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Madeline DawsonVictoria Ticorat From:Madeline Dawson <madeline@lozeaudrury.com> Sent:Monday, September To:Planning Commission; Nicholas J. Taylor Cc:Rebecca Davis; Kylah Staley; Chase Preciado Subject:\[EXTERNAL\] Comment on Hills Preserve Project Environmental Impact Report (SCH No. 2023080600) Attachments:2024.09.30 SAFER Comments - Hills Preserve - Final + exhibits.pdf Youdon'toften getemailfrom Learnwhy thisisimportant Warning: This email originated from outside theCity ofAnaheim. Donotclicklinks oropen attachments unless you recognize thesender andareexpecting themessage. Dear Chair Walker, Vice Chair Kring, Honorable Commissioners, and Mr. Taylor, Attached please find comments submitted onbehalf ofSupporters Alliance forEnvironmental Responsibility (“SAFER”) regarding theEnvironmental Impact Report (“EIR”) prepared fortheHills Preserve Project (SCH No. 2023080600). Ifyou could please confirmreceipt ofthis email and theattached comments, itwould bemuch appreciated. Sincerely, Madeline Madeline Dawson (she/her) Legal Assistant Lozeau | Drury LLP Oakland, CA94612 1 September 30, 2024 Via Email Christopher Walker, Chairperson Lucille Kring, Vice Chairperson Jeanne Tran-Martin, Commissioner Michelle Lieberman, Commissioner Luis Andres Perez, Commissioner Amelia Castro, Commissioner Deirdre Kelly, Commissioner City of Anaheim Planning Commission 200 South Anaheim Boulevard Anaheim, CA 92805 planningcommission@anaheim.net Nicholas Taylor Principal Planner Planning and Building Department City of Anaheim 200 South Anaheim Boulevard, Suite 162 Anaheim, CA 92805 njtaylor@anaheim.net Re: Comment on Hills Preserve Project Environmental Impact Report (SCH No. 2023080600) Dear Chair Walker, Vice Chair Kring, Honorable Commissioners, and Mr. Taylor: The following comments are submitted on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Hills Preserve Project (“Project”) and the Environmental Impact Report (“EIR”) prepared for the Project. The Project will require a General Plan amendment, Specific Plan, Zoning reclassification, Zoning Code amendment, Tentative Tract Map, Final Plan, Discretionary Tree Removal Permit, and Development Agreement to build six single-family detached residential lots, 498 wrap-style apartment units, and 80,000 square feet of commercial space. The Project sits on an approximately 76-acre site with East Santa Ana Canyon Road and Highway 91 to the north, South Eucalyptus Drive to the west, and Festival Drive to the east in the City of Anaheim. In support of its comments, SAFER has retained expert wildlife ecologist Dr. Shawn Smallwood, Ph.D to review the Project’s impacts to biological resources. Dr. Smallwood’s comments and CV are attached at Exhibit A. Comments on Hills Preserve Project and EIR September 30, 2024 Page 2 of 11 LEGAL STANDARD I. CEQA and Environmental Impact Report CEQA has two primary purposes. First, CEQA is designed to inform decision makers and the public about the potential, significant environmental effects of a project. (14 CCR § 15002(a)(1).) “Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. Thus, the EIR ‘protects not only the environment but also informed self-government.’” (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.) Second, CEQA requires public agencies to avoid or reduce environmental damage when “feasible” by requiring “environmentally superior” alternatives and all feasible mitigation measures. (14 CCR § 15002(a)(2) and (3); see also Berkeley Jets Over the Bay Com. v. Board of Port Cmrs. (2001) 91 Cal.App.4th 1349,1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.) CEQA requires that an agency analyze the potential environmental impacts of its proposed actions in an Environmental Impact Report (EIR) except in certain limited circumstances. (See, e.g., Pub. Resources Code, § 21100.) The EIR is the very heart of CEQA. (Dunn-Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652. The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” (Bakersfield Citizens for Local Control v. City of Bakersfield (2004), 124 Cal.App.4th 1184, 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR serves to provide agencies and the public with information about the environmental impacts of a proposed project and to “identify ways that environmental damage can be avoided or significantly reduced.” (14 CCR § 15002(a)(2).) Critical to this purpose, the EIR must contain an “accurate and stable project description.” (County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185 at 192-93 (“An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR.”) The project description must contain (a) the precise location and boundaries of the proposed project, (b) a statement of the project objectives, and (c) a general description of the project's technical, economic, and environmental characteristics. (14 CCR § 15124.) II. Standard of Review The California Supreme Court has emphasized that: When reviewing whether a discussion is sufficient to satisfy CEQA, a court must be satisfied that the EIR (1) includes sufficient detail to enable those who did not Comments on Hills Preserve Project and EIR September 30, 2024 Page 3 of 11 participate in its preparation to understand and to consider meaningfully the issues the proposed project raises [citation omitted] . . . (Sierra Club v. Cty. of Fresno (2018) 6 Cal.5th 502, 510 (2018) [citing Laurel Heights Improvement Assn., 47 Cal.3d at 405].) The Court in Sierra Club v. Cty. of Fresno also emphasized that another primary consideration of sufficiency is whether the EIR “makes a reasonable effort to substantively connect a project’s air quality impacts to likely health consequences.” (Id. at 510.) “Whether or not the alleged inadequacy is the complete omission of a required discussion or a patently inadequate one-paragraph discussion devoid of analysis, the reviewing court must decide whether the EIR serves its purpose as an informational document.” (Id. at 516.) Although an agency has discretion to decide the manner of discussing potentially significant effects in an EIR, “a reviewing court must determine whether the discussion of a potentially significant effect is sufficient or insufficient, i.e., whether the EIR comports with its intended function of including ‘detail sufficient to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.’” (Sierra Club, 6 Cal.5th at 516 [citing Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1197].) “The determination whether a discussion is sufficient is not solely a matter of discerning whether there is substantial evidence to support the agency’s factual conclusions.” (Id. at 516.) As the Court emphasized: [W]hether a description of an environmental impact is insufficient because it lacks analysis or omits the magnitude of the impact is not a substantial evidence question. A conclusory discussion of an environmental impact that an EIR deems significant can be determined by a court to be inadequate as an informational document without reference to substantial evidence. (Id. at 514.) Additionally, “in preparing an EIR, the agency must consider and resolve every fair argument that can be made about the possible significant environmental effects of a project.” (Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App. 4th 1099, 1109.) DISCUSSION III. The EIR’s Analysis of the Project’s Impacts on Biological Resources is Not Supported By Substantial Evidence. Dr. Smallwood reviewed and analyzed the EIR’s analysis of the Project’s impacts to biological resources prepared by Psomas Environmental Consulting (“Psomas”) and found that Psomas failed adequately analyze significant impacts to wildlife including habitat loss, Comments on Hills Preserve Project and EIR September 30, 2024 Page 4 of 11 interference with wildlife movement, vehicle collisions, bird-window collisions, and cumulative impacts. As a result, the Project’s analysis of impacts to biological resources is insufficient and not supported by substantial evidence. A. Wildlife detected on the Project Site. Dr. Smallwood’s associate, Noriko Smallwood, conducted a 3.3-hour site visit on September 19, 2024, and a 1.17-hour evening site visit to conduct a nocturnal survey. During her surveys, Ms. Smallwood detected 46 species of vertebrate wildlife. (Ex. A, p. 1-13.) Psomas detected 28 species of vertebrate wildlife that Ms. Smallwood did not detect, resulting in a combined 74 species detected in total. (Id. at p. 17.) During her survey, Ms. Smallwood observed 11 special-status species, including Allen’s hummingbird, turkey vulture, Cooper’s hawk, red- shouldered hawk, red-tailed hawk, western screech-owl, Nuttall’s woodpecker, American kestrel, oak titmouse, wrentit, California gnatcatcher, and California thrasher. (Id. at p. 12-13.) Allen’s hummingbird, Nuttall’s woodpecker, oak titmouse, wrentit, and California thrasher are listed by the U.S. Fish and Wildlife Service as a Bird of Conservation Concern, meaning that these species have been identified as a priority for conservation action. The turkey vulture, red-tailed hawk, red-shouldered hawk, western-screech owl, and American kestrel are naturally rare because of their position at the top of the food chain. The California gnatcatcher is listed as threatened under the Endangered Species Act and as a Species of Special Concern by the California Department of Fish and Wildlife. B. Significant impacts to wildlife. Dr. Smallwood concluded that the Project would result in significant impacts to wildlife including habitat loss, interference with wildlife movement, vehicle collisions, and bird-window collisions. i. Habitat loss Dr. Smallwood found that Psomas made “no attempt” to assess the impact of the Prroject on habitat loss and loss of numerical or productive capacities of any of the wildlife species potentially affected by the Project. (Ex. A, p. 32.) Instead, Psomas merely “speculates the ‘loss of wildlife habitat would be considered limited in relation to the total amount of wildlife habitat available in the BSA region.” (Id.) However, Dr. Smallwood was able to calculate the loss of numerical and productive capacities for birds as a result of habitat lost as a result of the Project. He determined that the Project would result in the loss of 191 nest sites and 265 nest attempts per year. (Id. at p. 33.) Furthermore, Dr. Smallwood determined that reproductive capacity of the Project site would be lost, resulting in 845 birds per year denied to California. (Id.) Dr. Smallwood concluded that the loss of 845 birds per year would be substantial and “[m]any of these birds would be special-status species such as Cooper’s hawks, California thrashers, and some would be threatened or endangered species such as California gnatcatcher. (Id.) This is a significant impact that must be analyzed and mitigated in the EIR. Comments on Hills Preserve Project and EIR September 30, 2024 Page 5 of 11 ii. Interference with wildlife movement Dr. Smallwood determined that Psomas improperly concluded that the Project would not interfere with wildlife movement. (Ex. A, p. 34.) As Dr. Smallwood explains: Psomas [] concludes that the project site does occur within a movement corridor, but downplays the project’s interference with wildlife movement within the corridor by claiming ‘The Project’s impact area is located at the terminus of the continuous open space . . . therefore, it would not disrupt wildlife movement along the corridor, but would truncate the open space.’ Lost in this analysis is the result that wildlife would not longer be capable of moving within the truncated space. In other words, the [P]roject would interfere with wildlife movement in the region. (Id.) Thus, Psomas findings that the Project would prevent wildlife from moving throughout the “truncated space” created by the Project is not consistent with its determination that the Project would not interfere with wildlife movement. Furthermore, Psomas failed to provide any support for its conclusions regarding the Project’s interference with wildlife movement and “[b]ased on what [was] reported, Psomas did not record or measure wildlife movement in any way.” (Id.) However, Dr. Smallwood determined that “[t]he [P]roject would in fact eliminate a sizeable portion of the existing riparian environment . . . [which] are one of the few widely-recognized corridors in natural settings, forming a backbone of wildlife movement in the area.” (Id.) iii. Wildlife-vehicle collisions Dr. Smallwood also found that the EIR fails to account for significant impacts to wildlife from road collision mortality from increased traffic generated by the Project. As Dr. Smallwood explains, vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level. (Id.) Dr. Smallwood provides several studies demonstrating significant animal deaths due to collisions in the thousands annually per 100 km of road. (Id.) The DEIR has failed to analyze whether increased traffic generated by the Project would result in significant local impacts to wildlife. Based on the Project’s annual VMT, Dr. Smallwood was able to predict that the Project would result in 13,925 vertebrate wildlife fatalities per year. (Ex. A, p. 36.) Yet, Psomas failed to analyze this significant impact (Id.) The EIR must be revised to analyze, disclose, and mitigate this significant impact. Comments on Hills Preserve Project and EIR September 30, 2024 Page 6 of 11 iv. Bird-window collisions Dr. Smallwood also found the EIR fails to analyze potentially significant impacts to avian species from window collision mortality. Dr. Smallwood determined that the Project will result in approximately 1,359 to 1,518 annual bird deaths due to window collisions. (Ex. A at p. 39.) Dr. Smallwood also notes that “[t]he vast majority of these predicted deaths would be birds protected under the Migratory Bird Treaty Act and under the California Migratory Bird Protection Act, thus causing significant unmitigated impacts even with the implementation of established mitigation measure.” (Id. at 40.) “Given the predicted level of bird-window collision mortality . . . the [] [P]roject would result in potentially significant adverse biological impacts, including the take of both terrestrial and aerial habitat of birds and other sensitive species.” (Id.) The EIR must be revised to analyze and mitigate this significant impact. i. Cumulative impacts Lastly, Psomas failed to properly analyze the Project’s cumulative impacts. Psomas claims that “[c]umulative impacts are related to site-specific impacts to biological resource and thus would be mitigated, as necessary, on a project-by-project basis,” and therefore assumes that “cumulative impacts are really just residual impacts left over by inadequate mitigation of project- level impacts, and that project-specific environmental reviews prevent these residual impacts.” (Ex. A, p. 41.) Psomas’ interpretation of what constitutes a cumulative impact is incorrect and inconsistent with CEQA, which defines cumulative impacts as “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts.” (14 CCR § 15355.) Under this definition, “[t]he individual effects may be changes resulting from a single project,” such as here, “or a number of separate projects.” (Id.) Given Psomas misunderstanding of what constitutes a cumulative impact, Psomas conclusion that the Project “would not make a cumulatively considerable contribution to the already less than significant cumulative impacts related to biological resources” is unsupported. (Ex. A, p. 41.) As Dr. Smallwood explains: An aerial view of the landscape around the project site reveals very little wildlife habitat remains. If the project goes forward, the landscape would lose an additional 44 acres of wildlife habitat as well as some capacity for wildlife to move between the few isolated patches of habitat that remain. The environmental reviews of past projects did not avoid cumulative impacts, not with their analyses and not with the mitigation measures they implemented. (Id.) Comments on Hills Preserve Project and EIR September 30, 2024 Page 7 of 11 CONCLUSION For the forgoing reasons, SAFER respectfully requests that Project’s environmental impact report be revised to adequately analyze and mitigate significant impacts and to ensure compliance with CEQA. SAFER reserves its right to supplement these comments during review of the EIR for the Project. Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109, 1120 (“any party may bring an action pursuant to section 21167 if it has raised an objection to the adequacy of an EIR prior to certification”). A revised EIR should be prepared and recirculated to address these comments. Thank you for your attention to these comments. Sincerely, Kylah Staley Lozeau | Drury LLP EXHIBIT A 1 Shawn Smallwood, PhD 3108 Finch Street Davis, CA 95616 Nick Taylor City of Anaheim 200 South Anaheim Boulevard, Suite 162 Anaheim, California 92805 25 September 2024 RE: Hills Preserve Project Dear Mr. Taylor, I write to comment on potential impacts to biological resources from the proposed Hills Preserve Project, which I understand would develop a seven-story, 498-unit, apartment complex, up to six single-family homes, and up to 80,000 square-foot commercial buildings on 76.01 acres along the south side of Santa Ana Canyon Road in Anaheim, California. I comment on the analyses of impacts to biological resources in Psomas (Psomas 2024) and in the draft Environmental Impact Report (DEIR). I am concerned that the SMND mischaracterizes the wildlife community, inadequately analyzes potential impacts to wildlife, and provides insufficient mitigation. My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a post- graduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I’ve lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached. SITE VISIT On my behalf, Noriko Smallwood, a wildlife biologist with a Master’s Degree from California State University Los Angeles, visited the project site for 3.3 hours from 06:48 to 10:14 on 19 September 2024, and for 1.17 hours from 18:48 to 19:58 for both evening and nocturnal surveys on 21 September 2024. During her diurnal surveys, Noriko walked the northern and southern perimeters of the site where accessible, stopping to scan for wildlife with use of binoculars. Noriko recorded all species of vertebrate wildlife she detected, including those whose members flew over the site or were seen nearby, off the site. Animals of uncertain species identity were either omitted or, if possible, recorded to the Genus or higher taxonomic level. During her nocturnal survey, Noriko 2 used a telescoping pole to extend a Petterson M500 bat detector 25 feet above ground and cabled to her computer. She used Sonobat to identify species based on sonograms. During Noriko’s diurnal surveys, conditions were cloudy with mist for the first hour with no wind and temperatures of 50-63° F on 19 September 2024, and clear with no wind and 70° F on 21 September 2024. The site contained chaparral, sage scrub, oak woodland, annual grassland, riparian, and wetland (Photos 1 and 2). Photos 1 and 2. Noriko Smallwood’s views of the project site, 19 September 2024. Noriko saw American kestrel, red-tailed hawk, turkey vulture, and Cooper’s hawk (Photos 3, 4, 5, and 6), ash-throated flycatcher (Photo 7), California thrasher and Allen’s hummingbird (Photos 8 and 9), California scrub-jay (Photo 10), lesser goldfinch and California gnatcatcher (Photos 11 and 12), song sparrow and bushtit (Photos 13 and 14), acorn woodpecker and black phoebe (Photos 15 and 16), house finch and lesser goldfinch (Photo 17), American crow and common raven (Photos 18 and 19), California towhee and spotted towhee (Photos 20 and 21), house wren and common yellowthroat (Photos 22 and 23), eastern fox squirrel and Anna’s hummingbird (Photos 24 and 25), desert cottontail (Photo 26), California ground squirrel (Photo 27), and she detected 3 canyon bat, Mexican free-tailed bat and silver-haired bat (Photos 28–30). Noriko detected 46 species of vertebrate wildlife at or adjacent to the project site, including 13 species with special status (Table 1). Noriko Smallwood certifies that the foregoing and following survey results are true and accurately reported. Photos 3–6. American kestrel just off site (top left), red-tailed hawk (top right), turkey vulture (bottom left), and Cooper’s hawk (bottom right) on the project site, 19 September 2024. Photos by Noriko Smallwood. 4 Photo 7. Ash-throated flycatcher on the project site, 19 September 2024. Photo by Noriko Smallwood. Photos 8 and 9. California thrasher (left), and Allen’s hummingbird (right) on the project site, 19 September 2024. Photos by Noriko Smallwood. 5 Photo 10. California scrub-jay on the project site, 19 September 2024. Photo by Noriko Smallwood. Photos 11 and 12. Lesser goldfinch on the project site (left), and California gnatcatcher just off of the project site (right), 19 September 2024. Photos by Noriko Smallwood. 6 Photos 13 and 14. Song sparrow (left), and bushtit (right) on the project site, 19 September 2024. Photos by Noriko Smallwood. Photos 15 and 16. Acorn woodpecker just off of the project site (left), and black phoebe on the project site (right), 19 September 2024. Photos by Noriko Smallwood. 7 Photo 17. House finch and lesser goldfinch just off of the project site, 19 September 2024. Photo by Noriko Smallwood. Photos 18 and 19. American crow (left), and common raven (right) on the project site, 19 September 2024. Photos by Noriko Smallwood. 8 Photos 20 and 21. California towhee (left) and spotted towhee (right) just off of the project site, 19 September 2024. Photos by Noriko Smallwood. Photos 22 and 23. House wren (left) and common yellowthroat (right) just off of the project site, 19 September 2024. Photos by Noriko Smallwood. 9 Photos 24 and 25. Eastern fox squirrel just off of the project site (top), and Anna’s hummingbird on the project site (bottom), 19 September 2024. Photos by Noriko Smallwood. 10 Photo 26. Desert cottontail just off of the project site, 19 September 2024. Photo by Noriko Smallwood. Photo 27. California ground squirrel just off of the project site, 19 September 2024. Photo by Noriko Smallwood. 11 Photos 28, 29, and 30. Sonograms of canyon bat (top), Mexican free-tailed bat (middle), and Silver-haired bat (bottom) on the project site, 21 September 2024, recorded using a Petterson D500 detector and Sonobat. 12 Table 1. Species of wildlife Noriko observed during 3.3 hours of diurnal survey on 19 September 2024 and 1.17 hours of nocturnal survey on 21 September 2024. Common name Species name Status1 Notes California quail Callipepla californica Covey just off site Mourning dove Zenaida macroura Anna’s hummingbird Calypte anna Allen’s hummingbird Selasphorus sasin BCC Many Great egret Ardea alba Flew over just off site Turkey vulture Cathartes aura BOP Cooper’s hawk Accipiter cooperii TWL, BOP Red-shouldered hawk Buteo lineatus BOP Red-tailed hawk Buteo jamaicensis BOP Western screech-owl Megascops kennicotti BOP Multiple called at night Acorn woodpecker Melanerpes formicivorus Just off site Nuttall’s woodpecker Picoides nuttallii BCC American kestrel Falco sparverius BOP Just off site Ash-throated flycatcher Myiarchus cinerascens Cassin’s kingbird Tyrannus vociferans Just off site Black phoebe Sayornis nigricans Foraged California scrub-jay Aphelocoma californica American crow Corvus brachyrhynchos Many Common raven Corvus corax Oak titmouse Baeolophus inornatus BCC Just off site, calling Barn swallow Hirundo rustica Bushtit Psaltriparus minimus Foraged Wrentit Chamaea fasciata BCC Just off site singing Blue-gray gnatcatcher Polioptila caerulea California gnatcatcher Polioptila c. californica FT, SSC2 One on northern portion of site, one just south of site Bewick’s wren Thryomanes bewickii House wren Troglodytes aedon California thrasher Toxostoma redivivum BCC Sang House finch Haemorphous mexicanus Large flock Lesser goldfinch Spinus psaltria Song sparrow Melospiza melodia California towhee Melozone crissalis Foraged Spotted towhee Pipilo maculatus Brown-headed cowbird Molothrus ater Flew over Brewer’s blackbird Euphagus cyanocephalus Flew over Common yellowthroat Geothlypis trichas Just off site Canyon bat Parastrellus hesperus WBWG:L Big brown bat Episticus fuscus WBWG:L Indefinite species ID Silver-haired bat Lasionycteris noctivagans WBWG:M Mexican free-tailed bat Tadarida brasiliensis WBWG:L Desert cottontail Sylvilagus audubonii 13 Eastern fox squirrel Sciurus niger Non-native Just off site California ground squirrel Otospermophilus beecheyi Coyote Canis latrans Scat and tracks Striped skunk Mephitis mephitis Scat Botta’s pocket gopher Thomomys bottae Burrows 1 Listed as FT = federal threatened, SSC = California Species of Special Concern, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, TWL = Taxa to Watch List (Shuford and Gardali 2008), BOP = Birds of Prey (California Fish and Game Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H). The species of wildlife Noriko detected at the project site comprised only a sampling of the species that were present during her survey. To demonstrate this, I fit a nonlinear regression model to Noriko’s cumulative number of vertebrate species detected with time into her survey to predict the number of species that she would have detected with a longer survey or perhaps with additional biologists available to assist her. The model is a logistic growth model which reaches an asymptote that corresponds with the maximum number of vertebrate wildlife species that could have been detected during the survey. In this case, the model fit to the early morning survey data predicts 59 species of vertebrate wildlife were available to be detected at that time, whereas the model fit to the later morning survey data predicts 35 species were available to be detected during that later time. The model predicts that Noriko missed 24 species in the early morning, but only 4 species in the later morning which left five species undetected during her survey (Figure 1). Unknown are the identities of the species Noriko missed, but the pattern in her data indicates relatively high use of the project site compared to 34 surveys at other sites she and I have completed in the region. Compared to models fit to data Noriko and I collected from 34 other sites in the region between 2019 and 2024, the data from the Hills Preserve Project site quickly exceeded the upper bound of the 95% confidence interval of the rate of accumulated species detections with time into the survey (Figure 1). Importantly, however, the species Noriko did and did not detect on 19 and 21 September composed only a fraction of the species that would occur at the project site over the period of a year or longer. This is because many species are seasonal in their occurrence. 14 Figure 1. Actual and predicted relationships between the number of vertebrate wildlife species detected and the elapsed survey time based on Noriko’s visual- scan surveys on 19 September 2024. At least a year’s worth of surveys would be needed to more accurately report the number of vertebrate species that occur at the project site, but I only have Noriko’s one survey. However, by use of an analytical bridge, a modeling effort applied to a large, robust data set from a research site can predict the number of vertebrate wildlife species that likely make use of the site over the longer term. As part of my research, I completed a much larger survey effort across 167 km2 of annual grasslands of the Altamont Pass Wind Resource Area, where from 2015 through 2019 I performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods I and other consulting biologists use for surveys at proposed project sites. At each of the 46 survey stations, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours (number of surveys, as each survey lasted 1 hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least-squares, best-fit nonlinear models of the number of cumulative species detected regressed on hours of survey (number of surveys) at the station: 𝑅̂=1 1 𝑎⁄+𝑎×(𝐻𝑜𝑢𝑟𝑟)𝑐 , where 𝑅̂ represented cumulative species richness detected. The coefficients of determination, r2, of the models ranged 0.88 to 0 50 100 150 200 250 300 Minutes into survey 0 10 20 30 40 50 Cumulative number of wildlife species detectedSpecies count, 08:28 hours Model prediction r2 = 0.98, loss = 31.7 Model prediction r2 = 0.99, loss = 11.2 Species count, 06:48 hours 95% CI, 2018-2024 Y06:48 Y08:28 15 1.00, with a mean of 0.97 (95% CI: 0.96, 0.98); or in other words, the models were excellent fits to the data. I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model-predicted asymptote of species richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations of my research site. