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DowSlgn EnvaloOa ID:3FC9Fa6t-BBtD1tDF-BD90-AA23Ft6t9DFE Mr. Frank Girardi San Joaquin County Community development apartment February 22, 202'1 Page 8 foraging habitat at a minimum of a 3:1 mitigation ratio (conserved habitat to impacted habitat)for permanent impacts and a 1:> ratio for tam porary impacts, as well as language defining the Project's obligation to obtain take coverage through an ITP issued by C�FW. In the event SJMSCP does not cover the Project or the Proponent elects to not participate in the SJMSCP, C�FW recommends the following specific and enforceable measures for Swainson's hawk be incorporated into a revised and recirculated ND to minimize and avoid impacts: "Pre-construction Surveys and Nest Buffers for Swainson's HawK. COFWrecommends conducting protect activities outside of the Swainson's hawk breeding season (March 20 to September >6). /f Project activities are to be conducted during the breeding season, surveys for Swainson's hawKs and their nests she//be conducted by the Designated Bio/ogist(s)prior to the beginning of Project-re/ated activities at each Project site. Surveys she//be conducted in a manner consistent with the Recommended Timing and Methodology for Swainson's HawK Nesting Surveys in Ca//fornia's Centra/ Va//ey (httos://www.wi/d/ife.ca.oov/Conservation/Survey-Protoco/s#37728>284-birds). Surveys she//cover a minimum of two survey periods with the minimum number of surveys prior to project initiation as fo//ows: January to March 20-survey a//day for raptor nests a minimum of one survey. March 20 to Apri/5— survey from either sunrise to >ODO or >600 to sunset with a minimum of three surveys. a Apri/5 to Apri/20— survey from either sunrise to >200 or >630 to sunset with a minimum of 3 surveys. An a/ternaY/ve methodology may ba approved by COFW speciFic to each Project location. /f a /apse in Project-related worK of 7 days or longer occurs at Project site, then a focused a//-day survey she//ba performed, and the results she//be sent to COFW prior to resuming worK. Surveys she//be conducted in proposed worK areas, staging and storage areas, and access routes. /f any active Swainson's hawK nests are found within Y-mi/e of a Project site, an avoidance buffer of/e-mi/e in urban areas or a Y=-mi/e buffer in non-urban areas she//be imp/emented from March 20 to September >6 unless otherwise approved in writing by COFW." Comment 7: Revisions needed to mitigate impacts to San Joaquin Kit fox to a less-than-significant tavel Tha ND does not mitigate potential impacts to San Joaquin kit fox (Vu/pas macrotis mutica) to less-than-significant because the ND lacks an evaluation of impacts to San Joaquin kit fox and does not include either a mitigation measure that requires full