Loading...
HomeMy WebLinkAbout153-02 RESOLUTIONRESOLUTION NO. 1.53-02• e A RESOLUTION TO ACCEPT THE REPORT OF THE WILSON SPRINGS BUSINESS PARK ASSESSMENT TASK FORCE WHEREAS, the City of Fayetteville is very appreciative for the concern and dedication demonstrated by the volunteers of the Wilson Springs Business Park Assessment Task Force; and WHEREAS, the City of Fayetteville for itself and all the citizens of Fayetteville expresses its sincere gratitude and thanks to every member of the Task Force and especially its Chairman, Jeff Collins, who volunteered countless hours to forge a consensus that included both the partial development and the. careful preservation of the Wilson Springs acreage. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF FAYETTEVILLE, ARKANSAS: Section 1. That the City Council of the City of Fayetteville, Arkansas hereby gratefully accepts the Report of the Wilson Springs Business Park Assessment Task Force which is attached as Exhibit A, and adopts its recommendations for both development and preservation of the Wilson Springs acreage. Section 2. That the City Council of the City of Fayetteville, Arkansas hereby requests that the City Staff proceed with the recommendations of the Task Force. PASSED and APPROVED this the 2nd day of October, 2002. ATTEST: Bv: • •Woodruff, City Cle • APPROVED: By: NAME OF FILE: CROSS REFERENCE: Item # Date Resolution No. 153-02 Document 1 10/02/02 Resolution 153-02 NOTES: FAYETTEVItLE THE CITY OF FAYETTEVILLE, ARKANSAS KIT WILLIAMS, CITY ATTORNEY DAVID WHITAKER, ASST CITY ATTORNEY DEPARTMENTAL CORRESPONDENCE I 'A I A LEGAL DEPARTMENT TO: Dan Coody, Mayor THRU: Heather Woodruff, City Clerk okFROM: Kit Williams, City Attorney DATE: October 3, 2002 RE: Passed Resolution from Special City Council meeting of October 2, 2002 The following Resolution was passed at the Special City Council meeting and is ready for the mayor's signature Enclosed is: 1. Wilson Springs: Resolution to accept report of Wilson Springs Business Park Assessment Task Force THE WILSON SPRING BUSINESS AND TECHNOLOGY PARK TASK FORCE The Wilson Spring Business and Technology Park Task Force (TF) was formed to provide independent analysis and to make a recommendation to the City Council and Mayor's office of the City of Fayetteville as to the "highest and best" use of the approximately 289 acres owned by the city and located on Interstate 540. In the course of our examination, three subcommittees focused on the economic/development, biological, and hydrological issues associated with the site, gathered information and studied important attributes and/or impacts of various uses of the property. The TF held two pubic forums for to gamer input from citizens, as well as allowing statements and questions from various representatives of constituent groups during regularly held meetings, which began June 20th' The results of this work, found below, accomplish the following purposes: 1. The formation of a Business and Technology Park sufficient in size to create critical mass for business development and located to take maximum advantage of potential synergies with Fayetteville's most unique resource, the University of Arkansas. 2. The increase and enhancement of Fayetteville's tax base and further insurance of the financial viability of the City of Fayetteville. Developing these lands produces financial advantages for the City in three ways: a. It retums acreage to the property tax base critical to the support our schools and other city and county services. b. It produces "profit" for the City, with which to fund and support such things as the development of trails, green space, parks, and parks improvements. c. It fosters the development of high wage jobs by improving the climate for the creation of knowledge-based industry. 3 The preservation of at roughly 180 acres of wetlands, floodplain, and floodway, creating a valuable environmental resource, in perpetuity, for the citizens of Fayetteville. RECOMMENDATIONS Note: These acreages referenced in this recommendation are taken from the Development Area plat, as drawn by McClelland Engineers, showing a wetland impact of 17 acres. 1. Recommendation: Immediately apply for and receive the permit from the Corps of Engineers for the 17 -acre wetlands impact, with mitigation, as necessary. 2. Recommendation: Approximately 70 acres at the south end of the property be platted and planned for the Wilson Spring Business and Technology Park Development 3. Recommendation: The 38 acres at the southeast comer (and a part of the above referenced 70 acres) be developed immediately (Phase 1). a. Development of these lands would require some or all mitigation be done on the front end, since some of the 38 acres is in the wetlands impact area. Monies for the mitigation would provide initial funding for immediate restoration, etc. (However, per the U.S. Army Corps of Engineers, due to the substantial amount of land being preserved in the recommendations of the Task Force, possible mitigation acreages could be significantly reduced.) 4. Recommendation: The City of Fayetteville to construct Covenants and Restrictions for the Business Park: a. To insure that the Business Park will not include heavy industrial or be dominated with retail business and will encourage "knowledge based", technology oriented businesses. b. To insure that the resulting development will have a campus style environment with a maximum amount of area in green space. c. To insure that the wetlands are "developed" to provide the maximum benefit to the entire surrounding property d. To insure that all storm water collection systems from development be constructed to protect the sensitive wetlands • • 5. Recommendation: Commence as soon as possible a formal inventory assessment and evaluation of the lands lying north of Clabber Creek, currently not designated as wetlands or mitigation areas for wetlands impact, for development potential. These lands to include the approximately 11 acres lying west of Deane Soloman Road. Such evaluation should include a thorough needs assessment, potential environmental impact of development, biological assessment, further wetlands delineation assessment, dispersed recreational study, storm water runoff assessment and economic impact of development. If such an evaluation of such lands yields the possibility of development of some kind, the TF recommends the inclusion of a significant buffer of "not -to -be -disturbed lands" of at least 600' wide lying north of and parallel to Clabber Creek. 6. Recommendation: That all of the lands lying south of Clabber Creek and north of the aforementioned 70 acres of commercial development be preserved, in perpetuity, as delineated wetlands and/or an extension of said delineated wetlands. • • • • • • SUPPORTING DOCUMENTATION PROVIDED BY INTERESTED CITIZENS • • • • • • • Task Force, September 12, 2002 The only reason I'm here is due to the fact that our City administration has forgotten about the 'public interest,' which is, I realize, an outmoded concept. But for this proposal to make any sense at all, in addition to the 'public interest,' there is a great deal more that one has to forget about, to ignore. In its zeal as lobbyist for the idea of development at all costs, which is really what we're talking about, the City has made ordinary citizens into guarantors of a risky and massive expenditure of public funds. The current estimate for the full development stands at $8m, which represents 10% of the City's annual budget. Over the past six months, the City administration and now the Task Force have made presentations, and not once has the word 'risk' been spoken. This despite the fact that there is ample public information available which shows that the risks to the City's investment are considerable, leaving aside the 12 years of fiscal mismanagement by the City and the Chamber of Commerce. And what about the 'free market? This is another thing we should forget about. If the demand was so great for what the City proposes, would it not exist already? The problem is, I'm • afraid that it *does*. In talking about building an office park, we are supposed to 'forget' that Fayetteville already has an oversupply problem in the commercial real estate market (I refer you to pp. 56 & 57 of the City's most recent Appraisal). In this Appraisal, one can read such phrases as " less than ideal demand situation," "increasing supply of competing tracts,"`speculative office buildings ... are being absorbed slowly," "a good amount of competing locations should be anticipated in the coming years...' These are not the utterances of an Alan Greenspan, requiring the hiring of a psychic to interpret. And yet, one feels they continue to be ignored. In fact, since this Appraisal was done, another Office Park is slated to be built across from the new Washington Regional Hospital. But how did we get to talking about an Office Park in the first place? The City had a proposal for a "Research & Technology" park for a number of years. Based on this concept letters were sought and received from mayors of nearby municipalities and a grant application was made to the Economic Development Fund of AR. This grant money was received and it now appears that these funds will be used to build anything which comes under 'C-2' zoning -which is what the Appraisal was based upon. I ask you: would this money have been given to the City to fund an • Office Park? • • • • • • • The City should have to rigorously justify putting itself in direct competition with the private sector by adding to our local oversupply problem. To date, the City has failed to do so Apparently, the `build it and they will come' belief system requires no justification. And then there is the idea of jobs.' If I were an outside company looking to relocate here, what would I be looking for? I'd be looking for an ample supply of well-educated workers, which we do not have (witness our low unemployment rate). I'd be looking for tax credits, which the City cannot provide. In any event, jobs are not 'created' by employers. Demand for workers is itself an expression of the demand for the goods or services the company is providing to the community. Constructing buildings does not, by itself, create more demand for goods and services. What the City does have is the unique ability, unlike a private developer, to give away the land. This precedent will be set when the deal with Arkansas Game & Fish Commission is settled. Combined with holding this property for over 12 years, this deal puts the City in a less than ideal bargaining position m the marketplace. Under normal conditions, there would be a conversation between the developer/entrepreneur and the bank. They would analyze the market situation. Citizens now represent the bank's shareholders, but the 'bank' is not representing our interests. Unlike shareholders, we do not have the right to force the City to take their scheme down the road to another bank. As a reluctant 'investor,' I say this is a bad deal (with apologies to Mr. McGuire). One would like to believe that part of the Mayor's mtent in setting up this Task Force, was for it not only to appear to be independent, but also to function independently. This means taking a very sober look at the City's record of ownership as well as the scientific and economic facts. I hope that you will conclude that the time for forgetting certain facts is long past. Respectfully submitted, Stephen Vallus • • • • •ECONOMIC IMPACT OF TENNIS ON OVR CO J�Y Ertfmated turban re Did of town Owen and spectators that will b. baryht to Columbus In 2002 *Rough tarots tovr.wnisra • • • Senior Clip Maybe Plwyar+/.3peaeRMar6 Eearamda Thean per Dar • TOTAL ECONOIATC IMPACT/DAY At �1DTALTIAPACTITCM IMENT Junior Clusopionships Nunbar Player ononstotent 500 Eamon* boat pon Doi • . LAW rcra. ECONOAUCTMPACT/DAY $63,000 �, a TOTAL E�IMPACY/TOURNAMBIT $666P00 +oo t$ThL MOD $300,600 • to Senior District Championships .oD Nunn Pw nne/Spee/ataro• awn* Ilapeet per OpsLAW TOTAL ECONOMICXMPACT/DAY 1 $1.=6.60D a as TOTAL ecoraze IMPACT/TOANrN4Ae1T . $04,400 Junior Deslynafied • Number MeyarsA eetatars town Dnpmet per oar TOTAL ECONOMTCXMPACY/DAY rr Day tiburnmen t TOTAL ECOIJOP ATe ntPACTITOUPNAMI NT Junior Clay Court Championship Ninnies PlaypraSpanatw foam* Menet pr bay TOTAL rtowah=vaACT/DAY M TOTAL ECONOAILC IMPACT/TOURNAMENT Senior Sou1thern Championship Number Playerallspeetw►eraf Ewwmle I vsnot Por Dug TOTAL ECONOMIC IMPACT/DAY • Derzfrouragnat TOTAL ECONOMIC SMRIMCTl7OUANAMB'T • AL IMPACT' OF THE ABOVE (4) TOVANAMENTS YOM. SMS PLAYlge;/i tTATON1 100201111 114100 TMTrAL =PAO e. TT ti 6001 • do0 ASIE $!33.600 a! $034,400 no $41.700 ALA $1674000 3'!a • alai SNAG : SL San .0OD i a • • PO. " ;. • ..•LLkO'ZZS 105 i • 1 E 1 3NOW B 118HS?NU 11d £E:ZI 31U. ZOOZ-Ll-d3S 121 °S.0 . 675 • 148 L.Fd.2d 576, 69 USLW, 51' 1833, 31 EnvtL L. Rep. 20:382,. 2001 Daily Journal D.A.R. 267, 20010 C.A.R. 346, 14 Fla. L. Weekly Fed. S 48 (Cite as: 531 ILS. 159, 121 S.Ct. 675) Supreme Court of the United States SOLID WASTE AGENCY OF NORTHERN COOK COUNTY, Petitioner, v. UNITED STATES ARMY CORPS OF ENGINEERS, et al. No. 99-1178. Argued Oct 31, 2000. Decided Jam 9, 2001. of wamictpalities sued the United States AIM Corps of Engi ts, challenging CM( exercise of jurisdiction over abandoned sand and gravel pit on which consortium planned to develop disposal she for nonhazardous solid waste and denial of a Clean Water Act (CWA) permit for that purpose. The United States District Court for the Northern District of Mots. George W. Lindberg, J., 998 F.Supp. 946, granted summary judgment for Corps oa jmisdicdonal issue, and consortium voluntarily dismissed remainder of its claims. Consortium appealed. The Court of Appeals for the Seventh Circuit, 191 F.3d 845. affirmed. Certiorari was granted. The Supreme Court, Chief Justice Rehnquist, held that Corps' rule extending timid= of 'navigable waters' under CWA to include intrastate waters used as habitat by migratory birds exceeded authority granted to Corps under CWA. Reversed. Justice Stevens fled dissenting opinion in which Jushces Souter. Ginsburg. and Breyer West Headnotes (1] Statutes �'+i 217.4 361k217.4 Failed legislative proposals are a particularly dangerous ground on which to rest an interpretation of a prier statute. [2] Statutes €:= 3611220 Serv. 269, Page 17 For purposes of statutory ioaerpretaeam, subsequent legislative history is less illuminating than contemporaneous evidence. [3] Environmental Law X525 149Ek525 (Formerly 18713.5) [3) Em3mnmenial Law G'a173 149Ek173 (Formerly 270708) [3] Environmental Law e 127 149Ek127 (Formerly 270.138) Army Coxps of Engineers' rule extending definition of -navigable waters- under Clean Water Act (CWA) to irecbide intrastate waters used as habitat by migratory birds exceeded authority gamed to Corps under CWA, and therefore, abandoned sand and gravel pit corms ponds used by nig' birds was not subject to Corps' jurisdiction corder CWA. Federal Water Pollution Control Act Ameadmesa of 1972. § 404(a). as amended, 33 U.S.C.A. § 1344(a); 33 C.F.R. § 328.3(4(3). [4] Statuses @219(6.1) 3611419(6.1) of (CWA) to include intrastate waters used ea habitat by ten birds which cross stat litres was not en ed to Chevron deference; rule raised significant Constitutional questions, such as _whether .hep tss bad ever to re. - such waters under the mce Mese.4-y1J.S.C.A. Court. Art. 1, § 8, el. 3; Federal Water Polludon Control Act Amendments of 1972, § 404(a), as amended. 33 U.S.C.A. § 1344(a); 33 C.F.R. § 328.30(3). [5] Administrative Law and Precedent 4=0330 15Ak330 Where an administrative imerpretadon of a statute invokes the outer limits of Congress' power, agency must establish a clear indication that Congress intended that result Copt. 0 West 2002 No Claim to Orig. U.S. Govt. Works 121 s.ct. 675 (Cite az 531 U.S. 159, 121 S.Ct. 675) [6] Adminimative Law and Procedure 4=1330 1SA1330 Concern that agency iutcrpretadon of a statute exceeds limits of power granted by Congress is heightened where interpretation alters the federal - stare framework by permitting federal encroachment upon a traditional state power. p) Constitutional Law X4M1) 92148(1) Where an otherwise acceptable eonsuuction of' a federal statute would raise serious constitutional problems, court will construe the statute to avoid such problems unless such construction is plainly contrary to the intent of Congress. "676 Syllabus [P141 Fs The syllabus constitutes no pan of the opinion of the Court but has been prepared by the Reporter of Decisions for the eonvenlenoe of the reader. See United States v. Detroit Timber ek Loeber Co.; 200 V.S. 321, 337, 26 S.Ct. 282, 50 L.Ed. 499. 959 Petitioner, a consortium of suburban Chicago municipalities, selected as a solid waste disposal site an abandoned sand and gravel pit with excavation trend= that bad evolved into permanent and seasonal ponds. Because the operation called for filling in some of the ponds, petitioner contacted federal respondents, hteluding the Army Corps of Engineers (Corps). to determine if a landfill permit was required under § 404(a) of the Clean Water Act (CWA), which authorizes the Corps to issue permits alto • the discharge of dredged or int material vi able wawa.% The CWA defines "navigable waters as the waters of the United States,' 33 U.S.C. § 1362(7). and the Corps' regulations define such waters to include intrastate waters, "the use, degradation or destrucden of which could affect innateor foreign commerce;" 33 CFR § 328.3(a)(3). hi 1986, the Corps attempted to clari$• its jurisdiction, stating, in what has been clubbed the "Migratory Bird Rule.' that § 404(a) extends to intrastate waters that, utter alio, provide habitat for migratory birds. 51 Fcd.Reg. 41217. Asserting jurisdiction Durr the instant site pursuant to that Rule, the Corps refused to issue a § 404(a) permitWhen petitioner. challenged the Corps' jurisdiction and the merits of the permit denial, the District Court granted respondents • • Page 18 summary judgment on the jurisdictional issue. The Seventh Circuit held that Congress bas authority under the Commerce Clause to regulate intrastate waters and that the Migratory Bird Rule .is a reasonable interpretation of the CWA. Held Title 33 CFR § 328.3(ax3), as clarified and applied to petitioner's site pursuant to. the Migratory Bird Rule. exceeds the authority granted to respondents under § 404(a) of the CWA. Pp. 679484. (a) In United Stater v. Riverside Bayview Homes, Inc., 474 U.S. 121, 106 S.Ct. 455, 88 L.E41.2d 419, this Coat held that the Corps had § '!' a) over. wedands a noting that the 'limited import' and that Congress •,..._. its intent to "regulate at least some waters that would not be deemed avigailo' er term s classical understanding„ at 133, 106 S.Ct. 455. But that holding was based in large measure upon Congress' =equivocal acquiescence to, and 4160 approval of, the Corps' regulations in the CWA to cover wetlands adjacent e See id, at 135-139, 106 S.Ct expressed no opinion on the question of the Corps' authority to regulate wetlands not adjacent to open water, and the statute's text will not allow extension of the Corps' jurisdiction to such wetlands here. Pp. 679-681- (b) The Corps' original interpretation of the CWA in its 1974 regulations-- which emphasized that a water body's capability of use by the public for transportation or commerce determines whether it is navigable—is inconsistent with that which it espouses here, yet respondents present no persuasive evidence that the Corps mistook Congress' intent in 1974. Respondentscontend that whatever Its original aim, when Congress amended the CWA in 1977, it approved the mom expansive definition of 1 �"ijxvtgab waters :%umd in the Corps' 1977 ( regulate& SpecificaIy. respond submit that Congress' failure to pass legislation that would have overturned the 1977 regulation and the extension of the Environmental Protection Agency's jurisdiction in § 404(g) to include waters "other than traditional "navigable ••677 waxers' indicates that Congress recognized accepted a broad definition of 5j " rale waters",; that includes no>mavigable, isolated, intrastate waters. This Court recognizes Copr. C West 2002 No Claim to Orig. U.S. Govt. Works • 121 S.Ct. 675 • • ((Ste as: 531 U.S. 159, '160, 121 S.Ct. 675, "677) • congressional acquiescence to administrative interpretations of a statute with extreme care. Palled' legislative proposals are a particularly dangerous ground on wbicb to rest an interpretation of a prior statute, Cereal Bank of Denver. Nat- Y. Fiat tuentare Bast of Deriver, N.A., 511 U.S. 164, 187, 114 S.Ct. 1439. 128 L.Ed.2d 119, bemuse a bid can be proposed or rejected for my number of reasons. Here, respondents have failed to maks the necessary showing that Congress failure to pass legislationdemonstrates acquiescence to the 1977 regulations or 1986 Migratory Mid Rule. Section 404(g) is equally , it ' oto does na conclusively determine the be PHOS on the use of the term -waters' elsewhere m the CWA. Riverside Bayview Hones, supra' at 138, n. 11, 106 S.Ct. 455. Pp. 680.683. (c) Even if § 404(a) were not dear. this Court would not extend deference to the Migratory Bird Rule rude Chevron U.S.A. Dec v. Naaaal Resources Defense Council, Die., 467 U.S. 837, 104 S.Ct. 2778, 81 L.E4.2d 04. Where an administrative huerpretadoa of a statute would raise serious constitutional problems, the Court will • cavoid such problems unless . the construction is poly country to Congress' intern. Edward J. DeBartolo Corp. v. Florida Calf Coast Bulking & Constr. fomes Comtdl. 