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours (Figure 2). On average I would have detected 13.5 species over my first 3.3 hours of diurnal surveys at my research site in the Altamont Pass (3.3 hours to match the 3.3 hours Noriko surveyed at the project site), which composed 23.7% of the predicted total number of species I would detect with a much larger survey effort at the research site. Given the example illustrated in Figure 2, the 41 species that Noriko detected after her 3.3 hours of morning surveys at the project site likely represented 23.7% of the species to be detected after many more visual-scan surveys over another year or longer. With many more repeat surveys through the year, Noriko would likely detect 41 0.237⁄=173 species of vertebrate wildlife at the site. Assuming Noriko’s ratio of special-status to non-special-status species was to hold through the detections of all 111 predicted species, then continued surveys would eventually detect 46 special-status species of vertebrate wildlife. Figure 2. Mean (95% CI) predicted wildlife species richness, 𝑅̂, as a nonlinear function of hour-long survey increments across 46 visual-scan survey stations across the Altamont Pass Wind Resource Area, Alameda and Contra Costa Counties, 2015‒2019. Note that the location of the study is largely irrelevant to the utility of the graph to the interpretation of survey outcomes at the project site. It is the pattern in the data that is relevant, because the pattern is typical of the pattern seen elsewhere. Because my prediction of 173 species of vertebrate wildlife, including 46 special-status species of vertebrate wildlife, is derived from daytime visual-scan surveys, and would detect few nocturnal mammals such as bats, the true number of species composing the wildlife community of the site must be larger, and based on Noriko’s follow-up 0 20 40 60 80 100 0 10 20 30 40 50 Cumulative number of surveys (hours)(95% CI) 16 evening/nocturnal survey, we already know this is true. Noriko’s reconnaissance survey should serve only as a starting point toward characterization of the site’s wildlife community, but it certainly cannot alone inform of the inventory of species that use the site. More surveys are needed than her one survey to inventory use of the project site by wildlife. Nevertheless, the large number of species I predict at the project site is indicative of a relatively species-rich wildlife community that warrants a serious survey effort. EXISTING ENVIRONMENTAL SETTING The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status. A reasonably accurate characterization of the environmental setting can provide the basis for determining whether the site holds habitat value to wildlife, as well as a baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project site’s regional setting, is one of CEQA’s essential analytical steps. Methods to achieve this first step typically include (1) surveys of the site for biological resources, and (2) reviews of literature, databases and local experts for documented occurrences of special-status species. In the case of the proposed project, these required steps remain incomplete and misleading. Environmental Setting informed by Field Surveys To CEQA’s primary objective to disclose potential environmental impacts of a proposed project, the analysis should be informed of which biological species are known to occur at the proposed project site, which special-status species are likely to occur, as well as the limitations of the survey effort directed to the site. Analysts need this information to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources. Two biologists from Psomas performed a survey on the project site on 10 November 2022 to map vegetation and to detect plant and wildlife species (Psomas 2024). Psomas performed focused surveys for special-status plant species, California gnatcatcher, coastal cactus wren, and least Bell’s vireo and southwestern willow flycatcher. John Aguayo surveyed on the same dates for California gnatcatcher and coastal cactus wren. He did the same for least Bell’s vireo and southwestern willow flycatcher. One could question whether these were focused surveys for each of these bird species, but based on Mr. Aguayo’s overall survey findings, I think he was qualified to survey for all of these bird species in the manner he did. Compared to plant and wildlife surveys I have reviewed for hundreds of project sites, Psomas (2024) did an outstanding job. The surveys for California gnatcatcher, coastal cactus wren, least Bell’s vireo and southwestern willow flycatcher achieved the standards of the available detection survey protocols. Less consistent with the available survey protocol were the surveys for rare plants (Table 2). Psomas (2024) fails to mee the minimum standards of qualifications 17 and reporting, which I suspect are both failures of reporting. It is unclear from Psomas (2024) that the biologists who performed the surveys were qualified to do so. I assume they were qualified, but the reporting needs to demonstrate that. Although the survey effort by Psomas (2024) compares well against the survey efforts I have reviewed from hundreds of other project sites, there remain two important shortfalls. One shortfall is the lack of surveys in seasons other than spring and summer. The other is the lack of any surveys for bats and other nocturnal species, and no trapping for small mammals. The scope of surveys should have been broadened. Noriko’s surveys fill some but not all of the gaps in Psomas’s surveys, as she surveyed in September and at night. Noriko’s surveys combined with the surveys of Psomas (2024) bring the total number of vertebrate wildlife species detected on or adjacent to the project site to 74 (Table 3). Noriko’s surveys added 12 species of vertebrate wildlife to those detected by Psomas, and two of the species she added are special-status species. Four of the species she added are bats. That 74 species of vertebrate wildlife including 14 special-status species of wildlife have so far been detected by professional wildlife biologists on the project site is evidence that my prediction of at least 173 diurnally active vertebrate wildlife species on the site is not only plausible but probable. And yet, guessing at the number of bats, nocturnal birds, and small mammals that would not have been detected by visual-scan surveys, the number of species detected comprises only about a third of the number of species that rely on the project site. The project site remains under-surveyed for wildlife. More surveys are warranted. Also of note is that all three survey efforts – those of Psomas’s reconnaissance survey, Aguayo’s focused surveys, and Noriko’s September surveys – detected California gnatcatcher. That California gnatcatcher is consistently detected on the project site is indicative of this species being a substantial member of the local wildlife community. The project site is obviously important to California gnatcatcher. In fact, the entirety of the project area of 76.01 acres is Critical Habitat for California gnatcatcher. Environmental Setting informed by Desktop Review The purpose of literature and database review and of consulting with local experts is to inform the field survey, and to augment interpretation of its outcome. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special-status species could conceivably occur at the site due to geographic range overlap and migration flight paths. 18 Table 2. Crosscheck between the minimum standards of the CDFW (2018) rare plant survey protocol and the surveys performed by Psomas (2024). Standard in CDFW (2018) Assessment of surveys completed Was the standard met? Purpose and Timing to adequately disclose potential impacts pursuant to CEQA Qualifications Knowledge of plant taxonomy and natural community ecology No information provided No Familiarity with plants of the region, including special status plants No information provided No Familiarity with natural communities of region, including sensitive natural communities No information provided No Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards No information provided No Experience conducting floristic botanical field surveys as described in this document, or experience conducting such botanical field surveys under the direction of an experienced botanical field surveyor No information provided No Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting No information provided No Experience analyzing the impacts of projects on native plant species and sensitive natural communities No information provided No Survey Preparation Compile relevant botanical information in the general project area to provide a regional context, i.e., data base review, and to generally identify vegetation and habitat types potentially occurring in the project area based on biological and physical properties (e.g., soils) of the project area CNDDB query output Yes Develop list of special status plants and sensitive natural communities with potential to occur within the vegetation and habitat types identified (special status plants and sensitive natural communities in a project area may not be limited to those on the list) Yes Survey Design Survey extent should cover entire project area, including areas that will be directly or indirectly impacted by the project, and adjoining properties Yes 19 Use systematic field techniques, e.g., parallel transects, in all habitats of the project area to ensure thorough coverage Systematic survey in all suitable areas; no mention of transects Probably Survey at the times of year when plants will be both evident and identifiable, usually during flowering or fruiting Surveyed on 1 May and 5 June 2023 Yes Space (multiple) survey visits throughout the growing season to accurately determine what plants exist in the project area Only two surveys Partial When special status plants are known to occur in the type(s) of habitat present in a project area, observe reference sites to determine whether those plants are identifiable at the times of year the surveys take place; Describe reference site(s), if visited, and phenological development of special status plant(s) at those reference sites Three reference sites Yes Survey Methods Identify names and qualifications of botanical field surveyor(s) Names reported, but no qualifications Partial Dates of surveys (indicating the botanical field surveyor(s) that surveyed each area on each survey date) Dates reported Yes Total person-hours spent 23 person-hours Yes Discuss survey preparation methodology Yes List special status plants and sensitive natural communities with potential to occur in the region; identify all taxa to level necessary to determine whether they are special status Yes Describe and map the area surveyed relative to the project area Area survey not clearly demarked No Reporting Describe the proposed project Yes Discuss all adverse conditions in the botanical survey report No mention No Document all plant taxa observed Yes Detailed data and maps for all special status plants and sensitive natural communities detected Yes Report specific geographic locations where the special status plants and sensitive natural communities were found, usually via GPS Yes Site-specific characteristics of occurrences, such as associated species, habitat and microhabitat, structure of vegetation, topographic features, soil type, texture, and soil parent material. If in wetland, describe direction of flow and Yes 20 integrity of surface or subsurface hydrology and adjacent off-site hydrological influences as appropriate The number of individuals in each special status plant population as counted (if population is small) or estimated (if population is large) Yes Percentage of each special status plant in each life stage such as seedling, vegetative, flowering, and fruiting No Density of special status plants No Digital images of special status plants and sensitive natural communities in the project area, with diagnostic features No image of black walnut Partial Detailed map of the project area that identifies topographic and landscape features and includes a north arrow and bar scale Yes Vegetation map of project area using Survey of California Vegetation Classification and Mapping Standards at thematic and spatial scale that allows the display of all sensitive natural communities No Soil map of the project area Yes Describe biological setting, including all natural communities, geological and hydrological characteristics, and land use or management history Partial Discuss potential for a false negative botanical field survey No Discuss how climatic conditions may have affected survey results No Discuss how survey timing may affect comprehensiveness No List references used, including persons contacted and herbaria visited Yes 21 Table 3. Species of wildlife observed by Psomas’s reconnaissance survey, John Aguayo’s focused wildlife surveys, and Noriko Smallwood’s reconnaissance surveys. Common name Species name Status1 Psomas Aguayo NLS Western fence lizard Sceloporus occidentalis longipes X X Western side-blotched lizard Uta stansburiana elegans X X Mallard Anas platyrhynchos X California quail Callipepla californica X X X Rock pigeon Columba livia Non-native X Band-tailed pigeon Patagioenas fasciata X Eurasian collared-dove Streptopelia decaocto Non-native X Mourning dove Zenaida macroura X X X Greater roadrunner Geococcyx californianus X White-throated swift Aeronautes saxatalis X Black-chinned hummingbird Archilochus alexandri X Anna’s hummingbird Calypte anna X X X Allen’s hummingbird Selasphorus sasin BCC X X Great egret Ardea alba X Turkey vulture Cathartes aura BOP X X X Cooper’s hawk Accipiter cooperii TWL, BOP X X Red-shouldered hawk Buteo lineatus BOP X X Red-tailed hawk Buteo jamaicensis BOP X X X Western screech-owl Megascops kennicotti BOP X Acorn woodpecker Melanerpes formicivorus X X Downy woodpecker Dryobates pubescens X Nuttall’s woodpecker Picoides nuttallii BCC X X X Northern flicker Colaptes auratus X American kestrel Falco sparverius BOP X X Red-crowned parrot Amazona viridigenalis X Ash-throated flycatcher Myiarchus cinerascens X X Cassin’s kingbird Tyrannus vociferans X X X Western flycatcher Lonchura punctulata X Black phoebe Sayornis nigricans X X X Say’s phoebe Sayornis saya X X 22 California scrub-jay Aphelocoma californica X X X American crow Corvus brachyrhynchos X X X Common raven Corvus corax X X X Oak titmouse Baeolophus inornatus BCC X X Northern rough-winged swallow Stelgidopteryx serripennis X Barn swallow Hirundo rustica X X Cliff swallow Petrochelidon pyrrhonota X Bushtit Psaltriparus minimus X X X Wrentit Chamaea fasciata BCC X X X Phainopepla Phainopepla nitens X Blue-gray gnatcatcher Polioptila caerulea X X X California gnatcatcher Polioptila c. californica FT, SSC2 X X X Bewick’s wren Thryomanes bewickii X X X House wren Troglodytes aedon X California thrasher Toxostoma redivivum BCC X X X Northern mockingbird Mimus polyglottos X Western bluebird Sialia mexicana X American robin Turdus migratorius X House finch Haemorphous mexicanus X X X Lesser goldfinch Spinus psaltria X X X Song sparrow Melospiza melodia X X X California towhee Melozone crissalis X X X Spotted towhee Pipilo maculatus X X X Hooded oriole Icterus cucullatus X Bullock’s oriole Icterus bullockii BCC X Brown-headed cowbird Molothrus ater X Brewer’s blackbird Euphagus cyanocephalus X Orange-crowned warbler Oreothlypis celata X Nashville warbler Leiothlypis ruficapilla X Common yellowthroat Geothlypis trichas X Yellow-rumped warbler Setophaga coronata X X Wilson’s warbler Cardellina pusilla X Black-headed grosbeak Pheucticus melanocephalus X 23 Canyon bat Parastrellus hesperus WBWG:L X Big brown bat Episticus fuscus WBWG:L X Silver-haired bat Lasionycteris noctivagans WBWG:M X Mexican free-tailed bat Tadarida brasiliensis WBWG:L X Desert cottontail Sylvilagus audubonii X X X Eastern fox squirrel Sciurus niger Non-native X X California ground squirrel Otospermophilus beecheyi X X X Raccoon Procyon lotor X Coyote Canis latrans X X X Striped skunk Mephitis mephitis X Botta’s pocket gopher Thomomys bottae X 1 Listed as FT or FE = federal threatened or endangered, CT or CE = California threatened or endangered, CFP = California Fully Protected (CFG Code 3511), SSC = California Species of Special Concern, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, TWL = Taxa to Watch List (Shuford and Gardali 2008), BOP = Birds of Prey (California Fish and Game Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H). 24 As noted above, the combined survey efforts of Psomas and Noriko Smallwood detected 74 species of vertebrate wildlife. I commented that more surveys are warranted, as more surveys would reveal more species of wildlife making use of habitat on the project site. It turns out that more surveys had already been completed in support of the previously proposed Deer Canyon Estates Project on the same site. According to Psomas (2024), “Results of these surveys have been incorporated into this report, as appropriate based on accepted industry standards and protocols.” Psomas (2024) cited BonTerra Consulting (2005) and RBF Consulting (2002) as the reports of the earlier surveys, and also reported that these reports are available on CEQAnet for SCH No. 2004021044. However, these reports are not available on CEQAnet, and I was unable to obtain them. Also, Psomas (2024) should have explained the accepted industry standards and protocols it claimed to have used for incorporating the results of past surveys into its report. It is unclear which standards or protocols would apply. In sum and substance, I did not see any evidence that the results of previous surveys were incorporated into Psomas’s report. Had the results of those earlier surveys been incorporated, the list of wildlife species detected on site would be longer. Psomas (2024) did not reportedly review eBird (https://eBird.org) or iNaturalist (https://www.inaturalist.org) for documented occurrence records at or near the project site. Instead, Psomas (2024) queried the California Natural Diversity Data Base (CNDDB) for documented occurrences of special-status species within four CNDDB quadrangles. By doing so, Psomas (2024) screened out many special-status species from further consideration in the characterization of the wildlife community as part of the existing environmental setting. CNDDB is not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community. As noted by the CNDDB, “The CNDDB is a positive sighting database. It does not predict where something may be found. We map occurrences only where we have documentation that the species was found at the site. There are many areas of the state where no surveys have been conducted and therefore there is nothing on the map. That does not mean that there are no special status species present.” Psomas (2024) misuses CNDDB. The CNDDB relies entirely on volunteer reporting from biologists who were allowed access to whatever properties they report from. Many properties have never been surveyed by biologists. Many properties have been surveyed, but the survey outcomes never reported to the CNDDB. Many properties have been surveyed multiple times, but not all survey outcomes reported to the CNDDB. Furthermore, the CNDDB is interested only in the findings of special-status species, which means that species more recently assigned special status will have been reported many fewer times to CNDDB than were species assigned special status since the inception of the CNDDB. The lack of many CNDDB records for species recently assigned special status had nothing to do with whether the species’ geographic ranges overlapped the project site, but rather more to do with the brief time for records to have accumulated since the species were assigned special status. And because negative findings are not reported to the CNDDB, the CNDDB cannot provide the basis for estimating occurrence likelihoods, either. 25 In my assessment based on database reviews and site visits, 131 special-status species of wildlife are known to occur near enough to the site to warrant analysis of occurrence potential (Table 4). Of these 131 species, 26 (20%) were recorded on the project site, and another 43 (33%) species have been documented within 1.5 miles of the site (‘Very close’), another 20 (15%) within 1.5 and 4 miles (‘Nearby’), and another 30 (23%) within 4 to 30 miles (‘In region’). More than two-thirds (69%) of the species in Table 4 have been reportedly seen within 4 miles of the project site. The site therefore supports multiple special-status species of wildlife and carries the potential for supporting many more special-status species of wildlife based on proximity of recorded occurrences. The site is far richer in special-status species than is characterized in Psomas (2024). Only 52 (40%) of the species in Table 4 are analyzed for occurrence potential in Psomas (2024), having omitted from its analysis 79 (60%) of the species in Table 4. Of the 52 species Psomas analyzes for occurrence potential, Psomas reports three were observed and one is expected to occur, but Psomas determines 30 may occur, six have limited potential, and 12 are not expected. Of the 30 species that reportedly may occur, four have been documented on site, 10 have been reported within 1.5 miles, and six have been reported between 1.5 and 4 miles from the site. Of the six species determined to have limited potential (whatever limited means), one has been reported within 1.5 miles and four have been reported between 1.5 and four miles from the site. Of the 12 species not expected to occur, two have been reported on site by online databases, four have been recorded within 1.5 miles, and one between 1.5 and 4 miles of the site. Therefore, on the whole, Psomas’s (2024) analyses of occurrence likelihoods comport poorly with occurrence records. Of the species omitted from Psomas’s analysis, 17 (22%) have been recorded on or just next to the project site, 28 (35%) have been recorded within 1.5 miles of the site, 9 (11%) have been recorded between 1.5 and 4 miles of the site, and 19 (24%) have been recorded between 4 and 30 miles of the site. The omissions hide too many cases of special-status species that have been documented on the site or that have relatively high likelihoods of occurrence due to the proximity of their occurrence records. And found on the survey site by Noriko were multiple special-status species left out of Psomas’s analysis, as well as a species Psomas determines absent from the site. Again, the site is richer in special-status species than Psomas (2024) reports. 26 Table 4. Occurrence likelihoods of special-status bird species at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings, where ‘Very close’ indicates within 1.5 miles of the site, “nearby” indicates within 1.5 and 4 miles, and “in region” indicates within 4 and 30 miles , and ‘in range’ means the species’ geographic range overlaps the site. Entries in bold font identify species detected by Noriko. Common name Species name Status1 Covered by NCCP, HCP DEIR occurrence potentials Data base records, Site visits Monarch Danaus plexippus FC Not expected Very close Quino checkerspot butterfly Euphydryas editha quino FE Not expected In range Crotch’s bumble bee Bombus crotchii CCE May occur Very close Coast Range newt Taricha torosa SSC May occur In region Western spadefoot Spea hammondii SSC May occur Nearby Arroyo toad Anaxyrus californicus FE, SSC Not expected In region Western pond turtle Emys marmorata SSC Not expected Nearby Blainville’s horned lizard Phrynosoma blainvillii SSC Yes May occur Nearby Orange-throated whiptail Aspidoscelis hyperythra WL Yes Observed On site Coastal whiptail Aspidoscelis tigris stejnegeri SSC Yes Expected On site San Diegan legless lizard Anniella stebbinsi SSC May occur Nearby California glossy snake Arizona elegans occidentalis SSC May occur In region Coast patch-nosed snake Salvadora hexalepis virgultea SSC May occur In region Two-striped gartersnake Thamnophis hammondii SSC May occur Nearby South coast gartersnake Thamnophis sirtalis pop. 1 SSC Not expected In region Red-diamond rattlesnake Crotalus ruber SSC Yes May occur Very close Fulvous whistling-duck Dendrocygna bicolor SSC1 In region Brant Branta bernicla SSC2 In region Cackling goose (Aleutian) Branta hutchinsii leucopareia WL Very close Redhead Aythya americana SSC2 Very close Western grebe Aechmophorus occidentalis BCC Very close Clark’s grebe Aechmophorus clarkii BCC Very close Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, BCC Not expected Very close Black swift Cypseloides niger SSC3, BCC In region 27 Common name Species name Status1 Covered by NCCP, HCP DEIR occurrence potentials Data base records, Site visits Vaux’s swift Chaetura vauxi SSC2, BCC Very close Costa’s hummingbird Calypte costae BCC Very close Rufous hummingbird Selasphorus rufus BCC On site Allen’s hummingbird Selasphorus sasin BCC On site American avocet2 Recurvirostra americana BCC Very close Mountain plover Charadrius montanus SSC2, BCC In region Snowy plover Charadrius nivosus BCC Nearby Western snowy plover Charadrius nivosus nivosus FT, SSC, BCC In region Whimbrel2 Numenius phaeopus BCC Very close Long-billed curlew Numenius americanus WL Very close Marbled godwit Limosa fedoa BCC Very close Red knot (Pacific) Calidris canutus BCC In region Short-billed dowitcher Limnodromus griseus BCC Nearby Willet Tringa semipalmata BCC Very close Laughing gull Leucophaeus atricilla WL In region Heermann’s gull Larus heermanni BCC In region Western gull Larus occidentalis BCC Very close California gull Larus californicus BCC, WL Very close California least tern Sternula antillarum browni FE, CE, FP Not expected Very close Gull-billed tern Gelochelidon nilotica BCC, SSC3 In region Black tern Chlidonias niger SSC2, BCC Nearby Elegant tern Thalasseus elegans BCC, WL In region Black skimmer Rynchops niger BCC, SSC3 Very close Common loon Gavia immer SSC Very close Double-crested cormorant Phalacrocorax auritus WL On site American white pelican Pelacanus erythrorhynchos SSC1, BCC On site California brown pelican Pelecanus occidentalis californicus FP In region Least bittern Ixobrychus exilis SSC2 Very close White-faced ibis Plegadis chihi WL Very close 28 Common name Species name Status1 Covered by NCCP, HCP DEIR occurrence potentials Data base records, Site visits Turkey vulture Cathartes aura BOP On site Osprey Pandion haliaetus WL, BOP Very close White-tailed kite Elanus luecurus CFP, BOP May occur Very close Golden eagle Aquila chrysaetos BGEPA, CFP, BOP, WL May occur Very close Northern harrier Circus cyaneus BCC, SSC3, BOP Yes May occur On site Sharp-shinned hawk Accipiter striatus WL, BOP Yes May occur On site Cooper’s hawk Accipiter cooperii WL, BOP Observed On site Bald eagle Haliaeetus leucocephalus CE, BGEPA, BOP May occur Very close Red-shouldered hawk Buteo lineatus BOP Yes On site Swainson’s hawk Buteo swainsoni CT, BOP Very close Red-tailed hawk Buteo jamaicensis BOP On site Ferruginous hawk Buteo regalis WL, BOP Limited potential Nearby Zone-tailed hawk Buteo albonotatus BOP Very close Harris’ hawk Parabuteo unicinctus WL, BOP Nearby Rough-legged hawk Buteo lagopus BOP Yes In region Barn owl Tyto alba BOP Very close Western screech-owl Megascops kennicotti BOP On site Great horned owl Bubo virginianus BOP Very close Burrowing owl Athene cunicularia BCC, SSC2, BOP Limited potential Nearby Long-eared owl Asio otus BCC, SSC3, BOP Limited potential In region Short-eared owl Asia flammeus BCC, SSC3, BOP In region Lewis’s woodpecker Melanerpes lewis BCC Nearby Nuttall’s woodpecker Picoides nuttallii BCC On site American kestrel Falco sparverius BOP On site, Just off site Merlin Falco columbarius WL, BOP May occur Very close Peregrine falcon Falco peregrinus BOP Yes Limited potential Very close Prairie falcon Falco mexicanus WL, BOP May occur Very close Olive-sided flycatcher Contopus cooperi BCC, SSC2 On site 29 Common name Species name Status1 Covered by NCCP, HCP DEIR occurrence potentials Data base records, Site visits Willow flycatcher Empidonax trailii CE Very close Southwestern willow flycatcher Empidonax traillii extimus FE, CE Not expected In region Vermilion flycatcher Pyrocephalus rubinus SSC2 Very close Least Bell’s vireo Vireo bellii pusillus FE, CE Not expected On site Loggerhead shrike Lanius ludovicianus SSC2 May occur Very close Oak titmouse Baeolophus inornatus BCC On site, Just off site California horned lark Eremophila alpestris actia WL Limited potential Nearby Bank swallow Riparia riparia CT Very close Purple martin Progne subis SSC2 Nearby Wrentit Chamaea fasciata BCC On site, Just off site California gnatcatcher Polioptila c. californica FT, SSC2 Yes Observed On site Coastal cactus wren Campylorhynchus brunneicapillus sandiegensis SSC1, BCC Not expected On site California thrasher Toxostoma redivivum BCC On site Cassin’s finch Haemorhous cassinii BCC In region Lawrence’s goldfinch Spinus lawrencei BCC On site Grasshopper sparrow Ammodramus savannarum SSC2 Limited potential Nearby Black-chinned sparrow Spizella atrogularis BCC Very close Gray-headed junco Junco hyemalis caniceps WL Nearby Bell’s sparrow Amphispiza b. belli WL May occur Very close Oregon vesper sparrow Pooecetes gramineus affinis SSC2, BCC In range Southern California rufous- crowned sparrow Aimophila ruficeps canescens WL Yes May occur On site Yellow-breasted chat Icteria virens SSC3 May occur Very close Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 Very close Bullock’s oriole Icterus bullockii BCC On site 30 Common name Species name Status1 Covered by NCCP, HCP DEIR occurrence potentials Data base records, Site visits Tricolored blackbird Agelaius tricolor CT, BCC, SSC1 Not expected Very close Lucy’s warbler Leiothlypis luciae SSC3, BCC Nearby Virginia’s warbler Leiothlypis virginiae WL, BCC In region Yellow warbler Setophaga petechia SSC2 May occur On site Summer tanager Piranga rubra SSC1 Nearby Pallid bat Antrozous pallidus SSC, WBWG:H May occur In range Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG:H May occur In region Silver-haired bat Lasionycteris noctivagans WBWG:M On site Spotted bat Euderma maculatum SSC, WBWG:H In range Hoary bat Lasiurus cinereus WBWG:M Very close Western yellow bat Lasiurus xanthinus SSC, WBWG:H May occur In region Western small-footed myotis Myotis cililabrum WBWG:M In range Miller’s myotis Myotis evotis WBWG:M In region Little brown myotis Myotis lucifugus WBWG:M In region Fringed myotis Myotis thysanodes WBWG:H In range Long-legged myotis Myotis volans WBWG:H In range Yuma myotis Myotis yumanensis WBWG:LM In region Western mastiff bat Eumops perotis SSC, WBWG:H May occur In region Pocketed free-tailed bat Nyctinomops femorosaccus SSC, WBWG:M May occur In range San Diego black-tailed jackrabbit Lepus californicus bennettii SSC In region Northwestern San Diego pocket mouse Chaetodipus fallax fallax SSC May occur In region Los Angeles pocket mouse Perognathus longimembris brevinasus SSC In range San Diego desert woodrat Neotoma lepida intermedia SSC Yes May occur Nearby Southern grasshopper mouse Onychomys torridus ramona SSC Not expected In range American badger Taxidea taxus SSC May occur In region Mountain lion Puma concolor CCT May occur Nearby 31 1 Listed as FT or FE = federal threatened or endangered, FC = federal candidate for listing, BCC = U.S. Fish and Wildlife Servi ce Bird of Conservation Concern, CT or CE = California threatened or endangered, CCT or CCE = Candidate California threatened or endangered, CFP = California Fully Protected (California Fish and Game Code 3511), SSC = California Species of Special Concern (not threatened with extinction, but rare, very restricted in range, declining throughout range, peripheral portion of species' range, associated with habitat that is declining in extent), SSC1, SSC2 and SSC3 = California Bird Species of Special Concern priori ties 1, 2 and 3, respectively (Shuford and Gardali 2008), WL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (CFG Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low (L), moderate (M), and high (H). 2 Uncertain if BCC based on 2021 Bird of Conservation Concern list. 32 POTENTIAL BIOLOGICAL IMPACTS An impacts analysis should consider whether and how a proposed project would affect members of a species, larger demographic units of the species, the whole of a species, and ecological communities. The accuracy of this analysis depends on an accurate characterization of the existing environmental setting. In the case of the proposed project, the existing environmental setting has not been accurately characterized, and several important types of potential project impacts have been inadequately analyzed. These types of impacts include habitat loss, interference with wildlife movement, bird- window collision mortality, and wildlife-automobile collision mortality. HABITAT LOSS Habitat loss not only results in the immediate numerical decline of wildlife, but it also results in permanent loss of productive capacity. Habitat fragmentation multiplies the negative effects of habitat loss on the productive capacities of biological species (Smallwood 2015). However, instead of analyzing this type of impact with any rigor, Psomas (2024) speculates the “loss of wildlife habitat would be considered limited in relation to the total amount of wildlife habitat available in the BSA region.” Psomas fails to explain what it means by limited, but the acreage of direct impacts would be 44.09 acres, and indirect impacts would extend to even greater acreages of what already composes a habitat fragment on a landscape where habitat has been severely fragmented. Even with its report of 44.09 acres of direct impacts, Psomas (2024) makes no attempt to estimate the loss of numerical or productive capacities of any of the wildlife species potentially affected. Density estimates are available to predict reductions of numerical capacity. In the case of birds, two methods exist for estimating the loss of productive capacity that would result from habitat loss of 44.09 acres. One method would involve surveys to count the number of bird nests and chicks produced. The alternative method would be to infer productive capacity from estimates of total nest density elsewhere. Several studies have estimated total avian nest density at locations that had likewise been highly fragmented. Two study sites in grassland/wetland/woodland complexes within agricultural matrices had total bird nesting densities of 32.8 and 35.8 nests per acre (Young 1948, Yahner 1982) for an average 34.3 nests per acre. To acquire a total nest density closer to conditions in California, Noriko and I surveyed various patches of vegetation cover in northern and southern California throughout the breeding seasons of 2023 and 2024 (Table 5). Applying the means of these estimates to the 44.09 acres of vegetation cover that would be lost to the project would predict 191 nest sites would be destroyed. Assuming 1.39 broods per nest site, which is the average among 322 North American bird species I asked Noriko to review, then I predict the project would cost California 265 nest attempts/year. 33 Table 5. Estimates of nest sites per acre at California sites studied by me (KSS) and Noriko (NS) multiplied against Psomas’s reported acreages that would be lost to the project. Vegetation cover Source Nest sites/acre Acres of direct take Predicted nest sites Riparian and woodland Mean of 3 riparian forest sites outside urban areas, one studies by KSS in Rancho Cordova, two studied by NS in San Jacinto and Murrieta, 2023 2024 19.89 0.88 17.5 Scrub & chapparal Mean of two NS sites, one in Murrieta and one in Cleveland National Forest, 2023 1.82 29.08 52.9 Grassland & marsh Mean of three sites, one studied by KSS east of Davis, and two studied by NS in Murrieta, 2024 3.84 10.32 39.6 Parks and ornamentals KSS hedges and edge between urban and walnuts in Rancho Cordova, 2023 21.25 3.81 81.0 Total 44.09 191.0 The loss of 191 nest sites and 265 nest attempts per year would qualify as significant impacts that have not been analyzed by the City. But the impacts would not end with the immediate loss of nest sites. