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JUN 16 '93 15:33 REGION 2P. 1 Poet.lt''brand tax transmittal memo= #of 02086 ► STATE orrhog" PETE WILSON, Govem" DEP o 'g-411i D, a /Q'Z N . Dm r4, ��. t 0"0 AN35-5$ 7d�U 1701 701 1 I `/l p 8ANC1 FAX FAY+P ( 91b) JjD- iuzu June 15, 1993 Ms . Kerry Sullivan San Joaquin County Community Development Department 1810 East Hazelton Avenue Stockton, California 95205-6232 Dear Ms . Sullivan: The Department of Fish and Game (DFG) has reviewed the Final Environmental Impact Report (EIR) for the Buckeye Ranch Subdivision project. Beginning in October 1989, the DFG reviewed and provided comments on the Catwil Corporation' s Pre-Application Notification, the Notice of Preparation of the Draft EIR for Buckeye Ranch, the Draft EIR, and the Revised Biological Section for the Draft EIR. Our comments are a matter of record and it is not our purpose here to reiterate them in detail. We would like to note that over the course of our review we have found a number of inadequacies in the environmental documents that have been prepared for this project. These inadequacies have rendered the environmental documents, particularly the Draft EIR, virtually unusable. This fact, in combination with competing applicant sponsored management plans has produced an air of confusion. We are concerned that this confusion tends to overshadow and obscure the project' s overall impact. However, two things remain clear: 1 ) the project site possesses extremely high natural habitat values, and 2) it will be very difficult, if not impossible to avoid significant adverse impacts to these resources. Mitigation measures must be extensive and even then cannot estimate all adverse impacts. As a result of the Draft EIR' s inadequacies, a Revised Biological Section (RBS) was developed and added to the Final EIR. The RBS addressed a number of resource issues and removed some of our concerns regarding the overall adequacy of the document. uowavor, it £ailed to pro>sent matisation maasurea which reduced impacts to a level of insignificance. While the RBS recommends that- some of the project features be removed from the most sensitive habitat areas of the project site, the project still results in a significant loss of habitat and leaves unresolved the following issues: 1 . Surveys of the federally threatened valley elderberry longhorn beetle (Desmocer_u$ palifornicus dimcrohua)