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JUN 16 '93 15:34 REGION 2 P.2 <br /> Ms. Kerry Sullivan <br /> June 15, 1993 <br /> Page Two <br /> are inadequate. The Response to Comments does not <br /> remove our concerns that information for this species <br /> is lacking. The Final EIR does not contain the <br /> results of searches that were designed to disclose <br /> the presence and location of critical habitat <br /> (elderberry plants) within the project boundaries. <br /> x . The Draft EIR does not contain a discussion of,. or <br /> provide mitigation for the project's impacts upon the <br /> ,state-listed threatened greater sandhill crane (Grua <br /> QIUAdensis tbda) . The Response to Comments further <br /> identifies the Draft EIR's lack of adequate <br /> information regarding impacts to the greater aandhill <br /> crane. <br /> 3 . While the Final EIR contains a proposal to avoid <br /> impacts to the south Tracy Lake, the Final EIR still <br /> does not contain information .regarding the amount of <br /> seasonal wetland habitat (vernal poola, seasonal <br /> wetlands, riparian) which will be lost as a result of <br /> the project, i .e. , construction of roadways, home <br /> sites, and the. golf course. Similarly, it does not <br /> contain a plan to mitigate this loss. <br /> 4. The Final EIR and the Response to Comments leaves <br /> open the issue of how to mitigate intrusion into the <br /> mature riparian forest, the resultant loss of 13 <br /> acres of habitat, and subsequent degradation of <br /> habitat quality. All of these issues must be <br /> resolved if impacts to the riparian forest are to <br /> off-get. <br /> In our original comments on Catwil Corporation' s Pre- <br /> Application, we opposed this project on the grounds that it was <br /> unwise to propose a project which is not site-dependant and which <br /> will at the same time result in significant habitat loss in an <br /> environmentally rich and sensitive area. We are again reminded <br /> of our original recommendation to San Joaquin County Planning <br /> Department questioning the wisdom of placing a subdivision/golf <br /> course project in one of the last remaining significant mature <br /> riparian and seasonal wetland habitat areas of the Central <br /> Valley. <br /> In conclusion, we do not believe that many of the impacts <br /> associated with this project have been reduced to a level of <br /> insignificance. while the Final EIR proposes to move some of the <br /> most disruptive project features away from the most <br /> environmentally sensitive areas of the project site, the project <br /> will still result in a significant lose of habitat quality and <br /> quantity. Therefore, we recommend against certification of the <br />