VENTURA COUNTY WATERSHED PROTECTION DISTRICT

INVASIVE PLANT REMOVAL PLAN for the VENTURA RIVER INVASIVE PLANT REMOVAL AND ECOSYSTEM RESTORATION PROJECT (V-11)

In partnership with Ojai Valley Land Conservancy and Ventura Hillsides Conservancy

Funded by: Watersheds Coalition of Ventura County Proposition 84 IRWMP Implementation Grant Round 2

Project No. FC141655

July 2014 Invasive Plant Removal Plan

1.0 PROJECT OVERVIEW The project will remove non-native, invasive plant species in the Ventura River Watershed and contribute to the broader Matilija Dam Ecosystem Restoration Project. The primary invasive species targeted will be giant reed (Arundo donax), with fennel (Foeniculum vulgare) and castor bean (Ricinus communis) as secondary targets. Work will occur in the mainstem of the Ventura River on four preserves which are either owned and/or maintained primarily by the project partners: Ventura County Watershed Protection District (VCWPD), the Ojai Valley Land Conservancy (OVLC), and the Ventura Hillsides Conservancy (VHC) (Figure 1). Several privately held properties and public works facilities are also in the project work area. In total, approximately 29.2 acres of giant reed will be treated on about 165.6 acres of land (Table 1).

Table 1. Estimated Acreage for Invasive Plant Removal Plan PERCENT ESTIMATED COVER TOTAL TREATMENT LOCATION COVER CLASS (ACRES) (ACRES) Rio Vista Preserve <5% 0.7 29.3 5-25% 0.5 3.4 25-50% 0.0 0.0 50-75% 0.0 0.0 75-90% 17.0 20.6 TOTALS 18.2 53.3 Steelhead Preserve <5% 0.9 34.4 5-25% 3.9 26.3 25-50% 0.0 0.0 50-75% 0.0 0.0 75-90% 0.0 0.0 TOTALS 4.8 60.7 Foster Park Preserves <5% 0.7 28.8 5-25% 2.7 18.2 25-50% 0.0 0.0 50-75% 2.7 4.4 75-90% 0.1 0.2 TOTALS 6.2 51.6 GRAND TOTALS 29.2 165.6

The Rio Vista Preserve is located on the Ventura River mainstem along the east bank upstream of the confluence with San Antonio Creek. This area has the highest cover giant reed patches of the project area (Figure 2). Access will be from the Ojai Valley Trail. The Steelhead Preserve is located immediately downstream of the Rio Vista Preserve but primarily along the west bank of the river. The upstream portion of the preserve supports low cover of giant reed; the portions of the downstream part of the preserve support slightly higher cover giant reed (Figures 3 and 4). Access to the Steelhead Preserve will be via unpaved roads off Santa Ana Road. The North and South Foster Park Preserves are located along the Ventura River south of the Casitas Vista Road bridge (Figure 5). High cover giant reed occurs along the river bottom and lower cover giant reed occurs on the upper terraces. Access to these areas will be from Ventura Avenue and the Ojai Valley Trail.

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Staging for the project will occur along the Ojai Valley Trail bike path adjacent to the work areas for the Rio Vista Preserve (approximately 0.2 acres) and the Foster Park Preserves (approximately 1.5 acres). Staging for the Steelhead Preserve will be on about 1.0 acre of uplands adjacent to the work areas within the OVLC property. Primary access and transport roads would include the Ojai Valley Trail, Highway 33, Ventura Avenue, and Santa Ana Road, although other roads may be used. Following initial giant reed and castor bean removal activities, the project areas will be monitored by the WPD and/or its partners, and subsequently re-treated with herbicides, as needed, to control the re-growth of these plant species. Native plant species are present at the majority of the targeted removal sites, and it is anticipated that these species will recolonize each site following non-native plant removal. Consequently, re-vegetation with native plant species is not proposed. Long-term, these areas will be periodically retreated by the conservancies to keep the giant reed and other non-native plants at minimal levels. According to the Arundo donax Distribution and Impact Report prepared by the California Invasive Plan Council in 2011, the net gain in available riparian water averages 20 acre feet per year for each acre of giant reed removed. Therefore, this project may result in a total water savings of 584 acre feet per year, enough for roughly 1,460 typical single-family homes using 360 gallons of water per day. 2.0 METHODS 2.1 Initial Removal Initial giant reed removal activities will begin on or after November 1, 2014 and will take an estimated 12 weeks, or up to 60 working days, to complete. These initial treatments will likely be completed by several crews of approximately five workers each. The total number of hours required for initial herbicide treatments at any given location would be dependent on the percent cover and extent of giant reed to be removed, as well as the type of treatment applied; therefore, initial site-specific treatment activities would range between several days to several weeks. A “cut and daub” treatment will be used for the initial giant reed removal in the fall of 2014 at all sites (with the exception of shredding explained below), but the herbicide applied varies based on field conditions. Herbicide Method A would be used for areas within 25 feet of surface water and for giant reed stalks emerging from or overhanging surface water, and Herbicide Method B would be used for areas further than 25 feet from surface water. Both glyphosate (e.g. Aquamaster®) and imazapyr (e.g. Habitat®) are approved and labeled for use near and in open water. A Pest Control Advisor (PCA) who holds either a Qualified Applicator License (QAL) or a Qualified Applicator Certificate (QAC) from the California Department of Pesticide Regulation would prepare a written recommendation for herbicide use for the VCWPD, and would submit it to the Ventura County Agricultural Commissioner for review and approval prior to the start of work. While the proposed herbicides are not restricted materials, all work conducted for the VCWPD must have a PCA written recommendation. All on-site herbicide applications would be supervised or completed by personnel that have a QAC or QAL. Additionally, the on-site supervisor would ensure that specific safety measures and manufacturer label specifications

