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DocuSlgn Envelope ID:3FC9FB61-66t D-4t OF-BD90.M23FBt9DFE Mr. Frank Girardi San Joaquin County Community Development Department February 22, 202'1 Page 9 avoidance of take of San Joaquin kit fox or their habitat. The NO does not define avoidance measures in the event San Joaquin kit fox are discovered or reduce impacts from permanent loss of open space and movement corridors and foraging habitats or indirect impacts to foraging and donning impacts from increased construction activity to alass-than-significant level as it does not offset those impacts with compensatory mitigation requirements. San Joaquin kit fox era designated as a State of California Endangered Species. The loss of valley and foothill grasslands due to conversion to agriculture and urbanization is the primary threat to San Joaquin kit fox populations throughout California. The U.S. Fish and Wildlife Service's Recovery P/an fog Up/and Species of the San Joaquin Va//ay, Ca//fon/a (�998) states connectivity between the sub-populations of the kit fox are essential for recovery of the species. The Project's potential impacts to connectivity and permanent loss of habitat requires an impacts evaluation in a revised and recirculated ND. Given the severe population declines of the species and magnitude of historic habitat loss, any impacts identified can ba considered as significant and even more so when evaluated in a cumulative manner. CDFW recommends the ND be revised and r®circulated to include an impacts analysis that provides an evaluation and discussion of potential impacts of the Project to San Joaquin kit fox and their habitats. If the impacts analysis indicates there will be direct or indirect take and the Project cannot fully avoid impacts to and take of San Joaquin kit fox, CDFW recommends the ND be revised to include a measure requiring participation in the SJMSCP, or in the event SJMSCP does not cover[he Project or the Proponent elects to not participate in the Plan, then CDFW recommends the ND include language defining the Project's obligation to obtain take coverage through an ITP issued by CDFW. Comment 8: Biological Resources does not define floristic survey protocol Section IV of the ND does not include defined survey protocols for floristic surveys or require a qualified botanist to conduct the surveys. CDFW recommends Section IV. Biological Resources be revised to include adherence to CDFW's Protoco/s for Surveying and Eva/uating /mpacts to Specie/-Status Native P/ant Popu/ations and Natuna/Communities(20'18), including the reporting requirements contained in those protocols, and to indicate a qualified botanist shall conduct the surveys according to the protocols. Comment 9: Revisions ne®dad to mltlgate impacts to spacial-status plants to less-than-significant level Caper-fruited tropidocarpum (Tropidocarpum capparideum) is especial-status plant with the potential to occur on the Project site, but the ND does not define avoidance measures in the event they or other special-status plants era discovered or reduce