portions of the certified Local Coastal Program maps and
policies that establish the District's right to serve this proposed Project, along with General
Plan maps confirming this position, as Attachment H9. Please note that the applicants and the
County repeatedly assert that no LCP amendments are necessary to permit this proposed
Project. However, it is clear that the Project conflicts with the certified LCP and amendments
would be necessary to adjust the service area maps and water supply estimate tables.
Summary ofMWSD Comment 231-5: !\1WSD acquired all assets of the former CUCC
Montara District on Augustl, 2003, stands in place of CUCC as successor in interest,
and is currently the only legally authorized public water provider for the )'roject.
MWSD Comment on Response 231-5: MWSD finds the County's response inadequate, in
that it fails to consider existing certified maps and depends on future actions, i.e., potential
LAFCo and Coastal Commission approvals, that are by no means certain. CEQA requires
analysis of the environmental situation as it exists now, not as the applicants or the County
hope it might exist in the future. This is a fatal flaw in the FEIR and requires recirculation
with the environmental considerations related to public water supply adequately analyzed.
9 San Matco County LCP Water Suppliers and Sanitary Sewer District Maps; Table 2.9, "Estimate of Water
Consumption Demand from Buildout of Land Use Plan I Citizens Utility Company"; and Table 2.10,
"Estimate of Water Consumption Demand from Buildout of Land Use Plan I Coastside County Water
f)istrict within County Jurisdiction"; "San Mateo County General Plan / Water Su ppliers", Page lO.1M.
NOU-15-2010 10:51~ F~OM:~~50
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Comments on Big Wave Final Environmental rmpact Report and Related Permits
Curiously, the FEIR refuses to consider likely future changes to the Half Moon Bay Airport
safety zones to incorporate the airport land use compatibility guidelines from the California
Airport Land Use PlatIDi.ng Handbook 1o, which would preclude this Project, and yet depends
on hypothetical future approvals for water service, which is essential to the Project.
Summary of MWSD Comment 231-6: Project would exceed Coastal Commission

extraction limit for aquifer.
MWSD Conunent on Response 231-6: MWSD respectfully disagrees with the conclusion of
the County. See the earlier section of this letter, "Inadequate Analysis of HalfMoon Bay /
Pillar Point Marsh Aquifer", together with the references and attachments.
Summary of MWSD Comment 231-7: Plans to serve the entire former CUCC service
area arc included in MWSU's Master Plan for water service and Public Works Plan,
Phase I ccrtifielll.Jy the Clllifornia Coustnl Commission.
MWSD Comment on Response 231-7: The County continues its circular reasoning, claiming
that evaluating the water supply capabilities ofMWSD as part of the environmental study for
the proposed Project is unnecessary because the County has already concluded that MWSD
cannot be the water service provider. This conclusion is contradicted by the facts presented
by our District Counsel in several letters, is a matter for the courts to decide, not the FErR,
and is prejudicial to the interests ofMWSD_ MWSD submits its Master PIEln and Master Plan
Addendum to the Administrative Record as Attachments I" and J12, and submits its certified
Public Works Plan, Phase I ("PWP"), as Attachment K13.
MWSD notes for the record that it has published a Notice ofImpending Development
("NOID") as required under the PWP to complete the new Alta Vista Well as a permanent
public water supply source for the District, increasing supply capacity by 150 gallons per
minute, and that fmal Coastal Commission approval of this major infra.c;tructure improvement
is anticipated at the November Commission meeting. The District has also published a NOm
for new water storage facilities, which the District anticipates constructing during 2011.
Summary of MWSD Comment 231-8: Omission of MWSD from Municipal Water

Service section is prejudicial.
MWSD Comment on Response 231-8: MWSD respectfully disagrees with this response, for
the reasons noted repeatedly. This is yet another example afthe County failing to adequately
respond to a substantive comment. The County, via the FEIR, is improperly attempting to
constrain the discretionary action ofLAfCo by the wording in Condition of Approval 9.
10 See, for Instance, Exhibit 58, "Potential New Safety Areas / Half Moon Bay Airport", in the
"Comprehensive Airport Land Use Plan Update for San Mateo County, Phase I Report, Draft" prepared for
the San Mateo County Airport Land Use Commission hy Coffman Associates, Inc., January 1998,
incorporated into the Administrative Record by reference.
11 "Montara Water and Sanitary District /2004 W;!ter System Master Plan", OlivIa Chen Consultants, [nc.,
January 2004.
12 "Montara Water and Sanitary District / Water System Master Plan /2005 Addendum", SRT
Con5l1ltar:t.~, April 200S.
13 '·Montara Water and Sanitary District / Public Works Plan, Phase roo, SRT Consultants
------------~-------~~~.--~--"---<~-----,--< -,---
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Summary ofMWSD Comment 231-9: MWSD stands ready to provide water for the
proposed Project's fire protection requirements.
MWSD Comment on Response 231-9: MWSD reasserts its readiness to provide fire service
to the proposed Project. MWSD notes for the record that it already has public fire hydrants
and distribution infrastructure serving parcels adjacent to the proposed Project.
Summary ofMWSD Comment 231-10: MWSD is the water service agency with the
authority to provide recycled water to serve tbe proposed Project.
MWSD Comment on Response 23 t -1 0: MWSD again raises the service duplication issue
and asserts it has exclusive rights to provide recycled water within its Service Area.
The County in the FEIR incorrectly concludes that LCP Policy 1.19 does not apply to this
proposed Project. The Waterfront zoning district is subdivided and zoned for residential
development at densities greater than one dwelling unit per 5 acres: Waterfront zoning has a
minimum parcel size of 5000 square feet and allows caretaker quarters (which are
residential) on 20% of the parcels, thus yielding an allowed density of 8 dwelling units per 5
acres. Therefore LCP Policies 1.18 and 1.19 do apply.
Summary of MWSD Comment 231-12: Project would violate Coastal Act section 30254
regarding wastewater treatment capacity.
MWSD Comment on Response 231-12: The County completely ignored the point of this
comment in its FEIR response. The proposed private wastewater system adds lit lea.'5t 26,000
gallons per day to the overalI regional wastewater treatment capacity. Existing regional
capacity is sufficient for, and limited to that necessary to serve, buildout of the LCP land use
plan. Adding 11 R equivalent residential units ("ERUs") of private capacity to the existing
regional total is thus growth inducing, and no study of these growth inducing impacts is
included in the FEIR. Consequently, the FEIR must be rejected as deficient in its analysis.
Summary of MWSD Comment 231-13: Critical documents on biological resources,

hydrology, and water resources were not referenced nor were they included in
analyzing Project em'ironmental impacts.
MWSD Comment on Response 231-13: MWSD asserts that a complete understanding of

critical environmental issues related to groundwater requires consideration of all available
studies and documentation, not just those that arc converuently useful in support of an
applicant. As discussed earlier, these documents are submitted for the Administrative Record
as Attachments n, E, and F.
Summary of MWSD Comment 231-14: Will the proposed recycled water treatment plant
be designed to treat Ilnd remove toxic wllste and chemicals from the research and
development activities and the light manufacturing activities?
MWSD Comment on Response 321-14: The County does not have an adequate enforcement
mechanism to enforce its use permits or zoning regulations, relying instead on citizen
complaints to spur action. The use permit hearing on September 8, 2010 for PLN200 J-00553
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Comments on Big Wave Final Environmental Impact Report and Re16ted Permits
- a use pennit that expired 9 years ago - is a case in point. That business is reported to be
disposing of contaminated waste water into lhe PrinceLon drainage system and has an
occupancy far in excess of that allowed in the Airport Overlay zone, among other violations.
Monitoring of hazardous chemicals every two years is not adequate.
Summary of MWSD Comment 231-15: Cumulative impacts are inaccurate us they are
based on an incomplete list of projects and inadequate analysis of those mentioned.
MWSD Comment on Response 231-15: The County's FEIR response is djsmissive and
inadequate. CEQA requires a full examination of cumulative impacts.
The Farallone Vista project, Moss Beach Highlands project, and North EI Granada
Affordable Housing projects remain as planning priorities for the County as documented in
the Local Coastal Program. The water needs and traffic impacts of all of these projects need
to be included as part ofthc cumulative impacts. Farallone Vista and Moss Beach Highlands
will require water service from MWSD. The traffic generated by all three should be included
in the lrll.ffic analysis.
~1WSD anticipates it will have adequate water to serve new development well within 20
years, the anticipated timefT8me over which the proposed Project would be constructed (see
proposed tenn of the draft Development Agreement). The listed affordable housing projects
have priority for new water capacity and would therefore likely be first in line. Therefore it is
"reasonably foreseeable" that projects with [l comparable cumulative impact will be proposed
and approved during this 20 year time span. The approved ElRs for previous proposals on
these sites provide an excellent basis for performing a cumulative impact analysis.
In addition, the HalfMoon Bay Airport Master Plan contemplates commercial and industrial
development on the airport grounds. This Master Plan, which tht: Count)' asserts was
approved by the Board of Supervisors in 1997, forms the best guide for anticipating
cumulative effects from County plans, even if the Federal Aviation Administration no longer
require.> general aviation airports to complete master plans, and should be included in the
cumulative impact analysis.
Summary ofMWSD Comment 231-20: Letter from David Schricker citing authority for
MWSn to serve the proposed Project (Attachment B to MWSD's comment letter).
MWSD Comment on Response 231-20: MWSD reasserts all points and legal authorities,
including case law decisions, cited in David Schricker's letter.
Summary ofMWSD Comment 231-21: .Letter from Mark Woyshncr, Balance

Hydrologies, Inc. regarding inadequacies in hydrological analysis (Attachment C to
MWSD's conmlent letter).
MWSD Comment on Response 231-21 : The Phase II of the K1einfelder report does not
contain any long tenn study of the Pillar Point Marsh or the specific endangered species or
wetland habitats or information to evaluate the impacts of this proposed Project on the Pillar
Ridge water supply or the Montara Water and San itary District water wells. The FETR needs
to rely on the long term studies contained in the Half Moon Bay/Pillar Point Marsh Ground-
Water Basin Report Phase II by Luhdorff and Scalmaniru. September 1991 and the
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MWSD to San Mateo County Planning Commission - November 12, 20 J0 Page 10 of 12

Comments on Big Wavc Final Environmental Impact Report and Related Permits
December 2, 1993 California Coastal Commission Permits A-3-SMC-86-155 and A-3-SMC-

86-15SA Compliance Report submitted as Attachment D.
OUT consulting hydrogeologist has also had adequate time, as a result of the postponement of
the October 27,2010 Planning Commission hearing, to preRare a response, which is
submitted as a separate letter to the Planning Commission. 4
MWSD Comment on Responses 231-23 to 231-32. MWSO's Water Engineer, Tanya

Yurovsky, emphasizes the correctness of her previous comments on the DEIR.
Adequacy of Alternative Water Supply Providers
As extensively documented earlier in this letter and in our many letters from our District
COLlnsel, in the General Plan, and in the Local Coastal Program, MWSD is the appropriate
Responsible Agency to serve this proposed Proj eet. Therefore, n revised and recirculated
DEIR should appropriately examine the environmental aspects ofMWSD providing water
service to the proposed Project.
Notwithstanding the clear legal basis in favor of MWSD, if the County continues, contrary to
its own approved and certified planning documents, to insist that CCWD is a potential
alternative public watcr supplier for this proposed Project, then a complete and competent
environmental analysis ofthat potential water supply as it relates to the proposed Project and
all other cumulative development anticipated by the LCP is necessary.
For this analysis, the relevant question is not whether CCWD has enough uninstalled
connections today to serve the proposed Big Wave Project (if allowed by MWSD, LAFCo,
and the ccq, but whether CCWD will have sufficient watcr supply in 2080 (i.e., at the end
of the 50-year economic life of buildings constructed at end of the time allowed by a 20-year
Development Agreement), after all Crystal Springs connections have been installed.
Note that the existing County and HalfMoon Bay growth limits do not necessarily assure
CC\VD that water connections will not be needed quickly. For example, this single Project
proposal requires 118 ERUs of sewer capacity and might require a similar amount of water.
Other non-residential development, plus priority uses, could quickly place significant
demand On CCWD's system, beyond its existing drought year supply assurance.
There is no environmental analysis of CCWD water supply impacts to serve the proposed
Project long term. The FEIR is deficient in failing to adequately analyze the environmental
impacts for either district (CCWD or MWSD) of providing a public water supply.
Conclusion Regarding Certification of Final Environmentnllmpact Report
The Final Environmental Impact Report is so thoroughly inadequate, with so many fatal
flaws, that the only appropriate action for the Planning Commission is to direct County staff
to correct the deficiencies, include MWSD as a Responsible Agency, and recirculate the
r~viscd and updated document as a new Draft EIR for agency and public comment.
14 Letter from Mark Wnyshner, Balance Hydrologies, Inc., to Camille Leung, San Mateo County Planning
and Building Department, drlted November 10,2010.
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MWSD to Sun Mateo County Planning Commission - November 12.2010 Page 11 of 12

Comments Regarding the Coastal Development Permit for the Proposed Project
The necessary Findings for Approval of the Coastal Development Penn it ("CDP") and Use
Permit cannot be made due to the following inadequacies. This is only a partiullisting of the
reasons why the findings cannot be made.
Local Coastal Program Policy 1.3 defines urban areas suitable for urban development as "(3)
served by sewer and water utilities." The Project must be served by a public utility, however
no discussions with MWSD as to how to best accomplish this have taken place. MWSD,
having purchased the right to serve this area as part of its acquisition of Citizens Utilities, is
the water utility designated in the General Plan and Local Coastal Program.
LCP Policy 1.18 41u directs the County to "Direct new development to existing urban areas ...
(2) maximize the efficiency of pUblic ... utilities." MWSD serves the adjacent Pillar Point
Manufactured Home Community and has confirmed that we are able to serve the needed fire
protection system as soon us the Project is pennittcd. MWSD Resolution 1480 affinns the
intention ofMWSD to provide water service to the Project in compliance with the District's
governing statute, all pertinent District regulations, specifications, and related tenns and
conditions.
The Public Works Policy "'2.4 of the LCP requires the public works agencies to obtain CDPs
for any development projects that conforms to the "County's zoning ordinance and the
policies of the Local Coastal Program." The proposed components of the water system have
not heen specifically identified in such a way as to ensure that this policy can be
implemenled.
LCP Map 7.1 defines the boundaries oftbe PiUar Point Marsh. Policy 7.20 (a) and (b) have
set limits on the extraction of water from the aquifer feeding the marsh. MWSD intends to
utilize its full extraction allocation. There is no study to examine the effects ofthe extraction
of additional water from this marsh by the Big Wave Project, which will have detrimental
cffects on the marsh. Policy 7.20 (e) requires "All adjacent development shall, where
feasible, contribute to the restoration and biologic productivity and habitat." The radical
restructuring of the soils, landscape, and topography as well as changes to the hydrology and
groundwater movemenl from the area immediately surrounding this marsh have not been
analyzed for the long term effect on the marsh and surrounding habitat arcas.
Tn conclusion, the proposed Pro.iect FEIR and related permits cannot be approved at
this time.
Pllul Perkovic, President

MWSD Board of Directors
Cc: Applicant
California Coastal Commission
NOU-:S-2010 10:54~ ~ROr:~~SD 5507288555 TO: 35::34849 P.13
MWSD to San Mateo County Planning Commission - November 12, 20 I 0 Page 12 of 12

Comments on Big Wave Final Environmental Impact Report and Related Pennits
List of Attachments
A - MWSD Resolution No. 1376 (previously transmitted to County)

B - MWSD Resolution No. 1438 (previously transmitted to County)
C - Email exchanges with Project Proponents (previously transmitted to County)
0- CCC Condition Compliance Report (previously transmitted to County)
E - CCC Staff Report on SMC Major 2-90 (previously transmitted to County)
F - Biological Report from Questa (previously transmitted to County)
G - Montara Water Supply Study for Montara Sanitary District
H - General Plan and LCP Water Service Maps and Tables
1- MWSD Master Plan
.r - M\VSD Master Plan Addendum
K - MWSD PlIblic Works Plan, Phase I
L - MWSD Resolution No. 1480 (previously transmitted to County)
Note: Attachments will be sent to County in electronic fonn in separate transmittals and
will be submitted in hard copy for the Administrative Record at the November 17,2010
Planning Commission hearing.
NDU-15-20:0 10:54~ FROM:MW5D 5507288555 TD:3534849 P.1<1
Attachments to MWSD to San Mateo County Planning Commission - November 12,2010
Attachment A
Resolution No. 1376, "Resolution of the Montara Water and Sanitary District Recounting All
of the Actions the Board of Directors Has Taken to Increase Water Supply for the
Community", adopted November 2,2006
Attachment B
Resolution 1\0. 1438, "Resolution of Application to the Local Agency Formation

Commission of San Mateo County, California, Initiating Proceedings for Consolidation of
County Service Area 12 with the Montara Water and Sanitary District and Establishing Said
District as Successor Agency", adopted November 6, 2008
Attachment C
Email from Paul Pcrkovic to Jeff Peck dated November 7, 2008 with follow-ups; email from
Paul Perkovic to Scott Holmes dated November 24, 2009 summarizing the first meeting with
Big Wave proponents on November 23, 2009; email from Scott Holmes dated April 14,
2010; email from Scott Holmes dated May 28, 2010
Attachment D
California Coastal Commission staff report dated December 2, 1993, "Condition Compliance
for Pennit A-3-SMC-86-155 and Permit A-3-SMC-86-155A, Citizens Utilities Company",
with Exhibits A through N
Attachments A. E, C. and D can be/olUld al

hnn:llm~s.dfiles.montara.org/BWFETRCommentAttachmentA-D.pdf
Attachment E
California Coastal Conunission staff report dated May 14, 1991, "Sun Mateo County Local
Coastal Program, Major Amendment 2-90", with Exhibits A and B
Attachment F
"Report on Biological Monitoring, Pillar Point Marsh, Half Moon Bay", prepared for
Coastside County Water District by Questa Engineering Corporation, May 1991
Attachments E and F can be found at

http://mwsdfi Ies. montara.orglB WFELRCommentA ttachmentE-F. pdf
NDU-15-2010 10:54~ FRDM:MWSJ 5507288555 TO: 3534849 P.15
AttElchments to MWSD to San Mateo County Planning Commission - November 12, 2010
Attachment G
"Montara Water Supply Study for Montara Sanitary District", prepared by the California
Department of Water Resources, June 1999
Attachment G can be found at

http://mwsdfi les .montara.orgi I 999D WRMontara WaterSuppl yS tud y.pdf
Attachment H
San Ma[eo County LCP Water Suppliers and Sanitary Sewer Dislrict Maps; Table 2.9,
"Estimate ofWatcT Consumption Demand from Buildout of Land Use Pian/ Citizens Utility
Company"; and Table 2.10. "Estimate of Water Consumption Demand from Buildout of
Land Use Plan / Coastsidc County Water District within County Jurisdiction"; "San Mateo
County General Plan I Water Suppliers", Page lO.lM
These maps and tables follow 0/1 the next pages.

