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Home My WebLink AboutR-3436 United States Dppartmpt of the Interior FISH AND WILDLIFE SERVICE Raleigh Field Office Post Office Box 33726 Raleeigh. North Carolina 27636.3726 December 18, 2003 WETLANDS 1401 GROUP DEC 2 3 2003 W. Lyndo Tippett, Secretary WATER QUALITY SECTION North Carolina Department of Transportation 1501 Mail Service Center Raleigh, NC 27699-1501 Dear Secretary Tippett: This letter is intended to provide comments to the North Carolina Department of Transportation (NCDOT) from the U.S. Fish and Wildlife Service (Service) regarding Governor Easley's proposal to construct an interstate highway from US 17 at the South Carolina state line in Brunswick County to US 74-76 west of Whiteville in Columbus County, North Carolina. According to the Transportation Improvement Program available on the NCDOT's web page, this project is referred to as R-3436. These comments are submitted in accordance with provisions of the Fish and Wildlife Coordination Act and the Endangered Species Act of 1973 (Act), as amended. As proposed, a significant portion of this project would follow the existing route of NC 211 through central Brunswick County and would bisect the Green Swamp Preserve, a nature preserve owned by The Nature Conservancy. This 15,907 acre preserve and the adjacent lands contain excellent examples of longleaf pine savanna and pocosin habitat. Of the original 92 million acres of longleaf pine communities that once extended from Virginia to Texas, less than three percent of these communities remain today. Less than one percent of the original acreage is in good condition (Frost 1993). The Green Swamp savanna is considered one of the most botanically diverse plant communities in temperate North America (Walker and Peet 1983). The area is home to the federally endangered red cockaded woodpecker (Picoides borealis) and rough-leaf loosestrife (Lysimachia asperulaefolia), both species protected by the Act. In addition, the Green Swamp provides habitat for six species of plants and eight species of animals that are listed as Federal Species of Concern by the Service (species under consideration for listing under the Act). The Green Swamp is also habitat for many other, species listed as rare in North Carolina by the North Carolina Natural Heritage Program (NCNHP). Much of the Green Swamp preserve has been designated a Registered Heritage Area with the NCNHP. Additional information about rare species known from this part of North Carolina as well as the Registered Heritage Area can be obtained from Ms. Linda Pearsall, director of the NCNHP (919-715-4195). The construction of an interstate highway through the Green Swamp would have both direct and indirect impacts on several state and federally listed rare species. Section 7(a)(2) of the Act requires that all federal agencies, or their designated non-federal representatives, insure that any action federally authorized, permitted, funded, or carried out by such agencies is not likely to jeopardize the continued existence of any federally-listed threatened or endangered species or result in the destruction or adverse modification of designated critical habitat. Impacts to protected species resulting from a project such as the one proposed will require section 7 consultation with the Service. A project of this scope will require that extensive measures be taken to avoid and minimize impacts to these species. Specifically, we are concerned that such measures may not adequately address the following important issues: 1. Historically, wildfires played an important role in maintaining the longleaf pine savannas throughout the southeastern United States. Today, the use of prescribed fire is necessary to maintain habitat for the federally protected species and plant communities found in the Green Swamp. Due to temporary reduced visibility that would result from prescribed fires, continued management of this preserve for rare species would be compromised if it is bisected by an interstate highway. 2. Much of the Green Swamp is considered to be high value wetlands. High quality wetlands are becoming increasingly rare in eastern North Carolina. In order to mitigate for the loss of these high quality, unique wetlands (as required by the Clean Water Act), wetland restoration and/or creation activities would require decades of work and are unlikely to achieve the functional values of the existing system. 