Prepare Technical Reports. Based on our understanding of the Project we are recommending preparation of the following technical reports to support the EIR. In our experience water is not used for operation (panel washing) but water is required for construction. In addition, because the site will disturb more than 40 acres a water supply assessment (WSA) is required. It is assumed either the San ▇▇▇▇ Water District or Santa Nella County Water District would provide water required for construction activities. Either of these districts may be able to prepare the WSA. If not, ▇▇▇▇▇ has the expertise to prepare this analysis but it may be less expensive to use a local firm that may have previously prepared a WSA for the County. At this time we are not including preparation of a WSA. A Biological Resource Assessment (BRA) has been conducted as part of the San ▇▇▇▇▇▇▇ kit ▇▇▇ survey work which will be referenced to prepare the biological resources section of the EIR. However, special-status species reports have not yet been prepared; therefore, ▇▇▇▇▇ is including preparation of these reports. We are assuming the applicant team will provide ▇▇▇▇▇ with the following reports: • Phase 1 Environmental Site Assessment (ESA) • Geotechnical Report • Lighting Plan to address lighting associated with project construction and operation • WSA (to be prepared by the water district or the applicant team) • Fire Safety Plan. Air Quality – Construction Health Risk Assessment The Project may result in a short- term increase in toxic air contaminants (TAC) emissions related to Project activities. Due to the scrutiny this EIR may receive it is recommended a construction HRA be prepared. In the short-term, the Project may generate TAC emissions from construction equipment and diesel vehicles. The main contaminant of concern is diesel particulate matter (DPM), which has been listed as a TAC by the California Air Resources Board or CARB. To evaluate the potential for the Project to expose nearby sensitive receptors to TACs that would result in a health risk impact, ▇▇▇▇▇ will use the AERMOD model, which is required by the San ▇▇▇▇▇▇▇ Valley Air Pollution Control District (SJVAPCD) to conduct dispersion modeling, and CARB’s Hot Spots Analysis and Reporting Program Version 2 (HARP2) to calculate the health impacts, along with local meteorological data obtained from SJVAPCD and the estimated annual average DPM emissions. The SJVAPCD’s AERMOD modeling guidance will be followed. Notably, the health impact calculations in HARP2 are based on the Office of Environmental Health Hazard Assessment’s Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments. The maximum cancer risks at the appropriate receptors (e.g., proximate residential receptors) will be tabulated. Cancer risk isopleths (i.e., lines of equal cancer risk) will be plotted on figures showing the Project site if the maximum cancer risk exceeds the SJVAPCD significance threshold. If the health impacts exceed the thresholds of significance, we will suggest appropriate mitigation measures to reduce the health impacts. A construction HRA will be prepared as a technical appendix and a summary of the methodology and results will be provided in the air quality section of the EIR. Biological Resources Special-Status Species Surveys Burrowing Owl, American Badger, and Other Nesting Bird Surveys Qualified ▇▇▇▇▇ biologists will conduct surveys for American badger, burrowing owl, and other ground-nesting and low-shrub nesting bird species. Because both the badger and burrowing owl breed/nest within small mammal ▇▇▇▇▇▇▇, surveys for these two species will be conducted concurrently. Surveys for burrowing owl will follow CDFW protocols for this species which require a minimum of three survey visits at least three weeks apart, with at least one survey between February 15 and April 15, one between April 14 and June 15, and one visit after June 15. Based on the habitat assessment conducted in August 2021, and assuming site conditions have not substantially changed since that time, this scope of work assumes that only those portions of the site where suitable ground squirrel ▇▇▇▇▇▇▇ were mapped will be surveyed. Such ▇▇▇▇▇▇▇ occurred primarily in the northern and southern portions of the site. During the owl and badger surveys, searches for active nests for other ground-nesting and shrub-nesting bird species will also be conducted. Data on any active owl and badger ▇▇▇▇▇▇▇, as well as any active nests of other bird species, will be collected and all active nests/▇▇▇▇▇▇▇ will be mapped. The methods and results of this survey effort will be documented and included in a biological technical report for all surveys of special-status plant and animal species conducted on the site. This will require a team of three biologists to conduct three 1-day surveys at least three weeks apart. California Tiger Salamander and California Red-Legged Frog Habitat Assessment for USFWS and CDFW Pursuant to U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) assessment protocols for these two species, a site habitat assessment document will be prepared for the California Tiger Salamander (CTS) and California red legged frog (RLF) and submitted to the appropriate agency (USFWS for CTS and RLF, CDFW for CTS). Each assessment will contain a thorough characterization of the existing natural resources on the project site, confirm whether or not the site is within the known range of each species, note known records/localities of each species within the project site region, and describe the suitability of onsite aquatic features to support either of these species. Any previous/historical surveys conducted for these species will also be compiled. The purpose of the assessment is for each agency to make a determination as to whether or not