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HomeMy WebLinkAboutArmy Corps of Engineers - PLN General - 10/23/2002 DEPARTMENT OF THE ARMY . SEATTLE DISTRICT,CORPS OF ENGINEERS P.O. BOX 3755 ` SEATTLE,WASHINGTON 98124-3755 -- REPLY TO ATTENTION OF OCT 2 3 2002 Regulatory Branch Ms. Jane C. Martin 240 North Ayock Beach Drive Lilliwaup, Washington 98555 Ms. Anna M. Chester 1509 Northwest 100th Street Seattle, Washington 98177-5401 Reference: 2002-2-01088 Martin, Jane C. and Anna M. Chester Dear Ms. Martin and Ms. Chester: I have received your application for a Department of the Army permit to do work for the purpose of erosion prevention in Hood Canal, at Lilliwaup, Washington. We have assigned the above referenced file number to this project. Please cite this number in any correspondence with us concerning this project. I will be the project manager for the processing of this application. The JARPA that you submitted is incomplete. The proposed work must be described both in a written document and graphically in your drawings. Especially in this case, when drawings are unreadable, the narrative provided in response to JARPA question 7a is essential. Your response to question#2 indicates that you would like to designate Ms. Sharon Moth as your agent. However, although you both signed the section in question#19,which allows you to designate an agent, you did not fill in the blank for the agent's name. Until I receive a signed document designating Ms. Moth as your agent, I will continue to route all correspondence to you both, as the applicants. The drawings that you submitted were unclear and in some cases, unreadable. It appears that they have lost clarity due to excessive copying. In order to expedite the review of your application, you should submit drawings for the project as detailed below and on the Drawing Checklist(enclosure 1). Clean drawings are essential for the prompt evaluation of your application. The ultimate objective is a set of drawings that allows someone who is unfamiliar with the project to get a clear and accurate understanding of the project in general and the details of how the streams and wetlands will be affected. i 1 Ar -2- Please provide a set of the project drawings in black and white, on 8 %-by 11-inch sheets showing the current and proposed features, current and proposed elevations, wetland boundaries, adjacent property ownership, etc. Drawings should be originals and not reduced copies of large- scale plans. If you must reduce large drawings, make sure that the text and labels are legible at the smaller size and that the scale is adjusted to the reduction. Sheet 1 should be a site/vicinity map,which clearly shows the project in relation to nearby roads,waterways and other landmarks. Include the boundaries of your property and the longitude and latitude of the project site on this sheet. Sheet 2 should be a plan view that shows the location and dimensions of the proposed work. Sheet 3 should show a cross sectional or elevation view of the proposed work. This sheet should include the dimensions of the proposed work. All drawings should include a graphic scale. The Mean Higher High Water(MHHW) line should be shown on the plan and section views. You should include the appropriate datum if available. All of your drawings should include a title block listing the applicant, location,project purpose,project description, date, and sheet number. I have provided you with an example title block you may use on your drawings. Reference:2002- Applicant: Proposed: Purpose: At Washington Sheet of Date In the project vicinity, a number of fish and wildlife species have been listed as threatened under the Endangered Species Act(ESA), effective May 24, 1999. Under the U.S. Army Corps of Engineers (Corps)Federal permit program,permit applications are reviewed for the potential impact on threatened and endangered species pursuant to Section 7 of the ESA, as amended. The ESA requires that Federal agencies such as the Corps take action as necessary to ensure that we do not authorize, fund, or carry out actions that are likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of designated critical habitat for such species. To fulfill our obligations required under the ESA, the Corps, through consultation with the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (FWS),must evaluate the potential impact of the proposed work on listed species. -3- Before we can move forward with the required consultations, you must contact NMFS and FWS to determine what listed or proposed species are present in your project area. You must then submit a Biological Evaluation(BE)to address all listed or proposed species present. A qualified biologist,with experience and/or strong understanding of the species of concern and their habitat as it relates to your project(i.e. marine or fresh water systems), should prepare your BE. Many consulting firms in the area have qualified biologists on staff that can prepare a BE. Enclosure 2 is a public notice describing the Corps' responsibilities under the ESA with guidance on how to prepare a BE. For a species list, contact: U.S. Fish and Wildlife Service Endangered Species Division 510 Desmond Drive Southeast, # 102 Lacey, Washington 98503-1273 Telephone: (360) 753-9440 Website: http://endangered.fws.gov/index.html National Marine Fisheries Service Washington Habitat Conservation Branch 510 Desmond Drive Southeast, Suite 103 Lacey, Washington 98503 Telephone: (360) 753-9530 Website: http://www.nwr.noaa.gov The Corps must review the potential project impacts on threatened and endangered species for the majority of the permit applications received. As a consequence, we currently have a large backlog of permit applications. Your application will be reviewed in the order it was received. We request your patience as we attempt to serve all applicants in as timely and equitable a manner as possible. The Magnuson-Stevens Fishery Conservation and Management Act(MSA), as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures designed to identify, conserve, and enhance Essential Fish Habitat(EFH) for those species regulated under a Federal fisheries management plan. The MSA requires Federal agencies to consult with NMFS on all actions, or proposed actions, authorized, funded, or undertaken by the agency,that may adversely affect EFH (MSA §305(b)(2)). You will need to assess your project to include a discussion on the potential impacts of EFH. Enclosure 3 is a template developed by NMFS for the EFH assessment. Where possible, refer to the BE/BA. For example, project description,parts of the effects analysis, and -4- conservation measures may be appropriate to the EFH assessment. If the project will adversely affect EFH,then the Corps will initiate consultation with NMFS in associated with the ESA consultation. You must complete the Certification of Consistency with the Coastal Zone Management Program (enclosure 4). Please fill in any relevant permitting information and sign the form. We require this form before we issue a Public Notice. You must submit the requested information within 90 days of the date of this letter. After you submit the required information, I may contact you to discuss more specific aspects of your proposal. If you do not submit the requested information, your application will be cancelled. However,this would not preclude you from submitting another application in the future. Since a Department of the Army permit is necessary for this work, do not commence construction before the permit has been issued. A copy of this letter will be furnished with enclosures to Ms. Sharon Moth, 12100 129 Lane Northeast#N305, Kirkland, Washington 98034. If you have any questions,please call me at(206) 766-6438. Sincerely, Qx q�a 4AK JJe ica Gram ling Project Manager Enclosures pars ose ro US Army Corps Drawing Checklist ' of Engineers ' �s Seattle District ck+roK�o°P 1. GENERAL ❑Use clear black lettering and fewest number