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young’s (1948) study was 2.9. Assuming Young’s (1948) study site typifies bird productivity, the project would prevent the production of 769 fledglings per year. Assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production can be estimated from an equation in Smallwood (2022): {(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number of years ÷ years/generation)} ÷ (number of years) = 845 birds per year denied to California. The loss of 845 birds per year would be a substantial loss of birds, the vast majority of which are protected by the federal Migratory Bird Treaty Act and by California’s Migratory Bird Protection Act. Many of these birds would be special-status species such as Cooper’s hawks and California thrashers, and some would be threatened or endangered species such as California gnatcatcher. INTERFERENCE WITH WILDLIFE MOVEMENT One of CEQA’s principal concerns regarding potential project impacts is whether a proposed project would interfere with wildlife movement in the region. Unfortunately, while I agree with much of Psomas’s characterization of the corridor concept, I must point out that Psomas (2024) focuses too much on whether corridors exist on the project site or whether the project site exists within a movement corridor. Whether the site functions as a wildlife movement corridor or is located within a corridor is not the only consideration when it comes to the standard CEQA Checklist question of whether the project would interfere with wildlife movement in the region. The primary phrase of 34 the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. Habitat loss and habitat fragmentation have been removing avian stopover and staging opportunities from the area, and blocking movement pathways for non-volant wildlife. As this process has progressed, the project site has become all the more important to wildlife movement in the region, as few opportunities for stopover and staging remain. Many of the species detected by Psomas and by Noriko would not have occurred at the project site if it was not for their ability to rely on the project site for movement. Psomas (2024:63) concludes that the project site does occur within a movement corridor, but downplays the project’s interference with wildlife movement within the corridor by claiming “The Project’s impact area is located at the terminus of the continuous open space … therefore, it would not disrupt wildlife movement along the corridor, but it would truncate the open space.” Lost in this analysis is the result that wildlife would no longer be capable of moving within the truncated space. In other words, the project would interfere with wildlife movement in the region. Psomas (2024:63) further concludes, “while the Project’s impacts on wildlife movement would be adverse, they would be less than significant because the Project would not substantially change or disrupt wildlife movement along the wildlife corridor.” However, Psomas cannot have it both ways. The project impacts cannot be both adverse to wildlife movement and not substantially disrupt wildlife movement. The project would in fact eliminate a sizable portion of the existing riparian environment. Riparian environments are one of the few widely-recognized corridors in natural settings, forming a backbone of wildlife movement in the area (Andy 2020). Moreover, Psomas’s conclusions regarding whether the site functions as a corridor or is located within a corridor, or whether the project would not substantially disrupt wildlife movement, lack supporting evidence. Psomas (2024) reports no survey methodology designed to determine whether and how wildlife rely on the site for movement in the region. There was no sampling regime. There was no program of observation to record wildlife movement patterns, nor to quantify them or to qualitatively assess them. Based on what is reported, Psomas (2024) did not record or measure wildlife movement in any way. The conclusions of Psomas (2024) regarding wildlife movement on the project site are speculative and conclusory, and short on logical flow. TRAFFIC IMPACTS TO WILDLIFE Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic to get to and from the project site (Photos 31―33), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife (Forman et al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year (Bishop and Brogan 2013), and the US estimate of avian mortality 35 on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al. 2014). Local impacts can be more intense than nationally. The nearest study of traffic-caused wildlife mortality was performed along a 2.5-mile stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find (or not find) during their routine periodic fatality searches. This step was not taken at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study next to Vasco Road (Brown et al. 2016). Brown et al.’s (2016) adjustment factors for carcass persistence resembled those of Santos et al. (2011). Also applying searcher detection rates from Brown et al. (2016), the adjusted total number of fatalities was estimated at 12,187 animals killed by traffic on the road. This fatality number over 1.25 years and 2.5 miles of road translates to 3,900 wild animals per mile per year. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. (2009) study would translate to 243,740 animals killed per 100 km of road per year, or 29 times that of Loss et al.’s (2014) upper bound estimate and 68 times the Canadian estimate. An analysis is needed of whether increased traffic generated by the project site would similarly result in local impacts on wildlife. Photo 31. A Gambel’s quail dashes across a road on 3 April 2021. Such road crossings are usually successful, but too often prove fatal to the animal. Photo by Noriko Smallwood. Photo 32. Mourning dove killed by vehicle on a California road. Photo by Noriko Smallwood, 21 June 2020. 36 Photo 33. Raccoon killed on Road 31 just east of Highway 505 in Solano County. Photo taken on 10 November 2018. For wildlife vulnerable to front-end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. (2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data resulted in an estimated 3,900 animals killed per mile along a county road in Contra Costa County. Two percent of the estimated number of fatalities were birds, and the balance was composed of 34% mammals (many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others), 52.3% amphibians (large numbers of California tiger salamanders and California red-legged frogs, but also Sierran treefrogs, western toads, arboreal salamanders, slender salamanders and others), and 11.7% reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. (2009), hence enabling a rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates. Predicting project-generated traffic impacts to wildlife The DEIR predicts 69,624.25 daily VMT, which projected to the year would predict 25,412,851 annual VMT. During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non- volant fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years = 22,242,187.5 vehicle miles per 12,187 wildlife fatalities, or 1,825 vehicle miles per fatality. This rate divided into the predicted annual VMT would predict 13,925 vertebrate wildlife fatalities per year. Based on my analysis, the project-generated traffic would cause substantial, significant impacts to wildlife. The DEIR does not analyze this potential impact, nor does it propose to mitigate it. Mitigation measures to improve wildlife safety along roads are available and are feasible, and they need exploration for their suitability with the proposed project. Given the predicted level of project-generated, traffic-caused mortality, and the lack of any proposed mitigation, it is my opinion that the proposed project would result in potentially significant adverse biological impacts. 37 BIRD-WINDOW COLLISIONS The project would add 504 residential units, two restaurants and a coffee shop to open space that is currently habitat to many birds. These new residences would present glass windows to birds attempting to use an essential portion of their habitat – that portion of the gaseous atmosphere that is referred to as the aerosphere (Davy et al. 2017, Diehl et al. 2017). The aerosphere is where birds and bats and other volant animals with wings migrate, disperse, forage, perform courtship and where some of them mate. Birds are some of the many types of animals that evolved wings as a morphological adaptation to thrive by moving through the medium of the aerosphere. The aerosphere is habitat. Indeed, an entire discipline of ecology has emerged to study this essential aspect of habitat – the discipline of aeroecology (Kunz et al. 2008). The project would add a 7-story, 99.5-foot-tall multi-family building with many glass windows. The renderings of the building depict the glass as transparent – One of two qualities of glass known to increase the risk of lethal bird-window collisions (the other quality being reflectivity). The renderings depict deep interior spaces on the building’s north and south ends, and these spaces would be surrounded by glass windows. Birds entering these interior spaces are known to panic and to collide with windows. The renderings also depict glass panels bordering the pool deck, representative of another factor known to contribute to bird-window collision mortality. The renderings also depict vegetation growing on and very close to the building, which is another recognized factor that contributes to bird-window collision mortality. Despite all these previews of a bird-window collision problem, the DEIR gives it little attention in one small paragraph. Many special-status species of birds have been recorded at or near the aerosphere of the project site. My database review and Noriko’s and Psomas’s site visits indicate there are 93 special-status species of birds with potential to use the site’s aerosphere (Table 4). All of the birds represented in Table 4 can quickly fly from wherever they have been documented to the project site, and many are already on the project site, so they would all be within brief flights to the proposed project’s windows. At the California Academy of Sciences, the glass facades facing adjacent gardens killed 0.077 and 0.086 birds per m2 of glass per year (Kahle et al. 2016), which might not look like large numbers at first read, but which translate to large numbers of dead birds when projected to the extent of glass on the project (see below). This study also documented many Allen’s hummingbird collisions as well, which is significant to the project because Noriko observed Allen’s hummingbird on the site. Window collisions are often characterized as either the second or third largest source or human-caused bird mortality. The numbers behind these characterizations are often attributed to Klem’s (1990) and Dunn’s (1993) estimates of about 100 million to 1 billion bird fatalities in the USA, or more recently by Loss et al.’s (2014) estimate of 365 -988 million bird fatalities in the USA or Calvert et al.’s (2013) and Machtans et al.’s (2013) estimates of 22.4 million and 25 million bird fatalities in Canada, respectively. The proposed project would impose windows in the airspace normally used by birds. 38 Glass-façades of buildings intercept and kill many birds, but are differentially hazardous to birds based on spatial extent, contiguity, orientation, and other factors. At Washington State University, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a three-story glass walkway (no fatality adjustments attempted). Prior to marking the windows to warn birds of the collision hazard, the collision rate was 84.7 per year. At that rate, and not attempting to adjust the fatality estimate for the proportion of fatalities not found, 4,574 birds were likely killed over the 54 years since the start of their study, and that’s at a relatively small building façade. Accounting for the proportion of fatalities not found, t he number of birds killed by this walkway over the last 54 years would have been about 14,270. And this is just for one 3-story, glass-sided walkway between two college campus buildings. Klem’s (1990) estimate was based on speculation that 1 to 10 birds are killed per building per year, and this speculated range was extended to the number of buildings estimated by the US Census Bureau in 1986. Klem’s speculation was supported by fatality monitoring at only two houses, one in Illinois and the other in New York. Also, the basis of his fatality rate extension has changed greatly since 1986. Whereas his estimate served the need to alert the public of the possible magnitude of the bird- window collision issue, it was highly uncertain at the time and undoubtedly outdated more than three decades hence. Indeed, by 2010 Klem (2010) characterized the upper end of his estimated range – 1 billion bird fatalities – as conservative. Furthermore, the estimate lumped species together as if all birds are the same and the loss of all birds to windows has the same level of impact. By the time Loss et al. (2014) performed their effort to estimate annual USA bird- window fatalities, many more fatality monitoring studies had been reported or were underway. Loss et al. (2014) incorporated many more fatality rates based on scientific monitoring, and they were more careful about which fatality rates to include. However, they included estimates based on fatality monitoring by homeowners, which in one study were found to detect only 38% of the available window fatalities (Bracey et al. 2016). Loss et al. (2014) excluded all fatality records lacking a dead bird in hand, such as injured birds or feather or blood spots on windows. Loss et al.’s (2014) fatality metric was the number of fatalities per building (where in this context a building can include a house, low-rise, or high-rise structure), but they assumed that this metric was based on window collisions. Because most of the bird-window collision studies were limited to migration seasons, Loss et al. (2014) developed an admittedly assumption-laden correction factor for making annual estimates. Also, only 2 of the studies included adjustments for carcass persistence and searcher detection error, and it was unclear how and to what degree fatality rates were adjusted for these factors. Although Loss et al. (2014) attempted to account for some biases as well as for large sources of uncertainty mostly resulting from an opportunistic rather than systematic sampling data source, their estimated annual fatality rate across the USA was highly uncertain and vulnerable to multiple biases, most of which would have resulted in fatality estimates biased low. In my review of bird-window collision monitoring, I found that the search radius around homes and buildings was very narrow, usually 2 meters. Based on my experience with bird collisions in other contexts, I would expect that a large portion of bird-window 39 collision victims would end up farther than 2 m from the windows, especially when the windows are higher up on tall buildings. In my experience, searcher detection rates tend to be low for small birds deposited on ground with vegetation cover or woodchips or other types of organic matter. Also, vertebrate scavengers entrain on anthropogenic sources of mortality and quickly remove many of the carcasses, thereby preventing the fatality searcher from detecting these fatalities. Adjusting fatality rates for these factors – search radius bias, searcher detection error, and carcass persistence rates – would greatly increase nationwide estimates of bird-window collision fatalities. Buildings can intercept many nocturnal migrants as well as birds flying in daylight. As mentioned above, Johnson and Hudson (1976) found 266 bird fatalities of 41 species within 73 months of monitoring of a four-story glass walkway at Washington State University (no adjustments attempted for undetected fatalities). Somerlot (2003) found 21 bird fatalities among 13 buildings on a university campus within only 61 days. Monitoring twice per week, Hager at al. (2008) found 215 bird fatalities of 48 species, or 55 birds/building/year, and at another site they found 142 bird fatalities of 37 species for 24 birds/building/year. Gelb and Delacretaz (2009) recorded 5,400 bird fatalities under buildings in New York City, based on a decade of monitoring only during migration periods, and some of the high-rises were associated with hundreds of fatalities each. Klem et al. (2009) monitored 73 building façades in New York City during 114 days of two migratory periods, tallying 549 collision victims, nearly 5 birds per day. Borden et al. (2010) surveyed a 1.8 km route 3 times per week during 12-month period and found 271 bird fatalities of 50 species. Parkins et al. (2015) found 35 bird fatalities of 16 species within only 45 days of monitoring under 4 building façades. From 24 days of survey over a 48-day span, Porter and Huang (2015) found 47 fatalities under 8 buildings on a university campus. Sabo et al. (2016) found 27 bird fatalities over 61 days of searches under 31 windows. In San Francisco, Kahle et al. (2016) found 355 collision victims within 1,762 days under a 5-story building. Ocampo-Peñuela et al. (2016) searched the perimeters of 6 buildings on a university campus, finding 86 fatalities after 63 days of surveys. One of these buildings produced 61 of the 86 fatalities, and another building with collision-deterrent glass caused only 2 of the fatalities, thereby indicating a wide range in impacts likely influenced by various factors. There is ample evidence available to support my prediction that the proposed project would result in many collision fatalities of birds. Project Impact Prediction By the time of these comments, I had reviewed and processed results of bird collision monitoring at 213 buildings and façades for which bird collisions per m2 of glass per year could be calculated and averaged (Johnson and Hudson 1976, O’Connell 2001, Somerlot 2003, Hager et al. 2008, Borden et al. 2010, Hager et al. 2013, Porter and Huang 2015, Parkins et al. 2015, Kahle et al. 2016, Ocampo-Peñuela et al. 2016, Sabo et al. 2016, Barton et al. 2017, Gomez-Moreno et al. 2018, Schneider et al. 2018, Loss et al. 2019, Brown et al. 2020, City of Portland Bureau of Environmental Services and Portland Audubon 2020, Riding et al. 2020). These study results averaged 0.073 bird deaths per m2 of glass per year (95% CI: 0.042-0.102). This average and its 95% 40 confidence interval provide a robust basis for predicting fatality rates at a proposed new project. Based on the renderings of the proposed multi-family building, I measured window and extents to estimate the building would expose birds to 14,355 m2 of exterior glass. The two commercial buildings would expose birds to an estimated 2,986 m2 of exterior glass. The six single-family units would be large, so I conservatively assume the exterior glass would be double the average 27 m2 typical of homes built 20 and 30 years ago, totaling 324 m2 among all six homes. The total exterior glass in the project would be about 17,655 m2. Applying the mean fatality rate (above) to my estimate of 17,655 m2 of window and fence glass in the project, I predict annual bird deaths of 1,291 (95% CI: 766‒1,815). Relying on the mean fatality rates from the closest building studied for bird- window collision mortality, the fatality rate at the California Academy of Sciences would predict a mean fatality rate of 1,359 to 1,518 birds per year. The vast majority of these predicted deaths would be of birds protected under the Migratory Bird Treaty Act and under the California Migratory Bird Protection Act, thus causing significant impacts even with the implementation of established mitigation measures. Even if the efficacy of a proposed mitigation measure was to prevent 90% of the predicted mortality, annual bird-window collision mortality would still average 129 birds based on the national mean, and 136 to 152 birds based on the study at the California Academy of Sciences building. Given the predicted level of bird-window collision mortality, it is my opinion that the proposed project would result in potentially significant adverse biological impacts, including the take of both terrestrial and aerial habitat of birds and other sensitive species. Not only would the project take habitat of rare and sensitive species of birds, but it would transform the building’s airspace into a lethal collision trap to birds. INTERFERENCE WITH HCP/NCCP The project site is located within the Orange County Central-Coastal Subregion of the Natural Communities Conservation Plan/Habitat Conservation Plan (NCCP/HCP). If the project does not mitigate by paying the NCCP/HCP mitigation fee, then the project’s impacts to wildlife covered by the HCP would interfere with the goals and objectives of the HCP unless the project’s impacts are appropriately mitigated. Development of the project site itself would eliminate land that remains available for mitigation from within the NCCP/HCP, so not participating with the NCCP/HCP would additionally interfere with it by removing California gnatcatcher habitat from its potential acquisition. CUMULATIVE IMPACTS The DEIR presents a flawed analysis of potential project contributions to cumulative impacts to wildlife in the region. For example, at p. 4.3-47, it asserts “Cumulative impacts are related to site-specific impacts to biological resources and thus would be mitigated, as necessary, on a project-by-project basis. For example, as noted below, each cumulative project would be required to complete a site-specific, biological technical report and incorporate all recommendations set forth therein and otherwise ensure 41 compliance with all applicable laws and regulations governing biological resources. Given the site-specific nature of these issues, combined with a comprehensive regulatory framework with which each cumulative development would be required to comply, this would ensure there would be a less than significant cumulative impact given the site- specific nature of these issues.” However, this argument in the DEIR rejects the CEQA’s conceptual description of cumulative impacts by asserting that many project impacts are site-specific and generally do not influence the impacts of other projects. Furthermore, it implies that the mitigation proposed for project-level impacts would leave no residual impacts that could be considered incremental or cumulatively considerable. That is, the DEIR implies that cumulative impacts are really just residual impacts left over by inadequate mitigation of project-level impacts, and that project-specific environmental reviews prevent these residual impacts. This notion of residual impacts being the source of cumulative impacts is inconsistent with CEQA’s definition of cumulative effects. Individually mitigated projects do not negate the significance of cumulative impacts. If they did, then CEQA would not require a cumulative effects analysis. Ample evidence refutes the DEIR’s assertion that project-specific environmental reviews shield new projects from contributing to cumulative impacts. An aerial view of the landscape around the project site reveals very little wildlife habitat remains. If the project goes forward, the landscape would lose an additional 44 acres of wildlife habitat as well as some capacity for wildlife to move between the few isolated patches of habitat that remain. The environmental reviews of past projects did not avoid cumulative impacts, not with their analyses and not with the mitigation measures they implemented. In the face so many development projects, California’s wildlife have continued to decline. Breeding Bird Survey trends are mostly negative. eBird trends are mostly negative. Emergency listings are made for an increasing number of species, and listing petitions are being submitted. To measure the impacts of habitat loss to wildlife caused by development projects, and to measure cumulative impacts of development, Noriko Smallwood and I revisited 80 sites of proposed projects that we had originally surveyed in support of comments on CEQA review documents (Smallwood and Smallwood 2023). We revisited the sites to repeat the survey methods at the same time of year, the same start time in the day, and the same methods and survey duration in order to measure the effects of mitigated development on wildlife. We structured the experiment in a before-after, control-impact experimental design, as some of the sites had been developed since our initial survey and some had remained undeveloped. All of the developed sites had included mitigation measures to avoid, minimize or compensate for impacts to wildlife. Nevertheless, we found that mitigated development resulted in a 66% loss of species on site, and 48% loss of species in the project area. Counts of vertebrate animals declined 90%. We reported that “Development impacts measured by the mean number of species detected per survey were greatest for amphibians (-100%), followed by mammals (-86%), grassland birds (-75%), raptors (-53%), special-status species (-49%), all birds as a group (-48%), non-native birds (-44%), and synanthropic birds (-28%). Our results indicated that urban development substantially reduced vertebrate species richness and numerical abundance, even after richness and abundance had likely already been depleted by the cumulative effects of loss, fragmentation, and degradation of habitat in the urbanizing 42 environment,” and despite all of the mitigation measures and existing policies and regulations. The DEIR’s (p. 4.3-44) conclusion is not supportable that the Project “…would not make a cumulatively considerable contribution to the already less than significant cumulative impacts related to biological resources.” No evidence would support this conclusion. MITIGATION MM BIO‐1: Coastal sage scrub and coastal California gnatcatcher: (1) payment of the NCCP/HCP mitigation fee, if USFWS and CDFW allow; (2) long-term preservation of existing coastal sage scrub habitat occupied by coastal California gnatcatchers at an on-site or off-site location; and/or (3) restoration of coastal sage scrub habitat at an on-site or off-site location. Coastal sage scrub shall be replaced at a minimum 1:1 ratio, or as otherwise determined by the USFWS and CDFW. … If the preservation option is selected, a Long Term Protection and Management Plan (LTPMP) shall be prepared by a qualified Restoration Ecologist and shall be reviewed and approved by the USFWS and CDFW prior to the issuance of a grading permit. If the option of restoration of coastal sage scrub habitat is selected, a Habitat Mitigation and Monitoring Program (HMMP) shall be prepared by a qualified Restoration Ecologist and reviewed and approved by the USFWS and CDFW prior to the issuance of a grading permit. If either options #2 or #3 are selected, the Property Owner/Developer shall be responsible for implementing either the LTPMP and/or HMMP and ensuring that the mitigation program achieves the approved performance criteria. If either options #2 or #3 are selected, the Property Owner/Developer shall implement the LTPMP or HMMP per its specified requirements, materials, methods, and performance criteria. If option #3 is selected, the HMMP shall include the following items: Responsibilities and Qualifications, Performance Criteria, Site Selection, Seed Materials Procurement, Wildlife Surveys and Protection, Site Preparation and Plant Materials Installation, Schedule, Maintenance Program, Monitoring Program, Long‐term preservation. Because this measure’s implementation depends on whether the USFWS and CDFW allows the payment of the NCCP/HCP mitigation fee, the DEIR should be removed from public circulation until it is known whether the USFWS and CDFW would allow payment of the fee. Whether the fee payment is allowed is central to the mitigation plan and to the question of whether the project would interfere with an existing NCCP or HCP. Option 2 needs to be revised so that the term “long-term” is replaced by “permanent.” Long-term can be interpreted in many ways, whereas the meaning of permanent is clear. Furthermore, more detail is needed of option 2. Most critically, the DEIR needs to identify candidate properties where option 2 can be exercised. Considering the degree of habitat fragmentation that has occurred in the region, the public and decision-makers need to know that coastal sage scrub occupied by California gnatcatcher is available for permanent protection in sufficient acreage and reasonably close to the project site. The 43 mitigation ratio should be at least 2:1, or otherwise the project will have caused a net loss of California gnatcatchers. On-site, permanent protection should require a 3:1 mitigation ratio to prevent the growth-inducement to the south of the project, as the DEIR acknowledges is likely. A 3:1 ratio would better ensure that the habitat to the east of the project footprint, as well as habitat to the south of it, is permanently protected so that growth to the south is not allowed. Option 3 needs to be revised to include candidate sites for habitat restoration and management. Candidate sites should be vacant of California gnatcatcher, as restoration at occupied sites could adversely affect resident gnatcatchers. However, candidates sites need to be located near enough to California gnatcatcher habitat to increase the likelihood that gnatcatchers would eventually move into restored habitat. Candidate sites should also be unlikely to cause adverse effects to other special-status species, and