Loading...
HomeMy WebLinkAbout20120186 Ver 1_401 Application_201202124PUnited States Forest National Forests in 160A Zilhcoa Street Department of Service North Carolina P O Box 2750 Agriculture Asheville NC 28802 2® 12 0 18 6 File Code 2530 3 Date February 16, 2012 Cyndi Karoly North Carolina Division of Water Quality 401 /Wetlands Unit 1650 Mail Service Center Raleigh, NC 27699 1650 Dear Ms Karoly 12c�ca��� L E E 2 1 2012 ,--. I QENR WATER QJALITY This letter is to request Section 401 Water Quality Certification from the North Carolina Division of Water Quality for U S Forest Service project Kimsey Creek Bank Stabilization/Habitat Improvement Project 2012 Located on the Nanatahala National Forest in Macon County, North Carolina, this project is situated on Kimsey Creek in the Little Tennessee River Basin This reach of Kimsey Creek is a C4 stream type near the Forest Service Kimsey Creek Campground flowing within a wide valley bottom At the site proposed for permit the channel is scouring an approximately 45 length of the toe of the valley side slope resulting in a tall unstable bank The potential for further erosion and sedimentation into Kimsey Creek is high Since Kimsey Creek is considered an Outstanding Resource Water (ORW) by NC the need for stabilization of the site is important The purpose of this project is to eliminate the bank erosion and accelerated sedimentation to Kimsey Creek The proposed work would improve the health of the stream ecosystem by improving channel stability and aquatic habitat diversity along with improving riparian and streamside vegetation conditions The proposed action is needed at this time, at these locations because taking no action would lead to further erosion and sedimentation which in turn would cause further adverse impacts to aquatic habitat With the success experienced at other similar stream sites (e g N Fork Mills R and N Indian Creek Tennessee), the proposed work is expected to both stabilize the stream bank and further enhance aquatic and riparian habitat This project proposes to 1 Using a medium sized trackhoe construct a pool and a 45 long Toe Wood ( Bankfull Bench) structure (see Typical) using trees and slash from the surrounding area Transplant shrubs from the area to a bankfull elevation 2 Lay back the —10 feet tall upper bank, but only to a 1 1 slope to minimize excavation and retain trees at the top 3 Cover the Toe Wood structure & upper bank with a native seed mix weed free straw and Coir matting Live stake the Toe Wood structure and plant trees and shrubs on the bank (see Specs for Seed, Trees & Shrubs) Caring for the Land and Serving People P nted o Recycled P pe �1°� A copy of the 404 permit application has also been sent to the N C Wildlife Resources Commission and U S Fish and Wildlife Service for review Additionally, a Trout Buffer Waiver Request and an Erosion and Sediment Control Plan have not been submitted to NC Division of Land Quality since the length of stream disturbance is less than 100 feet and disturbed area is less than one acre respectively Enclosed are the following materials • Five copies of the Pre Construction Notice (form 12 11 2008 version 1 3) application for 404 permit (Nationwide Permit #13) with the Letter of Delegation of Authority • Five copies of the vicinity map and site plans for the project • Five copies of the signed NEPA documentation (Decision Notice) for the project • A check made payable to the Division of Water Quality for $240 00 since the length of stream channel impacts is less than 150 feet If you require any additional information please contact me at 828 257 4214 Sincerely Brady N od National Forests in North Carolina Forest Hydrologist W A T 9 1 1 ? _+ -c 20 120 18 6 `O�0F Office Use Only Corps action ID no DWQ project no Form Version 13 Dec 10 2008 Page 1 of 11 PCN Form — Version 1 3 December 10 2008 Version Pre - Construction Notification (PCN) Form A 2 Applicant Information 1 Processing 1 a Type(s) of approval sought from the ® Section 404 Permit ❑ Section 10 Permit Corps 1 b Specify Nationwide Permit (NWP) number 13 or General Permit (GP) number n/a 1c Has the NWP or GP number been verified by the Corps? ❑Yes ® No 1 d Type(s) of approval sought from the DWQ (check all that apply) ® 401 Water Quality Certification — Regular ❑ Non 404 Jurisdictional General Permit ❑ 401 Water Quality Certification — Express ❑ Riparian Buffer Authorization 1 e Is this notification solely for the record For the record only for DWQ 401 For the record only for Corps Permit because written approval is not required? Certification ❑ Yes ® No ❑ Yes ® No if Is payment into a mitigation bank or in lieu fee program proposed for mitigation ❑ Yes ® No of impacts? If so attach the acceptance letter from mitigation bank or in lieu fee program 1g Is the project located in any of NC s twenty coastal counties If yes answer 1h ❑ Yes ® No below 1h Is the project located within a NC DCM Area of Environmental Concern (AEC)? ❑ Yes ® No 2 Project Information 2a Name of project Kimsey Creek Bank Stabilization /Habitat Improvement Project 2012 2b County Macon 2c Nearest municipality / town Franklin NC 2d Subdivision name USDA Forest Service Nantahala Ranger District 2e NCDOT only T I P or state project no a= rnk LEM \7 LE3'Inj 3 Owner Information 3a Name(s) on Recorded Deed USDA Forest Service 3b Deed Book and Page No 3c Responsible Party (for LLC d 11kNR WATER Marisue Hilliard �ANDJAN STOR��WAATERBWCH applicable) 3d Street address 160 Zillicoa Street Suite A 3e City state zip Asheville NC 28801 3f Telephone no 828 257 4269 3g Fax no 828 259 0584 3h Email address mhdliard @fs fed us Page 1 of 11 PCN Form — Version 1 3 December 10 2008 Version 4 Applicant Information (if different from owner) 4a Applicant is ® Agent ❑ Other specify 4b Name Brady N Dodd 4c Business name (if applicable) USDA Forest Service Hydrologist 4d Street address 160 Zdlicoa Street Suite A 4e City state zip �. Asheville NC 28801 4f Telephone go- , 828 257 -4214 4g Fax no 4h Email address bdodd @fs fed us 5 Agent/Consultant Information (if applicable) 5a Name 5b Business name (if applicable) 5c Street address 5d City state zip 5e Telephone no 5f Fax no 5g Email address Page 2 of 11 B Project Information and Prior Project History 1 Property Identification 1a Property identification no (tax PIN or parcel ID) USDA Forest Service National Forest in NC Nantahala RD 1 b Site coordinates (in decimal degrees) if you can t get Latitude 35 072046 Longitude 83 530467 these dust include a very good vicinity map 1c Property size 251 817 