[Cover]

Supplemental Environmental Assessment 

Fire Road Restoration 
Helen Putnam Regional Park

Sonoma County

FEMA-DR-1628-CA, PW #2482

August 2008

U.S. Department of Homeland Security
1111 Broadway, Suite 1200 Oakland, California 94607


[Inside Cover]
This document was prepared by

Nationwide Infrastructure Support Technical Assistance Consultants
A Joint Venture of URS Group, Inc., and Dewberry & Davis LLC

1333 Broadway, Suite 800
Oakland, California 94612


Contract No. HSFEHQ-06-J-0016

Task Order HSFEHQ-06-D-0489

15708016.00100

Supplemental Environmental Assessment to the Programmatic Environmental Assessment (PEA) for Typical Recurring Actions Resulting From Flood, Earthquake, Fire, Rain, and Wind Disasters in California as Proposed by the Federal Emergency Management Agency

County of Sonoma
Fire Road Restoration at Helen Putnam Regional Park
FEMA-DR-1628-CA, FEMA PW # 2482
August 2008

1. 	INTRODUCTION
The County of Sonoma (COS) has applied for funds from the Federal Emergency Management Agency (FEMA), through the State of California Governors Office of Emergency Services (OES), to re-grade and armor an existing park trail for use as a fire access road in Helen Putnam Regional Park in Petaluma, California. The new fire road is needed because a pre-existing fire road was washed out during the severe storms of the 2005-2006 rainy season. The storms resulted in the presidential disaster declaration FEMA-DR-1628-CA. FEMA is proposing to fund the project under the Public Assistance (PA) Program that was implemented in response to the presidentially declared disaster.

1.1	 SCOPE OF DOCUMENT
FEMA has prepared a Final Programmatic Environmental Assessment for Typical Recurring Actions Resulting from Flood, Earthquake, Fire, Rain, and Wind Disasters in California (PEA), which assesses common impacts of the action alternatives that are under consideration at the proposed project site (FEMA, 2003). The PEA adequately assesses impacts from the action alternatives for some resource areas, but for the specific actions of this particular project, some resources are not fully assessed in the PEA. 

Therefore, for this project to comply with the National Environmental Policy Act (NEPA), FEMA has prepared this Supplemental Environmental Assessment (SEA) to tier from the PEA and fully assess the additional impacts to resources that are not adequately addressed in the PEA. The SEA hereby incorporates the PEA by reference, in accordance with Title 40 Code of Federal Regulations (CFR) Part 1508.28.

1.2	PURPOSE OF AND NEED FOR ACTION
Under the authority of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 93-288, as amended and Title 44 CFR, the PA Program provides supplemental aid to states and communities to help them recover from major disasters as quickly as possible. Specifically, the program provides assistance for the removal of debris, the implementation of emergency protective measures, and the permanent restoration of public infrastructure. The program also encourages protection from future damage by providing assistance for mitigation measures during the recovery process. Therefore, the purpose of this project is to provide PA funding to COS to replace the fire road that was damaged during the presidentially declared disaster.

COS operates the 216-acre Helen Putnam Regional Park, outside of Petaluma, California (Figure 1, Appendix A). The 2005-2006 winter storms washed out a section of an 8 feet (ft) wide dirt fire road approximately 0.25 miles north of the Park parking lot off Chileno Valley Road in Petaluma, CA. The fire road travels from this parking lot north for approximately 0.6 miles, where it turns northeast to intersect the junction of the Panorama hiking trail and the Pomo hiking trail (Figure 2, Appendix A). At the site of the slip-out, there is a large knoll five ft east of the fire road and a privately-owned pasture five ft west of the fire road. The area of the slip-out extends from the knoll down to the adjacent pasture and is approximately 45 ft long x 11 ft wide x 11 ft deep. The fire roads in Helen Putnam Regional Park are necessary for maintenance purposes as well as for potential access to wildfires. Therefore, action is needed to replace the damaged fire road. 

2. 	DESCRIPTION OF THE PROPOSED ACTIONS AND ALTERNATIVES
2.1 	NO ACTION ALTERNATIVE
NEPA requires the inclusion of a No Action Alternative in the environmental analysis and documentation. The No Action Alternative is defined as maintaining the status quo with no FEMA funding for any alternative action. The No Action Alternative is used to evaluate the effects of not providing eligible assistance for the project, thus providing a benchmark against which action alternatives can be evaluated. The No Action Alternative is in conflict with FEMAs mission and the purpose of the PA Program. For the purpose of this alternative, it is assumed that COS would be unable to implement this project for lack of federal assistance, and the fire road would not be restored. The No Action Alternative would severely impact fire hazard and maintenance issues in Helen Putnam Regional Park.

