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HomeMy WebLinkAbout15.UP23-0011 Exhibit K - Environmental Reports www.cenergypower.com 26880 Aliso Viejo Parkway, Suite 100, Aliso Viejo, CA 92656 Page 38 of 53 Conditional Use Permit Application NCS Solar Project North Chico Solar LLC Exhibit K: Gallaway Environmental Reports  Preliminary Constraints Analysis  Preliminary Wetland Assessment Impacts, and  Botanical Survey for Butte County meadowfoam 117 Meyers Street • Suite 120 • Chico CA 95928 • 530-332-9909 1 Cenergy Power Nance Canyon Preliminary Constraints Analysis GE# 23-008 June 5, 2023 North Chico Solar, LLC. C/O: William Pham 3176 Lionshead Ave, 2nd Floor Carlsbad, CA 92010 RE: Cenergy Power Nance Canyon - Preliminary Constraints Analysis Mr. Pham; Per your request, Gallaway Enterprises conducted a preliminary constraints analysis (PCA) to determine the potential for aquatic resources (including waters of the United States [WOTUS] and waters of the State [WOTS]) and other natural resource constraints. The extent of our survey area (Site) was extended to the edge of pavement along Skyway Road (Skyway), to accommodate for potential infrastructure improvements. The Site is approximately 1,734 acres, located between Neal Road and Skyway, east of Highway 99, in Butte County, CA. (Figure 1). The purpose of this constraints analysis is to provide a professional opinion regarding, 1) the general location and extent of any feature(s) that meet the regulatory criteria to be considered WOTUS, 2) the location and extent of any aquatic feature(s) that would be considered WOTS as currently defined and as based on the approved definition1, and 3) the existence of habitat for any plants or animals listed as threatened or endangered pursuant to either the State or Federal Endangered Species Acts or otherwise determined to have a special-status listing. The determination of WOTUS is based on the current definition of WOTUS in effect on the date of this letter. Our process for conducting this PCA involved a comparison of publicly available historic aerial imagery from Google Earth, www.historicaerials.com, United States Department of Agriculture (USDA), United States Geological Survey (USGS), and Environmental Systems Research Institute (ESRI). Gallaway staff compared aerial photographs and topographical maps, taken during various times of the year dating back to 1941. Features exhibiting wetland signatures were analyzed and mapped accordingly. Current species occurrence data from the California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB), as well as the location of United States Fish and Wildlife Service (USFWS) critical habitat designations within 5 mile of the Site was also reviewed. Our focus for determining the potential for resource constraints involved a review of the presence/absence of sensitive species defined as: • Designated or proposed as rare, threatened, or endangered by the federal government (Endangered Species Act [ESA], 50 CFR 17.12) and various notices in the Federal Register, the California Environmental Quality Act (CEQA), the “Fully Protected” species provisions in the California Fish and Game Code (CFGC), and/or California ESA 1 The State Wetland Definition and Procedures for the Discharges of Dredged or Fill Material to Waters of the State (Procedures) became effective as of May 28, 2020. 2 Cenergy Power Nance Canyon Preliminary Constraints Analysis GE# 23-008 • California Native Plant Society (CNPS) List 1 and 2 plant species • Protected under the Migratory Bird Treaty Act (MBTA) or CFGC Site Conditions and Resource Constraints The Site is located off Skyway Road within Butte County, California, Latitude 39.697056, Longitude - 121.736888, within the United States Geological Survey (USGS) “Hamlin Canyon”, and “Chico” quadrangles, Sections 2, 3, 4, 9, 10, 11, 15 16, Township 21 north and Range 02 east. The Site is bound by Neal Road to the south, Highway 99 to the west, and Skyway Road to the north. The Site is in a rural area, located in the foothills of the Sierra Nevada Mountains approximately one (1) mile east of the City of Chico, four (4) miles south of the Town of Paradise, and eight (8) miles west of Lake Oroville. The Site’s