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and requirements are followed, and that the VCWPD’s protocols to avoid herbicide application or drift into adjacent areas or non-target species are implemented

Cut and Daub: To implement the cut and daub method, all live giant reed material will be cut with hand held equipment such as chain saws, loppers and power brush cutters to a maximum of six inches above grade level. Herbicide (Method A or B as appropriate) would then be applied to the freshly cut stalk cambium. For stalks emerging from surface water, the stalks would be cut about 6 inches above the water surface. The herbicide application would be completed within approximately two minutes of cutting and within six inches of grade (or surface water); it would comprise painting the cambium layer of the freshly cut stalks with a cloth-covered wand or a sponge in a manner that would maximize the stalks’ herbicide absorption. Application of herbicides to the ground, open water, or to non-target vegetation shall be avoided. The cut plant material would be taken off-site either by hand or with small loaders to a haul truck, which would be parked at the closest point of a road that provides access to the targeted removal site. The haul truck would then transport the cut plant material to designated chipping sites at the staging areas. No loose cut plant material may remain on site. As described below, the giant reed material may be chipped and used as landscaping mulch on upland sites.

Method A: Within 25 feet of or for stalks emerging from surface water, a solution of approximately 50% glyphosate, such as full strength Aquamaster®, will be applied with a colorant to cut stems immediately (within 2 minutes) after cutting.

Method B: For treatment areas more than 25 feet from surface water, to the glyphosate- based herbicide and colorant solution used for Method A, imazapyr-based (29%) herbicide, such as Habitat® would be added. No surfactant is required with the cut and daub application method.

Fennel and Castor Bean. These two species would also be controlled using a cut and daub application treatment. The same herbicide mix as described for the giant reed would be used. Due to the invasiveness of fennel and castor bean, the seed heads, stalks, and leaves would be bagged or otherwise wrapped and hauled to a landfill as a destruction load. Bagged castor bean and fennel plant material may be transported to the staging areas for storage until taken to the landfill.

Shredding Option. For areas designated with 75-90% cover of giant reed at the Rio Vista Preserve, the contractor will have the option to use small mechanized equipment to shred the standing giant reed canes to near ground level as an initial treatment method. Shredded material will remain in situ. No soil disturbance or road grading would occur; no driving of equipment in flowing water would occur. No herbicide application would occur during or immediately after the shredding. No road grading (earth moving) or crossing of open water with shredding equipment will be allowed; driving the shredder over dry land will be allowed. No shredding will occur as a re-treatment or in any other areas of the project.

Chipping. Cut giant reed will be transported to designated staging areas for chipping. Cut plant material would be placed in haul trucks which would park at points along existing access roads that provide the closest vehicular access to the targeted removal sites. Unchipped plant material would be transported to staging areas for chipping, and on any given day approximately five to seven truck trips to these areas will occur.

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Chipping and project-related equipment and materials staging areas will be needed in several locations. The location of the primary chipping area will be on the Steelhead Preserve on the grassy field near the buildings. It is estimated that one chipper would be required for the proposed project. The chippers would operate Mondays through Fridays between the hours of 8:00 p.m. and 5:00 p.m. to minimize disturbance to wildlife and park users. Operation of the chippers would likely not be necessary every day. The chippers would be operated only after enough plant material has been accumulated to warrant their efficient use. In total, it is estimated that the chippers would be operated approximately every several calendar days, but would vary. All chipped material would be used by either Ojai Valley Land Conservancy, Ventura Hillsides Conservancy, or the Ventura County Parks Department for mulch, trail cover or other uses which would not allow the spread of giant reed or be a fire hazard. The chipping and staging area may be fenced and posted with signs to restrict unauthorized access and ensure public safety. Bagged castor bean and fennel plant material may be transported to the staging areas for storage until transported to a landfill as a destruction load, but will not be chipped to avoid mixing it with other chipped materials.

2.2 Re-Treatments Following the initial treatments, re-treatment via foliar application of herbicide would occur in those areas where giant reed, castor bean, and fennel re-emerges. Grant funding is available for quarterly re-treatments through September 2018. Like the initial treatments, two herbicide methods would be used depending on the proximity to surface water. Either Methods A and B may be used as retreatments using the cut and daub methods. Or, foliar application using Methods C and D may be used when the plants are resprouting or new growth is observed. Application of herbicides shall only occur to above-ground plant material and not to the ground, open water, or to non-target species.