2.2 	PROPOSED ACTION ALTERNATIVE
As defined in Section 2.3.5 of the PEA, the proposed project falls under the action alternative of Constructing New Facilities or Relocating Existing Facilities. COS is proposing to leave the damaged fire road in its current state and re-grade and armor an existing hiking trail, the Panorama Trail, to vehicle-grade conditions so that it may be used as an alternate fire access road (Figures 2 and 3, Appendix A). This would require the following work:

*	 Re-grade 2130 linear ft of trail to 12 ft width and install cover to 3 inch (in) depth,
*	 Grade in four 20 ft x 12 ft rolling drain dips and install cover to 3 in depth,
* 	Grade in two armored 20 ft x 12 ft rolling drain dips and install cover with compacted 2 in minus blue shale,
* 	Grade in a 700 square feet (sq ft) Hammerhead fire access turn-around cover, and
* 	Remove one existing 4 in x 4 in post and move one existing trail maker on a 4 in x 4 in post.

The ingress/egress and project laydown area would occur on the existing Paved Ridge Trail Road, a paved road between the Panorama Trail and the parking lot. 

2.3 	OTHER ACTION ALTERNATIVES NOT CARRIED FORWARD
COS considered reconstructing the damaged fire road. However, the soils at the site of the damaged trail are on steep slopes and erode easily. As a result, the cost involved in stabilizing these soils would be higher than constructing a new trail to connect with existing roads. Therefore, the alternative was dismissed from further consideration.

3. 	AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
The PEA has adequately described the affected environment and impacts of the proposed action for many resource areas, except for geology, seismicity, and soils; air quality; water resources; biological resources; cultural resources; noise and visual resources; and land use and planning. Therefore, the affected environment and environmental consequences for those resources are described in this section, which is intended to supplement the information contained in the PEA. Necessary avoidance and minimization measures, either stipulated in the PEA, or based on the results of the impact analysis in the SEA, that are appropriate for the proposed action, are discussed in Section 4. 

3.1 	GEOLOGY, SEISMICITY, AND SOILS
Helen Putnam Regional Park is located in Sonoma County, three miles south of the city of Petaluma and approximately five miles north of the border with Marin County. The park is located near the top of the Petaluma River valley, which flows southeast from Petaluma and empties into the tidal flats of the San Pablo Bay. The park lies within the California North Coast Range and is bordered to the north by the Mayacama Mountains and to the east by the Sonoma Mountains. The park terrain consists of moderately steep rolling hills, ranging from 280 ft to 558 ft in elevation. The park has a generally east-west trending ridge, with the steepest portion of the park at the northeastern section. 

It is a seismically active area, with the San Andreas Fault lying approximately twenty miles to the east. The rocks in this area were originally part of the Franciscan Complex, a mix of ocean crust rocks which formed on the ocean floor about 140-142 million years ago as the oceanic plate slid under the continental plate. Subsequent uplift, erosion, and sedimentation formed weakly cemented, fine-grained sandstone known as the Merced Formation, which is located in the Petaluma area near the proposed project location. The landscape in the area is generally rounded, but rocky knobs and low cliffs protrude in scattered places where the sandstone contains tuff and is strongly cemented. The soils in this area were formed in material weathered from this sandstone and are generally well drained loams and clay loams of the Steinbeck-Los Osos Association (Miller 1972). 

The project would cause temporary impacts to the ground surface around the project location. The re-grading and armoring of the Panorama Trail would result in short-term soil loss through water and wind erosion due to disturbance of soil structure and removal of vegetation. Construction would entail grading, compaction, and digging along a 12 ft wide and 2130 ft long section of the Panorama Trail. Section 4.1 of this SEA describes best management practices (BMPs) that would minimize erosion and prevent runoff. Construction activities associated with the repair work would not exceed two ft in depth. The ingress/egress and staging areas would occur on the existing Paved Ridge Trail Road, a paved road between the Panorama Trail and the parking lot.