NOl-15-2010 10:5a A FROr:MWSD 6507288555 TO: 3634849 P.16
SAN MATEO COUNTY GENERAL PLAN
WATER SUPPLIERS
.J~"
,., .
\~
.~
, j "'.
f'ACne
ocr AN
R-wr.t. OIJ!
NDU-15-2010 10:S6R F~Dr:MWSD 6507288555 TO:]634849 P.l?
TABLE 2.9
ESTIMATE OF WATER CONSUMPTION DEMAND FROM BUILOOUT OF LAND USE PLAN

CITIZENS UTILITY COMPANY
Water Water
Number of Number of Generation Generation
lind u•• Acru 1 People Factor (GPO)
MONTARA-MOSS
BEACH
RESIDENTIAL
Developed - 3,607 93-134 g/d/c 335,550-483,300
Single-Family - (3,523) -
Multi-Family - (84) --
Undeveloped - 3,825 93-134 gfdfc 355,700-512,600
Single-Family6 -- (3,549) -
Multi-Family - {276} --
QQMME;BQI~L2
Developed 1.05 - 2,000
Retail (O.40) -- 2,000 gal/acre (1,000)

Recreation (0.65) - 1,500 gal/acre (1,000)
Undeveloped 11.14 - 27,400
Retail (10.32) -- 2,500 gaJlacre (25,800)

INDUSTRIAL'
Marine Related (0.00) -- --

General (42.60) - 2,000 gal/acre (85,200)
EUe!.IC B!;QBt;~IIQ~2
Parks and Beaches - 408 3 11.5 gal/day/capita 4,700
El.QBIC!.!l.IURAL -- - 40,000~
Developed - - (20,000)
Expansion - - 100% increase (20,000)
I~;:!TII!.!T1Q~~5
Developed -- - 13,600
TOTAL 864,100-1,168,000
(See next page for noles.)
2.30
NOU-15-2010 10:55R FROM:MWSD 6507288556 TO: 3634849 P.18
TABLE 2,9 (continued)
ESTIMATE OF WATER CONSUMPTION DEMAND FROM BUILDOUT OF LAND USE PLAN

CITIZENS UTILITY COMPANY
NOTES:
1. Commercial and industrial acreages based on planimeter measurements of the LCP Land
Use Plan.
2. Waler generation factors for commercial, industrial and public recreation uses derived from
estimates of sewage generation il'\ the sewer section of this component and the estimates
of the relation between sewage generation and water consumption by Williams,
Kuebelbeck and Associates, Inc., in the Pillar Point Harbor preieet EnYironmental Jmpact
&u.l.2r1. A 15% system loss is included.
3. Based on an estimate of average daily visitors to Montara State Beach at buildout.
4. Estimate of CUC existing floricultural usage, prOjected to e)(pand 100% at buildout.
5. Institutions include schools and convalescent homes. School equals about 1.200 gpd
(Farallone). The rest Is a convalescent home. Expansion at buildout assumes a 35%
increase for schools, assuming a probable year-round system with the potential to
accommodate about 35% more children than the system now serves.
6. Tt1is table reflects the second units that are permitted in R-1 Coastal Zoning Districts. It is
estimated that 299 persons would be housed in second units located in this area based on
a household size estimate of 1.410 persons per second unit as derived using standards for
a one-bedroom duplex from the U.S. Department of Commerce and Housing and Urban
Development, Annual Housing Survey, 1977.
GDBI0562.6FM
(6/101918)
2.31
NOU-15-2010 10:5SA FROM:~~SJ 6507288556 TO: 3634849 P.19
TABLE 2,10

COASTSIDE COUNTY WATER DISTRICT WITHIN COUNTY JURISDICTION
Water Water
Number of Number of G9neration Generation
land Use Acres People Factor (GPO)
EL GRANADA-
PRINCETON
BESIQE~IIAL
Developed -- 3,400 Q3-134 g/d/c 316,200-455,600
Single-Family - - -
Multi-Family - - -
Undevelooed -- 5,193 93-134 g/dfc 482,900-£95,900
Single-Family6 - (4,042)
Multi-Family -- (1,151 )
CQMME8~IA~1, 2
Developed 6.90 - 14,600
Retail (4.25) - 2,500 galfacre (10,600)

Retail (14.70) - 4,700 gal/acre (68,100)

Recreation (42.50) - 1,900 gallacre (80,750)
INDUSTRIAL 1,:1
Developed 11.00 - 27,500
Marine Related (11.00) -- 2,500 gal/acre (27,500)

General (0.00) - -
Marine Related (29.29) -- 2,500 gal/acre (73,225)

General (0.00) - -
t;SSE~I!~!. eU61.IC
SERYICES
Developed 5 - - 1,700
Undevelopeo -- -- 6,425
2.32
NCU-1S-2010 10:55R FROM:MWSD 5507288555 TO: 3534849 P.20
TABLE 2.10 (continued)

COASTSIOE COUNTY WATER DISTRICT WITHIN COUNTY JURISDICTION
Water Water
Number of Number of Generation Generation
Land Use Acre. People Factor (GPO)
!:!.!6L1C BECBEATIQ~2
Parks and Beaches -- 318 3 11.5 gal/day/capita 3,700
ELQBI~!.!LI!.!B8L • -- -- 230,000
Developed -- - (60,000)
Expansion -- -- (170,000)
1,306,100-1,668,500
TOTAL
NOTES:
1, Commercial and Industrial acreages based on planimeter measurements of the LCP Land Use
Plan. These figures, as revised In 1991, do not include roads.
2. Water generation factors for commercial, industrial and public recreation uses derived from
estimates of sewage generation in the sewer section of this component and the estimates of
the relation between sewage generation and water consumption by Williams, Kuebelbeck and
Associates, Inc., in the Pillar Point Harbor Project Environmental Impact Report. A 15% system
loss is included.
3. Based on an estimate of average daily visitors to Fitzgerald Marine Reserve at buildout.
4. Floricultural water usage is estimated as follows:
Deyeloped (.2 mgd) CCWD actual 1978 floricultural usage.

60,000 gpd CCWD County areas (30% of actual).
140,000 gpd Half Moon Bay (70% of actual).
Expansjon 50,000 gpd Water usage by existing Pilarcitos Valley

floriculturalists now relying on creek and well water.
120,000 gpd 100% expansion of existing floricultural use at

buildout.
5. EI Granada School projected to expand its existing consumption (1,300 gpd at the time of LCP
adoption) by 35% at buildout because of a probable year-round system with the potential to
accommodate about 35% more children.
2.33
NDU-15-2010 If:57R FROM:MWSJ 5507288556 TO: 3634849 P.21
TABLE 2.10 (continued)

COASTSIDE COUNTY WATER DISTRICT WITHIN COUNTY JURISDICTION
6. This table reflects the second units that are permitted in R·1 Coastal Zoning Districts. It is
estimated that 350 persons would be housed In second units located in this area based on a
household size estimate of , .410 persons per second unit as derived using standards for a
on'e-bedroom duplex from the U.S. Department of Commerce and Housing and Urban Develop-
ment, Annual Housing Survey, 1977.
7. Essential public services Include the following uses: Emergency Facilities, Correctional
Facilities, Transportation Facilities (public), Utility Facilities, Hospitals, Skilled Nursing Facilities,
Intermediate Care Facilities, Libraries, Community Centers, Elementary and Secondary
Schools, Institutional Day Care Facilities for Children (Day Care Centers as defined by State
law), Adults and the Elderly, Institutional Full-Time Care Facilities for Children and Adults, and
In$titutiona1 Shared Housing Facilities for the Elderly. These services must be provided by a
public agency or prIvate non-profit or government-funded (partially or fully) purveyor to be
considered an essential public service. The reserve capacity allocated 10 these priority uses
may nol be shared by any associated, non-priority use and must be forfeited when the priority
use is discontinued.
GDBIOS63 eFM
(6/10196)
2.34
-~----- ----~ - -_ _ _ _ _ _ _ _ A
- --------~-~-- - ~-.---
NO~-15-2010 10:S7R FRoM:MWSD 6507288556 TO: 3634849 P.22
Attachments to MWSD to San Matco County Planning Commission - November 12,2010
Attachment I
"Montara Water and Sanitary District 12004 Water System Master Plan", Olivia Chen
Consultants, Inc., January 2004
Attachment J can be found ar

http://m wsd .montara.orglWaterMasterPlan. pd f
Attachment J
"Montara Water and S~nitary District I Water System Master Plan / 2005 Addendum", SRT
Consultants, April 2005
Arrachmenr J can befound at

httpJ/mwsd.montara.org/WnterMasterPlan2005Addendum.pdf
Attachment K
"Montara Water and Sanitary District / Public Works Plan, Phase I", SRI Consultants
Attachment K can befound at

htt]:/lmwsd.montara.org/WaterMasterPlan2005Addendum.pdf
Attachment L
Resolution No. 1480, "Resolution of the Montara Water and Sanitary District Conceming
Proposed 'Big Wave' Office and Wellness Center Development in the Vicinity of Pillar
Point Marsh", adopted unanimously on November 4,2010
Thi,~ resolution/allows on the next pages.

NJU-15-2010 10:57A FROM:MWSD 6507288556 TO: 3634849 P.23
RESOLUTION NO. 1480

(APN 047-311-060,047-312-040)
WHEREAS, significant improvements to the District's water system have

been made, and additional sources of water have been acquired, by our District
subsequent to acquiring the privately-owned system in 2003; and
WHEREAS, the District's Water Master Plan provides for service
throughout the entire service area acquired by the District including the Project
area; and
WHEREAS, this District has commented upon both the DEIR and FEIR
regarding their omission to acknowledge our authority and duty to provide water
service to the Project and the corresponding deficiencies and inaccuracies in
those documents; and
WHEREAS, this Board desires to set forth its policy and intentions
regarding the provision of water service within the service area currently located
olJtside District boundaries and to the Project;
NOW, THEREFORE,
BE IT RESOLVED BY THE BOARD OF THE MONTARA WATER AND
SANITARY DISTRICT AS FOLLOWS:
1. The foregoing recitals are incorporated herein by reference.
2. The service area acquired by this District in 2003 is a valuable asset of
the District and of the citizens served by the District, both within and outside our
corporate boundaries.
3. Public policy and the legislative authority conferred upon our District
require that connection to a pUblic water system shall be paramount to, and
preferred over, on-site systems such as that proposed for the Project.
4. Our District currently is capable of providing fire protection seNice for
the Project and our District likewise is capable of providing commercial and
domestic service for the Project.
5. In accordance with the foregoing, this Board fully intends to provide
service throughout its entire service area acquired by purchase of the water
NDU-15-2010 lO:57R FRDr:~~SD 6507288555 TO: 3534849 P.24
RESOLUTION NO. 1480

(APN 047-311-060,047-312-040)
WHEREAS, the Final Environmental Impact Report ("FEIR") for the

development of 19.4 acres of land currently devoted primarily to agricultural use
and including wetlands in the vicinity of Pillar Point Marsh in the mid-coast region
of unincorporated San Mateo County ("County") has been submitted to the
County's Planning Commission for certification under the California
Environmental Quality Act ("CEQA"; Pub. Res. C. §21000 et seq.); and
WHEREAS, the development, named "Big Wave" ("Project"), consists of
an office component and a "wellness center" component with associated
aopurtenances and amenities; and
WHEREAS, as proposed by the Project proponent domestic and
commercial water service for the Project would be provided through on-site wells
with fire protection service and "backup" water service from Coastside County
Water District ("CCWD"); and
WHEREAS, the Project is located within the service area acquired by this
Dist~ict through its purchase in 2003 of the privately-owned water system then
serving our District; and
WHEREAS, the Project is located outside the corporate boundaries of
both CCWO and this District; and
WHEREAS, this District has initiated proceedings through the County
Local Agency Formation Commission ("LAFCo") to reorganize the District's
boundaries to incorporate that portion of the District's service area, including the
Project area, that currently is located outside the District boundaries; and
WHEREAS, this District currently provides water service to the Half Moon
Bay Airport outside our corporate boundaries and to the Pillar Ridge
Manufactured Home Community within our boundaries, both of which service
areas are adjacent to the Project; and
NDU-15-2010 10:58A FROM:MW~D 6507288556 TO: 3634849 P.2S
RESOLUTION NO. 1480

(APN 047-311-060, 047-312-040)
system described above, including service to the Project in compliance with the
District's governing statute, all pertinent District regulations, specifications and
related terms and conditions in furtherance of the public health, welfare and
safety.
S. The District Secretary is hereby authorized and directed to transmit a
certified copy of this resolution to the County Planning Commission in
conjunction with its review of the FEIR, to the Project proponent and to the
County Local Agency Formation Commission. I.
" r /J-_;!
)
r eJL' 1Lpc,.It:
COUNTERSIGNED:
secr~-1.ter and Sanitary District

.......
I HEREBY CERTIFY that the foregoing Resolution No. 1480 was duly and
regularly adopted and passed by the Board of the Montara Water and Sanitary
District, San Mateo County, California, at a Regular Meeting thereof held on the
4th day of November 2010, by the following vote:
AYES, Directors: Boyd, Harvey. Perkovic, Slater-Carter & Ptacek
NOES, Directors: n/a
ABSENT, Directors: None
r nd Sanitary District
Page 1 of 1
To Whom It May Concern,
I am writing to implore you to approve the EIR and not to succumb to bigoted, ignorant, or self-centered lobbies
whose transparent attempts to
stall - yet again - the Big Wave project from moving forward continue to emerge. It seems that those who
scream loudest, no matter their standing,
get their way. I believe that the mentality of 'last one in close and lock the gate' should not be encouraged by
stalling progress on this incredibly
important project for the coastside special needs community. This will not just benefit special needs however, it
will benefit the coastside overall.
As I research projects that have been approved on the coastside, certain patterns emerge.
1. For-profit projects seem to be approved - making me wonder about the money that changes hands during
approval processes
2. Discrimination against special needs and surprisingly, youth, seem to be emerging.
It certainly warrants further investigation as it seems that altruistic projects, even though they will positively
impact the coastside in many ways, both tangible
and intangible, don't move forward. It also appears that no special needs developments, or projects, make any
headway....why is that do you think?
I have lived on the coastside for over 14 years, have paid taxes and supported the coastside in many ways and
will be very disappointed if the vocal,
selfish minority continue to block good things, that might inconvenience them, or create obstacles for their
perceived 'God given rights' to a view,
comfort, and all the other issues they complain about.
The day that a 'view' or 'shell mounds' become more important than people will be a very sad day indeed for the
coastside, and indeed humanity.
This process has dragged on for over 5 years, plenty of time for everyone to educate themselves on the real
issues, so I hope you see these latest
attempts for that they really are - selfishness and discrimination being foremost among them.
Yours sincerely,
Petra Syme
Page 1 of 2
- Big Wave
From: "Petra Syme" <petra_syme@hotmail.com>

To: <pprice@finexgroupllc.com>, <rdkline1@aol.com>, <pfoster222@aol.com>, <s...
Date: 10/26/2010 5:05 PM
Subject: Big Wave
Mr. Kline
I am disappointed that so little is understood, yet so much ignorant rhetoric is broadcast to such a large group as
in the email below which found its way into my hands.
If you bothered to actually read the Environmental Impact Report for Big Wave you would see why it is over 3000
pages long. It does answer many questions about the environmental impact, the social and economic impact of
the Big Wave project. The so-called 'developer' is a dad of a special needs young adult who is donating his land
to create an independent living and working environment for his daughter and other special needs youth/adults
on the coastside. This avoids them having to leave the coastside to go to other states, and other parts of
California to get such assistance - other places that actually give a damn about special needs people.....
This is NOT a shopping mall, or a hotel, or some major For Profit development - this is specifically to fill a huge
gap on the coastside. This needs careful, considerate, compassionate thought and input, not a 'No Growth -last
one in shuts the gate' knee-jerk reaction.
Please do not encourage others to blindly follow a vocal minority who believe that their right (not sure who
bestowed it) to a 'view', or that shell mounds, or frogs, or anything else like that is more important than a
disenfranchised group of people on this very coastside - children of friends of some of yours no doubt - who
desperately need a place to call home, some independence, some dignity, some skills, and the ability to add value
to the coastside through working and creating jobs, rather than being dependent on the county, the coastside
and others.
This project is not a surprise, it has been over 5 years in the making and plans have been made available all
along. There is no 'sneakiness' here and the developer and the others working on putting this together are
receiving no funds and will receive no funds for their efforts here. This is not something that should be opposed
just for the sake of opposing something. If you want to attend the meeting please do so in an effort to actually
understand the intent, and ask honest questions and expect honest answers, but do not go with the agenda to
'slow down' something that needs to happen sooner rather than later.
Go to the website and see what it is all about if you don't know:
http://www.bigwaveproject.org/
There has actually been a lot of thought and effort gone into create an economic sustainable environment for
special needs, and mitigating environmental impact, and in fact creating some valuable environmental impact.
Are you really that scared or bigoted towards special needs individuals that you must stop this project just to
make another notch in your belt? Seriously?
I am cc:ing the planning commission and ms leung as I had emailed them earlier today on this issue.
I want them to see the rationale behind the type of opposition to Big Wave - ignorance, and No Growth and a
selfish desire to maintain some desired standard of living at the expense of others just because some of you
happen to live on the coast and don't want anyone else to enjoy that privilege (notice, not a right but a privilege
11/16/2010
Page 2 of 2
that you abuse with this kind of selfish behavior). The special needs residents of this proposed project also live
on the coast and want to enjoy the 'splendid Coastside living' you mention in your email below. Do they not have
the same 'rights' as you? or because they need some more infrastructure to support them, they don't have the
same rights as you? Very sad....very sad.
Yours sincerely,
Petra Syme
Subject: OUR ATTENTIOIN IS NEEDED !!!!!!!
Hello!!!! EGNAG ,
At our celebration party, someone let it slip that I was applying for the open seat at MCC. The cell tower
issue revitalized my community spirit and thanks to all of you and your outstanding efforts during the Cell
Tower fight, I applied. There was a MCC meeting last Wednesday. I was interviewed and accepted by
the Council. I need to be interviewed by two persons from the Board of Supervisors. Depending on how
quickly they act, I could be installed by the middle or end of November.
After I was accepted,I stayed for the rest of the meeting, The Big Wave project was discussed. I knew
very little about Big Wave and thought they were going to discuss the Maverick's event. It is not.
This project is a proposed 250,000 square foot facility with 600 parking spaces. I am attaching
information from Len Erickson on the project. There is additional info at the MCC website.
The situation is this. The developer is pushing this through with code and environmental issues not
resolved. MCC is tasked to answer these and other issues found in a 3,000 page document created by
the developer and the Planning Commission.
The Board of Supervisors is holding a meeting this Wednesday, October 27 at 6:00 PM. The place is El
Granada Elementary School.
MCC needs our help and support to slow this process down. This project infringes on our coastal
community.as much or even more so than the cell tower did .The developer seems to be as sneaky as
was AT&T. There are code, environmental, water , traffic and other issues not answered.
A show of community support is essential in order to slow down Big Wave. EGNAG can make a big
impact here. Regardless of your position, even if you have one, more information is needed before this
project becomes reality. So, please try and attend this meeting on October 27 at 6:00 PM at El Granada
School
I believe EGNAG can lead by example. If believe EG NAG reaches out to other Coastside Communities
we can take an active, effective part in protecting and maintaining our splendid Coastside living.
Regards,
Bob Kline
11/16/2010...
Page 1 of 1
- Big Wave Project
From: "Rosabelle Lynes" <rosabelle1@gmail.com>

