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Phase 2, TASK 2: Prepare a Corps Regional General Permit Application The RGP has been identified by the Corps as the preferred permitting vehicle for recurring maintenance in the creek channels. Once approved, the RGP would allow the City to submit brief annual work plans for review and approval rather than going through the Corp's complete permit review process annually. Initial RGP application submittals include the preliminary jurisdictional delineations already underway. The application will include a quantified Project Description containing a list of anticipated maintenance activities, anticipated annual impact limits, avoidance and minimization measures, and a mitigation proposal. Additional submittals include typical work plans, projections of recurrence intervals for different maintenance activities, proposed timing and schedules. WRA will produce a draft RGP application for City review prior to submittal. Phase 2, TASK 3: RWQCB Section 401 Water Quality Certification for the RGP The San Francisco RWQCB must certify the use of the Corps RGP. WRA will process an application for 401 Water Quality Certification (WQC) for the RGP. For any wetlands or jurisdictional areas found not to fall under Corps jurisdiction, the RWQCB will likely claim these areas as "Waters of the State". WRA will prepare and submit a Section 401 Water Quality Certification application addressing waters of the State for submittal to the RWQCB. WRA will produce a draft WQC application for City review prior to submittal. Phase 2, TASK 4: ESA Section 7 Formal Consultation for the RGP A Section 7 Biological Assessment is anticipated to be required to enable the Corps to issue the RGP, as described in Task 2. This consultation would be required for Section 7 consultation with the U.S. Fish and Wildlife Survey (USFWS) and National Marine Fisheries Service (NMFS) under the ESA. The process requires the applicant provide a description of the Project (specifically any actions which may have an effect on federally-listed species), a description of the specific areas which may be affected, the manner in which impacts may occur, an analysis of cumulative impacts, and a description of the listed species or critical habitats that may be affected. This document is called a Section 7 Biological Assessment (BA). WRA will utilize available data from the BRA to the maximum extent possible, and may need to generate additional field survey data to compile all data necessary to prepare the BA report for submittal to the Corps. The BA will describe the suitability of onsite habitat conditions for the federal-listed species known to occur in the vicinity. The report will discuss any potential impacts (including direct, indirect, and cumulative impacts) which may occur to these species as a result of the Project, and any mitigation measures recommended to offset potential impacts. WRA will produce a draft BA application for City review prior to submittal. Phase 2. TASK 5: CDFW Streambed Alteration Agreement for Routine Maintenance CDFW requires any person who may affect the bed or bank of a perennial, intermittent, or ephemeral river, stream, or lake to provide notification via a California Fish and Game Code Section 1602 Streambed Alteration Agreement. The Streambed Alteration Agreement notification requires completion of an application form and project environmental questionnaire, and inclusion of supplemental data regarding issues covered in the project environmental questionnaire. WRA will prepare the application using the prior agreement information, the current standard forms and attachments. and provide additional supporting information, such as site plans, maps, and the BRA, needed to support application processing. WRA will prepare a draft LSAA for Client review and comment before submitting a final package upon Change Order City of Pleasanton Stream and Pond Maintenance—Project#29118—October 2019 3