20230615_ltr_RFO JCA_re_Knollwood_Apartments_SouthernPinesMooreCounty_s_.pdf

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
June 15, 2023
Ms. Alicia Jackson
Dr. J.H. Carter III & Associates, Inc.
515 F Midland Road
Southern Pines, NC 28387
Re: Construction of Knollwood Apartments, Southern Pines, Moore County, North Carolina
Dear Ms. Jackson:
The Fish and Wildlife Service (Service) has reviewed your May 1, 2023, email, and Biological
Assessment titled "Red -cockaded Woodpecker Biological Assessment for the Knollwood
Apartments, Southern Pines, Moore County, North Carolina (BA). The proposed action is the
construction of a 27-acre apartment complex north of U.S. Highway 1, in the Town of Southern
Pines, Moore County, North Carolina. The project falls within the foraging partitions of two
active red -cockaded woodpecker (Picoides [=Dryobates] borealis; RCW) clusters. Our
comments are provided in accordance with sections 7 and 9 of the Endangered Species Act (Act)
of 1973, as amended (16 USC 1531 et seq.) and the Service's Private Lands Guidelines found in
Appendix 5 of the Service's Recovery plan for the red -cockaded woodpecker (Picoides
borealis): second revision (U.S. Fish and Wildlife Service 2003).
The proposed action is the construction of an apartment complex and related amenities on 27
forested acres north of US Highway 1, east of Pine Needles Golf Club and McDeeds Creek,
south of Camp Easter Road and McDeeds Creek Elementary School, and west of forested land
also owned by Knollwood Partners, LLC, in the Town of Southern Pines, Moore County, North
Carolina. The owners plan to construct nine apartment buildings, a clubhouse, a pool, tennis and
pickleball courts, a putting green, two parking garages, two retention ponds, a small dog park,
and associated driveways, parking areas and sidewalks on the project site. site. A sewer line
will also be installed to connect with an existing line and pump station.
Other than an existing sewer line, the project site is currently undeveloped and is vegetated with
a mixed pine -oak forest. The project falls within the 0.5-mile radius of the foraging partitions for
RCW Clusters SOPI 23 and SOPI 22-112. Dr. J.H. Carter III & Associates, Incorporated (JCA)
conducted surveys for RCW cavity trees within the 48-acre preliminary project study area and
within the 0.5-mile radius foraging partitions of the involved RCW clusters using approved
methods in January 2023. JCA also documented the status of RCW cavities/cavity starts in
Clusters SOPI 23 and 22-112 in the spring of 2023.

The BA summarizes the historical use of the two involved clusters by RCWs for over 40 years.
Both clusters contain between 20 and 25 cavity trees with cavities in various stages of
completion and suitability. SOPI Clusters 22 and 112 merged into a single cluster many years
ago. At least one RCW group has occupied this cluster the entirety of the 40+ year period,
including 2023. SOPI 23 was inactive in 2000 and 2001, but has been active every year since
2002.
JCA previously conducted a foraging habitat analysis (FHA) for SOPI 22-112 in February 2017.
JCA biologists updated stand delineations in April 2019 and February 2023. JCA also updated
stand delineations for SOPI 23 in March 2023. The company had stand data from a FHA for this
group conducted in 2003.
The BA outlines standard for managed stability (SMS) guidance and contains a brief description
of stand characteristics for assessing project impacts and making beneficial changes to habitat.
Pine stands meeting SMS overstory guidelines and have a sparse hardwood midstory, a
moderately dense hardwood midstory that is low in height or a dense hardwood midstory that is
low in height are considered "suitable" foraging habitat.
"Potentially suitable habitat" includes stands that meet most requirements, but exceed maximum
pine basal area/stocking in smaller diameter -at -breast -height (DBH) classes, hardwood midstory
density/height and/or overstory hardwood density. These stands have the necessary basal area
for 10-inch and larger DBH pines and could meet the SMS with midstory removal, prescribed
burning and/or thinning. Stands with suitable overstory characteristics containing a moderately
dense or dense midstory that is moderate or tall in height are placed in this category. All stands
on sites managed for pine dominance that did not fall into the suitable or potentially suitable
categories are classified as "future potential habitat." These stands will require time and
management to meet the SMS requirements.
RCW foraging habitat (timber stands) separated by more than 200 feet from other foraging
habitat was considered non-contiguous and was not counted as available habitat (Service 2003).
The acreage for each stand was calculated using ArcGIS software. The resulting acreages were
then multiplied by the average number of pine stems per acre for each two-inch diameter class in
order to determine the total pine stems >10 inches DBH per stand. The appropriate basal area
conversion number was multiplied by the total pine stem count in each two-inch diameter class
to get the pine basal area for each two-inch diameter class for each stand.
The distribution of foraging habitat within the involved 0.5-mile radius foraging partitions is
somewhat fragmented with patches of non -habitat (e.g., roads, fairways, etc.) interspersed among
stands of pine and mixed pine -hardwoods. Sufficient acreage of suitable and potentially suitable
habitat was not available within 0.25- mile radius inner core foraging partitions and JCA's
habitat assessment included the 0.5-mile radii for both RCW groups.
Pre -project, SOPI 22-112's 0.5-mile foraging partition contains 3,275.87 square feet (ft) of pine
basal area for pine stems > 10 inches DBH on 32.65 acres of suitable habitat, 7,340.63 ft2 on
85.19 acres of potentially suitable habitat and 113.03 ft2 on 4.11 acres of future potential habitat.
The project will not require removal of any currently suitable habitat.
2

