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J MHMP. The drainage would also not be adversely affected by urban runoff from the project site because the College Park drainage plan includes features to ensure that urban runoff flows away from the drainage and/or is collected before entering the drainage. Potential direct loss of special-status plans would therefore be restricted to the irrigation canals and ponds that would be filled under the proposed project. Potentially suitable habitat exists within the irrigation canals in small isolated areas where vegetation has become established. Neither the MHMP nor the MHMP MMP identify measures to mitigate for potential impacts to the special-status plant species that could inhabit the College Park site. Measures are only presented for plants that could grow in the Mountain House Creek corridor,which is outside the College Park site. Therefore,a significant impact could occur. Mitigation Measure 4.10-2: Biological Resources—Conversion of Habitat for Special-Status Plants The College Park developers shall request coverage under the SJMSCP,and the project applicants shall pay the SJMSCP impact fees determined by SJCOG during the application and review process for each project under — College Park. Suitable habitat for special-status plants that would be affected by implementation of College Park is currently _ limited to the irrigation canals and ponds. Before implementation of each Tentative Map(or of individual development projects if no Tentative Map),pre-construction surveys for special-status plants shall be conducted by a qualified botanist in areas identified as suitable habitat by SJCOG at the appropriate time of year when the target species would be in flower or otherwise clearly identifiable. Surveys shall be conducted in accordance with specific methodologies described in Section 5.2.2.5 of the SJMSCP. If special-status plants are found,the following measures shall be implemented, depending on the species found: — Sanford's arrowhead,Delta button-celery,and slouch thistle.The SJMSCP requires complete avoidance for these species; therefore,potential impacts on these species could not be covered through participation in the plan. If these species are present in the project area and cannot be avoided, a separate consultation with the appropriate regulatory agencies(likely DFG)would be required. This consultation shall determine appropriate mitigation measures for any populations affected by the project, such as creation of off-site — populations through seed collection or transplanting,preserving and enhancing existing populations, or restoring or creating suitable habitat in sufficient quantities to compensate for the impact. All mitigation measures determined necessary during this consultation shall be implemented by the project proponents. — Mason's lilaeopsis,rose mallow,Delta tule yea,and Delta mudwort. These species are considered widely distributed species by the SJMSCP, and dedication of conservation easements is the preferred option for mitigation. If these species are found in the project area,the possibility of establishing a conservation — easement or in-lieu land dedication shall be evaluated. If neither establishment of a conservation easement nor in-lieu land dedication is feasible,no mitigation(in addition to payment of SJMSCP fees)shall be required. Bristly sedee and blue skullcap. These species are considered narrowly distributed by the SJMSCP,and dedication of conservation easements is the preferred option for mitigation. If these species are found in the _ project area,the possibility of establishing a conservation easement shall be evaluated. If dedication of a conservation easement is not a feasible option,the SJMSCP requires a consultation with the permitting agency representatives on the Technical Advisory Committee to determine the appropriate mitigation _ measures. These may include seed collection or other measures and would be determined on a population basis,taking into account the species type,relative health, and abundance. After the appropriate mitigation has been determined,it shall be implemented by the project proponents. Implementation of the above mitigation measure would reduce habitat conversion impacts on special-status plants to a less-than-significant level. EDAW College Park at Mountain House Specilic Plan III Draft EIR — Biological Resources 4.10-34 San Joaquin County