Implementation of the proposed action would result in negligible long-term impacts. Excavated materials would be permanently removed from the site and disposed in accordance with applicable federal, state, and local laws. Project implementation would minimally alter site topography. Therefore, FEMA has determined that with the implementation of the avoidance and minimization measures described in Section 4.1 of the SEA, the proposed action would not result in adverse, long-term impacts to geology, soils, and seismicity.

3.2 	AIR QUALITY
The Federal Clean Air Act (CAA) of 1970 was enacted to regulate air emissions from area, stationary, and mobile sources. This law authorized the U.S. Environmental Protection Agency (EPA) to establish National Ambient Air Quality Standards (NAAQS) to protect public health and the environment. The six criteria pollutants regulated by the CAA are carbon monoxide (CO), lead (Pb), nitrogen oxides (NOx), ozone (O3), particulate matter (less than 10 micrometers [PM10] and less than 2.5 micrometers [PM2.5]), and sulfur dioxide (SO2). 

Additionally, the State of California set California Ambient Air Quality Standards (CAAQS) for ten criteria pollutants including CO, Pb, PM10, PM2.5, NOx, O3, SO2, sulfates, hydrogen sulfide (H2S), and visibility reducing particles. CAAQS are the same or more stringent than the NAAQS.

Under the 1977 amendments to the Clean Air Act, states with air quality that does not achieve the NAAQS are required to develop and maintain state implementation plans (SIPs). These plans constitute a federally enforceable definition of the states approach (or plan) and schedule for the attainment of the NAAQS. Air quality management areas are designated as attainment, non-attainment, or unclassified for each individual pollutant depending on whether or not they exceed an applicable NAAQS or CAAQS. Areas that have been re-designated from non-attainment to attainment are called maintenance areas. 

Prior to approval of any Federal action, the General Conformity Rule (GCR) (Title 40 CFR Part 51.853) states that a a conformity determination is required for each criteria pollutant or precursor where the total of direct and indirect emissions of the criteria pollutant or precursor in a non-attainment or maintenance area caused by a Federal action would equal or exceed (40 CFR 51.853 b) any of the threshold screening rates specified in the GCR. This requires the responsible Federal agency of a Federal action to determine the following:

*	 Does the proposed action generate emissions of criteria pollutants or their precursors;
*	 Does the proposed action generate emissions of criteria pollutants or their precursors in a federally designated nonattainment or a federally designated maintenance area for each pollutant;
*	 Is the proposed action exempt based on criteria listed in the GCR;
* 	Are emissions of criteria pollutants or their precursors resulting from the proposed action below applicable screening threshold rates (hence, exempt from conformity determination requirements); or 
* 	Are emissions of criteria pollutants or their precursors resulting from the proposed action above applicable screening threshold rates (hence, conformity determination requirements apply to, and a formal conformity determination would be needed for the proposed action).

The project area is located within the San Francisco Bay Air Basin, which covers Marin, Napa, Alameda, San Francisco, Contra Costa, San Mateo, and Santa Clara counties, the western portion of Solano County, and the southern portion of Sonoma County. The air basin consists primarily of urban areas with some rural areas along the outskirts of the basin. The climate in the air basin is a typical coastal climate with cool, moist air and moderate temperatures year-round. The summers are dry, and most of the years precipitation occurs during the winter (28-20 inches per year). Specifically, the project area is under the jurisdiction of the Bay Area Air Quality Management District (AQMD). The primary sources of air pollution within the district are personal motor vehicles and industrial facilities. 

If the proposed project is in a federally designated non attainment or maintenance area, direct and indirect project emissions must be compared to applicable GCR screening threshold rates to determine whether or not a formal conformity determination is required. The southern portion of Sonoma County is:

* 	Federally designated as non-attainment for the O3 NAAQS, but is in attainment or unclassified for all other NAAQS (EPA 2007). 
* 	Federally classified as a CO maintenance area; and 
* 	Designated as non-attainment for the O3, PM10, and PM2.5 CAAQS, but is in attainment or unclassified for all other California criteria pollutants (California Air Resources Board 2007).

Therefore, a comparison must be made to demonstrate that the proposed actions emissions would be below the applicable screening threshold rates listed in the GCR. A summary of the applicable GCR emission threshold rates for Sonoma County is presented below.

