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Agenda 12/30/2014 PELICAN BAY SERVICES DIVISION Municipal Service Taxing and Benefit Unit NOTICE OF PUBLIC MEETING DECEMBER 30, 2014 THE CLAM BAY COMMITTEE OF THE PELICAN BAY SERVICES DIVISION WILL MEET TUESDAY, DECEMBER 30 AT 1 PM AT THE COMMUNITY CENTER AT PELICAN BAY, LOCATED AT 8960 HAMMOCK OAK DRIVE, NAPLES, FLORIDA. AGENDA The agenda includes, but is not limited: 1 . Roll call 2. Agenda approval 3. Audience comments 4. Options for biological, hydrological, and water quality monitoring of Clam Bay 5. Review of biological assessment 6. Update on tidal gauges 7. Date for next meeting 8. Other 9. Adjourn ANY PERSON WISHING TO SPEAK ON AN AGENDA ITEM WILL RECEIVE UP TO ONE (1) MINUTE PER ITEM TO ADDRESS THE BOARD. THE BOARD WILL SOLICIT PUBLIC COMMENTS ON SUBJECTS NOT ON THIS AGENDA AND ANY PERSON WISHING TO SPEAK WILL RECEIVE UP TO THREE (3) MINUTES. THE BOARD ENCOURAGES YOU TO SUBMIT YOUR COMMENTS IN WRITING IN ADVANCE OF THE MEETING. ANY PERSON WHO DECIDES TO APPEAL A DECISION OF THIS BOARD WILL NEED A RECORD OF THE PROCEEDING PERTAINING THERETO, AND THEREFORE MAY NEED TO ENSURE THAT A VERBATIM RECORD IS MADE, WHICH INCLUDES THE TESTIMONY AND EVIDENCE UPON WHICH THE APPEAL IS TO BE BASED. IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS AN ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS MEETING YOU ARE ENTITLED TO THE PROVISION OF CERTAIN ASSISTANCE. PLEASE CONTACT THE PELICAN BAY SERVICES DIVISION AT (239) 597-1749. VISIT US AT HTTP://PELICANBAYSERVICESDIVISION.NET. 0 12/23/2014 4:25:46 PM Clam Bay Monitoring A.Biological Monitoring) Current cost Monitor 22 established mangrove plots,including data and photos $22,250 of each plot and quarterly roof-top photos of mangroves Monitor eight seagrass transects in Outer Clam Bay and nearby 4,650 channels Monitor three continuous water level loggers deployed in Clam Bay 9770 Inspect and schedule maintenance as needed of the hand-dug channels 10,400 Provide additional consulting services,such as meetings,field 15,0002 observation,reports,as needed Prepare,present,and submit annual report 14,815 Additional biological monitoring beginning in May 2015 Est.Cost Establish and monitor plots in scrub and hammock habitats $60003 Monitor gopher tortoise burrows 37504 Monitor other bird/fish/benthic invertebrates5 5000 Monitor archeological sites 750 Monitor upland activities that could affect flow 600 Inspect canoe trail and Clam Bay signage 300 Promote education information re:exotic&nuisance species 700 Coordinate with Collier County&Naples Grande re: vegetation 500 and litter control Monitor for piping plover presence before&after dredging events 75006 B.Hydrographic Monitoring Annual tidal data analysis and reporting' $28,750 Additional hydrographic monitoring beginning in May 2015 Annual bathymetric survey of Clam Pass and report 29,300 Bathymetric survey of interconnecting waterways as needed8 30,000 C. Water Quality Monitoring9 Annual water quality analysis and reporting10 5520 Additional Water Quality Analysis and Reporting beginning in May 2015 Quarterly water quality analysis and reportingll TBD 1 Currently done under Contract 10-5571 with Turrell,Hall&Associates,Inc. 2 Time and materials,not to exceed 3 First year cost; in subsequent years cost would be about$2000 4 Cost would not be incurred every year but every 2°d/3rd year 5 Surveys for each species would be done every 3-4 years,resulting in one survey per year 6 2x/month for 3 months before a dredging event and for ten months a year for 3 years after a dredging event 7 Currently done by Humiston and Moore Engineers under Contract 10-5771 8 Will be conducted every 3-5 years 9 Currently done by Turell,Hall&Associates,Inc.under Contract 10-5771 1016 parameters and 9 locations - 1115 parameters and 15 locations 1 CLAM PASS DREDGING AND ECOSYSTEM ENHANCEMENTS BIOLOGICAL ASSESSMENT DECEMBER 2014 PREPARED BY: TURRELL HALL& ASSOCIATES,INC 3584 EXCHANGE AVENUE NAPLES,FL 34104 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 The Clam Bay Natural Resource Protection Area (NRPA) is a 560.05-acre estuarine system consisting of sandy beaches, Clam Pass, shallow bays, tidal creeks or tributaries, seagrass beds, and mangrove forests on the west coast of Collier County in Southwest Florida. The NRPA includes three primary bays, Outer Clam Bay (southernmost), Inner Clam Bay (central), and Upper Clam Bay (northernmost), connected by a series of tidal creeks and connected to the Gulf of Mexico by Clam Pass. The Pelican Bay Services Division has conducted monitoring and management activities within the NRPA for the past 15+years. Some of these activities, such as dredging, require federal authorizations which can include review by the US Fish and Wildlife Service and the National Marine Fisheries Service. This document addresses federally listed species associated with the proposed and potential ecosystem enhancement activities and the effect, or lack thereof, of this project on these species. The species at issue include: the endangered American crocodile (Crocodylus acutus), the threatened eastern indigo snake (Drymarchon corais couperi), the endangered green (Chelonia mydas), hawksbill (Eretmochelys imbricata), Kemp's ridley (Lepidochelys kempii), and leatherback (Dermochelys coriacea) sea turtles, the threatened loggerhead sea turtle (Caretta caretta), the candidate gopher tortoise (Gopherus polyphemus), the threatened wood stork (Mycteria americana), the endangered piping plover (Charadrius melodus), the endangered Florida bonneted bat (Eumops floridanus), the endangered Florida panther (Puma concolor coryi), the endangered West Indian manatee (Trichechus manatus), and the endangered smalltooth sawfish (Pristis pectinata). The result of the analysis in this document is a determination that the management activities proposed or likely to occur within Clam Pass and its associated estuary are not likely to adversely affect any of the above listed species. This document is based on information compiled from the South Florida Multi-Species Recovery Plan ("SFMSRP"), Statewide Programmatic Biological Opinions, the NOAA office of protected species,wildlife surveys, field inspections, and other sources of information. I. CONSULTATION HISTORY [The information supplied applies to discussions held between the project consultant(s) and the U.S. Fish and Wildlife Service(FWS)or the National Marine Fisheries Service(NMFS). No record of communication between FWS or NMFS, and the Army Corps of Engineers (Corps), or other commenting parties is included.] Consultation to date with USFWS was via a pre-application meeting held at the Corps of Engineer's Ft. Myers Service Center in January 2013. Representatives of USFWS and NMFS participated in the meeting via phone. During this informal meeting sea turtles, piping plovers, manatees, and smalltooth sawfish were mentioned as species of concern. On February 22, 2013 the USFWS issued a Biological Opinion in association with the Corps of Engineers Nationwide Permit SAJ-1996-02789 for a single event dredging of Clam Pass following the Pass's closure in December 2012. The Biological Opinion addressed potential effects of the proposed project on the threatened piping plover, threatened loggerhead sea turtle, 1 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 endangered leatherback sea turtle, endangered green sea turtle, endangered hawksbill sea turtle, endangered Kemp's ridley sea turtle, and endangered West Indian manatee. Subsequent updates on the status of the Clam Bay NRPA Management Plan have been provided to USFWS and NMFS in May and September 2014. II. BIOLOGICAL ASSESSMENT Site Description Clam Pass is a small, marginally stable inlet that has migrated north and south along the shore over the years. Prior to dredging, average water depths of Clam Pass were -2.5' to -1.0', and its width ranged from 30-50' (Collier County, 1994). The Pass remains the primary source of tidal exchange for the Clam Bay system, but it is restricted by sediment deposits just inside the Pass and in the long meandering tidal creeks surrounded by mangrove forests. The Clam Bay Natural Resource Protection Area(NRPA) is an approximately 560-acre estuarine system connected to the Gulf of Mexico through Clam Pass. The system consists of sandy beaches, shallow bays, tidal creeks, seagrass beds, and mangrove forests on the west coast of Collier County in Southwest Florida. It is one of the few remaining estuarine systems in the Cocohatchee-Gordon River Drainage System and the only coastal NRPA in Collier County. Historically the Clam Bay System was connected to Wiggins Pass to the north via a system of mangrove swamps and shallow creeks with intermediate open water areas that were excavated and are now known as Vanderbilt Lagoon (Collier County, 1994, Tropical Biolndustries, 1978). It is recognized that the connection was marginal at best and while passable at times, it was not uniformly and consistently navigable (Clam Bay Restoration and Management Plan, 1998). Connection to Vanderbilt Lagoon ended in 1952 with the construction of Vanderbilt Beach Road. Similarly, historical aerials of the Seagate Drive area taken prior to its construction show that Outer Clam Bay was connected to the mangrove swamps to the south via shallow meandering creeks and intermediate open waters leading to Doctors Pass. These creeks were periodically navigable by canoes and small skiffs. These swamps to the south were eventually excavated to become Venetian and Moorings Bays. The connection to Outer Clam Bay ended in 1958 when Seagate Drive was constructed. Today, the Clam Bay NRPA includes three primary bays, Outer Clam Bay (southernmost), Inner Clam Bay (central), and Upper Clam Bay (northernmost), connected by a series of tidal creeks and connected to the Gulf of Mexico by Clam Pass. The community of Pelican Bay abuts the northern and eastern edges of the system, while Seagate and Naples Cay communities abut the southern portion of the system. This system is an important natural and recreational resource for local residents and visitors. 2 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 The Clam Bay NRPA Management Plan provides an overview of the Clam Bay Estuary and past management activities which have been undertaken. Fish and Wildlife Resources The Florida Department of Transportation's Land Use, Cover and Forms Classification System (FLUCFCS 1999) has been used to identify the plant communities found within the Clam Bay NRPA. See the attached Exhibit 3 for an overall FLUCFCS map of the Clam Bay system. List of FLUCFCS Communities within the Clam Bay NRPA Based on 2014 mapping by Turrell,Hall&Associates, Inc. FLUCFCS Community Description Upland or Acreage within %of Clam Bay Code Wetland the NRPA NRPA 181 Swimming Beach Upland 33.35 5.95 186 Community Recreation Upland 2.06 0.37 Facilities 322 Coastal Scrub Upland 22.31 3.98 428 Cabbage Palm Hammock Upland 2.50 0.45 510 and Interior Creeks and Bays (with Wetland 129.73 23.16 540 and without direct connection to Gulf or Ocean) 612 Mangrove Swamp Wetland 359.56 64.20 642 Saltwater Marsh Wetland 2.35 0.42 651 Tidal Flat Wetland 8.05 1.44 814 Roads and Highways Upland 0.14 .03 911 Seagrasses** Wetland 2.85** 0.84** **included in the Bays (510 and 540) category Description of Proposed Action The Pelican Bay Services Division (PBSD) proposes to periodically dredge the Clam Pass inlet and channel in Collier County, Florida (Exhibit 4). The intent of the proposed dredging project is to aid in tidal flushing and water quality in order to maintain and enhance ecological improvements to the estuary outlined in the November 2014, Clam Bay NRPA Management Plan. It is anticipated that the dredging of Clam Pass (or portions of the Pass) could occur on a three to five year basis. Using hydraulic, mechanical or a combination of dredges, approximately 1,700 linear feet of Clam Pass inlet and channel will be dredged as needed between Stations 0+00 and 17+00 (Exhibit 5). The proposed dredge template elevation will be -5.0 feet North American Vertical Datum(NAVD) from between Stations 0+00 and 3+64.5. A 0.5-foot over-dredge allowance will be requested. The profile of the dredge cuts within this section of work will consist of a 1 vertical foot to 1 horizontal foot slope up to the MLW elevation and then gentler sloping to 3 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 mimic the wide intertidal swash area that naturally forms in association with this Pass. The proposed dredge template elevation from Stations 3.64.5 to 17+00 will be -4.0 feet North American Vertical Datum (NAVD). A 0.5-foot over-dredge allowance will be requested. The profile of all dredge cuts within this section of the work will consist of a 1 vertical foot to 1 horizontal foot slope from the bottom to the top of the dredge cut. Appropriate buffers will be maintained between the dredge cuts and adjacent mangroves and/or seagrasses to minimize the potential for adverse impacts to adjacent resources. A 50-foot wide (bottom width) cut will be dredged, which is sufficient to allow access for a shallow-draft, barge with appropriate dredging equipment(mechanical or hydraulic) inside Clam Pass. All excavated and dredged beach compatible material will be deposited within the fill template (Florida Department of Environmental Protection [DEP] reference monument R-39+733 feet to R-41, and R-42 to R-45+500 feet [total fill template is approximately 0.85 mile]), and graded using bulldozers or other appropriate grading equipment, to the permitted design fill profile (1 vertical foot : 10 horizontal feet slope with an elevation of+5.0 and+6.6 feet NAVD in the north and south fill template, respectively). Construction vehicles will either access the shoreline at one of two beach corridors located approximately 2.4 and 2 miles north and south of Clam Pass, respectively (Exhibit 6) or may be delivered directly to the site by barge. All sand placed within the fill template must be approved by the DEP and meet all requirements as outlined in the Florida Administrative Code subsection 62B-41.007. Although not anticipated, any non-beach compatible material will be stockpiled on the upland and ultimately disposed of landward of the Coastal Construction Control Line at the Collier County Landfill. Construction vehicles and equipment may traverse or be stored at the staging areas, stockpile area, and/or within the pipeline corridor. Existing vegetated habitat at these sites and corridors shall be protected to the maximum extent practicable. Any impacted vegetation at each of these sites and corridors shall be restored to preconstruction conditions. In addition, if heavy equipment and vehicles are required to traverse the dry beach above the mean high water line, the path will be tilled to 3 feet to avoid compaction impacts prior to the following sea turtle nesting season. The interconnecting waterways between Upper, Inner, and Outer Clam Bays will be inspected periodically (Exhibit 7). If blockages or shoaling is discovered within these waterways, additional permitting may be pursued to re-open these channels. Depth of cut, width of cut, and amount and type of material to be removed will all be determined as needed at the time of the work. The project will also continue to conduct periodic ecological maintenance activities within the tidal Clam Bay estuary involving: a) manual clearing of existing hand-dug channel cuts (using round-point shovels/machetes); b) creation of additional hand-dug channel cuts; c) mangrove trimming and vegetation/debris removal along the main interconnecting waterways and the approximately 56,660 linear feet of flushing cuts within the estuary system (Exhibit 8). Removed natural materials will be dispersed along the channel cuts, mulched for reuse, or disposed of at the Pelican Bay Services landscape disposal site or a licensed local disposal facility. No mechanical equipment will be used for these maintenance activities. The clearing within these small channels is contingent upon conditions of >50% flow reduction due to 4 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 blockage or obstructions. The work area consists of a network of hand-dug channel cuts of 3 various widths (Type 1: 36-inch wide along 28,480 linear feet; Type 2: 12-inch wide along 19,720 linear feet; Type 3: 6-12-inch wide along 8,460 linear feet) that improve flushing and eliminate water ponding within the mangrove forest areas. The proposed work will continue ecological restoration work that has been conducted since the implementation of the 1998 Clam Bay Restoration and Management Plan and which has resulted in successful restoration of mangrove habitat. The volume of material to be removed is approximately 20 cubic yards per year on an as needed basis. This annual work is conducted in May and June, generally for a 1-2 week duration. Site access is by foot from upland areas, or via small vessels. This work area is generally at or above the Mean High Water (MHW) line in waters that are characterized as having a maximum water depth of 18 inches. Action Area The action area is usually defined as all areas that will be affected directly or indirectly by the action and not merely the immediate area involved in the action. For the activities potentially occurring under the requested authorizations, the action area would be identified as the entire Clam Bay NRPA area including dredge template(s), sand fill template(s), beach corridors, pipeline corridors, staging areas, upland disposal sites, and extending up to 300 feet offshore within 0.5 mile around the Pass. The project is located along the Gulf of Mexico, in Collier County,Florida, centered at latitude N 26.2197 and longitude W 81.8169. Status of the Species/Critical Habitat This section summarizes the biology and ecology of the potentially affected species that may be present within the Action Area, as well as information regarding the status and trends of the species throughout their entire range. The U.S. Fish and Wildlife Service and National Marine Fisheries Service use this information to assess whether a federal action is likely to jeopardize the continued existence of the species. The "Environmental Baseline" section summarizes information on status and trends of the species, specifically within the action area. This summary provides the foundation for the assessment of the effects of the proposed action, as presented in the "Effects of the Action" section. American Crocodile The Florida population of the American crocodile was federally listed as a threatened species on September 25, 1975 (40 Federal Register[FR] 44149). The American crocodile inhabits coastal habitats of extreme South Florida,the Caribbean, Mexico, Central America and northern South America.At the northern limit of its range in Florida,American crocodiles coexist with American alligators. The American crocodile typically inhabits brackish and saltwater habitats. Frequently confused with the American alligator, crocodiles have several distinguishing characteristics. Adults are a grayish-green with a white or yellowish undersides. Crocodiles have narrow triangular shaped snouts and the fourth tooth on both sides of the lower jaw is exposed when the jaw is closed. Alligators are darker in color,with a more rounded snout and no teeth exposed. 5 f Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 The northern end of the American crocodiles range is extreme south Florida. They can be found in shallow lakes, marshes, ponds, swamps, rivers and creeks. Although crocodiles occur primarily in estuarine areas,they prefer areas with lower salinities, except for nesting activities. Critical habitat has been designated for the American crocodile in south Florida in the vicinity of Florida Bay and the Florida Keys. Critical habitat includes all land and water within the area from Turkey Point, Miami-Dade County, on the coast of Biscayne Bay;down to the westernmost tip of Long Key;back up along the shore of the Gulf of Mexico to the north side of Little Sable Creek; east to Nine-Mile Pond; and then back to Turkey Point(50 CFR 17.95). Life History/Population Dynamics Crocodiles go through a complicated courtship which may last for several hours or several days. Eggs are typically laid during wet season, beginning around the end of April and beginning of May. Females lay between 20 and 60 eggs per clutch, which will incubate for about 85 days. Sex of the hatchling is determined by the temperature at which the eggs are incubated. Nests are constructed so that the eggs will be above the high water mark. Eggs cannot survive flooding for more than 12 hours. Most nesting sites are near higher salinity water (greater than 80% seawater, 29 ppt). The mother does not typically stay near the nest during incubation, but will dig open the nest around hatching and assist hatchlings from the nest. After this the adult leaves the nesting area and leaves the hatchlings on their own. Status and Distribution Historically the American crocodile reaches the northern end of its range around Lake Worth in Palm Beach County on the east coast of Florida, and as far north as Tampa Bay on the west coast of Florida. It is also found throughout the Caribbean and Central America all the way to Venezuela in South America. The Florida population is now restricted to extreme South Florida, north to Miami-Dade County on the east coast and Lee County on the west coast. The population has always been believed to be relatively small, approximately 400-500 individuals. Threats to the crocodile population include predation of hatchlings, habitat loss, and changes to the hydrological regime. Alteration of salinity and water levels as a result of drainage programs throughout the state effects where the crocodile can lay viable nests. The population appears to be making a rebound, but with very little habitat and such a limited range, the species remains threatened. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the American crocodile in the Action Area. Habitat Conservation - Habitats used by the American crocodile are being impacted by encroachment into estuarine habitats to support a growing human population in the State of Florida. Demographic Concerns - The relatively small distribution of the American crocodile population limit the status and trends, although the trend appears to be an increasing population in south 6 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Florida. Habitat Loss/Habitat Degradation - The most threatening issue facing the survival and recovery of the American crocodile is habitat loss and degradation as a result of changes in hydrology. Human-induced Effects - Indirect adverse effects on the American crocodile are likely to occur in populations adjacent to or near human habitations. For example, individual encounters between humans and crocodiles are likely to result in increased mortality rates. Further, as remaining habitats are either lost or impacted by changes in hydrology, increased pressure will be placed on resident individuals. Eastern Indigo Snake(Drymarchon corais couperi) Species/Critical Habitat Description The eastern indigo snake is a large, black, non-venomous snake found in the southeastern U.S. It is widely distributed throughout central and south Florida, but primarily occurs in sandhill habitats in northern Florida and southern Georgia. The eastern indigo snake was listed as a threatened species as a result of dramatic population declines caused by over-collecting for the domestic and international pet trade, as well as mortalities caused by rattlesnake collectors who gassed gopher tortoise burrows to collect snakes. Since its listing by the Service as a threatened species, habitat loss and fragmentation have become much more significant threats to the eastern indigo snake. No critical habitat has been designated for the eastern indigo snake. Over most of its range, the eastern indigo snake frequents several habitat types, including pine flatwoods, scrubby flatwoods, high pine, dry prairie, tropical hardwood hammocks, edges of freshwater marshes, agricultural fields, coastal dunes, and human-altered habitats. Eastern indigo snakes need a mosaic of habitats to complete their annual cycle. Interspersion of tortoise- inhabited sandhills and wetlands improves habitat quality for this species. Eastern indigo snakes require sheltered retreats from winter cold and desiccating conditions. Wherever the eastern indigo snake occurs in xeric habitats, it is closely associated with the gopher tortoise, the burrows of which provide shelter from winter cold and desiccation. In wetter habitats that lack gopher tortoises, eastern indigo snakes may take shelter in hollowed root channels, hollow logs, or the burrows of rodents, armadillo, or land crabs. In the milder climates of central and southern Florida, eastern indigo snakes exist in a more stable thermal environment, where availability of thermal refugia may not be as critical to the snake's survival. Throughout peninsular Florida, this species may be found in all terrestrial habitats, which have not suffered high-density urban development. They are especially common in the hydric hammocks throughout this region. In extreme south Florida, these snakes are typically found in pine flatwoods, pine rocklands, tropical hardwood hammocks, and in most other undeveloped areas. Eastern indigo snakes also use some agricultural lands (e.g., citrus) and various types of wetlands. Even though thermal stress may not be a limiting factor throughout the year in south Florida, eastern indigo snakes still seek and use underground refugia in the region. Life history/Population Dynamics Most information on the reproductive cycle of eastern indigo snakes is from data collected in north Florida. Here, breeding occurs between November and April, and females deposit four to 7 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 12 eggs during May or June. Eggs are laid from late May through August, and young hatch in approximately three months. Peak hatching activity occurs between August and September, and yearling activity peaks in April and May. Limited information on the reproductive cycle in south-central Florida suggests that the breeding and egg laying season may be extended. In this region, breeding extends from June to January, laying occurs from April to July, and hatching occurs during mid-summer to early fall. Female indigo snakes can store sperm and delay fertilization of eggs. There is no information on how long eastern indigo snakes live in the wild; in captivity,the longest an eastern indigo snake lived was 25 years, 11 months(Shaw 1959). Status and Distribution Historically, the eastern indigo snake occurred throughout Florida and in the coastal plain of Georgia, Alabama and Mississippi. Georgia and Florida currently support the remaining endemic populations of the eastern indigo snake. In south Florida, the eastern indigo snake is thought to be widely distributed. Given their preference for upland habitats, eastern indigos are not commonly found in great numbers in the wetland complexes of the Everglades region. As stated above, the eastern indigo snake was listed because of a population decline caused by habitat loss, over-collecting for the pet trade, and mortality from gassing gopher tortoise burrows to collect rattlesnakes. At the time of listing, the main factor in the decline of this species was attributed to exploitation for the pet trade. As a result of effective law enforcement, the pressure from collectors has declined but still remains a concern. The eastern indigo snake will use most of the habitat types available in its home range, but prefers open, undeveloped areas. Because of its relatively large home range, this snake is especially vulnerable to habitat loss, degradation, and fragmentation. Extensive tracts of wild land are the most important refuge for large numbers of eastern indigo snakes. The wide distribution and large territory size of the eastern indigo snake complicate evaluation of its population status and trends. Although the Service has no quantitative data with which to evaluate the trend of eastern indigo snakes in south Florida, it surmises the population as a whole is declining because of current rates of habitat destruction and degradation. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the eastern indigo snake in the Action Area. Habitat Conversion - Upland habitats used by the indigo snake are rapidly being converted to commercial, residential, and other uses to support a growing human population in the State of Florida. Demographic Concerns - The wide distribution and large territory size of the eastern indigo snake complicate evaluation of its population status and trends. Although the USFWS has no quantitative data with which to evaluate the trend of eastern indigo snakes in south Florida, it surmises the population as a whole is declining because of current rates of habitat destruction and degradation. 