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Mr. Frank Girardi San Joaquin County Community Development Department September 24, 2019 Page 6 of 7 conducted in all suitable habitat located at the project work site, in staging, storage, and stockpile areas, and along transportation routes. Surveys shall be conducted within %-mile of the project area. if any active Swainson's hawk nests are found within %-mile of the project site, CDFW shall immediately be contacted and additional survey measures may be required for project activities. Comment 6: revisions 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 macrotis mutica) to 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 take of San Joaquin kit fox or their habitat. 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, CDFW recommends the IS/MND be revised to include a measure requiring participation in the SJMSCP, or in the event SJMSCP does not cover the Project or the Proponent elects to not participate in the Plan, then CDFW recommends the IS/MND include language defining the Project's obligation to obtain take coverage through an ITP issued by CDFW. ENVIRONMENTAL DATA CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database, which may be used to make subsequent or supplemental environmental determinations [Pub. Resources Code, § 21003, subd. (e)]. Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be found at the following link: https•//www.wildlife.ca.gov/Data/CNDDB/Submitting- Data#44524420-pdf-field-survey-form. The completed form can be mailed electronically to CNDDB at the following email address: cnddb(a-),wildlife.ca.gov. The types of information reported to CNDDB can be found at the following link: https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.