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1 Ms. Kerry Sullivan April 8, 1992 Page 17 Page 4.7- 23 Mitigation 4.7-1(e) In accordance with Section II-3-6-c of the CDFG Mitigation Guidelinesfor the Swainson's hawk, (Appendix F) purchase and dedicate for preservation a minimum of 12.5 acres off-site of prime mature riparian forest within the Dry Creek Swainson's hawk subpopulation area to replace the 12.5 acres previously cleared. It should be noted that the restoration project presently underway in the south central part of the site cannot be considered adequate mitigation for the loss of C211 critical Swainson's hawk nesting habitat because it would take at least 50 years for such a stand of young oak sapling to grow to the size required for nesting by this species. The purpose of the Endangered Species Act is to preserve critical habitat now, as opposed to providing more in I the future when the species could very well be extinct within the region in questions. Where is the evidence that lack of nesting sites is limiting the population (as opposed to farming practices or bird hunting in South America,e.g.,)? Page 4.7- 24 Specifically,the conversion would entail the loss of 100 acres of classical seasonal wetland that presently functions as a shallow foraging site for water birds during the winter in normal rainfall C212 years and dries in spring to produce seasonal rodent and rabbit habitat. This latter function in turn enhances the area as a summer Swainson's hawk foraging habitat. The Environmental Impact Report author either did not understand or did not consider the Management Plan in his analysis. Page 4.7- 24 Mitigation 4.7-2(c) Retain a waterfowl management specialist to design and supervise the planting and management of a permanent cover crop for the lake basin. An annual seed crop would be C213 produced for invading rodent populations in summer and migrant water birds in winter. What is this proposal by the Environmental Impact Report author mitigating? Page 4.7 - 26 Disseminate these in pamphlet form biannually to the new residents of this and adjacent foothill edge communities. No herbicides should be used in the riparian woodland. As previously stated, Larry Gilhuly of the United States Golf Association is working with the applicant on C214 an integrated pest management program for the property. We will be revising the Management Plan to include additional discussion on proposed IPM methods for Buckeye Ranch. Page 4.7 - 27 Mitigation 4.7-7 Incorporate into the CC&R's or Management Plan measures to enforce a dog leash requirement and prohibit livestock for the entire community. C21E 1 .- HI-132 ,