8 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Habitat Loss/Habitat Degradation - The most threatening issue facing the survival and recovery of the eastern indigo snake is habitat loss and fragmentation resulting from the conversion of suitable habitats to other uses. Human-induced Effects - Indirect adverse effects on the indigo snake are likely to occur in populations adjacent to or near human habitations. For example, individual encounters between humans and their pets with indigos are likely to result in increased mortality rates. Further, as remaining habitats are either lost or fragmented, increased pressure will be placed on resident individuals. Sea Turtles Loggerhead Sea Turtle The loggerhead sea turtle was federally listed as a threatened species on July 28, 1978 (43 Federal Register [FR] 32800). The loggerhead occurs throughout the temperate and tropical regions of the Atlantic,Pacific, and Indian Oceans. The loggerhead sea turtle grows to an average weight of about 200 pounds and is characterized by a large head with blunt jaws. Adults and subadults have a reddish-brown carapace. Scales on the top of the head and top of the flippers are also reddish-brown with yellow on the borders. Hatchlings are a dull brown color (NMFS 2009a). The loggerhead feeds on mollusks, crustaceans, fish, and other marine animals. The loggerhead may be found hundreds of miles out to sea, as well as in inshore areas such as bays, lagoons, salt marshes, creeks, ship channels, and the mouths of large rivers. Coral reefs, rocky places, and ship wrecks are often used as feeding areas. Within the Northwest Atlantic, the majority of nesting activity occurs from April through September, with a peak in June and July (Williams-Walls et al. 1983, Dodd 1988, Weishampel et al. 2006). Nesting occurs within the Northwest Atlantic along the coasts of North America, Central America, northern South America, the Antilles, Bahamas, and Bermuda, but is concentrated in the southeastern U.S. and on the Yucatan Peninsula in Mexico on open beaches or along narrow bays having suitable sand (Sternberg 1981,Ehrhart 1989, Ehrhart et al. 2003,NMFS and Service 2008). No critical habitat has been designated for the loggerhead sea turtle. Life history/Population Dynamics Loggerheads are long-lived, slow-growing animals that use multiple habitats across entire ocean basins throughout their life history. This complex life history encompasses terrestrial, nearshore, and open ocean habitats. The three basic ecosystems in which loggerheads live are the: 1. Terrestrial zone (supralittoral) - the nesting beach where both oviposition (egg laying) and embryonic development and hatching occur. 2. Nearshore (Neritic) zone - the inshore marine environment (from the surface to the sea floor) where water depths do not exceed 656 feet. 3. Oceanic zone - the open ocean environment (from the surface to the sea floor) where water depths are greater than 656 feet. 9 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Loggerheads nest on ocean beaches and occasionally on estuarine shorelines with suitable sand. Nests are typically laid between the high tide line and the dune front (Routa 1968, Witherington 1986, Hailman and Elowson 1992). Wood and Bjorndal (2000) evaluated four environmental factors (slope, temperature, moisture, and salinity) and found that slope had the greatest influence on loggerhead nest-site selection on a beach in Florida. Loggerheads appear to prefer relatively narrow, steeply sloped, coarse-grained beaches, although nearshore contours may also play a role in nesting beach site selection. The warmer the sand surrounding the egg chamber, the faster the embryos develop. Sand temperatures prevailing during the middle third of the incubation period also determine the sex of hatchling sea turtles (Mrosovsky and Yntema 1980). Incubation temperatures near the upper end of the tolerable range produce only female hatchlings while incubation temperatures near the lower end of the tolerable range produce only male hatchlings. The loggerhead occurs throughout the temperate and tropical regions of the Atlantic, Pacific, and Indian Oceans. However, the majority of loggerhead nesting is at the western rims of the Atlantic and Indian Oceans. Two loggerhead nesting beaches have greater than 10,000 females nesting per year: South Florida (U.S.) and Masirah (Oman). Those beaches with 1,000 to 9,999 females nesting each year are Georgia through North Carolina (U.S.), Quintana Roo and Yucatan (Mexico), Cape Verde Islands (Cape Verde, eastern Atlantic off Africa), and Western Australia (Australia). Smaller nesting aggregations with 100 to 999 nesting females annually occur in the Northern Gulf of Mexico (U.S.), Dry Tortugas (U.S.), Cay Sal Bank (Bahamas), Sergipe and Northern Bahia (Brazil), Southern Bahia to Rio de Janerio (Brazil), Tongaland (South Africa), Mozambique, Arabian Sea Coast (Oman), Halaniyat Islands (Oman), Cyprus, Peloponnesus (Greece), Island of Zakynthos (Greece),Turkey, Queensland (Australia), and Japan. The loggerhead is commonly found throughout the North Atlantic including the Gulf of Mexico, the northern Caribbean, the Bahamas archipelago, and eastward to West Africa, the western Mediterranean, and the west coast of Europe. The major nesting concentrations in the U.S. are found in South Florida. However, loggerheads nest from Texas to Virginia. Total estimated nesting in the U.S. has fluctuated between 49,000 and 90,000 nests per year from 1999-2008 (FWC 2009a,NMFS and Service 2008). About 80 percent of loggerhead nesting in the southeast U.S. occurs in six Florida counties (Brevard, Indian River, St. Lucie, Martin, Palm Beach, and Broward Counties). Adult loggerheads are known to make considerable migrations between foraging areas and nesting beaches (Schroeder et al. 2003, Foley et al. 2008). During non-nesting years, adult females from U.S. beaches are distributed in waters off the eastern U.S. and throughout the Gulf of Mexico,Bahamas, Greater Antilles, and Yucatan. Status and Distribution The USFWS has identified five recovery units in the Northwest Atlantic based on genetic differences and a combination of geographic distribution of nesting densities, geographic separation, and geopolitical boundaries (NMFS and Service 2008). Recovery units are subunits of a listed species that are geographically or otherwise identifiable and essential to the recovery of the species. 10 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Recovery units are individually necessary to conserve genetic robustness, demographic robustness, important life history stages, or some other feature necessary for long-term sustainability of the species. The five recovery units identified in the Northwest Atlantic are: 1. Northern Recovery Unit (NRU) - defined as loggerheads originating from nesting beaches from the Florida-Georgia border through southern Virginia (the northern extent of the nesting range); 2. Peninsula Florida Recovery Unit (PFRU) - defined as loggerheads originating from nesting beaches from the Florida-Georgia border through Pinellas County on the west coast of Florida, excluding the islands west of Key West,Florida; 3. Dry Tortugas Recovery Unit (DTRU) - defined as loggerheads originating from nesting beaches throughout the islands located west of Key West, Florida; 4. Northern Gulf of Mexico Recovery Unit (NGMRU) - defined as loggerheads originating from nesting beaches from Franklin County on the northwest Gulf coast of Florida through Texas; and 5. Greater Caribbean Recovery Unit (GCRU) - composed of loggerheads originating from all other nesting assemblages within the Greater Caribbean (Mexico through French Guiana, The Bahamas, Lesser Antilles, and Greater Antilles). The NRU is the second largest loggerhead nesting aggregation in the Northwest Atlantic. Annual nest totals from northern beaches averaged 5,215 nests from 1989-2008, a period of near- complete surveys of NRU nesting beaches (NMFS and Service 2008), representing approximately 1,272 nesting females per year(4.1 nests per female, Murphy and Hopkins 1984). The loggerhead nesting trend from daily beach surveys showed a significant decline of 1.3 percent annually.Nest totals from aerial surveys conducted by the South Carolina Department of Natural Resources showed a 1.9 percent annual decline in nesting in South Carolina since 1980. Overall, there is strong statistical data to suggest the NRU has experienced a long-term decline (NMFS and Service 2008). The PFRU is the largest loggerhead nesting assemblage in the Northwest Atlantic. A near complete nest census of the PFRU undertaken from 1989 to 2007 reveals a mean of 64,513 loggerhead nests per year representing approximately 15,735 females nesting per year (4.1 nests per female, Murphy and Hopkins 1984) (FWC 2008d). This near-complete census provides the best statewide estimate of total abundance, but because of variable survey effort, these numbers cannot be used to assess trends. In 1979, the Statewide Nesting Beach Survey (SNBS) program was initiated to document the total distribution, seasonality, and abundance of sea turtle nesting in Florida. In 1989, the INBS program was initiated in Florida to measure seasonal productivity, allowing comparisons between beaches and between years (FWC 2009b). Of the 190 SNBS surveyed areas, 33 participate in the INBS program (representing 30 percent of the SNBS beach length). The NGMRU is the third largest nesting assemblage among the four U.S. recovery units.Nesting surveys conducted on approximately 186 miles of beach within the NGMRU (Alabama and Florida only) were undertaken between 1995 and 2007 (statewide surveys in Alabama began in 2002). The mean nest count during this 13-year period was 906 nests per year, which equates to about 221 females nesting per year (4.1 nests per female, Murphy and Hopkins 1984, (FWC 2008d). Evaluation of long-term nesting trends for the NGMRU is difficult because of changed 11 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 and expanded beach coverage. Loggerhead nesting trends are best assessed using standardized nest counts made at INBS sites surveyed with constant effort over time. There are 12 years (1997-2008) of Florida INBS data for the NGMRU (FWC 2008d). A log-linear regression showed a significant declining trend of 4.7 percent annually(NMFS and Service 2008). The DTRU, located west of the Florida Keys, is the smallest of the identified recovery units. A near-complete nest census of the DTRU undertaken from 1995 to 2004, excluding 2002, (nine years surveyed) reveals a mean of 246 nests per year, which equates to about 60 females nesting per year(4.1 nests per female, Murphy and Hopkins 1984) (FWC 2008d). Surveys after 2004 did not include principal nesting beaches within the recovery unit(i.e., Dry Tortugas National Park). The nesting trend data for the DTRU are from beaches that are not part of the INBS program,but are part of the SNBS program. There are nine years of data for this recovery unit. A simple linear regression accounting for temporal autocorrelation revealed no trend in nesting numbers. Because of the annual variability in nest totals, a longer time series is needed to detect a trend (NMFS and Service 2008). The GCRU is composed of all other nesting assemblages of loggerheads within the Greater Caribbean. Statistically valid analyses of long-term nesting trends for the entire GCRU are not available because there are few long-term standardized nesting surveys representative of the region. Additionally, changing survey effort at monitored beaches and scattered and low-level nesting by loggerheads at many locations currently precludes comprehensive analyses. The most complete data are from Quintana Roo andYucatan, Mexico, where an increasing trend was reported over a 15-year period from 1987-2001 (Zurita et al. 2003). However, since 2001, nesting has declined and the previously reported increasing trend appears not to have been sustained (NMFS and Service 2008). Other smaller nesting populations have experienced declines over the past few decades (e.g., Amorocho 2003). The Recovery Plan for the Northwest Atlantic Population of the Loggerhead Sea Turtle was signed in 2008 (NMFS and Service 2008), and the Recovery Plan for U.S. Pacific Populations of the Loggerhead Turtle was signed in 1998 (NMFS and Service 1998e). Green Sea Turtle The green sea turtle was federally listed on July 28, 1978 (43 FR 32800). Breeding populations of the green turtle in Florida and along the Pacific Coast of Mexico are listed as endangered; all other populations are listed as threatened. The green sea turtle has a worldwide distribution in tropical and subtropical waters. The green sea turtle grows to a maximum size of about four feet and a weight of 440 pounds. It has a heart-shaped shell, small head, and single-clawed flippers. The carapace is smooth and colored gray, green, brown and black. Hatchlings are black on top and white on the bottom (NMFS 2009b). Hatchling green turtles eat a variety of plants and animals, but adults feed almost exclusively on seagrasses and marine algae. Major green turtle nesting colonies in the Atlantic occur on Ascension Island, Ayes Island, Costa Rica, and Surinam. Within the U.S., green turtles nest in small numbers in the U.S. Virgin Islands and Puerto Rico, and in larger numbers along the east coast of Florida, particularly in Brevard, Indian River, St. Lucie, Martin, Palm Beach, and Broward Counties (NMFS and 12 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Service 1991). Nesting also has been documented along the Gulf coast of Florida from Escambia County through Franklin County in northwest Florida and from Pinellas County through Collier County in southwest Florida(FWC 2009a). Green sea turtles are generally found in fairly shallow waters (except when migrating) inside reefs, bays, and inlets. The green turtle is attracted to lagoons and shoals with an abundance of marine grass and algae. Open beaches with a sloping platform and minimal disturbance are required for nesting. Critical habitat for the green sea turtle has been designated for the waters surrounding Culebra Island, Puerto Rico, and its outlying keys. Life history/Population Dynamics Green sea turtles deposit from one to nine clutches within a nesting season, but the overall average is about 3.3 nests. The interval between nesting events within a season varies around a mean of about 13 days(Hirth 1997). Mean clutch size varies widely among populations. Average clutch size reported for Florida was 136 eggs in 130 clutches (Witherington and Ehrhart 1989). Only occasionally do females produce clutches in successive years. Usually two or more years intervene between breeding seasons (NMFS and Service 1991). Age at sexual maturity is believed to be 20 to 50 years(Hirth 1997). About 100 to 1,000 females are estimated to nest on beaches in Florida annually (FWC 2009c). In the U.S. Pacific, over 90 percent of nesting throughout the Hawaiian archipelago occurs at the French Frigate Shoals, where about 200 to 700 females nest each year (NMFS and Service 1998b). Elsewhere in the U.S. Pacific, nesting takes place at scattered locations in the Commonwealth of the Northern Marianas, Guam, and American Samoa. In the western Pacific, the largest green turtle nesting aggregation in the world occurs on Raine Island, Australia, where thousands of females nest nightly in an average nesting season (Limpus et al. 1993). In the Indian Ocean, major nesting beaches occur in Oman where 30,000 females are reported to nest annually(Ross and Barwani 1995). Status and Distribution Annual nest totals documented as part of the Florida SNBS program from 1989-2008 have ranged from 435 nests laid in 1993 to 12,752 in 2007.Nesting occurs in 26 counties with a peak along the east coast, from Volusia through Broward Counties. Although the SNBS program provides information on distribution and total abundance statewide, it cannot be used to assess trends because of variable survey effort. Therefore, green turtle nesting trends are best assessed using standardized nest counts made at INBS sites surveyed with constant effort over time (1989-2009). Green sea turtle nesting in Florida is increasing based on 19 years (1989-2009) of INBS data from throughout the state (FWC 2009a). The increase in nesting in Florida is likely a result of several factors, including: (1) a Florida statute enacted in the early 1970s that prohibited the killing of green turtles in Florida; (2) the species listing under the Act afforded complete protection to eggs, juveniles, and adults in all U.S. waters; (3) the passage of Florida's constitutional net ban amendment in 1994 and its subsequent enactment, making it illegal to use 13 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 any gillnets or other entangling nets in State waters; (4) the likelihood that the majority of Florida green turtles reside within Florida waters where they are fully protected; (5) the protections afforded Florida green turtles while they inhabit the waters of other nations that have enacted strong sea turtle conservation measures (e.g., Bermuda); and (6)the listing of the species on Appendix I of Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), which stopped international trade and reduced incentives for illegal trade from the U.S. The Recovery Plan for U.S. Population of Atlantic Green Turtle was signed in 1991 (NMFS and Service 1991), the Recovery Plan for U.S. Pacific Populations of the Green Turtle was signed in 1998 (NMFS and Service 1998b), and the Recovery Plan for U.S. Pacific Populations of the East Pacific Green Turtle was signed in 1998 (NMFS and Service 1998a). Leatherback Sea Turtle The leatherback sea turtle was federally listed as an endangered species on June 2, 1970 (35 FR 8491). Leatherbacks have the widest distribution of the sea turtles with nonbreeding animals have been recorded as far north as the British Isles and the Maritime Provinces of Canada and as far south as Argentina and the Cape of Good Hope (Pritchard 1992). Foraging leatherback excursions have been documented into higher-latitude subpolar waters. They have evolved physiological and anatomical adaptations (Frair et al. 1972, Greer et al. 1973) that allow them to exploit waters far colder than any other sea turtle species would be capable of surviving. The adult leatherback can reach four to eight feet in length and weigh 500 to 2,000 pounds. The carapace is distinguished by a rubber-like texture, about 1.6 inches thick, made primarily of tough, oil-saturated connective tissue. Hatchlings are dorsally mostly black and are covered with tiny scales; the flippers are edged in white, and rows of white scales appear as stripes along the length of the back (NMFS 2009c). Jellyfish are the main staple of its diet, but it is also known to feed on sea urchins, squid, crustaceans, tunicates, fish, blue-green algae, and floating seaweed. This is the largest, deepest diving of all sea turtle species. Leatherback turtle nesting grounds are distributed worldwide in the Atlantic, Pacific and Indian Oceans on beaches in the tropics and sub-tropics. The Pacific Coast of Mexico historically supported the world's largest known concentration of nesting leatherbacks. The leatherback turtle regularly nests in the U.S. Caribbean in Puerto Rico and the U.S. Virgin Islands. Along the U.S.Atlantic coast,most nesting occurs in Florida(NMFS and Service 1992). Adult females require sandy nesting beaches backed with vegetation and sloped sufficiently so the distance to dry sand is limited. Their preferred beaches have proximity to deep water and generally rough seas. Marine and terrestrial critical habitat for the leatherback sea turtle has been designated at Sandy Point on the western end of the island of St. Croix, U.S. Virgin Islands (50 Code of Federal Regulations (CFR) 17.95). Life history/Population Dynamics Leatherbacks nest an average of five to seven times within a nesting season, with an observed 14 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 maximum of 11 nests (NMFS and Service 1992). The interval between nesting events within a season is about nine to 10 days. Clutch size averages 80 to 85 yolked eggs, with the addition of usually a few dozen smaller, yolkless eggs, mostly laid toward the end of the clutch (Pritchard 1992).Nesting migration intervals of two to three years were observed in leatherbacks nesting on the Sandy Point National Wildlife Refuge, St. Croix, U.S. Virgin Islands (McDonald and Dutton 1996). Leatherbacks are believed to reach sexual maturity in six to 10 years (Zug and Parham 1996). A dramatic drop in nesting numbers has been recorded on major nesting beaches in the Pacific. Spotila et al. (2000) have highlighted the dramatic decline and possible extirpation of leatherbacks in the Pacific. The East Pacific and Malaysia leatherback populations have collapsed. Spotila et al. (1996) estimated that only 34,500 females nested annually worldwide in 1995, which is a dramatic decline from the 115,000 estimated in 1980 (Pritchard 1982). In the eastern Pacific, the major nesting beaches occur in Costa Rica and Mexico. At Playa Grande, Costa Rica, considered the most important nesting beach in the eastern Pacific, numbers have dropped from 1,367 leatherbacks in 1988-1989 to an average of 188 females nesting between 2000-2001 and 2003-2004. In Pacific Mexico, 1982 aerial surveys of adult female leatherbacks indicated this area had become the most important leatherback nesting beach in the world. Tens of thousands of nests were laid on the beaches in 1980s, but during the 2003-2004 seasons a total of 120 nests was recorded. In the western Pacific, the major nesting beaches lie in Papua New Guinea, Papua, Indonesia, and the Solomon Islands. These are some of the last remaining significant nesting assemblages in the Pacific. Compiled nesting data estimated approximately 5,000 to 9,200 nests annually with 75 percent of the nests being laid in Papua, Indonesia. However, the most recent population size estimate for the North Atlantic alone is a range of 34,000 to 94,000 adult leatherbacks (TEWG 2007). In Florida, an annual increase in number of leatherback nests at the core set of index beaches ranged from 27 to 615 between 1989 and 2010. Nesting in the Southern Caribbean occurs in the Guianas (Guyana, Suriname, and French Guiana), Trinidad, Dominica, and Venezuela. The largest nesting populations at present occur in the western Atlantic in French Guiana with nesting varying between a low of 5,029 nests in 1967 to a high of 63,294 nests in 2005, which represents a 92 percent increase since 1967 (TEWG 2007). Trinidad supports an estimated 6,000 leatherbacks nesting annually, which represents more than 80 percent of the nesting in the insular Caribbean Sea. Leatherback nesting along the Caribbean Central American coast takes place between Honduras and Colombia. In Atlantic Costa Rica, at Tortuguero, the number of nests laid annually between 1995 and 2006 was estimated to range from 199 to 1,623. Modeling of the Atlantic Costa Rica data indicated that the nesting population has decreased by 67.8 percent over this time period. In Puerto Rico, the main nesting areas are at Fajardo on the main island of Puerto Rico and on the island of Culebra. Between 1978 and 2005, annual population growth rate was estimated to be 1.10 (TEWG 2007). Recorded leatherback nesting on the Sandy Point National Wildlife Refuge on the island of St. Croix, U.S. Virgin Islands between 1990 and 2005, ranged from a low of 143 in 1990 to a high of 1,008 in 2001 (Garner et al. 2005). In the British Virgin Islands, annual nest numbers have increased in Tortola from zero to six nests per year in the late 1980s to 35 to 65 nests per year in the 2000s (TEWG 2007). 15 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 The most important nesting beach for leatherbacks in the eastern Atlantic lies in Gabon, Africa. It was estimated there were 30,000 nests along 60 miles of Mayumba Beach in southern Gabon during the 1999-2000 nesting season (Billes et al. 2000). Some nesting has been reported in Mauritania, Senegal, the Bijagos Archipelago of Guinea-Bissau, Turtle Islands and Sherbro Island of Sierra Leone, Liberia, Togo, Benin, Nigeria, Cameroon, Sao Tome and Principe, continental Equatorial Guinea, Islands of Corisco in the Gulf of Guinea and the Democratic Republic of the Congo, and Angola. In addition, a large nesting population is found on the island of Bioko (Equatorial Guinea) (Fretey et al. 2007). Status and Distribution Declines in leatherback nesting have occurred over the last two decades along the Pacific coasts of Mexico and Costa Rica. The Mexican leatherback nesting population, once considered to be the world's largest leatherback nesting population (historically estimated to be 65 percent of the worldwide population), is now less than one percent of its estimated size in 1980. Spotila et al. (1996) estimated the number of leatherback sea turtles nesting on 28 beaches throughout the world from the literature and from communications with investigators studying those beaches. The estimated worldwide population of leatherbacks in 1995 was about 34,500 females on these beaches with a lower limit of about 26,200, and an upper limit of about 42,900. This is less than one-third the 1980 estimate of 115,000. Leatherbacks are rare in the Indian Ocean and in very low numbers in the western Pacific Ocean. The largest population is in the western Atlantic. Using an age-based demographic model, Spotila et al. (1996) determined that leatherback populations in the Indian Ocean and western Pacific Ocean cannot withstand even moderate levels of adult mortality and that the Atlantic populations are being exploited at a rate that cannot be sustained. They concluded that leatherbacks are on the road to extinction and further population declines can be expected unless action is taken to reduce adult mortality and increase survival of eggs and hatchlings. In the U.S.,nesting populations occur in Florida, Puerto Rico, and the U.S. Virgin Islands. In Florida, the SNBS program documented an increase in leatherback nesting numbers from 98 nests in 1988 to between 800 and 900 nests per season in the early 2000s (FWC 2009a, Stewart and Johnson 2006). Although the SNBS program provides information on distribution and total abundance statewide, it cannot be used to assess trends because of variable survey effort. Therefore, leatherback nesting trends are best assessed using standardized nest counts made at INBS sites surveyed with constant effort over time (1989-2009). An analysis of the INBS data has shown a substantial increase in leatherback nesting in Florida since 1989 (FWC 2009b, TEWG Group 2007). The Recovery Plan for Leatherback Turtles in the U.S. Caribbean, Atlantic, and Gulf of Mexico was signed in 1992 (NMFS and Service 1992), and the Recovery Plan for U.S. Pacific Populations of the Leatherback Turtle was signed in 1998 (NMFS and Service 1998d). Hawksbill Sea Turtle The hawksbill sea turtle was federally listed as an endangered species on June 2, 1970 (35 FR 8491). The hawksbill is found in tropical and subtropical seas of the Atlantic, Pacific, and Indian Oceans. The species is widely distributed in the Caribbean Sea and western Atlantic Ocean. 