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Ms. Carol Whltcslde Ms. Derry Sullivan April 6, 1992 Page Three In addition, the DEIR should include an analysis of the effects of water diversion from jahant Slougb, Tracy Lakes and the Mokelumne River on the public trust resources and not just dry season diversions from the Mokelumne River as proposed in the DEIR (Mitigation 4.6-3(a), page 4.6-18). The DEIR should specify what methodology, standard A27 and scientific protocol will be used to determine "instrcam flow requirements". This analysis should be completed and reviewed by appropriate resource agencies including the U.S. Fish and wildlife Sella. Department of Fish and Game and the State Lands Commission prior to tentative map approval- 'The DEIR should discuss how the restriction on ground water pumping will be A28 enforced and what will the sanction be if the restrictions are violated (page 4.16-18). J 'Ise DEIR should include an alternative site analysis. The alternative site should be selected on the basis of minimal environmental constraints, but with development A29 opportunities consistent with the project goals. Incorporated into this analysis should be the environmental constraints of the project, namely, water supply, limited leachfield I potential, sensitive habitats, and public trust resources. J We support the use of a Deed of Conservation Easement as a mechanism to preserve and protect in perpetuity the biologically sensitive areas of the project site (page 2-9). However, more detailed information is necessary in order for our staff to be assured that the provisions of the Easement will further this goal. As the discussion under Impact 4.1-5 states, there is insufficient information in the DEIR concerning how the Easement wf11 be implemented and maintained. Will all of the 870 acres of the total project acreage be plac.;.i in the preserve? The DEIR states it is the applicant's "intent" A30 to have an environmental organization manage the preserve. The Draft Deed in the supplemental material identifies the Nature Conservancy as that organization, but no definitive decision has been made to guarantee its selection. In addition, the Management Plan referred to in the Draft Deed is not included in the DEIR; only an outline of the Plan is providedDEIR in orderplemental that our staff can ecan be that the pubetails of this lic should be, included in the D trust resources will be protected. The Conservation Easementement willare rreduiree moni o6ng to assure that the quahpurposes nes and pposes o , The DEIR should discuss this monitoring program, its elements and a funding source to ensure timely and routing assessment. We suggest that the Easement contain a provision and an enforcement program to prohibit all offroad vehicles within the Easement area. Likewise, an enforcement A31 mecbanisrn should be included in the drainage and erosion control plan (page 4.6-23). These enforcement programs should be identified prior to final map approval. III-29 7C lora inn