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DocoSign Envalo0e ID:3FC9F66'I-BB'I D-4'I OF-BD90.AA23F'I B'19DFE Mr. Frank Girardi San Joaquin County Community Development Department February 22, 202'1 Pages 3 CLAPS Plant Ranks: t B = Rara, Threatened, or Endangered in California and Elsewhere; CLAPS Thr¢at Ranks: 0.1 =Seriously threatened in California (over 80%of occurrences threatened/high degree and immediacy of threat) General Comments Comment 1: Disclose Project impacts and avoidance, minimization, and mitigation measures In the ND, the Section IV Biological Resources Impact Discussion for items a-f, it is stated that the proposed multi-family apartment project will have no impact on Biological Resources. The ND does not include a Project description or discuss Project impacts on plants or wildlife. CDFW does not concur that the Project will have no impacts on biological resources because the ND does not address impacts, quantify impacts, or identify biological resources that could be impacted by the Project. Without a Project description with an impact discussion, it is not possible to know if Project impacts are less-than-significant and if an ND is appropriate for the Project. Also, the pra- construction survey conditions of the San Joaquin Multi Species Conservation and Open Space Plan (SJMSCP) are unknown; therefore, it is not known if an ND is adequate to prevent environmental impacts to ales-than-significant level. Because participation in the SJMSCP is voluntary, the ND must include: 1)An evaluation and discussion of potential direct and indirect impacts of the Project to biological resources including fish, wildlife, and their habitats, 2)feasible avoidance, minimization, and mitigation measures to reduce those impacts to ales-than-significant level, and 3) specific and sufficient compensatory for all impacts that cannot be fully avoided, including on-site habitat loss in the event the SJMSCP will not provide coverage of the Project in whole or part as a means to mitigate impacts to ales-than-significant level. If the impacts analysis indicates there will be direct or indirect take of California Endangered Species Act(CESA)-listed species, and if the Project cannot fully avoid take of CESA-listed species, and the SJMSCP does not offer take coverage, then CDFW recommends the ND include language defining the Project's obligation to obtain take coverage through an Incidental Take Permit (ITP) issued by CDFW. Comment 2: IS/ND does not mitigate biological impacts to a les-than-significant level Alternate mitigation needs to be specified in case the San Joaquin Council of Governments (SJCOG) does not approve the Project and/or the applicant chooses not to participate. The ND states: ':4//deve/opment approve/s/n Mountain House are required to comp/y with pre- consfruction survey conditions of approve/for discretionary projects and era subject to