Avocet Research Associates

_{P.O. Box 839, Point Reyes, CA 94956. Tele: 415/663-8032; <avocetra@gmail.com>}

 

_{Date:  July 22, 2012}

Memorandum

 

To:       San Rafael Planning Commission

 

From: Jules Evens, Principal

 

Re:       Subject: 397-400 Smith Ranch Road (San Rafael Airport Recreational Facility)

 

Please consider this memorandum a response to the Final Environmental Impact Report (FEIR) with reference to that report as well as the Report to the Planning Commission dated January 24, 2012. I am particularly concerned about assumptions and assertions made in those documents regarding sensitivity of the federal- and state-endangered California Clapper Rail  to human disturbance and claims of habituation.

I also commented on the Draft EIR and have conducted numerous surveys of the California Clapper Rail in Gallinas Creek as well as other tidelands of the greater San Francisco Estuary for three decades. I also consulted with the U.S. Fish and Wildlife Service on the "Draft Recovery Plan for Tidal Marsh Ecosystems o(Northern  and

Central California" and contributed to the species account of California Clapper Rail in

 

that plan.¹ Selected excerpts from The Plan relevant to the Gallinas Creek Clapper Rails are provided in.Appendix A. Particularly relevant are the sections on Human Disturbance and Habitat Degradation. Additionally, I was the co-author of the California Clapper Rail species narrative in the San Francisco Bay Area Wetlands Ecosystem Goals Project (Albertson and Evens 2000). My comments are limited mostly to the statements by Monk and Associates that make assertions of "habituation" by Clapper Rails and that either misinterpret or misrepresent the citations they rely on to support their contentions.

 

Responses to assertions made in FEIR and the PC report:

 

Assertion #1: "Wildlife, and birds in particular, are able to habituate to human beings and associated disturbances, especially when the stimuli is predictable (routine or repeated sounds) and when the disturbances that are "nonthreatening" (i.e. not directed toward the bird), as illustrated by Knight and Temple 1995, Knight and Cole 1995, and Riffell et. al. 1996." (PC, p.12-13)

 

 

Response:   These are very broad generalities based on sweeping assumptions referencing studies that do not support the conclusions stated by Monk and Associates. Responses of wildlife to human disturbance are complex and influenced by a range of factors (Bejder eta/. 2009). The studies cited by Monk and Associates relate to common landbirds in forested habitats of the Inner Mountain West, not to a rare and endangered species in tidal marshlands. (Those cited studies are discussed, below.) A better informed and more tenable discussion  of habituation as it relates to the California Clapper Rail is given by the Huffman-Broadway Group (San Rafael) in the Bair Island

(San Mateo Co.) EIR-EIS²:

"Clapper rails vary in their sensitivity to human disturbance, both individually  and between marshes. Certain types of disturbances have occurred  within or adjacent to some marsh areas for a long time and certain clapper rails appear to have habituated or become tolerant of these disturbances, while others appear to habituate over time or are unable to habituate to these disturbances at all. For example, certain clapper rails in Palo Alto Baylands Nature Preserve appear to be somewhat tolerant of the relatively common pedestrian traffic on the public boardwalk that dissects the marsh. Clapper rail nests have been documented within 10 feet of trails in Elsie Romer and Cogswell marshes in Alameda County, and within 65 feet of a busy street near White Slough (Solano County). In contrast, Albertson (1995) documented  a clapper rail abandoning  its territory in Laumeister Marsh in south San Francisco Bay, shortly after a repair crew worked on a nearby transmission tower. The bird did not establish a stable territory within the duration of the breeding season, but eventually moved closer to its original home range several months after the disturbance. As a result of this territorial abandonment, the opportunity for successful reproduction  during the breeding season was eliminated (J. Takekawa, pers. comm.). Clapper rails in Laumeister Marsh have little contact with people, and are apparently quite sensitive to human-related disturbance. On numerous occasions at the Corte Madera Ecological Preserve, rails have been observed seeking refuge from unrestrained dogs entering tidal marshes from adjacent levees with public access (J. Garcia, pers. comm. 1994). These disturbances  have occurred despite the presence of signs notifying users that they are entering sensitive wildlife species areas and that pets must be under restraint while in the preserve area. Similarly, along the Redwood Shores Peninsula in San Mateo County, fences and signs installed to prevent access into areas with endangered  species habitat have been repeatedly vandalized and people continue to enter the prohibited areas beyond the fences and signs (Popper and Bennett 2005). Evens and Page (1983) documented 4 rail breeding territories along the Greenbrae boardwalk in the Corte Madera Ecological Preserve. In 1993, no rail breeding territories were discovered along the boardwalk even though rail habitat conditions remained unchanged (J. Garcia, pers. comm.). This territorial abandonment  is attributed to an increase in domestic and feral dogs and cats along the boardwalk resulting from new residents moving into nearby residential areas since 1983 (J. Garcia, pers. comm.). According to Harvey (1980) and Foerster et al. (1990), predators, especially rats, accounted for nest losses of 24 to 29 percent in certain South Bay marshes. Clapper rail reactions-to disturbance may vary with season, however both breeding and non- breeding seasons are critical times. Disturbance during the nonbreeding season may primarily affect survival of adult and subadult rails. Adult clapper rail mortality is greatest during the winter (Albertson 1995; Eddleman 1989), and primarily due to predation (Albertson 1995). Human-related disturbance of clapper rails in the winter, particularly during high tide and storm events, may increase the birds' vulnerability to predators. The presence of

