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D^cu518^Envelope ID:3FCBFBBt-BBt D-4iDF-BOB0.AA23FBtBOFE Mr. Frank Girardi San Joaquin County Community Development Department February 22, 2021 Page 5 adjacent to the Project site and access routes; and pooling of rainwater on parcels that provide temporary habitat for amphibians. CDFW is unable to analyze these impacts without inclusion of a description of the Project's timing and implementation in relation to site preparation, infrastructure installation, and complete buildout. CDFW retrommends revising and recirculating the ND with a description of the Project's phasing and estimated timeframes from start of construction to complete buildout. If the Project's timeframe from start of construction to complete build out includes breaks in construction longer than 15 days or periods of inactivity that could allow establishment of habitat elements such as burrows and vegetation, then impacts to wildlife utilizing vacant sections or parcels of the Project not built out must be included in the impacts analysis to ensure the Project mitigates impacts to aless-than-significant level. When and if such a delay occurs, and to ensure the Project is mitigating to less-than- significant, CDFW recommends revising the ND to include a mitigation measure that meets the following criteria: 1)a qualified biologist shall conduct a habitat assessment survey to determine what potential wildlife and habitat elements are present that may be utiliving the vacant sections and/or parcels prior to Project-related activities taking place when there is a break in these activities greater than 15-days; 2) if unbuilt or fallow sections and/or parcels are being utilized, avoidance and minimization measures (including the measures discussed in this letter) shall be used to prevent impacts and take, and if impacts and take are not fully avoidable, additional compensatory mitigation shall be discussed and agreed upon with CDFW's approval prior to the re-initiation of construction activities. Biological Comments Comment 4: Revisions n®adad to identify and mitigate impacts to burrowing owls to aless-than-significant level The ND does not mitigate potential impacts to burrowing owls(Athene cunicu/aria)to less-than-significant because the ND lacks an evaluation of impacts to burrowing owls and does not include mitigation measures requiring t) pre-construction surveys conducted according to CDFW'S Staff Report on Burrowing Ow/Mitigation(20'12) and 2) avoidance measures determined by CDFW if and when burrowing owls are discovered at the Project site. The ND does not define avoidance measures in the event burrowing owls are discovered or reduce impacts from permanent loss of burrowing owl nesting or foraging habitats to aless-than-significant level as it does not offset those impacts with a compensatory mitigation requirement. Burrowing owls era designated as a California SSC, a designation used to describe at-risk taxa within the state that warrant proactive conservation to ensure the populations' persistence. As an SSC, the Project's potential impacts are compounded with ongoing impacts to the populations within the San Joaquin Valley through the loss of arid scrub and upland habitats. In addition, the urbanization and conversion of row-crop agriculture to orchard and