HomeMy WebLinkAbout20161268_Information Package for 4-20-2010_20100420ft
CONCURRENCE MEETING
INFORMATION PACKET
FOR YOUR REVIEW
PRIOR TO MEETING ON
o
Wednesday. April z o .9 o
PROJECT ENGINEER
Olivia Farr
TIP #U-4751
Please bring this packet
to the meeting.
US 1 7 CORRIDOR STUDY
NEW HANOVER AND RENDER COUNTIES
TIP PROJECT NOS. U-4751 AND 4 -3300
STATE PROJECT,JVO. 40191.1.1
A
NEPA/SECTION 404 MERGER MEETING AGENDA
APRIL 20, 201 0
1. Introductions and Sign-in
2. Purpose of Meeting
3. Project Review
a. Overview
b. Purpose and Need
c. Project Status
4. Project Alternatives
5. Water Resources
6. Hydraulic Structure Requirements
7. Field Meeting Discussion
t
8. Summary/Final Comments
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE
GOVERNOR
AGENDA
Western Concurrence Meeting
Wednesday April 14, 2010
Board Room, Transportation Building
Raleigh, North Carolina
EUGENE A. CONTI, JR
SECRETARY
10:30 AM to 12:00 PM, Olivia Farr, Project Planning Engineer, PDEA Branch
TIP No. U-4751, US 17 Corridor Study
New Hanover and Pender Counties, Division 3
Team Members:
Brad Shaver, USACE
Olivia Farr, PDEA
Chris Militscher, USEPA
Gary Jordan, USFWS
Ron Sechler, NMF
Travis Wilson, WRC
Steve Sollod, DCM
Rich Carpenter, DMF
David Wainwright, DWQ
Renee' Gledhill-Early, SHPO
Don Eggert, Cape Fear RPO (non-signatory)
Mike Kozlosky, Wilmington MPO
NCDOT Technical Support Staff and Other Agency Staff:
Allen Pope, Division 3
Jackson Provost, Division 3
Mason Herndon, Division 3
Gary Lovering, Roadway Design
Ron Allen, Roadway Design
Jerry Snead, Hydraulics
Ray McIntyre, Program Development
Mark Staley, Roadside Environmental
Earlene Thomas, TPB
Elizabeth Lusk, NEU
Mary Pope Furr, HEU
Greg Smith, HEU
Matt Wilkerson, HEU
Jay McInnis, PDEA
Rob Hanson, PDEA
Consultants:
Liz Kovasckitz, Mulkey, Inc.
Jay Bissett, Mulkey, Inc.
* The purpose of this meeting is to reach concurrence on CP 2A.
Please bring the Packet mailed to you for the April 14th meeting.
MAILING ADDRESS: TELEPHONE: 919-733-3141 LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: 919733-9794 TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE: WWW.N000T.GOV RALEIGH NC
RALEIGH NC 276991548
lne 441'IV
U-4751 CP2A - Corbett Tract
History/Background
Wetland Mitigation Fatal Flaw/Feasibility Study for the Corbett property dated
October 2001 reports that:
"NCDOT has identified a section of the Corbett property as a candidate
for potential wetland mitigation (study area). The Corbett Tract will be
bisected by the 1-40 Connector. The study area consists of approximately
621.8 acres..."
Study area contains three community types. Approximately 400 acres of
pond pine woodland, 120 acres of wet pine flatwoods, and 65 acres of bay
forest (see attached Figure 4).
Provides four options for mitigation credit involving combinations of
restoration, preservation & enhancement as well as a paragraph discussing
preservation of the entire site at enhancement ratios of 5:1 (see attached)
Mitigation & Suitablity and Recommendations states final credit and
ratios dependent on "interpretation of exisiting jurisdictional wetland
status by US ACOE" as well as if "one or more combinations is
acceptable a detailed mitigation plan will finalized"
• Draft Biological Assessement dated January 2002 has a map showing Corbett
Tract Mitigation Site, Corbett Strip Residual Site, Plantation Road Site and two
residual sites (see attached Figure 1 Location Map and document excerpts on each
of these sites)
• The USFWS Biological Opinion dated May 2002 states specifically that NCDOT
will retain the "Corbett Strip to act as a buffer between the I-40 Connector and
adjacent rough-leaf loosestrife clusters further pointing towards no mitigation
being within the strip (see attached excerpt)
• Letter to ACOE dated 2-13-2003 discusses the Corbett Tract in detail including
why restoration activities were not performed (see attached). It also clarifies
community types included in provided mitigation.
• ACOE permit # 199403620 dated 9-22-03 for TIP R-2405A Special Conditions,
14a.states: 467.0 acres of wet pine flat preservation and 26 acres of bottomland
hardwood preservation were provided by the Corbett Tract. Special Condition 14c
states "the Corbett Tract shall be maintained by the permittee in its natural
condition in perpetuity" (see attached)
• According to the NEU Geo-Database, the Corbett Tract contains 617.5 acres and
the Corbett Strip Residual Site contains 28.5 (see attached aerial labeled Corbett
Tract)
Conclusions
• 493 acres of the Corbett Mitigation Tract were permitted (ACOE permit
#199403620) as part of the compensatory mitigation requirement for 98.2 acres
of wetland impacts associated with R-2405A at a 5:1 ratio
• Corbett Strip Residual Site was not used for compensatory mitigation but as part
of the Conservation Measures of both NCDOT's Biological Assessment and the
USFWS issued Biological Opinion
• Additional research & information is needed to determine actual location of
jurisdictional wetland areas on Corbett Tract used for R-2405A
• Other information?
M
PLANT COMMUNITIES
WET PINE FLATWOODS:E
BAY FOREST
(BOTTOMLAND)
REMAINING AREA CONSISTS
'OF POND PINE WOODLAND
PRINCE GEORGE
r CREEK
r , li s >? 1
Eta iti' ? 1 A 1?
t n.. -]' -g r 1 ?
?sPP§y ; ?? APPROXIMATE LOCATION ' l
`, Ilaf 1`"' m ,WILMINGTON BYPASS
) { a
y ,? t k } 2F. {_ it I??'. r e/z ?.t +ar ia..rjt 7? t ,n+ n_i rt
I
r^$<A,
li
..F i
.1?ia 5) T v I.C ? ? i.'!1 I a
o
! I J.2:.
t,u Ij?t11 ?{: D Sfo ff
?11^
' t cqm ,u 1"f
y
? t?.i -
:+}
3j 1 ,un"nY?i'
.W? L
..I y
t,
1 Y?tl it-?'a OF '. L
C isY 1
?