elevation ranges from approximately 340 feet to 660 feet, with an average of 468 feet above sea level. Surrounding land uses consist primarily of small residential communities along Skyway. The Site’s topography consists of hills, canyons, ridge tops, and is predominately comprised of oak woodland and annual grassland vegetation. Large volcanic rocks punctuate the landscape. Unnamed ephemeral and intermittent drainages occur throughout the Site flowing northeast to southwest. Some drainages enter the Site via roadside Culvert along Skyway. Evidence of wetland features occur during the spring and winter months. Overhead transmission lines, near the southwestern and northeastern borders, span the Site. Evidence of pedestrian/vehicular trails, most likely of maintenance or recreational use, occur in proximity to the transmission lines and parallel to some drainage features. Historically, the Site has experienced wildfires most notably the Camp Fire in 2018. Waters of the US and Waters of the State Based on our preliminary assessment, the Site contains multiple ephemeral and intermittent drainages (other waters), and seasonal wetland features. The extent of potential WOTUS and WOTS is depicted in Figure 2. The Preliminary Wetland Assessment (PWA) map was developed for planning purposes only and does not contain sufficient data for submission to the United States Army Corps of Engineers (Corps) or Central Valley Regional Water Quality Control Board (CVRWQCB) for a jurisdictional determination. Multiple features present on-site appear to exhibit surface connectivity to known jurisdictional waters, and therefore would be considered jurisdictional WOTUS; however, the jurisdictional status of all aquatic features on the Site would need to be mapped through the development of a formal aquatic resources delineation. All of the features identified on the Site also meet the definition of WOTS and are regulated by the CVRWQCB. A total of 15.21 acres of potentially jurisdictional WOTUS and WOTS, have the potential to occur on-site. Presence of Special-status Species The CNDDB occurrence map (Figure 3) identified a number of special-status animal and plant species known to occur within 5 miles of the Site. Many of these species require specific habitat requirements that do not occur within the Site boundary. However, the Site may provide low to moderate suitable habitat conditions for special-status birds, and vernal pool botanical and invertebrate species. Based on the habitats present within the Site, the following special-status species have the potential to occur on- site. 3 Cenergy Power Nance Canyon Preliminary Constraints Analysis GE# 23-008 Migratory birds and raptors are protected under the MBTA (16 USC 703) and the CFGC (§3503) and have potential to occur on the Site. Further, some species with potential to occur have special-status designations in California. The MBTA (16 USC §703) prohibits the killing of migratory birds or the destruction of their occupied nests and eggs except in accordance with regulations prescribed by the USFWS. Bird species covered by the MBTA includes nearly all of those that breed in North America, excluding introduced (i.e., exotic) species (50 Code of Federal Regulations §10.13). The Site has low to moderate potential to support bird species protected by the MBTA and CFGC. Activities that involve the removal of trees, vegetation, including grasses and forbs, or ground disturbance can adversely impact birds and should be considered early in the planning process. Vernal pool invertebrates including vernal pool fairy shrimp (Branchinecta lynchi) and vernal pool tadpole shrimp (Lepidurus packardi) are listed as threatened under the ESA and have a low to moderate potential to occur within the wetlands on-site. These vernal pool invertebrates are small crustaceans that inhabit vernal pools and seasonal wetlands. Further, CNDDB occurrences of vernal pool fairy shrimp and vernal pool tadpole shrimp have been recorded within 5 miles of the Property. However, some of the wetlands present on the Site are too shallow or are swale features and do not likely provide ponded habitat for long enough duration to support habitat for listed vernal pool