of sheets possible;use 8 '/2-by 11-inch sheets ❑State the purpose of the proposed or existing work ❑List property owners and indicate number by number on plan view drawing ❑ Show datum used in plan and elevation drawings ❑Use a graphic scale on all drawings ❑Use a north arrow;prepare drawing with north being directed to the top of the page ❑Label all proposed and existing work as such(e.g.,Proposed Pier,Proposed Fill...) 2. TITLE BLOCK ❑ A completed title block(first example)must be on every sheet;for subsequent sheets you can use the abbreviated form(second example) PURPOSE: APPLICANT PROPOSED: 2002- DATUM: IN: LOCATION ADDRESS NEAR/AT: ADJACENT PROPERTY COUNTY: STATE: WA OWNERS: 1• SHEET*OF 2. DATE: Reference: 2002- Applicant: Proposed: At Washington Sheet *of * Date 3. VICINITY MAP ❑ Clearly show location of project(e.g.,arrow,circle,etc.) ❑ List latitude,longitude,section,township,and range ❑ Name waterways ❑ Show roads,streets,and/or mileage to nearest town or city limits 4. PLAN VIEW ❑ Show shorelines: Tidal: Show mean high water(MHW)line,mean higher high water(MHHW)line Lakes or streams: Show the ordinary high water(OHW)line ❑ Show dimensions of proposed structures/fills;distance to property lines;encroachment beyond applicable shoreline;show wetland boundaries and specific impacts to wetlands ❑Indicate location,quantity,and type of fill,if any ❑ Show all existing structures or fills on subject and adjacent properties ❑ Show direction of currents such as tidal ebb and flood ❑Indicate adjacent property ownership 5. ELEVATION AND/OR SECTION VIEW ❑ Show shorelines,MHW line,MHHW line,OHW line,wetland boundary ❑Show original and proposed elevations,water depths,dimensions of proposed structures or fills,and pertinent vertical dimensions to top and base of structure/fill;use the same vertical and horizontal scale,if possible pecial l!S Army Corps EngineersSe u fisc No tice Seattle District Regulatory Branch Post Office Box 3755 Publication Date: 11 April 2000 Seattle, Washington 98124-2255 Telephone (206) 764-3495 CORPS OF ENGINEERS REGULATORY PROGRAM AND THE ENDANGERED SPECIES ACT Since May 24, 1999, a number of species of salmon, steelhead, and trout inhabiting Northwest waters were listed in the Federal Register by the National Marine Fisheries Service and the U.S. Fish and Wildlife Service as endangered, threatened, or proposed species under the Endangered Species Act (ESA) of 1973. In addition, the habitat for most of these species has been designated as critical for their conservation. The purpose of this special public notice is to advise permit applicants and agents who apply for Department of the Army permits, as well as other interested parties, of the following: • Purpose of the Endangered Species Act • How the ESA Listings and Critical Habitat Designations Affect the U.S. Army Corps of Engineers' (Corps) Regulatory Program and Permit Applicants • Actions Being Taken by the Corps and Other Agencies to Expedite the Processing of Permit Applications • Table of Current ESA Listings for Washington State Waters (see enclosure 1) • Draft Guidance for Preparation of a Biological Evaluation or Biological Assessment (see enclosure 2) • Project Conditions or Actions Determined to Have No Effect on Listed Species or Designated Critical Habitat for Fresh, Marine, and Estuarine Waters (see enclosure 3) • Common Terms Used in the ESA (see enclosure 4) PURPOSE Or: THE ESA OF 1973. The Endangered Species Act of 1973 was passed by the United States Congress for the purpose of providing a means whereby ecosystems and the endangered and threatened species that depend upon them may be conserved. It is the declared policy of Congress that all Federal departments and agencies shall seek to conserve endangered and threatened species and shall utilize their authorities in furtherance of the purposes of the ESA. Congress further declared that Federal agencies shall cooperate with �e,� a State and local agencies to resolve water resource issues in concert with conservation of- endangered species (see 50 CFR, Part 402 and 33 CFR, Part 320.3(i)). Section 7(a)(1) of the Act authorizes Federal agencies, in consultation with the Secretary of the Interior or Commerce, depending on the species involved, to utilize their resources in furtherance of the purposes of the Act by carrying out programs for the conservation of endangered and threatened species ("listed species") listed pursuant to Section 4 of the Act. Section 7(a)(2) of the Act requires Federal agencies, in consultation with the Secretary, to ensure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any listed species or result in the destruction or adverse modification of habitat of such species which has been designated as critical ("critical habitat"). Authority to conduct consultations has been delegated by the Secretary of the Interior to the U.S. Fish and Wildlife Service (FWS) and by the Secretary of Commerce to the National Marine Fisheries Service (NMFS) (the Services). HOW THE ESA LISTINGS AND CRITICAL HABITAT DESIGNATIONS AFFECT THE CORPS' REGULATORY PROGRAM AND APPLICANTS. Under the Corps' Federal permit program, permit applications must be reviewed for the potential impact on threatened and endangered species pursuant to Section 7 of the ESA. The Corps, through informal and formal consultation procedures with the Services, must evaluate information on the presence of listed species (including timing and life stages), habitat for such species and their prey sources, and other parameters. These consultation procedures are outlined in a March 1998 Consultation Handbook prepared by the Services. The information required for ESA evaluation must be prepared in the form of a Biological Evaluation (BE) or Biological Assessment (BA) which is utilized to assess project impacts to listed, and/or proposed species and designated and/or proposed critical habitat (see enclosure 2 of this special public notice for a list of required information that must be included in a BE/BA). As required by the Corps' regulations at 33 CFR, Part 325.2(b)(5), ESA information is required for all pending and future permit applications for work affecting listed species before a permit decision can be made. Department of the Army permit regulations (33 CFR, 325.1(e)) authorize the District Engineer to obtain additional information from permit applicants deemed essential to making a public interest determination including environmental data such as the ESA information discussed herein. Before the Corps can make a permit decision on pending and future permit applications for work affecting listed species or critical habitat, a BE/BA must be prepared by a qualified biologist at the applicant's expense and be provided to the Corps so that the required ESA coordination can be conducted with the appropriate agencies. Many consulting firms in the area have qualified biologists on staff that can prepare a BE/BA. In the event that an applicant is unable to have a BE/BA prepared, they should contact the Corps' Seattle District, Regulatory Branch, at telephone (206) 764-3495 for assistance. Additional project information may also be requested before the permit application is processed. Because the new ESA listings are all aquatic species, the Corps must now review the potential project impacts on listed species and designated critical habitat for the majority of the permit 2 z applications received. In addition, the Corps must also review potential project impacts on species proposed for listing and proposed critical habitat. The additional ESA requirements have resulted in much longer permit processing times by the Corps' Seattle District, Regulatory Branch, than in the past and a large backlog of permit applications. The backlog as of March 16, 2000, was approximately 849 pending permit applications, a 103 percent increase since the May 24, 1999, ESA listings. As discussed below, the Corps is currently placing ESA emphasis on large groups of