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leechfield would be extremely difficult at best, given that D12 <br /> no one knows for sure the sites of additional burial or <br /> habitation spots. <br /> The impossibility of effectively monitoring the <br /> application of pesticides and herbicides by the resident <br /> community is another of the "unmitigatible mitigations" . The <br /> mitigation is advisory, but who will enforce it? The same <br /> with the impact of domestic pets and their considerable <br /> negative effect on the native wildlife. Unless the <br /> developer is willing to provide a local "pet police" , I doubt <br /> that there can be much guarantee that the residents will D13 <br /> always confine their animals indoorsVon leashes. It <br /> wouldn' t take much disturbance on the part of the domestics <br /> to successfully drive some of the more delicate species from <br /> the area. The language of the proposed mitigation is <br /> especially weak and inadequate when it seeks to "encourage <br /> restriction of pets, particularly cats, to the house area. " <br /> It needs to require not merely "encourage" . <br /> Two other areas of confusion and inadequate mitigation <br /> are the issues of "public trust" and "water diversion and <br /> pumping" . With a present groundwater overdraft of 270, 000 <br /> acre feet per year, and a river that frequently "runs-to- <br /> ground" below Woodbridge Dam, likelihood of using either of <br /> these two beleagured sources is slim. The Mokelumne River <br /> is currently the source of public hearings at the State Water <br /> Resources Control Board because biologists and scientists are <br /> concerned with the current low flows down the river, D14 <br /> declaring it "aquatically dead" and presently unable to <br /> support native fisheries. Yet page 4. 6-12 of the D. E. I . R. <br /> says that "diversion, if obtained entirely from the Mokelumne <br /> River, could represent 10 to 15 percent of the summer <br /> streamflow. " Both of these sources, the underground aquifer <br /> and the River, are already depleted beyond their present <br /> capacity to replenish themselves as is. The idea of <br /> removing even more water from these depleted systems is aS <br /> questionable as the idea of filling the lakes in the first <br /> place. <br /> In addition, State Lands Commission confirms in their <br /> April 6, 1992 letter that portions of Tracy Lakes and Jahant <br /> Slough are indeed sovereign lands and subject to public trust D15 <br /> claims. There is some discussion that not only the water <br /> bodies, but the whole rarity of the project site qualify it <br /> as worthy of public trust definition. These issues are not <br /> resolved in the current D. E. I . R. or the supplements. <br /> Of side interest is the fact that while perhaps <br /> mitigatible, it is of questionable wisdom to plan housing on D16; <br /> the 100 year flood plain, deliberately exposing future <br /> residents to the inconvenience and possible hazard of those <br /> conditions. <br /> page four <br /> VI-50 <br />