16 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Data collected in the Wider Caribbean reported that hawksbills typically weigh around 176 pounds or less; hatchlings average about 1.6 inches straight length and range in weight from 0.5 to 0.7 ounces. The carapace is heart shaped in young turtles, and becomes more elongated or egg-shaped with maturity. The top scutes are often richly patterned with irregularly radiating streaks of brown or black on an amber background. The head is elongated and tapers sharply to a point. The lower jaw is V-shaped(NMFS 2009d). Within the continental U.S., hawksbill sea turtle nesting is rare and is restricted to the southeastern coast of Florida (Volusia through Miami-Dade Counties) and the Florida Keys (Monroe County) (Meylan 1992, Meylan et al. 1995). However, hawksbill tracks are difficult to differentiate from those of loggerheads and may not be recognized by surveyors. Therefore, surveys in Florida likely underestimate actual hawksbill nesting numbers (Meylan et al. 1995). In the U.S. Caribbean, hawksbill nesting occurs on beaches throughout Puerto Rico and the U.S. Virgin Islands (NMFS and Service 1993). Critical habitat for the hawksbill sea turtle has been designated for selected beaches and/or waters of Mona,Monito, Culebrita, and Culebra Islands, Puerto Rico. Life history/Population Dynamics Hawksbills nest on average about 4.5 times per season at intervals of approximately 14 days (Corliss et al. 1989). In Florida and the U.S. Caribbean, clutch size is approximately 140 eggs, although several records exist of over 200 eggs per nest (NMFS and Service 1993). On the basis of limited information, nesting migration intervals of two to three years appear to predominate. Hawksbills are recruited into the reef environment at about 14 inches in length and are believed to begin breeding about 30 years later. However, the time required to reach 14 inches in length is unknown and growth rates vary geographically. As a result, actual age at sexual maturity is unknown. About 15,000 females are estimated to nest each year throughout the world with the Caribbean accounting for 20 to 30 percent of the world's hawksbill population. Only five regional populations remain with more than 1,000 females nesting annually (Seychelles, Mexico, Indonesia,and two in Australia) (Meylan and Donnelly 1999). Mexico is now the most important region for hawksbills in the Caribbean with about 3,000 nests per year (Meylan 1999). In the U.S. Pacific, hawksbills nest only on main island beaches in Hawaii, primarily along the east coast of the island of Hawaii. Hawksbill nesting has also been documented in American Samoa and Guam (NMFS and Service 1998c). Status and Distribution The hawksbill sea turtle has experienced global population declines of 80 percent or more during the past century and continued declines are projected (Meylan and Donnelly 1999). Most populations are declining, depleted, or remnants of larger aggregations. Hawksbills were previously abundant, as evidenced by high-density nesting at a few remaining sites and by trade statistics. The Recovery Plan for the Hawksbill Turtle in the U.S. Caribbean, Atlantic, and Gulf of Mexico 17 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 was signed in 1993 (NMFS and Service 1993), and the Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle was signed in 1998 (NMFS and Service 1998c). Kemp's Ridley Sea Turtle The Kemp's ridley sea turtle was federally listed as endangered on December 2, 1970 (35 FR 18320). The Kemp's ridley, along with the flatback sea turtle (Natator depressus), has the most geographically restricted distribution of any sea turtle species. The range of the Kemp's ridley includes the Gulf coasts of Mexico and the U.S., and the Atlantic coast of North America as far north as Nova Scotia and Newfoundland. Adult Kemp's ridleys, considered the smallest sea turtle in the world, weigh an average of 100 pounds with a carapace measuring between 24-28 inches in length. The almost circular carapace has a grayish green color while the plastron is pale yellowish to cream in color. The carapace is often as wide as it is long. Their diet consists mainly of swimming crabs, but may also include fish,jellyfish, and an array of mollusks. The majority of nesting for the entire species occurs on the primary nesting beach at Rancho Nuevo, Mexico (Marquez-Millan 1994). Outside of nesting, adult Kemp's ridleys are believed to spend most of their time in the Gulf of Mexico, while juveniles and subadults also regularly occur along the eastern seaboard of the U.S. (Service and NMFS 1992). There have been rare instances when immature ridleys have been documented making transatlantic movements (Service and NMFS 1992). It was originally speculated that ridleys that make it out of the Gulf of Mexico might be lost to the breeding population (Hendrickson 1980), but data indicate that many of these turtles are capable of moving back into the Gulf of Mexico (Henwood and Ogren 1987). In fact, there are documented cases of ridleys captured in the Atlantic that migrated back to the nesting beach at Rancho Nuevo (Schmid and Witzell 1997, Schmid 1998, Witzell 1998). Hatchlings, after leaving the nesting beach, are believed to become entrained in eddies within the Gulf of Mexico, where they are dispersed within the Gulf and Atlantic by oceanic surface currents until they reach about 7.9 inches in length, at which size they enter coastal shallow water habitats (Ogren 1989). No critical habitat has been designated for the Kemp's ridley sea turtle. Life history/Population Dynamics Nesting occurs from April into July during which time the turtles appear off the Tamaulipas and Veracruz coasts of Mexico. Precipitated by strong winds, the females swarm to mass nesting emergences, known as "arribadas or arribazones," to nest during daylight hours. The period between Kemp's ridley arribadas averages approximately 25 days (Rostal et al. 1997), but the precise timing of the arribadas is highly variable and unpredictable (Bernardo and Plotkin 2007). Clutch size averages 100 eggs and eggs typically take 45 to 58 days to hatch depending on temperatures (Marquez-Millan 1994,Rostal 2007). Some females breed annually and nest an average of one to four times in a season at intervals of 10 to 28 days. Analysis by Rostal (2007) suggested that ridley females lay approximately 3.1 nests per nesting season. Interannual remigration rate for female ridleys is estimated to be approximately 1.8 (Rostal 2007) to 2.0 years (Marquez-Millan et al. 1989). Age at sexual 18 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 maturity is believed to be between 10 to 17 years(Snover et al. 2007). Most Kemp's ridleys nest on the coastal beaches of the Mexican states of Tamaulipas and Veracruz, although a small number of Kemp's ridleys nest consistently along the Texas coast (TEWG 1998). In addition, rare nesting events have been reported in Alabama, Florida, Georgia, South Carolina, and North Carolina. Historical information indicates that tens of thousands of ridleys nested near Rancho Nuevo, Mexico, during the late 1940s (Hildebrand 1963). The Kemp's ridley population experienced a devastating decline between the late 1940s and the mid 1980s. The total number of nests per nesting season at Rancho Nuevo remained below 1,000 throughout the 1980s, but gradually began to increase in the 1990s. In 2009, 16,273 nests were documented along the 18.6 miles of coastline patrolled at Rancho Nuevo, and the total number of nests documented for all the monitored beaches in Mexico was 21,144 (Service 2009). In 2010, a total of 13,302 nests were documented in Mexico (Service 2010). In addition, 207 and 153 nests were recorded during 2009 and 2010,respectively, in the U.S.,primarily in Texas. Status and Distribution Today, under strict protection, the population appears to be in the early stages of recovery. The recent nesting increase can be attributed to full protection of nesting females and their nests in Mexico resulting from a binational effort between Mexico and the U.S. to prevent the extinction of the Kemp's ridley, and the requirement to use Turtle Excluder Devices (TEDs) in shrimp trawls both in the U.S. and Mexico. The Mexico government also prohibits harvesting and is working to increase the population through more intensive law enforcement, by fencing nest areas to diminish natural predation, and by relocating most nests into corrals to prevent poaching and predation. While relocation of nests into corrals is currently a necessary management measure, this relocation and concentration of eggs into a "safe" area is of concern since it makes the eggs more susceptible to reduced viability. The Second Revision of the Kemp's ridley sea turtle Bi-National Recovery Plan was signed in Mexico City on September 22, 2011. Analysis of the Species/Critical Habitat Likely to Be Affected Common threats to sea turtles in Florida - Anthropogenic factors that impact hatchlings and adult female turtles on land, or the success of nesting and hatching include: beach erosion; armoring and nourishment; artificial lighting; beach cleaning; increased human presence; recreational beach equipment; beach driving; coastal construction and fishing piers; exotic dune and beach vegetation; and poaching. An increased human presence at some nesting beaches or close to nesting beaches has led to secondary threats such as the introduction of exotic fire ants (Solenopsis spp.), feral hogs (Sus scrofa), dogs (Canis familiaris), and an increased presence of native species (e.g., raccoons (Procyon lotor), armadillos (Dasypus novemcinctus), and opossums (Didelphis virginiana)), which raid and feed on turtle eggs. Although sea turtle nesting beaches are protected along large expanses of the western North Atlantic coast, other areas along 19 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 these coasts have limited or no protection. Anthropogenic threats in the marine environment include oil and gas exploration, and transportation; marine pollution; underwater explosions; hopper dredging; offshore artificial lighting; power plant entrainment or impingement; entanglement in debris; ingestion of marine debris; marina and dock construction and operation; boat collisions; and poaching and fishery interactions. Fibropapillomatosis, a disease of sea turtles characterized by the development of multiple tumors on the skin and internal organs, is also a mortality factor, particularly for green turtles. This disease has seriously impacted green turtle populations in Florida, Hawaii, and other parts of the world. The tumors interfere with swimming, eating, breathing, vision, and reproduction, and turtles with heavy tumor burdens may die. Analysis of the habitat likely to be affected The threatened loggerhead sea turtle,the endangered green sea turtle,the endangered leatherback sea turtle, the endangered hawksbill sea turtle, and the endangered Kemp's ridley sea turtle are currently listed because of their reduced population sizes caused by overharvest and habitat loss with continuing anthropogenic threats from commercial fishing, disease, and degradation of remaining habitat. The proposed action has the potential to adversely affect nesting females of these species, their nests, and hatchlings on all beach areas where equipment transport and sediment deposition will occur. Conducting all activities outside of the sea turtle nesting season will minimize the likelihood of this occurring. The following broad categories of factors may ultimately affect the status and distribution of sea turtles within the Action Area. Coastal Development — Loss of nesting habitat related to coastal development has had the greatest impact on nesting sea turtles in Florida. Beachfront development not only causes the loss of suitable nesting habitat, but can result in the disruption of powerful coastal processes accelerating erosion and interrupting the natural shoreline migration. This may in turn cause the need to protect upland structures and infrastructure by armoring, groin placement, beach emergency berm construction and repair, and beach nourishment which cause changes in, additional loss of, or impact to the remaining sea turtle habitat. Hurricanes — Hurricanes generally produce damaging winds, storm tides and surges, and rain, which can result in severe erosion of the beach and dune systems. Overwash and blowouts are common on barrier islands. Hurricanes and other storms can result in the direct or indirect loss of sea turtle nests, either by erosion or washing away of the nests by wave action, inundation or "drowning" of the eggs or hatchlings developing within the nest or indirectly by loss of nesting habitat. Depending on their frequency, storms can affect sea turtles on either a short-term basis (nests lost for one season and/or temporary loss of nesting habitat) or long term, if frequent (habitat unable to recover). How hurricanes affect sea turtle nesting also depends on its characteristics (winds, storm surge, rainfall), the time of year (within or outside of the nesting season), and where the northeast edge of the hurricane crosses land. 20 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Because of the limited remaining nesting habitat in a natural state with no immediate development landward of the sandy beach, frequent or successive severe weather events could threaten the ability of certain sea turtle populations to survive and recover. Sea turtles evolved under natural coastal environmental events such as hurricanes. The extensive amount of predevelopment coastal beach and dune habitat allowed sea turtles to survive even the most severe hurricane events. It is only within the last 20 to 30 years that the combination of habitat loss to beachfront development and destruction of remaining habitat by hurricanes has increased the threat to sea turtle survival and recovery. On developed beaches, typically little space remains for sandy beaches to become reestablished after periodic storms. While the beach itself moves landward during such storms, reconstruction or persistence of structures at their prestorm locations can result in a loss of nesting habitat. Erosion— The designation of a Critically Eroded Beach is a planning requirement of the State's Beach Erosion Control Funding Assistance Program. A segment of beach shall first be designated as critically eroded in order to be eligible for State funding. A critically eroded area is a segment of shoreline where natural processes or human activity have caused or contributed to erosion and recession of the beach or dune system to such a degree that upland development, recreational interests,wildlife habitat, or important cultural resources are threatened or lost. Critically eroded areas may also include peripheral segments or gaps between identified critically eroded areas which, although they may be stable or slightly erosional now, their inclusion is necessary for continuity of management of the coastal system or for the design integrity of adjacent beach management projects (FDEP 2009). It is important to note, that for an erosion problem area to be critical, there shall exist a threat to or loss of one of four specific interests — upland development, recreation, wildlife habitat, or important cultural resources. Beachfront Lighting — Artificial beachfront lighting may cause disorientation (loss of bearings) of sea turtle hatchlings. Artificial beachfront lighting is a documented cause of hatchling disorientation and misorientation on nesting beaches. The emergence from the nest and crawl to the sea is one of the most critical periods of a sea turtle's life. Hatchlings that do not make it to the sea quickly become food for ghost crabs, birds, and other predators, or become dehydrated and may never reach the sea. Some types of beachfront lighting attract hatchlings away from the sea while some lights cause adult turtles to avoid stretches of brightly illuminated beach. Research has documented significant reduction in sea turtle nesting activity on beaches illuminated with artificial lights (Witherington 1992). During the 2007 sea turtle nesting season in Florida, over 64,000 turtle hatchlings were documented as being disoriented (FWC 2007). Exterior and interior lighting associated with condominiums had the greatest impact causing approximately 42 percent of documented hatchling disorientation. Other causes included urban sky glow and street lights (FWC 2007). Predation — Predation of sea turtle eggs and hatchlings by native and introduced species occurs on almost all nesting beaches. Predation by a variety of predators can considerably decrease sea turtle nest hatching success. The most common predators in the southeastern U.S. are ghost crabs, raccoons, feral hogs, foxes, coyotes, armadillos, and fire ants (Stancyk 1995). In the absence of nest protection programs in a number of locations throughout the southeast U.S., raccoons may depredate up to 96 percent of all nests deposited on a beach(Labisky et al. 1986). 21 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 In response to increasing predation of sea turtle nests by coyotes, foxes, hogs, and raccoons, multiagency cooperative efforts have been initiated and are ongoing throughout Florida, particularly on public lands. Driving on the Beach—The operation of motor vehicles or equipment on the beach can affect sea turtle nesting by interrupting or striking a female turtle on the beach, headlights disorienting emergent hatchlings, vehicles running over hatchlings attempting to reach the ocean, and vehicle tracks traversing the beach which interfere with hatchlings crawling to the ocean. Hatchlings appear to become diverted not because they cannot physically climb out of the rut, but because the sides of the track cast a shadow and the hatchlings lose their line of sight to the ocean horizon (Mann 1977). The extended period of travel required to negotiate tire tracks and ruts may increase the susceptibility of hatchlings to dehydration and depredation during migration to the ocean (Hosier et al. 1981). Driving on the beach can cause sand compaction which may result in adverse impacts on nest site selection, digging behavior, clutch viability, and emergence by hatchlings, decreasing nest success and directly killing preemergent hatchlings (Mann 1977, Nelson and Dickerson 1987,Nelson 1988). The physical changes and loss of plant cover caused by vehicles on dunes can lead to various degrees of instability, and therefore encourage dune migration. As vehicles move either up or down a slope, sand is displaced downward, lowering the trail. Since the vehicles also inhibit plant growth, and open the area to wind erosion, dunes may become unstable, and begin to migrate. Unvegetated sand dunes may continue to migrate across stable areas as long as vehicle traffic continues. Vehicular traffic through dune breaches or low dunes on an eroding beach may cause an accelerated rate of overwash and beach erosion (Godfrey et al. 1978). If driving is required,the area where the least amount of impact occurs is the beach between the low and high tide water lines. Vegetation on the dunes can quickly reestablish provided the mechanical impact is removed. Climate Change — The varying and dynamic elements of climate science are inherently long term, complex, and interrelated. Regardless of the underlying causes of climate change, glacial melting and expansion of warming oceans are causing sea level rise, although its extent or rate cannot as yet be predicted with certainty. At present, the science is not exact enough to precisely predict when and where climate impacts will occur. Although we may know the direction of change, it may not be possible to predict its precise timing or magnitude. These impacts may take place gradually or episodically in major leaps. Climate change is evident from observations of increases in average global air and ocean temperatures, widespread melting of snow and ice, and rising sea level, according to the Intergovernmental Panel on Climate Change Report (IPCC 2007a). The IPCC Report (2007a) describes changes in natural ecosystems with potential widespread effects on many organisms, including marine mammals and migratory birds. The potential for rapid climate change poses a significant challenge for fish and wildlife conservation. Species' abundance and distribution are dynamic, relative to a variety of factors, including climate. As climate changes, the abundance and distribution of fish and wildlife will also change. Highly specialized or endemic species are likely to be most susceptible to the stresses of changing climate. Based on these findings and 22 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 other similar studies, the U.S. Department of the Interior (DOI) requires agencies under its direction to consider potential climate change effects as part of their long-range planning activities (Service 2007c). Gopher Tortoise Species/Critical Habitat Description The gopher tortoise is a dry-land turtle that lives in relatively well-drained sandy soils. They can be found in scrub, dry hammock, pine flatwoods, dry prairie, coastal grassland and dunes, mixed hardwood-pine communities and a variety of other habitats that have been disturbed or man- altered. Gopher tortoises can be found throughout the southeastern United States, including Louisiana, Mississippi, Alabama, Georgia, Florida and southern South Carolina. The majority being found in north-central Florida and southern Georgia. Gopher tortoises are listed under the Endangered Species Act (ESA) in Alabama west of the Mobile and Tombigbee Rivers, and in Mississippi and Louisiana. In all other areas of the gopher tortoises' range it is a candidate species for possible listing under the ESA. In Florida,the tortoise is listed as threatened and both the tortoise and the burrow are protected by state law. Threats to the gopher tortoise include habitat destruction and fragmentation, predation, inadequacy of regulatory mechanisms, and incompatible use of herbicides. Life history/Population Dynamics Gopher tortoises are adept diggers. Burrows that gopher tortoises dig provide protection from predators and the elements. The tortoises are most active during the warmer months but spend the majority of their lives in their burrows. Each tortoise may dig and use many burrows. Each burrow can be three to fifty feet long and nine to twenty feet deep. The burrows also provide refuge for other species including but not limited to snakes, frogs, mice, skunks, opossums, rabbits, armadillo, and many invertebrates. Several of the species that utilize the burrows are also listed species. Gopher tortoises can live to approximately 80 years in the wild. They do not reach sexual maturity until 10-20 years old and have a low reproductive rate. They often lay their eggs at the entrance of their burrows to capture the heat. Only about three to five percent of young tortoises survive. Status and Distribution As stated above, Gopher tortoises can be found throughout the southeastern United States, including Louisiana, Mississippi, Alabama, Georgia, Florida and southern South Carolina. The majority being found in north-central Florida and southern Georgia. They live in well-drained sandy areas with sparse tree canopy and abundant low growing vegetation. They need large parcels of undeveloped land not fragmented by roads, buildings, and other structures. Road kill is one of the major causes of death in adult tortoises. Additionally, they can be killed and eaten or taken from their habitat as pets. Analysis of the Species/Critical Habitat likely to be affected The following broad categories of factors may ultimately affect the status and distribution of the 23 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 gopher tortoise in the Action Area. Habitat Conservation — As noted above, the habitats used by the gopher tortoise are being fragmented by roads, buildings and other barriers to support a growing human population in the State of Florida. Demographic Concerns — It appears that the gopher tortoise population has declined range-wide as a result of current rates of habitat destruction and degradation. Habitat Loss/Habitat Degradation—The most threatening issue facing the survival and recovery of the gopher tortoise is habitat loss and fragmentation resulting from the conversion of suitable habitats to other uses. Human-induced Effects — Indirect adverse effects on the gopher tortoise are likely to occur in populations adjacent to or near human habitations. For example, individual encounters between humans and gopher tortoises are likely to result in increased mortality rates. Further, as remaining habitats are either lost or fragmented, increased pressure will be placed on resident individuals. Piping Plover(Charadrius melodus) Species/Critical Habitat Description The piping plover is a small,pale sand-colored shorebird,about 7 inches long with a wingspan of about 15 inches. The piping plover was listed as endangered in the Great Lakes watershed and threatened elsewhere within its range, including migratory routes outside of the Great Lakes watershed and wintering grounds on January 10, 1986. Piping plovers were listed principally because of habitat destruction and degradation,predation,and human disturbance. Protection of the species under the Act reflects the species'precarious status range-wide. Three separate breeding populations have been identified,each with its own recovery criteria: the northern Great Plains (threatened),the Great Lakes(endangered), and the Atlantic Coast(threatened). The piping plover winters in coastal areas of the U.S.from North Carolina to Texas,and along the coast of eastern Mexico and on Caribbean islands from Barbados to Cuba and the Bahamas. The USFWS has designated critical habitat for the piping plover on three occasions. Critical habitat for the Great Lakes breeding population was designated May 7, 2001 (66 Federal Register [FR] 22938), and critical habitat for the northern Great Plains breeding population was designated September 11, 2002 (67 FR 57637). The Service designated critical habitat for wintering piping plovers on July 10,2001 (66 FR 36038). Wintering piping plovers may include individuals from the Great Lakes and northern Great Plains breeding populations as well as birds that nest along the Atlantic Coast. The three separate designations of piping plover critical habitat demonstrate diversity of constituent elements between the two breeding populations as well as diversity of constituent elements between breeding and wintering populations. Designated wintering piping plover critical habitat originally included 142 areas though the rule erroneously states 137 units encompassing approximately 1,793 miles of mapped shoreline and 24 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 165,211 acres of mapped areas along the coasts of North Carolina, South Carolina, Georgia, Florida,Alabama,Mississippi,Louisiana, and Texas. Revised critical habitat units were published for units in North Carolina and Texas on October 21,2008 (73 FR 62816) and May 19, 2009 (74 FR 23476)respectively. The primary constituent elements(PCEs)for piping plover wintering habitat are those biological and physical features that are essential to the conservation of the species. The PCEs are those habitat components that support foraging,roosting,and sheltering, and the physical features necessary for maintaining the natural processes that support these habitat components. PCEs typically include those coastal areas that support intertidal beaches and flats,and associated dune systems and flats above annual high tide(USFWS 2001). PCEs of wintering piping plover critical habitat include sand or mud flats or both with no or sparse emergent vegetation. Adjacent unvegetated or sparsely vegetated sand,mud,or algal flats above high tide are also important,especially for roosting piping plovers(USFWS 2001). Important components of the beach/dune ecosystem include surf-cast algae, sparsely vegetated back beach and salterns,spits,and washover areas. Washover areas are broad, unvegetated zones,with little or no topographic relief,that are formed and maintained by the action of hurricanes,storm surge,or other extreme wave action. The units designated as critical habitat are those areas that have consistent use by piping plovers and that best meet the biological needs of the species. Life history/Population Dynamics Piping plovers live an average of 5 years, although studies have documented birds as old as 11 and 15 years. Piping plover breeding activity begins in mid-March when birds begin returning to their nesting areas (Coutu et al. 1990; Cross 1990; Goldin et al. 1990; Maclvor 1990; Hake 1993). Plovers are known to begin breeding as early as 1 year of age (Maclvor 1990; Haig 1992); however, the percentage of birds that breed in their first adult year is unknown. Piping plovers generally fledge only a single brood per season,but may re-nest several times if previous nests are lost. Plovers forage on moist substrate features such as intertidal portions of ocean beaches, washover areas, mudflats, sand flats, algal flats, shoals, wrack lines, sparse vegetation, and shorelines of coastal ponds, lagoons, and ephemeral pools, and adjacent to salt marshes. Behavioral observations of piping plovers on the wintering grounds suggest that they spend the majority of their time foraging (Nicholls and Baldassarre 1990a; Drake 1999a, 1999b). Feeding activities may occur during all hours of the day and night (Staine and Burger 1994; Zonick 1997), and at all stages in the tidal cycle (Goldin 1993a; Hoopes 1993). Wintering plovers primarily feed on invertebrates such as polychaete marine worms,various crustaceans, fly larvae, beetles, and occasionally bivalve mollusks (Bent 1929; Cairns 1977; Nicholls 1989; Zonick and Ryan 1996) found on top of the soil or just beneath the surface. Wintering piping plovers prefer coastal habitats that include sand spits, islets (small islands), tidal flats, shoals (usually flood tidal deltas), and sandbars that are often associated with inlets (Harrington 2008). Sandy mud flats, ephemeral pools, and overwash areas are also considered primary foraging habitats. These substrate types have a richer infauna than the foreshore of high energy beaches and often attract large numbers of shorebirds (Cohen et al. 2008). Wintering 25 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 plovers are dependent on a mosaic of habitat patches and move among these patches depending on local weather and tidal conditions(Nicholls and Baldassarre 1990a). Plovers depart their breeding grounds for their wintering grounds between July and late August, but southward migration extends through November. Piping plovers use habitats in Florida primarily from July 15 through May 15. Both spring and fall migration routes of Atlantic Coast breeders are believed to occur primarily within a narrow zone along the Atlantic Coast(USFWS 1996). The pattern of both fall and spring counts at many Atlantic Coast sites demonstrates that many piping plovers make intermediate stopovers lasting from a few days up to 1 month during their migrations (Noel and Chandler 2005; Stucker and Cuthbert 2006). Information from observation of color-banded piping plovers indicates that the winter ranges of the breeding populations overlap to a significant degree. Cryptic coloration is a primary defense mechanism for piping plovers where nests, adults, and chicks all blend in with their typical beach surroundings. Piping plovers on wintering and migration grounds respond to intruders (e.g., pedestrian, avian, and mammalian) usually by squatting,running, and flushing(flying). Several studies identified wrack (organic material including seaweed, seashells, driftwood, and other materials deposited on beaches by tidal action) as an important component of roosting habitat for nonbreeding piping plovers. Lott et al. (2009) found greater than 90 percent of roosting piping plovers in southwest Florida in old wrack with the remainder roosting on dry sand. In South Carolina, 18 and 45 percent of roosting piping plovers were in fresh and old wrack, respectively. Thirty percent of roosting piping plovers in northwest Florida were observed in wrack substrates, with 49 percent roosting on dry sand and 20 percent using intertidal habitat(Smith 2007). The 2006 International Piping Plover Breeding Census, the last comprehensive survey throughout the breeding grounds, documented 3,497 breeding pairs with a total of 8,065 birds throughout Canada and the U.S, and a total of 454 in Florida(Elliott-Smith et al. 2009). The surveys covered approximately 760.5 miles and included 186 sites (Elliott-Smith et al 2009). The breakdown for the Gulf Coast of Florida was: 321 piping plovers at 117 sites covering approximately 522 miles of suitable habitat(Elliott-Smith et al 2009). Numbers for Florida can be further broken down into 3 regions along the Gulf Coast. The northwest Florida census area in the panhandle extends from the Alabama line to Jefferson County, the north Florida census area from Taylor County south to Manatee County, and southwest Florida from Sarasota County south to Key West National Wildlife Refuge. Northwest Florida numbers for the 2006 International Piping Plover Census were 111, with an increased survey effort from previous years. This represents an increase from the 53 piping plovers sighted in the 2001 effort. North Florida reported 96 birds and estimated an additional 40 from missing data sheets. There were 74 piping plovers located in southwest Florida as compared to 50 in the 2001 effort(Elliott-Smith et al 2009). 