Method C: Within 25 feet of or for stalks emerging from surface water, a solution of 5% glyphosate, non-toxic colorant, and a non-ionic surfactant will be applied to foliar giant reed growth when it is between 2 and 4 feet in height. The surfactant must be approved for aquatic use. For fennel and castor bean, the plants would be treated concurrently with the giant reed, regardless of height.

Method D: For treatment areas more than 25 feet from surface water, a solution of 2% glyphosate and 2% imazapyr, with a non-toxic colorant and a non-ionic surfactant will be applied to foliar giant reed growth when it is between 2 and 4 feet in height. The surfactant must be approved for aquatic use. For fennel and castor bean, the plants would be treated concurrently with the giant reed, regardless of height. Depending on site-specific plant growth conditions, the re-treatment will occur about four times annually. Early retreatments may require about six weeks or 30 work days, and are expected to decrease over time to two or three weeks per retreatment. As with the initial treatment, re- treatments would adhere to all VCWPD protocols and manufacturer specifications, be completed or supervised by a PCA, and follow applicable protocols.

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3.0 VEGETATION COMMUNITIES

Vegetation and habitat types in the project area can be broadly classified as mixed riparian scrub, oak woodland, open water, freshwater marsh and grassland. The majority of the project area supports mixed riparian scrub, which is an open to dense stand of native willows (Salix spp.), cottonwood (Populus spp.), mule fat (Baccharis salicifolia), with varying quantities of giant reed. This habitat type occurs along most of the low flood terraces within the river bottom; shifting substrates during storm events erode and deposit material which support this plant community. Oak woodland occurs in a few places within the project area, primarily on steep north facing slopes above the river. Few non-native plants occur in the oak woodland areas, so little removal work will be done in this habitat type. Grassland occurs on the higher floodplain terraces outside the normal scour zones and comprises mostly non-native annual grasses and forbs. Several large patches of giant reed occur in these grasslands, especially along the river edges and along some fence lines. Perennial open water occurs in the VHC work area, but tends to be seasonal in the two OVLC areas. Water can be a few inches to several feet deep and supports many species of aquatic wildlife and invertebrates. Freshwater marsh occurs at the open water edges, and is typically dominated by cattails (Typha spp.), rushes (Scirpus spp.), and watercress (Rorippa spp.). 4.0 SENSITIVE SPECIES

The habitats in the project areas are suitable, at least in part, for least Bell's vireo (Vireo bellii pusillus), southwestern willow flycatcher (Empidonx trailii extimus) and California red-legged frog (Rana draytonii). Protocol surveys for these species have not been recently conducted.

4.1 California Red-legged Frog

Impacts to California red-legged frogs will be minimized during implementation of the Plan by relocating frogs encountered and prohibiting foliar herbicide applications over and near open water. The Biological Opinion for the Matilija Dam Ecosystem Restoration Project, Ojai, Ventura County, California (CON-1-8-04-F-38) March 31, 2005 covered giant reed control for the entire Ventura River. However, at that time, California red-legged frogs were not known to occur near the confluence of the river and San Antonio Creek and along the Casitas Springs Levee, which include portions of the work areas in the two OVLC preserves. The frogs may also occur downstream of Foster Park, in the VHV project areas. In 2012, the District obtained a second biological opinion, Final Programmatic Biological and Conference Opinion for Ventura County Watershed Protection District’s Routine Operation and Maintenance Program, Ventura County, California (8-8-11-F/C-12), in which 2.5 acres of routine maintenance and 10 acres of habitat restoration activities are authorized each year. Relocation of up to 75 eggs, tadpoles, adults and juveniles is authorized, but no more than 1 dead adult, 5 dead tadpoles, or 1 disturbed egg mass may occur each year. Night surveys will be conducted to better assess the distribution and population size in suitable habitat prior to project work.

4.2 Least Bell’sVireo

The 2005 Biological Opinion (BO) for the Matilija Dam Ecosystem Restoration Project also addressed least Bell’s vireo potential impacts from giant reed control activities. The BO concluded project actions were not likely to adversely affect the least Bell's vireo. This species has increased in number within the Ventura River watershed since 2005. Avoidance measures included conducting least Bell's vireo surveys prior to work and if nests are found, project

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activities would be set back a minimum of 500 feet from nest sites or avoided until the young have fledged. To avoid nest impacts during initial removal work, removals will begin in late fall, after the birds have migrated south for the winter. However, retreatments would occur during the nesting season, therefore pre-work surveys will be conducted and any nests given a 500 foot no-work radius until the nestlings have fledged and moved out of the area.

