San Clemente Brush Clearance Site #1

2025010793

City of San Clemente

NOE - Notice of Exemption

1/24/2025

1/24/2025

Amir K. Ilkhanipour, P.E.

City of San Clemente

Principal Civil Engineer

Lead/Public Agency / Project Applicant

100 N. Calle Seville
San Clemente, CA 92673

(949) 361-6140

IlkhanipourA@san-clemente.org

678- 163-010

County of Orange

The San Clemente Brush Clearance Project (proposed project) spans approximately 33.7 acres and is located within the City of San Clemente in Orange County, California (APN 678-163-01). The project site is an undeveloped field situated north of Via Sonrisa, directly across from residential homes, and south of the San Clemente Aquatics Center and an adjacent soccer hub. This area has been identified for goat brush clearance to address vegetation management and reduce potential fire hazards in proximity to nearby facilities and residences. See Figure 1 through Figure 3, which depict the project site on both regional and local scales, and Figure 4, which includes photographs of the project site.

Categorical Exemption

Section 15301, Section 15304

CEQA Guidelines § 15301 sets forth the following conditions projects must meet to qualify for a Class 1 (Existing Facilities) categorical exemption: Class 1 consists of the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use. The key consideration is whether the project involves negligible or no expansion of use. An example of this exemption includes, but is not limited to: (h) Maintenance of existing landscaping, native growth, and water supply reservoirs (excluding the use of pesticides, as defined in Section 12753, Division 7, Chapter 2, Food and Agricultural Code) This project qualifies for a Class 1 (Existing Facilities) categorical exemption under CEQA as it involves minor alterations to existing topographical features for the purpose of maintaining the site’s ecological balance and reducing wildfire risk. The goat vegetation management project will not result in any expansion of use, as the grazing activities are planned as a short-term, temporary measure. Specifically, the project aligns with subsection (h) as it focuses on the maintenance of existing landscaping and native growth by targeting invasive plant species while preserving sensitive native vegetation. The use of goats as a natural, non-mechanical method ensures negligible environmental impact while supporting ecosystem health and wildfire mitigation efforts. CEQA Guidelines § 15304 sets forth the following conditions projects must meet to qualify for a Class 4 (Minor Alterations to Land) categorical exemption: Class 4 consists of minor public or private alterations in the condition of land, water, and/or vegetation which do not involve removal of healthy, mature, scenic trees except for forestry or agricultural purposes. Examples include, but are not limited to: (b) New gardening or landscaping, including the replacement of existing conventional landscaping with water efficient or fire-resistant landscaping. (i) Fuel management activities within 30 feet of structures to reduce the volume of flammable vegetation, provided that the activities will not result in the taking of endangered, rare, or threatened plant or animal species or significant erosion and sedimentation of surface waters. This exemption shall apply to fuel management activities within 100 feet of a structure if the public agency having fire protection responsibility for the area has determined that 100 feet of fuel clearance is required due to extra hazardous fire conditions. The goat vegetation management project qualifies for a Class 4 (Minor Alterations to Land) categorical exemption as it involves minor alterations to the condition of land and vegetation without the removal of healthy, mature, or scenic trees. The project aligns with subsection (b) by replacing overgrown and invasive vegetation with a more sustainable, fire-resistant landscape through targeted grazing. It also meets the criteria of subsection (i) by implementing fuel management activities to reduce the volume of flammable vegetation within 30 feet of structures, thereby decreasing wildfire risk and creating defensible space. These activities will be carefully managed to avoid significant erosion, sedimentation, or harm to endangered, rare, or threatened species, ensuring that the project remains environmentally sensitive while effectively mitigating wildfire hazards.

Emergency Project

Sec. 21080(b)(4); 15269(b)(c)

CEQA Guidelines § 15359 sets forth the following conditions projects must meet to qualify for a Class 59 (Emergency) categorical exemption: “Emergency” means a sudden, unexpected occurrence, involving a clear and imminent danger, demanding immediate action to prevent or mitigate loss of, or damage to life, health, property, or essential public services. Emergency includes such occurrences as fire, flood, earthquake, or other soil or geologic movements, as well as such occurrences as riot, accident, or sabotage. The goat vegetation management project qualifies for a Class 59 (Emergency) categorical exemption because it addresses a sudden and imminent wildfire risk that poses a clear and immediate danger to life, health, property, and essential public services. Given the ongoing wildfire activity in Southern California as of January 2025, the project aims to mitigate the threat by rapidly reducing flammable vegetation, creating defensible space around structures, and preventing the spread of fires to nearby homes and communities. The immediate action taken through this vegetation management aligns with the emergency definition, which addresses occurrences like wildfire that demand urgent intervention to protect lives, health, and infrastructure. CONCLUSION Class 1 (Existing Facilities), Class 4 (Minor Alterations to Land), and Class 59 (Emergency) categorical exemptions both apply to the proposed project.