26 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Atlantic Coast population The Atlantic Coast piping plover breeds on coastal beaches from Newfoundland and southeastern Quebec to North Carolina. Historical population trends for the Atlantic Coast piping plover have been reconstructed from scattered, largely qualitative records. Nineteenth- century naturalists, such as Audubon and Wilson, described the piping plover as a common summer resident on Atlantic Coast beaches (Haig and Oring 1987). However, by the beginning of the twentieth century, egg collecting and uncontrolled hunting, primarily for the millinery trade, had greatly reduced the population, and in some areas along the Atlantic Coast, the piping plover was close to extirpation. Following passage of the Migratory Bird Treaty Act(MBTA) in 1918, and changes in the fashion industry that no longer exploited wild birds for feathers,piping plover numbers recovered to some extent(Haig and Oring 1985). Available data suggest the most recent population decline began in the late 1940s or early 1950s (Haig and Oring 1985). Reports of local or statewide declines between 1950 and 1985 are numerous, and many are summarized by Cairns and McLaren (1980) and Haig and Oring (1985). While Wilcox (1939) estimated more than 500 pairs of piping plovers on Long Island, New York, the 1989 population estimate was 191 pairs (Service 1996). There was little focus on gathering quantitative data on piping plovers in Massachusetts through the late 1960s because the species was commonly observed and presumed to be secure. However, numbers of piping plover breeding pairs declined 50 to 100 percent at seven Massachusetts sites between the early 1970s and 1984 (Griffin and Melvin 1984). Piping plover surveys in the early years of the recovery effort found counts of these cryptically colored birds sometimes increased with increased census effort, suggesting some historic counts of piping plovers by one or more observers may have underestimated the piping plover population. Thus, the magnitude of the species decline may have been more severe than available numbers imply. Great Lakes population The Great Lakes plovers once nested on Great Lakes beaches in Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, Wisconsin, and Ontario. Great Lakes piping plovers nest on wide, flat, open, sandy or cobble shoreline with very little grass or other vegetation. Reproduction is adversely affected by human disturbance of nesting areas and predation by foxes, gulls, crows and other avian species. Shoreline development, such as the construction of marinas, breakwaters,and other navigation structures,has adversely affected nesting and brood rearing. Northern Great Plains population The Northern Great Plains plover breeds from Alberta to Manitoba, Canada, and south to Nebraska; although some nesting has recently occurred in Oklahoma. Currently, the most westerly breeding piping plovers in the U.S. occur in Montana and Colorado. The decline of piping plovers on rivers in the Northern Great Plains has been largely attributed to the loss of sandbar island habitat and forage base due to dam construction and operation. Nesting occurs on sand flats or bare shorelines of rivers and lakes, including sandbar islands in the upper Missouri River system, and patches of sand, gravel, or pebbly-mud on the alkali lakes of the northern Great Plains. Plovers do nest on shorelines of reservoirs created by the dams, but reproductive success is often low and reservoir habitat is not available in many years due to high water levels or vegetation. Dams operated with steady constant flows allow vegetation to grow on potential 27 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 nesting islands, making these sites unsuitable for nesting. Population declines in alkali wetlands are attributed to wetland drainage, contaminants, and predation. Status and Distribution Piping plovers spend up to 10 months of their life cycle on their migration and at wintering grounds, generally July 15 through as late as May 15. Piping plover migration routes and habitats overlap breeding and wintering habitats, and, unless banded, migrants passing through a site usually are indistinguishable from breeding or wintering piping plovers. Migration stopovers by banded piping plovers from the Great Lakes have been documented in New Jersey, Maryland, Virginia, and North Carolina (Stucker and Cuthbert 2006). Migrating breeders from eastern Canada have been observed in Massachusetts, New Jersey, New York, and North Carolina (Amirault et al. 2005). As many as 85 staging piping plovers have been tallied at various sites in the Atlantic breeding range (Perkins 2008), but the composition (e.g., adults that nested nearby and their fledged young of the year versus migrants moving to or from sites farther north), stopover duration, and local movements are unknown. In general, distance between stopover locations and duration of stopovers throughout the coastal migration range remains poorly understood. Review of published records of piping plover sightings throughout North America by Pompei and Cuthbert (2004) found more than 3,400 fall and spring stopover records at 1,196 sites. Published reports indicated piping plovers do not concentrate in large numbers at inland sites and they seem to stop opportunistically. In most cases, reports of birds at inland sites were single individuals. Piping plovers migrate through and winter in coastal areas of the U.S. from North Carolina to Texas and in portions of Mexico and the Caribbean. Data based on four rangewide mid-winter (late January to early February) population surveys, conducted at 5-year intervals starting in 1991, show that total numbers have fluctuated over time, with some areas experiencing increases and others decreases. Regional and local fluctuations may reflect the quantity and quality of suitable foraging and roosting habitat, which vary over time in response to natural coastal formation processes as well as anthropogenic habitat changes (e.g., inlet relocation, dredging of shoals and spits). Fluctuations may also represent localized weather conditions (especially wind) during surveys, or unequal survey coverage. For example, airboats facilitated first-time surveys of several central Texas sites in 2006 (Elliott-Smith et al. 2009). Similarly, the increase in the 2006 numbers in the Bahamas is attributed to greatly increased census efforts; the extent of additional habitat not surveyed remains undetermined (Elliott-Smith et al. 2009). Changes in wintering numbers may also be influenced by growth or decline in the particular breeding populations that concentrate their wintering distribution in a given area. Abundance estimates for non-breeding piping plovers may also be affected by the number of surveyor visits to the site. Preliminary analysis of detection rates by Maddock et al. (2009) found 87 percent detection during the midwinter period on core sites surveyed three times a month during fall and spring and one time per month during winter, compared with 42 percent detection on sites surveyed three times per year(Cohen 2009). The findings of Gratto-Trevor et al. (2009) provide evidence of differences in the wintering distribution of piping plovers from four separate breeding areas. However, the distribution of 28 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 birds by breeding origin during migration remains largely unknown. Other major information gaps include the wintering locations of the U.S. Atlantic Coast breeding population(banding of U.S. Atlantic Coast piping plovers has been extremely limited) and the breeding origin of piping plovers wintering on Caribbean islands and in much of Mexico. The status of piping plovers on winter and migration grounds is difficult to assess, but threats to piping plover habitat used during winter and migration identified by the Service during its designation of critical habitat continue to affect the species. Unregulated motorized and pedestrian recreational use, inlet and shoreline stabilization projects, beach maintenance and nourishment, and pollution affect most winter and migration areas. Conservation efforts at some locations have likely resulted in the enhancement of wintering habitat. Analysis of the Species/Critical Habitat Likely to Be Affected The following general categories discuss threats to piping plovers, associated with their migration and wintering range. Exotic/invasive vegetation -A relatively recent identified threat to piping plover habitatis the spread of coastal invasive plants into suitable piping plover habitat. Like most invasive species, coastal exotic plants reproduce and spread quickly and exhibit dense growth habits, often outcompeting native plant species. If left uncontrolled, invasive plants cause a habitat shift from open or sparsely vegetated sand to dense vegetation, resulting in the loss or degradation of piping plover roosting habitat,which is especially important during high tides and migration periods. Inlet stabilization/relocation - Many navigable mainland or barrier island tidal inlets along the Atlantic and Gulf of Mexico coasts are stabilized with jetties, groins, seawalls, and/or adjacent industrial or residential development. Inlet stabilization with rock jetties and associated channel dredging for navigation alter the dynamics of longshore sediment transport and affect the location and movement rate of barrier islands. Unstabilized inlets naturally migrate, reforming important habitat components,whereas jetties often trap sand and cause significant erosion of the downdrift shoreline. These combined actions can affect the availability of piping plover habitat. Tidal inlet relocation can also cause loss and/or degradation of piping plover habitat, although less permanent than construction of hard structures where effects can persist for years. Habitat Loss/Habitat Degradation - The most threatening issue facing the survival and recovery of the piping plovers is loss or degradation of shoreline habitats that are used as nesting, roosting, and foraging habitat. Throughout the range of migrating and wintering piping plovers, inlet and shoreline stabilization, inlet dredging, beach maintenance and nourishment activities, and seawall installations continue to constrain natural coastal processes. Dredging of inlets can affect spit formation adjacent to inlets and directly remove or affect ebb and flood tidal shoal formation. Jetties, which stabilize an island, cause island widening and subsequent growth of vegetation on inlet shores. Seawalls restrict natural island movement and exacerbate erosion. Construction of these projects during months when piping plovers are present also causes disturbance that disrupts the birds' foraging efficiency and hinders their ability to build fat reserves over the winter and in preparation for migration,as well as their recuperation from migratory flights. 29 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Sand mining/dredging - The practice of dredging sand from sand bars, shoals, and inlets in the nearshore zone, is a less expensive source of sand than obtaining sand from offshore shoals for beach nourishment. Sand bars and shoals are sand sources that move onshore over time and act as natural breakwaters. Inlet dredging reduces the formation of exposed ebb and flood tidal shoals considered to be primary or optimal piping plover roosting and foraging habitat. Removing these sand sources can alter depth contours and change wave refraction as well as cause localized erosion. Exposed shoals and sandbars are also valuable to piping plovers, as they tend to receive less human recreational use (because they are only accessible by boat) and therefore provide relatively less disturbed habitats for birds. Sand placement projects - Managers of lands under public, private, and county ownership often protect coastal structures using emergency storm berms which are frequently followed by beach nourishment or renourishment activities (nourishment projects are considered"soft" stabilization versus "hard" stabilization such as seawalls). Berm placement and beach nourishment projects deposit substantial amounts of sand along Gulf of Mexico and Atlantic beaches to protect local property in anticipation of preventing erosion and what otherwise will be considered natural processes of overwash and sand migration. Wrack removal and beach cleaning - There is increasing popularity for beach communities to carry out "beach cleaning" and "beach raking" actions. Beach cleaning occurs on private beaches, where piping plover use is not well documented, and on some municipal or county beaches that are used by piping plovers. Most wrack removal on State and Federal lands is limited to poststorm cleanup and does not occur regularly. These efforts remove accumulated wrack, topographic depressions, and sparse vegetation nodes used by roosting and foraging piping plovers. Removal of wrack also eliminates a beach's natural sand trapping abilities, further destabilizing the beach. In addition, sand adhering to seaweed and trapped in the cracks and crevices of wrack is removed from the beach. Tilling beaches to reduce soil compaction, as sometimes required by USFWS for sea turtle protection after beach nourishment activities, has similar effectsSea turtle protection provisions in Florida now require tilling,when needed,to be conducted above the primary wrack line,not within it. Recreational disturbance - Intense human disturbance in shorebird winter habitat can be functionally equivalent to habitat loss if the disturbance prevents birds from using an area (Goss- Custard et al. 1996), which can lead to roost abandonment and local population declines (Burton et al. 1996). Disturbance (i.e., human and pet presence) that alters bird behavior can disrupt piping plovers as well as other shorebird species. Disturbance can be addressed by implementing recreational management techniques such as vehicle and pet restrictions and symbolic fencing (usually sign posts and string) of roosting and feeding habitats. In implementing conservation measures, managers need to consider a range of site specific factors, including the extent and quality of roosting and feeding habitats, and the types and intensity of recreational use patterns. In addition, educational materials such as informational signs or brochures can provide valuable information so that the public understands the need for conservation measures. 30 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Factors affecting the species environment within the action area Prior to the development of the 1998 Clam Bay Restoration and Management Plan, Clam Pass was dredged in 1996 and 1997. In accordance with the Clam Bay Restoration and Management Plan adopted in 1998, DEP permit 0128463-001-JC and Corps permit 199602789 OP-CC) authorized periodic channel maintenance dredging events, which were undertaken in 1999, 2002, and 2007. Clam Pass closed in December 2012 following a cold front with sustained northerly winds and was subsequently re-opened in March 2013 under DEP permit #0296087-001-JC and Corps Nationwide permit SAJ-1996-02789 (NWP-WDD). Based on dredging and sand placement activities, piping plovers have the potential to be affected due to habitat loss, sand placement, wrack removal, predation, contaminants, recreational disturbance,and storm events within the action area. Wood Stork Species/Critical Habitat Description Wood storks are one of two species of storks that breed in North America. This large, long- legged inhabitant of marshes, cypress swamps, and mangrove swamps reaches the northern limit of its breeding range in the southeastern U.S., where it breeds in colonies with great egrets, snowy egrets, white ibises, and many other species. The habitats on which wood storks depend have been disrupted by changes in the distribution, timing, and quantity of water flows in south Florida. The population declines that accompanied this disruption led to its listing as an endangered species and continue to hinder the recovery of this species in the U.S. No critical habitat has been designated for the wood stork. The wood stork is a large, long-legged wading bird,with a body length(head to tail) of 85 to 115 cm and a wingspan of 150 to 165 cm. Its plumage is white, except for iridescent black primary and secondary feathers and a short black tail. On adult wood storks, the rough scaly skin of the head and neck is unfeathered and blackish in color. Its legs are dark with dull pink toes. The bill color is blackish. Male and female wood storks are similar in appearance, although male wood storks tend to be larger, have longer wingspans and weigh more. Immature storks, up to the age of about 3 years, differ from adults in that their bills are yellowish or straw colored and they exhibit varying amounts of dusky feathering on the head and neck. During courtship and the early nesting season, adults have pale salmon coloring under the wings, fluffy undertail coverts that are longer than the tail, and toes that brighten to a vivid pink. The wood stork is primarily associated with freshwater and estuarine habitats for nesting, roosting, and foraging. Wood storks typically construct their nests in medium to tall trees that occur in stands located either in swamps or on islands surrounded by relatively broad expanses of open water. Historically,wood storks in south Florida established breeding colonies primarily in large stands of bald cypress and red mangrove. During the nonbreeding season or while foraging, wood storks occur in a wide variety of wetland habitats. Typical foraging sites for the wood stork include freshwater marshes and stock ponds, shallow, seasonally flooded roadside or agricultural ditches, narrow tidal creeks or shallow tidal pools, managed impoundments, and depressions in cypress heads and swamp sloughs. Because of their specialized feeding behavior, wood storks forage most effectively in shallow-water areas with highly concentrated prey. With 31 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 a diet comprised of small fish and macro-invertebrates (2-25 cm in length), feeding areas are shallow water bodies (5-40 cm deep) where prey becomes concentrated. Densities at feeding sites of 15-141 fish per square meter have been recorded. Sufficient hydroperiod is necessary to allow development of a fish population and, as a pond or depression dries, the storks feed by feeling in the shallow water with open bills. Storks may stir up the benthic vegetation with their feet and, as the prey move away, snap the bill shut. Using touch allows feeding in water of low visibility but requires a greater prey concentration. Storks will fly some distances between feeding and roosting sites. In south Florida, low, dry-season water levels are often necessary to concentrate fish to densities suitable for effective foraging by wood storks. As a result, wood storks will forage in many different shallow wetland depressions where fish become concentrated, either due to local reproduction by fishes or as a consequence of seasonal drying. The loss or degradation of wetlands in central and south Florida is one of the principal threats to the wood stork. Wood storks tend to use the same colony sites over many years, as long as the sites remain undisturbed and sufficient feeding habitat remains in the surrounding wetlands. Traditional wetland nesting sites may be abandoned by storks once local or regional drainage schemes remove surface water from beneath the colony trees. Maintaining adequate water levels to protect nests from predation is a critical factor affecting production of a colony. The lowered water levels allow nest access by raccoons and other land-based predators. As a result of such drainages and predation, many storks have shifted colony sites from natural to managed or impounded wetlands. Life history/Population Dynamics Wood storks are seasonally monogamous, probably forming a new pair bond every season. Three and 4-year-old birds have been documented to breed, but the average age of first breeding is unknown. Once wood storks reach sexual maturity,they are assumed to nest every year; there are no data on whether they breed for the remainder of their life or whether the interval between breeding attempts changes as they age. Wood storks construct their nests in trees that are usually standing in water or in trees that are on dry land if the land is a small island surrounded by water. The nests are large rigid structures usually found in the forks of large branches or limbs. The date on which wood storks begin nesting varies geographically. In Florida,wood storks lay eggs as early as October and as late as June. In general, earlier nesting occurs in the southern portion of the state (below 27°N). Female wood storks lay a single clutch of eggs per breeding season. However, they will lay a second clutch if their nests fail early in the breeding season. Wood storks lay two to five (usually three) eggs depending on environmental conditions; presumably larger clutch size in some years are responses to favorable water levels and food resources. Once an egg has been laid in a nest, one member of the breeding pair never leaves the nest unguarded. Both parents are responsible for incubation and foraging. Incubation takes approximately 28 days, and begins after the first one or two eggs are laid; therefore egg-hatching is asynchronous. It takes about 9 weeks for the young to fledge; once they fledge,the young stay at the nest for an additional 3 to 4 weeks to be fed by their parents. The U.S. population of the wood stork was listed as endangered in 1984 because it had declined by more than 75 percent since the 1930s. The original listing recognized the relationship 32 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 between the declining wood stork population, the loss of suitable foraging habitat, and colony nesting failures, particularly in the breeding colonies in south Florida where human actions have reduced wetland areas by about 35 percent. More recent survey data provided by FWS (1997) in the wood stork recovery plan give a U.S. breeding population of 4,073 nests in 1991, 4,084 nests in 1992, 6,729 nests in 1993, 5,768 nests in 1994, and 7,853 nests in 1995. These data suggest that the breeding population of wood storks is increasing, although the number of nests per year varies considerably. Since the 1960s, the wood stork population has shown a substantial decline in southern Florida and a substantial increase in northern Florida, Georgia, and South Carolina. On the average, the south Florida subpopulation represents 53 percent of the Florida population and 34 percent of the southeastern U.S. population. These data show a nesting population of 1,339 nests in 1991, 2,546 nests in 1993, 2,015 nests in 1994, and 2,639 nests in 1995. Most authors agree that the decline of the U.S. wood stork population far exceeds the range of historic variability in total population size, and is correlated with water management activities in south Florida (Palmer 1962, Frederick 1993, Ogden 1996). During wet years, current water management practices prevent the formation of shallow pools that concentrate the fish on which wood storks forage. During dry years, current water management practices overdrain the freshwater sloughs, reduce freshwater flows into the mainland estuaries and reduce their ability to produce the fish on which wood storks forage. Prognosis of the U.S. wood stork population between 1996 and 2020 is partially dependent on the success of the overall South Florida Ecosystem restoration effort. The freshwater flows need to be restored to more closely mimic the pre-drainage system; it is believed that by restoring the quantity, quality, timing, and distribution of flows in the remaining Everglades wetlands that the prey base so critical to wood storks during the breeding season will be recovered in both the estuarine and freshwater systems. Status and Distribution Breeding populations of the wood stork occur from northern Argentina, eastern Peru, and western Ecuador north to Central America, Mexico, Cuba, Hispaniola, and the U.S. In the U.S., wood storks historically nested in all coastal states between Texas and South Carolina. Currently, wood storks breed in Florida, Georgia, and coastal South Carolina. Post breeding storks from Florida, Georgia, and South Carolina disperse occasionally as far north as North Carolina and as far west as Mississippi and Alabama. In south Florida, breeding colonies of the wood stork occur in Broward, Charlotte, Collier, Miami-Dade, Hardee, Indian River, Lee, Monroe, Osceola, Palm Beach, Polk, St. Lucie, and Sarasota counties. Wood storks have also nested in Martin County, and at one time or another, in every county in south Florida. It is believed that storks nesting in north Florida, Georgia, and South Carolina move south during the winter months (December through February). In some years, the inland marshes of the Everglades have supported the majority (55 percent) of the U.S. population of wood storks. