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gjaM19 � January 30, 1993 FEB 11993 V COMMUNN Y UUrwriviuv i UEpT. PLANNING DIVISION Kerry Sullivan Senior Planner San Joaquin County Community Development Department 1810 Hazelton Ave Stockton CA 95205-6232 Dear Ms Sullivan, I have provided comments regarding the Draft Environmental Impact Report prepared for the proposed Buckeye Ranch project in Brovelli Woods. I do not think that the Draft EIR is complete as addended by the "Supplemental Biotics Study" and the "Archaeological Identification Studies". The project should not be allowed to proceed. Impact 4.13-1 The proposed development would result in the loss and disruption of nesting and foraging habitat for the Swainson's hawk. D114 Mitigation Measure 4.13-1(d) indicated that a management plan that would result in a net benefit to Swainson's hawk must be prepared according to CDFG Regulations, Section 2081. The project should not be allowed to proceed until such time as a management plan is developed. Impact 4.13-3 The proposed "restoration" of Tracy Lakes would greatly reduce or eliminate the water bird habitat value of two thirds of this historic seasonal wetland site. D115 Mitigation Measures 4.13-3(c) and 4.13-3(e)require securing the services of professional scientist,waterfowl management specialist and hydrologist,to prepare management plans. The project should not be allowed to proceed until such time as the plans are developed and approved by the County. Impact 4.13-5 Human activities could cause potential impacts to the adjacent natural community. Mitigation Measure 4.13-5(b) d. indicate that a development restriction would include a D116 stipulation that all pets must be contained and not permitted to run free through open space areas. Unless cats are specifically prohibited within the development, it is unlikely that this mitigation will be sufficient to prevent cat prowling of rodents. Rodents are necessary to sustain bird populations. VI-105