similar types of activities (programmatic BEs) to expedite the processing of some of the permit applications. We request your patience as we attempt to serve all permit applicants in as equitable a manner as possible. The ESA procedures discussed above must be followed for all pending and future projects potentially affecting listed species or designated critical habitat, regardless of the size or potential impacts (adverse or beneficial) of a proposed project, whether a project is for new work or the repair or replacement of existing work (i.e., Nationwide Permit 3), or the type of permit process utilized by the Corps. The ESA procedures must be followed for all projects that could be authorized by nationwide permits, including those that did not previously require prior notification to the Corps. This requires submittal of appropriate notification (JARPA, pre-construction notification, or letter) to the Corps including project drawings and a BE/BA. A BE/BA prepared for a specific project will have one of three conclusions as to its effect on listed species. These conclusions are as follows: (1) no effect; (2) may affect, not likely to adversely affect; or (3) may affect, likely to adversely affect. If the Corps determines that a project will have "no effect" on a listed species, consultation with the Services is not required and the Corps can proceed with the permit process and a permit decision. The Corps, in consultation with the Services, has determined that certain actions would have "no effect" on listed species. A description of actions determined to have "no effect" on listed species or designated critical habitat is provided in enclosure 3 of this public notice. This list will be update, as needed. Where the conclusion in a BE/BA is a "may effect, not likely to adversely effect" or "may effect, likely to adversely effect," see discussion below. ACTIONS BEING TAKEN BY THE CORPS AND OTHER AGENCIES TO EXPEDITE THE PROCESSING OF PERMIT APPLICATIONS. The Corps and the Services have been meeting on a bi-weekly basis ("batched consultation meetings") to discuss permit applications in which completed Draft BE/BAs have been prepared and the Corps has concluded that the proposed work "may affect, but is not likely to adversely affect" listed species or designated critical habitat. This is part of the "informal consultation" process. If the Services concur with a Corps determination that a project is "not likely to adversely affect" listed species or designated critical habitat, then the Corps can complete its permit process and permit decision. If either of the Services non-concurs with the Corps' determination, then formal consultation can be initiated as discussed below. In the informal consultation process, the Services will typically respond within 30 days of receipt of a BE/BA. If a permit is issued, special conditions may be added to the permit to protect listed species or designated critical habitat [33 CFR, Part 325.4(a)(1)]. When the Corps determines that a proposed project is "likely to adversely affect" listed species or designated critical habitat, "formal consultation" with one or both of the Services is initiated. 3 f The formal consultation process is similar to the informal consultation process described 9bove with the major exception of time allowances for resource agency review. In the formal consultation process, the agencies have up to 90 calendar days to prepare a draft Biological Opinion (BO) and have up to an additional 45 calendar days for the Corps' review and comment and for preparation of a final BO. Also, in formal consultation, the Services can require certain reasonable and prudent measures, terms, and conditions to be incorporated into the project if they believe the work can proceed with only incidental take that will not cause jeopardy to the continued existence of the species. However, if the Services believe no conditions could be placed upon the work to reduce impact to that level, they can then make a determination of "jeopardy." If this occurs, then the Corps must deny the permit request. As a result of the large backlog of permit applications due to the new ESA requirements, the Corps is working closely with the Services to develop "programmatic" BE/BAs to expedite the ESA compliance process for the majority of permit applications. These programmatic permits will be prepared in two phases. The Phase I programmatic BEs will include a number of different types of minor construction activities considered "not likely to adversely affect" listed species or designated critical habitat. The Services must then provide a concurrence letter (with or without conservation measures) or non-concur and explain why they believe certain types of projects would adversely affect listed species. The Phase II programmatic BAs will include a number of different activities considered "likely to adversely affect" listed species or designated critical habitat. This is intended to result in formal consultation as described above with a programmatic BO either stipulating measures to allow projects to proceed with appropriate permit conditions (reasonable and prudent measures to reduce potential impacts on listed species), or stipulating that one or more activities are likely to cause jeopardy in the areas of their intended use. Phase I of the programmatic consultations has been initiated and is expected to be finalized in the spring of 2000. Work on developing Phase II of the programmatic consultations will be initiated after the submittal of Phase 1 to the Services. Upon conclusion of these processes, a special public notice will be published announcing the results of each of these phases. The Corps is also planning to delegate certain State or local agencies as non-Federal representatives to work one-on-one with the Services on informal consultation, as allowed by 50 CFR 402.08 of the ESA regulations. If an agency has a consultation protocol in place and has qualified biological staff dedicated to preparing BEs, then the Corps' Seattle District, Regulatory Branch, may consider such delegation. The Corps is currently working closely with King County and the Washington State Department of Transportation on ESA delegation authority. In addition to the above actions, the Corps will be holding workshops in the summer of 2000 for consultants and other interested parties concerning the preparation of BE/BAs. A public notice will be issued announcing the proposed dates of these workshops. 4 Additional ESA information may be obtained from the following web sites: htt-o : //www . nwr . noaa . gov/lsalmon/salmesa/index . htm,l http : //www . fws . gov/r9endspp/endspp . html www4 . Law . Cornell . edu/uscode/16/ch35 . ht:n1 If you have any questions or need additional information on the ESA, please contact the Corps' Seattle District, Regulatory Branch, at telephone (206) 764-3495. Corps' Seattle District's web site http://www.nws.usace.army.mil 5 a Threatened & Endangered Salmonid ESUs & DPSs Occurring in Washington State (by species) Critical Habitat Evolutionary Sig. Unit(ESU) Status Fed Register Date Snake R. Spring/Summer Chinook Final, Threatened Apr. 22, 1992 Y Snake R. Fall Chinook Final, Threatened Apr. 22, 1992 Y NOTE: On Mar. 9, 1998, proposal made to add areas to Snake R. fall chinook ESU Lower Columbia R. Chinook Final, Threatened Mar. 24, 1999 Y Upper Columbia R. Spring Chinook Final, Endangered Mar. 24, 1999 Y Upper Willamette R. Chinook Final, Threatened Mar. 24, 1999 Y Puget Sound Chinook Final, Threatened Mar. 24, 1999 Y Snake R. Sockeye Final, Endangered Nov. 20, 1991 Y Ozette Lake Sockeye Final, Threatened Mar. 25, 1999 Y Snake R. Steelhead Final, Threatened Aug. 18. 