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<br />. .- <br /> <br />and enhance such wetlands are best pursued under the "on-farm" program of the NRCS <br />(formerly the Soil Conservation Service). Consistent with our Draft BA comment on page <br />16, paragraph 1, we would place high priority in evaluating proposals initiated by a <br />landowner to use existing or potential wetlands under their control for mitigation purposes. <br />However, proposed areas could not contribute significant amounts of salt loading to the river <br />system, nor create problems with selenium loading. <br /> <br />Comment 19: "The concept of replacing wetlands with uplands habitat requires further <br />explanation and justification, especially in view of the "no net loss" concept for wetland <br />mitigation and the need to retain wetland function with the area served." (Clark) <br /> <br />Response 19: A section in Chapter 3 on the habitat replacement program discuss many <br />factors considered by the study team, considering both hydrologic and biologic functions of <br />impacted wetlands. Replacement along the river corridor is desired because riparian habitat <br />has been shown to have higher value to wildlife, is natural to the area, has high aesthetic and <br />recreation values, and would be consistent with solving water quality problems. The current <br />program does not propose replacing wetland with upland habitat, it emphasizes restoring <br />natural communities and converting upland to wetland habitat. The goal is to acquire a <br />sufficient resource base to replace lost values; upland areas will be included in the <br />acquisitions and would be managed to maximize wildlife habitat values. <br /> <br />Comment 20: "The explanation of why mitigative habitat development and wetland <br />provision is to occur some distance from the site of loss should identify any specific wetland <br />functions other than habitat to be lost and not mitigated in the immediate area." (Clark) <br /> <br />Response 20: The discussion of wetland impacts identifies that hydrologic functions for the <br />seepage-dependent wetlands were evaluated and found to be very low. Hydrologic functions <br />of replacement lands within the floodplain of the river will be much higher. <br /> <br />Comment 21: "Specific goals for [wildlife] land acquisition should be identified... establish <br />procedure whereby Reclamation and the Service can monitor whether habitat replacement is <br />concurrent. (FWS) <br /> <br />Response 21: The EA identifies the goal of the program is to concurrently replace lost <br />habitat values. Guidelines listed as "Environmental Commitments" are intended to clarify <br />monitoring responsibilities. Measuring our effectiveness in avoiding, minimizing, and <br />mitigating wetlandfhabitat impacts of the project will be a long-term and coordinated effort <br />with the FWS and any other interested parties. This includes efforts to determine the value <br />and potential of any given parcel prior to acquisition, and plan for development and <br />management. Monitoring actions need to focus on measuring our effectiveness in meeting <br />replacement goals. Results should help direct future activities. Monitoring needs to begin <br />with a baseline inventoryfevaluation, using agreed-upon procedures, of existing habitat types <br />and wildlife use. Follow-up evaluations would detect changes in terms of size, vegetative <br /> <br />36 <br />