Mitigation recommendations contained in this report are based on the Service's Mitigation Policy (Federal Register 46:15, January 23, 1981), which provides guidance for establishing appropriate mitigation for projects under our purview. In addition, the Service has a Regional policy that establishes a goal of no net loss of wetland acreage or value, whichever is greater.

Under the Service's Mitigation Policy, resources are divided into four resource categories to ensure that recommended mitigation is consistent with fish and wildlife habitat values effected. How a proposed action affects selected (evaluation) species occupying these habitats is one element of determining what mitigation the Service will seek for the project.

The categories cover a range of habitat values from those considered to be unique and irreplaceable to those believed to be much more common and of relatively lesser value to fish and wildlife. Each of the four resource categories has a criteria with specific mitigation goals.

Resource category criteria are:

1. areas of high value for the evaluation species and are unique and irreplaceable;
2. areas of high value for the evaluation species which are scarce or becoming scarce regionally
3. areas of high to medium value for the evaluation species which are relatively abundant; and
4. areas with medium to low value for the evaluation species.

The respective resource category mitigation goals are:

1. no loss of existing habitat value;
2. no net loss of in-kind habitat value;
3. no net loss of habitat value while minimizing loss of in-kind habitat value; and
4. minimize loss of habitat value.

The Council on Environmental Quality regulations for implementing the National Environmental Policy Act (NEPA)define mitigation to include:

1. avoiding the impact;
2. minimizing the impact;
3. rectifying the impact;
4. reducing or eliminating the impact over time; and
5. compensating for the impact.

The Service's Mitigation Policy uses this same definition of mitigation and considers the specific elements to represent the desirable sequence of steps in the mitigation planning process. Accordingly, we maintain that the best way to mitigate for the adverse biological impacts is to avoid them whenever possible.

1. unique and irreplaceable areas (Shaded Riverine Aquatic) Putah Creek

2. areas scarce or becoming scarce regionally (Wetland) Pescadero Marsh