Date: 10/23/2010 1:36 PM
Dear Ms. Leung:

I am a teacher at Half Moon Bay High School and my husband is a teacher at Cunha Intermediate
School and we live in Half Moon Bay. I teach English and my husband teaches Special Education. I am
writing to ask that you do everything you can to move the Big Wave Project forward. This is an
important project for the developmentally disabled population on the Coastside and will contribute to
their and the community's well-being. Please help those working on this project and stop the continual
delays. It is time to do something to help this population!
Following are reasons you should be in support of Big Wave and move this project forward:
1)The County has spent five years studying Big Wave. They produced an environmental document over
4,000 pages in length the proves Big Wave has no significant environmental impact and meets County's
the planning goals and zoning requirements.
2) In contrast, our nation's sweeping health care reform bill was only 1,900 pages in length and spent
about a year in Congress.
3) The County has failed to develop sufficient housing options for this population. Moreover, the
County has failed to develop any affordable housing options in the unincorporated San Mateo County
Coastside. Our community of special needs adults is aging and so are their parents. For special needs
adults, the rates of homelessness and abuse are high. Delays in creating a safe housing option have very
real effects on the lives of our future residents.
4) There are 88,000 acres in the San Mateo County Coastside. Not one- not even one- is currently
dedicated to the special needs population. The Wellness Center will develop 2 acres of a 5 acre parcel.
After five years and 4,000 pages of analysis, the County has enough information to say, "Yes, we can
allow the special needs population to have 2 acres of 88,000."
We hope we can count on your for your support and for your vote in favor of moving Big Wave
forward.
Thank you,
Rosabelle and Michael "Arvin" Lynes
11/16/2010
From: "Stella & Bob Pellegrini" <stellarte@sbcglobal.net>
CC: "Lennie Roberts" <lennie@darwin.ptvy.ca.us>
Date: 10/25/2010 2:22 PM
Dear Ms Leung:
I'm writing this email to request the Planning Commission to extend

the jurisdictional
(and discretionary) public review period for the FEIR to sixty days
(60). The extended time
frame is required in this instance due to the complexity of the
proposed project and the
amount of literature that must be reviewed. Ten days for the review
is unacceptable and
an abuse of the Commission's discretionary authority in this instance.
Sincerely,
Robert L. Pilgrim
L O M A P R I E T A C H APT E R
San Mateo Santa Clara San Benito Counties
_ _
Ms. Camille Leung, Planner November 08,

20010
San Mateo County, Planning and Building Department
cleung@co.sandmateo.ca.us
Re: Comments on the Final Environmental Impact Report for Big Wave Wellness and Office Park Project.
Dear Ms Leung:
A year ago we wrote informing you that the Sierra Club Loma Prieta Chapter Coastal Issues Committee
had a substantial number of concerns regarding the scope and feasibility of this project, which we described
in our letter. To the applicants’ credit, we find a substantial number of our concerns seem to be recognized
by announced changes to the project development plan, although some of these hinge on questionable
claims or assumptions that are open to dispute. We have now had the opportunity to read comment letters
from other relevant agencies – i.e. Granada Sanitary District, Montara Sewer and Water District, Federal
Aviation Administration and California Coastal Commission – that raise significant and unresolved issues
either not addressed, or simply ignored in the FEIR. Because of numerous contradictions, and because the
magnitude and impacts of this project are so great, we conclude that the Planning Commission and the
Supervisors should not certify the FEIR.
The County’s Staff Report accompanying the FEIR failed to provide a copy of the California Coastal
Commission’s December 23, 2009 comment letter, a document that all interested parties should have been
able to read. Besides raising a boundary question about its own jurisdictional permitting authority on part of
the property, it discussed specific aspects of the project that are subject to the constraints imposed by the
Coastal Act, and which, in the CCC’s Staff view, needed addressing in the FEIR; many of these issues are
the same ones our Coastal Issues Committee raised a year ago, but are dealt with in questionable ways in
the FEIR – i.e. availability of potable water, waste water disposal, and wetlands issues, including the
adequacy of buffers, being key concerns of the Sierra Club.
We applaud the change from the DEIR of on-site waste disposal to the plan to funnel it through Granada
Sanitary District’s (GSD) facility, but GSD’s comment letter says that they’ve not been consulted about the
applicants’ plan, nor do they think the 8 EDU annual estimate is realistic by a factor of five, with GSD’s
annual estimate at 40 EDU, which raises a flag about whether miscommunication of this magnitude, and at
the point a “final” EIR, should be sanctioned by the County. We view this as too important a subject to the
public interest to have dangling now.
A similar set of unresolved issues revolves around potable water and the stated plan by the applicants of
using and treating water from a former agricultural well, one that it claims it can draw from without
adversely affecting hydrology of Pillar Point Marsh on its southwestern flank, or the water table for other
nearby wells including Montara Sewer and Water District’s (MSWD) that draws 30% of its water at the
airport. The applicants cite being able to rely on Coastside Community Water District (CCWD) for their
backup emergency water supply, but MSWD disputes CCWD’s legal ability to supply this resource and has
issued a strong claim to the contrary. It does not seem likely this will be resolved anytime before the FEIR
will be certified, but resolution of these issues is crucial before the County underwrites the FEIR and incurs
potential liability.
The wetlands issues are perhaps the most important given the protections afforded by the Coastal Act. The
Coastal Commission’s December 23, 2009 letter calls for careful delineation of all of the wetlands in and
around the property. San Mateo County has long had historical maps showing these wetlands, but the
applicants disked the wetlands on its southern property in the middle of this current decade, then under the
guise of farming, brought in enormous quantities of fill to eliminate them in perpetuity, or at least until they
could get this project approved along with buffers acceptable to the applicants. Now their FEIR ignores the
Coastal Commission’s specific request for an adequate delineating wetlands map at the risk the CCC will
block a CDP until the applicants provide the missing information, at a minimum.
Also significantly omitted from the DEIR, and now the FEIR, which was requested by the Coastal
Commission Staff, are habitat maps for affected species like California Red-legged Frog, Western Pond
Turtle, San Francisco Garter Snake, Salt Marsh Yellowthroat, etc. Last year our Coastal Issues Committee
wrote in comment on the DEIR, “we are compelled to remark that the known occurrence of the Red-legged
frog around the Big Wave property merits (demands) closer attention than specified in the DEIR.” The
Coastal Commission is blunt in saying the DEIR was inadequate in not commenting on the upland habitat
for the known Species of Concern, and expected this to be remedied in the FEIR; however, it is not, and
because of major omissions like this, we cannot find favor with this report.
Included in the County’s Staff Report is a copy of the proposed Development Agreement. A development
agreement designed to last twenty years is fraught with problems, no matter how good the lawyers or how
many eyes pass over it before signing. It’s akin to trying to nail the future to a wall like a map, while
expecting it to cover every contingency, which just isn’t possible. At the outset it must be predicated on
accurate inputs, yet 5.3 Phase 1 says the Developer will construct the sewer connection to GSD, which it,
according to GSD, hasn’t reached an agreement with yet; or 5.3 Phase 5 “Developer can do multiple
phases in order simultaneously.” Louis Carroll might have understood what this means, but it is doubtful
two different lawyers would. 7.3 “Moratorium Not Applicable” relieve the applicants from onerous
conditions in order to keep developing, but such moratoria do not usually result from cavalier post hoc
political decisions, but are more often brought about by real emergency situations. Therefore, is it in the
public interest to forsake and override any future emergency, no matter how dire the circumstance? 12.1
“Modification because of conflict with State or Federal Laws” says the Developer and County will work in
good faith to overcome such conflicts, but what if they’re built into the agreement at the outset? The
Federal Aviation Administration’s letter of July 8, 2010 opposes permitting the Big Wave housing portion
so close to airport operations (under 500 feet) because, based on its long experience, conflict with unhappy
residents is guaranteed, and that the pressure that causes will affect the airport’s ability to conduct normal
operations. Question: If a Development Agreement is flawed now, what odds are there it will last six, ten,
fifteen or twenty years without serious litigation becoming part of its intrinsic fabric?
However, nothing in the Development Agreement rankles so much as 16.6 “Failure to Hold Review,”
which basically says that if the County does not do its job of regular performance reviews during any
period, it is automatically deemed “conclusive” that the Developer has complied in good faith with its
work, no matter what the condition of that work is. Could the public possibly be more ill served than by
this toothless commitment to performance reviews by the County? There is enough history from the
County’s experience with Westinghouse on the Harbor House Hotel Development Agreement, and in its
failure years later to conduct performance reviews while the successive owner completed that project, that
this clause in the Big Wave Development Agreement makes perfect sense, as an escape hatch for avoiding
the responsibility and due diligence that government is ordinarily supposed to render.
We appreciate your having extended the review time so that we could examine the many pages involved
with the FEIR, commenters’ letters, Staff responses, etc. This is a complex project with a demanding set of
constraints that need careful attention, more than they’ve received from the applicants heretofore. Please
look out for the interest of all of the citizens interested in the outcome of this project, and for the
environment as well.
Respectfully,
Ken King
Co Chair
Sierra Club Loma Prieta Chapter Coastal Issues Committee
633 Terrace Avenue
650 726 4268
Cc: Jim Eggemeyer, Director of Planning

Ruby Pap, North Central Coast District Supervisor, California Coastal Commission
Lennie Roberts, Legislative Advocate, Committee for Green Foothills
Mike Ferreira, Conservation Chair, Sierra Club, Loma Prieta Chapter
October 19, 2010
David Bomberger, Chair

RE: Request for Extension of Time to 60 days for Public Review of Big Wave Project Final
Environmental Impact Report (“FEIR”)
Via electronic mail
On behalf of the San Mateo County Chapter of Surfrider Foundation (“Surfrider”), I am writing
to request an extension of the review and comment period for the Big Wave Office Park and
Wellness Center (“Big Wave”) FEIR. The Surfrider Foundation is a non-profit environmental
organization dedicated to the protection and enjoyment of our world’s oceans, waves and
beaches, for all people, through conservation, activism, research and education.
To assure that the public and responsible agencies have sufficient time to review and submit
additional comment on the FEIR for this sizeable and complex project, Surfrider finds that it
would be reasonable and desirable to extend the review and comment period to a time of sixty
(60) days from the date of release of the FEIR. Given the multiple components of this project,
which is not merely a building project but also a treatment works and power generation project,
it would be mutually beneficial for all parties that stakeholders have adequate time to digest any
new information and analyses provided—including changes made to the project, new impacts
and mitigation strategies identified—or, in the case that no substantial changes were made, to
have time to fully understand the rationale provided to explain why that is the case.
Surfrider respectfully requests that the review period for the FEIR be extended to 60 total days.
Sincerely,
Sarah Damron
Central California Regional Manager
Surfrider Foundation

Page 1 of 1
- BIG WAVE.. NO MORE DELAYS!!
From: <sdesoto85@aol.com>
Date: 10/25/2010 12:23 PM
Subject: BIG WAVE.. NO MORE DELAYS!!
CC: <rgordon@co.sanmateo.ca.us>, <barbers430@gmial.com>
To whom it may concern:
I'm a longtime Coastside resident who has lived in El Granada and now in Half Moon Bay. I have not herd
or seen a project better suited for the community as a whole and for individuals. Many others and I hope that the
County of San Mateo will approve this project as soon as possible for all the people who are involved and the
ones who this will help. Since the Owner's of this project have accepted and completed all of the conditions for the
approval for this project this should be a done deal and there should be no question what should be done. "BIG
WAVE". Please get this project approved now! please no more delays for The Big Wave Project.
Sincerely,
Sara DeSoto
1506 Spinnaker Lane
Half Moon Bay, California 94019
11/16/2010..
October 25, 2010
Dear Ms. Camille Leung,
I am writing to urge your timely approval of the Big Wave project. The county
has spent five years studying the impact of the wellness center and has
produced an environmental document over 4,000 pages in length. The study
concludes Big Wave has no significant environmental impact and meets the
county’s goals for both affordable housing options and addressing the needs of
the adult special needs population.
There are a few noisy opponents to this project who seek to delay the vote and
force the developers to continue to incur costs of gaining approval. This money
would be better spent directly on building the wellness center and getting the
special needs adults housed in an appropriate setting. Please consider the
amount of valuable time and resources to get to this point and approve the
project now. There has been enough time and information to make a decision to
allow the Big Wave project to proceed.
Thank you for a decision to provide housing and employment for the adult
special needs population of San Mateo County. I am sure Big Wave and San
Mateo County will become a benchmark of how to meet needs in many ways:
affordable safe housing for a population too often marginalized by society, new
jobs for those residents and others in the coastal community, an
environmentally sensitive design, all together in one locally “grown” center.
I have met several of the adults who might become residents of Big Wave, and I
believe they deserve our advocacy and our action. Please do not delay a vote on
the Big Wave. Thank you.
Sincerely,
Sandy Gainza
1614 Amaral Court
Fairfield, CA 94534
STATE OF CALIFORNIA-BUSINESS TRANSPORTATION AND HOUSING AGENCY ARNOLD SCHWARZENEGGER Goyernor
DEPARTMENT OF TRANSPORTATION
DIVISION OF AERONAUTICS - M.S.#40
1120 N STREET
P. O. BOX 942873 Flex your power!
SACRAMENTO, CA 94273-0001 Be energy efficient!
PHONE (916) 654-4959
FAX (916) 653-9531
TTY 711
October 25, 2010
Ms. Camille Leung

San Mateo County
nd
Dear Ms. Leung:
Re: San Mateo County's Final Environmental Impact Report (EIR) for the Big Wave Wellness Center
and Office Park; SCH# 2008102109
The California Department of Transportation (Caltrans), Division of Aeronautics (Division), reviewed

the Final EIR with respect to airport-related noise and safety impacts and regional aviation land use
planning issues pursuant to the California Environmental Quality Act (CEQA). The Division
previously commented on the Notice of Preparation on November 17, 2008, and the Draft EIR on
December 21,2009. The following comments are offered in response to San Mateo County's (County)
Final EIR.
The proposal includes "housing and employment opportunities for low-income developmentally
disabled" individuals. The project site is located immediately adjacent to Half Moon Bay Airport,
approximately 300 feet from the runway. The Final EIR states that the residential portion has been
reduced from 70 residential units to 57 units. Even at a reduced number, however, we consider placing
residential units for the developmentally disabled in such close proximity to an airport runway as an
unnecessary risk.
The Final EIR's Topical Response 14 (TP-14), Location of Project near the Half Moon Bay Airport,
referenced a letter from the Federal Aviation Administration (FAA) that raised concerns about the
project with respect to Assurance 21, Compatible Land Use, and objected to the project. In response to
the FAA, TP-14 states that Mitigation Measure HAZ-3 has been revised to "further clarify and disclose
the potential airport noise to the Wellness Center owner(s), staff, and residents." The County does not
appear to acknowledge the very serious matter of noncompliance with FAA grant assurances. The
proposal, even after revising HAZ-3, could jeopardize future FAA funding for airport safety and
improvement projects if the County fails to comply with the assurances.
The Final EIR recognizes that a portion of the project site is within the Approach Protection Zone for
Runway 30 as designated in the San Mateo County Comprehensive Airport Land Use Plan (CALUP).
We recommend that the proposal should, therefore, be submitted to San Mateo County Airport Land
Use Commission (ALUC) to ensure the proposal is consistent with the CALUP.
We previously said that the project site appeared to be within the Inner Approach and Departure Zone 2
as designated in the California Airport Land Use Planning Handbook (Handbook), available on-line at
http://www.dot.ca.gov/hq/planning/aeronaut/documents/ALUPHComplete-7 -02rev. pdf.
"Caltrans improves mobility across California"