I y.y t
` r
44 ^
?,,. ?7a I
* a
' S? f j r t L r•?',,?fL'iG' > r'?
' i?Ya
' -i' ?.
- +
- i
s
n ?'y`.?\? 2J 3.
Nt2 ?
" r . . 1
!
i: {
r
I4?'t9u s
kn 1
I ;
r t r: Y I ?? .p x f 4
b
?,
x
r g>
..rs '' ?' _ 271 I, dI
`
2000 k.
0 4000 ft. „i - -
T- j
1:24.000
Sou ce'. l1SGS 7.5 Minute Quadrangle (Scotts H II N C.) ' L ;-
Dnc o . MAE
rlcuae
I'
CptiC;C„CC PLANT COMMUNITIES oyo:
.
cf)rpm-ario n
CORBETT PROPERTY
oa1a, AVPd
WN
Raleigh. NmthCarohna New Hanover County, North Carolin a JUN 2001
00.046.02
Option 3 .
New Lo cation Stream Restoration
(not possible without extensive hydrologic trespass)
Option 4
Pocosin (Interstream Flats) 31.7 (12.8) 2:1 15.8
Restoration
Bay forest Preservation 26.0 (10.5) 10:1 2.6
Pocosin (Interstream Flats) 409.5 (165.7) 10:1 40.9
Preservation
Existing Uplands 117.9 (47.7)
1-40 Connector 36.8 (14.9)
TOTALS 621.8 (251.6) 59.3
The study area provides an exceptional region of transition between several distinct plant
communities and includes habitat for protected and rare plants and animals. The combination of
wetland and upland communities, as well as the associated ecotonal boundaries, promotes a
diverse assemblage of plants and animals. The study area potentially may provide education and
research opportunities within unique plant communities that are becoming much less extensive.
Preservation of this study area, along with long-term management, will provide a contiguous
bioreserve and potentially valuable education and research opportunity abutting the proposed 1-40
Connector. In order to assure preservation of a unique combination of undisturbed natural
communities, agencies should consider enhancement ratio credits for the preservation of the study
area (5:1). Estimates indicate as much as 409.5 acres (165.7 hectares) and 117.9 acres (47.7
hectares) of uplands are available for preservation.
Endangered Species Habitat Preservation/Enhancement
One red-cockaded woodpecker colony has been documented in southwestern portions of the
Corbett Property. Numerous start holes (new cavity construction) have also been identified
throughout adjacent areas. In addition, documented populations of rough-leaved loosestrife occur
south of the study area. Sandy upland ridges and domes supporting Leon soils represent potential
habitat areas for rough-leaved loosestrife and Cooleys meadowrue. Undocumented populations of
these species most likely occur on some of these upland inclusions (surveys are currently being
conducted). Preservation of the study area will protect habitat required for these species under the
current conditions. Management of the study area for red-cockaded woodpecker, Cooleys
meadowrue, and rough-leaved loosestrife, would consist primarily of fire break establishment, and
24
.?i
4.2 Mitigative Measures
n Construction of the proposed project will result in the direct impact to a minimum of 354 RILL
stems present in 2001. rnmize overall im
species as a result of this roe , NCDOT i i
mitigation several properties adjacent to the 1-40 Connector right-of-
way The areas 6}f r^,?91?J@liaar include the Corbett Tract Mitigation Site w;44RC original
1996 populations, rill as three right-of-way residual properties. h
^' deg de 'pt ^ y a tiens, resdlts ffem RLL seroe? s, and
rar dRt'° R f°r R LL p@tei^l Each of these areas is described below.
4.2.1 Corbett Tract Mitigation Site
The Corbett Tract Mitigation Site is an approximately 621.8-acre (251.6-ha) parcel being
considered by NCDOT for on-site, wetlands mitigation for the 1-40 Connector. The parcel is
bisected by the western section of the 1-40 Connector (Figure 3). This parcel contains an active
red-cockaded woodpecker colony and a substantial portion of the foraging habitat for this
colony. Any activities on this parcel within 0.5 mile (0.8 km) of the red-cockaded woodpecker
colony must take the nesting and foraging habitat requirements of this federally Endangered
species into account.
i An evaluation of this parcel was conducted 1-4 October. 2001 and included a survey to
I determine whether RLL is present and an evaluation of habitat potential for supporting RLL.
Several previously undocumented clusters of RLL were documented across the Corbett Tract
Mitigation Site during this evaluation and are identified as L-11 through L-28 on Figure 3.
Soils within the Corbett Tract Mitigation Site are mapped mostly as Murville fine sand. Minor
areas of Seagate fine sand and Leon sand are interspersed throughout the site.
i
4
Hydrology within the Corbett Tract Mitigation Site ranges from scattered areas of somewhat
poorly drained (Seagate series) and poorly drained soils (Leon series), to large areas of very
poorly drained soils (Murville series). Hydrology has been locally affected by ditching
?; at
associated with a dirt road system traversing the site, as well as interior silvicultural ditching and
agricultural ditches located to the west. Ditching across the Corbett Tract Mitigation Site ranges
- 1 in overall depths between approximately 2 to 6 feet (0.6 to 1.8 m). Based on field observations,
3[
the effective depth of ditching is approximately 18 inches (0.46 m). Based on hydrologic
T predictive modeling (DRAINMOD) the ditches are expected to remove sufficient hydrology such
E that saturation within 12 inches (0.31 m) of the soil surface is forecast to not occur for 14
,
` consecutive days (5 percent of the growing season) within 196.9 feet (60.0 m) of the ditch edge.
The ditches are expected to remove sufficient hydrology such that saturation within 12 inches
(0.31 m) of the soil surface is forecast to not occur for 34 consecutive days (12.5 percent of the
growing season) within 369.1 feet (112.5 m) of the ditch edge.
12
Vegetation within the Corbett Tract Mitigation Site varies in composition and density.
The majority of the Corbett Tract Mitigation Site is classified as pond pine woodland. Overstory
vegetation is limited in these areas, consisting of scattered pond pine stems. Midstory
vegetation is generally very thick except for areas which have been manually cleared. Midstory
vegetation consists of pond pine saplings, sweet gallberry, fetterbush, evergreen bayberry
(Myrica heterophylla), and titi (Cyrilla racemiflore). Catbrier is present throughout this
community. Herbaceous vegetation is generally absent in this community due to the thick
midstory. Where present, herbaceous vegetation includes netted chain-fern (Woodwardia
areolata), Virginia chain-fern, and yellow pitcher plant.