people and their pets in the high marsh plain or near upland areas during winter high tides may prevent rails from leaving the lower marsh plain (Evens and Page 1983). Rails that remain in the marsh plain during inundation are vulnerable to

predation due to minimal vegetative cover available (Evens and Page 1986). A population viability analysis under development for clapper rails identifies changes in adult survivorship as causing the greatest change in the population growth rate (M. Johnson, pers. comm). Another model also indicates that adult survivorship of clapper rails is the primary demographic variable for maintaining a stable population or causing the population to either increase or decline (Foin et a/. 1997). These models indicate that survival of adult birds has the strongest effect on the perpetuation or extinction of the overall population.

 

This more balanced and cautionary approach provided by Huffman-Broadway touches on (but does not elaborate on) the underlying problem with the assertion that a given species or a given population will "habituate" to ongoing disturbance. To determine that fact, one would have to compare reproductive success and other demographic variables of a clapper rail population in a disturbed marsh with that of an undisturbed or relatively pristine marsh. Such studies are simply not available because this is an federally endangered species; research is limited by the USFWS Office of Endanger Species to avoid negatively impacting those few individuals that still survive and there are few, if any, pristine sites left.

The claim by Monk and Associates that habituation is a foregone conclusion for the California Clapper Rail is unsupported by any studies or the references they cite (see below), and provides a shallow and misleading interpretation of the concept:

Habituation is often used incorrectly to refer to any form of moderation in wildlife response to human disturbance, rather than to describe a progressive reduction in response to stimuli that are perceived as neither aversive nor beneficial. This misinterpretation, when coupled with the widely held assumption that habituation has a positive or neutral outcome for animals, can lead to inappropriate decisions about the threats human interactions pose to wildlife. (Bejder eta/. 2009)

Regarding the references used to support Monk and Associates assertions about habituation: A peer-reviewed source (Cline eta/. 20007) interpreted the Knight and Temple reference cited by Monk and Associates: "A number of biological  and environmental variables also contribute to individual response to disturbance.  These variables are complex because wildlife responds differently to disturbance  between species, between individuals of the same species, and between different periods of time for a single individual (HaySmith and Hunt 1995; Knight and Temple 1995). These confounding variables make studying disturbances  difficult at best."

Likewise the other two references cited by Monk and Associates do not support their assertion about habituation.

The Riffel eta/. study was conducted in mixed conifer forests in Wyoming and states in the abstract that "common species showed significant declines in richness  and abundance over the 5 years." That study looked at common forest birds not rare, furtive and endangered tidal marsh species. (The Clapper Rail does not occur in the Intermountain West.) Indeed, another peer-reviewed  study suggests a different interpretation of Riffel eta/. 1996, as follows, from Tanner and Gange (2004): "Activities including hill walking (Riffell et at., 1996), power boating (Bell, 2000), wildlife­ photography and skiing (Burger, 2000) have all been shown to disturb wildlife and habitats."

