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L <br /> 1. Project ' s Coordinator <br /> 2 . Mr. Kerry Sullivan <br /> April 3 , 1992 <br /> Page Five <br /> World. These projects have resulted in the deterioration or <br /> loss of riparian, oak woodland, and Swainson's hawk foraging <br /> habitat. The cumulative loss of important native habitat is <br /> one of the principle reasons for population declines of <br /> species like the Swainson' s hawk and the giant garter snake. <br /> We do not agree with the Draft EIR's assertion that the A18 <br /> cumulative impact analysis should be limited to traffic, <br /> noise, and air quality. The Draft EIR must be revised to <br /> include an analysis on the project' s cumulative effects on <br /> riparian forest, seasonal wetlands, oak savannah, and <br /> Swainson' s hawk foraging habitat. <br /> 5. The Draft EIR fails to accurately identify the <br /> environmentally superior alternative as required by Section <br /> 15126 (d) of the CEQA Guidelines. The Draft EIR states that <br /> the "no project" alternative cannot be selected -as the <br /> environmentally superior alternative because "there is no <br /> guarantee that the site can be preserved for its cultural <br /> and biotic resources" . <br /> The voters of California provided such a guarantee in 1988 <br /> when they passed Proposition 70. At that time the project <br /> site (Brovelli woods) was identified as an area of great <br /> biological significance and moneys were set aside for its <br /> purchase and protection. It is arguable that the "no A19 <br /> project" alternative would result in a higher level of <br /> biotic and cultural protection than the Mitigated <br /> Alternative and, therefore, would constitute an <br /> environmentally superior alternative. We recommend, <br /> therefore, that the Draft EIR be changed to reflect that <br /> following passage of Proposition 70, the "no project" <br /> alternative is the environmentally superior alternative. <br /> The DFG supports a project alternative which results in the <br /> least destruction of habitat and disturbance of wildlife. <br /> In our opinion, this would at least necessitate deleting the <br /> golf course and permanent ponds from the project design. <br /> This concludes our review of the Buckeye Ranch Subdivision <br /> project. Due to the project' s size and the potential for <br /> adverse impacts to wildlife, the DFG opposes certification <br /> of the Draft EIR until the issues we have raised are <br /> resolved. <br /> Pursuant to Public Resources Code Section 21092 and 21092 . 2 , <br /> the DFG requests written notification of proposed actions <br /> and pending decisions regarding this project. Written <br /> notification should be directed to this office. <br /> III-ll <br />