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Home My WebLink About20191704 Ver 1_FWS_Response_20-044 Duke Energy__20191211United States Department of the Interior FISH AND WILDLIFE SERVICE Asheville Field Office 160 Zillicoa Street Suite #B Asheville, North Carolina 28801 December 4, 2019 Ms. Johanna Velasquez HDR, Inc. 440 S. Church Street, Suite 1000 Charlotte, North Carolina 28202 Dear Ms. Velasquez: Subject: Federally Listed Species Assessment, Duke Energy Carolina’s - Proposed Capps to Hendersonville 44kV Transmission Line Rebuild Project, in Hendersonville, Henderson County, North Carolina On November 20, 2019, we received (via e-mail) your letter requesting our review and comments on the subject project. The following comments are provided in accordance with the provisions of the National Environmental Policy Act (42 U.S.C.§ 4321 et seq.) and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). According to the information presented, your client (Duke Energy Carolinas, LLC) is proposing to replace about 4.2-miles of transmission structures and overhead lines. The 38.84-acre project area consists of utility corridor, undeveloped land, and public open space. Duke Energy Carolinas will replace the current power infrastructure with double circuit conductors and light duty steel poles and towers in the predominantly maintained/existing right-of-way. Though no specific plans or details of project impacts were included in your letter, you indicated that the proposed project will require a Clean Water Act – Section 404 Nationwide Permit. Federally Listed Species – According to the information that you provided, HDR biologists conducted species surveys within the project area in May 2016, May 2019, and November 2019. Your letter states, “The field surveys revealed the Project Area is maintained on a routine basis to prevent growth of mid-story and canopy species.” Given the findings, the biologists concluded that no federally listed species or their habitat occurs within the project area. We concur with the conclusions from the field surveys and concur that no federally listed species or their habitats occur in the project area. Therefore, we believe the requirements under section 7 of the Act are fulfilled. However, obligations under section 7 of the Act must be reconsidered if: (1) new information reveals impacts of this identified action that may affect listed species or critical Ms. Velasquez – HDR, Inc. habitat in a manner not previously considered, (2) this action is subsequently modified in a manner that was not considered in this review, or (3) a new species is listed or critical habitat is determined that may be affected by the identified action. Project Recommendations – We are concerned about the introduction and spread of invasive exotic species in association with the proposed project. Therefore, we strongly recommend that only species native to the natural communities within the project area be used in association with all aspects of this project. Furthermore, we recommend that seeds for native plants that are beneficial to pollinators be included in any erosion control seed mixes. Pollinators, such as most bees, some birds and bats, or other insects, including moths and butterflies, play a crucial role in the reproduction of flowering plants and in the production of most fruits and vegetables. Declines in wild pollinators are a result of loss, degradation, and fragmentation of habitat and disease; while declines in honey bees has also been linked to disease. To offset the overall impacts of development and/or to increase the habitat and species diversity within the project area, we recommend the following measures be implemented into project design: 1. Sow native seed mixes with plant species that are beneficial to pollinators throughout the site. Taller growing pollinator plant species should be planted anywhere on the site where mowing can be restricted during the summer months. Taller plants, left un-mowed during the summer, would provide benefits to pollinators, provide habitat to ground nesting/feeding birds, and cover for small mammals. Low growing/groundcover native species should be planted in areas that need to be maintained. This would provide benefits to pollinators while also minimizing the amount of maintenance such as mowing and herbicide treatment. Using a seed mix that includes milk weed species (milk weed is an important host plant for monarch butterflies) is especially beneficial. The following website provides a comprehensive list of native plant species that benefit pollinators: http://www.xerces.org/wp-content/uploads/2014/09/MidAtlanticPlantList_web.pdf Additional information regarding plant species, seed mixes, and pollinator habitat requirements can be provided upon request. We also offer our assistance with developing seed mixes that can be used in conjunction with fast growing erosion control seed mix for overall soil stability and pollinator benefits. 2. We recommend that Duke Energy implement a right-of-way maintenance plan that targets ecological/habitat benefits to wildlife species, especially pollinators and birds that require early successional habitats. One of the best ways to accomplish this objective is to use Integrated Vegetation Management (IVM) practice using low-volume herbicide applications when planning management activities. Pollinator nest sites in ROWs managed with IVM practices have been found to contain about 30% more pollinator nesting sites and species richness than traditionally mowed maintenance areas. Aside from removing problem vegetation, the primary focus should be placed on establishing compact flowering shrubs and managing for native grasses and wildflowers. The overall objective is to reach a sustainable level of grasses, forbs, and flowering shrubs (wherever feasible) throughout the project area. The following website provides additional information on pollinators and habitat conservation methods: http://www.fws.gov/pollinators/pollinatorpages/yourhelp.html Ms. Velasquez – HDR, Inc. Invasive Exotic Species – Without active management, including the re-vegetation of disturbed areas with native species, the project area will likely be a source for the movement of invasive exotic plant species. Exotic species are a major contributor to species depletion and extinction, second only to habitat loss. Exotics are a factor contributing to the endangered or threatened status of more than 40 percent of the animals and plants on the Federal List of Endangered and Threatened Wildlife and Plants.1 It is estimated that at least 4,000 exotic plant species and 2,300 exotic animal species are now established in the United States, costing more than $130 billion a year to control.2 Additionally, the U.S. Government has many programs and laws in place to combat invasive species (see www.invasivespecies.gov) and thus cannot spend money to counter these efforts. Specifically, Section 2(a)(3) of Executive Order 13112 - Invasive Species (February 3, 1999) directs federal agencies to “not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere.” Despite their short-term erosion-control benefits, many exotic species used in soil stabilization seed mixes are persistent once they are established, thereby preventing the reestablishment of native vegetation. Many of these exotics plants 3 are also aggressive invaders of nearby natural areas, where they are capable of displacing already established native species. Therefore, we strongly recommend that only native plant species be used in association with all aspects of this project. We appreciate the opportunity to provide these comments. If we can be of assistance or if you have any questions, please contact Mr. Bryan Tompkins of our staff at 828/258-3939, Ext. 42240. In any future correspondence concerning this project, please reference our Log Number 4-2-20-044. 1Wilcove, D. S., D. Rothstein, J. Dubow, A. Phillips, and E. Losos. 1998. Quantifying threats to imperiled species in the United States. BioScience 48:607-615. 2Pimentel, D., L. Lach, R. Zuniga, and D. Morrison. 2000. Environmental and economic costs of nonindigenous species in the United States. BioScience 50:53-65. 3 Lists of invasive exotic plants can be found at http://www.tneppc.org/ and http://www.invasive.org/eastern/srs/ on the Internet.