Applicable GCR Emission Threshold Rates
		GCR Guidance
Pollutant		Non-Attainment (ton/yr)
CO		100 (maintenance area) *
NOx		100 (marginal non-attainment, O3 precursor) *
PM10		100
PM2.5		100
SO2		100
VOC		100 (marginal non-attainment, O3 precursor) *
* Note: Please note that GCR determinations are based on federal attainment designations, not state. The project area is federally classified marginal non-attainment for the 8-hr O3 NAAQS. The area is federally classified as a maintenance area for CO.

Implementation of the proposed action would result in temporary impacts to the existing air quality in the area. These impacts include temporary increases of fugitive dust (PM10 and PM2.5) and combustion emissions (CO, NOX, PM10, PM2.5, SO2, and volatile organic compounds or VOC). Fugitive dust emissions would be generated by vehicle movement over paved and unpaved roads, dirt tracked onto paved areas from unpaved areas at the access point, and particulate matter that is suspended during construction. Combustion emissions would be generated from the operation of construction equipment during the construction process.

It is important to note that there are no NAAQS or CAAQS for VOCs. However, VOCs are a precursor to O3, which has both a Federal and State ambient air quality standard. The formation of O3 occurs in the troposphere as precursor pollutants react in the presence of sunlight. Therefore, the only way to regulate/reduce O3 is through the control of its reactive precursors, one of which is VOC. 

Unmitigated emission estimates were determined using the following guidance and assumptions:

* 	50 construction days/year.
* 	10 working hours/day.
* 	Assumed 0.6 acre of ground disturbance
* 	Emissions were estimated using the equipment loading for a permitted construction project with 38 acres of ground disturbance scaled down to the assumed 0.6 acres of this project; and
* 	US EPA AP-42 and AQMD Guidance.

Based on the above assumptions, the following unmitigated emissions are expected for this project:

Estimated Emissions Rates of Proposed Action
Pollutant		Emission Ratea (ton/yr)
CO
		0.5
NOx		0.2
PM10b		0.1
PM2.5b		0.02.3SO2		0.0004.6
VOC		0.1
a Emissions include contributions from construction equipment and employee vehicles
b Includes particulate from fugitive dust and combustion activities
Even without mitigation measures, the proposed projects emissions are below the applicable GCR threshold emission rates. Therefore, no further analysis is required to establish conformity with the State Implementation Plan; air quality impacts as a result of implementation of this action would be temporary. Mitigation measures to minimize air quality impacts are outlined in Section 4.2 of the SEA.

3.3 	WATER RESOURCES
The project is located within the Petaluma River watershed, which collects water from the low hills surrounding the Petaluma River valley and drains into the tidal flats of the San Pablo Bay. Surface water resources in Helen Putnam Regional Park include a small stock pond (Cattail Pond) and several intermittent or ephemeral streams. One stream channel runs parallel to the Arroyo Trail and crosses the Paved Ridge Trail in the vicinity of the gazebo and picnic area near the parking lot at the entrance to the park. Another stream runs parallel to the Paved Ridge Trail along the eastern edge of the park and drains into Cattail Pond. 

The Panorama Trail is not located close to any stream or tributary; therefore, the re-grading and armoring of the trail would have no long-term impact to surface water resources in the area. Construction would have no effect on groundwater recharge or groundwater quality.

Temporary impacts to surface water resources in the area may occur due to soil erosion caused by the use of heavy equipment on unpaved areas around the Panorama Trail. Section 4.3 of the SEA outlines BMPs which would be utilized to minimize sedimentation into nearby surface waters. With the implementation of these BMPs, and because access and equipment staging would be limited to the paved surface of the Paved Ridge Trail, no adverse impacts to water resources are anticipated as a result of construction activities.

3.3.1 	Floodplain Management
In compliance with Executive Order 11988, Floodplain Management, FEMA considered the proposed actions impacts to the floodplain. The site of the proposed action was examined to determine if the new fire road would be located in either the 100-year or 500-year floodplain. The site is not within the 100-year or 500-year floodplain, so construction of the fire road would not affect the floodplain. Therefore, the proposed action complies with EO 11988.

3.3.2 	Protection of Wetlands
In compliance with Executive Order 11990, Protection of Wetlands, FEMA considered the proposed actions impacts to wetlands. The site of the proposed action was examined to determine if it contained wetlands. The site does not contain wetlands. Therefore, the proposed action complies with EO 11990.

