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Mokelumne River Alliance April 8, 1992 APR 81992 -' WMMUIVI I Y 0i:'/�t.vi'�'�i`i PUNNING DIVISION San Joaquin County Community Development Department Attention: Kerry Sullivan 1810 East Hazelton Avenue Stockton, CA 95205-6232 Re: Comments on the Draft Environmental Impact Report, No. ER-91-2. SCH No. 91012103, for the "Buckeye Ranch Subdivision" Proposed by The Catwil Corporation. Dear Community Development Department, Kerry Sullivan, and Mills Associates: i The mission of the Mokelumne River Alliance (MRA) is "the long-term preservation and restoration of the Mokelumne River and its bordering habitat for the present and future benefit of wildlife, fisheries, and citizens of the area." We feel the proposed Buckeye Ranch Subdivision and its potential identified and unidentified adverse impacts on biotic and cultural resources are contrary to our mission and wise planning in this County. We feel that the potential adverse impacts on this one- of-a-kind biotic and cultural resource wonderland are not and can not be adequately mitigated, therefore, we submit the following comments: We compliment the developers and the Draft EIR authors for what appears to be a comprehensive and worthy risk assessment of the Buckeye Ranch Subdivision proposal. In reading through the Draft EIR, though, we can not help, but wonder, if the developer made a mistake in purchasing "Brovelli Woods" for this project. The old adage, "buyer be ware," seems to be an C40 appropriate consideration in hindsight. The identified potential adverse impacts on biotic and cultural resources will be admittedly significant and we suggest unmitigable. We ask, "How do you mitigate r for the unmitigable?" We note that the suggested mitigation to lesson the adverse impacts to less 1 than a significant level, if followed, will radically alter the proposed project to the point, where we feel, that the project would be unfeasible for the proponents. We suggest that infeasibility is an accurate summation of any consideration of this project. Considering the current and historic integrity of biotic and cultural resources on the project site, we recommend no project, with the caveat that a public agency, conservation organization, or land trust work with the developers towards a purchase or the granting of a conservation easement to protect these valuable resources. The biotic resources of the Brovelli Woods/Tracy Lakes area are widely known throughout the 1 state. What remains of the woods are the last remaining plant community examples of a closed- C41 canopy, interior, live oak, riparian forest that exists in San Joaquin County and the Valley. We hope ,he developer, the County, and the Draft EIR authors adequately understand and consider the P. O. Box 1971,Lodi IH-71 '.41 209-368-9396