University of San Diego
OP-10: Biodiversity

The areas along the border of campus are protected lands. Per the USD Campus Master Plan (2016), several of the habitats present on the campus are regarded as sensitive under City Biology Guidelines, Environmentally Sensitive Lands (ESL) Regulations, and the City’s Multiple Species Conservation Program (MSCP). Habitats acknowledged as such include Diegan coastal sage scrub, Baccharis scrub (a type of coastal sage scrub), southern mixed chaparral, non-native grassland, southern willow scrub, and Arundo-dominated riparian (a type of disturbed wetland).

Several species of sensitive plants and animals are observed on campus, including the Coastal California Gnatcatcher (Polioptila californica), Belding’s Orange-throated Whiptail (Cnemidorphorus hyperythrus beldingi), Coast Barrel Cactus (Ferocactus viridescens), and Spineshrub (Adolphia californica). Wetland habitats represent, by far, the greatest constraint within the campus study area, especially given the City’s requirements that impacts to wetlands be avoided. The Multi-Habitat Planning Area (MHPA) ordinance also represents a significant constraint to future development of the on-campus environment. More detailed information is available as part of the USD Master Plan Update: http://catcher.sandiego.edu/items/usd/USD-MasterPlan-120816.pdf (especially pages 13 and 14).

The following plants and bird species have been marked as protected in the USD Master Plan Update:

Coastal California Gnatcatcher (Polioptila californica californica)
Belding's Orange-throated Whiptail (Aspidoscelis hyperythra beldingi)
California Adolphia (Adolphia californica)
San Diego Barrel Cactus (Ferocactus viridescens)

The areas along the border of campus are protected lands, including the Tecolote Canyon Natural Park immediately to the north. These lands are governed by a Master Plan, a Natural Resources Management Plan, and the Tecolote Canyon Rim Development Guidelines, all of which impact how USD may develop its campus lands.

Several of the habitats present on campus are regarded as sensitive under City Biology Guidelines, Environmentally Sensitive Lands (ESL) Regulations, and the City’s Multiple Species Conservation Program (MSCP). Thirteen vegetation communities and one land cover type (developed) encompassing a total of approximately 180 acres are present within the Master Plan Update area. Of the 180 acres, 7.6 acres fall within the Multihabitat Planning Area (MHPA), which is the City’s Multiple Species Conservation Plan (MSCP)Preserve. Habitats on campus lands acknowledged as such include Diegan coastal sage scrub, Baccharis scrub (a type of coastal sage scrub), southern mixed chaparral, non-native grassland, southern willow scrub, and Arundo-dominated riparian (a type of disturbed wetland).

A number of biological surveys and related investigations, including the Biological Technical Report for the USD Master Plan Update and Conditional Use Permit (CUP) Amendment, were conducted on the site and presented as part of the Environmental Impact Review report in 2017. Please see: http://catcher.sandiego.edu/items/usd/SEIR_01-06-17.pdf

The surveys included vegetation communities/land cover types; jurisdictional areas (Waters of the US, Waters of the State of CA, and City of San Diego Wetlands); sensitive plant species surveys, including searches for species noted in a 1993-94 survey; sensitive wildlife species surveys; and wildlife corridor surveys.

The City of San Diego environmental regulations that apply to the USD campus include designations under the Multi-Habitat Planning Area (MHPA) and the Environmentally Sensitive Lands (ESL) ordinance which protect sensitive biology, floodplains, and steep slopes. The MHPA is the city’s planned habitat preserve within the Multiple Species Conservation Program. Land use adjacency guidelines limit development within and adjacent to the MHPA. The City defines environmentally sensitive lands (ESA) to the north and south of campus. USD will adhere to all City, County, State and Federal requirements as they pertain to potential impacts to these lands and/or sensitive species that are found on or near campus. Further, as part of the SEIR, governing the Master Plan Update, USD must adhere to the following Mitigation, Monitoring and Reporting to reduce the Master Plan Update’s direct and indirect impacts to sensitive vegetation communities and sensitive wildlife species to below a level of significance.