acres 2 Surface Waters 2a Name of nearest body of water (stream river etc ) to proposed project Kimsey Creek 2b Water Quality Classification of nearest receiving water C Trout ORW 2c River basin map is available at http //h2o enr state nc us /admen /maps/ Little Tennessee River Basin 3 Project Description 3a Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application This reach of Kimsey Creek is a C4 stream type near the Forest Service Kimsey Creek Campground flowing within a wide valley bottom At the site proposed for permit the channel is scouring an approximately 45 length of the toe of the valley side slope resulting in a tall unstable bank The potential for further erosion and sedimentation into Kimsey Creek is high Since Kimsey Creek is considered an Outstanding Resource Water (ORW) by NC the need for stabilization of the site is important 3b List the total estimated acreage of all existing wetlands on the property 0 Acres of wetlands 3c List the total estimated linear feet of all existing streams (intermittent and perennial) on the property —26 000 feet in the Kimsey Creek drainage 3d Explain the purpose of the proposed project With the success experienced at other stream sites e g North Fork Mills River and North Indian Creek (TN) the proposed work is expected to both stabilize the stream bank and further enhance aquatic and riparian habitat 3e Describe the overall project in detail including the type of equipment to be used Prior to construction install a water pump in a constructed depression where the tributary comes into the main channel & pump flow around construction site during work Thus work would occur out of the flow thus reducing turbidity and sedimentation 1 Using a medium sized trackhoe construct a pool and a 45 long Toe Wood ( Bankfull Bench) structure (see Typical) using trees and slash from the surrounding area Transplant shrubs from the area to a bankfull elevation 2 Lay back the —10 feet tall upper bank but only to a 1 1 slope to minimize excavation and retain trees at the top 3 Cover the Toe Wood structure & upper bank with a native seed mix weed free straw and Coir matting Live stake the Toe Wood structure and plant trees and shrubs on the bank (see Specs for Seed Trees & Shrubs) Page 3 of 11 PCN Form —Version 1 3 December 10 2008 Version 4 Jurisdictional Determinations 4a Have jurisdictional wetland or stream determinations by the Corps or State been requested or obtained for this property / project (including all prior phases) in the past? Comments ❑ Yes ® No ❑ Unknown 4b If the Corps made the jurisdictional determination what type of determination was made? ❑ Preliminary ❑ Final 4c If yes who delineated the jurisdictional areas? Name (if known) Agency /Consultant Company Other 4d If yes list the dates of the Corps jurisdictional determinations or State determinations and attach documentation 5 Project History 5a Have permits or certifications been requested or obtained for this project (including all prior phases) in the past? ❑ Yes ® No ❑ Unknown 5b If yes explain in detail according to help file instructions 6 Future Project Plans 6a Is this a phased project? ❑ Yes ® No 6b If yes explain Page 4 of 11 i C Proposed Impacts Inventory 1 Impacts Summary 1a Which sections were completed below for your project (check all that apply) ❑ Wetlands ® Streams tributaries ❑ Buffers ❑ Open Waters ❑ Pond Construction 2 Wetland Impacts If there are wetland impacts proposed on the site then complete this question for each wetland area impacted 2a 2b 2c 2d 2e 2f Wetland impact Type of jurisdiction number — Type of impact Type of wetland Forested (Corps 404 10 Area of impact Permanent (P) or (if known) DWQ — non -404 other) (acres) Temporary T W1 ❑ P ❑ T ❑ Yes ❑ Corps ❑ No ❑ DWQ W2 ❑ P ❑ T ❑ Yes ❑ Corps ❑ No ❑ DWQ W3 ❑ P ❑ T ❑ Yes ❑ Corps ❑ No ❑ DWQ W4 ❑ P ❑ T ❑ Yes El Corps El No ❑ DWQ W5 ❑ P ❑ T ❑ Yes ❑ Corps ❑ No ❑ DWQ W6 ❑ P ❑ T ❑ Yes ❑ Corps ❑ No ❑ DWQ 2g Total wetland impacts 2h Comments 3 Stream Impacts If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site then complete this question for all stream sites impacted 3a 3b 3c 3d 3e 3f 3g Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact number Permanent (P) or (PER) or intermittent (Corps 404 10 DWQ — non -404 stream width length (linear Temporary (T) (INT)? other) (feet) feet) Excavate stream S1 ®P ❑ T bed and bank to install Toe Wood Kimsey Creek ® PER ❑ INT ® Corps ® DWQ 18 50 structure S2 ®P ❑ T Excavation of Kimsey Creek ® PER ® Corps 18 10 pump site ❑ INT ® DWQ S3 ❑ P ❑ T ❑ PER ❑ Corps ❑ INT ❑ DWQ S4 ❑ P ❑ T ❑ PER ❑ Corps ❑ INT ❑ DWQ S5 ❑ P ❑ T ❑ PER ❑ Corps ❑ INT ❑ DWQ S6 ❑ P ❑ T ❑ PER ❑ Corps ❑ INT ❑ DWQ 3h Total stream and tributary impacts 60 31 Comments All impacts are considered necessary for the long term stabilization of the site to reduce sedimentation and turbidity Page 5 of 11 4 Open Water Impacts If there are proposed impacts to lakes ponds estuaries tributaries sounds the Atlantic Ocean or any other open water of the U S then individually list all open water impacts below 4a 4b 4c 4d 4e Open water Name of waterbody impact number — (if applicable) Type of impact Waterbody type Area of impact (acres) Permanent (P) or Temporary T 01 ❑P ❑T 02 ❑P ❑T 03 ❑P ❑T 04 ❑P ❑T _ 4f Total open water impacts 4g Comments 5 Pond or Lake Construction If pond or lake construction proposed then complete the chart below 5a 5b 5c 5d 5e Wetland Impacts (acres) Stream Impacts (feet) Upland Pond ID Proposed use or purpose (acres) number of pond Flooded I Filled f Excavated Flooded I Filled I Excavated Flooded P1 P2 5f Total 5g Comments 5h Is a dam high hazard permit required? ❑ Yes ❑ No If yes permit ID no 51 Expected pond surface area (acres) 5j Size of pond watershed (acres) 5k Method of construction 6 Buffer Impacts (for DWQ) If project will impact a protected riparian buffer then complete the chart below If yes then individually list all buffer impacts below If any impacts require mitigation then you MUST fill out Section D of this form 6a ❑ Neuse ❑ Tar Pamlico ❑ Other Project is in which protected basin? ❑ Catawba ❑ Randleman 6b 6c 6d 6e 6f 6g Buffer impact number — Reason Buffer Zone 1 impact Zone 2 impact Permanent (P) or for Stream name mitigation (square feet) (square feet) Temporary T impact -required? El Yes 131 ❑P ❑T ❑ No El Yes 62 ❑P ❑T ❑ No El Yes 63 ❑P ❑T ❑ No 6h Total buffer impacts 61 Comments Page 6 of 11 i D Impact Justification and Mitigation 1 Avoidance and Minimization la Specifically describe measures taken to avoid or minimize the proposed impacts in