20140957 Ver 2_USFWS Biological Opinion_20171016

Burdette, Jennifer a
From: Spencer Trichell <[e-mail]>
Sent: Monday, October 16, 2017 4:57 PM
To: 'Dailey, Samantha J CIV USARMY CESAW (US)'; Gibson, Steven W CIV USARMY CENAO
(US); Greer, Emily C CIV USARMY CESAW (US); 'Kube, Peter R CIV USARMY CENAO
(US)'; Shaffer, Joshua D CIV USARMY CELRP (US); Adam Fannin
([e-mail]); Gibby, Jean B CIV USARMY CESAW (US)
Cc: '[e-mail]'; [e-mail]; Burdette, Jennifer a;
Higgins, Karen; Richard B Gangle; 'Wade Hammer'; 'Linda Morrison'; 'Owen, Randy
(M RC)'
Subject: [External] Biological Opinion - Atlantic Coast Pipeline/Supply Header Project
Attachments: 20171016_letter_Service to FERC -ACP SHP biological opinion SIGNED.PDF
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
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All, USFWS has completed the biological opinion for ACP and SHP. A copy is attached for your
records.
Regards,
Spencer
From: Troy Andersen [mailto:[e-mail]]
Sent: Monday, October 16, 2017 4:45 PM
To: [e-mail]
Cc: [e-mail]; Cindy Schulz; [e-mail]; Kevin Bowman; John Schmidt; Tom
Augspurger; Lora Lattanzi; [e-mail]; Adams, Jennifer - FS; [e-mail]; Tignor, Keith
(VDACS); Ewing, Amy (DGIF); Hypes, Rene (DCR); Brown, Clifford L; Spencer Trichell (Services - 6); Thomas Wittig;
Bryan Kluever; [e-mail]
Subject: [External] Biological Opinion - Atlantic Coast Pipeline/Supply Header Project
Mr. Swearingen:
Subject document is attached. Let me know if you have any questions.
V/R
Troy
------------------------------------------
Endangered Species/Conservation Planning Assistance Supervisor
USFWS - Virginia Field Office
Phone: [phone]
Visit us at: http://www.fws.gov/northeast/virginiafield/

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EUT OF F"."w' . .'
SERVICE
tip United States Department of the Interior
y O
7 �
_ FISH AND WILDLIFE SERVICE
�49CH
Virginia Field Office
6669 Short Lane
Gloucester, VA 23061
October 16, 2017
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room IA
Washington, D.C. 20426
Attn: David Swearingen, Branch Chief
Re: Atlantic Coast Pipeline, LLC,
Atlantic Coast Pipeline; Dominion
Energy Transmission, Inc., Supply
Header Project; Docket Numbers
CP 15-554-000, CP 15-554-001,
CP 15-555-000; Project #05E2VA00-
2016-F-1219, 905E2WV00-2014-F-
0832, 905E2PA00-2016-TA-0960,
904EN2000-2017-1-073 8
Dear Ms. Bose:
This document transmits the U.S. Fish and Wildlife Service's (Service) biological opinion
(Opinion) based on our review of the referenced project and its effects on the federally listed
species in Table 1 in accordance with Section 7 of the Endangered Species Act (16 U.S.C. 1531-
1544, 87 Stat. 884), as amended (ESA).
Table 1. Species considered in this Opinion.
Species Common Name
Species Scientific
ESA Status
State
FERC Action
Name
Small whorled pogonia
Isotria medeoloides
threatened
WV
Atlantic Coast Pipeline
(SWP)
(ACP)
Running Buffalo clover
Trifolium
endangered
WV
ACP
(RBC)
stoloni Brum
Roanoke to erch (RLP)
Percina rex
endangered
VA
ACP
Clubshell
Pleurobema clava
endangered
WV
ACP
Rusty patched bumble bee
Bombus affinis
endangered
VA
ACP
(RPBB)
Madison Cave isopod (MCI)
Antrolana lira
threatened
VA
ACP
Indiana bat (lbat)
Myotis sodalis
endangered
VA, WV
ACP (VA, WV);
Supply Header Project

(SHP) (WV)
Northern long-eared bat Myotis septentrionalis threatened WV ACP
(NLEB)
Your July 21, 2017 request for formal consultation was received on July 21, 2017.
This Opinion is based on information provided in the July 2017 Final Environmental Impact
Statement (FEIS) (Federal Energy Regulatory Commission [FERC] 2017), telephone
conversations, field surveys/investigations, and other sources of information. The consultation
history is located in Appendix A. Because the project traverses 4 states under the geographic
jurisdiction of the 4 Service Field Offices in Raleigh, North Carolina (NC), State College,
Pennsylvania (PA), Gloucester, Virginia (VA), and Elkins, West Virginia (WV), each maintain
their geographic portion of the administrative record in their respective Field Office.
FERC, under Section 7 of the Natural Gas Act, is required to consider, as part of its decision to
authorize interstate gas facilities, all factors bearing on the public convenience and necessity.
This includes any "nonjurisdictional" facilities that do not come under the jurisdiction of FERC
but may be integral to the project objective. Nonjurisdictional facilities that lie outside the
footprint of jurisdictional facilities were not included in the analysis of impacts to federally listed
species provided to the Service by FERC. Therefore, any effects to and take of listed species
associated with nonjurisdictional facilities may not be covered in this Opinion. The
nonjurisdictional facilities associated with this project are summarized in table 2.8-1 of the FEIS
and further discussed in Section 4.13 (FERC 2017).
BIOLOGICAL OPINION
DESCRIPTION OF PROPOSED ACTION
As defined in the ESA Section 7 regulations (50 CFR 402.02), "action" means "all activities or
programs of any kind authorized, funded, or carried out, in whole or in part, by federal agencies
in the United States or upon the high seas." The "action area" is defined as "all areas to be
affected directly or indirectly by the federal action and not merely the immediate area involved
in the action."
Atlantic Coast Pipeline, LLC (Atlantic) and Dominion Energy Transmission, Inc. (DETI) have
requested the FERC authorize the construction and operation of a total of 642.0 miles of natural
gas transmission pipeline and associated facilities in PA, WV, VA, and NC (Figure 1).
The following is a summary of the proposed action and a detailed description can be found in
FERC's ACP and SHP FEIS, July 2017 (FERC 2017).
Proposed Facilities — ACP will be located in WV, VA, and NC (Figure 2). As proposed, this
project includes 2 mainline pipeline facilities and 3 pipeline laterals consisting of 519.7 miles of
new 42- and 36 -inch (in) diameter natural gas pipeline and 84.8 miles of 20- and 16 -in diameter
natural gas pipeline. Additional components include 3 new compressor stations, 9 metering and
regulation (M&R) stations, 41 valves, and 8 sets of pig launchers/receivers. ACP will deliver up
to 1.5 billion cubic feet per day (Bcf/d) to customers in WV, VA, and NC.
2

SHP will be located in PA and WV (Figure 3). As proposed, this project includes 37.5 miles of
new 30 -in diameter natural gas pipeline, modifications to 4 existing compressor stations, 1 M&R
station, 6 valves, and 2 sets of pig launchers/receivers. DETI also proposes to abandon 2 existing
gathering compressor units and build 2 new ones at an existing compression station. SHP will
deliver up to 1.5 Bcf/d to various customers including Atlantic.
A brief description of the 6 types of above -ground facilities proposed to be installed is included
below. Additional details describing the facilities are included in Section 2.1.2 of the FEIS
(FERC 2017).
• Compressor stations — utilize engines to maintain pressure within the pipeline to deliver
the contracted volumes of natural gas to specific points at specific pressures. Designed to
attenuate noise and allow for operation and maintenance (O&M) activities.
• M&R stations — measure the volume of gas removed from or added to a pipeline system
at receipt and delivery interconnects. Consist of a small graveled area with a small
building(s) that enclose the measurement equipment.
• Valves — consist of a small system of aboveground and underground piping and valves
that control the flow of gas within the pipeline and can also be used to vacate, or blow-
off, the gas within a pipeline segment, if necessary.
• Pig launchers and receivers — facilities where internal pipeline cleaning and inspection
tools, referred to as "pigs", can be inserted or retrieved from the pipeline. Generally
consist of a segment of aboveground piping, 20-30 feet (ft) in length, which ties into the
mainline pipeline facilities below the ground surface.
• Cathodic protection systems — systems that help prevent corrosion of underground
pipeline facilities. Typically include a small, aboveground transformer -rectifier unit and
an associated anode ground bed located underground.
• Communication towers and antennas — provide wireless communications necessary to
operate monitoring and control systems.
3

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Figure 3. SHP project overview.

Land Requirements — Collectively, construction of ACP and SHP will disturb 11,775.9 acres of
land. Following construction, 4,929.6 acres will be maintained for O&M of the project facilities.
The remaining 6,846.3 acres of land disturbed by ACP and SHP will be restored and allowed to
revert to former use. A brief description of the 4 types of land requirements is included below.
Additional details describing the land requirements are included in Section 2.2 of the FEIS
(FERC 2017).
• Pipeline right-of-way (ROW) — Atlantic and DETI will use a variety of ROW
configurations to construct and operate the pipeline facilities. Section 2.2.1 and table
2.1.1-1 of the FEIS provide specific details (FERC 2017). The construction ROW
consists of 2 portions, the temporary construction ROW and the permanent ROW.
Temporary construction ROW will be restored or will revert to former use while
permanent ROW will be maintained and utilized for O&M purposes.
• Additional temporary workspace (ATWS) — additional space required in particular areas
necessary to complete construction of the pipeline. Examples include, but are not limited
to, certain pipe bend locations, truck turnarounds or equipment passing lanes, and
construction constraint areas that require special construction techniques such as
horizontal directional drill (HDD) entry and exit locations.
• Pipe/contractor yards (CY) and staging areas — used for equipment, pipe sections, and
construction material and supply storage, as well as temporary field offices, parking, and
pipe preparation and preassembly staging areas.
• Access roads — necessary to gain access to the construction ROW and aboveground
facilities. Many of the proposed access roads are existing roads that can accommodate
construction traffic without modification.
Construction Procedures — Atlantic and DETI will design, construct, operate, and maintain their
respective pipelines and facilities in accordance with U.S. DOT regulations under 49 CFR 192
and other applicable federal and state/commonwealth requirements. Atlantic and DETI will
comply with siting and maintenance requirements under 18 CFR 380.15 and implement various
forms of mitigations as defined in 40 CFR 1508.20. They will adopt FERC's general
construction, restoration, and operational mitigation measures as outlined in FERC's Upland
Erosion Control Revegetation and Maintenance Plan (FERC 2013a) and Wetland and Waterbody
Construction and Mitigation Procedures (FERC 2013b). Specific mitigation plans for National
Forest lands have been determined in consultation with the U.S. Forest Service (USFS).
Construction plans for both projects include some modifications to FERC's procedures and more
details can be found in FEIS section 2.3.1.1 (FERC 2017).
A brief description of the 9 types of typical construction procedures associated with the project is
included below. Additional details describing the typical construction procedures are included in
Section 2.3.2 of the FEIS (FERC 2017). Construction at any single point along the pipelines
could last from 6 to 12 weeks or longer. The complete proposed construction schedule can be
found in FEIS section 2.4 and FEIS Table 2.4-1 (FERC 2017).
• Surveying and staking — marking of the limits of construction ROW, centerline, ATWS,
other approved work areas, and environmentally sensitive areas using temporary flagging
or tape.
• Clearing and grading — removal of trees, shrubs, brush, roots, and large rocks from the
construction work area and leveling of the construction ROW to allow for operation of
7

construction equipment.
• Trenching — digging of pipeline trench by removal of soil and rock by rotary trenching
machine, track -mounted excavator, or similar equipment. Tractor -mounted mechanical
rippers, hydraulic hoe rams, rock trenchers, or blasting may be used to fracture rock prior
to removal.
• Rock removal and blasting — where bedrock cannot be fractured by mechanical
equipment, blasting will be required following a project -specific Blasting Plan
(http://elibrar f�gov/idmws/common/OpenNat.asp?fileID=14395436). Typical
blasting methods include mass rock blasting, production blasting, and trench blasting.
• Pipe stringing, bending, welding, and coating — transportation of pipe segments to CY or
work areas and bending of pipes to fit contours of the trench. Pipeline segments are
aligned and welded together. Welds are inspected and coated with epoxy or other
protective coating.
• Lowering -in and backfilling — lowering of pipe using side -boom tractors and backfill of
trench with suitable excavated material. In rocky areas, protective materials may be
placed in trench to protect pipe. Trench breakers (stacked sandbags or polyurethane
foam) will be placed in trench prior to backfilling to prevent subsurface water movement
along pipeline.
• Internal pipe cleaning and hydrostatic testing — cleaning of pipe to remove dirt, water, or
other debris and hydrostatic testing to ensure that the system is capable of withstanding
the operating pressure for which is it designed.
• Commissioning — verifying that equipment has been properly installed and working,
verifying that controls and communication systems are functioning, and confirming that
the pipeline is ready for service. As a final step, the pipeline will be purged of air and
loaded with natural gas.
• Cleanup and restoration — grading and restoration of all work areas to pre -construction
contours and natural drainage patterns as closely as possible.
Specialized construction methods for crossing under sensitive resources such as agricultural
lands, roads, foreign utilities, residential areas, waterbodies, wetlands, and other sensitive
environmental resources will be employed. A brief description of the specialized construction
methods is included below. Additional details describing the specialized construction methods
are included in Section 2.3.3 of the FEIS (FERC 2017).
e Waterbody crossings —
o Wet open -cut construction method — trench excavation, pipeline installation, and
backfilling in a waterbody without controlling or diverting streamflow.
o Flume construction method — diversion of streamflow through flume pipes and
placement of dam structures to exclude water flow from trench area.
o Dam and pump construction method — diversion of stream flow using pumps and
hoses and placement of dam structures to exclude water flow from trench area.
o Cofferdam method — installation of a temporary diversion structure from 1 bank
of the waterbody to the approximate midpoint of the waterbody crossing to isolate
that section of the stream from the rest of the waterbody, creating discrete dry
sections around which water flows unimpeded.
e Trenchless methods —
o Conventional bore method — bore pits are excavated on both sides of the sensitive

resource, boring machines are used to excavate a tunnel between the bore pits,
and a pre -fabricated pipe is pushed through the borehole without affecting the
surface of the resource.
o HDD construction method — drilling of a hole under a sensitive resource and
installation of a pre -fabricated pipe segment through the hole. A pilot hole is first
drilled and then enlarged using several passes of successively larger reaming
tools. Drilling mud composed of 65% water and 30% bentonite clay is required to
lubricate the drills.
o Direct pipe method — excavation and hole boring is performed with a navigable
microtunneling machine and a cutterhead while simultaneously installing the pipe
using a pipe thruster.
• Wetland crossings — construction ROW through wetlands are typically 75 ft wide with
ATWS located in upland areas a minimum of 50 ft from wetland edge, unless granted
site-specific approval for a reduced setback. Sediment barriers such as silt fence and
staked straw bales will be utilized during clearing and construction. The push-pull
technique, conventional bore, and HDD methods may be used to install pipes.
• Karst sensitive areas — crossing of karst sensitive areas will follow the project -specific
construction, restoration, and mitigation methods outlined in the Karst Mitigation Plan
included in Appendix I of the FEIS (FERC 2017).
• Steep slopes — temporary and permanent controls measures such as trench breakers,
trench plugs, silt fencing, erosion control matting, and hydro -mulching will be put in
place to minimize erosion and sedimentation. In steepest area, techniques such as
"winching" and two-tone construction methods may be employed.
• Residential construction — implement measures to minimize construction -related impacts
on all residences and other structures located within 50 ft of the construction ROW
following site-specific Residential Construction Plans included in Appendix J1 of the
FEIS (FERC 2017).
• Agricultural areas — a maximum 12 -in of topsoil in actively cultivated and rotated
croplands, pastures, and hayfields and in other areas at the specific request of the
landowners or land management agency will be segregated during construction and
replaced to the upper soil layer during backfill. Any disrupted irrigation and drainage
systems will be permanently repaired.
• Road, railroad, and trail crossings — railroads and roads where traffic cannot be detoured
will generally be crossed by boring beneath the road or railroad. Most gravel and dirt
roads, driveways, and roads in areas with a high water table, as well as most USFS
system trails, will be crossed by open -cut method, which will require temporary closure
of the road or trail and establishment of detours.
• Foreign utilities — buried utilities will be identified and flagged using One -Call systems
prior to ground -disturbing activities.
• Winter construction — specialized construction methods or procedures will be utilized to
protect resources during the winter season as described in the Winter Construction Plan
(htlp://elibrM.ferc. gov/idmws/common/OpenNat. asp?fileID=14475037).
Environmental Inspection, Compliance Monitoring, and Post -Approval Variances — Atlantic and
DETI have developed procedures for environmental inspection, compliance monitoring, and
post -approval variances. A brief description of the procedures is included below. Additional
E

details describing the procedures are included in Section 2.3.3 of the FEIS (FERC 2017).
• Coordination and Training — copies of all applicable environmental permits, construction
drawings, and specifications will be provided to construction contractors. Contractors
will attend an environmental training program tailored to the proposed projects and their
construction requirements.
• Environmental Inspection — trained environmental inspectors (EIs) will be employed to
ensure that construction complies with construction and mitigation procedures imposed
by FERC and other regulatory agencies. EIs will have the authority to stop activities that
violate conditions of the FERC certificate, other permits, or landowner requirements, and
have authority to order the appropriate corrective actions.
• FERC Compliance Monitoring — in additions to EIs, a third -party compliance monitoring
program will be funded to provide daily environmental monitoring services during
construction. Other federal, state/commonwealth, and local agencies may also monitor
the project to the extent determined necessary by the agency.
• USFS Compliance Monitoring — USFS will monitor implementation of ACP to assure
that the terms and conditions of the Special Use Permit are carried out during and after
construction.
• Post -Approval Variance Process — a "variance request" will be submitted to FERC in the
event that minor route realignment or other workspace refinements are required
subsequent to project approval. FERC will take the lead on evaluating the request and
coordinating with any appropriate land -managing agencies for approval or denial.
• Post -Construction Monitoring — follow-up inspections of all disturbed uplands areas will
be conducted, at a minimum after the first and second growing seasons to determine the
success of restoration, and inspections will continue monitoring areas until revegetation
thresholds are met, temporary erosion control devices are removed, and restoration
deemed complete.
Operation and Maintenance — ACP and SHP pipelines and aboveground facilities will be
operated and maintained in accordance with U.S. DOT regulations in 49 CFR 192, FERC's
guidance at 18 CFR 380.15, the USFS Special Use Permit, and the maintenance provisions of the
FERC Plan (https://www.ferc.gov/industries/gas/enviro/plan.pdf) and Procedures
(https://www.ferc.gov/industries/gas/enviro/procedures.pdf). A brief description of the O&M
details is included below. Additional details describing O&M are included in Section 2.6 of the
FEIS (FERC 2017).
• Pipeline Facility O&M — an O&M plan and an emergency plan will be established that
includes procedures to minimize the hazards in a natural gas pipeline emergency. Regular
patrols, inspection, and repair of the pipeline will be conducted.
• Aboveground Facility O&M — new and modified compressor stations will be operated
and maintained in accordance with Pipeline and Hazardous Materials Safety
Administration requirements and standard procedures. Standard operations at compressor
stations include such activities as the calibration, maintenance, and inspection of
equipment, as well as periodic checking of safety and emergency equipment and cathodic
protection systems.
Future Plans and Abandonment — ACP Foundation Shippers have a right to request an increase
in contracted capacity by participation in an Optional Expansion or Second Expansion. Any
10

future increase in capacity or expansion would require additional environmental review and
FERC authorization. If at some point in the future, any of the approved project facilities are
proposed to be abandoned, Atlantic and/or DETI would have to seek specific authorization from
FERC for that action and the public will have the opportunity to comments on the applicant's
abandonment proposal.
Conservation Measures — Conservation measures proposed as part of the action (measures that
will avoid, minimize, and mitigate effects of the proposed action on the species and/or benefit
the species as a whole) are referred to as avoidance and minimization measures (AMMs) in this
Opinion. AMMs are provided in the FEIS (FERC 2017) and discussed, as applicable, in
Appendix B.
Action Area
The action area is defined (50 CFR 402.02) as "all areas to be affected directly or indirectly by
the federal action and not merely the immediate area involved in the action." The Service has
determined that the action area for this project is all lands in PA, WV, VA, and NC affected
directly or indirectly by the project's components described in Description of Proposed Action.
STATUS OF THE SPECIES
Per the ESA Section 7 regulations (50 CFR 402.14(g)(2)), it is the Service's responsibility to
"evaluate the current status of the listed species or critical habitat."
To assess the current status of the species, it is helpful to understand the species' conservation
needs which are generally described in terms of reproduction, numbers, and distribution (RND).
The Service frequently characterizes RND for a given species via the conservation principles of
resiliency (ability of species/populations to withstand stochastic events — numbers, growth rates),
redundancy (ability of a species to withstand catastrophic events — number of populations and
their distribution), and representation (variation/ability of a species to adapt to changing
conditions) (collectively known as the three Rs).
Small whorled pogonia — As described in Service (2008) the SWP conservation needs include
"resolving data gaps and assessing the conservation potential for populations on private lands."
Currently, as a whole, the rangewide status of the species is stable (Service 2008). From 1985-
2007, population numbers in WV remained low but stable (Service 2008). The primary factors
influencing the status include risks posed by land development; however these activities are
diffuse across the species' range and do not constitute an acute threat to SWP survival and
recovery (Service 2008). For a more detailed account of the species description, life history,
population dynamics, threats, and conservation needs, refer to:
https://ecos.fws. og v/ecp0/profile/speciesProfile.action?spcode=Q1XL.
Running Buffalo clover — As described in Service (2011), the RBC conservation needs include
assessing "direct and indirect human impacts that lead to habitat loss, alteration, significant
degradation such as development, and the introduction of non-native invasive species."
Currently, as a whole, the rangewide status of the species is stable or improving. In WV,
11

populations are improving (Service 2011). The primary factors influencing the status include
risks posed by "habitat destruction, habitat succession, and invasive plant competition" (Service
2011). In WV, "invasive species such as multiflora rose (Rosa multiflora) and Japanese stiltgrass
(Microstegium vimineum), a lack of protection from heavy trail use, and shading are severe
threats to populations." Small population size and climate change continue to be threats as well
(Service 2011). For a more detailed account of the species description, life history, population
dynamics, threats, and conservation needs, refer to:
https://ecos.fws. og v/ecpO/profile/speciesProfile.action?spcode=Q2RE.
Roanoke logperch — As described in Service (2007), the RLP conservation needs include solving
data gaps that limit an accurate assessment of population abundance, maintaining the health and
vigor of present populations by addressing sediment loading at the watershed level and
preserving ecological processes, increasing connectivity of populations by identifying and
eliminating barriers, and preventing and reducing the risk of catastrophic extirpation from toxic
spills. Currently, as a whole, the rangewide status of the species is improving, although the
geographic range remains small. The populations in VA seem to be stable or increasing (Service
2007). The primary factors influencing the status include risks posed by large dams and
reservoirs, small dams and barriers, watershed urbanization, agricultural and silvicultural
activities, channelization, roads, toxic spills, riparian/woody debris loss, and water withdrawals
(Service 2007). For a more detailed account of the species description, life history, population
dynamics, threats, and conservation needs, refer to:
https://ecos.fws.gov/ecpO/profile/speciesProfile?spcode=E01 G.
Clubshell — As described in Service (2008), the clubshell conservation needs include assessing
habitat loss, susceptibility to land use changes, and reproductive success. Currently, as a whole,
the rangewide status of the species is declining. In the Kanawha River system of WV the species
appears to be stable (successfully reproducing). However, in the Monongahela River system of
WV, the species is in "severe decline" (Service 2008). The primary factors influencing the status
include risks posed by water quality degradation and alterations, instream activities, exploration
and extraction of coal, oil, and natural gas, even at a distance from clubshell populations, and
development near streams and adjacent uplands (Service 2008). For a more detailed account of
the species description, life history, population dynamics, threats, and conservation needs, refer
to: https://ecos.fws. og v/ecpO/profile/speciesProfile?spcode=FOLD.
Rusty_patched bumble bee — As described in Service (2016), the RPBB conservation needs
include assessing resiliency to environmental variation, perturbations affecting habitat size and
quality, and population size. Currently, as a whole, the rangewide status of the species is
declining (82 FR 3186-3209). The primary factors influencing the status include risks posed by
"pathogens, pesticides, habitat loss and degradation, small population dynamics, and climate
change" (82 FR 3186-3209). For a more detailed account of the species description, life history,
population dynamics, threats, and conservation needs, refer to:
htlps://ecos.fws.gov/ecpO/profile/speciesProfile?spcode=IOWI.
Madison Cave isopod — As described in Service (2011), the MCI conservation needs include
assessing "thermal and chemical pollution from urban development and agricultural runoff,
physical pollution, and human disturbance (cave vandalism and visitation)." Currently, as a
12

whole, the rangewide status of the species appears to be stable (Service 2011). The primary
factors influencing the status include risks posed by habitat degradation from altering streams,
isolation of populations from physical barriers, shifts in subterranean sediment associated with
development, and groundwater contamination (Service 2011). For a more detailed account of the
species description, life history, population dynamics, threats, and conservation needs, refer to:
hLtps://ecos.fws.gov/ecpO/profile/speciesProfile?spcode=KO08.
Indiana bat — As described in Service (2016), the That conservation needs include assessing and
offsetting adverse impacts to the species and promoting recovery. Currently, as a whole, the
rangewide status of the species is declining (Service 2016) and the degree of threat to the
continued existence of the species is high (Service 2009). The primary factors influencing the
status of the species include risks posed by White -Nose Syndrome (WNS), habitat loss and
degradation, forest fragmentation, winter disturbance, environmental contaminants, climate
change, and collisions with manmade objects (Service 2009, 2016). For a more detailed account
of the species description, life history, population dynamics, threats, and conservation needs,
refer to: https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=A000.
Northern long-eared bat — The NLEB conservation needs include protecting and reducing
disturbance of hibernacula, summer roosts, and the buffer zone known as "WNS zone" (81 FR
1900-1922). Currently, as a whole, the rangewide status of the species is declining (81 FR 1900-
1922). The primary factors influencing the status include risks posed by WNS, tree removal,
disturbance around roosts during the summer months, and disturbance at the entrance and
interior of hibernacula. "This includes the physical or other alteration of the hibernaculum's
entrance or environment when bats are not present if the result of the activity will impair
essential behavioral patterns" (81 FR 1900-1922). For a more detailed account of the species
description, life history, population dynamics, threats, and conservation needs, refer to:
htlps://ecos.fws.gov/ecpO/Trofile/speciesProfile?spcode=AOJE.
STATUS OF CRITICAL HABITAT
No critical habitat has been designated for SWP, RBC, RLP, clubshell, RPBB, MCI, or NLEB.
Critical habitat for Ibat has been designated at Hellhole Cave, Pendleton County, WV; however,
this action does not affect that area.
ENVIRONMENTAL BASELINE
Regulations implementing the ESA (50 CFR 402.02) define the environmental baseline as the
past and present impacts of all federal, state, or private actions and other human activities in the
action area. Also included in the environmental baseline are the anticipated and/or ongoing
impacts of all proposed federal projects in the action area that have undergone Section 7
consultation, and the impacts of state and private actions which are contemporaneous with the
consultation in progress.
Status of the Species within the Action Area
13

Small whorled pogonia — Two new SWP colonies were found within the action area during 2016
plant surveys (Allstar Ecology 2016a, 2016b; Vanasse Hangen Brustlin, Inc. [VHB] 2016a,
2016b, 2017; Environmental Resource Management [ERM] 2017). One colony is located in the
Seneca State Forest, WV (Seneca colony) and 1 colony is located in the Monongahela National
Forest (MNF), WV (MNF colony).
The Seneca colony in Pocahontas County, WV, is located 70 ft downslope from the construction
ROW (Allstar Ecology 2016a, 2016b; ERM 2017; VHB 2017). Ten stems were observed above
an alluvial bench on a hillside in an oak -pine forest. Three of the stems were flowering. This
colony is characterized by a relatively dense understory, larger light gaps, and a higher frequency
of coarse woody debris compared to the MNF colony. During a 2017 pre -construction survey, 24
stems were observed (VHB 2017). This colony has the potential to meet the definition of a self-
sustaining, viable population (i.e., geometric mean of 20 emergent stems, of which at least 25%
are flowering stems, over a 10 -year period) (Service 1992). The colony is approximately 550 ft
from the nearest trail and 1,000 ft from the nearest road. No invasive plants are present near this
colony, thus no invasive species control plan has been established by the WV Division of Natural
Resources (WVDNR) (C. Brown, WVDNR, email to J. Stanhope, Service, September 15, 2017).
The MNF colony in Pocahontas County, WV, is located approximately 221 ft downslope of the
construction ROW (Allstar Ecology 2016a, 2016b; ERM 2017; VHB 2017). Three stems were
observed mid -slope on a south -facing hillside dominated by an oak -hickory -heath community,
characterized by presence of dappled sunlight, low-density understory, and some coarse woody
debris. The colony is on a MNF parcel "landlocked" by private landowners and thus inaccessible
by the general public (K. Karriker, USFS, email to E. Stout, Service, August 11, 2017). The
USFS is not conducting invasive species control in this area, because, until recently, they did not
have invasive plant inventory data for that parcel (K. Karriker, USFS, email to J. Stanhope,
Service, September 26, 2017). Plant surveys identified invasive Japanese stiltgrass and Japanese
barberry (Berberis thunbergii) in the general vicinity.
For the Seneca colony, maintenance of existing roads by the WV Department of Transportation
and maintenance of trails and adjacent areas by WVDNR likely reduces suitability of SWP
habitat due to vegetation management, soil compaction, vehicle operation, foot traffic, and
chemical contamination. The close proximity of trails and roads to the Seneca colony provides
for easy public access to the colony and resulting foot traffic. Collection by orchid enthusiasts
and vandalism continues to be a threat for both Seneca and MNF colonies. SWP plants were
illegally removed from MNF in Randolph County, WV in 2016. Herbivory by white-tailed deer
(Odocoileus virginianus) or other mammals and invertebrates occurs throughout the range of
SWP (Service 1992). In 2017, 1 plant from the MNF colony appeared to have been browsed and
only the stem was observed (VHB 2017). Herbivory of SWP or an obvious white-tailed deer
browse line in the forest area has not been observed near the Seneca colony (C. Brown,
WVDNR, email to J. Stanhope, Service, September 19, 2017).
Running Buffalo clover — Survey efforts completed in 2015, 2016, and 2017 (AllStar Ecology
2015, 2016, 2017) documented 27 RBC occurrences (Table 2) on private land in Randolph and
Pocahontas Counties, WV, within the action area. Most occurrences were documented in areas
with intermittent soil disturbance, such as former logging roads and off-road vehicle (ORV) trails
14

under primarily closed -canopy mixed -hardwood forest with filtered sunlight. All occurrences
were within, or in close proximity to, limestone geology of the Mississippian age.
Delineating RBC populations from occurrences is difficult and involves distinguishing and
mapping discrete occurrences. For the purposes of our analysis, the 27 occurrences were
delineated as 6 populations (Table 2). The populations were delineated based on distance of the
occurrences from one another and habitat connectivity between the occurrences.
Table 2. RBC populations and occurrences within action area. Population number 3 and 4 are not included because
they are not affected by the proposed action. Data on rooted crowns in the limits of disturbance obtained from ERM
(2017).
Population
Number
County
Size of Occurrence
(acres)
Total Rooted
Crowns
Number of Rooted
Crowns in Limits of
Disturbance
1
Randolph
0.0354
159
108
2
Randolph
0.7143
4,722
3,055
2
Randolph
0.0014
15
15
2
Randolph
0.0051
31
31
5
Pocahontas
0.0015
6
6
5
Pocahontas
0.0020
34
34
5
Pocahontas
0.1104
447
167
5
Pocahontas
0.0022
26
26
5
Pocahontas
0.0006
39
39
6
Pocahontas
0.0140
118
118
6
Pocahontas
0.0589
24
17
6
Pocahontas
0.0004
10
10
6
Pocahontas
0.0144
60
60
7
Pocahontas
0.0007
7
7
7
Pocahontas
0.0004
7
7
7
Pocahontas
0.0124
85
85
7
Pocahontas
0.0009
30
30
7
Pocahontas
0.0013
17
17
7
Pocahontas
0.0069
108
108
7
Pocahontas
0.020
291
3
15

7
Pocahontas
0.0161
610
220
7
Pocahontas
0.0014
47
47
7
Pocahontas
0.0021
53
53
7
Pocahontas
0.0005
26
26
7
Pocahontas
0.3484
3,313
1,233
8
Pocahontas
0.0012
220
220
8
Pocahontas
0.0024
10
10
All RBC occurrences are on private land and we are not aware of specific activities that have
occurred that benefit or adversely affect the species. However, because most occurrences of RBC
are located on or near old logging roads or trails, they have likely received some type of
occasional disturbance. For example, beneficial effects may have occurred at some RBC
occurrences as a result of occasional foot traffic or ORV use by landowners. Conversely, adverse
effects may have occurred from higher frequencies of ORV travel during a shortened time period
or heavy equipment use of old logging roads during land management or timbering operations.
Roanoke logperch — Presence/absence surveys for RLP were not conducted for the proposed
action. RLP presence is assumed where suitable habitat was identified within potential habitat
and in areas known to support RLP. Genetic analysis (Roberts et al. 2013) of RLP indicated a
dispersal extent of up to 80 river kilometers (km) and the authors recommended monitoring and
recovery efforts should target entire catchment areas. The following waterbody crossings were
categorized as suitable habitat identified by desk -top analysis or in-situ assessment: Butterwood
Creek (milepost [(MP]) 253.7) and Sturgeon Creek (MP 272). The following waterbody
crossings were categorized as known to support RLP -presence assumed: Nottoway River 1 (MP
260.7) and Waqua Creek (MP 267.4).
Butterwood Creek crossing, Dinwiddie County, VA, is a tributary to the Nottoway River and
was not assessed for RLP habitat suitability due to access restrictions. The construction ROW is
26 meters (m) wide at this crossing. We assume the wetted width is the same as the other
tributary crossings, 8 in. The Lahey and Angermeier (2007) model infer this segment is not
occupied by RLP due to stream order and Shreve link values. However, the VA Department of
Game and Inland Fisheries (VDGIF 2005) model and Anderson (2016) model identify this
crossing as potential RLP habitat and RLP presence is assumed. RLP occurrences are
documented 17-22 km downstream of the crossing (VA Fish and Wildlife Information Service
2017). Lahey and Angermeier (2006) hypothesized RLP in Nottoway River tributaries are likely
sparsely distributed at low densities. We expect numbers in this tributary are comparable to RLP
numbers reported in other tributaries of the Nottoway River. Waqua Creek is the only tributary
crossed for this project that has applicable RLP survey information, details of which are
discussed below.
Sturgeon Creek crossing, Brunswick County, VA, is a tributary to the Nottoway River and
1L

contains suitable RLP habitat based on the in-situ assessment (Environmental Solutions &
Innovations, Inc. [ESI] 2017). Sturgeon Creek is a perennial, low gradient stream at the crossing.
The substrate is composed of 20% gravel, 10% clay, 10% cobble, and 60% sand. The stream
morphology is characterized as 50% run, 20% riffle, and 30% pool habitats. Average and
maximum depths measured 0.4 m and 1.3 m, respectively (ESI 2016, 2017). The construction
ROW is 38 m wide at this crossing, the wetted width is 8 m. The Anderson (2016) model
identifies this crossing as potential RLP habitat. RLP occurrences are documented 9.7-10.5 km
downstream of the crossing (VA Fish and Wildlife Information Service 2017). We expect
numbers in this tributary are comparable to RLP numbers reported in other tributaries of the
Nottoway River. Waqua Creek is the only tributary crossed for this project that has applicable
RLP survey information, details of which are discussed below.
Nottoway River 1 crossing, Dinwiddie and Brunswick Counties, VA, is known to support RLP.
Therefore, RLP presence is assumed and habitat suitability was not assessed. The construction
ROW is 38 m wide at this crossing, the wetted width is 22 m. The Anderson (2016) model
identifies this crossing as potential RLP habitat. Documented RLP occurrences are 0.8 km
downstream of the crossing (VA Fish and Wildlife Information Service 2017). During 2016 and
2017 mussel surveys, RLP were found in the area of direct impact from the proposed pipeline
crossing and downstream of the proposed pipeline crossing (ESI 2017). Twelve RLP were
observed during the July 2017 mussel survey of this crossing (S. Trichell, Dominion Energy
Services, email to T. Andersen and S. Hoskin, Service, August 25, 2017). Mussel surveys were
conducted 200 m upstream and 800 m downstream of the proposed crossing, the same distance
instream sedimentation is expected to travel. We used this survey information to estimate the
total number of RLP present at this crossing. We added a correction factor since mark -recapture
data indicates that only about 10% of RLP are actually detected during surveys (P. Angermeier,
U.S. Geological Survey VA Cooperative Fish and Wildlife Research Unit, email to Service,
February 2, 2012). To incorporate the detectability correction factor we multiplied the 12 RLP
found in the action area by 10 and estimate that approximately 120 RLP occur within the
Nottoway River at this crossing.
Waqua Creek crossing, Brunswick, VA, is a tributary to the Nottoway River and known to
support RLP. Therefore, RLP presence is assumed and habitat suitability was not assessed. The
construction ROW is 27.4 m wide at this crossing, the wetted width is 8 m. Waqua Creek is a
low gradient stream and substrates are composed of 15% gravel, 5% silt, and 80% sand. Stream
morphology is characterized as 70% run and 30% pool habitats. Average and maximum depths
measure 0.49 and 2.0 m, respectively (ESI 2016, 2017). The Anderson (2016) model identifies
this crossing as potential RLP habitat. One RLP was documented on July 12, 2012, 3.7 km
downstream of the crossing (Roberts and Angermeier 2012). To incorporate the detectability
correction factor we multiplied the 1 RLP found in a reach of similar length to the action area by
10 and estimate that approximately 10 RLP occur within Waqua Creek at this crossing.
As stated earlier, we expect Butterwood and Sturgeon Creeks support the same density of RLP as
Waqua Creek. Ten RLP are estimated to occur at the Waqua Creek crossing; therefore an
estimated 10 RLP are expected to occur at each of the Butterwood and Sturgeon Creek crossings.
An estimated 120 RLP are expected to occur at Nottoway River 1. A total of 150 RLP are
expected to occur in the action area.
17

In the Anderson (2016) model, RLP potential habitat covers approximately 2,552 km in VA and
NC, of which 497.753 km are in the Nottoway River basin. The proposed project crosses 4
waterbodies (Butterwood Creek, Sturgeon Creek, Nottoway River 1, and Waqua Creek) known
or with potential to support RLP. The proposed action has the potential to impact 1,000 m (200
m above and 800 m below a crossing) plus the construction ROW at each crossing or a total of
4,130 m in VA. The action area represents approximately 0.80% of the total RLP potential
habitat in the Nottoway River basin and 0.16% of the total RLP potential habitat in NC and VA.
RLP decline in the action area is primarily the result of destruction and modification of habitat
and fragmentation of the species range. Primary causes of RLP habitat degradation include
chemical spills, non -point runoff, channelization, impoundments, impediments, and siltation; and
the Nottoway River and tributaries were added to VA's impaired waters list in 2014.
Clubshell — In 1995, 168 clubshell were documented at a site downstream of the I-79 Bridge
over Hackers Creek in Lewis County, WV. In 2004, WVDNR visited this location to establish a
long-term clubshell monitoring location and found 18 live clubshell. During this visit, a
"hazmat" boom was found along the bank of Hackers Creek under the I-79 Bridge indicating a
spill had occurred (WVDNR 2004). Additionally, a spring that appeared to be high in iron was
located between the proposed monitoring site and the I-79 Bridge. As a result, the long-term
monitoring site was relocated further upstream in Hackers Creek at the Life's Run Bridge
(County Route 14) in Lewis County, WV, where a population of 38 clubshell occurred. The 18
clubshell from the downstream area were relocated to this upstream site because it was
determined to be safer for the species (WVDNR 2004).
Data from the long-term monitoring site (the Hackers Creek population) has been collected every
5 years. The 2009 and 2014 monitoring events documented a continued decline and no
recruitment (29 individuals in 2009; 19 individuals in 2014) (WVDNR 2009, 2014). The
Hackers Creek population is the only extant clubshell population in the Monongahela River
drainage (WVDNR 2004). Continued declines in the number of individuals have raised concerns
that the population may be in peril (WVDNR 2014). Surveys for clubshell were conducted in
Hackers Creek in Lewis County, WV, in 2015 (ESI 2016) approximately 3.2 miles upstream of
the long-term monitoring site. This survey effort did not document clubshell.
Approximately 6.4 miles of construction ROW and 11.9 miles of access roads from MP 14.7 to
MP 21.1 are proposed in the upstream drainage area of the Hackers Creek 12 -digit hydrologic
unit code (HUC-12) watershed. The construction ROW and access roads in this area total
approximately 151.28 acres, of which 149 acres are forested. Six tributaries of Hackers Creek are
proposed to be crossed within this HUC-12; the closest is 1.23 miles upstream from the Hackers
Creek clubshell population and the furthest is 6.25 miles upstream from the Hackers Creek
clubshell population.
Threats leading to the decline of the Hackers Creek population include a high sediment load
suspected to result from mining, gas well construction, highway runoff, and agricultural practices
(WVDNR 2014). The action area is currently affected by traditional oil and gas drilling activities
and newer oil and gas activities that involve water withdrawals and horizontally fracked

Marcellus shale wells. Water withdrawals have been suspected of affecting aquatic life during
low flow conditions by causing more fluctuation in water levels which sometimes leads to the
dewatering of mussel beds. Additionally, sedimentation and erosion from the supporting
infrastructure for Marcellus shale gas developments are impacting streams in this area. Bank
stability, often a result of land use practices, has resulted in excessive sedimentation that may
reduce suitable habitat for the clubshell and can smother individuals, causing death. Excessive
suspended sediments can impair feeding processes, leading to acute short-term or chronic long-
term stress. Both excessive sedimentation and excessive suspended sediments can lead to
reduced mussel populations (Ellis 1931, 1936; Houp 1993; Box and Mossa 1999; Anderson and
Kreeger 2010).
Rusty patched bumble bee — The action area in NC is not within the historical range of RPBB.
Within the action area in WV there are historical records of RPBB in Randolph County in the
1990s and in Lewis, Pocahontas, and Upshur Counties prior to 1980. Prior to the mid- I990s,
RPBB was widespread and considered common throughout its historical range, which included
Lewis, Pocahontas, Randolph, and Upshur Counties. In 2017, a RPBB was collected in Mineral
County, WV, which is outside the action area.
Within the action area in VA, there are no historical records for RPBB in Augusta, Bath, and
Highland Counties. Prior to the mid-1990s, RPBB was widespread and considered common
throughout its historical range, which included Augusta, Bath, Highland, and Nelson Counties.
There is a record of I RPBB collected from Nelson County in 1976. There is 1 documented
occurrence in VA from 2014, in Fauquier County, which is outside the action area.
An entomology survey documented a RPBB on June 6, 2017 (S. Throndson, ERM, email to S.
Hoskin, Service, June 8, 2017) in Bath County, VA (Figure 4). A single worker bee foraging on
a rhododendron (Rhododendron catawbiense) within the George Washington National Forest
(GWNF) along Forest Road 124 (Project access road 36-014-AR2) was captured for
identification and then released. The capture site is located approximately 1.6 km from the
construction ROW (MP 93.7). One hour of additional sampling in the area surrounding the
capture location was completed and no additional RPBBs were found. The magnitude of RPBB
population losses and range contractions to date (82 FR 3186-3208) has greatly reduced the
likelihood that the species is present elsewhere in the action area. Therefore, comprehensive
RPBB surveys were not conducted throughout the action area in VA.
We assume the RPBB is most likely to occur in the 653 -hectare (ha) high potential zone (HPZ)
(Figure 4), which was modeled based on the single 2017 RPBB location and the species'
potential ability to disperse across the landscape (Service 2017). The HPZ is primarily forested,
with a few openings that may be characterized as field or meadow. Forested areas are
characterized by oak (Quercus spp.) dominated overstory, with understory coverage of 30-50%
rhododendron (Rhododendron spp.), mountain laurel (Kalmia latifolia), blueberry (Vaccinium
spp.) and flowering forbs, and few non-native plants (ACP 2017, VDCR-DNH [VA Department
of Conservation and Recreation -Division of Natural Heritage] 2017). Small openings have been
created throughout the forested area by gypsy moth (Lymantria dispar dispar) caterpillar and
wind damage. These openings provide opportunities for sub -canopy flowering shrubs and forbs
to develop.
19

