20200516 Ver 1_USFWS Comments_20200618

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United States Department of the InteriorSERVIUE
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa StreetFl
Asheville, North Carolina 28801
June 18, 2020
Amanda Jones
USACE — Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801
Dear Amanda Jones:
Subject: Silver Line Park; Buncombe County, North Carolina
Log No. 4-2-20-212
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in your
correspondence dated May 6, 2020, wherein you solicit our comments regarding project -
mediated impacts to federally protected species. We submit the following comments in
accordance with the provisions of the Fish and Wildlife Coordination Act, as amended
(16 U.S.C. 661-667e); 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).
Project Description
According to the information provided, the proposed project would consist of a municipal
recreation park on approximately five partially developed, but vacant acres in Woodfin, North
Carolina. The site contains approximately 1,400 linear feet of stream and 0.64 acre of wetland
and is bounded by the French Broad River to the south. Onsite habitats are significantly
disturbed due to a legacy of development activities and consist of sparse woody and herbaceous
vegetation throughout. A very thin vegetated riparian buffer occurs along the French Broad
River. Surrounding land use consists of commercial and industrial developments within riparian
areas and adjacent uplands.
The proposed project would entail several facilities, including roadways, parking areas, walking
paths, playground areas, stormwater management features, and appurtenances. Proposed work
would also entail the installation of a boat ramp, boulder toe, and associated methods for
temporary dewatering within the French Broad River.
Federally Listed Endangered and Threatened Species
Suitable summer roosting habitat may be present in the project area for the federally threatened
northern long-eared bat (Myotis septentrionalis). However, the final 4(d) rule (effective as of
February 16, 2016), exempts incidental take of northern long-eared bat associated with activities
that occur greater than 0.25 miles from a known hibernation site, and greater than 150 feet from
a known, occupied maternity roost during the pup season (June 1 — July 31). Based on the
information provided, the project (which may or may not require tree clearing) would occur at a
location where any incidental take that may result from associated activities is exempt under the

4(d) rule. Although not required, we encourage the Applicant to avoid associated tree
clearing activities during this animal's maternity roosting season from May 15 — August 15.
Service records indicate known occurrences of the federally endangered Appalachian elktoe,
(Alasmidonta raveneliana) and gray bat (Myotis grisescens) in the project vicinity. Gray bats
have established multiple roosts in manmade structures in the project vicinity. However, based
on the information provided, suitable roost habitats (natural or artificial) do not appear to be
present onsite. Moreover, disturbances associated with onsite and adjacent development
activities have likely precluded site suitability for foraging or migrating gray bats. It is more
likely that foraging and migrating bats would utilize the intact, forested areas on the opposite,
left -descending bank of the French Broad River.
Appalachian elktoe is known to occur in the French Broad River upstream from the project area.
Biologists evaluated the project area on June 17, 2020, described silt -dominant substrate
conditions, and did not detect evidence for this species at that time. Additionally, regional and
general permit conditions associated with applicable nationwide permits, would effectively
minimize or preclude project -mediated impacts to aquatic habitats within the French Broad
River.
For these reasons, we believe the probability for project -mediated take of gray bat and
Appalachian elktoe would be insignificant and discountable and would therefore concur with a
"may affect, not likely to adversely affect" determination from the appropriate action agency.
Based on the information provided, we have no concerns for project -mediated impacts to any
other federally protected species and we require no further action at this time. Please be aware
that obligations under section 7 of the Endangered Species Act must be reconsidered if: (1) new
information reveals impacts of this identified action that may affect listed species or critical
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.
We offer the following general recommendations on behalf of natural resources:
Permanent Lighting Recommendations
Gray bats are light adverse. We assume that the proposed project would comply with Buncombe
County lighting standards which are intended to minimize light pollution, light trespass and
glare, and promote energy efficiency. Still, we encourage the Applicant to consider the use of
warmer color temperature lighting (CCT < 3,000K), utilize LED light fixtures with lumen output
equal to or less than Buncombe County requirements, (e.g. Type II LED light fixtures with a 1-0-
1 BUG rating), minimize mounting height of outdoor area lighting, and employ downward -
facing fully shielded lighting to minimize light trespass into riparian areas.
Pollinator Habitat
Declines in wild pollinators are a result of loss, degradation, and fragmentation of habitat and
disease. Although not required, we encourage the Applicant to consider the recommendations
below to benefit the rusty -patched bumble bee and other pollinators. Moreover, the creation and
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maintenance of pollinator habitats at this site may increase the value of the project for the
community and help reduce the spread of invasive exotic plants. Please consider the following:
1. Sow native seed mixes in disturbed areas or in designated pollinator areas with plants
that bloom throughout the entire growing season.
2. Taller growing pollinator plant species should be planted around the periphery of the
site and 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, habitat to ground nesting/feeding birds, and cover for small mammals.
3. 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. Milk weed species
are an important host plant for monarch butterflies.
4. Avoid mowing of flowering plants. Designated pollinator areas show be mow only
50% of the plant height, but no lower than 8 inches.
5. Avoid mowing outside the active season for rusty -patched bumble bee and other
pollinators (April 15 — October 15).
6. Leave slash piles, mulch piles, or loose dirt piles along woodland edges. These areas
provide nesting habitats and/or nest materials for some pollinators.
7. Avoid the use of pesticides and specifically neonicotinoids.
8. Additional information regarding plant species, seed mixes, and pollinator habitat
requirements can be provided upon request.
The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-20-212.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
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