Some areas located on the western portion of the Corbett Tract Mitigation Site are classified as
wet pine flatwoods. These areas have canopies of mature pond pine with scattered longleaf
pine (Pinus palustris). Within this community, midstory vegetation ranges from nearly absent to
thick areas of red bay and sweetbay. Herbaceous vegetation includes creeping blueberry,
dwarf huckleberry (Gaylussacia frondosa), wiregrass and scattered bracken fern (Pteridium
aquilinum).
RILL Recommendation
Eighteen (18) separate clusters of RLL were documented within the Corbett Tract Mitigation Site
during evaluations conducted 1-4 October 2001 (L-11 through L-28 as shown on Figure 3); one
of these (L-28) is located within the 1-40 Connector right-of-way. Most RLL clusters were
identified along cleared lanes that had been established through the dense vegetation prevalent
throughout most of the site. Stem counts were not conducted in all clusters identified, however,
a minimum of over 100 stems were identified within Corbett Tract Mitigation Site. Based on field
observations, five (5) areas of potential RILL habitat are present within the Corbett Tract
Mitigation Site (Figure 3). More detailed investigation of these clusters is warranted during the
next growing season.
NCDOT will consider additional survey work conducted during a more optimal survey period,
preferably earlier in its annual growth cycle, and may consider some form of site preparation to
open up potential habitat areas. Clearing additional transects through the dense vegetation
may trigger a response by the plants if additional RLL is present. RLL may persist in a
rhizomatous stage for years before producing stems and possibly flowering in response to
opening up of the habitat (personal communication, David DuMond, 4 October 2001).
Discussion with the timber manager for the site, D. Thompson Tew (3 October 2001), indicates
that active fire suppression has led to a high fuel load on the site. Burning this site may not be
possible without damage to or destruction of the existing trees, including the pond pines stems
which are considered foraging substrate for red-cockaded woodpeckers, as well as possibly
destroying the RLL rhizomes. Mechanical clearing of additional lanes may be the most
13
effective, non-destructive means of creating open areas through potential habitat, but this
method may be limited by the wet soil conditions. Further discussions will be pursued among
NCDOT, its consultants, and individuals with expertise on the ecological requirements of this
species to determine the most feasible approach to determining the extent of RLL on the site as
well as identifying the best management strategy for RLL.
e LA46w7+1?-J a?0l7 suC 4, µS1
ldpal;m NCDOT i the Corbett Tract Mitigation Site as an on-site wetland
mitigation area. NCDOT will consider the presence of RLL within this area during the evaluation
of this site as a wetland mitigation area. NCDOT will coordinate and solicit input from the
USFWS concerning viability of incorporating RLL issues into any wetland mitigation possibilities,
including: 1) habitat maintenance protocols; 2) vegetation monitoring for RLL; and 3)
dispensation of the property to a responsible party who will continue maintaining the area for
RLL as well as wetlands.
4.2.2 Original 1996 Populations
In 1996, during the course of a jurisdictional delineation of the 1-40 Connector corridor, a
specimen of RLL was identified in the vicinity of the US 17 terminus. At the time of the
discovery, RLL had not been previously identified within New Hanover County. A total of seven
(7) clusters comprised of a minimum of 645 RILL stems were identified at two sites during the
initial survey conducted in 1996- Six of these clusters are located in a series of parcels north of
Plantation Road and these clusters along with five. (5) additional clusters subsequently located
in this area in 2001 are collectively designated as the Plantation Road Site. Two of these
clusters are located within the 1-40 Connector right-of-way and are discussed in Section 2.4.1.
The original cluster located in 1996 near the US 17 Interchange is more than 0.5 mile (0.8 km)
from the Plantation Road Site and is designated as a separate site, the US 17 Site.
US 17 Site (Dtj? b`
One RILL cluster (L-4) was located north of the proposed US 1 nterchange, west of existing
US 17 in 1996. This cluster was comprised of five (5) RLL stems at the edge of a tire rut. In
2000, the area was searched with Plant Conservation Se ice (PC EP personnel as part of a
species status review. Recent timbering operations had been undertaken in this area. Severe
rutting was documented at the cluster location and no evidence of RILL was noted. PC11e
personnel determined that L-4 had been eliminated through the clearing activities. In June
2001, the area was again searched for the presence of RLL. No evidence of RLL was found.
Based on the apparent loss of the US 17 Site (L-4), the remainder of the evaluation of the
original 1996 sites deals strictly with the Plantation Road Site south of the 1-40 Connector right-
of-way.
14
'lantation Road Site
hree of the original 1996 clusters (L-1, L-2 and L-3) are located approximately 1.6 miles (2.6
m) west of US 17, and approximately 1500 feet (457 m) north of Plantation Road (Figure 2).
)ne additional cluster, L-9, was noted in the area of these clusters during the 2001 evaluation.
Three of the other original 1996 clusters (L-5, L-6, and L-7) are located approximately 0.3 mile
0.5 km) west of L-3, approximately 1500 feet (457 m) north of Plantation Road (Figure 2).
Additional RLL stems were documented along a new trail linking L-5 and L-6; this cluster is now
designated as L-5/6. An additional cluster, L-8, was identified in the area of these clusters in
2001.
During the 2001 review, an additional cluster (L-10) was identified approximately 900 feet (274
m) west of L-3 and 1300 feet (396 m) north of Plantation Road (Figure 2). The two clusters
located in the 1-40 Connector right-of-way, L-29 and L-30, are also considered part of the
Plantation Road Site. These clusters are located approximately 800 feet (244 m) northwest of
L-5/6.
In 1996, the Plantation Road Site contained a minimum of 640 RLL stems; in 2001, this site was
found to contain a minimum of 623 stems, exclusive of the stems in the two right-of-way
clusters.
Soils within the Plantation Road Site are mapped as Murville fine sand, with areas of Leon sand
and Lynn Haven fine sand (Typic Haplaquod).
On-site review indicates soils in the area of L-1, L-2, L-3 and L-9 (Figure 2) are consistent with
the descriptions of the Murville series, with some areas transitioning to the Lynn Haven series.