Although it is unknown where the colony nest associated with the single observed RPBB is
located, suitable habitat for nest sites and overwintering queens is located within the HPZ. The
colony nest associated with the single observed RPBB may be located anywhere within the 0.8
km foraging distance of the observation location (Osborne et al. 1999, Knight et al. 2005, Wolf
and Moritz 2008, Service 2017). There are 201 ha (area of a circle with radius of 0.8 km) of
suitable habitat for nesting within 0.8 km of the observed location.
Due to the rarity of the species in VA and uncertainty associated with some RPBB life history
requirements, there is uncertainty regarding habitat use and distribution of the species during
certain life stages and time periods. As a result, the following assumptions, based on the best
available information, have been made about RPBB distribution and habitat use for this Opinion:
• RPBB activity (foraging, nesting, overwintering queens) is concentrated in the HPZ.
• Floral resources of sufficient quality for RPBB foraging are found throughout the HPZ
and are concentrated in patches where canopy openings have been created, and these
patches are evenly distributed throughout the HPZ.
• Average foraging distance for an individual RPBB is 0.8 km from a nest site (Service
2017).
• The RPBB observed in June 2017 is part of a colony consisting of 100 to 1,000 workers
(Service 2016).
• The RPBB observed in June 2017 represents at least 1 colony, which is part of at least 1
population.
• Maximum dispersal distance for new queens in fall is 1 to 10 km (Service 2016) (Figure
4).
• Overwintering queens are likely to be in proximity to spring ephemerals and may be
found near woodland edges or in wooded areas with canopy openings that provide light
to the forest floor in the spring.
• Approximately 6-8 new foundress queens are produced at the end of summer (Goulson
2010).
• Status of colony and population in the HPZ is unknown at this time because while the
presence of a worker bee signifies the existence of a colony, we have no accurate way to
assess the status of the local population.
• Density of colonies in the HPZ is estimated to be approximately 14 nests per 100 ha
(Dreier et al. 2014). A density of 0.14 nests/ha is among the lowest of 10 estimates of
nest density found in a variety of landscape settings for the buff -tailed bumblebee
(Bombus terrestris), a close relative of the RPBB (Chapman et al. 2003 [as cited in
Charman et al. 2010], Darvill et al. 2004, Knight et al. 2005, Kraus et al. 2009, Wolf et
al. 2012, Dreier et al. 2014, Wood et al. 2015). The buff -tailed bumble bee is common
and abundant compared to the RPBB, but a nest density of 0.14/ha in suitable habitat is
reasonable because:
• the nest density estimates available in the literature for the buff -tailed bumble bee
are for landscapes, whereas we are assuming a nest density of 0.14/ha in suitable
habitat where nests would be concentrated;
• the mean of the 10 nest density estimates made for the buff -tailed bumble bee was
34/ha, with a high of 88/ha; and,
• it is lower than the nest density (19/ha) found for the precipitously declining great
20

yellow bumblebee (B. distinguendus), whose nests "remain thinly distributed even
in current strongholds" (Charman et al. 2010). Like the RPBB, this species relies
"on the continued presence of flower -rich, unimproved grassland that provides
floral resources throughout the colony cycle (June to September) and contains, or
is close to, suitable sites for nesting, mating and hibernation" (Charman et al.
2010).
Figure 4. HPZ (green polygon in center of map) and dispersal zone (blue polygon) associated with 2017 RPBB
location (green dot) in GWNF. The construction ROW (dark blue circles) bisects the tops of the HPZ.
21

RPBB in the HPZ are affected by existing actions associated with forest management at GWNF.
Current activities in the HPZ are use of the access road by pedestrians and occasional vehicle use
by 1 private landowner who rarely uses the road to access his property. No timber sales have
occurred in the HPZ in recent years.
Climate change effects on RPBB are summarized from the species final listing rule (82 FR 3186-
3209), "Global climate change is broadly accepted as one of the most significant risks to
biodiversity worldwide; however, specific impacts of climate change on pollinators are not well
understood. The changes in climate likely to have the greatest effects on bumble bees include:
increased drought, increased flooding, increased storm events, increased temperature and
precipitations, early snow melt, late frost, and increased variability in temperatures and
precipitation. These climate changes may lead to decreased resource availability (due to
mismatches in temporal and spatial co -occurrences, such as availability of floral resources early
in the flight period), decreased availability of nesting habitat (due to changes in rodent
populations or increased flooding or storms), increased stress from overheating (due to higher
temperatures), and increased pressures from pathogens and nonnative species, (Goulson et al.
2015, p. 4; Goulson 2016, pers. comm.; Kerr et al. 2015, pp. 178-179; Potts et al. 2010, p. 351;
Cameron et al. 2011a, pp. 35-37; Williams and Osborne 2009, p. 371)."
Madison Cave isopod — The presence or abundance of MCI in the action area cannot be
accurately determined due to lack of effective survey protocols, access to subterranean habitat,
and knowledge of subsurface connectivity. We believe the species may occur throughout the
phreatic karst waters in the vicinity of the proposed project based on the MCI potential habitat
model (Orndorff and Hobson 2007), which is based on the geologic layer in which MCI have
been found. MCI potential habitat covers approximately 266,822 surface acres in Augusta
County, VA. The construction ROW, access roads, and ATWS cross approximately 25 linear
miles, covering approximately 1,974 surface acres (approximately 0.74%) of MCI potential
habitat in Augusta County.
The construction ROW centerline and ATWS cross Cochran's Cave (MP 139.8 -140.4), a
privately owned site identified as a VDCR-DNH Conservation Site, a shallow depression in
Augusta County, VA, which includes the vertical entrance to Cochran's Cave No. 3
(GeoConcepts Engineering, Inc. 2017b). VDCR-DNH Conservation Site designation is their tool
for representing key areas of the landscape worthy of protection and stewardship action. The
construction ROW and ATWS cover 11.2 surface acres of MCI potential habitat in the
Cochran's Cave Conservation Site. While surveys of this site have not documented MCI, the site
is within MCI potential habitat (Orndorff and Hobson 2007) and MCI presence should be
assumed based on its location and a phreatic upwelling stream at the site (W. Orndorff, VDCR-
DNH, email to S. Hoskin, Service, August 11, 2017). Cochran's Cave is surrounded by
agricultural fields interspersed with some forested land and it is likely some pesticides and
sediments have entered the phreatic water in runoff from the agricultural fields.
Five sinkholes ranked "high risk potential" were found within the action area in MCI potential
habitat (GeoConcepts Engineering, Inc. 2017a). Features assigned a "high risk potential"
possessed a combination of 2 or more of the ranking criteria: 1) located on or immediately
adjacent to the proposed construction trench; 2) presence of an open "throat" leading into the
22

subsurface; 3) drainage characteristics (i.e., presence of a clear-cut drainage path leading into the
structure); or 4) evidence of active soil raveling, tension cracks, or collapse. The sinkholes range
from 0.6 to 6.6 miles from the Cochran's Cave Conservation Site.
While we do not know the subsurface connectivity between the sinkholes and the Cochran's
Cave Conservation Site, the sinkholes are in MCI potential habitat and we assume some
connectivity exists. As with Cochran's Cave, the area around the sinkholes is a mixture of
agriculture and forest. The sinkholes provide a conduit for sediments and contaminants to MCI
habitat and we expect they contribute to degradation of MCI habitat in this area.
Indiana bat — The action area crosses the That Appalachian Mountain Recovery Unit (RU)
(Service 2007), encompassing 2,015.992 acres of the RU in VA and 2,431.99 acres of the RU in
WV (Table 3). The Appalachian Mountain RU covers 8,762,586 acres in VA and 15,506,210
acres in WV. The action area crosses 0.023% of the Appalachian Mountain RU in VA and
0.016% in WV. The construction ROW is approximately 159 miles in WV and VA. The Service
(2017a) estimates the 2017 That population is 425 in VA and 1,076 in WV; these numbers
indicate an 8.4% decline in VA and a 54.7% decline in WV since the 2015 census. The action
area is within 4 categories of Ibat habitat: suitable unoccupied summer habitat in VA and WV;
known use summer habitat in WV; unknown use spring staging/fall swarming habitat within
WV, and known use spring staging/fall swarming habitat in VA and WV.
Suitable unoccupied summer habitat is defined as forested/wooded habitats in an That RU in
which survey results per the level of effort outlined in the Range -wide Indiana bat Summer
Survey Guidelines (Service 2017b) suggest probable absence during the summer months. As of
the date of this Opinion, Ibats have been acoustically detected at 17 sites along the proposed
pipeline route, 13 in VA and 4 in WV. Follow up mist -net surveys per the level of effort outlined
in Phase 2/Step 4 of the Range -wide Indiana bat Summer Survey Guidelines did not capture
Ibats (ERM 2017a, 2017b, 2017c). Surveys are pending at 4 acoustic sites in VA; none are
pending in WV (M. Voth, ERM, email to S. Hoskin, Service, September 8, 2017).
Approximately 1,589.992 acres in VA and 1,685.39 acres in WV (83.6 miles in total) proposed
for clearing are classified as suitable unoccupied summer habitat (Table 3).
Known use summer habitat is defined as areas within: a 5 -mile radius (home range) of a pregnant
female or juvenile capture or within 2.5 miles of a known roost tree. None occurs in VA (Table
3). Approximately 8.54 miles of construction ROW and 6.38 miles of access roads, a total of
144.1 acres, will be cleared within known use summer habitat in WV (Table 3). Potential roost
tree surveys in known use summer habitat in WV documented 2,888 potential roost trees, of
which 329 were potential primary trees and 2,595 were potential secondary trees (ERM 2017d).
Primary roost trees are more likely to support a maternity colony of Ibats than secondary trees.
Approximately 11.9 acres remain to be surveyed in WV for potential roost trees in known use
summer habitat.
Unknown use spring staging/fall swarming habitat is defined as areas within a 5 -mile radius of a
potentially suitable hibernaculum that have not been surveyed. Potential hibernaculum surveys
are complete in VA and Phase 1 and 2 potential surveys per the Service Guidance (Service 2015)
did not document new Ibat hibernacula in VA (ERM 2017e) (Table 3). Phase 2 surveys have not
23

been completed for 4 sites in WV. Approximately 178.1 acres proposed for clearing remain to be
surveyed for potential hibernacula in WV (Table 3).
Table 3. That habitat (in acres) nronosed to be cleared.
Habitat Category
VA
WV
Total
Suitable unoccupied summer habitat
1,589.992
1,685.39
3,275.382
Known use summer habitat
0
144.1
144.1
Unknown use spring staging/fall
swarming habitat
0
178.1
178.1
Known use spring staging/fall
swarming habitat
426
424.4
850.4
Appalachian Mountain RU
2,015.992
2,431.99
4,447.982
Known use spring staging/fall swarming habitat is defined as areas within: a 5 -mile radius of
priority 3 and 4 hibernacula or a 10 -mile radius of priority I and 2 hibernacula. The action area is
within 5 miles of 12 known That hibernacula, 5 in VA and 7 in WV (Table 4). Population
estimates for the 12 Ibat hibernacula from the 2016/2017 winter surveys range from 0-73 bats
(Service 2017a). The most recent Ibat counts in each hibernaculum (A. King, Service, email to S.
Hoskin, Service, August 30, 2017 and C. Stihler, WVDNR, email to S. Hoskin, Service,
September 6, 2017) are in Table 4. Some hibernacula have not had a documented occurrence
since the 1990s. Of the known hibernacula within 5 miles of the action area, Ibats were
documented in 3 (Breathing, Clarks, and Starr Chapel Caves) during the 2017 winter counts. The
proposed action will clear known use spring staging/fall swarming habitat, 426 acres in VA and
WNS424.4 acres in WV (Table 3).
Table 4. Known That hibernacula within 5 miles of the action area'.
County, State
Hibernaculum
Approximate
Hibernaculum
WNS Status
That Population
Name
Distance
Priority
(date)
Estimate (date)
(miles) to
Number
ATWS
Randolph, WV
Gooseberry
1.6 (CYb)
4
Suspect (2014)
15 max (1990-
Cave
1999)
Randolph, WV
Fortlick Cave
2.5 (CY)
3
Confirmed
16 (2016)
(2012)
Randolph, WV
Stewart Run
Cave
4.9 (CY)
3
Suspect (2014)
55 (2009)
Pocahontas, WV
Dreen Cave
0.7 (ARb)4
Suspect (2013)
1 (2015)
Randolph, WV
Falling Spring
<0.1 (AR)
4
Confirmed
44 (2009)
Cave
(2011)
Randolph, WV
Simmons -Mingo
0.3
4
Suspect (2014)
17 max (1990-
Cave
1999)
24

Pocahontas, WV
Cass Cave
4.4
4
Suspect (2014)
2 max (1980-
1989)
Bath, VA
Starr Chapel
Cave
2.0 (AR)
3
Suspect (2010)
46 (2017)
Bath, VA
Mountain Grove
3.4 (CY)
4
Suspect (2014)
2 (2000)
Cave
Bath, VA
Breathing Cave
2.3 (AR)
3
Confirmed
(2009)
20 (2017)
Bath, VA
Clarks' Cave
3.1 (AR)
3
Suspect (2011)
73 (2017)
Bath, VA
Witheros Cave
4.7
4
Suspect (2011)
5 (2015)
'There are no known Ihat hibernacula within 5 miles of SHP.
bCY — contractor yard, AR — access road.
'Priority 1 is highest priority and most essential to recovery of the species. Priority 4 is least important to recovery
(Service 2007).
The abundance of Ibats rangewide has declined approximately 20% due to the effects of WNS
since its onset in 2006
(https://www.fws. gov/midwest/endangered/mammals/inba/pdf/2017IBatPQpEstimate5Jul 2
pdf). WNS was first detected in VA and WV during the 2008/2009 winter hibernacula surveys
(Stihler 2012, Powers et al. 2015). VA and WV hibernacula surveys indicate Ibat populations
have decreased at least 95% since the discovery of WNS
(https://www. fws. gov/midwest/endangered/mammals/inba/pdf/2017IBatPQpEstimate5Jul 2
pD-
Northern long-eared bat — This Opinion is for effects to the NLEB not addressed by the January
5, 2016 programmatic biological opinion implementing the final 4(d) rule
(https://www.fws. gov/midwest/endangered/mammals/nleb/pdf/BOnlebFina14d.pdf).
There are 4 known hibernacula in the action area: Simmons -Mingo Cave, PH -S018, PH-
S007/PH-S008, and PH -S019. Thirty-one NLEBs were captured at Simmons -Mingo Cave,
Randolph County, WV, and NLEBs were detected at PH -S018, Randolph County, WV, PH-
5007/PH-S008 and PH -S019, Pocahontas County, WV (FERC 2017).
WNS was detected in WV in 2009 at Trout Cave, Pendleton County. Since that time, WNS has
been confirmed in all areas of WV where NLEB hibernacula are known to occur (Stihler 2012).
EFFECTS OF THE ACTION
Direct effects are the direct or immediate effects of the project on the species, its habitat, or
designated/proposed critical habitat. Indirect effects are defined as those that are caused by the
proposed action and are later in time, but still are reasonably certain to occur (50 CFR 402.02).
An interrelated activity is an activity that is part of the proposed action and depends on the
proposed action for its justification. An interdependent activity is an activity that has no
independent utility apart from the action under consultation. Direct and indirect effects of the
25

proposed action along with the effects of interrelated/interdependent activities are all considered
together as the "effects of the action."
To standardize the effects analysis, the proposed action was divided into discrete actions
described as subactivities. Defining subactivities allows for easier interpretation and
consideration of complex activities. The project subactivities are defined in the species effects
tables (Appendix B Tables 1-8).
Small whorled pogonia — The potential effects of the proposed action are described in Appendix
B Table 1. The project subactivities unlikely to result in any impacts to SWP are described in
Appendix B Table 1; no effect (NE) subactivities. For those subactivities of the proposed action
that are determined to result in NE to SWP, there will be no further discussion in this Opinion.
The project subactivities that may affect, but are not likely to adversely affect (NLAA), the SWP
are described in Appendix B Table 1; NLAA subactivities. For those subactivities of the
proposed action that are determined NLAA SWP, there will be no further discussion in this
Opinion.
There are other subactivities of the project that are likely to adversely affect (LAA) SWP
(Appendix B Table 1; LAA subactivities). For some components of the proposed action that may
affect SWP, AMMs have been incorporated to ameliorate those effects and those are also noted
in Appendix B Table 1. These subactivities are LAA SWP by altering and degrading its habitat
or physically impacting individual plants.
These subactivities in the construction ROW will affect 17.0% and 12.7%, respectively, of the
Seneca and NMF colonies' upslope drainage areas. The subactivities during O&M will occur in
17.0% and 1.1%, respectively, of the Seneca and MNF colonies' upslope drainage areas. The
ground disturbing and vegetation clearing/management subactivities proposed in the upslope
drainage areas of the 2 SWP colonies will result in soil compaction and vegetation removal in the
construction ROW, which will increase surface water flow and downslope erosion rates and alter
surface and subsurface hydrology in the watershed of the colonies, causing changes in
evapotranspiration rates and soil moisture downslope of the construction ROW near the colonies.
Some of these subactivities will also redistribute and loosen soils in the construction ROW,
which will cause sedimentation downslope towards the colonies. These stressors will affect both
the mycorrhizal fungi relied on by SWP and individual SWP, decreasing SWP fitness and
reproductive success and possibly killing individual plants. Depending on the degree of surface
water runoff and sedimentation, SWP habitat may be degraded and individual stems may be
buried. Blasting will also loosen large rocks, which could fall and crush SWP.
During construction and restoration, methods described in the Upland Erosion Control Plan and
Restoration and Rehabilitation Plan and onsite AMMs (e.g., temporary diversion channels and
berms in the SWP Conservation Plan) are expected to minimize effects through surface water
erosion control and restoration of graded areas; however diversion of surface water flow away
from the colonies will alter hydrology in the watershed and soil moisture, causing decreased
fitness and reproductive success and possibly death of individual stems.
co

The vegetation clearing, management, and trimming subactivities in the construction ROW that
remove and thin mid- and over -story canopy trees will alter SWP habitat by increasing direct and
ambient light. ERM (2017) conducted qualitative analyses of the potential changes to light
regime near each colony as a result of tree removal in the construction ROW using 3D computer
modeling. For the Seneca colony, the simulations indicated significant increases in ambient and
direct light on the ground and surrounding area during summer, spring, and fall days, although
not quantified. For the MNF colony, the simulations indicated changes in ambient light on the
ground and surrounding area during early morning on summer and fall days. This light analysis
was conducted before the proposed pipeline route was moved 108 ft further from the MNF
colony, but we continue to anticipate changes in light in the surrounding area due to close
proximity (221 ft) of the construction ROW.
Increased light availability may increase SWP flowering and population size (Dibble et al. 1997;
Dibble 2000a, 2000b; Brumback et al. 2011; McCormick et al. 2015). However, increased light
availability above an unknown threshold is anticipated to degrade SWP habitat by increasing soil
temperature, drying soils, and changing evapotranspiration rates, which will cause decreased
fitness and reproductive success and possibly death of individual stems. Increased light levels
will also facilitate germination and development of other herbaceous and/or woody species,
including invasive species, which could compete with SWP. Significant changes to the sunlight
regime and potential competition due to increased vegetation are likely to cause decreased fitness
and reproductive success and possibly death of SWP individuals.
Methods described in the Non -Native Invasive Plant Species Management Plan (FERC 2017)
will minimize effects due to invasive species in the construction ROW and access roads, but will
not address herbaceous and invasive vegetation growing outside of the construction ROW and
near the SWP colonies due to increased light. The SWP Conservation Plan includes temporary
AMMs to monitor the population status of the SWP colonies annually for 10 years post -
construction and to minimize effects from invasive species outside of the construction ROW and
near the SWP colonies for 3 years (e.g., before, during, and 1 year after construction) (VHB
2017). The SWP Conservation Plan also includes planting native tree seedlings for 200 ft along
the construction ROW edge to the west of the pipeline (e.g., farther away from the colony) to
ameliorate for changes in sunlight regime and monitoring light levels in the colony for 3 years
(e.g., before, during, and 1 year after construction) (VHB 2017). Approximately 20-30 years
after planting, canopy trees (e.g., white oak [Quercus alba] and eastern white pine [Pinus
strobus] found at the Seneca colony) are expected to provide some mid -story shade (Burns et al.
1990), which would contribute to partially restoring the SWP habitat.
Running Buffalo clover — The potential effects of the proposed action are described in Appendix
B Table 2. The project subactivities unlikely to result in any impacts to RBC are described in
Appendix B Table 2; NE subactivities. For those subactivities of the proposed action that are
determined to result in NE to RBC, there will be no further discussion in this Opinion.
The project subactivities that may affect, but are NLAA, the RBC are described in Appendix B
Table 2; NLAA subactivities. For those subactivities of the proposed action that are determined
NLAA RBC, there will be no further discussion in this Opinion.
27

There are other subactivities of the project that are LAA RBC (Appendix B Table 2; LAA
subactivities). For some components of the proposed action that may affect RBC, AMMs have
been incorporated to ameliorate those effects and those are also noted in Appendix B Table 2.
These subactivities are LAA RBC by physically impacting individual plants and/or altering or
degrading its habitat. There are approximately 5.1 acres of RBC within 150 ft of the construction
ROW centerline and 0.8 acres of RBC will be affected and killed (FERC 2017).
Ground disturbance subactivities related to grading, grubbing, increased foot and vehicle traffic,
vegetation clearing and disposal, and trenching (Appendix B Table 2) for access roads and the
construction ROW will kill RBC plants and seeds from some occurrences in 5 populations and
all occurrences in 1 population (Table 2). Conducting these activities in wet conditions will
increase soil compaction, which may restrict seed germination preventing reestablishment of
RBC in the temporary construction ROW post -construction. The placement of fill and gravel will
cause permanent habitat loss in all permanently maintained areas, preventing populations from
re-establishing post -construction.
Burning for vegetation disposal (Appendix B Table 2) is expected to kill RBC because much of
the plant structure is above ground and plants exposed to fire are likely to be killed. Additionally,
topsoil containing RBC plant material and seed source is likely to be submerged in ash piles,
restricting further plant growth and recolonization. We expect RBC plants and seeds within
occurrences in 5 populations and all occurrences in 1 population exposed to fire and/or
submerged in ash piles to be killed within the footprint of burns conducted for vegetation
disposal.
Tree clearing and tree trimming subactivities (Appendix B Table 2) will remove all canopy cover
over the construction ROW and significantly reduce canopy cover over access roads. While RBC
is a disturbance dependent species and some level of tree removal may be beneficial (Madarish
and Schuler 2002), the proposed clearing will create too much sunlight for RBC, which prefers
partial to filtered sunlight. Burkhart et al. (2013) found that plots which received direct sun for
most of the day did not allow RBC to persist. Increased sunlight from openings in the canopy
may also increase competition from other native and invasive plant species. Invasive species are
one of the primary factors influencing the status of RBC. Seed from invasive species may
outcompete RBC, limiting the ability of RBC to germinate, thrive, and produce seeds.
Cleared construction ROW and improved access roads will facilitate ORV traffic and increase
white-tailed deer herbivory. AMMs (installation of barriers) will minimize ORV traffic along the
ROW; however, ORV traffic on access roads will not be prohibited. ORV traffic on improved
access roads and the construction ROW will exceed disturbance frequencies tolerated by RBC
and prevent re-establishment of RBC in some of these disturbed areas. New travel corridors are
expected to increase ease of access to RBC populations by white-tailed deer, and the resulting
herbivory will kill some RBC and lower reproductive output of other RBC.
Roanoke log=perch — The potential effects of the proposed action are described in Appendix B
Table 3. The project subactivities unlikely to result in any impacts to RLP are described in
Appendix B Table 3; NE subactivities. For those subactivities of the proposed action that are
determined to result in NE to RLP, there will be no further discussion in this Opinion.

The project subactivities that may affect, but are NLAA, the RLP are described in Appendix B
Table 3; NLAA subactivities. For those subactivities of the proposed action that are determined
NLAA RLP, there will be no further discussion in this Opinion.
There are other subactivities of the project that are LAA RLP (Appendix B Table 3; LAA
subactivities). For some components of the proposed action that are anticipated to affect RLP,
AMMs have been incorporated to ameliorate those effects and those are also noted in Appendix
B Table 3. These subactivities are anticipated to stun, entrain, or crush RLP, or result in habitat
degradation and loss due to dewatering and placement of cofferdams, placement of temporary
work bridges with a center support, and/or altering water quality.
Installation and dewatering of cofferdams is anticipated to injure or kill some RLP by crushing
individuals during placement of cofferdams and through stranding or entrainment as cofferdams
are dewatered. Installation of the bridge center supports is likely to injure or kill a small number
of RLP by crushing individuals during placement. Installation of the bridge center support is
expected to disrupt breeding activities of the RLP in the work zone because supports will be
installed during the RLP breeding season. We expect a range of impacts, from delaying breeding
until a suitable location is found to inhibiting breeding because all suitable breeding grounds in
the area have been disturbed. As a result, we anticipate that a few subsequent offspring will be
smaller than their counterparts and therefore more vulnerable to predation resulting in injury or
death. Inhibited breeding is expected to result in the loss of genetic contribution from those
adults for the breeding season.
Temporary loss of instream habitat will occur at stream crossings that use dam and pump,
cofferdams and bridge center supports. Additionally cofferdam placement/removal, installation
of bridge center supports, and other instream activities will temporarily re -suspend sediments
and increase turbidity. We expect the RLP in the work zone will avoid these areas until the
instream structures are removed and turbidity returns to baseline levels. If instream work occurs
during spawning, RLP will be unable to successfully spawn in these areas. If work occurs after
completion of spawning, crushing or removal of a small percent of eggs is likely.
Adjacent upland ground -disturbing activities, such as tree clearing, grading
constructing/improving access roads, and pipe stringing, are likely to introduce sediment into
RLP habitat. Moderately silted and high turbidity areas will be unusable to most RLP for
foraging and spawning in the immediate vicinity of the crossing. Heavy siltation is anticipated to
result in a loss of prey items. If instream work occurs during spawning, a reasonable worst case
scenario is a majority of RLP in the work zone will be unable to successfully spawn in these
areas. If work occurs after completion of spawning, crushing or removal of a small percent of
eggs is likely.
If blasting is needed for any crossings, a small number of RLP in the immediate blast area are
likely be killed and the RLP in the vicinity will be temporarily stunned and/or permanently
injured; some of the RLP will recover, while a small percentage of RLP will have internal
injuries and die.
29

While implementation of AMMs (VA Fish Relocation Plan, Appendix K, and Restoration and
Rehabilitation Plan, Appendix F, of the FEIS [FERC 2017]) should significantly reduce the
likelihood of mortality or injury from stream crossings, which include placement of cofferdams,
these effects are still anticipated. Additionally, streambank vegetation removal is likely to alter a
small portion of RLP habitat. Loss of streambank vegetation is expected to result in increased
water temperatures, which can lower dissolved oxygen levels, and changes in light regime in
small areas. Changes in water temperature and light regime are anticipated to shift the RLP prey
base to species that are more tolerant to light and lower dissolved oxygen and make the habitat
less suitable for the RLP themselves. For work along existing ROW, riparian vegetation will be
replanted. New alignments will result in permanent removal of riparian vegetation. These
changes are anticipated to decreased fitness of a small portion of RLP individuals by shifting
their diet and potentially decreasing the dissolved oxygen levels in small patches of the
waterbodies.
Clubshell — The potential effects of the proposed action are described in Appendix B Table 4.
The project subactivities unlikely to result in any impacts to clubshell are described in Appendix
B Table 4; NE subactivities. For those subactivities of the proposed action that are determined to
result in NE to clubshell, there will be no further discussion in this Opinion.
The project subactivities that may affect, but are NLAA, the clubshell are described in Appendix
B Table 4; NLAA subactivities. For those subactivities of the proposed action that are
determined NLAA clubshell, there will be no further discussion in this Opinion.
There are other subactivities of the project that are LAA clubshell (Appendix B Table 4; LAA
subactivities). For some components of the proposed action that may affect clubshell, AMMs
have been incorporated to ameliorate those effects and those are also noted in Appendix B Table
4.
Subactivities that are LAA clubshell result from increased sediment loads to Hackers Creek
upstream of the Hackers Creek clubshell population. Approximately 6.4 miles of construction
ROW and 11.9 miles of access roads from MP 14.7 to MP 21.1 are proposed in the upstream
drainage area of the Hackers Creek HUC-12 watershed. The construction ROW and access roads
in this area total approximately 151.28 acres, of which 149 acres are forested. Six tributaries of
Hackers Creek are proposed to be crossed within this HUC-12; the closest is 1.23 miles upstream
from the Hackers Creek clubshell population and the furthest is 6.25 miles upstream from the
Hackers Creek clubshell population. Sedimentation will affect clubshell and degrade/alter
clubshell habitat.
Mussels close their valves during periods of heavy siltation to avoid irritation and clogging of
feeding structures (Loar et al. 1980). Mussel gills can become overwhelmed with excessive
suspended sediment, causing a mussel to either reduce its water and food intake rate or close
altogether. The stream crossings and access roads are expected to result in sedimentation and
increased turbidity causing impaired feeding, resulting in reduced physiological function;
depressed rates of growth, reproduction, and recruitment. We expect this will result in the death
of a few individual clubshell.
30

Sedimentation may permanently alter and degrade habitat through siltation such that conditions
are no longer favorable for clubshell. These effects will persist until high flows flush settled
sediment downstream. Excessive siltation also degrades water and substrate quality. High levels
of suspended sediments will reduce dissolved oxygen levels in the water, while heavy sediment
deposition will fill interstitial spaces in the substrates, both of which can suffocate mussels
particularly if sufficient accumulation occurs (Ellis 1936, Marking and Bills 1980).
Construction will occur during months of highest precipitation and flow rates in WV (S.
Throndson, ERM, email to E. Stout, Service, September 13, 2017). Large releases of sediment
may occur during storm events. Much of the sediment released from disturbed areas during
storm events is expected to be transported downstream, temporarily elevating suspended solids,
with those solids not washed out of the action area settling in pools. It is difficult to determine
what level of excess sedimentation will be generated by the project, how far downstream
sedimentation will occur, or how long these effects will persist. Factors such as storm intensity,
stream channel morphology, flow rates during and post construction, and effectiveness of
sediment and erosion control measures, can affect the duration and severity of instream
sedimentation.
We anticipate these changes in habitat will further impair feeding, resulting in sublethal effects
on growth and reproduction or starvation with long-term exposure. As a result of decreased
water quality, and degraded and altered habitat we anticipate that most of the clubshell will
experience impaired feeding. When high flows continue to flush sediment downstream, we
expect that within 6 months post -construction the habitat will begin to return to pre -construction
condition. At that time, the remaining mussels will be able to feed in an unimpaired manner.
However, the population will remain below pre -construction numbers.
The implementation of AMMs (e.g., erosion and sedimentation control measures along
workspace edges, and temporary equipment crossings) may ameliorate some of the
sedimentation effects. However, due to the magnitude of anticipated disturbance, not all
sediment will be prevented from entering waterways. As a result, we expect habitat degradation
and loss will occur and some individual clubshell will experience impaired feeding while others
may suffocate and die.
Rusly patched bumble bee — The potential effects of the proposed action are described in
Appendix B Table 5. The project subactivities unlikely to result in any impacts to RPBB are
described in Appendix B Table 5; NE subactivities. For those subactivities of the proposed
action that are determined to result in NE to RPBB, there will be no further discussion in this
Opinion.
The project subactivities that may affect, but are NLAA, the RPBB are described in Appendix B
Table 5; NLAA subactivities. For those subactivities of the proposed action that are determined
NLAA RPBB, there will be no further discussion in this Opinion.
There are other subactivities of the project that are LAA RPBB (Appendix B Table 5; LAA
subactivities). For some components of the proposed action that may affect RPBB, AMMs have
been incorporated to ameliorate those effects and those are also noted in Appendix B Table 5.
31

Within the HPZ, these subactivities may crush individuals, crush a colony, expose RPBBs to
noise/vibration, and render habitat temporarily and permanently unsuitable.
Ground disturbance associated with the construction ROW is proposed to occur during the active
foraging season for RPBB workers. RPBB workers are expected to be crushed by machinery
during vegetation removal and construction, which will affect the ability of the workers to
provide sufficient resources to the colony, resulting in reduced survival of individual workers
and reduced reproductive capacity of the queen. Machinery is also expected to crush any
colonies present within the action area in the HPZ.
Construction ROW activities, and restoration and maintenance activities on the access road and
construction ROW may expose RPBBs to noise/vibration, causing individuals to expend
additional energy to seek out alternate foraging and nesting areas, which may reduce survival
and reproduction.
In the HPZ (653 ha) the proposed action (7.3 ha) is expected to include permanent (access road
widening and permanent ROW) and temporary (temporary construction ROW and ATWS)
habitat loss. Soil compaction during road construction may affect the ability of queens to
excavate an overwintering site and may reduce the ability of rodents to excavate burrows, which
reduces the ability of colonies to find appropriate nest locations, resulting in reduced
reproduction. Floral resources will be removed from the entire 7.3 ha, with permanent loss
within the expanded road surface and temporary loss within the construction ROW and ATWS
These floral resources include concentrations of spring ephemerals (ACP 2017, VDCR-DNH
2017) potentially used by queens after overwintering and loss of these resources will result in
reduced survival and reproduction of queens. Loss of floral resources is expected to temporarily
displace all RPBBs the following active season, and displaced RPBBs are expected to move to
suitable habitat in the surrounding area, which will result in reduced reproduction.
Herbaceous floral resources will re-establish within 1 growing season adjacent to the new access
road alignment. Flowering shrubs are likely to take 8-10 years to re-establish. As floral resources
are re-established post -construction, introduction and spread of invasive plant species and use of
fertilizer are expected to reduce the diversity of native floral resources, limiting the suitability of
restored habitat for RPBB.
Madison Cave isopod — The potential effects of the proposed action are described in Appendix B
Table 6. The project subactivities unlikely to result in any impacts to MCI are described in
Appendix B Table 6; NE subactivities. For those subactivities of the proposed action that are
determined to result in NE to MCI, there will be no further discussion in this Opinion.
The project subactivities that may affect, but are NLAA, the MCI are described in Appendix B
Table 6; NLAA subactivities. For those subactivities of the proposed action that are determined
NLAA MCI, there will be no further discussion in this Opinion.
There are other subactivities of the project that are LAA MCI (Appendix B Table 6; LAA
subactivities). For some components of the proposed action that are anticipated to affect MCI,
AMMs have been incorporated to ameliorate those effects and those are also noted in Appendix
32

B Table 6. Details of the AMMs are located in the Karst Terrain Assessment Construction,
Monitoring and Mitigation Plan (GeoConcepts Engineering, Inc. 2017c) in Appendix I and page
4-300 of the FEIS (FERC 2017). These subactivities are expected to crush or introduce sediment
that smothers MCI, or collapse or fill subsurface features and/or alter subsurface water quality
and/or quantity resulting in habitat degradation, fragmentation, and loss.
There are a total of 896.7 surface acres within 0.5 mile of the construction ROW centerline and
ATWS. We anticipate ground disturbing activities such as, digging, trenching, blasting, grading,
constructing/improving access roads, culvert installation, and wetland crossings may introduce
sediment into the subsurface areas, which could smother MCI up to 0.5 mile from the
construction site. Trenching or blasting is also likely to loosen subsurface rocks, which could fall
and crush MCI. Grading redistributes and loosens soil making it more prone to erosion.
Depending on the amount and speed of the erosion event, MCI will either avoid a particular area
until the sediment is settled or be smothered. Any MCI present in the zones of impact will likely
be crushed or smothered.
Loosened subsurface rocks from trenching or blasting are expected to disrupt the subsurface
water flow and alter MCI travel corridors. The fractured nature of the geology in the area
generally provides numerous travel corridors, which reduces the likelihood that a blocked
corridor will completely isolate an individual; however, MCI will need to expend additional
energy to find an alternate route. Additionally, trenching or blasting is anticipated to intercept a
subsurface void, creating a direct conduit for soil and sediment to enter into the subsurface
habitat. Depending on the degree of sedimentation, habitat will be degraded or lost. These
changes will render habitat temporarily or permanently unsuitable for use by the MCI and are
likely to prevent movements among or between populations.
Indiana bat — The potential effects of the proposed action are described in Appendix B Table 7.
We did not reach a NE determination for Ibat for any of the subactivities.
The project subactivities that may affect, but are NLAA, the That are described in Appendix B
Table 7; NLAA subactivities. For those subactivities of the proposed action that are determined
NLAA Ibat, there will be no further discussion in this Opinion.
There are other subactivities of the project that are LAA Ibat (Appendix B Table 7; LAA
subactivities). For some components of the proposed action that are likely to affect Ibats, AMMs
have been incorporated to ameliorate those effects and those are also noted in Appendix B Table
7. These subactivities will temporarily or permanently remove a total of 4,448 acres of suitable
habitat in the That Appalachian Mountain RU. The amount of tree removal proposed in suitable
unoccupied summer habitat is 3,275.382 acres (Table 3). The amount of tree removal proposed
in known use summer habitat is 144.1 acres (Table 3), which includes over 9 miles of
construction ROW centerline and 1.94 miles of access roads; a TOYR (trees will be removed
between November 15 and March 31 in WV and November 16 and April 14 in VA, when Ibats
will not be present) will be implemented in known use summer habitat. The amount of tree
removal in unknown use spring staging/fall swarming is 178.1 acres (Table 3); we are assuming
Ibat presence in unknown use spring staging/fall swarming habitat, and a TOYR (trees will be
removed between November 15 and March 31, when Ibats will not be present) will be
33

implemented in unknown use spring staging/fall swarming habitat. The amount of tree removal
in known use spring staging/fall swarming habitat is 850.4 acres (Table 3); a TOYR (trees will
be removed between November 15 and March 31, when Ibats will not be present) will be
implemented in known use spring staging/fall swarming habitat.
We expect direct effects to Ibats from tree clearing will not occur in suitable unoccupied summer
habitat. However, indirect effects may occur to a small number of Ibats searching for potential
roosting sites and those traveling through the area. Approximately 3,275 acres (83.6 miles) of
suitable unoccupied summer habitat in VA and WV will be cleared. We do not anticipate tree
clearing will impact current Ibat home ranges due to the negative survey results; however, the
cleared areas will not be suitable summer habitat available for future use. Ibat home ranges vary
in size from 205.1-827.8 acres (Menzel et al. 2005, Sparks et al. 2005, Watrous et al. 2006,
Kniowski and Gehrt 2014, Jachowski et al. 2014). The 3,275 acres of suitable unoccupied
summer habitat to be cleared represents 4-16 home ranges that will be removed from future use
if tree clearing were to occur in large blocks. The proposed action is linear and therefore tree
clearing is not anticipated to remove entire potential home ranges rather, sections of potential
home ranges. Worst case scenario is potential home ranges will be centered along the 83.6 miles
of the construction ROW every 5 miles, affecting 17 potential home ranges. This is not a
reasonable scenario for several reasons. First, the construction ROW goes through previously
cleared areas. Depending on the level of previous clearing, the center of the construction ROW
may not be ideal because there is too much solar exposure, too much noise, or not enough cover
from predators. Second, forest cover in the counties in action area is 55-86%
(https://www.fia.fs.fed.us/tools-data/), which provides ample area to establish new home ranges.
It is likely that tree clearing will affect a part of a potential home range, which is a fraction of the
potential habitat in WV and VA. We anticipate some of the areas that will be cleared are
currently used as a travel corridor between hibernacula and roost trees. The construction ROW
will go through a mix of previously fragmented areas and unfragmented areas. Likely Ibats
would not have used previously cleared areas as travel corridors and will only be impacted in
previously unfragmented areas or if tree clearing removed a narrow treed corridor that was the
sole travel corridor. We anticipate effects will be greatest to pregnant females that expend
additional energy to seek alternate travel corridors as a result of tree clearing. If pregnant females
dramatically alter their travel corridor they will divert their energetic demands to seek new
corridors and will likely give birth to smaller pups, which could decrease pup survival. Maternity
roost trees were not documented in VA; therefore we expect the likelihood of pregnant females
and the need to alter travel corridors to be low in VA. It is more likely that tree removal in WV
will cause pregnant females to seek alternate travel corridors because known use summer habitat
has been documented in WV. Ibats consistently follow tree -lined paths rather than cross open
areas (Murray and Kurta 2004) and, depending on the amount of forested habitat in the
surrounding area, tree removal may fragment the habitat such that Ibats traveling through the
area will be more vulnerable to predation, resulting in injury or death. Because we expect Ibats
will avoid the cleared areas, depending on the resulting level of fragmentation, tree clearing is
likely to make the remaining forest less suitable for roosting or foraging, which will cause Ibats
to expend more energy searching for alternative roosting or foraging sites, delaying their ability
to gain post -hibernation weight.
34

Tree removal in known use summer habitat is likely to limit roosting options or necessitate roost
tree switching when Ibats return the following season. Because maternity roost trees are
ephemeral, Ibats have evolved to relocate roosts at the beginning of the season if needed.
Because trees will be removed outside of the active season when the roost trees are not in use,
the stress on an That is decreased. Ibats have primary and secondary roosts and will shift between
sites during a season (Humphrey et al. 1977, Gardner et al. 1991, Callahan 1993, Kurta et al.
1993, Romme et al. 1995). Therefore, in the rare instance a primary roost tree is cut, as long as
alternate roosts remain in the vicinity, effects associated with loss of individual roost trees are
likely to be short-term. There is a substantial amount of roosting habitat in the action area and we
expect Ibats will relocate roosting areas with minimal effects to individuals.
Tree removal in unknown use spring staging/fall swarming habitat will remove foraging and
roosting areas for a concentrated number of Ibats in an abbreviated season (i.e., spring
emergence or fall swarming). Bats use the area around hibernacula to build fat reserves prior to
hibernation and to socialize and mate in the fall. In the spring, bats spend a few hours or days
around hibernacula or migrate immediately to summer habitat. Clearing trees around hibernacula
will permanently decrease foraging and roosting habitat, requiring bats to spend more time
searching for food, which could result in bats entering hibernation with less fat reserves resulting
in decreased overwinter survival or poorer spring body condition or result in less time on social
interactions, which could result in decreased breeding success. We expect the same effects on
Ibats from tree removal in known use spring staging/fall swarming habitat as those described for
unknown use spring staging/fall swarming habitat.
We do not anticipate Ibats will be present during tree removal activities, a TOYR (trees will be
removed between November 15 and March 31, when Ibats will not be present) will be
implemented around known hibernacula in WV and VA and no impacts are anticipated to Ibats
hibernacula or hibernating bats. However, as discussed above tree clearing will render the habitat
temporarily or permanently unsuitable for use by Ibats. Vegetation will grow back in the
temporary construction ROW. We expect pine (Pinus spp.) and sweet gum (Liquidambar
styraciflua) will colonize the temporary construction ROW in VA and beech (Fagus spp.) and
maple (Acer spp.) will colonize the temporary construction ROW in WV, which will not create
Ibat habitat. Trees that create suitable Ibat habitat will be planted along the construction ROW
edge only in the limited native tree planting near 1 SWP colony (VHB 2017).
Northern long-eared bat — The potential effects of the proposed action are described in Appendix
B Table 8. We did not reach a NE determination for NLEB for any of the subactivities.
There are several project subactivities that may affect (MA) the NLEB. Some of these have
effects that have been previously addressed in the Service's January 5, 2016 programmatic
biological opinion implementing the final 4(d) rule
(https://www.fws.gov/midwest/endangered/mammals/nleb/pdf/BOnlebFinal4d.pdD and are
described in Appendix B Table 8; MA subactivities. For those subactivities, no detailed effects
analysis discussion is required. For some components of the proposed action that MA NLEB,
AMMs have been incorporated to ameliorate those effects and those are also noted in Appendix
B Table 8.
35

