Golf Course Wetland Mitigation Monitoring

The City of Palo Alto completed construction of the Palo Alto Municipal Golf Course Reconfiguration Project in 2017 following a flood protection project on San Francisquito Creek that impacted the golf course. The Golf Course, now the Baylands Golf Links, is located within the Palo Alto Baylands at 1875 Embarcadero Road in Palo Alto, California.

The reconfiguration project resulted in 0.29 acres of temporary and 1.36 acres of permanent impacts to wetlands/waters of the United States and State. The project’s permits (Attachment A) and Mitigation and Monitoring Plan (Attachment B) require at least 4.0 ac of on-site wetland expansion (i.e., wetland creation) and 0.20 ac of on-site wetland enhancement to compensate for the project’s impacts (ICF International 2016).

The plan to expand and enhance the project wetlands is provided in the project’s Mitigation and Monitoring Plan (MMP). The plan included 8.03 ac of wetland expansion and 0.42 of enhancement of existing wetlands at the golf course project site, exceeding the minimum permit required mitigation acreage by 100%. The RWQCB permit states (on Page 4) that, “Of the 8.03 acres of wetlands that the Applicant proposes to expand and the 0.42 acres that the Applicant proposes to enhance, 4 acres of expansion and 0.20 acres of enhancement are required to compensate for the Project’s impacts to waters of the State. Additional acres of expanded or enhanced wetlands may be used to provide for any additional mitigation required by Condition 33.”

The City implemented grading and planting to expand and enhance the wetland habitat in 2016 and 2017. Wetland expansion included excavating fill from elevated terrain surrounding existing wetlands, while wetland enhancement included invasive species removal. Both expanded and enhanced wetlands were then hydroseeded and planted with native brackish marsh plant species such as brown-headed rush ( Juncus phaeocephalus ), slough sedge ( Carex obnupta ), meadow barley ( Hordeum brachyantherum ), alkali barley (Hordeum depressum), and common spikeweed (Centromadia pungens). The project’s permits and MMP call for a minimum of 5 years of habitat monitoring of the expanded and enhanced wetlands. Since the wetland expansion/enhancement occurred in 2016 and 2017, mitigation monitoring was required in 2017 through 2021.

While the correct acreage of wetlands was constructed, the maintenance and monitoring necessary to attain performance standards was not completed. Per Condition 33 of the RWQCB permit, the amount of mitigation required increases by 10% for each year that successful implementation of mitigation was deferred.

The City has been in communication with the RWQCB and is working diligently to get the project into compliance. The following documents have been submitted to the RWQCB and are attached as reference to this RFP.

• Palo Alto Municipal Golf Course Reconfiguration Project Wetland Mitigation Condition Assessment Report (H.T. Harvey & Assoc., August 2024) (Attachment C)

• Palo Alto Municipal Golf Course Reconfiguration Project Wetland Delineation Report (H.T. Harvey & Assoc., June 2025) (Attachment D)

• Palo Alto Municipal Golf Course Reconfiguration Project Remedial Wetland Mitigation Plan (H.T. Harvey & Assoc., September 2025) (Attachment E)

Remedial Actions

Several remedial actions have been completed, or are planned, to increase the cover and diversity of native hydrophytic species and to increase the probability that success criteria will be met. These include:

• trail decommissioning through wetlands,

• removal of invasive plant species,

• hydrologic modifications to drains present in some wetlands, and

• revegetation to increase wetland species richness and native wetland cover, including:

• Seeding with native wetland seed,

• Revegetation with container plants (native plant species) in expanded and enhanced wetland areas.

The revegetation will occur over a two-year timeframe. In 2025, 0.3 acres will be revegetated – 0.2 acres with seed and 0.1 acres with container plants. In 2026, an additional 0.3 acres will be revegetated with either seed, container plants, or a combination depending on success of the revegetation effort in 2025.

Mitigation Monitoring Plan

This scope consists of CONSULTANT providing the CITY with professional services for the monitoring and reporting of wetland mitigation associated with the City of Palo Alto Golf Course Reconfiguration Project. The scope of services includes, but is not limited to, wetland mitigation monitoring and annual reporting for a period of five years, or until success criteria are met and the RWQCB has indicated in writing that the City’s mitigation obligations have been met. It is understood that all monitoring and reporting services shall be conducted in compliance with applicable environmental regulations and permit requirements, MMP and revisions to the MMP.

The monitoring methods are based on the project’s Mitigation and Monitoring Plan (MMP; ICF International 2016) and revised monitoring methodology approved for the project by RWQCB in 2024 and as described in Section 4-Monitoring and Adaptive Management of the Remedial Wetland Mitigation Plan.