20181598_Att. 50 - USFS comments on Draft FEIS (M_20160222

USDA United States Forest l'Vatior�al Farests in Nart� Carolina�
� Departme�t of Ser��ice Supervisor's Office
Aeric�lture
Mr. �'ed Devens
Praj�ct D�ve�opment Er�gineer
North Caralina Department of Transp�rtati�n
l 548 Mail Service Cente�
Italei�h, NC 27699-1 S48
�}ear Mr. Devens:
Attachment 50
16fl ZdI.LiCOA ST STE A
ASAEVIL�E NC 28$Ol-� 082
$2$-257-4204
I'ile Code: 2730
Date: �arch b, 2U15
Enclasec� are iF►e �'orest Service comments an ihe Draft Fina] �nviro��ental Impact S�atement fpr
�[JS 70 I�avelock �3ypass in Craven County STIP R-Y015. Please contact Karen Coinpton vf my
staff at $2$ Q257�4230) ta discuss ar clar�fy ou� comments on the report. Thar�k you �or t�e
oFport�ity to comanent om this repart.
Sineerely,
� � �f ��+�
!f
S'�IN M. BAIL
Forest 5upervisor
cc: Arny Sackaroff, Stantec
Jim C�umm, District Ranger, Croatar� 1'�ational �'ot'est
Enclasure
� ��
Caring Por t��e Lfuid antl Servd�7g 1'eople Pr�mea on Recyc�e� �a�e�

USFS COMMENTS ON THE DRAFT FEIS
US 70 Havelock Bypass
Craven County, NC
STIP No. R-1015
Review completed March 6, 2015
General Comments
Al) maps included in the FEIS must show the Croatan National Forest (CNF) boundaries.
Indirect and cumulative effects to all biological resources must be disclosed in the FEIS. Using a chart or
a matrix is one way to accomplish this for cumulative effects. The various impacts could be given for this
project and for other past, present, or foreseeable actions. A table similar to Table 4.21.1 with
additional data could be used for this purpose.
PROJECT COMMITMENTS
Proiect Development and Environmental Analvsis Sheet 1 of 7: Item 2: Pertaining to spring-flowering
golden rod—Mitigation will include plantings either from seed and/or plugs as well as monitoring for
successful survival. Planting failures will be replanted until establishment is successful.
Sheet 1 of 7: Item 2: Pertaining to Leconte's thistle—Change to Item 3{and renumber all succeeding
numbers under this heading). Mitigation will also include monitoring for successful survival. Planting
failures will be replanted until establishment is successful.
Roadside Environmental Unit & Division Z Sheet 4 of 7: The FEIS states "...NCDOT will use seed mixes of
native grasses and forbs or other non-aggressive, NNIS on NFS lands:' We suggest using the term non-
native species instead of non-aggressive, NNIS. By nature a NNIS is considered aggressive.
Risht-of-Wav Unit & Lacation and Survevs & Roadwav Desi�n & Construction Sheet 3 of 7: The USFS
will set the price for the timber through appraisal at rates effective at the time the timber sale contract
is executed not at the time of the right-of-way transfer. Comment also applies to footnote #2 in Table
4.12.2.
Divisiun 2 Sheet 7 of 7: We would like the following information associated with bypass closure for
burning nutlined and included in the Record of Decision: gates/enforcement, advance signing, advance
notification, and timing windows.
SUMMARY
Table S.1 cont. p. S-8: Footnote #10 states "...outside shoulder widths increased from 10 feet to 12 feet
with paved shoulders increasing from 4 feet to 10 feet." Why did the paved shoulder width increase
from 4 feet to 10 feet and was this change discussed and approved by the merger team?
5.8 SUMMARY OF IMPACTS FRAM THE PREFERR�D ALTERNATIVE
Indirect Effects p. 5-20: The Indirect and Cumulative Effects (ICE) Analysis that is referenced here is not
a true disclosure of indirect and cumulative effects for this project. The screening matrices in the ICE

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 2
document focus totally on land use and social factors. There is no analysis of indirect and cumulative
impacts to the natural environment and natural resources in the ICE Analysis.