There are other subactivities of the project that have not been addressed in the Service's January
5, 2016 programmatic biological opinion implementing the final 4(d) rule (Appendix B Table 8;
LAA subactivities). Each of these subactivities involves tree clearing within 0.25 mile of
hibernaculum PH -S018. Similar to the subactivities mentioned above, AMMs have been
incorporated to ameliorate those effects and those are also noted in Appendix B Table 8.
For context, 170.94 acres of tree removal is proposed within 5 miles (anticipated spring
staging/fall swarming range) of hibernaculum PH -S018. This activity will impact foraging and
roosting areas for a concentrated number of bats in an abbreviated season (spring emergence or
fall swarming). Bats use the area around hibernacula to build fat reserves prior to hibernation, to
socialize and mate in the fall. In the spring, bats may spend a few hours or days around
hibernacula or migrate immediately to summer habitat. Clearing trees around hibernacula will
permanently decrease foraging and roosting habitat, which will require bats to spend more time
searching for food, which could result in bats entering hibernation with less fat reserves resulting
in decreased overwinter survival or poorer spring body condition or result in less time on social
interactions, which could result in decreased breeding success.
In addition, NLEB may have summer maternity colonies around hibernaculum PH -S018.
Individual NLEB home ranges have been minimally estimated at 148.8-173.7 acres (Owen et al.
2003, Lacki et al. 2009). The proposed clearing of 170.94 acres represents a loss of 98.4-100%
of an individual home range. However, the proposed action is linear and therefore tree clearing is
not anticipated to remove an entire potential home range rather, sections of potential home
ranges. Depending on the resulting level of habitat fragmentation, tree clearing will make the
remaining forest less suitable for future roosting or foraging. We expect NLEB will avoid the
permanently cleared areas and start exploring undisturbed areas for future roost sites. This will
cause NLEBs to expend more energy searching for alternative roosting or foraging sites, which
will delay their ability to gain post -hibernation weight resulting in decreased growth.
We do not anticipate NLEBs will be present during tree removal activities, a TOYR (trees will
be removed between November 15 and March 31, when NLEBs will not be present) will be
implemented around known hibernacula in WV and no impacts are anticipated to NLEB
hibernacula or hibernating bats. Tree clearing will render the habitat permanently unsuitable for
use by NLEBs. However, because this clearing will occur when bats are in hibernation, it will
avoid killing NLEB. We anticipate impacts will occur during the first spring, summer, and fall
after tree clearing as bats emerge from hibernation. Most impacts will occur during the season
after tree clearing. All impacts are expected to be limited and short-term in nature, and NLEBs
are expected to acclimate to this change and shift to alternative habitat.
The majority of effects described above have been previously addressed in the Service's January
5, 2016 programmatic biological opinion implementing the final 4(d) rule and any incidental
take that may occur further than 0.25 mile from a hibernacula is not prohibited under the final
4(d) rule (50 CFR § 17.40(0)). However, any anticipated take of NLEB that may occur within
0.25 mile of a hibernaculum requires separate incidental take authorization (see Incidental Take
Statement).
CUMULATIVE EFFECTS
36

Cumulative effects are those "effects of future State or private activities, not involving federal
activities, that are reasonably certain to occur within the action area" considered in this Opinion
(50 CFR 402.02).
Small whorled pogonia— While the Service is not aware of any specific proposed projects
scheduled to occur immediately within the action area, SWP is currently being affected by a
variety of actions and activities in Seneca State Forest, such as trail maintenance, as described in
the Environmental Baseline section above. WVDNR is considering options to reroute the
existing trail (currently 550 ft away) further from the Seneca SWP colony to reduce potential
foot traffic, which may crush SWP and spread invasive plants. This action would be beneficial to
SWP.
Running Buffalo clover — While the Service is not aware of any specific proposed projects
scheduled to occur immediately within the action area, RBC is likely currently being affected by
a variety of actions and activities such as disturbance from foot traffic or ORV use on private
lands as described in the Environmental Baseline section above. All RBC occurrences are on
private land and most are located on or near old logging roads or trails; therefore, they will likely
received some type of occasional disturbance, some of which may be beneficial and some of
which may cause adverse effects.
Roanoke logperch —While the Service is not aware of any specific proposed projects scheduled
to occur immediately within the action area, RLP is likely currently being affected by a variety
of actions and activities such as alteration habitat, as described in the Environmental Baseline
section above. RLP habitat destruction, modification, and fragmentation from chemical spills,
non -point runoff, channelization, impoundments, impediments, and siltation is expected to
continue to occur, resulting in declines in RLP abundance.
Clubshell — While the Service is not aware of any specific proposed projects scheduled to occur
immediately within the action area, clubshell is currently being affected by a variety of actions
and activities such as oil and gas development and associated water withdrawals as described in
the Environmental Baseline section above. Multiple oil and gas wells, pipelines, and water
impoundments are under construction within the watershed. These activities often result in
increased sedimentation and erosion to waterways due to a large quantity of earth disturbing
activities. Additionally, private landowner practices within riparian areas of Hackers Creek (e.g.,
clearing all riparian vegetation and application of herbicides within the riparian zone) have
adversely affected habitat conditions which place added stress to the already declining clubshell
population.
Rusty patched bumble bee — The Service is not aware of any future state, tribal, local, or private
actions that are reasonably certain to occur within the action area at this time; therefore, no
cumulative effects are anticipated.
Madison Cave isopod — While the Service is not aware of any specific proposed projects
scheduled to occur immediately within the action area, MCI is likely currently being affected by
a variety of actions and activities such as agriculture and forest management, as described in the
37

Environmental Baseline section above. These areas provide for sediments and contaminants to
MCI habitat and we expect they contribute to degradation of MCI habitat in this area.
Indiana bat — The Service is not aware of any future state, tribal, local, or private actions that are
reasonably certain to occur within the action area at this time; therefore, no cumulative effects
are anticipated.
Northern long-eared bat — The Service is not aware of any future state, tribal, local, or private
actions that are reasonably certain to occur within the action area at this time; therefore, no
cumulative effects are anticipated.
JEOPARDY ANALYSIS
Section 7(a)(2) of the ESA requires that federal agencies ensure that any action they authorize,
fund, or carry out is not likely to jeopardize the continued existence of any endangered or
threatened species or result in the destruction or adverse modification of designated critical
habitat.
Jeopardy Analysis Framework
"Jeopardize the continued existence of means to engage in an action that reasonably would be
expected, directly or indirectly, to reduce appreciably the likelihood of both the survival and
recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of
that species (50 CFR 402.02). The following analysis relies on 4 components: (1) Status of the
Species, (2) Environmental Baseline, (3) Effects of the Action, and (4) Cumulative Effects. The
jeopardy analysis in this Opinion emphasizes the rangewide survival and recovery needs of the
listed species and the role of the action area in providing for those needs. It is within this context
that we evaluate the significance of the proposed federal action, taken together with cumulative
effects, for purposes of making the jeopardy determination.
Analysis for Jeopardy
Small whorled pogonia
Impacts to Individuals — The proposed action includes herbaceous vegetation and ground cover
clearing, tree and shrubs clearing, tree side trimming, grading, trenching, blasting,
regrading/stabilization, vegetation management, and permanent ROW repair/regrading. As
discussed in the Effects of the Action, potential effects of the action include effects to SWP
present within the action area year -around during construction and O&M. Effects include
decreased fitness and reproductive success or death of individual SWP due to degradation and
loss of SWP habitat caused by altered hydrology, changes in soil moisture, downslope erosion,
sedimentation, changes to sunlight regime, and competition. Individual SWP may be crushed by
rocks from blasting and experience injury and death. The AMMs (e.g., SWP Conservation Plan,
Upland Erosion Control Plan, Restoration and Rehabilitation Plan, and Non -Native Invasive
Plant Species Management Plan) will minimize the potential effects from surface water runoff
during construction and restoration and competition from invasive plants. In summary, there will
be impacts to individual SWP in their annual reproduction and survival rates.
W.

Impacts to Populations — As we have concluded that individual SWP are likely to be killed or
experience some reductions in their annual or lifetime reproductive success, we need to assess
the aggregated consequences of the anticipated losses of the exposed individuals on the
population to which these individuals belong.
Two colonies of SWP, Seneca and MNF containing 24 and 3 individuals (i.e., stems),
respectively, were found during surveys of the action area and represent individual populations.
A SWP colony of 4 individuals was found outside of the action area, approximately 0.3 mile
away from the MNF colony (Allstar Ecology 2016a, 2016b; ERM 2017; VHB 2017), and is
considered part of the MNF population because the 2 are less than the 0.62 mile (1 km)
minimum separation distance for an "element occurrence" or population, as defined by
NatureServe (2002). We expect that multiple project subactivities (Appendix B Table 1) will
permanently affect the Seneca population because of the permanent habitat alteration and
degradation of the population's upslope drainage and long-term changes in sunlight regime. We
anticipate that the long-term viability of the Seneca population will be reduced significantly due
to decreased fitness, reproductive output, and death of individual SWP and the population will
have a lower number of SWP individuals permanently, but will likely not be extirpated. A
portion of the MNF population (43%) will be temporarily affected by the subactivities in the
construction ROW (Appendix B Table 1). For the MNF population, we anticipate a long-term
reduction in fitness and reproductive success until the temporary construction ROW is restored
and permanent vegetation, including shrubs and mid -story trees, is established. The affected
populations represent 25% of all documented SWP populations in WV.
Impacts to Species — As we have concluded that populations of SWP are likely to experience
reductions in their fitness or mortality, we need to assess the aggregated consequences of the
anticipated losses and reductions in fitness of the exposed populations on the species as a whole.
To understand the consequences of population -level effects at the species level, we need to
understand the RND needs of the species. To meet the recovery objectives of SWP, the
following must be met: 1) a minimum of 61 sites (or populations) (75% of number of sites
known in 1992) must be permanently protected and distributed proportionately among the 3
geographic centers and the outliers; 2) these sites must represent at least 75% of the known self-
sustaining, viable populations as determined at the time of reclassification, including a total of 20
sites having 80 stems or more (self-sustaining, viable population defined as showing a geometric
mean of 20 emergent stems, over a 10 -year period); 3) establishment of appropriate habitat
management programs for occupied SWP habitat or protection of sufficient amount of
unoccupied habitat adjacent to existing populations (Service 1992). The rangewide status of
SWP is considered stable (Service 2008). As of 2007, 150 extant SWP populations were
documented rangewide; however few SWP populations are monitored annually and some
populations may only be visited once every 5 to 10 years, therefore it is difficult to fully assess
population viability. Since 2007, 6 additional populations have been found in WV, thus the total
rangewide is approximately 156 SWP populations.
The proposed action is anticipated to cause a long-term reduction in fitness of 1 population and
permanent reduction in fitness of 1 population, affecting 1.3% of SWP populations rangewide.
Due to the presence of 156 populations throughout its range, the reduced fitness of 2 populations
39

is not anticipated to change the status of the species.
Running Buffalo clover
Impacts to Individuals — The proposed action includes multiple subactivities (Appendix B Table
2) that will result in mortality of RBC individuals and will permanently alter and/or destroy RBC
habitat. As discussed in the Effects of the Action, ground disturbance, tree clearing and
trimming, and burning subactivities will kill individual plants. Additionally, these activities will
permanently alter and degrade habitat such that conditions are no longer favorable for RBC re-
establishment. Elimination of canopy cover which modifies the amount of sunlight reaching
individual plants may reduce seed production and germination of some individuals and may lead
to mortality of others. The increase in sunlight may also increase competition from invasive
species which can outcompete RBC, prohibiting growth of individual plants. ORV traffic on
improved access roads and the construction ROW will exceed disturbance frequencies tolerated
by RBC and prevent re-establishment of RBC to some of the disturbed areas. Increased ease of
access by white-tailed deer and the resulting herbivory will kill some RBC and lower
reproductive output of other RBC. In summary, there will be impacts to individual RBC survival
and fitness.
Impacts to Populations — As we have concluded that individual RBC are likely to experience
mortality due to the proposed action, we need to assess the aggregated consequences of the
anticipated losses of the exposed individuals on the populations to which these individuals
belong.
Six populations of RBC, each consisting of multiple occurrences, will be affected by the
proposed action (Appendix B Table 2). The loss of individuals from these occurrences will cause
a reduction in fitness to 5 of the 6 affected populations; the remaining population will experience
mortality as all individuals and occurrences will be killed due to project subactivities. There are
approximately 5.1 acres of RBC within 150 ft of the construction ROW centerline and 0.8 acres
will be directly affected and killed as a result of the action (FERC 2017).
Impacts to Species — As we have concluded that RBC populations are likely to experience
reductions in their fitness and mortality, we need to assess the aggregated consequences of the
anticipated losses of the exposed populations on the species as a whole. To understand the
consequences of population -level effects at the species level, we need to understand the RND
needs of RBC. To meet the goal of recovery of RBC, at least 34 populations, in total, must be
distributed as follows: 2 A -ranked, 6 B -ranked, 6 C -ranked, and 20 D -ranked populations across
at least 2 of the 3 regions in which RBC occurs (Appalachian, Bluegrass, and Ozark) (Service
2017). The rangewide status of the species is considered stable/improving with 152 healthy
populations across all 3 regions (16 A -ranked, 35 B -ranked, 42 C -ranked, and 59 D -ranked) and
15% of these occur on protected lands (Service 2017). With the addition of the populations found
during surveys for the proposed action, there are 160 RBC populations rangewide.
This proposed action will cause a reduction in fitness of 5 populations due to mortality of some
individuals from some occurrences that make up these populations and will result in the loss of 1
population. There are approximately 5.1 acres of RBC within 150 ft of the construction ROW
centerline and 0.8 acres will be directly affected and killed (FERC 2017). The 6 affected
M

populations represent 9.1% of RBC populations in WV and 3.75% of RBC populations
rangewide. Due to the presence of 160 populations throughout its range, the reduced fitness of 5
populations and mortality of 1 population is not anticipated to change the status of the species.
As part of the proposed action, a 400 -acre property containing part of an RBC population
(approximately 50,000 rooted crowns) has been obtained and will be protected in perpetuity.
This property will not be adversely affected by the proposed action. It will be enhanced for RBC
by managing and treating invasive species, removing trees to provide more filtered sunlight, and
providing periodic soil disturbance (e.g., disking, tractor tilling, and harrow rake digging)
(AllStar Ecology 2017). Initial habitat enhancements will be monitored for a period of 5 years,
which includes monitoring of existing populations. Protecting part of a RBC population is not
anticipated to change the status of the species rangewide.
Roanoke logperch
Impacts to Individuals — The proposed action includes trenching, grading,
constructing/improving access roads, and stream and wetland crossings. As discussed in the
Effects of the Action, effects to individual RLP are expected to include injury or death from
installation and dewatering of cofferdams, installation of the bridge center supports and blasting,
if it occurs. Additionally, a temporary reduction in feeding or reproducing is expected as a result
of either temporarily preventing access to a foraging or spawning area or altering habitat through
the introduction of sediments, cofferdams, or bridge center supports such that the habitat is
unsuitable for foraging or spawning. In response to sediment plumes, most RLP are anticipated
to cease feeding or breeding activities and move to clearer water until sediment levels return to
background levels. In particular, we expect spawning will be delayed or inhibited at Waqua and
Sturgeon Creeks due to the installation of the bridge center supports during the RLP breeding
period. Individuals will expend more energy to seek out different foraging and spawning areas. A
TOYR (March 15 - June 30) to protect RLP during their spawning season will be implemented at
Butterwood Creek and Nottoway River 1, which will minimize the potential for effects from
sedimentation. Permanent removal of riparian vegetation is expected to decrease fitness of a
small portion of RLP individuals. In summary, there will be impacts to individual RLPs in their
annual reproduction and survival rates.
Impacts to Populations — As we have concluded that individual RLP are likely to be killed or
experience some reduction in their annual reproductive success, we need to assess the aggregated
consequences of the anticipated losses of the exposed individuals on the population to which
these individuals belong.
We expect that the population level impacts from injury, death, and spawning disruption to the
RLP will be relatively small because the proposed action affects a small number of individuals in
0.8% of the RLP habitat within the Nottoway River drainage, which is a small portion (0.16%)
of the entire range of the species. Following completion of each action that results in adverse
effects to RLP, we expect that the RLP population, given no other major stressors, will recover
within 1-3 years assuming that most RLP in the action area experience temporary impacts.
Similarly, habitat impacts are minor compared to the overall amount of RLP habitat available.
The effects of the proposed action are expected to be primarily temporary; in general, RLP
habitat will recover to a suitable condition following temporary impacts; and RLP are expected
41

to continue to occupy waterways within the action area. Therefore, we conclude that the effects
from the proposed action do not pose a significant risk to the RLP and will not result in
permanent population declines.
Impacts to Species — As we have concluded that populations of RLP are unlikely to experience
reductions in their fitness, there will be no harmful effects (i.e., there will be no reduction in
RND) on the species as a whole.
Clubshell
Impacts to Individuals — The proposed action includes multiple subactivities (Appendix B Table
4) that are ground disturbing and will result in sediment entering tributaries to Hackers Creek. As
discussed in the Effects of the Action, potential effects of the action include effects to all
individuals in the Hackers Creek clubshell population. Effects from sedimentation will impair
feeding of individual mussels and degrade and alter habitat. Impaired feeding is anticipated to
result in reduced physiological function; depressed rates of growth, reproduction, and
recruitment; and ultimately mortality of a few individuals. Additionally, sedimentation may
permanently alter and degrade habitat through siltation such that conditions are no longer
favorable for clubshell. These effects will persist until high flows flush settled sediment
downstream. We anticipate these changes in habitat will further impair feeding, resulting in
sublethal effects on growth and reproduction or starvation with long-term exposure, affecting a
majority of individual mussels. In summary, there will be impacts to individual clubshell
survival and fitness as a result of impaired feeding and habitat degradation and alteration.
Impacts to Populations — As we have concluded that individual clubshell are likely to experience
mortality due to the proposed action, we need to assess the aggregated consequences of the
anticipated losses of the exposed individuals on the populations to which these individuals
belong.
There is 1 population of clubshell in Hackers Creek. As a result of sedimentation, decreased
water quality, and degraded and altered habitat we anticipate the Hackers Creek clubshell
population will experience impaired feeding. When high flows continue to flush sediment
downstream, we expect that within 6 months post -construction the habitat will begin to return to
pre -construction conditions. At that time, the remaining mussels will be able to feed in an
unimpaired manner. However, the population will remain below pre -construction numbers.
Impacts to Species — As we have concluded that I population of clubshell is likely to experience
reductions in its fitness and mortality, we need to assess the aggregated consequences of the
anticipated loss of the exposed population on the species as a whole. To understand the
consequences of population -level effects at the species level, we need to understand the RND
needs of the species.
In brief, the clubshell recovery criteria (Service 1994) are:
1. Viable populations must be established in 10 separate drainages (Tippecanoe River, IN;
East Fork West Branch St. Joseph River, MI/OH; Fish Creek, IN/OH; Green River; KY;
Little Darby Creek, OH; Elk River, WV; French Creek, PA; Allegheny River, PA; plus
two additional drainages).
42

2. Each of the 10 populations must be large enough to survive a single adverse ecological
event.
3. The populations and their drainages must be permanently protected from all foreseeable
and controllable threats, both natural and anthropogenic.
The rangewide status of the species is considered declining. Throughout its range, there are 13
populations of clubshell occupying 21 streams (Service 2008). This includes more than 1 million
individuals (Villella 2007). However, only 7 of these populations show evidence of reproductive
success, none of which occur in WV (Service 2008). Clubshell populations exist in 3 river
systems in WV: the Monongahela, Kanawha, and Ohio Rivers. The Hackers Creek population is
the only remaining population in the Monongahela River system.
The proposed project is anticipated to adversely impact the Hackers Creek population; however,
this population is not in one of the specified drainages listed in Recovery Criteria 1 nor is it
likely to be part of the 2 unspecified additional drainages. The reduction in fitness of the Hackers
Creek population will not prevent meeting the Recovery Criteria. Therefore, we conclude that
this project will not reduce the likelihood of survival and recovery of the clubshell.
Rusty patched bumble bee
Impacts to Individuals — As discussed in the Effects of the Action, anticipated effects of the
action include effects to individual RPBBs present within the HPZ year-round. Effects include
reduced reproductive success of queens as a result of removal of spring ephemerals and other
floral resources, and injury or death of individual workers or queens during the active season as a
result of crushing by machinery during vegetation removal and construction in the construction
ROW.
In response to removal of floral resources, the following season RPBB workers will be displaced
and expend more energy to seek out nearby available foraging areas and experience reduced
survival as a result of the decrease in food availability. Consequently, there will be impacts to
annual survival rates of a small percentage of individual RPBB workers. Individual worker bees
are responsible for supporting the reproductive success of the colony by providing food
resources to the queen. The health of the colony is dependent on the number of workers foraging
and providing resources. This is reflected by the higher likelihood of colony collapse associated
with haplodiploidy, when 50% of the workers are replaced by diploid males that do not
contribute food resources to the colony. Loss of a percentage of RPBB workers will reduce the
reproductive success of the queen (i.e., not as many foundress queens produced) as a result of
loss of foraging resources provided by workers.
Overwintering queens may be found within the HPZ. The access road surface is not suitable
overwintering habitat due to soil compaction; however, suitable habitat exists alongside the
access road. Widening and improvements will impact approximately 3 m of potentially suitable
overwintering habitat on either side of the existing access road within the HPZ. Within the HPZ
(653 ha), the proposed action will impact 7.3 ha (1.1%) of potentially suitable overwintering
habitat. Because the probability of a queen being located in that 1.1% of potentially suitable
overwintering habitat is unlikely, effects to individual overwintering queens are not anticipated.
43

Impacts to Populations — As we have concluded that a small percentage of individual RPBB are
likely to be killed or experience some reductions in their annual or lifetime reproductive success,
we need to assess the aggregated consequences of the anticipated losses and reductions in fitness
(i.e., reproductive success and long-term viability) of the exposed individuals on the population
to which these individuals belong.
A population of RPBB is represented by the number of successful nests or colonies comprising a
given geographical area, rather than a number of individuals, because a colony is founded by a
single queen and represents 1 reproductive unit (Chapman and Burke 2001, Zayed 2009, Service
2016). As a result of their genetic structure, a RPBB population can only persist on the landscape
in a meta -population structure. A healthy population typically contains many colonies, and loss
of a colony or overwintering queen could reduce the overall viability of any metapopulation
associated with those colonies due to lost opportunities to interbreed and small population
dynamics. Impacts to populations may result from loss of a colony nest through crushing,
crushing overwintering foundress queens, or loss of a percentage of colony workers.
The colony nest associated with the single observed RPBB may be located anywhere within a 0.8
km radius (201 ha) of the observation location (Osborne et al. 1999, Knight et al. 2005, Wolf and
Moritz 2008, Service 2016). Nest density of RPBB is assumed to be approximately 0.14/ha
(Chapman et al 2003 [as cited in Charman et al. 2010], Darvill et al. 2004, Knight et al. 2005,
Kraus et al. 2009, Wolf et al. 2012, Dreier et al. 2014, Wood et al. 2015). There are 201 ha of
suitable nesting habitat in proximity to the observed location; therefore, there may be up to 28
nests (0.14 nests/ha x 201 ha) within 0.8 km of the observed RPBB worker. The proposed action
will affect up to 1.08 ha (1,800 m total access road length x 6 m additional access road width) of
suitable nesting habitat within a 0.8 km radius of the observed location, which represents 0.5%
(1.08 ha/201 ha) of the suitable nesting habitat, and represents the territory of I colony if
colonies are evenly distributed. As a result, there is a 15% (affected nesting area (1.08
ha)/average area utilized by each nest (7 ha) within nesting habitat) likelihood that 1 nest will be
crushed within the 1.08 ha of suitable nesting habitat to be removed. However, due to the
potential presence of an additional 27 colony nests within 0.8 km of the observed RPBB, and the
metapopulation dynamics of RPBB, loss of 1 colony as a result of crushing is not likely to
negatively impact the fitness or survival of the population.
Loss of a small percentage of colony workers may decrease the reproductive success of the
colony as a result of loss of foraging resources provided by workers to the queen (i.e., not as
many foundress queens produced to start new colonies); however, the overall survival of the
original colony is unlikely to be affected. The proposed action will remove 7.3 ha (1.1%) of
suitable habitat within the HPZ. Habitat removed as a result of widening and improving the
access road is likely to be permanently lost; however, the project activities will shift the canopy
opening such that floral resources will develop along the new edge of the access road over time.
There are potentially up to 28 colonies within foraging distance of the HPZ; however, only a
small percentage of foraging bees are expected to be impacted, which may represent a few
individuals from each colony. Impacts to individuals from most colonies will not be
measureable. Nest densities are estimated to be 0.14 nests/ha; therefore, there is likely to be no
more than I nest in direct proximity to the 7.3 ha impacted by the project. Effects to 1 colony are
expected through limited and temporary impacts to reproduction as a result of loss of foraging

habitat. We anticipate a small reduction in the reproductive capacity of queens associated with
colonies within average foraging distance (0.8 km) of the proposed action, as a result of
decreased foraging ability of workers. However, due to the metapopulation dynamics of RPBB,
limited indirect impacts to ability of queens associated with 1 colony to produce workers and
foundress queens are not likely to negatively impact the fitness or survival of the population.
Impacts to Species — As we have concluded that populations of RPBB are unlikely to experience
reductions in their fitness, there will be no harmful effects (i.e., there will be no reduction in
RND) on the species as a whole.
Madison Cave isopod
Impacts to Individuals — The proposed action includes trenching, blasting, grading,
constructing/improving access roads, and wetland crossings. As discussed in the Effects of the
Action, potential effects of the action include effects to MCI present within the action area
during construction. Individuals will need to expend more energy to seek out different travel
corridors, food sources, or mates. Effects include a temporary reduction in feeding or
reproducing as a result of either a potentially blocked travel corridor or the need to shift from an
area where MCI could be feeding or reproducing. Depending on the severity of the impact, some
individuals are likely to die from crushing or smothering if they do not move from the area
quickly. However, the AMMs (enhanced sediment and erosion control measures) will minimize
the potential for direct and indirect effects from sedimentation. In summary, there will be
impacts to individual MCIs in their annual survival rates.
Impacts to Populations — As we have concluded that individual MCIs are likely to be killed or
experience some reduction in their annual reproductive success, we need to assess the aggregated
consequences of the anticipated losses of the exposed individuals on the population to which
these individuals belong.
No documented MCI localities occur in the proposed construction ROW centerline or ATWS;
however, we consider Cochran's Cave an undocumented MCI locality. Documented localities
represent a sampling point where MCI were captured. For this analysis we are using localities as
a surrogate for a population.
Limited information exists on the connectivity of MCI populations, preventing an understanding
of how impacts at a given site may relate to populations. Sites that are be impacted could be
rapidly recolonized if the site was part of a larger population, or they could be eliminated with
little chance of subsequent recolonization if not part of a larger population.
We expect decreased fitness of the Cochran's Cave MCI population. A total of 896.7 surface
acres of MCI potential habitat is within 0.5 mile of the construction ROW centerline and ATWS
that bisect Cochran's Cave. Within that area, the construction ROW centerline and ATWS bisect
the Cochran's Cave Conservation Site, including the vertical entrance to the cave, totaling 11.2
surface acres of disturbance. While the AMMs provided in the FEIS (FERC 2017) will
ameliorate much of the adverse effects, they will not be completely effective in preventing all
sediment from entering the phreatic water. Additionally, the AMMs cannot completely prevent
shifts in surface and sub -surface formations and hydrology from trenching, digging, or blasting.
45

Sudden shifts in subterranean structures are likely to crush or trap MCIs, alter their travel
corridors, or isolate portions of the population. We anticipate a reduction in the fitness of this
undocumented population.
Impacts to Species — As we have concluded that 1 undocumented population of the MCI is likely
to experience a reduction in fitness, we need to assess the aggregated consequences of the
anticipated reductions in fitness of the exposed population on the species as a whole.
To understand the consequences of population -level effects at the species level, we need to
understand the RND needs of the species. In brief, the MCI recovery criteria (Service 1996) are:
1. Populations of MCI at Front Royal Caverns, Linville Quarry Cave No. 3, and Madison
Saltpeter Cave/Steger's Fissure are shown to be stable over a 10 -year monitoring period.
2. The recharge zone of the deep karst aquifer at each of the population sites identified in
Criterion I is protected from all significant groundwater contamination sources.
3. Sufficient population sites are protected to maintain the genetic diversity of the species.
Protection of newly discovered populations, if any, will be incorporated into this
criterion insofar as they contribute to maintenance of overall genetic diversity.
The rangewide status of the species appears to be stable (Service 2011). The proposed project is
anticipated to adversely impact 1 undocumented population; however, it is unlikely to adversely
impact any of the populations listed in Recovery Criteria 1. The potential reduction in the fitness
of 1 undocumented population will not measurably reduce the species ability to recover.
Therefore, we conclude that this project will not reduce the likelihood of survival and recovery
of the MCI.
Tndiana hat
Impacts to Individuals — The proposed action includes removal of 4,448 acres of Ibat suitable
habitat that is likely to cause pregnant females to expend energy when required to alter their
travel corridors, and as a result give birth to smaller sized pups with a lower likelihood of
survival. While a pup might die as a result of being born small, it is not expected given the low
likelihood that maternity roost trees are in the action area. Tree removal may fragment the habitat
such that individual Ibats traveling through the area will be more vulnerable to predation,
resulting in injury or death. Tree clearing is likely to make the remaining forest less suitable for
roosting or foraging, which will cause Ibats to expend more energy searching for alternative
roosting or foraging sites resulting in impacts to individual Ibats in their annual survival rates.
We expect most effects from tree removal will occur during spring staging or fall swarming to
individual Ibats that hibernate in Starr Chapel, Breathing, or Clark's Caves, which were known
hibernacula with documented Ibats in the 2017 winter surveys. No direct effects are anticipated
but individual Ibats may be temporarily harmed (reduced overwinter survival or reproductive
success) by loss of spring staging/fall swarming habitat. Bats travel between hibernacula during
fall swarming to mate and likely assess the relative suitability of potential hibernation sites
(Brack et al. 2005). Effects to individual Ibats could be minor such as a slight shift in
roosting/foraging areas or more significant such as delayed mating in the fall or fertilization in
the spring. Bats born earlier in the year have a greater chance of surviving their first winter and
breeding in their first year of life (Frick et al. 2010). Removing some of the roosting/foraging
we

habitat is likely to delay the birth of a small number of Ibats, thereby decreasing their odds of
surviving.
Impacts to Populations — As we have concluded that individual Ibats are likely to experience
some reduction in their lifetime survival or reproductive success, we need to assess the
aggregated consequences of the anticipated reductions in fitness of the exposed individuals on
the population to which these individuals belong.
Individuals using the known use spring staging/fall swarming habitat at 3 hibernacula will be
affected. The effects are not expected to measurably decrease the fitness of the hibernating
populations. Any removal of trees within the known use spring staging/fall swarming habitat will
occur during the winter when bats are hibernating, which will limit disrupting fall swarming or
spring staging activities and will avoid directly killing Ibats. Further, not every That from the 3
hibernacula will be exposed to stressors associated with tree clearing because effects are to a
small portion of the known use spring staging/fall swarming habitat around each hibernaculum.
Acres of trees removed around the 3 hibernacula are as follows: Star Chapel Cave 96 acres
(0.2% of known spring staging/fall swarming habitat); Breathing Cave 189 acres (0.5% of
known spring staging/fall swarming habitat), and Clarke's Cave 141 acres (0.3% of known
spring staging/fall swarming habitat) (see Table 4.7.1-7, page 4-265 of the FEIS for details
[FERC 2017]). We anticipate limited effects during the first spring after tree clearing as bats
emerge from hibernation. We anticipate most effects will occur during the first fall swarm after
tree clearing. Bats are expected to acclimate to this change and shift to alternative habitat within
the known use spring staging/fall swarming habitat. All effects are expected to be limited and
short-term in nature. We do not expect a long-term reduction in any hibernating populations
because the That is adapted to ephemeral environments and a significant portion of the known use
spring staging/fall swarming habitat will remain. The effects from the proposed action will not
result in permanent population declines.
Impacts to Species — As we have concluded that populations of Ibats are unlikely to experience
reductions in their fitness, there will be no harmful effects (i.e., there will be no reduction in
RND) on the species as a whole. Additionally, as part of the proposed action, a 400 -acre property
containing 10 caves and 396 acres of forest that will not be affected by the action has been
obtained and will be protected in perpetuity. The property will be improved and enhanced for
bats through installation of watering/foraging pools, snag creation, and erection of artificial roost
structures (bat boxes). Ibats have not been detected in any of these caves as of the date of this
Opinion, but protection of this site may benefit Ibats in the future.
Northern long-eared bat
Impacts to Individuals — The majority of impacts to NLEB have been previously addressed in the
Service's January 5, 2016 programmatic biological opinion implementing the final 4(d) rule.
Some effects to NLEB associated with impacts to habitat surrounding hibernaculum PH -S018
have not. The proposed action includes the permanent removal of 170.94 acres of forest around a
NLEB known hibernaculum; 0.4 acres are not addressed by the programmatic opinion. This area
may be used as roosting/foraging habitat in the fall or spring or by maternity colonies. No direct
effects are anticipated but individual NLEB may be temporarily affected by loss of fall
swarming, spring staging, and summer habitat resulting in reduced overwinter survival or
47

reproductive success.
Impacts to Populations — As we have concluded that individual NLEB are likely to experience
some reduction in their lifetime survival or reproductive success, we need to assess the
aggregated consequences of the anticipated reductions in fitness of the exposed individuals on
the population to which these individuals belong.
Bats are expected to acclimate to this permanent habitat removal by shifting to alternative
habitat. All impacts are expected to be limited and short-term in nature. We do not expect a long-
term reduction in the PH -S018 population or potential maternity colony because the NLEB is
adapted to ephemeral environments and a significant portion of the spring staging/fall swarming
winter habitat or potential maternity colony habitat will remain. Therefore, we conclude that the
effects from the proposed action will not result in permanent population declines.
Impacts to Species — As we have concluded that populations of NLEB are unlikely to experience
reductions in their fitness, there will be no harmful effects (i.e., there will be no reduction in
RND) on the species as a whole. Additionally, as part of the proposed action, a 400 -acre property
containing 10 caves and 396 acres of forest that will not be affected by the action will be
protected in perpetuity. The property will be improved and enhanced for bats through installation
of watering/foraging pools, snag creation, and erection of artificial roost structures (bat boxes).
NLEBs have not been detected in any of these caves as of the date of this Opinion, but protection
of this site may benefit NLEBs in the future.
CONCLUSION
Small whorled pogonia — We considered the current overall stable status of the SWP and the
similar condition of the species within the action area (environmental baseline). We then
assessed the effects of the proposed action and the potential for cumulative effects in the action
area on individuals, populations, and the species as a whole. These types of effects of the
proposed action are currently considered primary factors influencing the status of the species.
While the proposed action may compound those factors, as stated above, we do not anticipate
any reductions in the overall RND of the SWP. It is the Service's Opinion that authorization to
construct and operate the pipeline, as proposed, is not likely to jeopardize the continued
existence of the SWP.
Running Buffalo clover — We considered the current overall stable/improving status of RBC and
the similar condition of the species within the action area (environmental baseline). We then
assessed the effects of the proposed action and the potential for cumulative effects in the action
area on individuals, populations, and the species as a whole. These types of effects of the
proposed action are currently considered primary factors influencing the status of the species.
While they may compound those factors, as stated above, we do not anticipate any reductions in
the overall RND of RBC. It is the Service's Opinion that authorization to construct and operate
the pipeline, as proposed, is not likely to jeopardize the continued existence of RBC.
Roanoke log=perch — We considered the current overall improving status of the RLP and the
stable condition of the species within the action area (environmental baseline). We then assessed

the effects of the proposed action and the potential for cumulative effects in the action area on
individuals and populations, and the species as a whole. These types of effects of the proposed
action are not currently considered primary factors influencing the status of the species. While
they may compound those factors, as stated above, we do not anticipate any reductions in the
overall RND of the RLP. It is the Service's Opinion that authorization to construct and operate
the pipeline, as proposed, is not likely to jeopardize the continued existence of the RLP.
Clubshell — We considered the current overall declining status of clubshell and the similar
condition of the species within the action area (environmental baseline). We then assessed the
effects of the proposed action and the potential for cumulative effects in the action area on
individuals, populations, and the species as a whole. These types of effects of the proposed
action are currently considered primary factors influencing the status of the species. While they
may compound those factors, as stated above, we do not anticipate any reductions in the overall
RND of the species. It is the Service's Opinion that authorization to construct and operate the
pipeline, as proposed, is not likely to jeopardize the continued existence of the species.
Rusty patched bumble bee — We considered the current overall declining status of the RPBB and
the unknown condition of the species within the action area (environmental baseline). We then
assessed the effects of the proposed action and the potential for cumulative effects in the action
area on individuals, populations, and the species as a whole. These types of effects of the
proposed action are not currently considered primary factors influencing the status of the species.
While they may compound those factors, as stated above, we do not anticipate any reductions in
the overall RND of the RPBB. It is the Service's Opinion that authorization to construct and
operate the pipeline, as proposed, is not likely to jeopardize the continued existence of the
RPBB.
Madison Cave isopod — We considered the current overall stable status of the MCI and the
similar condition of the species within the action area (environmental baseline). We then
assessed the effects of the proposed action and the potential for cumulative effects in the action
area on individuals, populations, and the species as a whole. These types of effects of the
proposed action are currently considered primary factors influencing the status of the species.
While the proposed action may compound those factors, as stated above, we do not anticipate
any reductions in the overall RND of the MCI. It is the Service's Opinion that authorization to
construct and operate the pipeline, as proposed, is not likely to jeopardize the continued
existence of the MCI.
Indiana bat — We considered the current overall declining status of the That and the similar
condition of the species within the action area (environmental baseline). We then assessed the
effects of the proposed action and the potential for cumulative effects in the action area on
individuals, populations, and the species as a whole. These types of effects of the proposed
action are currently considered primary factors influencing the status of the species. While they
may compound those factors, as stated above, we do not anticipate any reductions in the overall
RND of the Ibat. It is the Service's Opinion that authorization to construct and operate the
pipeline, as proposed, is not likely to jeopardize the continued existence of the Ibat.
Northern long-eared bat — We considered the current overall declining status of the NLEB and
IRI

the similar condition of the species within the action area (environmental baseline). We then
assessed the effects of the proposed action and the potential for cumulative effects in the action
area on individuals, populations, and the species as a whole. These types of effects of the
proposed action are currently considered primary factors influencing the status of the species.
While they may compound those factors, as stated above, we do not anticipate any reductions in
the overall RND of the NLEB. It is the Service's Opinion that authorization to construct and
operate the pipeline, as proposed, is not likely to jeopardize the continued existence of the
NLEB.
INCIDENTAL TAKE STATEMENT
Section 9 of the ESA and federal regulation pursuant to Section 4(d) of the ESA prohibit the take
of endangered and threatened species, respectively, without a special exemption. Take is defined
as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to
engage in any such conduct. Harm is further defined by the Service to include significant habitat
modification or degradation that results in death or injury to listed species by significantly
impairing essential behavioral patterns including breeding, feeding, or sheltering (50 CFR §
17.3). Harass is defined by the Service as intentional or negligent actions that create the
likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior
patterns, which include, but are not limited to, breeding, feeding, or sheltering (50 CFR § 17.3).
Incidental take is defined as take that is incidental to, and not the purpose of, the carrying out of
an otherwise lawful activity. Under the terms of Section 7(b)(4) and Section 7(0)(2), taking that
is incidental to and not intended as part of the agency action is not considered to be prohibited
taking under the ESA provided that such taking is in compliance with the terms and conditions of
this incidental take statement.
The measures described below are nondiscretionary, and must be undertaken by the FERC so
that they become binding conditions of any grant or permit issued to the applicant, as
appropriate, for the exemption in Section 7(0)(2) to apply. The FERC has a continuing duty to
regulate the activity covered by this incidental take statement. If the FERC: (1) fails to assume
and implement the terms and conditions or (2) fails to require the applicant to adhere to the terms
and conditions of the incidental take statement through enforceable terms that are added to the
permit or grant document, the protective coverage of Section 7(0)(2) may lapse. To monitor the
impact of incidental take, the FERC must report the progress of the action and its impact on the
species to the Service as specified in the incidental take statement [50 CFR 402.14(1)(3)].
On January 14, 2016, the Service published a final species-specific rule pursuant to Section 4(d)
of the ESA for the NLEB (50 CFR § 17.40(0)), which became effective February 16, 2016. The
Section 4(d) rule defines prohibited take of the NLEB, which is limited to certain circumstances
and activities within the full suite of prohibitions otherwise applicable to threatened species
under 50 CFR § 17.31. The majority of incidental take of the NLEB that may occur from the
proposed action is not considered prohibited take under the NLEB 4(d) rule. Therefore, that
taking does not require exemption from the Service. However, any incidental take associated
with impacts to 0.4 acres of habitat removal within 0.25 miles of a hibernaculum is addressed
below.
50

Section 7(b)(4) and 7(0)(2) of the ESA generally do not apply to listed plants species. However,
limited protection of listed plants from take is provided to the extent that the ESA prohibits the
removal and reduction to possession of federally listed endangered plants or the malicious
damage of such plants on areas under federal jurisdiction, or the destruction of endangered plants
on non-federal areas in violation of State law or regulation or in the course of any violation of a
State criminal trespass law.
AMOUNT OR EXTENT OF TAKE ANTICIPATED
The Service analyzed the effects to the species above.
Roanoke logperch — To estimate incidental take, we calculated the area of RLP habitat at each
crossing (i.e., wetted width of the waterbody by the total of the construction ROW width and the
1,000 m stream length at each crossing) as follows: Butterwood Creek (8 m)(26 m + 1,000 m) _
8,208 m2; Sturgeon Creek (8 m)(38 m + 1,000 m) = 8,304 m2; Nottoway River 1 (22 m)(38 m +
1,000 m) = 22,836 m2; and Waqua Creek (8 m)(27.4 m + 1,000 m) = 8,219.2 m2. Total = 47,564
m2. Then we calculated the subset of the action area (i.e., wetted width of the waterbody by the
construction ROW width) for cofferdam and bridge center support placement and removal:
Butterwood Creek (8 m x 26 m) = 208 m2; Sturgeon Creek (8 m x 38 m) = 304 m2; Nottoway
River 1 (22 m x 38) = 836 m2; and Waqua Creek (8 m x 27.4 m) = 219.2 m2. Total = 1,567.2 m2.
Effects from cofferdam and bridge center support placement and removal comprise
approximately 3.3% [(1,567.2 m2/47,564 m2)(100)] of the action area. The anticipated take is
described in Table 5 below.
Table 5. RLP amount and type of anticipated incidental take.
Species
Amount of Take
Life Stage
Type of
Take is Anticipated as a Result of
Anticipated
when Take
Take
is
Anticipated
RLP
5
Adults or
Injury
Crushing due to installation and removal of
juveniles
or Kill
cofferdams and bridge center support (i.e., 3.3%
of the action area x 150 RLP in action area).
RLP
145
Adults or
Harm or
Sedimentation and subsequent habitat alteration
juveniles
Harass
from cofferdam dewatering and upland
construction activities.
Clubshell — The Service anticipates incidental take of clubshell will be difficult to detect for the
following reason: up to 70% of a population can be distributed below the substrate surface.
However, the following level of take of this species can be anticipated by loss of habitat from
130 m downstream to 455 m upstream of Life's Run Bridge (County Route 14) (total of 585 m)
because this area contains suitable clubshell habitat. The anticipated take is described in Table 6
below.
Table 6. Clubshell amount and type of anticipated incidental take.
Species
Amount of Take
Life Stage
Type of
Take is Anticipated as a Result of
Anticipated
when Take
Take
is
Anticipated
Clubshell
Small percent of
Adults
Kill
Mortality of a few individuals from
51

