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The Falcon: Protected Habitats & Species of Concern

Part of the Falcon Public EIA Project

Major pipeline projects are scrutinized by state and federal agencies for their potential impacts to threatened, endangered, and protected species. As part of the planning process, operators are required to consult with agencies to identify habitats known to support these species and are often asked to conduct detailed field surveys of specific areas. In this segment of the Falcon Pipeline EIA Project, we investigate how Shell corresponded with different agencies in complying with federal and state protected species guidelines.

Quick Falcon Facts

  • More than half (54%) of construction areas are currently forested or farmland
  • Botanical species Purple Rocket and Climbing Fern located in proximity to workspaces
  • 67 Northern Harrier observations documented during site studies
  • One active Bald Eagle nest and two inactive nests in proximity to workspaces
  • Northern Long-eared Bat roost trees discovered as close as 318 feet from workspaces
  • Clusters of protected freshwater mussels, coldwater fish, and hellbenders in the path of the Falcon

Map of Protected Habitats & Species of Concern

The following map will serve as our guide to exploring the Falcon’s proximity to protected habitats and species of concern. Expand the map full-screen to explore its contents in greater depth. Some layers only become visible at closer zoom levels. A number of additional layers are not shown by default, but can be turned on in the “layers” tab. Click the “details” tab in full-screen mode to read how the different layers were created.

View Map Fullscreen | How FracTracker Maps Work

Shell’s permit applications detail extensive correspondences over a number of years — as early as August 2015 — with the U.S. Fish and Wildlife Service (USFWS), Pennsylvania Game Commission (PGC), Pennsylvania Fish & Boat Commission (PFBC), Pennsylvania Department of Conservation and Natural Resources (DCNR), Ohio Department of Natural Resources (ODNR), and the West Virginia Division of Natural Resources (WVDNR), among other agencies. These interactions tell a story of locating and cataloging threatened flowers, birds of prey, aquatic species, and bats.

Land Cover Assessment

A number of terrestrial habitat types are present along the Falcon pipeline’s route that will be disrupted during its construction. These are easily determined using data maintained by the USGS that tracks land cover and land use trends often used for understanding geospatial biodiversity. Shell used this data in their ecological impacts analysis and we have used it as well for comparison.

Habitat documentations from Shell’s permit applications

More than half (54%) of land in the Falcon’s construction area is currently forested land (deciduous and evergreen). Shell’s permits describe these areas as “contained cool, forested stream valleys and seeps and rich slopes” similar to the image above, which was submitted as part of Shell’s permit applications. An additional 35% is currently farmland (pasture/hay/crops). The remaining land cover is generally made up of water and wetlands, as well as residential and commercial development.

These numbers reflect the fact that the Falcon will travel through predominantly rural areas. Note that this analysis does not account for disruptions that will result from the pipeline’s 111 temporary and 21 permanent access roads. Land Cover for areas along the pipeline can be seen on the FracTracker map by activating the data in the “layers” tab.

Botanical Studies

In their correspondences with state agencies, Shell was notified that a number of important species would likely be found in these habitats. For instance, Pennsylvania Department of Conservation and Natural Resources (DCNR) noted the following botanical species on their watch list would be present:

  • Vase-vine Leather-flower (endangered): documented in floodplain and slopes of Raccoon Creek
  • Harbinger-of-spring (rare): documented in forested floodplain of Raccoon Creek
  • White Trout-lily (rare): documented in forested floodplain of Raccoon Creek
  • Purple Rocket (endangered): documented in forested floodplain of Raccoon Creek
  • Declined Trillium (threatened): documented along wooded tributaries and slopes of Raccoon Creek
  • Snow Trillium (rare): documented in tributary ravines along Raccoon Creek

DCNR requested a survey the Falcon’s route through all of Beaver County and the portion of Allegheny County north of the western fork of Raredon Run. AECOM, Shell’s contractor for this work, surveyed a 300-foot wide buffer along the pipeline route to allow for “minor alignment shifts” as construction plans are refined.

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A final survey report was submitted to DCNR in March 2017. In it, AECOM noted having found multiple populations of Harbinger-of-spring (seen below), Purple Rocket, as well as Climbing Fern (Lygodium palmatum), also the PA Watch List. FracTracker’s map locates the general location of botanical discoveries nearest to the pipeline route.