designing project Construction of in stream structures would temporarily increase turbidity and sediment deposition downstream of the excavation Potential adverse impacts would be avoided by pumping flow around construction site during work minimizing excessive excavation and adhering to the State turbidity standard b Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques A Minimize the area and degree of sod disturbance that reduces infiltration capacity and permeability and destroys protective forest floor and ground cover B All hazardous materials will be stored outside of flood prone areas and surrounded with sediment fence to reduce the risk of materials reaching the river C Work activities would not be scheduled on rainy days D Heavy Equipment Operation 1 All equipment shall be cleaned before entering the project area and stream so as to reduce the risk of fine grained sediment and oils and grease from entering the stream This would also reduce the risk of invasive weed spread onto the Forest 2 Do not operate on wet sods when they are most susceptible to damage and erosion 3 Operate heavy equipment on slopes less than 12 percent so as to reduce the risk of sod erosion Avoid operating heavy equipment on over hanging stream banks 4 Move large woody debris and boulders in a manner that minimizes disturbance of the forest floor exposure of mineral sod or degradation of stream bank stability E Install sediment fence or coir logs to trap potential sediment Stabilize any disturbed area at the end of each workday F Re vegetate exposed sods as soon as possible to take advantage of the loose soil conditions for seeding 1 Exposed soil will be covered with straw mulch or erosion control matting at the end of the project Matting will be secured in place with stakes and live stakes where conditions allow 2 Temporary seeding will occur on all bare sod within five days of ground disturbing activities or sooner if rain is forecasted to provide short and long term erosion control 3 Stabilize channel banks with a native seed mix as work is completed G Do not move sediment trap devices until the vegetation in the disturbed areas has been established H During on -going operations inspect the site frequently inspect occasionally during inactive penods 1 Check for potentially damaging or fading situations that may cause unacceptable water quality impacts 2 Correct failing situations as soon as practical I Conduct visual inspections of Kimsey Creek while the work is being conducted to maintain acceptable turbidity levels Use a skilled heavy equipment operator Instruct the operator to minimize disturbance to the streambed 2 Compensatory Mitigation for Impacts to Waters of the U S or Waters of the State 2a Does the project require Compensatory Mitigation for ❑ Yes ® No impacts to Waters of the U S or Waters of the State? 2b If yes mitigation is required by (check all that apply) ❑ DWQ ❑ Corps ❑ Mitigation bank 2c If yes which mitigation option will be used for this project? ❑ Payment to in lieu fee program ❑ Permittee Responsible Mitigation 3 Complete if Using a Mitigation Bank 3a Name of Mitigation Bank 3b Credits Purchased (attach receipt and letter) Type Quantity Page 7 of 11 PCN Form — Version 1 3 December 10 2008 Version 3c Comments 4 Complete if Making a Payment to In lieu Fee Program 4a Approval letter from in lieu fee program is attached ❑ Yes 4b Stream mitigation requested linear feet 4c If using stream mitigation stream temperature ❑ warm ❑ cool ❑cold 4d Buffer mitigation requested (DWQ only) square feet 4e Riparian wetland mitigation requested acres 4f Non riparian wetland mitigation requested acres 4g Coastal (tidal) wetland mitigation requested acres 4h Comments 5 Complete if Using a Permittee Responsible Mitigation Plan 5a if using a permittee responsible mitigation plan provide a description of the proposed mitigation plan 6 Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWQ 6a Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? If yes you will have to fill out this entire form — Please contact the State for more information El Yes ® No 6b If yes then identify the square feet of impact to each zone of the riparian buffer that requires mitigation Calculate the amount of mitigation required Zone 6c Reason for impact 6d Total impact (square feet) Multiplier 6e Required mitigation (square feet) Zone 1 3 (2 for Catawba) Zone 2 15 6f Total buffer mitigation required 6g If buffer mitigation is required discuss what type of mitigation is proposed (e g payment to private mitigation bank permittee responsible riparian buffer restoration payment into an approved in lieu fee fund) 6h Comments Page 8 of 11 E Stormwater Management and Diffuse Flow Plan (required by DWQ) 1 Diffuse Flow Plan la Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules? Yes E] Yes 1 b If yes then is a diffuse flow plan included? If no explain why Comments E] Yes ❑ No 2 Stormwater Management Plan 2a What is the overall percent imperviousness of this project? 0% 2b Does this project require a Stormwater Management Plan? ❑ Yes ® No 2c If this project DOES NOT require a Stormwater Management Plan explain why The current site contains less than 24% impervious area and an increase in impervious area is not planned from the proposed work Additionally all stormwater is transported primarily via vegetated conveyances 2d If this project DOES require a Stormwater Management Plan then provide a brief narrative description of the plan ❑ Certified Local Government 2e Who will be responsible for the review of the Stormwater Management Plan? ❑ DWQ Stormwater Program ❑ DWQ 401 Unit 3 Certified Local Government Stormwater Review 3a In which local government s jurisdiction is this project? ❑ Phase II 3b Which of the following locally implemented stormwater management programs ❑ NSW apply (check all that apply) ❑ USMP ❑ Water Supply Watershed ❑ Other 3c Has the approved Stormwater Management Plan with proof of approval been ❑ Yes ❑ No attached? 4 DWQ Stormwater Program Review ❑ Coastal counties 4a Which of the following state implemented stormwater management programs apply [--] El El ORW (check all that apply) ❑ Session Law 2006 246 ❑ Other 4b Has the approved Stormwater Management Plan with proof of approval been attached? ❑ Yes ❑ No 5 DWQ 401 Unit Stormwater Review 5a Does the Stormwater Management Plan meet the appropriate requirements? ❑ Yes ❑ No 5b Have all of the 401 Unit submittal requirements been met? ❑ Yes ❑ No Page 9 of 11 PCN Form — Version 1 3 December 10 2008 Version F Supplementary Information 1 Environmental Documentation (DWQ Requirement) la Does the project involve an expenditure of public (federal /state /local) funds or the ® Yes ❑ No use of public (federal /state) land? 1 b If you answered yes to the above does the project require preparation of an environmental document pursuant to the requirements of the National or State ® Yes ❑ No (North Carolina) Environmental Policy Act (NEPA/SEPA)? 