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The described mitigation procedures are placating at best, to the Native American Community. Placing wire mesh over burial mounds, D104 documenting found archaeological objects, and having a "Native American monitor," do not preserve the sacred nature of this site. The "no-build" alternative is the only viable option at this time. The remaining Brovelli Woods area is uniquely significant from an ecological standpoint. the importance of this area, including the D105 surrounding uplands, is such that impacts and further habitat loss is not acceptable. The proposed development of any of the build alternatives is simply not compatible with the need to preserve such critical habitat. The proposed project is not compatible with the Conservation designation called for in the General Plan. There are significant adverse impacts associated with the proposed project. In addition, D106 there are public trust issues associated with the determination that public access is not planned for in this project. Although such access needs to be managed so as to protect sensitive natural and cultural resources that make this area unique and important, such access still must be provided. The loss of at least 12% of the existing woodland habitat at this site has not been fully assessed. If the tree clearing actions that were already taken by the applicant had been instead proposed in the DEIR, there is a strong possibility they would not have been allowed to occur. The proposed project has already had a very significant D107 adverse impact on the Swainson's Hawk. This state-listed threatened species has suffered loss of nesting and foraging habitat as a direct result of the project activities. It is also possible that another state- listed species, the greater sandhill crane, was also impacted. This impact would certainly increase greatly if the project were approved in any form. The only appropriate compensation for the significant impacts that have already occurred would be to provide permanent conservation protection for the remaining area. This would also require the current development proposal to be dropped. The supplemental biological studies that have been performed for the proposed Buckeye Ranch Development are still inadequate in D108 scope and duration to reach conclusions that the project can be successfully mitigated. The stakes are in fact too high to take the great risk that this project poses. VI_%