Rusly patched bumble bee — The Service anticipates incidental take of RPBB will be difficult to
detect for the following reasons: species has small body size, losses may be masked by seasonal
fluctuations in numbers and other environmental factors, and species occurs in habitat (i.e.,
underground) that makes detection difficult. However, the following level of take of this species
can be anticipated by loss of 7.3 ha in the HPZ because this area contains suitable RPBB habitat.
The anticipated take is described in Table 7 below.
Table 7. RPBB amount and type of anticipated incidental take.
Species
individuals present
Life Stage
when Take is
Anticipated
Type of
Take
sedimentation.
RPBB
within 585 m
Queens
Harm or
Reduced reproduction associated with loss or
Clubshell
Majority of
Adults
Harm or
Impaired feeding as a result of habitat
individuals present
Anticipated
Harass
degradation from sedimentation.
MCI
within 585 m
All
Harm or
Reduced reproduction associated with loss or
Rusly patched bumble bee — The Service anticipates incidental take of RPBB will be difficult to
detect for the following reasons: species has small body size, losses may be masked by seasonal
fluctuations in numbers and other environmental factors, and species occurs in habitat (i.e.,
underground) that makes detection difficult. However, the following level of take of this species
can be anticipated by loss of 7.3 ha in the HPZ because this area contains suitable RPBB habitat.
The anticipated take is described in Table 7 below.
Table 7. RPBB amount and type of anticipated incidental take.
Species
Amount of Take
Anticipated
Life Stage
when Take is
Anticipated
Type of
Take
Take is Anticipated as a Result of
RPBB
Small percent of
Queens
Harm or
Reduced reproduction associated with loss or
individuals from 1
is
Harass
alteration of foraging habitat.
colony present
Anticipated
MCI
within 7.3 ha
All
Harm or
Reduced reproduction associated with loss or
RPBB
1 colony present
Adult
Kill
Crushing due to pipeline construction, vegetation
within 7.3 ha
workers,
removal, and operational vehicle traffic.
males, or
construction.
queen
Madison Cave isopod — The Service anticipates incidental take of the MCI will be difficult to
detect for the following reasons: small body size, finding a dead or impaired specimen is
unlikely, and species occurs in habitat (underground) that makes detection difficult. However,
the following level of take of this species can be anticipated by disturbance of 896.7 surface
acres because this area represents the MCI subterranean habitat within 0.5 mile of the
construction ROW centerline and ATWS that bisects Cochran's Cave Conservation Site; and by
disturbance of 11.2 surface acres because this subset of the 896.7 surface acres represents the
MCI subterranean habitat disturbed by the construction ROW centerline and ATWS. The
anticipated take is described in Table 8 below.
Table 8. MCI amount and type of anticipated incidental take.
Species
Amount of Take
Life Stage
Type of
Take is Anticipated as a Result of
Anticipated
when Take
Take
is
Anticipated
MCI
All individuals
All
Harm or
Reduced reproduction associated with loss or
present within 896.7
Harass
alteration of foraging habitat from sediment
acres
introduced into flooded voids during
construction.
52

MCI ISmall percent of All Kill Crushing or smothering during trenching or
individuals present blasting during construction.
within 11.2 acres
Indiana bat — The Service anticipates incidental take of the Ibat will be difficult to detect for the
following reasons: species has small body size, finding a dead or impaired specimen is unlikely,
and species occurs in habitat (forest and caves) that makes detection difficult. However, the
following level of take of this species can be anticipated by loss of 4,447.982 acres because this
area contains suitable Ibat habitat. To account for differences in Ibat use of the habitat categories
(suitable unoccupied and unknown use habitat vs. known use habitat), a multiplier of 0.5 was
used to estimate Ibat use for suitable unoccupied summer habitat and unknown use spring
staging/fall swarming habitat. The anticipated take is described in Table 9 below.
Table 9. That amount and type of anticipated incidental take.
Species
Amount of Take
Life Stage
Type of
Take is Anticipated as a Result of
Anticipated
when Take
Take
is
Anticipated
That
Small percent of
Adults
Harm,
Reduced reproduction associated with loss or
individuals present
Harass,
alteration of travel corridors; increased
within 1,637.69
Injure,
vulnerability to predation; and decreased habitat
acres of suitable
or Kill
suitability for future roosting and foraging.
unoccupied summer
habitat
Ihat
Small percent of
Adults
Harass
Relocating roosting areas when returning the
individuals present
following season.
within 144.1 acres
of known use
summer habitat
Ihat
Small percent of
Adults or
Harm,
Reduced pup viability associated with loss or
individuals present
pups
Harass,
alteration of spring staging and fall swarming
within 89.05 acres
or Kill
habitat. Reduced overwinter survival associated
of unknown use
with loss of fall swarming habitat. Temporary
spring staging/fall
reduced reproduction associated with loss or
swarming habitat
alteration of fall swarming, spring staging
habitat, and summer roosting/foraging habitat.
Ihat
Small percent of
Adults
Harm,
Reduced pup viability associated with loss or
individuals present
Harass,
alteration of spring staging and fall swarming
within 850.4 acres
or Kill
habitat. Reduced overwinter survival associated
known use spring
with loss of fall swarming habitat. Temporary
staging/fall
reduced reproduction associated with loss or
swarming habitat
alteration of spring staging, fall swarming
habitat, and summer roosting/foraging habitat.
Northern long-eared bat — The majority of effects have been previously addressed in the
Service's January 5, 2016 programmatic biological opinion implementing the final 4(d) rule and
any incidental take further than 0.25 mile from hibernacula PH -SO 18 is not prohibited under the
53

final 4(d) rule (50 CFR § 17.40(0)). The Service anticipates incidental take of NLEB will be
difficult to detect for the following reasons: species has small body size, finding a dead or
impaired specimen is unlikely, and species occurs in habitat (forest and caves) that makes
detection difficult. However, the following level of take of this species can be anticipated by the
loss of 0.4 acres of habitat because this area is within 0.25 miles of hibernacula PH -S018. The
anticipated take is described in Table 10 below.
Table 10. NLEB amount and type of anticipated incidental take.
Species
Amount of Take
Life Stage
Type of
Take is Anticipated as a Result of
Anticipated
when Take
Take
is
Anticipated
NLEB
Small percent of
Adults
Harm
Reduced overwinter survival associated with loss
individuals present
or
of fall swarming habitat. Temporary reduced
within 0.4 acres
Harass
reproduction associated with loss or alteration of
spring staging, fall swarming, and summer
roosting/foraging habitat.
REASONABLE AND PRUDENT MEASURES
The Service believes the following reasonable and prudent measures are necessary and
appropriate to minimize take:
Roanoke logperch —
• Provide information to individuals involved in project construction on how to avoid and
minimize potential effects to the RLP.
• Conduct construction in a manner that minimizes disturbance to RLP.
Clubshell —
• Relocate clubshell.
• Provide information to individuals involved in project construction on how to avoid and
minimize potential effects to the clubshell.
• Implement best management practices to protect water quality.
Rusly patched bumble bee —
• Minimize pre -construction vegetation clearing and ground disturbance.
• Use native species in restoration activities.
• Maintain suitable habitat within the permanent ROW.
Madison Cave isopod —
e Provide information to individuals involved in project construction on how to avoid and
minimize potential effects to the MCI.
Indiana bat —
e Provide information to individuals involved in project construction on how to avoid and
minimize potential effects to the Ibat.
54

Northern long-eared bat —
e The Service believes that all reasonable and prudent measures necessary and appropriate
to minimize take of NLEB have been incorporated into the proposed action.
TERMS AND CONDITIONS
In order to be exempt from the prohibitions of Section 9 of the ESA, the FERC must comply
with the following terms and conditions, which implement the reasonable and prudent measures
described above and outline required reporting/monitoring requirements. These terms and
conditions are nondiscretionary.
Roanoke logperch —
1. Prior to initiation of on-site work, notify all prospective employees, operators, and
contractors about the presence and biology of the RLP, special provisions necessary to
protect the RLP, activities that may affect the RLP, and ways to avoid and minimize
these effects. This information can be obtained by reading RLP -related information in
this Opinion or a fact sheet containing this information can be created and provided by
FERC or the applicant.
2. No riprap will be placed below ordinary high water at any of the 4 crossings
(Butterwood, Waqua, and Sturgeon Creeks and Nottoway River 1) where RLP is
present/assumed present.
3. Construct cofferdams (Butterwood, Waqua, and Sturgeon Creeks and Nottoway River 1)
using non -erodible materials. Remove cofferdams in their entirety upon project
completion.
4. Fill any sandbags used in cofferdams with clean sand and no other materials. All
sandbags must be new with no prior use and must be removed at the time of cofferdam
removal.
5. Build cofferdams to a height, strength, and configuration to resist no less than normal
peak daily flows. All construction must take place outside of the RLP TOYR.
6. Minimize instream (Butterwood, Waqua, and Sturgeon Creeks and Nottoway River 1)
foot traffic during construction.
7. Vehicles or construction equipment may not enter Butterwood, Waqua, and Sturgeon
Creeks and Nottoway River 1, except within cofferdams.
8. Inspect all vehicles for leaks immediately prior to instream or cofferdam work
(Butterwood, Waqua, and Sturgeon Creeks and Nottoway River 1). Repair any leaks and
clean construction vehicles thoroughly to remove any residual dirt, mud, debris, grease,
motor oil, hydraulic fluid, coolant, or other hazardous substances from construction
vehicles. Inspections, repairs, cleaning, and/or servicing will be conducted either before
the vehicle, equipment, or machinery is transported into the field or at the work site
within the staging area. All wash -water runoff and/or harmful materials will be
appropriately controlled to prevent entry into the waterbody, including the riparian zone.
Clubshell —
1. One week prior to any construction activities, search the area 130 in downstream and 455
in upstream of Life's Run Bridge and collect all federally listed freshwater mussels. The
search and collection will be conducted by a qualified surveyor(s) with a valid WVDNR
55

State Collecting Permit for these activities. The permitted surveyor(s) will take all
federally listed mussels found to a Service -approved holding facility. These federally
listed mussels will be held and propagated at the approved facility for reintroduction into
the Monongahela River basin after project construction is completed. Contact the WV
Field Office (WVFO) at elizabeth—[e-mail] regarding Service -approved facilities
and reintroduction details.
2. Prior to initiation of on-site work, notify all prospective employees, operators, and
contractors about the presence and biology of the clubshell, special provisions necessary
to protect the clubshell, activities that may affect the clubshell, and ways to avoid and
minimize these effects. This information can be obtained by reading clubshell-related
information in this Opinion or a fact sheet containing this information can be created and
provided by FERC or the applicant.
3. An EI will be onsite during construction activities within the Hackers Creek HUC-12
watershed between MP 14.7 and 21.1 and will have stop work authority. If compliance
concerns are identified, the EI will resolve them.
4. Fuel and maintain vehicles or equipment and store all potentially toxic substances (fuels,
paints, solvents, lubricants, etc.) within a containment site with adequate buffering
(berms, vegetation, etc.) from any receiving waters of Hackers Creek.
5. Stabilize all disturbed sites and check that all erosion and sedimentation controls are
properly installed and functioning within 24 hours of rain events along the construction
ROW and access roads from MP 14.7 to 21.1.
Rusty patched bumble bee —
1. Minimize pre -construction clearing, grading, and vegetation removal within the HPZ.
2. Re -seed all construction ROW areas (temporary and permanent) within the HPZ and the
dispersal zone with pollinator friendly native seed mixes consistent with
recommendations for plant restoration by GWNF. Include species preferred by RPBB,
list available at:
https://www.fws. gov/midwest/endangered/insects/rpbb/pdf/PlantListRPBBJune20l 7.pdf.
3. In the HPZ, plant disturbed areas adjacent to the improved access road with established
(not seeds) native flowering shrub varieties that will bloom within 3 years. Plant the same
native flowering shrub varieties present within the HPZ.
4. Maintain suitable habitat for RPBB within the permanent ROW through mowing once
every 3 years, as well as woody vegetation removal and select application of herbicide at
a rate sufficient to discourage growth of trees.
Madison Cave isopod —
1. Prior to initiation of on-site work, notify all prospective employees, operators, and
contractors about the presence and biology of the MCI, special provisions necessary to
protect the MCI, activities that may affect the MCI, and ways to avoid and minimize
these effects. This information can be obtained by reading MCI -related information in
this Opinion or a fact sheet containing this information can be created and provided by
FERC or the applicant.
Indiana bat —
1. Prior to initiation of on-site work, notify all prospective employees, operators, and
56

contractors about the presence and biology of the Ibat, special provisions necessary to
protect the Ibat, activities that may affect the Ibat, and ways to avoid and minimize these
effects. This information can be obtained by reading Ibat-related information in this
Opinion or a fact sheet containing this information can be created and provided by FERC
or the applicant.
Northern long-eared bat —
No terms and conditions provided.
MONITORING AND REPORTING REOUIREMENTS
Care must be taken in handling any dead specimens of proposed or listed species to preserve
biological material in the best possible state. In conjunction with the preservation of any dead
specimens, the finder has the responsibility to ensure that evidence intrinsic to determining the
cause of death of the specimen is not unnecessarily disturbed. The finding of dead specimens
does not imply enforcement proceedings pursuant to the ESA. The reporting of dead specimens
is required to enable the Service to determine if take is reached or exceeded and to ensure that
the terms and conditions are appropriate and effective. Upon locating a dead specimen, notify the
Service's VA Law Enforcement Office at 804-771-2883 and the Service's VA Field Office
(VAFO) at the phone number provided below or at 804-693-6694.
Roanoke logperch —
I . Any high water event that disturbs the construction site, including failure or overtopping
of cofferdams, must be reported to the Service at the contact phone number/email address
below within 24 hours.
2. Any spills of motor oil, hydraulic fluid, coolant, or similar fluids, not contained before
entry into the action area, must be reported to the Service at the contact number/email
provided below and National Response Center (800-424-8802) immediately.
3. Conduct a RLP survey and habitat assessment at Butterwood, Waqua, and Sturgeon
Creeks and Nottoway River 1 crossings 6 months after project is complete to assess the
status of the RLP. Survey/habitat assessment will be conducted 200 m upstream and 800
m downstream of each crossing site by a qualified surveyor(s) with a valid VDGIF
Permit for these activities. Provide a report containing raw data and summarized
information from the surveys and habitat assessments at each site to the VAFO at
[e-mail] within 30 days of completion of the survey/habitat assessment.
Clubshell —
1. Notify the WVFO at [e-mail] 2 weeks prior to beginning freshwater
mussel removal upstream and downstream of Life's Run Bridge. Provide a report
documenting the removal effort to the WVFO at [e-mail] within 30 days
of completion of the removal effort. Include the following in the report: surveyor names,
protocols used for surveying, handling, and transporting mussels; total number of
individuals of each mussel species collected; date collected; water and air temperatures;
river stage; condition, size and approximate age of live clubshell; non -listed mussels; and
maps or figures showing the collection area relative to project features.
2. Notify the WVFO at [e-mail] when work begins within the Hackers
57

Creek HUC-12 between MP 14.7 and 21.1.
3. If compliance concerns are identified by the EI regarding construction activities within
the Hackers Creek HUC-12 between MP 14.7 and 21.1, the EI will report these activities
to the WVFO at elizabeth stoutgfws. og_v within 24 hours.
4. If erosion and sedimentation controls fail within the Hackers Creek HUC-12 between MP
14.7 and 21.1 as a result of a precipitation event, the WVFO should be notified within 24
hours at [e-mail].
5. To monitor sedimentation effects on remaining clubshell, measure turbidity 150 in
downstream of and 455 in upstream of Life's Run Bridge (County Route 14). Measure
turbidity downstream and upstream of the mouth of 1 or more tributaries with crossings
approximately 5 in downstream and 5 in upstream of the mouth. Measure turbidity
continuously at least I month prior to construction, through the duration of construction
activities, and I year post -construction or vegetation has become fully established,
whichever happens last. Every 30 days, provide the last 30 days of raw data, and any
summarized data, to the WVFO at [e-mail].
6. Immediately report any unpermitted discharge of any potentially toxic substance to the
WVFO at [e-mail] and WV Department of Environmental Protection
(800-642-3074) upon discovery.
Rusty patched bumble bee —
1. Prior to initiation of vegetation clearing in the HPZ, provide the VAFO, at the email
address below, the limits of equipment and vehicle traffic and staging and the methods to
be used to ensure that traffic and staging will not exceed these limits.
Madison Cave isopod —
The Service believes that all monitoring and reporting has been incorporated into the proposed
action.
Indiana bat —
1. Monitor Ibat activity around Star Chapel, Breathing Cave, and Clark's Cave to determine
effects to Ibats in the fall swarming/spring staging areas. Two weeks prior to the start of
tree clearing place acoustic monitors outside the entrance of each cave. Monitors will
remain in place until 2 hibernating seasons after construction. Provide a report including
the raw acoustic data every year on January 30th to the VAFO at
[e-mail].
Northern long-eared bat —
The Service believes that all monitoring and reporting has been incorporated into the proposed
action.
CONSERVATION RECOMMENDATIONS
Section 7(a)(1) of the ESA directs federal agencies to utilize their authorities to further the
purposes of the ESA by carrying out conservation programs for the benefit of endangered and
threatened species. Conservation recommendations are discretionary agency activities to
minimize or avoid adverse effects of a proposed action on listed species or critical habitat, to

help implement recovery plans, or to develop information.
Small whorled po�onia—
• Conduct 10 years of post -construction monitoring annually (i.e., monitor each colony 1
time each year) during optimal survey timeframes for SWP to assess each colony's status
and any potential threats to its continued success. Monitor the Seneca and MNF SWP
colonies and the 2 SWP colonies immediately outside the action area (second MNF
colony, GWNF colony). Atlantic is working with WVDNR, USFS, and the Service to
fund continuation of monitoring efforts beyond 1 year post -construction. We recommend
FERC verify that a monitoring plan is developed and funded.
• To determine the effectiveness of temporary diversion channels and temporary berms
within the construction workspace located near the SWP colonies, install equipment to
continuously monitor soil moisture and temperature prior to, during, and after
construction (e.g., until the end of the first growing season after restoration activities are
completed). Conduct this monitoring at Seneca and MNF SWP colonies and at a
reference site to establish baseline conditions and take into account local
weather/seasonal variation.
• Monitor ambient light levels prior to, during, and after construction (e.g., until the end of
the first growing season after restoration activities are completed) at the MNF SWP
colony.
• Conduct surveys of suitable SWP habitat in the surrounding area of the Seneca and MNF
SWP colonies and the 2 SWP colonies immediately outside the action area (second MNF
colony, GWNF colony) to determine if additional colonies are present.
Running Buffalo clover —
• Monitor the 8 known RBC populations within and adjacent to the action area and conduct
surveys to locate additional populations.
• Contribute towards seed storage efforts from selected locations, and develop management
agreements that will remain in place if the species was delisted.
Roanoke logperch —
• Fund or conduct riparian and stream restoration throughout the RLP range, especially the
Nottoway River drainage, to limit siltation and nutrient releases into receiving
waterways.
• Fund or conduct projects to identify and remove manmade barriers to fish passage that
will benefit RLP.
Clubshell —
e Provide funding to the WVDNR or other Service -approved facilities to support activities
to determine captive husbandry techniques suitable for propagation and augmentation of
clubshell populations within the Monongahela River system.
Rusty patched bumble bee —
e Improve pollinator habitat throughout the permanent ROW by using pollinator friendly
native seed mixes. Include species preferred by RPBB, list available at:
htlps://www.fws. gov/mi dwest/endangered/insects/rpbb/pdf/PlantListRPBBJune20 l 7.pdf.
59

Madison Cave isopod —
e Fund VDCR-DNH or other qualified and permitted entity to conduct research to improve
knowledge of MCI basic biology and connectivity between documented locations.
Indiana bat —
• Fund research on understanding/controlling and mitigating the effects of WNS.
• Fund research to improve knowledge of Ibat use of suitable habitat in WV and VA.
• Plant native trees with exfoliating bark in the temporary construction ROW to replace
those that were cleared. Contact VAFO (sumalee_hoskinkfws.gov) and WVFO
(elizabeth_stout(cr�,fws. og_v) for area -specific recommendations.
• Purchase or otherwise protect additional That habitat, particularly known use summer
habitat and known use spring staging/fall swarming habitat.
Northern long-eared bat —
e Fund research on understanding/controlling and mitigating the effects of WNS.
For the Service to be kept informed of actions minimizing or avoiding adverse effects or
benefitting listed species or their habitats, the Service requests notification of the implementation
of any conservation recommendations.
REINITIATION NOTICE
This concludes formal consultation on the action outlined in the request. As provided in 50 CFR
402.16, reinitiation of formal consultation is required where discretionary federal agency
involvement or control over the action has been retained (or is authorized by law) and if. (1) the
amount or extent of incidental take is exceeded; (2) new information reveals effects of the
agency action that may affect listed species or critical habitat in a manner or to an extent not
considered in this Opinion; (3) the agency action is subsequently modified in a manner that
causes an effect to the listed species or critical habitat not considered in this Opinion; or (4) a
new species is listed or critical habitat designated that may be affected by the action. In instances
where the amount or extent of incidental take is exceeded, any operations causing such take must
cease pending reinitiation.
Any modifications to the proposed action made since the issuance of the FEIS (FERC 2017)
were not considered as part of this Opinion. The Service strongly recommends that any changes
or modifications to the various construction and restoration plans listed in table 2.3.1-1 of the
FEIS be summarized and provided to the Service to ensure reinitiation is not necessary prior to
commencing work.

If you have any questions regarding this Opinion or our shared responsibilities under the ESA,
please contact Troy Andersen of this office at [phone] or via email at
[e-mail].
Sincerely,
4a�'t' l'
A��+
Cindy Schulz
Field Supervisor
Virginia Ecological Services
Enclosures
cc: Corps, Norfolk, VA (Attn: William Walker)
DOI, Washington, DC (Attn: Erika Vaughan)
FERC, Washington, DC (Attn: Kevin Bowman)
Service, Elkins, WV (Attn: John Schmidt)
Service, Raleigh, NC (Attn: Tom Augspurger)
Service, State College, PA (Attn: Lora Lattanzi)
USFS, Atlanta, GA (Attn: Timothy Abing)
USFS, Elkins, WV (Attn: Kent Karriker)
USFS, Roanoke, VA (Attn: Jennifer Adams)
NCWRC, Raleigh, NC (Attn: Shannon Deaton)
VDACS, Richmond, VA (Attn: Keith Tignor)
VDGIF, Richmond, VA (Attn: Amy Ewing)
VDCR-DNH, Richmond, VA (Attn: Rene Hypes)
WVDNR, Elkins, WV (Attn: Cliff Brown)
ACP, Richmond, VA (Attn: Spencer Trichell)
61

LITERATURE CITED
Introduction
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP 15-554-000, CP 15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Description of Proposed Action
Federal Energy Regulatory Commission. 2013a. Upland erosion control, revegetation, and
maintenance plan. Washington, DC.
Federal Energy Regulatory Commission. 2013b. Wetland and waterbody construction and
mitigation procedures. Washington, DC.
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Status of the Species
SWP
U.S. Fish and Wildlife Service. 2008. Small whorled pogonia (Isotria medeoloides) 5 -year
review: summary and evaluation. New England Field Office, Concord, NH.
RBC
U.S. Fish and Wildlife Service. 2011. Running buffalo clover (Trifolium stoloniferum) 5 -year
review: summary and evaluation. Ohio Field Office, Columbus, OH.
RLP
U.S. Fish and Wildlife Service. 2007. Roanoke logperch (Percina rex) 5 -year review: summary
and evaluation. Virginia Field Office, Gloucester, VA.
Clubshell
U.S. Fish and Wildlife Service. 2008. Clubshell (Pleurobema clava) 5 -year review: summary
and evaluation. Pennsylvania Field Office, State College, PA.
RPBB
U.S. Fish and Wildlife Service. 2016. Rusty patched bumble bee (Bombus affznis) species status
assessment. Twin Cities Ecological Services Field Office, Bloomington, MN.
MCI
U.S. Fish and Wildlife Service. 2011. Biological opinion, Warren County Power Station low
effect habitat conservation plan. Virginia Field Office, Gloucester, VA.
Ibat
62

U.S. Fish and Wildlife Service. 2009. Indiana bat (Myotis sodalis) 5 -year review: summary and
evaluation. Indiana Field Office, Bloomington, IN.
U.S. Fish and Wildlife Service. 2016. Revised programmatic biological opinion for
transportation projects in the range of the Indiana bat and Northern long-eared bat.
Midwest Regional Office, Bloomington, MN.
NLEB
N/A
Environmental Baseline
SWP
Allstar Ecology. 2016a. Atlantic Coast Pipeline, West Virginia interim botanical survey.
Monongahela National Forest, Pocahontas County, WV. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service,
Monongahela National Forest, Elkins, WV; and West Virginia Division of Natural
Resources, Elkins, WV.
Allstar Ecology. 2016b. Atlantic Coast Pipeline, West Virginia botanical survey report. Report to
U.S. Fish and Wildlife Service, West Virginia Field Office, Elkins, WV; U.S. Forest
Service, Monongahela National Forest, Elkins, WV; and West Virginia Division of
Natural Resources, Elkins, WV.
Environmental Resource Management. 2017. Atlantic Coast Pipeline, evaluation of the small
whorled pogonia in the Monongahela and George Washington National Forests and the
Seneca State Forest. Report to U.S. Forest Service, Monongahela National Forest, Elkins,
WV.
U.S. Fish and Wildlife Service. 1992. Small whorled pogonia (Isotria medeoloides) recovery
plan, first revision. Northeast Regional Office, Newton Corner, MA.
Vanasse Hangen Brustlin, Inc. 2016a. Atlantic Coast Pipeline, Virginia segment survey report
for rare, threatened, and endangered plant species. 2016 Field Season. Report to U.S. Fish
and Wildlife Service, Virginia Field Office, Gloucester, VA; Virginia Department of
Conservation and Recreation, Richmond, VA; and U.S. Forest Service, George
Washington National Forests, Roanoke, VA.
Vanasse Hangen Brustlin, Inc. 2016b. Atlantic Coast Pipeline, Virginia segment survey report
for rare, threatened, and endangered plant species. George Washington National Forest -
2016 Field Season. Report to U.S. Fish and Wildlife Service, Virginia Field Office,
Gloucester, VA; Virginia Department of Conservation and Recreation, Richmond, VA;
and U.S. Forest Service, George Washington National Forest, Roanoke, VA.
Vanasse Hangen Brustlin, Inc. 2017. Atlantic Coast Pipeline, revised small whorled pogonia
conservation plan. Report to U.S. Fish and Wildlife Service, West Virginia Field Office,
63

Elkins, WV; U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S.
Forest Service, Monongahela National Forest, Elkins, WV; U.S. Forest Service, George
Washington and Jefferson National Forests, Roanoke, VA; and West Virginia Division of
Natural Resources, Elkins, WV.
RBC
AllStar Ecology. 2015. West Virginia Botanical Survey Report. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; and West Virginia Division of Natural
Resources, Elkins, WV.
AllStar Ecology. 2016. West Virginia botanical survey report. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service, Monongahela
National Forest, Elkins, WV; and West Virginia Division of Natural Resources, Elkins,
WV.
AllStar Ecology. 2017. West Virginia botanical survey report. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service, Monongahela
National Forest, Elkins, WV; and West Virginia Division of Natural Resources, Elkins,
WV.
Environmental Resources Management. 2017. Shapefile of botanical survey results in West
Virginia. Unpublished shapefile to U.S. Fish and Wildlife Service, Elkins, WV.
RLP
Anderson, G.B. 2016. Development and application of a multiscale model of habitat suitability
for Roanoke logperch. Final Report to U.S. Fish and Wildlife Service, Virginia Field
Office, Gloucester, VA.
Environmental Solutions & Innovations, Inc. 2016. Habitat assessments conducted in 2016 for
Roanoke logperch (Percina rex) along the proposed Atlantic Coast Pipeline in Virginia.
Report to U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA.
Environmental Solutions & Innovations, Inc. 2017. Habitat assessments conducted for Roanoke
logperch (Percina rex) along the proposed Atlantic Coast Pipeline in Virginia. Report to
U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA.
Lahey, A.M. and P.L. Angermeier. 2006. Survey for Roanoke logperch in the Roanoke and
Meherrin river drainages, Virginia. Final Report to U.S. Fish and Wildlife Service,
Virginia Field Office, Gloucester, VA. 21 pp.
Lahey, A.M. and P.L. Angermeier. 2007. Range -wide assessment of habitat suitability for
Roanoke logperch (Percina rex). Final Report to Virginia Transportation Research
Council, Charlottesville, VA. 54 pp.
Roberts, J.H. and P.L. Angermeier 2012. Monitoring of endangered Roanoke logperch (Percina
rex) in Smith River upstream from the Philpott Reservoir on U.S. Army Corps of
N

Engineers property near Martinsville, Virginia: U.S. Geological Survey Open -File Report
2012-1221, 11 p.
Roberts, J.H., P.L. Angermeier, and E.M. Hallerman. 2013. Distance, dams and drift: what
structures populations of an endangered, benthic stream fish? Freshwater Biology 58:1-
15.
Virginia Department of Game and Inland Fisheries. 2005. Virginia's comprehensive wildlife
conservation strategy. Virginia Department of Game and Inland Fisheries, Richmond,
VA.
Virginia Fish and Wildlife Information Service. 2017. Species Information [Internet]. Richmond,
VA [cited October 5, 2017]. Available from: htlp://vafwis.org/fwis.
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Anderson, R.M. and D.A. Kreeger. 2010. Potential for impairment of freshwater mussel
populations in DRBC special protection waters as a consequence of natural gas
exploratory well development. Unpublished Report to U.S. Fish and Wildlife Service,
State College, PA; and the Partnership for the Delaware Estuary, Wilmington, DE.
Box, J.M. and J. Mossa. 1999. Sediment, land use, and freshwater mussels: prospects and
problems. Journal of the North American Benthological Society 18:99-117.
Ellis, M.M. 1931. Some factors affecting the replacement of the commercial fresh -water
mussels. U.S. Department of Commerce Bureau of Fisheries. Fishery Circular 7:1-10.
Ellis, M.M. 1936. Erosion silt as a factor in aquatic environments. Ecology 17:29-42.
Environmental Solutions & Innovations, Inc. 2016. Freshwater mussel (Unionidae) surveys for
the proposed Atlantic Coast Pipeline in West Virginia. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV, and West Virginia division of Natural
Resources, Elkins, WV.
Houp, R.E. 1993. Observations on long-term effects of sedimentation on freshwater mussels
(Mollusca: Unionidae) in the North Fork of Red River, Kentucky. Transactions of the
Kentucky Academy of Science 54:93-97.
West Virginia Division of Natural Resources. 2004. Federal Assistance Performance Report:
Endangered Species (Animals). Project E-1, Segment 21 (1 October 2003 — 30 September
2004) Elkins, WV.
West Virginia Division of Natural Resources. 2009. Federal Assistance Performance Report:
Endangered Species (Animals). Project E-1, Segment 36 (1 October 2008 — 30 September
2009) Elkins, WV.
65

West Virginia Division of Natural Resources. 2014. Federal Assistance Performance Report:
Endangered Species (Animals). Project E-1, Segment 31 (1 October 2013 — 30 September
2014) Elkins, WV.
RPBB
Atlantic Coast Pipeline, LLC. 2017. Summary of the rusty patched bumble bee habitat
assessment conducted on the George Washington National Forest. Report to U.S. Fish
and Wildlife Service, Virginia Field Office, Gloucester, VA.
Charman, T.G., J. Sears, R.E. Green, and A.F.G. Bourke. 2010. Conservation genetics, foraging
distance and nest density of the scarce Great Yellow Bumblebee (Bombus distinguendus).
Molecular Ecology 19:2661-2674.
Darvill B., M.E. Knight, and D. Goulson. 2004. Use of genetic markers to quantify bumblebee
foraging range and nest density. Oikos 107:471-478.
Dreier, S., J.W. Redhead, I.A. Warren, A.F.G. Bourke, M.S. Heard, W.C. Jordan, S. Sumner, J.
Wang, and C. Carvell. 2014. Fine -scale spatial genetic structure of common and
declining bumble bees across an agricultural landscape. Molecular Ecology 23:3384-
3395.
Goulson, D. 2010. Bumblebees: behavior, ecology, and conservation. Oxford University Press,
New York, NY.
Knight, M.E., A.P. Martin, S. Bishop, J.L. Osborne, R.J. Hale, A. Sanderson, and D. Goulson.
2005. An interspecific comparison of foraging range and nest density of four bumblebee
(Bombus) species. Molecular Ecology 14:1811-1820.
Kraus, F.B., S. Wolf, and R.F.A. Moritz. 2009. Male flight distance and population substructure
in the bumblebee Bombus terrestris. Journal of Animal Ecology 78:247-252.
Osborne, J.L., S.J. Clark, R.J. Morris, I.H. Williams, J.R. Riley, A.D. Smith, D.R. Reynolds, and
A.S. Edwards. 1999. A landscape -scale study of bumble bee foraging range and
constancy, using harmonic radar. Journal of Applied Ecology 36:519-533.
U.S. Fish and Wildlife Service. 2016. Rusty patched bumble bee (Bombus affznis) species status
assessment. Twin Cities Ecological Services Field Office, Bloomington, MN.
U.S. Fish and Wildlife Service. 2017. Survey protocols for the rusty patched bumble bee
(Bombus affznis). Version 1.2. Twin Cities Ecological Services Field Office,
Bloomington, MN.
Virginia Department of Conservation and Recreation Division of Natural Heritage. 2017. Rusty
patched bumble bee habitat assessment. Report to U.S. Fish and Wildlife Service,
Virginia Field Office, Gloucester, VA.
.P

Wolf, S. and R.F.A. Moritz. 2008. Foraging distance in Bombus terrestris (Hymenoptera:
Apidae). Apidologie 38:419-427.
Wolf, S., T. Toev, R.L.V. Moritz, and R.F.A. Moritz. 2012. Spatial and temporal dynamics of
the male effective population size in bumblebees (Hymenoptera:Apidae). Population
Ecology 54:115-124.
Wood, T.J., J.M. Holland, W.O.H. Hughes, and D. Goulson. 2015. Targeted agri-environment
schemes significantly improve the population size of common farmland bumblebee
species. Molecular Ecology 24:1668-1680.
MCI
GeoConcepts Engineering Inc. 2017a. Karst Survey Report Revision 1 Atlantic Coast Pipeline
Augusta, Bath and Highland Counties VA and Pocahontas and Randolph Counties, WV.
Report to U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S.
Fish and Wildlife Service, West Virginia Field Office, Elkins, WV; and Virginia
Department of Conservation and Recreation Division of Natural Heritage, Richmond VA.
GeoConcepts Engineering Inc. 2017b. Cochran's Cave Conservation Area (CCCA) and Moffett
Lake investigation update. Report to U.S. Fish and Wildlife Service, Virginia Field
Office, Gloucester, VA; U.S. Fish and Wildlife Service, West Virginia Field Office,
Elkins, WV; and Virginia Department of Conservation and Recreation Division of
Natural Heritage, Richmond VA.
Orndorff, W.D. and C.S. Hobson. 2007. Status survey for the Madison Cave isopod (Antrolana
lira) in Virginia, 2005-2007. Natural Heritage Technical Report 07-11. Virginia
Department of Conservation and Recreation, Division of Natural Heritage, Richmond,
VA. 17pp.
Ibat
Environmental Resources Management. 2017a. Atlantic Coast Pipeline, Virginia segment
protected bat species year 3 presence/ likely absence survey report. Report to U.S. Fish
and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S. Forest Service, George
Washington National Forest, Roanoke, VA; and Virginia Department of Game and
Inland Fisheries, Richmond, VA.
Environmental Resources Management. 2017b. Atlantic Coast Pipeline, West Virginia segment
protected bat species year 3 presence/ likely absence survey report. Report to U.S. Fish
and Wildlife Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service,
Monongahela National Forest, Elkins, WV; and West Virginia Division of Natural
Resources, Elkins, WV.
Environmental Resources Management. 2017c. Supply Header Project, West Virginia segment
protected bat species year 3 presence/ likely absence survey report. Report to U.S. Fish
and Wildlife Service, West Virginia Field Office, Elkins, WV and West Virginia
Division of Natural Resources, Elkins, WV.
67

Environmental Resources Management. 2017d. Atlantic Coast Pipeline, West Virginia segment
protected bat species habitat assessment report spring 2017. Report to U.S. Fish and
Wildlife Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service,
Monongahela National Forest, Elkins, WV; and West Virginia Division of Natural
Resources, Elkins, WV.
Environmental Resources Management. 2017e. Atlantic Coast Pipeline, Virginia segment
protected bat species habitat assessment report. Report to U.S. Fish and Wildlife Service,
Virginia Field Office, Gloucester, VA; U.S. Forest Service, George Washington National
Forest, Roanoke, VA; and Virginia Department of Game and Inland Fisheries,
Richmond, VA.
Powers, K.E., R.J. Reynolds, W. Orndorff, W.M. Ford, and C.S. Hobson. 2015. Post -white —nose
syndrome trends in Virginia's cave bats, 2008-2013. Journal of Ecology and the Natural
Environment 7(4):113-123.
Stihler, C.W. 2012. White -nose syndrome a deadly enigma. West Virginia Wildlife Magazine.
Fall/Winter edition. http://www.wvdnr.gov/wildlife/magazine/Archive/12Winter/White-
nose_Syndrome.pdf.
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revision. Midwest Regional Office, Fort Snelling, MN. 258 pp.
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hibernacula.
hLtps://www.fws.gov/midwest/Enda,ngered/mammals/inbL/pdf/inba srvyprtcl.pdf.
U.S. Fish and Wildlife Service. 2017a. Ibat hibernacula data 3-6-2017. Unpublished data.
Indiana Field Office, Bloomington, IN.
U.S. Fish and Wildlife Service. 2017b. Rangewide Indiana bat summer survey guidelines.
htips://www.fws. gov/midwest/endangered/mammals/inba/inbasummersurveyguidance.ht
MI.
NLEB
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Stihler, C.W. 2012. White -nose syndrome a deadly enigma. West Virginia Wildlife Magazine.
Fall/Winter edition. htlp://www.wvdnr.gov/wildlife/magazine/Archive/12Winter/White-
nose_Syndrome.pdf.
Effects of the Action

SWP
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medeoloides population to canopy thinning. Northeastern Naturalist 18(2):185-196.
Burns, R.M. and B.H. Honkala. 1990. Silvics of North America: 1. Conifers; 2. Hardwoods.
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Dibble, A.C. 2000b. Demographic monitoring and habitat manipulation of the small whorled
pogonia, Isotria medeoloides, (Orchidaceae), in New England, U.S.A. Draft manuscript
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Dibble, A.C., W.A. Wright, and C.S. Campbell. 1997. Small whorled pogonia (Isotria
medeoloides): demographic monitoring and habitat manipulation experiment. Report to
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whorled pogonia in the Monongahela and George Washington National Forests and the
Seneca State Forest. Report to U.S. Forest Service, Monongahela National Forest, Elkins,
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Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
McCormick, M.K., D.F. Whigham, and J.P. O'Neill. 2015. Restore the federally threatened
small whorled pogonia (Isotria medeoloides) in three National Park Service regions.
Report to the U.S. National Park Service, Washington, DC.
Vanasse Hangen Brustlin, Inc. 2017. Atlantic Coast Pipeline, revised small whorled pogonia
conservation plan. Report to U.S. Fish and Wildlife Service, West Virginia Field Office,
Elkins, WV; U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S.
Forest Service, Monongahela National Forest, Elkins, WV; U.S. Forest Service, George
Washington and Jefferson National Forests, Roanoke, VA; and West Virginia Division of
Natural Resources, Elkins, WV.
RBC
Burkhart, J.Q., J.S. Rentch, and T.M. Schuler. 2013. Effects of forest management on Running
Buffalo clover (Trifolium stoloniferum, Muhl. ex A. Eaton) distribution and abundance in
the Femow Experimental Forest. Natural Areas Journal 33:156-162.
we

Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Madarish, D. and T.M. Schuler. 2002. Effects of forest management practices on the federally
endangered Running Buffalo clover (Trifolium stoloniferum Muhl. ex A. Eaton). Natural
Areas Journal 22:120-128.
RLP
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
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001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Clubshell
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mussels. Pages 204-211 in J.L. Rasmussen, ed. Proceedings of the symposium on Upper
Mississippi River bivalve mollusks. Upper Mississippi River Conservation Committee,
Rock Island, IL.
RPBB
Atlantic Coast Pipeline, LLC. 2017. Summary of the rusty patched bumble bee habitat
assessment conducted on the George Washington National Forest. Report to U.S. Fish
and Wildlife Service, Virginia Field Office, Gloucester, VA.
Virginia Department of Conservation and Recreation Division of Natural Heritage. 2017. Rusty
patched bumble bee habitat assessment. Report to U.S. Fish and Wildlife Service,
Virginia Field Office, Gloucester, VA.
MCI
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
GeoConcepts Engineering Inc. 2017c. Karst terrain assessment, construction, monitoring and
mitigation plan, Atlantic Coast Pipeline, Randolph and Pocahontas Counties in West
Virginia, and Highland, Augusta, and Nelson counties in Virginia. Report to Dominion
Transmission, Inc. Clarksburg, WV.
Ibat
70

Callahan, E.V. 1993. Indiana bat summer habitat requirements. M.S. Thesis, University of
Missouri, Columbia, MO.
Frick, W.F., D.S. Reynolds, and T.H. Kunz. 2010. Influence of climate and reproductive timing
on demography of little brown myotis Myotis lucifugus. Journal of Animal Ecology
79:128-136.
Gardner, J.E., J.D. Garner, and J.E. Hofmann. 1991. Summary of Myotis sodalis summer habitat
studies in Illinois: with recommendations for impact assessment. Report to Indiana/Gray
bat Recovery Team Meeting, Columbia, MO.
Humphrey, S.R., A.R. Richter, and J.B. Cope. 1977. Summer habitat and ecology of the
endangered Indiana bat, Myotis sodalis. Journal of Mammalogy 58:334-346.
Jachowski, D.S., J.B. Johnson, C.A. Dobony, J.W. Edwards, and W.M. Ford. 2014. Space use
and resource selection by foraging Indiana bats at the northern edge of their distribution.
Endangered Species Research 24(2):149.
Kniowski, A.B. and S.D. Gehrt. 2014. Home range and habitat selection of the Indiana bat in an
agricultural landscape. Journal of Wildlife Management 78(3):503-512.
Kurta, A., J. Kath, E.L. Smith, R. Foster, M.W. Orick, and R. Ross. 1993. A maternity roost of
the endangered Indiana bat (Myotis sodalis) in an unshaded, hollow, sycamore tree
(Platanus occidentalis). American Midland Naturalist 130:405-407.
Menzel, J.M., W.M. Ford, M.A. Menzel, T.C. Carter, J.E. Gardner, J.D. Garner, and J.E.
Hofmann. 2005. Summer habitat use and home -range analysis of the endangered Indiana
bat. Journal of Wildlife Management 69(1):430-436.
Murray, S.W. and A. Kurta. 2004. Nocturnal activity of the endangered Indiana bat (Myotis
sodalis). Journal of Zoology 262:197-206.
Romme, R.C., K. Tyrell, and V. Brack, Jr. 1995. Literature summary and habitat suitability index
model: components of summer habitat for the Indiana bat, Myotis sodalis. Report to
Indiana Department of Natural Resources, Division of Wildlife, Bloomington, Indiana by
3D/Environmental, Cincinnati, OH.
Sparks, D.W., C.M. Ritzi, J.E. Duchamp, and J.O. Whitaker, Jr. 2005. Foraging habitat of the
Indiana bat, (Myotis sodalis) at an urban -rural interface. Journal of Mammalogy 86:713-
718.
Watrous, K.S., T.M. Donovan, R.M. Mickey, S.R. Darling, A.C. Hicks, and S.L. VonOettingen.
2006. Predicting minimum habitat characteristics for the Indiana bat in the Champlain
Valley. Journal of Wildlife Management 70(5):1228-1237.
71