4.3 Southwestern Willow Flycatcher

The 2005 USFWS BO also addressed this species and determined habitat suitability in the project area was “marginal at best.” These birds will be treated the same as described for the least Bell’s vireo, as they share some habit characteristics. If a nesting pair is found, project activities would be set back a minimum of 500 feet from nest sites or avoided until the young have fledged and moved from the work area.

4.4 Southern Steelhead

Both the Matilija BO and the Routine Operations and Maintenance BO prepared by NMFS concluded that herbicide use for giant reed control or general vegetation control would not substantially adversely affect steelhead. Precautions/best management practices were included in the permits and project descriptions to minimize potential impacts to water quality and avoid grading adjacent to or in creeks with steelhead. Since grading, water diversion, and aquatic application of herbicide are not part of the Invasive Plant Removal Plan, impacts will be avoided and minimized in compliance with permits. 5.0 CALIFORNIA ENVIRONMENTAL QUALITY ACT & NATIONAL ENVIRONMENTAL QUALITY ACT Giant reed removal throughout the Matilija Creek and Ventura River mainstem is a component of the Matilija Dam Ecosystem Restoration Project. Potential impacts caused by this component were analyzed in the Public Draft and Final CEQA/NEPA documents for the project. The Final Environmental Impact Statement/Environmental Impact Report was certified by the Ventura County Board of Supervisors acting as the District’s Board of Directors in December 2004. The Record of Decision was issued by the U.S. Army Corps of Engineers in April 2007. Vegetation removal conducted for the District’s Routine Operations and Maintenance Program was evaluated in the Environmental Protection Measures for the Ongoing Routine Operations and Maintenance Program Environmental Impact Report, certified in May 2008. 6.0 PERMITS The grant-funded work will be covered by a series of existing permits held by the District. These permits authorize maintenance and mitigation/habitat restoration work with the application of Environmental Best Management Practices (listed in the next section).

Routine Operations and Maintenance Streambed Alteration Agreement (SAA): SAA No. 1600-2004-0512-R5 covers the District’s Routine Operations and Maintenance Program, as well as mitigation and restoration activities, in Conditions 35 through 48.

USACE Regional General Permit No. 92: Requires submittal of proposed work and receipt of written authorization from the USACE prior to work. Covers vegetation management and Environmental Best Management Practices.

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NOAA Fisheries Biological Opinion for Routine Operations and Maintenance (2012/02834): Covers vegetation management in southern steelhead habitat, including aquatically-approved herbicide use, and Environmental Best Management Practices in the Ventura River watershed.

USFWS Programmatic Biological and Conference Opinion (8-89-11-F/C-12): Allows for mitigation/restoration projects in least Bell’s vireo, southwestern willow flycatcher, and California red-legged frog habitat. Currently allows for 10 acres of habitat impact annually for restoration; the BO will be amended to allow for this and other large restoration projects on case-by-case basis.

Los Angeles Regional Water Quality Control Board Section 401 Water Quality Certification for Routine Maintenance Program (File No 08-148): Covers brush and weed control activities and Environmental Best Management Practices.

NOAA Fisheries Biological Opinion for Matilija Dam Removal and Ecosystem Restoration Project (SWR/2002/01708): This BO covers the removal and retreatment of giant reed throughout Matilija Creek and in the Ventura River downstream of Matilija Dam. This is described as component H of the Matilija Dam Ecosystem Restoration Project on page 7 of the BO. NMFS considered the anticipated effected on critical habitat and steelhead are “expected to be confined to juveniles and discountable” (page 30).

USFWS Biological Opinion for the Matilija Dam Ecosytem Restoration Project (CON 1-8- 04-F-38): Since the BO was issued, California red-legged frogs and least Bell’s vireo are now known to occur or have a higher likelihood to occur within the proposed restoration project boundaries. The BO is included here to acknowledge best management practices for giant reed control. 7.0 BEST MANAGEMENT PRACTICES The District has conducted several of these invasive plant removal projects in the past, and has assembled a set of project best management practices (below). The District also developed and implements Environmental Best Management Practices for the Routine Operations and Maintenance Program, which includes habitat restoration and mitigation projects. Project Best Management Practices are provided below, as are the appropriate Environmental Best Management practices. These two sets of BMPs incorporate or cover specific conditions from each permit document described above.

7.1 Project Best Management Practices Water Quality Monitoring. During implementation of the Matilija Dam Ecosystem Restoration Project Giant Reed Removal Project water quality monitoring was conducted to test for glyphosate and surfactants. A similar methodology will be implemented for this project. Baseline and routine sampling of water upstream and downstream of the treatment areas will occur throughout the project schedule when surface water is present. The District or its qualified consultants will conduct the water quality monitoring. The contractor will be required to comply with all water quality regulations, permits, and best management practices as part of its contract.

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Public Noticing. Active work areas near public roads or intersections would be clearly posted with signs that would discourage plant gathering or other uses. Prior to any site-specific activities, work crews would also survey the targeted removal areas to ensure that no people or wildlife are present. The VCWPD would also notify adjacent or nearby property owners of removal activities by mail at least two weeks prior to initial work, and secure all necessary property access agreements.

