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significance of this riparian forest, its understory, and the riverine and grassland habitat it supports. We are concerned over the projects adverse impacts on the identified and resident eight species of mammals, forty-seven species of birds, two species of reptiles, two species of amphibians, eight species of fish and all the other species dependent on this area that were not identified. We support C42 the Draft EIR's identification of biotic resources that may be affected by this proposed project, but wonder if the study is sufficient to provide required environmental safeguards. With do respect to Sam McGinnis, the project proponent's biotic resource consultant, we have been made aware of the inadequacy of his work on the Mountain House and New Jerusalem new town/communities. We are concerned that this one-of-a-kind biotic resource area is getting a boilerplate treatment when it deserves and requires special consideration and mitigation. We wonder why the developer would be C43 F--o presumptuous to choose a project site that is the last area remaining in San Joaquin County with ;moderate environmental and archaeological integrity. We would hope the County does not ignore is significance. It is stated in the Draft EIR that the goal of the cultural resources study is to identify, locate or Fre-locate, and record all cultural resources lying on the surface of the project area: to determine the C44 impacts; and to define mitigation measures. We feel that the study is cursory, generally addressing cultural resources, but is inadequate to make required determinations necessary-to properly offset and mitigate for adverse impacts on the identified cultural resources. A complete and detailed archaeological inventory and study is necessary before any project determinations are decided. We have noted in the cultural resource section that the work of Dr. James Bennihoff is extensively referenced. The statement is made that he is an excellent source of ethnographic information. Because of his familiarity with the site and, specifically, the historic inhabitants of the site, the Plains Miwoks, we feel it is appropriate to incorporate his comments in the consideration of Cob determining the cultural significance of the area. We took it upon ourselves to call him and notify him of this pending project and the current review of the Draft EIR. He had not been contacted regarding the project and was alarmed that the site was being considered for a subdivision. We !,,ave _-een recently made aware of his health problems, but we still think he should have been given ;he o-t;cn c commenting on the project and the Draft EIR. To not do so seems to be a selective omissicn. We sent him a copy of the Draft EIR and asked for his review and comments. We have asked Kerry Sullivan, of the San Joaquin Community Development Department, to provide him with the confidential cultural resources report. We are aware that he has personally requested and received copy of this report. Dr. Bennihoff is widely respected in the archaeological field and to our understanding he is more familiar with the significance of the Brovelli Woods/Tracy Lakes archaeological resources than anyone. We ask that you give serious attention to his comments. I have placed twenty or more calls to agencies, archaeology societies and other individuals that, I thought, might give me insight into to the significance of the archaeological resources present t Fin the Tracy Lakes area. The response I've received has supported the significant categorization of Cos the Draft EIR authors. The most disturbing comment is the unanimous declaration that not enough It. known about the site to accurately gage how significant the archaeological resources are that are contained within the Tracy Lakes Complex. No modern comprehensive investigative studies have III-72