Likewise, the Knight and Cole (1995) paper-a generalized  study of various wildlife species in Colorado-is interpreted quite differently in a government  literature review of wildlife disturbance impacts. Cline eta/. 2007 state: "The mere presence of visitors may harm wildlife by displacing them from essential habitats or disrupting the raising of young (Knight and Cole, 1995). Therefore, the question is not so much does the activity cause impact, but rather, how much and what level of impact is acceptable. Disturbance includes both direct and indirect effects toward wildlife"

Again, Becker eta/. (2012) draw quite a difference conclusion  from Knight and Cole: "Human disturbance stimuli can distract animals from pursuing  fitness-enhancing activities (e.g., feeding, mating), alter normal behavior, and cause animals to avoid suitable habitat or to reduce the size of their ranges (Boyle and Samson 1985, Knight and Cole 1995, Cole and Anthony 1997, Shively et al. 2005, Borkowski  et al. 2006). [Emphasis added]

In summary, there is no evidence that California Clapper Rails habituate to human disturbance and it is reckless to assert otherwise, especially  when determining  land-use practices that may have adverse impacts on a federally-endangered species.

 

Assertion #2: Monk and Associates state without qualification: "The fact that Clapper rails have persisted in this area over at least several years of study, and have been repeatedly detected during the nesting season, demonstrates that the Clapper rail must be successfully reproducing."

 

Response: Note the emphatic use of "demonstrates" and "must." Although their conclusion may seem "logical" it is at odds with basic precepts of conservation biology and no such conclusion is certain or warranted . The presence of Clapper Rails in the area does not "demonstrate" successful reproduction. As the Draft Recovery Plan (q.v.) states explicitly: ' Although clapper rails may occur in areas with high levels of human­ related disturbance. the effects of the disturbance on the rails is unknown and potentially significant ... Because most clapper rail marshes are subjected to a variety of uses, the cumulative detrimental effects may be appreciable. Numerous routine human activities have the potential to adversely affect individual rails and overall population viability ..." (p. 114). [Emphasis added]

 

In fact, very little is known about the reproductive success of the local population. It is a basic precept of conservation biology that presence or abundance of a given species is not a reliable indicator of breeding success (Vickery eta/. 1992) or habitat quality (VanHorne 1983). We do know that the Gallinas Creek marshlands are contiguous with perhaps the largest extant population of clapper rails left in San Pablo Bay marshes­ those associated with the broad bayshore marshlands that extend from the mouth of Gallinas Creek north to Hamilton Field (Evens and Collins 1992, Collins eta/. 1994, Albertson and Evens 2000, Avocet 2004). This is the most extensive and least disturbed parcel of tidal marsh habitat left in the North Bay, hence the presence of an apparently viable population. When the bayshore population has a successful nesting year, it likely serves as a source for those birds that disperse up Gallinas Creek. However, we have

no idea how successful those dispersants are reproductively and there are no data on

 

survivorship of the population.

 

The subject of metapopulation dynamics is too complex and nuanced a subject for this memorandum, but suffice it to say that some habitats are "sources" and other are "sinks" (Pulliam 1996, Battin 2004, Akcakaya eta/. 2006, Gilroy and Sutherland 2007). Just because a species occurs in a given habitat does not mean that that habitat is viable or optimal The contention that because clapper rails are present they are "thriving" is far too facile an assumption to make when considering a federally endangered species. Rather, the responsible course of action for governmental  agencies  and consulting biologists is a conservative approach taking precautionary  measures.  It is reckless to make assumptions based on limited information and to select references  that appear to support those assumptions while ignoring counterbalancing information, as is done in the FEIR and the PC report.

