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4 Environmental Analysis 4.4 Biological Resources specified in the conditions of Project approval (see SJMSCP, Section 5.2.2.1b). The results of the preconstruction surveys shall be submitted to the Implementing agency prior to start of construction. Before Project construction, and under the direction of a qualified biologist, a wildlife exclusion fence shall be installed at strategic locations (e.g., where a work area occurs within 500 feet of suitable breeding habitat). The exclusion fence will remain in place and be maintained for the duration of ground disturbance. The wildlife exclusion fence will be tall enough to discourage dispersal of western spadefoot into active work areas. Any damage or gaps in the wildlife exclusion fence will be repaired immediately during routine inspections. For impacts to spadefoot toad upland dispersal habitat, compensatory mitigation shall be completed by the Project owner in accordance with the mitigation ratios and requirements in the SJMSCP. Compensatory mitigation may be combined with other special-status plant and animal species, such as the CTS. San Joaquin Coachwhip The San Joaquin coachwhip (also called the San Joaquin whipsnake) is covered under the SJMSCP, but is considered of very limited distribution in the County and specific Incidental Take Minimization Measures are not provided for this species (see Section 5.2.4.9). This species is not a focal species in the EACCS. The following measure would be implemented in accordance with the SJMSCP to mitigate impacts to this species in all Project areas: A qualified biologist shall conduct preconstruction surveys prior to (or, for some Incidental Take Minimization Measures, during) ground-disturbing activities to determine if SJMSCP Covered Species are present and/or verify that the appropriate Incidental Take Minimization Measures have been implemented, as specified in the conditions of Project approval (see SJMSCP, Section 5.2.2.1 b). If any special-status reptiles are found and cannot or do not move off-site on their own, work would not begin until coordination with the USFWS and/or CDFW has occurred to determine the appropriate course of action. Incidental Take Minimization Measures shall be formulated by the Technical Advisory Committee (TAC) and approved by the Joint Powers Authority (JPA) with the concurrence of the Permitting Agencies' representatives on the TAC in accordance with the SJMSCP's Adaptive Management Plan (see Section 5.9.4). Special-status Vernal Pool Invertebrates The longhorn fairy shrimp and vernal pool fairy shrimp are covered species under the SJMSCP (see Sections 5.2.4.4 and 5.5.9). Per the SJMSCP, if final site design is confirmed to be within 250 feet of the ephemeral pond, then one of the following will occur: 1. Receive concurrence from USFWS that the ephemeral pond does not support special- status vernal pool invertebrate species given the lack of ponding observed in historic aerial imagery. 2. Conduct pre-construction surveys in compliance with current USFWS protocols to determine the presence or absence of longhorn fairy shrimp within ponds southwest of 1- 580 unless complete avoidance of vernal pools and/or wetlands is achieved, per Section 5.2.2 of SJMSCP. 3. Conduct a hydrologic study to determine if a setback less than 250 feet would maintain the hydrology of the ephemeral pond and achieve the same, if not greater, habitat value Griffith Energy Storage Project 4.4-41 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023