Cumulative Effects p. S-20: The FEIS states "Because minimal indirect impacts are anticipated, the
cumulative effect of the. project, when considered in the context of other past, present and future
actions, and the resulting impact on notable human and natural factors should be minimal. Therefore,
any contribution of the project to cumulative impacts resulting from current and planned development
patterns is expected to be minimal:' First, having minimal or no indirect impacts does not preclude
having cumulative impacts. (A cumulative impact is the impact on the environment, which results from
the incremental impact of the action when added to other past, present, and reasonably foreseeable
future actions regardless of what agency (Federal or non-Federal) or person undertakes such other
actions. Cumulative impacts can result from individually minor but collectively significant actions taking
place over a period of time (40 CFR § 1508.7)]. Both direct and indirect impacts from the proposed
action must be taken into account as well as other past, present, and reasonably foreseeable actions
when analyzing cumulative effects.
Secondly, cumulative effects must be considered separately for each individual resource and cannot be
lumped together for a determination of cumulative effects for the entire project.
Hazardous Materials p. 5-23: Could the USFS get a copy of the geoenvironmental investigation report
completed for the Craven County Waste Transfer facility. The paved surface located on this site
contains oils and other potentially hazardous chemicals that have penetrated into it over the years of
using the facilityr. Were these potentially hazardous materials tested for or detected during the
geoenvironmental investigation?
USFS Rare Species p. S-26: Ensure that the numbers shown here are consistent with the numbers shown
Sections 3 and 4 of this document and with numbers presented in the Biological Evaluation Report for
the US 70 Havelock Bypass R-1015 (July, 2014).
S.9 ACTIONS REQUIRED BY OTHER FEDERAL AND STATE AGENCIES p. 5-27: The FEIS states "It is
currently proposed that the Croatan Wetland Mitigation Bank will provide mitigation for impacts to
USFS lands and land management activities." The USFS does not consider the Croatan Wetland
Mitigation Bank (CWMB) compensation for the loss of 75 acres of mature longleaf pine/wiregrass
communities. The USFS will continue discussions with NCDOT on compensation for the loss of longleaf
pine.
Table 5.21MPACT SUMMARY TABLE FOR THE PREFERRED ALTERNATIVE p. S-28: The footnote numbers
do not match the reference numbers in the table.
2.0 DESCRIPTION OF ALTERNATIVES CONSIDERED
Pro�ect Studv Area p. 2-1: We do not consider the dominant land use of The Croatan National Forest
(CNF) to be siiviculture. While timbe� production is an important part of the use of the CNF, the
protectEon of watersheds, terrestrial and aquatic habitat, and recreation are also important uses of the
CNF.
2.1 NO-BUILD ALTERNATIVE p. 2-2: It needs to be made clear that the purpose of the CWMB is "for use
in providing in-kind compensatory mitigation for unavoidable wetland impacts on NCDOT projects for

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 3
which no on-site, in-kind mitigation is available' (Final Mitigation Plan, Croatan Wetland Mitigation Bank,
Craven County, North Carolina; April, 2002, p.1). The CWMB is not being transfer to the USFS "for
management including the management of RCW and rare plant habitaY' as stated in the FEIS.
The CWMB does not potentially provide management for RCW since it will be impractical to manage for
longleaf pine savanna and/or flatwoods. The only two rare plant species documented in the CWMB,
Florida peat moss and Loomis's loosestrife, are being recommended for removal from the USFS Region 8
sensitive species list which is now anticipated to be completed prior to the end of the 2015 calendar
year. These two species are abundant enough across other portions of the CNF that there is no concern
for their viability; however, we need to administratively assess them as sensitive until they are formally
removed from the list by the regional office in Atlanta.
2.10.2 Basis for Selection p. 2-39: A prescribed burning plan is also vita) to some rare plant populations
located in the corridor.
The FEIS states that "the existing Croatan Wetland Mitigation Bank (CWMB) provides over 3800 wetland
acres that are protected in perpetuity". Assuming these are the acres that were certi�ed as mitigation
credits, the USFS still cannot reconcile how NCDOT has determined that over 1000 acres within the
CWMB can be managed for RCW. If these acres have characteristics that qualify them for wetlands
mitigation credit this does not seem compatible with active and effective management as RCW habitat.
