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MEMORANDUM TO FILE <br /> FROM: Tom; Zuckerman ✓ <br /> ... <br /> :: r.••` i.• yon ..r;,.... ; <br /> u <br /> �y <br /> DATE: Ndve r 12;;. `1992 <br /> M,Suppl. emental' Biotic Study for: -M b <br /> • Buckearci D�ve10 ment - <br /> ,. <br /> October .:1992, <br /> My basic criticisms of tha Supplemental Biotic Study <br /> remain: (1) factual inaccuracy; (2) erroneous baseline <br /> assumptions; and (3) lack of balance given the proposed <br /> enhancements described in the Management Plan. <br /> 1. FActual Inaccuracy. <br /> Page 1, last paragraph: Tracy Lake did not fill to <br /> anywhere near its capacity in mid January 1992 . At present D28 <br /> capacity, the maximum lake depths at capacity would be + 20 feet. <br /> Page 3, last paragraph: The Mokelumne River has not <br /> overflowed its banks in this vicinity at least since the D 9 <br /> completion of Comanche Dam and Reservoir. Consequently, the <br /> implication that overflows remain a dynamic part of the fishery or <br /> forest habitat is erroneous. <br /> Page 11, "Fish" paragraph: Again, the Mokelumne River D30 <br /> no longer periodically overflows its banks. <br /> Page 22 , "Habitat" paragraph: This statement is at best <br /> misleading; to my knowledge, there has been no determination that <br /> Tracy Lake constitutes "critical habitat for migratory water birds <br /> under the Migratory Bird Conservation Act, 1929 . " Such a finding <br /> would be at direct odds with the annual drainage and tillage of <br /> the lake bottoms which occurred for many years under the prior D31 <br /> ownership. <br /> Page 22, "Project Description" paragraph: The final <br /> sentence describes the proposed Mokelumne River crossing as <br /> 'Primary project access. "' Actually, there would be two primary D32 <br /> access points, the other being the existing Forest Lake Road on <br /> the north. There is a third, but secondary, access road by means <br /> of the private right-of-way connecting Jahant Road on the south <br /> VI-b9 <br /> Z0•d 29TE89V 01 NOSi�GgM! W0dj Zb:TT 266T-TO-U-d <br />