On-site review indicates soils in the area of L-5/6, L-7, and L-8 are consistent with the
descriptions for the Murville series, with some areas transitioning to the Lynn Haven and Leon
series.
On-site review of L-10 indicates soils in this area are consistent with descriptions for the Murville
series.
Hydrology within these areas ranges from scattered areas of poorly drained soils (Leon and
Lynn Haven series) to larger areas of very poorly drained soils (Murville series). The area
adjacent to the clusters was reviewed for the presence of internal or adjacent ditching. No
ditches were found within or between the clusters; however, large ditches were noted north of
all clusters and east of clusters L-1, L-2, L-3 and L-9. On-site review indicated the ditches have
an overall depth 3-6 feet (1-1.8 m). Based on field observations, the effective depth of the
ditches is approximately 18 inches (0.46 m). Based on hydrologic predictive modeling
(DRAINMOD) the ditches are expected to remove sufficient hydrology such that saturation
15
;A? -
:t
i
within 12 inches (0.31 m) of the soil surface is forecast to not occur for 14 consecutive days (5
percent of the growing season) within 196.9 feet (60.0 m) of the ditch edge. The ditches are
expected to remove sufficient hydrology such that saturation within 12 inches (0.31 m) of the
soil surface is forecast to not occur for 34 consecutive days (12.5 percent of the growing
season) within 369.1 feet (112.5 m) of the ditch edge.
RLL Recommendation
During the original population surveys in 1996, a minimum of 640 RLL stems was noted within
the Plantation Road Site. During the 2001 population-survey, a minimum of 623 stems was
noted, exclusive of the clusters in the 1-40 Connector right-of-way. The midstory vegetation,
consisting mainly of sweet gallberry and pond pine saplings, is beginning to assert itself over the
area.
RLL clusters within this potential mitigation/conservation site are located on five (5) parcels
owned by four separate individuals. The parcels are not contiguous, with two (2) separate
parcels located between parcels containing RLL clusters. The entire block of seven (7) parcels
encompassing the Plantation Road Site includes five (5) separate property owners.
The area offers potential for plant conservation based on the threat of ditching and
encroachment of residential areas. Two contiguous rows consisting of eight (8) parcels each
have been identified as essential for protecting and managing the Plantation Road Site for RLL.
These sixteen (16) parcels are under the control of eleven (11) property owners. These parcels
total approximately 89.9 acres (36.4 ha) and are bounded by ditches to the east, south, and
west. The narrow Corbett Strip (see Section 4.2.3.1) and associated ditch bound the Plantation
Road Site to the north.
pro Pow 7D acf,:re-
NCDOT' a? the sixteen (16) parcels totaling approximately
89.9 acres (36.4 ha). NCDOT will evaluate this area as a plant conservation habitat as well as
for wetland mitigation purposes and will coordinate with USFWS to determine a responsible
party for dispensation,
4.2.3 Right-of-Way Residual Properties
4.2.3.1 Corbett Strip Residual Site
The residual Corbett Strip Residual Site (Corbett Strip) has been identified as an area of land
F
approximately 6.0 to 84.0 feet (1.8 to 25.6 m) wide adjacent to the 1-40 Connector right-of-way
southern boundary (Figures 2 and 3). This strip extends approximately 8200 feet (2500 m)
eastward from the Corbett Tract Mitigation Site (see Section 4.2.1). The eastern end of the
a? Corbett Strip is adjacent to the northern boundary of the Plantation Road Site (see Section
4.2.2) and the 34-Acre Residual Site (see Section 4.2.3.2).
?J
`j 16
yiExisting Conditions
I Soils within the Corbett Strip are mapped as Murville fine sand throughout most of the length,
with minor areas mapped as Leon sand and Lynn Haven fine sand.
On-site investigation indicates the soils within the Corbett Strip are consistent with descriptions
of the mapped series.
Hydrology within the Corbett Strip ranges from poorly drained soils (Leon and Lynn Haven
series) to very poorly drained soils (Murville series). Overall hydrology is strongly influenced by
the presence of a ditch running adjacent to or though its entire length. The maximum distance
from the existing ditch for any point along the Corbett Strip is approximately 65 feet (20 m).
i Jurisdictional hydrology was determined to be lacking from the Corbett Strip during the
delineation undertaken for this project in 1996 (ESI 1996).
Vegetation along this strip is variable, but tends to be dominated in the low shrub and herb
strata by species indicative of drier conditions, including stagger-bush (Lyonia mariana) and
bracken fern.
RILL Recommendation
No RILL were identified within the Corbett Strip during surveys in October 2001. RILL cannot be
ruled out as potentially occurring within this strip based on the proximity of RLL clusters L-29
and L-30 to the northern boundary of the same ditch and the proximity of RLL clusters L-1
through L-3 and L-5 through L-10 to the southern boundary of the same ditch. Although not
likely based on the proximity of the ditch and associated zone of drainage influence, the Corbett
Strip should be considered as potential RILL habitat, particularly along stretches extending.
farthest from away from the ditch where rhizomes of RILL may be able to extend from more
suitable adjacent areas. The Corbett Strip will be retained by NCDOT to act as a buffer
between the 1-40 Connector and adjacent RILL clusters.
4.2.3.2 34-Acre Residual Site
i
g
r?
The 34-Acre Residual Site has been identified as an area of land including six residual parcels
labeled as R1 through R6, respectively, on Figure 2. R2 through R6 are contiguous and located
adjacent to the northern boundary of the 1-40 Connector right-of-way northeast of Plantation
Road Site (see Section 4.2). R1 is located adjacent to the southern boundary of the 1-40
Connector right-of-way and adjacent to the eastern boundary of the Plantation Road Site. The
evaluation of this collective residual property included a survey to determine whether RLL is
present, an evaluation of habitat potential for supporting RILL, and an evaluation of wetlands
mitigation potential.
17
Existing Conditions
Soils within the 34-Acre Residual Site are mapped as Murville fine sand with small areas of
Seagate fine sand and Leon sand.
On-site investigation indicates soils present within the 34-Acre Residual Site are consistent with
descriptions of the mapped series.
