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Ms. Kerry Sullivan April S, 1992 Page 20 Page 5 - 3 Water Consumption The expansion and year-round maintenance of the Tracy Lakes, along with the increased use of water for irrigation (golf course and pasture) and domestic water supply will result in a net loss C226 of water to the local surface and groundwater system in comparison with existing conditions. The main losses will be from lake evaporation and evapotranspiration from turf and other irrigated areas. Water rights pertain to this property and are regulated under State law by the concept of "reasonable beneficial use and should not be reprioritized by an Environmental Impact Report consultant's subjective views. For instance, domestic use is afforded the highest priority under State law. Instream uses, such as those that will serve the nature preserve under the Management Plan, are highly encouraged as well. Agricultural use on this property would far exceed the proposed usage without any opportunity of control under the Environmental Impact Report process - no irrigated agriculture would exist in the Central Valley of California if the standard was no use beyond the water than originates on the surface of the property. Page 5 - 4 Groundwater Overdraft The existing groundwater-esources in San Joaquin County are in a state of overdraft. Project C227 plans to pump groundwater for lake water level maintenance and irrigation will further add to the overdraft conditions. This could affect groundwater levels locally to the detriment of other water users in the area. The overdraft would not be as great as would be caused by farming the property. Does anybody contend it couldn't be irrigated like the adjoining properties? This use is water conservative. Page 5 - 4 Nitrate Loading C228 The introduction of nitrogen via on-site wastewater disposal and irrigation and fertilization of golf course and pasture areas will add to the long-term nitrate concentration in groundwater in the area. Nitrate concentration in groundwater are generally increasing throughout the Central Valley as a result of agricultural and waste disposal practices, causing violation of drinking water standards in many areas. The project will add to the overall nitrate loading. As I previously stated,the nitrate impact of 320 cows is significantly greaterthan 75 people. Page 5 - 4 Biological Resources Development of the project site would contribute towards the reduction of foraging habitat for {C229 the Swainson's hawk. Converting much of the original Tracy Lakes habitat from a seasonal wetland to a permanent lake removes a valuable habitat resource for migratory waterfowl in the Central Valley. It is clear from the Environmental Impact Report text that the Environmental Impact Report author did not read the Management Plan which explains the seasonal marshes that are proposed to be created in the fingers of the lakes. III-135