  

Concluding remarks

 

The presence of rails in the linear tidelands bordering Gallinas Creek does not support the assumption that the population is "thriving" or even viable.  Again, as stated in the from the U.S. Fish and Wildlife Service's "Draft Recovery Plan for Tidal Marsh Ecosystems of Northern and Central California:" 

Although clapper rails may occur in areas with high levels of human-related disturbance, the effects of the disturbance on the rails is unknown and potentially significant ... Because most clapper rail marshes are subjected to a variety of uses, the cumulative detrimental effects may be appreciable. Numerous routine human activities have the potential to adversely affect individual rails and overall population viability ...

Even if it were possible to conclude that Clapper Rails in the vicinity of the Project were habituated to human presence based on existing levels of use, that does not mean that the construction and operation of an active sports facility drawing over a thousand visitors per day would not adversely impact the Clapper Rail.  There is no evidence  to support the FEIR's conclusion that the Clapper Rail will simply adapt to the additional noise impacts, lighting, and intrusions into Gallinas Creek caused by the Project. With its daily generation of food waste, the Project. is highly likely to increase populations  of scavengers, especially rats- known predators of the California Clapper Rail. The FEIR does not evaluate impacts of the Project caused by increased predation from rats and other predators that will be subsidized by the Project.

Additionally noise mitigations during the construction phase of the project are inadequate. Specifically, the FEIR proposes no piling driving during the nesting season, but allows other construction during that time with a 250-foot buffer.  The USFWS requires a minimum 250-foot buffer from occupied habitat during the period January  15- September 1.

"Size of buffer areas or transitional habitat (area between the marsh and uplands) is important because outside influences from the upland area may

have devastating  effects in the marsh. The larger the buffer, the less severe or direct the impacts will be."³

 

In summary, the EIR's conclusion  that the Proje-ct will not have a significant impact on California  Clapper Rail is based on the assumption that the population of Clapper Rail in the vicinity of Gallinas Creek has became habituated to human presence. This conclusion  is not supported by the research.

 

Thank you for your consideration of this matter.

 

 

 

 

Jules Evens, Principal Avocet Research  Associates P.O. Box 839

Point Reyes Station, CA 94956-0839

415/663-8032 avocetra@gmail.com

 

U.S. Fish and Wildlife Endangered  Species Permit: TE 786728-3

California Department of Fish and Game Collectin9 Permit# 801092-04

Federal Bird Marking and Salvage Permit:# 09316-AN

 

 

 

^{3 http://www.fws.gov/desfbay/Archives/Ciapper/carail.htm}

 

APPENDIX A. Selected excerpts from the U.S. Fish and Wildlife Service's "Draft Recovery Plan for Tidal Marsh Ecosystems  of Northern and Central California"

 

"California clapper rails were recognized  as endangered  by the Federal government and added to the List of Endangered Species on October 13, 1970 (U.S. Fish and Wildlife Service 1970). California clapper rails were added to the State endangered species list on June 27, 1971 (California Department of Fish and Game 2005). It has a recovery priority number of 3C, based on a high degree of threat, a high potential of recovery, and its taxonomic standing as a

subspecies. The additional "C" ranking indicates some degree of conflict between the conservation needs of the species and economic development (U.S. Fish and Wildlife Service 1983) The first recovery plan for the species was published November 16, 1984 (U.S. Fish and Wildlife Service 1984). Factors currently impacting raii numbers baywide include predation, contaminants, and habitat loss/alteration/degradation."

 

Regarding local distribution:"San Pablo Bay. Small populations of clapper rails are patchy and discontinuously distributed throughout San Pablo Bay in small isolated tidal marsh habitat fragments (Collins et a/. 1994). In 2004 there were between 84 and a few hundred pairs (not individuals)  in the San Pablo Bay region (Avocet Research Associates 2004). Highest numbers of clapper rails in San Pablo Bay currently occur in South Gallinas and Hamilton Army Airfield marshes, and at the mouth of Gallinas Creek (Herzog eta/. 2006)." [Emphasis added-JE].

 

Productivity. Reproductive success of the California clapper rail is much reduced below the natural potential (Schwarzbach  eta/. 2006).

 

Survivorship. The only estimates of annual adult California clapper rail survivorship were relatively low, ranging from 0.49 to 0.52 (Albertson 1995). These are similar to sur1ival estimates reported for the Yuma subspecies (Eddleman 1989). Increased predation occurs during extreme winter high tides, probably due to increased movement  of rails at this time when little cover is available (Albertson and Evens 2000). Adult survivorship has been suggested as the key demographic  variable associated with survival of clapper rail populations (Fain eta/. 1997).

