SU0013876 - Laserfiche WebLink

Home Browse Search

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