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The 2007 survey on the proposed project site was based on the 1995 CDFW protocol.
BonTerra Psomas (2015, Attachment F:3) selected terrain to be surveyed that was "not
too steep,", but it was not explained what "not too steep" means. I have found breeding
burrowing owls on very steep slopes, including on cliffs and slopes so steep that walking
on them is challenging. Just this year I found a pair of burrowing owls breeding at the
top of a slope so steep that I had to access the burrow site by walking along the ridge
crest from further up the ridge. I am concerned that Bon Terra Psomas's assumption
that burrowing owls only breed on shallow slopes might have resulted in considerable
breeding habitat having not been surveyed.

Bon Terra Psomas's (2015, Attachment F:4) description of the surveys indicate that the
surveys were mostly winter surveys. The survey methods described by Bon Terra
Psomas indicate lack of experience with winter surveys and what can be expected to be
discovered from them. I have performed winter surveys over large areas where I also
performed breeding season surveys (Smallwood, unpublished data - scientific papers in
progress). I found non-breeding surveys yield very low detection rates because
burrowing owls are cryptic when not breeding. During the breeding season there is
always an adult sentry near the nest burrow, but when not breeding there is no need for
a sentry and burrowing owls almost always hide inside their burrows. I found that the
most effective winter survey method is to walk transects no more than 30 m apart, and
to often stop and look back over ground already covered. Burrowing owls often emerge
from their burrows or fly to other burrows after the biologist walks past the owl's last
hide. But even this approach will detect fewer than 10% of the available owls.

Another useful winter-time method is to scan large areas relatively far from the
observer, using high-quality binoculars stabilized on a monopod or tripod. While
walking transects in winter, it is useful to stop often and scan ahead (and behind, as
explained earlier) using binoculars stabilized on a monopod. Also, contrary to BonTerra
Psomas (2015, Attachment F:4), it is useful to perform nocturnal surveys using a
thermal imaging camera. BonTerra Psomas (2015, Attachment F:4) claimed that
nocturnal surveys are not useful because burrowing owls fly away from nest burrows to
forage. This is true, but BonTerra Psomas (2015, Attachment F) was performing winter
surveys and not breeding season surveys. The owls they could have surveyed for at
night would not have been breeding. And even during the breeding season, whereas it is
true that breeding owls often fly from the burrow to forage, it is still readily easy to see
the owls leaving to forage and returning with prey items. I have been using my thermal
camera for such surveys with great effectiveness since 2012, during all times of year.

BonTerra Psomas also demonstrated lack of experience with winter burrowing owl
surveys by relying on sign at the burrows, such as pellets and whitewash and prey items.
These types of sign are useful for finding nest burrows, but not as useful for finding
winter refuge burrows. Many winter refuge burrows are used too briefly for sign to
accumulate, as wintering owls tend to move around. Also, there is little connection
between breeding and non-breeding distributions, as I have found in two large study
areas, including in the Altamont Pass (Figure 3). Burrowing owls generally depart from
breeding areas to winter somewhere else, but not necessarily very far from breeding
areas.

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