Ms. Camille Leung
October 25,2010
Page 2
The Response to Comments 169-3 (and TP-14) states that neither the ALUC nor the County had
mapped Zone 2 for Half Moon Bay Airport. It then incorrectly links the size of Zone 2 with the
dimensions of Zone 1, which is the Runway Protection Zone or RPZ. The RPZ is based on FAA
approach visibility criteria and varies depending on the use of the runway. Like Example 4 in Figure
9K of the Handbook, Zone 2 is based on the length of the runway. In the case of Half Moon Bay
Airport, the width of Zone 2 is 1,500 feet, not 450 feet as stated in Response 196-3. The Handbook
generally recommends against residential uses except on large agricultural parcels within Zone 2.
As we stated in our previous comment letters, "Protecting people and property on the ground from the
potential consequences of near-airport aircraft accidents is a fundamental land use compatibility-
planning objective. While the chance of an aircraft injuring someone on the ground is historically quite
low, an aircraft accident is a high consequence event. To protect people and property on the ground
from the risks of near-airport aircraft accidents, some form of restrictions on land use is essential."
Of particular concern is the safety of the developmentally disabled individuals who will reside in the
units. They are considered a "sensitive use" according to the Handbook, which states, "certain types of
land uses are also regarded as requiring special protection from hazards such as potential aircraft
accidents." They fall into two categories: Hazardous Materials and Low Effective Mobility
Occupancies. As discussed on page 9-3, with respect to Low Effective Mobility Occupancies, the
Handbook recognizes that "society normally seeks a high degree of protection for certain groups of
people, especially children and the infirm." As discussed, a common characteristic among these groups
is the inability to move out of harm's way, either due to inexperience or physical limitations.
Additionally, the Final EIR addresses emergency evacuation for fires and tsunamis but not in the event
of an aircraft accident.
These comments reflect the areas of concern to the Division with respect to airport-related noise and
safety impacts and regional airport land use planning issues. We advise you to contact our Caltrans
District 4 office concerning surface transportation issues.
Thank you for the opportunity to review and comment on this proposal. If you have any questions,
please call me at (916) 654-5314 or by email atsandy.hesnard@dot.ca.gov .
Sincerely,
Original Signed by
SANDY HESNARD
A viation Environmental Specialist
c: State Clearinghouse, HalfMoon Bay Airport, San Mateo County ALUC, FAA

STATE OF CALIFORNIA-BUSINESS TRANSPORTATION AND HOUSING AGENCY ARNOLD SCHWARZENEGGER Govemor
.. .
~
DEPARTMENT OF TRANSPORTATION l~ ....... .. ~
DIVISION OF AERONAUTICS - M.S.#40

1,., .
1120 N STREET .... ,.
P. O. BOX 942873 Flex YOllr power'
SACRAMENTO, CA 94273-0001 Be energy efficient!
PHONE (916) 654-4959
FAX (916) 653-9531
TTY 711
October 25,2010
Ms. Camille Leung

San Mateo County
Dear Ms. Leung:
Re: San Mateo County' s Final Environmental Impact RepOli (EIR) for the Big Wave Wellness Center
and Office Park; SCH# 2008102109
The California Depatiment of Transportation (Caltrans), Division of Aeronautics (Division), reviewed

the Final EIR with respect to airport-related noise and safety impacts and regional aviation land use
planning issues pursuant to the California Environmental Quality Act (CEQA). The Division
previously commented on the Notice of Preparation on November 17,2008, and the Draft EIR on
December 21,2009. The following comments are offered in response to San Mateo County's (County)
Final ElR.
The proposal includes "housing and employment 0ppOliunities for low-income developmentally
disabled" individuals. The project site is located immediately adjacent to HalfMoon Bay AirpOli,
approximately 300 feet from the runway. The Final EIR states that the residential pOliion has been
reduced from 70 residential units to 57 units. Even at a reduced number, however, we consider placing
residential units for the developmentally disabled in such close proximity to an airport runway as an
unnecessary risk.
The Final ElR's Topical Response 14 (TP-14), Location of Project near the Half Moon Bay Ailport,
referenced a letter from the Federal Aviation Administration (FAA) that raised concerns about the
project with respect to Assurance 21 , Compatible Land Use, and objected to the project. In response to
the FAA, TP-14 states that Mitigation Measure HAZ-3 has been revised to "fmiher clarify and disclose
the potential airpOli noise to the Wellness Center owner(s), staff, and residents." The County does not
appear to acknowledge the very serious matter of noncompliance with FAA grant assurances. The
proposal, even after revising HAZ-3, could jeopardize future FAA funding for airport safety and
improvement projects if the County fails to comply with the assurances.
The Final EIR recognizes that a pOliion of the project site is within the Approach Protection Zone for
Runway 30 as designated in the San Mateo County Comprehensive AirpOli Land Use Plan (CALUP).
We recommend that the proposal should, therefore, be submitted to San Mateo County AilpOli Land
Use Commission (ALUC) to ensure the proposal is consistent with the CALUP.
We previously said that the project site appeared to be within the Inner Approach and Depatiure Zone 2
as designated in the California AilPOli Land Use Planning Handbook (Handbook), available on-line at
http://www.dot.ca.gov /hq/platming/aeronaut/documents/ALUPHComplete-7 -02rev.pdf.
"Caltrans ill/proves II/obility across California "

Ms. Camille Leung
October 25,2010
Page 2
The Response to Comments 169-3 (and TP-14) states that neither the ALUC nor the County had
mapped Zone 2 for Half Moon Bay Airport. It then incorrectly links the size of Zone 2 with the
dimensions of Zone 1, which is the Runway Protection Zone or RPZ. The RPZ is based on FAA
approach visibility criteria and varies depending on the use of the runway. Like Example 4 in Figure
9K of the Handbook, Zone 2 is based on the length of the runway. In the case of HalfMoon Bay
Airport, the width of Zone 2 is 1,500 feet, not 450 feet as stated in Response 196-3. The Handbook
generally recommends against residential uses except on large agricultural parcels within Zone 2.
As we stated in our previous comment letters, "Protecting people and property on the ground from the
potential consequences of near-airport aircraft accidents is a fundamental land use compatibility-
planning objective. While the chance of an aircraft injuring someone on the ground is historically quite
low, an aircraft accident is a high consequence event. To protect people and property on the ground
from the risks of near-airport aircraft accidents, some form of restrictions on land use is essential."
Of particular concern is the safety of the developmentally disabled individuals who will reside in the
units. They are considered a "sensitive use" according to the Handbook, which states, "certain types of
land uses are also regarded as requiring special protection from hazards such as potential aircraft
accidents." They fall into two categories: Hazardous Materials and Low Effective Mobility
Occupancies. As discussed on page 9-3, with respect to Low Effective Mobility Occupancies, the
Handbook recognizes that "society normally seeks a high degree of protection for certain groups of
people, especially children and the infirm." As discussed, a common characteristic among these groups
is the inability to move out of harm's way, either due to inexperience or physical limitations.
Additionally, the Final EIR addresses emergency evacuation for fires and tsunamis but not in the event
of an aircraft accident.
These comments reflect the areas of concern to the Division with respect to airport-related noise and
safety impacts and regional airpOli land use planning issues. We advise you to contact our Caltrans
District 4 office concerning surface transportation issues.
Thank you for the opportunity to review and comment on this proposal. If you have any questions,
please call me at (916) 654-5314 or by email atsandy.hesnard@dot.ca.gov.
Sincerely,
~"-cJ~ 4eLJ ~
SANDY<tIESNARD
Aviation Environmental Specialist
c: State Clearinghouse, HalfMoon Bay Airport, San Mateo County ALUC, FAA

Page 1 of 2
- Big Wave Project, El Granada Multipurpose Room, 6pm, Oct 27, 2010
From: "Terrence Gossett" <texterry@pacbell.net>

To: "camille leung" <cleung@co.sanmateo.ca.us>
Date: 10/25/2010 11:12 AM
Subject: Big Wave Project, El Granada Multipurpose Room, 6pm, Oct 27, 2010
Californians for Property Rights (CPR) supports the Big Wave

Project and the staff recommendation to "approve the project
as described in Alternative C and as presented in the Final
EIR...".
Furthermore, CPR supports the eight recommendations by staff

to the Planning Commission, regarding certification of the Final
EIR, granting of a Use Permit for the Wellness center, granting
of a major subdivision for the northern parcel, granting of a
CDP for the Office park buildings and Wellness Center
buildings, a Design Review Permit for proposed structures and
grading, an off street parking exception, a grading permit, and
that the Planning Commission recommend approval of a
Development Agreement to the Board of Supervisors.
It should be noted that the Big Wave project has been

modifying their initial proposal to comply with all county issues
raised over the past five years, and now the current proposal is
in compliance with all county requirements with no significant
environmental impacts.
Please do not further delay this urgently needed project for our
coastal community. It is time to develop affordable housing on
11/16/2010
Page 2 of 2
our coastside and to provide for our special needs population.
Vote yes to your staff recommendations. If you are unable to

vote at the 6pm meeting at El Granada on October 27th on
this issue, please hold a special meeting the first week of
November to vote on this project.
Respectfully yours,
Terry Gossett
Director
Californians for Property Rights
Moss Beach, CA, 94038
11/16/2010
SHUTE MIHALY
~WE I N BERG ER LLP
396 HAYES STREET, SAN FRANCISCO, CA 94102 WINTER KING
T: 415552-7272 F: 415 552-5816 Attorney
www.smwlaw.com king@smwlaw.com
November 9, 2010
Via Federal Express -0 Cj)

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Re: Big Wave Wellness Center and Office Park
Dear Chair Bomberger and Members of the Planning Commission:
We respectfully submit this letter on behalf of the Committee for Green

Foothills (CGF) and the Surfrider Foundation San Mateo Chapter (Surfrider) with respect
to the proposed Big Wave Wellness Center and Office Park (Project) and its
environmental impact report (EIR).l We have reviewed the Final EIR (FEIR) for the
Project, which San Mateo County made available to the public on October 15,2010. For
the reasons set forth below, it is our opinion that the FEIR does not correct the
deficiencies of the Draft EIR (DEIR). Therefore, we request that the Planning
Commission delay further consideration of this Project until the County has prepared a
legally adequate EIR that fully complies with the California Environmental Quality Act
(CEQA)2 and the CEQA Guidelines. 3
In its previous letter to the Planning Commission, this firm identified

numerous flaws and omissions in the DEIR. Unfortunately, the FEIR neither adequately
1 CGF and Surfrider are also submitting separate comment letters on the FEIR.
2 Public Resources Code § 21000 et seq. Unless stated otherwise, all section
references in this comment letter are to CEQA.
3 California Code of Regulations, title 14, section 15000 et seq.
Planning Commission
November 9,2010
Page 2
responds to comments previously raised nor cures the legal inadequacies identified by
those comments. Instead, the FEIR frequently dismisses the public's concerns without
substantive discussion or deals with them by proposing new mitigation or project
elements that will do little, if anything, to address them. For example, in response to the
public's concerns that the Project's location next door to an active airport runway poses
dangers to both Project occupants and airport users, the FEIR proposes a mitigation
measure that would require Project residents to promise not to complain about the noise,
fumes, and other irritants inherent in the airport's operation. Even the FEIR
acknowledges that such a measure will not reduce the actual impacts caused by these
incompatible land uses. The FEIR also continues to defer essential analysis and
mitigation until after Project approval. Thus, the public still has no clear idea of how the
Project's wastewater and stormwater runoff will be handled. This information is
essential given the proposed Project's location adjacent to wetlands and other valuable
coastal resources.
Additionally, the FEIR contains significant new information and Project

changes that require recirculation of the EIR for further public review. As described
below, the FEIR acknowledges that the Project is not likely to be completed in 36
months, as described in the DEIR, but rather will take 7 to 20 years. This prolonged
construction schedule creates new and potentially significant aesthetic, water quality, and
biological impacts that must be analyzed in a revised and recirculated EIR. The FEIR
also substantially modifies Alternative C to the Project by changing the configuration of
Office Park buildings and the proposed traffic circulation. These changes necessarily
alter the aesthetic and traffic impacts of Alternative C. Yet, even though County staff is
recommending approval of this alternative instead of the proposed Project, the FEIR
contains no visual simulations or proper traffic analysis of it. The public must have an
opportunity to review this additional analysis before the Planning Commission considers
approval of Alternative C.
In addition to these flaws in the EIR, the Project also violates provisions of
San Mateo County's General Plan (General Plan), Local Coastal Program (LCP), and
zoning ordinance, as well as the California Coastal Act. Neither the Project's residential
uses or commercial uses such as the "general office" are permitted within the General
Plan's "General Industrial" land use designation for the Project site. Nor is the
residential component of the Project truly a "sanitarium" permitted under the County's
conditional use provisions. Moreover, the Project violates the LCP and Coastal Act
because it will likely destroy or otherwise degrade environmentally sensitive habitat areas
and adversely impact the sensitive species that rely on this habitat as well. Thus,
approval of the Project would not just violate CEQA, but would also violate California
Planning and Zoning Law, Gov't Code § 65000 et seq., and the California Coastal Act,
Public Resources Code §§ 30000-30900, as well.
SHUTE MIHALY
~ WEI N BE RG E R LLP
Planning Commission
November 9,2010
Page 3
I. The EIR Fails to Comply with CEQA.
A. The FEIR Discloses New Information and Changes in the Project that
Require Recirculation of the EIR.
The FEIR discloses several significant changes to the Project as well as

significant new information about how it would be developed. As discussed below, these
changes have the potential to result in significant environmental impacts. As a result, the
EIR must be recirculated for further public review. See CEQA Guidelines § 15088.5.
1. Prolonged Construction Schedule.
The FEIR acknowledges that the Office Park will likely not be completed
in 36 months, as the DEIR had indicated, but instead will take 7 to 20 years to complete.
This new information suggests that there could be additional, significant environmental
impacts associated with the Project. For example, unless the County requires the
applicant to complete landscaping during the interim between construction periods, the
delay in completion could cause additional water quality impacts due to erosion of
exposed soils. Similarly, if construction fencing is kept in place for 7 to 20 years, rather
than the previously estimated 36 months, this fencing could have new, significant impacts
to wildlife movement and aesthetics not addressed in the DEIR. The FEIR does not
identify any additional mitigation measures to address these new and potentially
significant impacts.
A protracted construction schedule could also substantially degrade the

visual character of the site and significantly affect views of the site. Without additional
mitigation, much of the site could be graded, but left undeveloped, potentially for years.
Given the depressed nature of the real estate market, nearby residents and coastside
visitors alike would have to endure this blighted scenery - scarred land, stockpiled soils,
material storage, construction equipment and vehicles, and dust - for the foreseeable
future. Landscaping would only be added when the market allows and promised
screening of views of tall buildings and parking lots would be impermissibly deferred.
Furthermore, according to the FEIR, portions of the Project site would

remain in agricultural use until the Project is fully developed (see FEIR at III.A-24).
Agricultural activities have the potential to adversely affect Project residents. Dust,
noise, and odors are common phenomena associated with farming operations. Absent a
sufficiently sized buffer zone between these operations and the Project's residential and
commercial uses, Project residents and employees could certainly be adversely impacted
by these interim farming operations.
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Planning Commission
November 9, 2010
Page 4
Finally, a protracted construction schedule poses problems regarding the

implementation of mitigation measures. For example, it is unclear how the stormwater
runoff infiltration system would work if construction is spread out over two decades. The
FEIR relies heavily on this system to mitigate the Project's water quality impacts.
Mitigation Measure AQ-2 proposes to implement a dust control program which includes
measures that must be performed daily or even multiple times per day to adequately
mitigate construction dust. If construction takes place over a twenty year period, it is not
clear whether such measures would indeed take place every day or multiple times per day
continuously throughout the twenty year construction schedule or whether these measures
would be implemented sporadically at a less-than-adequate frequency.
2. Widening of Trail.
The applicant now proposes to widen the trail between the two properties to
10 feet. While it appears this proposed widening would provide improved access and
movement between the Wellness Center and the Office Park, it is unclear how this
widening can occur without either requiring additional construction over the
drainage/wetlands area or exposing those utilizing the trail to danger from car and truck
traffic along Airport Street.
3. Revised Alternative C.
The FEIR includes a revised Alternative C, which County Staff has

recommended for approval. This alternative differs significantly from that previously
proposed, as it involves eight smaller buildings (although four of these would still be
three stories) rather than four larger ones. No simulations of this alternative are provided
and thus it is impossible to determine what the visual impacts of this alternative would
be. Moreover, the FEIR fails to analyze the visual impacts caused by the incremental
development of this alternative over time. What will the site look like with just one
building and a large parking lot? In what order will the buildings be constructed?
Finally, this revised alternative does nothing to address the concern raised in our
comments on the DEIR that the County has not analyzed any alternative involving a
substantial reduction of scale.
4. New Traffic Circulation Option.
As will be discussed further below, the Project has also been revised to
include a new on- and off-site traffic circulation "option." This new circulation option
would redirect Project traffic from Cypress Avenue and Cabrillo Highway to roadways to
the south including Capistrano Road. While this new circulation option may benefit the
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Planning Commission
November 9, 2010
Page 5
Moss Beach neighborhoods (compared to the circulation pattern identified in the DEIR),
it will nevertheless increase impacts to roadways and intersections to the south. Indeed
the FEIR admits the potential for significant impacts to several intersections yet fails to
adequately analyze these impacts or to include sufficient mitigation for these newly
impacted intersections.
5. Wastewater Treatment System and Service.
The applicant is proposing several revisions regarding the Project's

wastewater treatment system. The environmental implications of these revisions are
discussed in detail below. However, it is important to acknowledge that the applicant's
proposal to eliminate the membrane bioreactor wastewater treatment plant and replace it
with three separate smaller plants (see FEIR at II.A-5) has the potential to result in
significant environmental impacts that are unanalyzed in the EIR. The FEIR explains that
the "small MBR plants" would be located in separate on-site locations. Id. Yet we can
find no indication that the FEIR identifies the locations of these treatment plants nor any
details as to the design or operation of these plants. Details relating to the plants are
critical inasmuch as wastewater treatment plants that are incorrectly designed, engineered
or operated can result in environmental impacts including, but not limited to, degraded
water quality, public health risks, and air quality and odor impacts.
B. The FEIR's Responses to Comments Raised by Government Agencies,

