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DocuSign Envelope lD:3FC9FB8t-BBt D-4tOF-BD90-AA23F'I6t9DFE Mr. Frank Girardi San Joaquin County Community Development Department February 22, 202'1 Page 1 O impacts to a less-than-significant level by identifying compensatory mitigation in the event impacts to special-status plants cannot be fully avoided. CDFW recommends Section IV, Biological Resources be revised to include a statement of how impacts to special-status plants will be avoided in the event they are discovered in the Project area. If significant impacts to spacial-status plants are not fully avoidable, CDFW recommends the ND be revised to require compensatory mitigation for impacts to special-status plant species at a minimum of a 3:1 mitigation ratio (conserved habitat to impacted habitat)for permanent impacts. CDFW also recommends inclusion of language defining the Project's obligation to obtain CESA-listed plant take coverage through an Incidental Take Permit(ITP) issued by CDFW when take of caper-fruited tropidocarpum (Tropidocarpum capparideum) cannot be fully avoided. Comment 10: CDFW recommends additional mitigation measures for Project construction b¢ included in the ND CDFW also recommends the following avoidance and minimization measures to be included in the ND: "Oven Pioes Restriction. A//pipes, cu/vans, or Simi/ar structures that are stored at the construction site (either vartica//y or horizonta//y) for one or mora overnight periods wf// be secure/y capped on both ends prior to storage and thorough/y inspected for wi/d/ifa prior to imp/ementation by a Qua/ifiad Bio/ogist. Fence and Sion-Post Restriction. Any fencing posts or signs insta//ed, temporari/y or permanent/y, throughout the course of the Project she//ba designed to be wi/d/ife friend/y(e.g.,.smooth top and bottom wires, 6-inches above grade) and have fha top three post ho/es covered or fi//ed with screws or bo/ts to prevent snaring. ENVIRONMENTAL DATA CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. [Pub. Resources Code, § 2'1003, subd. (e)j. Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form, online field survey form, and contact information for CNDDB staff can be found at the following IinK: httos://wild life.ca.cov/data/CNDDB/submitt'nc-data. The types of information reported to CNDDB can be found at the following link: https://wildlife.ca.cov/Data/CNDDB/Plants- and-Animals.