should be reasonably near the project site and of sufficient size to be relevant. All three options rely on Psomas’s (2024) delineation of vegetation cover types on the project area. These cover types are depicted as hard-bounded polygons on a map of the project area. However, I saw no expression of uncertainty over the boundaries of polygons. There is no expression of graduation from one cover type to another, and therefore the map is unrealistic. Also unrealistic is the notion that California gnatcatchers occur only in coastal sage scrub, and that the complex of vegetation cover is irrelevant to California gnatcatcher conservation. The DEIR parses out vegetation cover types to separate mitigation ratios and probably to separate mitigation sites, but this approach could result in protected fragments of vegetation cover types that achieve the acreage ratio but fail to maintain their ecological connections or their capacity to support California gnatcatchers. In addition to the above details, a revised DEIR should include performance standards . The current DEIR says that these standards would be formulated in the LTPMP or HMMP, but these standards are too important to defer to plans drawn up outside the public’s view. The performance standards need to go not only to the protection or propagation of the targeted vegetation cover types, but also and more importantly to California gnatcatchers and other special-status species. The efficacy of the mitigation needs to be measured; otherwise the project’s impacts and whether the impacts were mitigated can never be known. To measure efficacy of mitigation, more surveys are needed on the project site prior to construction. These surveys are needed to document the abundance and distribution of California gnatcatchers and other special-status species among the vegetation cover types. Simultaneous surveys are needed to document the same at the mitigation receiving sites, followed by monitoring to measure effects to California gnatcatchers and other special-status species (Morrison 2002). MM BIO‐2: Chaparral vegetation. The same options (2) and (3) as above, but option 1 would be payment into a conservation bank. 44 See my comments under MM BIO-1, but in the case of the new option 1, I suggest revising the DEIR to identify candidate conservation banks where the option can be exercised. The public and decision-makers need to be aware that candidate conservation banks are available. MM BIO‐3: Obtain all necessary permits that are required under applicable laws and regulations for impacts to CDFW and RWQCB jurisdictional areas. As approved by CDFW and RWQCB, potential mitigation options shall include … the following: (1) payment of an in-lieu mitigation fee to an approved mitigation bank; (2) long-term preservation of existing riparian habitat at an on-site or off-site location; or (3) restoration of riparian habitat at an on-site or off-site location. Riparian habitat/jurisdictional areas shall be replaced at a minimum 1:1 ratio ... The obtaining of all necessary permits is not a legitimate mitigation measure, as it does not necessarily avoid, minimize, rectify, reduce, or compensate for impacts. Otherwise, see my comments on MM BIO-1 and MM-BIO-2. And in the case of this measure, I will reiterate that the vegetation cover map is central to this measure but expresses no ecological connections to upland environments other than shared boundaries. This omission is important because one of the few widely-recognized corridors in natural settings is the riparian corridor (Andy 2020). The existence of riparian corridors serves as a stabilizing force on wildlife movement and persistence on larger landscapes (Andy 2020). The functionality of the existing riparian corridor is partly tied to those upland vegetation communities to which it connects. The vegetation cover types mapped within the riparian environment get lumped into a larger riparian polygon used as the basis for MM BIO-3. This lumping simplifies the representation of the riparian environment, thereby losing the potential contributions to wildlife via complexity in plant species composition and structure. This loss of information is important because riparian environments contribute much more value to wildlife than simply as movement corridors. Wildlife concentrate in riparian environments (Ohmart 1994, Ballard et al. 2004), where mammal species diversity is higher (Hamilton et al. 2015), and where reptile and amphibian species diversity increases with habitat complexity of the riparian environment (Bateman and Merritt 2020). Bird species richness is also highest in riparian environments (Ballard et al. 2004). Lee and Rotenberry (2015) found that whereas the occurrences of some bird species in riparian forests correlated with local variables defined by percent tree cover versus percent shrub cover, the occurrences of twice as many bird species correlated with landscape variables such as adjacency and extent of upland land uses such as agriculture, shrubland or forest. However, Lee and Rotenberry (2015) identified a guild of bird species that correlate most strongly with local variables, and is composed of species that are obligates of riparian environments. This guild is composed largely of special-status species, probably because riparian environments have been reduced in the western states from 80% to 95% (Ohmart1994) and even to 98% (Jones et al. 2010). In summary, riparian environments are important to wildlife diversity and critically important to multiple special-status species of wildlife, but the complexity of riparian environments and the juxtaposition of these environments to certain upland vegetation 45 complexes multiply the value of the riparian environment. It is therefore extremely important to appropriately characterize the riparian environment so that its potential loss can be mitigated by protecting the appropriate riparian environment elsewhere. By parsing out the mitigation by cover type, the possibility has been introduced for protecting some riparian environment that is adjacent to residential homes or to warehouses rather than to grasslands, coastal sage scrub or chapparal. For this reason, it is all the more important that the public and decision-makers have the opportunity to see candidate mitigation sites. MM BIO‐4: Crotch’s bumble bee. The Property Owner/Developer shall retain a qualified Biologist to conduct pre-construction focused surveys for Crotch’s bumble bee within 500 feet of the relevant Project construction work area. … If present, … shall notify the City …and consult with CDFW to determine if a permit … will be needed under applicable laws and regulations. The obtaining of a permit is not legitimate mitigation. Also, the available survey guidelines for Crotch’s bumble bee (CDFW 2023) need to be implemented prior to the public circulation of the DEIR, not afterwards. Detection surveys for Crotch’s bumble bee are intended to inform the CEQA review, but the DEIR falsely presents the surveys as a mitigation measure. The DEIR needs to be revised to detail the compensatory mitigation that would be needed should Crotch’s bumble bees be found on the project site. The mere performance of detection surveys would accomplish nothing towards conserving Crotch’s bumble bee. MM BIO‐5: Burrowing owls. Per the Staff Report on Burrowing Owl Mitigation (CDFW 2012), the Property Owner/Developer shall retain a qualified Biologist to conduct a preconstruction survey for the burrowing owl no less than 14 days prior to any ground disturbance… There are three types of surveys recommended and described in the CDFW’s (2012) survey and mitigation guidelines: (1) Habitat assessment, (2) Detection surveys, and (3) Preconstruction survey. The habitat assessment is intended to evaluate the likelihood that the site supports burrowing owls, and to decide whether detection surveys should be performed. The detection surveys, otherwise described as either or both breeding- season or non-breeding-season surveys, are intended to detect whether the site actually does support burrowing owls, and if so where and how many. The preconstruction survey, otherwise known as a take-avoidance survey, is intended to determine whether burrowing owls immigrated to the site since completion of the detection survey, or returned to the site since passive or active relocations were performed as mitigation. The three types of survey carry distinct but inter-related purposes, and they are to be completed in chronological order. The first two types of survey support impacts analysis, whereas the third type of survey is a mitigation measure. As indicated above, preconstruction surveys re not designed to function as detection surveys. Completing a preconstruction survey without having 46 completed detection surveys cannot generate findings supportive of an absence determination. The DEIR misapplies the CDFW (2012) survey and mitigation guidelines. I recommend that the City withdraws the DEIR from public circulation so that the appropriate detection surveys can be completed and their results include in a revised DEIR. This is especially important because burrowing owls have recently declined so rapidly and across such large portions of California that a listing petition was submitted to the California Fish and Game Commission (Miller 2024), and CDFW staff have endorsed it (CDFW 2024). With burrowing owls approaching extirpation from California, it is very important that the appropriate survey effort be made at the appropriate time, which in this case is detection surveys ahead of the public circulation of the DEIR. The public needs to know whether burrowing owls are present. MM BIO‐6: Preconstruction survey for nesting birds. Whereas a preconstruction nesting bird survey should be completed, it needs to be understood that a preconstruction survey achieves very little. Preconstruction, take- avoidance surveys consist of two steps, both of which are very difficult. First, the biologist(s) performing the survey must identify birds that are breeding. Second, the biologist(s) must locate the breeding birds’ nests. The first step is typically completed by observing bird behaviors such as food deliveries and nest territory defense. These types of observations typically require many surveys on many dates spread throughout the breeding season, and these observations are to find the nest sites of single targeted species such as burrowing owl (Smallwood et al. 2013) or loggerhead shrike (Smallwood and Smallwood 2021). To identify the birds of all species nesting on a site requires a much greater survey effort than a single survey only days prior to the start of construction. The biologists conducting the preconstruction survey would be very lucky to find any of the bird nests that are available to be found at the time of the survey. One reason why preconstruction surveys achieve very little is because species of bird vary in their nest phenology within what is generally understand as the avian breeding season. Whereas killdeer begin nesting in mid-March, western meadowlarks begin in late April, burrowing owls usually begin in May, and American goldfinches do not nest until July-August. Whenever the preconstruction survey is conducted, the biologists conducting the survey would be searching only for the nests of the birds that happen to be breeding at the time, and would miss the nests begun between the survey and the start of construction. On the project site, this task would be further complicated by the size of the site, by its terrain, and by its diversity of vegetation communities. Another reason why preconstruction surveys achieve very little is because the nests they might salvage are only the nests of the year. Preconstruction surveys can do nothing to mitigate the loss of productive capacity that ensues construction. All subsequent years of productivity would be destroyed by the project regardless of the success of a preconstruction survey. Preconstruction surveys achieve little mitigation of the impacts I predict above under Habitat Loss. 47 MM BIO‐7: Pre-construction roosting bat survey. See my comments under MM BIO-6. But I will add that the surveys for bat roosts should have already been completed, and their results reported in the DEIR. Preconstruction surveys do not carry the same detection probabilities as do detection surveys, so the former should not be relied upon without having completed the latter. And again, any salvage of bats discovered during a preconstruction survey cannot compensate for the permanent loss of productive capacity that would result from habitat loss caused by the project. MM BIO‐8: Fencing to contain dogs and cats to the developed areas. If the project goes forward, this measure should be implemented. However, I must point out that it would not prevent all disturbances from dogs and cats that would come with the project. Fences do not thwart the movements of free-ranging cats, nor do all dog owners adhere to fences and signage. Having surveyed many sites where dogs and cats are not permitted, I have documented many occurrences of dogs and cats. Fencing and signage would not prevent downstream loading of Toxoplasma gondii From house cats. According to a UC Davis wildlife health research program, “Toxoplasma gondii is a parasite that can infect virtually all warm-blooded animals, but the only known definitive hosts are cats – domesticated and feral house cats included. Cats catch the parasite through hunting rodents and birds and they offload it into the environment through their feces… and …rain that falls on cement creates more runoff than rain that falls on natural earth, which contributes to increased runoff that can carry fecal pathogens to the sea” (http://www.evotis.org/ toxoplasma-gondii- sea-otters/). Nor would fencing and signage prevent disturbance and displacement of wildlife by dogs (Hennings 2016), and accumulation and spread of parasites. In one study of dog parks in Portugal (Ferreira et al. 2017), at least 7 different types of parasites were found in fecal and soil samples, and “the soil of all the parks was contaminated with hookworm eggs.” The parasite loading of the project site could spill-over to wildlife of the immediate area MM BIO‐9: Anticoagulant rodenticides shall not be used anywhere within the Project Site. If the project goes forward, I concur with this measure. However, the benefits of this measure would be very small compared to the project’s impacts. MM BIO‐10: Avoid and minimize the introduction and spread of invasive exotic plant species. Best Management Practices are listed. If the project goes forward, I concur with this measure. However, the benefits of this measure would be very small compared to the project’s impacts. 48 MM BIO‐11: Lighting plan. If the project goes forward, I concur with this measure. However, the benefits of this measure would be very small compared to the project’s impacts. MM BIO‐12: Bird-window collision mortality. …Property Owner/Developer shall submit the Project’s plans for to the City of Anaheim for review and approval that demonstrates that window/glass designs for the multiple-family residential building, commercial buildings, perimeter fencing, and exterior landscaping minimizes bird strikes. This may include minimization measures such as the use of bird-safe glass or through placement or the angling of windows/glass downward so that the windows reflect the ground instead of the surrounding habitat or sky. The American Bird Conservancy has established the “2 X 4 Rule”, which describes the distance between elements making up a pattern applied to windows for the purpose of preventing bird strikes. To be effective, the pattern must uniformly cover the entire window and consist of elements of any shape (e.g., lines, dots, other geometric figures) separated by no more than 2 inches if oriented in horizontal rows, or 4 inches if oriented in vertical columns (i.e., the 2 X 4 Rule). These patterns reduce bird-window collisions when applied to the outer surface of reflective panes. Greater spacing between pattern elements increases the risk of a strike and casualties. Bird-safe glass may include a uniformly dense dot, striped, or grid pattern created as ceramic frit on the external surface of the window or a uniformly dense dot, striped, or grid patterns of clear UV- reflecting and UVabsorbing film applied to the exterior of windows. It should be noted that single decals (e.g., falcon silhouettes or large eye patterns) are ineffective and shall not be used unless the entire glass surface is uniformly covered with the objects or patterns (Klem 1990). Although I am relieved to see some consideration of the bird-window collision mortality issue, I do not believe sufficient commitment is made to minimize this impact in MM BIO-12. The renderings of the project’s buildings that are in the DEIR and available on various websites depict multiple grossly hazardous situations for birds. A great deal of exterior glass is proposed, much of it transparent and which will emit lots of interior sources of light at night. The multi-family residential building includes deep interior spaces that would trap birds, and it is covered in grasses, shrubs and trees, which is contrary to any of the available guidelines to minimize bird-window collision mortality. I am also concerned that the measure proposes to prepare a plan to be evaluated by City staff, who are not necessarily expert on the issue. The details of the Project’s plans should be included in a publicly circulated draft of the DEIR so that those of us who are expert on the issue can provide meaningful input. If the Project goes forward, it should adhere to available Bird-Safe Guidelines, such as those prepared by American Bird Conservancy and New York and San Francisco. The American Bird Conservancy (ABC) produced an excellent set of guidelines recommending actions to: (1) Minimize use of glass; (2) Placing glass behind some type of screening (grilles, shutters, exterior shades); (3) Using glass with inherent properties to reduce collisions, such as patterns, window films, decals or tape; and (4) Turning off lights during migration seasons (Sheppard and Phillips 2015). The City of San Francisco 49 (San Francisco Planning Department 2011) also has a set of building design guidelines, based on the excellent guidelines produced by the New York City Audubon Society (Orff et al. 2007). The ABC document and both the New York and San Francisco documents provide excellent alerting of potential bird-collision hazards as well as many visual examples. New research results inform of the efficacy of marking windows. Whereas Klem (1990) found no deterrent effect from decals on windows, Johnson and Hudson (1976) reported a fatality reduction of about 69% after placing decals on windows. In an experiment of opportunity, Ocampo-Peñuela et al. (2016) found only 2 of 86 fatalities at one of 6 buildings – the only building with windows treated with a bird deterrent film. At the building with fritted glass, bird collisions were 82% lower than at other buildings with untreated windows. Kahle et al. (2016) added external window shades to some windowed façades to reduce fatalities 82% and 95%. Brown et al. (2020) reported an 84% lower collision probability among fritted glass windows and windows treated with ORNILUX R UV. City of Portland Bureau of Environmental Services and Portland Audubon (2020) reduced bird collision fatalities 94% by affixing marked Solyx window film to existing glass panels of Portland’s Columbia Building. Many external and internal glass markers have been tested experimentally, some showing no effect and some showing strong deterrent effects (Klem 1989, 1990, 2009, 2011; Klem and Saenger 2013; Rössler et al. 2015). For example, Feather Friendly® circular adhesive markers applied in a grid pattern across all windows reduced bird-window collision mortality by 95% in one study (Riggs et al. 2023) and by 95% in another (de Groot et al. 2021). Another study tested the efficacy of two filmshades to be applied exteriorly to windows prior to installations: BirdShades increased bird-window avoidance by 47% and Haverkamp increased avoidance by 39% (Swaddle et al. 2023). Monitoring and the use of compensatory mitigation should be incorporated at any new building project because the measures recommended in the available guidelines remain of uncertain efficacy, and even if these measures are effective, they will not reduce collision mortality to zero. The only way to assess mitigation efficacy and to quantify post-construction fatalities is to monitor newly constructed buildings or homes for fatalities. MM BIO‐13: A Worker Environmental Awareness Program Training and biological monitoring... If the project goes forward, I concur with this measure. However, the benefits of this measure would be very small compared to the project’s impacts. Regarding biological monitoring and should the project go forward, I recommend that qualified biologists should be required to monitor construction impacts to wildlife. However, it should also be required that the monitor completes a report of the findings of construction monitoring. All cases of potential construction harm to wildlife should be reported to US Fish and Wildlife/California Department of Fish and Wildlife, and to the City, along with what was done to prevent or minimize or rectify injuries. All injuries 50 and fatalities should be reported to the same parties, along with the disposition of any remains. The report be made available to the public. RECOMMENDED MEASURES Fund Wildlife Rehabilitation Facilities: Compensatory mitigation ought also to include funding contributions to wildlife rehabilitation facilities to cover the costs of injured animals that will be delivered to these facilities for care. Many animals would likely be injured by collisions with automobiles and windows and by depredation attempts by house cats and dogs. Landscaping: If the Project goes forward, California native plant landscaping (i.e., grassland and locally appropriate scrub plants) should be considered to be used as opposed to landscaping with lawn and exotic shrubs and trees. Native plants offer more structure, cover, food resources, and nesting substrate for wildlife than landscaping with lawn and ornamental trees. Native plant landscaping has been shown to increase the abundance of arthropods which act as importance sources of food for wildlife and ar e crucial for pollination and plant reproduction (Narango et al. 2017, Adams et al. 2020, Smallwood and Wood 2022.). Further, many endangered and threated insects require native host plants for reproduction and migration, e.g., monarch butterfly. Around the world, landscaping with native plants over exotic plants increases the abundance and diversity of birds, and is particularly valuable to native birds (Lerman and Warren 2011, Burghardt et al. 2008, Berthon et al. 2021, Smallwood and Wood 2022). Landscaping with native plants is a way to maintain or to bring back some of the natural habitat and lessen the footprint of urbanization by acting as interconnected patches of habitat for wildlife (Goddard et al. 2009, Tallamy 2020). Lastly, not only does native plant landscaping benefit wildlife, it requires less water and maintenance than traditional landscaping with lawn and hedges. Thank you for your consideration, ______________________ Shawn Smallwood, Ph.D. LITERATURE CITED Adams, B. J., E. Li, C. A. Bahlai, E. K. Meineke, T. P. McGlynn, and B. V. Brown. 2020. Local and landscape-scale variables shape insect diversity in an urban biodiversity hot spot. Ecological Applications 30(4):e02089. 10.1002/eap.2089 Andy, K. E. 2023. 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Gelb. 2007. Bird-safe buildings guidelines. New York City Audubon, New York. Parkins, K. L., S. B. Elbin, and E. Barnes. 2015. Light, glass, and bird–building collisions in an urban park. Northeastern Naturalist 22:84-94. Porter, A., and A. Huang. 2015. Bird collisions with glass: UBC pilot project to assess bird collision rates in Western North America. UBC Social Ecological Economic Development Studies (SEEDS) Student Report. Report to Environment Canada, UBC SEEDS and UBC BRITE. Psomas. 2024. Biological Technical Report Hills Preserve Project, City of Anaheim, Orange County, California. Prepared for City of Anaheim, California. RBF Consulting. 2002 (August 14). Delineation of Jurisdictional Waters, 32-Acre Stonegate Property, City of Anaheim, County of Orange, California. Irvine, CA: RBF Consulting. Riding, C. S., T. J. O’Connell, and S. R. Loss. 2020. Building façade-level correlates of bird–window collisions in a small urban area. The Condor: Ornithological Applications 122:1–14. Riggs, G. J., C. M. Barton, C. S. Riding, T. J. O’Connell1, and S. R. Loss. 2023. Field‑testing effectiveness of window markers in reducing bird‑window collisions. Urban Ecosystems (2023) 26:713–723. https://doi.org/10.1007/s11252-022-01304- w Rössler, M., E. Nemeth, and A. Bruckner. 2015. Glass pane markings to prevent bird- window collisions: less can be more. Biologia 70: 535—541. DOI: 10.1515/biolog- 2015-0057 Sabo, A. M., N. D. G. Hagemeyer, A. S. Lahey, and E. L. Walters. 2016. Local avian density influences risk of mortality from window strikes. PeerJ 4:e2170; DOI 10.7717/peerj.2170 56 San Francisco Planning Department. 2011. Standards for bird-safe buildings. San Francisco Planning Department, City and County of San Francisco, California. Santos, S. M., F. Carvalho, and A. Mira. 2011. How long do the dead survive on the road? Carcass persistence probability and implications for road-kill monitoring surveys. PLoS ONE 6(9): e25383. doi:10.1371/journal.pone.0025383 Schneider, R. M., C. M. Barton, K. W. Zirkle, C. F. Greene, and K. B. Newman. 2018. Year-round monitoring reveals prevalence of fatal bird-window collisions at the Virginia Tech Corporate Research Center. PeerJ 6:e4562 https://doi.org/10.7717/ peerj.4562 Sheppard, C., and G. Phillips. 2015. Bird-friendly building design, 2nd Ed., American Bird Conservancy, The Plains, Virginia. Shuford, W. D., and T. Gardali, [eds.]. 2008. California bird species of special concern: a ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California. Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84-101 in M. L. Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, challenges, and solutions. John Hopkins University Press, Baltimore, Maryland, USA. Smallwood, K. S. 2022. Utility-scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https://doi.org/10.1002/jwmg.22216 Smallwood, K. S., and N. L. Smallwood. 2021. Breeding density and collision mortality of loggerhead shrike (Lanius ludovicianus) in the Altamont Pass Wind Resource Area. Diversity 13, 540. https://doi.org/10.3390/d13110540. Smallwood, K. S., and N. L. Smallwood. 2023. Measured effects of anthropogenic development on vertebrate wildlife diversity. Diversity 15, 1037. https://doi.org/10.3390/d15101037. Smallwood, N.L. and E.M. Wood. 2022. The ecological role of native plant landscaping in residential yards to urban wildlife. Ecosphere 2022;e4360. Somerlot, K. E. 2003. Survey of songbird mortality due to window collisions on the Murray State University campus. Journal of Service Learning in Conservation Biology 1:1–19. Swaddle, J. P., B. Brewster, M. Schuyler, and A. Su. 2023. Window films increase avoidance of collisions by birds but only when applied to external compared with internal surfaces of windows. PeerJ 11:e14676 http://doi.org/10.7717/peerj.14676 57 Tallamy, D.W. 2020. Nature’s Best Hope: A New Approach to Conservation that Starts in Your Yard. Timber Press. Wood, E. M., and S. Esaian. 2020. The importance of street trees to urban avifauna. Ecological Applications. 0:e02149. Yahner, R. H. 1982. Avian nest densities and nest-site selection in farmstead shelterbelts. The Wilson Bulletin 94:156-175. Young, H. 1948. A comparative study of nesting birds in a five-acre park. The Wilson Bulletin 61:36-47. Photo 34. House finch next to the project site. Photo by Noriko Smallwood. 