HomeMy WebLinkAbout20040325 Ver 2_Emails_20090313Barra Farms, Phase II
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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
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