3.4 	BIOLOGICAL RESOURCES
The project area is confined to the north side of the park in an area of grassland with patches of forest dominated by coast live oak (Quercus agrifolia). The grassland is typical annual type but contains local areas with relatively high proportion of native perennial grasses. Plant species observed during an October 2006 site visit include thimbleberry (Rubus parviflorus), cow-parsnip (heracleum lanatum), poison oak (Toxicodendron diversilobum), coyote brush (Baccharis pilularis), sweet fennel (Foeniculum vulgare), coast live oak (Quercus agrifolia), California black oak (Quercus kelloggii), California laurel (Umbellularia californica), western sycamore (Platanus racemosa), arroyo willow (Salix lasiolepis), willow (Salix spp.), Eastwood manzanita (Arctostaphylos glandulosa), blue gum (Eucalyptus globules), and California coffeeberry (Rhamnus californica). 

Animal species observed visually or by sign and calls during the site visit include Beechey ground squirrel (Spermophilus beecheyi), Columbia blacktail deer (Odocoileus hemionus columbianus), turkey vulture (Cathartes aura), red-tailed hawk (Buteo jamaicensis), American kestrel (Falco sparverius), California quail (Callipepla californica), northern flicker (Colaptes auratus),western scrub-jay (Aphelocoma californica), barn swallow (Hirundo rustica), western bluebird (Sialia mexicana), American robin (Turdus migratorius), savannah sparrow (Passerculus sandwichensis), song sparrow (Melospiza melodia), dark-eyed junco (Junco hyemalis), western meadowlark (Sturnell neglecta), red-winged blackbird (Agelaius phoeniceus), and purple finch (Carpodacus purpureus). There are no fish streams present within the project action area. 

The action area provides habitat suitable to support one federally listed species: the California red-legged frog (Rana draytonii)(CRLF). The CRLF is listed as threatened and under the jurisdiction of the United States Fish and Wildlife Service (USFWS). The California Natural Diversity Database indicates that there are several records of CRLF existing within less than one mile of the action area. In addition, suitable breeding habitat exists for CRLF in Cattail Pond, which is approximately 600 feet from the action area. Since CRLF are known to migrate up to one mile from their breeding ponds, the upland areas surrounding these breeding ponds represent suitable dispersal habitat for CRLF. Therefore, the grassland areas and oak woodlands surrounding the action area provide suitable dispersal habitat for CRLF.

Implementation of the proposed action could affect dispersing frogs. Therefore, the proposed action requires consultation with USFWS, under Section 7 of the Endangered Species Act (ESA). To expedite the review process under Section 7 of the ESA, FEMA has developed programmatic compliance documents with the USFWS. In order for the proposed action to qualify under this expedited review process, COS would be required to fully and correctly implement the appropriate conservation measures described in Appendices B and C of FEMAs May 2006 Programmatic Biological Assessment (PBA) for FEMA-Funded Disaster Assistance Projects in California, as amended, for species under USFWS jurisdiction. 

In a letter dated November 21, 2007, FEMA described the conservation measures necessary to protect the CRLF, as listed in the PBA, and requested assurance that COS would implement these measures as a stipulation of funding. On June 23, 2008, COS agreed to implement these measures (Appendix B). These conservation measures are outlined in Appendix B of the SEA.

No other federally listed species or appropriate habitats for potential listed species were observed within the project area. Because the action area does not provide habitat for species under NMFS jurisdiction, no consultation with NMFS is necessary. Therefore, with implementation of the appropriate minimization and avoidance measures pertaining to CRLF that are described in Appendix B of this SEA, this project would have no adverse impact on any federally listed species or their critical habitat and is thus in compliance with the ESA.

3.5	 CULTURAL RESOURCES
FEMA subjected the project area to a cultural resources records review at the Northwest Information Center (NWIC) of the California Historical Resources Information System on October 18, 2006. According to the data provided by the NWIC, there are no recorded sites within the project area, and there are three historic, and one prehistoric, sites within one-half mile of the project area. There were no previous studies of the project area, and five previous studies within one-half mile of the project area. According to the NWIC, none of these sites are listed in, or have been determined eligible for, listing in the NRHP.

In addition, the California Native American Heritage Commission (NAHC) was contacted for a review of its Sacred Lands File and a list of Native American groups and individuals that the Commission believes should be contacted about the project. The Sacred Lands File search was negative. On October 20, 2006, FEMA sent letters to those groups and individuals listed by NAHC, but no responses have been received to date. An archaeological survey of the project area was undertaken on August 9, 2007 by a NISTAC archaeologist, as a consultant to FEMA. The results of the survey were negative.