Hydrology within this area ranges from poorly drained soils (Leon and Seagate series) to very
poorly drained soils (Murville series). Overall hydrology is influenced by the presence of
ditching associated with the property boundary and adjacent road side. Based on field
observations, the effective depth of the ditches is approximately 18 inches (0.46 m). Based on
hydrologic predictive modeling (DRAINMOD)' the ditches are expected to remove sufficient
hydrology such that saturation within 12 inches (0.31 m) of the soil surface is forecast to not
occur for 14 consecutive days (5 percent of the growing season) within 196.9 feet (60.0 m) of
the ditch edge. The ditches are expected to remove sufficient hydrology such that saturation .
within 12 inches (0.31 m) of the soil surface is forecast to not occur for 34 consecutive days
(12.5 percent of the growing season) within 369.1 feet (112.5 m) of the ditch edge. The
remaining areas within the property are considered jurisdictional. This area offers the.potential
for limited wetland restoration and enhancement, with large areas available for wetland
preservation.
Vegetation within the 34-Acre Residual Site varies in composition and density.
The majority of this area is characterized as pond pine woodland. Overstory vegetation is
limited, consisting of scattered pond pine and loblolly bay stems. Midstory vegetation is
generally very thick except for areas which have been cleared for fire breaks. Midstory
vegetation generally consists of thick areas of sweet gallberry, often reaching heights of
approximately 12 feet (3.5 m). Other vegetation within this area includes fetterbush, evergreen
bayberry, and titi. Catbrier is present throughout this community. Herbaceous vegetation is
generally absent in this community due to the thick midstory. Where present, herbaceous
vegetation includes netted chain-fern, Virginia chain-fern, and yellow pitcher plant.
One area at the northern end of the 34-Acre Residual Site is characterized as wet pine
flatwoods and contains large stems of long leaf and pond pine. Midstory vegetation ranges from
nearly absent to thick areas of red bay and sweetbay. Herbaceous vegetation includes
creeping blueberry, sweet gallberry, dwarf huckleberry, wiregrass, staggerbush, and scattered
bracken fern.
The cleared fire break located within the 34-Acre Residual Site contains no tree-sized material.
The fire break is dominated by large areas of peatmoss (Sphagnum spp.) with herbaceous
material including giant cane, yellow-eyed grass (Xyris sp.), bluestem (Andropogon sp.), and
18
( F ? f`TxtM"li:.n .
2i
t
Carolina redroot (Lachnanthes caroliniana). Small hummocks within the fire break are generally
dominated by sweet gallberry and evergreen bayberry.
RLL Recommendation
No RLL were identified within the 34-Acre Residual Site during surveys of potential habitat in
October 2001- RLL cannot be ruled out as potentially occurring within the area. Portions of the
34-Acre Residual Site should be considered as potential RLL habitat (Figure 2). NCDOT may
consider this site for wetland mitigation purposes and may consider conducting more detailed
investigations of the potential RILL habitat during a more optimal survey period.
4.2.3.3 22-Acre Residual Site
The 22-Acre Residual Site has been identified as an area of land including two residual parcels
labeled as R10 and R11, respectively, on Figure 2. R10 and R11 are contiguous and located
adjacent to the northwestern boundary of the 1-40 Connector interchange at US 17. The
evaluation of this collective residual property included a survey to determine whether RLL is
present, an evaluation of habitat potential for supporting RLL, and an evaluation of wetlands
mitigation potential.
Existing Conditions
Soils within southern and western portion of the 22-Acre Residual Site are predominately
mapped as Murville fine sand with interspersed areas of Leon sand. The northern portion of the
site is mapped as Pamlico muck (Terric Medisaprist). The eastern portion of the site is mapped
as Rimini sand (Grossarenic Entic Haplohumod).
On-site investigation indicates soils present within the 22-Acre Residual Site are consistent with
the descriptions of the mapped series.
Hydrology ranges from excessively drained soils along the eastern portion of the site (Rimini
series) to very poorly drained soils in the northern portion of the site (Pamlico series). No
ditching was observed on the site, but deep rutting of hydric soils occurs throughout the
southern portion of the site.
Vegetation in R11 and the southern portion of R11 has been clearcut and is in the process of
regenerating. The clearcut area formerly contained pond pine woodland on the Murville fine
sand. The Leon sand areas contained wet pine flatwoods and pine savanna communities.
Nonriverine swamp forest occurs on the Pamlico muck in the northern portion of the site.
Coastal fringe sandhill community is present on the Rimini sand. A small family cemetery
(Futch Family, 15-20 graves from the mid-1800's) is identified on NCDOT mapping in the
eastern corner of R11.
19
RLL Recommendation
No RLL were identified on the 22-Acre Residual Site during surveys of potential habitat in
October 2001. The recent clear-cutting has opened up the habitat within the Murville fine sand
and Leon sand areas, but severe rutting and land disturbance has occurred. This area may still
offer potential RLL habitat. NCDOT may consider this site for wetland mitigation purposes.
Given the recent disturbance, additional RLL surveys may be considered during a more optimal
survey period in the next growing season, particularly along the Murville/Leon transitional areas.
5.0 CONCLUSION
Construction of the proposed 1-40 Connector will result in a direct impact to a minimum of 354
RLL stems. A BI I teal Conclusion of "is Likely to Adversely Affect" is warranted based on
anticipated iuci?ewtW ttake of these individuals. iJeDOT Preretr ?}(a `}e?(ec0it? aG?.`e..c
4e m ?..? r..(,w? u' rr,?G.cb K- ?k•?- ALL
NCDO??T?its actively eval ting properties djacent to the 1-40 Connecter right'-of-way totaling
more>Kan 750 acres 03.5 ha) to act mitigative and cons" fion effortor this spas.
7k 0C)0T luc ?WJ{ t4
.fhe 621.8-acre (251.6-ha) Corbett Tract Mitigation Sits I?as
The Corbett Tract Mitigation Site%not been systematically censused for RLL, but an evaluation of
potential RLL habitat in October 2001 resulted in the identification of 17 RILL clusters located
outside the 1-40 right-of-way. Theese ctu?er c ntain in excess of 100 RLL stems. The Corbett
'JI Tract Mitigation Site is currently being ? 4a for wetland mitigation purposes.
wtU ?LL,rc.
Cif NCDOT 16 parcels totaling approximately 89.9 acres
(36.4 ha) that-sarrt'ain the known RLL cluste s nd adjacent potential habitat comprising the
Plantation Road Site. This site will be °&94 or RLL mitigative and conservation efforts as
well as wetland mitigation purposes. The northern portion of the Plantation Road Site adjacent
to the 1-40 Connector right-of way was systematically censused in October 2001 resulting in a
minimum of 623 RLL stems within ten (10) clusters located outside the 1-40 Connector right-of-
way. The Plantation Road Site is currently zoned as a residential district and may be subject to
future development activities.
