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O!1" t'O? u.J......O::)..... Wetland Mitigation A- 3 aerial and ground-based monitoring. This will include monitoring for new, unanticipated impacts, as well as the success of indirect mitigation work. The first three components of the plan are described in Section 4.F of the 404 Application, Section XI of the Final Report - Uncompahgre River Bank Stabilization Study, and Chapter 2 of the SEIR. Channel stability is discussed in a Channel Monitoring Plan, included as a separate appendix to the SEIR. The current document contains details of proposed plans to address the third and fifth items: The Wetland Mitigation Site, and mitigation for indirect impacts on wetlands and riparian resources. A.2.2 Goals PElS and subsequent studies have indicated that the project will cause a net benefit to Uncompahgre system wetlands. The goal of our monitoring plan is to observe and record changes over time, and ultimately ensure that, at minimum, the project does not cause a net loss of wetlands. If a net adverse impact is identified, then the Sponsors have agreed to mitigate such additional losses. Monitoring should provide sufficient detail that functional losses can be identified, and mitigation be modified or implemented that replaces thOse lost functions. These goals shall extend to woody/riparian vegetation, in addition to wetlands. A.2.3 Requirements The PElS sets the basic framework for wetlands monitoring: "Aerial photography, supported by ground-level inspection, would ... be used to document unanticipated changes to wetlands that could occur due to project-related scour or erosion. If a net loss of wetlands is caused by project operation beyond that estimated in this PElS, the Sponsors would be required to mitigate the loss through replacement or enhancement pursuant to Federal regulations and further consultation with Reclamation, COE and EPA." PElS at p. 42. The Record of Decision authorizing the project elaborates on this obligation: "A detailed monitoring plan will be developed by the Sponsors and will require approval from Reclamation, in consultation with the COE and EP A, prior to initiation of construction. This will develop the baseline conditions against which system stability will be measured in the future. The inventory will include the terrestrial environment associated with the river as well as the aquatic community. Channel stability analyses will be conducted based on methodologies approved by Reclamation in consultation with COE and EPA. Wetland and riparian resources will be delineated. The habitat values will be documented with Habitat Evaluation Procedures developed by the FWS or by other approved technologies. The monitoring, to reassess AS Lateral Hydropower Project JUlY 2000 ,', '. j ,1 ;i "",,;,,-,,;, ", ~Jii