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i r s Ms.Alisa Goulart San Joaquin County Community Development Department February 11,2020 Page 5 In addition,the measure should be revised to require conservation and management in perpetuity through recordation of conservation easements on lands where mitigation occurs to ensure impacts to special-status plant species are mitigated to a level of less-than-significant, Conservation lands should be placed under a Conservation Easement,an endowment should be funded for managing the lands for the benefit of the conserved species in perpetuity,and a long-term management plan should be prepared and Implemented by a land manager.The Grantee of the Conservation Easement should be an entity that has gone through the due diligence process for approval by CDFW to hold or manage conservation lands. Comment 4:Section IV.Biological Resources does not define floristic survey protocol Section IV of the IS/MND does not Include defined survey protocols for floristic surveys or r' require a qualified botanist to conduct the surveys. j To correct this,CDFW recommends Section IV.Biological Resources be revised to include adherence to CDFW's Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Natural Communities(2018),including the reporting requirements contained in those protocols,and to indicate a qualified botanist shall conduct the surveys according to the protocols.See https://wildlife.ca,gov/conservation/survey- pro tocols#377281280-plants. Comment 5:Revision needed to mitigate impacts to San Joaquin kit fox to a level of less- than-significant The IS/MND does not mitigate potential impacts to San Joaquin kit fox(Vulpes rnacrotis mutica) to a level of less-than-significant because the IS/MND lacks an evaluation of impacts to San Joaquin kit fox and does not include either a mitigation measure that requires full avoidance of lake of San Joaquin kit fox or their habitats.The IS/MND does not define avoidance measures In the event San Joaquin kit fox are discovered or reduce impacts from permanent loss of open space and movement corridors and foraging habitats or indirect Impacts to foraging and denning Impacts from Increased construction activity to a level of less-than-significant as It does not offset those impacts with compensatory mitigation requirements.San Joaquin kit fox are designated as a State of California Endangered Species.The loss of valley and foothill grasslands due to conversion to agriculture and urbanization is the primary threat to San Joaquin kit fox populations throughout California.The U.S.Fish and Wildlife Service's Recovery Plan for Upland Species of the San Joaquin Valley, California(1998)states connectivity between the sub-populations of the kit fox are essential for recovery of the species.The Project's potential impacts to connectivity and permanent loss of habitat requires an impacts evaluation in a revised and recirculated IS/MND.Given the severe population declines of the species and magnitude of historic habitat loss,any impacts identified can be considered as significant and even more so when evaluated in a cumulative manner. To correct this,CDFW recommends the IS/MND be revised and recirculated to include an impacts analysis that provides an evaluation and discussion of potential impacts of the Project to San Joaquin kit fox and their habitats.If the impacts analysis indicates there will be direct or indirect take and the Project cannot fully avoid impacts to and take of San Joaquin kit fox,