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Figure 3.  Burrowing owl densities             Difference in density from spring
                within 46 randomized sampling plots in            30~~~~~~~~~~~~~---.
                                                                                                    0
                the Altamont Pass Wind Resource Area
                shifted between seasons as a function of          20
                density observed in spring, where green                  c   0
                circles represent summer, red triangle            10     •  0
                represent fall, and blue squares represent               1~  c   c
                winter (Smallwood, unpublished data).              0      ~ c   0
                                                                         0   o 0 ~ to
                                                                            c c  Q)~   0
                                                                                ..
                                                                 -10
                                                                                g  t:.  0
                                                                                c  c
                                                                                                    D
                                                                                0        0
                                                                                   c
                                                                 -20              0
                                                                                      D   0
                                                                                         •
                                                                 -30
                                                                                         c
                                                                                          •
                                                                                          c
                                                                 -40
                                                                         0   10   20   30   40   50   60   70
                                                                           Burrowing owls detected
                                                                              per km  in spring
                                                                                     2
                Further demonstrating lack of familiarity with burrowing owl surveys was Bon Terra
                Psomas's (2015, Attachment F:5) reference to satellite burrows in the context of winter
                surveys.  Satellite burrows are meaningful only during the breeding season; there is no
                such thing as a satellite burrow in winter.

                BonTerra Psomas (2015, Attachment F:7) estimated 9 burrowing owls used the project
                area during the winter of 2007.  However, as I pointed out earlier, burrowing owls are
                very difficult to detect during winter.  In my experience, and given the survey methods
                used, I would expect that BonTerra Psomas (2015, Attachment F7) grossly
                underestimated the number of burrowing owls wintering on the project site.

                BonTerra Psomas (2015, Attachment F:7) reported that wintering owls had left the
                project area by 30 March 2007, leading to the SEIR (2017:5.2-39) conclusion, "The
                burrowing owl winters on the Project site. This is an unusual wintering location for
                this species, since it is located in thefoothills rather than on the valleyfioor."  However,
                there is nothing unusual about burrowing owls wintering in the foothills, nor would
                there be anything unusual about them nesting there on the proposed project site.  I have
                documented one of the largest burrowing owl populations in California both wintering
                and nesting in foothills (Smallwood et al. 2013, Smallwood 2016).  Burrowing owls
                migrating from British Columbia winter in the foothills of Santa Clara County at even
                higher elevations than in the Altamont Pass or the proposed project site (Lynn Trulio,
                personal communication, 2017).

                Of greater significance, however, is BonTerra Psomas's (2015, Attachment F:7)
                unfounded conclusion that the project site is used only by wintering burrowing owls.
                According to BonTerra Psomas (2015, Attachment F:7), " ... there was no evidence of
                breeding in the survey area during the 2007 breeding season."  But the only survey
                performed during the breeding season was on 28 April 2007.  The 2007 survey effort

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