1997 Y Lower Columbia R. Steelhead Final, Threatened Mar. 19, 1998 Y Middle Columbia R. Steelhead Final, Threatened Mar. 25, 1999 Y Upper Columbia R. Steelhead Final, Endangered Aug. 18, 1997 Y Upper Willamette Steelhead Final, Threatened Mar. 25, 1999 Y Columbia River Chum Final, Threatened Mar. 25, 1999 Y Hood Canal Summer Chum Final, Threatened Mar. 25, 1999 Y Lower Columbia R./SW WA. Coho Candidate Jul. 25, 1995 N/A Puget Sound/St. of Georgia Coho Candidate Jul. 25, 1995 N/A Coastal/Puget Sound Bull Trout Final, Threatened Nov. 1, 1999 N Columbia River Bull Trout Final, Threatened Jun. 20, 1998 N SW Washington/Columbia River Coastal Cutthroat Trout Proposed, Threatened Apr. 5, 1999 N Common Name : Scientific Name Chinook salmon : Oncorhynchus tshawytscha Sockeye salmon : Oncorhynchus nerka Chum salmon : Oncorhynchus ket Steelhead : Oncorhynchus mykiss Coho salmon : Oncorhynchus kisutch Bull Trout : Salvenlinus conf/uentus Cutthroat Trout : Oncorhynchus clarki clarki March 28, 2000 Enclosure 1 • CENWS-OD-RG Version: February 5, 2001 WORKING DOCUMENT for Preparation of a Biological Evaluation (BE) or Biological Assessment (BA) This outline is to serve as a guide for the preparation of average Biological Evaluations or Biological Assessments (BEs/BAs) required for consultation under the Federal Endangered Species Act (ESA). The U.S. Fish and Wildlife Service and the National Marine Fisheries Service (the Services) administer the ESA, and all Federal action agencies must be in compliance. Informal consultation (submission of a BE) is geared to demonstrate to the Services that impacts to listed species are insignificant and/or discountable', and if the Services agree they will write a concurrence letter. Formal consultation (submission of a BA), indicates that the impacts to listed species are not insignificant and/or discountable. In the case of formal consultation, the Services will write a Biological Opinion (BO). While the U.S. Army Corps of Engineers, Seattle District, Regulatory Branch (Corps) requires that applicants prepare BEs and BAs, we encourage applicants or their consultants to first work with the Corps project manager on defining action area (note caveats in bolded italics below). Applicants should be aware that the Corps requires revisions to the majority of the BE/BA's. As the Corps consults with the Services, new information and new understandings are developed as to the level of detail needed for varying activities. The process, especially in regards to listed fish species, is evolving so rapidly that updates from the Corps and the Services are only periodic. For the most recent updates, please see the Corps website http://www.nws usace army mil/reg/reg htm. In between updates, the Corps' only means of dispersing new information is through individual comments on BE/BA's. I. Project Description: A. Project Location: City, county, State, township, range and section number. Provide vicinity maps. B. Project Description: Describe the proposed project (briefly), the project purpose and the methods and timing of construction to be employed in building the project (in detail). The idea is to identify both temporary and permanent actions that could affect the species or critical habitat in sufficient detail to allow an assessment of potential impacts. Consider actions such as, but not limited to, vegetation removal, temporary or permanent elevations in noise level, temporary or permanent water quality impacts associated with sedimentation, turbidity and/or erosion, temporary or permanent All italicized words have specific definitions under the Endangered Species Act(ESA). Refer to these definitions, not those within other Corps or federal guidance. 1 Fnclosure 2, Revised channel modifications, temporary or permanent hydrological or hydraulic alterations (i.e. dewatering). Include secondary impacts such as access roads, power lines etc. Provide project drawings. In some cases it is useful to provide drawings showing the location of the staging, access, detours, and work corridors associated with the construction activity. C. Construction Technique: Address the following items: • Construction Sequenq( • Site Preparation: • Equipment Used: • Materials Used: • Work Corridor: • _Staging areas and equipment wash outs: • Stockpiling areas: • Running of Equipment During Construction: • Soil stabilization: • Clean-Up and Reve etation: • Project Timing: • Duration of Construction.- Common mistakes: Common mistakes in the Project Description and Project Construction include: • Addressing only the project description and not the project construction • Describing an aspect of project construction and then not addressing the associated impacts of project construction under "Effects of the Action". • Failure to discuss temporary impacts such as detours, temporary road accesses, temporary clearing for staging areas, construction areas, and dewatering. • Failure to identify the location of borrow sites or disposal sites. • Failure to discuss construction sequencing and timing of construction. • Failure to discuss methods of clean-up, disposal, and/or revegetation. • Failure to discuss mitigation areas (plans) that may be required through the Corps, state or local regulations (i.e. wetland mitigation areas). • Referring to "Best Management Practices (BMPs)" and/or "Temporary Erosion and Sediment Controls (TESC)" without stating each BMP or TESC under Conservation Measures. • Referring to construction or revegetation monitoring without providing the monitoring plans with the BE/BA. II. Action Area: The action area includes not only the activity proposed within Corps jurisdiction but also all interrelated and/or interdependent activities. The action area must include the project area and all the areas surrounding the activity proposed in Corps jurisdiction up to where effects will no longer be felt. All potential direct and indirect, and short- and long-term effects to the listed species and its habitat are included. These impacts vary from species to species. For example, when driving piling, the project area would include the pile being driven and the equipment and barge driving the pile. If listed fish and bald eagles occur in the vicinity, the action area would include the project area and, among other impacts, the potential water quality impacts to fish through increased turbidity during the pile driving (typically a 25-foot radius around the pile) and the potential noise impacts to bald eagles from the pile driving (a radius of 1 mile around the pile). Interrelated activities are those activities that are a part of the activity in the Corps jurisdiction and depend on the activity in the Corps jurisdiction for its justification. The interrelated activity may be proposed by the applicant or a separate entity. For example, a weir is being placed in a stream and wetlands, changing the stream into a pond. Although not proposed by the applicant, an adjacent property owner installs an irrigation pump in the pond. The irrigation pump is an interrelated activity and must be addressed in the BE/BA. Interdependent activities are those activities that have no independent (separate) utility apart from the activity in Corps jurisdiction. A new boat house in the uplands is being constructed along with a new pier. The boat house is an interdependent activity because it does not have independent (separate) utility apart from the pier. It is often easier and less complicated to discuss interrelated and/or interdependent activities together. However, be sure to identify all potential interrelated and/or interdependent activities. We recommend that you coordinate with the Corps Project Manager to help define the action area for your proposed activity, especially linear projects. Common mistakes: Common mistakes in the action area include: • Failure to address interrelated/interdependent activities. • Failure to define the construction access areas (temporary and permanent and both in- water and uplands), staging areas, washout areas, and work corridors. • If defining potential area of effect for short-term impacts (i.e. water quality), failure to provide a justification or citation for the defined area of effect. • Failure to include