Documented Harbinger-of-spring

DCNR’s response to the survey stated that route changes and plans to bore under Raccoon Creek using HDDs eliminated risks to Harbinger-of-spring and Purple Rocket. Meanwhile, Climbing Fern was determined to be in close proximity, but not directly in the pipeline’s construction area. Although, documents note that a number of ferns were transplanted “to further the species’ success within the Commonwealth.” As a result of these determinations, DCNR granted clearance for construction in August 2017.

Short-eared Owls & Northern Harriers

Shell was also notified by the Pennsylvania Game Commission (PGC) that portions of the Falcon’s workspace would be located near six areas with known occurrences of Short-eared Owls (PA endangered species) and Northern Harriers (PA threatened species).

PGC requested a study of these areas to identify breeding and nesting locations, which AECOM executed from April-July 2016 within a 1,000-foot buffer of the pipeline’s workspace (limited to land cover areas consisting of meadows and pasture). One Short-eared Owl observation and 67 Northern Harrier observations were recorded during the study, but that some of these harriers appeared to be nesting just outside the study area. The study area is visible on the FracTracker map, as shown below.

AECOM’s Owl & Harrier study areas

In February 2017, Shell notified PGC that a number of reroutes had occurred that would shift the Falcon pipeline away from a subset of the observed Northern Harrier habitat. Although, there is no mention in the permit applications about identifying potential nest locations in the neighboring areas where AECOM’s biologists observed additional harriers. Nevertheless, PGC’s final determination in August 2017, approved the project, stipulating that, “based on the unusually high number of observations at these locations” work should not be done in these areas during harrier breeding season, April 15 through August 31.

Bald Eagles

The U.S. Fish & Wildlife Service (USFWS) notified Shell that a known Bald Eagle nest was located in Beaver County. Meanwhile, the Ohio Department of Natural Resources (ODNR) and West Virginia Division of Natural Resources (WVDNR) noted that two potential “alternate nests” were located where the Falcon crosses the Ohio River. National Bald Eagle Management Guidelines bar habitat disturbances that may interfere with the ability of eagles to breed, nest, roost, and forage.

AECOM surveyed these areas in March 2016 and March 2017. The first stage included an analysis of land cover data to determine other areas along the Falcon’s route that may be desirable eagle habitat. In addition to the sites noted above, AECOM determined that Fort Cherry Golf Course (discussed in gerater detail here) and Beaver Conservation District owned land (discussed in greater detail here) would serve as eagle habitat, although in later field surveys no additional nests were found.

The one active nest in close proximity to the Falcon, called the Montgomery Dam Nest, is located just west of the pipeline’s terminus at Shell’s ethane cracker facility. AECOM’s study determined that the foraging areas for a pair of eagles using the nest span the Ohio River and Raccoon Creek.

An additional nesting site was found near Tomlinson Run, along the Ohio River. During initial field observations it was noted that the nest was not in-use and is in an unmaintained condition. Nevertheless, its use by Bald Eagles as recently as 2015 means it is still considered an “alternate nest” and thus accorded protection from habitat modifications. A second alternate nest was found the west bank of the Ohio River. No previous history of the nest had been recorded by state agencies.

Bald Eagle Study Gaps?

Below are maps from Shell’s permit applications identifying the locations of the three nests. These can also be found on the FracTracker map.[/av_icon_box]

USFWS requested that Shell only implement setback buffers for the one active nest at Montgomery Dam. These include no tree clearing within 330 feet, no visible disturbances with 660 feet, and no excessive noise with 1,000 feet of an active nest. Furthermore, Shell must avoid all activities within 660ft of the nest from January 1st to July 31st that may disturb the eagles, including but not limited to “construction, excavation, use of heavy equipment, use of loud equipment or machinery, vegetation clearing, earth disturbance, planting, and landscaping.”

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According to Shell’s permit applications, the reroute that occurred at the Ohio River crossing took the Falcon pipeline away from the two alternate nest sites of concern, and the crossing at the river will be done with HDD boring, thus no impacts will occur. Apparently USFWS agreed with this position. However, as we see in the above maps, the HDD staging area on the WV side of the river (where a great deal of noise will likely occur) is just barely outside the 1,000 foot buffer.

