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1. Projects Coordinator -2- April 26 , 1990 2 . Mr. Richard Larrouy The Initial Study indicates that the California Natural Diversity Data Base (CNDDB) was consulted and contained no records for sensitive species within the project site. Consulting CNDDB is a necessary first step in a process of disclosing the presence of sensitive species . However, the fact that CNDDB has no record of a species for a particular site does not indicate that the species does not occur there. It may only mean that no one has ever looked for the species at that site. The DFG has records of the presence of the Federally-listed endangered bald eagle within the project area. The site may also provide habitat for the Federally-listed endangered valley elderberry longhorn beetle (pesmoc&= r„ylifornicus dimornhus) . Surveys for the above listed sensitive species should be done on the subject property by a qualified biologist . If sensitive species are found, mitigation should be proposed to protect them. The survey report and its recommended mitigation measures should be included in the mitigated Negative Declaration. We are particularly concerned with the project ' s impact upon the Mokelumne River riparian corridor. These riparian wetlands provide essential habitat for many species of fish and/or wildlife as well as providing a corridor of travel for many wildlife species. Construction of houses, roads, and other amenities along the riparian corridor will significantly impact the habitat value of this area. Riparian wetlands are a unique habitat type and have been greatly diminished statewide, The DFG ' s policy of "no net loss of either wetland acreage or habitat value" requires us to oppose projects which may negatively impact wetlands. We recommend that in order to mitigate the negative impacts resulting from the proposed project, especially along the river, an area along the south bank of the Mokelumne River be removed from the project and preserved as open space. This area would include the riparian corridor, namely the area from the edge of the Mokelumne River to the natural break in the terrain, plus a 100-foot natural buffer setback measured from the natural break in the terrain. If the above biological survey and mitigation measures are made a condition of project approval , we are willing to withdraw our concerns. if these mitigation measures are not made a condition of project approval, pursuant to the California Environmental Quality Act (CEQA) , an Environmental Impact Report (ETR) must be prepared. CEQA Section 15065 (c) under Mandatory Findings of Significance states that a project may have significant effect on the environment and thereby requires an EIR when "the project has possible environmental effects which are individually limited but cumulatively considerable" . Those cumulative effects may occur