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1 Ms. Kerry Sullivan April 8, 1992 Page 16 Page 4.7 - 22 The daily presence of golfers, plus fairway maintenance personnel and equipment on the six fairways that are proposed within and adjacent to Brovelli Woods, would create a disturbance factor for nesting hawks which is prohibited in Section II-a-A of the CDFG Mitigation Guidelines 0207 (Appendix F). It should be noted in making this projection, that the proposed golf course is presently slated for the exclusive use of future residents and their guests, and on some days traffic in the woodland fairways may be minimal. However, heavy weekend use plus occasional tournaments would create a disturbance factor that would affect nesting hawks. It seems to me that daily presence would cause nest sitting in less disturbed areas; i.e., a tree or two removed from a fairway, but not eliminate most of the forest from their habitat. Visual observation of Swainson's hawk nesting on other properties indicates the hawk can accommodate nesting in far more "disturbed"urban uses. Page 4.7 - 22 The applicant's Management Plan recommends the use of an integrated pest management program, but does not directly address how rodents will be controlled. 0208 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 4.7 - 22 In contrast to the already documented use of Brovelli Woods as a Swainson's hawk nesting area, the degree to which it uses the grassland, oak savanna, and dry summer lake basins is unknown. In such cases as this where sufficient time has not been allotted to obtain all C209 information necessary to arrive at a correct biological decision,CECA Guidelines mandate that a "worst-case assumption"be adopted. In this case the EIR author is assuming that the entire site, including Tracy Lakes but excluding the woods and permanent pond, is critical foraging habitat for the threatened raptor and, therefore, cannot be developed. Such an assumption could only be invalidated by a spring-summer survey to document Swainson's hawk foraging patters in the project site area. Why can't information developed by others over many years of "non-disturbance"be used? Certainly the lake bottoms weren't used for foraging when historically flooded and when farmed to sudan grass which provides dense ground cover several feet high. Page 4.7 - 22 Mitigation 4.7-1(a) C210 Redesignthe developmentto position the 26 homesites as far away as possible from the Brovelli Woods Swainson's hawk nesting habitat and presumed productive foraging habitat such as the Tracy Lakes shorelinearea and lakebed. Where is the habitat when the lake is being farmed with Sudan grass? Doesn't the applicant get credit for creating a "productive foraging habitat"? III-131