Important Bird Areas

USFWS determined that the Falcon pipeline was also in close proximity to many migratory bird species protected under the Migratory Bird Treaty Act and that “direct or indirect, unintentional take of migratory birds may result even if all reasonable measures to avoid avian mortality are utilized.” In particular, the USFWS brought attention to the Raccoon Creek Valley and State Park Important Bird Area (IBA), which is located just south and west of the Falcon pipeline’s two major branches, as seen below.

USFWS recommended a number of strategies, such as co-locating the Falcon pipeline along rights-of-way used by existing pipelines. We see this indeed became the case, as 11 of the Falcon’s 23 pipeline miles in Beaver County are found adjacent to or parallel to existing ROWs.

Additional restrictions were placed on the project in Ohio, where ODNR determined that the Falcon is within range of the Upland Sandpiper, a state endangered bird that nests in grasslands and pastures. Shell was instructed to avoid construction in these habitat types from April 15-July 31 if such areas were to be disturbed. As we can see on the FracTracker map’s analysis of land cover data, there are significant areas of grassland and pasture in Ohio along the pipeline route.

No Peregrine Falcon?

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One absence we noted in AECOM’s birds of prey studies was any mention of Peregrine Falcons, listed as endangered and protected under the PA Game and Wildlife Code. Peregrine Falcons nest in cliffs and bridges along rivers in Allegheny and Beaver counties and are particularly prized by the PA DEP, as evidenced by a prominently displayed booth at their Harrisburg headquarters.

PA DEP Falcon Exhibit

One known nest is located under the East Rochester-Monaca Bridge just north of the Falcon pipeline’s terminus at Shell’s ethane cracker facility. While it is unlikely that activities such as tree clearing would affect falcon habitat, other aspects of the pipeline’s construction, such accidental drilling mud spills at HDD sites or ethane releases along Raccoon Creek, may indeed impact Falcon populations.

Federally Protected Bats

The USFWS notified Shell that the Falcon is located within the range of federally protected Indiana Bats and Northern Long-eared Bats in Pennsylvania and West Virginia and requested Shell conduct a bat “mist net” survey to identify breeding areas. Mist netting involves setting up nylon mesh nets at predetermined locations to capture and document bat populations.

AECOM’s bat survey was conducted from April-July 2016. While bats are known to live in caves and abandoned mines in winter, the study focused on summer habitats — mainly forests that support roost trees — given that tree clearing from building the pipeline would be the most likely impact. These forested areas constituted about 27 of the Falcon pipeline’s 97 miles in the two states. Mist net locations (MNLs) were established at 46 sites along the route, roughly 1/2 mile apart, as shown on the FracTracker map. A later reroute of the pipeline led to setting up 4 additional MNLs in June 2017.

A total of 274 bats from 6 different species were captured in the study, included 190 Big Brown Bats, 2 Silver-haired Bats, 62 Eastern Red Bats, 2 Hoary Bats, and 1 Little Brown Bat. 17 Northern Long-eared Bats were found at 13 of the MNL sites, but no Indiana Bats were captured. Radio transmitters were then attached to the Northern Long-eared Bats in order to follow them to roost trees. A total of 9 roost trees were located, with the nearest roost tree located 318 feet from the pipeline’s workspace.

A captured Northern Long-eared Bat

In January 2018, USFWS stated that, because the Falcon’s construction area is not within 150 feet of a known roost tree during breeding season or within a 1/4 mile of a known year-round hibernation site, that “incidental take that might result from tree removal is not prohibited.” However, USFWS also stated that “Due to the presence of several Northern Long-eared Bat roost trees within the vicinity of the project footprint (although outside of the 150-foot buffer), we recommend the following voluntary conservation measure: No tree removal between June 1 and July 31.”

Furthermore, the PGC noted in early correspondences that Silver-haired Bats may be in the region (a PA species of special concern). This was confirmed in AECOM’s mist net study. PGC did not require a further study for the species, but did request a more restrictive conservation of no tree clearing between April 1 and October 31.

Bat Study Gaps?