As described earlier, no properties eligible for the NRHP were identified through a literature review or pedestrian survey of the project area. Therefore, the proposed project is not expected to have any effect on historic properties. Therefore, FEMA has determined that there would be no historic properties affected as described in Stipulation VII, C of the First Amended Programmatic Agreement among FEMA, the State Historic Preservation Officer (SHPO), OES, and the Advisory Council on Historic Preservation.

FEMA informed the SHPO of its determination in a letter dated August 14, 2007. The SHPO failed to object to FEMAs determination or otherwise comment on FEMAs findings. Therfore, in accordance with Stipulation VII.C of the First Amended Programmatic Agreement among FEMA, SHPO, OES, and the Advisory Council on Historic Preservation, FEMA will complete the historic review of the proposed project and may authorize funding. Thus, with implementation of the appropriate minimization and avoidance measures described in Section 4.5 of the SEA, this project complies with Section 106 of the National Historic Preservation Act. 

3.6 	NOISE
The project area is generally quiet due to its rural location within a regional park. The park is located on Chileno Valley Road, which is a rural road and is not a significant source of noise for the project area. Noise-sensitive receptors within and near the existing site include people using the park for recreational purposes. Noise associated with implementation of the proposed action includes the operation of equipment such as backhoes, loaders, and excavators, which generate noise levels ranging from about 70 to 95 dB at 50 feet from the source.

Noise associated with project activities would not occur for more than a period of two months, which is the time required re-grade the Panorama Trail. With implementation of the minimization and avoidance measures described in Section 4.6 of the SEA, impacts to noise-sensitive receptors would be minimal and temporary.

3.7	 VISUAL RESOURCES
The scenic qualities of the landscape within the action area mainly consist of a vegetated environment with grasses, shrubs, and trees. Because the proposed action would only widen a pre-existing trail and would not remove vegetation, the visual context and visual quality of the project area would not change. No new viewsheds would be created and existing views of the action area would not be deteriorated. Short-term impacts to views within the action area would occur during construction when crews are working within the action area. The visual resources of the action area would not change once the proposed action has been implemented.

3.8 	RECREATION
Helen Putnam Regional Park provides trails for hiking, biking, and horseback riding. During construction, these recreational activities would be halted along the Panorama Trail. Parking and traffic flow could also be affected by the presence of construction crews and equipment. However, in the long term, recreational activities along the Panorama Trail would not be impacted. With implementation of the minimization and avoidance measures outlined in Section 4.8 of the SEA, all impacts to recreation activities would be minimal and temporary. 

3.9 	CUMULATIVE IMPACTS
Cumulative impact is the impact on the environment, which results from the incremental impact of the proposed action when added to other past, present, and reasonable future actions regardless of the person or group that undertakes the other actions. FEMA knows of no other projects planned in the vicinity of the proposed project sites. Cumulative impacts are not expected to occur as a result of the proposed action.

4. 	MINIMIZATION AND AVOIDANCE MEASURES
The following minimization and avoidance measures applicable for the proposed action have been extracted from the PEA Section 4, or from measures developed for this SEA based on site specific impacts. 

4.1 	GEOLOGY, SOILS AND SEISMICITY
To avoid adverse impacts to geology, soils, and seismicity, COS would be responsible for implementing construction BMPs to minimize soil loss from the re-grading and armoring of the Panorama trail. Examples of BMPs include the following measures: developing and implementing an erosion and sedimentation control plan, installing and maintaining silt fences or hay bales, mulching cleared areas, revegetating with native species when construction is completed, covering soil that is stockpiled on-site, and constructing a sediment barrier around stockpiles to prevent sediment loss.

4.2 	AIR QUALITY
COS would be responsible for implementing the following BMPs to reduce potential short-term air quality impacts from construction activities:

* 	Watering disturbed areas;
* 	Scheduling the location of the staging areas to minimize fugitive dust;
* 	Keeping construction vehicles tuned properly;
* 	Requiring all trucks to cover their loads;
* 	Sweeping adjacent roads if visible soil is carried over to these areas from the construction site; and
* 	During high-wind periods, curtailing activities to the degree necessary to prevent fugitive dust from construction operations from being a nuisance or hazard on- or off-site.

