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8. Special-Status Plants: Before ground disturbance, 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 slough 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 pea,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 sedge 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. [Mitigation Measure 4.10-21 9. Conversion of Burrowing Owl Habitat: If SJCOG determines suitable habitat is present on or adjacent to a given project site, the following SJMSCP incidental take avoidance and minimization measures shall be implemented: Burrowing owls shall be discouraged from entering or occupying construction areas by employing one of several methods outlined in Section 5.2.4.15 of the SJMSCP. These include retention of tall vegetation, regular discing of the site, or use of chemicals or traps to kill ground squirrels. Pre-construction surveys for burrowing owls shall be conducted where project construction activities would occur within 75 meters of suitable habitat(based on SJCOG review). The survey shall be conducted within 2 weeks of the beginning of construction. If burrowing owls are found, the following measures shall be implemented: a. During the nonbreeding season (September 1 through January 31), burrowing owls occupying the project site shall be evicted from the project site by passive relocation, as described in the DFG's Staff Report on Burrowing Owls(DFG 1995). b. During the breeding season (February 1 through August 31), occupied burrows shall not be disturbed and shall be provided with a 250-foot protective buffer until and unless the 35