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a <br /> Mr. Richard Larrouy 2 <br /> The larvae of the threatened valley elderberry longhorn beetle feed and mature <br /> within the elderberry shrub. Use of the plants by the early stages of the <br /> animal, a wood borer, is very rarely apparent. Frequently, the only exterior <br /> evidence of the use of the shrub by the beetle is the exit hole created by the <br /> larvae prior to the pupal stage. The beetle has been found in plants with <br /> trunks possessing a diameter of one inch or greater. If direct and indirect <br /> impacts to the elderberry shrubs that were discussed with the biological <br /> consultants are carried out then take of the threatened valley elderberry <br /> longhorn beetle will be avoided. <br /> The information we have received indicates that vernal pools are found on the <br /> southside of the proposed project. Over 90 percent of vernal pools in the <br /> Central Valley have been lost due to past agricultural conversion, urban <br /> development, and flood control activities. Wetlands provide important <br /> resting, feeding, and nesting habitat for many species of migratory birds. <br /> Because of the value of this habitat to migratory birds and because of the <br /> scarcity of this habitat, the wetland areas with the project area belong in <br /> Resource Category 2 as defined in our Mitigation Policy. For unavoidable <br /> impacts to this habitat the Service recommends provision of mitigation that <br /> results in no net loss of in-kind habitat values or acres. These pools may <br /> also provide habitat for the California linderiella (Linderiella occidentalis) <br /> and the vernal pool fairy shrimp (Branchinecta lynch!) . Although candidate <br /> species are not protected, the 1988 amendments to the Act require the Service <br /> to monitor their status. If any of these candidates decline precipitously, <br /> they could be listed under an emergency basis. We, therefore, encourage your <br /> department to address impacts to these candidates. <br /> The U.S. Fish and Wildlife Service encourages all efforts to protect, improve <br /> and restore fish, wildlife and naturally functioning aquatic and wetland <br /> ecosystems of our nation. Under the provisions of the Fish and Wildlife <br /> Coordination Act, the Service advises the U.S. Army Corps of Engineers on <br /> projects involving dredge and fill activities in waters and wetlands of the <br /> United States. The proposed projects allowed under the General Plan revision <br /> may require a Corps of Engineers permit, thus triggering Service involvement <br /> per the Coordination Act. Because of our interest in the biological integrity <br /> of our Nation's waters, we generally recommend against a project when its <br /> construction would result in the destruction of wetland habitat values and is <br /> not water dependent. When projects impacting waterways or wetlands are deemed <br /> acceptable to the Service, full mitigation is recowmnended for any fish and <br /> wildlife value losses shown to be unavoidable. However, as directed by <br /> Section 404(b) (1) of the Clean Water Act, the project proponent must first <br /> demonstrate that there are no other less damaging, practicable alternatives to <br /> the proposed project that would achieve the basic project purpose. <br /> The Council of Environmental Quality regulations for implementing the National <br /> Environmental Policy Act define mitigation to include: 1) avoiding the impact; <br /> 2) minimizing the impact; 3) rectifying the impact; 4) reducing or eliminating <br /> the impact over time; and 5) compensating for impacts. The Service supports <br /> and adopts this definition of mitigation and considers the specific elements <br /> to represent the desirable sequence of steps in the mitigation planning <br /> process. Accordingly, we maintain that the best way to mitigate for adverse <br /> biological impacts is to avoid them altogether. <br />