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the wood stork in the Action Area. 33 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Habitat Conversion - As noted above, nesting, roosting, and foraging habitats used by the wood stork are rapidly being altered to support a growing human population in the State of Florida. Demographic Concerns - South Florida populations can be expected to continue to decline as wetlands, marshes and estuarine systems are lost or as water management systems alter the volume and timing of water flows in these areas. Habitat Loss/Habitat Degradation - The most threatening issue facing the survival and recovery of the wood stork is loss or degradation of wetlands that are used as nesting, roosting, and foraging habitat. Human-induced Effects— Indirect adverse effects are likely to occur in areas where water levels are artificially manipulated. For example, current water management practices prevent formation of shallow pools that concentrate fish on which wood storks forage. During dry years, current water management practices over-drain the freshwater sloughs, reduce freshwater flows into the mainland estuaries and reduce their ability to produce the fish on which wood storks forage. Florida Panther(Puma concolor coryl) Species/Critical Habitat Description The Florida panther, a subspecies of mountain lion, is one of the most endangered large mammals in the world. A small population in south Florida represents the only known remaining wild population of an animal that once ranged throughout most of the southeastern United States from Arkansas and Louisiana eastward across Mississippi, Alabama, Georgia, Florida and parts of South Carolina and Tennessee. The panther presently occupies one of the least developed areas in the eastern United States - a contiguous system of large private ranches and public conservation lands in Broward, Collier, Glades, Hendry, Lee, Miami-Dade, Monroe, and Palm Beach counties totaling more than 2 million acres. Geographic isolation, habitat loss, population decline, and associated inbreeding have resulted in a significant loss of genetic variability and overall health of the Florida panther population. The survival and recovery of the Florida panther is dependent upon: (1) protection and enhancement of the extant population, associated habitats, and prey resources; (2) improving genetic health and population viability; and (3) re-establishing at least two additional populations within the historic range. No critical habitat has been designated for the Florida panther. The Florida panther is a medium-sized puma or mountain lion that is described as being relatively dark tawny in color, with short, stiff hair (Bangs 1899), and having longer legs and smaller feet (Cory 1896) than other subspecies. Adult male panthers reach a length of 2.15 m from their nose to the tip of their tail and may reach or exceed 68 kg in weight, but typically average around 54.5 kg. They stand approximately 60 to 70 cm at the shoulder. Female panthers are considerably smaller with an average weight of 34 kg and length of 1.85 m. Florida panther kittens are gray with dark brown or blackish spots and five bands around the tail. Early radiotelemetry investigations indicated that panther (n=6) use of mixed swamp forests and 34 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 hammock forests was greater than expected in relation to the availability of these vegetative communities within the panthers' home range area (Belden et al. 1988). As investigations expanded onto private lands between 1985 and 1990, it was determined that panthers (n=26) preferred native, upland forests, especially hardwood hammocks and pine flatwoods, over wetlands and disturbed habitats (Maehr et al. 1991 a). Hardwood hammocks provide important habitat for white-tailed deer(Odocoileus virginianus), an important panther prey species(Harlow 1959, Belden et al. 1988, Maehr 1990a, 1992a, Maehr et al. 1991a). Understory thickets of tall, almost impenetrable saw palmetto (Serenoa repens) have been identified as the most important resting and denning cover for panthers (Maehr 1990a). Agricultural and other disturbed habitats, freshwater marsh, thicket swamp, and mixed swamp are not preferred, and are either used in proportion to their availability or are avoided (Maehr 1990a). Panthers have not been found in pastures during daytime radiotelemetry flights but may travel through them at night(Maehr et al. 1991a, Maehr 1992a). Male and female panther home range size is inversely related to habitat quality; the greater the extent of agricultural land and wetland habitats the larger the home range, and the greater the extent of mixed hardwood forests and dry pine forests the smaller the home range. High-quality habitat produces abundant prey and influences female panther reproductive success (Maehr 1992b, Maehr et al. 1989b). The largest contiguous tract of panther habitat is in the Big Cypress Swamp/Everglades physiographic regions. Life history/Population Dynamics The pattern of Florida panther distribution involves several males maintaining large, mutually exclusive home ranges containing several adult females and their dependent offspring. This spatial arrangement seems to be a prerequisite for successful reproduction (Maehr 1993). Male Florida panthers are polygynous. Breeding activity peaks in fall and winter. Parturition is distributed throughout the year with 81 percent of births occurring between March and July(July having the greatest number of births). Litter sizes range from one to four kittens, with a mean of 2.2 kittens surviving to at least 6 months. Intervals between litters range from 16 to 37 months (Land 1994). Den sites are usually located in dense, understory vegetation, typically saw palmetto at distances greater than 1 km away from roads (Maehr 1996). Den sites are used for up to 2 months by female panthers and their litters from parturition to weaning. Female panthers losing their litters generally produce replacement litters. Female Florida panthers have bred as young as 18 months of age and as late as 11 years of age. The first sexual encounters for males occur at about 3 years of age. Dispersal of young typically occurs around 1.5 to 2 years of age, but may occur as early as one year of age. Infant mortality is thought to be relatively high with fewer than half of all pregnancies resulting in offspring that survive beyond 6 months of age. Young panthers are considered recruited into the population when they have successfully reproduced. Females are readily recruited into the population as soon as they are capable of breeding (Maehr et al. 1991a). Males appear to have more difficulty being recruited. Without large areas of suitable habitat to accommodate dispersal, young males have few opportunities for recruitment as residents. As a result, the panthers' ability to increase and outbreed has been severely restricted. Successful male recruitment appears to depend on the death, or home range shift, of a resident adult male. Turnover in the breeding population is low, with documented mortality in radio-collared Florida panthers being greatest in subadult and non-resident males. Florida panther mortality (n=67) averaged 3.5 deaths per year from 1978 through June 30, 1998. Male panthers accounted for 57.6 percent of mortality. Sub-adult panthers (0 to 3 years) of both sexes accounted for 45.5 percent of mortality. Specific causes of panther mortality include road 35 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 kill (37.9 percent), intraspecific aggression (21.2 percent), disease and old age (18.2 percent), causes unknown (12.1 percent), shootings (9.1 percent), and research related (1.5 percent) (Land and Taylor 1998). These mortality figures only include panthers endemic to south Florida, and not the introduced Texas cougars. Status and Distribution The only known, reproducing panther population is located in the Big Cypress Swamp/Everglades physiographic region of south Florida. The core of the breeding population is centered in Collier,Hendry and Miami-Dade counties. Radio-collared panthers have also been documented in Broward, DeSoto, Glades, Highlands, Lee, Monroe, Osceola, Palm Beach, and Polk counties. There are still large areas of privately owned land in Charlotte, Collier, Hendry, Lee, and Glades counties where uncollared individuals may reside (Maehr 1992b). Private lands account for approximately half the occupied panther range in south Florida. Of the 27 Puma concolor subspecies described in Hall(1981),the Florida panther is the only one remaining in the eastern U.S. The panther population in Florida numbered about 500 at the turn of the century (Seal et al. 1989). The Big Cypress population was estimated at 125 in 1969 (DOI 1969) and a south Florida population at 92 in 1972 (Schemnitz 1972). Radiotelemetry research began in 1981 and through 1983 was limited to Fakahatchee Strand State Preserve and Big Cypress National Preserve (Belden et al. 1988). The research program gradually expanded to include Everglades NP, Florida Panther NWR, Picayune Strand State Forest, Okaloacoochee Slough State Forest,the Corkscrew Regional Ecosystem Watershed, and private lands in Collier, Hendry, and Lee counties. A total of 72 panthers (41 male, 31 female) have been radio-collared since telemetry research began in 1981. As of June 30, 1998 there were 30 panthers (14 male, 16 female)being monitored. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the Florida panther in the Action Area. Habitat Conversion - As noted above, upland habitats used by the Florida panther are rapidly being converted to commercial, residential, and other uses to support a growing human population in the State of Florida. Demographic Concerns - Geographic isolation, habitat loss, population decline, and associated inbreeding have resulted in a significant loss of genetic variability and overall health of the Florida panther population. Habitat Loss/Habitat Degradation - The most threatening issue facing the survival and recovery of the Florida panther is habitat loss and fragmentation resulting from the conversion of suitable habitats to other uses. Human-induced Effects - Indirect adverse effects on the Florida panther are likely to occur as habitat loss and fragmentation geographically isolates panthers, resulting in inbreeding and, thus, a loss of genetic variability. 36 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Florida Bonneted Bat The Florida bonneted bat was federally listed as an endangered species on October 2, 2013 (78 Federal Register [FR] 61003). The Florida bonneted bat is thought to be rare, with only a few nursery roosts documented. The Florida bonneted bat is the largest bat species in Florida. This species can be 6.5 inches in length and have a wingspan of 20 inches. It varies in color from black, to brown, to gray, to a cinnamon color. They typically feed on flying insects. No critical habitat has been established for this species,therefore none will be impacted. Life History/Population Dynamics There is very little information regarding the life history of the Florida bonneted bat. It is thought to have a very low reproduction rate, only giving birth to one off-spring each breeding season however, there may be two breeding seasons per year. The bat is thought to have a lifespan of 10-20 years. The majority of roosts are found in non-native habitat or artificial roosts, such as bat houses. Typically the colonies are small consisting of one male and several females. Roosting can occur in tree cavities or in artificial structures such as bat houses or buildings. Foraging typically occurs in native habitats including hardwoods, pinelands and mangrove habitats,but golf courses and neighborhoods may also be utilized. The bats have only been found in south Florida in Lee, Collier, Charlotte and Miami-Dade counties. Status and Distribution Very little is known about the distribution of the Florida bonneted bat. To date they are found in extreme south Florida, having be documented in Charlotte, Lee, Collier, and Miami-Dade counties. There are many threats to the population of the bat. It has such a small range that the population is susceptible to decline as a result of natural disasters and diseases. Additionally, habitat loss and the use of pesticides pose threats to the population. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the Florida bonneted bat in the Action Area. Habitat Conservation - As noted above, the Service believes that upland habitats used by the Florida bonneted bat are rapidly being converted to commercial, residential, and other uses to support a growing human population in the State of Florida. These man-made habitats seem to be utilized by the bat for roosting and foraging. Demographic Concerns - The limited distribution and small territory size of the Florida bonneted bat complicate evaluation of its population status and trends. Although the Service has no quantitative data with which to evaluate the trend of the bat in south Florida, it surmises the population as a whole is declining because of current rates of habitat destruction and degradation,and stress to the already limited population. 37 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Habitat Loss/Habitat Degradation — A significant threatening issue facing the survival and recovery of the Florida bonneted bat is habitat loss and fragmentation resulting from the conversion of suitable habitats to other uses. Human-induced Effects - Indirect adverse effects on the Florida bonneted bat are likely to occur in populations adjacent to or near human habitations. Remaining habitats are either lost or fragmented, increased pressure will be placed on resident individuals. The bat however, utilizes man-made structures for roosting and non-natural areas for foraging. West Indian Manatee Species/Critical Habitat Description Manatees, like the Florida panther, were listed in 1967 under the original endangered species list (32 FR 4001). Manatees have large, seal-shaped bodies with paired flippers and a round,paddle- shaped tail. They are typically grey in color (color can range from black to light brown) and occasionally spotted with barnacles or colored by patches of green or red algae. The muzzle is heavily whiskered and coarse, single hairs are sparsely distributed throughout the body. Adult manatees, on average, are about nine feet long and weigh about 1,000 pounds. At birth, calves are between three and four feet long and weigh between 40 and 60 pounds. Florida manatees are found in freshwater, brackish, and marine environments. Typical coastal and inland habitats include coastal tidal rivers and streams, mangrove swamps, salt marshes, freshwater springs, and vegetated bottoms (Florida Fish and Wildlife Conservation Commission 2007). As herbivores, manatees feed on the wide range of aquatic vegetation that these habitats provide. Shallow seagrass beds, with ready access to deep channels, are generally preferred feeding areas in coastal and riverine habitats (Smith 1993). In coastal northeastern Florida, manatees feed in salt marshes on smooth cordgrass (Spartina alternora) by timing feeding periods with high tide (Zoodsma 1991). Manatees use springs and freshwater runoff sites for drinking water; secluded canals, creeks, embayments, and lagoons for resting, cavorting,mating, calving and nurturing their young; and open waterways and channels as travel corridors (Gannon et al. 2007). Manatees occupy different habitats during various times of the year, with a focus on warmwater sites during winter. Most of the manatee-accessible waters in peninsular Florida from the St. Marys River on the Atlantic Coast to Crystal River on the Gulf Coast, as well as the St. Johns River watershed, are designated as critical habitat (50 CFR Part 17.95(a)). However, the most important element of that habitat is the availability of warm water during winter months. This warm water habitat influences the geographic extent of the species' range and is necessary for the species' survival during cold periods. Potential loss of this habitat is one of the most significant threats to the species. Other habitat components such as seagrasses and other aquatic food plants are not known to be limiting to manatee populations. Life history/Population Dynamics Manatees have also adapted to changing ecosystems in Florida. Industrial warmwater discharges and deep-dredged areas are used as wintering sites, stormwater/freshwater discharges provide manatees with drinking water, and the imported exotic plant, Hydrilla sp. (which has replaced 38 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 native aquatic species in some areas), has become an important food source at wintering sites (Smith 1993). Manatees are herbivores that feed opportunistically on a wide variety of marine, estuarine, and freshwater plants, including submerged, floating, and emergent vegetation. Common forage plants include and are not limited to: cord grass, alga, turtle grass, shoal grass, manatee grass, eel grass, and other plant types. (Calves initially suckle and may start feeding on plants when a few months of age. Weaning generally takes place within a year of birth.) Manatees also require sources freshwater, obtained from both natural and anthropogenic sources. Manatees mature at three to five years of age. Mature females go into heat for anywhere from two to four weeks. Mating activity can occur throughout the year. When in heat, females will attract numerous males and mate repeatedly; aggregations that include an estrus or focal female and numerous males are described as mating herds. Gestation lasts for about 13 months and cows usually give birth to a single calf; twinning is known to occur. While calving primarily peaks in the spring, calves may be born at any time of the year. Reproductive senescence is poorly described; a known female has given birth to seven individual calves over a period of about 30 years. A calf may remain with its mother for about two years. Calving intervals range from two and three years. The oldest known manatee is 65 years of age. The most current published information of Florida manatee population dynamics indicate that, with the exception of southwest Florida, manatee populations are increasing or stable throughout the state. However, Langtimm et al. (2004) reported that adult survival rates for Southwest Florida used in those analyses could be biased low due to effects from temporary emigration. The most recent synoptic survey, conducted in January 2014, recorded approximately 4,824 manatees (FWC FWRI Manatee Synoptic Aerial Surveys 2014). The highest count ever recorded was 5,077 manatees in 2010. Status and Distribution The Florida manatees' range is generally restricted to the southeastern United States; individuals occasionally range as far north as Massachusetts and as far west as Texas.Antillean manatees are found in coastal and riverine systems in South and Central America (from Brazil to Mexico) and in the Greater and Lesser Antilles throughout the Caribbean Basin. Due to a variety of human activities (hunting, loss of habitat, etc.), manatees have been extirpated from many areas and their distribution is patchy throughout the region. USFWS recovery activities primarily focus on manatees in Florida and Puerto Rico, although the species is managed throughout its range. Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the manatees in the Action Area. Threats to the Florida manatee encompass anthropogenic factors and catastrophic, natural events that could cause declines in reproductive and survival rates or loss and degradation of habitat. The future of the Florida manatee is also jeopardized by the predicted loss and deterioration of warm-water habitat, caused by retirement of or changes in the operations of aging power plants and reductions in natural spring flows. Threats that can be determined through necropsy of manatee carcasses over the past 10 years are depicted in Figure 2. A recent assessment of threats 39 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 to the Florida manatee indicated that watercraft-related mortality had the greatest impact on manatee population growth and resilience and that, particularly in the long term, loss of warm water was also a substantial threat(Runge et al. 2007b). Watercraft collisions—The largest known cause of human-related manatee mortality in Florida is watercraft collision. Watercraft strikes result in numerous injuries and deaths each year. Watercraft collisions account for approximately 25% of all documented manatee deaths since 1976 (and 35% of documented deaths of known cause), and are the single greatest known cause of mortality(Deutsch et al. 2002). Loss of warm-water habitat—Expected changes in the network of warm-water refuges over the next several decades present one of the most serious long-term threats to manatees in Florida. As noted in the federal Florida Manatee Recovery Plan, "one of the greatest threats to the continued existence of the Florida manatee is the stability and longevity of warm-water refuges" (USFWS 2001,p. 28). Other anthropogenic threats — Other human-related causes of manatee death and injury include entrapment in water-culvert pipes, crushing (in flood-control structures, in canal locks, or between large ships and wharfs), entanglement in fishing gear or debris, and incidental ingestion of debris (Ackerman et al. 1995). Together, these other human-related causes accounted for approximately 6%of all documented manatee deaths over the past two decades. Loss of forage plants — Human population growth in coastal Florida over the past half century has resulted in drastic losses of coastal wetland habitats. Seagrass distribution and abundance in many estuaries have declined as the result of direct human impacts (e.g., dredge-and-fill activities, propeller scarring) and indirect effects of development (declining water quality and nutrient loading). It will be particularly important to protect, restore, and maintain aquatic vegetation communities in the vicinity of warm-water aggregation sites. Harmful algal blooms —Naturally occurring catastrophic threats to manatees include prolonged periods of very cold temperatures, hurricanes, harmful algal blooms (i.e., "red tide"), and the potential for a disease epizootic. The threat from extended periods of cold weather relates to the availability and quality of warm-water habitat,which has already been discussed above. Manatees on Florida's Gulf coast are frequently exposed to brevetoxin, a potent neurotoxin produced by the dinoflagellate Karenia brevis during red tide events. Red tide represents a major natural source of mortality for manatees in the southwest region. Exposure to pathogens — In addition to red tide, manatees could potentially be exposed to pathogens. Spread of such pathogens could be particularly rapid during winter when manatees are concentrated in warm-water refuges. Large-scale mortality events caused by disease or toxins have decimated other populations of marine mammals, including seals and dolphins, removing 50%or more of the individuals in some events (Harwood and Hall 1990). Hurricanes —Another type of phenomenon that can potentially impact manatee Populations are hurricanes. In the Northwest region, Langtimm and Beck (2003) found that adult survival rate were depressed in years with severe storms or hurricanes. The mechanisms underlying the lower 40 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 survival probabilities are unknown as there has not been a corresponding elevation in the number of reported carcasses. Such events could also result in large-scale emigration out of the affected region. Smalltooth Sawfish Species/Critical Habitat Description The smalltooth sawfish is a tropical marine and estuarine elasmobranch fish (sharks and rays) that has been reported to have a circumtropical distribution. Although they are rays, sawfish physically more closely resemble sharks, with only the trunk and especially the head ventrally flattened. Smalltooth sawfish are characterized by their "saw," a long, narrow, flattened rostral blade with a series of transverse teeth along either edge. In the western Atlantic, the smalltooth sawfish has been reported from Brazil through the Caribbean and Central America, the Gulf of Mexico, and the Atlantic coast of the United States. Smalltooth sawfish are euryhaline, occurring in waters with a broad range of salinities from freshwater to full seawater. Their occurrence in freshwater is suspected to be only in estuarine areas temporarily freshwater from receiving high levels of freshwater input.Many encounters are reported at the mouths of rivers or other sources of freshwater inflows, suggesting estuarine areas may be an important factor in the species distribution(Simpfendorfer and Wiley 2004). Smalltooth sawfish feed primarily on fish, with mullet,jacks, and ladyfish believed to be their primary food resources (Simpfendorfer 2001). By moving its saw rapidly from side to side through the water, the relatively slow-moving sawfish is able to strike at individual fish. The teeth on the saw stun, impale, injure, or kill the fish. Smalltooth sawfish then rub their saw against bottom substrate to remove the fish, which are then eaten. In addition to fish, smalltooth sawfish also prey on crustaceans (mostly shrimp and crabs), which are located by disturbing bottom sediment with their saw. Critical habitat was established in 2009 (74 FR 45353) in the Charlotte Harbor Estuary and Ten Thousand Islands/ Everglades Estuary. The designation is meant to specifically protect red mangrove habitat and shallow euryhaline habitat that is essential to juvenile smalltooth sawfish as nursery habitat. No physical or biological features could be identified as essential to adult sawfish. Life history/Population Dynamics Few long-term abundance data exist for the smalltooth sawfish, making it very difficult to estimate the current population size. However, Simpfendorfer (2001) estimated that the U.S. population may number less than five percent of historic levels, based on anecdotal data and the fact that the species' range has contracted by nearly 90 percent, with south and southwest Florida the only areas known to support a reproducing population. The decline in the population of smalltooth sawfish is attributed to fishing (both commercial and recreational), habitat modification, and sawfish life history. Large numbers of smalltooth sawfish were caught as bycatch in the early part of this century. Smalltooth sawfish were historically caught as bycatch in various fishing gears throughout their historic range. Frequent accounts in earlier literature document smalltooth sawfish being entangled in fishing nets from areas where smalltooth 41 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 sawfish were once common but are now rare or extirpated. Loss and/or degradation of habitat contributed to the decline of many marine species and continues to impact the distribution and abundance of smalltooth sawfish. Since actual abundance data are limited,researchers have begun to compile capture and sightings data (collectively referred to as encounter data) in the National Sawfish Encounter Database (NSED) that was developed in 2000. Since the conception of the NSED, over 3,000 smalltooth sawfish encounters have been reported and compiled in the encounter database (NSED 2012). Although this data cannot be used to assess the population because of the opportunistic nature in which they are collected (i.e., encounter data are a series of random occurrences rather than an evenly distributed search over a defined period of time), researchers can use this database to assess the spatial and temporal distribution of smalltooth sawfish. Status and Distribution The majority of smalltooth sawfish encounters today are from the southwest coast of Florida between the Caloosahatchee River and Florida Bay. Outside of this core area, the smalltooth sawfish appears more common on the west coast of Florida and in the Florida Keys than on the east coast, and occurrences decrease the greater the distance from the core area (Simpfendorfer and Wiley 2004). The capture of a smalltooth sawfish off Georgia in 2002 is the first record north of Florida since 1963. New reports during 2004 extend the current range of the species to Panama City, offshore Louisiana (south of Timbalier Island in 100 ft of water), southern Texas, and the northern coast of Cuba. Despite the lack of scientific data on abundance, recent encounters with young-of-the-year, older juveniles, and sexually mature smalltooth sawfish indicate that the U.S. population is currently reproducing (Seitz and Poulakis 2002; Simpfendorfer 2003). The abundance of juveniles encountered, including very small individuals, suggests that the population remains viable. Also, the declining numbers of individuals with increasing size is consistent with the historic size composition data(Simpfendorfer and Wiley 2004). The effective population size, the number of animals in the population that produce offspring was recently estimated to be between 250 and 350 individuals (Chapman et al. 2011). Given the small effective population size and the increasing number of neonates produced, inbreeding depression was suspected to be a concern for smalltooth sawfish. Given the degree of decline and range contraction that smalltooth sawfish have experienced over the last few generations, it was originally hypothesized that the remnant smalltooth sawfish population had experienced a genetic bottleneck. However, an analysis of tissue samples collected under a recent study indicates that inbreeding is rare (Chapman et al. 2011). The status and trends and recent encounters in new areas beyond the core abundance area suggest that the population may be increasing. However, smalltooth sawfish encounters are still rare along much of their historical range and they are thought to be extirpated from areas of historical abundance such as the Indian River Lagoon and John's Pass (Simpfendorfer and Wiley 2004). 