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There are a number of possible gaps in AECOM’s study that need attention. First, the study notes the nearest roost tree is 318 feet from the Falcon’s workspace, but this does not fully represent the likely impact to bat populations. As is seen in the map below, taken from Shell’s permits, this tree is just one in a cluster of five trees all within 750 feet of the pipeline’s workspace.

A dense cluster of bat roosting trees

Furthermore, tree clearing in this area will be extensive considering its proximity to the Falcon’s juncture in Beaver County that also must accommodate a metering pad and access roads. This area is shown in the permit application map below and can be explored on the FracTracker map as well.

A second questionable aspect of the study is that, while the USFWS letter states the Falcon is not “within a 1/4 mile of a known year-round hibernation site,” this was not proven in the study as it did not identify nearby winter habitats. These omissions are noteworthy given the already significant stressors to bat populations in the region, as well as increasing pressure from oil and gas companies to relax standards for protecting endangered bat species.

A Note on Noise Control

As part of their ability to build the Falcon pipeline, USFWS mandated that Shell employ an “independent noise consultant” to measure ambient pre-construction noise levels at each HDD site and at designated Noise Sensitive Areas (NSA), which are generally determined by the presence of protected bird and bat species. Less is known about the details of this part of AECOM’s study plan for Shell. However, we have located noise monitoring sites on the FracTracker map for reference.

Freshwater Mussels

The USFWS and PGC identified very early in the Shell’s construction plans that the project would likely impact four endangered mussel species: the Northern Riffelshell, the Clubshell, the Rayed Bean, and the Snuffbox. AECOM conducted a survey in May 2016, at the request of Pennsylvania and Ohio agencies at 16 perennial streams along the route in those two states. These are shown on the FracTracker map. In PA, mussels were found to be present at both of the Falcon’s intersections with Raccoon Creek, as seen in a photo from Shell’s permit application below.

Documented freshwater mussels in Raccoon Creek

The results of the Ohio study are unknown at this time. However, we found it interesting that ODNR’s letter to Shell stated that unavoidable impacts could be resolved by allowing specialists to collect and relocate mussels to suitable and similar upstream habitats. Meanwhile, it appears that the USFWS and PFBC have also green lighted construction around the two known Raccoon Creek mussel habitats, as Shell’s applications argue these waters would not be impacted due to the fact that they would be crossing using HDD boring.

Coldwater Fish

The PA Fish & Boat Commission notified Shell that the Falcon may impact the Southern Redbelly Dace. This threatened species is especially vulnerable to physical and chemical (turbidity, temperature) changes to their environment. PAFB explicitly notes in their correspondences that “we are concerned about potential impacts to the fish, eggs and the hatching fry from any in-stream work.” Of note is that these sites of concern are located in HQ/CWF streams of the Service Creek watershed (discussed in greater detail here), as shown on the map below.

Headwater streams in the Service Creek watershed

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Early correspondences with PFBC show the agency requesting that directional boring be used for these stream crossings or, if work necessitated direct impacts (such as open-cut crossings), that these activity be avoided during the spawning season. Shell responded to the request in stating that, with the exception of the Service Creek itself which will be crossed by HDD, the terrain surrounding its headwater streams was not suitable for boring, and would thus require open-cuts.

PFBC’s final determination on these matters is that they generally agreed, with the exception of the HDD site and one headwater stream (S-PA-151104-MRK-001), all other crossings must adhere to seasonal restrictions with no in-stream activity being conducted between May 1-July 31.

In Ohio, we see similar circumstances related to the River Darter, the Paddlefish, and the Channel Darter, all threatened species in the state. The ODNR recommended no in-stream work in the Ohio River from March 15-June 30 and no in-stream work in any of the state’s perennial streams from April 15-June 30.

Eastern Hellbenders

The Falcon is also within range of Eastern Hellbender habitat in Ohio, a state endangered species and a federal species of concern. In particular, ODNR noted that Yellow Creek, in Jefferson County, is known to host the species. Because of this, ODNR requested that if any in-stream work was to occur in Yellow Creek, a habitat suitability survey must be conducted to determine if Hellbenders were present. Yellow Creek’s tributaries are indeed crossed by the Falcon. Whether or not a study was conducted as a result of this is unknown due to our not having reviewed Shell’s Ohio permit applications. The below image, captured from our page on water crossings, shows these locations.