Limits to Site Disturbance • Contractor shall limit the work area to the smallest area possible. • Contractor actions shall not result in soil disturbance. • Contractor shall limit native vegetation and tree damage to the maximum extent possible. • Contractor shall locate staging areas in designated areas outside of the active channel. • Contractor shall designate access paths to avoid damage to native vegetation to the maximum extent possible and limit to the smallest area possible.

Site and Personnel Management • Contractor shall be responsible for being in compliance with all applicable permit conditions. • Contractor shall coordinate Project scheduling with the biological monitor to allow the biological monitor adequate time to schedule monitoring activities. • Chemical toilets for personnel shall be kept in staging areas during Project activities and remain easily accessible by workers. • Contractor shall limit extraneous noise (e.g., no radios for entertainment). • Equipment and machinery use shall comply with all applicable noise ordinances and policies. • Smoking shall not be allowed on site or in designated staging areas. • No work shall occur at night. • Signs shall be posted on affected trails for a sufficient time to warn trail users of equipment crossings. The signs shall be posted on either side of the active access and shall be maintained for the entire period of Project-related trail use. • Signs and flaggers shall be used in areas where equipment use would access paved roads and the Ojai Valley Trail. • All neighbors within 100 feet of work areas shall receive notice of the proposed work schedule at least one month before start of work. • All trash items shall be enclosed in sealed containers and regularly removed from the site daily. • Disposal of Project waste materials such as trash, used equipment, oil, grease and chemicals shall be done in accordance with Federal, State and local regulations. • Stockpiling of cut vegetation shall not occur within waters of the U.S. overnight. Materials shall not be stockpiled for more than two weeks in the staging areas and shall be disposed of properly. • Pets of Project personnel shall not be allowed on site in work areas or staging areas.

Personnel Education • All Project personnel shall be briefed on environmental concerns regarding the Project, including the use of herbicides, appropriate work practices (including spill prevention and response measures) and other measures needed to minimize Project impacts. • All Project personnel will participate in an educational program to identify the target plant species on site prior to invasive plant control activities. • Before any giant reed removal activities begin, a USFWS-approved biologist will conduct a training session for all construction personnel. At a minimum, the training will include a description of the California red-legged frog and its habitat, the importance of the California red-

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legged frog and its habitat, the general measures that are being implemented to conserve the California red-legged frog as they relate to the Project, and the boundaries within which the Project may be accomplished. Brochures, books, and briefings may be used in the training session, provided that a qualified person is on hand to answer any question.

Air Quality BMPs • Prohibit vehicle engine idling in excess of two minutes and restrict diesel engine idle time, to the extent practical, to no more than 10 minutes. • Require all trucks to cover their loads as required by California Vehicle Code §23114. • Install wheel washers where vehicles enter and exit unpaved roads onto paved roads, or wash off trucks and any equipment leaving the site each trip. • Post on site signs that limit traffic to 15 miles per hour or less. • During period of high winds (i.e., wind speed sufficient to cause fugitive dust impacts to adjacent properties), all shredding and chipping operations shall be curtailed to the degree necessary to prevent fugitive dust created by activities from being a nuisance or hazard, either off site or on site. • Adjacent streets and roads shall be swept at least once per day, preferably at the end of the day, if visible soil material is carried over to adjacent streets and roads. • Personnel involved in shredding and chipping operations, including contractors and subcontractors, should be advised to wear respiratory protection in accordance with OSHA regulations.

Water Quality BMPs • No work, including herbicide application, shall occur within 24 hours of a predicted rain event, during a rain event, or within 24 hours following a rain event. • No herbicide shall be applied to surface water at any time. • Herbicide storage during application and the fueling and lubrication of mechanical equipment shall be confined to designated staging areas. • Vehicles and equipment must be moved to the staging area at the end of each work day. • Spill kits shall be maintained on site and shall be adequately stocked for the amount of fuel and herbicides to be handled. • Refueling of vehicles/equipment and mixing of herbicides shall occur at designated upland staging areas at least 100 feet from riparian and wetland habitats where feasible. Where it is not feasible to refuel vehicles/equipment and mix herbicides in designated staging areas due to topographical constraints, these activities shall occur in uplands as far away from riparian and wetland habitats as feasible. • Appropriate spill containment devices (e.g., spill mats, tarpaulins) shall be used when refueling vehicles/equipment or mixing herbicides. • In the event of a hazardous material spill within the floodplain, wetland or riparian area associated with the Project Area, USFWS, CDFW, LARWQCB, and SWRCB must be contacted within 24 hours to determine the proper course of action and clean-up methods. The latter two agencies require 24-hour notice regardless of the spill date, and written report within five calendar days, in accordance with the District’s Aquatic Pesticides Application Plan, dated September 2013. If a spill occurs on a weekend or late Friday, USFWS and CDFW must be contacted by close of business the following Monday. • All vehicles and equipment used within the floodplain or associated riparian area of Project Area must be inspected daily to ensure they are free of any leaks of fuel, cooling, lubricating or other potentially polluting fluid. • No vehicles or other heavy equipment shall be rinsed or cleaned within the waters, floodplain, or associated riparian areas of Project Area. All necessary precautions must be taken to prevent release of any toxic substances into the waters or onto soils of the Project Area.