Vanasse Hangen Brustlin, Inc. 2017. Atlantic Coast Pipeline, revised small whorled pogonia
conservation plan. Report to U.S. Fish and Wildlife Service, West Virginia Field Office,
Elkins, WV; U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S.
Forest Service, Monongahela National Forest, Elkins, WV; U.S. Forest Service, George
Washington and Jefferson National Forests, Roanoke, VA; and West Virginia Division of
Natural Resources, Elkins, WV.
NLEB
Lacki, M.J., D.R. Cox, L.E. Dodd, and M.B. Dickinson. 2009. Response of northern bats (Myotis
septentrionalis) to prescribed fires in eastern Kentucky forests. Journal of Mammalogy
90(5):1165-1175.
Owen, S.F., M.A. Menzel, W.M. Ford, B.R. Chapman, K.V. Miller, J.W. Edwards, and P.B.
Wood. 2003. Home -range size and habitat used by the Northern Myotis (Myotis
septentrionalis). American Midland Naturalist 150(2):352-359.
Analvsis for Jeopardy
SWP
Allstar Ecology. 2016a. Atlantic Coast Pipeline, West Virginia interim botanical survey.
Monongahela National Forest, Pocahontas County, WV. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service,
Monongahela National Forest, Elkins, WV; and West Virginia Division of Natural
Resources, Elkins, WV.
Allstar Ecology. 2016b. Atlantic Coast Pipeline, West Virginia botanical survey report. Report to
U.S. Fish and Wildlife Service, West Virginia Field Office, Elkins, WV; U.S. Forest
Service, Monongahela National Forest, Elkins, WV; and West Virginia Division of
Natural Resources, Elkins, WV.
Environmental Resource Management. 2017. Atlantic Coast Pipeline, evaluation of the small
whorled pogonia in the Monongahela and George Washington National Forests and the
Seneca State Forest. Report to U.S. Forest Service, Monongahela National Forest, Elkins,
WV.
NatureServe. 2002. Element Occurrence Data Standard [Internet]. Arlington, VA [Created
February 6, 2002; cited October 5, 2017] . Available from:
http://www.natureserve.org/conservation-tools/standards-methods/element-occurrence-
dntn_etnndnrd
U.S. Fish and Wildlife Service. 1992. Small whorled pogonia (Isotria medeoloides) recovery
plan, first revision. Northeast Regional Office, Newton Corner, MA.
U.S. Fish and Wildlife Service. 2008. Small whorled pogonia (Isotria medeoloides) 5 -year
review: summary and evaluation. New England Field Office, Concord, NH.
72

Vanasse Hangen Brustlin, Inc. 2017. Atlantic Coast Pipeline, revised small whorled pogonia
conservation plan. Report to U.S. Fish and Wildlife Service, West Virginia Field Office,
Elkins, WV; U.S. Fish and Wildlife Service, Virginia Field Office, Gloucester, VA; U.S.
Forest Service, Monongahela National Forest, Elkins, WV; U.S. Forest Service, George
Washington and Jefferson National Forests, Roanoke, VA; and West Virginia Division of
Natural Resources, Elkins, WV.
RBC
AllStar Ecology. 2017. West Virginia botanical survey report. Report to U.S. Fish and Wildlife
Service, West Virginia Field Office, Elkins, WV; U.S. Forest Service, Monongahela
National Forest, Elkins, WV; and West Virginia Division of Natural Resources, Elkins,
WV.
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
U.S. Fish and Wildlife Service. 2017. Draft Running Buffalo clover (Trifolium stoloniferum) 5 -
year review. Ohio Field Office, Columbus, OH.
RLP
N/A
Clubshell
U.S. Fish and Wildlife Service. 1994. Clubshell (Pleurobema clava) and northern riffleshell
(Epioblasma torulosa rangiana) recovery plan. Hadley, MA.
U.S. Fish and Wildlife Service. 2008. Clubshell (Pleurobema clava) 5 -year review: summary
and evaluation. Pennsylvania Field Office, State College, PA.
Villella, R. 2007. A reassessment of freshwater mussels in the Allegheny River: some surprising
results. (abs). Freshwater Conservation Society Symposium, 2007. Little Rock, Arkansas.
Watters, G.T. 1990. 1990 survey of the unionids of the Big Darby Creek System. Final Report to
The Nature Conservancy. 229 pp.
RPBB
Chapman, R.E. and A.F.G. Bourke. 2001. The influence of sociality on the conservation biology
of social insects. Ecology Letters 4:650-662.
Charman T.G., J. Sears, R.E. Green, and A.F.G. Bourke. 2010. Conservation genetics, foraging
distance and nest density of the scarce great yellow bumblebee (Bombus distinguendus).
Molecular Ecology 19:2661-2674.
Darvill B., M.E. Knight, and D. Goulson. 2004. Use of genetic markers to quantify bumblebee
foraging range and nest density. Oikos 107:471-478.
73

Dreier, S., J.W. Redhead, I.A. Warren, A.F.G. Bourke, M.S. Heard, W.C. Jordan, S. Sumner, J.
Wang, and C. Carvell. 2014. Fine -scale spatial genetic structure of common and
declining bumble bees across an agricultural landscape. Molecular Ecology 23:3384-
3395.
Knight M.E., A.P. Martin, S. Bishop, J.L. Osborne, R.J. Hale, A. Sanderson, and D. Goulson.
2005. An interspecific comparison of foraging range and nest density of four bumblebee
(Bombus) species. Molecular Ecology 14:1811-1820.
Kraus F.B., S. Wolf, and R.F.A. Moritz. 2009. Male flight distance and population substructure
in the bumblebee Bombus terrestris. Journal of Animal Ecology 78: 247-252.
Osborne, J.L., S.J. Clark, R.J. Morris, I.H. Williams, J.R. Riley, A.D. Smith, D.R. Reynolds, and
A.S. Edwards. 1999. A landscape -scale study of bumble bee foraging range and
constancy, using harmonic radar. Journal of Applied Ecology 36:519-533.
U.S. Fish and Wildlife Service. 2016. Rusty patched bumble bee (Bombus affznis) species status
assessment. Twin Cities Ecological Services Field Office, Bloomington, MN.
Wolf, S. and R.F.A. Moritz. 2008. Foraging distance in Bombus terrestris (Hymenoptera:
Apidae). Apidologie 38:419-427.
Wolf, S., T. Toev, R.L.V. Moritz, and R.F.A. Moritz. 2012. Spatial and temporal dynamics of
the male effective population size in bumblebees (Hymenoptera:Apidae). Population
Ecology 54:115-124.
Wood, T.J., J.M. Holland, W.O.H. Hughes, and D. Goulson. 2015. Targeted agri-environment
schemes significantly improve the population size of common farmland bumblebee
species. Molecular Ecology 24:1668-1680.
Zayed, A. 2009. Bee genetics and conservation. Apidologie 40(2):237-262.
MCI
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Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
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plan. Northeast Regional Office, Hadley, MA. 36 pp.
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effect habitat conservation plan. Virginia Field Office, Gloucester, VA.
Ibat
74

Brack, V.W. 2005. Field techniques for biological assessment: assessment of potential
hibernacula and swarming/staging habitat. Pages 89-92 in K.C. Vories and A. Harrington,
eds. The proceedings of the Indiana bat and coal mining: A technical interactive forum.
U.S. Department of the Interior: Office of Surface Mining, Alton, IL.
Federal Energy Regulatory Commission. 2017. Atlantic Coast Pipeline and Supply Header
Project Final Environmental Impact Statement. Docket Nos. CP15-554-000, CP15-554-
001, CP15-555-000, CP15-556-000. Office of Energy Projects, Washington, DC.
Frick, W.F., D.S. Reynolds, and T.H. Kunz. 2010. Influence of climate and reproductive timing
on demography of little brown myotis Myotis lucifugus. Journal of Animal Ecology
79:128-136.
NLEB
N/A
75

Appendix A.
CONSULTATION HISTORY
09-04-14 The Service and Dominion Resources Services, Inc. (DRSI) met to discuss ACP
in NC.
09-15-14 The Service received a letter from DRSI initiating early Section 7 coordination
and requesting technical assistance for ACP in VA.
11-21-14 The Service received a letter from DRSI providing notification of pre -filing to
FERC regarding ACP.
12-09-14 The Service submitted a letter to DRSI providing initial recommendations on
ACP in WV.
01-23-15 The Service submitted a letter to DRSI providing initial recommendations on
ACP in VA.
02-04-15 The Service participated in a site visit to see examples of existing gas pipeline
crossings of waterbodies in NC.
03-25-15 The Service submitted a letter to DRSI providing initial recommendations on
ACP in NC.
05-21-15 The Service, WVDNR, USFS, The Nature Conservancy, DRSI, and Natural
Resource Group, LLC (NRG) met to discuss ACP alternatives analysis in WV.
07-07-15 The Service, WVDNR, USFS, DRSI, and NRG met to discuss the alternatives
assessment and to participate in a helicopter flyover of proposed alternative routes
for ACP in WV.
09-17-15 The Service received a letter from DRSI providing information about ACP and
SHP and requesting a meeting.
10-02-15 The Service received a letter from Atlantic providing notification of certification
application to FERC for ACP.
10-26-15 The Service and DRSI met to discuss ACP and SHP, FERC application, and
development of a biological assessment (BA).
12-01-15 The Service and DRSI met to discuss bat survey results and current project status
for ACP in NC.
12-17-15 The Service, DRSI, and NRG met to discuss 2015 survey results and project
schedule in WV.
76

01-07-16 The Service submitted a letter to FERC providing further recommendations on
ACP in WV.
01-28-16 The Service submitted a letter to DRSI accepting their bat survey results for SHP
and made a NLAA determination for the Indiana and northern long-eared bats in
PA.
02-22-16 The Service received a letter from DRSI requesting Section 7 review and
technical assistance for the GWNF-6 alternative route of ACP in VA.
02-25-16 The Service and DRSI met to discuss freshwater mussels and other aquatic
species survey study plan and current project status for ACP in NC.
03-02-16 The Service received a letter from DRSI submitting the draft BA for ACP and
SHP.
05-02-16 The Service submitted a letter to FERC providing comments on the draft BA for
ACP.
06-02-16 The Service submitted a letter to FERC providing clarification and
recommendations regarding ACP and upcoming field season and bats, aquatic
species, and migratory birds.
06-04-16 The Service and DRSI met to discuss sensitive waterbody crossings by ACP in
NC.
08-16-16 The Service received a letter from DRSI providing a revised draft BA for ACP
and SHP.
11-02-16 DRSI submitted the revised BA to the Service.
11-07-16 The Service and FERC met to discuss SHP, ACP, and development of the Draft
Environmental Impact Statement (DEIS).
11-22-16 The Service, DRSI, and ERM met to discuss survey results and current project
status in WV.
11-29-16 The Service, DRSI, ERM, and U.S. Army Corps of Engineers met to discuss ACP
and SHP.
12-30-16 The Service received the FERC's DEIS via the electronic docket.
01-31-17 The Service submitted a letter to FERC outlining key ACP issues recommended
for resolution prior to finalizing the BA.
77

02-24-17 The Service received a letter from DRSI providing response to Service's 1/31/17
letter.
03-02-17 The Service submitted a letter to FERC clarifying the Service's 1/31/17 letter.
03-21-17 to The Service and FERC met to discuss SHP, ACP, and development of the
03-22-17 FEIS.
03-29-17 The Service, DRSI, and ERM met to discuss comments on the BA.
03-30-17 The Service submitted a letter to FERC providing comments on the DEIS.
04-28-17 The Service received a letter from DRSI submitting the ACP RBC Conservation
Plan in WV.
07-21-17 The Service received FERC's 7/21/17 request to initiate formal consultation and
conference and FEIS.
07-26-17 The Service received a letter from DRSI submitting the ACP SWP Conservation
Plan in WV and VA.
09-06-17 The Service submitted a letter to FERC initiating formal consultation.
09-15-17 The Service received a letter from DRSI submitting the RPBB Impact Analysis
and Conservation Measures.
09-21-17 The Service received a letter from DRSI submitting the revised ACP SWP
Conservation Plan in WV and VA.
W.

Appendix B. Species -Specific Effects Tables.
Tables 1-8 are color coded as follows:
• NE rows are light green
• NLAA rows are light yellow
• LAA are light red
79

Table 1. Analvsis of effects on Small whorled noLlonia.
Q:Disturbance -
Vehicle Operation and Foot Traffic
physical impacts to
crashing, competition,
introduction of invasive
NA
NA
NA
NA
NLAA
AMMs (e.g., Upland Erosion Control Plan, Restoration and Rehabilitation Plan, temporary
tract"
individuals, habitat
collection, chemical
species, poaching, exposure
diversion channels and berms in SWP Conservation Plan, Nov -Native Invasive Plant Species
degradation
contaminants
to chemicals firm surface
Management Plan) will mivvnize potential effectsfrom surface wazer mvoff and competition from
water mvoff
ve plants iv ROW. Cleared ROW may increase chances of poaching and attract ORV traffic
due to increased ease ofpablic access, potentially causing collection, crashing, and death. AMM
of installing barrier, such as signs, fences, gates, vegetation, or boulder along the ROW to
discourage use of ORV s on ROW to avoid illegal access will minimize ORV effects.
New Disturbance -
Clearing - herbaceous vegetation and ground
physical impacts to
soil compaction, altered
oval ofvegetaziov in
habitat, population,
injury, death
reproduction,
umbers,
LAA
This subactiviry m the pipeline covstmc[iov ROW will affect 17.0 and 12.7%, respectively, ofthe
Construction
cover
individuals, habitat
hydrology, changes to
upslope drainage area,
individuals
nutrition, habitat
reproduction
Seneca and NINE colonies' upslope drainage areas. AMM, (e.g., Upland Erosion Control Plan,
degradation
evapotranspiration razes
erosion, spread ofherbaceous
Restoration and Rehabilitation Plan, temporary diversion channels and beans m SWP
and soil moisture,
and invasive plant species
Conservation Plan,Nov-Native Invasive Plant Species Management Plan) will minimize potential
downslope erosion,
effects from surface wazer mvoffand competition firm invasive plants in ROW. Soil compaction
sean
d -won, burial,
and clearing of vegetation inthe upslope drainage area and diversion of surface water flow away
ompetition
from SWP colonies will alter the surface and subsurface hydrology in the watershed of the
SWP
colonies, causing changes iv evapotranspiration rotes and soil moisture ofthe SWP habitat
downslope ofthe ROW. These stressors are likely to affect both the myco fungi and SWP
and cause decreased fitness and re roductive success and ossibl death ofSWP individuals.
New Disturbance-
Clearing - trees and shrubs
physical impacts to
changes to sunlight
oval of over- and mid-
habitat, population,
injury, death
reproduction,
umbers,
LAA
This mbactiviry in the pipeline con,tmction ROW will affect 17.0 and 12.7%, respectively, of the
Construction
individuals, habitat
regime, soil compaction,
story vegetation in upslope
individuals
nutrition, habitat
reproduction
Seneca and NINE colonies' upslape drainage areas. AMMs (e. g., Upland Erosion Control Plan,
degradation
altered hydrology,
drainage area, erosion, spread
Restoration and Rehabilitation Plan, temporary diversion channels and beans m SWP
aced soil
ofherbaceous and invasive
Conservation Plan [SWPCP],Nov-Nazivelnvasive Plant Species Management Plan [NNIPSMP])
temperature, changes to
plant species
will mini, ie potential effects from mr wewazer mvoff and competition from invmiveplmts iv
evapotranspiration razes
ROW. Soil compaction and clearing of vegetation in the upslope drainage area and diversion of
W soil moisture,
surface water flow away from SWP colonies will alterthe surface and subsnrfacehydrology in the
downslope erosion,
watershed ofthe colonies, causing changes in evapotranspiration razes and soil moisture of the
sedan -won, burial,
SWP habitat downslope ofthe ROW. These stressors are likely to affectboth the mycorrhizaz
ompetition
fungi and SWP and cause decreased fitness and reproductive success and possibly death of SWP
individuals. Removal ofmid- and over -story trees will also increase direct and ambient light,
which may increase SWP flowering and population size, but beyond an unknown threshold, is
anticipated to degrade the SWP habitat by increasing soil temperature, drying soils, and changing
evapotranspiration rtes, thereby affecting SWP as described above. ERM (2017) conducted
qualitative analyses ofthe potential changes to light regime near each colony as aresult oftree
removal in the pipeline construction ROW using 3D computer modeling. For the Seneca colony,
the simulations indicated significant increases in ambient and direct light on the ground and
surrounding area during summer, spring, and fall days, although not quantified. For the MNF
colony, the simulations indicated changes in ambient light on the ground and surrounding area
during early morning on summer and fall days. This light analysis was conducted before the
proposed pipeline route was moved 108 ft further from the MNF colony, but we continue to
anticipate changes m light iv mrrouvding area due to close proximity (221 ft) of the pipeline
on,tmction ROW. TheNNIPSMP will not address herbaceous and invasive vegetation growing
outside of the ROW and year the SWP colonies due to the increased light. Invasive species could
compete with SWP for light, space, and nutrients, causing decreased fitness and reproductive
success and possibly death ofivdividual SWP. The SWPCP includes temporary AMMs to monitor
the population status of the SWP colonies annually for 10 years post -construction and minimize
effects from invasive species outside oftheROW and near the SWP colonies for 3 years (e.g.,
before, during, and 1 year after covstmctia ) (VHB 2017). Atlantic is working with the Service
and USFS to fund the continuation ofpopulmion monitoring efforts beyond 1 year post-
onstmctiov. For the Seneca SWP colony, the SWPCP also includes planting native tree seedlings
for 200 If along the construction ROW edge to the west ofthe pipeline (e.g., farther from the
colony) to ameliorate for changes in sunlight regime and monitoring light levels in the colony for 3
years (e.g., before, during, and 1 year after construction). Approximately 20-30 years after
planting, canopy trees (e.g., white oak and eastern white pine found az the Seneca colony) are
expected to provide some mid -story shade (Bums et al. 1990), which would contribute to partially
restoring the SWP habitat. Based on the evaluation ofERM's (2017) wind analysis ofpotential
changes to wind patterns and speed within a 1 km radius around each ofthe SWP colonies, we
anticipate that changes in wind pattern and speed will be min..., and are likely to be discountable
vificant.
New Disturbance-
Vegetation Disposal (upland) -dragging,
habitat degradation
competition
spread ofherbaceous and
NA
NA
NA
NA
NLAA
Methods described in th e Nov -Native Invasive Plant Species Management Plan will mina, ize
Construction
chi , hauliv , piling, AmAin
id -owe plant species
acts due to invasive species.
New Disturbance-
Vegetation Disposal(upland) - brash pile
neutral
none
NA
NA
NA
NA
NA
NE
Activity not proposedwithin the upslope drainage areaand 100 -ft bufferdownslope ofSWP
Constructionburin
colonies.
New Disturbance -
V egetazion Clearing -tree side trimming by
physical impacts to
changes to sunlight
trvnmivg of over- and mid-
habitat, population,
injury, death
reproduction,
numbers,
LAA
Trimming ofmid- and over -story trees will increase direct and ambient light, which may increase
Construction
bucket track or helicopter
individuals, habitat
regime, increased soil
story vegetation in upslope
individuals
nutrition, habitat
reproduction
SWP flowering and population size. Beyond an unknown threshold, an increase in direct and
degradation
temperature, changes to
drainage area, spread of
ambient light is anticipated to degrade SWP habitat by increasing soil temperature, drying soils,
evapotranspiration razes
herbaceous and invasive
and changing evapotranspiration razes, causing decreased fitness and reproductive success and
and soil moisture,
plant species
possibly death ofivdividuals. Methods described inthe Nov -Native Invasive Plant Species
competition
Management Plan will minnnize impacts due to invasive species in the ROW, but not address
herbaceous and invasive vegetation growing outside of RO W and near SWP colonies due to
increased light. Invasive species could compete with SWP for light, space, and nutrients, causing
decreased fitness and reproductive success and possibly death of individual SWP. The Small
Whorled Pogovia Conservation Plan inctudes temporary AMMs to mivvnize effects from invasive
outsides 2ROWandneartueSWP colonies for 3 e HB 2017.
New Disturbance -
Grading, erosion control devices
physical impacts to
soil compaction, altered
grading in upslope drainage
habitat, population,
injury, death
reproduction,
umbers,
LAA
This'subactivity in the pipeline construction ROW will affect FT0 and MAY respectively, ofthe
Construction
individuals, habitat
hydrology, changes to
area, erosion
individuals
nutrition, habitat
reproduction
Seneca and NINE colonies' upslope drainage areas. AMMs (e.g., Upland Erosion Control Plan,
degradation
soil moisture, downslope
Restoration and Rehabilitation Plan, temporary diversion channels and beans m SWP
sedv -Wion,
Conservation Plan) will mivvnize potential effects from surface wazer mvoff Soil compaction and
barialn
ground disturbance in the upslope drainage area and diversion of surface wazer flow away firm
SWP colonies will alter the surface and subsurface hydrology in the watershed oftue colonies,
S=
changes iv evapotransprztion razes and soil moisture ofthe SWP habitat downslope ofthe
ROW. These stressors are likely to affect both the mycorffiizal fungi and SWP and cause
decreased fitness and reproductive success and possibly death of SWP individuals.

Table 1. Analvsis of effects on Small whorled noLlonia.
New Disturbance -
Tm,,hi.g (digging, blasting dewatering open
physical impacts to
crushing altered
trenching in pslope drainage
habitat, pop.lotio.,
ivjory, death
reprodoctiov,
ombers,
LAA
This ,.b.tmty in the pipeline co.,tructio. ROW will affect 17.0 and 12.7%, respectively, ofthe
Construction
trench, sedimentation)
individuals, habitat
hydrology, changes to
area, erosion, movement of
individual,
nutrition, habitat
reproduction
Seneca and MNF colonies' pslope drainage areas. AMM, (e.g., Upland Ero,io, Control Plan,
degno hdio.
soil moisture, dowoslope
soil and larger material (e.g.
Restoration and Rehabilitation Plan, temporary diversion channels and beans in SWP
n sednnentotion,
boulder, ) when blastingConservation
Plam) will minn omfface water runoff Gm..d disNd�ance
nize potential effects fr,.
oria
t l
in the pslope drainage area and diversion of,.rface water flow away from SWP colonies will
alter the,.rface and subsurface hydrology in the watershed ofthe colonies, causing changes in
evapotranspiration rates and soil moisture ofthe SWP habitat dowoslope of the ROW. These
stressors are likely to affect both the mycorhizal fungi and SWP and cause decreased fitness and
reproductive success and possibly death of SWP individuals. Blasting may also loosen large rocks,
which could fall and crush SWP.
New Disturbance -
Pipe Stringing - bending, welding coating
ventral
.e
NA
NA
NA
NA
NA
NE
No i pacts to SWP habitat are anticipated firm this action.
Construction
padding and backfilling
New Disturbance-
Hydrostatic Testing(woter withdrawal and
ventral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the pslope drainage area and 100-11 buffer downslope of SWP
Construction
disch
colonies.
New Disturbance -
Regrading and Stabilization -restoration of
physical impacts to
soil compaction, altered
regrading in pslope drainage
habitat, population,
ivjory, death
reprodoctiov,
ombers,
LAA
This sobwtivity in the pipeline construction ROW will affect 17.0 and 12.7/ respectively, ofthe
Construction
mridor
individuals, habitat
hydrology, changes to
area, erosion, spread of
individuals
nutrition, habitat
reprodoctiov
Seneca and XI colonies' opslope drainage areas. AMM, (e.g., Upland Erosion Control Plan,
degradation
soil moisture, downslope
herbaceous and invasive
Restoration and Rehabilitation Plan, temporary diversion channels and beans in SWP
sed—tatio.,
plant ecies, exposure to
sp
Conservation Plan,Nov-Native Invasive Plant Species Management Plan [NNIPSMP])will
ton-ml,.competition,
nutrients from surface waterSze
pote.fial effects from ,.rface water novo$ compaction, mpaction, and competition firm
noneplant,
aced nutrients,
no.off(fertilizers,
in ROW. Gro..ddi,Nd�amce in the opslope drainage area and diversion ofsorface
chemical contaminants
decomposed vegetation),
water flow away firm SWP colonies will alter the surface and,.b,.fface hydrology in the
exposure to chemicals from
watershed ofthe colonies, causing changes in evapoft--pvation rates and soil moisture of the
—fife water no.off and
SWP habitat downslope ofthe ROW. These stressors are likely to affect both the my—hizal
wind
fungi and SWP and cause decreased fitness and reprod.cfive success and possibly death of SWP
individuals. For controlling invasive plants, hand application methods will be used along the ROW
and no herbicides will be applied within 25 If offederally listed plant specie,..less approved by
the Service or USES. Ino additio,, SWP are lo—d at least 70 If finm the ROW and therefore are
not lik,lv to be ex used to herbicides.
New Disturbance-
Compre„io. Facility, noise
ventral
.e
NA
NA
NA
NA
NA
NE
Facilities do not occur within thenpdope drainage—and 100-ftb.fferdowoslope ofSWP
Co.str.ctio.
colonies.
New Disturbance-
Comm..icatio.Facility- g.y lines, noise, lights
neutral
.e
NA
NA
NA
NA
NA
NE
Facilities do not oce.r within thenpdope drainage—and 100-ftb.fferdowoslope ofSWP
Co.str.ctio.
colonies.
New Disturbance-
Access Roads-.pgradexisting road,,.ew
neutral
.e
NA
NA
NA
NA
NA
NE
No temporary or permanent access roads propo,ed.ear SWP colonies.
Co-fi-octio.
eivg
roads tem and a .t- nodiv , avelin
New Disturbance-
Access Roads-.pg,.di.g existing—&,.ew
neutral
.e
NA
NA
NA
NA
NA
NE
No temporary or permanent access roads propo,ed.ear SWP colonies.
Co.str.ctio.
roads temp and p— me.t - calved i.stallatio.
NewDisturbance-
Access Roads -upgradingexisting ood,,.ew
neutral
.e
NA
NA
NA
NA
NA
NE
No temporary or permanent access roads propo,ed.ear SWP colonies.
Co.str.ctio.
roads temp and pe.mame.t-tree tramming and
tree removal
New Disturbance -
Stream Crossings, wet open cut ditch
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Crossings, fl.—
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Crossings, dam &pomp
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Crossings, cofferdam
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Crossings, Horizontal Dimdio.al Drill
neutral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Cov,trnctio.
(HDD)
New Disturbance -
Stream Crossings, co.ve.tio.al bore
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Crossings, direct pipe
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance -
Stream Eq.ipment Crossing Structures
ventral
.e
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Co.,trnctio.
New Disturbance-
Crossings, wetlands and otherwaterbodies(.o.-
neutral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the.pdope drainage area and 100-11 b.ffer downslope of SWP
Co.str.ctiov
- clean.
colonies.
N—Disturbance-
Crosings, wetlaodsandother water bodie,(.o.-ventral
.e
NA
NA
NA
NA
NA
NE
Acfivitynot proposed within the.pdope drainage area and 100-1 b.ffer downslope of SWP
Construction
-tree side trimmit
colonies.
N—Disturbance-
Crosimg,, wetlands and other waterbodie,(.o.-
neutral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the.pdope drainage area and 100-11 b.ffer downslope of SWP
Co.,trnctio.
riparian) - gnodi.g, tt_hiog regrading
colonies.
New Disturbance-
Crossings, wetlands and other waterbodie,(.o.-
ventral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the.pdope drainage area and 100-11 b.ffer downslope of SWP
Constructione,triv
m
colonies.
New Disturbance-
Crosimg,, wetlands and otherwaterbodies(.o.-
ventral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the.pdope drainage area and 100-11 b.ffer downslope of SWP
co.str.ctiov-HDD
colonies.
New Disturbance-
Crosings, wetlands and other water bodie,(.o.-
ventral
.e
NA
NA
NA
NA
NA
NE
Activity not proposed within the.pdope drainage area and 100 -ft b.ffer downslope of SWP
Co.str.ctio.
vevtio.al bore
colonies.
Operatio.&
Facilities vehicles, foot traffiq noise,
ventral
.e
NA
NA
NA
NA
NA
NE
Facilities do not occur within the.pdope drainage area and 100 -ft b.ffer dowoslope ofSWP
Maintenance
vicatio. facilities
colonies.
Operatio. &
V egetatio. Management - mowi.g
physical impacts to
soil compwtio., altered
oval ofvegetatio. in
habitat, pop.lation,
ivjory, death
reprodoctiov,
ombers,
LAA
This s.bwtivity m the pipeline permanent ROW will affect 17.0 and 1.1%, re,pectiwly, ofthe
Maintenance
individ.als, habitat
hydrology, changes to
opslope drainage area, spread
individuals
..triton, habitat
reprodoctiov
Seneca and MNF colonies' opslope drainage areas. Soil compaction and removal ofvegetation i.
degradation
evapotranspvatiov razes
ofherbw,o., and invasive
the.pdope drainage area will increase surface water flow and dowoslope erosion rates and alter
and soil moisture,
plant species
surface and subsurface hydrology in the watershed ofthe colonies, causing changes in
downslope erosion,
evapotranspiration notes and soil moisture i. SWP habitat downslope ofthe ROW. These stressors
t orial, competition
are likely to affect both the mycorhizal fungi and SWP and cause decreased fitness and
mtnod-tiw success and possibly death ofSWP individ.als. Methods described in the No. -Native
Invasive Plant Species Management Plan will mimimi- i pwt, doe to invasive species.

Table 1. Analvsis of effects on Small whorled noLlonia.
Operation &
Vegetation Management - chainsaw and tree
physical impacts to
changes to sunlight
removal of over- and mid-
habitat, population,
injury, death
reproduction,
numbers,LAA
namt ROW will affect 17.0 and 1.1%, respectively, ofthe
This sabactivity in the pipeline perem
Maintenance
clearing
individuals, habitat
regime, soil compaction,
story vegetation in pslope
individuals
vatrition, habitat
tion
reproduction
Seneca and MNF colonies' pslope drainage areas. Soil compaction and removal ofvegetatiov in
degradation
altered hydrology,
drainage area, spread of
the pslope drainage area will increase surface water flow and downslope erosion rates and alter
increased soil
herbaceous and invasive
surface and subsurface hydrology in the watershed ofthe colonies, causing changes in
temperature, changes to
plant species
evapotranspiration rates and soil moisture in SWP habitat downslope ofthe ROW. These stressors
evapotranspvatiov rates
are likely to affect both the mycmrhizal fungi and SWP and cause decreased fitness and
and soil moisture,
reproductive success and possibly death of SWP individuals. This sobactivity will also redistribute
downslope
sedimentationsion, and loosen soils, which will cause sedimentation downslope towards the colonies. Depending on
burial, competition
the degree of surface waterranoffand sedimentation, SWP habitat may be degraded and
individual stems may be buried. Removal afraid- and over -story trees will also increase direct and
ambient light, which may increase SWP flowering and population size, but beyond an unknown
threshold, is anticipated to degrade the SWP habitat by increasing soil temperature, drying soils,
and changing evapotranspiration rates, causing decreased fitness and reproductive success and
possibly death ofivdividual SWP. Methods described in the Nov -Native Invasive Plant Species
Management Plan will mini, ize impacts due to invasive species in the ROW, but not address
herbaceous and invasive vegetation growing outside ofthe ROW and near the SWP colonies due
to the increased light. Invasive species could compete with SWP for light, space, and nutrients,
causing decreased fitness and reproductive success and possibly death of individual SWP. The
SWP Conservation Plan includes temporary AMMs to monitor the population status of the SWP
colonies annually for 10 years post -construction and to mini. ize effects from invasive species
outside ofthe ROW and near the SWP colonies for 3 years (e.g., before, during, and 1 year after
construction) (VHB 2017). Atlantic is working with the Service and USES to fund the continuation
ofpopulation monitoring efforts beyond 1 year post -construction.
Operation &
Vegetation Management - herbicides - hand,
physical impacts to
chemical contaminants
exposure to chemicals from
NA
NA
NA
NA
NLAA
Hand application methods will be used along the ROW and no herbicides will be applied within 25
Maintenance
vehicle mounted, acrial applications
individuals, habitat
surface water mnoff and
ft offederally listed plant species unless approved by the Service or USES. Iv addition, SWP are
alteration
wind
located at least 70 If from the ROW and therefore are not likely to be exposed to herbicides. The
SWP Conservation Plan also includes AMMs to mini. ize herbicide exposure by prohibiting
herbicide use within 60 If of SWP colonies and only using handpulling within this area (VHB
2017).
Operation &Vegetation
Disposal (upland) - dragging,
habitat degradation
competition
spread ofherbaceous and
NA
NA
NA
NA
NLAA
Methods described in the Nov -Native Invasive Plant Species Management Plan will min. ize
Maintenance
chipping, hauling, piling, stacking'
ve plant species
impacts due to invasive species.
Operation&
Vegetation Disposal(upland) - brash pile
neutral
none
NA
NA
NA
NA
NA
NE
Activity not proposed within the upslope drainage area and 100 -ft buffer downslope of SWP
Maintenance
burning
colonies.
Operation &
Vegetation Management - tree side tramming by
habitat degradation
changes to sunlight
tramming of over- and mid-
habitat, population,
injury, death
reproduction,
umbers,
LAA
Trimming afraid- and over -story trees will increase direct and ambient light, which may increase
Maintenance
bucket track or helicopter
regame, increased soil
story vegetation in upslope
individuals
nutrition, habitat
reproduction
SWP flowering and population size. Beyond an unknown threshold, an increase in direct and
temperature, changes to
drainage area, spread of
ambient light is anticipated to degrade SWP habitat by increasing soil temperature, drying soils,
evapotranspratiov rates
herbaceous and invasive
and changing evapotranspiration rates, causing decreased fitness and reproductive success and
and soil moisture,
plant species
possibly death ofivdividuals. Methods described in theNon-Native Invasive Plant Species
competition
Management Plan will minors ize impacts due to invasive species in the ROW, but not address
herbaceous and invasive vegetation growing outside of RO W and near SWP colonies due to
increased light. Invasive species could compete with SWP for light, space, and nutrients, causing
decreased fitness and reproductive success and possibly death of individual SWP. The SWP
Conservation Plan includes temporary AMMs to minimize effects from invasive species outside of
the ROW and new the SWP colonies for 3 yews (e.g., before, during, and 1 year after
construction) VH13 2017).
Operation &ROW
repair, regrading, revegetation (upland) -
physical impacts to
soil compaction, altered
regrading in upslope drainage
habitat, population,
injury, death
reproduction,
umbers,
LAA
This subactivity in the pipeline permanent ROW will affect 17.0 and 1.1%, respectively, ofthe
Maintenance
hand, mechanical
individuals, habitat
hydrology, changes to
area, erosion
individuals
nutrition, habitat
reproduction
Seneca and MNF colonies' upslope drainage areas. Soil compaction and ground disturbance will
degradation
soil moisture, downslope
increase surface water flow and downslope erosion rates and alter surface and subsurface
on, burial,
hydrology in the watershed of the colonies, causing changes in evapotranspiration rates and soil
sedimentation
moisture in SWP habitat downslope ofthe ROW. These stressors are likely to affect both the
mycorffiizal fungi and SWP and cause decreased fitness and reproductive success and possibly
death of SWP individuals. This subactivity will also redistribute and loosen soils, which will cause
sedimentation downslope towards the colonies. Depending on the degree of surface waterranoff
and sedimentation, SWP habitat may be degraded and individual stems may be buried.
Operation &
ROW repair, regrading, revegetation (wetland) -
neutral
none
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Maintenance
hand, mechanical
Operation &ROW
repair, regrading, revegetation - in ream
neutral
none
NA
NA
NA
NA
NA
NE
SWP is not an aquatic species and not found in streams and wetland areas.
Maintenance
stabilization and/or fill
Operation &
Access Road Maintenance - grading, graveling
neutral
none
NA
NA
NA
NA
NA
NE
No temporary or permanent access roads proposed new SWP colonies.
Maintenance
Operation &
Access Road Maintenance - culvert replacement
neutral
none
NA
NA
NA
NA
NA
NE
No temporary or permanent access roads proposed new SWP colonies.
Maintenance
Operation&
General Appurtenance and Cathodic Protection
neutral
none
NA
NA
NA
NA
NA
NE
Activity not proposed within the upslope drainage area and 100 -ft buffer downslope of SWP
Maintenance
Construction -Off ROW Clear
colonies.
Operation&General
Appurtenance and Cathodic Protection
neutral
none
NA
NA
NA
NA
NA
NE
Activitynotpra osed within the upslope drain age area and 100 -ft buffer downslope of SWP
Maintenance
Construction - trevchiv ,anode, bell hole
colonies.
Operation &Inspection
Activities - ground and acrial
neutral
ve
NA
NA
NA
NA
NA
NE
No impacts to SWP habitat are anticipated firm this action.
Maintenance

Tabic 2. Analysis of effects on RBC.
New Disturbance -
Vehicle Operation and Foot
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
Traffic
habitat degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Clearing - herbaceous vegetation
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
and ground cover
habitat alteration and degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Clearing - trees and shrubs
habitat alteration/degradation
crushing,changes
removal of
habitat,
injury, death
reproduction,
numbers,
LAA
Will remove all canopy cover over the construction
Construction
in sunlight
overstory
population,
nutrition, habitat
reproduction
ROW and significantly reduce canopy cover over
exposure
vegetation,
individuals
access roads. Will create too much sunlight for RBC,
spread of
which prefers partial to filtered sunlight.
herbaceous and
invasive plant
species
New Disturbance -
Vegetation Disposal (upland) -
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
dragging, chipping, hauling,
habitat alteration and degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
piling, stacking
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Vegetation Disposal (upland) -
habitat alteration/degradation
burning
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
The plant structure is above ground and plants
Construction
brush pile burning
habitat
population,
nutrition, habitat
reproduction
exposed to fire are likely to be killed. Additionally,
destruction
individuals
topsoil containing RBC plant material and seed
source is likely to be submerged in ash piles,
restricting further plant growth and recolonization
New Disturbance -
Vegetation Clearing - tree side
habitat alteration/degradation
changes in
removal of
habitat,
injury, death
reproduction,
numbers,
LAA
Will remove all canopy cover over the construction
Construction
trimming by bucket truck or
sunlight exposure
overstory
population,
nutrition, habitat
reproduction
ROW and significantly reduce canopy cover over
helicopter
vegetation,
individuals
access roads. Will create too much sunlight for RBC,
spread of
which prefers partial to filtered sunlight.
herbaceous and
invasive plant
species
New Disturbance -
Grading, erosion control devices
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
habitat alteration and degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Trenching (digging, blasting,
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
dewatering, open trench,
habitat alteration and degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
sedimentation)
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Pipe Stringing - bending,
NA
NA
NA
NA
NA
NA
NA
NE
This activity will occur in areas that have already
Construction
welding, coating, padding and
been disturbed and will not effect RBC
backfilling
New Disturbance -
Hydrostatic Testing (water
NA
NA
NA
NA
NA
NA
NA
NE
No impact from hydrostatic testing
Construction
withdrawal and discharge)
New Disturbance -
Regrading and Stabilization -
NA
NA
NA
NA
NA
NA
NA
NE
This activity will occur in areas that have already
Construction
restoration of corridor
been disturbed and will not effect RBC
New Disturbance -
Compression Facility, noise
NA
NA
NA
NA
NA
NA
NA
NE
No impact from noise
Construction
New Disturbance -
Communication Facility - guy
NA
NA
NA
NA
NA
NA
NA
NE
No impact from guy lines, noise, lights.
Construction
fines, noise, lights
New Disturbance -
Access Roads - upgrading
physical impacts to individuals,
crushing, changes
soil compaction,
individuals,
mortality
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
existing roads, new roads temp
habitat alteration and degradation
in hydrology,
habitat
habitat
nutrition, habitat
reproduction
activities in wet conditions will increase soil
and permanent - grading,
contaminants
destruction
compaction, which may restrict seed germination
graveling
preventing reestablishment of RBC in the temporary
construction ROW post -construction.

