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M.akelumne lover Alliance February 1 , 1993 San Joaquin County Community Development Department Attention: Kerry Sullivan 1810 East Hazelton Avenue Stockton, CA 95205-6232 Re: Comments on the Revised Draft Environmental Impact Report (RDEIR). No. ER-91 -2 SCH No. 91012103, for the "Buckeye Ranch" Project. -proposed by the Catwil Corporation aka Robertson Homes. Dear Community Development Department, Kerry Sullivan, and the RDEIR Authors: The mission of the Mokelumne River Alliance (MRA) is "the long-term preservation and restoration of the Mokelumne River and its bordering habitat for the present and future benefit of wildlife, fisheries, and citizens of the area." The proposed Buckeye Ranch Subdivision and D121 its potential identified and unidentified adverse impacts on biotic and cultural resources are contrary to our mission and wise planning in this County. It must be remembered that this is not just another piece of dirt. The project site functions as a "biological island" containing two of the few remaining examples of a once dominant feature of the Central Valley, large wetland lakes and a mature riparian woodland. Further loss of these areas is opposed by governmental agencies and private conservation groups. This is the last remaining example in San Joaquin County of a place with moderate environmental and cultural integrity. Potential significant adverse impacts on this one-of-a-kind biotic and cultural resource wonderland are not and can not be adequately mitigated to less-than-significant levels, therefore, we submit the following comments: We note that there appears to be an internal inconsistency between mitigation recommendations made for the archaeological resources and those made for the biological resources. The biological review recommends that site disturbance activities be kept out of the -122 woodland area and limited to the upland savannah area. The archaeological consideration suggests that site disturbance not occur on the upland areas next to the lakes, where the most sensitive cultural resources are found. Unfortunately, this upland area is the very location where the home-sites are desired. BIOLOGICAL REVIEW: We appreciate the additional biological field work conducted in the interim while the archaeological study was completed. We are thankful that the prior inadequate biological 1123 section has been revised. In general the biological study seems to be a worthy risk assessment, but we suggest that thorough species studies be undertaken before this project is VI-109 P. O.Box 1971,Lou., _.- .5241 209-368-9396