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HomeMy WebLinkAbout20171204 Ver 1_Appendix E_20170920ONPiedmont Natural Gas Supporting Documentation for PCN Application Appendix E: USFWS Coordination PNG Line 434 Extension Project Appendix E Page intentionally blank Inserted for double sided printing A=COM January 25, 2017 Mr. Gary Jordan Raleigh Field Office US Fish and Wildlife Service P.O. Box 33726 Raleigh, North Carolina 27636-3726 AECOM 919 854 6200 tel 701 Corporate Center Drive 919 854 6259 fax Suite 475 Raleigh, North Carolina 27607 www.aecom.com Re: PNG Line 434 30 -inch Natural Gas Pipeline Robeson, Scotland, and Richmond Counties, North Carolina Dear Mr. Jordan: AECOM, on behalf of Piedmont Natural Gas (PNG), would like to request your agency's review of the proposed Line 434 30 -inch Natural Gas Pipeline Project. PNG is proposing to install approximately 33.6 miles of new 30 -inch natural gas pipe in Robeson, Scotland, and Richmond Counties, North Carolina. The project begins at NC Highway 710 in Robeson County and terminates at the Duke Smith Energy Center Complex, just west of Airport Road in Richmond County (see figures, Attachment A). The potential impact area runs the entire 33.6 miles and is approximately 200 feet wide, although slightly narrower or wider in some sections. The proposed pipeline runs directly parallel to an existing natural gas pipeline, the 120 -mile 20 -inch Sutton line. The proposed pipeline is offset from the Sutton line by approximately 30 feet, except in four areas where the proposed line diverges from the existing easement (see detail maps 2-5). Endangered Species Act In 2010, S&ME Inc. conducted a protected species assessment for the then -proposed 120 -mile Sutton pipeline, as well as a biological assessment for the red -cockaded woodpecker (RCW). The biological assessment concluded that no RCW habitat was located within one half mile of the Sutton pipeline. S&ME Inc. also conducted federally protected plant species surveys during appropriate times of the year, during which no protected plant species were observed. The USFWS provided comments in response to S&ME Inc.'s assessment in a letter dated May 21, 2011 (Attachment C). The USFWS concurred with the determination that the Sutton pipeline was not likely to adversely affect federally threatened or endangered species, and stated that the Section 7 (a)(2) requirements of the ESA had been satisfied for the project. Regarding the proposed Line 434 pipeline, AECOM obtained federally listed endangered and threatened species data from the USFWS county lists for Robeson, Scotland, and Richmond Counties. In addition, the NC Natural Heritage Program (NCNHP) Data Explorer website was used to generate a list of known element occurrences within one mile of the proposed project (Attachment B). The NCNHP lists one historical occurrence of RCW, located approximately 0.8 mile northeast of the proposed pipeline. Otherwise, there are no element occurrences of any federally threatened or endangered species located within one mile of the proposed project. In November and December, 2016, AECOM biologists conducted pedestrian surveys of the proposed project area for habitat and individual occurrences of the federally protected species listed for Robeson, Scotland, and Richmond Counties. These surveys were not conducted within the optimal survey windows for the plant species. A=COM Mr. Gary Jordan, USFWS January 25, 2017 Page 2 In lists updated on December 3, 2012, December 26, 2012, and July 24, 2015, respectively, the USFWS lists seven federally protected species for Robeson, Scotland, and Richmond Counties (Table 1). A brief description of each species' habitat requirements follows, along with the Biological Conclusion rendered based on survey results in the study area. Table 1. Federally protected species listed for project counties Scientific Name Common Name _T Counties Federal Habitat Biological Listed Status Present Conclusion Vertebrate: Alligator American alligator Robeson, T (S/A) N Not Required mississippiensis Scotland Robeson, Picoides borealis Red -cockaded Scotland, E N No effect woodpecker Richmond Vascular Plant: May effect, not Helianthus Schweinitz's schweinitzii sunflower Richmond E Y likely to adversely affect May effect, not Lysimachia Rough -leaf Scotland, asperulaefolia loosestrife Richmond