Table 2.10.5 COMPARISON OF BYPASS ALTERNATIVES p. 2.47: The Total Cost{sj show in the table are
actual costs not "in millions" as indicated.
3.0 AFFECTED ENVIRONMENT
3.3 COMMUNITY FACILITIES
3.3.2 Parks & Recreation Facilities p. 3.32: The CNF has several designated recreation areas near the
proposed project area. In addition to the Fishers Landing Picnic area just north of the Croatan Ranger
Station there is: 1) Neuse River/Flanners Beach Recreation Area, just south of the Croatan Ranger
Station. This Development Scale 4 area includes a 40-site campground with showers and flush
restraoms; a large picnic area with access to Neuse River; and a three-mile bike/hike trail, part of which
is wheelchair-accessible. Plans are to increase the mileage of this bike/hike trail; 2) Just off NC 101 near
Cherry Point MCAS on FR 1717 is a deep water boat launch, Cahooque Creek, operated in partnership
with NCWRC; and 3) Nearby, off NC 101 on FR 132 are a sequence of recreation opportunities and sites
including the Neusiack Trail, a part of the Mountains to the Sea National Recreation Trail, is a long
distance trail that runs through NFS lands between the Newport and the Neuse rivers. One trailhead is
off NC 101 and one is at Pine Cliff Picnic Area; Pine Cliff Picnic Area, a Development Scale 3 site, is
located at the end of FR 132 on the Neuse River; and also on FR 132 is the Pinecliff Horse Trailhead, a
Development Scale 3 site, sized for more than 20 horse trailers and vehicles to park for day use on the
14-mile Pinecliff Horse Trail Complex in the same vicinity.
Adding wildlife watching and fishing to the list of dispersed recreation activities on the CNF would more
accuratefy describe the dispersed recreation activities in the area. Cansider adding "although it is open
for a wide range of dispersed recreations activities" to the sentence "Currently there are no developed
recreation areas in the vicinity of the proposed bypass:'

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 4
3.6 UTILITIES �
3.6.1 Electric Power Transmission Service p. 3.39: Exhibit 3.3.1 p. 3-33 referenced here has a lot of
information on it and it is very difficult to identify the location of powerlines. A map with CNF
boundaries that shows just the powerlines such as those included for sewer and municipal water lines
would make it easier to identify which powerlines cross NFS lands.
3.6.5 Communications p. 3-40: Please include a map with CNF boundaries showing the location of the
Centurylink communication lines. If these lines are located on CNF and need to be relocated as a result
of this p�oject, coordination with the USFS will be required. �
3.9 HAZARDOUS MATERIALS
Craven Countv Waste Transfer Facilitv p. 3-60: See comments under Hazardous Materials p. 5-23.
3.11 PRIME, IMPORTANT, AND UNIQUE FARMLANDS p. 3-70: The FEIS states "the Croatan National
Forest contains large areas of prime and state-important farmland soil types. However, since it is public
land, these areas are not considered prime farmlands". Please provide a reference where public land
cannot be considered as prime farmland.
3.13 BIOTIC RESOURCES
3.13.3 Protected Lands
State/National Forests p. 3-99: The FEIS states "the forest contains numerous natural features
including pocosin habitat, estuaries, and a large number of carnivorous plants:' While estuaries are
present on the CNF they are not a common feature. The most dominant plant communities on the CNF
are pocosin, pine flatwoods, and pine savannas.
pp.3-99 — 3-100: Habitat is provided on the CNF for two federally endangered species; the red cockaded
woodpecker (RCW) and rough-leaf loosestrife.
Gamelands p. 3-100: Please change the term fishermen to anglers. The CNF are gamelands identified
by the NC Wildlife Resources Commission (NCWRC). The USFS manages these gamelands not the
NCW RC.
Preservation Areas p. 3-100: The NC Natural Heritage Program now refers to heritage areas as "natural
heritage natural areas" (nhna). They are no longer called "significant natural heritage areas"(snha).