(J) The approximately 8200-fool (2500 m) long Corbett Strip, a residual property located along the
southern boundary of the 1-40 Connector right-of-way, will be retained as a buffer between the
roadway and RLL clusters located on adjacent properties.
idin
(y) NCDOT is considering the wetland mitigation potential for two other residual sites, totaling
approximately 34 acres (13.8 ha) and 22 acres (8.9 ha) respectively, located adjacent to the I-
40 Connector. *These two sites contain potential RLL habitat. Nf DOT .? ?? . ev&14wS& vo?t
?e?t?,`?b Q +-?4 sr1(tr tar RLL Co%tlrVw
CS? ?[t)0r Wlit C&ki4o a 1411,uwx?? ?W i ItSF ?nS
?? cu n u k w111 .??.ur dG? me c rxA, .? p r `?- jc s? f?•/
?..s..rw..rar o^, it.t-? o.•?(ai ? a`?? `kc.A?-a /C?CadT ??-J0?
? s/l,. ,Srr_cfes .
February 5, 2002 - The Service (Dale Suiter) provided comments by phone to NCDOT (Gordon
Cashin) on a draft BA.
February 12, 2002 - The Service received a letter (dated February 12, 2002) and an attached BA
from NCDOT requesting formal consultation on the I-40 Connector project.
February 21, 2002 - The Service received an electronic version of the BA.
March 14, 2002 - The Service responded by letter to NCDOT's February 12, 2002 letter by
initiating formal consultation.
April 22, 2002 - The Service requested (by fax) further information related to the conservation
measures proposed in the BA.
April 30, 2002 - The Service received (by fax) an update to the BA as requested on April 22,
2002.
BIOLOGICAL OPINION
DESCRIPTION OF THE PROPOSED ACTION
A. Project Description and Location
The NCDOT proposes to construct a four-lane, divided, access-controlled facility on new
location connecting I-40 and US Highway 17 (US 17) from approximately 4.67 miles east of an
interchange at I-40 located south of Sidbury Road (SR 1336) to an interchange on US 17 near
Porter's Neck Road (SR 1402) (Figure 1). In addition, the NCDOT is proposing improvements
to approximately 2.75 miles of US 17 from approximately 0.13 miles south of SR 1402 in New
Hanover County, northward to approximately 0.13 miles northeast of Scott's Hill Loop Road
(SR 1571) in Pender County. A temporary detour adjacent to US 17 extends an additional 0.28
miles north of Scott's Hill Loop Road. This project, including the new location alignment and
US 17 improvements, is referred to as the I-40 Connector (T.I.P. R-2405A). This project, as
designed, will impact part of a population of rough-leaf loosestrife. For the purposes of this
opinion, the action area for rough-leaf loosestrife is the area within the construction limits of the
proposed NCDOT project described above.
B. Conservation Measures
When used in the context of the Act, "conservation measures" represent actions pledged in the
project description that the action agency or applicant will implement to further the recovery of
the species under review. Since conservation measures are part of the proposed action, their
implementation is required under the terms of the consultation. The NCDOT has proposed
several actions which will reduce impacts to this species and its habitat in the project vicinity:
1. The NCDOT will complete a feasability study for the several alternative wetland mitigation
strategies for the 621.8-acre (251.6-ha) Corbett Tract Mitigation Site as an on-site wetland
mitigation area.
2. The NCDOT will contract additional survey work for rough-leaf loosestrife to be conducted
during the optimal survey period and will consider the presence of rough-leaf loosestrife within
this area during the evaluation of this site as a wetland mitigation area.
3. The NCDOT may consider some form of site preparation to open up potential habitat areas
and will also identify the best management strategy for roueh-leaf loosestrife at this site.
4. The NCDOT will coordinate with the Service concerning viability of incorporating rough-leaf
loosestrife issues into any wetland mitigation possibilities, including:
a. habitat maintenance protocols;
b. vegetation monitoring for rough-leaf loosestrife; and,
c. dispensation of the property to a responsible party who will continue maintaining the area
for rough-leaf loosestrife as well as wetlands.
5. The NCDOT will acquire sixteen (16) parcels totaling approximately 89.9 acres (36.4 ha) that
are referred to in the BA as the Plantation Road Site and will evaluate this area for rough-leaf
loosestrife habitat as well as for wetland mitigation purposes and will coordinate with the Service
to determine a responsible party for dispensation.
6. The NCDOT will retain the Corbett Strip to act as a buffer between the I-40 Connector and
adjacent rough-leaf loosestrife clusters.
7. The NCDOT may consider the 34 acre residual site for wetland mitigation purposes and will
contract additional survey work for rough-leaf loosestrife to be conducted durine the optimal
survey period. If found, the NCDOT will consider the presence of rough-leaf loosestrife within
this area during the evaluation of this site as a wetland mitigation area.
8. The NCDOT may consider the 22 acre residual site for wetland mitigation purposes and will
contract additional survey work for rough-leaf loosestrife to be conducted during the optimal
survey period, particularly along the Murville/Leon transitional areas. If found, NCDOT will
consider the presence of rough-leaf loosestrife within this area during the evaluation of this site
as a wetland mitigation area.
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
U.S. Army Corps of Engineers
Wilmington Regulatory Field Office
P.O. Box 1890
Wilmington, North Carolina 28402-1890
Attention: Mr. Dave Timpy
NCDOT Coordinator
February 13, 2003
LYNDO TIPPETT
SECRETARY
Subject: New Hanover and Pender Counties, I-40 Connector from just east of the I-40 Interchange
to the US 17 Interchange north of Porter's Neck Road (SR 1402) and US 17 from
Porter's Neck Road to Scott's Hill Loop Road, TIP No. R-2405A; State Project No.
6.279001T.
Dear Mr. Timpy:
As you are aware, the North Carolina Department of Transportation (NCDOT) has requested
authorization from. the U. S. Army Corps of Engineers (USACE) under a Section 404 Individual Permit to
build a four-lane divided facility on new location extending approximately 4.9 miles from just east of the I-
40 Interchange to US 17 north of Porter's Neck Road (SR 1402) with interchanges at both termini. The
NCDOT initially applied for this permit on November 3, 2000. This application included an extensive
discussion of the project's history and planning process. A revised application was submitted November
28, 2001 to correct errors in the earlier application, depict a stormwater plan, and update the mitigation
plan.