Local Residents, and Community Groups Are Inadequate.
The County received over two hundred comment letters on the DEIR, many
of which expressed concern over the lack of information and analysis provided about the
Project. The responses to these comments contained in the FEIR are wholly inadequate,
frequently glossing over the issue raised or further confusing matters. Below are some
examples of these inadequate responses.
1. Project Description.
One of the main flaws in the DEIR was its failure to provide a clear
description of the Project. "An accurate, stable and finite project description is the sine
qua non of an informative and legally sufficient EIR." San Joaquin RaptorlWildlije
Rescue Center v. County o/Stanislaus, 27 Cal. App. 4th 713, 730 (1994) (quoting County
o/Inyo v. City o/Los Angeles, 71 Cal.App.3d 185, 193 (1977)). While extensive detail is
not necessary, CEQ A mandates that an EIR describe a proposed project with sufficient
detail and accuracy to permit informed decision making. See CEQA Guidelines § 15124
(describing the requirements for an EIR). Here, the FEIR continues to leave out
important details about the Project. For example, the FEIR repeatedly notes that there
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~ WEI N BE R G E R LLP
Planning Commission
November 9,2010
Page 6
will be onsite farming/organic gardens and a native and/or ornamental plant nursery, but
none of the plans show where these uses will be located. These omissions are important
because neither the gardens nor the nursery can be located in the wetland buffer area.
Moreover, locating them in the A-O zone poses dangers to those working in the gardens
and nursery.
This problem is exacerbated by the FEIR's continued use of maps showing

an outdated site plan for the Wellness Center. For example, Revised Figure 111-24, which
purports to show the planting plan for the Wellness Center site, is based on the prior
Wellness Center site plan. Because the revised site plan differs substantially from the
prior one, Revised Figure 111-24 is, at best, unhelpful. Moreover, Revised Figure 111-24
continues to show the rain gardens, which have since been removed from the Project
description.
2. Biological Impacts.
It is impossible to adequately assess environmental impacts, alternatives, or

mitigation measures for a proposal lacking basic information about biological resources,
including the nature of the habitat and the presence of species on or near the premises.
Unfortunately, the responses to comments with regard to biological resources are
woefully inadequate. For example, the FEIR fails to adequately respond to comments
related to impacts on special-status plant species. Comments on the DEIR stated that,
given the acknowledged potential for four special-status plant species to occur on site, the
EIR cannot conclude that impacts to those species are less-than-significant. Rather than
respond to those comments with appropriate analysis and avoidance or mitigation
measures to minimize potential impacts, the FEIR doggedly reiterates the conclusions of
the DEIR. FEIR at Response to Comment 205-15. The document makes the
incomprehensible assertion that because only four of the 60 special-status plant species
analyzed in the EIR have the potential to occur on site, the EIR was reasonable in
concluding that the Project's impact on special-status plant species is less than
significant. Id. The EIR thus fails to provide the evidentiary basis to conclude that
impacts to special-status plant species are less than significant.
In another example, the FEIR and County Staff present contradictory

statements about impacts to biological resources. On the one hand, the FEIR
acknowledges a moderate potential for California red-legged frog to occur on site. FEIR
at Response to Comment 205-16. The October 27,2010 County Staff Report asserts that
"no direct impact or take of special status species due to lack of habitat suitable on-site to
support those species" but then imposes a Condition of Approval to minimize habitat
disturbance. Staff Report at 31 and 76-78. The EIR cannot have it both ways. Given
that the site has suitable habitat for special-status species, the Project has the potential to
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~WEINBERGERLLP
Planning Commission
November 9,2010
Page'7
result in significant impacts and thus has an obligation to mitigate those impacts. Here,
the EIR's mitigation for the loss of habitat is completely vague and states only that the
Project will comply with applicable laws. CEQA requires more.
As the U.S. Fish and Wildlife Service (USFWS) commented during the
scoping period for this Project, "the proposed project area is located adjacent to and
within suitable habitat for the red-legged frog and garter snake, and is located adjacent to
environmentally sensitive areas, such as the Pillar Point Marsh and the mouth of
Denniston Creek, which provides habitat for the garter snake and red-legged frog." See
USFWS letter to County dated February 27,2009 at 2, attached as Exhibit A.
"Observations of both red-legged frogs and garter snakes, have been made upstream
within Denniston Creek, which provides dispersal and foraging habitat, as well as
possible, breeding habitat for both of these listed species." Id. In addition, research has
shown that agriculturally disturbed lands do not preclude the presence of red-legged
frogs.ld. For these reasons, the USFWS "believes that the garter snake and red-legged
frog are reasonably certain to occur at the proposed project area." Id.
Despite the concerns expressed by the USFWS and numerous other

commenters, the EIR fails to provide sufficient information about, or timely and effective
mitigation measures to address, the Project's impacts. This approach runs afoul of
CEQA's mandate that in responding to comments, an agency must provide a reasoned
analysis supported by factual information. CEQA Guidelines § 15088(c). Where an
agency fails to provide analysis and data in response to a comment regarding a specific
environmental issue, the response is inadequate. See Santa Clarita Org. for Planning the
Envt v. County ofLos Angeles, 106 Cal. App. 4th 715,722 (2003).
In addition, in response to our comment that cat feces from residents' pets
could adversely impact marine species along the coast, the FEIR notes that the Project
has been revised to include signs reminding cat and dog owners to restrict animals to
allowed areas and to pick up their pets' waste. Response to Comment 205-22, This
response appears to acknowledge the potentially significant impact to marine species, but
fails to adopt effective mitigation measures to reduce the impact. Simply erecting signs
will not remedy the problem of cat feces contaminating coastal waters, however, because
cats are not usually kept on a leash when outside, and thus their owners will not likely
know where to pick up the waste even if they are reminded to do so. The EIR must be
revised to accurately analyze and mitigate the Project's significant impacts to sensitive
species and marine species,
Finally, the FEIR fails to analyze potential impacts associated with the
proposed filling and grading activities within the 100-foot wetland buffer. DEIR at 111-
43. The Project proposes to deposit grading spoils resulting from development of the site
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Planning Commission
November 9,2010
Page 8
in the buffer area in association with restoration activities in the buffer. However, given
that the soils could contain pesticide contaminants, the use of the grading spoils in the
restoration areas could adversely impact the existing wetlands. The wetlands buffer zone
should be just that - an undisturbed buffer protecting adjacent wetlands - not a
depository of grading spoils resulting from Project development.
3. Geology, Soils and Water Quality.
The FEIR clarifies that the Project would use infiltration to treat stormwater
runoff from the buildings. FEIR at III.B-13. To that end, all runoffwill be directed to
the parking lots, where it will purportedly seep into the ground and recharge the
groundwater. Id. Asserting that the parking lots are currently underlain with 12-18
inches of clayey, expansive, and impermeable soil, the FEIR states that the applicant will
remove this impermeable soil and replace it with gravel. Id. at IILC-4-5;.RTC 205-31;
but see IILC-9 (stating these impermeable soils will be removed "when practical"). It is
far from clear that the FEIR includes this removal in its calculation of grading, cut, and
fill required for the Project. New Table 111-9 shows no soil being "cut" from either the
Office Park or Wellness Center Parking lot. Id. at IILA-28. Additionally, the use of a
parking lot as an instrument for groundwater recharge defies common sense inasmuch as
parking lots are a common source of groundwater contamination since cars leak fluids
such as oil, gas, antifreeze, brake fluid and gear oil.
Nor does the EIR address runoff, potential flooding and water quality
impacts from this new infiltration system. The northern California rainy season can
result in intense and protracted rain events, creating a tremendous amount of stormwater
in a short period of time. During these events, soils beneath the parking lot may already
be inundated with water and saturated to a point where additional stormwater would not
infiltrate; instead it would result in surface water runoff. Despite numerous comments on
this potential impact, the FEIR still lacks a drainage plan. Absent design details and
hydrological flow data, the EIR lacks the evidentiary support to conclude that water-
related impacts such as flooding and water quality would be less than significant.
The FEIR further fails to address the propriety and feasibility of utilizing an
infiltration system on the Project site, given that the groundwater table is so high (ranging
from 3 to 9 feet below the ground surface - DEIR IV.H-51). Although the FEIR suggests
that the high groundwater table has been taken into consideration in the technical analysis
of the Project's hydrological impacts (see FEIR III.B-17), no evidence has been presented
to substantiate this suggestion. Moreover, the infiltration system has only been sized to
handle a 1O-year storm event. IILC-7. This virtually guarantees that the system will fail
several times over the life of the Project.
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Planning Commission
November 9,2010
Page 9
4. Hazards and Hazardous Materials. '
In commenting on the DEIR, we informed the County that the DEIR was
inappropriately deferring the analysis of impacts relating to hazards from pesticides or
other hazardous substances at the Project site. See Comment 205-39. We explained that
a Phase II Environmental Site Assessment (ESA) should have been prepared to fully
evaluate the extent of contamination to soils and groundwater. Id. Indeed, our request
simply reiterated what the DEIR preparers themselves recommended:
According to the Phase I ESA, one recognized environmental condition has

been identified at the project site, most likely due to the possible
application of pesticides to the soil during its use as farmland. The
assessment recommends that further investigation be conducted to identify
potential environmental liabilities which may be present at the project area.
Specifically recommended are additional investigations that are designed to
test the surface soils for pesticides and the agricultural well for the presence
of groundwater pollution.
DEIR at IV.G-7. The DEIR identified the soil contamination hazard as a potentially
significant effect and conceded that the actual impacts were not yet known. See DEIR at
IV.G-24 ("the extent of potential past contamination of soils is not yetfully known, the
impacts related to the exposure of contaminants to construction workers, nearby
businesses and residents during soil grading and excavation activities is unknown.)"
(Emphasis added.) .
Rather than conduct the necessary impact analysis, the FEIR instead
directly contradicts the DEIR - and the findings of the experts who prepared the Phase I
site assessment - when it states that "the environmental site condition identified by the
Phase I study generally does not represent a threat to human health or the
environment. .. ". See Response to Comment at 205-39. The FEIR provides no evidence
or analysis to support this assertion. Even more alarming, the FEIR states that "the Phase
II ESA is only a recommended mitigation measure and compliance is not required in
order to mitigate any potential significant effect of the project." Id. Again, as the DEIR
clearly states, the Phase II site assessment is intended to mitigate the Project's significant
impacts relating to the exposure of construction workers, nearby business and residents
during soil grading and excavation activities to hazardous contaminants. See DEIR at
IV.G-24. To the extent that the applicant intends to not conduct the necessary Phase II
site assessment, this impact is significant and unmitigated. Consequently, recirculation of
the EIR is required.
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Planning Commission
November 9,2010
Page 10
5. Airport-Related Impacts.
Numerous commenters noted the inherent risks associated with locating

this Project directly adjacent to the HalfMoon Bay Airport. The FEIR, however, fails to
fully disclose or analyze these risks. For example, the California Department of
Transportation, Division of Aeronautics, noted that "30% to 50% of near-airport aircraft
accident sites lie within the RPZ (runway protection zone) and Zone 2." In response, the
FEIR concludes that "it appears that Zone 2 would not extend over the project parcels."
FEIR at II -75 (emphasis added). However, final determination of the extent of Zone 2
must be made by the County's Airport Land Use Commission. Id. Contrary to the
FEIR's conclusion, the County cannot defer this critical analysis until after Project
approval. The County must determine the precise extent of Zone 2 prior to considering
allowing high-density residential and commercial uses of the property so close to the
airport.
The F ederal Aviation Administration (FAA) similarly noted the inherent

land use conflicts and related environmental impacts caused by locating the Wellness
Center within 500 feet of Runway 30. See FEIR App. I. As the FAA noted, the noise
from planes landing and taking off at the Airport will be considered a significant nuisance
by the Project's occupants. Id. In response, the FEIR includes revised Mitigation
Measure HAZ-3, which requires the Property owner and all Wellness Center residents to
grant an avigation easement, promising to relocate if they are unwilling to live with the
airport noise. FEIR II -79. As even the FEIR acknowledges, this easement does nothing
to mitigate the noise and hazard impacts caused by the location of the Wellness Center
next to the airport. Id. at III.C-6. Consequently, the EIR lacks the necessary evidentiary
support to conclude that health, safety and noise impacts to Project residents would be
less than significant.
Finally, the Chairperson of the County's Airport Land Use Commission

noted that the DEIR did not contain adequate analysis of the noise and wind impacts
caused by constructing the Project so near the HalfMoon Bay Airport. According to Mr.
Newman, the noise data relied on in the EIR does not accurately reflect the potentially
significant noise impacts caused by the Project's proximity to an active runway. See
Letter from Richard Newman, Chairperson of the County's Airport Land Use
Commission, attached hereto as Exhibit B, at 2. Moreover, the County did not conduct
any wind study, incorrectly assuming that the Project's location near the Airport would
not create a hazard because the hills to the west would block the wind off the ocean. To
the contrary, as Mr. Newman states, the nearby hills create wind turbulence, a problem
that will likely be exacerbated by the construction of three-story buildings nearby. Id.
Because the FEIR did not remedy these deficiencies, it is inadequate under CEQA.
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Planning Commission
November 9, 2010
Page 11
6. Transportation and Circulation Impacts.
As we explained in our comments on the DEIR, the document is hamstrung

in its analysis of transportation impacts in large part by its failure to adequately describe
the characteristics of the local roadways in the Project vicinity. Because the Project site
is relatively remote, and tucked behind a rural residential community, access to the site is
highly constrained. Only a few roads provide direct access to the site and these roads are
very narrow and appear to be substandard. Clearly these narrow roads were never
intended to support a use as intensive as the Big Wave Project. Because the EIR fails to
disclose the highly constrained nature of site access, it necessarily downplays the impacts
that would result from construction and operation of the Project. In response to this
comment, the FEIR admits that Appendix J: Addition of Big Wave Office Park and
Wellness Center Traffic Report, prepared by Hexagon Transportation Consultants, Inc.
(Hexagon), June 24, 2009 was inadvertently omitted from the DEIR. .See FEIR Response
to Comments 205-43. Yet, our review of Appendix J does not provide any of the
information we requested in our letter on the DEIR. In this regard the EIR continues to
be legally inadequate.
In addition, the County Staff recommended Alternative C includes "a new

on and off-site traffic circulation option" that would prohibit traffic on Cypress Avenue.
See FEIR at III.A-3. Consequently, the FEIR boldly proclaims that this new circulation
option would result in traffic benefits. Id. and FEIR, Appendix G. 4 Yet what the FEIR
fails to make clear is that the new traffic analysis actually admits that the revised
circulation option may result in new impacts (i.e., exceed level of service "C") at several
area intersections including, but not limited, Cabrillo Highway at North Capistrano Road,
Prospect Way at Capistrano Road, Prospect Way at Broadway/Cornell Avenue and
Airport Road at Stanford/Avenue/Cornell Avenue. See FEIR, Appendix G. While
Appendix G deliberately does not use the term "significant" in its discussion of these new
Project impacts, it does nonetheless look to a newly revised mitigation measure to reduce
these transportation impacts, thus implying that the EIR preparers recognized the
significance of the Proj ect' s traffic impacts. Yet, as discussed below, this mitigation is
entirely inadequate and therefore the EIR lacks the evidentiary support to conclude that
the Project's newly identified traffic impacts would in fact be less than significant.
Consequently, the identification of these new significant traffic impacts requires
recirculation of the EIR for public review and comment.
Notwithstanding the FEIR's determination of new Project-specific and

cumulative traffic impacts, the FEIR fails to adequately analyze these impacts. For
4 No page numbers are cited because Appendix G contains no page numbers.
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Planning Commission
November 9, 2010
Page 12
example, as discussed above, the FEIR acknowledges that the new traffic circulation
option has the potential for several area intersections to exceed the level of service "c"
standard. FEIR, Appendix G. Yet the new analysis never actually conducts the required
intersection level of service analysis as required by CEQA. An EIR must include
sufficient detail about the specific impacts connected with the Project before it will be
adequate under CEQA. See Whitman v. Board a/Supervisor, 88 Cal. App. 3d 397, 411
(1979) ("The use of phrases such as 'increased traffic' and 'minor increase in air
emissions,' without further definition and explanation, provides neither the responsible
agency nor the public with the type of information called for under CEQA."). Moreover,
the County may not use the failure of its review to avoid disclosing an impact as
significant. Here, the EIR authors use their failure to gather data as an excuse for their
inability to document the significance of the Project's impacts.
Rather than conduct this necessary impact analysis, the FEIR relies on a
newly revised measure that would allegedly mitigate the Project's significant
transportation impacts. Revised mitigation measure TRANS-1 calls for the applicant to
conduct periodic traffic studies at various times following Project occupancy and if such
studies demonstrate that study area intersections exceed level of service standards, the
applicant will identify methods for reducing vehicle trips from the Project as well as other
roadway or intersection improvements that would improve traffic operations to level "C".
FEIR, Appendix G. Yet, simply requiring the applicant to promise to conduct additional
traffic studies after project approval and then leaving the actual corrective method up to
the applicant is wholly inadequate to mitigate the Project's impacts on traffic. The EIR
provides no basis to judge how or whether this measure would be effective. Rather it is a
"mere expression[] of hope" that the County - or more aptly the applicant - will be able
to devise a way around the problem of an inadequate transportation network. Lincoln
Place Tenants Ass 'n v. City a/Los Angeles, l30 Cal. App. 4th 1491, 1508 (2005). CEQA
requires more than that to mitigate significant impacts. Id. Indeed, given the highly
constrained nature of the area's roadways, it may simply not be possible to mitigate the
Project-specific and cumulative traffic impacts to a less-than-significant level.
Indeed, the new circulation option would likely have numerous effects on
traffic patterns in the Project study area that remain unanalyzed. For example, if Project
traffic is directed to the south, it will funnel onto Prospect Way. This will create a
chokepoint on this narrow street. The EIR must analyze these impacts, including an
evaluation of whether the Project's traffic would exceed level of service standards and, if
so, identify specific measures to mitigate them now, prior to the County's consideration
of the Project. In the absence of a legally sufficient transportation analysis, decision
makers and the public are simply left in the dark as to the impact this Project would have
on the area's transportation system.
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Planning Commission
November 9, 2010
Page 13
There are also numerous additional flaws in the FEIR's new traffic report
that warrant recirculation of the EIR. First, the new traffic study is buried in a technical
appendix rather than in the EIR itself. CEQA requires that the analysis be presented in
the EIR. See Santa Clarita Organization/or Planning the Environment v. County o/L.A.
("SCOPE") (2003) 106 Cal. App. 4th 715, 722 (agency's analysis must be contained in
the EIR, not "scattered here and there in EIR appendices"). Second, the revised
circulation pattern may result in myriad other potentially significant impacts, none of
which appear to have been studied in the EIR. For example, the new traffic study states
that the intersection of Cabrillo Highway at North Capistrano Road has sight visibility
constraints for cars being detained at the signalized intersection. FEIR Appendix G.
Despite this acknowledgment, we can find no analysis of the effect this sight visibility
constraint would have on public safety. For example, would this limited sight distance
result in an elevated risk of accidents? In addition, the Project site is in a tsunami zone.
As such adequate emergency evacuation routes are of critical importance. Yet, we can
find no analysis of how the Project's revised circulation plan would affect emergency
access. Nor can we find an analysis of the traffic impacts that would occur during Project
construction as a result of this new circulation pattern. In addition, the FEIR fails to
study the effect of the revised circulation plan on pedestrian and bicycle routes.
Finally, as we explained in our prior letter, it is not sufficient to delay for

five years the installation of a traffic signal at Cypress Avenue and Highway 1 inasmuch
as traffic is projected to operate at level of Service F upon implementation of the Project.
The FEIR preparers apparently recognized this flaw and the document now revises this
mitigation measure and explains that if a traffic signal is warranted at this intersection it
would be installed within one year - rather than five years - of Project occupancy. FEIR
at 11-54,55. Yet twelve months is still too long for area motorists to endure traffic
gridlock. The FEIR provides no explanation as to why this traffic signal will not be
installed prior to project occupancy. Consequently, the EIR lacks the evidentiary support
to conclude that the Project's traffic impacts would be less than significant.
7. Wastewater Treatment.
Notwithstanding numerous comments, including those submitted by the