1c If you answered yes to the above has the document review been finalized by the State Clearing House? (If so attach a copy of the NEPA or SEPA final approval ❑Yes No letter ) f Comments NEPA Decision Notice document is attached 2 Violations (DWQ Requirement) 2a is the site in violation of DWQ Wetland Rules (15A NCAC 2H 0500) Isolated Wetland Rules (15A NCAC 2H 1300) DWQ Surface Water or Wetland Standards ❑ Yes ® No or Riparian Buffer Rules (15A NCAC 2B 0200)? 2b Is this an after the fact permit application? ❑ Yes ® No 2c If you answered yes to one or both of the above questions provide an explanation of the violation(s) 3 Cumulative Impacts (DWQ Requirement) 3a Will this project (based on past and reasonably anticipated future impacts) result in ❑ Yes ® No additional development which could impact nearby downstream water quality? 3b If you answered yes to the above submit a qualitative or quantitative cumulative impact analysis in accordance with the most�recent DWQ policy If you answered no provide a short narrative description 4 Sewage Disposal (DWQ Requirement) 4a Clearly detail the ultimate treatment methods and disposition (non discharge or discharge) of wastewater generated from the proposed project or available capacity of the subject facility No sewage disposal is necessary Page 10 of 11 PCN Form — Version 1 3 December 10 2008 Version 5 Endangered Species and Designated Critical Habitat (Corps Requirement) 5a WIII this protect occur in or near an area with federally protected species or ❑ Yes ® No habitat 5b Have you checked with the USFWS concerning Endangered Species Act ® Yes El No impacts 5c If yes indicate the USFWS Field Office you have contacted ❑ Raleigh ® Asheville 5d What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? I consulted the Corp website http / /www saw usace army milMETLANDS /esa to obtain needed information 6 Essential Fish Habitat (Corps Requirement) 6a Will this protect occur in or near an area designated as essential fish habitats ❑ Yes ® No 6b What data sources did you use to determine whether your site would impact Essential Fish Habitat? Data source is http //ocean flondamanne org /efh_coral /ims /viewer htm website 7 Historic or Prehistoric Cultural Resources (Corps Requirement) 7a Will this protect occur in or near an area that the state federal or tribal governments have designated as having historic or cultural preservation Yes No status (e g National Historic Trust designation or properties significant in North Carolina history and archaeology)? 7b What data sources did you use to determine whether your site would impact historic or archeological resources? NFsNC Cultural Resources database 8 Flood Zone Designation (Corps Requirement) 8a Will this protect occur in a FEMA- designated 100 year floodplain? ® Yes ❑ No 8b If yes explain how protect meets FEMA requirements No development would occur with this work therefore there is no change in flood heights associated with this protect 8c What source(s) did you use to make the floodplain determination? NC Floodplain Mapping Information System http / /www ncfloodmaps com/ BradyN Dodd 02/1V ,?01 -Z Applicant/Agents Printed Name PP lica 9 e s Si nature Date (Agents signature is valid only if an authorization letter from the applicant is provided Page 11 of 11 United States Forest National Forests in Department of Service North Carolina Agriculture File Code 1230 Route To (2500) Subject Delegation of Authority To Brady Dodd 160A Zdlicoa Street P O Box 2750 Asheville, NC 28802 828 257 4200 Date October 12 2005 20120186 You are hereby delegated the authority to act as my agent for all phases of the application process for permits required by Section 404 of the Clean Water Act for watershed restoration and improvement projects such as aquatic habitat restoration and enhancement habitat restoration channel stabilization and channel relocation on the National Forests in North Carolina You are authorized to make formal application for all permits to the US Army Corps of Engineers and the North Carolina Division of Water Quality provide all necessary information and sign all correspondence Include this letter as part of all application for Section 404 permits to the US Army Corps of Engineers and Section 401 Water Quality Certification to the North Carolina Division of Water Quality lq- MARISUE HILLIARD Forest Supervisor Caring for the Land and Serving People Pn t d Recycled Pape DECISION NOTICE AND FINDING OF NO SIGNIFICANT IMPACT HAYSTACK PROJECT USDA FOREST SERVICE NANTAHALA NATIONAL FOREST NANTAHALA RANGER DISTRICT FRANKLIN NORTH CAROLINA SEPTEMBER 2011 The U S Department of Agriculture (USDA) Forest Service prohibits discrimination in all its programs and activities on the basis of race color national origin gender religion age disability political beliefs sexual orientation or marital or family status (Not all prohibited bases apply to all programs ) Persons with disabilities who require alternative means for communication of program information (Braille, large print audiotape etc ) should contact USDA s TARGET Center at (202) 720 2600 (voice and TDD) To file a complaint of discrimination write USDA Director Office of Civil Rights Room 326 W Whitten Building 14 "` and Independence Avenue SW Washington DC 20250 9410 or call (202) 720 5964 (voice and TDD) USDA Forest Service is an equal opportunity piovider and employer • INTRODUCTION E An Environmental Assessment (EA) with associated documents for the Haystack Project is available for public review at the Nantahala Ranger District office in Franklin, NC The EA discusses proposed timber harvest associated site preparation and reforestation activities and wildlife habitat and timber stand improvements for the Haystack Project Project activities are located on National Forest land in Compartments 96, 98, 105 109, 140, 118 120 134 139 and 144 149 on the Nantahala Ranger District, Nantahala National Forest, in Macon County, North Carolina The project is needed to recondition existing wildlife habitat to create new wildlife habitat in a variety of ways and to emphasize silvicultural treatments to provide for a high