The N.C. Division of Water Quality issued both a 401 Water Certification (WQC No. 3342) and a
stormwater permit (SW8 011006) based on the November 28, 2001 application. However, the local
community expressed objections to the permitted stormwater design. The NCDOT has modified its
stormwater proposal and applied for a revised stormwater permit. The purpose of this letter is to inform
you of changes in impacts to waters of the United States since the November 28, 2001 application, to
reiterate the mitigation plan for the subject project, and to update you regarding protected species.
Stormwater Design
The NCDOT has eliminated the stormwater facility shown on page 42A of the November
2001 application due to local objections. A new facility is now proposed adjacent to Scotts Hill
Loop Road (SR 1571) on the property of the Scotts Hill Baptist Church. This facility does not
impact wetlands, unlike the earlier proposal. On February 10, 2003, the NCDOT applied to
DWQ for a new stormwater permit for this facility.
Impacts to Waters of the United States
The project total impacts to wetlands were reduced slightly by relocating the stormwater facility.
This facility was shown as Wetland Site 18 on permit drawing 42A in the November 2001 application.
This site included 0.024 ha of temporary fill in wetlands, as enumerated in the Summary Sheet 83 of 83.
MAILING ADDRESS: TELEPHONE: 919-733-3141 LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: 919-733-9794 TRANSPORTATION BUILOING
PROJECT DEVELOPMENT ANO ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WESSITE: WWWDOH.DOTSTATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548
This site has been removed from the application. The new stormwater facility is not shown on a permit
drawing since it does not impact waters of the United States. However, it is shown on Sheet 37B of the
project plan sheets that are enclosed.
Aside from the elimination of the temporary impacts, all other impacts remain the same as in the
November 2001 application. The total for `Fill in Wetlands' remains 35.427 ha (87.542 ac). Likewise, the
total for `Mechanized Clearing' remains 3.640 ha (8.995 ac). The total for `Fill in Surface Waters' is 0.437
ha (1.08 ac) and includes all fill to surface waters, whether jurisdictional surface waters or not. Impacts to
jurisdictional waters, 0.010 ha (0.025 ac), remains valid, as Prince George Creek is the only jurisdictional
stream impacted by the proposed project. The additional 0.427 ha (1.06 ac) of impacts include 511 to
ephemeral channels and ditches along the project. Likewise, the summary sheet shows 1747.6 m of
`Existing Channel Impacted'. Only 52.8 to (173.2 ft) of this total reflects impacts to jurisdictional surface
waters. The additional 1694.8 m (5560.4 ft) includes impacts to non-jurisdictional channels and ditches.
The summary sheet also depicts 635.4 m (2084.6 ft) of relocated channel, reflecting changes to non-
jurisdictional channels and ditches. Also, the total for `Enclosed Channel' is shown as 1054.2 m (3458.7
ft). Only 52.8 to (173.2 ft) of this total reflects impacts to jurisdictional surface waters. The additional
1001.4 to (3285.4 ft) of enclosed channel includes impacts to non-jurisdictional channels and ditches.
There are only two changes to the permit drawings from the November 2001 application: Sheet
42A has been removed, and Site No 18 removed from Summary Sheet 83.
Compensatory Mitigation
As a result of this project 39.6 ha (98.2 ac) of wetlands will be impacted. A total of 37.9 ha (93.5
ac) of these impacts fall into the community type of pond pine woodland, pond pine scrubland, and wet
pine flatwood. The remaining 1.7 ha (4.3 ac) of wetlands are in a bottomland hardwood community
including the small stream swamp forest and non-riverine swamp forest. The following describes the
proposed mitigation for the wetland impacts (See Table 1), and is essentially the same proposal presented
in the November 2001 application.
Dale Tract
The Dale Tract, located in Brunswick County, was restored by NCDOT, through its contractor
ECOBANK, to be used as mitigation for wet pine flat ecosystems. Approximately 96.3 ha (238 ac) have
been restored or enhanced as described in the wetland mitigation plan which has been revised and was
included in the November 3, 2000 permit application package. This site had been extensively ditched,
although typical pine flat vegetation remained on the site. Construction of the Dale Tract was completed at
the end of December 1999. The Dale Tract is located approximately 22.5 km (14.0 mi) from the R-2405A
project area. NCDOT proposes to use 37.9 ha (93.9 ac) of restoration from the Dale Tract as compensatory
mitigation for the wetland impacted in the pond pine woodland, pond pine scrubland, and the wet pine
flatwood communities.
Haws Run
The Haws Run Mitigation Site was purchased in 1995 by NCDOT to provide compensatory
mitigation for unavoidable impacts to wetlands resulting from highway construction in the region. The site
is located approximately 35.4 km (22 mi) from the R-2405A project area. This 242.8 ha (600 ac) site
consists of riverine swamp forest, wet flatwood and savanna. Construction of the site was completed
February 1999 and the site was planted in early spring 1999. A mitigation plan has been approved for the
site. NCDOT proposes to use 1.7 ha (43 ac) of restoration from the Haws Run Mitigation Site as
compensatory mitigation for the wetlands impacted in the bottomland hardwood community including the
small stream swamp and the non-riverine swamp forest.
Corbett Tract
The Corbett Tract. a 2473 ha (611 ac) site was purchased in November 2001. The site includes
approximately 47.8 ha (118 ac) of uplands. an estimated 10.5 ha (26 ac) of bottomland hardwood forest,
and 189 ha (467 ac) of wet pine flatwood. NCDOT studied the feasibility of restoration on the Corbett
Tract, however the results were inconclusive and do not resolve the issues of hydrologic trespass. A study
with a drainage model other than DramMod will need to be conducted for conclusive results. In addition,
rough-leaved loosestrife (Lysimochio asperulaefolio) was identified on the Corbett Tract. The feasibility
study did not address the possible effects of wetland and stream restoration activities on.the loosestrife.