Falcon crossing Yellow Creek tributaries

Allowable Work Dates

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To summarize, there are numerous implications for how Shell’s construction of the Falcon pipeline must accommodate endangered, threatened, and rare species in different states. In particular, Shell must avoid land and aquatic disturbances during different breeding and spawning seasons. Below is a breakdown of these black-out periods. Note that these only apply to locations where sensitive species were found in AECOM’s studies.

Land Disturbances

  • Northern Harriers, Short-eared Owls (PGC): No clearing between April 15 and August 31
  • Bald Eagles (USFWS): No work between January 1 and July 31
  • Upland Sandpiper (ODNR): No clearing between April 15 and July 31
  • Bats (USFWS): No clearing between April 1 and October 31

Aquatic Disturbances

  • Southern Redbelly Dace (PFBC): No in-stream work between May 1 and July 31
  • River Darter, Paddlefish, Channel Darter (ODNR): No Ohio River work between March 15 and June 30; no perennial stream work between April 15 and June 30

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Related Articles

“Taking” Wildlife in PA, OH, WV

By Karen Edelstein, Eastern Program Coordinator, FracTracker Alliance

 

In an apparent move to step around compliance with comprehensive regulations outlined in the Endangered Species Act (ESA), a coalition of nine oil and gas corporations has filed a draft plan entitled the Oil & Gas Coalition Multi-State Habitat Conservation Plan (O&G HCP). The proposed plan, which would relax regulations on five species of bats, is unprecedented in scope in the eastern United States, both temporally and spatially. If approved, it would be in effect for 50 years, and cover oil and gas operations throughout the states of Ohio, Pennsylvania, and West Virginia—covering over 110,000 square miles. The oil and gas companies see the plan as a means of “streamlining” the permit processes associated with oil and gas exploration, production, and maintenance activities. Others outside of industry may wonder whether the requested permit is a broad over-reach of an existing loophole in the ESA.

Habitat fragmentation, air, and noise pollution that comes with oil and gas extraction and fossil fuel delivery activities have the potential to incidentally injure or kill bat species in the three-State plan area that are currently protected by the Endangered Species Act (ESA) of 1973. In essence, the requested “incidental take permit”, or ITP, would acknowledge that these companies would not be held to the same comprehensive regulations that are designed to safeguard the environment, particularly the flora and fauna at most risk to extirpation. Rather, they would simply be asked to insure that their impacts are “minimized and mitigated to the maximum extent practicable.”

Section 10(a)(2)(B) of the ESA contains provisions for issuing an ITP to a non-Federal entity for the take of endangered and threatened species, provided the following criteria are met:

  • The taking will be incidental
  • The applicant will, to the maximum extent practicable, minimize and mitigate the impact of such taking
  • The applicant will develop an HCP and ensure that adequate funding for the plan will be provided
  • The taking will not appreciably reduce the likelihood of survival and recovery of the species in the wild
  • The applicant will carry out any other measures that the Secretary may require as being necessary or appropriate for the purposes of the HCP

What activities would be involved?

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The Northern Long-eared Bat is a federally-listed threatened species, also included in the ITP

The proposed plan, which would seek to exempt both upstream development activities (oil & gas wells) and midstream development activities (pipelines). Upstream activities include the creation of access roads, staging areas, seismic operations, land clearing, explosives; the development and construction of well fields, including drilling, well pad construction, disposal wells, water impoundments, communication towers; and other operations, including gas flaring and soil disturbance; and decommissioning and reclamation activities, including more land moving and excavation.

Midstream activities include the construction of gathering, transmission, and distribution pipeline, including land grading and stream construction, construction of compressor stations, meter stations, electric substations, storage facilities, and processing plants, and installation of roads, culverts, and ditches, to name just a few.

Companies involved in the proposed “Conservation Plan” represent the major players in fossil fuel extraction, refinement, and delivery in the region, and include:

  • Antero Resources Corporation
  • Ascent Resources, LLC
  • Chesapeake Energy Corporation
  • EnLink Midstream L.P.
  • EQT Corporation
  • MarkWest Energy Partners, L.P., MPLX L.P., and Marathon Petroleum Corporation (all part of same corporate enterprise)
  • Rice Energy, Inc.
  • Southwestern Energy Company
  • The Williams Companies, Inc.

