14 ATTACHMENT 6 - Appendix A - E

56 result, Dr. Jennings observed no ground squirrel burrows on the Spotorno project area. However, it was observed that the neighboring property to the north of the site does continue to have ground squirrels and ground squirrel burrows present. Dr. Jennings also noted the presence of some clusters of Botta pocket gopher (Thomomys bottae) burrows, as well as large cracks in the clay soils of the site that could provide some refuge for estivating CTS, should they occur on the site. Therefore, although no breeding habitat exists on the Spotorno site, it is possible that CTS estivate on the site. The project would result in development of approximately 28 to 30 acres of areas that provide the least suitable estivation habitat for CTS due to ongoing hay production and ground squirrel abatement practices, while preserving via a deed restriction, conservation easement, or similar conservation mechanism, approximately 81 acres of grasslands that are used as rangeland. These latter areas are significantly less disturbed, and are immediately adjacent to properties known to support breeding CTS. The preservation of approximately 81 acres of open space with a deed restriction, conservation easement, or similar conservation mechanism, which provides more suitable CTS estivation habitat will compensate for the loss of approximately 28 to 30 acres of marginal estivation habitat, therefore the project as currently proposed will result in a less-than- significant impact on upland habitat for CTS. Although the development area is considered marginal estivation habitat, should CTS estivate on the development area during project construction, individual CTS could be harmed or killed by project construction activities and this would be considered a significant impact. Mitigations to lessen impacts to individual CTS to a less-than-significant level are provided below. Mitigation. Typically, mitigations to reduce impacts to CTS individuals would take the form of avoidance, minimization and compensatory measures. Avoidance and Minimization Measures. To avoid and minimize impacts to CTS individuals, the following measures will be followed:  Prior to the start of construction, a qualified biologist will train all construction personnel regarding habitat sensitivity, identification of special status species potentially occurring on the site, and required practices.