1 Kenneth Shawn Smallwood Curriculum Vitae 3108 Finch Street Born May 3, 1963 in Davis, CA 95616 Sacramento, California. Phone (530) 756-4598 Married, father of two. Cell (530) 601-6857 puma@dcn.org Ecologist Expertise • Finding solutions to controversial problems related to wildlife interactions with human industry, infrastructure, and activities; • Wildlife monitoring and field study using GPS, thermal imaging, behavior surveys; • Using systems analysis and experimental design principles to identify meaningful ecological patterns that inform management decisions. Education Ph.D. Ecology, University of California, Davis. September 1990. M.S. Ecology, University of California, Davis. June 1987. B.S. Anthropology, University of California, Davis. June 1985. Corcoran High School, Corcoran, California. June 1981. Experience  762 professional reports, including:  90 peer reviewed publications  24 in non-reviewed proceedings  646 reports, declarations, posters and book reviews  8 in mass media outlets  92 public presentations of research results Editing for scientific journals: Guest Editor, Wildlife Society Bulletin, 2012-2013, of invited papers representing international views on the impacts of wind energy on wildlife and how to mitigate the impacts. Associate Editor, Journal of Wildlife Management, March 2004 to 30 June 2007. Editorial Board Member, Environmental Management, 10/1999 to 8/2004. Associate Editor, Biological Conservation, 9/1994 to 9/1995. Member, Alameda County Scientific Review Committee (SRC), August 2006 to April 2011. The five-member committee investigated causes of bird and bat collisions in the Altamont Pass Wind Resource Area, and recommended mitigation and monitoring measures. The SRC reviewed the science underlying the Alameda County Avian Protection Program, and advised Smallwood CV 2 the County on how to reduce wildlife fatalities. Consulting Ecologist, 2004-2007, California Energy Commission (CEC). Provided consulting services as needed to the CEC on renewable energy impacts, monitoring and research, and produced several reports. Also collaborated with Lawrence-Livermore National Lab on research to understand and reduce wind turbine impacts on wildlife. Consulting Ecologist, 1999-2013, U.S. Navy. Performed endangered species surveys, hazardous waste site monitoring, and habitat restoration for the endangered San Joaquin kangaroo rat, California tiger salamander, California red-legged frog, California clapper rail, western burrowing owl, salt marsh harvest mouse, and other species at Naval Air Station Lemoore; Naval Weapons Station, Seal Beach, Detachment Concord; Naval Security Group Activity, Skaggs Island; National Radio Transmitter Facility, Dixon; and, Naval Outlying Landing Field Imperial Beach. Part-time Lecturer, 1998-2005, California State University, Sacramento. Instructed Mammalogy, Behavioral Ecology, and Ornithology Lab, Contemporary Environmental Issues, Natural Resources Conservation. Senior Ecologist, 1999-2005, BioResource Consultants. Designed and implemented research and monitoring studies related to avian fatalities at wind turbines, avian electrocutions on electric distribution poles across California, and avian fatalities at transmission lines. Chairman, Conservation Affairs Committee, The Wildlife Society--Western Section, 1999-2001. Prepared position statements and led efforts directed toward conservation issues, including travel to Washington, D.C. to lobby Congress for more wildlife conservation funding. Systems Ecologist, 1995-2000, Institute for Sustainable Development. Headed ISD’s program on integrated resources management. Developed indicators of ecological integrity for large areas, using remotely sensed data, local community involvement and GIS. Associate, 1997-1998, Department of Agronomy and Range Science, University of California, Davis. Worked with Shu Geng and Mingua Zhang on several studies related to wildlife interactions with agriculture and patterns of fertilizer and pesticide residues in groundwater across a large landscape. Lead Scientist, 1996-1999, National Endangered Species Network. Informed academic scientists and environmental activists about emerging issues regarding the Endangered Species Act and other environmental laws. Testified at public hearings on endangered species issues. Ecologist, 1997-1998, Western Foundation of Vertebrate Zoology. Conducted field research to determine the impact of past mercury mining on the status of California red-legged frogs in Santa Clara County, California. Senior Systems Ecologist, 1994-1995, EIP Associates, Sacramento, California. Provided consulting services in environmental planning, and quantitative assessment of land units for their conservation and restoration opportunities basedon ecological resource requirements of 29 special-status species. Developed ecological indicators for prioritizing areas within Yolo County Smallwood CV 3 to receive mitigation funds for habitat easements and restoration. Post-Graduate Researcher, 1990-1994, Department of Agronomy and Range Science, U.C. Davis. Under Dr. Shu Geng’s mentorship, studied landscape and management effects on temporal and spatial patterns of abundance among pocket gophers and species of Falconiformes and Carnivora in the Sacramento Valley. Managed and analyzed a data base of energy use in California agriculture. Assisted with landscape (GIS) study of groundwater contamination across Tulare County, California. Work experience in graduate school: Co-taught Conservation Biology with Dr. Christine Schonewald, 1991 & 1993, UC Davis Graduate Group in Ecology; Reader for Dr. Richard Coss’s course on Psychobiology in 1990, UC Davis Department of Psychology; Research Assistant to Dr. Walter E. Howard, 1988-1990, UC Davis Department of Wildlife and Fisheries Biology, testing durable baits for pocket gopher management in forest clearcuts; Research Assistant to Dr. Terrell P. Salmon, 1987-1988, UC Wildlife Extension, Department of Wildlife and Fisheries Biology, developing empirical models of mammal and bird invasions in North America, and a rating system for priority research and control of exotic species based on economic, environmental and human health hazards in California. Student Assistant to Dr. E. Lee Fitzhugh, 1985-1987, UC Cooperative Extension, Department of Wildlife and Fisheries Biology, developing and implementing statewide mountain lion track count for long-term monitoring. Fulbright Research Fellow, Indonesia, 1988. Tested use of new sampling methods for numerical monitoring of Sumatran tiger and six other species of endemic felids, and evaluated methods used by other researchers. Projects Repowering wind energy projects through careful siting of new wind turbines using map-based collision hazard models to minimize impacts to volant wildlife. Funded by wind companies (principally NextEra Renewable Energy, Inc.), California Energy Commission and East Bay Regional Park District, I have collaborated with a GIS analyst and managed a crew of five field biologists performing golden eagle behavior surveys and nocturnal surveys on bats and owls. The goal is to quantify flight patterns for development of predictive models to more carefully site new wind turbines in repowering projects. Focused behavior surveys began May 2012 and continue. Collision hazard models have been prepared for seven wind projects, three of which were built. Planning for additional repowering projects is underway. Test avian safety of new mixer-ejector wind turbine (MEWT). Designed and implemented a before- after, control-impact experimental design to test the avian safety of a new, shrouded wind turbine developed by Ogin Inc. (formerly known as FloDesign Wind Turbine Corporation). Supported by a $718,000 grant from the California Energy Commission’s Public Interest Energy Research program and a 20% match share contribution from Ogin, I managed a crew of seven field biologists who performed periodic fatality searches and behavior surveys, carcass detection trials, nocturnal behavior surveys using a thermal camera, and spatial analyses with the collaboration of a GIS analyst. Field work began 1 April 2012 and ended 30 March 2015 without Ogin installing its MEWTs, but we still achieved multiple important scientific advances. Smallwood CV 4 Reduce avian mortality due to wind turbines at Altamont Pass. Studied wildlife impacts caused by 5,400 wind turbines at the world’s most notorious wind resource area. Studied how impacts are perceived by monitoring and how they are affected by terrain, wind patterns, food resources, range management practices, wind turbine operations, seasonal patterns, population cycles, infrastructure management such as electric distribution, animal behavior and social interactions. Reduce avian mortality on electric distribution poles. Directed research toward reducing bird electrocutions on electric distribution poles, 2000-2007. Oversaw 5 founds of fatality searches at 10,000 poles from Orange County to Glenn County, California, and produced two large reports. Cook et al. v. Rockwell International et al., No. 90-K-181 (D. Colorado). Provided expert testimony on the role of burrowing animals in affecting the fate of buried and surface-deposited radioactive and hazardous chemical wastes at the Rocky Flats Plant, Colorado. Provided expert reports based on four site visits and an extensive document review of burrowing animals. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities. Discovered substantial intrusion of waste structures by burrowing animals. I testified in federal court in November 2005, and my clients were subsequently awarded a $553,000,000 judgment by a jury. After appeals the award was increased to two billion dollars. Hanford Nuclear Reservation Litigation. Provided expert testimony on the role of burrowing animals in affecting the fate of buried radioactive wastes at the Hanford Nuclear Reservation, Washington. Provided three expert reports based on three site visits and extensive document review. Predicted and verified a certain population density of pocket gophers on buried waste structures, as well as incidence of radionuclide contamination in body tissue. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities. Discovered substantial intrusion of waste structures by burrowing animals. Expert testimony and declarations on proposed residential and commercial developments, gas-fired power plants, wind, solar and geothermal projects, water transfers and water transfer delivery systems, endangered species recovery plans, Habitat Conservation Plans and Natural Communities Conservation Programs. Testified before multiple government agencies, Tribunals, Boards of Supervisors and City Councils, and participated with press conferences and depositions. Prepared expert witness reports and court declarations, which are summarized under Reports (below). Protocol-level surveys for special-status species. Used California Department of Fish and Wildlife and US Fish and Wildlife Service protocols to search for California red-legged frog, California tiger salamander, arroyo southwestern toad, blunt-nosed leopard lizard, western pond turtle, giant kangaroo rat, San Joaquin kangaroo rat, San Joaquin kit fox, western burrowing owl, Swainson’s hawk, Valley elderberry longhorn beetle and other special-status species. Conservation of San Joaquin kangaroo rat. Performed research to identify factors responsible for the decline of this endangered species at Lemoore Naval Air Station, 2000-2013, and implemented habitat enhancements designed to reverse the trend and expand the population. Impact of West Nile Virus on yellow-billed magpies. Funded by Sacramento-Yolo Mosquito and Vector Control District, 2005-2008, compared survey results pre- and post-West Nile Virus epidemic for multiple bird species in the Sacramento Valley, particularly on yellow-billed magpie and American crow due to susceptibility to WNV. Smallwood CV 5 Workshops on HCPs. Assisted Dr. Michael Morrison with organizing and conducting a 2-day workshop on Habitat Conservation Plans, sponsored by Southern California Edison, and another 1- day workshop sponsored by PG&E. These Workshops were attended by academics, attorneys, and consultants with HCP experience. We guest-edited a Proceedings published in Environmental Management. Mapping of biological resources along Highways 101, 46 and 41. Used GPS and GIS to delineate vegetation complexes and locations of special-status species along 26 miles of highway in San Luis Obispo County, 14 miles of highway and roadway in Monterey County, and in a large area north of Fresno, including within reclaimed gravel mining pits. GPS mapping and monitoring at restoration sites and at Caltrans mitigation sites. Monitored the success of elderberry shrubs at one location, the success of willows at another location, and the response of wildlife to the succession of vegetation at both sites. Also used GPS to monitor the response of fossorial animals to yellow star-thistle eradication and natural grassland restoration efforts at Bear Valley in Colusa County and at the decommissioned Mather Air Force Base in Sacramento County. Mercury effects on Red-legged Frog. Assisted Dr. Michael Morrison and US Fish and Wildlife Service in assessing the possible impacts of historical mercury mining on the federally listed California red-legged frog in Santa Clara County. Also measured habitat variables in streams. Opposition to proposed No Surprises rule. Wrote a white paper and summary letter explaining scientific grounds for opposing the incidental take permit (ITP) rules providing ITP applicants and holders with general assurances they will be free of compliance with the Endangered Species Act once they adhere to the terms of a “properly functioning HCP.” Submitted 188 signatures of scientists and environmental professionals concerned about No Surprises rule US Fish and Wildlife Service, National Marine Fisheries Service, all US Senators. Natomas Basin Habitat Conservation Plan alternative. Designed narrow channel marsh to increase the likelihood of survival and recovery in the wild of giant garter snake, Swainson’s hawk and Valley Elderberry Longhorn Beetle. The design included replication and interspersion of treatments for experimental testing of critical habitat elements. I provided a report to Northern Territories, Inc. Assessments of agricultural production system and environmental technology transfer to China. Twice visited China and interviewed scientists, industrialists, agriculturalists, and the Directors of the Chinese Environmental Protection Agency and the Department of Agriculture to assess the need and possible pathways for environmental clean-up technologies and trade opportunities between the US and China. Yolo County Habitat Conservation Plan. Conducted landscape ecology study of Yolo County to spatially prioritize allocation of mitigation efforts to improve ecosystem functionality within the County from the perspective of 29 special-status species of wildlife and plants. Used a hierarchically structured indicators approach to apply principles of landscape and ecosystem ecology, conservation biology, and local values in rating land units. Derived GIS maps to help guide the conservation area design, and then developed implementation strategies. Smallwood CV 6 Mountain lion track count. Developed and conducted a carnivore monitoring program throughout California since 1985. Species counted include mountain lion, bobcat, black bear, coyote, red and gray fox, raccoon, striped skunk, badger, and black-tailed deer. Vegetation and land use are also monitored. Track survey transect was established on dusty, dirt roads within randomly selected quadrats. Sumatran tiger and other felids. Upon award of Fulbright Research Fellowship, I designed and initiated track counts for seven species of wild cats in Sumatra, including Sumatran tiger, fishing cat, and golden cat. Spent four months on Sumatra and Java in 1988, and learned Bahasa Indonesia, the official Indonesian language. Wildlife in agriculture. Beginning as post-graduate research, I studied pocket gophers and other wildlife in 40 alfalfa fields throughout the Sacramento Valley, and I surveyed for wildlife along a 200 mile road transect since 1989 with a hiatus of 1996-2004. The data are analyzed using GIS and methods from landscape ecology, and the results published and presented orally to farming groups in California and elsewhere. I also conducted the first study of wildlife in cover crops used on vineyards and orchards. Agricultural energy use and Tulare County groundwater study. Developed and analyzed a data base of energy use in California agriculture, and collaborated on a landscape (GIS) study of groundwater contamination across Tulare County, California. Pocket gopher damage in forest clear-cuts. Developed gopher sampling methods and tested various poison baits and baiting regimes in the largest-ever field study of pocket gopher management in forest plantations, involving 68 research plots in 55 clear-cuts among 6 National Forests in northern California. Risk assessment of exotic species in North America. Developed empirical models of mammal and bird species invasions in North America, as well as a rating system for assigning priority research and control to exotic species in California, based on economic, environmental, and human health hazards. Peer Reviewed Publications Smallwood, K. S. 2022. Utility-scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https://doi.org/10.1002/jwmg.22216 Smallwood, K. S., and N. L. Smallwood. 2021. Breeding Density and Collision Mortality of Loggerhead Shrike (Lanius ludovicianus) in the Altamont Pass Wind Resource Area. Diversity 13, 540. https://doi.org/10.3390/d13110540. Smallwood, K. S. 2020. USA wind energy-caused bat fatalities increase with shorter fatality search intervals. Diversity 12(98); https://doi.org/10.3390/d12030098 Smallwood, K. S., D. A. Bell, and S. Standish. 2020. Dogs detect larger wind energy impacts on bats and birds. Journal of Wildlife Management 84:852-864. DOI: 10.1002/jwmg.21863. Smallwood, K. S., and D. A. Bell. 2020. Relating bat passage rates to wind turbine fatalities. Smallwood CV 7 Diversity 12(84); doi:10.3390/d12020084. Smallwood, K. S., and D. A. Bell. 2020. Effects of wind turbine curtailment on bird and bat fatalities. Journal of Wildlife Management 84:684-696. DOI: 10.1002/jwmg.21844 Kitano, M., M. Ino, K. S. Smallwood, and S. Shiraki. 2020. Seasonal difference in carcass persistence rates at wind farms with snow, Hokkaido, Japan. Ornithological Science 19: 63 – 71. Smallwood, K. S. and M. L. Morrison. 2018. Nest-site selection in a high-density colony of burrowing owls. Journal of Raptor Research 52:454-470. Smallwood, K. S., D. A. Bell, E. L. Walther, E. Leyvas, S. Standish, J. Mount, B. Karas. 2018. Estimating wind turbine fatalities using integrated detection trials. Journal of Wildlife Management 82:1169-1184. Smallwood, K. S. 2017. Long search intervals under-estimate bird and bat fatalities caused by wind turbines. Wildlife Society Bulletin 41:224-230. Smallwood, K. S. 2017. The challenges of addressing wildlife impacts when repowering wind energy projects. Pages 175-187 in Köppel, J., Editor, Wind Energy and Wildlife Impacts: Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland. May, R., Gill, A. B., Köppel, J. Langston, R. H.W., Reichenbach, M., Scheidat, M., Smallwood, S., Voigt, C. C., Hüppop, O., and Portman, M. 2017. Future research directions to reconcile wind turbine–wildlife interactions. Pages 255-276 in Köppel, J., Editor, Wind Energy and Wildlife Impacts: Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland. Smallwood, K. S. 2017. Monitoring birds. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom. www.bit.ly/2v3cR9Q Smallwood, K. S., L. Neher, and D. A. Bell. 2017. Turbine siting for raptors: an example from Repowering of the Altamont Pass Wind Resource Area. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom. www.bit.ly/2v3cR9Q Johnson, D. H., S. R. Loss, K. S. Smallwood, W. P. Erickson. 2016. Avian fatalities at wind energy facilities in North America: A comparison of recent approaches. Human–Wildlife Interactions 10(1):7-18. Sadar, M. J., D. S.-M. Guzman, A. Mete, J. Foley, N. Stephenson, K. H. Rogers, C. Grosset, K. S. Smallwood, J. Shipman, A. Wells, S. D. White, D. A. Bell, and M. G. Hawkins. 2015. Mange Caused by a novel Micnemidocoptes mite in a Golden Eagle (Aquila chrysaetos). Journal of Avian Medicine and Surgery 29(3):231-237. Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84-101 in M. L. Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, challenges, and solutions. John Hopkins University Press, Baltimore, Maryland, USA. Smallwood CV 8 Mete, A., N. Stephenson, K. Rogers, M. G. Hawkins, M. Sadar, D. Guzman, D. A. Bell, J. Shipman, A. Wells, K. S. Smallwood, and J. Foley. 2014. Emergence of Knemidocoptic mange in wild Golden Eagles (Aquila chrysaetos) in California. Emerging Infectious Diseases 20(10):1716- 1718. Smallwood, K. S. 2013. Introduction: Wind-energy development and wildlife conservation. Wildlife Society Bulletin 37: 3-4. Smallwood, K. S. 2013. Comparing bird and bat fatality-rate estimates among North American wind-energy projects. Wildlife Society Bulletin 37:19-33. + Online Supplemental Material. Smallwood, K. S., L. Neher, J. Mount, and R. C. E. Culver. 2013. Nesting Burrowing Owl Abundance in the Altamont Pass Wind Resource Area, California. Wildlife Society Bulletin: 37:787-795. Smallwood, K. S., D. A. Bell, B. Karas, and S. A. Snyder. 2013. Response to Huso and Erickson Comments on Novel Scavenger Removal Trials. Journal of Wildlife Management 77: 216-225. Bell, D. A., and K. S. Smallwood. 2010. Birds of prey remain at risk. Science 330:913. Smallwood, K. S., D. A. Bell, S. A. Snyder, and J. E. DiDonato. 2010. Novel scavenger removal trials increase estimates of wind turbine-caused avian fatality rates. Journal of Wildlife Management 74: 1089-1097 + Online Supplemental Material. Smallwood, K. S., L. Neher, and D. A. Bell. 2009. Map-based repowering and reorganization of a wind resource area to minimize burrowing owl and other bird fatalities. Energies 2009(2):915- 943. http://www.mdpi.com/1996-1073/2/4/915 Smallwood, K. S. and B. Nakamoto. 2009. Impacts of West Nile Virus Epizootic on Yellow-Billed Magpie, American Crow, and other Birds in the Sacramento Valley, California. The Condor 111:247-254. Smallwood, K. S., L. Rugge, and M. L. Morrison. 2009. Influence of Behavior on Bird Mortality in Wind Energy Developments: The Altamont Pass Wind Resource Area, California. Journal of Wildlife Management 73:1082-1098. Smallwood, K. S. and B. Karas. 2009. Avian and Bat Fatality Rates at Old-Generation and Repowered Wind Turbines in California. Journal of Wildlife Management 73:1062-1071. Smallwood, K. S. 2008. Wind power company compliance with mitigation plans in the Altamont Pass Wind Resource Area. Environmental & Energy Law Policy Journal 2(2):229-285. Smallwood, K. S., C. G. Thelander. 2008. Bird Mortality in the Altamont Pass Wind Resource Area, California. Journal of Wildlife Management 72:215-223. Smallwood, K. S. 2007. Estimating wind turbine-caused bird mortality. Journal of Wildlife Management 71:2781-2791. Type text here Smallwood CV 9 Smallwood, K. S., C. G. Thelander, M. L. Morrison, and L. M. Rugge. 2007. Burrowing owl mortality in the Altamont Pass Wind Resource Area. Journal of Wildlife Management 71:1513- 1524. Cain, J. W. III, K. S. Smallwood, M. L. Morrison, and H. L. Loffland. 2005. Influence of mammal activity on nesting success of Passerines. J. Wildlife Management 70:522-531. Smallwood, K.S. 2002. Habitat models based on numerical comparisons. Pages 83-95 in Predicting species occurrences: Issues of scale and accuracy, J. M. Scott, P. J. Heglund, M. Morrison, M. Raphael, J. Haufler, and B. Wall, editors. Island Press, Covello, California. Morrison, M. L., K. S. Smallwood, and L. S. Hall. 2002. Creating habitat through plant relocation: Lessons from Valley elderberry longhorn beetle mitigation. Ecological Restoration 21: 95-100. Zhang, M., K. S. Smallwood, and E. Anderson. 2002. Relating indicators of ecological health and integrity to assess risks to sustainable agriculture and native biota. Pages 757-768 in D.J. Rapport, W.L. Lasley, D.E. Rolston, N.O. Nielsen, C.O. Qualset, and A.B. Damania (eds.), Managing for Healthy Ecosystems, Lewis Publishers, Boca Raton, Florida USA. Wilcox, B. A., K. S. Smallwood, and J. A. Kahn. 2002. Toward a forest Capital Index. Pages 285- 298 in D.J. Rapport, W.L. Lasley, D.E. Rolston, N.O. Nielsen, C.O. Qualset, and A.B. Damania (eds.), Managing for Healthy Ecosystems, Lewis Publishers, Boca Raton, Florida USA. Smallwood, K.S. 2001. The allometry of density within the space used by populations of Mammalian Carnivores. Canadian Journal of Zoology 79:1634-1640. Smallwood, K.S., and T.R. Smith. 2001. Study design and interpretation of Sorex density estimates. Annales Zoologi Fennici 38:141-161. Smallwood, K.S., A. Gonzales, T. Smith, E. West, C. Hawkins, E. Stitt, C. Keckler, C. Bailey, and K. Brown. 2001. Suggested standards for science applied to conservation issues. Transactions of the Western Section of the Wildlife Society 36:40-49. Geng, S., Yixing Zhou, Minghua Zhang, and K. Shawn Smallwood. 2001. A Sustainable Agro- ecological Solution to Water Shortage in North China Plain (Huabei Plain). Environmental Planning and Management 44:345-355. Smallwood, K. Shawn, Lourdes Rugge, Stacia Hoover, Michael L. Morrison, Carl Thelander. 2001. Intra- and inter-turbine string comparison of fatalities to animal burrow densities at Altamont Pass. Pages 23-37 in S. S. Schwartz, ed., Proceedings of the National Avian-Wind Power Planning Meeting IV. RESOLVE, Inc., Washington, D.C. Smallwood, K.S., S. Geng, and M. Zhang. 2001. Comparing pocket gopher (Thomomys bottae) density in alfalfa stands to assess management and conservation goals in northern California. Agriculture, Ecosystems & Environment 87: 93-109. Smallwood, K. S. 2001. Linking habitat restoration to meaningful units of animal demography. Smallwood CV 10 Restoration Ecology 9:253-261. Smallwood, K. S. 2000. A crosswalk from the Endangered Species Act to the HCP Handbook and real HCPs. Environmental Management 26, Supplement 1:23-35. Smallwood, K. S., J. Beyea and M. Morrison. 1999. Using the best scientific data for endangered species conservation. Environmental Management 24:421-435. Smallwood, K. S. 1999. Scale domains of abundance among species of Mammalian Carnivora. Environmental Conservation 26:102-111. Smallwood, K.S. 1999. Suggested study attributes for making useful population density estimates. Transactions of the Western Section of the Wildlife Society 35: 76-82. Smallwood, K. S. and M. L. Morrison. 1999. Estimating burrow volume and excavation rate of pocket gophers (Geomyidae). Southwestern Naturalist 44:173-183. Smallwood, K. S. and M. L. Morrison. 1999. Spatial scaling of pocket gopher (Geomyidae) density. Southwestern Naturalist 44:73-82. Smallwood, K. S. 1999. Abating pocket gophers (Thomomys spp.) to regenerate forests in clearcuts. Environmental Conservation 26:59-65. Smallwood, K. S. 1998. Patterns of black bear abundance. Transactions of the Western Section of the Wildlife Society 34:32-38. Smallwood, K. S. 1998. On the evidence needed for listing northern goshawks (Accipter gentilis) under the Endangered Species Act: a reply to Kennedy. J. Raptor Research 32:323-329. Smallwood, K. S., B. Wilcox, R. Leidy, and K. Yarris. 1998. Indicators assessment for Habitat Conservation Plan of Yolo County, California, USA. Environmental Management 22: 947-958. Smallwood, K. S., M. L. Morrison, and J. Beyea. 1998. Animal burrowing attributes affecting hazardous waste management. Environmental Management 22: 831-847. Smallwood, K. S, and C. M. Schonewald. 1998. Study design and interpretation for mammalian carnivore density estimates. Oecologia 113:474-491. Zhang, M., S. Geng, and K. S. Smallwood. 1998. Nitrate contamination in groundwater of Tulare County, California. Ambio 27(3):170-174. Smallwood, K. S. and M. L. Morrison. 1997. Animal burrowing in the waste management zone of Hanford Nuclear Reservation. Proceedings of the Western Section of the Wildlife Society Meeting 33:88-97. Morrison, M. L., K. S. Smallwood, and J. Beyea. 1997. Monitoring the dispersal of contaminants by wildlife at nuclear weapons production and waste storage facilities. The Environmentalist 17:289-295. Smallwood CV 11 Smallwood, K. S. 1997. Interpreting puma (Puma concolor) density estimates for theory and management. Environmental Conservation 24(3):283-289. Smallwood, K. S. 1997. Managing vertebrates in cover crops: a first study. American Journal of Alternative Agriculture 11:155-160. Smallwood, K. S. and S. Geng. 1997. Multi-scale influences of gophers on alfalfa yield and quality. Field Crops Research 49:159-168. Smallwood, K. S. and C. Schonewald. 1996. Scaling population density and spatial pattern for terrestrial, mammalian carnivores. Oecologia 105:329-335. Smallwood, K. S., G. Jones, and C. Schonewald. 1996. Spatial scaling of allometry for terrestrial, mammalian carnivores. Oecologia 107:588-594. Van Vuren, D. and K. S. Smallwood. 1996. Ecological management of vertebrate pests in agricultural systems. Biological Agriculture and Horticulture 13:41-64. Smallwood, K. S., B. J. Nakamoto, and S. Geng. 1996. Association analysis of raptors on an agricultural landscape. Pages 177-190 in D.M. Bird, D.E. Varland, and J.J. Negro, eds., Raptors in human landscapes. Academic Press, London. Erichsen, A. L., K. S. Smallwood, A. M. Commandatore, D. M. Fry, and B. Wilson. 1996. White- tailed Kite movement and nesting patterns in an agricultural landscape. Pages 166-176 in D. M. Bird, D. E. Varland, and J. J. Negro, eds., Raptors in human landscapes. Academic Press, London. Smallwood, K. S. 1995. Scaling Swainson's hawk population density for assessing habitat-use across an agricultural landscape. J. Raptor Research 29:172-178. Smallwood, K. S. and W. A. Erickson. 1995. Estimating gopher populations and their abatement in forest plantations. Forest Science 41:284-296. Smallwood, K. S. and E. L. Fitzhugh. 1995. A track count for estimating mountain lion Felis concolor californica population trend. Biological Conservation 71:251-259 Smallwood, K. S. 1994. Site invasibility by exotic birds and mammals. Biological Conservation 69:251-259. Smallwood, K. S. 1994. Trends in California mountain lion populations. Southwestern Naturalist 39:67-72. Smallwood, K. S. 1993. Understanding ecological pattern and process by association and order. Acta Oecologica 14(3):443-462. Smallwood, K. S. and E. L. Fitzhugh. 1993. A rigorous technique for identifying individual mountain lions Felis concolor by their tracks. Biological Conservation 65:51-59. Smallwood CV 12 Smallwood, K. S. 1993. Mountain lion vocalizations and hunting behavior. The Southwestern Naturalist 38:65-67. Smallwood, K. S. and T. P. Salmon. 1992. A rating system for potential exotic vertebrate pests. Biological Conservation 62:149-159. Smallwood, K. S. 1990. Turbulence and the ecology of invading species. Ph.D. Thesis, University of California, Davis. Peer-reviewed Reports Smallwood, K. S., and L. Neher. 2017. Comparing bird and bat use data for siting new wind power generation. Report CEC-500-2017-019, California Energy Commission Public Interest Energy Research program, Sacramento, California. http://www.energy.ca.gov/2017publications/CEC- 500-2017-019/CEC-500-2017-019.pdf and http://www.energy.ca.gov/2017publications/CEC- 500-2017-019/CEC-500-2017-019-APA-F.pdf Smallwood, K. S. 2016. Bird and bat impacts and behaviors at old wind turbines at Forebay, Altamont Pass Wind Resource Area. Report CEC-500-2016-066, California Energy Commission Public Interest Energy Research program, Sacramento, California. http://www.energy.ca.gov/publications/displayOneReport.php? pubNum=CEC-500- 2016-066 Sinclair, K. and E. DeGeorge. 2016. Framework for Testing the Effectiveness of Bat and Eagle Impact-Reduction Strategies at Wind Energy Projects. S. Smallwood, M. Schirmacher, and M. Morrison, eds., Technical Report NREL/TP-5000-65624, National Renewable Energy Laboratory, Golden, Colorado. Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2016. Final 2012-2015 Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California. Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2014. Final 2013-2014 Annual Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California. Brown, K., K. S. Smallwood, and B. Karas. 2013. Final 2012-2013 Annual Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California. http://www.altamontsrc.org/alt_doc/p274_ventus_vasco_winds_2012_13_avian_ bat_monitoring_report_year_1.pdf Smallwood, K. S., L. Neher, D. Bell, J. DiDonato, B. Karas, S. Snyder, and S. Lopez. 2009. Range Management Practices to Reduce Wind Turbine Impacts on Burrowing Owls and Other Raptors in the Altamont Pass Wind Resource Area, California. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. CEC-500-2008-080. Sacramento, California. 183 pp. https://tethys.pnnl.gov/publications/range-management-practices-reduce-wind-turbine- Smallwood CV 13 impacts-burrowing-owls-other-raptors Smallwood, K. S., and L. Neher. 2009. Map-Based Repowering of the Altamont Pass Wind Resource Area Based on Burrowing Owl Burrows, Raptor Flights, and Collisions with Wind Turbines. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. CEC-500-2009-065. Sacramento, California. http:// www.energy.ca.gov/publications/displayOneReport.php?pubNum=CEC-500-2009-065 Smallwood, K. S., K. Hunting, L. Neher, L. Spiegel and M. Yee. 2007. Indicating Threats to Birds Posed by New Wind Power Projects in California. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. Submitted but not published. Sacramento, California. Smallwood, K. S. and C. Thelander. 2005. Bird mortality in the Altamont Pass Wind Resource Area, March 1998 – September 2001 Final Report. National Renewable Energy Laboratory, NREL/SR-500-36973. Golden, Colorado. 410 pp. Smallwood, K. S. and C. Thelander. 2004. Developing methods to reduce bird mortality in the Altamont Pass Wind Resource Area. Final Report to the California Energy Commission, Public Interest Energy Research – Environmental Area, Contract No. 500-01-019. Sacramento, California. 531 pp. http://www.altamontsrcarchive.org/alt_doc/cec_final_report_08_11_04.pdf Thelander, C.G. S. Smallwood, and L. Rugge. 2003. Bird risk behaviors and fatalities at the Altamont Pass Wind Resource Area. Period of Performance: March 1998—December 2000. National Renewable Energy Laboratory, NREL/SR-500-33829. U.S. Department of Commerce, National Technical Information Service, Springfield, Virginia. 86 pp. Thelander, C.G., S. Smallwood, and L. Rugge. 