Please make changes in the document to reflect this change. There is no "Croatan Station Flatwoods
and Powerline Corridor" NHNA; it is correctly referred to as the "Havelock Station Flatwoods and
Powerline Corridor Natural Area. Please include maps with CNF boundaries showing the location of the
various NHNAs located in the project study area.
p. 3-101: The Pine Flatwvod (Coastal Plain Subtype) should be referred to as Mesic Pine Savanna
(Coastal Plain Subtype). Neither the NC Natural Heritage Program nor the CNF uses the term flatwoods.
Havelock Station Flatwoods and Powerline Corridor: The powerline corridor did not create savanna. It
maintains a savanna condition which may actually have been destroyed when the powerline was first
installed. The savanna and flatwoods support 18 state rare species including five butterflies, three
birds, two reptiles, and eight plants.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 5
Masontown Pocosin Natural Area: Pacosins do not harbo� many rare species and only have three plant
communities with their various subtypes— low and high pocosins as well as pond pine woodlands.
Species diversity is high right after a fire and declines thereafter. In general, the greatest likelihood of
locating rare species is within the ecotone of pine savanna and low or high pocosin.
Croatan Wetland Mitigation Bank (CWMB) pp. 3-101— 3-105: As NCDOT knows the MOU for the
CWMB is currently being updated. The discussion on updating the MOU includes debate on the
applicability and management of RCW habitat, both for the potential capacity and the feasibility of
management considering the existing infrastructure.
Of the 1041 acres of pine dominated acres, the majority of it occurs on soils appropriate either for very
sparse to no tree cover (pocosins) or pond pine woodlands. As previously stated it will be very difficult
to burn these wet areas on a 2-3 year burn cycle which is even indicated within the November 2012
document assessing "Red-Cockaded Woodpecker Management Plans for the CWMB, Craven County,
NC". In fact on page 14 it notes that pine stands developing on hydric soils on the CWMB may never
meet RCW Standard for managed stability (SMSj and Recovery standard guidelines (RSG) because of
mid-story density and height. Over 904� of the identified 1041 acres are on hydric soils.
It is highly doubtful and speculative to suggest the CWMB can provide management for RCW. The RCW
analysis for that area indicated it would not be able ta provide nesting trees for 60 plus years and that it
would require both fire and perhaps othe� vegetation management which may not be possible with the
present road system and wetland designations. It is not certain that longleaf pine can be established on
the CWMB. Potential natural vegetation for the CWMB, based on soils and fire compartments, for
longleaf pine habitat is not substantial. While it would require management such as prescribed �res as
well as thinning, which the USFS thinks would be difficult to implement, it would still only results in � 8R6
of the mitigation bank. Approximately 899'0 of the CWMB is only suitable for pocosin or pond pine
woodlands. Thus it is doubtful the CWMB will ever provide a longleaf pine/wiregrass component to add
to the remainder of the Croatan NF.
3.151URISDICTIONAL ISSUES
3.15.1.1 Streams pp. 3-112 — 3-126
3.15.1.2 Wetlands pp. 3-127 — 3-131
Identify which streams and wetlands are in whole or in part located on NFS lands.
3.15.3 Protected Sqecies
3.15.3.1 Section 7 of the Endan�ered Species Act
Red-cockaded woodpecker (RCW) p. 3-137: The RCW Territory Analysis (NCDOT, 2014) was also
completed to determine if the CNF was meeting its obligations under the Recovery Plan for the Red-
cockaded Woodpecker (2003). Review by USFS biologists of this document and other documents
evaluating RCW within the proposed bypass has determined that the CNF will meet its obligations under
the RCW recovery plan without requiring mitigation for the loss of RCW habitat.
3.15.4 USFS Rare Species
3.15.4.1 Biola�ical Evaluation Reaort for NFS Lands p. 3-145: Add "across the CNF" to Objective
number 1 for writing the BE.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 6
Survey of Potential Habitat for Rare Species
Plant Species p. 3-149: There is a discrepancy between the BE and the FEIS in which community to
eliminate one species. In the BE Thalictrum macrostylum is associated with basic mesic forest or marl
while in the FEIS it is eliminated from further review since it is associated with tidal swamps. Essentially
a case could be made for either being correct; however the BE and FEIS should agree on the
classification.