quality sustainable forest The proposed action is in compliance with the direction set forth in the Land and Resouicc Management Plan (LRMP) 1986 2000 for the Nantahala and Pisgah National Forests and Amendment 5 (1994) in a manner which moves project area resources toward desired future conditions Specific project objectives are to 1) Conduct forest management activities to provide for restoration and improvement of existing forest stands within the analysis area, 2) Provide for a range of stand age classes through timber regeneration harvesting and other activities, while producing a minimum of 1 million board feet (MMBF) of sawtimber for the local economy, 3) Maintain and enhance biological diversity by protecting population viability of rare species which occur in the compartments by reproducing existing forest species especially oaks for hard mast production, and pines to perpetuate mixed hardwood pine or pine hardwood communities 4) Restoie optimal habitat conditions on existing area wildlife openings create new grasslforb openings and create /enhance additional wildlife habitat where practical, 5) Improve habitat for the golden winged warbler where possible DECISION Based on the results of the analysis documented in the EA and project file and comments during scoping and the formal 30 day comment period, my decision is to implement the proposed action, Alternative B Two Aged Regeneration Harvest Regenerate approximately 320 acres in 18 separate stands using a two aged method of regeneration followed by activities to prepare the sites for regeneration of new seedlings in the two age method the mature stand is partially cut Enough of the mature stand is removed in order to ensure enough light reaches the forest floor to sustain growth and development of the new stand Some trees, 2 approximately 15 to 20 square feet basal area" per acre are left standing to meet visual quality and wildlife objectives Den trees and hard mast producing trees are the favored leave trees Logging would be accomplished by using both a conventional ground based system that skids the logs on the ground to a designated landing and an overhead cable system to cable logs up terrain when it is too steep for operating ground based skidders Site preparation involves cutting down competing and noncommercial vegetation Unit/ Compartment Stand ACRES Unit/ Compartment Stand ACRES Unit 1 / C96 S32 22 Unit 18 / C137 — S44 10 Unit 2 / C96 S33 14 Unit 19 / C137 — S9 16 Unit 5 / C118 S34 23 Unit 23 / C145 — S38 15 Unit 8 / C118 S36 11 Unit 25 / C145 — S39 8 Unit 9 /C119 —S30 24 Unit 26 /C106 —S31 31 Unit 12/C119 —S31 24 Unit 27 /C106 —S27 25 Unit 13JC134 —S21 20 Unit 28 /C107 —S26 6 Unit 14JC136 —S12 31 Unit 29 /C108 —S26 21 Unit 15 / C137 — S41 9 Unit 16 / C137 — S43 10 TOTAL 320 Intermediate Thinning Harvest Conduct intermediate thinning in stands of immature sawtrmber, thinning to improve stand structure by removing smaller diameter intermediate and suppressed trees and also over mature declining individuals Do this tieatme& in stands 118 35 (14 acres) 136 2 (19 acres) 137 42 (14 acres) and 139 6 (26 acres) for a total of 73 acres Slash, Burn, and Plant Conduct contract slash down work removing most of the over story vegetation except for a few leave trees (15 20 square feet of residual basal area) to simulate a two aged regeneration harvest area Follow the slash down with a hot prescribed burn to accomplish site preparation Plant the areas with shortleaf pine or pitch pine seedlings on a 10 x 12' spacing Do this work in stands 136 36 (7 acres) and 145 -24 (11 acres) Firewood Unit Proposed Stand 136 37 (approximately 11 acres) is a firewood unit to be slashed down by a contractor and the down wood to be permitted to firewood gatherers This unit is close to Standing Indian campground adjacent to FS system road #67 Road Construction Construct approximately 0 7 mile of new system road, #7331G1, onto existing system road #7131 G to access Stand 106 31 This new road segment will facilitate efficient access for fire management prevention, and suppression as well as access for law enforcement It will also facilitate management actions in the future Road Reconstruction Conduct road reconstruction on approximately 0 5 miles on the end of FS system road #7219 to access Stand 134 21 Temporary Road Construction Construct approximately 0 2 mile of temporary road off of FS system road #67 to access Stand 134 21 and 0 2 miles to access Stand 136 2 0 0 Oak Mid -story Pre harvest Treatment Conduct an oak pre harvest mid -story treatment on three areas totaling approximately 95 acres in Stands 120 1 (59 acres) 137 42 (14 acres), and 139 31 (22 acres) Some mid story trees in these areas will be treated with herbicide by a contractor to increase the amount of light reaching the forest floor This will encourage the growth of advance oak regeneration 12 15 years prior to the next two aged regeneration harvest Crop Tree Release Conduct timber stand improvement work (crop tree release) on 234 acres in stands 108 14, 118 2,118 3, 118 13, 118 15 118 31 119 10 119 -13 119 19, 134 6 134 8 134 12 134 19 and 134 20 American Chestnut and /or Oak Seedling Planting As they become available plant genetically improved seedlings of American chestnut and/or oak in selected areas within proposed two aged iegeneiation units B Treatments for the purpose of wildlife habitat creation and/or improvement Construct four new wildlife openings Construct two new wildlife openings of appioximately 1 acre each near Tin Cup Knob in Compartment 140 Also construct 2 new openings (0 5 acre and 1 acre) on the east ndge in Stand 106 31 in Compartment 119 Riparian Area Restoration Restore natural hydrological function and plant species diversity in 16 areas of riparian flats along area streams Restore surface flow patterns by re contouring old roadbeds Shrubs and some small trees would be removed by cutting with hand tools Stumps of the cut vegetation would be sprayed with glyphosate or triclopyr herbicide to inhibit sprouting Some timber will be harvested using patch cutting methods in which a 30 buffer will be maintained on each side of the stream to protect the riparian corridor and to develop a multi aged stand Riparian Area sites Site # Acres Site # Acres 1 80 9 05 2 90 10 20 3 60 11 10 4 10 12 10 5 10 13 20 6 60 14 30 7 30 15 30 8 30 16 70 TOTAL 570 Spray Harvest Unit Skid Trails Spray saplings in harvest unit skid trails (postharvest) with tnclopyr 4E to promote the growth of grassers (nesting habitat) for the golden winged warbler 4 