E Y likely to adversely affect May effect, not Oxypolis canbyi Canby's dropwort Scotland E Y likely to adversely affect Robeson, May effect, not Rhus michauxii Michaux's sumac Scotland, E Y likely to Richmond adversely affect May effect, not Schwalbea American chaffseed Scotland E Y likely to americana adversely affect E - Endangered T (S/A) - Threatened due to similarity of appearance American Alligator USFWS Recommended Survey Window: year round (only warm days in winter) Habitat Description: In North Carolina, alligators have been recorded in nearly every coastal county, and many inland counties to the fall line. The alligator is found in rivers, streams, canals, lakes, swamps, and coastal marshes. Adult animals are highly tolerant of salt water, but the young are apparently more sensitive, with salinities greater than five parts per thousand considered harmful. Biological Conclusion: Not Required The American alligator is listed as Threatened due to Similarity of Appearance to the Endangered American crocodile, and is not afforded protection under Section 7 of the Endangered Species Act. A=COM Mr. Gary Jordan, USFWS January 25, 2017 Page 3 As such, Section 7 consultation with the USFWS is not required for this species. A review of the NCNHP records, accessed on October 14, 2016, indicates no known occurrences of American alligator within 1.0 mile of the study. Red -cockaded woodpecker USFWS optimal survey window: year round; April 1 through July 31 (optimal) Habitat Description: The red -cockaded woodpecker (RCW) typically occupies open, mature stands of southern pines, particularly longleaf pine (Pinus palustris), for foraging and nesting/roosting habitat. The RCW excavates cavities for nesting and roosting in living pine trees, aged 60 years or older, and which are contiguous with pine stands at least 30 years of age to provide foraging habitat. The foraging range of the RCW is normally no more than 0.5 mile. The USFWS RCW Recovery Plan outlines specific requirements for RCW foraging and nesting habitat (USFWS 2003). These requirements include, but are not limited to, little or no hardwood and/or pine midstory, pine stands of at least 30 years of age, and total stand basal area (BA) should be no higher than 80 square feet per acre. Biological Conclusion: No Effect Pedestrian surveys were conducted in November and December, 2016, within pine communities in the study area that could potentially contain habitat for RCW. It was determined that no suitable nesting or foraging habitat for RCW occurs within these communities due to their dense midstory, unsuitable tree diameter classes and stand age, and/or a BA higher than 80 square feet per acre. A review of NCNHP records, accessed on October 14, 2016, indicates no known RCW occurrences within 1.0 mile of the study area. Schweinitz's Sunflower USFWS Optimal Survey Window: late August through October Habitat Description: Schweinitz's sunflower occurs in full to partial sun and is found in areas with poor soils, such as thin clays that vary from wet to dry. It is believed that this species once occurred in natural forest openings or grasslands. Many of the remaining populations occur along roadsides. Biological Conclusion: May affect, not likely to adversely affect Surveys for Schweinitz's sunflower and its habitat were conducted during pedestrian surveys conducted in November and December, 2016. Suitable habitat for this species occurs along utility and transportation rights-of-way. No individuals were found during the survey. A review of the NCNHP records, accessed on October 14, 2016, indicates no known element occurrences within 1.0 mile of the study area. Rough -leaf loosestrife USFWS optimal survey window: Mid May through June Habitat Description: This species generally occurs in the ecotones or edges between longleaf pine uplands and pond pine pocosins (areas of dense shrub and vine growth usually on a wet, peaty, poorly drained soil) on moist to seasonally saturated sands and on shallow organic soils overlaying sand. Rough -leaf loosestrife has also been found on deep peat in the low shrub community of large A=COM Mr. Gary Jordan, USFWS January 25, 2017 Page 4 Carolina bays (shallow, elliptical, poorly drained depressions of unknown origin). The grass -shrub ecotone, where rough -leaf loosestrife is found, is fire -maintained, as