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Ms. Mo Hatef 2March 16, 2007 The project description does not provide enough details to assess all potential impacts from the various phases. The project does not describe how the new docks and an ADA accessible ramp will be designed and the extent of impacts to the river bank. The design also needs to consider how any improvements to the river bank would sustain periodic flooding and river bank erosion. The project proposes several restrooms but does not provide type of restrooms being proposed, source of water, and how the sewer would be treated. There is insufficient information on the caretaker quarters. Will the quarters be a permanent or seasonal residence? Will there be water and sewer service to these quarters? The Department of Public Works will require all new structures be constructed above the 100-year flood elevation, but the project does not specify how all the proposed structures, e.g., conference center, caretaker quarters, shop, and restrooms, will satisfy this requirement. Will all proposed buildings be raised structures or will exported fill or on-site graded material be used to elevate structure foundations? The proposed project requires grading but does not provide type of equipment and vehicles that would be used, equipment access and staging areas, temporary construction impacts, erosion control measures, etc. All of these types of improvements and methods of construction need to be considered in the impact analyses. 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 dripline. 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 constructing 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 not provide any measures to ensure that the mitigation is successful and fully compensates the losses. The cultural resources section in the Initial Study concludes that no resources were located within the area, but Figure 4 of the Biological Resources Report and Evaluation (Jones and Stokes, February 2007) has a mapped archeological site. This mapped resource needs verification/clarification. Based on the environmental review and the inadequacies of the Initial Study, it is recommended that a more detailed project description with all potential impacts from all construction and operation activities be fully assessed.