Table 3.15.5 USFS RARE PLANT SPECIES FOR THE CROATAN NATIONAL FOREST
pp. 3-150— 3-154: Table 3.15.5 is not correct. It has 99 species listed with 71 identified with present
habitat, not 107 as stated on page 3-148. There are 107 rare plant species on the current Croatan NF
list. The table submitted for the revised BE in July of 2014 is correct as is the specific BE for the �
Geotechnical investigation completed in November of 2014. Please update the table with that
information. In the FEIS and the attached BE it indicates 35 species were eliminated due to lack of
suitable habitat within or nearby the evaluation area. However there are only 34 species listed as being
excluded (pages 3-148-150) based on the following generalized habitats: Maritime (7 species), Tidal
swamps (10 species), marl or basic communities (5 species), cypress savanna or bays (10 species), and
sandhills or pine barrens (2 species). We suggest Utricularia olivacea be initially excluded and grouped
in the cypress swamps/limesink pond paragraph on page 3-149. If completed this would make the
reference to 35 species being initially dropped as correct.
To also make these numbers correct in Appendix B list of Croatan NF Rare plants for the July 2014 BE,
Sporobolus pinerorum, present in wet savanna habitat should be listed as potentially suitable habitat.
This is correctly discussed on page 31 in the BE. Conversely we suggest Utricularin olivacea should not
be listed as suitable habitat in Appendix B since it occurs in limesink ponds or beaver ponds. This species
was not discussed in the text of the BE describing the 72 species that were surveyed for. The BE should
be updated by discussing Peltrandra sagittifolia as well as Utricularia olivacea. A spreadsheet with the
list of the 107 in the different categories with suggested changes is provided. �
Table 3.15.6 USFS RARE ANIMAL SPECIES FOR THE CROATAN NATIONAL FOREST
pp. 3-156 — 3-160: Table 3.15.6 is not correct. It has 91 species listed with 34 identified with present
habitat, not 92 as stated on page 3-154 with 56 dropped with no habitat present as stated on page 3-
154. Actually there should be 93 species by including northern yellow bat and northern long-eared bat.
The table C-1 submitted for.the BE for the Geotechnical investigation completed in November of 2014 is
correct. Please update the table with that information. If a spreadsheet with this list is needed, we can
provide it.
3.16 VISUAL AND AESTHETIC VALUES p. 3-166: Could you include a copy of the "Havelock Bypass,
Croatan National Forest, Analysis of the Scenic Resource" report prepared by Kathy Ludlow, Landscape
Architect, November 1996 in the Appendices.
4.0 ENVIRONMENTAL CONSEQUENCES
4.1.2 Consistencv with Land Use and Transqortation Plans p. 4-2: Coordination with the CNF on the
proposed projects has included assessing the anticipated impacts to many resources on NFS lands. We
have coordinated on impacts to various resources including wildlife and rare species habitat and
management, vegetative communities, visual resources, recreation, aquatic resources, air quality, soils,
and archeology.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015
4.1.3 Transpartation Impacts
4.1.3.3 Rail Travel Patterns p. 48: Final design of the railroad crossings are discussed in Chapter 2.7 not
Chapter Z.10.
4.2 SOCIOECONOMIC IMPACTS
4.2.1 Relocations: p. 4-9: The Craven County Waste Transfer Facility is under a special use permit with
the USFS not a lease agreement.
4.3 COMMUNITY FACILITIES
4.3.4 Parks & Recreation Facilities: pp. 4-17 — 4-18: See comments concerning dispersed recreation
activities on the CNF under Section 3.3.2.
While there are no direct impacts to Croatan NF's recreation "facilities" in the Preferred Alternative, it
actually increases access into parts of the Forest that previously had few roads, thus increasing
opportunities for expanding dispersed recreation. The addition of the CWMB to the CNF could increase
the percentage of Semi-primitive recreation opportunities in the forest. These Semi-primitive
classifications are currently provided in onfy 159'0 of the Forest (see Croatan NF LRMP, Forest Plan
Appendices, December 2Q02, pp. 91 and 92, Appendix G: Recreation Opportunity Spectrum), and have
been identified as one of the unique contributions of Southern national forest lands. The existing 5.1-
mile road system in the CWMB would provide access into this potential new part of the forest.