 

Habitat: Rail foraging and refugial habitat encompasses  the lower, middle, and high marsh zones, as well as the adjacent transitional zone. Lower and middle marsh zones provide foraging habitat at low tide. Small tidal channels (i.e., first­ and second-order)  with dense vegetation covering the banks are particularly important habitat features (Keldsen 1997, Garcia 1995). These provide important foraging habitat and hidden routes for travel in close proximity to nesting habitat. Higher marsh areas (high marsh and transitional zones) with dense vegetation are used for nesting and high-tide refuqia (DeGroot .1927, Harvey 1988, Foerster eta/.  1990, Evens and Collins 1992, Collins eta/. 1994) ... Physical habitat characteristics critical to clapper rails include marsh size, location relative to

other marshes, presence of buffers or transitional zones between marshes and upland areas, marsh elevation, and hydrology (Collins eta/.  1994, Albertson

 

 

1995). [Emphasis added-JE]

Under "Reasons for Decline and Threats to Survival" (pgs 109-11OJ

Habitat Degradation. Other than outfight habitat loss due to marsh reclamation,

significant historic degradation to clapper rail habitat quality in remaining tidal marshes is caused by numerous human-caused physical and biological changes in the San Francisco Bay Estuary tidal marshes, including:

(1)         Construction and maintenance of dikes in tida.l wetlands-many adverse effects stem from these actions, including

a.marsh fragmentation and reduction to small isolated marshes b.reduction in quality, distribution. and abundance of critical sub-habitats. such as

high tide refugia

(2)  Replacement of tidal refugia along landward marsh edges with unbuffered urban edges

 

Human Disturbance: Data on reproductive success of nests near heavily trafficked areas are lacking. Clapper rails nesting next to regularly disturbed areas are likely to be subject to higher rates of predation due to easy access provided by trails, dikes, and roads. Disturbance of incubating or brooding adults may translate into reduced hatch or fledge success of young through lncreased nest predation if the adult vacates the nest, or through temperature stress (heat or cold) due to lack of thermoregulation by the adult. Reduced reproductive success results in reduced recruitment to an already unstable endangered population. In addition, continued disturbance may stress the adults and reduce survival through disruption of normal activities, such as reduced foraging or resting time or increased susceptibility to predators. Reduced survival of adult clapper rails may also impact the long-term viability of the population, which has been identified as the most critical life stage in population models (M. Johnson unpubl. data; Fain et at. 1997).

 

EXHIBIT D

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist

3.36_60_Annapolis Road

Annapolis, California  95412

 

 

(415) 310-5109                                                                                                          baye@earthlink.net

MEMORANDUM

 

To: Ellison Folk, Shute-Mihaley & Weinberger  LLP folk@smwlaw.com

 

Date: July 30, 2012

 

SUBJECT: San Rafael Airport  Recreational  Facility FEIR  (SCH 200612125) biological resources

 

1. I have reviewed the City of San Rafael's San Rafael Airport  Recreational  Facility FEIR  and DEIR's sections  on project  description  and biological resources, at your request. Following preliminary review of potentially significant impacts  and mitigation measures, I focused my review on an apparent gap (significant omission) in the EIR's  assessment  of long term cumulative impacts of the project on foreseeable future critical high tide refuge habitat for the California clapper rail, salt marsh  harvest mouse  (federal and state listed endangered species) and California black rail, as well as California black rails (state-listed endangered) inhabiting the fringing salt marsh  neighboring the Project site.

 

The FEIR  apparently fails to integrate  revised sea level rise assessment  (hydrological analysis; HYD-2)  with significant habitat and endangered  species impacts, in relation to levee maintenance, mowing  for "safety" requirements, and the feasibility of the (static) 130-250 ft buffer zone mitigation  (MM Bio 2b-c). Your comment letter on the DEIR as well as the comments of Jules Evens,  the Marin County Open  Space District, Marin Conservation League, and others  all identified  the failure of the EIR  to adequately address impacts  to the endangered  salt marsh  habitat and the species that rely on it, and the failure to analyze the project's  impacts in relation  to sea level rise.  My comments here will focus on the failure of the EIR  to address  the impact  of the Project, combined  with sea level rise, on tidal salt

marsh  habitat and endangered species that rely on it, including the California Clapper Rail and the salt marsh  harvest mouse.