General Mitigation
Bio–1 Biological Resource Protection

I. Prior to Construction
A. Biologist Verification: The owner/permittee shall provide a letter to the City’s MMC section stating that a Project Biologist (Qualified Biologist), as defined in the City’s Biology Guidelines (2012), has been retained to implement the biological monitoring program in this mitigation measure. The letter shall include the names and contact information of all persons involved in the biological monitoring of the Master Plan Update area.
B. Pre-construction Meeting: The Qualified Biologist shall attend a pre-construction meeting, discuss the Master Plan Update’s biological monitoring program, and arrange to perform any follow up mitigation measures and reporting including site-specific monitoring, restoration or revegetation, and additional fauna/flora surveys/salvage.
C. Biological Documents: The Qualified Biologist shall submit all required documentation to MMC verifying that any special mitigation reports including but not limited to, maps, plans, surveys, survey timelines, or buffers are completed or scheduled per City Biology Guidelines, MSCP, ESL Ordinance, project permit conditions; CEQA; endangered species acts; and/or other local, State or federal requirements.
D. Biological Construction Mitigation/Monitoring Exhibit: The Qualified Biologist shall present a Biological Construction Mitigation/Monitoring Exhibit which includes the Biological Documents listed above. In addition, include as applicable: restoration/revegetation plans, plant salvage/relocation requirements (e.g., coastal cactus wren plant salvage, burrowing owl exclusions, etc.), avian or other wildlife surveys/survey schedules (including general avian nesting and USFWS protocol), timing of surveys, wetland buffers, avian construction avoidance areas/noise buffers/barriers, other impact avoidance areas, and any subsequent requirements determined by the Qualified Biologist and the City ADD/MMC. The Biological Construction Mitigation/ Monitoring Exhibit shall include a site plan, written and graphic depiction of the Master Plan Update’s biological mitigation/monitoring program, and a schedule. The Biological Construction
Mitigation/Monitoring Exhibit shall be approved by MMC and referenced in the construction documents.
E. Resource Delineation: Prior to construction activities, the Qualified Biologist shall supervise the placement of silt and orange construction fencing or equivalent along the limits of disturbance (for Project Site Nos. 17, 19, 20, 22, 23, and 27) and verify compliance with any other conditions as shown on the Biological Construction Mitigation/Monitoring Exhibit. This phase shall include flagging plant specimens and delimiting buffers to protect sensitive biological resources (e.g., habitats/flora and fauna species, including nesting birds) during construction. Appropriate steps/care should be
taken to minimize attraction of nest predators to a site.
F. Education: Prior to commencement of construction activities, the Qualified Biologist shall meet with the owner/permittee or designee and the construction crew and conduct an on-site educational session regarding the need to avoid impacts outside of the approved construction area and to protect sensitive flora and fauna (e.g., explain avian and wetland buffers, flag system for removal of invasive species or retention of sensitive plants, and clarify acceptable access routes/methods and staging areas, etc.).

II. During Construction
A. Monitoring: All construction (including access/staging areas) shall be restricted to areas previously identified, proposed for development/staging, or previously disturbed as shown on “Exhibit A” and/or the Biological Construction Mitigation/Monitoring Exhibit. The Qualified Biologist shall monitor construction activities as needed to ensure that construction activities do not encroach into biologically sensitive areas, or cause other similar damage, and that the work plan has been amended to accommodate any sensitive species located during the pre-construction surveys. In addition, the Qualified
Biologist shall document field activity via the Consultant Site Visit Record. The Consultant Site Visit Record shall be e-mailed to MMC on the first day of monitoring, the first week of each month, the last day of monitoring, and immediately in the case of any undocumented condition or discovery.
B. Subsequent Resource Identification: The Qualified Biologist shall note/act to prevent any new disturbances to habitat, flora, and/or fauna on site (e.g., flag plant specimens for avoidance during access, etc.). If active nests or other previously unknown sensitive resources are detected, all project activities that directly impact the resource shall be delayed until species specific local, State or federal regulations have been determined and applied by the Qualified Biologist.

III. Post Construction
A. In the event that impacts exceed previously allowed amounts, additional impacts shall be mitigated in accordance with City Biology Guidelines, ESL and MSCP, State CEQA, and other applicable local, State and federal law. The Qualified Biologist shall submit a final Biological Construction Mitigation/ Monitoring Exhibit/report to the satisfaction of the City ADD/MMC within 30 days of construction completion.

Sensitive Vegetation Communities:
Bio–2 Sensitive Vegetation Communities
Impacts to 0.5 acre of Diegan coastal sage scrub shall be mitigated at a ratio of 1:1 pursuant to Table 3, Upland Mitigation Ratios, in the City’s Biology Guidelines (City 2012) for impacts outside the MHPA and mitigation inside the MHPA. Mitigation shall be accomplished via payment in to the City’s
Habitat Acquisition Fund equal to 0.5 acre of habitat.

Sensitive Wildlife Species—Cooper’s Hawk:
Implementation of Mitigation Measure Bio-3 would satisfy the City’s requirement to avoid construction activity within 300 feet of an active Cooper’s hawk nest in the MHPA.
Bio–3 Nesting Cooper’s Hawks
To avoid impacts to Cooper’s hawk, removal of habitat that supports active nests in the proposed area of disturbance should occur outside of the breeding season for this species (February 1 to September 15). If removal of habitat within 300 feet of the MHPA (Projects 20, 21, 24, 27, and 28) must occur during
the breeding season (February 1 to September 15), the Qualified Biologist shall conduct a pre-construction survey to determine the presence or absence of nesting Cooper’s hawk within the proposed area of disturbance. The pre-construction (precon) survey shall be conducted within 10 calendar days prior to the start of construction activities (including removal of vegetation). The applicant shall submit the results of the precon survey to City DSD for review and approval prior to initiating any construction activities. If nesting Cooper’s hawk are detected, a letter report or mitigation plan in conformance with the
City’s Biology Guidelines and applicable State and Federal Law (i.e., appropriate follow up surveys, monitoring schedules, construction and noise barriers/ buffers, etc.) shall be prepared and include proposed measures to be implemented to ensure that take of birds or eggs or disturbance of breeding activities is avoided. The report or mitigation plan will include the establishment of a 300-foot construction avoidance area that shall be maintained around any active Cooper’s hawk nest located inside the MHPA until the nest is no longer active as determined by the Qualified Biologist. The report or plan shall be submitted to the City DSD for review and approval and implemented to the satisfaction of the City. The City’s MMC Section and Biologist shall verify and approve that all measures identified in the report or mitigation plan are in place prior to and/or during construction. If nesting Cooper’s hawk are not detected during the precon survey, no furthermitigation is required.

Supplemental Environmental Impact Review: http://catcher.sandiego.edu/items/usd/SEIR_01-06-17.pdf