4.6 UTILITIES
4.6.1 Electric Power Transmission p. 4-20 and 4.6.5 Communications p. 4-21: The location of all utilities
needing to be moved on or off of NFS lands needs to be disclosed in the FEIS. We need maps identifying
the location of any facilities needing to be moved as well as the length of any new lines to be located on
NFS lands. Any new or moved utilities that need to be located on NFS lands can only be permitted by
the USFS. Utility companies cannot use NCDOT easements on NFS lands.
4.10 PRIME, IMPORTANT, AND UNIQUE FARMLANDS p. 4-28: See comments under 3.11 RRIME,
IMPORTANT, AND UNIQUE FARMLANDS p. 3-70.
4.12 BIOTIC RESOURCES
4.12.1 Terrestrial Communities
4.12.1.1 Dired impacts to Terrestrial Communities pp.430 — 4-31: The narrative description at the
bottom of page 4-30 does not match the information given in Table 4.12.2 Terrestrial Community
Impacts in the Croatan National Forest. The table shows 220.8 acres not 209 acres of NFS lands
categorized as natural vegetative communities.
4.12.1.2 Indirect Effects to Terrestrial Cammunities p. 4-31: Change "native seedling mix" to "native
seed mix" in the last paragraph.
4.12.3 Wildlife Communities
4.12.3.1� Habitat Connectivitv p. 4-33: Standard control access fencing is not tall or sturdy enough to
deter most large animals found in the area from climbing or jumping over.
4.12.3.2 Habitat Alteration p. 434: It should be stated that many non-native invasive plant species
thrive on edge habitats and the habitat alteration increases the suitable habitat for invasion by various
species such as multiflora rose, Johnson grass, Chinese wisteria,lapanese honeysuckle, and mimosa.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 8
4.12.3.3 Measures to Minimize Fra�mentation and Alteration p.4-36: See comment unde� S.9
ACTIONS REQUIRED BY OTHER FEDERAL AND STATE AGENCIES p. S-27 concerning the CWMB serving as
compensation for loss of Longleaf/Wiregrass communities.
4.12.4 Protected Lands
4.12.4.1 State/National Forests p. 436: Impacts acres on CNF should be 239 acres to match what is
shown in Table 4.12.2.
4.12.4.4 Preservation Areas: p. 4-37: Rare plant mitigation will be accomplished through plantings
either from seed and/or plugs as well as monitoring planting success. Planting failures will be replanted
until establishment is successful. '
4.12.4.5 Croatan Wetland Miti�ation Bank (CWMB) p. 438: As previousfy stated, it is highly doubtful
and speculative to suggest the CWMB can provide management for RCW. See comments Croatan
Wetland Mitigation Bank (CWMB) pp. 3-101— 3-105. The USFS does support the statement in the FEIS
that "long term RCW management of the CWMB has the potential to provide a net increase to the
Croatan National Forest RCW population in excess of the Recovery Plan goals".
p. 439: The FEIS states "Document records associated with the CWMB clearly establish longleaf pine
and RCW management as compatible and allowable activities on the property". The USFS is not
convinced that even though some management activities are allowable within the CWMB that they
could actually achieve CNF goals for longleaf pine and RCW management.
While 54% of the CWMB may have mineral soils over 90°Y of the CWMB have hydric soils also. The
potential natural vegetation for the majority (3726 or 924�0 of the area) of the CWMB is pocosin and
Pond Pine woodlands. Potentially 49'0 or 146 acres of the area has soils identified in the RCW
management plan for the CWMB that generally support various longleaf /wiregrass communities on the
CNF or have been identified as desired management goals based on historical potential natural
vegetation. Achieving this potential would require management, either prescribed burning, and mid-
story and over-story management, which as previously stated would be difficult to achieve based on the
existing infrastructure in the CWMB and the capacity to achieve such intensive management by CNF
personnel. Thus for the FEIS to state "the CWMB has the potential to establish substantial areas of
mixed pine flatwoods communities with longleaf pine as a dominant component" is erroneous. More
existing mature or maturing longleaf pine/wiregrass communities would be lost to construction of the
bypass than could be replaced with the CWMB and if replaced would require many years and substantial
personnel time and project dollars.
p. 4-40: The FEIS states "the CWMB furthers the overall management mission and objectives of the
2002 Land and Resource Management Plan". The CWMB does meet some of the objectives of the Land
and Resource Management Plan for the CNF; however, the sentence above is an over statement.