 

2. The DEIR and FEIR coverage of endangered  salt marsh species habitat issues, however, appears  to be limited to short-term or near-term impacts based only on current  sea level and habitat configurations, as though  "existing conditions" precluded analysis of foreseeable cumulative impacts  between  the project, its mitigation measures, and sea level rise over decades. Rising sea level will change the distribution, quality, and abundance  of salt marsh and high tide refuge habitat in relation to the flood control infrastructure and its maintenance  on which the project would depend. The EIR did not evaluate conflicts (impacts) between the project's new flood control requirements (HYD-2)  and the inevitable vertical and horizontal  displacement of high tide refuge habitat of endangered  species driven by sea level rise. To the extent that the proposed  project permanently  relies on perpetual maintenance  (or upgrading) of the existing levee for flood control  of new development (to prevent levee breaching and flooding of newly developed  recreational  facilities), and

proposes  to maintain mowing in the undeveloped  "buffer  zone" in perpetuity landward  of the existing levee, the project as proposed  would cause or contribute significantly to "coastal squeeze" of existing salt marsh and high tide transition zone habitat as sea level rises 12-18 inches by 2050. (The FEIR concedes that 2050 is not a speculative long-term planning horizon  for this project's re-assessment of sea level rise and flood vulnerability; see response

45-21).                                                                                                 .

 

3.  Even if portions  of the e:Jdsting narrow fringing salt marsh are able to keep pace \vith sea level rise by accreting vertically (sediment deposition),  the horizontal  extent of salt marsh between the levee and the channel would narrow as tidal prism increases with sea level rise, and the extent of the critically important high tide refuge habitat (dense, tall, vegetation cover for rails and salt marsh harvest mouse during flooding of extreme  high tides) would decrease if the levee is maintained in a fixed position. Maintaining ecological viability of existing salt marsh habitat, and feasible buffer zones proposed in mitigation measures  (MM Bio2b-c) in the long term would require levee set-back   andward realignment, widening the outboard  slope below the height of extreme high storm  tide flood elevations).

 

The FEIR does not assess the feasibility of this biological mitigation in relation to foreseeable sea level rise. The existing extent and quality of suitable salt marsh and critical flood refuge habitat for endangered  wildlife species (discussed in detail by Jules Evens, letter

40) and buffer zone functions could be maintained  during sea level rise, but only with set­ back of the levee  andward displacement or modification of the levee cross-section, or both). In existing conditions  of undeveloped  diked baylands or open space, there is less physical constraint  on adapting flood control levees to sea level rise that is compatible or beneficial to long-term  survival of endangered  resident tidal marsh -.,v11dlife. Project-induced

flood control requirements  or mitigation measures (such as spatially f1Xed, permanent buffer zone deed restrictions  that may conflict '\vith levee realignment)  may preclude or significantly impair feasibility of levee set-back for integrated coastal habitat and flood control realignment.  The DEIR and FEIR  are silent on this significant conflict in resource management  caused by the project and static mitigation  buffer zones in a regime of accelerated foreseeable sea level rise by 2050.

 

4. In conclusion, the FEIR apparently has not applied the revised assessment  of sea level rise (response to comment  45-21; Master Response  to Comments HYD-4)  to the assessment  of long-term  project impacts on the position, quality, stability, and extent of the critical high tide refuge habitat that currently (temporarily) occurs between the landward  edge of the regularly flooded intertidal salt marsh, and the outboard slope of the perimeter levee. The FEIR (citing the biological consultant, Monk & Associates) recognized  that resident California clapper rails must "occasionally" seek refuge of the uplands immediately adjacent to the channel (i.e., levee transition  zone), but the DEIR and FEIR  failed to consider the significant impacts  of forcing this critical habitat zone to occupy a fixed position on a levee and buffer zone maintained for flood control  and vegetation  mowing as sea level rises. In my professional opinion,  the proposed mitigation measures  to protect  clapper rails would be infeasible in the long term unless the project and its mitigation were redesigned to accommodate sea level rise with integrated  flood control  and wildlife habitat. As proposed, the recreational  facility development proposed would significantly increase conflicts with this necessary adaptation  of tidal marsh and flood control  structures  (levees) to sea level rise.  .

