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Mr. Frank Girardi San Joaquin County Community Development Department September 24, 2019 Page 3 of 7 To correct this, CDFW recommends correcting the location description on the cover page, pages 1 and 7, and providing a project location map to accurately indicate where the proposed Project's location is in a revised and recirculated IS/MND. Comment 2: revisions needed to mitigate impacts from project phasing to less-than- significant. The IS/MND does not include a description of timeframe or period during which construction will occur. Project activities may have additional significant biological impacts due to Project phasing over time. Phasing and the additional impacts from phasing are not discussed, analyzed, or mitigated for in the ISMND. Projects that include multiple phases with different sections or parcels built out at different time periods or phasing that includes whole-site grading with separate sections or parcels developed at later dates have impacts over a period longer than one year. This delay in full build out of a Project allows wildlife to utilize resources that develop post-grading on vacant sections or parcels. These resources include, but are not limited to; ruderal grassland and brush that provide nesting habitat for passerine birds and burrowing owls; infrastructure installed but not utilized that provide burrowing habitat for ground squirrels, burrowing owls, and short-eared owls; additional indirect impacts to nesting and foraging raptors with roost and nest trees adjacent to the project site and access routes; and pooling of rainwater on parcels that provide temporary habitat for amphibians. CDFW is unable to analyze these impacts without inclusion of a description of the Project's timing and implementation in relation to site preparation, infrastructure installation, and complete buildout. To correct this, please revise and recirculate the IS/MND with a description of the Project's phasing and estimated timeframes from start of construction to complete buildout. If the Project's timeframe from start of construction to complete build out includes breaks in construction longer than 15 days or periods of inactivity that could allow establishment of habitat elements such as burrows and vegetation, then impacts to wildlife utilizing vacant sections or parcels of the Project not built out must be included in the impacts analysis to ensure the Project mitigates impacts to less-than-significant. When and if such a delay occurs, and to ensure the Project is mitigating to less-than-significant, CDFW recommends revising the IS/MND to include a mitigation measure that meets the following criteria: 1) a qualified biologist shall conduct a habitat assessment survey to determine what potential wildlife and habitat elements are present that may be utilizing the vacant sections and/or parcels prior to Project-related activities taking place when there is a break in these activities greater than 15-days; 2) if unbuilt or fallow sections and/or parcels are being utilized, avoidance and minimization measures (including the measures discussed in this letter) shall be used to prevent impacts and take, and if impacts and take are not fully avoidable, additional compensatory mitigation shall be discussed and agreed upon with CDFW's approval prior to the re-initiation of construction activities. Comment 3: revisions needed to mitigate to a level of less-than-significant in the event the San Joaquin Multi Species Conservation Plan does not approve coverage. The statement presented on page 7 of the IS/MND, Environmental Issues, 3. Plant and Animal Life does not mitigate potential impacts to less-than-significant regarding CEQA. The IS/MND does not propose or identify specific, sufficient, and enforceable mitigation in the event the San Joaquin Multi Species Conservation Plan (SJMSCP or Plan)does not approve coverage or the Proponent chooses to not participate. Because participation in the Plan is voluntary, the IS/MND must include 1) an evaluation and discussion of potential direct and indirect impacts of the