invertebrates. More detailed hydrology data would need to be gathered to confirm which features lack suitable habitat. Special-Status Plants have potential to occur on-Site. These plants include, but are not limited to, Butte County checkerbloom (Sidalcea robusta), Butte County meadowfoam (BCM [Limnanthes flocossa]) and Ahart’s dwarf rush (Juncus leiospermus var. ahartii). A survey for BCM was conducted within the suitable habitats of the Site in 2023 and no BCM was found. Plants constituting California Rare Plant Rank (CRPR) 1B meet the definition of the California Endangered Species Act and the California Fish and Game Code (CFGC) for rare species and are eligible for State listing. Impacts to these species or their habitats must be analyzed during the preparation of environmental documents relating to CEQA, or those considered to be functionally equivalent to CEQA, as they meet the definition of Rare or Endangered under CEQA Guidelines §15125; (c) and/or §15380. Regulatory Approvals Depending on the proposed activities at the Site and the resources identified during protocol level surveys, the following regulatory approvals may be needed: • Clean Water Act 401 and 404 permits • California Department of Fish and Wildlife Lake and Streambed Alteration 1600 Agreement • ESA or CESA compliance permits Summary of Resource Constraints Potentially jurisdictional WOTUS and WOTS occur within the Site. It is recommended that all potentially jurisdictional features be avoided until a formal delineation can be conducted and verified by the Corps. When feasible, establish buffers around aquatic features to minimize indirect effects. Direct impacts to WOTUS as a result of filling activities would require a permit from the Corps (Clean Water Act [CWA] section 404 permit) and compensatory mitigation. Additionally, a CWA section 401 water quality certification from the CVRWQCB would be needed for any direct impacts to WOTS. 4 Cenergy Power Nance Canyon Preliminary Constraints Analysis GE# 23-008 Pre-construction surveys to determine the presence/absence of nesting raptors/migratory birds, rare plants, vernal pool botanical and invertebrate species should be conducted prior to construction activities. There are known populations of Butte County checkerbloom that occur in the oak woodlands. These populations would be considered in any project requiring CEQA approvals. Additional surveys for BCM may be required prior to development of portions of the site. Should you have any questions and need additional information please contact myself or Kevin Sevier at (530) 332-9909. Regards, Anthony McLaughlin, Environmental Planner Gallaway Enterprises, Inc. Site Exhibits: Figure 1. Site Location Map Figure 2. CNDDB Occurrences and Critical Habitat Figure 3. Preliminary Wetland Assessment M 0 0.25 0.5 Miles 1:24,000 Data Sources: ESRI, NAIP 2020 GE: #23-008 Map Date: 05/17/2023 Cenergy Power Nance Canyon Site LocationFigure 1 Site Boundary - (1734 acres) 39.675691,-121.742736 39.706671,-121.710649 Hi g h w a y 9 9 Neal RoadUSGS 7.5' Quad: Chico & Hamlin CanyonT21N, R02E, Section 2,3,4,9,10,11,15,16UTM Zone 10 SkywayButteC re e k M 0 0.25 0.5 Miles 1:24,000 Data Sources: ESRI, NAIP 2020,Historicaerials.com, Google Earth GE: #23-008 Map Date: 05/17/2023 Cenergy Power Nance CanyonPreliminary Wetland AssessmentFigure 2 Site Boundary - (1734 acres) Potential WOTUS and WOTS - (15.21 acres) Wetland Features - (8.47 acres) Other Waters - (6.74 acres) 39.675691,-121.742736 39.706671,-121.710649 Hi g h w a y 9 9 Neal RoadSkyway !! !!! !!!! !!! !!!!!!!!!!!!!!!! !!! !!!!!!!!!!!! ! !! !!!! !!!!!!!!!!!!!!!!!!!!!!!!!!! !!!!!!!!!!!!!! !!!!!!! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! American peregrine falcon American peregrine falcon adobe-lily pallid bathoary bat foothill yellow-legged frog - Feather River DPS western mastiff bat coast horned lizard Butte County fritillary silver-haired bat least Bell's vireo pink creamsacsButte County checkerbloom big-scale balsamrootAmerican bumble bee steelhead - Central Valley DPS North American porcupine California black rail North American porcupine vernal pool tadpole shrimp steelhead - Central Valley DPS adobe-lily California black rail big-scale balsamroot Butte County checkerbloom chinook salmon - Central Valley spring-run ESU Butte County checkerbloom tricolored blackbirdGreat Valley Mixed Riparian Forest bald eagle Great Valley Mixed Riparian Forest Great Valley Valley Oak Riparian Forest Butte County fritillary Butte County meadowfoam foothill yellow-legged frog - north coast DPS foothill yellow-legged frog - Feather River DPS northern slender pondweed veiny monardella foothill yellow-legged frog - Feather River DPS Butte County checkerbloom Hoover's spurge Butte County checkerbloom Swainson's hawk Butte County checkerbloom Butte County checkerbloomButte County checkerbloom Butte County checkerbloomButte County checkerbloomButte County checkerbloom Butte County checkerbloom western pond turtle foothill yellow-legged frog - Feather River DPS brownish beaked-rush vernal pool tadpole shrimp California linderiella burrowing owl valley elderberry longhorn beetle western spadefoot California satintail California beaked-rush vernal pool fairy shrimp Butte County checkerbloomButte County checkerbloomButte County checkerbloom Butte County checkerbloomButte County checkerbloom Butte County checkerbloom Butte County checkerbloom Butte County checkerbloom Butte County checkerbloom Butte County checkerbloom Butte County checkerbloom Northern Hardpan Vernal Pool valley elderberry longhorn beetle Greene's tuctoria Vernal pool tadpole shrimp Butte County meadowfoam Vernal pool tadpole shrimp Hoover's spurge Greene's tuctoria Vernal pool fairy shrimp Hairy Orcutt grass Steelhead Salmon, Chinook Salmon, Chinook Steelhead Steelhead Cenergy Power Nance CanyonCNDDB OccurrencesFigure 3M012Miles Data Sources: ESRI, CDFW, CNDDB, USGS GE: #23-008 Map Date: 05/17/2023 1:125,000 Project Boundary - (1734.1 acres) 5 Mile BufferCritical Habitat Salmon, Chinook ! !Steelhead Critical Habitat CNDDB Occurrences Plant Animal Terrestrial Communities Multiple Occurrences Sensitive Element Occurrence Project Location 117 Meyers Street • Suite 120 • Chico CA 95928 • 530-332-9909 1 Cenergy Power Nance Canyon Preliminary Wetlands Assessment Impacts GE# 23-008 June 5, 2023 North Chico Solar, LLC. C/O: William Pham 3176 Lionshead Ave, 2nd Floor Carlsbad, CA 92010 RE: Cenergy Power Nance Canyon - Preliminary Wetlands Assessment Impacts Mr. Pham; Per your request, Gallaway Enterprises conducted a preliminary impacts assessment to determine the potential for impacts to aquatic resources, as a result of the proposed project. The intent of this memorandum is to provide a professional opinion regarding, 1) the extent and quantity of potential impacts to aquatic resources, and 2) recommend strategies for the minimization and avoidance of impacts to aquatic resources. All impacts discussed are considered preliminary. This assessment was developed for planning purposes only and does not contain sufficient data to implement formal mitigation planning. Prior to any construction activities, a formal delineation of Jurisdictional Waters should be conducted and submitted to the United States Army Corps of Engineers (USACE) and Central Valley Regional Water Quality Control Board (RWQCB) for determination and jurisdiction. Site Conditions The extent of our assessment area (Site) is approximately 1,734 acres, located between Neal Road and Skyway Road, east of Highway 99, in Butte County, CA. The proposed project involves the construction and installation of approximately 717,444 solar panel modules, associated solar sub-stations and inverters, 7’ agricultural fencing, and 20’- 60’ wide access roads. The Site’s topography consists of hills, canyons, ridge tops, and is predominately comprised of oak woodland and annual grassland vegetation. Large volcanic rocks punctuate the landscape. Unnamed ephemeral and intermittent drainages occur throughout the Site flowing northeast to southwest. Some drainages enter the Site via roadside Culvert along Skyway. Evidence of wetland features occur during the spring and winter months. Overhead transmission lines, near the southwestern and northeastern borders, span the Site. Evidence of pedestrian/vehicular trails, most likely of maintenance or recreational use, occur in proximity to the transmission lines and parallel to some drainage features. Historically, the Site has experienced wildfires most notably the Camp Fire in 2018. Methodology Our process for determining impact areas involved a comparative analysis of the client supplied conceptual project designs (Site Plans) and the Preliminary Wetland Assessment Map (PWA). The Site Plans and PWA were georeferenced, using ground control points and aerial imagery, in order to spatially relate the two. Areas of potential impacts are, for the purpose of this analysis, areas of overlap and are depicted in Figure 1. 