 

  

STATEMENT OF QUALIFICATIONS

 

Peter Baye is a coastal ecologist and botanist  with 32 years professional  experience in conservation and management of coastal vegetation,  focusing on dunes, barrier beaches, tidal marshes, and lagoons.   He received his Ph.D.  from the University of Western Ontario, Department of Plant Sciences, Canada, in 1990. Peter performed environmental analysis for NEPA, Clean Water Act, and Endangered Species Act compliance  at the U.S. Army Corps of Engineers, San Francisco District, and prepared  endangered  species recovery plans and Section 7 consultations for the U.S. Fish and Wildlife Service, Sacramento. He currendy works as an independent consulting  coastal ecologist in the central California coast region, developing  coastal habitat restoration projects, vegetation  management plans, and endangered species recovery projects. His work in the San Francisco  Estuary includes:

•    lead author  and coordinator of USFWS administrative  draft recovery plan for tidal marsh ecosystems  of Central and Northern California (with appendices),  now in public draft;

•     author and co-author of two bayland plant community  chapters in the San Francisco Bay Ecosystem Habitat  Goals Project  Species and Community Profiles volume, co­ chair of Plant Team  of the Goals Project,  USFWS and U.S. Army Corps of

Engineers  representative for the Goals Project, and participant in the current  (2012) Goals Project  update  for climate change/ sea level rise;

•     co-author or sole author  of multiple tidal marsh restoration and management plans including habitat  for endangered species, includingSears Point Wedand Restoration Project, Bahia Wedand  Restoration Project, Pier 94 San Francisco  wedand shoreline enhancement, Petaluma  Marsh Enhancement Project.

 

  

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist,

^{baye@earthlink.net}                                                                                                                             3

(415) 310-5109

 

EXHIBIT E

CEQA –

  

EXHIBIT F

 A Geospatial Analysis of the Effects of

Aviation Gasoline on Childhood Blood Lead Levels

 …

…

…

Conclusions Aeronautical Fuel Impact

Our analysis indicates that living within 1,000 m of an airport where avgas is used may have a significant effect on blood lead levels in children. Our results further suggest that the impacts of avgas are highest among those children living closest to the airport. This study adds to the literature examining whether leaded avgas poses risks to children's health and speaks directly to the ongoing policy debate regarding the regulation of leaded avgas.

 

EXHIBIT G 

Federal Aviation Administration (FAA) requirements for

obstruction lighting equipment

 

 

TABLE OF CONTENTS

 

 

CHAPTER  1.  SCOPE AN

CLASSIFICATION................................................................................... !

 

1.1           SCOPE. ........................................................................................................................................... !

1.2           EQUIPMENT CLASSIFICATION. ...................................................................................................... 1

 

CHAPTER 2.  REFERENCED DOCUMENTS....................................................................................... 3

 

2.1           GENERAL.......................................................................................................................................3

2.2           FAA ADVISORY CIRCULARS (ACS)..............................................................................................3

2.3           FAA  ENGINEERING BRIEFS...........................................................................................................3

2.4           MILITARY STANDARDS AND SPECIFICATIONS..............................................................................3

2.5           CODE OF FEDERAL REGULATIONS (CFR)..................................................................................... 3

2.6           INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS (IEEE)  PUBLICATIONS.................... 3

2.7           INTERNATIONAL STANDARDIZATION ORGANIZATION (ISO) PUBLICATIONS...............................3

2.8           INTERNATIONAL CIVIL AVIATION ORGANIZATION (ICAO)......................................................... 3

2.9           ILLUMINATING ENGINEERING SOCIETY (IES)............................................................................... 3

 