All construction activities would comply with all Bay Area AQMD rules and standards.

4.3 	WATER RESOURCES
To avoid and minimize any adverse impacts to water resources, COS would be responsible for implementing construction BMPs that would prevent soils from eroding and resulting in sedimentation in the project vicinity. Examples of BMPs include the following measures: developing and implementing an erosion and sedimentation control plan, installing and maintaining silt fences or hay bales, mulching cleared areas, re-vegetating with native species when construction is completed, covering soil that is stockpiled on-site, and constructing a sediment barrier around stockpiles to prevent sediment loss.

4.4 	BIOLOGICAL RESOURCES
COS would be responsible for implementing the general conservation measures described in FEMAs May 2006 PBA for FEMA-Funded Disaster Assistance Projects in California, as amended, for species under USFWS jurisdiction. COS would also be responsible for implementing the appropriate conservation measures required to protect CRLF. These conservation measures are described in a November 21, 2007, letter from FEMA to COS. This letter is attached to the SEA in Appendix B. 

4.5 	CULTURAL RESOURCES
If unanticipated resources are discovered during construction, COS would stop project activities in the vicinity of the discovery, take all reasonable measures to avoid or minimize harm to the property, and notify OES and FEMA as soon as practicable so that FEMA can re-initiate consultation with the SHPO, in accordance with the First Amended Programmatic Agreement among FEMA, SHPO, OES, and the Advisory Council on Historic Preservation. If the discovery appears to contain human remains, COS would also contact the Sonoma County Coroner immediately. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes the remains to be those of a Native American or has reason to believe that they are those of a Native American, he or she would contact the NAHC by telephone within 24 hours.

4.6 	NOISE
COS would be responsible for implementation of the following measures to reduce noise levels associated with construction equipment:

* 	Project activity would not be conducted between 7:00 p.m. and 7:00 a.m. on weekdays,
* 	Project activity would not be conducted between 9:00 p.m. and 6:00 a.m. on Saturdays,
* 	No project related activity would be allowed on Sundays or Federal holidays, and
* 	All noise-producing project equipment and vehicles using internal combustion engines would be equipped with properly operating mufflers and air inlet silencers, where appropriate, that meet or exceed original factory specification.

4.7 	VISUAL RESOURCES
No minimization or avoidance measures are required for visual resources. 

4.8 	RECREATION
COS would be responsible for notifying the public prior to implementation of the proposed action and providing educational materials to the public, such as the posting of fliers at the entrance to the park. 

5.	 REFERENCES

California Air Resources Board. 2006. Area Designation MapsState and National. 
http://www.arb.ca.gov/desig/adm/adm.htm. Site accessed September 18, 2007.
      
Federal Emergency Management Agency (FEMA). 2003. Final Programmatic 	Environmental Assessment (PEA) for Typical Recurring Actions, Flood, Earthquake, Fire, 	Rain, and Wind Disasters in California. U.S. Department of Homeland Security FEMA 	Region IX.

Milliken, R. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San 
Francisco Bay Area, 1769-1810. Ballena Press Anthropological Papers; no. 43. Menlo 	Park, CA.

Miller, Vernon C. Soil Survey of Sonoma County, California. U.S. Department of 
Agriculture, Forest Service and Soil Conservation Service. May 1972.

Moratto, Michael J. 1984. California Archaeology. Academic Press, Orlando.

Sonoma County . 2007. Helen Putnam Regional Park. Electronic document, 
http://www.sonoma-county.org/parks/pk_helen.htm, accessed December 5.
      
Wikipedia. 2007. Sonoma County, California. Electronic document, 
http://en.wikipedia.org/wiki/Sonoma_County, California, accessed November 18.
   
Appendices   
[Appendices are not available in txt format. Refer to the pdf versions of appendices for 
images and full texts of appendices. To obtain a paper copy of appendices, please contact 
Mr. Alessandro Amaglio by phone at (510) 627-7027 or e-mail at Alessandro.Amaglio@dhs.gov.]

Appendix A: Figures
Figure 1: Vicinity Map
Figure 2: Project Area
Figure 3: Project Details

Appendix B: Letter regarding conservation measures to protect the California Red-Legged Frog
The letter, dated June 23, 2008, is from the County of Sonoma and indicates, through an attached and signed letter, the County of Sonoma's agreement with the conservation measures described as a stipulation of the funding for PW 2482.