485 U.S. 568, 375. 108 S.Ct 1392, 99 I PA Zd 645. The grantof authcaity to Congress under the Commace Clause. though broad. is not unlimited. See, e.g., United gates v. Morrison. 529 U.S. 598, 120 S.Ct. 1740. 146 L.Ed.2d 658. ' e.g., that the Migratory BIM Rule falls within 61 Congress' power to regulate intrastate 1 aetivltles that substantially affect interstate commerce. raise signify constitudonal questions, yet there is nothing approaching a clear statement Eton: Congress thal it intended § 404(a) to reach an abandoned sand and gravel pit ;adz as dm one at issue. Pamkling respondents to claim federal mon over ponds and nmd9ats falling within the Migratory Bird Rule would also result in a significant impingerncm of the States' traditional and primary power ova land and water use. me Court thus reads the statue as written to avoid such significant constimional and federalism questions and rejects the request for admimstnisve deference. Pp. 682-684. • 191 F.3d 845, reversed. • • Page19 REHNQUIST, C.L. delivered the opinion of the Court, im which O'CONNOR, SawA, KENNEDY, and THOMAS, XL, joined. STEVENS, 3., filed a dissenting opinin in which SOUTER, GINSBURG, and BREYEt, 31., joined. est, p. 684. TimomY S. Bishop. Chicago, II., for peiuior er. Lawrence G. Wallace, Washington. DC, for For U.S. Supreme Court Briefs See: • 2000 WL. 1369439 (Resp.Brlet 2000 WL 1369440 (Resp./hid) 2000 WL 1532361 (Reply.Brief) 2000 WL 1041190 (PetBrief) 2000 WL 1028522 (Amiau.Brid) 2000 WL 1041205 (Amicus.Briet) 2000 WL 1041206 (Amicus.BriSQ 2000 WL 1052146 (AmicutBrieO 2000 WL 1052154 (Amiens -Brief) 2000 WL 1052157 (Amiws.Briet) 2000 WL 1052159 (Amicus.BrieD 2000 WL 1059641 (Amiccu-Bdd) 2000 WL 1059644 (AmiwsBrief) 2000 WL 1059647 (Amicus -Brief) 2000 WL 1369409 (Amiens -Brief 2000 WL 1369410 (Amicus.Brief) 2000 WL 1369436 (Amicus.Brief) 2000 WL 1369438 (Amicas.BricO 2000 WL 1041204 (Amicus.Btief) Copt. 0 West 2002 No Claim to Orig. U.S. Govt. Works 121 S.Ct. 675 (Cite as: 531 U.S. 159, Ps.Ct. 5) 2000 WL 1041203 (Amicns.BrieQ 2000 WL 1041200 (Amicus.Briet) 2000 WL 1041198 (Amicas.BrjeO) 2000 WL 1041197 (Ani cus Brief) 2000 WL 1041196 (Amieus.Brief) 2000 WI. 1041194 (Amicus.Brief) 2000 WL 1041193 (Amie:m.Briet) 2000 WL 1041192 (Atoicus.Brici) For Transcript of Oral Argument See: 2000 WL 1669870 (U.S.Oral.Arg.) •162 Chief Justice REHNQUIST delivered the opinion of the Court. Section 404(0 of the Clean Water Act (CWA or Act), 86 Stat. 884, as amended, 33 U.S.C. § 1344(x), regulates the discharge of dredged or fill ii -i Y'navigable waters.",, The United States Army Corps of Engineers (Corps) has interpreted § 404(a) to confer federal authority over an abandoned sand and gravel pit in northern Illinois whkh provides habitat for migratory birds. We are asked to decide whether the provisions of § 404(a) may be fairly extended to these waters, and, if so, whether Congress could exercise such authority consistent with the Commerc *1%78 Clause, U.S. Const., Art. 1. § 8. cl. 3_ eanswer the !IIsi--• tuin in a naat ve and therefore do the sewn'�iye-., #rz tect4,Q# Petitioner, the Solid Waste • • P 20 scattering of permanent and seasonal ponds of varying size (from under one-tenth of an acne to several acres) and depth (from several inches to several feet); • The municipalities decided to purchase the site for disposal of their baled nonhazardous solid waste. By law, SWANCC was required to file for various permits from Cook Courcy and the State of Illinois before it could begin operation of its balefill project. In addition, because the operation called for the filling of some of the permanent and seasonal ponds, SWANCC contacted federal respondents respondents), including the Corps, to determine if a federal landfill permit was required under § 404(a). of the CWA, 33 U.S.C. § 1344(a). Section 404(a) grants the Corps authority to Issue permits 'for the discharge of dredged or :fill material namable w aged disposal sites." lbfd. The vigable waters" defused under the Act as waters of the United Stats, including the territorial seas? § 1362(7). The Corps has issued regulations defniag the term "wares of the United States' to include - isnseeintritteassee4akesrsaann (inch+d• >•..srmitr..e r 4^..,r nalsas smadflats_ wetlands sloughs, prairie potholes. wet meadows, playa 'lakes, or natural ponds, the use,, 'degradation or destruction of which could affect interstate or foreign commerce .... S.i Ckll 4 328 ga)(3) (1999). • '164 In 1986, in an attempt to 'clarify" the reach of its jurisdiction, the Corps stated that § 404(a) extends to intrastate waters: "a. Which are or would be used as habitat by birds protected by Migratory Bird Treaties; or Y 'b. Which are or would be used as habitat by other L f g�y birds which cross state lines; or ,/c. Which are or would be used as habitat for endangered species; or "d. Used to irrigate crops sold in interstate commerce.' 51 Fed.Reg. 41217. This last promulgation has been dubbed the "Migratory Bird Rule.' [ENT) FN1. The Corps issued the 'Migratory Bird Rule" without following the notice and comment procedures outlined In the Admluiszradye Procedure Aa, 5 U.S.C. § 553. QC4`- of NGithan Cook County (SWANCC). is a consorthmi of 23 suburban Chicago •163 cities and villages that united in an effort to locate and develop a disposal site for baled nonhazardous solid waste. The Oilcago Gravel Companytin ... t municipalities the availability `• na.rrl gridin2 be IDiaois counh oo t and and gra 120. Long since abandoned, the old coming site eventually gave way to a successional stage forest, with its remnant excavation trenches evolving into a The Corps initially concluded that it had no Copr. 0 West 2002 No Claim to Orig. U.S. Govt. Works • • 121 s.Ct 675 • (Cite as: 531 U.S. 159, •4 L2111.675, "678) jttriidiction over the site because i< "wedantls,' or areas which r itadapted for life conditions." 33 CFR § 328.3(b) (1999).—owcver, atter the Illinois Nature Preserves Commission informed the Corps that a number of migratory bird species had been observed at the site, the Corps reconsidered and ultimately asserted jmisdicdon over the balefif ate pursuant to subpart (b) of the 'Migratory Bird Rule? • me Corps found that approximately 121 bird species had been observed at the she, including several known to depend upon aquatic aavi onments for a significant portion of dick Bile requirements. Thus, on November 16, 1987, tie Carps formally 'determined that the seasonally ponded, abandoned gravel mining depressions located on die project site, '•679 while not wetlands, did qualify as 'waters of the linked Stares' ... based upon the following criteria: (1) the proposed site had been abandoned as a gravel mining operation; (2) the water areas and spoil piles bad developed a natural character; and (3) the water areas 6165 ate used as habitat by migratory bind fsidahich cross state line.' U.S. Army Corps of .Fsglaeera, Chicago District, Dept. of Army Permit Evaluation and Decision Document. Lodging of petitioner, Tab No. 1, p. 6. ivn. • [9• w.. 1)1 Durtng the application process, SWANCC made several proposals to midgate the Wetly displacement of the migratory birds and to preserve a great blue beton rookery located on the she. Its balefill project ultimately received die necessary local and state approval. By 1993, SWANCC had received a special use planned development permit from the Cook County Board of Appeals, a landfill development permit from the Illinois Enviroamceral Protection Agency, and approval from the Illinois Deparunent of Conservation. Despite SWANCC's seeming the required water quality certification from the Illinois Environmental Protection Agency, the Craps refused to issue a § 404(at) permit The Corps found that SWANCC bad not established that its proposal was the 'least environmentally fig. most practicatde ahernadve for disposal of nonhazardous solid waste; that SWANCC's failure to ser aside sufficient fluids to remediate leaks posed an 'unacceptable risk to the public's drinking water supply'; and that the impact of the project upon eve specks was 'tulmitigatable since a • • Page21 landfill surface cannot be redeveloped into a forested habitat." Id.. at 87. Petitioner Sled suit under the Administrative Procedure An, 5 U.S.C. § 701 a seq., in die Northern District of »limas challenging both the Corps' jurisdiction over the site and the merits of its denial of the § 404(a) permit. The District Court granted summary judgment to respondents on the jurisdictional issue, and petitioner abandoned ' its challenge to the Corps' permit decision. On appeal to the Court of Appeals for the Seventh Circuit, peddoner renewed its attack on respondents' use of the 'Migratory Bird Mee to assert jurisdiction over the site. Petitioner argued that respondents bad exceeded their statutory a .1:1, In 1 •narmavigab__, �. jam -tate waters based 1.. , Dresenoe of Co kackee lite power under the Commerce Clause to grant The Court of Appeals began its analysis with the constitutional quesdon, bolding that Congress has the authority to regulate such waters based spot the comuladve impact doctrine, under which a single activity that itself bas no discernible effect on int^tate commerce may still be regulated if the aggregate effect of that class of activity has a substantial impact on in state wmmette? 191 F.38 845, 850 (C.A.7 1999). The aggregate effect of the "destruction of the natural habitat of migratory birds" on hrterstate commercce, the court held, was substantial became each year millions of Americans cross state rims and speed over a billion dollars to hunt and observe migratory birds. [FN2) Ibid. The Court of Appeals then turned to the regulatory question. The court held that the CWA reaches as many waters as the Commerce Chaise allows and, given its earlier Commerce Clause ruling, it therefore followed that respondents' 'Migratory "680 Bird Rale was a reasonable interpretation of the Act See M., at 851-852. FNZ. Relying upon its earner decision in Elam Homes, Inc. v. EPA, 999 Fad 256 (C.A.7 1993), and a report from the United Stares Cercus Bureau, the Court of Appeab found that in 1996 approximately 3.1 minion Americans spent $1.3 billion to hunt mtgtatozy birds (with 11 percent crossing sate lines to do so) as another 17.7 million Americans observed migratory birds eolith 9.5 million traveling for the purpose of observing Copr. ® Wiest 2002 No Claim to Orig. U.S. Govt. Works 121 S.D. 675 (Cite as: S31 U.S. 159, *166, 121 S.Ct. 675,'680) shorebirds). See 191 F.3d. at 850. We granted certiorari, 529 U.S. 1129, 120 S.Ct. 2003, 146 L.Ed.2d 954 (2000), and now reverse. Congress passed the CWA for the stated purpose of "reswr[mB] and maid:An[mgl the chemical, physical, and biological integrity of the Nation's waters.' 33 U.S.C. § 1251(a). In so doing, Congress chose to 'recognize, preserve, and protect the primary responsibilities and rights of *167 States to prevent, reduce, and eliminate pollution, to plan the development and use (inducting restoradon, preservation, and enhancement) of land and water resources, and to consult with the Administrator in the exercise of his authority tinder this chapter.' § 1251(b). Relevant here. § 404(a) authorizes respondents to regulate the discharge of §B material sato "Drag* able waters,' 33 U.S.C. § 1344(a), which the mane defines as 'the waters of the United States, including the territorial seas,' § 13622(/). Renu have interpreted these words to cover the abandoned gravel pit at issue here because it is used as habitat for migratory birds. We conclude that the 'Migratory Bird Rule is not fairly supported by the CWA. This is not the first dine we have been called upon to evaluate the meaning of § 404(a). In United Stater v. Riverside Rayview. Homes, Inc., 474 U.S. held 106 S.he 455,E >1 � 419ltrr icc� over held that the. Corps wetlands that actually abutted on a navigable waterway. In so doing. we noted that the term 'navigable 1s of 'limited import' and that Congress evidenced its intent to 'regulate at least some wants that would not be deemed 'navigable' under the classical understanding of that term.' Id. at 133, 106 S.Ct. 455, But our holding was based in large measly. upon Congress' tmegnrvacal acquiescence to, and. approval of, the Corps' regulations interpreting the CWA to cover wetlands adjacent to navigable waters. See id., at 135-139, 106 S.Ct. 455. We found that Congress' concern for the protection of water quality and aquatic ecosystems indicated its intent to regulate wetlands 'inseparably bound up with the 'waters' of the United States.' Id, at 134, 106 S.Ct. 455. It was _the_sign}f4 ,nexu>s between the wetlands ,nexus informed our reading of the CWA in Riversi& Bayview Homes. Indeed, we • Copr. 0 West 2002 No Claim • • • • did not 'express any opinion' on the "question of the authority of the Corps to regulate d"twbarges of fill material into wetlands that ate not adjacent to bodies of open water ....' Id., at 131-132, '168 n. 8, 106 S.Ct. 455. In order to rule for resp here, we would have to bold that the jurisdiction of the Corps extends to ponds that are nor adjacent to open water. But we conclude that the text of the statute wit not allow this. Indeed, the Corps' original interpretation of the CWA, promulgated two yeats after its enaomabt, is inconsistent with that which it espouses here. Its 1974 regulations defined § 404(a)'s 'navigable waters' to mean 'those waters of the United States which are subject to the ebb and flow of the dde, and/or are presadly, or have been in the past, or may be in the future susceptible for use for proposes of interstate or foreign commerce.' 33 CFR § 209.120(d)(l). The Corps emphasized that '[7r t is the water body's capability of use by the public for purposes of transportation or commerce. which is the determinative factor." § 209.260(.X1). Respondents put forward no persuasive evidence that the Corps mistook Congress' intent in 1974. EFN3) FM. Respondents refer us to portions of the legislative history that they believe indicate Congress' intent to expand the definition of navigable waters." Although the Conference {- Report includes the ee-dase conferees intend that the term navigable wags' the broadest possible uaapremd°° ' S. Coef. Rep. No. 92- 1236, p. 144 (1972), U.S.Code Cong. & Admin.News 1972 pp. 3668, 3812,, niter this, war anything else in the legislative history to wbith respondents point signifies that Congress intended to exert any hhig more than its commerce power over navigation. Indeed,. respondents admit that the legislative bistary is somewhat ambiguous. See Brief for Federal Respondents 24. •*681 Respondents next contend that its original aimcharted five years la defmiti 1977 adopted 33 CFR § 323.2(a)(5) (1978). which defined 'waters of the United States' to include "Isolated wetlands and lakes, intermimeat streams, prairie potholes, and other waters that ate not part of a tributary system to interstate waters or to navigable 1 m 1972, Congas course ter when ed eve navigable waters found is the Corps' . the Corps formally to Orig. U.S. Govt. Works • • • • • 121 S.0.675 (Cite as: 531 U.S.159> 121S 675, "681) waters of the United States, the degradation or destruction of which could affect 6169 interstate commerce.' Respondents argue that Congress was aware of this more expansive interpretation during its 1977 amendments to the CWA. Specifically, respondents point to a failed Rouse bill, H.R. 3199, that would have defined 'navigable wafers” as 'all waters which are presently used, or are susceptible to use in their natural condition or by reasonable improvement as a means to transport interstate or foreign commerce.' 123 Cong. Rec. 10420. 10434 (1977). [PN4] They also point to the passage in § 404/g)(1) that authorizes a State to apply to the Environmental Protection Agency for permission 'to administer its own $ndividml and general permit program for the discharge of dredged or fill material into the navigable waters (other than those waters watch are presently used, or are susceptible to use in their naval conditiaa or by reasonable iniprovemess as i means to transport intentate or foreign commerce ..., including wetlands adjacent thereto) within its jurisdiction .... 33 U.S.C. § 1344(g)(1). The failt¢e to pass legislation that would have overarmed the Carps' 1977 regulations and the Gammon of jarisdictian is § 404(g) to waters borer man' traditional 'navigable waters,' respondents submit, indite that Congress recognized and accepted a broad definition of 'navigable waters' that includes nomnavigable,. isolated, intrastate s FI44. While rnia WO passed in the House, a similarly worded amendment to a bill origfmadug m the Senate, S.1952, faded. See 123 Cong. Rec. 26710, 26728 (1977). [17fn Although wo have recognized congressional acquiescence to administrative interpretations of a stance in some situations, we have done so with extreme tare. (FNS) '[F]ailed legislative *170 proposals are 'a particularly dangerous ground on winch to rest an mterpaeat[on of a prior statute.' " Cenral Bask of Dower, N.A. v. Fun herdsman Bacot ( Denver, NA., 511 U.S. 164, 187, 114 S.Ct. 1439, 128 LEd.2d 119 (1994) (quoting Pentton Benefit Guaranty Corponaton v. LTV Corp.. 496 U.S. 633, 650, 110 S.Ct. 2668, 110 L.Ed.2d 579 (1990)). A bill can be proposed for any mumbo of rte, and h can be rejected for just as many others. The relationship between the actions and inactions of the 95th Congress and the intent of the 924 "682 Congress hi Being § 404(a) • • Page 23 Is also considerably attenuated, Because 'subsequent history is less illuminating than the contemporaneous evidence," Hager v. Utah, 510 U.S. 399,420, 114 3.Q. 958, 127 L.E1.2d 252 (1994), respondents face' a difficult task in overcoming the plain ten and import of § 4044) - FM le Bob .Iona Univ. v. Unfurl Siam 461 US. 574, 595, 600- 601, 103 S.Q. 2017, 76 L.Ed.2d 157 (1983), for example, we upbdd an Internal Revenue Scrvico Its) Revenue bale dm revoked the tax-exempt sates of private scboob practicing racial c isciminadon because the IRS' imezpreaaon of elle relevant scannas was 'correct': because Conn= had beld Barings on this precise fie,' making k 'hardly conceivable that Congress -and in this setting. any Member of Congress—was not abundantly aware of what was going me; and became 'no fewer than 13 bills introduced to ovannn the WS mmpretadnc• bad faded. Absent such overwhebiling evidence of acquiesce**, we are loan to replace the plain tea and original emdersanding of a statute with an amended agency intexpraadon. See Consumer Produa Safety Comm'n v. GTE Sylvania, Dna, 447 U.S. 102. 118, n. 13, 100 S.O. 2051, 64 L.F.d.2d 766 (19 80) ( "(Elven when it would otherwise be useful, subsequent legislative blstoty will rarely override a reasonable interpretation of a sterane that can be gleaned from its language and iegisladve history prior to its marmrem7. We conclude that respondents have failed to make the necessary showing that the Patine of the 1977 Rouse ball demonstrates Congress' acquiescence to the Corps' regulations or the ,".figntary Bhd 1lila,' which, of course, did not first appear --a f 986. showing Congress' =opiates of the assertion of jurisdiction over isolated waters,' {FN6) as we explained in Riverside Bayview Henna, TO born Chambers, debate on the proposals to narrow the definition of navigable waters centered largely on die issue of wetlands preservation," 474 U.S., at 136. 106 S.Ct. 455. Beyond Congress' deshe to regulate "171 wetlands adiaoettt 93 respondents point m to no persuasive evidence that the House bull was proposed in rsspoase to the Carps' claim of jurisdiction over twmn'vivat l t ..1 et4 waters or that its failure indicated congressional acquiescence to such jurfsdicaon. FN6. Respondents cite. for example, the senate Report on S.1952, wbfcb referred to the Corps' Copt. 0 West 2002 No Claim to Ong. U.S. Govt. Worcs ►i 121 S.Ct. 675 • • (Cite as: S31 U.S.159, nn, 121 S.Ct. 675,'*68) 'isolated water' regulation. See S.Rep. No. 95-370, p. 75 (1977), U.S-Code Cong. & Admin.News 1977 pp. 4326, 4400. However, the same report reiterated that '[t]he committee ameadmeat does not redefine navigable waters." 