2 Cenergy Power Nance Canyon Preliminary Impacts Analysis GE# 23-008 Results Based on the preliminary impacts assessment, there is a total of 11.2 acres of impacts to aquatic resources. Potential impacts to wetlands total 6.3 acres, and potential impacts to WOTUS and WOTS total 4.9 acres. This analysis is based on preliminary conceptual designs; therefore, the total acreages of impacts reported are subject to change due to revision in future site plans as well as the development of a formal aquatic resources delineation. Adherence to regulatory agency oversight, and the conditions of the permit, will further refine and minimize potential impacts to aquatic resources. Recommendations To avoid and minimize impacts to the aquatic resources present on-site, the following is recommended: •Prior to any construction activities, a formal delineation of Jurisdictional Waters should be conducted and submitted to the United States Army Corps of Engineers (USACE) and Regional Water Quality Control Board (RWQCB) for determination and jurisdiction. •When feasible, establish buffers around aquatic features to minimize indirect effects. •Revise or refine the proposed Site Plans to further maximize avoidance to aquatic features. •Direct impacts to WOTS as a result of filling or dewatering activities would require a CWA section 401 water quality certification from the CVRWQCB and compensatory mitigation. If it is determined that the wetlands on the site are jurisdictional by the Corps, direct impacts to WOTUS as a result of filling or dewatering activities would require a CWA section 404 permit. Further, any proposed project impacting aquatic resources, such as those present on-site, would require a Lake and Streambed Alteration Agreement, prior to construction. Should you have any questions or need additional information please contact me or Kevin Sevier at (530) 332-9909 Regards, Anthony McLaughlin, Environmental Planner Gallaway Enterprises, Inc. Site Exhibits: Figure 1. Preliminary Wetland Assessment Impacts Map M 0 0.25 0.5 Miles 1:24,000 Data Sources: ESRI, NAIP 2020,Cenergy 05/15/2023 GE: #23-008 Map Date: 05/25/2023 Cenergy Power Nance Canyon Preliminary Wetland Assessment ImpactsFigure 1 Site Boundary - (1734.1 acres) Development Footprint - (1362.2 acres) Site Plan Potential WOTUS and WOTS - (15.2 acres) Wetland Features - (8.5 acres) WOTUS and WOTS - (6.7 acres) Potential Impacts - (11.2 acres) Impacted Wetland Features - (6.3 acres) Impacted WOTUS and WOTS - (4.9 acres) Solar Panel Placement Is Considered Conceptual 39.675691,-121.742736 39.706671,-121.710649 Hi g h w a y 9 9 SkywayThe extents and locations of features presented on this map do notconstitute a formal Delineation of Jurisdictional Waters and shouldbe used for planning purposes only. Prior to any construction activities, a formal Delineation ofJurisdictional Waters should be conducted and submitted to theUSACE and RWQCB for determination of jurisdiction. 117 Meyers Street • Suite 120 • Chico CA 95928 • 530-332-9909 1 Cenergy Power Nance Canyon Project 2023 BCM Survey May 12, 2023 North Chico Solar LLC. C/O: William Pham 3176 Lionshead Ave, 2nd Floor Carlsbad, CA 92010 Mr. Pham; As requested, Gallaway Enterprises conducted a focused protocol-level botanical survey for Butte County meadowfoam (Limnanthes flocossa ssp. californica, BCM) within a 1081-acre survey area (survey area) within the approximately 1,734-acre Cenergy Power Nance Canyon project (project) site (Figure 1) on March 30 and April 4, 6, 11, 13, 18, 26, and 27, 2023. Butte County meadowfoam is a state and federal endangered species and a California Native Plant Society (CNPS) Rank 1B.11 species, therefore, the survey