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Ms. Kerry Sullivan San Joaquin County �j A N 2 2 1993 , Community Development Department 1801 E. Hazelton Avenue UOMMUNI I T UOLLvrr,.c,v i D&T. Stockton,Ca 95205 PLANNING DIVISION January 20, 1993 Re: Buckeye Ranch Subdivision DEIR SCH#91012103 I am writing to provide comments regarding the proposed Buckeye Ranch Subdivision DEIR. I have reviewed the DEIR (2/92), Supplemental Biotics Study (10/92), and the Archaeological Identification Studies (11/92)reports. After careful review of these documents,I strongly believe that there are significant impacts associated with the project that would not be adequately mitigated by any of the build alternatives proposed. The only viable option is to select the no build alternative and then continue to work with the owner of this property with unique natural and cultural resources to insure longterm protection. My specific comments on the DEIR and supporting documents follow. The remaining Brovelli Woods area is uniquely significant from a ecological standpoint. The importance of this area,including the surrounding uplands,is such that impacts and further habitat loss is not acceptable. The proposed Di57. development of any of the build alternatives is simply not compatible with the I need to preserve such critical habitat. The proposed project is not compatible with the Conservation designation called for in the General Plan. There are significant adverse impacts associated with the proposed project. In addition, there are public trust issues associated with the determination that public access is not planned for in this project. Although such DI 58 access needs to be managed so as to protect sensitive natural and cultural resources that make this area unique and important,such access still must be provided. The proposed Conservation Easement and management of 720 acres as a "natural area" is incompatible with any of the proposed development alternatives. The loss of at least 12% of the existing woodland habitat at this site has not been fully assessed. If the tree clearing actions that were already taken by the applicant had been instead proposed in the DEIR, there is a strong possibility they would not have been allowed to occur. The proposed project has already had a very significant adverse impact on the Swainson's Hawk. This state-listed threatened D159 species has suffered loss of nesting and foraging habitat as a direct result of the project activities. It is also possible that another state-listed species, the greater sandhill crane,was also impacted. There has almost certainly been indirect displacement of both these protected species and other species of concern as a result to increased human activities. This impact would certainly increase greatly if the project were approved in any form. VI 14?