4 Section 404(g) is une nlighiening, Riverside Bayview Ho a we Congress intended the wat deemed waters ,it,, 1, ., + not be under the dassieal understan • • : o •- term.' Id., at 133, 106 S.Ct. 455. But § 404(g) gives no }ndmation of what those waters p be; it simply refers to than Coder") other ) Respondents conjecture that -must incorporate the Corps' 1971 regulations, bit it is also plausible, as petitioner Congress all water adjacent _ navigable waters, tech as nonnavigable Crib and streams. The exact meaning of § 404(g) is not before us and we express no opinion on it, but for present purposes it is student to say, as we did in Riverside Bayview Homo. that • § 404(g)(1) does not conclusively determine the construction to be placed on the use of the term 'waters' elsewhere in the Act (panicularly in § 502(7), which contains the relevant defrnidoaa of 'navigable waters') ....' Id, at 138, n. 11, 106 S.Ct. 455. (PN7] FN7. Respondents also mate a passing reference to Congress' decision in 1977 to exempt certain types of discharges from § 404(a), including, for example, 'discharge of dredged or fill material ... for the purpose of construction or maintenance Of farm or stock ponds or irrigation ditches. or the maintenance of drainage ditches.' § 67, 91 Stat. 1600, 33 U.S.G. § 1344(t)(C). As § 404(a) only regulates dredged or fill material that is discharged 'into navigable visnas,* Congress' decision to exempt certain types of these diet -barges does not affect, much -less address, the definition of "navigable waters? . C. [3] We tau &liline respondisswinvitation. to take what they see as the next ineluctable step after Riverside Bayview Homer: holding that isolated 'ponds, some only seasonal, wholly located within tion Illinois counties, fill ander § 404(a)'s definidon of JnaY]gaht� water' because they cern *172 as habitat for migratory bads. As counsel for respondents conceded at oral argument, such . a • •. • Page 24 ruling would assume that 'the use of the word nnavinble in theme .." o not have any mdse en�den[ significance." Tr. of Oral Arg. 28. v�e Cannot agree cher f` ng"�—g`Y- sfinidcga. ' am of rhe pine "warn* of the 7lttirc l Stales" csuglimMe a sin for rea�_the-.M _ _air ere emrs We said in 8lversfde Bayview Homes that the/word 'navigable' in the **683 statute was of "limited import" and weal on to hold that .§ 404(a) extended to wetlands ad'acent to • • waters. c at east the import of showmg t s what tad m mind as its authority for enacting the CNA: its traditional jurisdiction over waters that were or shad been navigable in fact or which could reasonably be <, Tie See, e.g., United Sian v. Appalachian Elec. Power Co., 311 U.S. 377, 407-408, 61 S.Ct. 291, 85 L.Ed. 243 (1940). [4] Respondents—relying upon all of the arguments addressed above—contend that, at the very least, it must be said that Congress did not address the precise quad= of § 404(a)'s scope with regard to , blee-isolated, intrastate waters,. and 812, therefore, we should give defence to the 'Migratory Bird Rule.' See, e.g., Chevron (1.54. Inc. v. Neutral Resources Deface. Council, Inc„ 467 U.S. 837, 104 S.Ct. 2778, 81 L.Fd2d 694 (1984). We find § 404(a) to be clear, but even were we to agree with respondents, we would not extend Chewevt deference hem. [5][6][7] Where an administrative interpretadon of a statute invokes the outer limits of Congress'. power, we expect a clear indication that Congress intended that result. See Edward 1. beBarrolo Corp. v. Florida Gdf Coact Building & Const: Trades Comuzl, 485 U.S. 568, 575, 108 S.Ct. 1392, 99 L.Ed.2d 645. (1988). This =gunmen: stems from our pmdagial desire not to needlessly reach constitutional issues and err assumpdoa than Congress does not casually authorize administrative agencies to interpret a *173 statute to push the limit of congressional authority. See fMd. This concern is heightened where the administrative interpraation alters the federal -state framework by permitting federal encroachment upon a traditional state power. See United States v. Ban, 404 U.S. 336, 349, 92 S.Ct. 515, 30 L.E.d_2d 488 (1971) ('[U]nless Congress conveys its purpose clearly, it will not be Cope. 0 West 2002 No Claim to Orig. U.S. Govt. Works • hurl a e—..i • a a ((Ste as: 531 U.S. 199, 0173, 121 S.Ct 675, "683) deemed to have significatab' changed the federal - sate balance-). Tina, "where an otherwise acceptable construction of a statute would raise salons constitutional problems, the Conti will consume the taamte to avoid such problems unless such construction is play copy to the intent of Congress.' De-Ranolo, supra, at 575, 108 &Ct. 1392. Twice in the past six years we have reaffirmed the proposition that die grant of authority to Congress under the rummer a Clause_ ,hough broad, is not intim* d. See trotted Staa v. Monson. 529 U.S. 598, 120 S.Ct. 1740, 146 L.Ed.2d 658 (2000); linked Stet v. Lopez 514 U.S. 549, 115 S.Ct. 1624, 131 L.E4.26 626 (1995). Fa that BirdRulefalls • ower m�ctulate intrastate activities that :� *ablat . They note note that the protec — of mreraton' birds is a "name= interest of very nearly the fust magnitude,' Minoan v Hoamrd 252 U.S. 416, 331a'S.Ct. 382, 64 L.Bd 641 (1920), and that, u the Court of Appeals found. matins of people spend over a billion dollars annually on recreational pursuits relatiug to migratory birds. These • argnmems raise significant consrimtioml questions. For example, we would have to evaluate the precise object or activity that, in the aggregate, substantially affects interstate cummasm. This is not clear, for although the Corps has claimed jurisdiction over petitioner's land because it contains water areas used as habitat by migratory birds, respondents now, Pau l rem 474 focus upon the fact that the regulated activity is petition's municipal landfill, which is 'plainly of a commercial nater.' Brief for Federal Respondents 43.. Brtt ibjs • •tares m Which the statute by lsie 0174 These are significant constitutional questions raised by respondents' application 00684 of their regulations, and yet we find nig approaching a clear stance from Congress that it intended § 404(a) to reach an abandoned sand and gravel pit here. Permitting respondents to infer jurisdiction ova ponds and mudflats falling within the 'Migratory Bird Rule' world result in a significant impingement of the States' traditional and primary power over land and water we. Sets, e.g., fest v. Pon Authority nuns - Hudson Corporation, 513 U.S. 30, 44, 115 S.Ct. 121 5.0. 675 • • • Page ss 394, 130 L.Ed.2d 245 (1994) ('[Rjegulation of land use Os) A tmcttoa traditionally performed by local governments"). Rather than expressing a desire to readjust the federal- state balance in this matuser. Congress chose to 'recognize, preserve, a= protect the primary responsibilities and rights of States ... to plan the development and me ... of land and water resources ....' 33 U.S.C. § 12$1(b). We thus read the stance as written to avoid the significant' constitutional and federalism quesdons raised by respondents' itderprctnion, and therefore' reject the request for administrative deference. [F148] FNS. Beouse violations of the CWA carry criminal penaidess. see 33 USX. f 1319(c)(2). perldoner invokes the sob of lenity as another barb for relearns the Corps' imeepmatbo a the CWA. Brief for petitioner 31.32. We need net address this alternative argamorn. See Haired Stam v. 5habimd, 513 V.S. 10, 17, 115 S.C. 382, 130 L.Ed.2d 225 (1994). We hold that 33 CFR § 328.3(0)(3) (1999). as clarified and applied to petitioner's baleSII site pursuant to the 'Migratory Bird Rule.' 51 Fed -Reg. 41217 (1986), exceeds the authority granted to respondents aria § 404(a) of the CWA. The judgment of the Cont of Appeals for the Seventh Circuit is therefore Reversed. Justice STEVENS, with GINSBURG, and 1111 .2 ._ J Justice SOUTER. BREYER join. In 1 the Cuyahoga it Cleveland. Ohio, coated a slick of ' waste, caught fire. Congress r 75 to that dramatic event, and to others le enacting the Federal Water Pollution Conte • (FWPCA) Amendments of 1972, 136 Stat. 8 , amended, 33 U.S.C. § 1251 et Sat.. •• •• .. •-•e% as the Cham Ware Act (Clean Water CW or Aa). [PN1j The Aet proclaimed ambltio goal of ending water pollution by 985. § 1251.. The Court's past iatetp s:tad of the have been fhlly consistent' . that goaL though Congress' vision of zero pollution =fulfilled, its pursuit unquestionably the destruction of the aquatic environment. Our ,''s waters no longer bum. Today, however, or Court takes Copt. 4) West 2002 No Clain to Orig. U.S. Govt. Works • OZARK HEADWATERS GROUP ARKANSAS SIERRA CLUB Not Blind Opposition to Progress but Opposition to Blind Progress A RESOLUTION IN SUPPORT OF ENVIRONMENTALLY SENSITIVE LANDS AT THE PROPOSED WILSON SPRINGS BUSINESS PARK WHEREAS the described. lowlands constitute an ecologically valuable natural resource as evidenced by: • Seasonal and perennial wetlands • Over 130 documented species of birds • The Ozark Burrowing Crayfish, endemic to eight counties in Arkansas • The presence of the largest population of Arkansas Darters in Arkansas documented to date, a candidate for listing under the Endangered Species Act • Tall grass prairie. vegetation, characteristic of the rarest ecosystem in Arkansas and North America, and • WHEREAS this parcel provides ecological services to the community including: Stoim watei detention • Water quality purification, and WHEREAS future uses for this property include: • Multi -use trail corridors 1itf4l*.2?i!ijtJittt1 €dluIhiuur11 NOW, THEREFORE, BE IT RESOLVED BY THE EXECUTIVE COMDH17TTEE OF THE SIERRA CLUB OZARKS HEADWATERS GROUP: Supports the preservation of all lowlands, as definedby the southern line of elevation at which all hydfic soils begin, on the Wilson Springs Business Park property located within the city limits of Fayetteville, AR Passed September 5, 2002 S • CJ September 23, 2002 The following is a response to the Guest Commentary written by Gary Coover appearing on September 22, 2002. 1 respectfully request that you publish my comments. Gary Coover's guest commentary of September 22 addressed a number of biological/ecological issues that are largely outside his field of technical expertise, which is that of hydraulic engineer. As a member of the Mayor's Task Force on Wilson Springs and its hydrology sub -group, I had expected Mr. Coover to provide some information on engineering aspects and construction costs of building on seasonal wetlands. Instead, he provided several misleading comments on biological/ecological issues that may confuse Times readers. As a biologist, I have been involved in direct assessment of the Wilson Springs site, and I have collected substantial scientific information from other scientists and the US Fish and Wildlife Service concerning a diverse collection of species that inhabit the Wilson Springs site. Thus, I am concerned about possible misinterpretations of several statements included in Mr. Coover's commentary. First, Mr. Coover mentions "obvious wetlands" and "low-grade wetlands" at the Wilson Springs site. There is an inference that "low-grade wetlands" are of little value. Ecologists prefer to distinguish between these lands as perennial wetlands (having standing water on them all year around) and seasonal wetlands (wet during part of the year — in this case, several months of the year). The seasonal wetlands of the Wilson Springs site are remnants of mesic (wet) prairie supporting rare and declining species of plants and animals including the Henslow's Sparrow. Contrary to Coover's comments, Northwest Arkansas is within the historical range of Henslow's Sparrows. They have been found throughout the nesting season in the seasonal wetlands at the Wilson Springs site the past two years. Additionally, Mr. Coover's superficial analysis of the relationship of the Arkansas Darter to other species at the site is simply not consistent with biological fact. He suggests that the Ozark Burrowing Crayfish threatens to eat Arkansas Darter eggs. In fact, it is a crayfish that lives in the groundwater of the seasonal wetland fields..There'are no fish in those fields to lay eggs upon which the crayfish could feed — certainly no Arkansas Darters. The Ozark Burrowing Crayfish is an endemic species to eight Northwest Arkansas counties, which means it lives in only those eight counties - counties that are undergoing rapid urbanization. Thus, there is no basis for the statement that the species is in no danger of decline. September 23, 2O02 To: Wilson Springs Task Force • From Andrea Radwell Follow-up comments related to Status Report dated July 9, 2002 Site Assessment • Highland and lowland differentiation • perennial and seasonal wetlands functioning as an ecosystem • Delineation of wetlands — vegetation issue, "mitigation" areas • Characteristics of northwest quadrant • Fragmentation issue Wetland Legislation — looking beyond short-term gain. • Biodiversity issue — looking beyond single species (darters, sparrows, crayfish) Ecological services — EPA Storm water Phase 11 • Irreversibility associated with development Candidate Conservation Agreement for Arkansas Darter • US Fish and Wildlife Service — no endorsement of changes in Clabber Creek or storm water flow • Sewer project to go through the Wilson Springs site • • Review of condition of Clabber Creek Legal aspects of mitigation • US Army Corps of Engineers — lowest common denominator of environmental protection — encouragement to take control at the local and regional level. • EPA and Army corps Memorandum of Agreement, February 1990: o Avoidance clause — must show that the proposed use cannot occur on other land... economic hardship is not just cause. o Minimization clause — impact must be justified —no other option. • Recommendation of a legal opinion. How should restoration be accomplished? • The Nature Conservancy and Audubon offers • Grant possibilities — strengths of our position o Preliminary biological assessment — candidate fish species, 130+ bird • species, endemic crayfish, tall grass prairie species o Location within a watershed identified to have water quality problems o Opportunities to study recovering channelization, analyze effectiveness of wetland in providing water purification, tall grass prairie restoration, etc. o www.mudwompers.ore - organized body of information. o People with credentials and commitment Mr. Coover suggests engineering projects intended to improve Arkansas Darter habitat • including re-establishing the "sinuosity" of Clabber Creek and diversion of storm water run-off from I-540. Neither of these costly engineering. proposals has the support of the US Fish and Wildlife Service, which the City has agreed to work with to establish a Candidate Conservation Agreement for the Arkansas Darter. Finally, let me add that I believe the Task Force is making a strong effort to analyze the scientific facts and best data available to arrive, at a sound multi -disciplinary recommendation that will be in the best interests of the citizens of Fayetteville. My hope is that Mr. Coover will contribute some of those facts related to his engineering expertise. Andrea Radwell . Research Assistant/PhD. Candidate Department of Biological Sciences University of Arkansas Home address: 2233 Elaine Avenue, Fayetteville 575-3534 (office) no messages — use email aradwell@uark.edu 443.6539 (home) messages may be left at this number • CI 5 October 2001 • Headquarters, U.S. Army Corps of Engineers ATTN: CECW-OR 441 G St NW Washington DC 20314 -1000 Dear Sirs: We are submitting this letter as an official comment on the Army Corps of Engineers Proposal to Reissue and Modify Nationwide Permits, the notice of which appeared in Federal Register, Thursday, August 9, 2001 (Vol 66, No. 154, pp. 42070 - 42100). The undersigned are senior aquatic scientists with broad knowledge and expertise in stream ecosystems including their physical structure, chemistry, and biology. Scientists who have signed this letter include members of the National Academy of Sciences and its scientific Boards, individuals who have been. president of national scientific organizations, and leading authors on the ecology, water quality, and biota of streams and rivers. According to law, Nationwide Permits are to be used only for activities that have minimal cumulative adverse effect on the aquatic environment. Because headwater streams provide valuable ecological goods and services for the public good, their elimination from stream networks has an adverse impact on riverine ecosystems. The available scientific evidence clearly demonstrates that the length of headwater streams in the • landscape has been significantly reduced because of the mining and development activities that have been permitted under this program. For example, suburban development around Rock Creek in Maryland reduced the drainage density (m stream channel / m2 watershed area) by 58% (Leopold 1994); drainage density of urban and suburban watersheds in the Chattahoochee River basin near Atlanta is one third less than drainage density in watersheds covered in forest and pasture (Meyer and Wallace 2001). At least 1450 km of streams were eliminated in the Southern Appalachians from 1986 - 1998 because of mountain -top removal valley -fill coal mining practices (U.S. Fish and Wildlife Service 1998). Untold miles of streams in the midwestern U.S. have been converted into drainage ditches that route water quickly out of the watershed. Because of their simplified channel structure, they no longer provide the ecological services of unchannelized headwater streams (Brookes 1994). This loss of headwater streams has profoundly altered the structure and function of stream networks, just as eliminating fine roots from the root structure of a tree would reduce its chances of survival. The accumulated scientific evidence points to numerous significant consequences when headwater streams are lost (Meyer and Wallace 2001). For example: • The loss of the hydrologic retention capacity provided by headwater streams (i.e. the ability to hold and store water) results in increased frequency and intensity of flooding downstream as well as lower base flows.(e.g. Dunne and Leopold 1978). • • • Increased frequency and intensity of flooding results in increased channel erosion downstream (e.g. Trimble 1997). • Reduced retention of sediments in headwater channels leads to excess sediment transport downstream; sediment accumulation in larger streams and rivers can affect fish spawning success and stream productivity (e.g. Waters 1995). • The predominance of organic debris dams in headwater streams (e.g. Bilby and Likens 1980) provides sediment retention, important habitat structure, and sites for critical metabolic activity (e.g. Steinhart et al. 2000). These important functions are eliminated when headwaters are channelized, piped, or filled. • Filling of stream valleys by mountain -top removal valley -fill coal mining has resulted in a greater proportion of fine particles in stream sediments amid an altered flow and temperature regime downstream of the filled valleys (Wiley et al. 2001). Substrate particle size, water temperature, and flow regime are physical parameters with significant impact on the biota of a stream (Allan 1995) . • The basic chemical. composition of unpolluted streams draining a landscape is largely established in headwater streams (Gibbs.1970, Likens 1999, Johnson et al.2000). • Small streams in the network are the sites of the most active uptake and retention of nutrients (Alexander et al. 2000, Peterson et al. 2001); hence elimination of small streams from the network results in increased downstream transport of nutrients. Recipient systems like lakes, estuaries, coastal waters, and ground waters may be sensitive to the resulting high nutrient concentrations with eutrophication and groundwater contamination being likely consequences of loss of the nutrient retention capacity afforded by headwater streams.. Headwater streams are sites for physical and biological processing of inputs of organic matter from the watershed such as falling leaves (e.g. Wallace et al. 1997) and a source of energy for downstream. reaches (Kaplan et al. 1980). The dissolved organic matter and fine particles exported from headwaters are important food resources for ecosystems downstream (Vannote et al. 1980). Hence the elimination of •small streams from the landscape can resultin reduced inputs of food resources for downstream ecosystems. Small, spring -fed headwater streams can serve as thermal refuges for fishes, providing a refuge from freezing for stream fishes during winter (e.g. Power et al. 1999) and cool refuges for young -of -the -year during summer (e.g. Curry et al. 1997). Etheostoma cragini, a federal candidate darter species, uses small first order streams as a summer time refuge from heat and drought (Radwell 2001), • In karst regions, small streams contribute to the recharge of subterranean phreatic and cave aquifers that harbor unique species. For example, small streams in the Ozarks enter caves that harbor threatened and endangered species of cave fishes, crayfishes, • amphipods and other organisms. The water quality and quantity in these small streams is important to the continued existence of the subterranean fauna (Elliot 2000). • Headwater streams provide unique habitats for numerous species. Their degradation and elimination from the landscape increases extinction vulnerability for aquatic invertebrate (e.g. Morse et al. 1993), amphibian, and fish species (e.g. Etnier 1997). For example, small headwater streams provide essential breeding habitat for a federally endangered darter species (Etheostoma boschungi). In addition, some terrestrial species are also dependent on high quality headwater streams. For example, the Louisiana Waterthrush (Seiurus motacilla) shows a strong habitat preference for unpolluted headwater streams (Prosser and Brooks 1998). Given the strong evidence that alteration of headwater streams has extensive cumulative adverse effects, we would argue that Nationwide Permits should not be used to allow filling or piping of stream channels in stream networks where previous development -or mining has resulted in a reduction of the network drainage density. In those drainage basins, there has already been a measurable cumulative effect of past permitting actions, and hence future permitting should require site -specific evaluation with extensive mitigation. Continued permitting of these activities under a Nationwide Permit without careful individual site review by personnel that include qualified aquatic biologists will result in further cumulative effects that can be experienced on site and far downstream. Furthermore, mitigation should be required for any piping or filling of streams covered by the Nationwide Permit system. As documented above and discussed in greater detail • in Meyer and Wallace (2001), the United States has already lost thousands of miles of headwater streams from the landscape. It is time to recognize the ecological services provided by these ecosystems, just as we recognize the services provided by wetlands. Mitigation should be required when even short lengths of these small streams are destroyed. We are concerned about the project -specific waiver of the 300 foot prohibition proposed by the Corps. We question the scientific basis for the argument that a stream that is "a six-inch wide by one inch deep area running for several thousand feet throughout a grassy upland field" may provide "few, if any aquatic functions." That type of stream can support a diverse and sometimes unique community of aquatic organisms. For example, in western Oregon, the number of invertebrate. taxa in intermittent streams exceeded that of permanent headwaters, and several undescribed species were associated with intermittent streams (Dieterich and Anderson 2000). The slackwater darter (Etheostoma boschungi) breeds in tiny streams, many of which are now small ditches flowing through pastures (Mettee et al. 1996). The trispot darter (Etheostoma trisella) attaches it eggs to submerged blades of grass in tiny rivulets that flow from ephemeral ponds in fields (Ryon 1986). We question the change in General Condition 19 which would waive the requirement of one -for -one mitigation of wetlands by allowing substitution of vegetated buffers in cases where the Corps determines that buffers would provide more effective mitigation. • Vegetated riparian buffers clearly have considerable value, but they do not always • provide the same benefits as wetlands. For example, the capacity of vegetated buffers to remove excess nitrogen is dependent on the extent to which the soil is saturated and the availability of sources of organic carbon (e.g. Hedin et al. 1998). In addition, wetlands provide habitat for a different suite of biota than would a vegetated riparian buffer. Without a clear statement of the criteria to be evaluated when deciding if vegetated buffers could substitute for wetland mitigation, this change could result in decisions that would be detrimental to the ecosystems it was designed to protect. : 1 'In'' jg 1 1 1 1' 1 til1 ItiI 1 goods: 1 1 n, 1 1 1 1 1 1 1 1 I: 1 : 1' I I I 1 1 1goods1 1 n 1 1 1 I' ' 1 1 1 : 1 1 11 1 1 1 :: 1 1 1 1 1 1 1 : I I I: I 1 1 1 1 1 11 1 Permitprogram 1 : 1 11 I 41 1 I.' I I 1 1. 