Focal species of the request

Populations of federally endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)

Populations of federally-endangered Indiana Bats could be impacted by the proposed Incidental Take Permit (ITP)

The five species listed in the ITP include the Indiana Bat (a federally-listed endangered species) and Northern Long-eared Bat (a federally-listed threatened species), the Eastern Small-footed Bat (a threatened species protected under Pennsylvania’s Game and Wildlife Code), as well as the Little Brown Bat and Tri-colored Bat. Populations of all five species are already under dire threats due to white-nose syndrome, a devastating disease that, since 2008, has killed an estimated 5.7 million bats in North America. In some cases, entire local populations have succumbed to this deadly disease. Because bats already have a naturally low birthrate, bat populations that do survive this epidemic will be slow to rebound. Only recently, wildlife biologists have begun to see hope for a treatment in a beneficial bacterium that may save affected bats. However, production and deployment details of this treatment are still under development. Best summarized in a recent article in the Pittsburgh Post-Gazette:

This [ITP] would be a huge deal because we are dealing with species in a precipitous decline,” said Jared Margolis, an attorney with the Center for Biological Diversity, a national nonprofit conservation organization headquartered in Tucson, Ariz. “I don’t see how it could be biologically defensible. Even without the drilling and energy development we don’t know if these species will survive.

In 2012, Bat Conservation International produced a report for Delaware Riverkeeper, entitled Impacts of Shale Gas Development on Bat Populations in the Northeastern United States. The report focuses on landscape scale impacts that range from water quality threats, to disruption of winter hibernacula, the locations where bats hibernate during the winter, en masse. In addition, because bats have strong site fidelity to roosting trees or groups of trees, forest clearing for pipelines, well pads or other facilities may disproportionately impact local populations.

The below map, developed by FracTracker Alliance, shows the population ranges of all five bat species, as well as the current areas impacted by existing development by the oil and gas industry through well sites, pipelines, and other facilities.

View map fullscreenHow FracTracker maps work

 

To learn more details about the extensive oil and gas development in each of the impacted states, follow these links:

  • Oil and gas threat map for Pennsylvania. Currently, there are ~104,000 oil and gas wells, compressors, and other related facilities here.
  •  Oil and gas threat map for Ohio. Currently, there are ~90,000 oil and gas wells, compressors, and other related facilities here.
  • Oil and gas threat map for West Virginia. Currently, there are ~16,000 oil and gas wells, compressors, and other related facilities here.

Public input options

The U.S. Fish and Wildlife Service (USFWS) announced in the Federal Register in late November 2016 its intent to prepare an environmental impact statement (EIS) and hold five public scoping sessions about the permit, as well as an informational webinar.  In keeping with the parameters of an environmental impact statement, USFWS is particularly interested in input and information about:

  • Aspects of the human environment that warrant examination such as baseline information that could inform the analyses.
  • Information concerning the range, distribution, population size, and population trends concerning the covered species in the plan area.
  • Additional biological information concerning the covered species or other federally listed species that occur in the plan area.
  • Direct, indirect, and/or cumulative impacts that implementation of the proposed action (i.e., covered activities) will have on the covered species or other federally listed species.
  • Information about measures that can be implemented to avoid, minimize, and mitigate impacts to the covered species.
  • Other possible alternatives to the proposed action that the Service should consider.
  • Whether there are connected, similar, or reasonably foreseeable cumulative actions (i.e., current or planned activities) and their potential impacts on covered species or other federally listed species in the plan area.
  • The presence of archaeological sites, buildings and structures, historic events, sacred and traditional areas, and other historic preservation concerns within the plan area that are required to be considered in project planning by the National Historic Preservation Act.
  • Any other environmental issues that should be considered with regard to the proposed HCP and potential permit issuance.

The public comment period ends on December 27, 2016. Links to more information about locations of the public hearings, as well as instructions about how to sign up for the December 20, 2016 informational webinar can be found at this website. In addition, you can electronically submit comments about the “conservation plan” by following this link.