are the adjacent plant communities (longleaf pine - scrub oak, savanna, flatwoods, and pocosin). Suppression of naturally - occurring fire in these ecotones results in shrubs increasing in density and height and expanding to eliminate the open edges required by this plant. Several populations are known from roadsides and power line rights of way where regular maintenance mimics fire and maintains vegetation so that herbaceous species are open to sunlight. Biological Conclusion: May effect, not likely to adversely affect Within the project study area, suitable habitat consists of Carolina bays, mesic pine flatwoods, and various poorly drained sites. A review of the NCNHP records, accessed on October 14, 2016, indicates no known element occurrences of rough -leaf loosestrife within 1.0 mile of the study. No populations or individuals of rough -leaf loosestrife were identified within the study area during pedestrian surveys conducted in November and December, 2016. Canby's Dropwort USFWS Optimal Survey Window: Mid -July through September Habitat Description: Canby's dropwort has been found in a variety of coastal plain habitats, including natural ponds dominated by pond cypress, grass -sedge dominated Carolina bays, wet pine savannas, shallow pineland ponds and cypress -pine swamps or sloughs. The largest and most vigorous populations have been found in open bays or ponds that are wet throughout most of the year but which have little or no canopy cover. Soils are sandy loams or acidic peat mucks underlain by clay layers which, along with the slight gradient of the areas, result in the retention of water. Biological Conclusion: May affect, not likely to adversely affect Pedestrian surveys for Canby's dropwort and its habitat were conducted in November and December, 2016. Suitable habitat for this species occurs within some of the wetland areas. No individuals were found during the survey. A review of the NCNHP records, accessed on October 14, 2016, indicates no known element occurrences within 1.0 mile of the study area. Michaux's Sumac USFWS optimal survey window: May through October Habitat Description: Michaux's sumac, endemic to the inner Coastal Plain and lower Piedmont, grows in sandy or rocky, open, upland woods on acidic or circumneutral, well -drained sands or sandy loam soils with low cation exchange capacities. The species is also found on sandy or submesic loamy swales and depressions in the fall line Sandhills region as well as in openings along the rim of Carolina bays; maintained railroad, roadside, power line, and utility rights-of-way; areas where forest canopies have been opened up by blowdowns and/or storm damage; small wildlife food plots; abandoned building sites; under sparse to moderately dense pine or pine/hardwood canopies; and in and along edges of other artificially maintained clearings undergoing natural succession. In the central Piedmont, it occurs on clayey soils derived from mafic rocks. The plant is shade intolerant and, therefore, grows best where disturbance (e.g., mowing, clearing, grazing, periodic fire) maintains its open habitat. A=COM Mr. Gary Jordan, USFWS January 25, 2017 Page 5 Biological Conclusion: May affect, not likely to adversely affect Within the project study area, suitable habitat for Michaux's sumac consists of maintained utility and transportation easements and areas along the edges of Carolina bays. A review of the NCNHP records, accessed on October 14, 2016, indicates no known element occurrences of Michaux's sumac within 1.0 mile of the study. No populations or individuals of Michaux's sumac were identified within the study areas during pedestrian surveys conducted in November and December, 2016. American Chaffseed USFWS optimal survey window: May through August (1-2 months after fire) Habitat Description: American chaffseed occurs in sandy (sandy peat, sandy loam), acidic, seasonally moist to dry soils. It is generally found in habitats described as open, moist pine flatwoods, fire - maintained savannas, ecotonal areas between peaty wetlands and xeric sandy soils, and other open grass -sedge systems. Chaffseed is dependent on factors such as fire, mowing, or fluctuating water tables to maintain the crucial open to partly -open conditions that it requires. Historically, the species probably existed on savannas and pinelands throughout the