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v � DEL A-SIERRA OUP � z MOTHER LODE CHAPTER SIERRA CLUB San Joaquin County Development Department 18 10 E. Hazelton Ave., Stockton Ca. 95205 D attn: Kerry Sullivan, Senior Planner We have received the revised biological section of the Draft EIR and the supplemental information on the archeological section of the original DEIR of the u 09 "Buckeye B ckeye Ranch/O ✓ �� Project. We have a few comments at this time and may have more at the time of the '0V hearing or the close of comments on January 29. v/y a 1) We are happy to=ee that, finally, adequate studie3 of both biological and archeological ��r`� ,`99`� y g 9 values of this unique property have been completed. Q/�<�� i ,/�c;�> 0 �- 2) It remains an unfortunate fact that the present owners were able to literally buy this property 'but from under the noses" of the Wildlife Conservation Board and the public. It would have made a outstanding wildlife preserve. No other comparable area project has been identified which could be purchased with funds set aside for this project. :.) When the proponents purchased the property they agreed to meet with us to show us their plans for development. At that meeting representatives of the local Audubon Society and the Sierra Club suggested several changes in their plans which would have allowed them to have their development but to also protect those wildlife values which they claimed to value. They rejected all of our suggestions. It is ironic that many of the mitigation measures suggested in this revised draft are the same which we suggested at that meeting. We particularly point out "Mitigation Measures 4. 13- 1(a) and 4. 13-1(b)" which we suggested to Mr. Zuckerman at that meeting. We agree with the necessity of all the proposed mitigation measures. 4)We did not originally know of the presence of Swainson Hawk nesting, but we did know of the I presence of Sandhi II Crane and have photos of them taken in the area near North Tracy Lake. D20 While the proposed mitigation measures would be desirable the irreversable loss of habitat for these species should also be mitigated for by the purchase of 175 acres of good off-site I habitat for these species. 5) Neither did we know of the extensive archaeological values of this site although we had seen clay artifacts and human bones when the field to the south-east along the Mokelumne River was leveled in the late 1960's. It does appear that some of the mitigations suggested in the revised biological section would D21 lessen some of the archeological impacts. This is difficult to determine since the actual location of the sites is only generally described in the supplement. Mitigation Measure 4. 13- 1(a) and 4. 13- 1(b) would move development away from the river side of the property and would so appear to lessen impact on most sites. It is a shame that the proponents of this project were not interested in considering our concerns at the outset of planning. Had they bePn willing to negotiate in good faith rather than rejecting our suggestions much of the expense and ill will which has transpired could have been avoided. I rely, Q�L M . K.. , o c k i n g Conservation Co:chair/ Delt - ierra Oroup VI-61