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Ms.Alisa Goulart j San Joaquin County Community Development Department February 11,2020 Page 3 ruderal grassland and brush that provide nesting habitat for passerine birds and burrowing owls; Infrastructure installed but not utilized that provide burrowing habitat for ground squirrels, burrowing owls,and short-eared owls;additional indirect impacts to nesting and foraging raptors with roost and nest trees adjacent to the Project site;and pooling of rainwater on parcels that provide temporary habitat for amphibians.CDFW is unable to analyze these impacts without inclusion of a description of the project's timing and implementation in relation to site preparation,Infrastructure installation,and complete buildout. To correct this,please revise and recirculate the IS/MND with a description of the Project's phasing and estimated timeframes from start of construction to complete buildout.If the Project's timeframe from start of construction to complete build out Includes breaks in construction longer than 15 days or periods of Inactivity that could allow establishment of habitat elements such as burrows and vegetation,then Impacts to wildlife utilizing vacant sections or parcels of the Project not built out must be Included in the impacts analysis to ensure the Project mitigates impacts to a level of less-than-significant.To ensure the Project is mitigating to a level of less-than-significant,CDFW recommends revising the IS/MND to include a mitigation measure for each phase of the Project that meets the following criteria:1)a qualified biologist shall conduct a habitat assessment survey to determine what potential wildlife and habitat elements are present that may be utilizing the vacant sections and/or parcels prior to Project- related activities taking place when there is a break in these activities greater than 15-days;2)if unbuilt or fallow sections and/or parcels are being utilized by special-status species or communities then avoidance and minimization measures(including the measures discussed in this letter)shall be used to prevent impacts and take,and 3)if impacts and take are not fully avoidable then additional compensatory mitigation shall be required In the form of permanent habitat preservation protected by a Conservation Easement with an endowment for managing the lands for the benefit of the conserved species in perpetuity,and a long-term management i plan should be prepared and Implemented by a land manager.The Grantee of the Conservation j Easement should be an entity that has gone through the due diligence process for approval by € CDFW to hold or manage conservation lands. Comment 2:Revision needed to mitigate to a level of less-than-significant in the event the San Joaquin Multi-Species Conservation Plan(SJMSCP or Plan)does not approve coverage The statement presented in the Impact Discussion in Section IV.Biological Resources of the IS/MND does not mitigate potential impacts to a level of less-than-significant.The IS/MND states that the San Joaquin Council of Governments(SJCOG)responded to the Project referral saying that the Project is subject to the Plan and that the Proponent has confirmed participation in the Plan;however,this information is not stated as an enforceable mitigation measure within the section.The IS/MND also does not propose or Identify specific,sufficient,and enforceable mitigation in the event the SJMSCP does not approve coverage or the Proponent chooses to not participate based on this lack of an enforceable measure.Because participation in the Plan Is voluntary,the IS/MND must include 1)an evaluation and discussion of potential direct and Indirect impacts of the Project to biological resources Including fish,wildlife,and their habitats, 2)avoidance and minimization mitigation measures to decrease those Impacts,and 3)specific and sufficient compensatory mitigation In the event the avoidance and minimization measures