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County general plan. We were told that in a County master plan or a master plan for County Parks & Recreation that the Brovelli Woods/Tracy Lakes area was identified as being a significant resource area that the County should work to obtain and manage as a preserve to protect the unique biotic-and C55 cultural resources. We made a cursory attempt at locating the document and were unsuccessful. Before the County moves forward in the consideration of this project we suggest that it identify if the project site is a priority acquisition identified in prior planning documents. It is correctly suggested in the mitigation measures for adverse impacts on biotic and cultural resources that the golf course be eliminated, the excavation of Tracy Lakes not occur and the houses be moved away from sensitive areas. Considering this latter recommendation we wonder how you Cys can move the houses away from sensitive areas when the whole project site has been determined to be sensitive. We find these suggestions telling and it does raise the question of the feasibility of the project. We feel there is no way to adequately mitigate for the adverse impacts on the significant resources contained within the project boundaries, therefore, we feel the project is unfeasible and should not be approved. We have other concerns regarding the riparian rights that the project proponent plans to use to 1 fill the Tracy Lakes for golf course irrigation from the Mokelumne River. Considering the beleaguered C57 state of the Mokelumne at present, we suggest that this plan of water appropriation be very carefully considered. We hope and presume that the Regional Water Quality Control Board and the State Water Resources Control Board have adequately responded to these concerns. We wonder if it is appropriate to build a bridge across the Mokelumne to accomodate the traffic of only twenty-six C58 houses. Bridge construction has been identified as causing problems of sedimentation, fish entrapment and other problems to the water bodies affected in bridge construction. If a bridge is constructed we feel the developers and the County are obligated to provide public access to the C59 Mokelumne at this point. We feel the Draft EIR is deficient in not addressing this issue. We would like to suggest to the developers and the County that if the wise recommendation is no project that a public agency, conservation organization, land trust or other entity should purchase the property or secure a conservation easement from the current owners to protect the biotic and C60 cultural integrity of the site. We are aware that the Wildlife Conservation Board still has moneys available from its prior attempt at buying Brovelli Woods. We have engaged in discussions with the Trust for Public Lands and they are currently studying the issue and may be able to put together an offer working with other public and private agencies to secure the project site with a fair market value offer to the developers. We incorporate by reference the comments of: Dr. James Bennihoff, Dr. Jerald Johnson, Central California Archaeological Foundation, Native American Heritage Commission, California State Lands Commission, California Soil Conservation Service, U.S. Fish & Wildlife Service, California Department of Fish & Game, San Joaquin County Parks & Recreation Department, San Joaquin County Farm Bureau, Ione Band of Miwoks, Sierra Club - Delta-Sierra Chapter, Stockton (San Joaquin) Audubon Society. III-75