was conducted per U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) guidelines. Location The project site is located in unincorporated Butte County, south of Chico, CA, within the USGS Hamlin Canyon and Chico Quadrangles, Sections 2, 3, 4, 9, 10, 11 and 15, Township 21N, Range 2E (-121.7376 W, 39.6960 N). It is positioned between Highway 99, Neal Road, and Skyway Blvd. The site has had very little human disturbance and is currently used for cattle grazing. The survey area is primarily composed of blue oak woodlands and annual grassland. The site is generally sloped between 0 to 15 percent and is composed of relatively flat terraces with mound-swale microtopography located between low fan terraces containing ephemeral and intermittent streams. A few dirt access roads and power line access roads occur within the survey area. Only the soil map units known to support habitat for BCM, including 614 Doemill-Jokerst, 0-3 percent slopes and 615 Doemill-Jokerst, 3-8 percent slopes, were surveyed for BCM (survey area, Figure 1). The remaining soil map units within the project site are defined by slopes that are too steep to support suitable habitat (8-15 percent slopes) and contain different soil components and composition of components than the soil map units BCM is know to have an affinity towards. Known populations of BCM occur within 1.5 miles of the project site to the north/northwest, which were observed within 615 and 302 soil map units. The project site is not within USFWS designated critical habitat for BCM, and no past occurrences of BCM or other rare plants species have been identified within the site. 1 According to the CNPS Inventory of Rare and Endangered Plants, 1B.1 plants are species that are rare, threatened, or endangered in California and elsewhere; and are seriously endangered in California (over 80% of occurrences threatened /high degree and immediacy of threat). M 0 0.25 0.5 Miles 1:24,000 Data Sources: ESRI, NAIP 2020 GE: #23-008 Map Date: 05/12/2023 Cenergy Power Nance Canyon2023 Butte County Meadowfoam Survey AreaFigure 1 Project Boundary - (1734 acres) Surveyed Area - (1081 acres) Not Suitable Habitat / Not Surveyed - (653 acres) 39.675691,-121.742736 39.706671,-121.710649 Project Location Hi g h w a y 9 9 Skyway 3 Cenergy Power Nance Canyon Project 2023 BCM Survey Methodology The survey for BCM was conducted on March 30 and April 4, 6, 11, 13, 18, 26, and 27, 2023 during the appropriate flowering window of the target species, by botanist Elena Gregg (see Attachment A for Botanist Qualifications) and assisted by senior biologist Jody Gallaway and biologist Cassie Corridoni. The entire survey area was surveyed for BCM. The survey area was traversed on foot using meandering transects with special emphasis placed on the vernal features present. A total of 75 staff-hours were spent in the field conducting this survey. A Trimble Geo Explorer 6000 Series GPS Receiver was on hand to record any special-status plant occurrences observed. The survey was conducted in accordance with the March 2018 CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities and the September 1996 and January 2000 USFWS Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed, and Candidate Plants. The rainfall and inundation was considered average to above average during the winter of 2022/2023 according to the National Oceanic and Atmospheric Administration (NOAA), and moisture in the soil was sufficient to allow for BCM seed germination based on a visit to a BCM reference population. A visit to the BCM reference population at the Meriam Park Preserve in Chico, CA was conducted on March 21, 2023, during which BCM was observed in the bud and flower stage. Additional later visits to the same reference population were conducted on April 19 and 27, 2023, during which the BCM was observed to be in the fruiting stage. Results Much of the survey area consisted of thin soils or on slopes that did not support wetland features, and thus, did not support habitat for BCM. However, a number of scattered vernal pools, swales, and ephemeral drainages were observed that contained suitable habitat for BCM. No BCM plants were observed within the survey area during the protocol-level