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Ms . Kerry Sullivan January 26, 1993 Page Seven Swainson' s hawk habitat. The California Environmental Quality Act (CEQA) requires that the EIR contain the details of actual mitigation proposals . In this case, that would involve an actual detailed plan for a Scottish type course, not a promise to develop one at some point in the future. We recommend that the RBS be revised to include the details of measures which are designed to off-set both the direct and indirect loss B10 of habitat for the Swainson' s hawk. Mitigation should ! be based on the DFG' s draft Mitigation guidelines for the Swainson' s Hawk (Buteo swainsoni) in the Central Valley of California (revised January 1 , 1992) . Mitigation measures presented in the DFG' s Guidelines are meant as "minimum" guidelines . Clearly, the importance of the project site to Swainson' s hawks warrants exceeding the minimum. - Item 4 . 13 ( f) . As indicated in Figure 4 . 7-15, the proposed development area is a large area that may be used by foraging Swainson' s hawks . Therefore, use of rodenticides should be prohibited in the development B11 area as well . To avoid take of Swainson' s hawk through secondary poisoning, the RBS should contain a provision that only burrow fumigants be used at any location on the project site regardless of the layout of the golf course . 2 . Loss of Seasonal Wetlands (Impact 4 . 13-3 ) None of the proposed mitigation measures discuss or address the loss of seasonal wetlands at north Tracy Lake. We recommend that the RBS be revised to include adequate mitigation for the direct loss of seasonal B12 wetlands at north Tracy. This should be accomplished through the creation of a like number of acres of a similar habitat value on the project site or in the near vicinity in a location acceptable to DFG. 3 . Loss of Mature Riparian Forest The proposed project has resulted in the loss of approximately 13 acres of mature riparian forest in an area known as Brovelli Woods . Approximately 98 percent of California' s original riparian habitat has been destroyed making the conservation of this habitat type B13: of critical importance . Further loss of riparian habitat type should be avoided. In order to mitigate the direct loss of 13 acres of mature riparian habitat, as well as, the loss of habitat value resulting from the fragmentation of the remaining forest, we recommend t that the RBS include the following measures : VI-11