Tabic 2. Analysis of effects on RBC.
..
New Disturbance -
Access Roads - upgrading
physical impacts to individuals,
crushing, changes
soil compaction,
individuals,
mortality
reproduction,numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Construction
existing roads, new roads temp
habitat alteration and degradation
in hydrology,
habitat
habitat
nutrition, habitat
reproduction
activities in wet conditions will increase soil
and permanent - culvert
contaminants
destruction
compaction, which may restrict seed germination
installation
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
New Disturbance -
Access Roads - upgrading
habitat alteration/degradation
changes in
soil compaction,
individuals,
mortality
reproduction,
numbers,
LAA
Will remove all canopy cover over the construction
Construction
existing roads, new roads temp
sunlight exposure
habitat
habitat
nutrition, habitat
reproduction
ROW and significantly reduce canopy cover over
and permanent- tree trimming
destruction
access roads. Will create too much sunlight for RBC,
and tree removal
which prefers partial to filtered sunlight.
New Disturbance -
Stream Crossings, wet ditch
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
New Disturbance -
Stream Crossings, flume
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
New Disturbance -
Stream Crossings, dam & pump
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
New Disturbance -
Stream Crossings, cofferdam
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
New Disturbance -
Stream Crossings, Horizontal
NA
NA
NA
NA
NA
NA
NA
NE
HDD will not be used in WV where RBC occurs
Construction
Directional Drill (HDD)
New Disturbance -
Stream Crossings, conventional
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
bore
New Disturbance -
Stream Crossings, direct pipe
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
New Disturbance -
Stream Equipment Crossing
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
Structures
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
water bodies (non -riparian) -
clearing
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
no impacts from tree trimming.
Construction
water bodies (non -riparian) -
tree side trimming
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
water bodies (non -riparian) -
grading, trenching, regrading
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
no impacts from pipe stringing component of activity
Construction
water bodies (non -riparian) -
pipe stringing
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
HDD will not be used in WV where RBC occurs
Construction
water bodies (non -riparian) -
HDD
New Disturbance -
Crossings, wetlands and other
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
Construction
water bodies (non -riparian)
conventional bore
Operation &Maintenance
Facilities - vehicles, foot traffic,
NA
NA
NA
NA
NA
NA
NA
NE
Facilities do not occur near RBC.
noise, communication facilities
Operation &Maintenance
Vegetation Management -
NA
NA
NA
NA
NA
NA
NA
NE
Mowing will occur in areas not suitable for RBC
mowing
Operation &Maintenance
Vegetation Management -
physical impacts to individuals,
changes to
removal of
habitat,
injury, death
reproduction,
numbers,
LAA
Will remove all canopy cover over the construction
chainsaw and tree clearing
habitat alteration
sunlightregime,
overstory
population,
nutrition, habitat
reproduction
ROW and significantly reduce canopy cover over
downslope
vegetation,
individuals
access roads. Will create too much sunlight for RBC,
erosion,
spread of
which prefers partial to filtered sunlight.
competition
herbaceous and
invasive plant
species
Operation &Maintenance
Vegetation Management -
physical impacts to individuals
chemical
exposure to
habitat,
injury, death
reproduction,
numbers,
NLAA
AMMs in place that will limit spraying of herbicides
herbicides - hand, vehicle
contaminants
chemicals from
population,
nutrition, habitat
reproduction
for invasive species managment within 25 -feet listed
mounted, aerial applications
stormwater
individuals
species unless FWS and FS are notified
runoff and wind

Tabic 2. Analysis of effects on RBC.
Operation &Maintenance
Vegetation Disposal (upland) -
physical impacts to individuals,
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
dragging, chipping, hauling,
habitat alteration and degradation
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
piling, stacking
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
Operation &Maintenance
Vegetation Disposal (upland) -
NA
NA
NA
NA
NA
NA
NA
NE
Burning will occur in areas not suitable for RBC
brush pile burning
(only in the ROW)
Operation &Maintenance
Vegetation Management - tree
habitat alteration
changes to
removal of
habitat,
injury, death
reproduction,
numbers,
LAA
Will remove all canopy cover over the construction
side trimming by bucket truck or
sunlight,
overstory
population,
nutrition, habitat
reproduction
ROW and significantly reduce canopy cover over
helicopter
competition
vegetation,
individuals
access roads. Will create too much sunlight for RBC,
spread of
which prefers partial to filtered sunlight.
herbaceous and
invasive plant
species
Operation &Maintenance
ROW repair, regrading,
physical impacts to individuals
crushing
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
revegetation (upland) - hand,
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
mechanical
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
Operation &Maintenance
ROW repair, regrading,
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in wetland areas
revegetation (wetland) - hand,
mechanical
Operation &Maintenance
ROW repair, regrading,
NA
NA
NA
NA
NA
NA
NA
NE
RBC does not occur in riparian zones
revegetation - in stream
stabilization and/or fill
Operation &Maintenance
Access Road Maintenance -
physical impacts to individuals,
crushing,
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
grading, graveling
habitat alteration and degradation
chemical
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
contaminants
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
Operation &Maintenance
Access Road Maintenance -
physical impacts to individuals,
crushing,
soil compaction,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
culvert replacement
habitat alteration and degradation
chemical
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
contaminants
destruction
individuals
compaction, which may restrict seed germination
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
Operation &
General Appurtenance and
habitat alteration
creushing
soil compactron,
habitat,
injury, death
reproduction,
numbers,
LAA
Will kill RBC plants and seeds. Conducting these
Maintenance
Cathodic Protection
habitat
population,
nutrition, habitat
reproduction
activities in wet conditions will increase soil
Construction - OffROW
destruction
individuals
compaction, which may restrict seed germination
Clearing
preventing reestablishment of RBC in the temporary
construction ROW post -construction.
Operation &
General Appurtenance and
NA
NA
NA
NA
NA
NA
NA
NE
These activities will occur in areas not suitable for
Maintenance
Cathodic Protection
RBC
Construction - trenching,
anode, bell hole
Operation &
Inspection Activities - ground
NA
NA
NA
NA
NA
NA
NA
NLAA
Aerial will nave no effect ground inspection foot
Maintenance
and aerial
traffic could pass over RBC populations but would
not adversely affect the species because these
inspections are periodic in nature which the species is
accustomed to and can benefit from

Table 3. Analvsis of effects on RLP.
New Dl9hmhanee
Vehiele Operation and Foot Traffic
Nertml
None
NA
NA
NA
NA
NA
NE
No.mpacts to seen habitats are antieipated from this no.. Will not iatrodace
- Construction
sediment or co.tommonts into the streams or rivers.
New Disfintowce
Clea .g - herbaceous vegetazio. and gro..d cover
Habitat degradazio. and
Sed.memotio,
de.odi.g bank, grabbing
Diseou.table
NA
NA
NA
NLAA
Tempenttore increases from hedbaceoos vegetation removal would be slight. ACP will
-Construction
water quality
I.emose i. Water
with heavy egoipme.t,
implement AMMs to minimize sedime.lobo.(e.g. eompost filter soek ww/i. 30011 of
degradation, Stress o.
Temperatures,
disturbing soil, water quality
ESA sensitive woterbodies and priority 1 belted silt retention fevee and inspect o. a
R
individuals, eduetio. in
Decrease of
degradazio. since vegetation
daily basis).
prey popola[io.
dissolved oxygen
.o lo.gerprovides
stormwnter filter or shade to
stream
New Disfintowce
Clearing - trees and shrubs
Habitat degradatio. and
Sed.nemation,
de.odi.g bank, grabbing
Habitat, Popolatio.,
Harass, Harm, Kill
Breeding, Feeding,
Numbers, rolnodo,tio.,
LAA
Moderately silted and high torbidity areas will be ... mble to RLP for foraging and
- Construction
water quality
I. erease i. Water
with heavy egoipme.t,
Individuals
Sheltering
distrito tio.
spawning in the.mmediate viei.ity of the crossing. Heavy siltation is also antieipated
degradation, Stress o.
Temperatures,
disturbing soil, water quality
to resolt in a loss ofprey items. Loss ofstreambank vegetation is expected to result i.
individuals, edoetio. in
R
Decrease of
degrodatio. since vegetation
eased water temperatures and changes in light regime in small areas. Changes to
prey popolatio.
dissolved oxygen
.o lo.gerprovides shade to
water temperature and light regime may affect the RLP prey base and make the
stream
habitat less suitable for the RLP themselves.
New Dl9hmhanee
Vegetation Disposal (upland) - dragging chipping hauling
Nentral
None
NA
NA
NA
NA
NA
NE
No .mpacts to stream habitats are antieipated from this aetio.. Will not introduce
-Construction
piling, stacking
sediment or emdami.ants into the streams orri—s.
New Dl9hmhanee
Vegetation Disposal( upland) -brash pile homing
Nentral
None
NA
NA
NA
NA
NA
NE
No.mpacts to stream habitats are antieipated from this aetio.. Will not introduce
- Construction
sediment or emdami.ants into the streams or rivers.
New Dl9h ntowee
Vegetation Clearing - tree side trimming by boeket truck or
Habitat degrodatio. and
I.erease i. Water
habitat and water polity
Unlikely
NA
NA
NA
NLAA
Temperature increases from hedbaceoos vegetation removal world be slight. ACP is
-Construction
helicopter
water quality
Temperatures,
degrodatio. since vegetation
awowmg their eo.stmetio. ROW at watebody erossi.gs to 7511 to minimize
degradation, Stress o.
Decrease of
vo l.gerp,ovid. shade to
eleari.g oftrees andriparian vegeation. Post eo.stmetio. ACP will maintai. a 1011
eggs
dissolved oxygen
stream
wide ROW, which will fortlier 1"...mpaets from vegetation removal.
New Dl9hmhanee
Grading erosion emdrol devices
Temporary loss of
Sed.mematio
storm water erosion
Unlikely
NA
NA
NA
NLAA
ACP will .mpleme d AMMs to minimize sedimentation (e.g. eompost filter soek ww/i.
- Construction
habitat, Habitat
30011 of ESA Se.sitive waterbodies and priority 1 belted silt retention fevee and
degradation, Physical
inspect on a daily basis).
impaets to individoals,
Redoetion ofprey
population
New Disfintowce
Tmnchi.g (diggi.g blasting dewateri.g, ope. trench,
Temporary loss of
Sed.memation,
m -stream, and tributary
Habitat, Popolatio ,
Harass, Harm, Kill
Breeding Feeding,
Numbers, rolnodo,tio.,
LAA
Cofferdams will be used to trench across waterbodies. I.atallatio. and dewatering of
- Construction
sed.mematio.)
habitat, Water polity
Short-term altered
earth disfintowee may resolt
Individoals
Sheltering
distribution
cofferdams is antieipated to injure or kill some RLP by eroshi.g individuals dming
degradation, Physical
flow, Contaminants
i ased sedimentation,
plaeeme.t ofeofferdams andthru gh stranding or e.trommeot as cofferdams are
impaets, Redoetio. of
altered flow res.lt i.
dewatered. Moderately silted and high torbidity areas will bemnsableto RLP for
prey popolatiov
inereased sednmemotion and
foraging and spawning in the.mmediate viei.ity of the emssi.g. Heavy siltation is
short-term .mpom dme.t,
also mticipmed to result in a loss ofprey items. If blasting is needed for any
co.ta mi.ant spills firm
sings, RLP in the mmedime blast area may be killed and RLP in the vicinity will
egoipme.t located iv- stream
betemporarily shoved and/or permme.tly injured. Installation and dewatering of
and trito tary, noise from in
cofferdams may injure or kill RLP by emshing individoals daring plaeement of
water work
cofferdams and through stranding or entrainment as cofferda ms are dewatered.

Table 3. Analvsis of effects on RLP.
New Distmbance
Pipe Stringing - bending, welding coating, paddi.g and
Temporary loss of
Sed.meatatiom,
m -stream, sod tributary
Habitat, Pop.latio.,
Harass, Harm, Kill
Breeding, Feeding
Numbers, rep,od.etio.,
LAA
Moderately silted and high turbidity areas will b....sable to RLP for foraging arud
- Construction
backfilling
habitat, Water polity
Short -tens uttered
earth distmbancemay result
Individuals
Sheltering
distribution
spawning iv the i mediate vicinity ofthe crossing. Heavy siltaziov is also anticipated
degradatio., Physical
flow, Contaminants
i used sedimentation,
to result m a loss ofprey items.
impacts, Redmtiov of
altered flow result iv
prey population
mereused sed.mem olio, and
short -tens vnpoovdmevt,
co.tami.ant spills from
eq.ipme.t located iv- stream
and tributary, noise from iv
water work
New Distmbance
Hydrostatic Testing (water withdrawal and discharge)
Temporary loss of
Minor
Withdrawal and discharge of
Discountable
NA
NA
NA
NLAA
ACP will use municipal water sources rather than withdrawwater at the RLP
- Construction
habitat, Habitat
sed.memtatio.,
water
emssums. ACP will not discharge into ESA sensitive waterbodies, and will discharge
degradation
Alteredflow
m upland areas a mi..m.mof 300 If from ESA sensitive water bodies.
New Distmbance
Regrading and Stabilization - restoration ofcor idor
Permanent or temporary
Minor
tributary and/or year stream
Habitat, Pop.latiom,
Harass, Hmm, Kill
Breeding Feeding
Numbers, reprod.ctio.,
LAA
Any gumml disturbaruce that may result m sedime.tatio. m habitat where RLP
- Construction
loss ofhabitat, Habitat
sed.memtatio., Loss
earth disturbance can cause
Individuals
Sheltering
distribution
presence is assumed is considered LAA. Moderately silted and high turbidity areas
degradation, Water
ofprey,mmor
eto
will be ... sable to RLPforforagiawn
.g and sping iv then—ediate vicinity ofthe
quality degmdatio.,
Contaminants
sedimevtatiov, Sturm water
ssum. Heavy siltation is also anticipated to result m a loss ofprey items.
Physical impacts to
runoff, fertilizers used m
individuals, Redmtiov of
evegetatio. can cause algae
prey
blooms which will lower
dissolved oxyge.,
New Distmbanee
Compression Facility, noise
Neutral
Nove
NA
NA
NA
NA
NA
NE
No i pacts to stream habitats are anticipated from this actio.. Will not introduce
- Construction
sediment or emdami.ants into the streams or rivers.
New Distmbanee
Comm..icatio. Facility - g.y lines, noise, lights
Neutral
Nove
NA
NA
NA
NA
NA
NE
No i pacts to stream habitats are anticipated from this actio.. Will not introduce
- Construction
sediment or emdami.ants into the streams or rivers.
New Distmbance
Access Roads-.pgradi.g existing m ds,.ewroads temp
Temporary loss of
Sed—oration,
m -stream, and tributary
Habitat, Pop.latio.,
Harass, Harm, Kill
Breeding Feeding
Numbers, reprod.ctio.
LAA
Adjacent upland gro..d-disturbing activities such as grading and
- Construction
and perrmarue.t- grading graveling
habitat, Water polity
Short -tens uttered
earth disturbance may result
Individuals
Sheltering
o.stmcti.g/i proving access roads may introduce sed.me.t into RLP habitat.
degradatio., Physical
flow, Contaminants,
iv aced sedimentation,
Moderately silted and high turbidity areas will be ... sable to RLP for foraging and
impacts, Redmtiov of
Loss ofprey,
altered flow result iv
spawning iv the i mediate vicinity ofthe crossing. Heavy siltation is also anticipated
prey pop.lztio.
Disuuptiov of
mueased sednmentatiov and
to result m a loss ofprey items. If instream work occurs during spawning RLP will be
spawning, Crushi.g
short-term, nmpo.vdmevt,
...bleto successfully spawn iv these areas. lfwmk occurs after completion of
removal of eggs
emdami.ant spills from
spawning crushing or removal of eggs is likely to occur.
eq.ipme.t located iv- stream
and tributary, noise from iv
water work
New Distmbance
Access Roads .pgradi.g existing ro.ds,.ewro.& temp
Permanent or temporary
Sed—oration,
tributary and i.sheam each
Habitat, Populatiom,
Harass, Hmm, Kill
Breeding Feeding
Numbers, reprod.ctio.,
LAA
Sediment hdroductio. into RLP habitat. Moderately silted and high turbidity areas
-Construction
and Permaruevt-culvert installation
loss ofhabitat, Habitat
Contaminants,
distmbanc can curse increase
Individuls
Sheltering
distribution
will bemmsable to RLP for foragi.g and spawning iv thenmmediate vicinity ofthe
degradation, Physical
Alteredflow,
m sed.me.tatio. and
urssum. Heavy siltaziov is also anticipated to result m a loss ofprey items. If
impacts to individu ls,
turbidity, Equipment located
mstream work occurs during spawning RLP will be moble to successfully spawn m
Reduction ofpreyv
stream or tributary can
these areas. If work occurs after completion of spawning crushing or removal of eggs
population
ase chance of spills,
is likely to occur.
altered flow velocities and
temporary impoundment
from v-waterwork, minor
se from eo.s roetio.
mtivities i. water.
water work, minor
New Distmbance
Access Roads - upgrading existing ro.ds,.ewroads temp
Habitat degradation and
Sed—oration,
de.udi.g bank, grubbing
Habitat, Populatiom,
Harass, Harm, Kill
Breeding Feeding
Numbers, reproductio.,
LAA
Loss of streambank vegetation is expected to result m increased water temperatures
-Construction
and perm, me.t- tree trnmming and tree removal
water quality
Increase iv Water
with heavy equipment,
Individuats
Sheltering
distribution
and changes m light regime m small areas. Changes iv water temperature and light
degradation, Stress o.
Temperatures,
disturbing soil, water quality
regime may affect the RLP prey base and make the habitat less suitable for the RLP
individuals, Redmtiov m
Decrease of
degradation since vegetation
themselves.
prey population
dissolved oxygen
vo lo.gerprovides shade to
stream

Table 3. Analvsis of effects on RLP.
New Diatfiub ce
&ream Cm ing., wet open cat ditch
Permanent or temporary
Sedhmtatiom,
hibatmy and instoo— eath
Habitat, Popalatiov,
Harass, Hann, Kill
Breeding Feeding,
Nambers, roto od-tio.,
NE
This is not proposed m a crossing method at the 4 RLP crossings (FEIS pg 4-288).
- Construction
loss ofhabitut, Habitat
Contaminants,
disturbanc can cause increase
Individaals
Sheltering
distribatiov
degradation, Physical
Alteredflow
i.sedi mtutio. and
impacts to individaals,
turbidity, Egaipmmt located
Redaction of preyv
stream or tribatary can
popalatiov
ase chance of spills,
altered flow velocities and
temporary impoandment
firm v-wzterwork, mivor
se from vstmctiov
activities iv water.
water work m
New Diatfiub ce
Stream Cmssivgs, flame
Permanent or temporary
Sedhmtation,
tribatary and instream eatb
Habitat, Popalatiov,
Harass, Hann, Kill
Breeding Feeding,
Nambers, roto od-tio.,
NE
This is not proposed m a crossing method at the 4 RLP crossings (FEIS pg 4-288).
- Construction
loss ofhabitut, Habitat
Contaminants,
disturbanc can cause increase
Individaals
Sheltering
distribatiov
degradation, Physical
Alteredflow
i.sedi mtutio. and
impacts to individaals,
turbidity, Egaipmmt located
Redaction of preyv
stream or tribatary can
popalatiov
ase chance of spills,
altered flow velocities and
temporary impoandment
firm v-wzterwork, mivor
se from m—tiov
activities iv water.
water work, minor
New Distadbance
Stream Cmssivgs, dam &pamp
Temporary loss of
Sedhmtation,
tribatary and year stream
Habitat, Popalaziov,
Harass, Hams Kill
Breeding Feeding,
Nambers, roto od-tio.,
LAA
Temporary loss of instream habitat will occar at stream crossings. Instream activities
- Construction
ecapiedhabitat,Alteredflow,
earth distadbance may result
Individaals
Sheltering
distribatiov
will temporarily re-.a.pmd sediments and increase N,bidity. We expect RLP will
Physical impacts to
Contaminants,
ut i,u,m,d sedimentation
o,oid these areas until the in.tream atmetare. are removed and Ndbidity r,Nm, to
individaal., Habitat
Impoandmmt
altered flow may resalt iv
baseline level..Ifinatream work occar. daring spawning RLP will be avable to
degradation and water
ased sed. oututiov,
e..fullyspawn m these areas. If work o- flu completion of spawning
gaality degradation,
contaminant int spills firm
coshing orremovat ofeggs is likely to occar Implementation offish relocation plan
redtetiov ofprey
egaipmud located to
will minimize direct i pwt..
popalatiov
tribatary stream, dam coald
restrict ap/down stream
meet of species, noise
from in water wod'
New Distadbance
Stream Cmssivgs, cofferdam
Temporary loss of
Sedhmtation,
tribatary and year stream
Habitat, Populutim,
Harass, Harm, Kill
Breeding Feeding
Numbers, mlo oductim,
LAA
Temporary loss of i-tuot habitat will occur at stream crossings that use cofferdams
- Con.tmetion
ecapiedhabitat,
altered flow,
earth distadbance may result
Individuals
Sheltering
distribution
and bridge center supports. Additionally cofferdam placemmt/removal, installation of
Physical impacts to
ontaminant.,
i. mu-d sedimentation
bridge center.apport., and other imtream activities will temporarily re-.a.pend
individuals, Habitat
nmpoundmmt,
altered flow may result iv
sediments and increase Nrbidity. We expect RLP will avoid these areas until the
degradaziovandwater
ase
aced sedi.outation,
instream stmetures are removed and N,bidity mou— to baseline levels. Ifivstream
quality degradation,
contaminant spills firm
work occurs during spawning RLP will be unable to --fully spawn m these
Reduction ofprey
equipment located iv
as. Ifwork occurs after completion of.pawuing, em,hing orremovat ofeggs is
population
tributary stream, dam could
likely to occur. TOYR will mi.ion- direct impacts at Butterwood Creek and
restrict up/down stream
Nottoway River 1. Implementation offish relocation plan will minimize direct
meet of species, noise
ampact..
from in water wodc
New Di.tu bb
Stream Cmssivgs, Horizontal Directional Drill (HDD)
Water quality
Sedhmtation,
tributary, year and iv stream
Habitat, Population,
Harass, Hamy Kill
Breeding Feeding
Numbers, reprodmtim,
NLAA
HDD at the Nottoway River 2 (XT32.6) crossing. RLP presence mm. d. Based on
- con—tiondegradation,
Physical
Frac-out,Noi.e
earth distu bance may resalt
Individuals
Sheltering
distribution
the flack -out report, risk offlac-out is low.
Impacts to Individuals,
i. mu-d sedimentation,
Reduction ofprey
risk offac-oat during
population
drilling operations, noise
firm drilling activities
New Di.tu bb
Stream Cmssivgs, conventional bore
Permanent or temporary
Sedhmtation,
tributary and iv stream earth
Habitat, Populatim,
Harass, Harm, Kill
Breeding Feeding
Numbers, relo od-tio.,
NE
This is not to m a crossing method at the 4 RLP crossings (FEIS pg 4-288).
- con—tion
loss ofhabitat, Habitat
Contaants,
min
disturbance can cause
Individuals
Sheltering
distribution
degradation, Physical
Altered flow, Noise
in m sedimentation and
impacts to individaals,
turbidity, Equipment located
Reduction of preyv
stream or tributary can
population
ase chance of spills,
altered flow velocities and
temporary impoundment
firm v- waterwork, mivor
e from mtmctiov
activities iv water.

Table 3. Analvsis of effects on RLP.
New Disturbance
Stream Crossings, di eetpipe
Permanent or temporary
Sed—minium,
hibotmy and iv stream earth
Habitat, Population,
Harass, Harm, Kill
Breeding, Feeding
Numbers, reproduction,
NE
This is not proposed os a crossing method az the 4 RLP crossings (FESS pg 4-288).
- Construction
loss ofhabitot, Habitat
Contaminants,
disturbance can cause
Individoals
Sheltering
distribution
degradation, Physical
Altered flow, Noise
in m sedimentation and
impoets to individoals,
turbidity, Equipment located
Reduction of preyv
stream or trit o y can
popolztion
ase chance of spills,
altered flow velocities and
temporary impoundment
from v- woterwork, minor
e fromemstroeho.
oetivities iv water.
New Disturbance
Stream Egoipmevt Crossing S-eo res
Permanent or temporary
Sed—minium,
tributary and iv stream earth
Habitat, Population,
Harass, Hann, Kill
Breeding Feeding
Northers, reproduction,
LAA
Temporary loss of instream habitat will oeeor az Botterwood and &orgeom Creeks
Construction
loss ofhabitot, Habitat
am
Contaminants,
disturbancean ccause
Individu is
Sheltering
distribution
because the bridge center support will be installed during the RLP TOYR.
degradation, Physical
Altered flow, Noise
in m sedimentation and
Additionally, installation ofbridge center supports will temporarily re -suspend
impoets to individu ls,
turbidity, Equipment located
sediments and increwe turbidity. We expect RLP will avoid these areas until the
on
Reductiof preyv
stream or tributary can
instream stmctures are removed and turbidity retums to baseline levels. If ivstream
populotion
ase chance of spills,
work occurs during spawning RLP will be unable to sueeessfully spawn m these
altered flow velocities and.
Ifwork oceurs after completion ofspawning, emshing orremoval ofeggs is
temporary impoundment
likely to occur.
from v- woterwork, minor
e fromemstroeho.
oetivities iv water.
New Disturbance
Crossings, wetlands and otuerwater bodies (von -riparian) -
Neutral
Nove
NA
NA
NA
NA
NA
NE
Activity is not loeazed m streams orrivers. Iv addition, ifvov-riparian then oetivity
-Comstmctiom
clearing
would not be adjacent to oceupied habitat and therefore this—old be avo effeet.
New Disturbance
Crossings, wetlands and otuerwater bodies (von -riparian) -
Neutral
Nom
NA
NA
NA
NA
NA
NE
Activity is not loeazed m streams orrivers. Iv addition, ifvov-riparian then oetivity
-Comstmctiom
tree side tramming
—old not be adjacent to oceupied habitat and therefore this—old be avo effeet.
New Disturbance
Crossings, wetlands and otuerwater bodies (von riparian)
Neutral
Nom
NA
NA
NA
NA
NA
NE
Activity is not located m streams orrivers. Iv addition, ifvov riparian then oetivity
-Comstmctiom
grading trenching regrading
—old not be adjacent to oceupied habitat and therefore this—old be avo effeet.
New Disturbance
Crossings, wetlands and other water bodies (von -riparian) -
Neutral
Nom
NA
NA
NA
NA
NA
NE
Activity is not loeazed m streams orrivers. Iv addition, ifvov-riparian then oetivity
-Comstmctiom
pipe stringing
—old not be adjacent to oceupied habitat and therefore this—old be avo effeet.
New Disturbance
Crossings, wetlands and other water bodies (von -riparian) -
Neutral
Nom
NA
NA
NA
NA
NA
NE
Activity is not loeazed m streams orrivers. Iv addition, ifvov-riparian then oetivity
-Comstmctiom
HDD
—old not be adjacent to oceupied habitat and therefore this—old be avo effeet.
New Disturbance
Crossings, wetlands and otuerwater bodies (vov-riparim) -
Neutral
Nom
NA
NA
NA
NA
NA
NE
Activity is not loeazed m streams orrivers. Iv addition, ifvov-riparian then oetivity
-Comstmctim
nventional bore
—old not be adjacent to oceupied habitat and therefore this—old be avo effeet.
Operation &
Facilities - vehicles, foot traffre, noise, communication
Habitat degradation,
Sed—minium,
Stormwoterrunofffiom
Unlikely
NA
NA
NA
NLAA
Maintenance
facilities
Wazer quality
Contaminants
pollution generating
degradation
pavement, Stomrwater
ero.o.
Operation &
Vegetation Management- mowing
Neutral
Nom
NA
NA
NA
NA
NA
NE
No i poets to stream habitats are mtieipazed from this oetion. Will not introduce
Maintenance
sediment or contaminants into the streams or rivers.
Operation&
Vegetation Management- ehaivsaw and tree clearing
Habitat degradation and
Sed—minium,
denuding bank, grabbing
Unlikely
NA
NA
NA
NLAA
ACP isvmmwivg their eovstmctiov ROW az wazerbody crossings to 7511 to minim-
Maintenance
water quality
Increase iv Wazer
with heavy equipment,
clearing oftrees aodripariao vegeaziom. Post eovstmetiov ACP will maintain a loll
degradation, Stress on
Temperatures,
disturbing soil, water quality
wide ROW, which will furtlrer lessen i paets from vegetation removal.
individuals, Reduction m
Decrease of
degradation since vegetation
prey population
dissolved oxygen
vo lovgerprovides shade to
stream
Operation &
Vegetation Management- herbicides - hand, vehicle
Habitat degradation and
Chemicaz
direct exposure to chemicals
Habitat, Populatioq
Harass, Harm, Kill
Breeding Feeding
Numbers, reproduction
NLAA
Herbicides or pesticides will not be used within 100 feet of awatut ody except as
Maintenance
ounted, aerial applications
water quality
Contaminants
from spills and stormwater
Individu is
Sheltering
allowed by the appropriate land management or state agency (Construction,
degradation, Stressors
.,off
Operations, and Maivtevanee Plans pg.143). Aerial spraying—oldvot be utilized for
individuals, Reduction m
vmv, species control along the ROW.
ulazion
Operation &
Vegetation Disposal (upland) - dragging chipping hailing,
Neutral
Nove
NA
NA
NA
NA
NA
NE
No i paets to stream habitats are aotieipazed from this aetion.
Maintenanceilio
, stackin
Operation &
Vegetation Disposal (upland) - brash pile buming
Neutral
Nove
NA
NA
NA
NA
NA
NE
No i paets to stream habitats are aotieipazed from this aetion.
Maintenance
Operation &
Vegetation Management -tree side trimming by bucket
Habitat degradation and
Increase iv Water
habitat and water qu lity
Unlikely
NA
NA
NA
NLAA
ACP is vmmwivg their eovstmctiov ROW azaz
werbody crossings to 7511 to mini m -
Maintenance
truek or helicopter
water quality
Temperatures,
degradation since vegetation
clearing oftrees and riparian vegeazion. Post eovstmetiov ACP will maintain a loll
degrodatioq Stress on
Decrease of
vo longer provides shade to
wide ROW, which will further lessen i paets from vegetation removal.
dissolved o.yge.
stream

Table 3. Analvsis of effects on RLP.
Operation &
ROW repair, regrading revegeta[iom (uplund) -
Habitat degradation,
Minor
tributary und/or year stream
Habitat, Population,
Harass, Harm, Kill
Breeding, Feeding,
Numbers, mproductioq
LAA
E&S measures will minmm ize mmpoets through erosion control undr Amotion of
Maintenance
hand, mechanical
Water quality
sedmentatio.,
earth dimubunce can cause
Individuals
Sheltering
distribution
graded areas. In addition, the FEIS states that grubbing will not occur within 50 feet
degradation
Lowered dissolveds
to
of ESA sensitive wambodies between November 15 - April l (FESS pg 4-252). RLP
oxygen,
sedimentation, Stone water
TOYR is March 15 -June 30 so this only somewhat benefits the RLP.
Contaminants
runoff, fertilizers used in
eveget"nov can cause algae
blooms which will lower
dissolved oxygen
Operation &
ROW repair, regrading, revegetation (wetland) -
Permanent or temporary
Minor
tributary und/or near stream
Habitat, Population,
Harass, Hann, Kill
Breeding Feeding,
Numb...... production,
LAA
Although there is a chance for contaminant spills firm equipment, this wouldnot
Maintenance
hand, mechanical
loss ofhabitat, Habitat
sedentation,
mm
earth dimubance can cause
Individuals
Sheltering
distribution
likely jeopardize this species as spills would take place outside ofhabitat. In addition,
degradation, Water
Lowered dissolvedminor
sto
contaminant spill impacts should be minimal in any habitat ifBMPs outlined in the
quality degradatioq
oxygen,
sedimentation, Storm water
ECS are followed. The FEIS states that grubbing will not occur within 50 feet of ESA
Physical impacts to
Contaminants
runoff, fertilizers used to
sousitwe waterbodies between November 15 -April l (FESS pg 4-252). RLP TOYR is
individuals, Reduction of
evegetation can cause algae
March 15 - June 30 so this only somewhat benefits the RLP.
prey
blooms which will lower
dissolved oxygen, Equipment
located in connected wetland
increasecan chance ofspills
Operation &
ROW repair, regrading revegetation - instream stabilization
Permanent or temporary
Sedmmemation,
tributary and in stream earth
Habitat, Population,
Harass, Harm, Kill
Breeding Feeding
Numbers, reproduction,
LAA
The FEIS states that grubbing will not occur within 50 feet of ESA sensitive
Maiommunce
and/or fill
loss ofhabitat, Habitat
Contaminants,
disturbance caro corse
Individuals
Sheltering
distribution
waterbodies between November 15 -April l (FESS pg 4-252). RLP TOYR is March
degradation, Water
Alteredflow
increase in sedimentation and
15 -June 30 so this only somewhat benefits the RLP. In addition the ECS outlines the
quality degmdatioq
turbidity, Equipment located
eoferosion control measures and restoration ofgraded areas.
Physical impacts to
instream or tributary can
individuals, Reduction of
increase chance of spills,
prey
uttered flow velocities and
temporary impoundment
from n-waterwork
Operation &
Access Road Maintenance- grading graveling
Temporary loss of
Sedmmemation
tributary and in stream earth
Unlikely
NA
NA
NA
NLAA
The FEIS state that vegetation maintenance will be limited in the 50 feet adjacent to
Maintenance
habitat, Habitat
disturbance caro cause
waterbodies, min. izing ground and vegetation dimubance (FESS pg 4-252). In
degradation, Physical
increase in sedimentation
addition the ECS outlines the use of erosion control measures and restoration of
impacts to individuals,
graded areas.
Reduction ofprey
Population
Operation &
Access Road Maintenance- culvert replacement
Permanent or temporary
Sedmmemation,
tributary and in stream earth
Habitm.Population,
Harass, Harm, Kill
Breeding Feeding,
Numbers, reproduction,
LAA
The FEIS states that grubbing will not occur within 50 feet of ESA sensitive
Maintenance
loss ofhabitat, Habitat
Contaminants,
disturbance caro cause
Individuals
Sheltering
distribution
waterbodies between November 15 -April l (FESS pg 4-252). RLP TOYR is March
degradation, Physical
Alteredflow
increase in sedimentation and
15 -June 30 so this only somewhat benefits the RLP. In addition the ECS outlines the
impacts to individuals,
turbidity, Equipment located
use of erosion control measures and restoration ofgraded areas.
Reduction of preyo
stream or tributary can
Population
ase chance of spills,
altered flow velocities and
temporary impoundment
firmn- waterwork, minor
e from co.structum
activities in water.
Operation&
General Appurtenance and Cathodic Protection Construction
Habitat degradation and
Sedmmemation,
denuding bank, grubbing
Unlikely
NA
NA
NA
LAA
The FEIS states that grubbing will not occur within 50 feet of ESA sensitive
Maintenance
- Off ROW Clearing
water quality
Increase in Water
with heavy equipment,
waterbodies between November 15 -April l (FESS pg 4-252). RLP TOYR is March
degradation, Stress on
Temperatures,
disturbing soil, water quality
15 -June 30 so this only somewhat benefits the RLP. In addition the ECS outlines the
individuals, Reduction in
Decrease of
degradation since vegetation
eoferosion control measures and restoration ofgraded areas.
prey population
dissolved oxygen
no longer provides shade to
stream
Operation &
General Appurtenance and Cathodic Protection Construction
Temporary loss of
Sedmmentation,
new, m -stream, and tributary
Habitat, Population,
Harass, Hour, Kill
Breeding Feeding,
Numbers, reproduction,
LAA
Trenching will cause sedmmentation. Moderately silted and high turbidity areas will be
Maintenance
- trenching anode, bell hole
habitat, Water quality
Short -tern uttered
earth dimubance may result
Individuals
Sheltering
distribution
unusble to RLP for foroging and spawning in the immediate vicinity ofthe crossing.
degradation, Physical
flow, Contaminants
i increased sedimentation,
Heavy siltation is also Anticipated to result in a loss ofprey items.
impacts, Reduction of
uttered flowresultm
prey population
increased sednmentation and
short-teno impoundment,
contaminant spills firm
equipment located in- stream
and tributary, noise from in
water work
Operation &
Inspection Activities - ground and aerial
Neutral
Nove
NA
NA
NA
NA
NA
NE
No nnpacts to stream habitats are anticipated from this action. Will not introduce
Maintenance
sediment or contaminants into the streams or rivers.

Table 4. Analysis of effects on Clubshell.
W
IMMU."TWUMMfM
New Disturbance -
Vehicle Operation and Foot
neutral
none
NA
NA
NA
NA
NA
NLAA
Foot traffic and vehicle operation is not likely to adversely affect
Construction
Traffic
clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
Clearing -herbaceous vegetation
habitat degradation
altering habitat
increased
juveniles, adults
harm, harass
feeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
and ground cover
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
Clearing -trees and shrubs
habitat degradation
altering habitat
increased
juveniles, adults
ktarm, harass
seeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
New Disturbance -
Vegetation Disposal (upland) -
Construction
dragging, chipping, hauling,
neutral
none
NA
NA
NA
NA
NA
NE
Vegetation disposal will not effect clubshell.
piling, stacking
New Disturbance -
Vegetation Disposal (upland) -
neutral
none
NA
NA
NA
NA
NA
NE
Brush pile burning will not effect clubshell.
Construction
brush pile burning
New Disturbance -
Vegetation Clearing - tree side
Construction
trimming by bucket truck or
neutral
none
NA
NA
NA
NA
NA
NE
Side trimming of trees will not effect clubshell.
helicopter
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
Grading, erosion control devices
habitat degradation
altering habitat
increased
juveniles, adults
ktarm, harass
feeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
Trenching (digging, blasting,
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
dewatering, open trench,
habitat degradation
altering habitat
increased
juveniles, adults
ktarm, harass
seeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
sedimentation)
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
New Disturbance -
Pipe Stringing - bending,
Construction
welding, coating, padding and
neutral
none
NA
NA
NA
NA
NA
NE
Pipe stringing will not effect clubshell.
backfilling
New Disturbance -
Hydrostatic Testing (water
neutral
none
NA
NA
NA
NA
NA
NE
No water withdrawals from Hackers Creek or nearby streams.Water will
Construction
withdrawal and discharge)
be jumped between segments and not discharged near clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
increased
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
Regrading and Stabilization -
habitat degradation
altering habitat
sedimentation and
juveniles, adults
harm, harass
feeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
restoration of corridor
contaminant
sheltering
can result in reduced physiological function; depressed rates of growth,
impacts to habitat
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
New Disturbance -
C Facility, noise
neutral
none
NA
NA
NA
NA
NA
NE
Noise will not effect clubshell
Constructionompression
New Disturbance -
Communication Facility - guy
neutral
none
NA
NA
NA
NA
NA
NE
Noise and lights will not effect clubshell.
Construction
lines, noise, lights

Table 4. Analysis of effects on Clubshell.
Stressor
Stressor Pathway
(optional)
Exposure (Resource
Affected)
Range of
Response
Conservation
NeedAffected
Demographic
Consequences
NEorNLAA,
orLAA
Corainents
I
Increased sediment load to stream will impair feeding of clubshell.
dislocating and
Mussel gills can become overwhelmed with excessive suspended
Access Roads - upgrading
physical impact to
direct impacts to
crashing
breecling,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
existing roads, new roads temp
individuals, habitat
individuals,
individuals,
juveniles, adults
kill, harm,
feeding,
numbers
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
and permanent -grading,
degradation
altering habitat
alteration of
harass
sheltering
can result in reduced physiological function; depressed rates of growth,
graveling
aquatic habitat
reproduction, and recruitment Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
Access Roads - upgrading
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
existing roads, new roads temp
habitat degradation
altering habitat
increased
juveniles, adults
harm, harass
feeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
and permanent - culvert
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
installation
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
Increased sediment load to stream will impair feeding of clubshell.
Mussel gills can become overwhelmed with excessive suspended
Access Roads - upgrading
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
existing roads, new roads temp
degradation
altering habitat
increased
juveniles, adults
harm, harass
feeding,
reproduction
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
and permanent - tree trimming
sedimentation
sedimentation
sheltering
can result in reduced physiological function; depressed rates of growth,
and tree removal
reproduction, and recruitment. Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
New Disturbance -
Stream Crossings, wet ditch
neutral
none
NA
NA
NA
NA
NA
NE
No wet ditch crossings near clubshell.
Construction
Installation of crossing structures may cause increased sediment load to
stream will impair feeding of clubshell. Mussel gills can become
dislocating and
overwhelmed with excessive suspended sediment, causing a mussel to
New Disturbance -
physical impact to
direct impacts to
crushing
kill ktarm
breeding,
either reduce its water and food intake rate or close altogether. Increased
Construction
Stream Crossings, flume
individuals, habitat
individuals
individuals,
juveniles, adults
, ,
harass
feeding,
numbers
LAA
turbidity causing impaired feeding can result in reduced physiological
degradation
alteration of
sheltering
function; depressed rates of growth, reproduction, and recruitment
aquatic habitat
Siltation resulting from increased seidment loads may also alter and
degrade habitat conditions which may suffocate and kill some individual
clubshell.
Installation of crossing structures may cause increased sediment load to
stream will impair feeding of clubshell. Mussel gills can become
dislocating and
overwhelmed with excessive suspended sediment, causing a mussel to
New Disturbance -
physical impact to
direct impacts to
crushing
kill, ktarm
breeding,
either reduce its water and food intake rate or close altogether. Increased
Construction
Stream Crossings, dam &pump
individuals, habitat
individuals
individuals,
juveniles, adults
,
harass
feeding,
numbers
LAA
turbidity causing impaired feeding can result in reduced physiological
degradation
alteration of
sheltering
function; depressed rates of growth, reproduction, and recruitment
aquatic habitat
Siltation resulting from increased seidment loads may also alter and
degrade habitat conditions which may suffocate and kill some individual
clubshell.
New Disturbance -
Stream Crossings, cofferdam
neutral
none
NA
NA
NA
NA
NA
NE
No cofferdam crossings near clubshell.
Construction
New Disturbance -
Stream Crossings, Horizontal
neutral
none
NA
NA
NA
NA
NA
NE
No HDD in VJV.
Construction
Directional Drill (HDD)
New Disturbance -
Stream Crossings, conventional
neutral
none
NA
NA
NA
NA
NA
NE
No horizontal bore in W V.
Construction
bore
New Disturbance -
Stream Crossings, direct pipe
neutral
none
NA
NA
NA
NA
NA
NE
No direct pipe crossings near clubshell.
Constmction
Installation of crossing structures may cause increased sediment load to
stream will impair feeding of clubshell. Mussel gills can become
dislocating and
overwhelmed with excessive suspended sediment, causing a mussel to
New Disturbance -
Stream Equipment Crossing
physical impact to
direct impacts to
crushing
kill, ktarm,
breeding,
either reduce its water and food intake rate or close altogether. Increased
Construction
Structures
individuals, habitat
individuals
individuals,
juveniles, adults
harass
feeding,
numbers
LAA
turbidity causing impaired feeding can result in reduced physiological
degradation
alteration of
sheltering
function; depressed rates of growth, reproduction, and recruitment
aquatic habitat
Siltation resulting from increased seidment loads may also alter and
degrade habitat conditions which may suffocate and kill some individual
clubshell.

Table 4. Analysis of effects on Clubshell.
Stressor
Stressor Pathway
(optional)
Exposure (Resource
Affected)
Range of
Response
Conservation
NeedAffected
Demographic
Consequences
NEorNLAA,
orLAA
Counnents
Installation of crossing structures may cause increased sediment load to
stream will impair feeding of clubshell. Mussel gills can become
dislocating and
overwhelmed with excessive suspended sediment, causing a mussel to
New Disturbance -
Crossings, wetlands and other
physical impact to
c
diret impacts to
crushing
killharm,
breeding,
either reduce its water and food intake rate or close altogether. Increased
Construction
water bodies (non -riparian)-
individuals, habitat
individuals
individuals,
juveniles, adults
,
harass
feeding,
numbers
LAA
turbidity causing impaired feeding can result in reduced physiological
clearing
degradation
alteration of
sheltering
function; depressed rates of growth, reproduction, and recruitment.
aquatic habitat
Siltation resulting from increased seidment loads may also alter and
degrade habitat conditions which may suffocate and kill some individual
clubshell.
New Disturbance -
Crossings, wetlands and other
Construction
water bodies (non -riparian) - tree
neutral
none
NA
NA
NA
NA
NA
NE
Side trimming will not adversely affect clubshell.
side trimming
Increased sediment load to stream will impair feeding of clubshell.
dislocating and
Mussel gills can become overwhelmed with excessive suspended
Crossings, wetlands and other
physical impact to
crushing
breeding,
sediment, causing a mussel to either reduce its water and food intake
New Disturbance -
water bodies (non -riparian) -
individuals, habitat
direct impacts to
individuals,
juveniles, adults
kill, ktarm,
feeding,
numbers
LAA
rate or close altogether. Increased turbidity causing impaired feeding
Construction
grading, trenching, regrading,
degradation
individuals
alteration of
harass
sheltering
can result in reduced physiological function; depressed rates of growth,
dewatering, restoration
aquatic habitat
reproduction, and recruitment Siltation resulting from increased
seidment loads may also alter and degrade habitat conditions which may
suffocate and kill some individual clubshell.
New Disturbance -
Crossings, wetlands and other
Construction
water bodies (non -riparian) - pipe
neutral
none
NA
NA
NA
NA
NA
NE
Pipe stringing will not adversely affect clubshell.
stringing
New Disturbance -
Crossings, wetlands and other
Construction
water bodies (non -riparian) -
neutral
none
NA
NA
NA
NA
NA
NE
No HDD in W V.
HDD
New Disturbance -
Crossings, wetlands and other
Construction
water bodies (non -riparian) -
neutral
none
NA
NA
NA
NA
NA
NE
No conventional bore in W V.
conventional bore
Operation &
Facilities - vehicles, foot traffiqTake
neutral
none
NA
NA
NA
NA
NA
NLAA
due to sedimentaiton is assumed from other activities occurring on
Maintenance
noise, communication facilities
the pipeline corridor prior to these activities.
Operation &
Vegetation Management -
neutral
none
NA
NA
NA
NA
NA
NE
Mowing will not effect clubshell.
Maintenance
mowing
Operation &
Vegetation Management -
neutral
none
NA
NA
NA
NA
NA
NLAA
While this activity may increase sediment loads, the effects will be
Maintenance
chainsaw and tree clearing
temporary and is not likely to adversely affect clubshell.
Operation &
Vegetation Management -
Maintenance
herbicides - hand, vehicle
neutral
none
NA
NA
NA
NA
NA
NE
mounted, aerial applications
Operation &
Vegetation Disposal (upland) -
Maintenance
dragging, chipping, hauling,
neutral
none
NA
NA
NA
NA
NA
NE
Vegetation disposal will not effect clubshell.
piling, stacking
Operation &
Vegetation Disposal (upland) -
neutral
none
NA
NA
NA
NA
NA
NE
Brush pile burning will not effect clubshell.
Maintenance
brush pile burning
Operation &
Vegetation Management - tree
Maintenance
side trimming by bucket truck or
neutral
none
NA
NA
NA
NA
NA
NE
Side trimming of trees will not effect clubshell.
helicopter
Operation &
ROW repair, regrading
While this activity may increase sediment loads, the effects will be
Maintenance
revegetation (upland) -
neutral
none
NA
NA
NA
NA
NA
NLAA
temporary and is not likely to adversely affect clubshell.
hand, mechanical
Operation &
ROW repair, regrading,
Maintenance
revegetation (wefland) -
neutral
none
NA
NA
NA
NA
NA
NLAA
Physical impacts to weflands would not likely transport to streams.
hand, mechanical
Operation &
ROW repair, regrading
While this activity may increase sediment loads, the effects will be
Maintenance
revegetation - in stream
neutral
none
NA
NA
NA
NA
NA
NLAA
temporary and is not likely To adversely affect clubshell.
stabilization and/or fill
Operation &
Access Road Maintenance -
neutral
none
NA
NA
NA
NA
NA
NLAA
While this activity may increase sediment loads, the effects will be
Maintenance
grading, graveling
temporary and is not likely to adversely affect clubshell.
Operation &
Access Road Maintenance -
neutral
none
NA
NA
NA
NA
NA
NLAA
While this activity may increase sediment loads, the effects will be
Maintenance
culvert replacement
temporary and is not likely to adversely affect clubshell.
Operation &
General Appurtenance and
While this activity may increase sediment loads, the effects will be
Maintenance
Cathodic Protection Construction
neutral
none
NA
NA
NA
NA
NA
NLAA
temporary and is not likely to adversely affect clubshell.
- Off ROW Clearing

Table 4. Analysis of effects on Clubshell.
Stressor Stressor Pathway Exposure (Resource Range of Conservation Demographic NEorNLAA, Counnents
(optional) Affected) Response Need Affected Consequences or LAA
Operation &
Maintenance
General Appurtenance and
Cathodic Protection Construction
- trenchng, anode, bell hole
neutral none NA NA NA NA NA NE These activities will not effect clubshell.
Operation &
Maintenance
Inspection Activities - ground and
aerial
neutral none NA NA NA NA NA NE Inspection activities will not effect clubshell.