coastal plain and on sandstone knobs and plains inland where frequent, naturally occurring fires maintained these sub -climax communities. Under these conditions, herbaceous plants such as Schwalbea were favored over trees and shrubs. Biological Conclusion: May affect, not likely to adversely affect Within the project study area, suitable habitat for American chaffseed consists of pine flatwoods and transitional areas between wetlands. A review of the NCNHP records, accessed on October 14, 2016, indicates no known element occurrences of American chaffseed within 1.0 mile of the study. No populations or individuals of American chaffseed were identified within the study areas during pedestrian surveys conducted in November and December, 2016. Bald Eagle and Golden Eagle Protection Act A review of the NCNHP records, accessed on October 14, 2016, indicated no known bald eagle occurrence within 1.0 mile of the study area. No bald eagles, bald eagle nests, or suitable habitat were observed within the study area during pedestrian surveys conducted in November and December, 2016 Based on the results of our review of the NCNHP records, our pedestrian surveys, and the absence of individuals or populations of protected plant species found during S&ME Inc.'s survey of the directly adjacent Sutton line during appropriate optimal survey windows in 2010, we propose a "May affect, not likely to adversely affect" conclusion for each of the federally protected plant species. We did not observe any suitable habitat for the RCW during our pedestrian surveys. Given this, and the fact that S&ME Inc. did not find any suitable habitat for the RCW within one half mile during their biological assessment for the directly adjacent Sutton pipeline, we propose a "No effect" conclusion for this species. We would appreciate your concurrence with the biological conclusions listed above. We would also appreciate your agency providing comments on any possible issues that might emerge with respect to endangered species, critical habitat, migratory birds, or other trust resources from the proposed project area. A preliminary jurisdictional determination for Waters of the US, including wetlands, is A=COM Mr. Gary Jordan, USFWS January 25, 2017 Page 6 pending the USACE review of our field delineation. Horizontal Directional Drilling (HDD) is proposed for the Lumber River crossing, and several other large wetland/stream crossings. Please contact me at (919) 239-7133 or paul.gerlach@aecom.com if you have any questions regarding this request. Sincerely, AECOM 4jaj-� Paul Gerlach Environmental Scientist Enclosures Attachment A — Figures Attachment B — NCNHP Report Attachment C — USFWS Section 7(a)(2) Response Letter to S&ME From: Ellis, John [mailto:john_ellisQfws.gov] Sent: Thursday, February 16, 2017 11:40 AM To: Gerlach, Paul Subject: PNG line 434 30" line? Paul, How many additional feet of clearing would occur for the new pipeline? For example it may now be a 100 ft corridor but the new one will need to widen that to 180 ft (just making up numbers). Thanks John From: Gerlach, Paul To: "Ellis. John" Subject: RE: PNG line 434 30" line? Date: Friday, February 24, 2017 4:57:00 PM Attachments: Alignment Figures 1-3.odf Clearing Limits Figures 1-3.odf Hi John, I was able to obtain some additional information about the project from the engineers. Clearing and grubbing along the new pipeline will vary in different areas (up to 70 feet of permanent clearing and 90 feet of temporary clearing). There are three (3) general scenarios that we describe below, and that are depicted on the attached "Clearing Limits Figures 1-3." Various sections of the proposed pipeline will require one of the three scenarios. In addition, subsequent to our initial correspondence letter, the project alignment has been redesigned in several locations. While most of the alignment is still collocated adjacent to the existing Line 175, there are now eight (8) areas where the proposed pipeline will diverge from the existing easement. These areas are presented on the attached "Alignment Figures 1-3." Clearing Limits Figure 1: The proposed 30 -inch Line 434 pipeline is collocated adjacent to the existing Line 175 (Sutton Line) pipeline, and will require 70 feet of permanent easement (50 feet and 20 feet each side of centerline). The proposed pipeline would be offset from