1 1' • 1 I: 1 1 1 1 1 11 1 1 1: 1 ' II L • We appreciate this opportunity to comment on the proposed changes in Nationwide Permits. Dr. Judy L Meyer Dr. J. Bruce Wallace, Professor Distinguished Research Professor* Dept of Entomology and Institute of Institute of Ecology Ecology University of Georgia University of Georgia Athens GA Athens GA Dr. Gene Likens President' and Director Institute of Ecosystem Studies Millbrook NY Dr. Richard W. Merritt Professor, Departments of Entomology and Fisheries and Wildlife Michigan State University East Lansing MI Dr. Barbara L Peckarsky Professor Entomology Department Cornell University Ithaca NY Dr. Kenneth W. Cummins Senior Advisory Scientist California Cooperative Fishery Unit Humboldt State University Arcata CA Dr. David D. Hart Vice President and Director Patrick Center for Environmental Research Academy of Natural Sciences Philadelphia PA Dr. Stuart Fisher Professor Department of Biology Arizona State University Tempe AZ Dr. Cliff Dahm Professor Department of Biology University of New Mexico Albuquerque NM Dr. Stanley V. Gregory Professor Department of Fisheries and Wildlife Oregon State University Corvallis OR Dr. Gene Helfman Professor Institute of Ecology University of Georgia Athens GA Dr. Robert Naiman Professor Aquatic and Fishery Sciences University of Washington Seattle WA Dr. Margaret A. Wilzbach Assistant Leader Cooperative Fish Research Unit Humboldt State University Arcata CA Dr. Louis A. Kaplan Senior Research Scientist Stroud Water Research Center Avondale PA Dr. Margaret A. Palmer • Professor Department of Biology University of Maryland College Park MD Dr. Vincent H. Resh Professor of Entomology Environmental Science, Policy & Mgmt. University of California Berkeley CA Dr. Gary Lamberti Professor and Associate Chair Biological Sciences Department University of Notre Dame. Notre Dame IN Dr. Walter Dodds Professor Division of Biology Kansas State University • Manhattan KS Dr. John C. Morse Professor Entomology Department Clemson University Clemson SC Dr. Amy D. Rosemond Assistant Director Institute of Ecology University of Georgia Athens GA • U ci • N ti y. . k , ' � fl 111 i Vv �4 j \ I � II 1r, ( II Under the land sales method, we have: Property Taxes Attributable to Park (146 Acres with land value of Property Tax Distribution Mills Property Tax Fayetteville Schools 44.00 $127,600 City of Fayetteville 0.80 $2,320 Washington County 7.16 $20,764 General Funds 5.00 $14,500 County Roads 1.16 $3,364 Library 1.00 $2,900 Total 51.96 $150684 Property Taxes Attributable to Park (38 Acres with land value of Property Tax Distribution Mills Property Tax Fayetteville Schools 44.00 $83600 City of Fayetteville 0.80 $1,520 Washington County 7.16 $13,604 General Funds 5.00 $9500 County Roads 1.16 $2,204 LIbrary 1.00 $1,900 Total 51.96 $98,724 Under the cost approach, we have: Property Taxes Attributable to Park 38 Acres f $1.9M) Property Tax Distribution Mills Property Tax Fayetteville Schools 44.00 $83,600 City of Fayetteville 0.80 $1 520 Washington County 7.16 $13,604 General Funds 5.00 $9,500 County Roads 1.16 $2,204 Library 1.00 $1900 Total 51.96 $98,724 • • • n L Under the indicated value via cost method, we have: Property Taxes Attributable to Park 38 Acres I $4.2M) Property Tax Distribution Mills .Property Tax Fayetteville Schools 44.00 $184,800 City of Fayetteville 0.80 $3,360 Washington County 7.16 $30,072 General Funds 5.00 $21,000 County Roads 1.16 $4,872 Library 1.00 $4,200 Total 51.96 $218,232 The taxes generated from the property using the market value of the property, under the subdivision analysis method are: Property Taxes Attributable to Park 38 Acres I $3.7M) Property Tax Distribution Mills Property Tax Fayetteville Schools 44.00 $162,800 City of Fayetteville 0.80 $2,960 Washington County 7.16 $26,492.. General Funds 5.00 $18,500 County Roads 1.16 $4292 Library 1.00 $3,700 Total 51.96 $192,252 The taxes generated from the property using the value in -use of the property, under the subdivision analysis method are: Property Taxes Attributable .to Park 38 Acres! $5.IM) Property Tax Distribution Mills Property Tax Fayetteville Schools 44.00 $224,400•• City of Fayetteville 0.80 $4,080 Washington County 7.16 $36,516 General Funds 5.00 $25,500 County Roads 1.16 $5,916 Library 1.00 $5,100 Total 51.96 $264,996 .J.",.'Cl[•\��'•� i�f of� 'Jl l � n J'_ fl ` •I �\ I� - iLk 'i_,,-xi�^�"-r"Th!J��lL1}F���+'u iTTJ"�'1455_T- ,>. .a �N�.a.�•��si.n 1�,... K_Aw i !1. aKi. ♦F �.\` ..ri 1..n fl l .vC�' •.... . ', wr iu -i.0 ;4,.t, *. .r. tl si \T/1• \\ i iT • ti ll�SP; .__a_/-_._N.—_�fW.� ]; -.fl .Biel lr• j�• i ll • �. •11 • • •11 • 1 •: Finally, what are the tax implications to the City of Fayetteville of non -development of the property where the Park is to be located? EJ First, if the City of Fayetteville owns the property, no property taxes are generated • from the land. Fayetteville School Millage = 44 mills. Fayetteville City Millage = 0.80 mills. County Millage = 7.16 (5.0 to general funds, 1.16 to county roads, 1.0 to the library) Total = 51.96 mills Changes in November. Taxes = Total Assessed Value * (0.001 * Millage) Source: Washington County Assessor's Office The Real Estate Consultants conducted an appraisal of the property. They appraised 38 acres of the property using the land sales method and the cost method, the indicated value via the cost method, the market value using a subdivision approach, and the value in -use using a subdivision approach. The following tables show the property taxes generated by the I-540 business park under these conditions. • • Based on the sales tax study conducted by the Center for Business and Economic • Research for the City of Fayetteville, we estimate the that consumer units with incomes between $30,000 and $39,999 spend 37.4 percent of their income on taxable expenditures (see Table 11 of Sales Tax Study). Multiplying this by the city's sales tax rate of 1.75 percent, we estimate the sales tax burden for this income group to be 0.65 percent. Likewise, for consumer units with incomes between $40,000 and $49,999, we estimate they spend 36.5 percent of their income on taxable expenditures.. Therefore, we estimate the sales tax burden for this income group to be 0.64 percent. Based on these estimates, we can make an estimate of the sales tax revenues for the City of Fayetteville, shown below. Annual Fayetteville Sales Tax Revenue Generated from Incomes of Park Workers 15% 107 • H -: LI • SOC Mean Code Annual Standard • Occupation Grouping Number Salary Error Low 111 b • Management 11-0000 $56,960 2.3% $53,585 $60,335 • Business and Financial • Operations 13-0000 $36,030 . 2.5% $33,710 $38,350 • Computer and Mathematical • Occupations 15-0000 $45,410 5.0% $39,561 $51,259 Architecture and Engineering Occupations 17-0000 $42,570 3.5% $38,732 $46,408 Security Guards 33-9032 $19260 8.3% $15142 $23,378 Building and Grounds Cleaning • and Maintenance 37-0000 $17,050 2.0% $16,172 $17,928 Sales Representatives, Wholesale and Manufacturing, Technical and Scientific • Products 41-4011 $31,080 8.5% $24,275 $37,885 • Sales Representatives, - Wholesale and Manufacturing, .Except Technical and Scientific products 41-4012 $45,610 7.7% $36,563 $54,657 Office and Administrative • Support Occupations 43-0000 $20,900 1.0% $20,362 $21,438 Average Salary oil -MO Business and Technology Park - Worker $37630 $33,296 $41,965 Source: U.S. Commerce Department, Bureau of Labor Statistics, Occupational Employment Statistics, Fayetteville -Springdale -Rogers Metropolitan Statistical Area, Year 2000 • Office • A combination of office and retail • Technology office The following table presents a list of categories of potential occupations at the Wilson Spring Business and Technology Park. We feel that one.in ten workers at the park will be a security guard, building/grounds worker, cleaning person, or maintenance worker. The, salaries have been weighted according to this assumption to yield an average annual salary for a worker at the Park. The remaining occupations have been weighted evenly. • • Appendix • The following tables detail the method used to estimate the economic impacts from • various levels of development. The first table indicates the total acreage that would be covered by non -parking structures under each scenario. The ratio of building to total space is estimated at 15 percent. This is a conservative estimate. Source: UACDC.. Net Acreage Developed Phase I A B C 15% Density 9.5 15.5 18.3 21.2 The figures in the preceding table can be translated to square -feet (1 acre = 43,560 square -feet) to estimate the amount of office space will be available in a two-story buildings based on the density assumptions. Office Space (Square Feet) - 2 stoiyBuilding Phase I A B C 15% Density 824,970 1,346 004 1,594 296 1,842 588 For an office environment, the building should allow for 200 to 400 square -feet of space per employee (includes hallways, restrooms, etc.). Source: UACDC Number of Employees at Park Phase I A B C • 15% Density 4 124. 6,730 7,971 9,213 • Assumption: I worker per 200 square feet of space Number of Employees at Park Phase I •A B C 15% Density 2,062 3,365 3,986 4606 Assumption: 1 worker per 400 square feet of space We assume that the buildings at the site will be predominately office space. We can not, ex ante determine what percentage would be related to technology versus other uses, however, even non -technology companies employee significant numbers of technical employees such as IT professionals. _To estimate the economic impact of the employees working at the site we first assume they work within the following defined job categories: • s Admittedly, the two-story assumption is just that, an assumption Per our discussions with developers, this is a conservative estimate. A question from the audience asked whether other land that the City had in possession • could be utilized for soccer fields. Several individual pieces of property were discussed but each had its own obstacles. The Wilson Spring site was considered preferable to others discussed. This report does not attempt to ascertain the need for a soccer complex; however, in any development scenario, the section desired by the Parks Department would probably be the last to develop and, due to a suspected high water table and soil type, could well be the most expensive on which to install the infrastructure as well as develop a specific project. Notwithstanding these factors, the potential benefit to the city of developing and selling these sections rather than utilizing the acreage for Parks is estimated gross proceeds of approximately $6,000,000*. *This figure was derived using a sales rate of $2.75 per square foot for 50 acres of land. • • • and start construction by the first quarter of 2003. Construction is estimated to be • complete within 18 months. The Northwest Regional Office of the Arkansas Game and Fish Commission would employee a full-time staff of ten with additional resources including field staff and enforcement that would increase the number of people that impact this area from 30 to 40. This facility would serve six counties through enforcement, administration and education. Outreach and education from this facility will be a main focus. Hunting and Boating Safety courses will be held, along with in -class programs for the area schools and in- house training for the area teachers. They will be "Training the Trainer". Should Game and Fish choose to provide expertise and oversight to protect and enhance the wetlands, this would constitute a significant benefit to the city. Other partners to consider would be the U.S. Fish and Wildlife, the Nature Conservancy, and the Audubon Society. A potential second benefit would be the long-term relationship the Arkansas Game and Fish Commission have with the U.S. Army Corps of Engineers. They lend credibility to the project and can help expedite the process. Don Nelms presented a request to the Task Force to consider leasing 300 acres for the • Audubon Society to manage. Their goal would be to build an Audubon Nature Center at the site and partner with the Arkansas Game and Fish Commission. Their plans would include trails through the natural wildlife habitat area. Although they will not consider .building if the available land is less than 300 acres, the Audubon Society is willing to assist the City of Fayetteville with evaluation at the site. The conclusions drawn by the sub -group regarding the aforementioned proposal is as follows. Partnership with Arkansas Game and Fish provides several benefits.. First, an initial tenant with plans to create the type of structure desired at the site. Second, they provide expertise to assist in the management of the wetlands area. The benefit of such collaboration would have significant additional non -monetary value. Further, the center provides an outlet for study of the eco-system, enhancing its value to the citizens of Fayetteville: Given the nature of the environmental amenity, lack of use as an opportunity to educate and inform citizens significantly reduces the value of the site to the City of Fayetteville City of Fayetteville Parks Department Kyle Cook, representing the Parks and Recreation Advisory Board, presented the Task Force with a proposal to utilize 50 acres. on the north end of the acreage to be used for a community park that included soccer fields and walking trails. Questions from the Task. Force included the use of herbicides and fertilizers on the site. This site was preferred by the parks department due to the visibility from I-540, easy access off I-540 and the land • being level. 0 • Please note that the property tax calculations are based only on land value. We have not • estimated the value of whatever improvements would be made to the property after sale. Therefore, these estimates should be viewed as conservative. The estimate for land value is based upon $3-$4 per square foot per the market analysis. Finally, several comments have been made regarding the potential economic impact of preservation. These would accrue from the following potential sources: 0 Grants to study the site 0 Grants/gifts for preservation 0 Tourism by birders/others 0 Increased property values from.preservation of green space 0 Recreation through use of trails It is all but impossible to do more than list potential granting sources that might be interested in the site. In addition to the site characteristics, the potential to generate dollars is a direct function of the quality of the researchers seeking funding, the quality of the proposed study, the interests at any given point in time of the funding group, and the availability of funds in any given year. With regard to tourism, this is a potential source of revenue from hotel visits, restaurant meals, etc. The impact is a direct function of the number of visits to the city from birders outside the community. Also, to directly impact the economy of Fayetteville, the meals and hotel stays would have to be consumed in Fayetteville. • Finally, the value of green space is inversely related to the quantity at any given point in time. The greater the density of the development in the area, the more the preserved area will be worth. To ascertain the non -market value of preservation of the site or some part of the site, we would have to survey the population of Fayetteville as to the value they ascribe to the site. Inference from value estimation studies of green space in other locations is a dubious path at best. Arkansas Game. and Fish, Audubon and Parks The Arkansas Game and Fish Commission approached the Task Force with a desire to build their Northwest Regional Office at the Wilson Springs Business and Technology Park. Their desireis to build a 7,500 sq. ft. to 8,000 sq. ft. structure on 5 acres with a plan design that can be expanded upon to serve the population growth for the next 15 to 25 years. The 2002-2003 budget for the Arkansas Game and Fish allocated $100,000 for the architectural design and the commissioners have committed up to one million dollars for building the facility. As a signature site, they are looking for a design that blends with the natural beauty of the • surroundings. Their.goal would be to have a design ready by the end of January 2003 Summary Table of Economic Impacts from Development 0 kW p sa a. �4 b ap M N Lc { 'fL4 N U.a R In G fl V t4 O O 1001W OD >" NW W ;Oc DWI M.+ WZa'yj t, :1{JQ O OD ,p), 000 LL N c') N O) iD M 5, O LLOD y M awn f/Ql at144"." ci r OD LL V 2 ? F w w Q v o allo Z on 00 V w OO_-CN-W r r r O Q U) O O O 3 N M C1 0 C C 8 Ii. CD - tow to� 8r' c V w m r C 1111 •, O O 1 'OW ) o n a 0 O N d E E v V co 8 . C W m m NO •5 c c W 2 E fl ''U O C 00z3 z 3 j. � N M V • Z • i • ''The "net profit" for the 38 acre tract was derived as follows: Estimated Discounted Net Proceeds $ 5,100,000 Less: Infrastructure Costs $ 1,220,000 Current Land Value 1,900,000 3,120,000 "Net Profit" $ 1,980,000 Revenue Projections The table found below compares the potential revenue from each of the three options proposed by McClelland Engineers for development of the property. The estimated infrastructure costs are from the McClelland report, and the gross revenue estimates are taken from the appraisal by "The Real Estate Consultants." No projections are made for. 1. The timing and phasing of the land sales 2. The (infrastructure) development of the project in phases 3. Any future appreciation of the land values 146 acres of developed lands 127 acres of developed lands 100 acres of developed lands $ 17,000,000. $ 14,000,000 $ 13,700,000 6 Note: The 146 acre development option includes $425,000 for mitigation costs & the 127 acre development option includes $12,500 for mitigation costs Phasine Development Per our research, the wisest course of action for the development of the project would be to plan for the entire development, including the amount of lands in the wetlands areas, the mitigation plan, if any, the Corps of Engineers permits, and the overall development plan of the project. Then, commence the project infrastructure in phases, moving forward from one phase to the next based on the logical extension of the infrastructure and on demand by purchasers. Financial Evaluation of 38 -Acre (Phase 1). The appraisal by The Real Estate Consultants, completed in June, 2002, contains information and value indications concerning the development of a 38 acre tract of the project's lands. These lands lie at the southeast comer of the property adjacent to the I-540 freeway and Moore Lane. The following is a summary of the projections and value indications, for that 38 acre tract, found in that appraisal. Estimated Absorption (or sell out) Period - 5 years Total Estimated Gross Proceeds (not discounted to present value) - $ 6,480,000 Total Estimated Net Proceeds (not discounted to present value) - $ 5,832,000 Total Estimated Net Proceeds (discounted to present value at 5%) - $ 5,100,000 Estimated Cost of Infrastructure - $ 1,220,000• Estimated "net profit" - $1.980.000** Notes: 1. The appraisal indicates that the current Market Value of this 38 acre portion of the site, is $1,900,000. 