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Mr. Michael Jewell From: 11 Benefits to delta smelt will accrue from the purchase of 123 credits from a Service -approved conservation bank. The proposed habitat compensation will provide benefits commensurate with or better than the permanent losses of habitat, either due to conversion, or due to partial loss of habitat function from gate operation. Those benefits will be accrued throughout the project life beginning with credit purchase before or concurrent with construction of the closure structures, well before the majority of anticipated effects due to the increased frequency of gate operation with sea level rise. For this reason, we believe that the 123 credits proposed are appropriate compensation for the effects on the 233 acres of tidal open water and included SWH. These lands and waters in the purchased credits will contribute to the smelt's recovery by securing habitat that is protected from development and other threat factors. To: Benefits to delta smelt will accrue from the purchase of 26.56 credits from a Service -approved conservation bank (7.46 credits for Smith Canal gate; 19.1 credits for FourteenMile Slough gate). The proposed habitat compensation will provide benefits commensurate with or better than the permanent losses of habitat, either due to conversion, or due to partial loss of habitat function from gate operation, Those benefits will be accrued throughout the project life beginning with credit purchase before or concurrent with construction of the closure structures, well before the majority of anticipated effects due to the increased frequency of gate operation with sea level rise. The proposed water hyacinth control will provide limited benefits to delta smelt within a portion of South Canal only. This control is expected to be done during the March -December hyacinth growing season, which overlaps part of the spawning season of smelt. Water hyacinth can shield predators of smelt, and it can also result in diminished water quality due to increased organic matter and reduced light. These factors could affect smelt and will be partially ameliorated by the control measure. For these reasons, we believe that the 26.56 credits proposed are appropriate compensation for the effects on the 238 acres of tidal open water and included SWH. These lands and waters in the purchased credits will contribute to the smelt's recovery by securing habitat that is protected from development and other threat factors. 10. CHANGE the following in Effects of the Action, Delta Smelt Critical Habitat, p. 27, second and third paragraphs, as follows: From: Implementation of the proposed project will affect PCE #1 Physical Habitat as described under the environmental baseline section above. Construction of the gate structures will result in the permanent loss of shallow water habitat of about I acre and temporarily affect 3 acres. These effects will be offset through the purchase of 3 credits at a delta smelt conservation bank. Operation of the gate structures will result in partial effects primarily on 233 acres of habitat east of the closure structures (Effects of the Action - Delta Smelt). There would also be some increment of effect of gate structure operation on tidal functions and values in connected