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0 <br /> STATE OF CALIFORNIA—THE RESOURCES AGENCY PETE WILSON, Govemor <br /> DEPARTMENT OF FISH AND GAME <br /> REGION 2 <br /> 1701 NIMBUS ROAD, SUITE A <br /> RANCHO CORDOVA, CA 95670 <br /> (916) 355-7020 <br /> June 15, 1993 <br /> Ms . Kerry Sullivan <br /> San Joaquin County <br /> Community Development Department <br /> 1810 East Hazelton Avenue <br /> Stockton, California 95205-6232 <br /> Dear Ms . Sullivan: <br /> The Department of Fish and Game (DFG) has reviewed the Final <br /> Environmental Impact Report (EIR) for the Buckeye Ranch <br /> Subdivision project. <br /> Beginning in October 1989, the DFG reviewed and provided <br /> comments on the Catwil Corporation' s Pre-Application <br /> Notification, the Notice of Preparation of the Draft EIR for <br /> Buckeye Ranch, the Draft EIR, and the Revised Biological Section <br /> for the Draft EIR. Our comments are a matter of record and it is <br /> not our purpose here to reiterate them in detail. <br /> We would like to note that over the course of our review we <br /> have found a number of inadequacies in the environmental <br /> documents that have been prepared for this project. These <br /> inadequacies have rendered the environmental documents, <br /> particularly the Draft EIR, virtually unusable. This fact, in <br /> combination with competing applicant sponsored management plans <br /> has produced an air of confusion. We are concerned that this <br /> confusion tends to overshadow and obscure the project' s overall <br /> impact. However, two things remain clear: 1 ) the project site <br /> possesses extremely high natural habitat values, and 2 ) it will <br /> be very difficult, if not impossible to avoid significant adverse <br /> impacts to these resources. mitigation measures must be <br /> extensive and even then cannot estimate all adverse impacts. <br /> As a result of the Draft EIR' s inadequacies, a Revised <br /> Biological Section (RBS ) was developed and added to the Final <br /> EIR. The RBS addressed a number of resource issues and removed <br /> some of our concerns regarding the overall adequacy of the <br /> document. However, it failed to present mitigation measures <br /> which reduced impacts to a level of insignificance. While the <br /> RBS recommends that some of the project features be removed from <br /> the most sensitive habitat areas of the project site, the project <br /> still results in a significant loss of habitat and leaves <br /> unresolved the following issues : <br /> 1 . Surveys of the federally threatened valley elderberry <br /> longhorn beetle (Desmocerus californicus dimorphus) <br />