CHAPTER 3.  EQUIPMENT REQUIREMENTS................................................................................... 7

 

3.1           GENERAL....................................................................................................................................... 7

3.2           ENVIRONMENTAL REQUIREMENTS...............................................................................................7

3.3           DESIGN REQUIREMENTS.............................................................,.................................................. 7

3.3.1       LightUnit. ............................................................................................................................. 7

3.3.2       Light  Covers.......................................................................................................................... 7

3.3.3       Light  Colors.......................................................................................................................... 7

3.3.4       Aiming (for L-856  and L-857).............................................................................................. 8

3.3.5       Control Unit.......................................................................................................................... 8

3.3.6       Input  Voltage................................................................................................................:....... 9

3.3.7       Performance Criteria............................................................................................................. 9

3.3.8       Transient Protection.............................................................................................................. 9

3.3.9       Radiated Emissions............................................................................................................. 10

3.3.10     Warning Labels. .................................................................................................................. 10

3.3.11    Interlock Switches............................................................................................................... 10

3.3.12     Nameplate...........................................................................................................................10

3.3.13    Optional Arctic Kit.............................................................................................................. 10

3.3.14     Component Ratings............................................................................................................. 11

3.3.15     Leakage Current. ................................................................................................................. 11

3.4           PERFORMANCE REQUIREMENTS.................................................................................................. 11

3.4.1       Photometric......................................................................................................................... 11

3.4.2       Flash  Rate  and Duration...................................................................................................... 14

3.4.3       System  Flashing Requirements........................................................................................... 15

3.4.4       Intensity Step  Changing...................................................................................................... 16

3.5           INSTRUCTION MANUAL............................................................................................................... 16

 

CHAPTER  4.  EQUIPMENT QUALIFICATION REQUIREMENTS............................................... 19

 

4.1           QUALIFICATION PROCEDURES....................................................................................................19

4.2           QUALIFICATION TESTS................................................................................................................ 19

4.2.1       Photometric Test. ................................................................................................................19

4.2.2       High  Temperature Test. ............................................:.........................................................20

4.2.3

4.2.4

4.2.5

4.2.6

4.2.7

4.2.8

4.2.9

4.2.10

4.2.11

_4.2.12

Low Temperature Test. ....................................................................................................... 20

Rain Test. ............................................................................................................................ 21

Wind Test............................................................................................................................ 21

Humidity Test. .................................................................................................................... 21

Salt Fog Test. ...................................................................................................................... 21

Sunshine Test. ..................................................................................................................... 21

Transient Protection Test. ................................................................................................... 22

System Operational Test..................................................................................................... 22

Leakage Current Test. ......................................................................................................... 23

_{Visual Examination.............................................................................................................23}

 

CHAPTER 5.  PRODUCTION TEST REQUIREMENTS................................................................... 25

 

5.1           SYSTEM PRODUCTION TESTS..................................................................................................... 25

5.2           INCANDESCENT LIGHT UNIT PRODUCTION TESTS..................................................................... 25

5.3           ALTERNATIVE LIGHTING DEVICES (ALD)................................................................................. 25

5.4           DISCHARGE LIGHT UNIT PRODUCTION TEST............................................................................. 25

5.5           PRODUCTION OPERATIONAL TEST............................................................................................. 25

5.6           PRODUCTION PHOTOMETRIC TEST............................................................................................. 26

5.7           PRODUCTION TEST RECORDS..................................................................................................... 27

5.8           PRODUCTION TEST EQUIPMENT................................................................................................. 27

 

LIST OF TABLES

 Table 1.  L-856 Intensity Requirements...................................................................................................... 13. Table 2.  L-857 Intensity Requirements...................................................................................................... 13

Table 3.  L-865 Intensity Requirements...................................................................................................... 14

 

Table 4.  Flash Characteristics for Obstruction Lights ............................................................................... 15

 Table 5.  L-856/L-857 Production Photometric Requirements................................................................... 26

_{Table 6.  L-865/866/864<1  /885<1  Production Photometric Requirements.................................................26}

 Nancy B. Kalinowski

Director, System Operations Airspace and Aeronautical Information Management