About 309.53 ft2 of pine basal area for stems > 10 inches on 5.57 acres of potentially suitable
habitat will be removed. A 0.5-acre area containing 13.75 ft2 of future potential habitat will be
eliminated.
Post -project, SOPI 22-112's 0.5-mile radius foraging partition will retain 3,275.87 ft2 of 10+ -
inch DBH pine basal area on 32.65 acres of suitable habitat, 7,030.99 ft2 on 79.62 acres of
potentially suitable habitat and 99.28 ft2 on 3.61 acres of future potential habitat. The BA states
that this partition will meet the SMS requirements post -project assuming potentially suitable
habitat is made suitable (USFWS 2003).
SOPI 23's 0.5-mile foraging partition contains 2,546.66 ft2 of pine basal area for pine stems > 10
inches DBH on 33.0 acres of suitable habitat, 10,320.82 ft2 on 147.42 acres of potentially
suitable habitat and 1,337.9 ft2 on 59.48 acres of future potential habitat. The project will require
removal of 47.86 ft2 of pine basal area for stems > 10 inches on 0.83 acre of currently suitable
habitat. About 55.91 ft2 of pine basal area for stems > 10 inches on 0.97 acre of potentially
suitable habitat will be removed. No acreage identified as future potential habitat will be
eliminated.
Post -project, SOPI 23's 0.5-mile radius foraging partition will retain 2,498.8 ft2 of 10+ -inch
DBH pine basal area on 32.17 acres of suitable habitat, 10,264.92 ft2 on 146.5 acres of
potentially suitable habitat and 12,763.72 ft2 on 178.62 acres of future potential habitat.
The BA states that SOPI 23's partition will meet the SMS requirements post -project if
potentially suitable habitat is made suitable (USFWS 2003).
The proposed Knollwood Apartments project is located on the outer edges of the 0.5-mile radius
foraging partitions for clusters SOPI 22-112 and SOPI 23. Construction will not involve habitat
removal within 0.25-mile of either cluster center, nor within 200 feet of any RCW cavity trees.
Sufficient acreage and stocking will remain to allow for both RCW groups to continue to exist.
We recommend enhancing the survival of these RCW groups by minimizing impacts to mature
pines wherever practicable. Longleaf plantings incorporated into landscaping plans would
promote re-establishment of future potential habitat.
Based on a review of the information contained in your May 1, 2023 email and Biological
Assessment, as well as information available to the Service, we concur with your determination
that the proposed construction of the Knollwood Apartments project may affect, but is not likely
to adversely affect the RCW. We believe that the requirements of section 7(a)(2) of the Act have
been satisfied. We remind you that obligations under section 7 consultation must be
reconsidered if. (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered; (2) this action is
subsequently modified in a manner that was not considered in this review; or, (3) a new species
is listed or critical habitat determined that may be affected by the identified action.

If you have any questions regarding this matter, please contact Mr. John Hammond at 919-856-
4520 (Ext. 28). Thank you for your continued cooperation with our agency.
Sincerely,
J O H N Digitally signed by JOHN
HAMMOND
023.06.15 15:05:11
H A M M O N D 04'00'
for Pete Benjamin
Field Supervisor
Literature cited:
U.S. Fish and Wildlife Service. 2003. Recovery plan for the red -cockaded woodpecker
(Picoides borealis): second revision. U.S. Fish and Wildlife Service, Atlanta, GA.
296 pp.
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