2. The appraisal also indicates that the current Market Value of the 146 acres of the site, that being the portion that has presumed development potential, is $2,900,000. * This number was derived using the estimate of $1,900,000 from the appraisal less grant monies the City has already received for infrastructure costs, in the amount of $679,200. • • • haul networks between cities NOT the high-speed connections linking businesses and homes to the network. Even the over -supply of long -haul fiber may be overstated.3 Cost of Construction of Buildings and other Improvements During the course of several task force meetings, it was suggested that the cost of construction of developing buildings and sites in a future development would be very costly and, possibly, prohibitive. No specific information of actual construction costs has been offered and, therefore, we cannot make any substantive comment on this matter. However, it should be pointed out that other major developments in the area have been accomplished, on similar types of lands, and appear to have been economically viable. Competitors In addition to the comments regarding the cost of development at the site, several comments have been made that question why anyone would build on a site with the associated difficulties of the Wilson Spring site when other parcels are available in the region. It is true there are other lands in the region that offer some of the convenience advantages and could be competitors to the proposed development. However, those developments are, generally, priced considerably higher than the prices projected for Wilson Springs. These other sites are primarily retail oriented sites, which do not lend themselves to a business park climate, or nodes at major interchanges on Interstate 540.° • In Fayetteville, the primary site for this type of development is the CMN Business Park, located south of the Northwest Arkansas Mall. Recent tenants in this development include Kohl's, Target, Party City, and an Olive Garden Restaurant, which is under construction. Current offering prices for land in this area average approximately $7.00-7.50 per square foot, 5 depending on the parcel size. Market Demand Because of a unique combination of location, access to major transportation route -Interstate 540, physical beauty, and technology infrastructure, Wilson Springs Business and Technology Park would little direct competition in the region. The site offers the potential for an upscale, high profile, campus style development. 3 According to an article in ebn by Bruce Gain and Darrell Dunn, a small but growing number of analysts say the world's telecommunications diet needs more fiber despite the massive layoffs, inventory write -downs, and lack of visibility that have plagued the sector. The article continues with Neil Dunay, analyst at RIM Corp., Providence, RI., remarking, "To say there's a glut is to overstate it" he said. "Instead, I would say the (telcos) were future - proofing their networks. The original business plan was not to light every fiber optic cable that was in the ground." A March 2002 article in the USA Today asked the question "Is the market really facing an oversupply of network capacity? In a word, no." says a report from research firm TeleChoice. The report adds that 63% of busy routes - those between big cities - are running at or near capacity. 4 Developments such as CMN have very high costs per square foot These high costs usually preclude office space because the economics do not justify paying the premium • 'Thu is roughly double the projected price for the Wilson Spring site. Market Factors Influencing Development of the Wilson Spring Business and • Technoloey Park The objective of this section of the report is to project the viability of developing the lands as a Business and Technology Park. Included in the section are the following topics: 0 Site description 0 Area and regional influences, including competition and general economic status of Northwest Arkansas 0 Possible phasing options of developing the project 0 A comparison of potential revenues of the development based on the information from the Appraisal completed by The Real Estate Consultants in June, 2002, and the estimates of infrastructure costs developed by McClelland Engineers in May, 2002, and revised in August, 2002. General Site Description The project contains approximately 289 acres of land. It contains significant frontage on Shiloh Drive, which is the frontage road for Interstate 540, Deane Soloman Road, and Moore Lane. All utilities, except sewer are to the property, including a major city water line that runs east to west, south of Clabber Creek and a looped fiber optic telephone cable (redundancy) that runs through the property. Sewer service will be served on the north side of Clabber Creek by a new 48" • gravity line that will connect to the new west side sewer plant and south of Clabber Creek by a lift system to exiting sewer service in Moore Land and Deane Soloman Road. Fiber Optic Network Two separate routes of fiber optics serve the Wilson Spring Business and Technology Park, connecting the park and SBC Southwestern Bell's digital central office. This provides a state of the art telecommunications network from the Park to the network, which connects to the global telecommunications network. The presence of fiber at the site enhances its attractiveness to potential tenants. . The digital fiber optic -based information infrastructure provided is capable of transporting voice, data and video at extremely high bit rates, at the highest quality. The redundant routes to the central office are uncommon. Redundancy guards against service interruptions, an attribute information -intensive companies find desirable. Business -parks with this level of infrastructure were once unique, now they are almost a necessity to be competitive for business location. Various cities are marketing fiber parks with success. For example we point to a partnership between St. Louis and St. Charles, Missouri. During the task force meetings, the question was raised as to the perception of a fiber glut in our nation. The Telecommunications Act of 1996 attempted to increase competition, thus driving demand and traffic for high -bandwidth services. The result has been a glut of fiber in the lonr` • • amount of wetland that is being preserved undisturbed, credits may be negotiated to reduce the amount mitigation required. • C1 0 established a classification system (Cowardin System) as a basis for identifying, classifying and • mapping wetlands and other special aquatic sites. The EPA and the Corps use the 1987 Corps of Engineers Wetlands Delineation Manual to define wetlands for the Clean Water Act Section 404 permit program. The 1987 manual organizes environmental characteristics of a potential wetland into three categories: soils, vegetation, and hydrology. The manual contains criteria for each category. With this approach, an area that meets all three criteria is considered a wetland Utilizing the 1987 Corps of Engineers Wetlands Delineation procedures, EGIS Environmental Consultants delineated 84.37 acres of jurisdictional wetlands in August 1999. The resulting wetland map was subsequently submitted to the U.S. Army Corps of Engineers for review and verification. Project activities resulting in greater than 0.5 -acre impact on jurisdictional wetlands (or greater than 300 lineal feet of stream) require an individual permit from the USACE before construction can commence. The basic premise of the program is that no discharge of dredged or fill material can he permitted if a practicable alternative exists that is less damaging to the aquatic environment or if the nation's waters would be significantly degraded. In other words, when you apply for a permit, you must show that you have: 0 taken steps to avoid wetland impacts where practicable, p minimized potential impacts to wetlands, • 0 provided compensation for any remaining, unavoidable impacts through activities to restore or create wetlands. Selecting the 146 -acre development option results in a concomitant 17 -acre impact to isolated pockets of forested and emergent wetlands and emergent marsh thereby necessitating an application for an individual permit. Typically, the permitting process requires a public notice followed by a 15 to 30 public comment period. However, because of the public involvement surrounding this project, these requirements have already been fulfilled. What remains, however is the development of a well -reasoned mitigation plan to "compensate" for the unavoidable impact to wetlands. It is assumed that this plan can be developed within two months of receiving notification of the preferred development option. Upon receiving the application, the USACE will evaluate the application, based on comments received from cooperating agencies and from internal review and conduct an internal environmental assessment before issuing a Statement of Finding, a publicly available document explaining how the permitting decision was reached. While the details of the mitigation plan are not known at this time, site analysis has shown that there are excellent opportunities to mitigate the impacts on -site. In fact, mitigating the loss adjacent to the forested wetland and bottomland hardwoods associated with Wilson Spring will result in one large contiguous wetland preserve, which greatly facilitate its management, maintenance and value as a educational resource. It is anticipated that the cost of mitigation will be from $10,000 to $25,000 per acre. Assuming a full one-to-one mitigation is required that would result in $170,000 to $425,000 in additional project cost. However, because of the . • • County is probable. The creation of a strong retailing base to the north will undoubtedly have significant impact on the tax base of Fayetteville. This, in turn, will significantly affect the ability of Fayetteville to make the types of investments necessary to accommodate demands for amenities by current/future residents, develop/improve infrastructure to accommodate growth of existing businesses, or attract new businesses to the city. The city of Fayetteville faces the distinct possibility that new retail development, driven by the disparate growth of population and income between Bentonville/Rogers and Fayetteville, will diminish the available tax base relative to that of Bentonville/Rogers. This reduction will reduce. the ability of the city to foster, through strategic investment in infrastructure, growth of knowledge -based industry within city limits. Fayetteville has no control over the growth and increased purchasing power in Benton County; however it does have the capacity to engage in activities that build on the assets that we do have in place, the most visible and most valuable to this effort beipg the University of Arkansas. The development of the Wilson Spring Business and Technology Park improves the tax base, providing funds that can directly be used to fund infrastructure investment to build on our current assets like the University of Arkansas2. Preservation of the Wilson Spring site provides an environmental amenity. Whether or not technology based industry chooses to locate at the Wilson Spring site, the city of Fayetteville's ability to make strategic infrastructure investments is in direct relation to the tax • base. Removing acreage form the tax base reduces the ability of the city to compete for high wage jobs. Failure to compete for high wage jobs reduces the attractiveness of Fayetteville as a location for retailing, further eroding our tax base and our ability to foster knowledge -based industry. Careless development of the site erodes the set of environmental amenities which are critical to attracting skilled professionals. The focal point of the discussion must be the optimal mix of preservation and development. Section 404 Permit Section 404 of the Clean Water Act establishes a program to regulate the discharge of dredge or fill material into the waters of the United States, including wetlands. Activities in waters of the United States that are regulated by this program include fills for development. In common language, wetlands are areas where the frequent and prolonged presence of water at or near the soil surface drives the natural system meaning the kind of soils that form, the plants that grow, and the fish and/or wildlife communities that use the habitat. Swamps, marshes, and bogs are well -recognized types of wetlands. However, the U.S. Fish and Wildlife Service have 2 For example, creating the climate for knowledge based industry through assisting to provide infrastructure for die • Arkansas Research and Technology Park. In addition, an important issue currently being discussed by a wide range of groups is the type of • growth we as a set of communities would like to see. The region has depended heavily on the growth of Wal-Mart and Tyson to lead the way. Indeed, growth in these and other large area businesses has facilitated rapid expansion.of both employment and the tax base. Unfortunately the economic base of Northwest Arkansas does not include adequate employment opportunities for graduates from area institutions of higher education. That is, employment opportunities for individuals with high levels of educational attainment are extremely limited. The type of growth we choose to pursue dictates what investments local municipalities will need to make in the coming years. Public discussions regarding what type of growth residents of the region would like to occur overwhelmingly supports the development of high -wage jobs correlated with high levels of educational attainment and clean industries. Development and/or recruitment of this type of industry would accomplish several goals. • 0 Diversify the regions economy. 0 Improve the tax base, directly improving financing for education, and other services. 0 Improve the tax base and facilitate the development of amenities, both cultural and environmental. 0 Provide employment opportunities for graduates of area institutions of higher education. 0 Maintain our high qualityof life. Unfortunately, our ability to attract this type of industry has been severely hampered by the lack • of an educated workforce. Conversely, we have great difficulty retaining the best and brightest graduates of the state's research institution, the University of Arkansas. This is essentially a chicken and the egg problem. The solution from a public perspective is investment in critical infrastructure, which improves our ability to attract both knowledge -based industry and the employees it depends upon. Growth of knowledge -based industry implies both continued immigration of talented professionals from other states, AND a reduction in the emigration of bright talented Arkansans to benefit the economies of other states. However, public investment requires funding sources. The City ofFayetteville- Fayetteville has both been influenced by and contributed to the rapid growth of the region. Fayetteville continues to benefit relative to its neighbors from unique set of attributes such as location, recreational, cultural, and educational amenities, the growth of the University of Arkansas, and its retail base. Growth has significantly increased the demands for publicly provided services and the ability of Fayetteville to fund those demands. Initially, this would seem to imply that the city is in prime position to compete for knowledge -based industry. Unfortunately, Benton County's near -term growth, both in terms of population and relative income levels could soon have a substantial impact on retailing in Fayetteville and subsequently, the tax base of the city. As the differential growth rate occurs, development of new retail establishments, as well as the potential for relocation of existing retail establishments to Benton • • WILSON SPRING TASK FORCE ECONOMICIDEVELOPMENT REPORT- • JEFF COLLINS, GEORGE FAUCETTE, CATHY FORAKER, JOHN LEWIS, AND PHIL STAFFORD Introduction This document represents the findings to date of the sub -group for economics and development of the Wilson Spring Business and Technology. The sub -group report details the synthesis of our research, experience, and expertise in determining the value to the city of Fayetteville of development of the Wilson's Spring Business and Technology Park. . The report is divided into six (6) sections. These are: • 0 Appraisal and Market Analysis 0 Wetlands and 404 Permitting 0 Economic Impact Analysis .0 Trade-offs 0 Arkansas Game and Fish, Audubon, and City of Fayetteville Parks 0 Economics of Preservation • This report represents the collaborative effort of the members of the economic and development sub -group: Jeff Collins, George Faucette, Cathy Foraker, John Lewis, and Phil Stafford. Fayetteville Regional Challenges - Northwest Arkansas has experienced incredible economic activity and population growth over the last decade. However, future growth in the region is not assured according to conclusions from a recent report sponsored by the Northwest Arkansas Council. The report indicates that serious concerns exist as to whether growth can be sustained in the mid to long term in the region without implementing a specific strategy targeted at developing/supplementing key infrastructure (cultural, environmental, educational, economic, etc.). Therefore, despite significant past growth along the entire north -south corridor, from Fayetteville to Bella Vista, future growth driven by the relatively narrow economic baser of Northwest Arkansas is in doubt. The report by the Northwest Arkansas Council points out that much of the growth in the area has been driven by the growth of Wal-Mart, Tyson, etc., and resulting growth of the vendor community. It is further noted that these • firms are unlikely to continue to increase their employee population at a pace approximating that experienced over the last decade. 1 '. {))V �p�i 5. i. � .�_ms x'`•\ �-• V f i�''gqTc�- r f'!�T i aT �+16Sn .o ,w�� yI- ♦ •� W _ �ryiY mgrs,- c�..dG 39 e. .pY -d --- --F tSQ•T y C':. • yi• v Y •c ��S i•cl• .^l t '- �^ Z t✓."' {���'� �.^"-'-!. ` .ors+. ,. Fa• � Ste• _.�n� - a•. ter•. oy�5 �. rt �yy� • � ,.-A 'Lx'v.at -a- �"`La' ��°��a .w. . Ems . '�'.: fl BIRD LIST AS OF JUNE 1, 2002 FOR THE WILSON SPRINGS FIELDS & FOREST (Site of Proposed B/T Park) • Sp = Spring, Su = Summer, F= Fall,' W = Winter ■ BOLD = Partners -In -Flight SPECIES OF CONCERN in Central Hardwoods region nesting or probably nesting in the park * = annual rate of decline at least 1.5 % range wide in USGS North American Breeding Bird Survey 1966-1999 • This is a list -in -progress. Species and seasons will change as more data is collected. For more information, contact Mike Mlodinow 443-2663. Pied -billed Grebe Sp. 'American Bittern Sp Great Blue Heron Sp, Su Green Heron Sp. Su • Black-cr. Night -heron Sp - Turkey Vulture Sp, S14 F, W Black -Vulture S)p Canada goose .5), Wood Duck Sp, & F Gadwall Sp, F W American Wigeon W Mallaid Sp. S14 F, W Blue -Winged Teal Sp, F Northern Shoveler W Green -Winged Teal Sp, F, W Coops Hawk Sp. F Red -shouldered Hawk Sp Red -t Hawk Sp, Su, F. W American Kestrel Sp 'Northern Bobwhite Sp,Su Sora Sp Killdeer Sp Spotted Sandpiper Sp. Rock Dove Sp Mourning Dove Sp.Su 'Black -billed Cuckoo Sp 'Yellow -b. Cuckoo Sp,Su Great Homed Owl Sp Common Nighthawk Sp Barred Owl Sp. 'Chimney Swift Sp Ruby-th. Hummingbird Sp 'Belted Kingfisher @Su Red -bellied Woodpecker Sp Downy Woodpecker Sp,Su 'Northern Flicker Sp 'Olive -sided Flycatcher Sp 'E. Wood -Pewee Sp Scissor -t. Flycatcher Sp.Su 'L. Shrike (season?) White -eyed Vireo Sp,Sri' 'Bell's Vireo Sp, Si, Blue -headed Vireo Sp Warbling vireo Sp Red -eyed Vito Sp Blue Jay SpSu American Crow SASu Fish Crow Sp Purple Martin Sp Tree Swallow Sp' No. R. -w. Swallow SpSu. • Barn Swallow Sp,SL Carolina Chickadee Spsu Tufted Titmouse %,$'iWhite-breasted Nuthatch Sp Carolina Wren Sp,Su House Wren Sp Sedge Wren Sp, F, IV.. Marsh Wren Sp, F, W Rubx-crowned Kinglet Sp' Blue -g. Gnatcatcher Sp.Su • Eastern Bluebird Sp •. .. • Swainson's Thrush Sp American Robin Sp • Gray Catb rd Sp Northern Mockingbird Sp,Su 'Brown Thrasher Sp European Starling Sp Cedar Waxwing Sp, Su Tennessee Warbler Sp Orange -crowned Warbler Sp Nashville Warbles Sp Yellow Warbler Sp -Magnolia WarWersp Yellow-ru. Warbler Sp, F. W Black-th. Green Warbler Sp Yellow-tb. Warbler Sp • Mourning Warbler Sp Com.Yellowtliroat Sp, S14 F Wilson's Warbler SP . 