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adequacy. The aquatic snake is particularly elusive and may not be seen using traditionally terrestrial snake survey methods. John Brode, of the Department of Fish and Game, who is an expert in reptiles of the area was not consulted. The surveys were lacking D96 not only in their method but in surveying only a limited area. This is a second example of a failure to utilize the best available information in these studies! This could result in a take according to the CESA. 5) The evaluation of Swainsons hawks also falls shorts. It fails to fully discuss how the project would disrupt the Dry Creek subpopulation. The probable effects are readily apparent by looking at the impacts of Galt. This somewhat social hawk is known to D97. interact peacefully with neighboring pairs in aerial displays and during migration. The fragmentation of social birds is know to have a negative effect on breeding. Once again, not even a simple phone call was made to Jim Estep who wrote the documents on which conclusions were made. 6) Other listed and protected bird species were dismissed from serious consideration for impacts because they don't breed on the site but merely use it for some part of their life cycle. If a site D98 is important for a species life cycle then loss of that area would be a take under FESA or CESA. Therefore, analysis for other bird species is inadequate and incorrect. 7) In one part of the Biotic study it states that the seasonal aspect of the lakes is important. Then in another part they propose D99 to deep and lose some of the seasonality as mitigation. This is an apparent conflict. 8) In the mitigation section, (4-13-1 (g) in particular) , states conclusions based on the EIR biologist 's opinion. The conclusion is given without the name or qualifications of the biologist. The D100 public can not adequately assess this conclusion without knowing the biologists name or qualifications. If light of the biologists other conclusions without consultation with resource agency personnel it is difficult to beleive this claim when combined with the skewed habitat evaluations as noted in #1. In summary, I urge the county to avoid a costly and tragic error in this project. Please select the "No-Build" alternative. The project would be contrary to the General Plan and violate state and �D101 federal endangered species mandates as well as the spirit of CEQA. The loss of natural resource to the county would be irreplaceable. I am also concerns that the county could easily become involved in legal battles over this project. That would cost all the taxpayers unduly. The General Plan was a good start to excellent planning, don't blow it! VI-93