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DocuSlgn Emebpe ID:3FCBFB6'I-061D4'I OF-BD90-AA23F�619DFE Mr. Frank Girardi San Joaquin County Community development Department February 22, 202'1 Page 6 vineyard agriculture has also contributed to the species' decline. Therefore, loss of burrowing owl habitat can be considered a significant impact that warrants mitigation to lass-than-significant through the ND. C�FW recommends the ND be revised and recirculated to include an impacts analysis that provides an evaluation and discussion of potential impacts of the Project to burrowing owls and their habitats. If impacts are identi£ed, C�FW recommends the ND be r®wised to include adherence to the mitigation strategies defined in tFM1e C�FW Staff Report on Burrowing Ow/Mitigation (20'1 2) in addition to adherence to the survey protocol or require participation in the SJMSCP. If the NO does not include a measure that requires participation in the SJMSCP, C�FW recommends the ND be updated to include a measure requiring compensatory mitigation for impacts to burrowing owl foraging habitat at a minimum of a 3:1 mitigation ratio (conserved habitat to impacted habitat)for permanent impacts and a >:� ratio for temporary impacts. Comment 5: Burrowing owl surveys and avoidance measures should ba incorporated in the NU If the SJMSCP does not cover the Project, then C�FW recommends the following specific and enforceable measures for burrowing owls be incorporated into a revised and recirculated ND to avoid impacts: "Pre-construction Surveys for Burro wino Ow/. To avoid impacts to burrowing ow/s, a qua/ified bio/ogist she//conduct a habitat assessment to determine if burrowing ow/ habitat Is present and if occupancy surveys are required. The fo//owing criteria for surveys she//be met: Surveys she//be conducted during the breeding season from February > to August 3>. A minimum of three (3) surveys she//be conducted and each survey she//occur at/east three (3) weeKs apart during the peaK of breedJng season (between Apri/ >5 and✓u/y >5), during the nesting period, and during the/ate Hast/ing period. e Each survey she//ba conducted during crepuscu/ar hours. /f surveys confirm occupied burrowing ow/habitat in or adjoining the Project area, the qua/iti®d bio/ogist she//comp/ete an impact assessment for burrowing ow/_ The impact assessment she//eve/uate a//factors that cou/d affect burrowing ow/s on the Project sits and inc/ude mitigation measures, if appropriate. Examp/as inc/ude, but are not/imitad fo, avoidance of occupied burrows during the nesting period of February > to August 3>, avoidance of occupied burrows during non-breeding season, pre-construction surveys, site survei//ants, use of buffer zones or visna/screens, and burrow ext/usion.