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of this destruction. The adverse impacts far outweigh the benefits to the resident plant and D127 animal communities. The combination of biological attributes resident at Brovelli Woods/Tracy Lakes, such I as. roosting and nesting sites in the mature foothill/riparian woodland, coupled with the adjacent grassland foraging areas is especially important for the threatened swainson's hawk. D128 Any disturbance of this interrelationship should be avoided. Project approval will result in significant adverse species impacts caused by increased human presence, the construction of the homes, the equestrian center, the golf course, roads, and the proposed bridge construction. According to the California Department of Fish & Game Mitigation Guidelines for Swainson's Hawk in the Central Valley, any project adversely affecting Swainson's Hawk habitat must result in a net benefit to the species. We are aware of the listed mitigation measures that attempt to "adequately offset adverse impacts," but they do not result in a "net benefit" to the species. There is no delineation of mitigation that attempts to provide a net D129 benefit. The RIDER review is deficient until a net benefit can be shown. The "time share" idea of using alternative golf course holes during sensitive nesting times may look appealing on paper, but in project reality is not reasonable and feasible. It appears that the good will gesture of the developer to set aside the major portion of the project site in a conservation easement is used too times as mitigation to offset several identified impacts to different biological resources. Tracy Lakes: The most dominant biological feature of the project site are the pluvial Tracy Lakes. The biological assessment of lake hydrology is predicated on the 91 -92 year, which approached a normal year, but followed several years in a row of drought. To generalize about the 91-92 year as being normal is dismissing the effects of the prior years on D130 lake hydrology and soil saturation, or lack thereof. The discussion, on page 3, supports the fact that in nearly all years without the artificial draining of the lakes they would be more accurately referred to as "permanent wetlands" not "seasonal wetlands," as described repeatedly in the review. To refer to the developers plans for the Tracy Lakes as a "restoration" project is a leap of faith we are not willing to make. To reduce or eliminate two-thirds of this water bird habitat value in a rare natural Central Valley wetland basin will be catastrophic. The Tracy Lakes destruction project may be a more appropriate description of the significant adverse impacts D131 on the animal and plant communities that will occur from the developers lake and quarry project plans. The yearly natural cycle of these lakes and the plant and animal communities dependent on them will forever be altered —to achieve what? —the convenience of watering the golf course from the lakes?! The Tracy Lakes are fully protected since they constitute critical wintering habitat for migratory water birds on the Pacific Flyway under the Migratory Bird Conservation Act, 1929. D132. We suggest that the projects "restoration" project is contrary to this act. The loss of winter foraging, refuge habitat ,and habitat for spring and summer nesting activities and the rearing of V1-111