'Yellow-br. Chat Sp, Sp Summer Tanager Sprn 'EasteTowhee Sp Cbpp+ng Sparrow Sp . Clay -colored Sparrow 'Field Sparrow Sp, Su 'Lark Sparrow Sp Savannah Sparrow Sp 'Grasshopper Sparrow Sp F 'Henslow's Sparrow Sp, Sit Le Conte's Sparrow Sp, W • Fox Sparrow Sp, W Song Sparrow Sp, F W Lincoln's Sparrow Sp • Swamp Sparrow Sp, F W White-tb. Sparrow Sp, F, W 'White -crowned Sparrow Sp Dark -eyed Junco Sp No. Cardinal Sp, SuF W Rose -breasted Grosbeak Sp - • Blue Grosbeak.Sp,Su- ... Indigo Bunting Sp, Si, 'Painted Bunting Sp, Su 'Dickclssel Sp, Si, Red-Wnged Blackbird Sp,Su 'East Meadowlark Sp, So 'Common Grackle Spsu Br. -headed Cowbird Sp,Su 'Orchard Oriole Sp Baltimore Oriole Sp House Finch Sp American Goldfinch Sp,Su Alder Flycatcher Sp Willow Flycatcher Sp, Su Least Flycatcher Sp Eastern Phoebe Sp Great Cr. Flycatcher Sp Eastern Kingbird Sp F, Pt t$4r), • We encourage the City of Fayetteville to seek grants for wetland restoration, research, and education. Such funding is available, and the unique nature of the site (the presence of a rare fish species) greatly improves the prospects for procuring these funds. C. Position • Loss of suitable habitat and degradation of habitat are the primary causes for the imperiled status of Arkansas darter populations. It is therefore the position of the University of Arkansas Student Subchapter of the American Fisheries Society that concerted effort to protect and restore habitat should be the highest priority in efforts to • maintain the viability of the Arkansas darter population in Fayetteville. . Wilson Springs lies within an approximately 285 -acre parcel that was purchased by the City of • Fayetteville in 1990. Wetland delineation has revealed approximately 85 acres of wetland and another 55 acres of Clabber Creek floodplain that has a water table near the land surface most of the year. Additional acres have been described as having emergent wetland properties. Wilson Springs lies near the north end of the parcel surrounded by wetland and the Clabber Creek floodplain. Portions of the south and southwest comer of the property (approximately 100 acres) lie outside the wetland or floodplain designation. Proposed development of a business/technology park by the City of Fayetteville poses an imminent threat to the Arkansas darter population. However, City officals have voiced their commitment to an environmentally responsible development that would provide protection to the Arkansas darter population. Hence, this position paper is intended to provide recommendations that would assure long-term protection of Wilson Springs and the adjoining habitat that is essential for the survival of the Arkansas darter population at this site. B. Recommended Actions • Development plans should maximize preservation of Wilson Springs, adjoining wetlands, and the portion of Clabber Creek and its tributaries in the development area Development should be restricted to south and southwest areas outside the designated wetland and Clabber Creek floodplain. • Every effort should be made to avoid mitigation of wetlands. While mitigation is intended to compensate for loss of wetlands, the wetlands in this situation support habitat for the . Arkansas darter population. Compensation under these circumstances is problematic. • 'I• Development plans for dry areas of the parcel should consider the physical, chemical, and biological impacts on adjoining wetlands. • In view of the aforementioned lack of research studieb on most aspects of the Arkansas darter population and the hydrological features of Wilson Springs, we recommend a conservative approach to management. Because Wilson Springs Is presently sustaining a viable Arkansas darter population, no changes in the spring run are recommended. No hydrological changes should be made without appropriate study of recharge zones and storm water discharge. The City should recognize that obtaining such information wiU require time. _ The City of Fayetteville should work cooperatively, with the U.S. Fish and Wildlife Service to develop a Candidate Conservation Agreement for the Arkansas darter and to receive restoration and management recommendations. The City should support long term monitoring of the biological, physical, and chemical attributes of Wilson Springs and the wetlands. The University of Arkansas AFS Student Subchapter can play a continuing role in stewardship. • Restoration efforts should focus on returning the Clabber Creek flood plain to its original wetland state. This will require removal of pasture grass and revegetation of wetland species. • We encourage the City of Fayetteville to seek a conservation easement for Wilson Springs and the adjoining wetlands from a conservation organization that can provide protection in • perpetuity L i • • • • UNIVERSITY OF ARKANSAS STUDENT SUBCHAPTER OF THE AMERICAN FISHERIES SOCIETY POSITION ON ARKANSAS DARTER (Etheostoma cragin►) HABITAT PRESERVATION WITH SPECIFIC REFERENCE TO THE WILSON SPRINGS/FAYETTEVILLE POPULATION A. Issue Definition and Background The Arkansas darter (Etheostoma cragint) is named for its association with the Arkansas River drainage. The American Fisheries Society has assigned a status of vulnerable' to the species because of its dependence on spring -fed, vegetated headwaters and creeks that are plagued with environmental problems. The U.S. Fish and Wildlife Service has reported that the Arkansas darter is in jeopardy across its range due to decline in groundwater that replenishes spring -fed habitats. In October 1999, the Arkansas. darter was designated a. candidate species for listing under the Endangered Species Act In Arkansas, 5 populations of Arkansas darter were known in 1985, all in headwater tributaries of the Illinois River in the northwest corner of the state. Currently, the existence of only 3 of those populations has been confirmed. Two populations are found in Benton County, and a third is found within the City of Fayetteville, Washington County. The Fayetteville population was first discovered during the planning of the US. Highway 71 bypass (now Interstate 540) around Fayetteville in 1979. The former director of the Arkansas Game and Fish Commission, Steve Wilson, found the population prior to construction. Completion of the highway actually resulted in the main springhead being covered by the highway, and a culvert system was built to extend the spring flow beneath the highway and offramp to its current outflow. The City adopted. the name Wilson Springs for the spring run, and the University of Arkansas AFS Student Subchapter has provided stewardship of Wilson Springs since 1994. The Wilson Spring run consists of two perennial springs that flow into Clabber Creek Numerous small springs and seeps are evident in wetlands surrounding the spring run. Sampling of Arkansas darters by the AFS Student Subchapter members during winter spawning (February 2000) indicated seasonal migration into Clabber Creek Channefization of Clabber Creek In 1990 has resulted in an unstable channel structure that is constrained by a buried waterline on one side. Change toward a natural meandering pattern is evident along some sections, but much of channel remains unstable. Small tributaries are less impacted by -structural change than the main channel but are subject to multiple problems associated with the urban environment These small tributaries may provide Arkansas darter habitat during cold, high flow periods in the winter. The Wilson Spring run is the essential refuge in summer when Clabber Creek and its tributaries become intermittent. While Wilson Springs is recognized as critical habitat for the Arkansas darter, no formal studies have been undertaken to describe the life history of the darter population including its migratory patterns. The recharge zones for the springs have not been delineated, and no hydrological data is available on the discharge of storm water from the Interstate 540/Highway 112 interchange into Wilson Springs. Toxic spills from vehicles present a potential threat to the recharge zone of the springs, and storm water discharge could carry toxic materials Into the spring. It can be speculated that the large volume of water that flows into the springs during storms is sufficiently dilute to have allowed the darter population to survive these conditions for over 20 years, but no monitoring of water quality has been done. Studies to address these issues are greatly needed. . I Lance -leaved Coreopsis Coreopsis lanceolata • False nettle Boehmeda cylinddca • Goldenrod Solidago pelicans Lady thumb Pologonum persicaria Horse nettle I Bull nettle Sdanum carofinense Cocklebur Xanthium strumarium Purple thistle Cirsium carolnianum Watercress • Nasturtium of Idnale Chickweed Stellirfa sp. Queen Ann's Lace Moss Corn Salad Wild Iris Dandelion Bedstrain Dead Nettle French Mulberry Unidentified Afium Unidentified Umbelliferae Rosacea Sismybrium sp. Ranunculus abortiuus Vibemum prurriolium fl TREES AND SHRUBS • Honey Locust Gleoftsia biacanthos Smooth Adler Alnus serrulata Greenbrier Smilax bona-nox Red Cedar Juniperus virginiana Wlnterberry flex vertidllate Hackberry Celds occidentalis Red Mulberry Morus tubra American Elm Ulmus ameticana . Persimmon Diospyras virginiana Black Locust Robinia pseudo -acacia Common Privet U'gustnrm vulgate Black Oak Quercus velutina Black Cherry Prunus serobna Post Oak Quercus stellate Blacyack Oak Quercus marflandrea Sycamore Plantanus oc identalis Bittemut Hickory Carya cos nbnnls Red Hickory Carya oveNs Shagbark Hickory Carya ovate Black Hickory Carya texana White Hickory Carya tomentosa White Ash Frardnus americana Green Ash • Fraxinus pennsylvanica • Blue Ash Fraranus quadrangulata Wilson Springs Biological Inventory 5 American Fisheries Society Student Subchapter Northern Bobwhite Mourning. Dove Yellow -billed Cuckoo Ruby -throated Hummingbird Downy Woodpecker Pileated Woodpecker Red -bellied Woodpecker Eastern Wood -pewee Acadian Flycatcher Blue Jay American Crow Tufted Titmouse Carolina Chickadee White -breasted Nuthatch Carolina Wren American Robbin Blue -gray Gnatcatcher European Starling Red -eyed Vireo Yellow -throated Vireo White -eyed Vireo Northern Parula Ovenbird Red -winged Blackbird Northern Cardinal Indigo Bunting Scarlet Tanager Summer Tanager FUNGI Lichens PLANTS (60 species) Herbs/Weeds/Grasses Gooseberry Arrow weed Common chicory Plantain White Heath Aster Japanese Honeysuckle Common Ragweed Great Ragweed New England Aster Pokeweed Poison Ivy Broad-leaved Arrowhead Colinus virginianus Zenaida macroura Coccyzus amedcanus Archilochus colubris Pica/des pubescens • Dryocopus pileatus • Melanerpes carolinus Contopus vixens Empidonax vinscens Cyanocitta cristata Corvus brachyrhynchos Baelophus bicolor Poedle canvlinensis Sitta carolinensis Thryothonis ludoridanus Turdus migratodus Poliopila caerulea Stumus vulgaris Vireo olivaceus Vireo flavfions Vireo griseus Panda americans Lymnothlypsis aurocapillus Agelalus phoeniceus CarcUnalic card/nails Passerine cyanea Piranga olivacea Piranga nib►a Rubes missouriends. Sagittaiia let/foils Chicodum intybus Plantago major Aster pilosus Lonicera japonica Ambrosia millefolium Ambrosia trifida Aster novae-angiae Pytolacca americana Toxicodendron red/cans Sagittaria latifdia Wilson Springs Biological Inventory American Fisheries Society Student Subchapter Iv • I• ARACHNIDA Spider Mite Harvestmen Pseudoscorpion VERTEBRATES (56 species) AMIPHIBIANS American Toad Spring Peeper Southern Leopard Frog Bullfrog Spotted salamander REPTILES Three toed box turtle Common snapping turtle Five -fined skink Ribbon snake Blotched waters flake Pack Rat snake Speddedlingsnake FISH Mosquito fish Green Sunfish Arkansas Darter MAMMALS Virginia Opossum Eastern Mole Eastern Cottontail Grey Squirrel House mice Red fox Racoon Striped skunk White-tailed deer Nine- banded Armadillo L Sri Oribatldae Opiliones Pseudoscorpiones Bufo americans Hyla crucifer Rana utdculada Rana totes beinana Ambystoma maculatum Terrapene carolna Chelydra serpentine Eumeces fasclatus Thaminophis proximus Nevada eiyfhmgaster transverse Elaphe obsolete • Lampropettis geltda Gambusia aflinls Lepomis cyaneflus Etheostoma cragini Didelphus virginiana Ste !opus aquatacus Syhvilagus floridanus Sdunrs carofonensis Mus musadus Vulpes vulpes Procyon Jo toe Mephitis meph/6s Odocoileus virginianus Desypus novemdnclus Canis Iabans Fells catus .Red-tailed Hawk Buteo jamaicensis • Wilson Springs Biological Inventory 3 American Fisheries Society Student Subchapter 0. • ARACHNIDA • Spider Aransas CRUSTACEA • Crayfish Orconectes sp. • Isopod (aquatic sow bugs) Lirceus sp. • Isopod (groundwater -adapted) Caecidotea sp. MOLLUSCA • Snail Physidae ROUNDWORMS • Nematode • CHILOPODA Millipede INSECTA • Beetles Carabidae. • Curculionidae • Psephenidae •• Staphilinidae Coilembda Entomobryidae Poduridae. Sminthuridae Diptera . Ceratopogonidae • Chironomidae (2 sp.) Forcipomyiinae • Psychodidae Micropeyidae Tipulidae Homoptera Cleadellidae •Cicadellidae • Hymenoptera Formiddae Termites. Lepidoptera Cosmopterigidae Pyralidae Tortriddae • Phthiraptera Psocoptera ura Diplipluran Thysanoptera Phlaeothripidae Wilson Springs Biological Inventory American Fisheries Society Student Subchapter 2 • PROTISTS - AQUATIC • Diatoms (16 species) Cocconeis sp. Cymatopleura so/ea Cymatopleura ellipilca Cymbella ehrenbergfl Cymbella sp. 2 Cymbella sp. 3 Fragillarfa sp. Gomphonema acuminatumm var. coronata Gy►osigma sp. Melosirs vadens Navicula radosa Navicrda sp. 2 Navicula sp. 3 Stanionefs sp. Surirells mbusta vat. splendda . Synedra sp. Green Algae (2 species) • Mougeotia sp.. Clostedum sp. • Other (3 species) cyclopoid copepods (and nauplil) ostracods dadocerans INVERTEBRATES — AQUATIC (17 species) INSECTS Mayfly Baetis sp. Water striders Guems sp. Trelobates sp. Broad- shouldered water striders Mrcmvelle sp. Mosquitoe Anopheles sp. Midges Bryophaenocladus sp. Dbra.sp. Crane fly Alderfly Sialis sp. Rove beetles Stems sp. Dragonfly Odonata Damselfly Hetaedne sp. I.. Wilson Springs Biological Inventory American Fisheries Society Student Subchapter • . • Because of its low elevation relative to the rest of the area, the Wilson Springs site is acting as a natural detention area for storm water. The lowlands of the • area are providing ecological services by retaining and purifying water. Development in the area in the last few years has increased the need for these services. According to City officials, developers will be required to build in such a way as to minimally affect the hydrology of the site including the use of permeable pavement, grass swales, no curbs, etc. The question has been raised as to. whether such measures can reasonably be expected to mitigate for the hydrological changes that may likely occur in association with development of the lowlands of the parcel, • ECONOMIC ISSUES • The goals for development are unclear to the public, and the present demand for business real estate development has been called into question. Over the past 12 years, the stated purpose of development at the site has changed several times. Those changes are reflected in the series of names — North Industrial Park, Arkansas Research and Technology Park, Arkansas Business • and Technology Park, and the most recent suggestion — Wilson Springs Business Park. • • Basic economic information is lacking — the City finally received an appraisal of the property five months after the development was proposed.- Citizens have posed numerous questions regarding the economics of the project that remain unanswered. • Estimated mitigation costs have been reported to be from $12,000 to $25,000 per acre, This is a very large investment of taxpayer dollars. The value of this investment has been called into question. Attachments: • . Map!- site with COE wetland delineation • Map 2- development proposal favored by City Administration • American Fisheries Society Student Subchapter Biological Inventory • American Fisheries Society Student Subchapter Statement of Position on the Arkansas Darter • Bird List for Wilson Springs Fields and Forests by Joe Neal and Mille MIodinow • • Page 27 of Wilson Springs site appraisal completed by The Real Estate Consultants, June 21, 2002. • WILSON SPRINGS Site Status Report . 6 • • The recharge area for Wilson Springs has not been delineated. Development could adversely affect the quality and quantity of ground water that maintains the springs. • Observations indicate that the Arkansas darter has a migratory pattern, but no formal study has been done. Hence, the impact of bridges over Clabber Creek and its tributaries on the life history of the Arkansas darter is unknown. • The proposed bridge over the tributary flowing northwest into Clabber Creek and the bridge over Clabber Creek are passing through an area that exhibits wetland characteristics. The City has suggested preservation of an approximately 3 -acre parcel in that area, but construction of two bridges is included in the development plan. Construction of these bridges may be complicated by wetland conditions. A test pit in that area retained water at or near the land surface during the observation period from March through May. • The Corps delineation was based on meeting the requirements of wetland hydrology, hydric soils, and presence of hydrophilic plants. It appears that portions of the lowlands covered in pasture grasses were not designated as. wetlands because of the lack of hydrophilic plants. It is difficult to differentiate ecological function between designated and non -designated areas on this site. Hence, there is little assurance that building in the pasture grass areas will not adversely affect the lowland ecosystem as a whole. • • Earlier this year, the City Administration suggested changing storm water patterns at the main Wilson spring head and modifying the Clabber Creek channel as part of a Candidate Conservation Agreement for the Arkansas • darter. Neither of these ideas presently has the support of the US Fish and • Wildlife Service, and no new ideas have been offered. It is the position of the • American Fisheries Society Student Subchapter and US Fish and Wildlife Service that habitat preservation should be the most important component of an agreement. This requires consideration of. all risks associated with roads, bridges, and other structures. • The, plan includes extensive development of lowland areas not formally designated as wetlands. Observations suggest that seasonal wetlands are far more extensive than reflected in the official wetland designation of 85 acres. These lowlands are utilized by numerous birds and crayfish, as well as species yet to be identified. • Areas that were designated as "mitigation areas" appear to have wetland • characteristics. The status of these areas needs to be determined. The use of these lands for mitigation has been called into question. It appears that I. mitigation of these lands will not compensate for loss of other wetland acres, • and will therefore result in a net loss of wetlands at the site. WILSON SPRINGS Site Status Report 5 • Presence of crayfish burrows throughout lowland grassy areas indicates thigh • water table. Ground water is supporting crayfish and organisms upon with they depend. • Wetlands have been delineated on the parcel adjacent and north of the Wilson Springs site. During storms, water flowed from the adjacent parcel onto the northwest quadrant of the site.t t+ 4c,(',L' .