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Based upon observations from 1989 to the present, savannah is not a preferred D77 habitat for sandhill cranes of this flock. The DER should have made the point that the site provides marginal habitat for cranes, Instead of placing emphasis on It possibly being significant. The lake bottoms are too deep to provide open vistas Sandhills seem to prefer. In our opinion they do not offer habitat for this spades. Page 22 - Weatam Pond Turtle The Identity of the subspecies status of the northwestern pond turtle D78 (Clemo=Marmorgta) is confusing. The Biotic Study states that the northwestern pond turtle (Q. M. mnrmnrgta) was Identified as occurring on the site (page 11). Yet In the discussion of rare and endangered species, the "threatened'form is listed (S. m, pguida). 111. Recommended Mitigation Measures P. 25-31 - Mitigation Measures - Ganaral Comments Since the Biotics Study fails to discuss the extent to which the site has been degraded due to past grazing and farming activities, it does not discuss the full range of opportunities for restoration of seasonal wetlands, vernal pools, riparian, oak woodland, savannah, and native grassland. These restoration opportunities will help to increase species richness and numbers. For example, D79 the understory shrubs In much of the Broveill Woods area, once grazing ceases, would gradually increase. This would provide substantially new habitat for many species of wildlife, especially the avifauna. The same would be true for wetlands and vernal pools. Very little riparian vegetation exists on the site largely due to overgrazing and farming. A remnant stand of willows, ash, buttonbush and boxelder exists at the south end of North Tracy Lake. This stand provides an example of the potential to establish this now scarce habitat along much of the perimeter of Tracy Lakes through the release of grazing and active restoration. Riparian species trees that would grow around the perimeter of the lake Dao would grow much faster than the woodland tress recently planted These trees reach "heritage" proportions in less than 40 years and thus would provide suitable habitat for nesting Swainson's Hawks. It is important to note that the successful Swainson's Hawk nest on the property was in an emergent cottonwood, not an oak. E!, 27 4-13-1(g) Dsi Eliminating grazing on the site will greatly benefit the establishment of riparian and woodland plants. However grazed grassland areas benefits some spades of wildlife, such as raptors, geese and other species that prefer short 6 VI-86