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side of the property. Furthermore, the characterization of the proposed Mokelumne River crossing access extending through D32 Brovelli Woods is misleading. This access point basically skirts the eastern side of Brovelli Woods rather than bisecting the forested area. Page 23, next to last paragraph: The characterization that the project would 'result in a loss of critical nesting habitat and foraging habitat" appears erroneous. There would appear -to be more than sufficient remaining nesting habitat for - the population of Swainson's Hawk which could be associated with the area. Furthermore, on a net qualitative basis I don't believe D33 there is a loss of foraging habitat. The combination of the tree removal which opened up "'fairway" area in the woods created additional foraging habitat, and the provision of permanent lake and elimination of cattle grazing should increase the available rodent population utilized by the Swainson's Hawk. Additionally, there is no evidence that the original logging constituted a "taking, of critical Swainson's Hawk habitat. Page 23 , last paragraph: Based upon actual sightings of nesting hawks in heavily utilized public parks and golf courses in the area, it is doubtful whether the proposed golf course project D34 would create a prohibited disturbance factor. As the author notes in the following paragraph, this raptor has accommodated itself to human presence in other locations. Page 24, 4th paragraph: As noted above, the available foraging habitat should be viewed on a net qualitative basis. The Management Plan should increase rodent production by greatly increasing the lineal extent of lakeshore, and by eliminating D35 cattle grazing. Moreover, the 49 acres in residential lots will not be totally lost. About one-half acre per lot (13 acres) will be actually involved in the residential development, the balance will remain in natural landscape. The golf course will provide excellent foraging habitat as well as the area surrounding the horse stables. I Page 24, 5th paragraph: By providing a permanent water supply in both lakes, the shoreline area will be dramatically D36 increased through the project development. The balance of the I paragraph is based upon an erroneous baseline assumption which will be discussed below, but the condition which this paragraph VI-70 �0'd £9T�89b 01 NOSidegOa WMiA ZV:TT Z66T-TO-HSS