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APPENDIX I - BIOLOGICAL RESOURCES noteworthy in this regard, although it will take many years for these trees to mature to a size suitable for nesting sites. The creation of permanent lakes would remove a potential foraging habitat for the hawk. Presently,the combination of shoreline,coupled with the lakebed,provides a blend of riparian brush and lakebed weed growth which creates prime rodent habitat most likely used by the Swainson's hawk. While it is recognized that the proposed plan creates more shoreline than presently exists,this new shoreline involves an open water/plant edge ecotone which would not be near as productive for rodents as existing conditions. The daily presence of golfers,plus fairway maintenance personnel and equipment on the six fairways that are proposed within and adjacent to Brovelli Woods,would create a disturbance factor for nesting hawks which is prohibited in Section II-1-A of the CDFG Mitigation Guidelines (Appendix F). It should be noted in making this projection,that the proposed golf course is presently slated for the exclusive use of future residents and their guests, and on some days traffic in the woodland fairways may be minimal. However, heavy weekend use plus occasional tournaments would create a disturbance factor that would affect nesting hawks. These concerns over the human disturbance of nesting hawks are based on the fact that this migratory species spends over half of each year in countries south of the border where they are afforded no protection and where they are regularly killed. Like the legally hunted species of waterfowl that winter in the Central Valley, hawk species that are harassed by humans with guns soon learn to react to the sight of people near nesting and roosting sites, no matter whether humans may be engaged in passive recreational activities, such as bird watching. The Swainson's hawk will not tolerate humans closer than a couple hundred feet. Each time this species is flushed from its habitat it expends considerable energy and eventually will desert the area. One other practice associated with golf course management that may also severely impact the Swainson's hawk and all other avian and mammalian carnivores is the use of rodenticides to periodically reduce small rodent numbers in fairway and green areas. Not only does such a control program reduce the supply of prey adjacent to nesting sites, but it also kills hawks outright which catch and eat dying, poisoned rodents. The applicant's Management Plan recommends the use of an integrated pest management program, but does not directly address how rodents will be controlled. In contrast to the already documented use of Brovelli Woods as a Swainson's hawk nesting area, the degree to which it uses the grassland, oak savanna, and dry summer lake basins is unknown. In such cases as this where sufficient time has not been allotted to obtain all information necessary to arrive at a correct biological decision, CEQA Guidelines mandate that a "worst-case assumption" be adopted. In this case the EIR authors assume that the entire site, including Tracy Lakes but excluding the woods and permanent pond, is critical foraging habitat for the threatened raptor and, therefore, cannot be 22