-c. DEVELOPMENT PROPOSAL - ISSUES AND CURRENT CONCERNS The Fayetteville City Administration has proposed development on the Wilson Springs site. They have formulated 3 options, but they have indicated that they favor the option shown on Map 2 that is enclosed. It impacts 17 acres of the 85 acres of designated wetlands and will require mitigation for loss of these acres. Infrastructure shown on Map 2 suggests that the plan would have large-scale impacts on the grassy lowlands that were not designated as wetlands. It includes 3 bridges — one over Clabber Creek and two over Clabber Creek tributaries. The following issues and concerns have emerged since early 2002: • Page 27 is enclosed from Appraisal Report, City of Fayetteville, I-540 Business and Technology Park, Fayetteville, AR, by The Real Estate Consultants, 118 N. East Avenue, Fayetteville, AR 72701. This page summarizes information provided by McClelland Engineering that is relevant to the suitability of the site for development. This information raises serious questions about the whether the City should promote the sale and development of lowlands with "wetness a severe hazard" in some areas and "an extreme hazard" in others. It indicates the necessity for "drilled pier systems" and "above average ground preparation" to "offset potential problems with standing water" for a good portion of the acreage. These • problems suggest that avoiding major hydrological impacts on the area from development would be an extremely challenging task and probably an unrealistic expectation. . • The area is known to have unique geological features that may complicate development particularly in the lowlands. Local residents have reported such problems in the Clabber Creek corridor. Developers who choose to build in the lowlands have no assurances that they will not encounter costly problems associated with soil types not supportive of development, high ground water, and long-term problems associated with ground faults. WILSON SPRINGS Site Status Report 4 S current status is unknown. Species is endemic to area that has undergone urbanization over the past 14 years. • Plants: rare grass species have been identified on the site by Dr. Chuck West, agronomist, University of Arkansas. HYDROLOGICAL OBSERVATIONS • Wilson Springs maintains perennial flow. It receives large amounts of storm water from the I-540 and Hwy 112 interchange. Last water quality sampling was done in April 2001— showed some impairment (described as typical of water from an urban area). . • Clabber Creek was channelized in 1990. The stream banks are now stable in terms of sediment load — there is no obvious stream bank erosion. Parts of the channel are filled with marsh plants and signs of development of a new sinuous channel are apparent. • Observations made this year suggest that the wetlands in the 500 year flood plain of Clabber Creek are more developed than they were five years ago. Increased discharge into Clabber Creek as a result of large-scale development in the headwaters may account for progressive wetland development along Clabber Creek, Observations made on at least 7 trips to the property from mid February to early June revealed all lowlands indicated on Map 1 to be inundated with water regardless of whether land was classified by the US Army Corps of Engineers as wetlands or not. Lowland areas consist of a mosaic of wooded wetlands designated as such by the Corps of Engineers and non -designated areas planted in pasture grass. All lowlands (as described on Map 1) appear to be functioning as a contiguous seasonal wetland. s, c°• All test pits (3-4 feet deep) on designated wetlands as well as non -designated ti. s• j v� r° grasslands retained water at or near the land surface, during the observation V '` ` period from mid February to early June 2001 • Dr. Van Brahma hydrogeologist, Department of Geoscien U v of it ces m etstty Arkansas has indicated that the area has unique geological features responsible for wetlands. Fault lines run through the area and continue down the Clabber Creek corridor. Clay soils do not wholly account for standing water in the lowlands. Test pits indicate a high water table. • • • 3 • • BIOLOGICAL OBSERVATIONS General Biological Inventory: See enclosed Wilson Springs Biological Inventory of protists, invertebrates, vertebrates, fungi, and plants compiled by students at the University Arkansas in conjunction with the American Fisheries Student Subchapter. Arkansas darter (Etheosroma cragim): a study completed by Chad Hargrave in 1998 (Coop Unit Publication No. 30 - Arkansas Cooperative Fish and Wildlife Research Unit, University of Arkansas, Fayetteville) estimated the Arkansas darter population in the Wilson Springs run to be. the largest of the three known populations in the state. Sampling of Clabber Creek and the tributary from the north during spawning season (early 2000) suggested migratory patterns that require further study. The smaller tributary flowing from the south may also be seasonal habitat See American Fisheries Society Student Subchapter Statement of Position for additional background information. Status: Candidate for listing under Endangered Species Act since October 1999. One of three known populations in Arkansas. The species has protective status in all states in which it occurs. Birds: 125 species identified on site by ornithologists Joe Neal and Mike Mlodinow. Includes wetland species and some species dependent on grasslands. See Bird List for the Wilson Springs Fields & Forests. Joe Neal has indicated that he does not consider the list complete — he expects other species to be identified. Status: Information from Partners -In -Flight Species of Concerns and USGS Bird Survey of birds in decline is included on the Bird List Crayfish: Ozark burrowing crayfish (Procambarus liberorum) from the northwest quadrant identified by. Dr. Art Brown and Mike Slay, Department of Biological Sciences, University of Arkansas. Burrows throughout grassy lowlands suggest it is widespread on the site and may playa major role in the food web supporting a wide range of species in the lowland areas of the parcel. States: Endemic to only 8 counties of northwest Arkansas. Description of status dates back to 1988 - shown as abundant and stable at that, time, but WILSON SPRINGS Site Status Report 2 I. WILSON SPRINGS SITE STATUS REPORT July 9, 2002 SITE DESCRIPTION (see Map 1) • 289 -acre parcel located near 1-540 and Hwy 112 owned by City of Fayetteville since 1990 • South end — elevated, dry land with an approximately 8 -acre woodland — remainder of the parcel is lowland — see approximate line on Map 1 that distinguishes between high and lowland areas • Lowland area includes designated wooded wetlands, land planted with pasture grass, Clabber Creek flood plain, and Wilson Springs • Elevation difference - 1270 ft at south end —1200 feet near Wilson Springs • 85 acres of wetlands designated by US Corps of Engineers shown in cross- hatched area of Map 1— designated on basis of hydrology, hydrophilic plants, and hydric soil MAJOR PHYSICAL FEATURES In. .lL u: .c :.. sm : . L. L 11kk. ...:. .I:. WILSON SPRINGS Site Status Report • • July 9, Ta Members of the Task Fo ssessing the Wilson Springs site • .L.JDepartment• • • • L K 1 • •I • .1 w't ii II FILl) 7.• • '4 .'L• 1 1 liii C u 1 - L • 1• • 1accumulation •: 11 • I • I • 1 , " Wilson •' 1 ' V 1 " q • 1 1: I 1 " :11 • C 11 : 1 • " • • • 1 111 • " • 1 • 1 •' 1 P: ' • >. 1 O 1 - • 1 1 . ` •- ' 1 1 • - 1. identification •: population •I 1 ' 1 on • 1 1the • 1: 1 • • - die11 ✓. 1 t'iFisheries• • L1• • 1 - •' 11 1 •' ,Y. 1 ' became11 - • •: :.M 1 1 immediateM •: •' ' r • • ' 11 . • 1 'J: . 1 1 • 1 11Students Y: v, • w • 11 • 1 • • 1 41 1 :I r • . "1' 1 •' �: much . •: 1." •: 1• -1 • 11 r- 1 n l: •" 1 I L a• 1 1 •, " •' 1 1 - 1' 1 1 N 1•" •• 1• d 11 - 1• 1• 1 • 1 •\ 1 -, • •' L Y•1. ' 111' 1- • •••. �• 1," •'1'11-1 ii.,t- • 1 • • K 1 •• 111 1 ✓. YI •I Lct 11 11 - providing • L f 11 •.,,,;!,r..I11 • • I ✓. 1 • I/1 11 • 1 • •1 11 ••' •'I1. •: ry.: 11 • 11 1 •'1 11 1 K • L 1 •"• 1. 1 1- 1 1 •+ V• 1 1 I• 1- ✓ •' Y 1• Y •' 1 1: M 11 1 11 1 q I:k• I I 1 • 1 4. 1 •. • 11 . 11 •: 1 11 " 11 • ' • • Y I 'l: : l • ' 11 • : ! 11 •il ll Id • •: informationee 1 . 1 '• : 11 . 1 • I N 1.• •LI Y' • wl Y. I w: • 11 1• ' • • 1 ' • 1 • 1 • !,r - , 11 L 1 • 1•y s Y • • y ✓. 11':11 • • a1•• LI -• 4.i • 1 1 : II • - 1 • • •;1 I 11 •1 1• a• • I •. •, 1 [J: 11 1• •1 1 •: 1/ • r: •Ir, I LI IJ 1••• 1 1 11 1 wY• •V ✓.•• • - •'•: 1 " 11 highly • I • 1 •. 11 - • : 11 • 11 •; . 1 • 11 '• 1 eII • •; •1 IiiL• : 4" • • • •J Il • •� ` •' •I 4Y" "1 •." • • 11 1 1 ••.1 • .wetness •I 11� - 11 • 1 ' N 11' • •' :1 •' ••24: 'y •usobst. y • I •'•11 1 1 •.. both .Ieconomic1 • I II1 ' • 1 11 1 Y, • u • L M 1 1 - • 1 • •. • 1 • offer1 1 1 1 • • • 1" 1 1 •,1<rra 1 JjIV • . ✓. 1 . 1 I d • • - 1 • 11 1 1 . • Y • • • • : 1 •' 1 K : Y Isupport11 • • 1 • 1 11 11 IV. 1-• 11•.11:••.1 IE1.ujljI.,,- Fb1II€.t;:, as 1II •1� P. cc: Mayor^oody • Members of the Fayetteville City Council C Dr. E. Fred Benfield • Professor Department of Biology Virginia Tech Blacksburg VA Dr. Leonard A. Smock Professor and Chairman Department of Biology Virginia Commonwealth University Richmond VA Dr. Arthur Benke Professor Department of Biology University of Alabama Tuscaloosa AL Dr. Ronald A. Hellenthal Professor and Assistant Chairman Department of Biological Sciences University of Notre Dame Notre Dame IN Dr. Darold Batzer Associate Professor Entomology Department University of Georgia Athens GA Dr. Peter H. Adler Professor Department of Entomology Clemson University Clemson SC Dr. Kirk 0. Winemiller Dr. Keller Suberkropp Associate Professor Professor Dept, of Wildlife and Fisheries Sciences Department of Biological Sciences Texas A&M University University of Alabama College Station TX Tuscaloosa AL • Dr. Stuart Findlay Research Scientist Institute of Ecosystem Studies Millbrook NY Dr. Jennifer Tank Galla Assistant Professor Departnietit of Biological Sciences University of Notre Dame Notre Dame IN Dr. Seth Reice Associate Professor Department of Biology University of North Carolina Chapel Hill NC Dr. Carl Richards Professor Biology Department University of Minnesota Duluth MN I. Dr. Peter Vila Assistant Professor Institute for Environmental Studies Shepherd College Shepherdstown WV Dr. Lucinda B. Johnson Research Ecologist Natural Resources Research Institute University of Minnesota Duluth MN Dr. Nancy B. Grimm Professor Biology Department Arizona State University Tempe AZ Dr. Jackson R Webster Professor of Ecology Biology Department Virginia Tech Blacksburg VA Sf rig ti Dr. John R Cannon Conservation Biologist Biology Department University of Maryland College Park MD Dr. Patrick J. Mulholland Senior Research Staff Member Environmental Sciences Division Oak Ridge National Laboratory Oak Ridge TN Dr. Arthur V. Brown Associate Professor Biological Sciences Department University of Arkansas Fayetteville AR (A copy of each journal article or book chapter cited is included with this letter.) Allan, J.D. 1995. Stream Ecology. Kluwer Academic Publishers,Boston. Alexander, RD., R.A. Smith, and G.E. Schwarz. 2000. Effect of stream channel size on the delivery of nitrogen to the Gulf of Mexico. Nature 403:758-761. Bilby, RE. and G.E. Likens. 1980. Importance of organic debris dams in the structure and function of stream ecosystems. Ecology 61: 1107-1113. Brookes, A. 1994. River channel change. pp. 55 — 75 In P. Calow and G.E. Pelts (eds.) The River Handbook Vol. 2. Blackwell Science. Curry, R.A., C. Brady, D.L.G. Noakes and R.G. Danzmann. 1997. Use of small streams by young brook trout spawned in a lake. Transactions of the American Fisheries Society 126: 77-83. Dieterich, M. and N.H. Anderson. 2000. The invertebrate fauna of summer -dry streams in western Oregon. Archiv fur Hydrobiologie 147: 273 - 295. n L CJ • Dunne, T. and L.B. Leopold. 1978. Water in Environmental Planning. W. H. Freeman and Company, New York. Elliott, W. 2000. Conservation of the North American cave and karst biota. pp.671-695. In H. Wilkins, D. Culver, and W. Humphreys (eds.) Subterranean Ecosystems. Elsevier, Oxford, United Kingdom. Etnier, D.A. 1997. Jeopardized southeastern freshwater fishes: a search for causes. In: Aquatic Fauna in Peril: The Southeastern Perspective (eds. (LW. Benz & D.E. Collins) Special Publication 1, Southeastern Aquatic Research Institute. pp. 87-104. Lenz Design and Communications, Decatur, Georgia. Gibbs, RJ. 1970. Mechanisms controlling world water chemistry. Science 170: 1088 - 1090. Hedin, L.O., J.C. von Fischer, N.E. Ostrom, B.P Kennedy, M.G. Brown, and G. Philip Robertson. 1998. Thermodynamic constraints on nitrogen transformations and other biogeochemical processes at soil -stream interfaces. Ecology 79: 684-703. Johnson, C.E., C.T. Driscoll, T.G. Siccama and G.E. Likens. 2000. Element fluxes and landscape position in a northern hardwood forest watershed ecosystem. Ecosystems 3:159-184. • Kaplan, LA., R.A. Larson and T.L. Bolt 1980. Patterns of dissolved organic carbon in transport. Limnology and Oceanography 25: 1034 -1043. Leopold, LB. 1994. A View of the River. Harvard University Press. Cambridge MA. Likens, G.E. 1999. The science of nature, the nature of science: Long-term ecological studies at Hubbard Brook. Proc. American Philosophical Society 143: 558-572. Mettee, M.F, P.E. O'Neil, and J.M. Pierson. 1996. Fishes of Alabama. Oxmoor House. Birmingham, Alabama. Meyer, J.L and J.B. Wallace. 2001. Lost linkages and lotic ecology: rediscovering small streams. Pp. 295 — 317 in M.C. Press, NJ. Huntly, and S. Levin (eds.). Ecology: Achievement and Challenge. Blackwell Science. Morse, J. C., B.P. Stark, and W.P. McCafferty. 1993. Southern Appalachian streams at risk: Implications for mayflies, stoneflies, caddisflies, and other aquatic biotaAquatic Conservation: Marine and Freshwater Ecosystems 3:293-303. Peterson, BJ., W.M. Wolheim, PJ. Mulholland, J.R. Webster, IL Meyer, J.L Tank, E. Mari, W.B. Bowden, H.M. Valets, A.E. Hershey, W.H. McDowell, W.K. Dodds, C S.K. Hamilton, S. Gregory, and D. D. Morrall. 2001. Control of nitrogen export from • watersheds by headwater streams. Science 292: 86-90. Power, G., R.S. Brown, and J.G. Imhof. 1999. Groundwater and fish — insights from northern North America. Hydrological Processes 13: 401-422. Prosser, D.J. and R.P. Brooks. 1998. A verified habitat suitability index for the Louisiana Waterthrush. Journal of Field Ornithology 69: 288 —298. Radwell, A. 2001. Efforts to protect critical fish habitat has heuristic value for student subunit Fisheries 26 (3): 28. Ryon, M.G. 1986. The life history and ecology of Etheostoma trisella (Pisces: Percidae). American Midland Naturalist 115: 73-86. Steinhart, G.S., G.E. Likens and P.M. Groffman. 2000. Denitrification in stream sediments in five northeastern (USA) streams. Verh. Internat. Verein. LimnoL 27: 1331-1336. Trimble, S.W. 1997. Contribution of stream channel erosion to sediment yield from an urbanizing watershed. Science 278: 1442 -1444. United States Fish and Wildlife Service. 1998. Permitted stream losses due to valley • filling in Kentucky, Pennsylvania, Virginia, and West Virginia: A partial inventory. Pennsylvania Ecological Services Field Office, State College PA. Vannote, R.L., G.W. Minshall, K.W. Cummins, J.R Sedell, and C.E. Cushing. 1980. The river continuum concept Canadian Journal of Fisheries and Aquatic Sciences 37: 130-137. Wallace, J. B., S.L. Eggert, J.L. Meyer, and J.R. Webster. 1997. Multiple trophic levels of a stream linked to terrestrial litter inputs. Science 277: 102-104. Waters, T.F. 1995. Sediment in Streams: Sources, Biological Effects and Control. American Fisheries Society Monograph 7. Bethesda, Maryland. Wiley, J.B., RD. Evaldi, J.H. Eychaner, and D.B. Chambers. 2001. Reconnaissance of stream geomorphology, low streamfiow, and stream temperature in the mountaintop coal -mining region, southern West Virginia, 1999-2000. Water Resources Investigations Report 01-4092.U. S. Geological Survey. n From: Andrea Radwell [aradwell®uark.edul Sent Tuesday, September 24, 2002 2:14 PM � o: Collins, Jeffery Subject: To the Task Force Jeff - A A message to you and the Task Force - please forward to the members - To the Wilson Springs Task Force All the members of the Task Force are to be commended for their willingness to give time and energy to produce a set of recommendations on the Wilson Springs site. I am particularly impressed with the degree of respect shown for the diverse points of view that have been expressed the past few months. You had the hard job - I had only to advocate for my position, while all of you had to mull over those diverse points of view and arrive at a consensus. You did an exemplary Job of handling that responsibility. Thank you for your consideration of the written comment that I provided to the Task Force and for the opportunity to address you last night. Your consideration is very much appreciated. • CI Urban Aquatic Ecosystem Models and Wetland Funding Options From Melissa Terry http://www.brec.org/nature/swamy.htm Background papers on Wetland Values and Functions http://www.ramsar.org/values intro e.htm • sTq Funding Wetlands http://www.epa. gov/owow/wetlands/facts/funding.ndf a 4LAROO4, Economic Benefits of Wetlands http://www.epa. gov/owow/wetlands/facts/fact4.html FY03 Wetland Program Development Grants Guidelines http://www.gpa. ovg /fedrgstr/EPA-WATER/2002/Au ug st/Day-26/W21670.ht 1 • (this proposal is due nov. 1) Five -Star Restoration Program http://www.epa.gov/owow/wetlands/restore/5 star/O2factsheet.html vEPA Wa, � Office of Water P"�°�• t i.LRIgY.I •• • Community -Based Restoration Program http://www.epa. gov/owow/watershed/wacademy/fund/based.html • .=. North American Wetlands Conservation Act Grants • http•//www epa gov/owow/watershed/wacademy/fund/nawetlands.html Private Organization Wetland Funding hLtp://www.epa. jzov/owow/wetlands/restore/privlinks.html Other misc. information: hUp://www.cwmb. sa.gov.aulkwc/sect1on5/5-04.htm htty://www. conservation. state.mo.us/nathis/lifeweb/wetland.htm To: Wilson Springs` Business Park Task Force • From: Environmental Concerns Committee of the City of Fayetteville Date: August 23, 2002 Subject: Recommendations regarding the 290 -acre parcel located at the I-540 Bypass and Highway 112 (proposed Wilson Springs Business Park) The Environmental Concerns Committee recommends that a thorough, coordinated environmental assessment be performed on this land, involving species inventory, surface, hydrology, subsurface hydrogeology, and fault analysis, before any decision is made as to the preferred use of the site. We understand that the cost of such an assessment could be a deterring factor and recommend that resources at the University of Arkansas be explored to possibly reduce the costs of these studies. • I I WILSON SPRINGS TASK FORCE BIOLOGY REPORT= JON JOHNSON, PETE HEINZELMANN, AND TOM MCKINNEY The Wilson Springs property, located north of Shilo Road and I-540 in Fayetteville, is a mixture of wetland hardwood forest, remnant wet tall grass prairie and planted fescue pasture that is gradually being inundated by the return of native grasses and trees. The 290 acres included within the boundaries of the site are underlain by a series of soils that play a large part in determining the biology of the area. The entire northwest, central and south central portion of the property is underlain by Toloka Complex mounded soils which consist of layers of silt loam underlain by a layer of clay. The soil stays wet for extended periods of time after heavy rains and runoff is slow. Extended wetness is classified as an extreme hazard. The north central portion of the property is underlain by Summit Complex mounded soils consisting of sticky silty clays underlain by a layer of plastic or silty clay. The soil stays wet for long periods of time after moderate to heavy rainfall. Runoff is very slow, or ponded, with wetness being classified as an extreme hazard. The southern portion of the property is underlain by Baxter cherty silt loam soils which are found on small ridges and hillsides. Runoff is medium with some erosion hazard. We mention the soil topography because that is what determines and drives the biology and the wildlife on this property. The Toloka and Summit soils trap water near the • surface allowing for wetland species to establish themselves and survive. The better - drained Baxter soils do not maintain such saturation levels and are, thus, not as rich biologically as, the Taloka and Summit soils. As part of the task of making a recommendation on the use of the Wilson Springs property the biology subcommittee has collected information from numerous sources, including professional biologists who have considerable on -site experience. Committee members have also visited the property in the company of experts, including biologists, herpetologists and landscape architects from the University of Arkansas. While no formal studies of the ecosystems on the property have been conducted, sufficient information does exist to draw preliminary conclusions about the impact of the development of significant portions. Many questions remain, however, about the nature of specific elements of the ecosystem, and about the environmental consequences of • developing several tracts of the property. There is little uncertainty regarding the southern 40-50 acres of the site adjoining Moore Lane (area A on the map), which contains a sloped area and Cherty soils that does not possess unique biological value for the city or the region. This includes a wooded section in the southeast comer of the property that may be amenable to development if done in an environmentally sensitive way. However, before this could be done we would recommend that a woody plant survey be conducted not only of this portion of the property but of entire site, to document significant trees or biological communities. Special attention should be given to protecting the lower wetlands on the property. There is little uncertainty about the biological value of the east -central sections of the site (B on the map underlain by the Taloka and Summit Complex soils), which is very high. • This area, which is a designated wetland, is covered with vegetation typical of wetland prairie and lowland hardwood vegetation, and is capable of supporting fully functional wetland ecosystems. A representative list of wetlands plants is included in the supporting documents. Wilson Springs, also located in this section, is the habitat of the Arkansas Darter (Etheostoma cragini), a candidate species for listing under the Endangered Species Act, and care should be taken to protect the drainage surrounding the spring. (A related issue is the highway drainage pipe near the source of the spring on the eastern border of the property. Runoff from the highway during periods of heavy rain could prove a potential hazard to the spring, though such runoff has not to date caused any serious problems. The threat of a chemical spill could, however, pose a serious danger to the spring.) The designated wetlands also contain a substantial population of Ozark Burrowing Crawfish or crawdads (Procambarus liberorum), a species that exists in only nine counties of northern Arkansas. The area also contains nesting populations of numerous birds. In fact, the whole of the Wilson Springs property is a valuable resource for resident and migrating birds; 125 species of birds have been documented on the property by volunteers, a much larger number of species than is usually found within the city limits of a medium sized community. (A list of birds seen on the property is included in the supporting documents.) The Wilson Springs property is also the only known nesting site in Arkansas for the Henslow's Sparrow (Ammodramus henslowii) which has been designated as a species of concern by the U.S. Fish and Wildlife Service because its population is declining throughout its range. It should be noted that these and other sensitive species of flora and fauna have been documented in inventories created by volunteers. A formal, systematic study may very well identify additional species deserving of protection. The subcommittee is very concerned with the segments of land adjoining the designated wetlands to the west and south of Clabber Creek (C on the map also underlain by Taloca and Summit Complex soils). The primary vegetation there is different, or atypical, from that found on the designated wetlands areas only because it has been planted in Fescue and cut over on a regular basis. This area also contains lands that might be classified as seasonal wetlands that are wet only part of the year and are associated with low "prairie mounds" that cover the area. Though delineated wetlands have legal protections, seasonal wetlands do not and they constitute the single most endangered habitat type in northwest Arkansas. These wetlands are deceptively dry during periods of low rainfall but, because of the high water table in the area, it takes only modest amounts of rainfall to nurture shallow, seasonally wet habitats, with their associated plants and animals. • • • Seasonal wetlands can be identified in a number of ways, some being: • 0 Numerous and widespread mud chimneys of the Ozark Burrowing Crayfish. • 0 Hydrophilic plants such as Prairie Cord grass are present as well as Buttonbush and Swamp Dogwood. 