Bog Restoration Combat woody encroachment by slashing rhododendron and other shrubs in and around 6 bogs in the Nantahala River area and treat the stumps with triclopyr herbicide Ponds Construct 25 vernal ponds in wildlife fields and on harvest unit landings Rehabilitate existing wildlife openings Disc, burn, and apply herbicide to all existing wildlife openings in the area that are in poor condition Follow this treatment with the seeding and establishment of new grasses and forbs Retreatment of Rhododendron Control Areas To maintain riparian area species diversity, slash down three previously treated rhododendron patches of approximately 60' by 100 in the Yellow Patch area south of FS road #67 Follow the slash down work with stump spraying with triclopyr herbicide Prescribed Burning Continue treating approximately 3,065 acres in 10 burn units within the prod ect area Oak Savannah Creation by Prescribed Burning Create an oak savannah woodland on the top of Pine Mountain (approximately 6 acres) by understory prescribed burning i Oak Savannah Creation by Vegetation Slashing and Prescribed Burning Restore oak savannah woodland conditions in 5 areas (approximately 20 acres total) by vegetation slash down and Rx burning These treatments would be conducted in the following areas 1) Kimsey Bald (about 3 acres), 2) Bee Tree Knob (about 7 acres), 3) Chestnut Knob (about 3 acres), 4) Dirty John (about 4 acres), and 5) Steeltrap (about 3 acres) Thin along FS System Roads Conduct roadside thinning along all existing FS system roads Fisheries Work 1) Place two new arched culverts in Kinsey Creek to allow for fish passage 2) Streambank stabilization and erosion control in Nantahala River/Kimsey Creek area Invasive Species Removal Control invasive species by spraying a triclopyr herbicide solution along all system roadsides in recreation area roadsides Also treat any existing invasive species along FS road #s 67A 7131A and C and 7217B Helispot Construction Create anew helicopter landing site inside the Steeltrap Rx bum unit This would be an extension of an existing wildlife opening on the south central end of the bum unit on the ridge above Henry Patch Branch t 5 • Big Indian area Water Removal Rehabilitate the area where water is running down the roadbed on FS Road # 67A by diverting the water into the adjacent wildlife opening Cypripedium parviflorum Forest Service botanists will revisit stand 106 31 during the growing season to locate individuals and populations of small flowered yellow lady s slipper (Cypripedtum parviflorum var pamflorum) prior to beginning any treatments Seepage Ai ea Management Approximately 0 25 acres will be left adjacent to the seepage area in the southeast portion of Unit 106 31 OTHER ALTERNATIVES CONSIDERED Two other alternatives were considered in detail Alternative A. No Action Under this alternative, the proposed protect would not be implemented Alternative A was not selected because it does not meet the purpose and need and specific project objectives stated in the EA In particular this alternative would not contribute to the desired future conditions for early successional habitat would not maintain and enhance biological diversity by reproducing existing forest species would produce no new grass /forb openings for wildlife habitat would not improve any habitat for the golden winged warbler and would not conduct any forest management activities for the improvement and /or restoration of existing forest stands Alternative C The nonpreferred alternative for this project would have no road construction or reconstruction no harvesting of units 3,13 25 and 26 (totaling 74 acres) roadside thinning of every system road in the analysis area and slash/burn/planting of one area only an 11 acre area adjacent to FS Road #67 In addition, there would be no new wildlife opening construction, no new arched culverts for fish passage or other fisheries work and no helnspot construction DECISION RATIONALE The above described actions are selected for unplementation because Alternative B best meets the purpose and need and specific project objectives This decision implements the direction in the Nantahala/Pnsgah Land and Resoui ce Management Plan (LRMP) and its amendments through the application of Forest wide and management as ea standards and mitigating measures The specific project objectives for the proposal are met by the project actions as follows 1) Objective Conduct forest management activities to provide for restoration and improvement of existing forest stands within the analysis area The actions in the selected alternative, Alternative B will provide timber stand improvement activities on approximately 506 acres This includes the stump spraying on the proposed 320 acres of two aged regeneration, 73 acres of intermediate thimungs 18 acres of slash burn and plant treatments, and 95 acres of oak pre harvest mid story treatments Additionally, 234 acres of crop tree release work will be conducted on 15 stands Alternative C in addition to few acres of silvncultural treatments, would result in fewer projects for wildlife and fisheries n habitat improvement Thus, Alternative B more appropriately addresses this project objective 2) Objective Provide for a range of stand age classes thi ough timber regeneration harvesting and other activities, while producing a minimum of 1 million board feet (MM131) of sawtimber for the local economy Alternative B proposes approximately 320 acres of new early successional habitat through two aged regeneration harvesting Alternative C proposes approximately 246 acres of new early successional habitat through regeneration harvesting For Alternative B, an estimated 0 94 million board feet (MMBF) of high value hardwood sawtimber, 0 88 MMBF of medium value hardwood sawtimber 0 37 MMBF of low grade hardwood sawtimber and 718 hundred cubic feet (CCF) of pulpwood would be offered for sale in the local market Thus Alternative B better meets the objectives of providing a range of stand age classes and more economic impact for the local economy 3) Objective Maintain and enhance biological diversity by protecting population viability of rare species which occur in the compartments, by reproducing existing forest species, especially oaks for hard mast production, and white pines to perpetuate mixed hardwood pine or pine hardwood communities Per the Haystack project EA and Biological Evaluation (BE) population viability of rare species in the analysis area will be protected with implementation of the project activities More reproduction/of