Table 5. Analysis of effects on RPBB.
human activity&d-lbance
det-eered foreging;
humanpre,ence
dll life stages
Kilt, hams hare„
breeding, feeding, sheltering
arab t -;reproduction
LAA
Vehicle opt-etion off e,tdblished roads may t-ush RPBB individoelx Therei,noe,td
New C-lbance-C—ttd t
Vehicle Op—b- end Foot Trattic
t- Ntg colonies or
that vehicle operation dt low speeds on e,Nbh,Nd,,dd, w ldi pad,.N,Nd lRPBB.
t-wi -tg queen,
Foot traffic is not ezp,d,d N t-u,h RPBB.
clearing of floral hab iter human
eltt-etion of,ummer
v egefation removal; human
ell life stages
kill, harm, harass
breeding, feeding, sheltering
umb—,reprodoction
LAA
Clearing ofherbaceonsvegetat- while RPBB are present in hdN.t is e,,c.d N haves
activity&d-lbance
foreging habitat,&colony
presence
d-ct effed on thegoahty, quantity, dnd timing of floral r„ ,,,—by reducing
New D-lbance-Construction
Clearing- herbaceoosvegetationdnd
grwnd cover
habitat; det-eared foraging
efficiency; em,hing
ivebility andreprododive success of queens; egoipmentosed could emsh individoels,
queens or coloni,s.
individuals, colonies or
t-wintt-ing queens
clearing of foreging habitat; human
eltt-etion of summer
v egetation remov al; human
dll life Ndge,
kill, harm, harass
breeding, sheltering
umb—,reprodoction
LAA
Clearing oftrees dndstwb, while RPBB are presort N habitat is bp,cted to have a direct
activity&d-lbance
foreging habitat,&colony
presence
effect on the quality, quantity, endtiming of tlorel resowce; tht-eby reducing
New Disturbance-Conshvetion
Clearing -trees
habitat; de foreging
survivabirlity dndrep,tdodi success ofq.,,t,, ego,p I,, d could ­,Nh itdi ttdls,
end shmbs
C ltd
efficiency; emshing
queens ocolonies.
individoels, colonies or
t-wintt-ing queens
human activity&d-lbance
altt-ation ofsummer
dll life Ndge,
kill, harm, harass
breeding, feeding, sheltering
umb—,reprodoction
LAA
Vegetation disposal may ­,Nforaging inddual,
V egetdtion Disposdl (opldnd) -
foreging habitat, & colony
New D-lbance-Conshvetion
drdgg�ng cNpp�nghaohng,,htg,
habifaf;d--di foreging
Ndcking
&hovel efflc—cy,
t-u,Nng�,d,,,d,,l, in
colonies or overwint g
New D-lbance-Conshvetion
Vegetation Disposdl(opldnd)-brush
human acti,±y&NN.,b,bt, smoke
det-eared foreging
moke; human presence&
dll life Ndge,
one e,,c.d
NA
NA
NLAA
Smoke;Halation may dg-, bees Ill response is not eN,ded N be detrtt-1
pile burning
Vegetation Clearing -tree side
No side trimming occurs for new
NA
NAS,
NA
NA
NA
NA
NE
NA
New Disturb -1
trimming by bockd hvck or
-1-cfioa
h,hb,.,
altt-etion of—, flow, veg,Nt-
d1­7of foraging
vegetation removal; human
dll life Nag,,
kill, harm, harass
breeding, feeding, sheltering
umbo;reprodoction
LAA
Con,frvd tesroc ted with gbdNtg dnd t -o, -1 devices could ­,Nforeging
New D-lbance-Conshvetion
(Ndding t-osion -1 devices
ov al; human adi,dy
habitat
presence
itdi ttdl,ifconductedin—
Trmching(Ngg,tg, bld,btg,
human dctivity; ground disturbance;
NA
in,heam sedimentation&
-11,1y
one e,,c.d
NA
NA
NLAA
This ad-ty is not e,,cNd to occurNHPZ
New D-lbance-Con,hvetion
dewatering, op­tch,
in,tream&riparian d-lbance;
watt- flow N-pt—,human
sedimentation)
tcmporery dewd—g
presence&noise
New DINdlbance-Comb ,e
IN, Stringing -bending welding
coating, pddNtgand backfilling
human activity
NA
human presence&noise
oNN,1Y
one e,,c.d
NA
NA
NLAA
Noi,et-ed.d Gom this ad-ty is anticipated N be insignificant and insignificant ­
cant notre,lt,t
N—bance ofRPBB.
New Disturbance-Conshvetion
Hydrostatic Te,ting(wata
withdrawal/discharge ofwatt- into
NA
watt- dl—b-,human
oNN,1Y
one e,,c.d
NA
NA
NLAA
This ad-ty is not e,,cNd to occurNHPZ
withdrawal dnd N,charg)
dgoatic hdN.., human d—ty
presence&noise
human activity&d-lbance
Removal of foraging
habitat disturbance, human
dll life Nag"
kill, harm, harass
breeding, feeding, sheltering
umb—,reprodoction
LAA
Con,'ry tesroc ted with this dctivity c ld crush foraging individuals ifc-d—din
New D-lbance-Comb ,e
Regrading dnd Stabilization-
ruNbdb,t ofc ,dor
vegetation and nesting
habitat; t-u,Ntg of
presence&noise
HPZ
individual,
New D-lbance-Conshvction
Compression Facility, noire
„e disturbance
NA
human presence
oNN,1Y
one e,,c.d
NA
NLAA
NN, et-eetcd—this ad-ty is anticipated N be insignificant and w wld notresult,n
N—bance N RPBB.
New D, urb ante-Conshvction
Communication Facility-
goy lines, noise, lights
human activity and facilities
NA
human presence
oNN,1Y
one e,,c.d
NLAA
NN, et-eetcd—this dd-ty is anticipated N be insignificantandwwldnotre,ul-
N—bance N RPBB.
altt-ation of surface weer flow,
Remo, al of foraging
oval of foraging habitat
dll life Nag"
kill, harm, harass
breeding, feeding, sheltering
umb—,reprodoction
LAA
Con—naso—bbd with this dctivity coNd crush foraging individuals ifc-d—din
Access Rodd, -upgrading -.g
vegetation r—o,dl, human activity
vegetation end nesting
HPZ
New D-lbance-Con,hvction
roads, new road, t—p dnd
habitat,t- Nng of
permanent -grading graveling
inN,N.N, in colon;,, or
t-wi -ng
treer oval, to„ or altt-ation of
Removal of foraging
vegetation removal; human
all life Nage,
kill, harm, hare„
breeding, feeding, sheltering
umb—,reprodoction
LAA
Con—na—tated with this activity could crush foraging individual, ifc-d-ed in
Acca„ Rodd, -upgrading -.g
forested habitat; human disturbance
vegetation and nesting
presence
HPZ
New D-lbance-Con,hvction
roads, new road, t—p and
habitat,t- Nng of
pernanent-cul—Aallat—
inNvN.N, in colon;„ or
t-wi -ng
Acce„Road, -opgbdNng ezi,ting
tree moval, to„ or altt-at-of
Removal of foraging
vegetation removal; human
all life Nage,
kill, harm, hare„
breeding, feeding, sheltering
umb—,reprodoction
LAA
Tree r—oval could crush foraging individual,.
roads, new roads tt-np and
forest ed hab rtat; human disturbance
vegetation and nesting
presence
New Disturbance-Conshvetion
pernanent h 1-ttingandhee
habitat; t-u'hNngof
inNvN.N, in colon- or
oval
t-wi -ng
New D-lbance-Con,hvction
Stream Cro„ing,, wet open cut ditch
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Disturb ante-Con,hvction
Stream Cro„ing,, flume
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Disturb ante-Con,hvction
Stream Cro„ing,,dem&pomp
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Disturb ante-Con,hvction
Stream Cro„ing,, cofferdam
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Disturb ante-Con,hvction
Stream Cro„ing,, Horizontal
RPBB not pr„ent
NA
NA
NA
NA
NA
NA
NE
NA
D -d -al Drill (HDD)
New Di ,bance-Con,hvction
Stream Cro„ing,, conn rational bore
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Di ,bance-Con,hvction
Stream Cro„ing,, direct pipe
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New
Stream Ego�pment Crossng
RPBB not pr„ent
NA
NA
NA
NA
NA
NA
NE
NA
D-lbance-
Con,—on
Shvch�re,
New Disturb ante-Con,hvction
Crossings,—land, and other water
RPBB not pr„ent
NA
NA
NA
NA
NA
NA
NE
NA
both„ (non -riparian) - clearing
Crossing,, wetland, and other water
No side trimming occurs for new
NA
NA
NA
NA
NA
NA
NE
NA
New Disturb ante- Con,hvction
boNe,(non riparian) lee s,de
on,f bon
-ng
Crossings, wetland, and other water
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
New Di,Nrb ante-Con,hvction
bo—,(non riparian) grading
benching, regbdNng
New D-lbance-Con,hvction
C, ,,ng,, wetland, and other water
RPBB not pr„ent
NA
NA
NA
NA
NA
NA
NE
NA
boNe,(non riparian) pNe, ngmg
New Disturb ante-Con,hvction
Crossings, wetland, and other water
both„ (non -riparian) - HDD
RPBB not p—ent
NA
NA
NA
NA
NA
NA
NE
NA
Crossing,, wetland, and other water
RPBB not pr„ent
NA
NA
NA
NA
NA
NA
NE
NA
New Di,Nrb ante-Con,hvction
boNe,(non -riparian) conventional
bore
FactLe, vehicle,, fol haffc,
e a,ed human activity/NNulance
det-eared foreging
human presence; vehicle
um
all life Nage,
Kilt, ham,, hares,
breeding, feeding
umbt-;reprodoction
LAA
Vehicle trafFemay crush fo
RPBB reging along roadside,. Traffic may disrupt foreging
Op t-abon&Maintenance
wication fac,hte,
'
efficiency; em,hing
individual,
traffic
behavior end di,placemdi dual RPBB,.
to„oral—bonofforededhabbat;
det-ea,ed foreging
vegetation removal
all He Nagel
one expected
NA
NA
NLAA
Mowing may reduce RPBB foraging--ce,,altt-ation ofhabblt, mowing blade,may
Opt-abon&Maintenance
Vegetation management -mowing
ea,ed human activity/NNulb—,
efficiency;
-,N -BB Con,e,ato ea, Ntta,Ianeminvnum blade height of 10 inch„
during maintenance of the ROW should signiflcanfly reduce the likelihood ofimpec6
from emshing

Table 5. Analysis of effects on RPBB.
Ions f foreging habitat;
alteration of,.,,
-g-- removal; h -man
ell life stages
Kilt, hams hares,
breeding feeding sheltering
umber, reprod-etion
LAA
Veg,lO,n eltere — t, foraging habits ,-Id be smell. Tree felling end heavy
Operation&Maintenance
Vegetation Management-chainsaw
end tree clearng
—,dhuman t,Oy/disturbance
f,reginghabifet,&nesting
habitat; loll or nj-re
disturbance
eq-ipmentmey.,h foreging individ-als
awintering queens
Vegetation Management -herbicides
d'ern�enl co1-0', vegdati,n
lethalo„ublethal exposure
contamination O—b,&
all life stages
one expected
NA
NA
NLAA
Voluntary consavetion meeswe l avoid aerial or broadcast pedicide end herbicide
Operation&Maintenance
- hand, vehicle mounted, aerial
loss; loss of floral heb iter
lt,xn;eltere If 1-1
veg--, to,,,f foraging
application Use oftargetedry0Tb,,ng„ wiping„ mednical pulling l target
applications
coeridors, summer f—,,vegetation
Md—
(e g. rhododendrons
end woody fl --g O,ub,)
es�ve end noxious weed,.
Vegetation O,p„al(-pland)-
human actio ity&d-lbance;
to„o, a1—O,n ofne,ting,
-g-- removal; human
all life stages
kill, harm, here„
breeding, sheltering
umber;reproduction
LAA
Vegetation disposal may cm,h individual,.
Operation&Maintenance
dragging chipping hauling, piling
/shaded nest entrances
awintering habitat
disturbance
stacking
Op nation&Maintenance
Vegetation Di,p„al(-pland)-brush
pile burning
human activity&d-,bance; smoke
disturbancehabitat
spoke iMalati,n
smoke N foraging or nesting
all life stages
one expected
NA
NA
NLAA
Reryonse,f—,t,sn,ke —1 expec.dt, be detrimental.
lo„ or a1_O,n of foreging habitat;
alteration of foraging
-g-- removal; human
-likely
one expected
NA
NA
NLAA
AMM, minimize potential effect,; vegdati,n alteration, t, foreging habitatshould be
Vegetation Management--lde
h -men dishubance; ccmpedion of soil
habOf%t lGrationofneg
disturbance
s.11.N,i,eand—,Ay level, are anticipated l be low with n,d-lbance t,,,Ionia,.
Operation&Maintenance
trimming by b-ckd truck or
end,vena..,.g heb iter
Altho-gh some foreging heb ifatmey be alterect, we do not expect indiredetfec6 to occur
heli,, .,
because the m j -y ,fhabif—Ol n,tbe altered. Trimming may resit N —reesed light
to the forest floor, creating opportunity for inereared floral resowces Effed, are expected
to be in,igniflcant
tree,ern,vat; loss or alteration offl—1
alteration of summer
-g--
all life stages
Kilt, ham,, hare„
breeding, feeding, sheltering
umber;reprod-etion
LAA
ROW repays occurN areas,f„il erosion where floret--, may be,fhigher
Operation&Maintenance
ROW ,peb, regrading r,,,g--
(-Aland)- hand,mechanical
resowces and forested habitat, h -men
disturbancehabitat,
foreging habitat,&colony
noshing ofcolome,
disturbance
q-alAy.ROW,e,,-.y,em,venestingheb ilS or nosh individ-els.
& overv✓intering q-een,
Operation&Maintenance
ROW repay, regrading r,,,g--
(wetland) -h and, mechanical
tree,er-1, to,,,, alteration of
forested heb alt; human disturbance
alteration of summer
f—,,heb iter
-g-- removal; h -men
d„tu,bance
all life stages
one expected
NA
NA
NLAA
Thesnellareeand level of vnpeR I—the,e activities is not expelled t, have notice able
webleimp—on RPBB„ they foraging habitat
Operation&Maintenance
ROW repay, regradingr,,,g--
n stream s.bl-O-and/,, fill
tree,er-1, to,,,,alteration of
forested habitat; human disturbance
alteration of summer
foreging habitat
-g-- removal; h-men
d„tu,bance
-lldsely
one expected
NA
NA
NLAA
The snail area and level,fvnp Rl.the,eactivitie- isnot expelled[,have noticeable
—blei,—on RPBB„ they habitat
oval; loss„ altereti,n,f floret
altereti,n,f summer
-g-- h -men
all life stages
kill, harm, hare„
feeding breeding, sheltering
umber;reprod-di,n
LAA
Veg,lO,n alt—twill rernoveh#q-ality foreging habitat, impeding,urvival and
Operation&Maintenance
Acca„ R,ad Maintenance -Wading,
gravelinghabitat,
habitat, human disturbance
foreging habitat,&colony
—,hing,fcl,me,
disturbance
reprod-dioa Ad,ft-,.ld em,h individ-als
&,venaiI—g q-een,
I,e,er-1, l,,,,, alteration offl—1
altereti,n,f,umme,
v egdation,em,val, h -men
all He stage,
one expected
NA
NA
NLAA
The matterea and level,f vnp act 1. these -,Oe, is not expeded[,have noticeable
Operation&Maintenance
Acca„ R,ad Maintenance c-Ivert
replacementhabitat,
habitat, human disturbance
f—,,habitat,&colony
noshing O-l—e,
presence
meesweble imp—on RPBB„R—habitat
&,ve—le-g q-een,
lee,er-1, loss oreltereti d
l,,, or a1—O,n,f,umme,
v egdati,n,em,v al; h -men
all He stage,
one expected
NA
NA
NLAA
The snellareeand level,fvnpeR I—theseactivities isnot expelled[,have noticeable
Ge -1 App—,eand Cathodic
forested habitat; human disturbance
f—,,habitat(e g
presence
meesweble imp—on RPBB lthebhkitat
Operation&Maintenance
Protection —1— OffROW
rhododendron,);
Clearing
awintering habitat
Oenerel Appurtznance and Cathodic
h-mend-,bance
deerea,ed f—,,—Wel
humanpre,ence
all He stage,
one expected
NA
NA
NLAA
The snellareeand level,f vnpeR I—these activities is not expelled[,have noticeable
Operation&Maintenance
P,otedi,n C,n,hvd- trenching,
efficiency
leimp—on RPBB lthebhkitat
bell hole
ranode,
Operation&Maintenance
Inspection Ad-te, gr,-ndand
h-mana,t,-,t,
deerearedf,reging&bevel
humanpre,ence
ell life stage,
one expected
NA
NA
NLAA
The level O,,,p Ifromthe,eaR—e, is not erpectedt, have noticeable or measureble
rial
efficiency
impacts ,n RPBB or their habitat

Table 6. Analvsis of effects on Madison Cave isonod.
New
Vehicle Operation and Foot Traffic
Physical impacts to
chemical contaminants
NA
NA
NA
NA
NA
NLAA
No impacts from foot traffic. AMMs address contaminants from vehicles.
Disturbance -
individuals
Constmction
New Distadbance
Clearing -herbaceous vegetation and ground cover
Physical impacts to
smothering sedmm munion,
NA
NA
NA
NA
NA
NLAA
Prmmary compact firm new construction is firm earth disturbing actions (grading and
- Construction
individuals, Habitat
changes in hydrology
trenching) not firm the vegetation removal. ACP has committed to AMMs to address the
alteration
potential for this impact. Details are located in the Karst Tenain Assessment Construction,
Monitoring and Mitigation Plan (GeoConcepts Engineering Inc. 2017c) in Appendir.I of
the FEIS and e4-300 of the FEIS.
New Distu bmee
Clearing -trees and shmbs
Physical impacts to
smothering sedum munion,
NA
NA
NA
NA
NA
NLAA
Prnnary nnpactfinto new construction is firm earth disturbing actions (grading and
- Construction
individuals, Habitat
changes in hydrology
trenching) not firm the vegetation removal. ACP has committed to AMMs to address the
alteration
potential for this impact. Details are located in the Karst Tenain Assessment Construction,
Monitoring and Mitigation Plan (GeoConcepts Engineering Inc. 2017c) in Appendir.I of
the FEIS and page4-300 ofthe FEIS.
New Distu bmee
Vegetation Disposal (upland) - dragging chipping hauling,
Physical impacts to
chemical contaminants,
NA
NA
NA
NA
NA
NLAA
AMMs address potential contaminants frmm chipper. No stacking or piling will be done in
-
piling, stacking
individuals
smothering
potential MCI habitat.
Constmction
New Distubmee
Vegetation Disposal(upland) - brush pile boning
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from boning. Will not affect the MCI because they will not introduce
-
sediment or contaminants into the phmatic water.
Constmction
New Distobmee
Vegetation Clearing- tree side trimming by bocket truck or
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from tree trimming. Will not affeetthe MCI because they will not introduce
-
helicopter
sediment or contaminants into the phmatic water.
Constmction
New Disco bmee
Grading erosion control devices
Physical impacts to
smothering sedum munion
grading year the karst
individuals,
harass to
breeding feeding
munbens,
LAA
Grading redistributes and loosens soil making it more prove to erosion. Depending on the
- Construction
individuals, Habitat
s" disturbs the ground,
habitat
mortality
sheltering
reproduction
amount and speed ofthe erosion event, MCI will either avoid apanticalar am.mdil the
degradation
may cave in sinkholes,
sediment is settled Orbe smothered. Due to the distance from the eonstmetion ROW and
displaced topsoil and
ATW S (0.5 mi), we anticipate the population of MCI at the Barterbrooke Blue -Cave Hill
vegetation may be placed in
Conservation Site will receive little to no sedmmemtation and effects to MCI at this site is
k—t features
NLAA.
New Dista bmee
Trenching (digging blasting dewatering open trench,
Physical impacts to
smothering sedum munion,
digging into k—t areas
individuals,
harass to
breeding feeding
munbens,
LAA
Digging redistributes and loosens soil making it more prove to erosion. Depending on the
-Construction
sednmeotation)
individuals, Habitat
contaminants
emses direct movement of
habitat
mortality
sheltering
reproduction
amount and speed ofthe erosion event, MCI will either avoid a particular am.mdil the
degradation
sediments into MCI habitat
sediment is settled Orbe smothered. Loosened subsafface rocks from trenching or blasting
and may smother MCI,
is expected to dismpt the subsurface water flow and alter MCI travel em,idors. Trenching
blasting fractures the rock
or blasting is anticipated to intercept .subsurface void, creating a dvect conduit for soil
and materials may fall out
mm
and sedeut to enter into the subsurface habitat. These changes will render habitat
MCI either smothering or
temporarily or penmanemtly unsuitable fosse by the MCI and is likely to prevent
rushing
movements among or between populations. Due to the distance from the eonstmetion
ROW and ATWS (0.5 mi), we anticipate the population ofMCI at the Barterbrooke Blue -
Cave Hill Conservation Site will receive little to no sedmmemtation and effects to MCI at
this site is NLAA.
New Dista bmee
Pipe Stringing - bending, welding coating padding and
NA
NA
NA
NA
NA
NA
NA
NE
- Construction
backfilling
New Dista bmee
Hydrostatic Testing (wnerwithdmwal and discharge)
Physical impacts to
smothering sedum munion,
NA
NA
NA
NA
NA
NLAA
Hydro test water AMMs reduce any compacts to insignifiemtldiseoantable. Details are
- Construction
individuals, Habitat
chemical contaminants,
located in the Karst Tenain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes in hydrology
(GeoConcepts Engineering Inc 2017e) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Dista bmee
Regrading and Stabilization - restoration of corridor
Physical impacts to
smothering sedum munion,
NA
NA
NA
NA
NA
NLAA
AMMs address sedum munion, contaminants and impacts to k—t features. Details are
- Construction
individuals, Habitat
chemical contaminants,
located in the Karst Tenain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes in hydrology
(GeoConcepts Engineering Inc 2017e) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Dista bmee
Compression Facility, noise
NA
NA
NA
NA
NA
NA
NA
NE
No impacts anticipated firm noise.
Constmction
New Dista bmee
Communication Facility - guy lines, noise, lights
NA
NA
NA
NA
NA
NA
NA
NE
No impacts anticipated firm communication towers.
Constmction
New Dista bmee
Access Roads -upgrading existing roads, new roads temp and
Physical impacts to
smothering sedum munion,
NA
individuals,
breeding feeding
Creation ofnew safface features (roads) may alter hydrology. Grading redistributes and
- Construction
penmanem - grading graveling
individuals, Habitat
changes in hydrology,
habitat
sheltering
loosens soil making it more prone to erosion. Depending on the amount and speed of the
degradation
contaminants
mortality
ambers,repro
LAA
emsio. event, MCI will either avoid a particular areaantil the sedmmeut is settled or be
mothered. Any MCI present in the zones of compact will likely be crushed or smothered.
New Dista bmee
Access Roads -upgrading existing roads, new roads temp and
Physical impacts to
smothering sedum munion,
NA
individuals,
mortality
breeding feeding
ambers, repro
LAA
Digging redistributes and loosens soil making it more prove to erosion. Depending on the
- Construction
penmanem - culvert instullation
individuals, Habitat
changes in hydrology,
habitat
sheltering
amount and speed of the erosion event, MCI will either avoid apartic hn areaantil the
degradation
contaminants
sediment is settled or be smothered. These changes willmoder habitat temporarily or
permanently unsuitable for use by the MCI and is likely to prevent movements among or
between populations. We do not anticipate culvert installation would generate a sediment
plume large enough to smother MCI, nor do we anticipate culvert installation —old
loosen subsurface rocks, which could fall and crush MCI. Due to the distance from the
eonstmetion ROW and ATW S (0.5 mi), we anticipate the population of MCI at the
Bartedbrooke Blue -Cave Hill Conservation Site will receive little to no sednmemation and
effects to MCI at this site is NLAA.
New Distudomee
Access Roads -upgrading existing roads, newroads temp and
Physical impacts to
sednmentation
NA
NA
NA
NA
NA
NLAA
No impact anticipated firm selectivetree removal. AMMs addmm
ress sedentation. Details
- Construction
penmanent- treetrimming and tree removal
individuals, Habitat
are located in the Karst Tenain Assessment Construction, Monitoring and Mitigation Plan
degradation
(GeoConcepts Engineering Inc 2017e) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.

Table 6. Analvsis of effects on Madison Cave isopod.
Pipali—ActiAty 11W
-'1WFpct.,7h
(op all
Affa�tad)
ffadad
C—aq.:-:c;&
a, LAA
New Distaabaace
Stream Crossings, wet ditch
Physical impacts to
mothering, sed am.tatio.,
NA
NA
NA
NA
NA
NLAA
AMMs address sed am.tatio., contaminants and impacts to kmst features. Details are
- Construction
individuals, Habitat
chemical coatomiaams,
located m the Karst Teaain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes m hydrology
(G -Concepts Engineering Inc 2017c) m Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Dista boam-
Stream Crossings, flame
Physical impacts to
mothering sed am.tatio.,
NA
NA
NA
NA
NA
NLAA
AMMs address sed am.tatio., contaminants and impacts to kmst features. Details are
C— amtion
individuals,Habitat
chemical contminants,
located m the Kmst Teaain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes m hydrology
(G -Concepts Engineering Inc 2017c) m Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Distaabance
Physical impacts to
mothering sed am.tatio.,
NA
NA
NA
NA
NA
NLAA
AMMs address sed am.tatio., contaminants and impacts to kmst features. Details are
- Construction
individuals, Habitat
chemical contminants,
located m the Kmst Teaain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes m hydrology
2017c) m AppendiI ofthe FEIS and page 4-300 of the
ngeering Inc r.
(G -Concepts Ein
Stream Crossings, dam &pump
FEIS.
New Dista boam-
Stream Crossings, cofferdam
Physical impacts to
mothering sed am.tatio.,
NA
NA
NA
NA
NA
NLAA
AMMs address sed am.tatio., contaminants and impacts to kmst features. Details are
Comtmetion
individuals,Habitat
chemical contminants,
located m the Kmst Teaain Assessment Construction, Monitoring and Mitigation Plan
degradation
changes m hydrology
(G -Concepts Engineering Inc 2017c) m Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Distaabance
Physical impacts to
mothering sedam.tatio.,
NA
NA
NA
NA
NA
NLAA
HDD will not beaxed within mapped MCI poteotial habit. -am.
- Construction
individuals, Habitat
chemical contminanls,
degradation
changes m hydrology
Stream Crossings, Horizontal Dimdimml Drill (HDD)
New Distaabance
Physical impacts to
mothering sedam.tatio.,
NA
NA
NA
NA
NA
NLAA
Conventional bore willnot be axed within MCI poteotial habitat.
- Construction
individuals, Habitat
chemical contminanls,
degradation
changes m hydrology
Stream Coa.mgs, oven do ml bore
New Distaabance
Physical impacts to
mothering sedam.tatio.,
NA
NA
NA
NA
NA
NLAA
Direct pipe will not be axed within MCI poteotial habitat
- Construction
individuals, Habitat
chemical contminanls,
degradation
changesm hydrology
Stream Crossings, direct pipe
New Distaabance
Stream Equipment Crossing Sm-tores
NA
NA
NA
NA
NA
NA
NA
NE
Impacts from stream crossings considered above
- Construction
New Distaabance
Crossings, wetlands mad other water bodies (non -riparian) -
Physical impacts to
mothering sed am.tatio.
NA
NA
NA
NA
NA
NLAA
AMMs address sed am.tatio., contaminants and impacts to kmst features. Details are
- Construction
clewing
individuals,Habitat
located m the Kmst Teaain Assessment Construction, Monitoring and Mitigation Plan
degradation
(G -Concepts Engineering Inc 2017c) m Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
New Distaabance
Crossings, wetlands aml other water bodies(non-ripmian) -
NA
NA
NA
NA
NA
NA
NA
NE
No anticipamdnnpacts firm tree trimming. Will not affect the MCI becmise they will not
-Construction
tree side tramming
introducedoat or contammamb, into the phooatic water.
New Distaabance
Crossings, wetlands mid other waterbodies mon—riparian)-
Physical impacts to
mothering sed—tatio.,
grading activity di—bs the
individuals,
harass to
breeding feeding
ambers, repro
LAA
Grading redistributes and loosens soil making it more prove to erosion. Depending on the
- Construction
grading trenching regrading
individuals, Habitat
contaminants
ground and sedin, natation
habitat
mortality
sheltering
mmamt and speed of the erosion event, MCI may either avoid apmticalar meaantil the
degradation
into possible connections to
sediment is settled or be mothered. Loosened subsurface rocks from trenching may
MCI habitat. Trenching
disrupt the subsurface water flow and alter MCI travel condom. Trenching may intercept
may result m connections
a subsurface void, creating a direct conduit for soil mid sediment to enter into the
with subsurface habitat.
subsurface habitat. These chaages willrender habitat tmpmmily or pe mmmly
suitable for ase by the MCI and is likely prevent movements among or between
populations.
New Distaabance
Crossings, wetlands aml otherwaterbodies (non -riparian) -
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from pipe stringing component of activity.
- Construction
pipe stringing
New Distaabance
Crossings, wetlands aml otherwaterbodies(non-ripmian)-
Physical impacts to
mothering sednm tation,
NA
NA
NA
NA
NA
NLAA
HDD willnot be axed within mapped MCI poteotial habit. -am.
- Construction
HDD
individuals, Habitat
chemical contminants,
degradation
changesm hydrology
NewDistadsance
Coassums,walands aml otherwaterbodies(non-riparian)-
Physical impacts to
chemical contminants
NA
NA
NA
NA
NA
NLAA
Conventional bomwillnotbe axed within mpImd MCI potential habit. -am.
-
nventionm bore
individuals
Const—tion
Operation &
Facilities -vehicles, foot haffiq noise, communication
Physical impacts to
chemical contminants,
NA
NA
NA
NA
NA
No impacts from foot traffic. AMMs address contminants and sed nm tatio t firm
Maintenance
facilities
individuals
sed nm tatio t
general vehid—s, NOTE vehicle impacts for all O&M s tbwtivities are evalaatedimm
NLAA
(i.e., vohkh,nnpacts willnot be considomdander the remaining O&M aolowtivities).
Details are located m the Karst Teaain Assessment Construction, Monitoring aml
Mitigation Plan (G -Concepts Engineering Inc. 2017c) m Appendix I ofthe FEIS and
page 4-300 of the FEIS.

Table 6. Analvsis of effects on Madison Cave isonod.
Operation &
Vegetation Management- mowing
NA
NA
NA
NA
NA
NA
NA
NE
Mowing is not an earth distumimg activity -va expected increased sed a captation or
Maintenance
omommantion from mowing.
Operation &Vegetation
Management- chainsaw and tree clearing
Physical impacts to
sedimentation
NA
NA
NA
NA
NA
NLAA
No impact from selective tree removal. AMMs address sedimentation. Details are located
Maintenance
individuals, Habitat
in the Karst Teaaim Assessment Construction, Monitoring and Mitigation Plan
degradation
(GeoConcepts Engineering, Inc 2017c) in Appe nlir. I ofthe FEIS and page 4-300 of the
FEIS.
Operation&
Vegetation Management - hebicides- hand, vehicle mounted,
Physical impacts to
chemical contaminants
NA
NA
NA
NA
NA
NLAA
AMMs addresshebicides. Details are located in the Karst Teaaim Assessment
Maintenance
aerial applications
individuals
Construction, Monitoring and Mitigation Plan(GeoConcepts Engineering, Inc. 2017c) in
Appendix. I of the FEIS and page 4-300 ofthe FEIS. No spraying of insecticides or
hedbicides wouldbe aIlo—dwithi. the 300 ftkarst featare buffer, exceptwhere allowed
by state or federal agencies. Aerira
al spyi—add uld not be utilized for invasive species
control along the ROW.
Operation &
Vegetation Disposal (upland) - dragging chipping hauling,
Physical impacts to
chemical contaminants,
NA
NA
NA
NA
NA
NLAA
AMMs address potential contaminants from chipper.No stacking or piling will be done in
Maintenance
piling, stacking
individuals,
smothering
potential MCI habitat. Details are located in the Karst T—am Assessment Consmiction,
Monitoring and Mitigation Plan (GcoConcepts Engineering, Inc. 2017c) in Appe nlir.I of
the NIS and page 4-300 ofthe FEIS.
Operation&Vegetation
Disposal brush pile bumimg
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from brash barring. Will not affect the MCI becsrse they will not introd.ce
Maintenance
sediment or contaminants into the phreatic water.
Operation &
Vegetation Management- tree side trimming by bucket Mick or
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from tree trimming. Will not affect the MCI because they will not introduce
Maintenance
helicopter
sediment or contaminants into the phreatic water.
Operation &
ROW repair, regrading revegetation (upland) -hand,
Physical impacts to
smothering sedimentation
NA
NA
NA
NA
NA
NLAA
No impacts from hand repair Mechanical repairimpacts are addressed by AMMs. Details
Maintenance
mechanical
individuals
are located in the Karst Teaaim Assessment Construction, Monitoring and Mitigation Plan
(GeoConcepts Engineering Inc 2017c) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
Operation &
ROW repair, regrading revegetation (wetland) - hand,
Physical impacts to
smothering sedimentation
NA
NA
NA
NA
NA
NLAA
No impacts from hand repair Mechanical repair i pwts are addressed by AMMs. Details
Maintenance
mechanical
individuals
are located m the Karst Teaain Assessment Construction, Monitoring and Mitigation Plan
(GeoConcepts Engineering Inc 2017c) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
Operation &
ROW repair, regrading revegetation - in stream stabilization
Physical impacts to
smothering sedimentation,
NA
NA
NA
NA
NA
NLAA
AMMs address sedimentation, contaminants and impacts to karst features. Details are
Maintenance
and/orfill
individuals, Habitat
chemical contaminants,
located in the Karst Teaaim Assessment Construction, Monitoring and Mitigation Plan
degradation
changes in hydrology
(GeoConcepts Engineering Inc 2017c) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
Operation &
Access Road Maintenance - grading graveling
Physical impacts to
smothering sedimentation,
NA
NA
NA
NA
NA
NLAA
AMMs address sedimentation, contaminants and impacts to karst features. Details are
Maintenance
individuals, Habitat
chemical contaminants
located in the Karst Teaaim Assessment Construction, Monitoring and Mitigation Plan
degradation
(GeoConcepts Engineering Inc 2017c) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS. We anticipate impacts from road maintance wouldbe smaller because the majority
of impacts are expected from the creation or wideoing of road.
Operation &
Access Road Maintenance - culvert replacement
Physical impacts to
smothering sedimentation
NA
NA
NA
NA
NA
NLAA
AMMs address sedimentation, contaminants and impacts to karstfeam s. Details are
Maintenance
individuals, Habitat
located in the Karst Teaaim Assessment Construction, Monitoring and Mitigation Plan
degradation
(GeoConcepts Engineering Inc 2017c) in Appendir.I ofthe FEIS and page 4-300 of the
FEIS.
Operation &
General Appurtenance and Cathodic Protection
Habitat alteration
sedimentation
NA
NA
NA
NA
NA
NLAA
AMMs address sedimentation and impacts to karst features. Details are located in the
Maintenance
Constmetion - Off ROW Clearing
Karst Tennin Assessment Construction, Monitoriog and Mitigation Plan (GeoCovicepts
Ev ineeriv ,Ine. 2017c ivA endixI ofthe FEIS and e4-300 of the FEIS.
Operation &
General Appurtenance and Cathodic Protection
Habitat alteration
sednm ematiov
NA
NA
NA
NA
NLAA
AMMs address sedmevta[iov and impacts to karst features. Details are located in the
Maintenance
Constmetion -trenching anode, bell hole
Karst Ten'ain Assessment Construction, Monitoring and Mitigation Plan (GeoConcepts
En imeerin ,Ine. 2017c in endixI ofthe FEIS and e4-300 of the FEIS.
Operation &
Inspection Activities - ground and aerial
NA
NA
NA
NA
NA
NA
NA
NE
No impacts from inspections. Will not affect the MCI because they will not introduce
Maintenance
sediment or contaminants into the ph,eatic water.

Table 7. Analysis of effects on Ibat.
New Distubance
Vehicle Operation and Foot
Haman activity and distrrbance
daytime arousal
human presence
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and world not result in
-Construction
Traffic
the flashing ofbats from adjacent roost trees.
New Dista bra"
Clearing - herbaceous vegetation
Clearing offimested habitat, Haman
alteration of summer
vegetation removal, human
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and world not result in
- Construction
and ground cover
activity, and disturbance
roosting habitat, &
presence
the flashing ofbats from most trees or disturb hibemating bats. Mowing ofherbaceoas
staging/swaoning habitat,
vegetation while bats are present in habitat is expected to have a direct effect on the
daytime arousal
quality, quantity, and timing ofprey resources; however, the affect on bats foraging is
considered insignificant due to the small area of impact within a bats -2.5 mile home
range.
New Disturbance
Clearing -trees and shrubs
Clearing offorested habitat, Haman
alteration of summer
vegetation removal, human
all life stages, spring -fall
kill, hour, harass
breeding, sheltering
numbers,
LAA
We expect the majority of effects to Ibazs firm tree clearing will occur in suitable
- Construction
activity and disturbance
roosting habitat, &
presence
reproduction
mm..pied summer habitat that Ibazs use as atravel corridor between hibemacala and
staging/swambing habitat,
roost trees. We anticipate effects will be greatest to pregnant females that expend
daytime arousal
additional energy to seek alternate travel corridors m aresalt oftree clearing. Ifpregna d
females dramatically alter their travel corridor they will divert their energetic demands to
seek new corridors and will likely give birth to smaller paps, which could decrease pop
rvival. Tree removal may fragment the habitat such that Ibazs traveling through the area
will be more vulnerable to predation, resulting in injury or death. Tree removal in known
use summer habitat will limit roosting options or necessitate roost tree switching when
Ibazs retrm the following season. Because maternity most trees are ephemeral, Ibazs have
volved to relocate roosts at the beginning of the season if needed. Tree removal in
unknown use spring staging/fall swooning habitat will remove foraging and roosting areas
for a concentrated number oflbats in an abbreviated season (i.e., fall swanning or spring
mergence). Clearing trees mad hibemacula will decrease foraging and roosting habitat,
requiring bats to spend more true searching for food, which could result in bats entering
hibematiov with less fat reserves or spending less true on social interactions, which can Id
delay breeding. W e expect the same effects on Ibazs from tree removal in known use
spring stagumdall swambing habitat as those described for unknown use spring
stagimb
ng/fall swaing habitat. We do not anticipate impacts to bats when they are
hibernating based on the protections Karst Mitigation Plan included in Appendix I ofthe
FEIS (FERC 2017).
New Disturbance
Vegetation Disposal (upland) -
Human activity and distrrbance,
loss or alteration of
alteration ofwater or air flow
all life stages, all seasons
NA
NA
NA
NLAA
AMMs avoid potential impacts to hibemacula; noise created from this activity is
-Construction
dragging, chipping, hauling
Obstructed hibemacula entrances or
hibernation conditions,
imout ofhibemacula, human
anticipated to be insignificant and—old not result in the flushing ofbats from roost trees.
piling, stacking
vents
hibemaculavo longer
presence
suitable, daytime arousal
New Disturbance
V egetazion Disposal (upland) -
Human activity and distrrbance,
alteration ofhibemating
smoke, human presence &
all life stages, all seasons
NA
NA
NA
NLAA
The direct loss ofbats from smoke caused by burning brash piles in summer is
- Construction
brash pile burning
smoke
conditions, daytime arousal
Muse
insignificant because the effects are difficult to detect and measure. Additionally, the
m jority of the project area is in suitable unoccupied summer habitat. AMMs will prevent
smoke from entering hibemacula in the winter.
New Disturbance
Vegetation Clearing -tree side
Human activity
daytime arousal
human presence &noise
all life stages, all seasons
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result in
- Construction
trimming by bucket track or
the flushing ofbats from most trees.
helicopter
New Disturbance
Grading erosion control devices
Alteration ofwazerflow, Vegetation
altered water flow&
altered water flow
all life stages, all seasons
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result in
-Construction
oval, Human activity
humidity in hibemacula
the flushing ofbats from most trees; AMMs prevent discharge of a significant amount of
water into the recharge area ofknowa hibemacula potentially flooding hibernating bats.
New Disturbance
Trenching (digging, blasting
Human activity, Ground disturbance,
decreased aquatic
instream sedvneuntiov &
all life stages, all seasons
NA
NA
NA
NLAA
AMMs limit potential impacts to hibemacula by reshicting blasting within 0.5 mile of
- Construction
dewatering open trench,
In stream and riparian disturbance,
invertebrates, daytime
water flow disruption, human
hibemacula; ECS requirements limit loss of aquatic invertebrates so that any loss oflbat
sedvneuntiov)
Temporary dewatering
arousal
presence &noise
forage is insignificant.
New Disturbance
Pipe Shinging- beading,
Human activity
daytime arousal
human presence &muse
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result in
- Construction
welding, coating, padding and
the flushing ofbats from most trees.
backfilling
New Disturbance
Hydrostatic Testing (water
Withdrawal/discharge ofwater into
decreased aquatic
water alterations, human
all life stages, all seasons
NA
NA
NA
NLAA
AMMs prevent discharge ofa significant amount ofwater into the recharge area ofknowa
- Construction
withdrawal and discharge)
aquatic habitats, Human activitynvertebrates,
daytime
presence &noise
aculapotevally flooding hibernating bats; noise created from this activity is
hibemti
arousal
anticipated to be insignificant and —old not result in the flushing ofbats from adjacent
roost trees, vn
ees, ECS requirements 1it loss of aquatic invertebrates so that any loss oflbat
rage is
forage insignificant.
New Disturbance
Regrading and Stabilization -
Human activity and distrrbance,
loss or alteration of
alteration ofwater or air flow
all life stages, all seasons
NA
NA
NA
NLAA
AMMs avoid potential impacts to hibemacula; noise created from this activity is
-Construction
restoration ofcooidor
Obstructed hibemacula
hibernation conditions,
in/out ofhibemacula, human
anticipated to be insignificant and—old not result in the flushing ofbats from adjacent
entrances or vents
daytime arousal
presence
roost trees.
New Disturbance
Compression Facility, noise
Noise disturbance
daytime arousal
human presence
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result in
- Construction
the flushing ofbats from adjacent roost trees.
New Disturbance
Communication Facility - guy
Human activity and Facilities
daytime arousal
human presence
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result in
- Construction
lines, noise, lights
the flushing ofbats from adjacent roost trees.
New Disturbance
Access Roads - upgrading
Alteration of surface water flow,
altered water flow &
oval offorested habitat,
all life stages
kill, hour, harass
breeding, sheltering
umbers,
NLAA
AMMs limit potential impacts to hibemacula; noise created firm this activity is
-Construction
existing roads, new mads temp
Vegetation removal, Human activity
humidity in hibemacula,
altered surface water flow into
reproduction
anticipated to be insignificant and—old not result in the flushing ofbats from adjacent
and permanent - grading,
alteration of summer
hibemacula, human presence
roost trees.
graveling
roosting habitat, & spring
staging/fall swanning
habitat, daytime arousal
New Disturbance
Access Roads - upgrading
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
all life stages
NA
NA
NA
NLAA
The small area and level of impact from these activities on forested habitat is not expected
- Const ruction
existing roads, new roads temp
forested habitat, Human disturbance
roosting habitat, & spring
presence
to have noticeable or memorable impacts on Ibazs or their habitat.
and permanent - culvert
staging/fall swanning
installation
habitat, increased
daytime arousal