42 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Analysis of the Species/Critical Habitat Likely to Be Affected The following broad categories of factors may ultimately affect the status and distribution of the smalltooth sawfish in the Action Area. Agriculture/Landscaping—Agricultural activities convert wetlands and shed nutrient, pesticide, and sediment-laden runoff. These in turn lead to excessive eutrophication, hypoxia, increased sedimentation and turbidity, stimulation of hazardous algal blooms, and delivery of chemical pollutants (SAFMC 1998). Coastal and Urban Development—Threats from development include loss of wetlands, point and non-point sources of toxins, eutrophication, and hydrologic modification. Since the mid 1980s, rates of habitat loss have been decreasing, but habitat loss continues. A major concern is the destruction of wetlands by filling for urban and suburban development. In addition, seawalls and canals for waterfront homes have replaced marsh and mangrove intertidal shorelines and shallow estuarine waters. Where beachfront development occurs, the site is often fortified to protect the property from erosion. Beach armoring is a common type of construction that includes sea walls, rock revetments, riprap, sandbag installations, groins and jetties. In Florida, coastal development often involves the removal of mangroves and the armoring of shorelines through seawall construction. Direct destruction of mangrove habitat is no longer allowed without permits, but indirect damage to mangrove habitat from increased urbanization and the resulting overall habitat degradation still occurs. Dredging — Modifications of natural freshwater flows into estuarine and marine waters through construction of canals and other controlled devices have changed temperature, salinity, and nutrient regimes; reduced both wetlands and submerged aquatic vegetation; and degraded vast areas of coastal habitat. Profound impacts to hydrological regimes have been produced in South Florida through the construction of a 1,400 mile network of canals, levees, locks, and other water control structures which modulate freshwater flow from Lake Okeechobee, the Everglades, and other coastal areas. Dredges are used to maintain these canals and shipping channels. While these modifications of habitat are not the primary reason for the decline of smalltooth sawfish abundance, it is likely a contributing factor and almost certainly hampers the recovery of the species. Fisheries Bycatch—Bycatch mortality is cited as the primary cause for the decline in smalltooth sawfish in the United States (NMFS 2010). Large-scale directed fisheries for smalltooth sawfish have not existed but historically, smalltooth sawfish were often bycatch in various fishing applications. Reports of smalltooth sawfish becoming entangled in fishing nets are common in early literature from areas where smalltooth sawfish were once common, but are now rare, if not extirpated. Climate Change — Changes to the global climate are likely to be a threat to smalltooth sawfish and the habitats they use. The Intergovernmental Panel on Climate Change has stated that global climate change is unequivocal (IPCC 2007) and its impacts to coastal resources may be significant. Some of the likely effects commonly mentioned are sea level rise, increased 43 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 frequency of severe weather events, changes in the amount and timing of precipitation, and changes in air and water temperatures (NOAA 2012). Sea level rise could impact mangrove resources, as sediment surface elevations for mangroves will likely not keep pace with projected rates of elevation in sea level (Gilman et al. 2008). Sea level increases could also affect the amount of shallow water available for juvenile smalltooth sawfish nursery habitat, especially in areas where there is shoreline armoring (e.g., seawalls). Further, the changes in precipitation coupled with sea level rise may also alter salinities of coastal habitats, reducing the amount of available smalltooth sawfish nursery habitat. III. ENVIRONMENTAL BASELINE Action Area As stated earlier, the action area is identified as the entire Clam Bay NRPA area including dredge template(s), sand fill template(s), beach corridors, pipeline corridors, staging areas, upland disposal sites, and extending up to 300 feet offshore within 0.5 mile around the Pass. The majority of the currently proposed impacts are associated with the maintenance dredging of Clam Pass and maintenance of the network of hand dug flushing channels distributed throughout the system. Ecological enhancements associated with this work are widespread throughout the system. Presence of the Species in the Action Area American Crocodile No crocodiles have been observed within the Clam Bay NRPA during the past 15 years of biological monitoring that has been conducted, though the presence of appropriate habitat types makes it suitable for crocodiles. Anecdotal sightings have been passed on by residents within the community though none of these sightings has been verified. Documented sightings both north (Sanibel Island) and south (Marco Island) of the Clam Bay NRPA lend credence to the possibility that crocodiles could travel through the area and pass through the NRPA. The Clam Bay NRPA contains 359.56 acres of mangrove swamp, 2.35 acres of saltwater marsh, 8.05 acres of tidal flats, and 129.73 acres of creeks and bays which are suitable crocodile habitat. Eastern Indigo Snake Eastern indigo snakes are frequently associated with high, dry, well-drained soils and have been documented using inactive gopher tortoise burrows. Gopher tortoise burrows have been found on site within the coastal strand (FLUCCS code 322 Coastal Scrub and 428 Cabbage Palm Hammock, see Figure 3 attached) portions of the Clam Bay NRPA. No eastern indigo snakes have been observed on-site,but the presence of gopher tortoise burrows on-site indicates that this area may be suitable for eastern indigo snakes. The Clam Bay NRPA contains 24.81 acres of coastal strand habitat which,will not be affected by the placement of spoil on the beach. 44 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Sea Turtles Sea turtle nesting has historically occurred along the beaches both north and south of Clam Pass. The most current 2014 data from the Collier County Sea Turtle Protection program is that 172 loggerhead sea turtle nests were laid on Vanderbilt Beach (4.7 miles of beach north of Clam Pass) of which 167 are documented as hatching. In addition, 160 loggerhead nests were documented on the Park Shore beach (approximately 3.2 miles from Clam Pas south) of which 152 were noted as hatching. Gopher Tortoise Gopher tortoise burrows have been found on site within the coastal strand (FLUCCS code 322 Coastal Scrub and 428 Cabbage Palm Hammock, see Figure 3 attached) portions of the Clam Bay NRPA. Gopher tortoises and their burrows have been observed on-site. The Clam Bay NRPA contains 24.81 acres of coastal strand habitat, none of which will be affected by the placement of spoil on the beach. Prior to commencement of dredging activities, all active and in- active gopher tortoise burrows within 50 feet of any work areas or travel corridors will be located and a 25' buffer established. Piping Plover Shorebird monitoring efforts have been undertaken in the proposed action area since January 2013 by Turrell, Hall and Associates in association with the previous maintenance dredging event. In addition, some data exists based on a beach nourishment project conducted along portions of Vanderbilt Beach, Park Shore Beach, and Naples City Beach in 2006. These surveys were conducted by the Conservancy of Southwest Florida between February 10 and May 30, 2006, (construction phase) and from June 1, 2006, to September 30, 2008 (post-construction). The bi-monthly surveys documented a total of 25 species and a total of 5,410 birds (Addison 2008). Although no piping plovers were observed during these surveys, piping plover PCEs are present throughout the proposed action area. Wood Stork According to the Service,nearby Corkscrew Swamp is home to the largest wood stork rookery in the United States. Wood storks have been observed foraging in the swale along the far eastern boundary of the NRPA boundary. Wood storks have also been observed foraging along the tidal flat areas just south of the central boardwalk and within the Pass channel in 2113 when the Pass had closed. Wood storks are not common visitors to the tidally influenced portions of the system but are occasional visitors. They are much more common along the berm and swale that defines the eastern boundary of the NRPA. Florida Bonneted Bat No Florida bonneted bats have been observed on-site, but the presence of the mangroves on-site indicates that this area may be suitable for the bat. Florida bonneted bats can utilize mangrove 45 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 areas for foraging of flying insects. Approximately 359.56 acres of mangrove swamp occur within the Clam Bay NRPA, which acts as suitable foraging habitat for the bat. The size of the bat requires that natural roosts be very large trees, of which there are few within the Clam Bay NRPA. The mangrove area within the Clam Bay NRPA will not be affected by the placement of spoil on the beach. Florida Panther No panthers have been observed within the Clam Bay NRPA in the recent history of biological monitoring though there was a historical sighting on one of the boardwalks about 20 years ago. A young male panther was documented on KeeWadin Island (south of the project site) in 2007 after having swum out to it. Given the location of the project site and the surrounding development it is highly unlikely that a panther would stray into the NRPA but not impossible. The Clam Bay NRPA contains approximately 37 acres of coastal and tidal habitats which could be utilized by panthers should one roam into the Action Area. Florida Manatee Manatees have been observed within the Clam Bay NRPA on multiple occasions. Both adults and adults with young have been observed. Several occurrences of manatees becoming temporarily stranded on the ebb shoal of the Pass have been documented in the past few years (2009, 2012, and 2014). While seagrass type and scarcity within the system do not make this a viable regular foraging area, the isolation of the bays do make it a good resting stopover for animals that may be moving up or down the coast. Smalltooth Sawfish Juvenile sawfish (<3 feet long) have been observed within the Clam Bay NRPA on multiple occasions. The most recent observances have been in Outer Clam Bay in 2014 and under the central boardwalk in 2013. Factors Affecting Species Environment within the Action Area Clam Pass is a small, marginally stable inlet that has migrated north and south along the shore over the years. Prior to dredging, average water depths of Clam Pass were -2.5' to -1.0', and its width ranged from 30-50' (Collier County, 1994). The Pass remains the primary source of tidal exchange for the Clam Bay system, but it is restricted by sediment deposits just inside the Pass and in the long meandering tidal creeks surrounded by mangrove forests. The Pass is susceptible to outside events and can periodically close, which has happened six times in the last 25 years, most recently in late 2012. The health of the mangrove forest is directly related to the connection at Clam Pass. The exchange of seawater between Clam Pass and the Gulf is critical to the ability of the estuary to export organic matter, as well as to help regulate excess salt and freshwater. It also supplies oxygen-rich water from the Gulf and keeps metabolic wastes from accumulating. 46 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 American Crocodile Approximately 359.56 acres of mangrove swamp, 2.35 acres of saltwater marsh, 8.05 acres of tidal flats and 129.73 acres of creeks and bays which, area appropriate crocodile habitat. These habitats will be impacted by the dredging of Pass itself and the interconnecting creeks that connect the Pass with the bays. Dredging activities and spoil disposal is proposed within a portion of these habitats, however it is expected to have little, if any, effect on the American crocodile or its suitable habitat. Prior to commencement of dredging activities, a survey for crocodiles in the area will be completed. Eastern Indigo Snake Approximately 24.81 acres of coastal strand habitat that is utilized by gopher tortoises, and therefore potentially utilized by the eastern indigo snake, is managed as part of the Clam Bay NRPA Management Plan. All dredging activities and spoil disposal is proposed outside of these habitats, thereby having little, if any, effect on the eastern indigo snake or its suitable habitat. Prior to commencement of dredging activities, all active and in-active gopher tortoise burrows within 50 feet of the work area will be located and a 25' buffer established. Sea Turtles Sea turtles are known to nest on the beaches adjacent to Clam Pass. Approximately 33.35 acres of beach and dune system are encompassed within the NRPA Boundary (Action Area). Spoil placement resulting from the proposed dredging of the Pass will potentially occur on stretches of the beach approximately 1500 feet north and 2800 feet south of the Pass. It is anticipated that sand placement will be done outside of the sea turtle nesting season unless an emergency situation necessitates re-opening of a Pass closure during the nesting season. In such a case, coordination will be undertaken with the appropriate wildlife agency personnel to identify, protect, and if necessary, relocate, any sea turtle nests that may be present within the emergency work area. Gopher Tortoise Gopher tortoises and their burrows have been observed on-site. The Clam Bay NRPA contains 24.81 acres of coastal strand habitat,none of which will be affected by the placement of spoil on the beach. Prior to commencement of dredging activities, all active and inactive gopher tortoise burrows within 50 feet of any work areas or travel corridors will be located and a 25' buffer established. Population data on tortoises within the NRPA boundaries will be collected periodically to look for trends and to help determine potential impacts associated with future management or catastrophic actions that may occur. Piping Plover Although no piping plovers were observed during these surveys, piping plover PCEs are present throughout the proposed action area. These PCEs are dependent on the tidal exchange and 47 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 fluctuations to make the foraging habitat available. Beach habitat may be temporarily impacted during the dredging and spoil placement activities but will recover. Wood Stork Approximately 10.4 acres of brackish marsh and tidal flat habitat are present where foraging is most likely to occur. The proposed Pass dredging and sand placement will have no direct impact on any of the areas where foraging and roosting activities have been observed. The hand dug channels provide concentration areas that enhance wood stork foraging opportunities. Maintenance of these is important in preserving this benefit. Florida Bonneted Bat Florida bonneted bats can utilize mangrove areas for foraging of flying insects. Approximately 359.56 acres of mangrove swamp occur within the Clam Bay NRPA, which can serve as foraging habitat for the bat. The size of the bat requires that natural roosts be very large trees, of which there are few within the Clam Bay NRPA. No Florida bonneted bats have been observed on-site, but the presence of the mangroves on-site indicates that this area may be suitable for the bat. The mangrove area within the Clam Bay NRPA will not be affected by the placement of spoil on the beach. Florida Panther Panthers are not a likely inhabitant of the Clam bay NRPA. None of the actions proposed will affect any of the habitat that is currently suitable for panther utilization. Florida Manatee There are approximately 130 acres of open waters in the Clam Bay NRPA through which manatees can travel. Seagrass coverage varies from year to year with estimates ranging generally between 2 and 5 acres. The closure of Clam Pass has the potential of trapping manatees within the bays or of denying manatee access to the bays if they are traveling along the coast. Manatee protections will be put in place during any in water work and all work will be stopped if manatees enter the work area(s). Smalltooth Sawfish Sawfish have access to the 130 acres of open waters as well as the 370 acres of mangrove and other tidal habitats. The closure of Clam Pass has the potential of trapping sawfish within the bays as well as blocking access to the estuary for juveniles and adults looking for nursery habitat. IV. EFFECTS OF THE ACTION This section includes an analysis of the direct and indirect effects of the proposed action on the species and critical habitat and their interrelated and interdependent activities. To determine 48 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 whether the proposed action is likely to jeopardize the continued existence of threatened or endangered species in the Action Area, we focus on consequences of the proposed action that affect rates of birth, death, immigration, and emigration because the probability of extinction in plant and animal populations is most sensitive to changes in these rates. American Crocodile Effects of the Project on the American crocodile are expected to be minimal or non-existent. No evidence of any crocodile presence or utilization has been documented within the Action Area. Direct Effects Project construction is not likely to result in the direct "take" of an American crocodile. The probability of direct incidental take is dependent upon the number of crocodiles in the Project area and available, suitable habitat. Considering fact that no crocodiles have been observed on site, and the fact that crocodile habitat on site is minimal at best, the Project is not likely to have a direct effect on the American crocodile. Indirect Effects The indirect effects of the Project on the American crocodile are anticipated to be minimal. Construction of the Project will allow for continued access and utilization to potential crocodile habitat within the NRPA. Cumulative Effects Considering the permitting required for any future work efforts within the Action Area, there will be no negative cumulative effects on the crocodile as a result of the proposed project. Any other like activities within the Action Area will have to undergo similar federal review and any potential impacts will be addressed at that time. Eastern Indigo Snake Effects of the Project on the eastern indigo snake may occur both as direct and indirect effects. Direct Effects Project construction is not likely to result in the direct "take" of an eastern indigo snake. The probability of direct incidental take is dependent upon the number of indigos in the Project area and available, suitable habitat. Although gopher tortoise burrows have been found on site, no indigo snakes have been observed. An indigo snake management plan for use during construction activities will be prepared. Considering this plan, the fact that no indigos have been observed on site, and the fact that indigo habitat on site will not be degraded by the proposed activities,the Project is not likely to have a direct effect on the eastern indigo snake. Indirect Effects Given the current conditions of the Project site and surrounding area as described above, the indirect effects of the Project on the eastern indigo snake are anticipated to be minimal. Construction of the Project may encourage additional recreational utilization which could increase the possibility of human and snake interactions. Preservation of existing habitat 49 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 education of visitors on the importance of indigo snakes will minimize the potential for these adverse interactions. Cumulative Effects As stated above,the Project is occurring in an already highly used coastal beach area which is all preserved within the NRPA boundary,thereby adding minimal additional cumulative impact. Sea Turtles The proposed project will occur within habitat that is used by sea turtles for nesting and, while not currently proposed, under emergency circumstances, it may be constructed during a portion of the sea turtle nesting season. Long-term and permanent impacts could include a change in the nest incubation environment from the sand placement activities. Short-term and temporary impacts to sea turtle nesting activities could result from project work occurring on the nesting beach during the nesting or hatching period, changes in the physical characteristics of the beach from the placement of the sand, and changes in the nest incubation environment from the material. Proximity of action: Sand placement activities would occur within and adjacent to nesting habitat for sea turtles and dune habitats that ensure the stability and integrity of the nesting beach. Hydraulic dredging would be pumping sand and water directly from the dredge site and could suck up small turtles into the dredge pipe. Distribution: Sand placement activities that may impact nesting and hatchling sea turtles and sea turtle nests would occur approximately 1500 feet north and 2800 feet south of Clam Pass along the Gulf of Mexico coast. Timing: The timing of the sand placement activities could directly and indirectly impact nesting females,their nests, and hatchling sea turtles if conducted between March 1 and November 30. Nature of the effect: The effects of the sand placement activities may change the nesting behavior of adult female sea turtles, diminish nesting success, and cause reduced hatching or emerging success. Sand placement can also change the incubation conditions within the nest. Any decrease in productivity and/or survival rates would contribute to the vulnerability of the sea turtles nesting in the area. Duration: The sand placement activity is anticipated to be conducted on a three to five year schedule and each sand placement project could take between three and four months to complete. Thus, the direct effects would be expected to be short-term in duration. Indirect effects from the activity may continue to impact nesting and hatchling sea turtles and sea turtle nests in subsequent nesting seasons. Disturbance frequency: Sea turtle populations in the area may experience decreased nesting success, hatching success, and hatchling emerging success that could result from the sand placement activities. Disturbance intensity and severity: Depending on the need and the timing of the sand placement 50 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 activities during sea turtle nesting season, effects to the sea turtle populations locally could be important. Beneficial Effects The placement of sand on a beach with reduced dry foredune habitat may increase sea turtle nesting habitat if the placed sand is highly compatible (i.e., grain size, shape, color, etc.) with naturally occurring beach sediments in the area, and compaction and escarpment remediation measures are incorporated into the project. In addition, a beach that is designed and constructed to mimic a natural beach system may benefit sea turtles more than an eroding beach it enhances. Adverse Effects It has been documented that placement of sand on beaches can have adverse effects on nesting female sea turtles and hatchlings and sea turtle nests. Results of monitoring sea turtle nesting and beach nourishment activities provide additional information minimization measures, and other factors that influence nesting, hatching, and emerging success. Measures will be incorporated pre-,during, and post-construction to reduce impacts to sea turtles. Direct Effects Direct effects are those direct or immediate effects of a project on the species or its habitat. Placement of sand on a beach in and of itself may not provide suitable nesting habitat for sea turtles. Although sand placement activities may increase the potential nesting area, significant negative impacts to sea turtles may result if protective measures are not incorporated during project construction. Sand placement activities during the nesting season, particularly on or near high density nesting beaches, can cause increased loss of eggs and hatchlings and, along with other mortality sources, may significantly impact the long-term survival of the species. For instance,projects conducted during the nesting and hatching season could result in the loss of sea turtles through disruption of adult nesting activity and by burial or crushing of nests or hatchlings. While a nest monitoring and egg relocation program would reduce these impacts, nests may be inadvertently missed (when crawls are obscured by rainfall, wind, or tides) or misidentified as false crawls during daily patrols. In addition, nests may be destroyed by operations at night prior to beach patrols being performed. Even under the best of conditions, about seven percent of the nests can be misidentified as false crawls by experienced sea turtle nest surveyors (Schroeder 1994). Equipment: The use of heavy machinery on beaches during a construction project may also have adverse effects on sea turtles. Equipment left on the nesting beach overnight can create barriers to nesting females emerging from the surf and crawling up the beach, causing a higher incidence of false crawls and unnecessary energy expenditure. The operation of motor vehicles or equipment on the beach to complete the project work at night affects sea turtle nesting by: interrupting or colliding with a female turtle on the beach; headlights disorienting or misorienting emergent hatchlings; vehicles running over hatchlings attempting to reach the ocean, and vehicle tracks traversing the beach interfering with hatchlings crawling to the ocean. Driving directly above or over incubating egg clutches or on the beach can cause sand compaction which may result in adverse impacts on nest site selection, digging behavior, clutch viability, and emergence by hatchlings, decreasing nest success and directly 51 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 killing preemergent hatchlings (Mann 1977,Nelson and Dickerson 1987,Nelson 1988). Depending on when the dredging project is completed dune vegetation may have become established in the vicinity of dredge spoil placement sites. The physical changes and loss of plant cover caused by vehicles on vegetated areas or dunes can lead to various degrees of instability and cause dune migration. As vehicles move over the sand, sand is displaced downward, lowering the substrate. Since the vehicles also inhibit plant growth, and open the area to wind erosion, the beach and dunes may become unstable. Vehicular traffic on the beach or through dune breaches or low dunes may cause acceleration of overwash and erosion. Driving along the beachfront should be between the low and high tide water lines. The areas for the truck transport and other equipment to work in should be designated and marked. Artificial lighting: When artificial lighting is present on or near the beach, it can misdirect hatchlings once they emerge from their nests and prevent them from reaching the ocean (FWC 2007). In addition, a significant reduction in sea turtle nesting activity has been documented on beaches illuminated with artificial lights (Witherington 1992). Therefore, construction lights along a project beach and on the dredging vessel may deter females from coming ashore to nest, misdirect females trying to return to the surf after a nesting event, and misdirect emergent hatchlings from adjacent non-project beaches. Installing appropriate beachfront lighting (when required) is the most effective method to decrease the number of disorientations on any developed beach. Collier County has adopted lighting ordinances to address artificial lighting along the beachfront. Indirect Effects Indirect effects are those effects that are caused by or result from the proposed action, are later in time, and are reasonably certain to occur. Effects from the proposed project may continue to affect sea turtle nesting on the project beach and adjacent beaches in future years. Increased susceptibility to catastrophic events: Nest locations within a given nesting season may concentrate eggs in an area making them more susceptible to catastrophic events. Hatchlings may also be subject to greater predation rates from both land and marine predators, because the predators learn where to concentrate their efforts. Increased beachfront development: It has been stated that beach enhancement frequently leads to more development in greater density within shorefront communities that are then left with a future of further replenishment or more drastic stabilization measures. The presence of the NRPA designation and built-out communities surrounding the NRPA would indicate that additional shoreline development will not occur as a result of this proposed project. Changes in the physical environment: Placement of sand on a