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48 conceptual grading plan, revegetation plan, schedule for mitigation construction, and a requirement for a biological as-built report to document restoration implementation. The MMP establishes a maintenance plan that outlines the vegetation maintenance required to meet the performance and success criteria for the habitat mitigation and rock slope protection (RSP) planting areas. The MMP also establishes a long-term, post-construction monitoring plan that defines objective performance standards, and success criteria that would be used to determine if riparian and wetland ecosystem establishment in the mitigation areas is on a trajectory toward meeting the target habitat type mitigation goals. A restoration ecologist will conduct project monitoring and reporting. If assessment of annual performance criteria indicates that the site will not meet final success criteria, the property owner will prepare an analysis of the cause(s) of failure and propose remedial actions to the permitting agencies. The property owner will provide funding for the planning, implementation, and monitoring of any remedial actions determined to be necessary to meet the mitigation goals. Although the proposed on-site mitigation ratio for project impacts is at least 1:1, additional off-site mitigation measures are proposed at Midpen’s Bear Creek Redwoods Preserve (Bear Creek Preserve) to compensate for the project’s temporal losses to regulated riparian and wetland habitats within RWQCB and CDFW jurisdiction. According to the Off-Site Habitat Mitigation and Monitoring Plan (Off-Site MMP) prepared by H. T. Harvey & Associates for the Commercial Component (“901 El Camino Real Project, Off-Site Habitat Mitigation and Monitoring Plan,” November 3, 2023), the proposed package of off-site habitat mitigation design and monitoring include riparian woodland and wetland habitats, which will be restored at a ratio of at least 1:1 at the off-site mitigation site and includes at least 140 linear feet of in-stream physical process restoration, and surface area of riparian and wetland enhancement. The goal of the off-site habitat mitigation design is to restore and enhance two habitat types through hydrologic improvements, vegetation removal, and revegetation: 1) Riparian woodland habitat with a native tree canopy and robust understory of native shrubs and 2) seasonal wetland habitat dominated by native wetland vegetation. Similar to the On-Site MMP, the Off-Site MMP also establishes a work plan, maintenance plan, and monitoring plan to ensure successful implementation of the off-site mitigation. If assessment of annual performance criteria indicates that the site will not meet final success criteria, the permittee will prepare an analysis of the cause(s) of failure and propose remedial actions to the RWQCB and CDFW. The permittee will provide funding for the planning, implementation, and monitoring of any remedial actions determined to be necessary to meet the mitigation goals. The Commercial Component is required to adhere to DTPP Plan-Wide Amendments program SEIR Mitigation Measure BIO-2a (formerly Mitigation Measure 15-1(b) from the DTPP Final EIR with clarifying amendments) which requires compliance with the Redwood City Stormwater Pollution Prevention Program, including maintenance of setbacks from Redwood Creek, erosion control methods, and measures for the avoidance of stormwater pollution. Additionally the Commercial Component has prepared a MMP in accordance with DTPP Plan-Wide Amendments program SEIR Mitigation Measure BIO-2b (formerly Mitigation Measure 15-2 from the DTPP EIR with clarifying amendments) which shows the project design modifications, habitat replacement, and mitigation measures required by the USACE, CDFW, and RWQCB which are required to be incorporated into the Commercial Component prior to issuance of grading or building permits. Also, in accordance with SEIR Mitigation Measure BIO-2b, the project applicant shall obtain all required permits and approvals from USACE, CDFW, and RWQCB. As a result, the Commercial Component would have a less-than-significant impact with mitigation. The potential impacts of the Commercial Component’s proposal to alter Arroyo Ojo on riparian habitat and other sensitive natural communities were previously analyzed in the DTPP Plan-Wide Amendments program SEIR, as described above. This component is consistent with the analysis in the EIR/SEIR because it would not create new impacts or increase impacts and there is no new information of substantial importance for CEQA purposes. c. The Downtown Precise Plan program EIR (pp. 15-14 and 15-15) found that future development adjacent to Redwood Creek may affect potential jurisdictional wetland habitat, and this represented a potentially significant impact. Mitigation Measure 15-2 from the DTPP Final EIR would reduce this impact to a less-than-significant level by obtaining and adhering to all required federal and State permits for wetlands. The DTPP Plan-Wide Amendments program SEIR (p. 15-14) concurred with the DTPP EIR conclusion and found that with implementation of Mitigation Measure BIO-2b (formerly Mitigation Measure 15-2 from the DTPP Final EIR) is sufficient to ensure that potential impacts on wetlands and open waters are minimized and adequate replacement or compensatory mitigation is provided, reducing impacts to a less-than-significant level (p. 15-14). The DTPP Plan-Wide Amendments program SEIR identified a small section of Arroyo Ojo proposed to be relocated and altered as part of a subsequent development project. These changes, if implemented, would result in temporary effects to open water during construction and could result in permanent impacts, depending on the intensity and nature ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 48 of 148