3. Interstate highways contribute greatly to ecosystem fragmentation. They generally create wide gaps of highway and grassed shoulders and medians and the right-of-way limits are typically fenced creating barriers that prevent the free movement of large mammals and some bird species. Research indicates that the federally endangered red- cockaded woodpecker rarely crosses unforested areas greater than 200 feet wide (USFWS 2003). Since interstate highways and associated right-of-way are typically more than 200 feet wide, they have the potential to inhibit foraging for this species. Studies have shown that large highways create corridors for non-native species to invade roadsides which could be detrimental to this botanically unique area. The National Environmental Policy Act requires that NCDOT consider multiple alternatives for a project of this scope and choose the alternative that would avoid and minimize environmental impacts to the greatest extent practicable. Given the concerns highlighted above, we believe the NCDOT should prepare an Environmental Impact Statement that addresses all alternatives considered and should work with resource agencies including the Service, the U.S. Army Corps of Engineers, the U.S. Environmental Protection Agency and the N.C. Wildlife Resources Commission to choose the alternative that will cause the least amount impact to the environment. In addition, we recommend careful coordination with The Nature Conservancy, who manages the Green Swamp Preserve. The contact for the Green Swamp is Mr. Dan Bell (910-762-6277). Thank you for considering our comments regarding this project and for your continuing 2 cooperation with our agency in protecting federally-listed species. Please continue to advise us of the progress of this project. If you have any questions regarding our comments or would like to meet to discuss project alternatives, please contact Mr. Gary Jordan or Mr. Dale Suiter of this office at (919) 856-4520 extension 32 and 18, respectively. Sincerely, Dr. Garland Pardue Ecological Services Supervisor References: Frost, C.C. 1993. Four centuries of changing landscape patterns in the longleaf pine ecosystem. Pages 17-43 in S.M. Hermann, ed. The longleaf pine ecosystem: ecology, restoration and management. Tall Timbers Fire Ecology Conference Proceedings, No. 18. Tall Timbers Research Station, Tallahassee, FL. U.S. Fish and Wildlife Service. 2003. Recovery plan for the red-cockaded woodpecker (Picoides borealis): second revision. U.S. Fish and Wildlife Service, Atlanta, GA. 296 pp. Walker, J. and R.K. Peet. 1983. Composition and species diversity of pine-wiregrass savannas of the Green Swamp, North Carolina. Vegetatio 55: 163-179. cc: Governor Mike Easley Office of the Governor 20301 Mail Service Center Raleigh, NC 27699-0301 Honorable Bill Ross Secretary, DENR 1601 Mail Service Center Raleigh, NC 27699-1601 Mr. Louis W. Sewell, Jr. NCDOT Board Member for Division 03 (At Large Member) P.O. Box 536 Jacksonville, NC 28540 3 r I Ms. Nina Szlosberg DOT Board Member (At-Large: Environment) 2710 Rosedale Ave. Raleigh, NC 27607 Mr. Lanny T. Wilson DOT Board Member for Division 03 1442 Quadrant Cir. Wilmington, NC 28405. Roger Sheats Deputy Secretary, NCDOT Mail Service Center 1548 Raleigh, NC 27699 Rep. Mike McIntyre 228 Cannon House Office Bldg. Washington, D.C. 20515 Rep. Dewey Hill 1309 Legislative Bldg. Raleigh, NC 27601-1096 Sen. R.C. Soles 2022 Legislative Office Bldg. Raleigh, NC 27601-2808 Rep. Bonner Stiller 508 Legislative Office Bldg. Raleigh, NC 27603-5925 . Rep. Thomas Wright 528 Legislative Office Bldg. Raleigh, NC 27603-5925 Ms. Emily Lawton Federal Highway Administration 310 New Bern Avenue Suite 410 Raleigh, NC 27601 Mr. Chris Militscher c/o Federal Highway Administration 310 New Bern Avenue Suite 412 4 - ,. Raleigh, NC 27601 Ms. Linda Pearsall N.C. Natural Heritage Program 1615 Mail Service Center Raleigh, NC 27699-1615 Mr. Dan Bell The Nature Conservancy 2725 Old Wrightsboro Road Building 4, Unit E Wilmington, NC 28405 Katerine Skinner The Nature Conservancy 4705 University Drive, Suite 290 Durham, NC 27707 Mr. Travis Wilson N.C. Wildlife Resources Commission 1142 I-85 Service Road Creedmoor, NC 27522 Mr. David Timpy U.S. Army Corps of Engineers P.O. Box 1890 Wilmington, NC 28402-1890 Mr. Richard Spencer U.S. Army Corps of Engineers P.O. Box 1890 Wilmington, NC 28402-1890 t/Mr. John Hennessy N.C. Division of Water Quality 2321 Crabtree Boulevard, Suite 250 Raleigh, NC 27604 5