2001. Bird risk behaviors and fatalities at the Altamont Wind Resource Area – a progress report. Proceedings of the American Wind Energy Association, Washington D.C. 16 pp. Non-Peer Reviewed Publications Smallwood, K. S. 2009. Methods manual for assessing wind farm impacts to birds. Bird Conservation Series 26, Wild Bird Society of Japan, Tokyo. T. Ura, ed., in English with Japanese translation by T. Kurosawa. 90 pp. Smallwood, K. S. 2009. Mitigation in U.S. Wind Farms. Pages 68-76 in H. Hötker (Ed.), Birds of Prey and Wind Farms: Analysis of problems and possible solutions. Documentation of an International Workshop in Berlin, 21st and 22nd October 2008. Michael-Otto-Instiut im NABU, Goosstroot 1, 24861 Bergenhusen, Germany. http://bergenhusen.nabu.de/forschung/greifvoegel/ Smallwood, K. S. 2007. Notes and recommendations on wildlife impacts caused by Japan’s wind power development. Pages 242-245 in Yukihiro Kominami, Tatsuya Ura, Koshitawa, and Tsuchiya, Editors, Wildlife and Wind Turbine Report 5. Wild Bird Society of Japan, Tokyo. Thelander, C.G. and S. Smallwood. 2007. The Altamont Pass Wind Resource Area's Effects on Birds: A Case History. Pages 25-46 in Manuela de Lucas, Guyonne F.E. Janss, Miguel Ferrer Smallwood CV 14 Editors, Birds and Wind Farms: risk assessment and mitigation. Madrid: Quercus. Neher, L. and S. Smallwood. 2005. Forecasting and minimizing avian mortality in siting wind turbines. Energy Currents. Fall Issue. ESRI, Inc., Redlands, California. Jennifer Davidson and Shawn Smallwood. 2004. Laying plans for a hydrogen highway. Comstock’s Business, August 2004:18-20, 22, 24-26. Jennifer Davidson and Shawn Smallwood. 2004. Refined conundrum: California consumers demand more oil while opposing refinery development. Comstock’s Business, November 2004:26-27, 29-30. Smallwood, K.S. 2002. Review of “The Atlas of Endangered Species.” By Richard Mackay. Environmental Conservation 30:210-211. Smallwood, K.S. 2002. Review of “The Endangered Species Act. History, Conservation, and Public Policy.” By Brian Czech and Paul B. Krausman. Environmental Conservation 29: 269- 270. Smallwood, K.S. 1997. Spatial scaling of pocket gopher (Geomyidae) burrow volume. Abstract in Proceedings of 44th Annual Meeting, Southwestern Association of Naturalists. Department of Biological Sciences, University of Arkansas, Fayetteville. Smallwood, K.S. 1997. Estimating prairie dog and pocket gopher burrow volume. Abstract in Proceedings of 44th Annual Meeting, Southwestern Association of Naturalists. Department of Biological Sciences, University of Arkansas, Fayetteville. Smallwood, K.S. 1997. Animal burrowing parameters influencing toxic waste management. Abstract in Proceedings of Meeting, Western Section of the Wildlife Society. Smallwood, K.S, and Bruce Wilcox. 1996. Study and interpretive design effects on mountain lion density estimates. Abstract, page 93 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp. Smallwood, K.S, and Bruce Wilcox. 1996. Ten years of mountain lion track survey. Page 94 in D.W. Padley, ed. Abstract, page 94 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp. Smallwood, K.S, and M. Grigione. 1997. Photographic recording of mountain lion tracks. Pages 75-75 in D.W. Padley, ed., Proceedings 5th Mountain Lion Workshop, Southern California Chapter, The Wildlife Society. 135 pp. Smallwood, K.S., B. Wilcox, and J. Karr. 1995. An approach to scaling fragmentation effects. Brief 8, Ecosystem Indicators Working Group, 17 March, 1995. Institute for Sustainable Development, Thoreau Center for Sustainability – The Presidio, PO Box 29075, San Francisco, CA 94129-0075. Wilcox, B., and K.S. Smallwood. 1995. Ecosystem indicators model overview. Brief 2, Smallwood CV 15 Ecosystem Indicators Working Group, 17 March, 1995. Institute for Sustainable Development, Thoreau Center for Sustainability – The Presidio, PO Box 29075, San Francisco, CA 94129- 0075. EIP Associates. 1996. Yolo County Habitat Conservation Plan. Yolo County Planning and Development Department, Woodland, California. Geng, S., K.S. Smallwood, and M. Zhang. 1995. Sustainable agriculture and agricultural sustainability. Proc. 7th International Congress SABRAO, 2nd Industrial Symp. WSAA. Taipei, Taiwan. Smallwood, K.S. and S. Geng. 1994. Landscape strategies for biological control and IPM. Pages 454-464 in W. Dehai, ed., Proc. International Conference on Integrated Resource Management for Sustainable Agriculture. Beijing Agricultural University, Beijing, China. Smallwood, K.S. and S. Geng. 1993. Alfalfa as wildlife habitat. California Alfalfa Symposium 23:105-8. Smallwood, K.S. and S. Geng. 1993. Management of pocket gophers in Sacramento Valley alfalfa. California Alfalfa Symposium 23:86-89. Smallwood, K.S. and E.L. Fitzhugh. 1992. The use of track counts for mountain lion population census. Pages 59-67 in C. Braun, ed. Mountain lion-Human Interaction Symposium and Workshop. Colorado Division of Wildlife, Fort Collins. Smallwood, K.S. and E.L. Fitzhugh. 1989. Differentiating mountain lion and dog tracks. Pages 58-63 in Smith, R.H., ed. Proc. Third Mountain Lion Workshop. Arizona Game and Fish Department, Phoenix. Fitzhugh, E.L. and K.S. Smallwood. 1989. Techniques for monitoring mountain lion population levels. Pages 69-71 in Smith, R.H., ed. Proc. Third Mountain Lion Workshop. Arizona Game and Fish Department, Phoenix. Reports to or by Alameda County Scientific Review Committee (Note: all documents linked to SRC website have since been removed by Alameda County) Smallwood, K. S. 2014. Data Needed in Support of Repowering in the Altamont Pass WRA. SRC document P284, County of Alameda, Hayward, California. Smallwood, K. S. 2013. Long-Term Trends in Fatality Rates of Birds and Bats in the Altamont Pass Wind Resource Area, California. SRC document R68, County of Alameda, Hayward, California. Smallwood, K. S. 2013. Inter-annual Fatality rates of Target Raptor Species from 1999 through 2012 in the Altamont Pass Wind Resources Area. SRC document P268, County of Alameda, Hayward, California. Smallwood, K. S. 2012. General Protocol for Performing Detection Trials in the FloDesign Study Smallwood CV 16 of the Safety of a Closed-bladed Wind Turbine. SRC document P246, County of Alameda, Hayward, California. Smallwood, K. S., l. Neher, and J. Mount. 2012. Burrowing owl distribution and abundance study through two breeding seasons and intervening non-breeding period in the Altamont Pass Wind Resource Area, California. SRC document P245, County of Alameda, Hayward, California. Smallwood, K. S 2012. Draft study design for testing collision risk of Flodesign wind turbine in former AES Seawest wind projects in the Altamont Pass Wind Resource Area (APWRA). SRC document P238, County of Alameda, Hayward, California. Smallwood, L. Neher, and J. Mount. 2012. Winter 2012 update on burrowing owl distribution and abundance study in the Altamont Pass Wind Resource Area, California. SRC document P232, County of Alameda, Hayward, California. Smallwood, S. 2012. Status of avian utilization data collected in the Altamont Pass Wind Resource Area, 2005-2011. SRC document P231, County of Alameda, Hayward, California. Smallwood, K. S., L. Neher, and J. Mount. 2011. Monitoring Burrow Use of Wintering Burrowing Owls. SRC document P229, County of Alameda, Hayward, California. Smallwood, K. S., L. Neher, and J. Mount. 2011. Nesting Burrowing Owl Distribution and Abundance in the Altamont Pass Wind Resource Area, California. SRC document P228, County of Alameda, Hayward, California. Smallwood, K. S. 2011. Draft Study Design for Testing Collision Risk of Flodesign Wind Turbine in Patterson Pass Wind Farm in the Altamont Pass Wind Resource Area (APWRA). http://www.altamontsrc.org/alt_doc/p100_src_document_list_with_reference_numbers.pdf Smallwood, K. S. 2011. Sampling Burrowing Owls Across the Altamont Pass Wind Resource Area. SRC document P205, County of Alameda, Hayward, California. Smallwood, K. S. 2011. Proposal to Sample Burrowing Owls Across the Altamont Pass Wind Resource Area. SRC document P155, County of Alameda, Hayward, California. SRC document P198, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Comments on APWRA Monitoring Program Update. SRC document P191, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Inter-turbine Comparisons of Fatality Rates in the Altamont Pass Wind Resource Area. SRC document P189, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Review of the December 2010 Draft of M-21: Altamont Pass Wind Resource Area Bird Collision Study. SRC document P190, County of Alameda, Hayward, California. Alameda County SRC (Shawn Smallwood, Jim Estep, Sue Orloff, Joanna Burger, and Julie Yee). Comments on the Notice of Preparation for a Programmatic Environmental Impact Report on Smallwood CV 17 Revised CUPs for Wind Turbines in the Alameda County portion of the Altamont Pass. SRC document P183, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Review of Monitoring Implementation Plan. SRC document P180, County of Alameda, Hayward, California. Burger, J., J. Estep, S. Orloff, S. Smallwood, and J. Yee. 2010. SRC Comments on CalWEA Research Plan. SRC document P174, County of Alameda, Hayward, California. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). SRC Comments on Monitoring Team’s Draft Study Plan for Future Monitoring. SRC document P168, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Second Review of American Kestrel-Burrowing owl (KB) Scavenger Removal Adjustments Reported in Alameda County Avian Monitoring Team’s M21 for the Altamont Pass Wind Resource Area. SRC document P171, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Assessment of Three Proposed Adaptive Management Plans for Reducing Raptor Fatalities in the Altamont Pass Wind Resource Area. SRC document P161, County of Alameda, Hayward, California. Smallwood, K. S. and J. Estep. 2010. Report of additional wind turbine hazard ratings in the Altamont Pass Wind Resource Area by Two Members of the Alameda County Scientific Review Committee. SRC document P153, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Alternatives to Improve the Efficiency of the Monitoring Program. SRC document P158, County of Alameda, Hayward, California. Smallwood, S. 2010. Summary of Alameda County SRC Recommendations and Concerns and Subsequent Actions. SRC document P147, County of Alameda, Hayward, California. Smallwood, S. 2010. Progress of Avian Wildlife Protection Program & Schedule. SRC document P148, County of Alameda, Hayward, California. SRC document P148, County of Alameda, Hayward, California. Smallwood, S. 2010. Old-generation wind turbines rated for raptor collision hazard by Alameda County Scientific Review Committee in 2010, an Update on those Rated in 2007, and an Update on Tier Rankings. SRC document P155, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Review of American Kestrel-Burrowing owl (KB) Scavenger Removal Adjustments Reported in Alameda County Avian Monitoring Team’s M21 for the Altamont Pass Wind Resource Area. SRC document P154, County of Alameda, Hayward, California. Smallwood, K. S. 2010. Fatality Rates in the Altamont Pass Wind Resource Area 1998-2009. Alameda County SRC document P-145. Smallwood, K. S. 2010. Comments on Revised M-21: Report on Fatality Monitoring in the Smallwood CV 18 Altamont Pass Wind Resource Area. SRC document P144, County of Alameda, Hayward, California. Smallwood, K. S. 2009. SRC document P129, County of Alameda, Hayward, California. Smallwood, K. S. 2009. Smallwood’s review of M32. SRC document P111, County of Alameda, Hayward, California. Smallwood, K. S. 2009. 3rd Year Review of 16 Conditional Use Permits for Windworks, Inc. and Altamont Infrastructure Company, LLC. Comment letter to East County Board of Zoning Adjustments. 10 pp + 2 attachments. Smallwood, K. S. 2008. Weighing Remaining Workload of Alameda County SRC against Proposed Budget Cap. Alameda County SRC document not assigned. 3 pp. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). 2008. SRC comments on August 2008 Fatality Monitoring Report, M21. SRC document P107, County of Alameda, Hayward, California. Smallwood, K. S. 2008. Burrowing owl carcass distribution around wind turbines. SRC document P106, County of Alameda, Hayward, California. Smallwood, K. S. 2008. Assessment of relocation/removal of Altamont Pass wind turbines rated as hazardous by the Alameda County SRC. SRC document P103, County of Alameda, Hayward, California. Smallwood, K. S. and L. Neher. 2008. Summary of wind turbine-free ridgelines within and around the APWRA. SRC document P102, County of Alameda, Hayward, California. Smallwood, K. S. and B. Karas. 2008. Comparison of mortality estimates in the Altamont Pass Wind Resource Area when restricted to recent fatalities. SRC document P101, County of Alameda, Hayward, California. Smallwood, K. S. 2008. On the misapplication of mortality adjustment terms to fatalities missed during one search and found later. SRC document P97, County of Alameda, Hayward, California. Smallwood, K. S. 2008. Relative abundance of raptors outside the APWRA. SRC document P88, County of Alameda, Hayward, California. Smallwood, K. S. 2008. Comparison of mortality estimates in the Altamont Pass Wind Resource Area. SRC document P76, County of Alameda, Hayward, California. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). 2010. Guidelines for siting wind turbines recommended for relocation to minimize potential collision- related mortality of four focal raptor species in the Altamont Pass Wind Resource Area. SRC document P70, County of Alameda, Hayward, California. Smallwood CV 19 Alameda County SRC (J. Burger, Smallwood, K. S., S. Orloff, J. Estep, and J. Yee). 2007. First DRAFT of Hazardous Rating Scale First DRAFT of Hazardous Rating Scale. SRC document P69, County of Alameda, Hayward, California. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). December 11, 2007. SRC selection of dangerous wind turbines. Alameda County SRC document P-67. 8 pp. Smallwood, S. October 6, 2007. Smallwood’s answers to Audubon’s queries about the SRC’s recommended four-month winter shutdown of wind turbines in the Altamont Pass. Alameda County SRC document P-23. Smallwood, K. S. October 1, 2007. Dissenting opinion on recommendation to approve of the AWI Blade Painting Study. Alameda County SRC document P-60. Smallwood, K. S. July 26, 2007. Effects of monitoring duration and inter-annual variability on precision of wind-turbine caused mortality estimates in the Altamont Pass Wind Resource Area, California. SRC Document P44. Smallwood, K. S. July 26, 2007. Memo: Opinion of some SRC members that the period over which post-management mortality will be estimated remains undefined. SRC Document P43. Smallwood, K. S. July 19, 2007. Smallwood’s response to P24G. SRC Document P41, 4 pp. Smallwood, K. S. April 23, 2007. New Information Regarding Alameda County SRC Decision of 11 April 2007 to Grant FPLE Credits for Removing and Relocating Wind Turbines in 2004. SRC Document P26. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, and J. Burger [J. Yee abstained]). April 17, 2007. SRC Statement in Support of the Monitoring Program Scope and Budget. Smallwood, K. S. April 15, 2007. Verification of Tier 1 & 2 Wind Turbine Shutdowns and Relocations. SRC Document P22. Smallwood, S. April 15, 2007. Progress of Avian Wildlife Protection Program & Schedule. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). April 3, 2007. Alameda County Scientific Review Committee replies to the parties’ responses to its queries and to comments from the California Office of the Attorney General. SRC Document S20. Smallwood, S. March 19, 2007. Estimated Effects of Full Winter Shutdown and Removal of Tier I & II Turbines. SRC Document S19. Smallwood, S. March 8, 2007. Smallwood’s Replies to the Parties’ Responses to Queries from the SRC and Comments from the California Office of the Attorney General. SRC Document S16. Smallwood, S. March 8, 2007. Estimated Effects of Proposed Measures to be Applied to 2,500 Wind Turbines in the APWRA Fatality Monitoring Plan. SRC Document S15. Smallwood CV 20 Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). February 7, 2007. Analysis of Monitoring Program in Context of 1/1//2007 Settlement Agreement. Smallwood, S. January 8, 2007. Smallwood’s Concerns over the Agreement to Settle the CEQA Challenges. SRC Document S5. Alameda County SRC (Smallwood, K. S., S. Orloff, J. Estep, J. Burger, and J. Yee). December 19, 2006. Altamont Scientific Review Committee (SRC) Recommendations to the County on the Avian Monitoring Team Consultants’ Budget and Organization. Reports to Clients Smallwood, K. S. 2022. Assessment of wildlife collision risk with initial wind turbine layout of Viracocha Wind Farm. Report to Viracocha Wind LLC and Salka LLC. Smallwood, K. S. 2020. Comparison of bird and bat fatality rates among utility-scale solar projects in California. Report to undisclosed client. Smallwood, K. S., D. Bell, and S. Standish. 2018. Skilled dog detections of bat and small bird carcasses in wind turbine fatality monitoring. Report to East Bay Regional Park District, Oakland, California. Smallwood, K. S. 2018. Addendum to Comparison of Wind Turbine Collision Hazard Model Performance: One-year Post-construction Assessment of Golden Eagle Fatalities at Golden Hills. Report to Audubon Society, NextEra Energy, and the California Attorney General. Smallwood, K. S., and L. Neher. 2018. Siting wind turbines to minimize raptor collisions at Sand Hill Repowering Project, Altamont Pass Wind Resource Area. Report to S-Power, Salt Lake City, Utah. Smallwood, K. S., and L. Neher. 2018. Siting wind turbines to minimize raptor collisions at Rooney Ranch Repowering Project, Altamont Pass Wind Resource Area. Report to S-Power, Salt Lake City, Utah. Smallwood, K. S. 2017. Summary of a burrowing owl conservation workshop. Report to Santa Clara Valley Habitat Agency, Morgan Hill, California. Smallwood, K. S., and L. Neher. 2018. Comparison of wind turbine collision hazard model performance prepared for repowering projects in the Altamont Pass Wind Resources Area. Report to NextEra Energy Resources, Inc., Office of the California Attorney General, Audubon Society, East Bay Regional Park District. Smallwood, K. S., and L. Neher. 2016. Siting wind turbines to minimize raptor collisions at Summit Winds Repowering Project, Altamont Pass Wind Resource Area. Report to Salka, Inc., Washington, D.C. Smallwood, K. S., L. Neher, and D. A. Bell. 2017. Mitigating golden eagle impacts from Smallwood CV 21 repowering Altamont Pass Wind Resource Area and expanding Los Vaqueros Reservoir. Report to East Contra Costa County Habitat Conservation Plan Conservancy and Contra Costa Water District. Smallwood, K. S. 2016. Review of avian-solar science plan. Report to Center for Biological Diversity. 28 pp Smallwood, K. S. 2016. Report of Altamont Pass research as Vasco Winds mitigation. Report to NextEra Energy Resources, Inc., Office of the California Attorney General, Audubon Society, East Bay Regional Park District. Smallwood, K. S., and L. Neher. 2016. Siting Wind Turbines to Minimize Raptor collisions at Sand Hill Repowering Project, Altamont Pass Wind Resource Area. Report to Ogin, Inc., Waltham, Massachusetts. Smallwood, K. S., and L. Neher. 2015a. Siting wind turbines to minimize raptor collisions at Golden Hills Repowering Project, Altamont Pass Wind Resource Area. Report to NextEra Energy Resources, Livermore, California. Smallwood, K. S., and L. Neher. 2015b. Siting wind turbines to minimize raptor collisions at Golden Hills North Repowering Project, Altamont Pass Wind Resource Area. Report to NextEra Energy Resources, Livermore, California. Smallwood, K. S., and L. Neher. 2015c. Siting wind turbines to minimize raptor collisions at the Patterson Pass Repowering Project, Altamont Pass Wind Resource Area. Report to EDF Renewable Energy, Oakland, California. Smallwood, K. S., and L. Neher. 2014. Early assessment of wind turbine layout in Summit Wind Project. Report to Altamont Winds LLC, Tracy, California. Smallwood, K. S. 2015. Review of avian use survey report for the Longboat Solar Project. Report to EDF Renewable Energy, Oakland, California. Smallwood, K. S. 2014. Information needed for solar project impacts assessment and mitigation planning. Report to Panorama Environmental, Inc., San Francisco, California. Smallwood, K. S. 2014. Monitoring fossorial mammals in Vasco Caves Regional Preserve, California: Report of Progress for the period 2006-2014. Report to East Bay Regional Park District, Oakland, California. Smallwood, K. S. 2013. First-year estimates of bird and bat fatality rates at old wind turbines, Forebay areas of Altamont Pass Wind Resource Area. Report to FloDesign in support of EIR. Smallwood, K. S. and W. Pearson. 2013. Neotropical bird monitoring of burrowing owls (Athene cunicularia), Naval Air Station Lemoore, California. Tierra Data, Inc. report to Naval Air Station Lemoore. Smallwood, K. S. 2013. Winter surveys for San Joaquin kangaroo rat (Dipodomys nitratoides) and Smallwood CV 22 burrowing owls (Athene cunicularia) within Air Operations at Naval Air Station, Lemoore. Report to Tierra Data, Inc. and Naval Air Station Lemoore. Smallwood, K. S. and M. L. Morrison. 2013. San Joaquin kangaroo rat (Dipodomys n. nitratoides) conservation research in Resource Management Area 5, Lemoore Naval Air Station: 2013 Final Report (Inclusive of work during 2000-2013). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. Smallwood, K. S. and M. L. Morrison. 2013. San Joaquin kangaroo rat (Dipodomys n. nitratoides) conservation research in Resource Management Area 5, Lemoore Naval Air Station: 2012 Progress Report (Inclusive of work during 2000-2012). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. Smallwood, K. S. 2012. Fatality rate estimates at the Vantage Wind Energy Project, year one. Report to Ventus Environmental, Portland, Oregon. Smallwood, K. S. and L. Neher. 2012. Siting wind turbines to minimize raptor collisions at North Sky River. Report to NextEra Energy Resources, LLC. Smallwood, K. S. 2011. Monitoring Fossorial Mammals in Vasco Caves Regional Preserve, California: Report of Progress for the Period 2006-2011. Report to East Bay Regional Park District. Smallwood, K. S. and M. L. Morrison. 2011. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2011 Progress Report (Inclusive of work during 2000-2011). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. Smallwood, K. S. 2011. Draft study design for testing collision risk of FloDesign Wind Turbine in Patterson Pass, Santa Clara, and Former AES Seawest Wind Projects in the Altamont Pass Wind Resource Area (APWRA). Report to FloDesign, Inc. Smallwood, K. S. 2011. Comments on Marbled Murrelet collision model for the Radar Ridge Wind Resource Area. Report to EcoStat, Inc., and ultimately to US Fish and Wildlife Service. Smallwood, K. S. 2011. Avian fatality rates at Buena Vista Wind Energy Project, 2008-2011. Report to Pattern Energy. Smallwood, K. S. and L. Neher. 2011. Siting repowered wind turbines to minimize raptor collisions at Tres Vaqueros, Contra Costa County, California. Report to Pattern Energy. Smallwood, K. S. and M. L. Morrison. 2011. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2010 Progress Report (Inclusive of work during 2000-2010). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. Smallwood, K. S. 2010. Wind Energy Development and avian issues in the Altamont Pass, California. Report to Black & Veatch. Smallwood CV 23 Smallwood, K. S. and L. Neher. 2010. Siting repowered wind turbines to minimize raptor collisions at the Tres Vaqueros Wind Project, Contra Costa County, California. Report to the East Bay Regional Park District, Oakland, California. Smallwood, K. S. and L. Neher. 2010. Siting repowered wind turbines to minimize raptor collisions at Vasco Winds. Report to NextEra Energy Resources, LLC, Livermore, California. Smallwood, K. S. 2010. Baseline avian and bat fatality rates at the Tres Vaqueros Wind Project, Contra Costa County, California. Report to the East Bay Regional Park District, Oakland, California. Smallwood, K. S. and M. L. Morrison. 2010. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2009 Progress Report (Inclusive of work during 2000-2009). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 86 pp. Smallwood, K. S. 2009. Mammal surveys at naval outlying landing field Imperial Beach, California, August 2009. Report to Tierra Data, Inc. 5 pp Smallwood, K. S. 2009. Mammals and other Wildlife Observed at Proposed Site of Amargosa Solar Power Project, Spring 2009. Report to Tierra Data, Inc. 13 pp Smallwood, K. S. 2009. Avian Fatality Rates at Buena Vista Wind Energy Project, 2008-2009. Report to members of the Contra Costa County Technical Advisory Committee on the Buena Vista Wind Energy Project. 8 pp. Smallwood, K. S. 2009. Repowering the Altamont Pass Wind Resource Area more than Doubles Energy Generation While Substantially Reducing Bird Fatalities. Report prepared on behalf of Californians for Renewable Energy. 2 pp. Smallwood, K. S. and M. L. Morrison. 2009. Surveys to Detect Salt Marsh Harvest Mouse and California Black Rail at Installation Restoration Site 30, Military Ocean Terminal Concord, California: March-April 2009. Report to Insight Environmental, Engineering, and Construction, Inc., Sacramento, California. 6 pp. Smallwood, K. S. 2008. Avian and Bat Mortality at the Big Horn Wind Energy Project, Klickitat County, Washington. Unpublished report to Friends of Skamania County. 7 pp. Smallwood, K. S. 2009. Monitoring Fossorial Mammals in Vasco Caves Regional Preserve, California: report of progress for the period 2006-2008. Unpublished report to East Bay Regional Park District. 5 pp. Smallwood, K. S. and M. L. Morrison. 2008. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2008 Progress Report (Inclusive of work during 2000-2008). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 84 pp. Smallwood CV 24 Smallwood, K. S. and M. L. Morrison. 2008. Habitat Assessment for California Red-Legged Frog at Naval Weapons Station, Seal Beach, Detachment Concord, California. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 48 pp. Smallwood, K. S. and B. Nakamoto. 2008. Impact of 2005 and 2006 West Nile Virus on Yellow- billed Magpie and American Crow in the Sacramento Valley, California. 22 pp. Smallwood, K. S. and M. L. Morrison. 2008. Former Naval Security Group Activity (NSGA), Skaggs Island, Waste and Contaminated Soil Removal Project (IR Site #2), San Pablo Bay, Sonoma County, California: Re-Vegetation Monitoring. Report to U.S. Navy, Letter Agreement – N68711-04LT-A0045. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 10 pp. Smallwood, K. S. and M. L. Morrison. 2008. Burrowing owls at Dixon Naval Radio Transmitter Facility. Report to U.S. Navy. Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 28 pp. Smallwood, K. S. and M. L. Morrison. 2008. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2007 Progress Report (Inclusive of work during 2001-2007). Naval Facilities Engineering Command, Southwest, Desert Integrated Products Team, San Diego, California. 69 pp. Smallwood, K. S. and M. L. Morrison. 2007. A Monitoring Effort to Detect the Presence of the Federally Listed Species California Clapper Rail and Salt Marsh Harvest Mouse, and Wetland Habitat Assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Installation Restoration (IR) Site 30, Final Report to U.S. Navy, Letter Agreement – N68711-05LT-A0001. U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, San Diego, California. 8 pp. Smallwood, K. S. and M. L. Morrison. 2007. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2006 Progress Report (Inclusive of work during 2001-2006). U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, Southwest, Daly City, California. 165 pp. Smallwood, K. S. and C. Thelander. 2006. Response to third review of Smallwood and Thelander (2004). Report to California Institute for Energy and Environment, University of California, Oakland, CA. 139 pp. Smallwood, K. S. 2006. Biological effects of repowering a portion of the Altamont Pass Wind Resource Area, California: The Diablo Winds Energy Project. Report to Altamont Working Group. Available from Shawn Smallwood, puma@yolo.com . 34 pp. Smallwood, K. S. 2006. Impact of 2005 West Nile Virus on yellow-billed magpie and american crow in the Sacramento Valley, California. Report to Sacramento-Yolo Mosquito and Vector Control District, Elk Grove, CA. 38 pp. Smallwood, K. S. and M. L. Morrison. 2006. San Joaquin kangaroo rat (Dipodomys n. nitratoides) Smallwood CV 25 Conservation Research in Resource Management Area 5, Lemoore Naval Air Station: 2005 Progress Report (Inclusive of work during 2001-2005). U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 160 pp. Smallwood, K. S. and M. L. Morrison. 2006. A monitoring effort to detect the presence of the federally listed species California tiger salamander and California red-legged frog at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter agreements N68711- 04LT-A0042 and N68711-04LT-A0044, U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 60 pp. Smallwood, K. S. and M. L. Morrison. 2006. A monitoring effort to detect the presence of the federally listed species California Clapper Rail and Salt Marsh Harvest Mouse, and wetland habitat assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Sampling for rails, Spring 2006, Installation Restoration (IR) Site 1. Letter Agreement – N68711-05lt-A0001, U.S. Navy Integrated Product Team (IPT), West, Naval Facilities Engineering Command, South West, Daly City, California. 9 pp. Morrison, M. L. and K. S. Smallwood. 2006. Final Report: Station-wide Wildlife Survey, Naval Air Station, Lemoore. Department of the Navy Integrated Product Team (IPT) West, Naval Facilities Engineering Command Southwest, 2001 Junipero Serra Blvd., Suite 600, Daly City, CA 94014-1976. 20 pp. Smallwood, K. S. and M. L. Morrison. 2006. Former Naval Security Group Activity (NSGA), Skaggs Island, Waste and Contaminated Soil Removal Project, San Pablo Bay, Sonoma County, California: Re-vegetation Monitoring. Department of the Navy Integrated Product Team (IPT) West, Naval Facilities Engineering Command Southwest, 2001 Junipero Serra Blvd., Suite 600, Daly City, CA 94014-1976. 8 pp. Dorin, Melinda, Linda Spiegel and K. Shawn Smallwood. 2005. Response to public comments on the staff report entitled Assessment of Avian Mortality from Collisions and Electrocutions (CEC-700-2005-015) (Avian White Paper) written in support of the 2005 Environmental Performance Report and the 2005 Integrated Energy Policy Report. California Energy Commission, Sacramento. 205 pp. Smallwood, K. S. 2005. Estimating combined effects of selective turbine removal and winter-time shutdown of half the wind turbines. Unpublished CEC staff report, June 23. 1 p. Erickson, W. and S. Smallwood. 2005. Avian and Bat Monitoring Plan for the Buena Vista Wind Energy Project Contra Costa County, California. Unpubl. report to Contra Costa County, Antioch, California. 22 pp. Lamphier-Gregory, West Inc., Shawn Smallwood, Jones & Stokes Associates, Illingworth & Rodkin Inc. and Environmental Vision. 2005. Environmental Impact Report for the Buena Vista Wind Energy Project, LP# 022005. County of Contra Costa Community Development Department, Martinez, California. Morrison, M. L. and K. S. Smallwood. 2005. A monitoring effort to detect the presence of the federally listed species California clapper rail and salt marsh harvest mouse, and wetland habitat Smallwood CV 26 assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Targeted Sampling for Salt Marsh Harvest Mouse, Fall 2005 Installation Restoration (IR) Site 30. Letter Agreement – N68711-05lt-A0001, U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 6 pp. Morrison, M. L. and K. S. Smallwood. 