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Ms. Kerry Sullivan <br /> January 26, 1993 <br /> Page Two <br /> I . Loss of Habitat <br /> 1 . Riparian Forest <br /> The proposed project has already resulted in the loss of <br /> approximately 13 acres of mature riparian forest along the <br /> Mokelumne River in the so-called Brovelli Woods through <br /> the clearing for construction of golf fairways . Mature <br /> riparian habitat in the Central Valley of California has <br /> undergone serious declines and there is presently a <br /> critical shortage of this habitat type. The loss of <br /> mature riparian forest through the construction of the <br /> B3 golf course fairways, and the proposed construction of <br /> roadways, bridges, and equestrian facilities is a <br /> significant adverse impact to the environment. <br /> i <br /> The RBS provides a narrative description of the Brovelli <br /> Woods portion of the project site, however it does not <br /> assess the loss of the 13 acres of mature riparian forest <br /> and its impact to wildlife other than as a possible "take" <br /> of Swainson' s hawk habitat. While the loss of Swainson's <br /> hawk habitat must be addressed, there are other <br /> significant impacts associated with the loss of habitat in <br /> Brovelli Woods . <br /> The incursion of the project features such as golf course <br /> fairways or roadways into Brovelli Woods may cause some <br /> loss of its habitat value through fragmentation. Some <br /> species of wildlife, particularly birds, are restricted to <br /> nesting in the dense forest conditions found at Brovelli <br /> Woods . "Opening up" mature riparian forest allows the <br /> invasion of a number of nest predators and obligate nest <br /> parasites like the brown-headed cowbird (Molothrus ater) <br /> and may lessen the forest' s value for other wildlife <br /> B4 restricted to this habitat type . <br /> We recommend that the RBS be revised so that the loss of <br /> 13 acres of mature riparian habitat in Brovelli Woods is <br /> mitigated. Appropriate mitigation should consist of <br /> protection of a like amount of mature riparian forest <br /> which is similar in habitat value to the 13 acres and <br /> development of new habitat of the same type at a 3 : 1 ratio <br /> in order to mitigate for values lost. Protection may be <br /> achieved either through acquisition of fee title or a deed <br /> restrictive conservation easement. We also recommend <br /> that, in order to avoid further habitat loss, the Brovelli <br /> Woods portion of the project site be removed from any <br /> further development impacts . <br /> VI-6 <br />