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<br />. <br /> <br />9. WHAT TYPE OF ADDITIONAL "BASIN-WIDE" MITIGATION IS <br />CONTEMPLATED? <br /> <br />The draft Biological Opinions recently released by <br />FWS call for additional monies to fund basin-wide <br />mitigation above and beyond the payment assessed <br />under the "l-lindy Gap" formula. Several fundamental <br />problems arise because of this approach, including: <br /> <br />a. The mitigation prop?sal is intended to <br />off-set impacts caused by current water <br />users and has no causal relationship to the <br />projects undergoing consultation. <br /> <br />b. The fifteen mile stretch of river does not <br />appear to be a technically sound choice: <br /> <br />c. The mitigation proposals are "moving <br />targets" continually undergoing revision, <br />reinterpretation, recision, reinstigation, <br />and so on. <br /> <br />These identified issues are discussed below: <br /> <br />a. Instead of pursuing mitigation measures <br />from existing project sponsors, FWS is <br /> <br />-22- <br />