For this reason, NCDOT is reluctant to change the hydrology or bring in heavy equipment in order to do
restoration on the Corbett Tract. NCDOT proposes to use the 189 ha (467 ac) of wet pine flatwood
preservation as compensatory mitigation for the wetlands impacted in the pond pine woodland, pond pine
scrubland, and wet pine flatwood communities. NCDOT also proposes to use the estimated 10.5 ha (26 ac)
of bottomland hardwood forest to mitigate for the wetlands impacted in the bottomland hardwood
community including the small stream swamp and the non-riverine swamp forest. The mitigation
feasibility study is available for review if desired.
Table 1. Mitigation Proposal
Wet Pine Flats 93.9 ac Dale Tract - 93.9 ac (37.9 ha) restoration
(37.9 ha) Corbett Tract - 467 ac (189 he) preservation
Bottomland Hardwood 4.3 ac Haws Run 4.3 ac (1.7 he) restoration
(1.7 ha) Corbett Tract - 26 ac (10.5 ha) preservation
Wet Flats include pond pine woodlands and pond pine scrublands
Bottomland Hardwood includes small stream swamp and non-riverine swamp forest communities
The subject project will impact 52.8 in (173.2 ft) of Prince George Creek, the only jurisdictional
stream in the project area. Impacts to the channel are due to the placement of the culvert and of rip-rap
downstream. Mitigation requirements for these impacts will be met using the Wetlands Restoration
Program (WPR). WRP has agreed to provide stream mitigation for this project by letter dated June 19,
2000. This letter is attached.
Protected Species
Plants and animals with federal classifications of Endangered, Threatened, Proposed Endangered,
and Proposed Threatened are protected under provisions of Section 7 and Section 9 of the Endangered
Species Act. As of February 26, 2001, a total of twelve federally-protected species are listed for New
Hanover and Pender Counties. A biological conclusion of "No Effect" remains valid for all listed species
except rough-leaf loosestrife and red-cockaded woodpecker.
On May 22, 2002 the U.S. Fish and Wildlife Service (USFWS) issued a biological opinion on the
effects of the project on the rough-leaf loosestrife. Their review concluded, on page 10, "that project
construction and conservation measures, as proposed and implemented, are not likely to jeopardize the
continued existence of the species." The NCDOT has continued work on the conservation measures
outlined on pages 3 & 4 of the biological opinion. A copy of this biological opinion document is enclosed
with this application.
An updated survey for red-cockaded woodpecker is currently being conducted. Previous surveys
have resulted in a "No Effect" conclusion for the project. However, the USFWS has requested an updated
survey due to the passage of time since the last survey. The updated survey will be provided to the
USFWS by mid-March.
Summary
In summary, NCDOT has explained minor changes to the impacts to waters of the United States
and provided revised permit drawings and summary sheet illustrating these changes. We have also
enclosed copies of the cover letters for the November 3, 2000 and November 28, 2001 applications, and
half-size project plan sheets. NCDOT is still proposing to use the Dale Tract. Haws Run Mitigation Site,
and the Corbett Tract as wetland mitigation. WRP has agreed to provide stream mitigation for this project.
I 1. The permittee will maintain the authorized work in good condition and in conformance
with the terms and conditions of this permit. The permittee is not relieved of this requirement if
he abandons the permitted activity without having it transferred to a third party.
12. No attempt will be made by the permittee to prevent the full and free use by the public of all
navigable waters at or adjacent to the authorized work. Use of the permitted activity must not
interfere with the public's right to free navigation on all navigable waters of the United States.
13. The permittee understands and agrees that, if future operations by the United States
require the removal, relocation, or other alteration of the structures or work herein authorized, or
if, in the opinion of the Secretary of the Army or his authorized representative, said structure or
work shall cause unreasonable obstruction to the free navigation of the navigable water, the
permittee will be required, upon due notice from the Corps of Engineers, to remove, relocate, or
alter the structural work or obstructions caused thereby, without expense to the United States.
No claim shall be made against the United States on account of any such removal or alteration.
14. -Compensatory mitigation for the 98.2 acres of wetland impacts associated with this project
shall be performed as described in the letter from the North Carolina Department of
Transportation dated February 13, 2003 and as detailed in the following conditions:
a. The Dale Tract Mitigation Site, the Corbett Tract Mitigation Site, and the Haws Run Tract
Mitigation Site in the following forms and amounts to provide any necessary compensatory
mitigation for the unavoidable wetland impacts associated with this project: The location of the Dale
Tract Mitigation Site, Corbett Tract, and Haws Runs Mitigation Site is shown on attachment A.
Community Impacts Site Amount
Wet Pine Flats 93.9 ac Dale Tract 93.9 acres restoration
Wet Pine Flats --- Corbett Tract 467.0 acres preservation
Bottomland Hardwood 4.3 ac Haws Run 4.3 acres restoration
Bottomland Hardwood --- Corbett Tract 26.0 acres preservation
b. The Dale Tract Mitigation Site and Haws Runs Mitigation Sites shall be maintained by the
permittee in its natural condition, as altered by the mitigation plan, in perpetuity. Prohibited activities
within the mitigation area specifically include, but are not limited to, the construction or placement of
buildings, signs, or any other structures; the discharge of dredged or fill material, any debris, waste,
or garbage; excavation; grading; dredging; leveling or any other earth moving activity; cutting,
removal or damage of any vegetation; any activity which would impact the drainage or water quality
on the site; except as required by implementation of the mitigation plan. This condition runs with the
land. The permittee shall not sell, lease, or otherwise convey any interest in the property making up
the mitigation property without first providing 60 days written notice to the Corps of the proposed
conveyance. The instrument effecting such conveyance shall include legally binding restrictions on
the use of the mitigation property as described in this condition to be enforceable by the permittee as
I,
ER00041.1Re zpo jt.dgn
41
f
L__9 L,,..3 L_?m L..9 L..:,..7
L:, rlm L_j l?A
?,• _. 'i Yr_ `fi'
f ? t1 ` ? i
x
A 4 Y
`
k
.
i
t ? I 1 ,
.-?
w e 11. Y I
i
I
I
a
x l I r 'r
1
°
x
g
"
.., . aQ
l
CD -0
I
t
: ? n x
LCD
I C
1 p\ ???
.y A Y
iL {9 r
J ? L
J L, r
' J
F
L j L"
5 c?
,
O Y
?
.? l JIt1
0 pr
41
(n N 5 '
r m ? '4
t e ,
y
? 5
1
r ,
J
1
l )
v
a
1 I It-
( `
a r I
"? , •
S `? ?
?Slf(NP 1
• .
i I.
N
is N
cn
_.
N
r
CIL