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'" ,'- t . . . 29 implementing the Price-San Rafael salinity control project. A primary objective of mitigation for wetland losses should be one-far-one, in-kind replacement of values lost. Out-of-kind mitigations are acceptable only when in-kind options are impractical such as in this project. Reclamation has informally committed to mitigating the 230 acres of riparian/wetlands that would be lost due to their portion of the project. No commitment to compensate for wetland losses has been forwarded from the SCS - ASCS - landowner project participants at this time. The Colorado River Basin Salinity Control Act, as amended (P.L. 93-320) and its implementation by the Department of Agriculture provide for voluntary replacement of "fish and wildlife values foregone." However, the Fish and Wildlife Service cannot credit mitigation measures fnr wildlife habitat losses without a commitment or guarantee that they will be completed. Therefore, it is the Service position that wildlife habitat losses associated with the on-farm implementation of this project are unmitigated losses. The biological opinion included as Appendix B to this report addresses impacts to the endangered Colorado squawfish, bony tail chub, humpback chub and razorback sucker. Compliance with requirements of the Endangered Species Act is accomplished through that document. RECOMMENDATIONS In order to partially offset wetland losses we propose that the project participants purchase the floodplain lands of Cottonwood, Ferron, and Huntington Creeks from Highway U-lO to the San Rafael River and the flood plains of the San Rafael River downstream to North Salt Wash in Emery County in fee title. In Carbon County we recommend purchasing the flood plains in fee title from Willow Creek downstream to Soldier Creek. The stream miles, acreage and present land ownership are displayed in Table XV. Water, water distribution systems, access roads and fences should also be provided by project participants to facilitate management. Presently the riparian and upland habitat in the proposed mitigation lands are severely overgrazed; however, with management and control these habitats could be improved. In the proposed area, wetlands can be improved where they exist, or created, by water management along these streams. Salt pick-up should be negligible because wetland development would be in the streamside alluvium where salts have been already leached out. This would not conflict with project purposes. It should be pointed out that the proposed out-of-kind mitigation would not reduce (replace) project caused wetland losses. Only newly developed wetlands from non-wetland habitats would do that; however, some wildlife values such as safe pheasant nesting, brooding and winter cover and deer hiding cover would in part be recovered in this out-of-kind mitigation. A deficit of 6,926 acres of wetland/riparian habitat would remain, as well as the loss of habitat needed by white-faced ibis, long-billed curlew, northern barrier and other wildlife species previously described. Public use opportunity woulq ba c 9 increased by the out-of-kind mitigation. ~Uvo.