Granada Sanitary District (GSD), regarding the design and operation of the Project's
wastewater treatment plant, the FEIR still fails to adequately evaluate this critical issue.
Indeed, what information that is provided in the FEIR raises more questions than it
answers about the ability of this Project to even provide wastewater service, let alone the
environmental implications of the applicant's proposed approach. We note in particular
that the FEIR fails to adequately respond to the myriad comments raised by GSD. This
letter hereby incorporates by reference GSD's December 5, 2008, February 20, 2009,
SHUTE MIHALY
Planning Commission
November 9, 2010 .
Page 14
October 30,2009 and December 22,2009 letters, and each'ofthe letters' technical
appendices, by reference.
Changes to the Project's wastewater system would result in impacts far

more severe than disclosed in the DEIR. As originally contemplated, the applicant
intended for the Project to handle much (the EIR fails to disclose the exact volume) of the
Project's wastewater demand on-site. Yet, as even the DEIR concedes, even with the
onsite drain field, the Project plans failed to demonstrate that GSD had adequate
capacity to handle the Project's wastewater flows. See DEIR at IV-N-15 (emphasis
added). Indeed, the DEIR identified this impact as potentially significant. DEIR at III.B-
31. Now with the elimination of the onsite drain field, GSD will be forced to
accommodate much, if not all, of the Project's wastewater demand. Id., see also FEIR
Volume 1 III.B-29; DEIR at IV.N-13, 15; and FEIR Response to Comment 205-60(3). In
addition, while the FEIR now discloses that the proposed Project will likely require GSD
to construct additional sewer system capacity (see FEIR at Response to Comment 205-
60), the EIR fails to disclose or evaluate the potential for this construction to result in
significant environmental effects as required by the EIR's thresholds of significance. See
DEIR at IV.N-10.
Nor does the EIR evaluate the environmental implications associated with
the applicant owning and operating an on-site wastewater treatment plant. Wastewater
treatment plants serve the critical function of protecting people and the environment from
exposure to untreated wastewater. The objective of wastewater treatment is to produce a
disposable effluent in a reliable manner without harming the community or polluting
nearby water bodies. If not properly maintained or operated, wastewater treatment plants
can malfunction, discharging untreated or partially treated effluent into the environment
and causing significant, adverse environmental impacts. The EIR provides no evidence
that the applicant is, in any way, sufficiently trained to operate this complicated facility.
The EIR should be revised to provide evidence that the operation of the Project's
wastewater treatment plant would not harm the environmental or the health of nearby
residents.
The EIR's approach to mitigating the Project's significant impacts relating

to wastewater service capacity remains flawed. The DEIR proposed to mitigate these
impacts either by revising the Project design to limit the sewage flow or to expand the
capacity of the sewer system. DEIR at IV.N-15 and FEIR Volume I Page III.B-31. The
FEIR now suggests that the implementation of this mitigation measure would require
separate CEQA review. There are several flaws with the EIR's approach to mitigation.
First and foremost, issues relating to the adequacy of sewer service and the environmental
impacts associated with inadequate sewer service must be resolved now, prior to Project
SHUTE MIHALY
Planning Commission
November 9,2010
Page 15
approval. The applicant cannot simply promise to change the Project once the Project is
approved. This approach, positing the illusory "mitigation" that the entire project could
be changed at some point after project approval is quite similar to the approach taken by
Stanislaus County and rejected by the court in Stanislaus Natural Heritage Project v.
County o/Stanislaus, 48 Cal.App.4th 182 (1996). In that case, the County had approved
a 25-year development plan when sufficient water had been secured only for the first five
years of the project. See id. at 195. Much like San Mateo County in the present case,
Stanislaus County inserted as mitigation that development would not proceed until
environmental impacts from obtaining additional water had been studied and mitigated.
See id. Disapproving this approach, the court found that a commitment had been made in
the present to the 25-year project and did not find credible the claim that the pre-
approved development would be stopped in its tracks at a later date if CEQA could not be
complied with. See id. at 195-196. Instead, the court required that the county analyze in
detail the water supply issues prior to project approval. San Mateo County, like
Stanislaus County, must provide complete environmental review at this stage in the
process.
Moreover, the FEIR cannot simply promise to conduct further

environmental review if it ultimately determines an expansion of the wastewater
treatment plant is necessary. Again, the Project cannot move forward in the absence of
wastewater treatment service. Consequently, issues relating to this service must be
resolved now. This includes, of course, the analysis of environmental impacts that would
result from the provision of wastewater service.
The FEIR also fails to resolve impacts relating to the undersizing of the
sewer connection line. As the DEIR explains, "no hydraulic analysis has been completed
by the applicant to confirm that the existing 8-inch sewer line has sufficient capacity to
accommodate additional flows of26,000 gpd." DEIR at IV.N-15. An undersized sewer
line could certainly result in significant environmental impacts if raw or even treated
sewage backs up onto the Project site or the surrounding area. Yet, the EIR fails to even
acknowledge the potential for a sewer service disruption, let alone the environmental
implications of such an occurrence.
In addition, the proposed elimination of the Project's onsite drain field

would exacerbate GSD's and the Sewer Authority Mid-Coastside's ("SAM" or
"Authority") capacity overflow problems during heavy rain periods. As we explained in
our comment letter on the DEIR, dry weather flow capacity is only one portion of the
equation. The EIR must address the more important concern relating to GSD' sand
SAM's wet weather flow capacity, and the ability of these sewer districts to
accommodate the proposed Project's wastewater flows during storm events. The DEIR's
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Planning Commission
November 9, 2010
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"analysis" of these issues was extraordinarily vague and ambiguous and the FEIR fails to
resolve the DEIR's many serious deficiencies.
The FEIR also fails to resolve whether the Miramar Pump Station (now
referred to as the Naples Beach Pump Station in the FEIR) will be sufficient to serve the
proposed Project. Indeed, the FEIR raises more questions than it answers when it states
that "as construction will be initiated based on economic demand, it is difficult to assess
whether the Miramar force main will be constructed and ready to serve the project should
the project wastewater connection needs exceed 8 EDUs." FEIR at Response to
Comment at 205-60(1).
The FEIR is further deficient in its failure to analyze the environmental

impacts of the proposed treatment plant. Although the applicant proposes to build a
wastewater treatment plant sized to handle double the required capacity (FEIR at III.B-30
(emphasis added)), the document fails to evaluate the environmental impacts of the entire
plant. The EIR makes clear that the size of the treatment plant is intended to allow for
redundancy and to allow potential future expansion ofservice. Id. (emphasis added).
Instead of providing an analysis of the environmental effects of the construction and
operation of the treatment plant, including the growth-inducing impacts of such a plan,
the FEIR states that "any future expansion of the wastewater treatment plant would not be
covered under this CEQA document." Id. As discussed above, inasmuch as the
oversized treatment plant is being constructed as part of the current project, the EIR must
analyze these environmental impacts now, not as part of some future environmental
study.
Finally, the FEIR fails to provide an analysis ofGSD's and SAM's ability
to accommodate the cumulative increase in wastewater demand or the environmental
impacts that may result from cumulative wastewater demand. Indeed, the DEIR
identifies the cumulative wastewater demand as a potentially significant impact (at IV.N-
20) yet fails to provide the actual analysis of this impact. While the EIR is undoubtedly
correct to conclude that this impact is significant, a conclusion of significance cannot take
the place of description and analysis of the impact. See Stanislaus Natural Heritage
Project v. County ofStan is la us , 48 Cal. App. 4th 182 (1996) (invalidating EIR that had
failed to adequately analyze water supply impacts but found them to be significant and
unavoidable). The FEIR, like the DEIR, provides no information whatsoever of the
cumulative increase in wastewater demand from other proposed development in the GSD
and SAM service areas and does not evaluate the ability of these agencies to
accommodate this demand.
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Planning Commission
November 9, 2010
Page 17
8. Solid Waste Impacts.
The FEIR contradicts the DEIR as regards the capacity and eventual closure
of the Ox Mountain Landfill and therefore remains deficient with regard to the analysis of
the Project's solid waste impacts. The DEIR clearly explains, based on information from
the California Integrated Waste Management Board ("CIWMB"), that Ox Mountain is
currently in excess of its total permitted capacity and that the landfill is expected to close
in 2018. See DEIR at IV.N-39. Rather than provide detail about the Ox Mountain
Landfill's capacity and the ability of the landfill to meet the solid waste generated by the
Big Wave Project, the FEIR simply asserts that the landfill operator has concluded that
the CIWMB documentation is erroneous. See FEIR Response to Comment 205-59. The
document does not, however, provide any evidence or analysis to support the operator's
conclusion. According to the CIWMB's Ox Mountain Facility Site Summary Details, Ox
Mountain is, indeed, scheduled to close in 2018. See CIWMB Ox Mountain Facility Site
Summary Details, attached as Exhibit C.
Moreover, the FEIR incorrectly asserts that the status of the Ox Mountain
Landfill and potential impacts to solid waste services is a regional planning issue and is
therefore outside of the purview of this EIR. See FEIR Response to Comment 205-59.
Contrary to this assertion, it is the very purpose of this EIR to evaluate whether sufficient
capacity exists to accommodate the Project's solid waste disposal needs. See DEIR
thresholds of significance at DEIR IV.N-42. Inasmuch as the agency with regulatory
authority over landfills has determined that the Ox Mountain Landfill does not have
sufficient capacity to serve the long term needs of the Big Wave Project, this impact is
significant and the EIR must be recirculated.
Finally, it is important to note that the FEIR fails to respond altogether to

other comments pertaining to the project-specific and cumulative solid waste service
impacts. For example, the FEIR ignores comments pertaining to the DEIR's failure to
analyze or resolve issues relating to: a) the Project's compliance with local statutes and
regulations; b) requirements pertaining to the preparation of a Waste Management Plan;
and c) cumulative solid waste impacts.
9. Air Quality Impacts.
Like the DEIR, the FEIR fails to adequately evaluate impacts relating to the
Project's air quality impacts. For example, as discussed above, the Project has been
revised to eliminate the Project's septic fields (Response 205-52), yet the EIR still fails
to analyze the effect that odors from the Project's three separate water recycling plants
would have on the adjoining residential community and Project residents and employees.
Indeed, the FEIR does not appear to even identify the location of the three treatment
SHUTE MIHALY
Planning Commission
November 9,2010
Page 18
plants so it is not possible to evaluate whether they are upwind or downwind of

neighboring residents or the Project's residents. Nor does the EIR provide the necessary
detail about the design, engineering or operation of the plants. Instead of providing this
information and an evaluation of the Project's potential odor impacts, the FEIR simply
asserts that the systems will be in plastic tanks with 2 feet of soil cover and that each
system will be required to comply with nuisance odor requirements of the BAAQMD
permits, Regional Water Quality Control permit and the Environmental Health permit
processes. The EIR should be revised to evaluate the potential for odor impacts and
identify mitigation measures or an alternative site design if the impacts are determined to
be significant.
10. Impacts to Agricultural Resources.
As the Committee for Green Foothills explained in its comments on the

DEIR, the Project would result in a significant impact to agricultural resources because of
the conversion ofagriculturallands. 5 See Comment 193-17. The FEIRresponds by
stating that the loss of these farm lands are not significant because the parcels are
designated for urban uses by the County's General Plan and Local Coastal Program
(LCP). FEIR Response to Comments 193-17.
The FEIR is incorrect to base its determination of no significant impact on

the fact that farmland conversion is already expected in the general plan and LCP.
CEQA requires that the significance of impacts be measured against a baseline of
existing conditions, not future conditions. 14 Cal Code Regs § 15125 (a); see also,
Woodward Park Homeowners Ass 'n v. City ofFresno, 150 Cal. App. 4th 683, 707 (2007)
(EIR must "compare what will happen if the project is built with what will happen if the
site is left alone."). The fact that regional planning documents acknowledge that
farmland conversion may occur in the future is irrelevant to the analysis of whether the
Big Wave Project or other past, current and probable development projects will have a
significant or cumulatively significant impact on farmland.
Because it finds no significant impacts on agricultural resources, the EIR does not
require any mitigation measures. Given that its finding of no significant impact is not
supported by substantial evidence, the EIR must be redrafted and must incorporate all
feasible mitigation measures. Such measures could include, but are certainly not limited
to, purchasing agricultural easements on nearby land to protect it from future
5The EIR also fails to adequately analyze or mitigate the Project's cumulative
impacts to agricultural resources.
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Planning Commission
November 9,2010
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development and the payment of mitigation fees. Other feasible mitigation measures are
identified in the Department of Conservation January 31, 2008 Letter from Dennis J.
O'Bryant to Jim Louie, attached as Exhibit C.
11. Inconsistencies Relating to General Plan and Zoning.
The EIR erroneously concludes that the Project is consistent with the
General Plan designation and zoning for the site, and, as a result, concludes that the
Project will not have a significant impact on land use in the County. However, the
General Plan designation for that portion of the site proposed for development is
"General Industrial," which allows "manufacturing and processing uses including but not
limited to fabricating, assembling, and storing products." General Plan Table 7.1 P, page
7.5P. Residential uses, like the Wellness Center, are not permitted. Nor are general
commercial uses, such as the "general office" space proposed to occupy 40% of the
office park.
The EIR attempts to sidestep this obvious inconsistency by noting that a

"sanitarium" may be permitted in any zoning district with a conditional use permit.
However, that fact does not mean that a sanitarium use could be located anywhere in the
County regardless of the general plan designation. Under state law, the general plan is
the constitution for development, and all zoning regulations and land use decisions must
be consistent with it-not the other way around. Lesher Communications, Inc. v. City of
Walnut Creek (1990) 52 Ca1.3d 531,540; see also Gov't Code § 65860(a) (zoning
ordinances shall be consistent with general plan); Gov't Code § 6647.35 (tentative maps
must be consistent with general plan); Neighborhood Action Group for the Fifth District
v. County of Calaveras (1984) 156 Cal.App.3d 1176, 1184 (conditional use permit must
be consistent with general plan). The County's attempt to let a zoning regulation trump
the General Plan violates this bedrock principle of planning.
The Project is also inconsistent with the uses permitted in an Airport

Overlay (A-O) district. This zoning designation covers the portion of the Project site that
is closest to the airport. As we noted in our comments on the DEIR, the County's zoning
ordinance prohibits residential uses in the A-O district that would involve more than three
persons in the A-O zone at one time. See DEIR at IV.I-9. The EIR concludes the Project
is consistent with this requirement because it locates only parking lots, storage facilities,
and a garage in the A-O zone. However, the Wellness Center parking lot is an essential
component of that residential use, and there is no evidence to support the conclusion that
only three or fewer people will ever use this parking lot at anyone time.
Similarly, the location of the storage facility portion of the Wellness Center
within the A-O district violates the County's zoning ordinance. It appears that these
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Planning Commission
November 9, 2010
Page 20
facilities are actually part of the larger Wellness Center building, not a separate building.
See Revised Figure 111-16. Thus, any damage that occurs to that portion of the Wellness
Center as the result of an aviation accident will likely impact the 50+ residents of the
Wellness Center, as well.
In sum, the Project is inconsistent with both the General Plan designation
for the site and the zoning. As a result, the EIR must be revised and recirculated with
analysis of this significant impact and proposed mitigation and/or alternatives. More
importantly however, this inconsistency means that the County cannot approve the
Project without first amending both the General Plan designation and zoning for the site.
12. Cumulative Impacts.
The EIR's analysis of cumulative impacts betrays an essential

misunderstanding of the concept of cumulative impacts. Under the Guidelines, "a
cumulative impact consists of an impact which is created as a result of the combination of
the project evaluated in the EIR together with other projects causing related impacts"
Guidelines § 15130(a)(l). Because "[c]umulative impacts can result from individually
minor but collectively significant projects" (Guidelines 15355(b)), an impact that appears
less than significant (or mitigable to such a level) when only the project is scrutinized
may tum out to contribute to a significant cumulative impact. In that case, the EIR must
determine whether the project's contribution is "cumulatively considerable:" that is,
whether its "incremental effects ... are significant when viewed in connection with the
effects of past projects, the effects of other current projects, and the effects of probable
future projects." Guidelines § 15065(a)(3).
This EIR, however, completely failed to consider cumulative impacts in

many areas. Instead it assumed that if an impact was less than significant, it could not be
cumulatively considerable. This, of course, turns cumulative analysis on its head. The
whole point of analyzing cumulative impacts is to determine whether a collection of less
than significant impacts may add up to a significant one. It is wholly inappropriate to end
a cumulative analysis on account of a determination that the project's impact was less
than significant. That should be the beginning of the analysis.
In addition to the deficiencies in the cumulative impact analyses discussed