survey conducted. A list of all of the plant species observed during the survey is provided as Attachment B. The USFWS require 2 years of consecutive surveys to make a presence/absence determination for BCM. This BCM survey is the first year of BCM surveys conducted within the survey area. Should you have any questions, please do not hesitate to contact me at (530) 332-9909 or via email at elena@gallawayenterprises.com. Sincerely, Elena Gregg, Senior Botanist Gallaway Enterprises Attachments: Attachment A – Surveyor Qualifications Attachment B – Observed Plant List Attachment A Cenergy Power Nance Canyon Project 2023 BCM Survey Attachment A Surveyor Qualifications Attachment A Cenergy Power Nance Canyon Project 2023 BCM Survey Elena Gregg, Senior Botanist / ISA Certified Arborist EDUCATION •B.S., Environmental Biology and Management, 2004 University of California, Davis EXPERIENCE 18 Years •Gallaway Enterprises (2013-Current) Senior Botanist, ISA Certified Arborist •NorthStar Engineering (2009-2013) Senior Botanist, ISA Certified Arborist •Gallaway Consulting, Inc. (2006-2008) Botanist, ISA Certified Arborist •Jones and Stokes (2005) On-call Field Botanist •U.S. Forest Service, Truckee and Sierraville Ranger Districts (2004 and 2005) Botanical Technician AREAS OF EXPERTISE •Rare Plant Surveys •Wetland Delineations •Habitat Assessments •Tree Inventories •State and Federal permit Facilitation •Endangered Species Act Documentation •Mitigation Monitoring •CRAM Assessments •Arborist Construction Monitoring •Habitat Restoration •Environmental Awareness Training Elena has over eighteen years of professional experience conducting rare plant surveys, wetland delineations, and habitat assessments in California. She has a working knowledge of CNPS, CDFW, and USFWS survey protocols and holds a CDFW collection permit for listed plant species. Through her ample field experience in a wide array of habitats and eco-regions in Northern California, Mrs. Gregg has gained knowledge of locally invasive plants species as well as rare species. In particular, Mrs. Gregg has surveyed extensively for Butte County meadowfoam, a locally endangered plant species. Mrs. Gregg has a working knowledge of the Clean Water Act regulations and facilitation of local and federal environmental permits. She regularly prepares Caltrans documentation for projects receiving Caltrans Local Assistance. In 2007 Mrs. Gregg gained her Professional Arborist Certification from the International Society of Arboriculture. As a Certified Arborist, Mrs. Gregg conducts tree inventories, tree health assessments, and heritage tree surveys. She also prepares tree preservation plans and has been called upon to monitor trees during construction. Her experience with habitat restoration includes preparing wetland restoration plans, mitigation and monitoring plans, and reclamation plans. Mrs. Gregg also conducts annual monitoring associated with mitigation and re-vegetation projects, and in 2012 was trained in using CRAM to assess riverine and vernal pool systems. Attachment B Cenergy Power Nance Canyon Project 2023 BCM Survey Attachment B List of Plant Species Observed Scientific Name Common Name Achyrachaena mollis Blow‐wives Acmispon parviflorus Hill lotus Acmispon wrangelianus Wrangel lotus Aira caryophyllea Silver hairgrass Allium amplectens Clasping onion Alopecurus saccatus Vernal pool foxtail Amsinkia intermedia Common fiddleneck Astragalus gambelianus Gambel's locoweed Athysanus pusillus Common sandweed Avena barbata Wild oats  Blenospermma nana Yellow carpet Briza minor Lesser quaking‐grass Brodiaea nana Bluestars Bromus rubens Red brome Bromus tectorum Cheatgrass Calandrinia ciliata Redmaids Callitriche sp. Water starwort Calochortus sp.Mariposa lily Carduus pycnocephalus Italian thistle Castilleja attenuata Valley tassels Castilleja lacera Cut‐leaved owl's clover Centaurea solstitialis Yellow star thistle Centromadia fitchii Fitch's spikeweed Cerastium glomeratum Mouse‐eared chickweed Chlorogalum pomeridianum var. pomeridianum Wavyleaf soap‐plant Cicendia quadrangularis Timwort Cirsium vulgare Bull thistle Clarkia purpurea ssp. quadrivulnera Clarkia Claytonia perfoliata Miner's lettuce Clematis ligusticifolia Virgin's