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The project area has been noted as particularly important natural resource of the county and has been identified for preservation as discussed with the county by conservation groups. The habitat D90 values and functions are irreplaceable within the constraints of modern planning. The restoration of an area like this could take well over one hundred years if at all. Surrounding wild areas no longer exist to expect recruitment of species as we have seen in the past. I am also greatly concerned that the supplemental studies would be fragmented from the EIR temporally as they are. This obscures the D91 full impacts of the project from the public. The public has a right to be informed in such a way that it can intelligently weigh the consequences. (Environmental Planning and Information Council v. County of E1 Dorado, 1982) . In addition to the general comments provided above I more specific comments on the adequacy and content of the EIR supporting Documents: 1) The studies were completed after the first near normal precipitation in six year. The consultant biologist states that these conditions allowed the most complete evaluation to date. It is very obvious that over a period of six year of drought that D92 conditions are far from normal. It is unreasonable to expect that conditions could revert to normal in the first growing season based on very basic ecological principles. Therefore, assessment of resources is inadequate due to non-normal circumstances., The habitat values on average should be higher and potentials for enhancement are overstated. 2) The conclusion of no elderberry longhorn beetles on site is D93 incorrect in two ways. First, under the federal endangered species act, habitat loss within the known range of the species would be considered a "take" and be in violation of FESA. Secondly, the random inspection of limbs for exits holes is not a reliable or accepted method of assessment. The US Fish and Wildlife has D94 required mitigation and consultation in similar situations. I also noted that the consultant biologist did not contact Chris Nigano of the USFWS, who is an expert on the species in the area. This points out the inadequacy of the evaluation for this species. Destruction of VELB habitat would be a FESA violation! 3) The Biotic supplement understates the importance of the D95 importance of the floodplain including the beaver pond, and Tracy lakes to fish for spawning during high water events. Again the studies of the fish populations in these ponds reflects non-normal times. The failure to find tiger salamanders may also be related to a temporal shift in the hydrology of the area. D96 4) The evaluation for Giant Garter Snakes also falls short of VI-92