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Ms . Kerry Sullivan <br /> June 21 , 1993 <br /> Page Two <br /> there are numerous "uncertainties" involved in <br /> establishing/restoring native perennial grasslands to <br /> Central Valley sites which have been subjected to livestock <br /> grazing and competition from exotic annual grasses. While <br /> the DFG recognizes the potentially greater productivity of <br /> native plant communities, we are concerned that elements of <br /> the Upland Grassland mitigation measure may not lead to <br /> increased habitat value for the sensitive species identified <br /> in the Final EIR. A worse case scenario is possible wherein <br /> the native grass establishment effort fails and/or the <br /> ongoing intensive management activities which are necessary <br /> for the survival of the native grasses (mowing, grazing, <br /> irrigation, herbicide application, etc. ) result in decreased <br /> habitat values for small mammals, and therefore the <br /> Swainson' s hawk. <br /> In order to insure that there are no negative effects to the <br /> Swainson' s hawk resulting from attempts to establish/restore <br /> native grasses, we recommend that any grassland management <br /> plan must be designed to increase and maintain habitat <br /> quality for rodents . Beyond any effort to restore native <br /> plant communities, the grassland management plan should <br /> provide foraging habitat for the Swainson' s hawk in an <br /> amount and quality necessary to off-set the loss of foraging <br /> caused by the project. <br /> Native grass establishment/restoration should proceed from <br /> the pilot study stage to a phased program. There should be <br /> sufficient high quality raptor foraging habitat on-site at <br /> any point in the native grass restoration program. <br /> In conclusion we would like to thank you for the opportunity <br /> to review and comment on the subject plan. Our overall <br /> impression is that the subject plan contains mitigation measures <br /> that are either already addressed, or conflict with the <br /> mitigation measures contained in the Final EIR for the Buckeye <br /> Ranch project. <br /> If we can be of further assistance, please contact Mr. Bob <br /> Mapes, Associate Wildlife Biologist, at (916) 355-7010, or <br /> Mr. Jerry Mensch, Environmental Services Supervisor, at <br /> (916) 355-7030 . <br /> Sincerely, <br /> L. -R an Broddrick <br /> Regional Manager <br /> cc: See attached list <br />