4.14 JURISDICTIOWAL ISSUES
4.14.1 Wetland and SurFace Water Imcacts pp. 4-44-4-46: Identify which streams and wetlands are in
whole or in part located on NFS lands.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 9
4.14.2 Wetland and Stream Mitigation
Croatan Wetland Mitisation Bank (CWMB1
Table 4.14.4 CROATAN WETLAND MITIGATION BANK COMPONENTS p. 4-49
Table 4.14.5 CROATAN WETLAND MITIGATION BANK STREAM AND WETLAND CREDITS p.4-49
Information given in these tables does not match the figures given on pages 9 and 10 of the Croatan
Mitigation Bank Addendum to NCDOT UMBI (May 2Q09).
p. 4-49: Please clarify how 3894.fs0 acres of the CWMB are being used for wetlands and stream
mitigation credits and 1041 of these same acres can also be used for longleaf pine and RCW
management (p. 4-38) without jeopardizing the mitigation credits. These two uses of the same (and
seem to be in conflict.
4.14.4 Protected Species
4.14.4.2 Red-cockaded wcodaecker (RCW) Impact Analvses
4.14.4.2.7 Croatan Wetland Miti�ation Bank (CWM61 p.4-71: The report referenced in this section
{Red-cockaded Woodpecker Management Plan for the Croatan Wetland Mitigation Bank, Craven
County, North Carolina; November 2012) states "that with proper management all pine stands on the
CWMB could provide suitable foraging habitat with pockets of suitable nesting habitat" also says
"pine stands developing on hydric soils may never meet [RCW] SMS and RSG guidelines because of
midstory density and height" (page 14). In general pine stands developed on wetter sites develop a
denser understory and require more frequent prescribed burns to maintain an open understory. That
document also states "Without reintroduction of fire at a landscape level, the ability to enhance and
maintain RCW habitat is limited. Without fire, pine dominated communities will shift towards hardwood
dominance as pines are cut or die ouY' (page 17). Given that it would take 30-60 years befo�e any of the
potential clusters could provide suitable nesting trees the potential for the CWMB to provide suitable
RCW clusters is overstated.
4.14.4.2.9 Summarv of RCW Impacts p. 4-73: The USFS does not consider the Croatan Wetland
Mitigation Bank (CWMB) compensation for the loss of 75 acres of mature longleaf pine/wiregrass
communities. The USFS will be continuing discussion with NCDOT on compensation for the loss of
longleaf pine.
4.15.4 USFS Rare Species
4.15.5.1 Biolo�ical �valuation Report for NFS Lands p. 4-74: As previously stated remove Utricularia
olivacea from the list of excluded species (BE, pp. 74-76). The number of excluded species following the
survey should be 51 rather than 52 stated on page 4-74 in the last paragraph as well as 72 species with
potential suitable habitat versus the indicated 73 species. This corresponds with the number previously
stated on page 3-150.
Need to determine if any further analysis is needed for Persicaria hirsuta. David Dumond, who
conducted a portion of the plant survey for ESI, commented in the NC rare plant list serve he had seen
Persicaria hirsuta in a few places on the Croatan NF during the last 10 years. The reference was to a
roadside ditch along Cat�sh Lake road and in a beaver impoundment along Southwest Prong of Slocum
Creek west of Havelock. This information needs to be updated and assessed for the BE. If you need the
rare plant list serve information please contact Gary Kauffman.

Forest Service Review 03/2015 of Draft FEIS for STIP No. R-1015 10
Yellow Fringeless Orchid p. 4-78: Platanthera integra First paragraph new info for indirectly affected
population: Four individuals were located in 2014 within this right-of-way at three separate microsites
not previously known for this species.
3`d paragraph down Platanthera integra counts at Little River savanna now 27 (resurveyed in 2014).
Hookers Milkwort p. 4-79: Polygala hookeri This species is a Region 8 sensitive species, not a locally
rare (Ir) species. It should be stated the single occurrence in the potential indirect effects impacted area
is the largest known population on the CNF. It was conservatively estimated with greater than 1000
individuals in 2Q13.