mitigation areas that may be required through Corps, state or local regulations (i.e. wetland mitigation). III. Species and Habitat Information: Identify each listed or proposed species, including terrestrial species, in the action area, and indicate whether or not there is designated or proposed critical habitat. To determine what listed or proposed species may occur in the action area, contact: US Fish and Wildlife Service (USFWS) National Marine Fisheries Service (NMFS) Endangered Species Division Habitat Conservation Branch 510 Desmond Dr., SE # 102 510 Desmond Dr., SE # 103 Lacey, WA 98503-1273 Lacey, WA 98503 (360) 753-9440 (360) 753-9530 http://endangered.fws.gov/index.html http://www.nwr.noaa.gov 3 For Central and Eastern Washington: U.S. Fish and Wildlife Service (USFWS) Post Office Box 848 Ephrata, Washington 98823 (509) 754-8580 ATTN: Mr. Greg Kurz A. Species Present: List all federally listed or proposed species present in the vicinity of the project , stating their listing status (threatened or endangered) and if there is designated or proposed critical habitat. B. Species Utilization: Describe how the listed species is currently utilizing the action area, such as spawning, breeding, rearing, over-wintering, or travel corridor (migration). Discuss the species status in the action area and range-wide. If known, provide a short discussion on how the species historically utilized the area. Do not include detailed life histories. Depending upon the scale of the potential impacts and the project's timeline you may elect to include candidate species. C. Survey Results: If surveys have been conducted providing information as to the species utilization of the action area or similar areas, it is beneficial to reference the surveys and summarize the survey results — discussing when the survey was conducted, and the timing and method of the survey as well as the results. Depending on the scale of potential impacts and the habitat element that might be impacted, the Corps and the Services may require specific surveys to be conducted, with defined timing and protocols. A typical survey required in marine areas is a dive survey to determine presence or absence of eelgrass or other macroalgae. Coordinate with the Corps Project Manager to determine what, if any, surveys may be needed for your project assessment. Common mistakes: Common mistakes for species and habitat information include: • Failure to discuss all listed or proposed species in the action area. Often the BE/BA only addresses listed fish species and other listed or proposed species that may occur in the area (i.e. birds, mammals, plants, reptiles, and marine mammals) are forgotten. • Failure to discuss habitat for forage species. IV. Existing Environmental Conditions (Environmental Baseline): The environmental baseline should paint a picture of the habitat for listed or proposed species in the action area and the amount of degradation that has occurred to date. Describe the present condition of the habitat elements essential for the listed or proposed species. If the action area includes designated or proposed critical habitat for the listed species, describe the critical habitat and level of degradation. For example, if bald eagles nest in the area, a typical concern is the topography — is the project in line of site of the nest? — or noise levels and human activity — what is the 4 ambient noise level in the area? For listed or proposed fish species, concerns may include existing water quality, existing riparian vegetation and cover, availability of forage species (other fish, insects or invertebrates). For a list of habitat elements essential for listed or proposed salmonids in freshwater habitats, refer to the Pathways and Indicators developed by NMFS in the NMFS' "A Guide to Biological Assessments," revised March 23, 1999, and the FWS' "A Framework to Assist in Making Endangered Species Act Determinations of Effect for Individual or Grouped Actions at the Bull Trout Subpopulation Watershed Scale," February 1998. To date, NMFS has not finalized a matrix for marine/estuarine waters. Do not include a table or matrix for marine/estuarine waters since quantitative criteria have only been approved for freshwater systems. Common mistakes: Common mistakes in the environmental baseline include: • Failure to address forage species habitat as well as listed species habitat elements. • Extensive discussion on aspects of the environmental baseline either outside the action area or unrelated to the affected listed or proposed species. • Use of a matrix for marine/estuarine waters when a matrix does not exist. V. Effects Analysis: Describe the direct and indirect and secondary effects of the action on the protected species and critical habitat within the action area. Direct and indirect effects have very distinctive meanings under the Endangered Species Act (ESA). These are not the same definitions as under the National Environmental Policy Act (NEPA). Direct effects under ESA are defined as "effects that may result from the project that would directly affect the species". Indirect effects under ESA are defined as "effects that may result from the project that would occur later in time." For example, with a bulkhead, the direct effects may include the construction impacts (i.e. water quality impacts) and the impacts of the immediate existence of the structure (i.e. loss of habitat due to encroachment of the structure on the beach). The indirect effects may include erosion of the beach in front of the bulkhead or erosion that is exacerbated on the adjacent properties due to the bulkhead. Consider the impact to both individuals and the population.P p p Discuss the short-term construction-related impacts as well as the long-term and permanent effects. With regard d to critical habitat, depending on the listed or proposed species, include habitat alterations to essential features such as spawning sites, loss of prey or food sources, water quality and quantity, riparian vegetation, loss of nesting or breeding habitat or cover. Address the timing of the disturbances relative to the life history of the listed or proposed species or their forage species in the action area, particularly nesting or spawning periods. For both Corps regulatory purposes and ESA, the applicant must avoid or minimize impacts as much as possible. Variations in design or the construction techniques may avoid or minimize impacts to such an extent that impacts to listed species are insignificant and/or discountable, thereby qualifying the project for "informal consultation" - a much speedier review process. Insignificant is defined as "effects that are not measurable or detectable and never reach the scale where "take" occurs." Discountable is defined as s I "effects that are extremely unlikely to occur." However, if an individual impact, either in the short- or long-term, breaches the threshold of insignificant and/or discountable, then the activity is "likely to adversely affect" the listed species or critical habitat and the project must go through "formal consultation" procedures — a more lengthy process. Aim to avoid causing a "take" of any listed species or degradation of the environmental baseline for those species. The analysis must include consideration of the interrelated and interdependent effects of the actions. For the BA's only, the analysis must also include consideration of cumulative impacts. For the purposes of the Endangered Species Act, cumulative impacts are defined as all future State, local, or private activities that are reasonably certain to occur within the action area of the project under consultation. The analysis does not include future Federal activities (including those which would need to be authorized by a Corps permit) unrelated to the proposed action, as those impacts will be subject to separate consultation. For activities that may impact freshwater habitats where listed or proposed fish species are likely