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Administrative Draft Environmental Impact Report Gill Medical Center Project are identified as a species of special concern (SSC) by the California Department of Fish and Wildlife (CDFW); are birds identified as birds of conservation concern (BCC) by the U.S. Fish and Wildlife Service (USFWS); are considered by the California Native Plant Society(CNPS) to be "rare, threatened, or endangered in California," "plants about which more information is needed," or"plants of limited distribution—a watch list" (i.e., species with a California Rare Plant Rank [CRPR] of 113, 2, 3, or 4); are plants listed as rare under the California Native Plant Protection Act (NPPA) (California Fish and Game Code, § 1900 et seq.); or are fully protected in California in accordance with the California Fish and Game Code, § 3511 (birds), §4700 (mammals), § 5050 (amphibians and reptiles), and § 5515 (fishes). 4.6.3.3 Project Impacts and Mitigation Measures Impact 4.6-1 The proposed project could directly or indirectly affect special-status plant and wildlife species and/or their habitats. Impact Determination: less than significant with mitigation incorporated Threshold: Substantial adverse impact, either directly or through habitat modifications, on any plant fish or wildlife species identified as candidate, sensitive, or special-status species in local or regional plans,policies, or regulations, or by CDFW, NMFS, or USFWS. Sanford's Arrowhead The existing Woodbridge Irrigation District irrigation canal centerline defines the northwest project boundary. As such, the south bank of the canal is located onsite and represents potential suitable habitat for Sanford's arrowhead. Project development plans include creation of a 100-foot wide buffer along the canal's south bank where it occurs onsite (see Site Plan Figure 3-4). As discussed in the project description, one purpose of this buffer is to address land use compatibility issues related to existing agricultural operations (such as noise, dust, and herbicide/pesticide application) that occur immediately north of the Project site. To accomplish this,the buffer area would be planted with trees and shrubs to create a uniform canopy and "vegetative screen"which would also result in resource benefits.As discussed in the project description, to reduce the area required for onsite stormwater detention, the buffer area may also accommodate a linear retention basin. All buffer area improvements, including the planting plan and any proposed retention basin, would be designed to ensure occurrences of Sanford's arrowhead are protected. While the likelihood of Sanford's arrowhead occurrence within the buffer areas is considered low due to the intermittent nature of the canal, potential presence cannot be ruled out. Therefore, any construction ground disturbance within the buffer area is considered a potentially significant impact to Sanford's arrowhead. With implementation of Mitigation Measures 4.6-1a, 4.6-1b and 4.6-1c, this impact would be reduced to less than significant with mitigation incorporated. Biological Resources 4.6-32 October 2021