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Ms.Alisa Goulart San Joaquin County Community Development Department February 11,2020 I Page 4 do not mitigate to less-than-significant or in the event the SJMSCP does not approve coverage of the Project in whole or part to mitigate to less-than-significant. To correct tills,please update the IS/MND to Include an impacts analysis that provides an evaluation and discussion of potential quantified impacts of the Project to biological resources Including fish,wildlife,and their habitats.Based on this Impact analysis,please update the section to Include mitigation measures that will ensure Project impacts are less-than-significant in the event SJMSCP does not approve of coverage of the Project in whole or part,or in the event the Proponent opts-out of participation in the SJMSCP. ! If the impacts analysis indicates there will be direct or indirect take of CESA-listed species,and the Project cannot fully avoid take of CESA-listed species and SJMSCP does not offer take coverage,then CDFW recommends the ISIMND include language defining the Project's obligation to obtain take coverage through an Incidental Take Permit(ITP)Issued by CDFW. Comment 3:Revision needed to mitigate impacts to special-status plants to less-than- significant The IS/MND identifies caper-fruited tropidocarpum(Tropidocarpum capparideum)as a special- status plant with the potential to occur on the Project site,but does not define avoidance measures in the event they or other special-status plants are discovered or reduce impacts to a level of less-than-significant by identifying compensatory mitigation in the event impacts to special-status plants cannot be fully avoided.CDFW recommends the IS/MND adhere to the definitions in SJMSCP by defining the Project's habitat types using the same terms used by the SJMSCP in section 2.2 of the Plan,and inclusion of a habitat map of the Project as an exhibit within a revised IS/MND.CDFW also recommends the addition of a mitigation measure in the revised IS/MND with the following language: "Special-Status Plant Assessment and Avoidance: A Qualified Botanist shall conduct a minimum of two(2)surveys for each special-status plant species with potential to occur within the Project Site prior to initiation of Project Activities during the appropriate blooming period in accordance with CDFW's Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Natural Communities (trttos://www,wildlife.ca.aov/conservation/survey-Protocols).Report of survey findings shall be done In accordance to the guidance In these protocols and submitted to CDFW prior to Project construction." E CDFW also recommends the measure state the following: I "A Qualified Botanist shall develop and implement a restorationlremedlation and mitigation plan according to CDFW guidelines and in coordination with CDFW.At a minimum,the plan shall Include collection of reproductive structures from affected plants,a full description of microhabitat conditions necessary for each affected species,seed germination requirements,restoration techniques for-temporarily disturbed occurrences,assessments of potential transplant end enhancement sites,success and performance criteria,and monitoring programs,as well as measures to ensure long-term sustainability." i I