the existing pipeline by 30 feet. Along the existing pipeline side, 50 feet is already cleared within the existing Line 175 easement. The 20 feet of permanent easement located along the other side of the proposed pipeline is also within cleared easement. As such, no permanent clearing is required for the 70 -foot easement around the proposed pipeline for this scenario. In addition to the permanent easement, temporary clearing is required for the construction of the pipeline. The limits of the temporary workspace (TWS) extend 110 feet from the centerline of the proposed pipeline. As such, 90 feet of temporary clearing would occur for this scenario. Post - construction, the TWS will be seeded with a native grass mix and allowed to revert back to a forested condition via natural seed recruitment from the adjacent canopy. Clearing Limits Figure 2: The proposed pipeline is collocated adjacent to the existing Line 1 pipeline, and will require 70 feet of permanent easement (50 feet and 20 feet each side of centerline). The proposed pipeline would be offset from the existing pipeline by 30 feet. Along the existing pipeline side, 50 feet is already cleared within the existing Line 175 easement. The 20 feet of permanent easement located along the other side of the proposed pipeline would be located outside of the existing cleared easement. As such, 20 feet of permanent clearing is required for the 70 -foot easement around the proposed pipeline for this scenario. The limits of the TWS extend 110 feet from the centerline of the proposed pipeline. As such, another 90 feet of temporary clearing would occur for this scenario. Post -construction, the TWS will be seeded with a native grass mix and allowed to revert back to a forested condition via natural seed recruitment from the adjacent canopy. Clearing limits Figure 3: The pipeline is re-routed away from the existing Line 175/Line 1 easement. The re-routed permanent easement will be 70 feet (50 feet and 20 feet each side of centerline). As such, 70 feet of permanent clearing is required around the proposed pipeline for this scenario. The limits of the TWS extend 110 feet from the centerline of the proposed pipeline. As such, 60 feet of temporary clearing would occur for this scenario. Post -construction, the TWS will be seeded with a native grass mix and allowed to revert back to a forested condition via natural seed recruitment from the adjacent canopy. Extra Workspace: Finally, there will be extra workspace (EWS) needed for Horizontal Directional Drilling (HDD) under large wetlands/waters. HDD pads are generally 200 feet by 250 feet. The placement of these HDD pads has not been finalized yet, but it is anticipated that they would be situated both within the existing cleared easement and within un -cleared areas. All clearing for HDDs would be temporary. Please let me know if you have any questions regarding this information, or if there are any specific locations of concern that you would like more specific information about. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Ellis, John [mailto:john_ellis@fws.gov] Sent: Friday, March 24, 2017 11:06 AM To: Gerlach, Paul; Dale Suiter Subject: Re: PNG line 434 30" line? So to summarize, there will be additional clearing for the pipeline but no pine habitat to be cleared was suitable for RCW foraging based on the Nov and Dec 2016 pedestrian surveys. Since it was a late fall, I will double check with our botanist to see if the plant determinations are acceptable or if surveys will need to be conducted during the optimal survey window. Do you know the name of the person who did the plant surveys? John ---------- Forwarded message ---------- From: Gerlach, Paul <naul.gerlachUaecom.com> Date: Fri, Mar 24, 2017 at 11:39 AM Subject: RE: PNG line 434 30" line? To: "Ellis, John" <john_ellis(&,fws.gov>, Dale Suiter <dale_suiterC&,fws.gov> John, Thanks for your response. That is correct — during Nov and Dec 2016 (survey of old proposed alignment, shown on attached Alignment Figures 1-3), and March 2017 (survey of new proposed alignment, shown on the same figures), the entire project area was covered with pedestrian surveys, and no suitable RCW habitat was observed, based on inappropriate stand age, understory thickness, or basal area. Pedestrian surveys for protected plant species were conducted during the same months by the following AECOM staff members: Charles Benton (Nov, Dec) Ron Johnson (Mar) Paul Masten (Mar) Kevin Lapp (Mar) Paul Gerlach (Nov, Dec) Chris Inscore (Nov, Dec, Mar) Peyton Daly (Nov, Dec, Mar) I've also attached our original correspondence letter, for Dale's reference, containing our Biological Conclusions for protected plant species. The figures shown in this letter show the old alignment, but the revised alignment can be found on the attached Alignment Figures 1-3. Please let me know if you need any additional information or if you have any questions. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Ellis, John [mailto:john_ellis@fws.gov] Sent: Tuesday, March 28, 2017 7:52 AM To: Gerlach, Paul; Leigh Mann Subject: Fwd: PNG line 434 30" line? Paul, The Service concurs with your determinations for listed species. John From: Gerlach, Paul To: "Ellis, John"; "Leigh Mann" Subject: RE: PNG line 434 30" line? Date: Tuesday, May 02, 2017 10:26:00 AM Attachments: Figure 1.odf Figure 2.odf project report line 434 richmond mill lake 7091 7091.12df Hi John, I'd like to give you an update on the Piedmont Natural Gas (PNG) Line 434 natural gas pipeline project that you reviewed a couple of months ago. PNG is now proposing to reroute approximately 5 miles of the alignment in Scotland County, as shown on the attached Figure 1(Richmond Mill Lake Reroute). Last week, AECOM surveyed this reroute study area for listed threatened and endangered species and habitat. No protected plant species were observed during this survey; however, possible habitat for the red -cockaded woodpecker (RCW) was observed in two locations along the new proposed alignment. These locations are shown on the attached Figure 2. The first area, labeled as "future potential RCW foraging habitat," had the following characteristics: • Basal area was averaged to around 100 sgft/ac., using a 10 factor prism. • Understory was variable in appearance. Some areas were sparse, with wiregrass present. Other areas were thick with blackberry, muscadine, and honeysuckle vines, 4-6 ft tall. • Mid -story was also variable. In some areas, mid -story was sparse to non-existent. Other areas had dense hardwood mid -story. • Based on the private lands guidance in the RCW Recovery Plan (USFWS 2003), this area meets the stand age requirement for foraging habitat — stand age was about 30 years. • It does not meet any other requirements (ideal basal area, lack of hardwood mid -story, prescription burning). • Based on the RCW Recovery Plan, this would qualify as "Future Potential Habitat" if it were thinned and burned AND if there is a cluster found within 0.25 mile and another foraging stand or existing cluster within 200 ft. The area labeled as "Suitable RCW Nesting Habitat" had the following characteristics: • Ideal appearance for nesting habitat. However, AECOM did not measure basal area, tree age, or DBH. Estimated 60-70 sgft/ac. basal area, no mid -story, sparse understory (wiregrass), 80 - year -old+ longleaf. Appears to be maintained with prescribed fire, as there were fire lines in place. This would also meet requirements for foraging habitat, if it is within 0.25 mile of an existing cluster and 200 ft from existing foraging habitat or an existing cluster. Additionally, according to the NC NHP, there is a current element occurrence of RCW (EO ID 24044) located approximately 0.6 mile north of the study area, as shown on the attached figures. AECOM confirmed the presence of individual birds and active RCW nests at this location, directly adjacent to McFarland Road, on April 25, 2017. No active nests or individuals of RCW were observed within the project study area. Based on our habitat observations within the reroute study area, and the lack of active nests found within the immediate vicinity, AECOM proposes changing our original biological conclusion for RCW from No Effect, to May Affect, Not Likely to Adversely Affect. We would appreciate your review of this reroute area, as well as any comments regarding our biological conclusion and whether any additional surveys may be required. PNG has a tight timeline for this project, so we would like to notify them as soon as possible whether the project is in compliance with the ESA. Please let me know if you have any questions or if you need any additional information. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach e aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Gerlach, Paul Sent: Wednesday, March 29, 2017 2:31 PM To: 'Ellis, John'; Leigh Mann Subject: RE: PNG line 434 30" line? John, Thanks. We'll be sure to let you know if anything changes with the project plans. We appreciate your review of this project. From: Gerlach, Paul To: "Ellis, John" Cc: John Hammond; Leigh Mann Subject: RE: PNG line 434 30" line? Date: Friday, June 02, 2017 12:06:00 PM John, Yes, thanks very much — we'll let the client know that surveys will need to be conducted. Have a great weekend, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach e aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Ellis, John [mailto:john—ellis@fws.gov] Sent: Friday, June 02, 2017 10:42 AM To: Gerlach, Paul Cc: John Hammond; Leigh Mann Subject: Re: PNG line 434 30" line? Paul, I conferred with John, and we recommend that red cockaded woodpecker surveys be conducted in a half mile radius of any pines 10" dbh or greater that are to be removed in the area of suitable habitat. The information will be used in our review of the Sect 7 determination. Will this be sufficient? John On Fri, Jun 2, 2017 at 9:49 AM, Gerlach, Paul <paul.gerlach(&,aecom.com> wrote: Hi John, Thanks for your response. To answer John's questions, yes, pines greater than or equal to 10 inches dbh will be removed in the area of suitable nesting habitat for both the permanent easement (approximately 70 feet maximum) and temporary easements (approximately 90 feet maximum). A survey for RCW was only conducted within approximately 300 -feet of the proposed centerline of the pipeline. Additional survey area (e.g. 1/2 mile radius of the trees to be removed) was not in our scope -of -work. Our current coordination with your agency on this issue is to determine if this additional survey area for RCW is recommended by the USFWS. If it is recommended, we would appreciate this recommendation be provided in writing (email is fine), so that we may inform our client of the additional scope -of -work required to satisfy the regulatory requirements for this project. Please let me know if you need any additional information. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach e aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Ellis, John [mailto:john ellis(a)fws.gov] Sent: Thursday, June 01, 2017 4:36 PM To: Gerlach, Paul; John Hammond Cc: Leigh Mann Subject: Re: PNG line 434 30" line? John H. and I spoke and he asked if pines greater than or equal to 10 inches dbh will be removed in the area of suitable nesting habitat. If so, did you all survey a 1/2 mile radius of the trees to be removed? John From: Gerlach, Paul To: "Ellis, John" Cc: John Hammond Subject: PNG Line 434 RCW Survey Date: Friday, June 16, 2017 2:10:00 PM Attachments: PNG Line 434 RCW memo 2017 06 16.pdf Hi John, In accordance with your June 2 request for RCW surveys along areas of the Piedmont Natural Gas (PNG) Line 434 project, and on behalf of PNG, AECOM recently conducted surveys within a half -mile radius of any pines 10 inches DBH or greater that will be removed within the area of suitable habitat. The results of these surveys are summarized in the attached memo. Please let me know if you have any questions regarding this information. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 paul.gerlach aecom.com AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com From: Ellis, John To: Gerlach, Paul Cc: John Hammond Subject: Re: PNG Line 434 RCW Survey Date: Wednesday, July 05, 2017 10:02:56 AM Paul, Thanks for the information. The Service concurs with your "no effect" determination. John Ellis On Fri, Jun 16, 2017 at 2:11 PM, Gerlach, Paul <paul.gerlach4aecom.com> wrote: Hi John, In accordance with your June 2 request for RCW surveys along areas of the Piedmont Natural Gas (PNG) Line 434 project, and on behalf of PNG, AECOM recently conducted surveys within a half -mile radius of any pines 10 inches DBH or greater that will be removed within the area of suitable habitat. The results of these surveys are summarized in the attached memo. Please let me know if you have any questions regarding this information. Thanks, Paul Gerlach Environmental Scientist D 1-919-239-7133 AECOM 701 Corporate Center Drive, Suite 475, Raleigh, North Carolina 27607 T 1-919-854-6200 www.aecom.com