2005. A monitoring effort to detect the presence of the federally listed species California clapper rail and salt marsh harvest mouse, and wetland habitat assessment at the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter Agreement – N68711-05lt-A0001, U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 5 pp. Morrison, M. L. and K. S. Smallwood. 2005. Skaggs Island waste and contaminated soil removal projects, San Pablo Bay, Sonoma County, California. Report to the U.S. Department of the Navy, Naval Facilities Engineering Command Southwest, Daly City, California. 6 pp. Smallwood, K. S. and M. L. Morrison. 2004. 2004 Progress Report: San Joaquin kangaroo rat (Dipodomys nitratoides) Conservation Research in Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 134 pp. Smallwood, K. S. and L. Spiegel. 2005a. Assessment to support an adaptive management plan for the APWRA. Unpublished CEC staff report, January 19. 19 pp. Smallwood, K. S. and L. Spiegel. 2005b. Partial re-assessment of an adaptive management plan for the APWRA. Unpublished CEC staff report, March 25. 48 pp. Smallwood, K. S. and L. Spiegel. 2005c. Combining biology-based and policy-based tiers of priority for determining wind turbine relocation/shutdown to reduce bird fatalities in the APWRA. Unpublished CEC staff report, June 1. 9 pp. Smallwood, K. S. 2004. Alternative plan to implement mitigation measures in APWRA. Unpublished CEC staff report, January 19. 8 pp. Smallwood, K. S., and L. Neher. 2005. Repowering the APWRA: Forecasting and minimizing avian mortality without significant loss of power generation. California Energy Commission, PIER Energy-Related Environmental Research. CEC-500-2005-005. 21 pp. [Reprinted (in Japanese) in Yukihiro Kominami, Tatsuya Ura, Koshitawa, and Tsuchiya, Editors, Wildlife and Wind Turbine Report 5. Wild Bird Society of Japan, Tokyo.] Morrison, M. L., and K. S. Smallwood. 2004. Kangaroo rat survey at RMA4, NAS Lemoore. Report to U.S. Navy. 4 pp. Morrison, M. L., and K. S. Smallwood. 2004. A monitoring effort to detect the presence of the federally listed species California clapper rails and wetland habitat assessment at Pier 4 of the Naval Weapons Station, Seal Beach, Detachment Concord, California. Letter Agreement N68711-04LT-A0002. 8 pp. + 2 pp. of photo plates. Smallwood, K. S. and M. L. Morrison. 2003. 2003 Progress Report: San Joaquin kangaroo rat Smallwood CV 27 (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 56 pp. + 58 figures. Smallwood, K. S. 2003. Comparison of Biological Impacts of the No Project and Partial Underground Alternatives presented in the Final Environmental Impact Report for the Jefferson- Martin 230 kV Transmission Line. Report to California Public Utilities Commission. 20 pp. Morrison, M. L., and K. S. Smallwood. 2003. Kangaroo rat survey at RMA4, NAS Lemoore. Report to U.S. Navy. 6 pp. + 7 photos + 1 map. Smallwood, K. S. 2003. Assessment of the Environmental Review Documents Prepared for the Tesla Power Project. Report to the California Energy Commission on behalf of Californians for Renewable Energy. 32 pp. Smallwood, K. S., and M. L. Morrison. 2003. 2002 Progress Report: San Joaquin kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 45 pp. + 36 figures. Smallwood, K. S., Michael L. Morrison and Carl G. Thelander 2002. Study plan to test the effectiveness of aerial markers at reducing avian mortality due to collisions with transmission lines: A report to Pacific Gas & Electric Company. 10 pp. Smallwood, K. S. 2002. Assessment of the Environmental Review Documents Prepared for the East Altamont Energy Center. Report to the California Energy Commission on behalf of Californians for Renewable Energy. 26 pp. Thelander, Carl G., K. Shawn Smallwood, and Christopher Costello. 2002 Rating Distribution Poles for Threat of Raptor Electrocution and Priority Retrofit: Developing a Predictive Model. Report to Southern California Edison Company. 30 pp. Smallwood, K. S., M. Robison, and C. Thelander. 2002. Draft Natural Environment Study, Prunedale Highway 101 Project. California Department of Transportation, San Luis Obispo, California. 120 pp. Smallwood, K.S. 2001. Assessment of ecological integrity and restoration potential of Beeman/Pelican Farm. Draft Report to Howard Beeman, Woodland, California. 14 pp. Smallwood, K. S., and M. L. Morrison. 2002. Fresno kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. Progress report to U.S. Department of the Navy, Lemoore, California. 29 pp. + 19 figures. Smallwood, K.S. 2001. Rocky Flats visit, April 4th through 6th, 2001. Report to Berger & Montaque, P.C. 16 pp. with 61 color plates. Smallwood, K.S. 2001. Affidavit of K. Shawn Smallwood, Ph.D. in the matter of the U.S. Fish and Wildlife Service’s rejection of Seatuck Environmental Association’s proposal to operate an Smallwood CV 28 education center on Seatuck National Wildlife Refuge. Submitted to Seatuck Environmental Association in two parts, totaling 7 pp. Magney, D., and K.S. Smallwood. 2001. Maranatha High School CEQA critique. Comment letter submitted to Tamara & Efren Compeán, 16 pp. Smallwood, K. S. and D. Mangey. 2001. Comments on the Newhall Ranch November 2000 Administrative Draft EIR. Prepared for Ventura County Counsel regarding the Newhall Ranch Specific Plan EIR. 68 pp. Magney, D. and K. S. Smallwood. 2000. Newhall Ranch Notice of Preparation Submittal. Prepared for Ventura County Counsel regarding our recommended scope of work for the Newhall Ranch Specific Plan EIR. 17 pp. Smallwood, K. S. 2000. Comments on the Preliminary Staff Assessment of the Contra Costa Power Plant Unit 8 Project. Submitted to California Energy Commission on November 30 on behalf of Californians for Renewable Energy (CaRE). 4 pp. Smallwood, K. S. 2000. Comments on the California Energy Commission’s Final Staff Assessment of the MEC. Submitted to California Energy Commission on October 29 on behalf of Californians for Renewable Energy (CaRE). 8 pp. Smallwood, K. S. 2000. Comments on the Biological Resources Mitigation Implementation and Monitoring Plan (BRMIMP). Submitted to California Energy Commission on October 29 on behalf of Californians for Renewable Energy (CaRE). 9 pp. Smallwood, K. S. 2000. Comments on the Preliminary Staff Assessment of the Metcalf Energy Center. Submitted to California Energy Commission on behalf of Californians for Renewable Energy (CaRE). 11 pp. Smallwood, K. S. 2000. Preliminary report of reconnaissance surveys near the TRW plant south of Phoenix, Arizona, March 27-29. Report prepared for Hagens, Berman & Mitchell, Attorneys at Law, Phoenix, AZ. 6 pp. Morrison, M. L., K. S. Smallwood, and M. Robison. 2001. Draft Natural Environment Study for Highway 46 compliance with CEQA/NEPA. Report to the California Department of Transportation. 75 pp. Morrison, M.L., and K.S. Smallwood. 1999. NTI plan evaluation and comments. Exhibit C in W.D. Carrier, M.L. Morrison, K.S. Smallwood, and Vail Engineering. Recommendations for NBHCP land acquisition and enhancement strategies. Northern Territories, Inc., Sacramento. Smallwood, K. S. 1999. Estimation of impacts due to dredging of a shipping channel through Humboldt Bay, California. Court Declaration prepared on behalf of EPIC. Smallwood, K. S. 1998. 1998 California mountain lion track count. Report to the Defenders of Wildlife, Washington, D.C. 5 pages. Smallwood CV 29 Smallwood, K.S. 1998. Draft report of a visit to a paint sludge dump site near Ridgewood, New Jersey, February 26th, 1998. Unpublished report to Consulting in the Public Interest. Smallwood, K.S. 1997. Science missing in the “no surprises” policy. Commissioned by National Endangered Species Network and Spirit of the Sage Council, Pasadena, California. Smallwood, K.S. and M.L. Morrison. 1997. Alternate mitigation strategy for incidental take of giant garter snake and Swainson’s hawk as part of the Natomas Basin Habitat Conservation Plan. Pages 6-9 and iii illustrations in W.D. Carrier, K.S. Smallwood and M.L. Morrison, Natomas Basin Habitat Conservation Plan: Narrow channel marsh alternative wetland mitigation. Northern Territories, Inc., Sacramento. Smallwood, K.S. 1996. Assessment of the BIOPORT model's parameter values for pocket gopher burrowing characteristics. Report to Berger & Montague, P.C. and Roy S. Haber, P.C., Philadelphia. (peer reviewed). Smallwood, K.S. 1997. Assessment of plutonium releases from Hanford buried waste sites. Report Number 9, Consulting in the Public Interest, 53 Clinton Street, Lambertville, New Jersey, 08530. Smallwood, K.S. 1996. Soil Bioturbation and Wind Affect Fate of Hazardous Materials that were Released at the Rocky Flats Plant, Colorado. Report to Berger & Montague, P.C., Philadelphia. Smallwood, K.S. 1996. Second assessment of the BIOPORT model's parameter values for pocket gopher burrowing characteristics and other relevant wildlife observations. Report to Berger & Montague, P.C. and Roy S. Haber, P.C., Philadelphia. Smallwood, K.S., and R. Leidy. 1996. Wildlife and their management under the Martell SYP. Report to Georgia Pacific, Corporation, Martel, CA. 30 pp. EIP Associates. 1995. Yolo County Habitat Conservation Plan Biological Resources Report. Yolo County Planning and Development Department, Woodland, California. Smallwood, K.S. and S. Geng. 1995. Analysis of the 1987 California Farm Cost Survey and recommendations for future survey. Program on Workable Energy Regulation, University-wide Energy Research Group, University of California. Smallwood, K.S., S. Geng, and W. Idzerda. 1992. Final report to PG&E: Analysis of the 1987 California Farm Cost Survey and recommendations for future survey. Pacific Gas & Electric Company, San Ramon, California. 24 pp. Fitzhugh, E.L. and K.S. Smallwood. 1987. Methods Manual – A statewide mountain lion population index technique. California Department of Fish and Game, Sacramento. Salmon, T.P. and K.S. Smallwood. 1989. Final Report – Evaluating exotic vertebrates as pests to California agriculture. California Department of Food and Agriculture, Sacramento. Smallwood, K.S. and W. A. Erickson (written under supervision of W.E. Howard, R.E. Marsh, and Smallwood CV 30 R.J. Laacke). 1990. Environmental exposure and fate of multi-kill strychnine gopher baits. Final Report to USDA Forest Service –NAPIAP, Cooperative Agreement PSW-89-0010CA. Fitzhugh, E.L., K.S. Smallwood, and R. Gross. 1985. Mountain lion track count, Marin County, 1985. Report on file at Wildlife Extension, University of California, Davis. Comments on Environmental Documents (Year; pages) I was retained or commissioned to comment on environmental planning and review documents, including:  Shirk & Riggin Industrial Park Application, Visalia (2022; 22);  Duarte Industrial Application, Visalia (2022; 17);  Amond World Cold Storage Warehouse IS/MND, Madera (2022; 23);  Replies on Schulte Logistics Centre EIR, Tracy (2022; 28);  Alta Cuvee Mixed Use Project Recirculated IS/MND, Ranch Cucamonga (2022; 8);  Fourth visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2022; 9);  Replies on 1242 20th Street Wellness Center Project FEIR, Santa Monica (2022; 5);  656 South San Vicente Medical Office Project EIR, Los Angeles (2022; 21);  UCSF New Hospital at Parnassus Heights DEIR. San Francisco (2022; 40);  DPR-21-021Warehouse IS, Modesto (2022; 19);  Ormat Brawley Solar Project DEIR, Brawley (2022; 37);  Site visits to Heber 1 Geothermal Repower Project IS/MND (2022; 31);  Heritage Industrial Center Design Review, Chula Vista (2022; 13);  Temporary Outdoor Vehicle Storage DEIR, Port of Hueneme (2022; 29);  CNU Medical Center and Innovation Park DEIR, Natomas (2022; 35);  Beverly Boulevard Warehouse IS/MND, Pico Rivera (2021; 28);  Hagemon Properties IS/MND Amendment, Bakersfield (2022; 23);  Airport Distribution Center IS/MND, Redding (2021; 22);  Orchard on Nevada Warehouse Staff Report, Redlands (2021; 24);  Landings Logistics Center Exemption, Bakersfield (2021; 19);  Replies on Hearn Veterans Village IS/MND, Santa Rosa (2021; 22);  North Central Valley BESS Project IS/MND, Stockton (2021; 37);  2nd Replies on Heber 1 Geothermal Repower Project IS/MND (2022; 21);  Stagecoach Solar DEIR, Barstow (2021; 24);  Updated Sun Lakes Village North EIR Amendment 5, Banning, Riverside County (2021; 35);  Freedom Circle Focus Area and Greystar General Plan Amendment Project EIR, San Jose (2021; 43);  Operon HKI Warehouse IS/MND, Perris (2021; 26);  Fairway Business Park Phase III IS/MND, Lake Elsinore (2021; 23);  South Stockton Commerce Center IS/MND, Stockton (2021; 31);  Starpoint Warehouse IS/MND, San Bernardino (2021; 24);  Replies on Heber 1 Geothermal Repower Project IS/MND (2021; 15);  Heber 1 Geothermal Repower Project IS/MND (2021; 11); Smallwood CV 31  Alviso Hotel Project IS/MND, San Jose (2021; 43);  Replies on Easton Research Park West IS/MND, Rancho Cordova (2021; 3);  Easton Research Park West IS/MND, Rancho Cordova (2021; 31);  US Cold Storage DEIR, Hesperia (2021; 30);  1242 20th Street Wellness Center Project FEIR, Santa Monica (2021; 23);  Third visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 10);  Roseland Creek Community Park Project IS/MND, Santa Rosa (2021; 23);  Vista Mar Declaration of Irreparable Harm, Pacifica (2021; 3);  LogistiCenter at Fairfield IS/MND (2021; 25);  Alta Cuvee Mixed Use Project IS/MND, Ranch Cucamonga (2021; 29);  Caligrows Architectural and Site Plan Review, Patterson (2021; 21);  1055 E. Sandhill Avenue Warehouse IS/MND, Carson (2021; 10);  Chestnut & Tenth Street Commercial Project IS/MND, Gilroy (2021; 27);  Libitzky Management Warehouse IS/MND, Modesto (2021; 20);  3rd Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2021; 10);  Medical Office Building DEIR, Santa Cruz (2021; 30);  Scannell Warehouse DEIR, Richmond (2021; 24);  Diamond Heights Application, San Francisco (2021; 24);  Costa Azul Mixed-Use EIR Addendum, San Diego (2021; 25);  Woodland Research Park DEIR (2021; 45);  2nd Replies on Diamond Street Industrial IS/MND, San Marcos (2021; 9);  Replies on Diamond Street Industrial IS/MND, San Marcos (2021; 3);  Diamond Street Industrial IS/MND, San Marcos (2021; 28);  DHS 109 Industrial Park IS/MND, Desert Hot Springs (2021; 33);  Jersey Industrial Complex Rancho Cucamonga (2022; 22);  1188 Champions Drive Parking Garage Staff Report, San Jose (2021; 5);  San Pedro Mountain, Pacifica (2021; 22);  Pixior Warehouse IS/MND, Hesperia (2021; 29);  2nd Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2021; 9);  Hearn Veterans Village IS/MND, Santa Rosa (2021; 23);  Second visit, Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 11);  Replies on Station East Residential/Mixed Use EIR, Union City (2021; 26);  Schulte Logistics Centre EIR, Tracy (2021; 30);  4150 Point Eden Way Industrial Development EIR, Hayward (2021; 13);  Airport Business Centre IS/MND, Manteca (2021; 27);  Dual-branded Hotel IS/MND, Santa Clara (2021; 26);  Legacy Highlands Specific Plan EIR, Beaumont (2021; 47);  UC Berkeley LRDP and Housing Projects #1 and #2 EIR (2021; 27);  Santa Maria Airport Business Park EIR, Santa Maria (2021; 27);  Replies on Coachella Valley Arena EIR Addendum, Thousand Palms (2021; 20);  Coachella Valley Arena EIR Addendum, Thousand Palms (2021; 35);  Inland Harbor Warehouse NOD, Ontario (2021; 8);  Alvarado Specific Plan DEIR, La Mesa (2021; 35);  Harvill Avenue and Rider Street Terminal Project MND, Riverside (2021; 23); Smallwood CV 32  Gillespie Field EIR Addendum, El Cajon (2021; 28);  Heritage Wind Energy Project section 94-c siting process, New York (2021: 99);  Commercial Street Hotels project Site Plans, Oakland (2021; 19);  Heber 1 Geothermal Repower Project MND, El Centro (2021; 11);  Citrus-Slover Warehouse Project MND, Fontana (2021; 20);  Scott Ranch Project RDEIR (Davidon Homes), Petaluma (2021; 31);  Replies on StratosFuel Renewable H2 Project MND, Victorville (2021; 5);  StratosFuel Renewable H2 Project MND, Victorville (2021; 25);  Replies on PARS Global Storage MND, Murietta (2021; 22);  Baldwin-Zacharias Master Plans EIR, Patterson (2021; 38);  1000 Gibraltar Drive EIR, Milpitas (2021; 20);  Mango Avenue Industrial Warehouse Project, Fontana, MND (2021; 20);  Veterans Affairs Site Plan Review No. 20-0102 MND, Bakersfield (2021; 25);  Replies on UCSF Comprehensive Parnassus Heights Plan EIR (2021; 13);  14 Charles Hill Circle Design Review (2021; 11);  SDG Commerce 217 Warehouse IS, American Canyon (2021; 26);  Mulqueeney Ranch Wind Repowering Project DSEIR (2021; 98);  Clawiter Road Industrial Project IS/MND, Hayward (2021; 18);  Garnet Energy Center Stipulations, New York (2020);  Heritage Wind Energy Project, New York (2020: 71);  Ameresco Keller Canyon RNG Project IS/MND, Martinez (2020; 11);  Cambria Hotel Project Staff Report, Dublin (2020; 19);  Central Pointe Mixed-Use Staff Report, Santa Ana (2020; 20);  Oak Valley Town Center EIR Addendum, Calimesa (2020; 23);  Coachillin Specific Plan MND Amendment, Desert Hot Springs (2020; 26);  Stockton Avenue Hotel and Condominiums Project Tiering to EIR, San Jose (2020; 19);  Cityline Sub-block 3 South Staff Report, Sunyvale (2020; 22);  Station East Residential/Mixed Use EIR, Union City (2020; 21);  Multi-Sport Complex & Southeast Industrial Annexation Suppl. EIR, Elk Grove (2020; 24);  Sun Lakes Village North EIR Amendment 5, Banning, Riverside County (2020; 27);  2nd comments on 1296 Lawrence Station Road, Sunnyvale (2020; 4);  1296 Lawrence Station Road, Sunnyvale (2020; 16);  Mesa Wind Project EA, Desert Hot Springs (2020; 31);  11th Street Development Project IS/MND, City of Upland (2020; 17);  Vista Mar Project IS/MND, Pacifica (2020; 17);  Emerson Creek Wind Project Application, Ohio (2020; 64);  Replies on Wister Solar Energy Facility EIR, Imperial County (2020; 12);  Wister Solar Energy Facility EIR, Imperial County (2020; 28);  Crimson Solar EIS/EIR, Mojave Desert (2020, 35) not submitted;  Sakioka Farms EIR tiering, Oxnard (2020; 14);  3440 Wilshire Project IS/MND, Los Angeles (2020; 19);  Replies on 2400 Barranca Office Development Project EIR, Irvine (2020; 8);  2400 Barranca Office Development Project EIR, Irvine (2020; 25);  Replies on Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 4); Smallwood CV 33  2nd comments on Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 8);  Heber 2 Geothermal Repower Project IS/MND, El Centro (2020; 3);  Lots 4-12 Oddstad Way Project IS/MND, Pacifica (2020; 16);  Declaration on DDG Visalia Warehouse project (2020; 5);  Terraces of Lafayette EIR Addendum (2020; 24);  AMG Industrial Annex IS/MND, Los Banos (2020; 15);  Replies to responses on Casmalia and Linden Warehouse, Rialto (2020; 15);  Clover Project MND, Petaluma (2020; 27);  Ruby Street Apartments Project Env. Checklist, Hayward (2020; 20);  Replies to responses on 3721 Mt. Diablo Boulevard Staff Report (2020; 5);  3721 Mt. Diablo Boulevard Staff Report (2020; 9);  Steeno Warehouse IS/MND, Hesperia (2020; 19);  UCSF Comprehensive Parnassus Heights Plan EIR (2020; 24);  North Pointe Business Center MND, Fresno (2020; 14);  Casmalia and Linden Warehouse IS, Fontana (2020; 15);  Rubidoux Commerce Center Project IS/MND, Jurupa Valley (2020; 27);  Haun and Holland Mixed Use Center MND, Menifee (2020; 23);  First Industrial Logistics Center II, Moreno Valley IS/MND (2020; 23);  GLP Store Warehouse Project Staff Report (2020; 15);  Replies on Beale WAPA Interconnection Project EA & CEQA checklist (2020; 29);  2nd comments on Beale WAPA Interconnection Project EA & CEQA checklist (2020; 34);  Beale WAPA Interconnection Project EA & CEQA checklist (2020; 30);  Levine-Fricke Softball Field Improvement Addendum, UC Berkeley (2020; 16);  Greenlaw Partners Warehouse and Distribution Center Staff Report, Palmdale (2020; 14);  Humboldt Wind Energy Project DEIR (2019; 25);  Sand Hill Supplemental EIR, Altamont Pass (2019; 17);  1700 Dell Avenue Office Project, Campbell (2019, 28);  1180 Main Street Office Project MND, Redwood City (2019; 19:  Summit Ridge Wind Farm Request for Amendment 4, Oregon (2019; 46);  Shafter Warehouse Staff Report (2019; 4);  Park & Broadway Design Review, San Diego (2019; 19);  Pinnacle Pacific Heights Design Review, San Diego (2019; 19);  Pinnacle Park & C Design Review, San Diego (2019; 19);  Preserve at Torrey Highlands EIR, San Diego (2019; 24);  Santana West Project EIR Addendum, San Jose (2019; 18);  The Ranch at Eastvale EIR Addendum, Riverside County (2020; 19);  Hageman Warehouse IS/MND, Bakersfield (2019; 13);  Oakley Logistics Center EIR, Antioch (2019; 22);  27 South First Street IS, San Jose (2019; 23);  2nd replies on Times Mirror Square Project EIR, Los Angeles (2020; 11);  Replies on Times Mirror Square Project EIR, Los Angeles (2020; 13);  Times Mirror Square Project EIR, Los Angeles (2019; 18);  East Monte Vista & Aviator General Plan Amend EIR Addendum, Vacaville (2019; 22);  Hillcrest LRDP EIR, La Jolla (2019; 36); Smallwood CV 34  555 Portola Road CUP, Portola Valley (2019; 11);  Johnson Drive Economic Development Zone SEIR, Pleasanton (2019; 27);  1750 Broadway Project CEQA Exemption, Oakland (2019; 19);  Mor Furniture Project MND, Murietta Hot Springs (2019; 27);  Harbor View Project EIR, Redwood City (2019; 26);  Visalia Logistics Center (2019; 13);  Cordelia Industrial Buildings MND (2019; 14);  Scheu Distribution Center IS/ND, Rancho Cucamonga (2019; 13);  Mills Park Center Staff Report, San Bruno (2019; 22);  Site visit to Desert Highway Farms IS/MND, Imperial County (2019; 9);  Desert Highway Farms IS/MND, Imperial County (2019; 12);  ExxonMobil Interim Trucking for Santa Ynez Unit Restart SEIR, Santa Barbara (2019; 9);  Olympic Holdings Inland Center Warehouse Project MND, Rancho Cucamonga (2019; 14);  Replies to responses on Lawrence Equipment Industrial Warehouse, Banning (2019; 19);  PARS Global Storage MND, Murietta (2019; 13);  Slover Warehouse EIR Addendum, Fontana (2019; 16);  Seefried Warehouse Project IS/MND, Lathrop (2019; 19)  World Logistics Center Site Visit, Moreno Valley (2019; 19);  Merced Landfill Gas-To-Energy Project IS/MND (2019; 12);  West Village Expansion FEIR, UC Davis (2019; 11);  Site visit, Doheny Ocean Desalination EIR, Dana Point (2019; 11);  Replies to responses on Avalon West Valley Expansion EIR, San Jose (2019; 10);  Avalon West Valley Expansion EIR, San Jose (2019; 22);  Sunroad – Otay 50 EIR Addendum, San Diego (2019; 26);  Del Rey Pointe Residential Project IS/MND, Los Angeles (2019; 34);  1 AMD Redevelopment EIR, Sunnyvale (2019; 22);  Lawrence Equipment Industrial Warehouse IS/MND, Banning (2019; 14);  SDG Commerce 330 Warehouse IS, American Canyon (2019; 21);  PAMA Business Center IS/MND, Moreno Valley (2019; 23);  Cupertino Village Hotel IS (2019; 24);  Lake House IS/ND, Lodi (2019; 33);  Campo Wind Project DEIS, San Diego County (DEIS, (2019; 14);  Stirling Warehouse MND site visit, Victorville (2019; 7);  Green Valley II Mixed-Use Project EIR, Fairfield (2019; 36);  We Be Jammin rezone MND, Fresno (2019; 14);  Gray Whale Cove Pedestrian Crossing IS/ND, Pacifica (2019; 7);  Visalia Logistics Center & DDG 697V Staff Report (2019; 9);  Mather South Community Masterplan Project EIR (2019; 35);  Del Hombre Apartments EIR, Walnut Creek (2019; 23);  Otay Ranch Planning Area 12 EIR Addendum, Chula Vista (2019; 21);  The Retreat at Sacramento IS/MND (2019; 26);  Site visit to Sunroad – Centrum 6 EIR Addendum, San Diego (2019; 9);  Sunroad – Centrum 6 EIR Addendum, San Diego (2018; 22);  North First and Brokaw Corporate Campus Buildings EIR Addendum, San Jose (2018; 30); Smallwood CV 35  South Lake Solar IS, Fresno County (2018; 18);  Galloo Island Wind Project Application, New York (not submitted) (2018; 44);  Doheny Ocean Desalination EIR, Dana Point (2018; 15);  Stirling Warehouse MND, Victorville (2018; 18);  LDK Warehouse MND, Vacaville (2018; 30);  Gateway Crossings FEIR, Santa Clara (2018; 23);  South Hayward Development IS/MND (2018; 9);  CBU Specific Plan Amendment, Riverside (2018; 27);  2nd replies to responses on Dove Hill Road Assisted Living Project MND (2018; 11);  Replies to responses on Dove Hill Road Assisted Living Project MND (2018; 7);  Dove Hill Road Assisted Living Project MND (2018; 12);  Deer Ridge/Shadow Lakes Golf Course EIR, Brentwood (2018; 21);  Pyramid Asphalt BLM Finding of No Significance, Imperial County (2018; 22);  Amáre Apartments IS/MND, Martinez (2018; 15);  Petaluma Hill Road Cannabis MND, Santa Rosa (2018; 21);  2nd comments on Zeiss Innovation Center IS/MND, Dublin (2018: 12);  Zeiss Innovation Center IS/MND, Dublin (2018: 32);  City of Hope Campus Plan EIR, Duarte (2018; 21);  Palo Verde Center IS/MND, Blythe (2018; 14);  Logisticenter at Vacaville MND (2018; 24);  IKEA Retail Center SEIR, Dublin (2018; 17);  Merge 56 EIR, San Diego (2018; 15);  Natomas Crossroads Quad B Office Project P18-014 EIR, Sacramento (2018; 12);  2900 Harbor Bay Parkway Staff Report, Alameda (2018; 30);  At Dublin EIR, Dublin (2018; 25);  Fresno Industrial Rezone Amendment Application No. 3807 IS (2018; 10);  Nova Business Park IS/MND, Napa (2018; 18);  Updated Collision Risk Model Priors for Estimating Eagle Fatalities, USFWS (2018; 57);  750 Marlborough Avenue Warehouse MND, Riverside (2018; 14);  Replies to responses on San Bernardino Logistics Center IS (2018; 12);  San Bernardino Logistics Center IS (2018; 19);  CUP2017-16, Costco IS/MND, Clovis (2018; 11);  Desert Land Ventures Specific Plan EIR, Desert Hot Springs (2018; 18);  Ventura Hilton IS/MND (2018; 30);  North of California Street Master Plan Project IS, Mountain View (2018: 11);  Tamarind Warehouse MND, Fontana (2018; 16);  Lathrop Gateway Business Park EIR Addendum (2018; 23);  Centerpointe Commerce Center IS, Moreno Valley (2019; 18);  Amazon Warehouse Notice of Exemption, Bakersfield (2018; 13);  CenterPoint Building 3 project Staff Report, Manteca (2018; 23);  Cessna & Aviator Warehouse IS/MND, Vacaville (2018; 24);  Napa Airport Corporate Center EIR, American Canyon (2018, 15);  800 Opal Warehouse Initial Study, Mentone, San Bernardino County (2018; 18);  2695 W. Winton Ave Industrial Project IS, Hayward (2018; 22); Smallwood CV 36  Trinity Cannabis Cultivation and Manufacturing Facility DEIR, Calexico (2018; 15);  Shoe Palace Expansion IS/MND, Morgan Hill (2018; 21);  Newark Warehouse at Morton Salt Plant Staff Report (2018; 15);  Northlake Specific Plan FEIR “Peer Review”, Los Angeles County (2018; 9);  Replies to responses on Northlake Specific Plan SEIR, Los Angeles County (2018; 13);  Northlake Specific Plan SEIR, Los Angeles County (2017; 27);  Bogle Wind Turbine DEIR, east Yolo County (2017; 48);  Ferrante Apartments IS/MND, Los Angeles (2017; 14);  The Villages of Lakeview EIR, Riverside (2017; 28);  Data Needed for Assessing Trail Management Impacts on Northern Spotted Owl, Marin County (2017; 5);  Notes on Proposed Study Options for Trail Impacts on Northern Spotted Owl (2017; 4);  Pyramid Asphalt IS, Imperial County (Declaration) (2017; 5);  San Gorgonio Crossings EIR, Riverside County (2017; 22);  Replies to responses on Jupiter Project IS and MND, Apple Valley (2017; 12);  Proposed World Logistics Center Mitigation Measures, Moreno Valley (2017, 2019; 12);  MacArthur Transit Village Project Modified 2016 CEQA Analysis (2017; 12);  PG&E Company Bay Area Operations and Maintenance HCP (2017; 45);  Central SoMa Plan DEIR (2017; 14);  Suggested mitigation for trail impacts on northern spotted owl, Marin County (2016; 5);  Colony Commerce Center Specific Plan DEIR, Ontario (2016; 16);  Fairway Trails Improvements MND, Marin County (2016; 13);  Review of Avian-Solar Science Plan (2016; 28);  Replies on Pyramid Asphalt IS, Imperial County (2016; 5);  Pyramid Asphalt IS, Imperial County (2016; 4);  Agua Mansa Distribution Warehouse Project Initial Study (2016; 14);  Santa Anita Warehouse MND, Rancho Cucamonga (2016; 12);  CapRock Distribution Center III DEIR, Rialto (2016: 12);  Orange Show Logistics Center IS/MND, San Bernardino (2016; 9);  City of Palmdale Oasis Medical Village Project IS/MND (2016; 7);  Comments on proposed rule for incidental eagle take, USFWS (2016, 49);  Replies on Grapevine Specific and Community Plan FEIR, Kern County (2016; 25);  Grapevine Specific and Community Plan DEIR, Kern County (2016; 15);  Clinton County Zoning Ordinance for Wind Turbine siting (2016);  Hallmark at Shenandoah Warehouse Project Initial Study, San Bernardino (2016; 6);  Tri-City Industrial Complex Initial Study, San Bernardino (2016; 5);  Hidden Canyon Industrial Park Plot Plan 16-PP-02, Beaumont (2016; 12);  Kimball Business Park DEIR (2016; 10);  Jupiter Project IS and MND, Apple Valley, San Bernardino County (2016; 9);  Revised Draft Giant Garter Snake Recovery Plan of 2015 (2016, 18);  Palo Verde Mesa Solar Project EIR, Blythe (2016; 27);  Reply on Fairview Wind Project Natural Heritage Assessment, Ontario, Canada (2016; 14);  Fairview Wind Project Natural Heritage Assessment, Ontario, Canada (2016; 41);  Reply on Amherst Island Wind Farm Natural Heritage Assessment, Ontario (2015, 38); Smallwood CV 37  Amherst Island Wind Farm Natural Heritage Assessment, Ontario (2015, 31);  Second Reply on White Pines Wind Farm, Ontario (2015, 6);  Reply on White Pines Wind Farm Natural Heritage Assessment, Ontario (2015, 10);  White Pines Wind Farm Natural Heritage Assessment, Ontario (2015, 9);  Proposed Section 24 Specific Plan Agua Caliente Band of Cahuilla Indians DEIS (2015, 9);  Replies on 24 Specific Plan Agua Caliente Band of Cahuilla Indians FEIS (2015, 6);  Sierra Lakes Commerce Center Project DEIR, Fontana (2015, 9);  Columbia Business Center MND, Riverside (2015; 8);  West Valley Logistics Center Specific Plan DEIR, Fontana (2015, 10);  Willow Springs Solar Photovoltaic Project DEIR (2015, 28);  Alameda Creek Bridge Replacement Project DEIR (2015, 10);  World Logistic Center Specific Plan FEIR, Moreno Valley (2015, 12);  Elkhorn Valley Wind Power Project Impacts, Oregon (2015; 143);  Bay Delta Conservation Plan EIR/EIS, Sacramento (2014, 21);  Addison Wind Energy Project DEIR, Mojave (2014, 32);  Replies on the Addison Wind Energy Project DEIR, Mojave (2014, 15);  Addison and Rising Tree Wind Energy Project FEIR, Mojave (2014, 12);  Palen Solar Electric Generating System FSA (CEC), Blythe (2014, 20);  Rebuttal testimony on Palen Solar Energy Generating System (2014, 9);  Seven Mile Hill and Glenrock/Rolling Hills impacts + Addendum, Wyoming (2014; 105);  Rising Tree Wind Energy Project DEIR, Mojave (2014, 32);  Replies on the Rising Tree Wind Energy Project DEIR, Mojave (2014, 15);  Soitec Solar Development Project PEIR, Boulevard, San Diego County (2014, 18);  Oakland Zoo expansion on Alameda whipsnake and California red-legged frog (2014; 3);  Alta East Wind Energy Project FEIS, Tehachapi Pass (2013, 23);  Blythe Solar Power Project Staff Assessment, California Energy Commission (2013, 16);  Clearwater and Yakima Solar Projects DEIR, Kern County (2013, 9);  West Antelope Solar Energy Project IS/MND, Antelope Valley (2013, 18);  Cuyama Solar Project DEIR, Carrizo Plain (2014, 19);  Desert Renewable Energy Conservation Plan (DRECP) EIR/EIS (2015, 49);  Kingbird Solar Photovoltaic Project EIR, Kern County (2013, 19);  Lucerne Valley Solar Project IS/MND, San Bernardino County (2013, 12);  Tule Wind project FEIR/FEIS (Declaration) (2013; 31);  Sunlight Partners LANDPRO Solar Project MND (2013; 11);  Declaration in opposition to BLM fracking (2013; 5);  Blythe