above, and in this firm's comment letter on the DEIR, the EIR also fails to adequately
examine cumulative impacts to water quality. Cumulative impacts to water quality occur
when many sites within the same watershed each contribute some pollutants to runoff.
When all the relatively small contributions are added up, a significant impact may occur.
Cumulative stormwater quality impacts are associated with almost all projects that
propose uses of increased intensity relative to existing conditions. The most common
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~WEINBERGERLLP
Planning Commission
November 9, 2010
Page 21
cumulative stormwater quality impact results from urbanization. Most urbanization is

associated with an increase in impervious surfaces and automobile use (as with the
proposed Project). An individual project may not, by itself, result in discharges of
pollutants at a level that would violate water quality objectives or substantially degrade
the quality of receiving waters (although this lack of "project level" impact has not been
adequately established in this EIR). The assimilative capacity of the receiving waters
might receive these pollutants without measurable impact to beneficial uses. However, if
the degraded runoff from the proposed Project is added to degraded runoff from all the
other developments in the watershed, it is likely that substantial water quality degradation
will occur. The EIR completely misses the mark and fails to analyze this likely
cumulative impact.
Rather than analyze the Project's cumulative impacts to water quality, the
EIR relies on the Project's future compliance with NPDES permit requirements to
conclude that impacts on water quality will not be significant. By adhering to these
standards the document asserts, runoff from the Project would not contribute significantly
to any deficiencies in water quality. FEIR Response to Comments 185-32. In other
words, water quality impacts will not be cumulatively considerable because they will not
be individually significant. This approach neglects the cumulative water quality impacts
resulting from the Project in conjunction with other regional projects. As discussed
above, this logic completely contradicts the purpose of cumulative analysis.
II. Approval of the Project Would Violate California Planning and Zoning Law.
The State Planning and Zoning Law (Gov't Code § 65000 et seq.) requires
that development decisions be consistent with the jurisdiction's general plan. As
reiterated by the courts, "[ u ]nder state law, the propriety of virtually any local decision
affecting land use and development depends upon consistency with the applicable general
plan and its elements." Resource De/ense Fundv. County o/Santa Cruz (1982) 133
Cal.AppJd 800, 806. Accordingly, "[t]he consistency doctrine [is] the linchpin of
California's land use and development laws; it is the principle which infuses the concept
of planned growth with the force oflaw." Families Unafraid to Uphold Rural El Dorado
County v. Board o/Supervisors (1998) 62 Cal.AppAth 1332, 1336.
To promote coordinated land use policies and practices, state law requires
local governments not just to formulate theoretical land use plans, but also to conform
their development and land use projects and approvals with those duly certified plans.
Citizens o/Goleta Valley v. Bd. o/Supervisors (1990) 52 Ca1.3d 553, 570; see also Gov't
Code §§ 65860 (requiring consistency of zoning to general plan), 66473.5 & 66474
(requiring consistency of subdivision maps to general plan, and 65867.5 (requiring
consistency of development agreements to general plan). It is an abuse of discretion to
SHUTE MIHALY
Planning Commission
November 9, 2010
Page 22
approve a project that "frustrate[s] the General Plan's goals 'and policies." Napa Citizens
for Honest Gov't v. Napa County (2001) 91 Cal.App.4th 342, 379. The project need not
present an "outright conflict" with a general plan provision to be considered inconsistent;
the determining question is instead whether the project "is compatible with and will not
frustrate the General Plan's goals and policies." Napa Citizens, 91 Cal.App.4th at 379.
For the reasons described in Part I of this letter, the Project is inconsistent
with the San Mateo County General Plan and Zoning. Because of the Project's glaring
inconsistencies with these planning and zoning provisions, approval of this Project would
violate State Planning and Zoning Law.
III. Approval of the Project Would Violate the San Mateo County Local Coastal
Program and the California Coastal Act.
The proposed Project is located in the coastal zone, as defined by the

California Coastal Act, Pub. Res. Code §§30000-30900. According to the FEIR, some
portion of the Project Site may lie within the original permit jurisdiction of the California
Coastal Commission, while the rest is subject to the County's permitting authority as set
forth in the San Mateo County Local Coastal Program (LCP). Because the proposed
Project would result in significant and unmitigated impacts to coastal zone resources, it
violates both the California Coastal Act and the County's LCP.
The County's LCP defines sensitive habitats as "any area in which plant or
animal life or their habitats are either rare or especially valuable" and any area that meets
certain criteria, including: 1) habitats containing or supporting rare and endangered
species, 2) all perennial and intermittent streams and their tributaries, 3) coastal tidelands
and marshes, 4) coastal and offshore areas containing breeding or nesting sites and
coastal areas used by migratory and resident water-associated birds for resting areas and
feeding. LCP Policy 7.1.
The Project site contains all of the aforementioned resources and therefore
is a sensitive habitat as defined by the LCP. Development of the proposed Project would
impact suitable habitat for several special-status species, including the California red-
legged frog and the San Francisco garter snake. See USFWS letter to County dated
February 27, 2009 at 2, attached as Exhibit A. The Project would also result in the
permanent loss of agricultural lands that, as the DEIR acknowledged, would likely revert
to Northern Coastal Salt Marsh if agricultural production were stopped. DEIR at IV.D-
23. This type of marsh has high wildlife value and supports a variety of species including
the endangered California and light-footed clapper rail, California black rail, salt marsh
yellowthroat, Belding's Savannah sparrow, and the endangered salt marsh harvest mouse.
SHUTE MIHALY
~WEI N BERGERLLP
Planning Commission
November 9,2010
Page 23
DEIR at IV.D-84. Thus, the Project would jeopardize sensitive species likely to occur on
site and/or that have the potential to occur if the agricultural lands were restored.
The impacts described above give rise to inconsistencies with LCP Policy
7.4 Permitted Uses in Sensitive Habitats, which permits only resource dependent uses in
sensitive habitats and Policy 7.3 Protection of Sensitive Habitats, which prohibits
development that would have significant adverse impacts on sensitive habitat areas and.
In addition, the Coastal Act specifies protection for environmentally sensitive habitat
areas (ESHAs). Specifically, it states:
(a) Environmentally sensitive habitat areas shall be protected

against significant disruption of habitat values, and only uses
dependent on those resources shall be allowed in those areas;
(b) Development in areas adjacent to environmentally
sensitive habitat areas ... shall be sited and designed to prevent
impacts which would significantly degrade those areas, and
shall be compatible with the continuance of those habitat
areas. Coastal Act § 30240.
Therefore, even if a use is dependent on the resources in sensitive habitat areas (which
this Project is not), LCP Policy 7.3(b) and Coastal Act Policy 30240(b) require that
development in areas adjacent to the sensitive habitat be sited to prevent impacts that
would significantly degrade those areas and prohibits uses that adversely impact the
biologic productivity of the habitats.
Clearly, the proposed Project's office park and residential center, which are
located adjacent to sensitive habitat but are not dependent on any sensitive habitat
resources, will significantly degrade these areas. Committee for Green Foothills has
objected to the destruction of wetlands on the southern parcel (residential center) as
delineated by the Army Corps of Engineers June 20, 1994 (see Final EIR Section III-D
New Figures). The destruction of wetlands for agricultural purposes and their conversion
to residential use violates Section 30240(a) of the LCP. Moreover, regardless of how the
use is characterized, the Project's permanent destruction of habitat values in the sensitive
habitat areas (Le., the permanent destruction of wetlands that are currently farmed but
could be restored) render it inconsistent with both the LCP and the Coastal Act.
Moreover, according to comments submitted by the Coastal Commission,

the Project site may also include historic tidelands that are within the Commission's
original permit jurisdiction. FEIR, Comment Letter 213 at 1. Therefore, the Proj ect
would require a coastal development permit from the California Coastal Commission and
would be subject to consistency with the California Coastal Act. Id. Notwithstanding a
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Planning Commission
November 9,2010
Page 24
mitigation measure added to the FEIR requiring the property owner to coordinate with
the Coastal Commission, the EIR defers analysis of the Coastal Commission's
jurisdiction on the site and of the Project's consistency with the California Coastal Act.
This deferral of analysis is unlawful under CEQA.
IV. The County Cannot Make the Findings Required for the Project Approvals.
Attachment A to the staff report for the proposed Project contains

recommended findings in support of the various land use approvals required for the
Project. Given the potentially significant impacts discussed above and in our previous
comments on the DEIR, several of these proposed findings are not supported by
substantial evidence in the record. As a result, the County cannot approve the Project as
proposed.
A. CEQA Findings.
Paragraphs 1 through 4 of the recommended findings state that the EIR is

adequate under CEQA and that the Project, as mitigated, will have no significant impact
on the environment. For all the reasons stated above and in our comments on the DEIR,
these findings are not supported by substantial evidence.
B. Subdivisions Findings.
Paragraphs 5 through 12 of Attachment A include the findings required for

approval of the Project's proposed major and minor subdivisions. However, several of
these findings are unsupported by substantial evidence. For example, paragraph 5 states
that the Project is consistent with the County's General Plan. To the contrary, the
General Plan designation for the site is "General Industrial," while the proposed uses are
almost exclusively residential and commercial.
Similarly, the County cannot, consistent with the evidence before it, make
the finding that the Project site is "physically suitable for the type and proposed density
of the development." As discussed above, the proposed Project site is threatened by
tsunamis, earthquakes, and hazards associated with the Half Moon Bay Airport, which
operates across the street. The site is further constrained by the clayey, impermeable, and
expansive soils underlying it. Access to the site requires traffic to use narrow,
substandard streets that were not designed to accommodate a use as intensive as the
proposed Project. Such a site is clearly not suitable for a residential development for a
vulnerable population or a 225,000 square foot commercial development. Nor is it
suitable for a project that proposes to rely heavily on private wastewater treatment
systems and infiltration devices to minimize stormwater runoff.
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Planning Commission
November 9,2010
Page 25
For similar reasons, the County cannot find that the "design of the subdivision and
the proposed improvements are not likely to cause serious public health problems,
substantial environmental damage, or substantially and avoidably injure fish or wildlife
of their habitat." Staff Report, Attach. A, at 71. As described at length in this and our
previous comment letter, the Project will have potentially significant, adverse
environmental impacts, including impacts to special status species and their habitat.
C. Coastal Development Permit Findings.
The staff report for the Project recommends that this Commission find that
the Project conforms with the plans, policies, requirements and standards of the San
Mateo County LCP. Staff Report, Attachment A, at 72. It does not. As discussed above,
the Project flatly contradicts the LCP's restrictions on development in and dear
environmentally sensitive habitat areas. See LCP Policies 7.3 & 7.4; see also Coastal Act
§ 30240. In addition, the Committee for Green Foothills comment letter provides
extensive analysis demonstrating that the Project is inconsistent with numerous LCP
policies, including those related to Locating and Planning New Development, Public
Works, Housing, Agriculture, Sensitive Habitats, Visual Resources, Hazards, Shoreline
Access, Recreation/Visitor Serving Facilities and Commercial Fishing/Recreational
Boating Components, as well as the public access and recreation policies of the Coastal
Act (Section 30604). Therefore, the County cannot make the findings required to issue a
Coastal Development Permit for the Project.
D. Conditional Use Permit Findings.
Even if the Project were consistent with the General Plan designation for
the site, the Project does not fit any conventional definition of "sanitarium," and thus may
not be permitted in the "Waterfront District" through issuance of a conditional use
permit. A defining feature of a sanitarium is that it provides treatment to those suffering
from some illness. As the FEIR recognizes, the Wellness Center proposes to provide no
such treatment. FEIR at II-67. It is a residential facility. Thus, contrary to the EIR's
conclusion, the Wellness Center may not be permitted as a conditional use.
Additionally, the County cannot make the findings required to issue such a
conditional use permit. The County's Zoning Regulations permit sanitariums as a
conditional use only "when found to be necessary for the public health, safety,
convenience or welfare." County Zoning Regulations, Chapter 24, section 6500(d). Far
from being necessary for the public health, safety, or welfare, the Project actually poses
potential risks to it, as discussed throughout this comment letter and in many others.
Specifically, the Project would place housing for developmentally disabled adults and
over 200,000 square feet of office space immediately adjacent to an airport, in a tsunami
SHUTE MIHALY
Planning Commission
November 9, 2010
Page 26
inundation area, and near a fault line, exposing the Project occupants to both man-made
and natural hazards. FEIR at 11-75. Moreover, the construction of the Project may create
new wind hazards for aircraft using the neighboring airport. Thus, far from advancing
the public's welfare, the Project as currently proposed may well endanger it.
V. Conclusion.
F or all of the foregoing reasons, we respectfully submit that the Planning

Commission cannot lawfully approve the Project as currently proposed. The Project
should be redesigned in a manner that is consistent with the County General Plan and
zoning, and the California Coastal Act, including the Local Coastal Program. Moreover,
the Commission must direct staff to revise the EIR to remedy the deficiencies identified
in this letter and recirculate any revised EIR for additional public review.
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP
Winter King
List of Exhibits:
Exhibit A: USFWS letter to County dated February 27, 2009

Exhibit B: Richard Newman, Chairperson of the County's Airport Land Use
Commission Letter
Exhibit C: CIWMB Ox Mountain Facility Site Summary Details
Exhibit D: Department of Conservation Letter from Dennis J.
O'Bryant to Jim Louie, January 31, 2008
cc: Lennie Roberts, Committee for Green Foothills

Sarah Damron, Surfrider Foundation San Mateo County Chapter
\\SmwO\ \voll_data\CGF\Big Wave\FEIR Comment Letter FINAL.doc
SHUTE MIHALY
~ WEI N B ERG E R LLP
· EXHIBIT A
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Sacramento Fish and Wildlife Office
2800 Cottage Way, Room W-2605
Sacramento, California 95825-1846
In Reply Refer To: FEB 272009

81420-2009-TA-0452
Ms. Camille Leung

San Mateo County Planning and Building Department
Redwood City, California 94063
Subject: Comments on the Big.Wave Project near the City of Half Moon Bay. in
San Mateo County, Califbmia
Dear Ms. Leung:
This letter contains the U.S. Fish and Wildlife Service's (Service) comments on the Big Wave
Project near the City of Hal fMoon Bay, San Mateo County~ California. The Service received
the project information and facilities Plan: Draft 2, Big Wave Property on January 21, 2009.
Our comments are provided under the authority of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531 etseq.)(Act).
It i~ our understanding the proposed project consists of the construction of four three-story
buildings and associated parking lots, 70 residential units, a storage building, a sWimming pool,
and associated infrastructure which includes parking lots, on-site trails and walkways, a water
treatment facility, and seawater desaJioization faci1ity~ The proposed project also includes 75
acres of row-crop agricultural areas, a native plant nursery, and livestock fanning and dairy
operation, The proposed project includes wetlands restoration, a groundwater infiltration
system, and the extension of the coastal trail to the Pillar Point Bluffs. The proposed project is
located adjacent to and within the Half Moon llay Airport property on Airport Street.
The Service is concerned about the potential adverse effects of the project on the threatened
California red~legged frog (Rana aurora draytonii) (red.legged frog) and the endangered San
Francisco garter snake (Thamnophis sirtalis tetralaenia) (garter snake). The Service is also
concerned that portions of the proposed project may adversely affect the threatened marbled
murrelet (Branchyramphus marmoratus), threatened pacific Coast population of the western
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Ms. Camille Leung 3
found that California red-legged frog migration corridors can be less "pristine'~ (e.g., closely
grazed fields, plowed agricultural lands) than breeding or non-breeding habitats. Bulger et al.
(2003) observed that this listed ranid did not avoid or prefer any landscape feature or vegetation
type. They tracked jndividuals that crossed agnculturalland, including recently tilled fields and
areas with mature crops. Due to the presence of suitable habitat and connectivity between
documented sightings, nearby observations ofred~legged frogs, garter snakes, and its prey, the
Pacific tree frog at or near the site, and the biology and ecology of these two·listed species, the
SetVice believesthat the garter Shake and ied';leggedfrog arereasonably certairi to occur at the
proposed project area.
The proposed project includes the extension of the existing coastal trail to the Pillar Point
Bluffs and the addition of desalination and brine return pipelines from the proposed project area
to the ocean. The Service beHeves that the proposed extension of the coastal trail would·
increase human presence and recreational activities to the adjacent Pillar Point Harbor Beach,
thereby degrading the quality of a known roosting and foraging site for wintering Western
snowy plovers through increased human presence, unleashed dogs, kites, and other disturbing
activities. Garter snakes and red-legged frogs may be harassed, inj ured or killed by pedestrian
and bicycle traffic on the trail. Garter snakes are often attr'dCted to trails for basking and are
likely to be crushed or harassed by pedestrian and bicycle traffic on the trail.
The construction and maintenance of the desalination intake and brine return pipelines and
associated infrastructure would also adversely affect garter snakes and red-legged frogs.through
entrapment in trenches and injury or death through crushing by equipment. The proposed
desalination intake and brine return may also adversely affect marbled murrelets and Southern
sea otters. Marbled murrelets have been documented utilizing the Pillar Point harbor and
surrounding areas for foraging with sightings ranging from 2 birds to 66 (CDFG 2009).
Southern sea otters range from Half Moon Bay to Point Conception on the central and southern
Cali fomia coa')ts~ but individuals may wander as far north as Marin County and south into
Mexico.
Myrtle's silverspot butterfly was described from specimens collected in coastal San Mateo
County. It hac; not recently been observed in this area. however, no surveys have been
conducted for the animal. The larvae feed on the blue violet (Viola adunca). Myrtle's
silverspot butterfly is known frOI:ll sand dune and coastal grassland habitats.
We recommend that adequate assessments for the six listed species ~ompleted and provided
to us and the CaJifornia Department of Fish and Game for review and conunent. If appropriate,
authorization for incidental take via sections 7 or IO(a)(1)(B) of the Act should be obtained for
the California red-legged frog, San Francisco garter snake, Pacific Coast population of the
western snowy plover. marbled murrelet, southern sea otter, and Myrtle's silvers pot butterfly
prior to certification of the environmental documents prepared for the CaHtbmia Environmental
Quality Act. •
170"d 617817 £9£ 0S9 031~W N~S ~O A1NnOJ

Ms. Camille Leung 5
Literature .Cited .
Bulger, J. B., N. J. Scott Jr., and R. B. Seymour. 2003. Terrestrial activity and conservation of
adult California red-legged frogs Rana aurora draytonii in coastal forests and
grasslands. Biological Conservation 110:85-95.
California Department ofFish and Game. 2009. RAREFIND. Natural Heritage Division.
Sacramento, California.
Fellers, O. M. and P. M. Kleeman. 2007. California Red-Legged Frog (Rana drayton;;)

