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Home My WebLink About20011102 Ver 1_Other Agency Comments_20111110� �Zj�al� ��l�a NCDENiR North Carolina Department of Environment and Natural Resources Office of Conservation, Planning, and Community Affairs Beverly Eaves Perdue Governor Linda Pearsall, D�reCtol' November 10 2011 To Melba McGee Environmental Coordinator 0 From Laura Gadd Botanist NC Natural Hentage Program Re Environmental Review of the proposed US 70 Havelock Bypass Craven County NC Pro�ect 12 0082 Dee Freeman Secretary The NC Natural Heritage Program (NHP) has reviewed the Draft Environmental Impact Statement (DEIS) for the US 70 Havelock Bypass in Craven County According to the DEIS there are currently three alternatives for the Bypass under consideration with Alternative 3 being the preferred route by NC DOT Each of the three alternatives poses significant direct or indirect threats to rare speaes and natural communities within the Croatan US National Forest NHP s first preference is to improve the existing US 70 corridor over the three alternatives for the US 70 Bypass in order to avoid impacts to rare species and Significant Natural Heritage Areas Failing that option we strongly oppose Alternative 3 preferred by NC DOT and would like the least damaging alternative be selected Alternative 3 passes through the most significant natural area within the pro�ect study area the Southwest Prong Flatwoods Significant Natural Hentage Area (SNHA) This site has one of the best examples of Mesic Pine Flatwoods (Coastal Plain Subtype) in the state The Longleaf Pine communities at this site occur on various soil types including ones that today only rarely support longleaf mainly because they have elsewhere been converted to agriculture or silviculture Southwest Prong Flatwoods SNHA also has state significant populations of Spring flowering Goldenrod (Sol�dago verna) a federal speues of concern and NC endangered Mudbank Crown Grass (Paspalum d�ssectum) Other rare species that would be impacted by Alternative 3 include Red cockaded Woodpecker (Pico�des 6oreal�s) US Endangered NC Endangered � Bachman s Sparrow (Peucaea aest�valis) US Federal Species of Concern NC Speaal Concern Lrttle Metalmark (Calephelis v�rgmiensis) NC Significantly Rare Leconte s Thistle (C�rsium leconte�) NC Special Concern Vulnerable Short bristled Beaksedge (Rhynchosporo breviseta) NC Significantly Rare Showy Orchid (Platanthera niveo) NC Threatened Alternative 3 would not only destroy significant natural communities and many rare species populations and their habitat but would also cause fragmentation on the landscape The Bypass would bisect the National Forest lands making management and prescribed fire very difficult given the strict DOT smoke regulations Alternative 2 the easternmost route would cause heavy direct impacts the Havelock Station Flatwoods and Powerline Corridor SNHA and part of the Southwest Prong Flatwoods SNHA The Havelock Station Flatwoods is significant for the large number of rare plant species that occur there Although this route would cause significant direct impacts to many rare plant and animal species and a colonial wading bird colony it causes the least amount of fragmentation of the natural communities and species habitat as a whole Records of rare species that occur within the pro�ect boundaries for this alternative include Dusky Roadside Skipper (Amblysartes alternata) — NC Significantly Rare Little Metalmark (Calephelis virginiensis) — NC Significantly Rare Bog Bluestem (Andropogon mohri�) — NC Threatened 1601 Mad Service Center Raleigh North Carolma 27699 1601 Phone 919 715 4195 I FAX 919 715 30601nternet www oneNCNaturally org An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper NorthCarolina , �aturallr� Leconte s Thistle (Grsium lecontei) NC Special Concern Vulnerable Yellow Fnngeless Orchid (Plotanthera mtegra) NC Special Concern Vulnerable Hooker s Milkwort (Polygala hookeri) NC Special Concern Vulnerable Spring flowering Goldenrod (Solidago verna) — US Federal Species of Concern NC Significantly Rare Eaton s Witch Grass (Dichanthelium spretum) — NC Significantly Rare Short bristled Beaksedge (Rhynchospora brev�seto) — NC Significantly Rare Alternative 1 the westernmost route imposes the least amount of direct impacts to rare species and natural communities There would still be significant impacts to rare species to the south where the Bypass is proposed to diverge from the existing US 70 and impact the Havelock Station Flatwoods and Powerline Corridor To the north this route extends through private land between the Croatan National Forest avoiding rare species However if Alternative 1 is chosen there may be senous indirect impacts by fragmentation of the Longleaf Pine communities and speaes habitat to the east This option could create significant challenges for managing and burning National Forest land to the east NHP is concerned that if management becomes extremely difficult rare species and natural communities east of the Bypass could be lost over time due to secondary impacts NHP most strongly opposes Alternative 3 the NC DOT preferred central route as the most environmentally damaging alternative and we are already on the record for doing so in at letter dated April 6 1998 Among the three alternatives NHP s first preference is Alternative 1 the westernmost route because it avoids and minimizes impacts to rare species and SNHAs However we are concerned of the long term impacts of fragmentation and difficulty in managing the isolated land to the east If this route is chosen it is imperative that the savannas and flatwoods to the east be burned on a several year rotation NHP would approve this alternative only if there is a written agreement stating that the fragmented stands would be burned regularly even if that means US 70 would be closed for several days in the winter or early spring to conduct prescribed burns Additionally NHP concurs with the NC Wildlife Resources Commission s recommendations to construct a wildlife underpass that would maintain the link between the Southwest Prong Flatwoods SNHA and the other Croatan National Forest land as an essential component of mitigation intended to maintain the ecological integrity of the SNHA However NHP is not �ust concerned about the passage for black bears but we are also concerned about several rare species that are particularly associated with longleaf flatwoods and savanna habitats Species falling in this category include the Southern Hognose Snake Pygmy Rattlesnake Gopher frog Mimic glass lizard and Oak Toad all of which NHP has records for in the immediate area of the pro�ect We would also like the chance to be involved in the selection of crossings that meet the needs of these species as well as those of bear deer and other wildlife If no wildlife crossing is included in the mitigation for this pro�ect and there is no written agreement to ensure that appropriate management will occur in perpetuity in the natural areas surrounding the Bypass then NHP s second preference is Alternative 2 the easternmost route which would keep the blocks of US National Forest land more intact This route would also cause the least amount of difficulty for management of habitat to the west However there would be a significant loss of rare species located at the northern end of the Southwest Prong Flatwoods SNHA and within the Havelock Station Flatwoods and Powerline Corridor SNHA Please do not hesitate to contact me at 919 707 8647 if you have questions or need further information 1601 Mad Serv►ce Center Raleigh No►th Carolina 27699 1601 Phone 919 715 4195 I FAX 919 715 3060 Internet www oneNCNaturally org An Equal Opportunity 1 Affirmative Action Empioyer — 50% Recycled 110% Post Consumer Paper NorthCarolina �!G�tll�'R'��lJ