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1. Project' s Coordinator <br /> 2 . Mr. Kerry Sullivan <br /> April 3 , 1992 <br /> Page Four <br /> The Draft EIR fails to adequately discuss the project' s <br /> potential for significant impacts to these unique habitats. <br /> In the case of riparian forest and foothill woodlands, we <br /> A14 recommend that any further loss be avoided. To mitigate <br /> losses that have already occurred, we recommend that the <br /> Draft EIR contain proposals which ensure the protection of <br /> mature riparian forest stands within the Mokelumne River/Dry <br /> Creek/Jahant Slough watersheds. <br /> The creation of the irrigation water storage ponds will <br /> result in a significant loss of seasonal wetlands. In the <br /> case of seasonal wetlands, the DFG recommends the project be <br /> A15 designed so that any impacts to wetlands are avoided. If <br /> impacts to wetlands cannot be avoided, mitigation should be <br /> provided that is based upon the concept of no net loss of <br /> wetland habitat values or acreage. As proposed, the <br /> irrigation water storage ponds will provide little wetland <br /> habitat value due to their design and operation. <br /> The development of the golf course, roads, and building <br /> sites, etc. , may result in the destruction of vernal pools <br /> A16 and oak savannah. We recommend that the Draft EIR be <br /> revised to include a survey of vernal pools so that their <br /> location is noted and excluded from both direct and indirect <br /> impacts of the project. Additionally, the Draft EIR should <br /> contain provisions to protect oak/buckeye savannah. <br /> The applicant should be advised that work within the 100- <br /> year flood plain, consisting of but not limited to diversion <br /> or obstruction of the natural flow or changes in the <br /> channel, bed, or bank of any river, stream, or lake will <br /> A17 require notification to the DFG as required by Fish and Game <br /> Code Section 1600, et seq. The notification (with fee) and <br /> subsequent agreement, must be completed prior to initiating <br /> any such work. Notification to the DFG should be made after <br /> the project is approved by the lead agency. The agreement <br /> process should not be used in lieu of specific mitigation <br /> measures to be included as conditions of project approval by <br /> the lead agency. <br /> �4 . The Draft EIR fails to address the cumulative impacts of the <br /> proposed project. Section 15130 (a) of the State California <br /> A18 Environmental Quality Act (CEQA) Guidelines states that <br /> "Cumulative impacts shall be discussed when they are <br /> significant" . Within the near watersheds of Jahant Slough <br /> and Dry Creek from State Highway 99 downstream to the <br /> proposed project, there are pending and approved residential <br /> development projects such as Woodson Estates and Western <br /> III-10 <br />