bower Crassula aquatica Aquatic pygmyweed Crassula tillaea Moss pygmyweed Cryptantha flaccida Weakstem cryptantha Delphinium hesperium  ssp. hesperium Foothill larkspur Deschampsia danthonoides Annual hairgrass Dichelostemma congestum Fork‐toothed ookow Dichelostemma multiflorum Round‐toothed ookow Dipterostemon capitatus Blue dicks Eleocharis macrostachya Pale spike‐rush Elymus caput‐medusae Medusahead Epilobium cleistogamum Selfing willowherb Eriogonum nudum var. pubiflorum Naked buckwheat Erodium botrys Long‐beaked stork's‐bill Attachment B: Plant Species Observed within the Cenergy Power nance Canyon Project on May  30, April 4, 6, 11, 13, 18, 26, and 27, 2023 Page 1 of 4 Scientific Name Common Name Erodium cicutarum Cut‐leaf filaree Eryngium castrense Coyote thistle Erythranthe glaucescens Shield‐bracted monkeyflower Erythranthe guttata Seep monkeyflower Eschscholzia lobbii Fryingpans Festuca bromoides Six‐weeks fescue Festuca microstachys Small fescue Festuca perennis Rye‐grass Frangula californica California coffeeberry Galium aparine Bedstraw Gastridium phleoides Nitgrass Geranium molle Dove's‐foot geranium Gilia tricolor Bird's eye gilia Gnaphalium palustre Western marsh cudweed Heteromeles arbutifolia Toyon Hordeum marinum  ssp. gussoneanum Mediterranean barley Hypericum perforatum Klamathweed Hypochaeris glabra Smooth cat's ear Juncus bufonius Toadrush Lasthenia californica California goldfields Lasthenia fremontia Goldfields Layia fremontii Tidy‐tips Leontodon saxatilis Hawkbit Lepidium nitidum Shinning pepperweed Leptosiphon bicolor True babystars Leptosiphon bolanderi Bolander's leptosiphon Lessingia sp.Wand lessingia Lithophragma parviflorum  var. trifoliatum Prairie woodland star Logfia gallica Narrowleaf cottonrose Lomatium caruifolium var. denticulatum Foothill lomatium Lupinus bicolor Annual lupine Lythrum hyssopifolia Hyssop loosestrife Matricaria discoidea Common pineapple weed Medicago praecox Mediterranean bur‐clover Micropus californicus var. californicus Q tips Microseris douglasii ssp. tenella Douglas' microseris Minuartia californica Sandwort Montia fontana Water chickweed Myosurus minimus Common mousetail Navarretia leucocephala White pin‐cushion Navarretia tagetina Marigold navarretia Nemophila pedunculata Meadow nemophila Pentagramma triangularis Goldenback fern Petrorhgia dubia Grass‐pink  Pinus sabiniana Gray pine Page 2 of 4 Scientific Name Common Name Plagiobothrys acanthocarpus Adobe popcorn flower Plagiobothrys austiniae Austin's popcorn flower Plagiobothrys fulvus Common popcorn flower Plagiobothrys stipitatus  var. micranthus Small‐flowered popcornflower Plantago elongata Prairie plantain Plantago erecta Erect plantain Plectritis ciliosa Pink plectritis Poa annua Annual bluegrass Poa bulbosa Bulbous bluegrass Poa secunda Bluegrass Pogogyne zizyphoroides Sacramento Valley pogogyne Polygonum bidwelliae Bidwell's knotweed Primula clevelandii  var. patula Lowland shootingstar Psilocarphus brevissimus Wooly marbles Quercus lobata Valley oak Quercus wislizeni Live oak Ranunculus muricatus Prickle‐seeded buttercup Sabulina californica Sandwort Sambucus nigra ssp. caerulea Blue elderberry Sanicula crassicaulis Pacific sanicle Scribneria bolanderi Scribner's grass Sedella pumila Dwarf‐stonecrop Selaginella hansenii Hansen's spikemoss Senecio vulgaris Old‐man‐in‐the‐Spring  Sherardia arvensis Field‐madder Silene gallica Common catchfly Silybum marianum Milk thistle Sisymbrium officinale Hedge mustard Soliva sessilis Lawn burweed Sonchus asper Sow thistle Spergularia bocconi Sandspurry Stellaria media Common chickweed Thysanocarpus curvipes Hairy lacepod Torilis arvensis Hedge parsley Toxicodendron diversilobum Poison oak Trifolium albopurpureum Indian clover Trifolium depauperatum Cowbag clover Trifolium dubium Shamrock clover Trifolium hirtum Rose clover Trifolium microcephalum Maiden clover Trifolium subterraneum Sub clover Trifolium varigatum White‐tipped clover Trifolium willdenovii Wildcat clover Triteleia laxa Ithuriel's spear Triteleia lilacina Foothill triteleia Page 3 of 4 Scientific Name Common Name Tryphisaria ericaria Johnnytuck Veronica peregrina  ssp. xalapensis Purslane speedwell Vicia sativa Garden vetch Page 4 of 4