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IC. U. M. E. oalition for Urban Management ExcclICnce 2/1/93 Kerry Sullivan San Joaquin County Community Development Dep 1810 East Hazelton Ave. 444777��777 Stockton, Ca. 95205 FEB 1 1993 Dear Ms. Sullivan, COMMUNII I UtYtLvr,,;�; PLANNING DIVISIONI DEPT. As spokesperson for C. U. M. E. , Coalition for Urban Management Excellence, representing 3500 residents of San Joaquin County, I am writing to express my concerns with the inadequacy of mitigations offered for the proposed Buckeye Ranch as defined in the D. E. I . R. #91012103. I have reviewed that document as well as the Supplemental Biotics Study and the Archaeological Identification Studies. At first glance, the project seems appealing and nicely designed, as well it might be located somewhere other than on Williamson Act state contracted farmlands, Indian burial grounds, Swainson hawk nesting and foraging sites, the 100 year flood-plain, protected wetlands, sovereign "public trust" lands, and the last mature riparian oak grove in the County. This list constitutes a staggering amount of unavoidable impacts for the developer to attempt to mitigate. D6 When the magnitude of the convergence of all these significant factors in one area--a truly unique combination of archaeological, cultural, and environmental conditions--is fully examined and appreciated, it is clear that the developer will be hard put to "mitigate the unmitigatible" . When 99% of the riparian forest of San Joaquin County has already disappeared to urbanization and agriculture, how does one mitigate the obvious degradation and destruction of the last remaining one percent of that resource? The D. E. I . R. itself claims the "placement of residential lots and golf course fairways undermine the integrity of the forest, and degrade a unique biological feature. " <pg. 3-2> . Preliminary development of Buckeye Ranch golf course has already resulted in the loss of 13 acres of mature riparian forest and an undetermined amount of oak savannah and vernal pool habitat. The developer' s 10 acre replant program, while lauditory in its intent, does not begin to replace the lost habitat in that it takes 100 years for the trees to gain the stature of those removed. According to Dept. of Fish and Game, this could constitute a "take" for the species of Swainson' s Hawk found- nesting and foraging there. ,VI-47 one P. O. Box 2117, Lodi, CA 95241