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APR. 8199c <br /> Rex O.Baker, Professor <br /> California State Polytechnic '.II tt �Llir��ri�1 OEPT <br /> Pomona, Ca. 'PLANNING DIVISION <br /> Plant & Soil Science Dept <br /> 3801 W. Temple Avenue <br /> Pomona, Ca. 91768 <br /> Kerry Sullivan, Senior Planner <br /> San Joaquin County <br /> Community Development Department <br /> 1810 E. Hazelton Avenue <br /> Stockton, Ca. 95205 <br /> Sub: Comments on Draft EIR No. ER-91-2 for the Proposed "Buckeye <br /> Ranch" Project <br /> As an educator, consultant and former regulatory official with over <br /> 30 years of experience in evaluating environmental factors, <br /> including; endangered species and other non-target animals, flora, <br /> contamination of water sources, health and human safety, and <br /> analysis of the need for pesticide applications; and after having <br /> prepared and participated in preparation of EIR's: I must comment <br /> on several sections of this E.I.R. with which I do not agree ! <br /> I . Impact section, 4.7-1 Pg. 4 .7-21. After review of this <br /> document and the Buckeye Ranch Management Plan (8-5-91) , I cannot <br /> agree with the EIR's statement that the plan "failed to recognize <br /> the importance of maintaining foraging habitat for the Swainson's <br /> Hawk" . The opposite is true 1 The plan goes to great length to <br /> spell out a well developed program that provides for Monitoring of <br /> the current habitats, and ecosystems (Fauna & Flora) to form a data <br /> base so that more specific Mitigating measures can be developed and <br /> implemented with continued monitoring of the ecosystems as C13 <br /> mitigation measures regeneration and management measures are <br /> applied to evaluate the effects on those systems. Some test plots <br /> for regeneration of native plants are under way. This local test <br /> plot approach is the responsible way to proceed avoiding possible <br /> set backs and failures. The plans for regeneration of native open <br /> grasslands, presently grazed by cattle and infested with <br /> undesirable forage should result in a significant improvement in <br /> the raptor foraging habitat. The present grazed grasslands are <br /> providing low food value for rodents and birds and little year <br /> round forage. Implementation of the restoration and management of <br /> native grasslands, including use of native grass and herbaceous <br /> plants on the golf fairways is very important for recovery and <br /> increased rodent and bird populations. Numerous references point <br /> out that the presence of green grass and forbes, like clover, is <br /> one of the most important factors in stimulating breeding of <br /> rodents and lagamorphs, and also plays a factor in litter size. <br /> This regeneration of Savanna, forest, pasture and Buffer type <br /> perennial plots-which might be amended to include some herbaceous <br /> III-53 <br />