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a SIERRA DELT -SIERRA GROUP SIERRA DELTA THER LODE CHAPTER 1.;Lus D •. '"SIERRA CLUB JAN 291993 P. 0. Box 9258 Stockton, CA 95208 ,../+VII uic l P LGYLLvi, ...ii, iJLf 1. PLANNING DIVISION January 29 , 1993 Kerry Sullivan San Joaquin County Department of Planning 1810 E. Hazelton Ave. Stockton, CA 95205 Dear Ms. Sullivan: The Delta-Sierra Group of the Sierra Club has reviewed the Supplemental Biotics Study for the Buckeye Ranch Development Draft Environmental Impact Report (DEIR) . We have comments and concerns in addition to those presented in our first letter. These fall into two broad categories: significant effects not addressed and inadequate mitigation for significant effects. The fragmentation of the closed canopy oak woodland and the removal of understory in conjunction with the golf course construction substantially diminishes habitat for wildlife and plants and should be considered to be a significant effect under CEQA. Fragmentation of the woodland and removal of understory plants changes the very nature of a closed canopy forest. It increases access for predators, including nest predators, and may result in the invasion of alien plants not associated with a closed canopy forest. This significant loss of habitat is not D22 mitigated for in the DEIR. There should be acquisition of 90+ acres of a like habitat for permanent protection either through a conservation easement or purchase and donation to an appropriate agency, land trust, or other non-profit group. This mitigation measure deserves strong consideration in light of the two conflicting mitigation measures proposed in the study: 4 . 13-1 (a) limits the golf course to the area surrounding North Tracy Lake while 4 . 13-1 (e) proposes "timesharing" the fairways that would be in the woodland with the Swainson's hawks. The potential value of the site for greater sandhill crane roosting was not adequately addressed in the study because no field work was conducted during the major roosting period for the cranes. We believe, based on the documented sightings on lands adjacent to the site, that there is a high possibility that D23 cranes do roost at the site. The biotics study is inadequate in this regard and field observations for roosting greater sandhill cranes should be conducted before the Final EIR is completed. The mitigation measures proposed for the Tracy Lakes claim to result in "no net loss of wetland habitat on the site" . This may be true when compared to the practice of the previous owner of pumping the lakes to plant crops some years. But there is DI24 insufficient information presented for us to conclude that VI-63