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HomeMy WebLinkAbout20040325 Ver 2_Emails_20090313Barra Farms, Phase II -2_00q D32-5 Subject: Barra Farms, Phase II From: Howard_Hall@fws.gov Date: Fri, 13 Mar 2009 15:49:50 -0400 To: Mickey.T.Sugg@saw02.usace.army.mil CC: Matthews.Kathy@epamail.epa.gov, molly.ellwood@ncwildlife.org, tammy.l.hill@ncmail.net Mickey, On this cold, rainy (very dreary) Friday in Raleigh I am trying to clear out some old business. For you, this involves Phase II of the Barra Farms (BF II) Mitigation Bank. As I have said, Pete Benjamin generally want this office to provide formal comments on mitigation banks only when federally threatened or endangered species may be adversely impacted. As you might expect, wetland and stream restoration/enhancement/preservation generally have a positive impact on fish and wildlife resources. With regard to section 7 for the current effort, please refer to pages 7-8 of our letter of March 4, 2003 (attached below). However, we no longer consider the small-whorled pogonia as likely to occur in Cumberland County and this species does not need to be considered for this permit. The other six listed species, especially Michaux's sumac, should be considered in the permitting of this bank. However, I can provide informal comments, such as this e-mail. I do want to continue receiving information on the planning for each bank and I will try to maintain a file on each bank. Regarding BF II, I have read the comments of Kathy Matthews (February 18, 2009) and Molly Ellwood (March 10, 2009). A major issue seems to the GSA. I share the concerns of Kathy and Molly regarding the proposed GSA and concur with their recommendations for a smaller GSA. As always, the bank can sell credits for impacts outside the GSA on a case-by-case basis. During the earlier planning effort for BF II, the Service provided comments on vegetative success criteria. These issues are addressed in our March 2003 letter and more specifically in a January 30, 2004, letter to you (attached below). I see that Kathy's letter addresses the three major areas of vegetative success (absolute abundance, relative abundance (problems with competition by unwanted plants), and species diversity (survival of species planted). While I proposed more complex standards, the criteria given by Kathy were the ones generally accepted and the Service finds them to be acceptable. The Service supports the requirement for 7 years of monitoring for forested wetland restoration along with the 7-year credit release schedule outlined in Kathy's letter. As our previous letters stated, we support the development of the Barra Farms Mitigation Bank. I regret that my comments cannot be more specific at this time. Take care and have a good weekend, Howard (See attached file: Barra2_FWS_ltr_0303.pdf) (See attached file: Barra2_FWS_ltr_0104.pdf) Howard F. Hall I of 2 4/9/2009 5:43 PM Barra Farms, Phase II U. S. Fish and Wildlife Service Ecological Services P. O. Box 33726 Raleigh, North Carolina 27636-3726 Ph: 919-856-4520, ext. 27 Fax: 919-856-4556 e-mail: howard hall@fws.q Barra2_FWS_ltr_0303.pdf Content-Type: application/pdf Content-Encoding: base64 Barra2_FWS_ltr_0104.pdf Content-Type: application/pdf Content-Encoding: base64 2 of 2 4/9/2009 5:43 PM