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N.. .,i improvements and methods of construction need to be considered in the impact analyses". • A grading permit is required by the San Joaquin County Community Development Department Building Division. All requirements of the Building Division will be met. Because the only access to the Island is by boat, equipment and construction materials will be brought to the Island by boat barge. Use of one small tractor is all that will be required as the intent of the project is to disturb as little of the environment as possible. Volunteers will do most of the work, including construction of trails, by hand. Because grading will occur over an area greater than 1 acre, CDHEF will comply with Section 402 of the Clean Water Act(CWA) and obtain coverage under the National Pollution Discharge Elimination System (NPDES) General Construction Permit, which will require the preparation of a Stormwater Pollution Prevention Plan (SWPPP) that describes the Best Management Practices (BMPs) to be employed on-site to reduce erosion and sedimentation impacts to surface waters. Mitigation measures and BMPs will be identified in the SWPPP and implemented to minimize impacts to waters of the U.S. and to water quality. "The proposed project has been designed to avoid all elderberries to protect the federally threatened Valley elderberry longhorn beetle, but the avoidance buffer zone is not adequate. The USFWS guidelines require a 100-foot buffer and any encroachment within the buffer requires consultation with the USFWS. Where encroachment is approved fencing would be necessary at a 20-foot setback from the shrub's drip line." • Project proponents have consulted with the USFWS and CDFG on a tour of the Island and with U.S. Army Corps of Engineers and construction within 100 feet of the shrub's drip line will be done according to USFWS and CDFG conditions. As stated in the Initial Study, if construction occurs within twenty feet of an elderberry shrub, a fence shall be installed at least 20 feet from the driplines of the elderberry shrubs before any ground-disturbing activity occurs. USFWS and CDFG have both reviewed the Initial Study and approved the project with conditions that will be monitored via a mitigation monitoring program. "The project would require removal of riparian and wetland habitat but does not provide the extent of habitat removal. What is the extent of temporary and permanent impacts to riparian and wetland habitats for construction the ADA accessible ramps and all of the boardwalks. The project proposes to compensate such losses but does not provide how much and where habitat mitigation will be implemented and does