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after the CEQA document has been adopted, it may constitute changed circumstances that should be addressed in a re-circulated CEQA document (CDFW 2012). COMMENT 4: Habitat Loss, Issue: Although both Swainson's hawk and burrowing owl, mentioned in the comments 1 and 3 respectively, are abundant throughout San Joaquin County (CNDDB 2025), both are listed species in California due to reduced population numbers. Declining populations result from impacts like loss of nesting and foraging habitat resulting from the wide-spread development supporting the growing human population. Both species have managed to adapt to the changes in land use in this area, either by using agricultural practices to advance foraging efficiency (Swainson's hawks) or by making use of existing bird nests (Swainson's hawks) or small mammals (burrowing owls). Optimal foraging theory suggests that in areas where foraging habitat is scarce, both Swainson's hawks and burrowing owls will choose the best foraging option that they have access to, even if it is not ideal (Swolgaard et al. 2008; Inselman et al. 2016; Sissons et al. 2001). Given the Project site's location within a predominantly urbanized landscape and its minimal vegetation cover(which allows birds to spot prey easily) and considering documented occurrences of burrowing owl northwest of the site and Swainson's hawks both within and adjacent to the project footprint, it is reasonable to conclude that both species are utilizing the available habitat within and surrounding the site for foraging. Such impacts to foraging habitat used by both species should be considered in assessment of project- related impacts to biological resources. The primary threat to the Swainson's Hawk population in California continues to be habitat loss, especially the loss of suitable foraging habitat, but also nesting habitat in some portions of the species' breeding range due to urban development and incompatible agriculture. This impact may have been the greatest factor in reducing Swainson's Hawk range and abundance in California over the last century (California Department of Fish and Game 1993, California Department of Conservation 2011), and if continued, could qualify it for State endangered status. Suitable foraging habitat is necessary to provide an adequate energy source for breeding Swainson's hawks adults, including support of nestlings and fledglings. If prey resources are not sufficient, or if adults must hunt long distances from the nest site, the energetics of the foraging effort may result in reduced nestling health and survival with an increased likelihood of disease and/or starvation. In more extreme cases, the breeding pair, in an effort to assure their own existence, may even abandon the nest and young (Woodbridge 1985). Any unmitigated loss of potential Swainson's hawk habitat could to contribute to a significant county-wide impact. Therefore, the loss of wildlife habitat (including raptor foraging habitat) is considered a cumulatively significant impact. CDFW recommends options for mitigating habitat below. Recommendation or Recommended Mitigation Measure: CDFW recommends that the San Joaquin County Community Development Department quantify the total acreage of permanent and temporary project impacts to Swainson's hawk and burrowing owl foraging and nesting habitat and provide mitigation in the upcoming Mitigated Negative Declaration (MND) based on the area on impacts. To reduce impacts to Swainson's hawk foraging and nesting habitat to a less than significant level, CDFW recommends that a habitat assessment for burrowing owl and Swainson's hawk be conducted as a part of the Initial Study . If suitable habitat is present, the San Joaquin County Community Development Department shall provide adequate mitigation on the calculated temporary and/or permanent impacts respectively. CDFW also recommends the project proponent provide an artificial burrow for owls on or near the project site if burrowing owl burrows cannot be avoided. ENVIRONMENTAL DATA 7