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City of Redwood City, Public Works Division Initial Study & Mitigated Negative Declaration <br />Document Date: October 15, 2015 <br />Revision Date: January 25, 2016 Page 28 Blankinship & Associates, Inc. <br /> <br />Table 1 Numbered Notes: <br /> <br />(1) Species not likely to have any exposure as its food base consists of terrestrial species. <br />(2) Species may forage in the shallow water at the margins of the Redwood Shores Lagoon. <br />Given the large amount of potential foraging area, the food items from treated areas <br />would likely constitute an insignificant percentage of the total diet. Therefore, no risk due <br />to copper exposure is anticipated. <br />(3) Species forages over water. Given the large amount of potential foraging area, the food <br />items from treated areas would likely only contribute an insignificant percentage of the <br />total diet. Therefore, no risk due to copper exposure is anticipated. <br />(4) According to the February 6, 2013 Final Rule issued by USFWS, no designated Critical <br />Habitat occurs within the San Francisco Bay. <br />(5) According to the January 5, 2011 Critical Habitat proposal issued by USFWS, no <br />designated Critical Habitat occurs within the San Francisco Bay. <br />(6) Not a submerged aquatic plant. Therefore exposure to copper treated water is indirect, if <br />any. Exposure will only occur through root uptake of soil water. Aquatic herbicide <br />concentration in root zone water is not expected to be sufficient to cause impaired growth <br />or cause death. <br />(7) According to the CalFlora Database, no reported occurrences of these species exist <br />within the county of the Project Area. <br />(8) Not an emergent plant and therefore does not grow in standing water but may grow on <br />moist banks of the Lagoon. Exposure to treated water containing aquatic herbicides is <br />indirect, if any. Exposure will only occur through root uptake of soil water; however, the <br />chemical properties of copper-containing herbicides make it unlikely that copper will be <br />able to move through soil pore water to the roots of the plant. Aquatic herbicide <br />concentration in root zone water is not expected to be sufficient to cause impaired growth <br />or cause death. <br />(9) According to the CalFlora Database, no reported occurrences of these species exist <br />within the project area. <br /> <br />Table 1 Status Abbreviation: <br />FE = Federally Listed as Endangered <br />FT = Federally Listed as Threatened <br />FD = Federally Delisted <br />SCSC = State Listed Species of Concern <br />SE = State Listed as Endangered <br />ST = State Listed as Threatened <br />CRPR-1 = California Rare Plant Rank 1; includes, Presumed Extinct, or Rare, Threatened, or <br />Endangered in California (and elsewhere) <br />CRPR-2 = California Rare Plant Rank 2; includes Rare, Threatened, or Endangered in <br />California, but more common elsewhere <br /> <br />(Continued Item a): Discussion) <br /> <br />Methods for Estimating Risk <br /> <br />The United States Environmental Protection Agency (USEPA) has developed Toxicity <br />Reference Values (TRVs) for many chemicals. However, published TRVs generally do not <br />exist for herbicides. Therefore, herbicide-specific TRVs were derived as part of this <br />document (USEPA 1999). Endpoints from studies available from the published literature or <br />government reports and databases can be used to establish TRVs. The endpoints used to <br />6.3.A. - Page 36