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• No water may be taken from the creek for any purpose. • Foot paths and equipment must cross surface water via plank bridges or similar materials to avoid walking or driving in the water. The plank bridges must be removed within 24 hours prior to any predicted rain event.

Noise BMPs • Use of loud hand-held construction equipment, such as chain saws, heavy-duty construction equipment and trucks shall not occur between the hours of 7 p.m. and 7 a.m. • Construction equipment shall be operated with standard factory silencer and/or muffler equipment. Equipment engine covers shall be in place and mufflers shall be in proper working order.

Biological Resources BMPs • A biological monitor shall be present at all times during work activities. • A California red-legged frog relocation plan shall be approved by USFWS before commencement of giant reed removal activities. The relocation plan shall identify appropriate areas to receive translocated California red-legged frogs. These areas must be in proximity to the capture site but outside any area likely to be adversely affected by construction activities. • If sensitive biological resources are found during construction activities, the biological monitor shall have the authority to stop work in the Project Area in order to protect the sensitive biological resource and will implement the relocation plan or other protective measures. • Preconstruction surveys for sensitive species (such as California red-legged frog, two-striped garter snake and southwestern pond turtle) shall be conducted within 24 hours before work begins in each 5-acre work area. • The qualifications of biologists contracted to survey for, capture, and move California red- legged frogs out of harm’s way shall be provided to USFWS for review and approval at least 30 days prior to the commencement of surveys and/or relocation efforts. No surveys and/or relocation activities shall begin until written approval has been received from USFWS that the biologist(s) is (are) qualified to conduct the work. • California red-legged frogs in danger of being taken by Project activities must be relocated to nearby appropriate habitat outside of harm’s way by biologist(s) authorized by USFWS. • The authorized biologist(s) must minimize the duration of handling and captivity of California redlegged frogs. While in captivity, individuals of this species must be kept in a cool, moist, aerated environment, such as a bucket containing a damp sponge or damp vegetation, and they must be maintained in a manner that does not expose them to any environmental conditions that could cause injury or undue stress (such as direct sunlight or excessive time spent in the container). Containers used for holding or transporting these species must not contain standing water (to avoid exhausting the frog by necessitating that it swim). California red-legged frogs should not be transported in the same bucket with western toads or other amphibian species (to avoid direct exposure to other animals’ toxins and to minimize the potential for disease transmission). • Soaps, oils, creams, lotions, repellants, nicotine or solvents of any sort must be cleaned from the hands of any personnel when they are capturing and relocating and California red-legged frogs. • To avoid transferring disease or pathogens between aquatic habitats during the course of surveys and handling of California red-legged frogs, the USFWS-approved biologist must follow the Declining Amphibian Population Task Force’s Code of Practice. Precautionary measures must be taken so that all traces of disinfectant have been removed from the equipment before it is used in a new aquatic habitat. • If least Bell’s vireo, southwestern willow flycatcher, or raptor nests are found, Project activities shall be set back a minimum of 500 feet from nest sites or avoided until the young have fledged.

VCWPD 10 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Invasive Plant Removal Plan

• During initial invasive plant control activities outside of the bird breeding season, if nesting birds protected by the Migratory Bird Treaty Act are found, a buffer shall be marked around the nest to prohibit treatment activities within this buffer. The buffer shall be a 100-foot radius for activities involving mechanized equipment, such as mowers and chainsaws. The buffer shall be a 15-foot radius for activities involving only hand tools such as sprayers and handsaws. • During retreatment activities within the bird breeding season, a biological monitor shall be present at all times. If nesting birds protected by the Migratory Bird Treaty Act are found, a 100- foot buffer shall be marked around the nest to prohibit construction activities within this buffer 7.2 Environmental Best Management Practices Specificity for the project added in brackets [-]. BMP 3: Location of Temporary Stockpiles. • Temporary stockpiles [cut vegetation biomass] in the channel bottom shall be limited to one working day and not overnight. • Temporary stockpiles may be placed in channel bottoms or debris basins if they are placed in such a manner that they would not be exposed to flowing water. • Permanent stockpiles shall be located landward of the 100-year floodplain to the maximum extent feasible. BMP 4: Survey for Habitat (nesting) Prior to Routine Maintenance Work. • A biological survey for nesting birds required prior to work from February 1 to September 15 if in or adjacent to suitable habitat. • Nesting habitat defined as cattail patches, short and tall trees, and shrubby areas. Open gravel, bridges, culverts, and fence posts may also support nests. • Work= [vegetation removal/retreatments] mowing/disking, earth work, clean outs, access road work lasting more than one day, and repairs where nesting bird habitat is in work area or within 300 feet. • If active bird nests are identified, work within 300 feet (500 feet for raptors) must be postponed until after September 15, unless the biologist determines the nest becomes inactive or a reduced buffer is approved by regulatory agencies. • No bio survey needed for routine herbicide application in/on facilities to sparse, short (<3 foot) weedy vegetation (includes young (<1year old mule fat, willows or cattails). [NOTE: BMP 5/6 was not included because it addressed earthwork impacts to creeks with sensitive aquatic species. No earthwork is included in this project description.] BMP 9: Aquatic Pesticide Application. • Follow the most up-to-date Best Management Practices and the monitoring and reporting requirements in the District’s NPDES Stormwater Quality Management Plan. • Comply with the Ventura County Application Protocol for Pesticides, Fertilizers, and Herbicides, including working under the direction of a Qualified Applicator, using materials approved for aquatic use, following the manufacturer’s application directions, avoiding application prior to forecasted storm events and ensuring wind conditions are suitable to avoid spray drift. BMP 21: Avoid Spills and Leaks. • Keep all equipment in good working condition and free of leaks. • No equipment maintenance or refueling in a channel or basin bottom. • Place drip pans under all stationary equipment such as motors, pumps, generators, compressors, and welders. • Spill containment materials must be on site or readily available for any equipment maintenance or refueling that occurs adjacent to a watercourse. • Train all maintenance crews in spill containment and response.

