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