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Ms. Kerry Sullivan <br /> January 26, 1993 <br /> Page Three <br /> 2 . Seasonal Wetlands <br /> The so-called Tracy Lakes provide a large area of shallow <br /> seasonal wetlands adjacent to the Mokelumne River. We <br /> agree with the RBS when it describes the Tracy Lakes as <br /> the "dominant biological feature of this area" . The <br /> proposed project as presented in the draft EIR would <br /> result in the deepening of all, or portions of the two <br /> Tracy Lakes for use as irrigation water storage <br /> reservoirs. <br /> We regard the habitat value of the present shallow lakes <br /> to be superior to the proposed deepened lakes. The <br /> current values include potential roost habitat for the <br /> sandhill crane, seasonal forage habitat for wintering <br /> waterfowl, nesting habitat for waterfowl, and seasonal <br /> foraging habitat for the Swainson' s hawk. The RBS <br /> proposes to lessen the impacts to wetlands by: <br /> a. Preserving and protecting south Tracy Lake in its <br /> present form. <br /> b. Concentrating development around, and deepening only, Bb <br /> north Tracy Lake. <br /> c . Mitigating the loss of seasonal wetlands at north Tracy <br /> Lake by a combination of cessation of tilling, water <br /> supply augmentation, and seeding of forage crops on the <br /> south Tracy Lake. <br /> Seasonal wetlands like those at Tracy Lakes have greatly <br /> diminished in the Central Valley due to past and present <br /> agricultural and residential development. In order to <br /> avoid further losses of this critical habitat type, the <br /> DFG pursues a policy of "no net loss" of wetland acreage <br /> or habitat value. In addition to the measures noted in <br /> the RBS, we recommend the project be designed so that any <br /> impacts to seasonal wetlands are completely avoided. If <br /> impacts to wetlands cannot be avoided, mitigation should <br /> be provided that is based upon the concept of no net loss <br /> of wetland habitat values or acreage. In this case the <br /> acres of seasonal wetlands that might be lost at north <br /> Tracy Lake must be off-set by the creation of a like <br /> number of acres of equal habitat value either on-site or <br /> in the near vicinity at a location acceptable to the DFG. <br /> II . Sensitive Species <br /> The RBS provides more information on the proposed <br /> project' s effect on listed species than the original draft B6 <br /> VI-7 <br />