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considered for approval. The cursory studies of various sensitive species that have been D123 identified on the project site tell more about what is not known than what is known. Considering the one-of-a-kind biotic resources, including rare and endangered species, we find it disturbing that this new study attempts to lesson the biological significance of the site. What D124 has been offered as mitigation is inappropriate and inadequate to offset the cumulative adverse impacts resulting from this project. Sandhill Cranes: We can not find any discussion of protection measures or m!tigation for adverse impacts caused by the project on the greater and lesser sandhill cranes. The greater sandhill crane is afforded protection under the California Endangered Species Act and D125 the Migratory Bird Conservation Act, 1929. We request that the RDEIR authors properly consider the projects adverse impacts on this species and attempt to mitigate for impacts in the FEIR. Elderberry Longhorn Beetle: The elderberry longhorn beetle and its host plant the elderberry bush were inadequately studied to make generalizations about their presence, or lack thereof, potential adverse impacts, and the mitigation necessary to offset impacts. A couple of inspections attempting to identify beetle bore holes on the Elderberry is not enough study to dismiss the beetles' presence. We have noted that the principal area containing the Elderberry bushes is at the confluence of the created fairways in the riparian woodland at the Mokelumne River's edge. We can not help but be suspicious that the project developers may D126 have removed Elderberry bushes during the clearing of the woodland for the fairways. This destruction of the woodland and Elderberry bushes was a clever and heinous way to not have to mitigate for this destruction if it was made part of project consideration. In destroying elderberry bushes evidence of the longhorn beetle was also destroyed. These acts of destroying or minimizing significant resources prior to project application, thereby, lessening the mitigation necessary to offset impacts, are unsavory acts that we fear are being emulated throughout the county. What a sad story —told too many times in San Joaquin County. If this project is approved, the County is blessing these acts and sending a message to all developers to destroy significant resources located on pending project sites so they will not have to mitigate for them! What an ugly chronicle devoid of any consideration of the future or wise planning. I'm, personally, embarrassed for the County and all the residents who expect proper planning that will protect our resources, not to encourage their destruction to satisfy greed. Swainson's Hawk: Although the threatened swainson's hawk review seems to be comprehensive there are many questions left unanswered. Are project adverse impacts on D127 swainson's hawk habitat sufficiently mitigated? Is there a net benefit to swainson's hawks accruing from the project to offset impacts? We find it very disturbing in the discussion of offsetting impacts that the foraging area created by the creation of the fairways is factored in as a benefit. What about the significant adverse impacts of destroying this one-of-a-kind closed-canopy-interior-live-oak-riparian-forest. We would ask in all fairness that any benefit from this despicable act be thrown out, or we ask that you factor in the adverse consequences VI-110