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Valley Elderberry Longhorn Beetle(VELB). Initial surveys detected several elderberry <br /> shrubs scattered within the upland habitats of the project. Due to the season of the survey <br /> (winter),elderberry shrubs were not readily identifiable. It is likely that more elderberry <br /> shrubs area present within the project area. Avoidance of impacts to elderberry shrubs <br /> often requires construction buffers as great as 100 feet around each shrub. Unavoidable <br /> impacts to elderberries may require shrub transplant and compensatory plantings of <br /> elderberries and associated plant species. 'These mitigation measures are based upon the <br /> VELB Conservation Guidelines (U.S. Fish and Wildlife Service 1999). Construction <br /> buffers for the protection of elderberry shrubs vary depending upon the nature and scope <br /> of the project. Preparation of a Biological Assessment in consultation with the U.S. Fish <br /> and Wildlife Service (USFWS) would be necessary to determine the appropriate <br /> minimization, avoidance and compensatory mitigation measures for this project. <br /> The results of these surveys and analysis of biological constraints were conducted to the <br /> level necessary for conceptual project planning. These surveys were not intended to be <br /> conducted according to agency"protocol' levels. Consultation with USFWS and CDFG <br /> would likely require the preparation of a formal Biological Assessment, including a <br /> detailed project description, a quantitative analysis of project impacts to special status <br /> species habitat, and a detailed description of proposed mitigation,minimization and <br /> avoidance measures. <br /> Please contact me if you have any questions or require additional information. <br /> Sincerely, <br /> Bill Roper <br /> Associate Biologist <br />