VCWPD 11 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Invasive Plant Removal Plan

• Immediately clean up all spills. Submit report to the Office of Spill Prevention and Response. BMP 22: Biological Surveys in Appropriate Habitat Prior to Vegetation Maintenance. • Biologists conducting surveys for tidewater goby, California red-legged frog, least Bell’s vireo and southwestern willow flycatcher shall be approved by the U.S. Fish & Wildlife Service in writing. • Prior to sediment removal, vegetation control, or repair work in earthen or earthen bottom facilities, an approved biologist shall survey for threatened, endangered, or sensitive species if suitable habitat occurs in or near work area. If such species are within or in close proximity to the work areas, the District shall reschedule the work when the species are not present. • If it is necessary to conduct the work while sensitive species are present or in proximity to the work areas, a species protection plan shall be developed, approved by USFWS/NMFS/CDFW, then implemented. • An approved biologist shall periodically monitor the work area during maintenance activities for wildlife and relocate species as needed to minimize mortality. • Exotic fish, invertebrate, amphibian and reptile species shall be captured when feasible, dispatched and properly disposed by a qualified biologist. BMP 23: Invasive Plant Removal Protocols. • Remove invasive plant species in a manner that prevents propagation. • Spray or mow plants before seeds ripen, when feasible. • All cut/removed invasive vegetation shall be taken to a dump as a destruction load. • Do not stockpile invasive vegetation (including mulch) where materials would wash downstream or allowed to propagate. • For giant reed (Arundo donax), minimize ground disturbance and use foliar glyphosate [and/or a combination of glyphosate and imazapyr] treatment on smaller infestations, as feasible. Best to apply herbicide May 1 to October 1, if breeding birds absent. No grading to remove root masses unless earthwork is part of routine maintenance work. BMP 24: Air Quality (Dust Control). The following measures shall be incorporated into maintenance activities to minimize fugitive dust emissions during grading, excavation, and construction activities. • Minimize the areas disturbed at any one time by clearing, grading, earth moving, or excavation operations to prevent excessive dust. • Cover all truck loads; required by California Vehicle Code §23114. • Prevent fugitive dust (via treatment) on all graded and excavated material, exposed soil areas, stockpiles, including unpaved parking and staging areas, and other active portions of the construction site. • District staff shall weekly monitor contractor graded and/or excavated inactive areas of the construction site for dust stabilization. • No grading/earth work [shredding/chipping] during periods of high winds (i.e., wind speed sufficient to cause fugitive dust to impact adjacent properties) to prevent excessive fugitive dust. • Use rumble strips or track out devices where vehicles enter and exit unpaved roads onto paved road. • All on site construction roads that have a daily traffic volume of more than 50 daily trips shall be stabilized as to minimize transport of earthen [removed non-native plant] material from the site.

VCWPD 12 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Invasive Plant Removal Plan