focused surveys would need to be conducted on the site to determine presence/absence. Additional surveys, if requested by USFWS or CDFW, would be subject to a separate scope/cost. USFWS Concurrence on San ▇▇▇▇▇▇▇ Kit ▇▇▇ Presence/Absence ▇▇▇▇▇ will prepare a habitat suitability and survey assessment for the project site and submit to the USFWS for concurrence on the potential of the site to support San ▇▇▇▇▇▇▇ kit ▇▇▇. Pursuant to the USFWS assessment checklist, the assessment will include the following: brief description of the proposed project and site map; compilation of CNDDB sighting records within a 10-mile radius of the project site; description of onsite vegetation communities and continuity of onsite vegetation with offsite areas within the 10-mile radius, and an evaluation of onsite habitat suitability for kit fox based on field transects (conducted as part of the 2021 overall biological habitat assessment). The results of previous/historical surveys conducted for kit fox, as well as the results of the 2021 scent dog surveys for evidence of kit fox, will be included in the assessment. Upon completion, the assessment will be submitted to USFWS for concurrence on habitat suitability and survey results. Additional surveys, if requested by USFWS, would be subject to a separate scope/cost. ▇▇▇▇▇▇▇▇’▇ Hawk Surveys Qualified ▇▇▇▇▇ raptor biologists will conduct protocol level surveys for ▇▇▇▇▇▇▇▇’▇ hawk nests pursuant to the 2000 survey methods prepared by the Swainson’s Hawk Technical Advisory Committee (SHTAC) and endorsed by CDFW. The survey protocol requires a minimum of three survey passes within each of the three survey windows indicated in the SHTAC protocol (March 20 – April 5, April 6 – April 20, June 10 – July 30). The surveys are to include suitable nest tree habitat within a 0.5 mile buffer from the project boundary, where accessible. The survey will also include concurrent searches for other nesting raptors. Any active SWHA or other raptor nests observed during the surveys will be recorded and mapped. The methods and results of this survey effort will be documented and included in a biological technical report for all surveys of special-status plant and animal species conducted on the site. This will require a team of two biologists to conduct three 1-day surveys for each of the three survey windows. Special-Status Plant Surveys Based on the results of the 2021 Biological Resources Assessment, a total of 13 special-status plant species have some potential to occur on the project site within the foothill annual grassland vegetation that dominate the site. Qualified ▇▇▇▇▇ botanists will conduct focused plant surveys, pursuant to CDFW protocols, along pre- determined parallel transects within the grassland vegetation. The protocols require that surveys be conducted within the appropriate blooming period of the target species to ensure the highest probability of detection. Because of the overlapping nature of the blooming periods associated with all 13 species, a total of two survey passes, one in April and one in June, will be necessary to meet the blooming period survey requirement for each species. The methods and results of this survey effort will be documented and included in a biological technical report for all surveys of special-status plant and animal species conducted on the site. This will require a team of three biologist to conduct two surveys requiring four days for each survey. Jurisdictional Delineation Based on the results of the 2021 Biological Resources Assessment, a total of five seasonal wetlands and one freshwater pond occur within the project boundary. In addition, portions of Quinto Creek and ▇▇▇▇▇▇ Creek run through the northern and southern portions of the project site, respectively. In order to determine the extent, if any, of each of these aquatic resources to be under the jurisdiction of the U.S. Army Corps of Engineers (ACOE), the CDFW, and/or the Regional Water Quality Control Board (RWQCB), qualified ▇▇▇▇▇ biologists will conduct a protocol-level jurisdictional delineation of each of these features. The delineation will be conducted pursuant to ACOE and CDFW protocols and will include a determination of the location and extent of the Ordinary High Water Mark within the two creeks and whether or not the creeks have any nexus with federal Waters of the U.S. An evaluation will also be made as to whether or not the seasonal wetlands and the pond have any nexus to Waters of the U.S. and to what extent all of these features would be under the jurisdiction of the CDFW and/or RWQCB. All data collected will be documented and all features will be precisely mapped pursuant to ACOE and CDFW protocols. The methods and results of the delineation will be compiled into an Aquatic Resources Delineation Report. Because the extent of impacts to these resources, if any, that would occur as a result of project implementation is not yet known, the need for any regulatory permits from the ACOE, CDFW, and/or RWQCB as a result of any impact to jurisdictional aquatic resources cannot be determined at this point. This will require a team of two biologists to conduct one day of survey work. If any such permits are determined to be needed, ▇▇▇▇▇ can prepare the appropriate permit applications subject to a separate scope/cost. Biological Survey Technical Report All methods and results of surveys for special-status animal species, including American badger, burrowing owl, and other ground-nesting and low-shrub nesting bird species; Swainson’s hawk; and special-status plant species will be compiled into a Biological Survey Technical Report. Appropriate figures depicting the location of any observed species or indications of species presence will also be included.
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