existing forest species would occur with Alternative B than with Alternative C because approximately 320 acres of hardwood stands (including oaks) will be regenerated whereas fewer acres and stands would be regenerated with the implementation of Alternative C Alternative B includes planting of American chestnut and/oak seedlings on selected sites as they become available 4) Objective Restore optimal habitat conditions on existing area wildlife openings, create new grass /forb openings, and create /enhance additional wildlife habitat where practical Alternative B would include existing wildlife opening rehabilitation, wildlife opening creation prescribed burning on about 3 065 acres riparian area restoration in 16 areas installation of fish passage structures, creation of 25 vernal pools bog restoration, rhododendron control spraying of nonnative invasive species and maintenance of linear wildlife openings by selectively thinning trees Alternative C includes the treatments described above for Alternative B but reduces the slash/burn/planting to one area only an 11 acre area adjacent to FS Road #67 In addition there would be no new wildlife opening construction no new arched culverts for fish passage or other fishenes work PUBLIC INVOLVEMENT Scoping is defined by the National Environmental Policy Act (NEPA) as "an early and open process for determining the scope of issues to be addressed and for identifying the issues related to a proposed action This project was discussed at Rapid Assessment public 7 L-- - -- meetings at the Nantahala RD office on March 25, 2008 October 14 2008, and on October 8, 2009 The project was scoped with the public in December of 2010 and January of 2011 A project Scoping Record with maps and a list of proposed actions was posted on the National Forests in North Carolina website for individuals and groups to comment on the project proposal In addition the Scoping Record was mailed to 41 individuals and groups on December 1, 2010 Responses to the Scoping Record included letters or emails from Yolanda Saunooke — Eastern Band of Cherokee Indians, Josh Kelly Wildlaw, Dave McHenry — NC Wildlife Resources Commission (NCWRC), Hugh Irwin — Souther Appalachian Forest Coalition, Brent Martin — The Wilderness Society, Ed Schwartzman - NC Natural Heritage Program and the U S Fish and Wildlife Service Since the December 2010 scoping the project has been listed in the NFsNC Schedule of Proposed Actions, which is distributed to several hundred individuals and groups throughout the United States A project Environmental Assessment (EA) was placed on the NFsNC website and a notification letter was mailed to the public on July 21, 2011 for the 30 day public comment period which began on July 29, 2011 and ended August 30, 2011 The legal notice for the comment period was published in the Franklin Press on July 29, 2011 Pursuant to 36 CFR 215, timely comments on the EA were received from four individuals or groups These comments aie addressed in my Response to Comments Appendix E to the EA FINDING OF NO SIGNIFICANT IMPACT After thorough consideration of the EA Appendices the Forest Plan (LRMP) and comments received, I have determined that the decision to implement this project is not a major federal action, individually or cumulatively, and will not significantly affect the quality of the human environment In a local context (EA pgs 3 8) the site specific actions of the selected alternative (Alternative B), both short and long term, are not significant Therefore an Environmental Impact Statement for this project is not needed My determination is based on the following intensity factors INTENSITY /SEVERITY OF THE Il"ACTS 1 This project will have a beneficial effect on the local community No significant adverse effects to the environment were identified in the environmental analysis (EA Section 3 pages 13 94) There is no nreversible commitment of resources in Alternative B These are no known significant irretrievable commitments of resources My determination that the effects are non - significant is not biased by any beneficial effects resulting from the project 2 There will be no significant effects on public health and safety resulting from the work conducted on this project (EA pages 11 13, 89) 3 There will be no significant effects on unique characteristics of the area, there are no prime farmlands wetlands or wild and scenic rivers in the project area Although the Appalachian Trail traverses a portion of the area, design criteria will be implemented so that project activities will meet designated visual quality objectives (VQOs) (EA page 7 and 88 89) 4 Based on the involvement of forest resource specialists state and federal agencies, and members of the public, I do not expect the effects of the selected alternative to be highly controversial in a scientific context (EA Section 3 pages 13 94) 5 The effects of the project as described in the Environmental Assessment are not highly uncertain and do not involve unique or unknown risks (EA, pages 13 94) 1 am confident that based on past experience with actions of a very similar nature there are no unknown or unique risks associated with this project 6 No precedent will be set through this action which will contribute to future actions with significant effects, the project is site specific and effects will remain localized and short term (EA pages 13 94) 7 No significant cumulative impacts will result fiom this action (EA, pages 13 94) 8 A Heritage Resources Survey of the project area has been completed There will be no significant effect on historic or cultural resource sites (EA page 86) 9 There will be no significant effect on any federally listed threatened endangered or sensitive (TES) species or their critical habitat (EA pages 40 47 47 66) No cumulative effects on species viability across the Forest will result from this project (EA, pages 13 79) 10 The project will not threaten a violation of federal state or local laws to protect the environment (EA, pages 13 94) For water quality management this project is designed to comply with the forest practices guidelines and standards found in the North Carolina Forest Practices Guidelines Related to Water Quality These guidelines and standards have been designed with the goal of producing water that meets state water quality standards The project will be monitored to ensure proper implementation If effects on a specific site are greater than anticipated due to unforeseen site factors or events appropriate corrective measures will be considered and