Energy Project (solar) CEC Staff Assessment (2013;16);  Rosamond Solar Project EIR Addendum, Kern County (2013; 13);  Pioneer Green Solar Project EIR, Bakersfield (2013; 13);  Replies on Soccer Center Solar Project MND (2013; 6);  Soccer Center Solar Project MND, Lancaster (2013; 10);  Plainview Solar Works MND, Lancaster (2013; 10);  Alamo Solar Project MND, Mojave Desert (2013; 15);  Replies on Imperial Valley Solar Company 2 Project (2013; 10);  Imperial Valley Solar Company 2 Project (2013; 13); Smallwood CV 38  FRV Orion Solar Project DEIR, Kern County (PP12232) (2013; 9);  Casa Diablo IV Geothermal Development Project (2013; 6);  Reply on Casa Diablo IV Geothermal Development Project (2013; 8);  Alta East Wind Project FEIS, Tehachapi Pass (2013; 23);  Metropolitan Air Park DEIR, City of San Diego (2013; );  Davidon Homes Tentative Subdivision Rezoning Project DEIR, Petaluma (2013; 9);  Oakland Zoo Expansion Impacts on Alameda Whipsnake (2013; 10);  Campo Verde Solar project FEIR, Imperial Valley (2013; 11pp);  Neg Dec comments on Davis Sewer Trunk Rehabilitation (2013; 8);  North Steens Transmission Line FEIS, Oregon (Declaration) (2012; 62);  Summer Solar and Springtime Solar Projects IS/MND Lancaster (2012; 8);  J&J Ranch, 24 Adobe Lane Environmental Review, Orinda (2012; 14);  Replies on Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II (2012; 8);  Hudson Ranch Power II Geothermal Project and Simbol Calipatria Plant II (2012; 9);  Desert Harvest Solar Project EIS, near Joshua Tree (2012; 15);  Solar Gen 2 Array Project DEIR, El Centro (2012; 16);  Ocotillo Sol Project EIS, Imperial Valley (2012; 4);  Beacon Photovoltaic Project DEIR, Kern County (2012; 5);  Butte Water District 2012 Water Transfer Program IS/MND (2012; 11);  Mount Signal and Calexico Solar Farm Projects DEIR (2011; 16);  City of Elk Grove Sphere of Influence EIR (2011; 28);  Sutter Landing Park Solar Photovoltaic Project MND, Sacramento (2011; 9);  Rabik/Gudath Project, 22611 Coleman Valley Road, Bodega Bay (CPN 10-0002) (2011; 4);  Ivanpah Solar Electric Generating System (ISEGS) (Declaration) (2011; 9);  Draft Eagle Conservation Plan Guidance, USFWS (2011; 13);  Niles Canyon Safety Improvement Project EIR/EA (2011; 16);  Route 84 Safety Improvement Project (Declaration) (2011; 7);  Rebuttal on Whistling Ridge Wind Energy Power DEIS, Skamania County, (2010; 6);  Whistling Ridge Wind Energy Power DEIS, Skamania County, Washington (2010; 41);  Klickitat County’s Decisions on Windy Flats West Wind Energy Project (2010; 17);  St. John's Church Project DEIR, Orinda (2010; 14);  Results Radio Zone File #2009-001 IS/MND, Conaway site, Davis (2010; 20);  Rio del Oro Specific Plan Project FEIR, Rancho Cordova (2010;12);  Results Radio Zone File #2009-001, Mace Blvd site, Davis (2009; 10);  Answers to Questions on 33% RPS Implementation Analysis Preliminary Results Report (2009; 9);  SEPA Determination of Non-significance regarding zoning adjustments for Skamania County, Washington (Second Declaration) (2008; 17);  Draft 1A Summary Report to CAISO (2008; 10);  Hilton Manor Project Categorical Exemption, County of Placer (2009; 9);  Protest of CARE to Amendment to the Power Purchase and Sale Agreement for Procurement of Eligible Renewable Energy Resources Between Hatchet Ridge Wind LLC and PG&E (2009; 3); Smallwood CV 39  Tehachapi Renewable Transmission Project EIR/EIS (2009; 142);  Delta Shores Project EIR, south Sacramento (2009; 11 + addendum 2);  Declaration in Support of Care’s Petition to Modify D.07-09-040 (2008; 3);  The Public Utility Commission’s Implementation Analysis December 16 Workshop for the Governor’s Executive Order S-14-08 to implement a 33% Renewable Portfolio Standard by 2020 (2008; 9);  The Public Utility Commission’s Implementation Analysis Draft Work Plan for the Governor’s Executive Order S-14-08 to implement a 33% Renewable Portfolio Standard by 2020 (2008; 11);  Draft 1A Summary Report to California Independent System Operator for Planning Reserve Margins (PRM) Study (2008; 7.);  SEPA Determination of Non-significance regarding zoning adjustments for Skamania County, Washington (Declaration) (2008; 16);  Colusa Generating Station, California Energy Commission PSA (2007; 24);  Rio del Oro Specific Plan Project Recirculated DEIR, Mather (2008: 66);  Replies on Regional University Specific Plan EIR, Roseville (2008; 20);  Regional University Specific Plan EIR, Roseville (2008: 33);  Clark Precast, LLC’s “Sugarland” project, ND, Woodland (2008: 15);  Cape Wind Project DEIS, Nantucket (2008; 157);  Yuba Highlands Specific Plan EIR, Spenceville, Yuba County (2006; 37);  Replies to responses on North Table Mountain MND, Butte County (2006; 5);  North Table Mountain MND, Butte County (2006; 15);  Windy Point Wind Farm EIS (2006; 14 and Powerpoint slide replies);  Shiloh I Wind Power Project EIR, Rio Vista (2005; 18);  Buena Vista Wind Energy Project NOP, Byron (2004; 15);  Callahan Estates Subdivision ND, Winters (2004; 11);  Winters Highlands Subdivision IS/ND (2004; 9);  Winters Highlands Subdivision IS/ND (2004; 13);  Creekside Highlands Project, Tract 7270 ND (2004; 21);  Petition to California Fish and Game Commission to list Burrowing Owl (2003; 10);  Altamont Pass Wind Resource Area CUP renewals, Alameda County (2003; 41);  UC Davis Long Range Development Plan: Neighborhood Master Plan (2003; 23);  Anderson Marketplace Draft Environmental Impact Report (2003; 18);  Negative Declaration of the proposed expansion of Temple B’nai Tikyah (2003; 6);  Antonio Mountain Ranch Specific Plan Public Draft EIR (2002; 23);  Replies on East Altamont Energy Center evidentiary hearing (2002; 9);  Revised Draft Environmental Impact Report, The Promenade (2002; 7);  Recirculated Initial Study for Calpine’s proposed Pajaro Valley Energy Center (2002; 3);  UC Merced -- Declaration (2002; 5);  Replies on Atwood Ranch Unit III Subdivision FEIR (2003; 22);  Atwood Ranch Unit III Subdivision EIR (2002; 19);  California Energy Commission Staff Report on GWF Tracy Peaker Project (2002; 20);  Silver Bend Apartments IS/MND, Placer County (2002; 13);  UC Merced Long-range Development Plan DEIR and UC Merced Community Plan DEIR (2001; 26); Smallwood CV 40  Colusa County Power Plant IS, Maxwell (2001; 6);  Dog Park at Catlin Park, Folsom, California (2001; 5);  Calpine and Bechtel Corporations’ Biological Resources Implementation and Monitoring Program (BRMIMP) for the Metcalf Energy Center (2000; 10);  Metcalf Energy Center, California Energy Commission FSA (2000);  US Fish and Wildlife Service Section 7 consultation with the California Energy Commission regarding Calpine and Bechtel Corporations’ Metcalf Energy Center (2000; 4);  California Energy Commission’s Preliminary Staff Assessment of the proposed Metcalf Energy Center (2000: 11);  Site-specific management plans for the Natomas Basin Conservancy’s mitigation lands, prepared by Wildlands, Inc. (2000: 7);  Affidavit of K. Shawn Smallwood in Spirit of the Sage Council, et al. (Plaintiffs) vs. Bruce Babbitt, Secretary, U.S. Department of the Interior, et al. (Defendants), Injuries caused by the No Surprises policy and final rule which codifies that policy (1999: 9).  California Board of Forestry’s proposed amended Forest Practices Rules (1999);  Sunset Skyranch Airport Use Permit IS/MND (1999);  Ballona West Bluffs Project Environmental Impact Report (1999; oral presentation);  Draft Recovery Plan for Giant Garter Snake (Fed. Reg. 64(176): 49497-49498) (1999; 8);  Draft Recovery Plan for Arroyo Southwestern Toad (1998);  Pacific Lumber Co. (Headwaters) HCP & EIR, Fortuna (1998; 28);  Natomas Basin HCP Permit Amendment, Sacramento (1998);  San Diego Multi-Species Conservation Program FEIS/FEIR (1997; 10); Comments on other Environmental Review Documents:  Proposed Regulation for California Fish and Game Code Section 3503.5 (2015: 12);  Statement of Overriding Considerations related to extending Altamont Winds, Inc.’s Conditional Use Permit PLN2014-00028 (2015; 8);  Covell Village PEIR, Davis (2005; 19);  Bureau of Land Management Wind Energy Programmatic EIS Scoping (2003; 7.);  NEPA Environmental Analysis for Biosafety Level 4 National Biocontainment Laboratory (NBL) at UC Davis (2003: 7);  Notice of Preparation of UC Merced Community and Area Plan EIR, on behalf of The Wildlife Society—Western Section (2001: 8.);  Preliminary Draft Yolo County Habitat Conservation Plan (2001; 2 letters totaling 35.);  Merced County General Plan Revision, notice of Negative Declaration (2001: 2.);  Notice of Preparation of Campus Parkway EIR/EIS (2001: 7.);  Draft Recovery Plan for the bighorn sheep in the Peninsular Range (Ovis candensis) (2000);  Draft Recovery Plan for the California Red-legged Frog (Rana aurora draytonii), on behalf of The Wildlife Society—Western Section (2000: 10.);  Sierra Nevada Forest Plan Amendment Draft Environmental Impact Statement, on behalf of The Wildlife Society—Western Section (2000: 7.);  State Water Project Supplemental Water Purchase Program, Draft Program EIR (1997);  Davis General Plan Update EIR (2000);  Turn of the Century EIR (1999: 10); Smallwood CV 41  Proposed termination of Critical Habitat Designation under the Endangered Species Act (Fed. Reg. 64(113): 31871-31874) (1999);  NOA Draft Addendum to the Final Handbook for Habitat Conservation Planning and Incidental Take Permitting Process, termed the HCP 5-Point Policy Plan (Fed. Reg. 64(45): 11485 - 11490) (1999; 2 + attachments);  Covell Center Project EIR and EIR Supplement (1997). Position Statements I prepared the following position statements for the Western Section of The Wildlife Society, and one for nearly 200 scientists:  Recommended that the California Department of Fish and Game prioritize the extermination of the introduced southern water snake in northern California. The Wildlife Society-- Western Section (2001);  Recommended that The Wildlife Society—Western Section appoint or recommend members of the independent scientific review panel for the UC Merced environmental review process (2001);  Opposed the siting of the University of California’s 10th campus on a sensitive vernal pool/grassland complex east of Merced. The Wildlife Society--Western Section (2000);  Opposed the legalization of ferret ownership in California. The Wildlife Society--Western Section (2000);  Opposed the Proposed “No Surprises,” “Safe Harbor,” and “Candidate Conservation Agreement” rules, including permit-shield protection provisions (Fed. Reg. Vol. 62, No. 103, pp. 29091-29098 and No. 113, pp. 32189-32194). This statement was signed by 188 scientists and went to the responsible federal agencies, as well as to the U.S. Senate and House of Representatives. Posters at Professional Meetings Leyvas, E. and K. S. Smallwood. 2015. Rehabilitating injured animals to offset and rectify wind project impacts. Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 9-12 March 2015. Smallwood, K. S., J. Mount, S. Standish, E. Leyvas, D. Bell, E. Walther, B. Karas. 2015. Integrated detection trials to improve the accuracy of fatality rate estimates at wind projects. Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 9-12 March 2015. Smallwood, K. S. and C. G. Thelander. 2005. Lessons learned from five years of avian mortality research in the Altamont Pass WRA. AWEA conference, Denver, May 2005. Neher, L., L. Wilder, J. Woo, L. Spiegel, D. Yen-Nakafugi, and K.S. Smallwood. 2005. Bird’s eye view on California wind. AWEA conference, Denver, May 2005. Smallwood, K. S., C. G. Thelander and L. Spiegel. 2003. Toward a predictive model of avian fatalities in the Altamont Pass Wind Resource Area. Windpower 2003 Conference and Convention, Austin, Texas. Smallwood, K.S. and Eva Butler. 2002. Pocket Gopher Response to Yellow Star-thistle Eradication as part of Grassland Restoration at Decommissioned Mather Air Force Base, Sacramento County, Smallwood CV 42 California. White Mountain Research Station Open House, Barcroft Station. Smallwood, K.S. and Michael L. Morrison. 2002. Fresno kangaroo rat (Dipodomys nitratoides) Conservation Research at Resources Management Area 5, Lemoore Naval Air Station. White Mountain Research Station Open House, Barcroft Station. Smallwood, K.S. and E.L. Fitzhugh. 1989. Differentiating mountain lion and dog tracks. Third Mountain Lion Workshop, Prescott, AZ. Smith, T. R. and K. S. Smallwood. 2000. Effects of study area size, location, season, and allometry on reported Sorex shrew densities. Annual Meeting of the Western Section of The Wildlife Society. Presentations at Professional Meetings and Seminars Long-Term Population Trend of Burrowing Owls in the Altamont. Golden Gate Audubon, 21 October 2020. Long-Term Population Trend of Burrowing Owls in the Altamont. East Bay Regional Park District 2020 Stewardship Seminar, Oakland, California, 18 November 2020. Smallwood, K.S., D.A. Bell, and S, Standish. Dogs detect larger wind energy effects on bats and birds. The Wildlife Society, 28 September 2020. Smallwood, K.S. and D.A. Bell. Effects of wind turbine curtailment on bird and bat fatalities in the Altamont Pass Wind Resource Area. The Wildlife Society, 28 September 2020. Smallwood, K.S., D.A. Bell, and S, Standish. Dogs detect larger wind energy effects on bats and birds. The Wildlife Survey, 7 February 2020. Smallwood, K.S. and D.A. Bell. Effects of wind turbine curtailment on bird and bat fatalities in the Altamont Pass Wind Resource Area. The Wildlife Survey, 7 February 2020. Dog detections of bat and bird fatalities at wind farms in the Altamont Pass Wind Resource Area. East Bay Regional Park District 2019 Stewardship Seminar, Oakland, California, 13 November 2019. Repowering the Altamont Pass. Altamont Symposium, The Wildlife Society – Western Section, 5 February 2017. Developing methods to reduce bird mortality in the Altamont Pass Wind Resource Area, 1999- 2007. Altamont Symposium, The Wildlife Society – Western Section, 5 February 2017. Conservation and recovery of burrowing owls in Santa Clara Valley. Santa Clara Valley Habitat Agency, Newark, California, 3 February 2017. Mitigation of Raptor Fatalities in the Altamont Pass Wind Resource Area. Raptor Research Foundation Meeting, Sacramento, California, 6 November 2015. Smallwood CV 43 From burrows to behavior: Research and management for burrowing owls in a diverse landscape. California Burrowing Owl Consortium meeting, 24 October 2015, San Jose, California. The Challenges of repowering. Keynote presentation at Conference on Wind Energy and Wildlife Impacts, Berlin, Germany, 10 March 2015. Research Highlights Altamont Pass 2011-2015. Scientific Review Committee, Oakland, California, 8 July 2015. Siting wind turbines to minimize raptor collisions: Altamont Pass Wind Resource Area. US Fish and Wildlife Service Golden Eagle Working Group, Sacramento, California, 8 January 2015. Evaluation of nest boxes as a burrowing owl conservation strategy. Sacramento Chapter of the Western Section, The Wildlife Society. Sacramento, California, 26 August 2013. Predicting collision hazard zones to guide repowering of the Altamont Pass. Conference on wind power and environmental impacts. Stockholm, Sweden, 5-7 February 2013. Impacts of Wind Turbines on Wildlife. California Council for Wildlife Rehabilitators, Yosemite, California, 12 November 2012. Impacts of Wind Turbines on Birds and Bats. Madrone Audubon Society, Santa Rosa, California, 20 February 2012. Comparing Wind Turbine Impacts across North America. California Energy Commission Staff Workshop: Reducing the Impacts of Energy Infrastructure on Wildlife, 20 July 2011. Siting Repowered Wind Turbines to Minimize Raptor Collisions. California Energy Commission Staff Workshop: Reducing the Impacts of Energy Infrastructure on Wildlife, 20 July 2011. Siting Repowered Wind Turbines to Minimize Raptor Collisions. Alameda County Scientific Review Committee meeting, 17 February 2011 Comparing Wind Turbine Impacts across North America. Conference on Wind energy and Wildlife impacts, Trondheim, Norway, 3 May 2011. Update on Wildlife Impacts in the Altamont Pass Wind Resource Area. Raptor Symposium, The Wildlife Society—Western Section, Riverside, California, February 2011. Siting Repowered Wind Turbines to Minimize Raptor Collisions. Raptor Symposium, The Wildlife Society - Western Section, Riverside, California, February 2011. Wildlife mortality caused by wind turbine collisions. Ecological Society of America, Pittsburgh, Pennsylvania, 6 August 2010. Map-based repowering and reorganization of a wind farm to minimize burrowing owl fatalities. California burrowing Owl Consortium Meeting, Livermore, California, 6 February 2010. Smallwood CV 44 Environmental barriers to wind power. Getting Real About Renewables: Economic and Environmental Barriers to Biofuels and Wind Energy. A symposium sponsored by the Environmental & Energy Law & Policy Journal, University of Houston Law Center, Houston, 23 February 2007. Lessons learned about bird collisions with wind turbines in the Altamont Pass and other US wind farms. Meeting with Japan Ministry of the Environment and Japan Ministry of the Economy, Wild Bird Society of Japan, and other NGOs Tokyo, Japan, 9 November 2006. Lessons learned about bird collisions with wind turbines in the Altamont Pass and other US wind farms. Symposium on bird collisions with wind turbines. Wild Bird Society of Japan, Tokyo, Japan, 4 November 2006. Responses of Fresno kangaroo rats to habitat improvements in an adaptive management framework. California Society for Ecological Restoration (SERCAL) 13th Annual Conference, UC Santa Barbara, 27 October 2006. Fatality associations as the basis for predictive models of fatalities in the Altamont Pass Wind Resource Area. EEI/APLIC/PIER Workshop, 2006 Biologist Task Force and Avian Interaction with Electric Facilities Meeting, Pleasanton, California, 28 April 2006. Burrowing owl burrows and wind turbine collisions in the Altamont Pass Wind Resource Area. The Wildlife Society - Western Section Annual Meeting, Sacramento, California, February 8, 2006. Mitigation at wind farms. Workshop: Understanding and resolving bird and bat impacts. American Wind Energy Association and Audubon Society. Los Angeles, CA. January 10 and 11, 2006. Incorporating data from the California Wildlife Habitat Relationships (CWHR) system into an impact assessment tool for birds near wind farms. Shawn Smallwood, Kevin Hunting, Marcus Yee, Linda Spiegel, Monica Parisi. Workshop: Understanding and resolving bird and bat impacts. American Wind Energy Association and Audubon Society. Los Angeles, CA. January 10 and 11, 2006. Toward indicating threats to birds by California’s new wind farms. California Energy Commission, Sacramento, May 26, 2005. Avian collisions in the Altamont Pass. California Energy Commission, Sacramento, May 26, 2005. Ecological solutions for avian collisions with wind turbines in the Altamont Pass Wind Resource Area. EPRI Environmental Sector Council, Monterey, California, February 17, 2005. Ecological solutions for avian collisions with wind turbines in the Altamont Pass Wind Resource Area. The Wildlife Society—Western Section Annual Meeting, Sacramento, California, January 19, 2005. Associations between avian fatalities and attributes of electric distribution poles in California. The Wildlife Society - Western Section Annual Meeting, Sacramento, California, January 19, 2005. Smallwood CV 45 Minimizing avian mortality in the Altamont Pass Wind Resources Area. UC Davis Wind Energy Collaborative Forum, Palm Springs, California, December 14, 2004. Selecting electric distribution poles for priority retrofitting to reduce raptor mortality. Raptor Research Foundation Meeting, Bakersfield, California, November 10, 2004. Responses of Fresno kangaroo rats to habitat improvements in an adaptive management framework. Annual Meeting of the Society for Ecological Restoration, South Lake Tahoe, California, October 16, 2004. Lessons learned from five years of avian mortality research at the Altamont Pass Wind Resources Area in California. The Wildlife Society Annual Meeting, Calgary, Canada, September 2004. The ecology and impacts of power generation at Altamont Pass. Sacramento Petroleum Association, Sacramento, California, August 18, 2004. Burrowing owl mortality in the Altamont Pass Wind Resource Area. California Burrowing Owl Consortium meeting, Hayward, California, February 7, 2004. Burrowing owl mortality in the Altamont Pass Wind Resource Area. California Burrowing Owl Symposium, Sacramento, November 2, 2003. Raptor Mortality at the Altamont Pass Wind Resource Area. National Wind Coordinating Committee, Washington, D.C., November 17, 2003. Raptor Behavior at the Altamont Pass Wind Resource Area. Annual Meeting of the Raptor Research Foundation, Anchorage, Alaska, September, 2003. Raptor Mortality at the Altamont Pass Wind Resource Area. Annual Meeting of the Raptor Research Foundation, Anchorage, Alaska, September, 2003. California mountain lions. Ecological & Environmental Issues Seminar, Department of Biology, California State University, Sacramento, November, 2000. Intra- and inter-turbine string comparison of fatalities to animal burrow densities at Altamont Pass. National Wind Coordinating Committee, Carmel, California, May, 2000. Using a Geographic Positioning System (GPS) to map wildlife and habitat. Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000. Suggested standards for science applied to conservation issues. Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000. The indicators framework applied to ecological restoration in Yolo County, California. Society for Ecological Restoration, September 25, 1999. Ecological restoration in the context of animal social units and their habitat areas. Society for Ecological Restoration, September 24, 1999. Smallwood CV 46 Relating Indicators of Ecological Health and Integrity to Assess Risks to Sustainable Agriculture and Native Biota. International Conference on Ecosystem Health, August 16, 1999. A crosswalk from the Endangered Species Act to the HCP Handbook and real HCPs. Southern California Edison, Co. and California Energy Commission, March 4-5, 1999. Mountain lion track counts in California: Implications for Management. Ecological & Environmental Issues Seminar, Department of Biological Sciences, California State University, Sacramento, November 4, 1998. “No Surprises” -- Lack of science in the HCP process. California Native Plant Society Annual Conservation Conference, The Presidio, San Francisco, September 7, 1997. In Your Interest. A half hour weekly show aired on Channel 10 Television, Sacramento. In this episode, I served on a panel of experts discussing problems with the implementation of the Endangered Species Act. Aired August 31, 1997. Spatial scaling of pocket gopher (Geomyidae) density. Southwestern Association of Naturalists 44th Meeting, Fayetteville, Arkansas, April 10, 1997. Estimating prairie dog and pocket gopher burrow volume. Southwestern Association of Naturalists 44th Meeting, Fayetteville, Arkansas, April 10, 1997. Ten years of mountain lion track survey. Fifth Mountain Lion Workshop, San Diego, February 27, 1996. Study and interpretive design effects on mountain lion density estimates. Fifth Mountain Lion Workshop, San Diego, February 27, 1996. Small animal control. Session moderator and speaker at the California Farm Conference, Sacramento, California, Feb. 28, 1995. Small animal control. Ecological Farming Conference, Asylomar, California, Jan. 28, 1995. Habitat associations of the Swainson’s Hawk in the Sacramento Valley’s agricultural landscape. 1994 Raptor Research Foundation Meeting, Flagstaff, Arizona. Alfalfa as wildlife habitat. Seed Industry Conference, Woodland, California, May 4, 1994. Habitats and vertebrate pests: impacts and management. Managing Farmland to Bring Back Game Birds and Wildlife to the Central Valley. Yolo County Resource Conservation District, U.C. Davis, February 19, 1994. Management of gophers and alfalfa as wildlife habitat. Orland Alfalfa Production Meeting and Sacramento Valley Alfalfa Production Meeting, February 1 and 2, 1994. Patterns of wildlife movement in a farming landscape. Wildlife and Fisheries Biology Seminar Smallwood CV 47 Series: Recent Advances in Wildlife, Fish, and Conservation Biology, U.C. Davis, Dec. 6, 1993. Alfalfa as wildlife habitat. California Alfalfa Symposium, Fresno, California, Dec. 9, 1993. Management of pocket gophers in Sacramento Valley alfalfa. California Alfalfa Symposium, Fresno, California, Dec. 8, 1993. Association analysis of raptors in a farming landscape. Plenary speaker at Raptor Research Foundation Meeting, Charlotte, North Carolina, Nov. 6, 1993. Landscape strategies for biological control and IPM. Plenary speaker, International Conference on Integrated Resource Management and Sustainable Agriculture, Beijing, China, Sept. 11, 1993. Landscape Ecology Study of Pocket Gophers in Alfalfa. Alfalfa Field Day, U.C. Davis, July 1993. Patterns of wildlife movement in a farming landscape. Spatial Data Analysis Colloquium, U.C. Davis, August 6, 1993. Sound stewardship of wildlife. Veterinary Medicine Seminar: Ethics of Animal Use, U.C. Davis. May 1993. Landscape ecology study of pocket gophers in alfalfa. Five County Grower's Meeting, Tracy, California. February 1993. Turbulence and the community organizers: The role of invading species in ordering a turbulent system, and the factors for invasion success. Ecology Graduate Student Association Colloquium, U.C. Davis. May 1990. Evaluation of exotic vertebrate pests. Fourteenth Vertebrate Pest Conference, Sacramento, California. March 1990. Analytical methods for predicting success of mammal introductions to North America. The Western Section of the Wildlife Society, Hilo, Hawaii. February 1988. A state-wide mountain lion track survey. Sacramento County Dept Parks and Recreation. April 1986. The mountain lion in California. Davis Chapter of the Audubon Society. October 1985. Ecology Graduate Student Seminars, U.C. Davis, 1985-1990: Social behavior of the mountain lion; Mountain lion control; Political status of the mountain lion in California. Other forms of Participation at Professional Meetings  Scientific Committee, Conference on Wind energy and Wildlife impacts, Berlin, Germany, March 2015.  Scientific Committee, Conference on Wind energy and Wildlife impacts, Stockholm, Smallwood CV 48 Sweden, February 2013.  Workshop co-presenter at Birds & Wind Energy Specialist Group (BAWESG) Information sharing week, Bird specialist studies for proposed wind energy facilities in South Africa, Endangered Wildlife Trust, Darling, South Africa, 3-7 October 2011.  Scientific Committee, Conference on Wind energy and Wildlife impacts, Trondheim, Norway, 2-5 May 2011.  Chair of Animal Damage Management Session, The Wildlife Society, Annual Meeting, Reno, Nevada, September 26, 2001.  Chair of Technical Session: Human communities and ecosystem health: Comparing perspectives and making connection. Managing for Ecosystem Health, International Congress on Ecosystem Health, Sacramento, CA August 15-20, 1999.  Student Awards Committee, Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000.  Student Mentor, Annual Meeting of the Western Section of The Wildlife Society, Riverside, CA, January, 2000. Printed Mass Media Smallwood, K.S., D. Mooney, and M. McGuinness. 2003. We must stop the UCD biolab now. Op- Ed to the Davis Enterprise. Smallwood, K.S. 2002. Spring Lake threatens Davis. Op-Ed to the Davis Enterprise. Smallwood, K.S. Summer, 2001. Mitigation of habitation. The Flatlander, Davis, California. Entrikan, R.K. and K.S. Smallwood. 2000. Measure O: Flawed law would lock in new taxes. Op-Ed to the Davis Enterprise. Smallwood, K.S. 2000. Davis delegation lobbies Congress for Wildlife conservation. Op-Ed to the Davis Enterprise. Smallwood, K.S. 1998. Davis Visions. The Flatlander, Davis, California. Smallwood, K.S. 1997. Last grab for Yolo’s land and water. The Flatlander, Davis, California. Smallwood, K.S. 1997. The Yolo County HCP. Op-Ed to the Davis Enterprise. Radio/Television PBS News Hour, FOX News, Energy in America: Dead Birds Unintended Consequence of Wind Power Smallwood CV 49 Development, August 2011. KXJZ Capital Public Radio -- Insight (Host Jeffrey Callison). Mountain lion attacks (with guest Professor Richard Coss). 23 April 2009; KXJZ Capital Public Radio -- Insight (Host Jeffrey Callison). Wind farm Rio Vista Renewable Power. 4 September 2008; KQED QUEST Episode #111. Bird collisions with wind turbines. 2007; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. December 27, 2001; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. May 3, 2001; KDVS Speaking in Tongues (host Ron Glick), Yolo County HCP: 1 hour. February 8, 2001; KDVS Speaking in Tongues (host Ron Glick & Shawn Smallwood), California Energy Crisis: 1 hour. Jan. 25, 2001; KDVS Speaking in Tongues (host Ron Glick), Headwaters Forest HCP: 1 hour. 1998; Davis Cable Channel (host Gerald Heffernon), Burrowing owls in Davis: half hour. June, 2000; Davis Cable Channel (hosted by Davis League of Women Voters), Measure O debate: 1 hour. October, 2000; KXTV 10, In Your Interest, The Endangered Species Act: half hour. 1997. Committees • Scientific Review Committee, Alameda County, Altamont Pass Wind Resource Area • Ph.D. Thesis Committee, Steve Anderson, University of California, Davis • MS Thesis Committee, Marcus Yee, California State University, Sacramento Other Professional Activities or Products Testified in Federal Court in Denver during 2005 over the fate of radio-nuclides in the soil at Rocky Flats Plant after exposure to burrowing animals. My clients won a judgment of $553,000,000. I have also testified in many other cases of litigation under CEQA, NEPA, the Warren-Alquist Act, and other environmental laws. My clients won most of the cases for which I testified. Testified before Environmental Review Tribunals in Ontario, Canada regarding proposed White Pines, Amherst Island, and Fairview Wind Energy projects. Testified in Skamania County Hearing in 2009 on the potential impacts of zoning the County for development of wind farms and hazardous waste facilities. Testified in deposition in 2007 in the case of O’Dell et al. vs. FPL Energy in Houston, Texas. Smallwood CV 50 Testified in Klickitat County Hearing in 2006 on the potential impacts of the Windy Point Wind Farm. Memberships in Professional Societies The Wildlife Society Raptor Research Foundation Honors and Awards Fulbright Research Fellowship to Indonesia, 1987 J.G. Boswell Full Academic Scholarship, 1981 college of choice Certificate of Appreciation, The Wildlife Society—Western Section, 2000, 2001 Northern California Athletic Association Most Valuable Cross Country Runner, 1984 American Legion Award, Corcoran High School, 1981, and John Muir Junior High, 1977 CIF Section Champion, Cross Country in 1978 CIF Section Champion, Track & Field 2 mile run in 1981 National Junior Record, 20 kilometer run, 1982 National Age Group Record, 1500 meter run, 1978 Community Activities District 64 Little League Umpire, 2003-2007 Dixon Little League Umpire, 2006-07 Davis Little League Chief Umpire and Board member, 2004-2005 Davis Little League Safety Officer, 2004-2005 Davis Little League Certified Umpire, 2002-2004 Davis Little League Scorekeeper, 2002 Davis Visioning Group member Petitioner for Writ of Mandate under the California Environmental Quality Act against City of Woodland decision to approve the Spring Lake Specific Plan, 2002 Served on campaign committees for City Council candidates