to occur, discuss and/or provide a matrix for the various environmental pathways and indicators of effect (See reference under Environmental Baseline). Depending on the activity proposed and its location, impacts to consider for listed or proposed fish species may include but are not limited to: • Effects of Construction: • Water Quality: • Effects of Stormwater Runoff: • Water Temperature: • Water Flow: • Habitat Access: • Riparian Area/Refugia: • Watershed Conditions: Common mistakes: Common mistakes seen in the effects analysis include: • Statements of effects with no rationale (i.e. "Impacts to water quality will be insignificant and/or discountable" without stating a reason). • Definitive statements of impacts or degree of impacts with no citation (i.e. Adult salmonids have a tolerance for 'Y' amount of suspended sedimentation levels above ambient background levels). • Describing a project aspect or construction method under project description and then not addressing the potential impacts of that aspect or method in the effects analysis. • Failure to address impacts associated with stormwater runoff and/or increase impervious surfaces. VI. Take Analysis: Assess and describe the potential for "incidental take." Take of a listed species means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct. Take may occur directly to individuals of a 6 species, or via a species' habitat or to designated critical habitat. "Incidental take" may occur if a species may be harmed or harassed, etc., in the conduct of your work though you intend it no harm. Harm is further defined to include significant habitat modification or degradation that results in death or injury to listed species by significantly impairing behavioral patterns such as breeding, feeding, or sheltering. Harass is defined as actions that create the likelihood of injury to listed species to such an extent as to significantly disrupt normal behavioral patters which include, but are not limited to, breeding, feeding, or sheltering. Incidental take is the "take" of individuals of a listed species that results from, but is not the purpose of, carrying out an otherwise lawful activity. Incidental take may be authorized through formal ESA Section 7 consultation. If you do intend to "take" species for scientific study or other purpose as part of your action, you must apply to the appropriate Service for an ESA Section 10 permit. Common Mistakes: Common mistakes in the take analysis include: • Writing a take analysis when the effects determination for a project is may affect, not likely to adversely affect. VII. Conservation Measures: Conservation measures are measures that would reduce or eliminate the adverse impacts of the proposed activity, particularly measures to be taken to reduce the likelihood of take. The measures need to be as specific as possible. Include a discussion of how construction methods and/or site locations have minimized potential impacts to the listed species. These conservation measures may include alterations in the proposed activity such as timing restrictions or changes in project features or location which are intended to reduce impacts, or Best Management Practices (BMPs) you intend to implement. It is essential to spell out the specific measures or BMPs implemented. Conservation measures may not simply defer to state or industry standards or guidelines, but must state the specific standard or guideline. If your project is approved, the conservation measures in the BE/BA will become conditions of the Corps authorization. Conservation measures need to be worded such that these measures shall be implemented, not that the measures may potentially be implemented if timing, money or other opportunities allow. Y pP Common Mistakes: Common mistakes in the Conservation Measures include: • Failure to define conservation measures in enforceable language (i.e. using terms such as "may", "to the practicable extent possible", "frequently", etc.). • Failure to define all the BMPs used (i.e. referring to contractor will implement BMPs). • Failure to provide revegetation and monitoring plans proposed as conservation measures. VIII. Determination of Effect: Summary of impacts concluding with statement(s) of effect, by listed or proposed species and designated or proposed critical habitat. Even projects that are intended to benefit the species might have short-term adverse impacts and those must be addressed. Only the following determinations are valid for listed species or designated critical habitat: • No Effect (NE) — meaning literally no effect whatsoever to the listed species or designated critical habitat. • May Affect, Not Likely to Adversely Affect (NLAA) — effects to the listed species or designated critical habitat are insignificant and/or discountable. A determination of "NLAA" would be made for those activities that have only a beneficial effect with no short- or long-term adverse impacts. • Likely to Adversely Affect (LAA) — effects will result in a short- or long-term incidental take of the listed species or designated critical habitat. Only one finding is made for the species and habitat, even if the project may have beneficial as well as detrimental affects. Therefore, even projects that ultimately benefit the species may be found to have an adverse affect, due to construction impacts. For proposed species, the finding is either Jeopardy or No Jeopardy. For proposed critical habitat the finding is will or will not adversely modify or destroy critical habitat. The Corps makes the official agency determination. We generally do not consult or request concurrence from the Services for No Effect determinations, though there are exceptions. The Services have the authority to veto a Corps determination— changing a NLAA to a LAA. of LAA to a NLAA. If the Services change the Corps determination, the Corps must accept the Services determination and consult as necessary. Common Mistakes: Common mistakes in the Determination of Effect includes: • Failure to justify a "no effect"determination appropriately. (Please see guidance on "no effect' determinations on the Corps website http://www.nws usace army mil/reg/req htm) • Failure to provide a detailed effects analysis to coincide with the determination of effect. For example: The determination of effect is "may affect, likely to adversely affect' but the effects analysis states that impacts are "insignificant and/or discountable". IX. References. Many BE/BA's either make definitive statements with no reference or cite studies or papers within the text of the BE/BA, but fail to provide full references. 8 X. Appendices (as needed): Such as condensed life histories, mitigation and/or revegetation implementation and Monitoring plans, results of studies, results of water or sediment quality testing, drawings, photos, etc. The Corps will attach detailed life histories, if needed. The detailed life histories are available on the Corps website http://www.nws.usace army mil/re /reo htm The Services and the Corps find it extremely helpful to have color photos of the existing project site included in the BE/BA, and this can serve to expedite our review of the environmental baseline and impacts. Common Mistakes: • Failure to include project drawings. The Services do not receive a co application, only the BE/BA. copy of the • Failure to include mitigation and revegetation implementation and monitoring plans referenced in the BE/BA. • Failure to include, if issued, a copy of the Hydraulic Project A Washington Department of Fish and Wildlife (WDFW). Approval (HPA) from • Failure to include color photographs of the project area. 9 Version: May 30, 2001 -WORKING DRAFT - PROJECT CONDITIONS OR ACTIONS THAT QUALIFY AS "NO EFFECT" ON LISTED OR PROPOSED T&E FISH OR THEIR CRITICAL HABITAT IN WASHINGTON STATE UNDER THE ENDANGERED SPECIES ACT' (All Fresh Waters, including Columbia River & Baker Bay) 1. No listed fish or fish proposed for listing, or their forage base, or designated or proposed critical habitat occur in the waterbody where work is to occur, and work will not result in short- or long-term water quality or quantity impacts which may affect listed or proposed species or their forage base downstream of the project site. This condition applies to all fresh waters of the U.S., including wetlands, and includes all isolated waters or wetlands. 