beach may result in changes in sand density (compaction), beach shear resistance (hardness), beach moisture content, beach slope, sand color, sand grain size, sand grain shape, and sand grain mineral content if the placed sand is dissimilar from the original beach sand. These changes could result in adverse impacts on 52 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 nest site selection, digging behavior, clutch viability, and hatchling emergence (Nelson and Dickerson 1987,Nelson 1988). Beach compaction and unnatural beach profiles resulting from beach nourishment activities could negatively impact sea turtles regardless of the timing of projects. Very fine sand or the use of heavy machinery can cause sand compaction on nourished beaches. Sand compaction may increase the length of time required for female sea turtles to excavate nests and cause increased physiological stress to the animals These impacts can be minimized by using suitable sand and by tilling (minimum depth of 36 inches) compacted sand after project completion. The level of compaction of a beach can be assessed by measuring sand compaction using a cone penetrometer(Nelson 1987). A change in sediment color on a beach could change the natural incubation temperatures of nests in an area, which, in turn, could alter natural sex ratios. To provide the most suitable sediment for nesting sea turtles, the color of the nourished sediments should resemble the natural beach sand in the area. Natural reworking of sediments and bleaching from exposure to the sun would help to lighten dark nourishment sediments; however, the timeframe for sediment mixing and bleaching to occur could be critical to a successful sea turtle nesting season. Escarpment formation: On nourished beaches, steep escarpments may develop along their water line interface as they adjust from an unnatural construction profile to a more natural beach profile (Coastal Engineering Research Center 1984, Nelson et al. 1987). These escarpments can hamper or prevent access to nesting sites. Researchers have shown that female sea turtles coming ashore to nest can be discouraged by the formation of an escarpment, leading to situations where they choose marginal or unsuitable nesting areas to deposit eggs (e.g., in front of the escarpments, which often results in failure of nests due to prolonged tidal inundation). This impact can be minimized by leveling any escarpments prior to the nesting season. Cumulative Effects Cumulative effects include the effects of future State, local, or private actions that are reasonably certain to occur in the action area. Future federal actions that are unrelated to the proposed action are not considered in this section because they require separate consultation pursuant to Section 7 of the Act. The Project is occurring in a protected area surrounded by highly developed areas, so minimal additional cumulative impacts are anticipated. On the other hand, the Project will have a net positive effect on the hydrology and habitat values of the Project site and surrounding area. Gopher Tortoise Effects of the Project on the gopher tortoise may occur both as direct and indirect effects. Direct Effects Project construction is may result in the direct "take" of a gopher tortoise if proper protections are not observed. The probability of direct incidental take is dependent upon the number of 53 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 tortoises in the Project area and available, suitable habitat. Gopher tortoise burrows have been found on site and actual tortoises have been observed. None of the proposed dredging or spoil placement activities will impact the gopher tortoise habitat but there is some risk that equipment could run over a tortoise or tortoise burrow. Prior to any work being done, any burrows within 50 feet of the proposed work area and travel corridors will be field located, appropriately marked, and a minimum 25 foot buffer established and protected. Indirect Effects Given the current conditions of the Project site and surrounding area as described above, the indirect effects of the Project on the gopher tortoise are anticipated to be minimal. Construction of the Project may encourage additional recreational utilization which could increase the possibility of human and snake interactions. Marking of the burrows and buffer establishment will highlight where burrows are located. Preservation of existing habitat and education of visitors on the importance of tortoises will minimize the potential for these adverse interactions. Cumulative Effects As stated above,the Project is occurring in an already highly used coastal beach area which is all preserved within the NRPA boundary. The State of Florida requires permitting for any activities that have the potential to impact tortoises or their burrows thereby minimizing the potential for any additional cumulative impacts. Piping Plover Beach topography and morphology: The geomorphic characteristics of barrier islands, peninsulas,beaches, dunes, overwash fans, and inlets are critical to a variety of natural resources, and the geomorphic characteristics influence a beach's ability to respond to wave action, including storm overwash and sediment transport. However, the protection or persistence of these important natural land forms, processes, and wildlife resources is often in conflict with shoreline projects. The manufactured berms and sand fill may impede overwash, thereby causing successional advances in the habitat that will reduce sand flat formation, and its subsequent use by piping plovers in the project area. Distribution: The project proposes dredging and sand placement activities within Clam Pass and along 0.80 mile of shoreline, respectively, with the former to provide ecological improvement to the estuary. The proposed construction activities could directly and indirectly affect the distribution of migrating and wintering piping plovers to roosting and foraging habitat within the action area. Disturbance frequency and intensity: The proposed project has the potential to temporarily adversely affect piping plovers within the proposed action area during dredging and sand placement activities. Piping plovers located within the action area would be expected to move outside of the construction zone due to disturbance. Duration: The timeframe associated with completion of the proposed dredging and excavation event is expected to be approximately 3 to 4 months, although this timeframe may vary depending on the amount of work necessary, weather conditions, and equipment mobilization and maintenance. 54 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Nature of the effect: The project has the potential to result in direct, indirect, and long term effects to piping plovers. Activities that affect or alter the use of optimal habitat or increase disturbance to the species, may decrease the survival and recovery potential of the piping plover. Timing: The timing of the proposed dredging and sand placement project may occur partially during the migration and wintering period for piping plovers (July 15 to May 15). Analyses for effects of the action: The proposed project includes dredging approximately 1,700 linear feet of Clam Pass for ecological improvement of the estuary, and placing the beach compatible material along 0.80 mile of shoreline north and south of the Pass. If the dredged material is placed on the beach, it has the potential to elevate the beach berm and widen the beach, providing storm protection and increasing recreational space. Sand placement may occur in and adjacent to habitat that are suitable for roosting and foraging piping. Project construction may overlap with portions of piping plover winter and migration seasons. Short-term and temporary construction effects to piping plovers will occur if the birds are roosting and feeding in the area during a migration stopover. The deposition of sand may temporarily deplete the intertidal food base along the shoreline and temporarily disturb roosting birds during project construction. Tilling to loosen compaction of the sand (required to minimize sea turtle effects) may affect wrack that has accumulated on the beach. This affects feeding and roosting habitat for piping plovers since they often use wrack for cover and foraging. Direct Effects The construction window (i.e., sand placement, dredging) may extend through a portion of one piping plover migration and winter season. If the dredged material is placed on the beach, heavy machinery and equipment (e.g., trucks and bulldozers), location of the dredge pipeline, and sand placement, may adversely affect migrating and wintering piping plovers in the action area by disturbing and disrupting normal activities such as roosting and feeding, and possibly forcing birds to expend valuable energy reserves to seek available habitat in adjacent areas along the shoreline. Impacts could affect the entire fill template(0.80 mile)in the project area. Indirect Effects The proposed project includes placing beach-compatible material dredged from Clam Pass and associated channel along 0.80 mile of shoreline. Indirect effects of reducing the potential for the formation of optimal habitats, especially along the shoreline, may pose a concern to piping plover survival and recovery within the action area. Eventually the shoreline within the fill template will reestablish and provide some feeding habitat for piping plovers. The project may also increase the recreational pressures within the project area. Recreational activities that have the potential to adversely affect piping plovers include disturbance by increased pedestrian use, though dogs are not permitted within the action area for this project. Long-term effects could include a decrease in piping plover use of habitat due to increased disturbance levels. 55 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Dredging Clam Pass and the associated channel may also allow for an increase in boat traffic. Boating related activities, and the associated pedestrian presence, may adversely affect the foraging and roosting behavior of piping plovers. Cumulative Effects Cumulative effects include the effects of future State, Tribal, local, or private actions that are reasonably certain to occur in the action area considered in this Biological Assessment. Future Federal actions that are unrelated to the proposed action are not considered in this section because they require separate consultation pursuant to section 7 of the ESA. No other additional activities in the project action area that could affect federally listed species other than those outlined in this Biological Assessment are contemplated. Any other activities in the Action Area would require a Corps permit. Therefore, no cumulative effects are expected. Beneficial effects Closure of the Pass has the potential to adversely affect flood shoal and tidal flat areas within the Clam Pass channel. The lack of tidal prism results in tidal flat areas remaining inundated, and unavailable to foraging piping plovers. Maintenance of the tidal exchange will insure that these flat and shoal areas undergo exposure at lowering tides and remain available to foraging and loafing piping plovers. Wood Stork There is likely to be no negative effects from the Project on the wood stork. Direct Effects The construction of the Project is not likely to result in the direct"take" of a wood stork. During species surveys, storks were observed on multiple occasions foraging in the spreader swale along the extreme eastern boundary of the NRPA. Only two storks have been observed on the beach side of the project and those observations coincided with the closure of the Pass. No nesting or other use of the site has been observed though, due to the types of habitat within the project area, it is possible that it could provide suitable habitat for stork nesting. Still, without any evidence of nesting or foraging within the proposed work areas, it is not likely that the Project will have any significant negative direct effect on wood storks. Indirect Effects No wood stork habitat will be directly lost by construction of the Project. Maintenance of the Pass and protection of the tidal exchange will continue to provide the quantity, distribution, and timing of water in the area and thereby maintaining any wood stork foraging opportunities that are currently present. Cumulative Effects The absence of direct or indirect effects, in conjunction with the permitting that would be required for any other activities that could impact wood stork foraging or nesting habitat lead to a conclusion that no cumulative effects will occur to wood storks or stork habitat. 56 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Florida Bonneted Bat The dredging and spoil disposal are not likely to have any direct, indirect or cumulative effects on the Florida bonneted bat since no tree or cavity removal are proposed as part of any of the proposed activities. Florida Panther The dredging and spoil disposal are not likely to have any direct, indirect or cumulative effects on the Florida panther. Given the unlikelihood of any panther entering the Project area or utilizing the project area for any portion of its life cycle, the proposed project will have no effect on panthers. Florida Manatee Effects of the Project on the manatee may occur both as direct and indirect effects. Direct Effects The dredging of the Pass will occur within an area known to be utilized by manatees. The possibility exists that manatees could be struck or trapped by the dredging equipment during construction activities. To reduce the possibility of direct construction related effects to the manatee, the applicant will incorporate the Standard Manatee Conditions for In-water Work (FWC 2010) as a condition for carrying out the proposed work. The proposed dredging could also directly impact seagrasses that may establish within proposed dredging templates. All opportunities will be explored to avoid or provide buffers to any seagrasses to reduce the possibility of seagrass loss associated with the dredging activities. Indirect Effects The proposed project may increase the recreational pressures within the project area. Recreational activities that have the potential to adversely affect manatees include disturbance by increased pedestrian use. Dredging Clam Pass and the associated channel may also allow for an increase in boat traffic. Boating related activities may adversely affect the manatee through increased disturbance or increased potential of vessel strikes. Long-term effects could include a decrease in manatee use of habitat due to increased disturbance levels. Cumulative Effects Cumulative effects include the effects of future State, Tribal, local, or private actions that are reasonably certain to occur in the action area considered in this Biological Assessment. Future Federal actions that are unrelated to the proposed action are not considered in this section because they require separate consultation pursuant to section 7 of the ESA. No other additional activities in the project action area that could affect federally listed species other than those outlined in this Biological Assessment are contemplated. Any other activities in the Action Area would require a Corps permit. Therefore, no cumulative effects are expected. 57 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 Beneficial effects Closure of the Pass has the potential to trap manatees within the Clam Pass channel and associated bays. The lack of tidal prism results in decreased water quality and likely eventual loss of seagrass habitat. Maintenance of the Pass to keep it open and maintain tidal exchange will insure that manatees have continued use of the Clam Bay NRPA system. Smalltooth Sawfish Effects of the Project on the sawfish may occur both as direct and indirect effects. The project is expected to have an overall beneficial effect. Direct Effects The dredging of the Pass will occur within an area known to be utilized by sawfish. The possibility exists that sawfish could be struck, injured, or trapped by the dredging equipment during construction activities. All construction activities will adhere to the Sea Turtle and Smalltooth Sawfish Construction Conditions (NOAA 2006) in an effort to reduce the possibility of any adverse effects to sawfish. The proposed dredging will also directly impact shallow tidal flat area within proposed dredging templates. All opportunities will be explored to avoid or provide buffers to any seagrasses to reduce the possibility of seagrass loss associated with the dredging activities. Sawfish utilization of the dredged areas will resume once the dredge activities are completed. Indirect Effects The proposed project may increase the recreational pressures within the project area. Recreational activities that have the potential to adversely affect sawfish include disturbance by increased pedestrian use, swimming, and fishing. Long-term effects could include a decrease in sawfish use of habitat due to increased disturbance levels. Cumulative Effects Cumulative effects include the effects of future State, Tribal, local, or private actions that are reasonably certain to occur in the action area considered in this Biological Assessment. Future Federal actions that are unrelated to the proposed action are not considered in this section because they require separate consultation pursuant to section 7 of the ESA. No other additional activities in the project action area that could affect federally listed species other than those outlined in this Biological Assessment are contemplated. Any other activities in the Action Area would require a Corps permit. Therefore,no cumulative effects are expected. Beneficial effects Closure of the Pass has the potential to trap sawfish within the Clam Pass channel and associated bays. The lack of tidal prism results in decreased water quality and likely eventual loss of seagrass habitat. Maintenance of the Pass to keep it open and maintain tidal exchange will insure that sawfish have continued use of the Clam Bay NRPA system. 58 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 VI. LEGAL ANALYSIS Legal Showing Required to Establish a Taking Endangered Species Act ("ESA") Section 9 prohibits the "taking" of any federally listed species of fish or wildlife. 16 U.S.C. § 1538(1). "Take" under ESA Section 9 and Section 7 should be interpreted in the same way. See Arizona Cattle Growers' Association v. United States Fish and Wildlife Service, 99-16102 (9th Cir. December 17, 2001). To demonstrate a taking under the ESA, there must be a showing of"harm" supported by actual evidence. House v. United States Forest Service, U.S. Department of Agriculture, 974 F.Supp. 1022 (E.D.Ky. 1997)(citing American Bald Eagle v. Bhatti, 9 F.3d 163, 165 (1st Cir. 1993)("the proper standard for establishing a taking under the ESA ... has been unequivocally defined as a showing of'actual harm."')). The term "take" means to "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct." 16 U.S.C. § 1532(19). As used in the definition of take,the term "harm" means an act which actually kills or injures wildlife. Such act may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering. 50 C.F.R. § 17.3 (emphasis supplied). Actual death or injury of a protected animal is necessary for a violation of Section 9. Id.; Babbitt v. Sweet Home Chapter of Communities for a Greater Oregon, 515 U.S. 687, 691 n.2 (1995)(Also, Justice O'Connor's concurrence was based on the understanding that the definition of harm was "limited to significant habitat modification that causes actual, as opposed to hypothetical or speculative, death or injury to identifiable protected animals."). American Bald Eagle v. Bhatti, 9 F.3d 163 (1st Cir. 1993), provides that "the proper standard for establishing a taking under the ESA, far from being a numerical probability of harm, has been unequivocally defined as a showing of'actual harm.' Id. Unfounded speculation is insufficient to prove a take under the ESA. See Hawksbill Sea Turtle v. Federal Emergency Management Agency, 11 F.Supp.2d 529 (D.V.I. 1998). The decision in United States v. West Coast Forest Resources, Civ. No. 96-1575-HO (D. Or. Mar. 13, 2000) also is instructive. West Coast concerned whether the clear-cut harvest of 94 acres of private forest land should be enjoined under ESA § 9 to prevent the take of a pair of spotted owls. The expert for the United States in West Coast testified that harvesting the forest would harm the owls by reducing the prey supply and causing an inability to roost in the area. Id. at 2. The expert acknowledged that if there was still enough habitat and prey after harvesting, there would be no significant effect on the owls. Id. The court found that the plaintiff did not satisfy its burden of establishing to a reasonable certainty that the proposed harvest would result in significant habitat modification that would actually kill or injure the owls. Id. at 12. The court stated: "'Mere speculation' is not sufficient; there must be a definite threat of future harm to [a] protected species." Id. at 12-13. The court found that, although the owls used and possibly even 59 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 selected the forest for foraging, there was 60-70% suitable habitat located within the owls' home range and the interference of the harvest (removing 5% of the total suitable habitat) was not enough to violate ESA § 9. Id. at 13. Application of the Law to the Project and Species Of the species addressed in this document, several have been observed on the Project site though there is no data to support that any of these species have spent significant time on the portions of the site that are to be impacted, or that they depend on these portions of the site for any essential life function. In fact, the available data indicates otherwise. Moreover, there is no data that indicates any likelihood that any of the species will be actually killed or injured by Project construction activities. Considering that the available data indicates that no direct take will result from construction of the Project, the following discussion primarily addresses the possibility of incidental take through significant habitat modification or degradation for those species most likely to occur within the proposed impact areas. Eastern Indigo Snake None of the potential indigo snake habitat on the Project site will be impacted. Although gopher tortoise burrows exist within the NRPA along the beach, no sightings of indigos have occurred within or adjacent to the project area; thus, there is no indication that indigos are present on or use the site at all. Absent designation of critical habitat for a species, "there is no evidence that Congress intended to allow the [Service] to regulate any parcel of land that is merely capable of supporting a protected species." Arizona Cattle Growers' Association v. United States Fish and Wildlife Service, 99-16102 (9th Cir. December 17,2001). Sea Turtles A recurring theme in the "harm" analysis for species on the Project site is the ecological maintenance and enhancement associated with the project and the intent to maintain tidal flow to the estuary system. Specifically concerning sea turtles, no work is currently contemplated along the beach or Pass during sea turtle nesting season. The placement of compatible material on the adjacent beaches during maintenance dredging events is a by-product, not the purpose of, the activity. Sea turtle nesting should not be adversely effected by the Project and it cannot be shown that any sea turtles will be actually killed or injured by any habitat maintenance or modification that may be associated with the Project. Gopher Tortoise None of the gopher tortoise habitat on the Project site will be impacted. Although gopher tortoise burrows exist within the NRPA along the beach, they will be specifically located and protected during all shoreline activities. Wood Stork In light of the analysis in the Effects of the Action section above, it is clear that wood stork 60 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 foraging habitat could be enhanced and increased through the implementation of the project components. The hand dug channels form concentration areas or forage fish at low tide. The post-project hydrology within the NRPA will restore a more significant tidal range. The increased range will inundate larger areas and allow for daily concentrations of forage material as the tide recedes which in turn will provide additional foraging opportunities for area storks. The Project will not harm the wood stork. Piping Plover It appears clear from the above discussions that the Project will not result in actual death or injury to piping plovers. Based on past and ongoing survey efforts, the site has not been a common or regular destination for wintering plovers. The 0.80 mile of shoreline represents approximately 0.03 percent of the 2,340 miles of sandy beach shoreline miles available (although not necessarily suitable)throughout the piping plover wintering range within the conterminous U.S. The USFWS in its previous BO for this project estimated 29 percent (668 miles) had permits for sand placement events. It was the USFWS's opinion that implementation of the project was not likely to jeopardize the continued existence of the piping plover, and no critical habitat would be affected. The application of the Terms and conditions associated with their BO as well as the criteria outlined in the Clam Bay NRPA Management plan should insure that implementation of the project was not likely to jeopardize the continued existence of the piping plover. Florida Manatee The implementation of the Standard Manatee Conditions for In-water Work (FWC 2010) as a condition for carrying out the proposed work in conjunction with educational outreach will insure no take of manatees occurs. Similar operations within the Action Area have been undertaken with no evidence of any deleterious effect on manatees. Smalltooth Sawfish The implementation of the Sea Turtle and Smalltooth Sawfish Construction Conditions (NOAA 2006) as a condition for carrying out the proposed work in conjunction with educational outreach will insure no take of sawfish occurs. In sum, the best scientific and commercial data available provides no evidence that the Project will actually kill or injure a protected species. Any conclusion that the Project would result in a taking of a protected species would be arbitrary and capricious. See Arizona Cattle Growers' Association, supra. 61 Biological Assessment Clam Pass Dredging and Ecosystem Enhancements December 2014 VII. 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Y , 0400 MEIN Z W Y I, N 1a- O _Z Y fY OC O p M O 8NV<V7 = SW JNOW C5 <w>ao &zoo )n rGeneral locations of the designated critical habitat for the American crocodile. 0 E Hm Homestead k ♦ice 1 r s t 4 ' Tuckey Point ilL s �.�x Largo R' } ., 1, a General Area Distance: Miles Legend 0 5 10 15 60hs '^ ,�,i`Z, i p Cityrrown 5t 111,..,,,i� . N Major Road/Highway 1 yj ' Critical Habitat 01 A is V/ Use Constraints: This map is Intended to be used as a guide to Identify the general areas where critical habitat has been designated. Refer to the narrative description published in the Code of Federal Regulations(CFR)50 Parts 1 to 199(a copy of this text is printed on the reverse of this map). F General locations of the designated critical habitat for the Wintering Piping Plover. , _ , _ . gCharloiie County,FL i° Charlotte Boca Harbor ,, Lee County,Fl. rj' Murdock Grande 6' r Point _ _ %±r f� j •FL-22 x • r Captiva Pass Foster : I �� p/Bay 1' % iT ``S�-' i • Coup FL FL-23 Pine ,, - , . - i - Island � '-',,., ' �• a Sound 1 ,Z,� Iv '. a., In `- ''. .. Punta Rassa e St.James •= 4 s a San Carlos Bay Fort M era, Beach 1 - \ 7 : ,=+ .*Estero Sanibel FL-25 ,_ :ii:0311Y Gulf of Mexico Sanibel Island Sanibel Estero Pas i Causeway Estero Island .1.7, ',1, FL-26 .),- ',r,;9 General Area Distance: Miles Legend NIS .N1, f:,, o s 10 g — --- Q City/Town VI,s 4e,',';,ti „ �„ N 111 Major Road/Highway D i Land --- Critical Habitat Use Constraints: This map is intended to be used as a guide to identify the general areas where Wintering Piping Plover critical habitat has been designated. Included within the designation of critical habitat are all land areas to the mean lower low water. Refer to the narrative unit descriptions as the precise legal definition of critical habitat Florida Units: 22, 23, 25 and 26 Some locations have been slightly enlarged for display purposes only. General locations of the designated critical habitat for the Wintering Piping Plover. 'Naples - _..,. Collier County,FL Big Marco Pass Collier Bay Tigerish Beach , FL-2 t.4- d r Gulf of Mexico Gallivan Bay t '' General Area Distance: Miles Legend MS .‘1, (A A 4 8 g -----__.__- o City/Town I r,.