• There shall be at least one qualified District staff on site each work day to monitor the provisions of the Fugitive Dust Mitigation Plan and any other applicable fugitive dust rules, ordinances, or conditions. • Personnel involved in grading operations shall be advised to wear respiratory protection in accordance with California Division of Occupational Safety and Health Regulations. • All project construction operations shall be conducted in compliance with all applicable APCD Rules and Regulations with emphasis on Rule 50 (Opacity) and Rule 51 (Nuisance). BMP 25: Construction Noise. • Noise-generating construction activities shall be restricted to the daytime (i.e., 7:00 AM to 7:00 PM, Monday through Friday). • Minimize sustained construction noise adjacent to sensitive wildlife during the nesting season, as directed by the biological monitor. • When construction noise is anticipated to affect sensitive wildlife, environmental staff shall consult with regulatory agencies regarding additional mitigation measures. BMP 28: Environmental Training. • Prior to any sediment removal, vegetation control, or repair work in earthen or earthen- bottomed channels and basins that contain surface water or native vegetation, a qualified biologist familiar with the work site shall provide training to the work crew regarding potential species present, habitats to avoid, measures to implement to minimize impacts, and events/situations that require work to be stopped and the biologist to be contacted. BMP 29: Work in California Red-legged Frog Habitat. • Any steep-walled excavations that may trap California red-legged frogs that will be left overnight in suitable habitat (Ventura River, San Antonio Creek) shall be covered. • Approved biologists handling California red-legged frogs shall not use gloves, unless they are well-rinsed and composed of vinyl. • Approved biologists working in California red-legged frog habitat shall follow the Declining Amphibian Task Force Fieldwork Code of Practice. CALIFORNIA RED-LEGGED FROG: USFWS Biological Opinion identified the following impact minimization measures. “Work” includes herbicide, earthwork, and other maintenance, except access road and fence maintenance. MEASURE # ACTION: CRLF-1 Approved biologist conducts daily pre-work surveys. Relocate all life stages potentially affected by work. CRLF-2 Relocation site will be shortest distance to suitable habitat not affected by work. CRLF-3 Biologist will maintain detailed descriptions of relocated individuals to determine if same individuals are recaptured. CRLF-4 Biologist will train all O&M personnel and contractors regarding species and work type/boundaries. CRLF-5 Biologist required to remain on site until all frogs have been relocated, worker education is complete, and vegetation removal has been completed. CRLF-6 Biologist to permanently remove non-native aquatic species, when feasible. Take Limits: Must report acreage of habitat affected by maintenance and mitigation/restoration each year in the Ventura River Watershed. TAKE TYPE ACRES/INDIVIDUALS ANNUALLY

VCWPD 13 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Invasive Plant Removal Plan

Suitable habitat affected by maintenance and 2.5 acres per year repair activities Expected take (relocation, harassment, etc) by 25 individuals (eggs, tadpoles or frogs) maintenance and repair Suitable habitat affected by mitigation or USFWS authorization prior to work. restoration activities Expected take by mitigation 50 individuals per year (eggs, tadpoles, frogs) Critical habitat affected by maintenance and 2.3 acres per year repair activities Critical habitat affected by mitigation activities USFWS authorization prior to work. LEAST BELL’S VIREO/SW WILLOW FLYCATCHER: USFWS Biological Opinion identified the following impact minimization measures. “Work” includes earthwork, and other maintenance, except access road and fence maintenance. MEASURE # ACTION LBV-1 If feasible, conduct work between Sept 16 to Feb 28 in facilities with LBV suitable habitat within 500 feet of work area. LBV -2 March 1 to September 15: approved biologist conduct surveys for LBV/SWFL prior to work with habitat within 500 feet. (see list of facilities) LBV -3 If LBV/SWFL nest detected, minimum 500 foot buffer between work and nest unless otherwise agreed to by USFWS. Biologist must monitor nest during work. LBV -4 Mitigation/restoration projects in suitable LBV/SWFL habitat: avoid removal of willow and cottonwood trees >8 inch dbh. Take Limits: Must report acreage of habitat affected by maintenance and mitigation/restoration each year for both species by take type, as follows. • Suitable habitat affected by mitigation or restoration • Expected take by mitigation • Critical habitat affected by mitigation or restoration

8.0 REFERENCE DOCUMENTS

California Invasive Plant Council. March 2011. Arundo donax Distribution and Impact Report Prepared for the State Water Resources Control Board. (Agreement No. 06-374-559-0).

National Marine Fisheries Service. March 29, 2007. Matilija Dam Ecosystem Restoration Project Biological Opinion.

USACE. September 2004. Matilija Dam Ecosystem Restoration Feasibility Study Final Report Main Report.

USACE/VCWPD. December 2014. Final Environmental Impact Statement/Environmental Impact Report (EIS/EIR) Changes to Draft EIS/EIR Responses to Comments on Draft EIS/EIR

USACE. February 13, 2013. Regional General Permit No 92 (SPL-2008-00052-AJS)

USFWS. March 31, 2005. Biological Opinion for the Matilija Dam Ecosystem Restoration

VCWPD 14 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Invasive Plant Removal Plan

Project, Ojai, Ventura County, California (CON-1-8-04-F-38)

USFWS. December 12, 2012. Final Programmatic Biological and Conference Opinion for Ventura County Watershed Protection District’s Routine Operation and Maintenance Program, Ventura County, California (8-8-11-F/C-12).

VCWPD. September 2013. Aquatic Pesticides Application Plan.

VCWPD. May 2008. Final Environmental Impact Report for the Routine Operations and Maintenance Program.

VCWPD 15 Ventura River Invasive Plant Removal July 2014 and Ecosystem Restoration Project Rio Vista Preserve OVLC

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