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particularly for recreational users for the park and river, users of the local transportation system and local residents" (EA p. 83). Biological Impacts There are direct and indirect impacts that are likely to occur to vegetation and wildlife as a result of construction activities. For example, the EA describes that riparian vegetation removal will be necessary within the project area. The clearing could extend up to but no more than "300 feet on either side of the proposed bridge work" (EA, p. 39). "For terrestrial wildlife, temporary effects would occur from minor temporary fragmentation of habitat, habitat alteration, and disruption of migration corridors. Construction activities would temporarily displace species and may potentially kill some individuals that are not able to move out of the area. Dust from demolition and construction activities could also affect habitat." (EA, p.39). In particular, it is anticipated that bird nesting in the area will be disrupted or discouraged by the project forcing several different species of birds to seek alternative nesting areas. This is particularly problematic for grassland ground nesting birds which have limited available nesting habitat in the area already. "The project also has the potential to spread invasive weeds and grasses through translocation of plants and/or seeds from the project site to other project area on construction equipment or vehicles. In addition, disturbance associated with the project and vehicle and pedestrian use of the area may aid in the dispersion of invasive species to areas of roadway construction" (EA, p.39). This potential impact is particularly worrisome in regards to Brachypodium sylvaticum (false brome), which is an extremely invasive weed that we have been attempting to eradicate from the park. The project area is currently a source of propagules for this species and it will be difficult if not impossible to control populations within the project area during construction. This will result in costly and continuous efforts to contain this species to the project area and prevent its expansion during the project construction period. Eradication prior to the project is not likely due to the extent of the population and existing well established seed bank along with the fact that the population extends into the Eastgate Woodland side as well as the south banks of the Willamette River. Summary of Indirect Impacts By considering all the indirect impacts described above (most of which are described in the Environmental Assessment for the project), we have attempted to calculate an indirect impact area that should be mitigated by ODOT according to the provisions in section 6(f) of the Land and Water Conservation Fund Act. As described above, these impacts are significant and require mitigation under Section 6(f) of LWCF. We have attempted to show the areas we believe to have substantial indirect impacts on the attached map, which identifies 39.23 acres of indirect impacts in the Whilamut Natural Area. When the acreage of direct impact (5.43) is added to the area of indirect impact (39.23), the total impacted area we believe is suitable for mitigation is 44.66 acres. Recommended Mitigation City staff has communicated with ODOT staff (including you, Tim Dodson, Gail Harbert, and Mike Spaeth) about lands that ODOT currently owns in Eugene that could potentially serve to mitigate the bridge replacement project as required by the Land and Water Conservation Fund Act. There are several parcels purchased for the West Eugene Parkway project in West Eugene that ODOT has deemed "surplus" (per Gail Harbert and Mike Spaeth) that could be transferred to the City as mitigation for the impacts noted above. After reviewing the options, -the City has identified two ODOT "file numbers" that are adjacent to one another and that wholly or in part would replace the values and uses that would be lost due to the I -5 Page 3