Table 7. Analysis of effects on Ibat.
New Distadbaace
Access Roads - upgrading
Clearing offimested habitat, Haman
alteration of sammer
vegetation removal, human
all life stages, spring -fall
kill, harm, harass
breeding sheltering
ambers,
LAA
We expect the m jority of effects to Ibats boom tree clearing will accor iv suitable
- Construction
existing roads, new roads temp
aetivity and disturbance
oostmg habitat, & spring
presence
reproduction
mmee,pied sammer habitat that Ibat, ase as att—1 corridor between hibemacala and
and permanent- tree trimming
smging/fall swanning
toast trees. We anticipate effects will be greatest to pregnant females that expend
and tree removal
habitat, daytime arousal
additional energy to seek altemate travel coridors as aresolt oftree clearing. Ifpregnant
females dramatically alter their travel corridor they will divert their energetic demands to
seek new co,idors and will likely give birtli to smaller pops, which could decrease pop
—w.]. Tree removal may fragment the habitat such that Ibats traveling through the area
will be more vulnerable to predation, resulting in injury or death. Tree removal m known
er habitat will limit roosting options or necessitate roost tree switching whey
Ibm, r,Mm the following season. Because matemity most trees are ephemeral, Ihat, have
volved to relocate roosts at the beginning of the season if needed. Tree removal m
unknown ase spring staging/fall swanning habitat will remove foraging and roosting areas
fora concentrated namber ofIbats m m abbreviated season (i.e., fall swam mg or spring
mergence). Clearing trees ou
arnd hibemaeola will decrease foraging and roosting habitat,
regoving bats to spend more tame searching for food, which could result m bats entering
hibemation with less fat reserves or spending less tame on social interaetions, which could
delay breeding. W e expect the same effects on Ibats from tree removal in known ase
spring staging/fall swanning habitat as those described for unknown ase spring
staging/fall swanning habitat. We do not anticipate impaets to bats whey they are
hibemating based on the protections Karst Mitigation Plan included m Appendix I ofthe
FEIS (FERC 2017).
New Disfiabmce
Stream Crossings, wet open cot
Tree removal, Loss or alteration of
alteration of sammer
vegetation removal, instream
all life stages, all seasons
NA
NA
NA
NLAA
AMMs will limit blasting aetivity so that karst features will not be altered or destroyed;
-Constmction
ditch
forested habitat, Homan distodsance,
oostmg habitat,&spring
sedimentation&water flow
mse created boom this aetivity is anticipated to be insamifi-at and would not result in the
In stream and riparian disturbance
staging/fall swanning
dismption, human presence &
flashing of bats from adjaeent roost trees; mmpaets to stream biota—.Id be temporary and
increased creased daytime
oise
limited & localized and not expected to cause any noticeable decrease inlbat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmce
Stream Crossings, flame
Tree removal, Loss or alteration of
alteration of sammer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit blasting aetivity so that karst features will not be altered or destroyed;
-Constmction
forested habitat, Homan distodsance,
oostmg habitat,&spring
sedimentation&water flow
created boom this aetivity is anticipated to be insamifi-at and would not result in the
Instream and riparian disturbance
staging/fall swanning
dismption, human presence &
flashing of bats from adjaeent roost trees; mmpaets to stream biota—.Id be temporary and
increased creased daytime
oise
limited & localized and not expected to cause any noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmce
Stream Crossings, dam & pomp
Tree removal, Loss or alteration of
alteration of Sommer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit blasting aetivity so that karst features will not be altered or destroyed;
-Constmction
forested habitat, Homan disfiabmce,
oostmg habitat, &spring
sedimentation&water flow
oise created boom this aetivity is anticipated to be insamifi-at and would not result in the
In stream and riparian disturbance
staging/fall swanning
dismption, human presence &
flashing of bats from adjaeent roost trees; mmpaets to stream biota—.Id be temporary and
increased creased daytime
oise
limited & localized and not expected to cause any noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmce
Stream Crossings, cofferdam
Tree removal, Loss or alteration of
alteration of sammer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit potential mmpaets to hibemaeola; noise created from this aetivity is
-Constmction
forested habitat, Homan disfiabmce,
oostmg habitat,&spring
sedimentation&water flow
mticipatedto be insign�cant a ndwooldnotresolt in the flashing ofbatsftom adjaeent
Instream and riparian disturbance bce
staging/fall swanning
dismption, human presence presence &
oast trees; impacts to stream biotawoold be temporary and li. ited & localized and not
increased creased daytime
ise
an
expected to cause y noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmce
Stream Crossings, Horizontal
Alteration of Suffaee water flow,
alteration of sammer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit potential mmpaets to hibemaeola; noise created from this aetivity is
-Constmction
Dvectiomd Drill(HDD)
Vegetation removal, Homan aetivity,
oostmg habitat,&spring
drilling fluids, human presence
anticipated to be insignificant and—old votresolt in the flashing ofbats from adjaeent
In stream and riparian disturbance
staging/fall swanning
&noise
toast trees; impacts to streambiotawoold be temporary and li. ited & localized and not
increased creased daytime
expected to cause any noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmce
Stream Crossings, conventional
Alteration of Suffaee water flow,
alteration of sammer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit potential i poets to hibemaeola; noise created from this aetivity is
-Constmetion
bore
Vegetation removal, Homan aetivity,
oostmg habitat,&spring
drilling fluids, human presence
anticipated to be insignificant and—old votresolt in the flashing ofbats from adjaeent
In stream and riparian disturbance
staging/fall swanning
&noise
toast trees; impacts to stream biotawoold be temporary and li. ited & localized and not
habitat, increased daytime
expected to cause any noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmee
Stream Crossings, direct pipe
Alteration of Suffaee water flow,
alteration of sammer
vegetation removal, instream
all life stages
NA
NA
NA
NLAA
AMMs will limit potential mmpaets to hibemaeola; noise created from this aetivity is
-Constmetion
Vegetation removal, Homan aetivity,
oostmg habitat,&spring
drilling fluids, human presence
anticipated to be insign�cant and—old votresolt in the flashing ofbats from adjaeent
In stream and riparian disturbance bce
staging/fall swanning
&noise
oast trees; impacts to stream biotawoold be temporary and li. ited & localized and not
habitat, increased daytime
expected to cause any noticeable decrease in Ihat foraging.
omsal, deemased aquatic
vertebrates
New Disfiabmee
Stream Equipment Crossing
Homan aetivity, I --ream and riparian
aced daytime arousal,
instream sedmmentation &
all life stages
NA
NA
NA
NLAA
It is extremely unlikely that this aetivity would resalt m amodification to recharge areas of
- Constmetion
Stmehaes
disturbance
decreased aquatic
changes in water flow, human
a streams and other k—t features that are hydrologically connected to known
nvertebrates
presence &noise
hibemaeola; noise created boom this aetivity is anticipated to be insignificant and would
not resalt m the flashing ofbats boom adjaeent most trees; impaets to stream biotawoold
be temporary and limited m localized and not expected to cause any noticeable decrease m
Ihat foraging.

Table 7. Analysis of effects on Ibat.
New Distadbaace
Crossings, wetlands and other
Clearing offorested habitat, Haman
alteration of sammer
vegetation removal, human
all life stages, spring -fall
kill, hams, harass
breeding sheltering
ambers,
LAA
We expect the m jority of effects to Ibazs firm tree clearing will a..r iv suitable
- Covstmctiov
water bodies (von -riparian) -
aetivity and disturbance
oostmg habitat, & spring
presence
reprodactiov
mmee,pied sammer habitat that Ibats ase as atravel corridor between hibemacala and
clearing
smging/fall swanning
toast trees. We anticipate effects will be greatest to pregnant females that expend
habitat, daytime arousal
additional energy to seek aItemate travel conidors as aremlt ofhee clearing. Ifpreg.ant
females dramatically alter their travel corridor they will divert their energetic demands to
seek new conidors and will likely give birtli to smaller pops, which could decrease pop
rein.]. Tree removal may fragment the habitat sash that Ibazs traveling through the area
will be more vulnerable to predation, resulting iv ivjary or death. Tree removal m known
er habitat will limit roosting options or necessitate roost tree switching whey
Ibazs r,Mm the following season. Because matemity most trees are ephemeral, Ibazs have
volved to relocate roosts at the begivvivg ofthe season if needed. Tree removal m
mflat n ase spring stagi.g/fall swanning habitatwill remove foraging and roosting areas
fora covicevtrated.amber oflbats m as abbreviated season (i.e., fall swanning or spring
mergence). Clearing trees oa
arvd hibemaeala will decrease foraging and roosting habitat,
regavivg bats to speed more tame searching for food, which could esalt m bats entering
hibematio. with less fat reserves or spevdivg less tame o. social interaetiovs, which could
delay breeding. W e expect the same effects o. Ibazs from tree removal iv known ase
spring stagi.g/fall swamai.g habitat as those described for ..known ase spring stagivg/fall
warming habitat. We do not anticipate impaets to bats whey they are hibemati.g based o.
the pmtectiovs Karst Mitigation Plan melded iv Appendix I ofthe LEIS (FERC 2017).
New Distubmee
Crossings, wetlands and other
Tree removal, Loss or alteration of
alteration of sammer
vegetation removal, human
unlikely
kill, hams, harass
breeding sheltering
ambers,
NLAA
AMMs mivvmize potential effects; vegetation alterations to travel conidors and foraging
- Covstmctiov
water bodies (von -riparian) - tree
forested habitat, Haman distubmee
oostmg/fmagmg habitat, &
dis.,bmee
reprodactiov
habitat should be extremely small; Noise and aetivity levels are anticipated to be so low as
side hammi.g
spring stagi.g/fall
to not cause bats to flash from adjaee.t roost trees or hibemae.la; Although some roosting
anni.g habitat, increased
habitat may be take. daring side trimming daring the winter, we do not expect indirect
nasal, daytime
effects to occar because the m jo ity of the tree and therefore roosting habitat will not be
disturbance, roost
eamwed. Thus, the effects are insignificant.
abando.m ad, increased
predation due
to daytime aetivity
New Distubmee
Crossings, wetlands and other
Alteration of surface water flow,
flooding hibemaeala,oval
ofwetlmd vegetation,
all life stages, all seasons
NA
NA
NA
NLAA
AMMs will limit potential nmpaets to hibemae.la; noise created from this aetivity is
-Covstmctiov
water bodies( nor -riparian)-
Vegetation removal, Haman aetivity,
decreased aquatic
w ate, dismptio., alteration of
anticipated to be ivsigvificant and—old votresalt iv the flashing ofbats from adjaeevt
grading he.chi.g, regrading
Wetland disturbance
.vertebrates, alteration of
water or airflow in/oat of
toast trees; impacts to wetland biota wo.ld be temporary and limited & localized and not
spring stagi.g/fall
hibemae.la, human presence
expected to cause any noticeable decrease iv Ihat foraging.
anni.g habitat, daytime
&
aro-al
New Distubmee
Crossings, wetlands and other
Haman aetivity
daytime arousal
human presence &noise
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this aetivity is anticipated to be insignificant and wo.ld votresalt iv
-Covstmctiov
water bodies( nor -riparian)-
the flashing ofbats from adiwe.t roost trees.
Pipe stringing
New Distubmee
Crossings, wetlands and other
Alteration of surface water flow,
flooding hibemae.la,
emoval ofwetlmd vegetation,
all life stages
NA
NA
NA
NLAA
AMMs will limit potential nmpaets to hibemae.la; noise created from this aetivity is
-Covstmetiov
water bodies( nor -riparian)-
Vegetation removal, Haman aetivity,
decreased aquatic
water dismptio., drilling fluids
anticipated to be i.sig.ifie,ad and—old votresalt iv the flashing ofbats from adjaee.t
HDD
Wetland disturbance
.vertebrates, altemtiov of
m wetland, increased water
toast trees; impacts to wetlaad biota wo.ld be temporary and limited & localized and not
spring stagi.g/fall
flow into hibemae.la, human
expected to cause any noticeable decrease iv Ihat foraging.
anni.g habitat, daytime
presence&nOise
usal
New Distubmee
Crossings, wetlands and other
Alteration of surface water flow,
flooding hibemae.la,
emoval ofwetlmd vegetation,
all life stages
NA
NA
NA
NLAA
AMMs will limit potential nmpaets to hibemae.la; noise created from this aetivity is
-Covstmetiov
water bodies( nor -riparian)-
Vegetation removal, Haman aetivity,
decreased aquatic
water dismptio., drilling flaids
anticipated to be i.sig.ifie,ad and—old votresalt iv the flashing ofbats from adjaeevt
vve.tio.al bore
Wetland disturbance
.vertebrates, altemtiov of
m wetland, increased water
toast trees; impacts to wetland biota wo.ld be temporary and limited & localized and not
spring stagi.g/fall
flow into hibemae.la, human
expected to cause any noticeable decrease iv Ihat foraging.
anni.g habitat, daytime
presence&nOise
usal
Operation &
Faeilities - vehicles, foot [raffia,
Increased human aetivity and
memased daytime arousal
human presence
all life stages, (not
NA
NA
NA
NLAA
Noise created from this aetivity is anticipated to be insignificant and wo.ld votresalt iv
Maintenance
Oise, emummieatio. facilities
disturbance
hibematiov)
the flashing ofbats from adiwe.t roost trees,nor would it nmpaet foraging bats or bats
sing travel corridors; NOTE vehicle nmpaets for all O&M sabaetivities are evaluated here
(i.e. vehicle nmpaets will not be considered ander the remaining O&M sabaetivities).
Operation &
V egetztio. Management -
Loss or alteration offorested habitat,
decreased foraging & travel
alteration ofspri.g- sammer-
all life stages, (not
NA
NA
NA
NLAA
Noise created from this aetivity is anticipated to be insignificant and wo.ld votresalt iv
Maintenance
mowmg
Increased human aetivity and
efficiency, increased
fall Navel conidors, vegetation
hibematiov)
the flashing ofbats from adjacent roost trees,nor —old it nmpaet foraging bats or bats
disturbance
predation
emoval
sing travel corridors.
Operation &
V egetztio. Management -
Loss or alteration offorested habitat
alteration oftravel
vegetation removal, human
all life stages(not
hams hums
Kill, haharass
breeding sheltering
ambers,
LAA
We expect the m jority of effects to Ibazs firm Nee clearing will a".,iv suitable
Maian
ntence
chainsaw and Nee clearing
onidms, sammer
dis.,bmee
hibematiov)
reprodactiov
ccapied sammer habitat that Ibazs ase as atravel corridor between hibemacala and
oosting/fmaging habitat, &
toast bees. We anticipate effects will be greatest to pregnant females that expend
spring stagi.g/fall
additional energy to seek altemate Navel conidors as aresalt ofhee clearing. Ifpreg.ant
anni.g habitat, increased
females dramatically alter their travel corridor they will divert their energetic demands to
nasal, daytime
seek new conidors and will likely give birtli to smaller pops, which could decrease pop
disturbance, roost
rvival. Tree removal may fragment the habitat sash that Ibazs traveling through the area
abando.m ad, increased
will be more valverable to predztio., ms.ltivg iv ivjary or death. Tree removal m known
predation d.e to daytime
me saaame, habitat may limit roosting options or necessitate roost tree switching when
aetivity
Ibazs etam the following season. Because matemity most bees are ephemeral, Ibazs have
volved to relocate roosts at the begivvivg ofthe season if needed. Tree removal m
unknown ase spring stagi.g/fall swamaing habitat may remove foraging and roosting areas
for a eo.ce.hated vamber oflbats m as abbreviated season (i.e., fall swanmi.g or spring
mergence). Clearing trees oa
arvd hibemacala will decrease foraging and roosting habitat,
regairi.g bats to speed more tame searching for food, which cold esalt m bats entering
hibematio. with less fat reserves or spevdivg less tame o. social interaetiovs, which cold
delay breeding. W e expect the same effects o. Ibazs from Nee removal iv known ase
spring stagi.g/fall swamai.g habitat as those described for ..known ase spring stagivg/fall
warning habitat. We do not anticipate impaets to bats whey they are hibemati.g based o,
the pmtectiovs Karst Mitigation Plan melded iv Appendix I ofthe LEIS (FERC 2017).

Table 7. Analysis of effects on Ibat.
Operation&
Vegetation Management-
Chemical commumatio., Vegetation
lethal or sublethal exposure
covtaminatio. ofwater&
..likely
NA
NA
NA
NLAA
Implementation of AMMs makes potential impacts to hibemativg bats extremely ..likely
Maintenance
herbicides - hand, vehicle
loss
to toxins alteration oftravel
vegetation, loss ofh.rbwco.s
to a..,,, the amount ofmc.to be treated that could be Ibat roosting, foraging or
ouded, aerial applications
comdons, summer
vegetation
travelling habitat is very small, making potential c.pos-c-t.em.ly..likely to occ.,.
oosting/fo.aging habitat, &
Aerial spraying would not be.tilized for invasive species control along the ROW.
spring staging/fall
arming habitat
Operation &
Vegetation Disposal (upland) -
Human activity and distn.bance,
loss or alteration of
alteration ofwat., or air flow
all life stages, spring -fall
NA
NA
NA
NLAA
AMMs avoid potential impacts to hibemac.la; noise created from this activity is
Maintenance
dragging chipping hauling,
Obstmcted hibemac.la entrances or
hibemation conditions,
immt ofhibemw.la, human
anticipated to be insignificant and would vat—It in the flushing ofbats from adjacent
piling, stacking
vents
hib.mw.l,.o longer
presence
toast trees.
suitable, daytime aro.sal
Operation &
Vegetation Disposal (upland) -
Human activity and distn.banc.,
smoke inhalation during
smoke in hibemae.la or
all life stages, all seasons
NA
NA
NA
NLAA
The harassment and resultant flushing ofbat, firm smoke caused by b.ming bmsh piles in
Maintenance
bmsh pile tanning
Smoke disturbance
hibemation, increased
omtmg habitat
saname, is msignificant because the effects are difficult to detect and meas...; AMM, will
o.sal, daytime
prevent smoke from entering hibemacvla in the winte,
distn.banc., roost
abandonment, increased
predation due to
daytime activity
Operation &
Vegetation Management - tree
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
..likely
han, harass
breeding sheltering
umbers,
NLAA
AMMs minnmize potential effects; vegetation alterations to hovel conido.s and foraging
Maintenance
side tramming by bucket muck or
forested habitat, Human distubance
oostmg/fmagmg habitat, &
distodbance
rcp,od.ctio.
habitat should be extremely small; Noise and activity levels are anticipated to be so low as
helicopter
spring stagi.g/fell
to not cause bazs to flush from adjacent roost trees or hibemac.la; Although some roosting
arming habitat, increased
habitat may be take. during side trimming dmim; the winter, we do not expect indirect
o.sal, daytime
effects to oce.. because the m imily of the tree and therefore roosting habitat will not be
distn.banc., roost
emoved. Thus, the effects are insignificant.
abandonment, increased
p.edatio. due
to daytime activity
Ope.atio. &
ROW repi,, rcg,.di.g,
Tree removal, Loss or alte.atio. of
alte.atio. of summer
vegetationremoval, human
..likely
NA
NA
NA
NLAA
The small area and level of impact from these activities is not expected to have noticeable
Maintenance
evegetatio. (upland) -
forested habitat, Human dist. bm"
oostmg habitat, &spring
distodbance
impact. o. Ibat ortheirhabitat; ROW repairs occur in areas ofsoil erosion
hand, mechanical
smging/fall swanning
=able
where roost trees me.likely to ace...
habitat, increased
daytime aro.sal
Operation &ROW
repi,, regrading,
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
..likely
NA
NA
NA
NLAA
The small area and level of impact from these activities is not expected to have .oticeabl.
Maintenance
evegetatio. (wetland) - hand,
forested habitat, Human distubance
oostmg habitat, & spring
dista Bance
impact. o. Ibat ortheirhabitat; ROW repairs occur in areas ofsoil erosion
mechanical
wann
smgmg/fiall sing
=able
where roost trees me.likely to ace...
habitat, increased
daytime aro.sal
Operation &ROW
repi,, regrading,
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
..likely
NA
NA
NA
NLAA
The small area and level of impact from these activities is not expected to have noticeable
Maintenance
evegetatio. - i.stream
forested habitat, Human distubance
oostmg habitat, & spring
distodbancea,
meas ... ble impact, o. Ibat or their habitat.
stabilization and/or fill
smging/fall swanning
habitat, increased
daytime aro.sal
Operation &Access
and Maintenance -
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
..likely
han, harass
breeding sheltering
umbers,
NLAA
.m
AMMs mi.ize potential effects; vegetation alterations to navel corridors and foraging
Maintenance
grading graveling
forested habitat, Human distubance
oostmg habitat, & spring
distodbance
reproduction
habitat should be.xmem.ly small; Noise and activity levels are anticipated to be so low as
smging/fall swanning
to not cause bazs to flush from adjacent roost trees or hibemac.la; Although some roosting
habitat, increased daytime
habitat may be taken during side trimming during the winter, we do not expect indirect
o.sal
effects to occur because the m imity of the tree and therefore roosting habitat will not be
,emoved. Thus, the effects are insignificant.
Operation &Access
Road Maintenance -
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
all life stages
NA
NA
NA
NLAA
The small area and level of impact from these activities is not expected to have noticeable
Maintenance
c.lvert replacement
forested habitat, Human distubance
oostmg habitat,&spring
distodbance
a, meas ... ble impact, o. Ibat or their habitat.
smging/fall swanning
habitat, increased
daytime aro.sal
Operation &General
Appurtenance and
Tree removal, Loss or alteration of
alteration of summer
vegetation removal, human
all life stages
nas
kill, ha, hars
breeding sheltering
umbers,
LAA
We expect the m jority of effects to Ibazs firm tree clearing will ace., i. suitable
Maintenance
Cathodic Protection Co.stmetion
forested habitat, Human distubance
oostmg habitat,&spring
presence
reproduction=ied
summer habitat that that, may .seas, travel coaidor between hibemac.l,
- Off ROW Clearing
smging/fall swanning
and roost trees. We anticipate effects will be greatest to pregnant females that expend
habitat, increased
additional energy to seek afemate navel corridors as ane„It oftr.e clearing. Ifp.egnmt
daytime aro.sal
females dramatically alter their travel emudo, they will divert their energetic demands to
seek new corridors and will likely give biub to smaller pups, which could decrease pop
.viva]. Tree removal may fragment the habitat such that Ibazs traveling through the area
will be more vulnerable to predation, resulting in injury or death. Tree removal in known
use e, habitat may limit roosting options a, necessitate roost tree switching when
Ibazs ..tam the following season. Became matemity most trees are ephemeral, Ibazs have
volved to relocate roosts at the beginning ofthe season if needed. Tree removal in
unknown .se spring staging/fall swanning habitat may remove foraging and roosting areas
.azed.umbe. ofl ons in an abbreviated season (i.e., fall swani.g or spring
fora covicetr
mergence). Clearing trees around hibemacula will decrease foraging and roosting habitat,
requvi.g bats to spend more tn,e searching for food, which could result in bats entering
hibemation with less fat reserves or spending less tn,e on social interactions, which can Id
delay breeding. W e expect the same effects o. Ibazs from tree removal in known use
spring staging/fall swanning habitat as those described for unknown use spring staging/fall
waning habitat. We do not anticipate impacts to bats when they are hibemati.g based on
the protections Karst Mitigation Plan included i. Appendix I ofthe FEIS (FERC 2017).
Operation &General
Appurtenance and
Human distmbance
inemased daytime arousal
human presence
all life stages
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result i.
Maintenance
Cathodic Protection Co.stmetion
the flushing ofbats from adjacent roost tees,no, —old it impact fomgi.g bats or bats
- meshing anode, bell hole
I
I
I
I
I
I
I
I
I using travel emudo.s.
Operation &
Inspection Activities - ground
Human activity and Disturbance
daytnne arousal
human presence
all life stages, spring -fall
NA
NA
NA
NLAA
Noise created from this activity is anticipated to be insignificant and would not result i.
Maintenance
and aerial
the flushing ofbats from adjacent roost trees

Table 8. Analysis of effects on Northern long-eared bat.
AL
IF
L
New Distmbooee -
Vehicle Operation and Foot Traffic
Homan activity and distarbznce
dayti a arousal
human presence
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
spring -fall
biological opinion implementing the F al 4(d) rule dated January 5, 2016.
New Distmboo e -
Clearing - herbaceous vegetation and
Clearing offorested habitat, Human
alteration of­merroosting habitat, &
vegetation removal, human
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
ground cover
activity, and di—bance
smging/swarming habitat, dayti a
presence
spring -fall
biological opinion implementing the F al 4(d) rule dated January 5, 2016.
usal
New Distmbaoce-
Clearing - trees and shmbs
clearing offorested habitat human
alteration ofmmmerroosting habitat,&
vegetation removal; human
all life stages;
kill, harm,
breeding,
mtroben,
LAA
Effects from this activity will occur within '/4 -mile of a known hibemacvla and take
Construction
activity & disturbance
smging/swarming habitat; daytime
presence
spring -fall
harass
sheltering
reproduction
not exempt by the 4(d) rule. Approximately 0.4 acres offorest clearing will
oosal
occ., along an existing access road. AMMs minimize potential effects; vegetation
alterations to travel corridors and foraging habitat should be extremely small; noise
created from this activity is covered by the 4d role. The flushing of bats from roost
trees as they are being cut during daylight hours would increase the likelihood that
the bats would become prey for predators.
New Distmbaoce -
Vegetation Disposal (upland) -
Human activity and disturbance,
loss or alteration ofhibemazion
alteration ofwater or it flow
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
dragging chipping hauling, piling,
Obstmcted hibemacula entrances or
onditions, hibemaculano longer
imout ofhibemacola, human
all seasons
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
stacking
vents
suitable, dayti a arousal
presence
New Distmbaoce -
Vegetation Disposal (upland) - brash
Human activity and disturbance,
loss or alteration ofhibemazion
alteration ofwater or it flow
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
pile t omimg
Obstmcted hibemacula entrances or
onditions, hibemaculano longer
imout ofhibemacula, human
all seasons
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
vents
suitable, dayti a arousal
presence
New Distudbance -
Vegetation Clearing - tree side
human activity
dayti a arousal
human presence & noise
all life stages;
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
tramming by bocket truck or
all seasons
expected
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
helicopter
New Distodbance-
Grading, erosion control devices
alteration ofwater flow; vegetation
altered water flow&humidity in
altered water flow
all life stages;
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmctiov
oval; human activity
hibemneola
all seasons
expected
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
New Distmbaoce -
Trenching (digging, blasting
h man wtivity;gmond di—bance;
decreased aquatic invertebrates; daytime
instream sedimentation &
all life stages;
none
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
dewatering, open trench,
instream & riparian disturbance;;
oosal
water flow dismption; human
all seasons
expected
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
sedimentation)
temporary dewatering
presence &noise
New Dlstmhance -
Pipe Stringing - bending, welding,
human activity
dayti a arousal
human presence & noise
all life stages;oneNA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
coating padding and backfilling
spring -fall
expected
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
New Distmbance -
Hydrostatic Testing (water
withdrawal/discharge ofwater into
decreased aquatic invertebrates; daytime
water alterations; human
all life stages;
One
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
withdrawal and discharge)
aquatic habitats; human activity
oosal
presence & noise
all seasons
expected
biological opinion implementing the F al 4(d) mle dated January 5, 2016.
New Distodbance -
Regrading and &abilization -
human activity & distorbance;obstmcted
loss or alteration ofhibemazion
alteration ofwater or it flow
all life stages;
OneNA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
restoration of coaidor
onditions; dayti e arousal
in/oot of caves; human
all seasons
expected
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
entrances or vents
presence
New Distmbance -
Compression Facility, noise
noise di—tomce
dayti e arousal
human presence
all life stages;noneNA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
spring -fall
expected
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
New Distmbance -
Commnication Facility - goy lines,
human activity and facilities
dayti e arousal
human presence
all life stages;
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmctiov
se, lights
spring -fall
expected
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
New Distmbance-
Access Roads-opgmding existing
alteration of surface water flow;
altered water flow &humiditym
oval offorestedhabitat;
all life stages;
kill, harm,
breeding,
nmoben,,
MA
These effects have been previously addressed in the Service's programmatic
Constmction
roads, new roads temp and permanent
vegetation removal; human activity
hibemacola; alteration of summer
altered surface water flow into
harass
sheltering
repmdoction
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
- grading graveling
ousting habitat, & staging/swarming
es; human presence
habitat; daytime arousal
New Distodbance-
Access Roads-opgmding existing
tree removal; loss or alteration of
alteration of summer roosting habitat,&
vegetation removakhomm
all life stages
noneNA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
roads, new roads temp and permanent
forested habitat; human di—bance
smgmg/,waromghabikd; increased
presence
expected
biological opinion implementing the frml 4(d) mle dated January 5, 2016.
- culvert installation
dayti e arousal
New Distmbance-
Access Roads -upgrading existing
Clearing of forested habitat, Homan
alteration ofsommerroostiog habitat,&
vegetation removal, human
all life stages,
kill, harm,
breeding,
ambers,
LAA
Effects from this activity will occur within '/4 -mile of a known hibemacvlo and take
Constmction
roads, new roads temp and
activity and di—bance
spring staging/fall swam ming habitat,
presence
spring -fall
harass
sheltering
repmdoction
not exempt by the 4(d) mle. Approximately 0.4 acres offorest clearing will
permanent- tree trimming and tree
dayti e arousal
or along an existing access road. AMMs minimize potential effects; vegetation
oval
alterations to travel corridors and foraging habitat should be extremely small; noise
created from this activity is covered by the 4d role. The flashing of bats from roost
trees as they are being cot daring daylight hoors world increase the likelihood that
the bats —old become prey for predators.
New Distmbance -
Stream Crossings, wet open cot ditch
Tree removal, Loss or alteration of
alteration of summer roosting habitat, &
vegetation removal, instream
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
forested habitat, Homan di—Bance,
spring staging/fall swam ming habitat,
sedimentation & water flow
all seasons
biological opinion implementing the final 4(d) mle dated January 5, 2016.
Instream and riparian di—Bance
in,remed daytime arousal, decreased
disruption, human presence &
agratie
no.e
vertebrates
New Distodbance -
Stream Crossings, flame
Tree removal, Loss or alteration of
alteration of sommerroosting habitat, &
vegetation removal, instream
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
forested habitat, Homan di—Bance,
spring staging/fall swam ming habitat,
sedimentation & water flow
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
Instream and riparian di—Bance
in,remed daytime arousal, decreased
disruption, human presence &
agratie
no.e
vertebrates
New Distmbance -
Stream Crossings, dam & pomp
Tree removal, Loss or alteration of
alteration of sommerroosting habitat, &
vegetation removal, instream
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
forested habitat, Homan di—Bance,
spring staging/fall swam ming habitat,
sedimentation & water flow
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
Instream and riparian di—Bance
in,remed daytime arousal, decreased
disruption, human presence &
agratie
no.e
vertebrates
New Distmbance -
Stream Crossings, cofferdam
Tree removal, Loss or alteration of
alteration of sommerroosting habitat, &
vegetation removal, instream
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
forested habitat, Homan di—Bance,
spring staging/fall swam ming habitat,
sedimentation & water flow
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
Instream and riparian di—Bance
in,remed daytime arousal, decreased
disruption, human presence &
agratie
no.e
vertebrates
New Distmbance -
Stream Crossings, Horizontal
Alteration of surface water flow,
alteration of sommerroosting habitat, &
vegetation removal, instream
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constmction
Directional Drill (HDD)
Vegetation removal, Homan activity,
spring staging/fall swam ming habitat,
drilling fluids, human pre—
biological opinion implementing the f rml 4(d) mle dated January 5, 2016.
Instream and riparian di—Bance
in,remed daytime arousal, decreased
& noise
agratie
vertebrates

Table 8. Analysis of effects on Northern long-eared bat.
New DistuWce -
&ream Crossings, conventionalbore
Alteration of surface water flow,
alteration of sam ouroosting habitat, &
vegetation removal, %t,c a
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
V egeta[ion removal, Human activity,
spring staging/fall swanning habitat,
drilling fluids, human presev
biological opinion implementing the final 4(d) rule dated January 5, 2016.
Instream and riparian disombou a
increased daytime arousal, decreased
& noise
aqa dic
vertebrates
New Distud�amce-
Stream Crossings, direct pipe
Alteration of surface water flow,
alteration ofsummerroosting habitat,&
vegetation removal, instream
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
V egeta[ion removal, Human activity,
spring staging/fall swanning habitat,
drilling fluids, human presev
biological opinion implementing the final 4(d) rule dated January 5, 2016.
Instm— and riparian disombou a
increased daytime arousal, decreased
&noise
agratic
vertebrates
New Disturbance -
Stream Equipment Crossing
Human activity, Instream and riparian
increased daytime arousal, decreased
instream sedimentation &
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
Stmemres
distud�ance
aquatic invertebrates
changes in water flow, human
biological opinion implementing the final 4(d) rule dated January 5, 2016.
pre—he
Crossings, wetlands and other water
Clearing offorested habitat, Human
alteration of summer roosting habitat,&
vegetation removal, human
all life stages,
kill, hour,
breeding
numbers,
LAA
Effects from this activity will occur within '/4 -mile of a known hibemacvla and take
Construction
bodies (non -riparian) - clearing
activity and disturbance
spring s[agivgM swanning habitat,
presence
spring -fall
harass
sheltering
reproduction
is not exempt by the 4(d) rule. Approximately 0.4 acres offorest clearing will
daytime arousal
occur along an existing access road. Noise created from clearing of ROW is
covered by the 4d role; the flushing ofbats from most trees as they are being cut
during daylight hours would increase the likelihood that the bats would become
prey for predators.
New Disturbance -
Crossings, wetlands and other water
Tree removal, Loss or alteration of
alteration of summer roosting/foraging
vegetation removal, human
unlikely
kill, hour,
breeding
numbers,
MA
These effects have been previously addressed in the Service's programmatic
Construction
bodies (non -riparian) - tree side
forested habitat, Human distrrbance
habitat, & spring stagi/fallngswanning
disturbance
harass
sheltering
reproduction
biological opinion implementing the final 4(d) rule dated January 5, 2016.
tramming
habitat, increased arousal, daytime
disturbance, roost abandonment,
used predation due
to daytime activity
New Disturbance -
Crossings, wetlands and other water
alteration of surface water flow;
flooding hibemacula; decreased aquatic
removal ofwetland vegetation;
all life stages;
none
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
bodies (non -riparian) - grading,
vegetation removal; human activity;invertebrates;
alteration of
waterdismption; alteration of
all seasons
expected
biological opinion implementing the final 4(d) role dated January 5, 2016.
trenching regrading
wetland disturbance
staging/swanming habitat; daytime
water or air flow in/out of
arousal
es; human presence &
noise
New Disturbance -
Crossings, wetlands and other water
human activity
daytime arousal
human presence & noise
all life stages;
none
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Construction
bodies (non -riparian) - pipe stringing
spring-fallexpected
biological opinion implementing the final 4(d) role dated January 5, 2016.
New Disturbance -
Crossings, wetlands and other water
Alteration of surface water flow,
flooding hibemacula, decreased aquatic
removal ofwetland vegetation,
all life stages
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Constra
bodies (non -riparian) - HDD
Vegetation removal, Human activity,
invertebrates, alteration of spring
water disruption, drilling fluids
expected
biological opinion implementing the final 4(d) role dated January 5, 2016.
Wetland disturbance
staging/fall swanning habitat, daytime
in wetland, increased water
arousal
flow into Wart Gals, human
s
prece&j—
w Disturbance -
Crossings, wetlands and other water
Alteration of surface water flow,
flooding hibemacula, decreased aquatic
removal ofwetland vegetation,
all life stages
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
vstmetion
bodies (non -riparian) - conventional
Vegetation removal, Human activity,
invertebrates, alteration of spring
water disruption, drilling fluids
biological opinion implementing the final 4(d) role dated January 5, 2016.
bore
Wetland disturbance
staging/fall swanning habitat, daytime
in wetland, increased water
arousal
flow into hibemacula, Imm-
presence&no
Operation &
Facilities - vehicles, foot traffic,
Increased human activity and
increased daytime arousal
human presence
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
noise, communication facilities
disturbance
(not
biological opinion implementing the final 4(d) role dated January 5, 2016.
hibernation)
Operation &
Vegetation Management - mowing
Loss or altem[iov offorested habitat,
decreased foraging & travel efficiency,
alteration of spring- sum o -
all life stages,
NA
NA
NA
MA
These effects Web— previously addressed in the Service's programmatic
Maintenance
Increased human activity and
creased predation
fall travel corridors, vegetatmn
(not
biological opinion implementing the final 4(d) role dated January 5, 2016.
disturbance
oval
hibernation)
Operation&
Vegetation Management- chainsaw
Loss or alteration offorested habitat
alteration oftravel couidom, summer
vegetation removal, human
WE, stages,
Kill,haum,
breeding
umbers,
LAA
Effects from this activity will occur within '/4 -mile ofaknown hibemacvla and take
Maintenance
and tree clearing
roosting/foraging habitat, &
disturbance
(not
harass
sheltering
reproduction
is not exempt by the 4(d) role. Approximately 0.4 acres offorest clearing will
staging/swanning habitat, increased
hibernation)
occur along an existing access road. AMMs minimize potential effects; vegetation
arousal, daytime disturbance, roost
alterations to travel corridors and foraging habitat should be extremely small; noise
abandonment, increased predation due
created from this activity is covered by the 4d role. The flushing ofbats from roost
to daytime activity
trees as they are being cut during daylight hours would increase the likelihood that
the bats —old become prey for predators.
Operation &
Vegetation Management - herbicides
Chemical contamination, Vegetation loss
lethal or sublethal exposure to toxins
contamination ofwater &
unlikely
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
- hand, vehicle mounted, acrial
all of travel corridors, summer
vegetation, loss ofherbaceous
biological opinion implementing the final 4(d) role dated January 5, 2016.
applicationsroosting/foraging
habitat,&spring
vegetation
staging/fall swanning habitat
Operation &
Vegetation Disposal (upland) -
Human activity and disturbance,
loss or alteration ofhibemation
alteration ofwater or air flow
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
dragging chipping hauling piling
Obstructed hibemacula entrances or
conditions, hibemacula no longer
in/out ofhibemacula, human
spriog-fall
biological opinion implementing the final 4(d) role dated January 5, 2016.
stacking
vents
suitable, daytime arousal
presence
Operation &
Vegetation Disposal (upland) - brash
Human activity and disturbance, Smoke
smoke inhalation during hibernation,
smoke iv hibemacula or
all life stages,
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
pile burning
disturbance
increased arousal, daytime disturbance,
r oosting habitat
all seasons
biological opinion implementing the final 4(d) role dated January 5, 2016.
roost abandonment, increased predation
re m
daytime activity
Operation &
Vegetation Management - tree side
Tree removal, Loss or alteration of
alteration of sammerroosting/foraging
vegetation removal, human
unlikely
hour, hamss
breeding
umbers,
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
tramming by bucket track or
forested habitat, Human disturbance
habitat, & spring staging/fall swanning
disturbance
sheltering
reproduction
biological opinion implementing the final 4(d) role dated January 5, 2016.
helicopter
habitat, increased arousal, daytime
disturbance, roost abandonment,
used predation due
to daytime activity
Operation &
ROW repair, regrading revWation
We removal, Loss or alteration of
alteration of sammerroosting habitat, &
vegetation removal, human
unlikely
NA
NA
NA
MA
These effects have been previously addressed in the Service's programmatic
Maintenance
(upland) -
forested habitat, Human disturbance
spring smging/fall swanning habitat,
disturbance
biological opinion implementing the final 4(d) role dated January 5, 2016.
hand, mechanicalased
daime arousal

Table 8. Analysis of effects on Northern long-eared bat.
16L-
JdL
Operation &
ROW repair, regrading, rc,cgcta[io.
Tree removal, Loss or aItc,ofo. of
aItc,ofo. of s.mmerroosting habitat, &
vcgcta[io. removal, human
..likely
NA
NA
NA
MA
These effects have bee. previously addressed iv the Service's programmatic
Mainte.ance
(wetland) - hand, mechanical
forested habitat, H.man distorbance
spring stagi.g/fall --i.g habitat,
dist.hbance
biological opi.io. impleme.ti.g the final 4(d) rule dated Jan.ary 5, 2016.
d.sed
.i.e aro.sa
Operatio. &
ROW repair, regradi.g, rc,cgcta[io.
Tree removal, Loss or aItc,ofo. of
aItc,ofo. of s.mmerroosting habitat, &
vcgcta[io. removal, h.mm
..likely
NA
NA
NA
MA
These effects have bee. previo.sly addressed i. the Service's programmatic
Mainte.ance
- i.stm: stabili—io. and/or fill
forested habitat, H.man distorbance
spring stagi.g/fall --i.g habitat,
dist.hbance
biological opi.io. impleme.ti.g the final 4(d) rule dated Jan.ary 5, 2016.
memosed
d.yti.e aro.sa
Operatio. &
Access Road Mai.teoance - gradi.g,
Tree removal, Loss or aItc,o io. of
aItc,o io. of s.mmerroosting habitat, &
vcgctazio. removal, h.mm..likely
harm, harass
breedi.g,
.mbers,
MA
These effects have bee. previo.sly addressed i. the Service's programmazic
Mainte.m"
graveling
forested habitat, H.mm distorbance
spring stagi.g/fall swahmi.g habitat,
dist.hbm"
shelteri.g
rcpmd.ctio.
biological opi.io. impleme.ti.g the final 4(d) rule dated Jm.ary 5, 2016.
memosed daytime aro.sal
Operatio. &
Access Road Mai.teom" - c.lvert
Tree removal, Loss or aItc,ofo. of
alteratio. of s.mmerroosting habitat, &
vcgcta[io. removal, h.mm
all life stages
NA
NA
NA
MA
These effects have bee. previo.sly addressed i. the Service's programmatic
Mainte.m"
rcp,.—c.t
forested habitat, H.mm distorbance
spring stagi.g/fall swahmi.g habitat,
dist.hbm"
biological opi.io. impleme.ti.g the final 4(d) rule dated Jm.ary 5, 2016.
memosed
d.yti.e aro.sa
Operatio. &
Ge.eral App.rteoance and Cathodic
tree removal; loss or aItc,o io. of
aItc,o io. of s.mmerroosting habitat, &
vcgctazio. removal;h.mm
all life stages
kill, harm,
breedi.g,
.mbers,
LAA
Effects from this activity will o"., withi.''/a-mile of. known hibemacula and take
Mainte.m"
Proteetio. Co-firetio. - Off ROW
forested habitat; h.mm distrrbance
stagi.g/swahminghabitat i.creased
prese.ce
harass
shelteri.g
rcpmd.ctio.
isnot exempt by the 4(d) rule. Approximately 0.4 acres offorest cleari.g will
Cleari.g
dayti c aro.sal
.r alo.g m c.isti.g access road. AMMs mi.imi- pote.tial effects; vcgcta[io.
olterztio.s to travel corridors and foragi.g habitat sho.ld be extremely small; noise
created from this activity is covered by the 4d rule. The fl.shi.g of bats from roost
trees os they are bei.g cot d.ring daylight hors world i.crease the likelihood that
the bats —old become prey for predazors.
Operatio. &
Ge.eral App.rtmoo" and Cathodic
H.mm distorbance
creased daytime aro.sal
h.man prese.ce
all life stages
NA
NA
NA
MA
These effects have bee. previo.sly addressed i. the Service's programmatic
Mainte.ance
Protectio. Co.stmetio. - tre.ching
biological opi.io. impleme.ti.g the final 4(d) rule dated Jan.ary 5, 2016.
anode, bell hole
Operatio. &
I.spectio. Activities - gm..d and
H.man activity and Dist.rbance
dayti e aro.sal
h.man prese.ce
all life stages,
NA
NA
NA
MA
These effects have bee, previo.sly addressed i. the Service's programmatic
Mainte.ance
aerial
sprig -fall
biological opi.io. impleme.ti.g the final 4(d) rule dated Jan.ary 5, 2016.