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ignorant of project impacts, but not looking also deprives decision-makers and the
public the thoroughness needed to adequately assess project impacts and mitigation.

Nocturnal surveys using thermal imaging cameras or spotlights also could have shed
light on the presence of other mammals, such as American badger (Taxidea taxis,
California species of special concern), mountain lion (puma concolor, California Fully
Protected [by voter referendum]), and San Diego black-tailed jackrabbit (Lepus
califomicus bennettii, California species of special concern). But nothing like this was
attempted, leaving those who prepared the SEIR the opportunity to conclude these
species may not occur on the project area.

There is no use made of eBird (https://ebird.org/ebird/map), which is curious because
at least one of those performing surveys in the study area reported findings to eBird. A
quick review of eBird also turned up a credible 2016 sighting of a California condor only
a few miles from the project boundary; it was credible because the observer reported the
large tag on the bird. Other reports of California condor were reported in 2017 just a
few miles farther north.

Surveys on the proposed project site confirmed the presence of 27 terrestrial vertebrate
species with special status, including 5 species listed as threatened or endangered under
state or federal laws. Multiple additional threatened or endangered species might occur
on the proposed project site, but were not detected for insufficient survey effort. That
the survey effort detected 27 terrestrial vertebrate species with special status indicates a
remarkable richness of special-status species in one place. The lists of species detected
in the SEIR and in various BonTerra Psomas (2015) reports are long, indicating the site
is rich in wildlife despite the many efforts in the SEIR to downplay the functionality of
species' occurrences (e.g., 'habitat may be suitable for foraging, but not for nesting') and
the attempts to characterize the site as degraded by cattle grazing and exotic species.
Below are some comments on species discussed in the SEIR.

California condor

According to the SEIR (2017:5.2-24), California condors might fly over the proposed
project area, but would not be expected to forage there. Why not? No reason is
provided for this conclusion. According to the SEIR the project area is used for cattle
grazing. If cows sometimes die out there like they do where I work in the Altamont Pass,
then California condors will feed on them just as turkey vultures do in the Altamont
Pass. Other animals also occur on the proposed project site, and upon death the
carcasses of these animals will feed condors. There is no reason why condors would not
forage on the project site, and as reported by eBird and noted earlier, California condors
have been observed very close by.

Bald eagle

The SEIR (2017:5.2-24) concludes that there is no suitable foraging habitat available on
the project site for bald eagle. This is not true. I have watched bald eagles for years
foraging for ground squirrels and carrion on the annual grasslands of the Altamont Pass,

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