2. For salmon and steelhead: Work that occurs as part of a single and complete project that is 300 feet or more away from a water of the U.S. which may contain listed fish or fish proposed for listing, including intermittent streams and adjacent wetlands, and work will not result in short- or long-term water quality or quantity impacts which may affect listed or proposed fish species or their forage base downgradient of the project site. The 300-foot measurement is a horizontal measurement from the ordinary high water (OHW) mark (or top of the bank if an OHW mark is not observable), and does not take topography into account. 3. For bull trout: For streams and rivers: Work that occurs as part of a single and complete project that is beyond the edge of the channel migration zone (CMZ) of streams and rivers which may contain listed fish or fish proposed for listing (including intermittent streams) plus one site-potential tree height, or that is 300 feet or more away from a water of the U.S., whichever is the greater distance, and work will not result in short- or long-term water quality or quantity impacts which may affect listed or proposed fish species or their forage base down-gradient of the project site. For the purposes of this determination, site-potential tree height shall be defined as 130 feet for areas east of the Cascade crest and 200 feet for areas west of the Cascade crest. The 300-foot measurement is a horizontal measurement from the ordinary high water (OHW) mark (or the top of the bank if an OHW mark is not Based on available literature [50 CFR Part 226, FR Vol. 65, No. 321, the Corps' Seattle District, Regulatory Branch, notes that a 300-foot riparian area should provide a high level of protection for these species and their critical habitat under the Endangered Species Act(ESA). This "No Effect" list is meant to cover those single and complete projects that meet the stated criteria. For projects that do not meet these criteria the applicant should contact the Corps for a case-by-case determination of effect under the ESA. Such projects may still qualify for a "No Effect" determination on an individual basis. This list does not represent any finding regarding the Clean Water Act, the Rivers and Harbors Act, nor any Federal law other than the ESA. observable), and does not take topography into account. For lakes and other waters: Work that occurs as part of a single and complete project that is 300 feet or more away from a lake or other water of the U.S. which may contain listed fish or fish proposed for listing, including wetlands, and work will not result in short- or long-term water quality or quantity impacts which may affect listed or proposed fish species or their forage base down-gradient of the project site. The 300-foot measurement is a horizontal measurement from the ordinary high water (OHW) mark (or the top of the bank if an OHW mark is not observable), and does not take topography into account. 4. Replacement of decking, rails, stringers, or other above-water parts on serviceable structures in navigable waters, provided that: any stain, paint, or preservatives to be applied on such components is completely dry/cured prior to installation, creosote and pentachlorophenol preserved wood will not be used, and no material shall enter the waterbody during the removal of decking, etc. [work typically allowed under Nationwide Permit 3] 5. Replacement of floats, provided that: replacement float is no larger and within the same footprint as the original float; only the over-water float is replaced and the original anchor system remains in place; the float is unchained from the anchor, moved onshore and new replacement float is placed in the water fully intact and chained to the existing anchor; any stain, paint, or preservatives to be applied onto the float is done while the float is on the land and all treatments are completely dry/cured prior to returning the float to the water; and the flotation is fully contained in a rigid protective casing. [work typically allowed under Nationwide Permit 3] (NOTE: The EPA/Corps jurisdiction under the Clean Water Act generally does not extend to: artificial lakes or ponds created by excavating and/or diking dry land to collect and retain water and which are used exclusively for such purposes as stock watering, irrigation, settling basins, or rice growing; nor artificial reflecting or swimming pools or other small ornamental bodies of water created by excavating and/or diking dry land to retain water for primarily aesthetic reasons; nor to waterfilled depressions created in dry land incidental to construction activity and pits excavated in dry land for the purpose of obtaining fill, sand, or gravel unless and until the construction or excavation operation is abandoned and the resulting body of water meets the definition of waters of the U.S. Additionally, construction or maintenance of farm or stock ponds is exempt from needing a Corps permit, as is construction of temporary sedimentation basins on a construction site which does not include placement of fill material into waters of the U.S.) Version: May 30, 2001 - WORKING DRAFT - PROJECT CONDITIONS OR ACTIONS THAT QUALIFY AS "NO EFFECT" ON LISTED OR PROPOSED T&E FISH OR THEIR CRITICAL HABITAT IN WASHINGTON STATE UNDER THE ENDANGERED SPECIES ACT' (All Marine/Estuarine Waters excluding Baker Bay) l. No listed fish or fish proposed for listing, or their forage base, or designated or proposed critical habitat occur in the marine or estuarine waterbody where work is to occur. 2. Work that occurs as part of a single and complete project and that is 300 feet or more upland from the shoreline (generally the line of Mean Higher High Water (MHHW) or ordinary high water (OHW) line), of any marine or estuarine waterbody (including any estuarine wetlands with or without tidal channels), except the mouth of the Columbia River (Baker Bay), and work will not result in short- or long-term water quality or quantity impacts which may affect listed or proposed fish species or their forage base downgradient of the project site. The 300-foot measurement is a horizontal measurement from the MHHW or OHW line, or from the upland edge of the estuarine wetland, and does not take topography into account. 3. Placement of navigation aids and regulatory markers on existing structures, and buoys for such purposes, in navigable waters, provided that: the buoys are not located over or adjacent to vegetated shallows or spawning areas for forage species and are anchored securely. [from Nationwide Permit (NWP) 1] 4. Replacement of decking, rails, stringers, or other above-water parts of serviceable structures in navigable waters, provided that: any stain, paint, or preservatives to be applied on such components is completely dried/cured prior to installation, creosote and pentachlorophenol preserved wood will not be used, and no material shall enter the waterbody during removal of decking, etc. [work typically allowed under NWP 3] ' Based on available literature [50 CFR Part 226, FR Vol. 65, No. 321, the Corps' Seattle District, Regulatory Branch, notes that a 300-foot-riparian area should provide a high level of protection for these species and their critical habitat under the Endangered Species Act(ESA). This "No Effect" list is meant to cover those single and complete projects that meet the stated criteria. For projects that do not meet these criteria the applicant should contact the Corps for a case-by-case determination of effect under the ESA. Such projects may still qualify for a "No