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3 involving dredge and fill activities in "waters of the United States", of which wetlands and some riparian habitats are subcategories. Since portions of this proposal may ultimately require a Corps permit, the Service will subsequently be involved under the Coordination Act. Therefore, if you have not done so already, we suggest that you or your representative consult the Corps regarding onsite wetlands and related habitats that may fall under their Jurisdiction, and include this information in the draft document. When reviewing Corps public notices, the Service generally does not object to projects meeting the following criteria: 1. They are ecologically sound; 2. The least environmentally damaging reasonable alternative is selected; 3. Every reasonable effort is made to avoid or minimize damage or loss of fish and wildlife resources and uses; 4. All important recommended means and measures have been adopted, with guaranteed implementation to satisfactorily compensate for unavoidable damage or loss consistent with the appropriate mitigation goal; and 5. For wetlands and shallow water habitats, the proposed activity is clearly water dependent and there is a' demonstrated public need. The Service may recommend the "no project" alternative for those projects which do not meet all of the above criteria, and where there is likely to be a significant fish and wildlife resource loss. When projects impacting waterways or wetlands are deemed acceptable to the Service, we recommend full mitigation for any impacts to fish and wildlife. The Council of Environmental Quality regulations for implementing the National Environmental Policy Act define mitigation to include: 1) avoiding the impact; 2) minimizing the impact; 3) rectifying the impact; 4) reducing or eliminating the impact over time; and 5) compensating for impacts. The Service supports and adopts this definition of mitigation and considers the specific elements to represent the desirable sequence of steps in the mitigation planning process. Accordingly, we maintain that the best way to mitigate for adverse biological impacts is to avoid them altogether. The document should describe all measures proposed to avoid, minimize, or compensate for impacts to fish and wildlife and their habitats. The measures should be presented in as much detail as possible to allow us to evaluate their probable effectiveness. Because of their very high value to migratory birds, and their ever-increasing scarcity in California, our mitigation goal for wetlands (including riparian and riverine wetlands) is no net loss of in-kind habitat value or acreage (whichever is greater) . For unavoidable impacts, to determine the mitigation credits available for a given mitigation project, we evaluate what conditions would exist on the mitigation site in the future in the absence of the mitigation actions, and compare those conditions to the conditions we would expect to develop on the site with implementation of the mitigation plan. Mitigation habitat should be equal to or exceed the quality of the habitat to be affected by the project. Baseline information would need to be gathered at the impact site to be able to quantify this goal in terms of plant species diversity, shrub and tree canopy cover, stems/acre, tree height, etc. The C-41