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DocuS�gn Envelope ID:3FC9FBBl-6B'I D-4'IDF-BO90-AA23F'1619DFE <br /> Mr. Frank Girardi <br /> San Joaquin County Community development Department <br /> February 22, 202'1 <br /> Page 4 <br /> the San Joaquin Mu/ti Species Habitat Conservation and Open Space P/an to reduce <br /> any impacts to sensitive species to /ess than significant." <br /> This mitigation measure does not mitigate potential impacts to ales-than-significant <br /> level regarding CEQA, as the ND does not propose or identify specific and sufficient <br /> mitigation in the event the SJCOG does not approve coverage or the applicant chooses <br /> to not participate. The statement also does not negate the need for a biological impact <br /> analysis, which includes, but is not limited to, potential impacts to nesting birds, <br /> Swainson's hawk (Buten swainsoni, SWHA), burrowing owl (Athena cunicu/aria, <br /> BUOW), San Joaquin kit fox (Vu/pes macrotis mutica, SJ KF), and other special-status <br /> species. The Project has the potential to impact special-status species that utilize the <br /> Project area through direct take due to Project construction, indirect take due to Project <br /> operation, and temporary and permanent losses of agricultural land that can serve as <br /> marginal habitat. <br /> To ensure that Project impacts to spacial-status species are mitigated to a less-tM1an- <br /> significant level, and in the event SJCOG does not offer full coverage, C�FW <br /> recommends the ND be revised to require compensatory mitigation for impacts to their <br /> habitat. Compensatory mitigation should be in the form of permanently conserved lands <br /> at the following ratios: 3:1 ratio (conserved land to impacted habitat)for permanent <br /> impacts; 5:1 for construction of new roadways, and 1:1 for temporary impacts (i.e., <br /> impact to baseline recovery in under one year). Conservation lands should be placed <br /> under a conservation easement with C�FW listed as a third-party beneficiary and an <br /> endowment should be funded for managing the lands for the benefit of the conserved <br /> species in perpetuity. Additionally, along-term management plan should ba prepared <br /> and im plemanted by a land manager. The Grantee of the conservation easement <br /> should be an entity that has gone through the due diligence process for approval by <br /> COFW to hold or manage conservation lands- <br /> Comment 3: Project phasing <br /> The ND does not include a description of timeframe during which construction will <br /> occur. Project activities may have additional significant biological impacts due to Project <br /> phasing over time. Phasing and the additional impacts from phasing are not discussed, <br /> analyzed, or mitigated for in the ND. Projects that include multiple phases with different <br /> sections or parcels built out at different time periods or phasing that includes whole-site <br /> grading with separate sections or parcels developed at later dates have impacts over a <br /> period longer than one year. This delay in full build out of a Project allows wildlife to <br /> utilize resources that develop post-grading on vacant sections or parcels. These <br /> resources include, but are not limited to; ruderal grassland and brush that provide <br /> nesting habitat for passerine birds and burrowing owls; infrastructure installed but not <br /> utilized that provide burrowing habitat for ground squirrels and burrowing owls; <br /> additional indirect impacts to nesting and foraging raptors with roost and nest trees <br />