LeConte's Thistle p, 4-82: Cirsium lecontei Areas were resurveyed in 2014--- Eos 12, 32,17, 24, and 29.
— 252 plants were recorded. An additional 55 plants have been recorded within Eos 26 and 27 in either
2013 or 2004.
Summary of Potential Effects on USFS Rare Plant Species pp 4-93-4-94: Corrections needed: Thirty-
five species were initially dropped from further consideration. Potentially 72 species were identified for
further evaluation. Fifty-one species were excluded after suroeys did not document individuals or
suitable habitat.
Terrestrial and Aquatic Animal Species p. 4-97: Remove northern long-eared bat from the list of rare
species considered. This species was considered under the Protected Species Section 4.14.4.
14.15.5.2 Mana�ement Indicator Species
longleaf pine (Pinus palustris) pp. 4-114-4-115: It should be noted that the loss of longleaf pine under
the preferred alternative would result in the loss of 75 acres of longleaf pine greater than 80 years old.
While the CNF is increasing its longleaf pine component by restoring (versus conversion used in FEIS)
loblolly pine dominated stands to longleaf pine, it is not reducing existing longleaf pine dominated
stands such as would occur with the construction of the bypass. While the amount of longleaf pine
dominated stands lost with the bypass construction will gradualiy be picked up with other longleaf pine
plantings (within 3-4 years as stated) across the CNF, the loss of older longleaf pine stands will not be
replaced for numerous decades. It is highly uncertain longleaf pine stands can be established in the
CWMB given existing infrastructure and CNF capacity for maintaining prescribed burns. Based on plant
community models tying the existing soil to the vegetation only 146 acres could support a longleaf pine
dominated stand which could be the undetermined acreage but even this number is optimistic given
difficulties in getting the stands established. Prior history of pine planting failures in the CWMB suggests
there should be no assurance any longleaf pine establishment will be completed within the mitigation
bank.
The USFS suggests that the loss of the older pines should be mitigated by vegetation management
activities within and surrounding recently and previously active RCW clusters, in particular clusters 58
and 901. While this mitigation would not make up for the loss of the older longleaf pine stands it will
improve the structure, reduced mid-story density and greater wiregrass/forb component, of existing
longleaf pine and provide more suitable habitat for RCWs.
Wiregrass (Aristida stricta) p. 4-115: The citation requested from Gary Kauffman:
" Clewell, A.F. 1989. Natural history of wiregrass (Aristida stricta Michx., Gramineae). Natural Areas
lourna/9:223-233".

Forest Service Review 03/2015 of Draft fEIS for STIP No. R-1015 11
As previously stated we think it is inaccurate to assume the CWMB can contribute to wiregrass
establishment and increases on the Croatan NF. As stated above it would be better to improve the
existing condition, either through thinning, herbicide activity or prescribed burning, within existing
longleaf pine stands which therefore will increase the wiregrass component.
4.15.5.3 Mi�ratarv Birds p. 4-116: NFS lands included for direct impacts for the Preferred Alternative
shauld be 239 acres (per Table 4.12.2j.
4.15.5.4 Miti�ation Measures for Imaacts to NFS lands
4.15.5.4.3 Herbicide Use Saeci�cations p. 4-122: Potential impacts to the various resources from the
use of herbicides needs to be disclosed in the FEIS in addition to the mitigation measures for their use.
This can be a summary of the information disclosed in the "Final Herbicide Evaluation Report" (lune
2014�. A copy of that report needs to be included in the Appendices.
4.18 IMPACTS DURING CONSTRUCTION
4.18.4 Borrow Sites and Construction Waste p. 4-144: Please include the following commitment in the
"PROJECT COMMITMENTS" Section of the document: "No borrow or disposa) sites �elated to this
project are to be located on NFS lands without express written permission from the USFS and
completion of all required environmental studies".
4.18.6 Utilities p. 4-145: Please include the following commitment in the "PROJECT COMMITMENTS"
Section of the document: "Before construction, a preconstruction conference wiil be held involving the
contractor, pertinent local officials, the U.S. Forest Senrice, and NCDOT Division of Highways to discuss
various construction procedures, including precautionary steps to be taken during construction that will
minimize the interruption of public utility and traffic services."