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Ms. Kerry Sullivan April 8, 1992 Page 23 Page 6 - 2 Cultural Resources Damage to the surface archaeological remains of the Tracy Lakes complex has already taken place due to the clearing and grading for the proposed roads and golf course. At this stage of planning, the no project alternative is the only acceptable alternative for these highly significant C239 sites providing the property continues to be used for grazing purposes. Leveling of the land for agricultural purposes would destroy most of the significant cultural resources. Due to the significance of these resources, it is unlikely the land could be substantially altered without proper mitigation. Dave Fisher,an owner of the property, and Jaime Nunez,superintendent,have presented declarations to San Joaquin County stating they found no archaeological remains during their removal or subsequent dirt managementthat was necessary to fill the stump holes. Damage to the archeological sites has been caused by various archaeologists over the years who have excavated the sites. Page 6 - 3 Land Use/Planning Policy The proposed golf course design intrudes on the existing riparian area, reducing its value as a habitat. Elimination of the course would preserve habitat and improve compatibility between on- C240 site land uses. The Environmental Impact Report author clearly does not understand the valuable habitat an environmentallysensitive golf course can create. Paae 6 - 3 Geoloav This alternative would reduce the soil-related impacts in two significant ways. First, with respect to wastewater disposal,the concern about inspections, maintenance,construction and repair of C241 leachfield systems would be reduced, since the systems would presumably be located in relatively accessible open space areas, rather than in golf course fairways. The need for dual systems and construction all leachfield systems at the start of developmentwould be reduced or eliminated. Second, with respect to erosion, the elimination of the golf course would reduce grading needs and the consequent soil erosion,dust generation and soil compaction concerns. It appears the Environmental Impact Report author is making the issue of the septic systems a bigger I issue that it needs to be. The concept of Planned development promotes flexibility in design. The elimination of the golf course would necessitate the need to introduce more cattle to the property increasing the likelihood of the creation of a dustbowl. Page 6 - 4 Water Resources 1 The elimination of the golf course would substantially reduce the water demand. Water trapped for storage from Jahant Slough would be adequate to meet the demands of the project except during the most severe droughts. Since surface water impoundments would meet the project demands, the need for make-up water from groundwater pumping or summer diversions from C242 the Mokelumne River would be eliminated,reducing impacts on these resources. Impacts to the flood storage and flood dynamics would be similar to those discussed above for the proposed project. The project would still create building pads, roads, canals and lakes that affect the floodplain storage and flood elevation on the site. Nitrate loading to groundwater would be reduced by about 20 percent in comparison with the proposed project. Erosion hazards III-138