implemented OTHER FINDINGS Forest Plan Consistency Alternative B (as described above), is consistent with the Land and Resource Management Plan for the Nantahala and Pisgah National Forests (LRMP) and all Amendments to the Plan The following paragraphs discuss the reasoning for this finding 1 These actions are feasible and reasonable and contribute to the desired future conditions identified as Forest Goals (LRMP, Amendment 5, pages III 1 2) The actions of this project 0 harvest timber on those lands identified as suitable for timber production (Management Areas 113 3B and 4D) 2 The actions of this project which alter vegetation comply with the seven requirements of 36 CFR 219 27 following Forest wide direction and standards and direction and standards for Management Areas IB, 3B, and 4D 3 Two aged regeneration is an appropriate method of meeting LRMP objectives in the stands proposed for regeneration (EA pages 3 4 83 86) APPEAL RIGHTS This decision is subject to appeal pursuant to 36 CFR 215 11 Any appeal of this decision must be fully consistent with 36 CFR 215 14 "Content of an Appeal including the seasons for appeal and must be filed with the Appeal Deciding Officer at this address Forest Supervisor, National Forests in North Caiohna 160 Zillicoa Street Asheville NC 28801 1082 Appeals also may be faxed to (828) 259 0584 or electronically filed by sending them to appe'ils southern north carohng@fs fed us Appeals must be postmarked or received no later than 45 days, beginning the day after the legal notice of this decision is published in the Franklin Press i IMPLEMENTATION Pursuant to 36 CFR 215 9, if no appeal is filed, this decision may be implemented on but not before the 5th business day following close of the appeal filing period If an appeal is filed implementation may occur on but not before the 15 "' business day following the date of appeal disposition CONTACT PERSONS For further information about this decision, contact Steverson Moffat at the Nantahala National Forest (telephone 828/837 5152 ext 108) or at comments southern north caiohna nantahala nantahala@fs fed us Vii/ 10 F,:,p -,,"/ DATE LUJ t , r 7Q'N Q < LL G� W z z m W Q J z U) 0 T< ?: p/aa�J 0 as tributary 0 � zv U O V N O u U Z 4-J O .-40 •-r 3z >N aw v o= ss= a a I U) W W F— z F- U) X W Q � rd v v bn Cn Q� 4-J U W o v a CJ 0 A~ N N �� 4O 0 rd U �J rA o v C) rd O v O fu 4O _C zF-. �z o 'd W N x x 'C� co Q) O moo' ~vv� ��wzz 0 � zv U O V N O u U Z 4-J O .-40 •-r 3z >N aw v o= ss= a a I U) W W F— z F- U) X W ml w z z Q U w 0 0 � I Q o� LL IL Q m F- z 0 d •.5t' 0 v � r , V v z ..y -J v a V >, C) .., rd � .� Q1 O ,� N a..r v) fa Cn o v U `4� C) � O co � tip N rd vb� rl 4-J U 4� Ot` }' 140. v 0 N �a c _°o o � � o Lo a, z �O �/ ) O 0. UU1 Y z m U- 0 Q W IC.y g c o 0 N 2 N LL N N C6 0 0 N W N N Q 0 0 0 .6 0 0 ED Q � rd 0 v bn Cn Q� 4-J 0 r N o v a CJ 0 u r .4-J 'C7 N �� 4O 0 rd U �J rA o v rd O v O fu 4O _C � .� o 'd c 4- M 'C3 ro Uj � 0 � O O 'C� co Q) O moo' ~vv� ml w z z Q U w 0 0 � I Q o� LL IL Q m F- z 0 d •.5t' 0 v � r , V v z ..y -J v a V >, C) .., rd � .� Q1 O ,� N a..r v) fa Cn o v U `4� C) � O co � tip N rd vb� rl 4-J U 4� Ot` }' 140. v 0 N �a c _°o o � � o Lo a, z �O �/ ) O 0. UU1 Y z m U- 0 Q W IC.y g c o 0 N 2 N LL N N C6 0 0 N W N N Q 0 0 0 .6 0 0 ED W LU U W U) 2 /1 .O L a 0 E a� O L C. E c� c� O :F+ N Y m x r� b v b 0 F GJ a$ 5 fd N O b bA 0 0 a 0 +j 0 a x a b v O v 4J a an b 0 0 a N 0 O a 0 0 4 a w Q J z 0 W N X > > W > o 0 a�J 0 as 0 O tributary "•••....... r+'o O � ro V 0 �o a° 3 0 14 O c w [� O w p O ro � v F z II II II ......... I ....... .......... ., ®R. O (J b V 0 0 o UV cu A � w •� O >a ........ xF "d ......... ° Qj b v b 3 �O v ff � Qa z b x �o z� 4-J •o W N � z - U b b v o AN 0 too C14 �� Roo ap" 4-J r+'o O � ro V 0 �o a° 3 0 14 O c w [� O w p O ro � v F z II II II ......... I ....... .......... ., ®R. O (J b V 0 0 o UV cu A � w •� O >a Q m z 0 a V O N cu m LL v 0) N C6 O 0 N 00 N 0 U -o 'a O 0 T V f0 m r_ b xF "d ° Qj b v b 3 o v ff o V) bl) v b y 4-J o - b v o AN 0 too C14 �� ap" 4-J v v U b o v >. o v> , En v � . o o o }' 4J p" ° �° v U • • �° o v a0 o b: @ �u 0 �� �"v4 a�1 cl x � tC ti `n ow o ° nb av ICJ b fib° �•�a�� 4�'� . 3 0 ��� ^�l �ro> 4-J v b � a� - 3 .bah s td 4-1 0 a U b V O w O 4--) odCO o;. b v rd a� Lh O 'f CO b O U Q %. � ~ N O >'.� O v o C F a, Ln o viV p .� • ti .- .. m�U�ca av�...a �H ::f4 N M Q m z 0 a V O N cu m LL v 0) N C6 O 0 N 00 N 0 U -o 'a O 0 T V f0 m r_ am1 AN 0 too cu X • o -• • CL • ( ) • . • • r. • 4- U • • -.. • U U W m 4- � c rn (6 _0 N_ O W N A O 4- O C C Cl) C C L � ` U ° L �0 0 U o-0 OG U W ° OU) 4— O O cn L c U C 0 a� d Y Z Q m w a a Z) C , @ 1 \ m I � c' -- UI c' °' I 0 J w Q �CO , > Q w �- -- :c a m \% , � 9 I C l0 , IL N .� c �> 3i > p y O v Gy.�� " o 1 1 V,°' 3� o W X i m' Q I 1 y '. a v o ° 3 v I c 1 o ro O OZA ...................�.E G %' I I L I UI o v o�bo U) c:��v ' c' CU a (n rii I I of I o It ' z I I J I OI O O CL ° ' O U) I I S Z 1 d I Q I I w I 1 1� 1 1 1 • �� -•' �1 ipwil • Mw w Dm U)w Z Z � U 1 1 1 1 1 1 1 1 1 1 1 1 1 ► ► 1 V O J z O z O LL O O = aU mZ LL mz 0: a m \% , � v � X � �� � w p y O v Gy.�� " o v $ 3� o W X I y '. a v o ° 3 v u o v o ro I OZA ...................�.E G %' ro 0 3 o v o�bo c:��v CU a rii o It ro ' w v CO w t o W Q v ° q � ro W o4 ov a °S -d v U 0 a b ° (o V W � O° a b v a bo Q ro y a nO v °o v ° b o o v G ro a v W$ >$ v ov v y bb H v o� o ox cu im� ° ono o v -O av o 41 �.� 0b 4 � b o2S > .a 4. X o?i 4J ,� o o a ro b ro o w -Q ro rd "" 0 U u u o G u i. 'o O ro ro ,� 11 b +' I a' a k ro x °o r° v� o� o o rro , v X �� v o o ro ro E- w a w a a, .o a..0 a, 3 b a -o w 3 v v v� v r W V J M U %-1 0 V V a) ^ r r'1 V J i I L cn E —i EV C ° V Q m W cu m ca E 2) > O A f� A a) -°, N (D o m O o L o E O cn G1 2 w- V% m co CO Q to Y U w co U C 2) E+ W O E a w 't° Q 7 N Q. w a�'i � C U E U C a CA cu m ft CA I cu p cn C cu L �N a)i Q N -0 C C cu >+ ca U cu c C U ca CU 0 rl (Q C �_ a cn - N E m 2 E ` C o E U N a 2 U c _� > (6 C (a N v .s� m W U cn N .L O C X U) Y W > E O N U CL x fQ V N x m 0 t E o CA I � I N i I t V N cu I = N off a w { to F- m cu p cn C cu L �N a)i Q N -0 C C cu >+ ca U cu c C U ca CU 0 C EO E fa to C `o U (Q C �_ a cn - N E m 2 E ` C o E U N a 2 U c _� > (6 C (a N v .s� m W U cn N .L O C X U) Y W > E O N U CL x fQ V N x m t N O 0 CO N +J O O N "a N E 0 _ N O O N �' > N -C .Q 3 Y a Y m Y c� cu p cn C cu L �N a)i Q N -0 C C cu >+ ca U cu c C U ca CU 0 C EO E fa to C `o U (Q C �_ a cn - N E m 2 E ` C o E U N a 2 U c _� > (6 C (a N v .s� m W U cn N .L O C X U) Y W > E O N U CL x fQ V N x m