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Ms. Kerry Sullivan April 8, 1992 Page 4 The purpose of the Endangered Species Act is to preserve critical habitat now, as opposed to ;150 providing more in the future when the species could very well be extinct within the region in question. ' Again, where is the evidence that there aren't enough nesting sites? The openings in the canopy will increase foraging opportunity in the forested area. Page 3 - 10 Retain an expert in raptor ecology to study the current state of Brovelli Woods and develop a habitat enhancement plan for the recently disturbed 12.5 acres riparian woodland community. X151 Upon approval by CDFG, the plan should be implemented and monitored for a minimum of five years. The developershould be responsible for the cost of restoration. The loss of 12.5 acres is insignificant for nesting. The cleared areas increase foraging habitat by approximately 12.5 acres. Page 3 - 10 Prohibit all use of rodenticides on the entire project area. C152 We have hired Animal Damage Management,Inc., a rodent control firm,who will be providing comments on this portion of the Environmental Impact Report. The firm is also in the process of preparing an addendum to the Buckeye Ranch Management Plan which will detail the proposed rodent control procedures. Page 3 - 11 The proposed "restoratio-i"of the Tracy Lakes would greatly reduce or eliminate the wildlife habitat value of two thirds of this historic seasonal wetland site, including its presumed function as a Swainson's hawk foraging area. .,153 Actually, the existing "seasonal wetland site" has been largely non-existent due to increased upstream depletion, dry years, and drainage by the former owners. The Management Plan proposes to create managed marsh (seasonal wetlands) every year. Additionally,during the spring months,the birds are in the nesting mode. At these times, the Tracy lakes would normally contain water if not purposefully drained to farm the lake bed. Therefore; during these prime nesting months, the surface area of the lakes would not often provide foraging habitat. Paae 3 - 11 Relocate all lots at least 300 feet from the high water shoreline of the lakes. Human activities in and around the lake would preclude water birds and Swainson's hawks from foraging in these 154 areas of the site. Without the proposed project, the majority of the time there wouldn't be any lakes to support water birds, etc. The proposal will create+/- 54,000 lineal feet of shoreline. Assuming each lot has 300 I.f. of shoreline 26 homes,that would be 7,800 I.f. used up, leaving almost nine miles of shoreline. III-119