Effect" determination on an individual basis. This list does not represent any finding regarding the Clean Water Act, the Rivers and Harbors Act, nor any Federal law other than the ESA. 5. Replacement of floats, provided that: replacement float is no larger and within the same footprint as the original float; only the over-water float is replaced and the original anchor system remains in place; the float is unchained from the anchor, moved onshore and new replacement float is placed in the water fully intact and chained to the existing anchor; any stain, paint, or preservatives to be applied onto the float is done while the float is on the land and all treatments are completely dry/cured prior to returning the float to the water; and the flotation is fully contained in a rigid protective casing. [work typically allowed under Nationwide Permit 3] COMMON TERMS USED IN THE ENDANGERED SPECIES ACT (ESA). The following definitions are provided to familiarize readers with important terms used in the ESA. • action Area. All areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action. • Biological Evaluation/Assessment (BE/BA). Information prepared by, or under the direction of, a Federal agency to determine whether a proposed action is likely to: (1) adversely affect listed species or designated critical habitat; (2) jeopardize the continued existence of species that are proposed for listing; or (3) adversely modify proposed critical habitat. The outcome of a biological evaluation/assessment determines whether formal consultation or a conference is necessary. An assessment is called a BE if the determination is "no effect" or "not likely to adversely affect." It is called a BA if the determination is "likely to adversely affect." • Biological Opinion (BO). Document which includes: (1) the opinion of the U.S. Fish and Wildlife Service (FWS) and by the Secretary of Commerce to the National Marine Fisheries Service (NMFS) (the Services) as to whether or not a Federal action is likely to jeopardize the continued existence of listed species; or result in the destruction or adverse modification of designated critical habitat; (2) a summary of the information on which the opinion is based; and (3) a detailed discussion of the effects of the action on listed species or designated critical habitat. • Candidate Species. The term "candidate species" means any species considered for possible addition to the List of Endangered and Threatened Species. The NMFS considers candidate species imminent for listing. • Conservation Measures. These are actions to benefit or promote the recovery of listed species that are included by the Federal agency as an integral part of the proposed action. These actions will be taken by the Federal agency or applicant, and serve to minimize or compensate for, project effects on the species under review. These may include actions taken prior to the initiation of consultation, or actions which the Federal agency or applicant have committed to complete in a BA or similar document. • Critical Habitat. The term "critical habitat" for a threatened or endangered species means: (1) the specific areas within the geographical area occupied by the species... on which are found those physical or biological features essential to the conservation of the species and which may require special management considerations or protection; and Enclosure 4 I (2) specific areas outside the geographical area occupied by the species... upon a determination by the Secretary that such areas are essential for the conservation of the species. • Destruction or Adverse Modification of Critical Habitat. A direct or indirect alteration that appreciably diminishes the value of critical habitat for both the survival and recovery of a listed species. • Effects of the Action. The direct and indirect effects of an action on the species or critical habitat, together with the effects of other activities that are interrelated or interdependent with that action. These effects are considered along with the environmental baseline and the predicted cumulative effects to determine the overall effects to the species for purposes of preparing a biological opinion on the proposed action. • Endangered Species. The term "endangered species" means any species which is in danger of extinction throughout all or a significant portion of its range. • Environmental Baseline. The past and present impacts of all Federal, State, or private actions and other human activities in an action area; the anticipated impacts of all proposed Federal projects in an action area that have already undergone formal or early Section 7 consultation; and the impact of State or private actions that are contemporaneous with the consultation process. • Formal Consultation. A process between the Services and a Federal agency or applicant that is initiated when a proposed Federal action is likely to adversely affect listed species or modify designated critical habitat. It begins with a Federal agency's or the Services written request and submittal of a complete initiation package. The process concludes with the issuance of a BO and incidental take statement by either of the Services. • Incidental Take. The take of listed fish or wildlife species that results from, but is not the purpose of, carrying out an otherwise lawful activity conducted by a Federal agency or applicant. • Indirect Effects. Those effects that are caused by or will result from the proposed action and are later in time, but are still reasonably certain to occur. • Informal Consultation. If a proposed Federal action may affect, but is not likely to adversely affect, listed species or designated critical habitat, the informal consultation process is required. This process allows the Federal agency to utilize the Services' expertise to evaluate the agency's assessment of potential Enclosure 4 2 Imo! effects or to suggest possible modifications to the proposed action which could avoid potentially adverse effects. It is also an optional process, prior to formal consultation, that includes all discussions and correspondence between the Services and a Federal agency or designated non-Federal representative to determine wh-!ther a proposed Federal action may affect listed species or critical habitat. • Interdependent Effects. Effects from activities which have no independent utility apart from the action being considered. • Interrelated Effects. Effects from activities that are part of a larger action and depend on the larger action for their justification. • Jeopardize. The determination given by the NMFS or FWS in their BO when an action that reasonably would be expected, directly or indirectly, to reduce species in appreciably the likelihood of both the survival and recovery of a listed s p the wild by reducing the reproduction, numbers, or distribution of that species. • Likely to Adversely Affect. The appropriate conclusion in a BA if any adverse effect to listed species may occur as a direct or indirect result of the proposed action or its interdependent or interrelated actions, and the effect is not: discountable, insignificant, or beneficial (see definition of "not likely to adversely affect" below). • No Effect. The appropriate conclusion when the action agency determines its proposed action will not affect a listed species or designated critical habitat. • Not Likely to Adversely Affect. The appropriate conclusion in a BE when effects on listed species are expected to be discountable, insignificant, or completely beneficial. • Proposed Species. Any species of fish, wildlife or plant that is proposed in the Federal Register to be listed under Section 4 of the Act. • Reasonable Prudent Measures. Actions the Director believes necessary or appropriate. • Take. To harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct. • Threatened Species. The term "threatened species" means any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range. Enclosure 4 3 I