Movement and Habitat Use: Implications for Conservation. Journal of Herpetology
41(2): 271-281.
90"d 617817 £9£ 0S9

EXHIBITB
10/13/2010 12:45 5503435111 ROCHEX PAGE 01/04
C/CAG
City/County Association of Governments
of San Mateo County
Ather'lon • Balmont • Brisbane· Burlingame· Colma· Daly City'· East Palo Alto • Foster City • Half Moon Bay
• Hillsborough· Menlo Park' Millbrae' Pacifica' Portola Valley· Redwood City' San Bruno' San CarlO$ • San Mateo
. • San Mateo County· South San FranciSCO' WOodside
October13,2010
Hon. Tom Kasten, Chairman

C/CAG Board of Directors
555 County Center Fifth Floor
Dear Chairman Kasten:
The purpose of this letter is to request that you, as the C/CAG Chair, write to the County Planning
Commission, the Board of Supervisors and the Community Development Director, to request an
extension of ti!p~~ior the not,i~ period for thl~~final Envirpgmental h1!g~\?~.'~eport (FEJR) for the 8ig
Wave Welln~~~~;:8\3nter an9~~ice Park, fr~:~/20 days tr:f~~o day~asetpCl~e information provided
below- Ai: .. .. "'.
<'F ·.·r:::··,
I ;.,~;:.
i./;;(
t;\.i··
!~>.,:..
1.\',,',
I!i.~··· ~~r
lftfP''"
.~ ~ ~
'.'..
At a spepi~FMe~~(Qg on q~\ttember 30, 21~P, the C/C~fj' Airath Land Use Committee (AlUC)
receive?~~B~2~fro~ I~unty Plan~in~~taff (Cam~~~1L.e~~~ Project Pla~ner) on the current status
of the, ,pl~nnln'g :':'in.~~rnvl~~mental revle~~:rocess fo~'e Blg~~ve Wellnt.,¥.i Center and, Office Park
pro~.o:sed on two a9F.'Jcehf.~ ~s""a..SfOss?;t)J~~tre~~rpm ~alf ~~~r.port, The project was first
brodght to the attention ~f;i ·'tlG:ln AprfrzoCij;;'8$ an Informa''tiffffi~j~'I'''. The ALUC members
provided some comments on airport land use compatibility issues to the project sponsor at that
meeting. The project sponsor agreed to conduct studies as to the impacts of the proposed
construction on wind patterns as they may affect aircraft in flight and noise impacts to residents in the
project. Given the extraordinarily close proximity of residential units (900 feet as currently configured)
to an active runway and flight pattern, these studies seemed quite logical and necessary. In
communications fallowing that meeting, the specifics of the noise studies were agreed.
The project is proffered as "a modem day sanitarium use that would provide housing for 50 low-
income developmentally disabled adults." There is testimony in our meeting ffiCOrd from those
who would Challenge that description. We heard those who claim that because of the "sanitarium"
designation, the project was exempt from an otherwise required ALUC review. Due to the exemptions
for the "sanitarium" designation, the project only requires use permit approval from the county and
several other discretionary permits, including action by the California Coastal Commission, However,
as the Chair, I believe it is the charge of the ALUC to review projects with impacts on any airport in
this County. Other ALUCs in the State of california consistently review projects where a formal action
is not required_ The purpose of the ALUC, to my understanding, is to provide advice and
recommendations as to airport impacts offered by no other body in the County of San Mateo-
Because I have never seen a proposal for housing this close to active runway, I felt that a further
review and consideration of the studies that were promised, was warranted, to try to ascertain if they
wEj{f i~ fact complete? in ~ manner desi9.re<b to lrst
these i~~~ts in a reasonablEhrnanner-
/ Ii {! fY"f'':':] A r~;i, Ii ~ F~ (1;'1 It u ~ 0 ~ B~ (; kq ten ftD. n.
/~JIA Ii Ii j!U!' r()! Ii I~ /;1""",, (141 t1 rl IX)) !~)/ v~ ~r;.' V
I·: (Vi rJ &1 NNS{1 t: KrL (;" it;;.;
ALUC Chalrp0l'$on: ALUC Vlee Chalrper$oo: C/CAG Airport Land Use Committee (ALUC) Staff:
Richard NClwman Ann Keighran. Council Member Davi.d F. C8(bOne. Ttensportation Systems Coordinator/Airport Environs
Avlaflon Representative City of Burlingame. California Planning, County of San Mateo PI enning and Building Department.
555 COU~TY CEN·TER. 5 'H FLOOR. REOWOOLl CITY. CA 94063 • 650/599-1406 ·650/594-9980
10/13/2010 12:45 5503435111 ROCHEX PAGE 03/04
Letter to the Hon. Tom Kasten C/CAG Chairperson, Re: A Request to Extend the Notice
Period for the Final Environmental Impact Report (FEIR) for the Big Wave Wenness Center and
Office Park
October 13, 2010
Page 3 of 3
I would appreciate knowing if C/CAG will be willing and able to forward ~these comments to the county
as suggested above, together with the postponement request, prior to the proposed meeting date of
the Planning Commission. , would ask that you copy the undersigned on any such correspondence,
directly to P .0, Box 1934. Burlingame. CA 94011. '
Thank your for your consideration and action on this request.
Since 0
~/ ~
rd Newman, ALUC Chairperson
/'RN:DFC:pac - DFCU0742_WPN.DOC
RNEWMANAI..UCBlgWavel..etler-Dfc74:Cwpn
Attachment: Location Map: Proposed Big Wave Well ness Center and Office Park
CC: ALUC Members. w/attachment

Richard Napier, C/CAG Executive Director, w/attachment
David F. Carbone, C/CAG ALUC Staff, w/attachment
Camille Leung, Project Planner, County of San Mateo, w/attachment
-
EXHIBIT C
Solid Waste Facility Listing/Details Page http://www.calrecycle.ca.gov/s WFacil i ti es/Directory/4l-AA-0002/Detai I
Cal Recycle
For this facility,please contact Local Enforcement Agency (LEA) below

CalRecycle Contact: 13"iino?c<;!ljQb.IW"iin
Phone Number: (916) 341-6344 Search New Facility
Detail Inspection Enforcement Maps Documents
Identification: Local Enforcement Agency (LEA):

.............. .1................... ................................
Location: Ox Mountain Sanitary Landfill County of San Mateo

2 Mi N-E Half Moon Bay Off Hwy 92 Health Services Department
Half Moon Bay, CA 94019 Environmental Health Services Division
Latitude: 37.50057 2000 Alameda de las Pulgas, Suite 100
Longitude: -122.41078 San Mateo, CA 94403
GIS Confidence: Map Phone: (650) 627-6200
Fax: (650) 627-8244
US EPA FRS 10: Not Available
Operator/Business Owner: Land Owner(s):
Republic Services Of California I, L.L.C Republic Services Of California I, L.L.C
4001 Vasco Road 4001 Vasco Road
Livermore, CA 94550 Livermore, CA 94550
Phone: (925) 447-0491 Phone: (925) 447-0491
Fax: Fax:
Surrounding Land Use:

Open Space - Irrigated
Permit Details:
Current - Permit or EA Notification Issue Date: June 26 ,2001 Type: Full View Document
Unit Specifications:
i).?.i? . [)iGti9n?JY
Unit: 01
Activity: Solid Waste Landfill Inspection Frequency: Monthly
Classification: Solid Waste Facility Max.Permitted Throughput: 3,598.00
Tons/day
Category: Disposal Remaining Capacity: 44,646,148
Cubic Yards
Regulatory Status: Permitted Remaining Capacity Date: January 01,
2000
Operational Status: Active Max.Permitted Capacity: 37,900,000
Cubic Yards
10f2 101201201012:37 PM
EXHIBITD
Feb-01-2008 12:42 From-DIVISION OF LAND RESOURCE PROTECTION 19163273430 T-886 P.001/005 F-207
STATE OF CALIFORNIA RESOURC:.;;.;ES;..;..A..;..;;G'"'"E;..;.NC _ _ _ _ _ _ _ _ _ _ _ _ _ _..;.AA..:.;;..f\;I~O;;:;LO_S;.;;;C~HW~AAl:..:.=E::.:..N;;;;;EGG..;;;..,;;.:!:;:.;R::..,;.GO~:V:..;;ER;;;.N.:.;:OR;.:.:;..

__V
D:EPARTMENT OF CONSEIRVATION
DIVISION OF LAND RESOURCE PROTECTION
eOl KSlRliST • MS 1a-Q1 • SACRAMENTO. CAUFORNIA 95814
PHONE 916/324.()86() • FAX 916/327-3430 • TOo' 916/324-2555 • W£IISIlE co~IVOffQn.c(l.QO\I
Jamtary 31, 200t!
VIA FACSIMILE .(.707) 784·2894

Jim Louie, Senior Planner
Solclno County RI~source Management
675 Texas Street Suite 5500
Fairfield, CA 945~;3
Subject: Sol~lno County 2008 General Plan Update Notice of Preparation
Dear Mr. Louie:
The Department cf Conservation's (Department) Division of Land ReHource Protection

(Division) has revi.::wed the Notice of Preparation (NOP) for the refer€:nced project. The
Division monitors ":armland conversion on a statewide basis and administers the California
Land Conservation (VVllllamson) Act and other agricultural land conservation programs.
We offer the follo\,IIing comments and recommendations with respect ·to the project's
impacts on agricultural land and resources.
Project DescriRti9,ll
The purpose of the Solano County (County) 2008 General Plan Update (update) is to
provide a compre'1ensive update of the County's General Plan (plan). The primary
objective of the updated plan is to provide pollcy guidelines for futurS! development and
conservation in t~le unincorporated portions of the County and to adapt the document to
pertinent issues tilat have emerged since the preparation of the pre1 /ious elements.
The County conUlins a significant amount of agricultural lands and, mOre specifically,
agricultural lands enrolled in Williamson Act contracts. Therefore, the Division
recommends that the Draft EIR (DEIR) address the following items to provide a
comprehensive di 5cussion of potential impacts of the project on agricultural land and
activities.
Agricultural Settirn of the Eroject
• Location al1d extent of Prime Farmland, Farmland of Statewide Importance,

Unique Farmland, and other types of farmland in and adjacent to the project
area.
• Current and past agricultural use of the project area.' Please include data on the
types of crops grown. and crop yields and farm gate sales values.
The Departm ~1lt of Conservation's miasion is 10 prClleCI Californians (lrn;/ thqir Imvttonmenr by: .
Protecll'ng IivBS anilproperly from earthquakes and /(l1Idslides; Ensuring safe mining (lnd oil and ga3 drilling;
ConserviJlg Califomia'sfarmland: and Savl'ng energy and resources rhrou[;h recycling.
F~b-Ol-2008 12:42 From-DIVISION OF LAND RESOURCE PROTECTION 19163273430 T-886 P.003/005 F-207
Mr..Jim Louie
January 31,2008
Page 3 of 5
established rationale similar to that of wildlife habitat mitigation. Mitigation via

agricultural conservation easements can be implemented by at least two alternative
approaches: the .)utright purchase of easements or the donation of mitigation fees to a
local, regional or !itatewide organization or agency whose purpose Includes the
acquisition and st.::wardship of agricultural conservation easements. The conversion of
agrtcultul'alland snould be deemed an impact of at least regional siunificance. Hence
the search for replacement lands should be conducted regionally or statewide, and not
limit~d strictly to lands within the project's surrounding area.
Other forms of mi1 igation may be appropriate for this project, includil'lg:
• Protecting "'armland in the project area or elsewhere in the County through the
use of less than permanent long-term restrictions on use sucll as 20-year
Farmland ~:jacurity Zone contracts (Government Code Sectio.1 51296 et seq.) or
1O~year W~ liamson Act contracts (Government Code Section 51200 et seq.).
• Directing a mitigation fee to invest in supporting the cOmmercial viability of the
remaining ;agricultural land in the project area, County or region through a
mitigation I;·ank that invests in agricultural infrastructure, water supplies,
marketing, .~tc.
The Department ~llso has available a listing of approximately 30 "conservation tools"

that have been uS;9d to conserve or mitigate project impacts on a~kiGulturalland. This
compilation report may be requested from the Division at the address or phone number
below. General information about agricultural conservation easeme!1ts, the Williamson
Act, and provision::;; noted above is available on the Department's wE:bsite, or by
contacting the Division at the address and phone number listed below. The Division's
website address i~.:
http://www.Q9nservatian.ca.gov/dlrp/index.htm
Of course, the USE: of conservation easements is only one form of mitigation that should
be considered. AllY other feasible mitigation measures should also I)e considered.
Williamson Act La~J..Q§
Under California C ode of Regulations Section 15206(b)(3), a project is deemed to be of

statewide, regionEll or area-wide significance if it will result in cancellation of a
Williamson Act contract for a parcel of 100 or more acres. Since lands under
Williclmson Act contracts and/or in agricultural preserves exist In the project area, the
Dep~lrtrnent reoon'mends that the following information be provided In the DEIR:
From-DIVISION OF lAND RESOURCE PROTECTION T-SSS P.005/005 F-ZQ7
Feb-01-200a 12:42
Mr. Jim Louie

January 31,2008
Page 5 of 5
• An agricultural preserve is a zone authorized by the Williamson Act and

established by the local government to designate qualified land to be placed
under the VJilliamson Act's 1O-year contracts. Preserves are also intended to
create a se·ting for contract-protected lands that is conducive to continuing
agriculturall~se. Under Government Code Section 51230, "Al agricultural
preserve m ~\Y contain land other than agricultural land, but tht~ use of any land
within the p"eserve and not under contract shall within two yei~rs of the effective
date of any contract on land within the preserve be restricted ,,)y zoning, including
appropriatel minimum parcel sizes that are at a minimum coneistent with this
chapter, in I.uch a way as not to be incompatible with the agriGultural use of the
land." Therefore. the DEIR should also discuss any proposed general plan
designation I;)r zoning within agricultural preserves affected by the project.
Thank you for givjr,g us the opportunity to comment on this NOP. If you have questions
regarding our com nents, or require technical assistance or informatj,:m on agricultural
land conservation. please contact Elliott Lum, Environmental Planner, at 801 K Street,
MS 18~Ol, Sacrarr;ento. California 95814; or, phone (916) 324~0869.
Sincerely,
0-'~<~>4-:f
Dennis J, Q'Bryant
Program Manager
cc: state Clearil1ghouse

Page 1 of 1
- Please Approve the Big Wave Project
From: "Vanessa Richter" <vrichter82@gmail.com>

Date: 10/25/2010 7:48 PM
Subject: Please Approve the Big Wave Project
I support the Big Wave Project and all staff recommendations in the County Staff Report, including
to "approve the project as described in Alternative C and as presented in the Final EIR..."
I believe the Big Wave Project is precedent setting in the way it sincerely cares for our environment, our
economy, and our special needs community. It should be noted that the the project applicant has been
modifying their initial proposal to comply with all County issues raised over the past five years, and now
the current proposal is in compliance with all County requirements with no significant environmental
impacts.
Please do not further delay this urgently needed project. It is time to develop affordable housing on the
Coastside and to provide for our special needs population. As the aunt to a special needs 5 year old,
I see Big Wave as a place where my niece could one day live as an independent, happy and productive
member of our community.
Vote yes to your staff recommendations. If you are unable to vote at the 6pm meeting at El Granada
on October 27th on this issue, please hold a special meeting the first week of November to vote on this
project.
Sincerely,
Vanessa Richter
11/16/2010..

Big Wave Final EIR Comments

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Big Wave Final EIR Comments

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Comments for the

November 17, 2010

Date: November 15, 2010

October 26, 2010

County of San Mateo, Planning and Building Department

Dear Ms. Leung,

Land Use Sensitivity Concerns related to Safety and Noise.

Pg 2 CalPilots FEIR Comments

b) Sensitive Uses. The CalTrans Handbook further states:

CalTrans Land Use Safety Zones Around Airports.

* Avoid hazardous uses (e.g. aboveground bulk fuel storage)

ii) Sideline Zone (5), which parallels the runway:

Incorrect Noise Measurement Techniques Used by the County Planning Consultant:

An example of inadequacy of the FEIR is Section V. General Impact Categories, Page V6

July 8,2010 JUL 1 2 2010

Dear Mr. Larson:

Half Moon Bay Airport

October 26, 2010

Dear Mr. Larson:

Half Moon Bay Airport

Son Mateo County Airports

Dear Mr. Larson:

Half Moon Bay Airport

Dear Planning Commission,

- Big Wave requests

From: BARRY <bevbarry@pacbell.net>

Greetings San Mateo Planning Commission:

RE: Big Wave

I - Big Wave comments

From: BARRY <bevbarry@pacbell.net>

Greetings San Mateo County Planning Commission

RE: Big Wave FEIR

I disagree with certain parts of the proposed FEIR:

1. APPENDIX G MODIFIED ALTERNATIVE C: ALTERNATE OFFICE PARK TRAFFIC

Subject: Big Wave FEIR Comments

2. Questionable process tactics to usurp the EIR process.

This is probably the most damning display of unprofessional conduct by the

a. Review period is inadequate. Over 3000 pages to be reviewed in 12 days

3. CEQA Guidelines Vol 1 page II-33 Section 15003. Policies.

a. Traffic. To mitigate the objections of the Seal Cove residents concerned

a. One of the Planning Commissions duties is to assess the viability of this

5. Adherence to the Local Coastal Plan.

- Re: Big Wave

Dear Mr. Syme,

Thanks for your email.. Look forward to meeting you tonight.

October 26, 2010

Dale and Bonnie Dunham

513 Ruisseau Francais Avenue

From: "Carolyn Maddux" <cmaddux@hctc.com>

San Mateo County Planning Commission

- My support for the Big Wave Project

From: "chris porter" <chrisporter8@gmail.com>

Dear Planning Commissioners and County Planner, Ms. Leung,

David Bomberger, Chair and

Thank you for consideration of this request.

October 25, 2010

Ms. Camille Leung

Re: Big Wave FEIR and Project Permitting

Dear Ms. Leung,

The Granada Sanitary District

Chuck Duffy, General Manager

Camille Leung, Project Planner

Dear Ms. Leung,