• M Y N 4\# Major Road/Highway Land Critical Habitat Use Constraints: This snap is intended to be used as a guide to identify the general areas where Wintering Piping Plover critical habitat has been designated. Included within the designation of critical habitat are all land areas to the mean lower low water. Refer to the narrative unit descriptions as the precise legal definition of critical habitat. Florida Unit: 27 Some locations have been slightly enlarged for display purposes only. I Smalltooth Sawfish Critical Habitat 82°W -- 80•W 1 ■ 28°N- \''' i -28•N ci:\ P I., i.._ � 1 Florida ti 1 , �-./ It ii Fort Myers mfr. -t 26°N- -26°N `'`.# 04 Miami 400,0 vi 4.4 /00.17444, ''44,V , 41100:000$0;01.0„,„0,v N s' .t:-t r "`4� Nautical Miles e j: 0 10 20 40 j '�` r Cy f NMFS,Office of Protected Resources "`��� October 2009 82 W 80°W ! . CLAM PASS 18-MONTHS POST 2013 DREDGING MONITORING REPORT f,� Y d y t} ✓ _ s-October 2014 4 Prepared for Pelican Bay Services Division Prepared by Humiston&Moore Engineers December 2014 1 CLAM PASS 18-MONTHS POST 2013 DREDGING MONITORING REPORT CONTENTS Background 3 Monitoring Data 3 Aerial Photos: 3 Hydrographic and Beach Survey. 3 Summary and Recommendations: 4 Appendix A. Aerial Photos 11 Appendix B. Survey Profiles and Comparison To Previous Surveys 23 2 BACKGROUND This report provides the 18-months post dredging monitoring results for Clam Pass. This update is the fourth monitoring report following the 2013 maintenance dredging of Clam Pass following the pass closure at the end of 2012.The inlet reopening was completed in April 2013 and tidal exchange between the bay and the Gulf of Mexico was restored to near design levels.The complete closure of the inlet in late 2012 resulted in the collapse of its ebb shoal onto the beach with a relatively large volume of sand being pushed onshore by waves. The collapse of the ebb shoal and presence of large volumes of sand at the adjacent shoreline provided additional challenges to the hydraulic stability of Clam Pass. A stable inlet system requires the ebb shoal features which support the inlet channel from rapid shoaling at the inlet mouth. The Clam Pass reopening design was limited to the previously authorized maintenance dredging template authorized by the Nationwide permit from the Corps of Engineers.The design was based on minimal dredging to connect the Gulf waters with bay system to protect the valuable environmental resources in the bay by restoring flushing and to allow natural evolution of the inlet morphological features. Given the critical nature of Clam Pass as a small tidal inlet and its vulnerability to rapid shoaling during storms, an interim monitoring plan was prepared. The plan included monthly aerial photography, 3 month, 6 month, and 12 month hydrographic survey of inlet bathymetry to observe the natural evolution of the inlet features and be prepared for any necessary maintenance to avoid detrimental shoaling of the inlet. Subsequent to the monitoring plan,a condition survey was completed in October 2014 to assess the condition of the inlet. MONITORING DATA This report documents the physical conditions of the inlet based on the monitoring data collected since dredging. This consists of surveys immediately post construction,3,6,12 and 18 months post construction. AERIAL PHOTOS: Perspective aerial views are taken on monthly basis and provided to document the channel alignment and the overall condition of the inlet.A series of ortho-rectified aerial images are also provided in this report to document changes from pre-dredging to current conditions.All aerial photos are included in Appendix A. HYDROGRAPHIC AND BEACH SURVEY: A hydrographic and beach survey for the 18 month post dredging monitoring was completed on October 14th,2014. The survey included the same monitoring scope used for the previous survey completed in March, 2014.The scope of the survey and comparative profile plots with previous survey data are included in Appendix B. Contour maps of Clam Pass and adjacent beach areas were prepared based on the collected data and compared to previous data sets. Figure 1 shows the inlet morphology for pre dredging conditions of January 2013 and post dredging conditions of April 2013. The figure also shows the elevation change due to the dredging and initial adjustments immediately post construction. Figure 2 shows the inlet morphology for post dredging conditions of April 2013 and monitoring data of August 2013. Figure 3 shows the inlet morphology for post dredging conditions of August 2013 and monitoring data of November 2013. Figure 4 shows the inlet morphology for post dredging conditions of November 2013 and monitoring data of March 2014. Figure 5 shows the inlet morphology for post dredging conditions of March 2014 and monitoring data of October 2014. Figures 2, 3, 4, and 5 also show the morphology change due to the natural adjustments and response to tidal flow and wave events over the 4, 7, 12, and 18 month periods post construction. The net change over the first 18 months is presented in Figure 6, which presents the inlet morphology at April 2013 and March 2014. The data shows the inlet and beach response and the inlet morphology adjustment to the re-established interaction between tidal flow and prevailing wave conditions over the 4, 7, 12, and 18 month periods post dredging. During the first seven months post construction the prevailing wind and wave conditions were primarily from SW and WSW direction.This resulted in sand moving toward the inlet from the south creating beach build up 3 on the south side while the north beach shoreline retreated landward. The monitoring data also indicate the formation of the nearshore features for the inlet ebb shoal and some shoaling within the flood shoal area. However,the shoaling rates inside the pass represent natural adjustment post dredging as the cross section areas of the flow remained within the design range. In the latter 7 to 12 months post construction the ebb shoal continued to expand and the south beach continued to recede as in the 3 to 6 month period. However, the north beach shoreline gained material as the Section A channel migrated to the north and eroded the fill area on the north side of the inlet.This and the continued south beach erosion likely contributed to continued shoaling within the inlet,particularly in Sections B and C. The 12 to 18 month period saw continued shoaling within the inlet and continued migration of the channel mouth toward the north. Scour was noted along the thalweg in the outer portion of Section B due to the significantly constricted cross section available to flow in this area. SUMMARY AND RECOMMENDATIONS: The monitoring data collected in October 2014 indicate that the Clam Pass system remains critically stable after 18 months of post construction adjustment. The inlet channel has migrated to the north of the dredge template but maintains adequate cross section area of flow. However, Sections B and C have shoaled to near pre-dredging conditions. The bathymetric survey and aerial photos indicate that the tidal flow was adequate to maintain the inlet open, however the inlet has shoaled to the point that the flow may be inadequate to withstand a significant wave event. The channel entrance is dynamic in nature and shifts within the ebb shoal delta in response to seasonal wave,climate,and tidal conditions.The flood shoal area is likely at or near capacity and has the potential to negatively impact the inlet channel if a greater cross section of flow is not restored. Clam Pass remains a wave dominated,small tidal inlet which can be subject to rapid shoaling following sustained wind and wave events or sequence of events. The inlet becomes more vulnerable when the sustained winds and waves move higher levels of sand toward the inlet entrance during neap tide conditions where tidal flow is at a minimum. The large volume of sand that has accumulated in the nearshore when the inlet closed last year continues to increase the level of vulnerability to shoaling following sustained storms. It is recommended to allocate resources for maintenance dredging within the design template to restore the flow efficiency to stable conditions. Future monitoring should follow recommendations from the 2014 Clam Bay NRPA Management Plan. It is recommend to continue the interim monitoring program as proposed and develop dredging contingencies in order to be able to respond to any future large shoaling events that may be detrimental to inlet stability. 4 t 0. Iy -0so ...led ,:' vt i. } ae c o es W g E w ..a •e ia s • Clam Pass morphology Pre dredging Conditions(January 2013) • f s y.x �- ' oe g� ; t' _ -0.i -0eo 11.1' s as o ex u 56 w 6J lx i° ]e Clam Pass morphology Post dredging Conditions(April 2013) ' , i) A _, , , a � xe 0,,,-„- ¢ ] Rz , 4 !7ta \ 0.6 p 02 -0R ■ `o I.. . xR W fig . l Pr ]. Clam Pass morphology change(January-April 2013) Figure 1. Clam Pass morphology and change(January 2013 April 2013). 5 Y p AAL Gaff of f� ��I ,` ' 0 ,441\ 13 as . o0 'a 's as o —— z qac a da $ s. /f az'd . A azg ae w ae -, / 78 Clam Pass morphology Post dredging Conditions(April 2013) t ` ,: 11 (tVçlt \v z 1.6 I f3 3�n t �Oa %.Ias a as ae 1 78] � I .. a16 Clam Pass morphology Post dredging Conditions (Aug 2013) -(-5,000)CYO / :7 • ^1,000 CY 4 1` i *y..i,ipp Cy e ) —(''1,000)CY `,, a.e 9 . —9.000 CY_ ��? IJi"4� t ._ "3 $ =zs .1a. . a ,i;z bilook 1 '* —(_300)C ps LL d8 A —5,000 CY —(-1 400) 14- -(.460)CY 22 i 3 0 3 F + Clam Pass morphology change(April 2013-August 2013) Figure2. Clam Pass morphology and change(April 2013-August 2013). 6 4. m ' € H'a � 12 NI ii 1.r. C oe as S. ''a•1 .r ` a x z z 4P— aea ax_ as N + o t` +tea u i axg 36 W 6 ♦A as •i, e xx as Clam Pass morphology 4 months Post dredging Conditions (Aug 2013) .4 / x ,''x fB 1 � 11 m' C O � n iz x z as -- .321—1. ax •JW .3 2 JB Y ax V 66 w 4 .1.x a Clam Pass morphology 7 months Post dredging Conditions (Nov 2013) +2,300 cy a' y ate' g cy ,�' 000 h `� •- 700 cy l k .e { ,t ;4 l C, - to 0 800 cy 300 cy . Q_� 4,000 cy i f i e 8 i IE f Clam Pass morphology change(August 2013-Nov 2013) Figure 3. Clam Pass morphology and change(Aug 2013-Nov 2013). 7 f .P A, (� Oa -1'1 ae ax N as o .e 5 ue + 46 6 w 6 49 y - u a a . Clam Pass morphology 7 months Post dredging Conditions (Nov 2013) ,- F . 7 V ''''-'*';'' .' v 1.: A / El ii Clam Pass morphology 12 months Post dredging Conditions (Mar 2014) a r, i.Ai 1,100 cv . ✓ °t l a -4,100 cv �i 1 . _�� ) r 900 cv .. -u 2,250 cv -;' 411(...c ; ' '' `s' =a S 4a`u 4,740 cV :. a:z i 1 -6,700 CV,. i . 4 4. . Clam Pass morphology change(Nov 2013-Mar 2014) Figure 4. Clam Pass morphology and change(Nov 2013-Mar 2014). 8 I r _ . , _ . ,,... , ,, ( A. 2 R g 2 ee ',. , oe o Vii-[„•. i 1jjjj��+�,.... 12 9 ���� oe_.Ig< I 2 ilk /�� -24 v 2g ]2 LL V 28 +`it J }2 2 10 14,:w 3 be 72 og .;.: ,_ e 1 '; Clam Pass morphology 12 months Post dredging Conditions (March 2014) *"--7.'-',.:-- , ' (1,",4k, v 1 s rt . 7 tk\ ' ' f' ti { g ; x ] - 4litt. . 1: O Z '6' " 26 t; xe G 02= J 0 I e'> 56 g }6 w 44 i 72 � T T G Clam Pass morphology 18 months Post dredging Conditions (Oct 2014) ''"."!..-;,- ,A,'.,, -,'' : --",, ' it .� 4,900 cy , it\ $ .tAk#1* 4,700 ty , • 4. 400 cy t; t 420 cy :: -2,900 cy s o , ! :, , y,. R.-, -250 cy ,;' f' 412 .c 670 cy , s 6 i 6,100 cy i 600 cy Clam Pass morphology change(Mar 2014-Oct 2014) Figure 5. Clam Pass morphology and change(Mar 2014-Oct 2014). 9 Or t . y- : - 11 - "Ilk oa 44 '..f. a sS 4,._ ' .2„, TT ' ' jii -, g , .72 4 as Clam Pass morphology Immediately Post Dredging (April 2013) �' M1 I I TAB T + }a a1 `rY f. i � 4 f 0 a./ . aa s s o o t d ,mo .+u a W Clam Pass morphology 18 months Post dredging (Oct t 2014) '4,,,.. „rt, ( ii,' ;IN 4 , r 1,950 cy i 4,100 cy ''S-. ea 1,100 cy a: +s -2,750 cy tf l. , ;: APPENDIX A. AERIAL PHOTOS 11 , - 4 r • y ♦.. xr January 2013 • r \ 1 !• t K.-: • March 2013 =� Figurel. Clam Pass Aerial photos Jan —March 2013 12 :; - y « �1 r • ��TTII� to �. April 2013 —k• r. y 4 r4 • CI • _fix¢ J spa May 2013 x ; Figure 2. Clam Pass Aerial photos April —May 2013 13 - • e r ar •1 t a June 2013 a t , July2013 IHMI Figure 3. Clam Pass Aerial photos June —July 2013 14 J @4S s� . r August 2013 r • d • . ' la 41 ':a iY z - ; '- x Ry September 2013 t `.. 1/4 I Figure 4. Clam Pass Aerial photos August—September 2013 15 • 4 • L October 2013 • .S�ice• a. vr , d . f' November 2013 Figure 5. Clam Pass Aerial photos October— November 2013 16 k ,'. I oripiti■ :II' t $rte fr December 2013 Figure 6. Clam Pass Aerial photos December 2013 17 a ■ -' >, w'r_ -•-• +r° .:ArliO4,.. )04t, ■ January 2014 - : .� . z.. w 1\t ,u 1 . i' „.viipp,„,„. ,,.,.t; a ♦ , February 2014 ` IHMI Figure 7. Clam Pass Aerial photos January—February 2014 1R yam} ' ry. • ..tit' y�y • 'f�? March 2014.1 r nSz April 2014 Figure 8. Clam Pass Aerial photos March—April 2014 19 F f ``1, -' i d ".. May 2014 j 4 { yp , ` d r. �si'Iffaw June 2014 a j r Figure 9. Clam Pass Aerial photos May—June 2014 20 - .K r � t July 2014 • wn* '. August 2014 'WI Figure 10. Clam Pass Aerial photos July—August 2014 71 t I - r September 2014 / r-. • s i • • • • J m.7" n . ,', ati Ir+ s ,•Sim . October 2014 1 ' ¶`l sri� Figure 11. Clam Pass Aerial photos September—October 2014 LL APPENDIX B. SURVEY PROFILES AND COMPARISON To PREVIOUS SURVEYS 23 1 F,,,&,,{J-:✓..0w,3.,..ciD;nn x',201,4',,,,I.;,,,,D:-•,:•n t 0 Monitor I:coi_0:•-10:3._;;P:1:4:Dec i I 1 1 ELEVATION FEET,(NAVD) I I LEVATION FEET,(NAND) 1 N - 1 a A 1 N A - •. 1 u - 1 ! P N - N - !-^: P7' n: WN7' Z O o £ i ° ; K O A I r N i i Z • Z n"G I 7. I - (D O D Z y o ... . 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A r* O r o 0 p — � _ J / ii ps tiZ — o cD z b ^f7, °i e. t 1.l 2�J1 O O O CO W co ,,g tz 10 o o- CDZ'7 C m I tn o in pr m m o_ 0 > 0 > A W —{ A ° 8 o �7 m o W °o O Q `1N O m m O \r- m K TI W 40 > c Z r \Z m M rii Z m W r , No z D D o OD 'rl '` co --1 m 73 - A C nW 0 D Z 0 o N > -I �.- ° < 0 00 D z 0 --I Z U) 2 3 n OZ 0 0 o- C r A Ir1 N N N N N N 00000 _ ??W W W 0 Co 1 1 1 1 1 0— —.0000 Z O W W A 1 I I I N CT —• -•0 —C p A W N m 0. O O O O A N_ z D Z Z Z Z r �mZN O D < -1'-I=C7 r =D y m o I< IO O O O O O X m v ° m m zI 7J z l • 1-LO __ Z r7 J" M zzzzcnM C - NNW 0000-1Z N N.I-- WmCO gsq W 1DUWa co ' (n?AO DZ Q CO I -•O _-I D }N O C _m 0 1 0 73 Z m 210(j'N .Wi m N 0 O 3 December 31, 2014 Collier County Board of Commissioners Dear Commissioner As directed by the Board of County Commissioners (BCC), the Pelican Bay Services Division (PBSD) has prepared an updated Clam Bay NRPA Management Plan. The initial Plan was modified at the direction of the BCC to incorporate proposals by the Conservancy of Southwest Florida and to tie the Plan to dredging permit applications. At its December 9, 2014 meeting, the BCC delayed approval of the Plan to allow Commissioner Penny Taylor additional time to review the Plan. Subsequently, the Naples City Council, prompted by the community of Seagate, raised objections to portions of the Plan. Many of those objections had already been addressed and the Plan modified accordingly (see Attachment 1). Remaining issues raised by Seagate involved dredging of an interconnecting waterway, placement of dredged sand and procedures for amending the Management Plan. The PBSD feels these three issues are adequately addressed in the current draft of the Plan (see Attachment 2). The PBSD respectfully requests the BCC to approve the Clam Bay NRPA Management Plan as submitted. David Trecker, Chair Susan O'Brien, Chair Pelican Bay Services Division Clam Bay Committee Copies ATTACHMENT 1 Comer Camp ay Pelican Bay Services Division Municipal Service Taxing and Benefit Unit December 1, 2014 Naples City Council and Mayor 735 Eighth Street South Naples, FL 34102 Dear Councilpersons: The Pelican Bay Services Division (PBSD) appreciates your interest in the Clam Bay NRPA Management Plan. In a July 2. 2014 memo to the PBSD, and later at the Naples City Council workshop on November 17, Dr. David Buser, President of the Seagate Property Owners Association voiced concerns about the Management Plan. As outlined below, many of his concerns have been addressed. • Dr. Buser called for monitoring and, if necessary, dredging of the channel connecting Clam Pass and Outer Clam Bay.The plan provides for bath■metric surveys of interconnecting waterways and intervention if appropriate(p. 40). • Dr. Buser asked that the plan specify site-specific alternative criteria(SSAC) for water- quality standards in Clam Bay, as established by the Florida Department of Environmental Protection(FDEP). The revised plan complies with his request (pp. 33-35, 40). • Dr. Buser asked that the plan address copper impairment. Reference has been made to efforts to deal with copper impairment (p. 40). [Note that an extensive,well-publicized program to address the copper problem has been underway for nearly two years.] • Dr. Buser requested that the channel leading from Clam Pass to Outer Clam Bay be described as a mixed-use waterway and that use of the waterway by motorized vessels be recognized. His suggestions have been incorporated into the plan (pp. 5. 7-8, 35-36). • Dr. Buser expressed concern about placement of sand from dredging Clam Pass on nearby beaches. The plan states "sand from dredging will be spread on adjacent beaches, as required by the permitting agencies" (pp. 43).This is consistent with the FDEP permit issued in August, 2012,which states "beach-compatible sand will be placed north of the Pass, along Pelican Bay Beach, and south of the Pass, along Collier County Clam Pass Park Beaches". Pelican Bay Services Division 1 801 Laurel Oak Drive,Suite 302 I Naples Florida 34108 I Tel 239-597-1749 Fax 239-597-4502 0 1 December 1, 2014 Naples City Council and Mayor Page 2 Please note that representatives of the Seagate community, including Dr. Buser, have had many opportunities to provide input to the plan during its development over an 18-month period. During that time, 28 publicly noticed committee meetings, workshops and board meetings were held. Those meetings were attended by biologists, engineers and dozens of stakeholders who provided input that shaped the plan. 'While Dr. Buser chose not to participate in those meetings, his concerns nonetheless have been addressed. The referenced draft of the Management Plan was approved by the PBSD board on November 14 and submitted to the Collier County Board of County Commissioners. Copies of the pages referenced above are attached. The entire Clam Bay NRPA Management Plan and the FDEP permit are available on the PBSD website at littp://pelicanbayservicesdivision.net. Please let us know if we can provide additional information. Sincerely, 0-13-117- L David {TTeker, Chairman Susan O'Brien. Chairman Pelican Bay Services Division Board PBSD Clam Bay Committee ATTACHMENT 2 SEAGATE OBJECTIONS TO THE CLAM BAY NRPA MANAGEMENT PLAN The Naples City Council (NCC), prompted by the community of Seagate, has objected to portions of the proposed Clam Bay NRPA Management Plan. Many of the changes previously suggested by Seagate have already been incorporated into the Plan (12/1/14 memo to NCC). Remaining issues include the following: • Seagate would like language pertaining to dredging the waterway between Section C of Clam Pass and Outer Clam Bay (Cut 4A) to be taken from the 1998 Management Plan. The PBSD feels the current draft of the Management Plan adequately deals with dredging Cut 4A and other interconnecting waterways. "Conduct bathymetric surveys of interconnecting waterways when needed. Determine whether ecological benefits of intervention activities outweigh potential negative ecological impacts. Seek appropriate federal and state permits to dredge Clam Pass or interconnecting waterways if needed. " [It should be noted that surveys taken by the county in 2012 show that design depth (- 4 ft.) and bottom width (30 ft.) of Cut 4A have been maintained since 1999 dredging.] • Seagate proposes the Management Plan specify that all dredged sand from Clam Pass be placed south of the Pass on the Clam Pass Park beach to reduce the amount of quarry sand needed for public beach renourishment. The PBSD feels this is inconsistent with state statute, which specifies dredged sand placement on "adjacent eroding beaches, " and with the existing FDEP permit, which states "beach-compatible sand will be placed north of the Pass along Pelican Bay Beach and south of the Pass along Collier County Clam Pass Park Beach. " The current draft of the Management Plan states "sand from dredging will be spread on adjacent beaches as required by the permitting agencies. " • Seagate opposes the proposed process for amending the Management Plan, namely that changes must first be approved by the PBSD prior to final approval by the BCC. Instead, Seagate would like to go directly to the BCC to propose changes, by-passing the PBSD. The PBSD, having been given responsibility for managing Clam Pass and the NRPA preserve,feels that its responsibility would be subverted by allowing third parties to propose changes directly to the BCC. The current draft of the Management Plan states, "The Management Plan is not expected to be a static document ... Conclusions, recommendations or alternative management activities that come about as a result of future studies will be examined and considered by the Pelican Bay Services Division and qualified engineers and biologists for their relevance to the Management Plan. Those modifications that are found to be relevant and economically feasible will be incorporated into the Management Plan for approval by the BCC. " In summary, the PBSD feels the final three issues raised by Seagate are adequately addressed and covered in the current draft of the Management Plan. To: PBSD Board Members From: Linda Roth, Montenero Subject: Preparation Suggestions for 1/13/15 BCC Meeting Date: 12/30/2014 1. Has PBSD received the revised Naples City Council Letter to the Commissioners? Has the letter been sent to the BCC? 2. Please write the Commissioners during the week before Jan. 13, 2015, and clarify the following important points the Commissioners seem to be unsure of: a) The current Clam Bay NRPA Management Plan has been developed according to the directions of the BCC. Coastal experts Tim Hall and Mohamed Dabees are the principal authors of the Plan with major contribution from Kathy Worley, chief scientist of the Conservancy. The dredging plans have also been peer-reviewed and endorsed by Erik Olsen of Olsen Associates, a highly respected and reputable coastal engineer. Inputs from multiple stakeholders have also been incorporated. b) Although Seagate chose not to participate in the 28 publicly noticed meetings over the past year and a half, and expressed concerns only after the Plan was finalized and approved by PBSD, PBSD has revised the Plan to incorporate Seagate's inputs that contribute to maintaining the health of the Clam Bay ecosystem. c) Language used in the Plan has been updated to reflect the current conditions of the Clam Bay estuary, as well as current State and Federal rules and regulations, e.g., sand placement on adjacent eroding beaches; Site Specific 1 Alternative Criteria (SSAC) for water quality; not conditions existed in 1998. d) The current Plan includes management of the biological/ecological component of Clam Bay, a concern of the Conservancy, not just restoration of the mangrove forests as in the 1998 Management Plan. The current Plan is a comprehensive plan that addresses the health of the entire Clam Bay ecosystem, and the management of it in the best interests of Collier County and its citizens and visitors. 3. Include the Dec. 1, 2014 PBSD Letter signed by Dave Trecker and Susan O'Brien to the Naples City Council together with the supporting pages from Ver. 6.5 of the Clam Bay NRPA Management Plan, as well as relevant communication between Mohamed Dabees and Erik Olsen. These documents can also serve as supporting materials for the PBSD Management Plan agenda item on the 1/13/15 BCC Meeting. 4. Please ask Neil Dorrill, Tim Hall, and Mohamed Dabees to attend the Jan. 13, 2015 BCC Meeting, and be ready to clarify any questions the Commissioners might have on the Management Plan and dredging permits. Thank you, and Happy New Year! Suggested edits to Biological Assessment Page 1 Add title (perhaps Introduction or Executive Summary) for first three paragraphs Page 1 Par 2 Delete scientific names of species. (perhaps use them in Section II where they are already used for the Eastern Indigo Snake, Piping Plover,and Florida Panther Page 1 Par 2 Put wood stork before piping plover so the order of species is the same as in the other sections of the document Page 1 Par 2 line 7 Delete candidate before gopher tortoise because it is not used in the rest of the document Page 1 Par 5 line 2 Use FWS, not USFWS so it is the same acronym used in Par 4 on page 1 Page 3 Par 3 line 2 Change Exhibit 4 to Exhibit 2 Page 3 Par 3 Change to "The Pelican Bay Services Division (PBSD) proposes to dredge the Clam Pass inlet and channel in Collier County, Florida (Exhibit 2) when monitoring data indicate that dredging is needed as outlined in the 2014 Clam Bay NRPA Management Plan. The intent of the proposed dredging is to ensure that the estuary has adequate tidal and freshwater flows to maintain ecological health within the Clam Bay NRPA. It is anticipated that the dredging of Clam Pass may be necessary about every three to five years." Page 3 Par 4 line 3 Change exhibit 5 to exhibit 11 Page 4 Par 1 line 5 Add after Appropriate buffers, as outlined in the Clam Bay NRPA Management Plan, Page 4 Par 1 line 8 Add after dredged either"at the mouth of the Pass" or"in Section A" Page 4 Par 2 Line Use FDEP which was the acronym used in Man. Plan. Page 4 Par 2 line 3 Change R-45+500 feet to R-44+500 so it matches Mohamed's drawings. Page 4 Par 2 An Exhibit of sheet 3 of Mohamed's drawings could be added and referenced to show placement of sand. Page 4 Par 4 line 2 Change Exhibit 7 to Exhibit 8 and change"is discovered" to "are adversely affecting adequate tidal low" so tidal flow remains the focus. Page 4 Par 5 line 5 Change Exhibit 8 to Exhibit 10 Page 5 Par 4 line 1 change threatened to endangered so it's consistent with page 1 Page 6 Par 3 line 7 explain meaning of ppt. Page 6 Par 5 line 1 change effects to affects Page 9 Insert Species/Critical Habitat Description under Sea Turtles Page 11 Par 3 line 10 I'm not sure INBS acronym has been previously used; if not, please use name Page 12 Par 3 line 11 Put space between two paragraphs. Page 14, Par 3 line 4 use having instead of have Page 14 Par 5 line 4 close space between Virgin and Islands Page 23 Par 5 line 3 Change being to are Page 29 Par 4 line 1 Add a space between habitat and is Page 30 Par 4 line 6 Add a period after effects. Page 31 Par 1 line 1 Capitalize Action Area is it is in rest of document Page 31 Par 4 line 1 &2 Use inches rather than centimeters so measurement usage throughout document is consistent. Page 33 Par 2 line 1 I think researchers works better than authors Page 34 Par 6 Use English rather than metric units so unit of measurement is consistent throughout document. Page 34-38 Transpose the sections on Florida Panther and Florida Bonneted Bat so the order of the species is in the same in each section of the document. Page 35 Par 2 line 9 use miles instead of kilometers for above reason Page 37 Insert Species/Critical Habitat Description under Florida Bonneted Bat Page 38 Par 2 line 2 Add If before remaining to make it a complete sentence. Page 38 Par 4 line 12 Make it warm-water so it's consistent with usage on pages 39 and 40 Page 38 Par 6 line 1 Make it warm-water for consistency Page 40 par 8 line 1 Use lower case on populations so it's consistent with rest of document Page 40 par 8 line 3 Change were to was Page 44 par 5 line 4 Change Figure to Exhibit Page 45 Par 1 line 2 Change is to are Page 45 Par 1 line 5 Add s to Pass Page 45 Par 1 line 5 saying 3.2 miles south of Clam Pass may be better than saying 3.2 miles from Clam Pass south Page 45 Par 2 line 2 Change Figure 3 to Exhibit 3 Page 45 line 6 & 7 Use either feet or'with both numbers for consistency Page 45 Par 3 line 3 change exits to exist Page 45 Par 4 line 1 delete nearby and add after Swamp, located about 36 miles northeast of the Clam Bay NRPA, Page 45 Par 4 line 4 Change 2113 to 2013 Page 47 Par 1 line 2 Delete which,area and add of the Clam Bay NRPA provide Page 49 Par 1 line 2 Change we to the and add is after focus Page 53 Par 9 line 1 Delete is Page 54 Par 5 line 1 Use upper case on Project because Project is capitalized throughout. Page 55 Par 2 line 6 Add plovers after piping Page 59 Starts with Section VI,but there is no Section V Page 60 Par 2 line 2 change is to are Page 60 Par 2 line 4 change indicates to indicate and is to are Page 60 par 2 line 5 change indicates to indicate Page 60 par 2 line 6 change indicates to indicate Page 60 par 4 line 6 change effected to affected Page 61 par 3 line 6 change USFWS to FWS as used previously in document Page 61 par 4 line 1 change USFWS to FWS as used previously in document Page 61 par 6 line 1 In summary maybe better than In sum Suggested enhancements to Biological Assessment Add Table of Contents Add bibliography of references cited in the document