0 Stands of various semi -aquatic plants are common, especially sedges, that require water and dryness during part of their life cycle. 0 Wet prairie species such as Sawtooth Sunflower are present and form extensive stands. 0 Marshland birds such as the small rail, Sora and larger species like American bittern. In seasonal wetlands there is a strong positive correlation between biodiversity and the presence of water. The Wilson Springs property supports a high biodiversity as a result of the high water table and presence of water on the surface for much of the year. Typical seasonal and delineated wetland vegetation has naturally begun to recolonize much of this area, and the soil and hydrology of the section is nearly identical to that of the designated wetlands. Ozark Burrowing Crayfish chimneys are located throughout the area, as well as nesting sites for Henslow Sparrows. There is every reason to expect that, if left unmolested, this area would develop into a sustained tall grass prairie, delineated wetland and seasonal wetland ecosystem. • Development of this section would destroy this habitat, and the subcommittee members are concerned that it would disrupt the adjoining designated wetlands as well. The greatest uncertainty involves the lowland property to the north of Clabber Creek (D on the map also underlain by Taloca and Summit Complex soils). As with other lowland areas of the property, these sections are characterized by soils and hydrological features typical of delineated and seasonal wetlands, and the same characteristic plants (e.g., Prairie Cord grass, Buttonbush, Swamp Dogwood) and animals (e.&, Ozark Burrowing Crayfish, nesting Henslow Sparrows) are found in these areas. Development of these tracts will have obvious implications for the less mobile species of • animals located there, but it is unclear what impact development of the perimeter of the property will have on bird populations. Contiguous tracts of unmolested land are necessary for many nesting birds to inhabit a site, and we cannot say with any degree of certainty what impact development of the northern sections will have on the bird populations for the whole of the property. This uncertainty is exacerbated by our ignorance of the actual species that exist on the site, insofar as no comprehensive survey of species has been conducted. When habitat shrinks those species associated with it can be forced out and their survival is not assured. These species need not just good quality Jtabitat, in this case delineated and seasonal wetlands and prairie, but they also need a certain quantity to assure survival. r In light of these findings, the biology subcommittee does not feel that it would be appropriate to develop the northern sections of the property without first commissioning a • formal inventory and environmental assessment of the development of this area. C • • BIOLOGY SUB -GROUP SUPPORTING DOCUMENTATION • • The. • • Pictures from Wilson Springs Narrative • If you are a PC user, an easy way to view these pictures is to save the CD contents to a file in "My Pictures" on your hard drive (you can just delete them when you want), then use the "slide show" feature to click through them. If you don't want to go to this trouble, just double click each individual picture on the CD. These photographs were the volunteer effort of Fayetteville resident, Joseph C. Neal, on the 289 acres of publicly owned land, between late March and early September 2002. The only exception is the picture of the Arkansas Darter that dates to 1990, but was also taken at Wilson Springs. If you have questions about these pictures, call Joe at 521-1858, or joecnealQ2iuno.com. Thanks for your interest in the fixture of this property. • 1 1 . F 1.: I- 1.: 1 1 1 1 • 1 . ii 11. \ 1 .�1 \ 11 11:\ 1 I • : 11 1 1 : 1 .•: : 1.1 \ e I 1 dl "r: 1. 1 : adapted 1 L . I : I.1 • IL1 I1 1. 1 • ill 1 1 1 1 � 1 1 1 `I 1: 11 1.:1 y_• 11 :I • 9 R 11 1: 111. prairie1 1' . . 11 11'.\ 1 1 1. .• 1 1 1 1 1 :. ..f fr 1 1 _L : 1 1 1 1: .- 1 \ 1 11. • I\ 1 1 1: . �1 11.: I plants,1 1 : 1 1 1 n \ 1• �1 • :11.. 1 1 1 •. V • 11..j.1. • 1 .� II 1 \ 11 : . 1 1 1conical1. 1 : 1 1 . 1 • i1 1 \ 1 • : 1 •4L Ii 1 1: 1 .: 1 1 . , L 1• • 1 . 11 1 1 .. 1 .: •J 1 11.1 original 1 : lu jj • : I 1111b" : •: I . 1 1 1 1 1: 1 :1 • \11c1 : 1 1 1 : 1 1 1 1. Il 1 . . 1 i1 • 11 i . 1 1" :I " 1 \ 1 • 1 : 1 habitats,. • prairies.I 1. I 1 • 1.:1 11 : . 1 1: I 1\ I 1 1\ 1 it; 1 1 11 : 1 : places• 1 .1 X11 1 ri • 1: • 1. Y- 1 \ 1• 1 1 1• 11 11 H I \ 1 . 1"Ii the11 1- 11 I 1 1 1 \ • 1 1 11 11 M: L. 1 1 (MI fi 1 1 " 11 • ..' tf 11.41 Prairiei r.ti 1 I 1 I , • ': 1 • . : 1 1 : 1 1 prairie11.1 I 1 : 1 . 1.: 1 • • • I e . P.S. 11 1 I r• .1 . 1 :1 1 ti• 1 1 ♦• .s 1 ti� .: 1 f1. . 1 1 1 1 1 1 11 ' through 11 1 1 1 : 1 • 1' V: I . • • .1,1'. 11 . 11 1 1the 1 �+ 1 male1 1 1 1 •J 1 L�1 :I P. 1 • 11 , e': 1 1 11.1 1 fr 11:1 I: 1 11 1' 1 •1: 1 'J 11 1.:1 Mild .r III'i11 1. 1 1 1• .• 11 1 . 1 1 This.11 1 1 1 • I �: F 1 11"1 1� :•1 1111 I.1 1• 11 1990, 4' during \ 1. . 1. V • LI • II' :- \'1:I 1 •1 1:I 1\attempt1 II11 1' 1 \ 1 1 1• 1- r 1- perennial11 . 1 11 IS' 1- - 1111 1' 1 1 11111 \\.� 1! j: "• • 1 11. •- i. 0 1 1• 1 11 I 11 along I- Wilson r l l• 1 1- 1 1 : I r- :- 1 bird •' 1- I' 1 1 tr 1 - i• \ 1 L 11 a:l : \ 1 1 •J 1 1 1! 1 r l- :I. • 11 :1 almostr- :-1 11! :Ira • I. 1.kJ, 1 1 11 : 1 , 1 1'- \ 1 1 r1 1 1r" 1' 11. 1 1: 1 1: 11 1- 1 1!� : W 1 11 -\ : 1 r 1 grading 1 1 1- 1- 1 - \ 1 - \ 1 111 1 1 1 • r 1 - :" 1 11 f' 1 - - 1 1 rI 11 : Lti \ 1' frP 1- I. 1- 1 on 1- 2O - - dominated 1 \ I 111 LIris i HI I 1 1 • L I 1 \ r 1 \ 1' IJ • 1 1 1 1 1 \ r I I and 1 11 1 11 : I : :+ IJ :1 1 . 11 1 1 1 \ 1 1 1• 1. •1: 11 1 1 1 1 1' 11 1 1 1 1.1 bone 1 \ I 11.E 1- 1• 1 1- - 11 11 1' i t 1 1' 1 1 1 1 lii ' 1 \�- I\ 1 1 x 1\ 1 :1apparently1 1 1 ll 1 1 \ 1 1 1 • I \ 11 1conditions \ 1, 11 - 111- 11' 1" :1- 111:1 \ 1-11 1: 1- 1 11 ii ':1•' 11-:11 11 : • I : 1 1 _1 1 11.1 / 1 1 1 1\ - I ,1 r\ - 1' I• 1- 1 1 1 1 1 1 1 1 I: I , 1 %I :•: • 1 , 1 • 1 • 1 1 1' 1- 1 1 \ 1• I- III I Y.1 1 1 i 1 1 I- : . i - 11 J r: 1 1- 9 • I • I 1- 1 1 1 :• 1 1 1 1 :- 11 1\ 1 1 1 1 1 1 _ _ 1: I"' 1 •• ! 1 1 i\ 1' 1- \•and 1- greatr :: 1 I I I ' 1 1 1 1 I I 1. 1' 1 1 1 1 r w 11 1 1 1 I Y I 1 1- :1 :1 f,.. 11 1 1 1. L 1 'M1 :•. \ :1 • i 111 1 1 1•'I: IS 11' • IL1 outII 1. 1' fr )F trig., - 1 .: 211 \ - �I 1 ! . 1 1 11 1 . I �- II 1 11 1 ❑:- \ 1 •- 1 1 11 1- w 1\ 1. :I •• fit 1: 1 1! I: 1: 1 1 1 1 1 1 1 :• . •'''J y: 11 1 1 1 1 r 1 I: 1 11 : 1 1n'Erfields1 1 1. -south J. 1 •IM • "I =\ 1 \ i• � 1 = 1 11 ' • ' 1\ I 1 1 1 11 V: • I 1 1 11,1 I.Y' 1' 11 1• �• jH- 1\ / \ Y I 1 I. 1 :I 1. 1 1 •. KI 1 1 1 11 1 1 1 1 \ 1' L' 1! 1. 1 I L• :I 1 a :• 1 1 1 1 1 1 1• II I- 1 - 1 • • =1 T'r'' 111 1Itr, I 1- 1I Y I- 1/ : 1 1 1 1 I :I - 11 I - 1' I- 1 1 1 1 r 1 11 11.1 I 1 11 11' •11 \ 1 1 �- 11 I I 1 :1 • I• 1 1 1111 1- 1 1 LS \ 1.- \ ill 1 1 1:1 - 1 ' IJ • 1 : 1 1 \ 1 - It 1 1 11 ! 1 1 1 II 111 •: • I 1 1 III 1:1I' •\1'•1 11 1111111 11 1." _•!- 1 :ItJ 1- •1 I • I =1 1 I- 1• -• 1' w 11 I �' I 1- ,• 1 ujjH I 1 ' 11 :' 1 1 1' r': •. • ' 1 :• : • 1 • 1 r • - 1 . , I I • ' 1 1 • \ 1 ' , • I 1 1 u.1 1 , : I 1.1 \ 1 L" - I - • L- 1 1 • ' _ .a •r I n •11 IJ11=1 I 1 1 1 - 1 �� I 1 ' 1 1 ,k7L I- I I- 1 I 1 I= 1_ • 1• 1 1• 1 n •ua 1 • 1 -n I• •I. I 1 1!u •r 1 -.Ii ti 1hj I ¶i:jriIT 11'1 1.- 1-1•-1 1w IIwY • u II .1Ir is I jjl•!II., •I 1 -' : 1. • 1 I• 1 ' 1: • 11 01) 1 1 I 1 J I I L" 1•. I 1- I I.I 11 I I I I• I, nil "nY 1 - \ • \ - 1 • • • u- I \ 1 I 1 • u I � L- i1 I ! I I = 1 - 1r 1 1 11 1 - I : 11 1 : • : ti till ''- •¢ L• 'k t f •U: 't •j,L .fl4tJ1 r I'A I I I I- 1 1 1 r I- I I I• I.11!:. I I1:i' 'hI• II 1.1 _. i 1 Y1 L41111111 111 11 :I I= • 1 w.Yll =: I • 1 I ".t • 1• 11 : \ 11 111 1 1 i - • I\ 1 1 : 1 1• • 1= I- 1- I i 1' 11 1 1 1- ji •. • 11 11.1 1 1 1 1 1 111D1 r 1 I •J 1' 1.: 1 11 1 1 u I• 1- 1 1 1 r." 1 • 1• u /e\T" j f!"7\�-{t `�``•riiiC F y�3f!_ti t.\,\:' ��� ��lfJ �{ alln iI .•� ft�i•. �.}'♦ f YI e'". 4 i L J Yj� l\ iL rrp¢� ''a 'f •1 :mot {f ,M .J{to I` .�vy ;i T ten_ I • ,.f. r \! - 1 • F Yf ,. \�� ��.i .p r. �(n S - (�� i .}e f f:�r Li 13 tf .�"a ry. `�Y{< -}$ �/}'_, R'`k Ft`�� i.. /��`il; � L� ^ 1 r 01 i py \ 4 y q _ ♦ _ }-` l \.. 1\.\ �r8 eL 1 ♦:��I�l li .'P-+]/ .. t<i%•fT :li i4Y CYi I(♦3'/na ! 1 _ ``ll 5 ,. e- _ . 7121 - J -� a'♦ P�Tt�'l-ti f��, �r a tip°, 1.! ).(J {ri / �• / l i - e • � T�1� 1I F ]fir 'i l is a T e\ 4 . li \ \ i r ,!l r / fL 1. _ �� .. �yti N T.itr I Ci \{ i / f ✓: i ✓_ 4 a• (n •er`u It /•,y f � � s- /I I (l r / � e h. / r It G l • x h 4' p v� � \ "rf .I F/� ��_ � Y li1Li 1.1 S�V/ `/•Y �.'Q.r by d�<''" (' ` � e.' i 1 { 11�� 1 � 1 "Y ip t , • L� F ' \�i �\� �v�,� j,•}� tI. -.• C{ e r .. i. 1,i3:'�� <-� _{e 1�^ 3 'xl rt { \ � I t tl � a.. ` `lT'ti/' tE {\ �i air. 'li p ..•I �s�T/a � \' / 1\: \[ �\ `!V�{ 1� by V3� ti�e.1 -ay_ Ill r' �`T 1 ..�a�f l .' �I i� .{ ../V `r4y4y . •� ! Ali {1 .aY l'\• i+l •Y ^ t�fi.3° 1tF an-. �,�1 � .. . 1. - a\ _ ^T c .: rFP r11M # 1 X.t\: \l, tJ•"` i 1 S•1'A,^�i i� 1 1 1/ ' i t t z f1 R. c i., Y •;, iy tt.° .11 ,. '. rT ti r I � / , frl � • ni .r f ~\i is \ n ° I rpt � A � i a', , 11 � f \^r `�J I11 � \ ` � �`�-` �I) � 'iY t .^ � �!f ~�t 1CJ ~ J' /•r- Y t �C' i{,� `[ i 'f .. Jy' y\ _� i [ `� 1 \ ♦ ��• �b♦r }t1 J'�Tva _ 1� s �<. T fFF _r c [ __ 1\'.��-af• 'J- ft �e%. •tv u 'i( `�L T'(.,A KnT�e R�^'`.gl 56! .I: JJ,i.' C / .1 \ '.\. k _ T v^�c r '(( -. 1 V r♦ \1 11 .yt1 x� f f r tT<a tl.' tr ♦ P. i. _ ll,ri .�.'1\r a ! r1 TII ` 'ayF{ 1 >df!IS1 v I tlIra1 ~'\/ 44 f ler 9tltS r I ♦ S rlJJ '!; tf�--�1 hi Imo} 1 \{♦l i�, 4 � ,. C. 1 -rrrKi • Lin •T'1111• (. i ~4 Yx yfl/t\��'•11v4.TT ` %a r 1 ♦ y 1 l ,�.a11 •} SdsiS .. ^atr t t �,.-,�i.rt"er `•. ♦. � c3.♦.� � .[.✓ ry r�yl tL . lP- r C 1 • :. O s Y a - � r'♦\;: Ye} sr' '.. r. .eke o .. .� � _. .' ". _ �.! • r .. 1 ��C5Rjn�Y!.•MlY.4'. C'abf.<.tiv \' . ._.- . l • n .. r' Y - r. 1 1 c - ir c - _ r a r �..•_.r P e�w.L! r• �IIV'•; j:iTV •a./•o r i .Z.Pi ivn `l:. r a _. : ' 4: •a t a I . eet .a " Tfg •v r, lZe J+/'•.!' f'/ i -urrlrt `.iv ,5 r \t r Yn 1 ,' L v: /n♦ f - r2[�1' �R 1♦ Ya I14 i:+ a i . • '.r /r • �♦ i 1 iji t iv'e ir. iI '-I r / A \r' s I' I r'f rt f•r.' r 1 a )- r tN �4♦ i.�.!.' ^ •`c`Sa •fvl '.i'1 r lr I...i r e • e IY` l.a t:e ♦ 11 la r Ir I. `I . I a � t C rrl. /3 [ r .� r ri iI n I. Vi r rr r 3 .i iI 1r r \ frY`4Jl4/l F4er� I4-i.r- i a[ w..a •'`"a♦ rI)1r ',l r L i ♦ 1 I ,r> i. i) � .. ''r ✓i r i Y {I i ♦., r 1 l- ..f 1 P � [ .r' , > sea Ti ♦ 1'S`.t v i Ywi�' V., g \ �S nl e sva T�. -Y+'--t- cro i. v"♦ Y\ �ay^'v1 'y-3 i'a11 v a T; - .t ..s:.s .,. s �ry Y r ae_•x. �fxl'a_ "4,4 M w 1`�n . iRa ✓ ` ♦ rs c Y to: . a S )e rFtt.c> �4♦ v :��1i S "• aY v.:t ! •-. af'iiji i ���I nt �q/f vTC.ri.�f'ay rl Y a _ f � `g f � z l i - .M art -/. tY✓"}_� ' [4r. 4 f a . -/ I.j i I ' Z i'f2% •c 5.. 1.s -�'�. _ _ a ,� _ ' z f /• M r4YW. • ru_ t, 1 .5•'S: ' >• /. •..C, a i• i e F ' • 'i. )I 1 l 11.'f l 7 •.I fir -s---'f > a w v - l r I �a: -t r e ♦ f ! L r.i ) r♦ r[F IiF ` Aei.i♦ "•. ler � !I' j `il. 3 •[ t[ S s ten `i Pr ♦• f O c i yR. ti.. ♦.: 4 '• ♦x i• I Oiw ,_;;_'. - Y 1)• ht ♦ y 1 isc,10i1 . .. r:5• „�Z\'[ Ar rrjl rh ' �'s3.a ,; ' i 1 ;11 0. • F;_.. { ♦r- yyi ',t J •{ jve, s. -_r`i ql " ., w. a. ' ' r .'F � /♦ f ra"G'Y iif .l ti rat i4 • p ` i ;74rr 1• F S I F ♦ i 6 Y h t f,l'I a" 1 I r 1 r t 1 p n l .. ' r• ♦ r f 1 .. `• I4{J: e 9 ♦ f+. rr, >.„�'Ifr ,r j F1 tr!. fi • I t• i t I lI\ 4 l,t lei r i, {�:l: rI 1 •`. •F 1 .4I r , r} �1 n l 1 Y r t i ' A .1 ♦ /r• : r 1 u :ti r ? .! j rr rt 7ln(r (, tsi "•y � a r - !1 J i1 • '�', , -i I 1 r ' •b 11 l .ii t T YalUl -� J !).} rr, J )t 11 •'r .. � � i I `.J i 1 �SI 1 i •rii I r.1 A J •f ,♦ rU • i ! ♦ i ' J, i'¢ rl, Y [tl Ir+T+'Y l , I r! f r A I ( r ♦♦� (:I. rV , 1[rl ylli. lr :5')�l,i�i)(r '11 tc LSl rr 1`Jy , \L'S �: .1r,w `rrl'ril ��1 ''.1 •. fir'. 'r t •^'r}r i 1 I r J 'i f rn `f�1't I: £ J - y s r j. i l 1'- Lr,n It.,'a. 5 R i I r - 91 tvi • i r • I<_ .. . - it ' 1` ` 'r_ — iJ `'Pm 4 � I n I � ' T T /'I 'r[ S T I L r .• J � 5'I'FI% ��� ` �♦fit a./>f..in 1'Y t. 1 _ '/ r6 , _ g. vl .. YI/ � L taL , n F w Y.� ^ \ f r i•r R Nis `i V �♦.+1 T( 0 (a '_. pKV♦u e ? { , .. ,S. • ' m ��ii T�- f .. 1..1 `' c . • : T - jf r '!�'. II L[F.� •�r ff ti yi'• �,/,qF t •My •.TrT ""_x r t( n r 1 b N } •\IT �. r: r. >. t T .• w r yy✓..A I�,P�'.�I` [ a • . • 1 -mot- ��,.•. & E b • (1 �lii rl`Y�H .Ii3r♦�"^L Yin v Lfi•\34 cvi.� L '.v�r 3 � y' ,i l • •)` ilvt � • n • - r• # i v w� � lr.. >�C 1�1 n.. • . :. .�. A ..,\, F 1D4 v. f.�j$•♦.. , r Y♦r -.ui. • •• 1A�' F'i •.i ♦•V il i.:.e�1] r\ t r�" r • ` g. 4` \ IaTli SS r N S L t \n: a '. [♦ilt V ♦ T .•t ` it ii'r ./ I^r x.�' •h la T:P( lv♦ .1 [ Y .♦ is SI F 1' f A ", yxx y�.i, rt y 1 ..I (4. i'd' C♦ lT• w♦t�i r (�" 1r�1111 �\i J7�• 1-i T♦ ♦� w iil % r • ' ipv f..� •Y Jaw t L�i _ .t j' .fit �..{~ •���ie• �i. �•tr -i ��e `i.♦.+; ?L ea` 44 1 } 4v"v. Y .I'i e+.l{ E. l�`•1{t. ^i•t,x1�j�^ {i, $r 'i`I ��..ii `,M^-1t;bl; �r+]Sr:�.� lt{1f •• Ii f a~-� • ': •F .j1 :. i•- ♦11 / 1•{ C�tir _I rJI i``�$.j 1, ...-. •'`iM• 1 I[I• c ifv[ { iiDv ♦1 .' 'Yvl •Vj i t• 1 L• 7 �q• c ♦� /f 'A^" S.`yy+. �. • r •' r 1 • f ry 4 ix{ I t \w - s \ •i \ I ♦f1 N e C `?\w Yn \t a J. eti.�:� _ �4 • v • x ai • .\ (S ( v r 4.. • '1.l 1 1, r a 1 H • 4 e' Tt�•v ♦ _ w. e-.. v r SiaL 1 �.l ♦� Fl♦ .• `' { I �t. \S• ` .C .11♦.' f air. TT� \4 „t ♦!4. '1 •Y [ '•h •. [' ry \. t. 1:• • r ♦ it 1 �1't011;{{. i �.� )'l[.�\ t\iv.3 �}e it`� '\: •i ••i Ic .. -t �. • .t •'l.wY�6•'. .1 �S'f`"1 (��V4 4y l LnY i • `�- 1 f -i i•' hY,4 i�14-4tR� "f:a i 1 •'e1f r_�Y?Y�"' rt Y it[ !t I -i • r r .f-S.t• Y. ..Y Y -C _. }". 1 i+ 1, {_ a�� rNw� �Y. a\ \'"% �:' S.` T•1 'iwtl�ti\ r, of '�~ • 1�` •/' ^ \ ''° w p..-Yy.'+ v :'♦ s -V ��a. .2♦ \ •n \.3 A e Y� v >`/e J[ �♦ L, .. • .1.. � a/ �I A4 n � f C � ! ta-. r • i i . na`.s_—r LL.r-C-a J.vv •.t ..� �� .�...♦a� .�.=rn ):..a "L Y1(h. r. ti 4•Yv�-.,)i ^•I T41 ^. .. ! r '' S .. r .n.. K .nor' + w �.. ..•S.h1Yt "S\ IV4. lr .'1. tiv ♦•1' fi\\.a �1, rtti . "i • ` -l- _ 4 .r- lJ. Ji �. �. ..`r. T I \ K, r. a A• a -I fr n I43 ! �r� t• J f •1 l� wyC •� ( V4 ( F-. i}♦. �lrr♦ •J�^• Y V.� •�\` �\AI 1(F •r ♦ Y cc ')P • • 1 1� TY1 �iY--a ✓h�.rT L... a ` v 1 • e f1.1.µ /� l i�.'•� \ �Y i.. w• v ♦ @\ter �r1^ wP.: •.¢.-Ct+J .�� . rw l'�..Jwr 4 ` Ir�. T [4 c.Ii 1 1v3 •, sf fyy:��5�\. fvi . ...I )..ter ^ � '•JY4PN.C'L'x+(.f TJ♦t)qM•�-- � �•�'a : �• Y�Tvw -� 7P �Ja�rRJ•�-iF+� LDnai _ �•" tF+'^'CJIL• I _ Y \ i { Y-'!�-.rw � � w �Z.ra�eS�: ��.?.,.�s•fy'T'.Pz�'-w l����"" �al� L [ • .. Jam_ _. Y�.�Y J y J �.� �_.�.. YCT. _ i. l ..I1rr4. it • ! I _ 'C r J... .. A `•�,�i'r •� '\:Y. � IN L•• « .• 'F:nrS 3[1J f .,;,.n1.;-, "'i'• 7r I n i. Yl•,31r1 f I�ll•r r •/BAs l�le Ys, it '/ ` 1� YfPit T. }}. fl lr Y t i ♦' 1, Fy \i St '.i 7.hj- ! I a 1 Y.. ten: rr : l t llstd '♦IJ� l r♦'. fi r(� �1♦ III 1Y4 / i \ 1 � i iLC .• # r . La 1fn/ si.t•Y•( rr a` \j 5j rr/ F ! / y / y ' it.. "� 'r .. rnfr•—`� ( \ 'L' Sy. '. p j� 1 Fx �..V4i1 fig Tr VP 5 tea t: .v(� .17r`Vi�{J� 11 �tl� t�<d'\ E y(:..: •' yr �l lf )Vf r, ♦ ! ) bar. rya.^ y Y✓.Cr-4✓T a♦ `G� I. t s- " 1 ..3 v �.;' ."£aC.P N1.r L6 a a L �! P N�rl v/. 1ya�,yVai;v..4 o. _ - s ♦.sl 5} ll.Jyt ri'xi T Y• a r a'Il .e.�p�4llal •p <1 B,.E•T e +- • ��I,-5"b`.,"SCai1r:.T r m'Is..s•'ye e , ♦`-s _ pis t11. T ♦ - • • / 5 ., 4 : J 1. i.l _ "a a • � Th 1• i J Ee{ \:J • I •r r x .il it 1 \ I • q1. $ wYGJ I• g xy' F Iv 1, ,I . v , f Ix( IN • i nr 11!!"11 +A . !\ I i,f/Y/ r J1 f I 1 •el "I •rfl .vn w -afac wLtl1 f e.J t -e f r 11 1/, t� 1 , J I t y.. r �1 •� • n -e:' I _Y y F.r c a •'� I a `. Yr � )•1 fr •r• yrl•r-1. v I/ rll -'M1. '�'j ,1 3_ .l 1 r t lr ✓ D r ) f! I4 er '1 a I♦ ♦ a`r . i ar yd ♦ <f u i' •{ y k it • ,i r s3 •rte i 11 r r ` 1 1 Ir l 1] / t l } • . f e. S a. x, G Ja 1 a• Y 1 r } J ) • Y •1 1t f 111 �I 1� I♦♦ E �1 yn •a i .+ -&_ _ r 3 n T'J ., a. 1 1 i1•.f 1 1 I n l y.- 5 ' ^ �Frfi rr��...� p 1 f �r ) l I i I l l yr ly' I �1 I l J / /4y/ • 1 1 I /1 1 r 1ai J/! • lwllllllw ` t ` r . L.Iu:r'•r'�".•`- f + G a` / u1'If S •a 1; r rl �, ir i i.I:al1 a.I ��Y �:.-a / I�fY �ili +11ir! 1ilfl V I IH Y' LV ( •r/ Bali rT� 1f1• 1 n li ♦r �T �tr\4 i l��l •, a� �^ I f r tl� r'v` 1 f I'1 u .1.11 t ♦1 ! 4 aPPI 5 1( f. i.. ` • 1 ��, Ida 4y \ \ `A! t D✓: ! {1 /is A , -:� Y -- /� [u L ✓. tAr1 _�.•-.� 1 4 4 k'_�.y!`--�. T d La • i <♦ t'._ • S s y e / ayc•��] I:rr fE IT � i I I • i Fi - _ Sr •-. „t. v i a'S ' � L' $ !S` i [ /' - f •. _ iI // .iJ1 1 (l `(< T _ ^ i K , i q s .J / S S 5.2,.,T�-• •' 1 a1 } yr i�v ( At �. x Yyl rt1 4e �y .}A ti/ a w r S iJ.N -aX `f _ . • \_ ♦ rf £ t �. i lrl� t i n - \y j. - � x`yy/ +N5 i . r E -• P'✓ . f SX.a ` "E! v S kR. �k. �r _ y ...'+k f 4t 'k(.T`V.s� • /.e+ i r""r'i - Spa•. C1 9 r' - ! V Sl I � ✓ ' r. t4nv� .r .L y.1" r 6 .,i .: <N'.S tf i. IY. I 11 t 4 J /I•/r([{< a t ` S T�1� -/ y1 1 \ `Y ✓ .. •- X et 1 1- • 1'1'h'11C<•- [L• J ' - `�j s\'E_ a .? �v /(+�T /^ r _' / 5r ilG1 r f'Y r 4 ♦ a tFiu N-5, Iti f { u F r //. \'\` v t-` l" `` ,Y; ••/J 5J i• •; ••x '4o )yF �[p1 �i rx'• . ,5♦ar_ iil 1�e a C! ' r 4. Fyy ,v 34 "5-`_ I>. tEFir tr .I i -s.✓ - • ! e. l h . ei __ -• �.4 t- /I . S.y� { 'A J / L-7#- lye ��Gt uR•!L ya. fi)a ' _♦-- (+T {1r /� 1 .F y -1 ♦ 1zC T� a ♦ ac Y`n vr KKKd}}}JJJ .�'- • r f �. r• Q n at ••• Y a n t i Ca- l 4i f 4 • J L a i 4 p y 'r r i� 1•T /f 4 d N K l r S ! l F♦ if J %< .gl , •' �ayu� a1f{'•� /ll l^ aR. -, d' a t F-i!' � --. \ � �wT /2 .f 1� r 'l: y. is /'- • !t 'E yc-' �-fa\ {"(y. 1:' ) _ C „T ` j. • ice. F a • fi A i � � _s' •Tys pYa 'a y ^I_ ' • { `♦t ! •`Qe- 1 _ - ry Ji -yyY• Y A 1 • 1 S 1 1 , fi\ F r (SC 1 r •'L'tr•�•��iil r.-P'Aj S i 1. i1M i �"' e} a+•FS'.i •,t VIYF-t •4 ra fi ir. •j � _ nOtl a ^Yr +.-. ) •iV/ui li, i` 5 •,n 1' H airy ..�1 ''If b x ^in v ✓e tni ,.f r{ 1.-,{[1!.-fb fp { i7 a l:M+ .a.• -F'N52i y"l .I ♦ P wiffl JS 3 'r t[ w v 1 _,• i :p Y' i\_�•y x♦•! .r i • 1. i�Yr 1 ) Y�.1r ii f t.r { 5 �`Ya"�+ { s>iv i ♦ f ? 3X/v''( �-'r a\ b )[-\ r l a.'1-.JrJI w, a.� aY•ly, p`h f a ♦r ,✓�-a ata•J' nk. ra \ a i0{�_r f� \ aA _{ ( ,f . l} i1f. 1•r K5�r < t 1 �� I•J'wa )r:. A. la} '[i• 1++Tr%fll Ka•♦ �! ivi a ..\ +r. •r. t' f�i 15 e4w LLip{ 1 ♦.CISv 1 :.f. . if' -tt ,1 t).:. 1.[ +w j \ •t ••J 4. & r is FI♦✓[ •5 '•- • 1 a1� i•ig �. • _ w \(•• }/ ){t ♦rF sarl♦ �! r 5• ♦jl[Jii s-` 11 -L� r i>ry a/ i11�.y1 tl \�M1i. 4��'"d4 x{;-i,'I V�fi{a r. y]l)a itla�`V ♦ro':• 1:eJ •a •' 1 l f/- AII 41 ria."•a r -/f/ 4i } 4 •. 1 \� ``I )) \ ! //ti� r i )•f Y! y i y l^ T \ T P� Y { .f hV rr P3 1 l)lr'.p(�r • I1 rf ri♦ (Cr-/i V, 1 al 1 1 ♦ 1 ♦ r 4 -0im♦ �) if-w?'R PG [F <♦ <ti"fG .YL C.'ti ♦ / 'w/le ny .' .. r • � f>✓'r 'C- • r • rt r 11 t u w'5' Y 4: fc ri ry .y �P� 5 PY S yi fP/ir I i ia-lasari •Zl�fi a�i/In t\.1 J— •Y fi r- %1 l ~_ 1 1 1 _`, ♦ 9 <X `L�4 nrV 6L Ja \`{" I ��,dd'.rj��1i •r rr _ \ �•ryrS `,-�JV5\RPi*t •+ 1 bra { i. W. al iw'rftl r' tom; i.! • aA/?r )1'\•?j^t t/r�. �5\ 1, a ii ♦s♦ fNP .�. 11:y (wlr ♦uf\V r♦ •( f){a• ``S {CI [ 6'P R 'r�l stl{ ≥`< ') • i {f it)` t* t; aP .l t • •i V ¢\_•� ^I r•it 9 • irk* \ } 14 ••rPY JYG iJ �f r rt IL a1`a'J j�3 L- ♦1 /i )3 p. 4 +•• i! biL. f 1 •,.a rr•( \ f • f 1 a r ♦ 11 +/+ I i as nV • •-f i L y 111{� rvir llA'• ! t }r tr)�w •e� .L +� .- �•.{ riV T'r; j�•k A,0. �'t(.•F J? YG {�.�i•<Jff)• 4'--\r ,I1 / fh cw !LzI .Yry / ri ']. {� • v.< r4' i1 1 {+i♦<.i li p r\ r •�ia ;. i ✓♦ v 71 -t\ts 1 ar \rv.a 11-lr�l , TfI 5I .r 1 i' •♦••\. 1} !♦^III Li�F .i lla `e'yr Y. \sfi ��w/y, :5. 5)"a. _. < i t • f ; A. S ♦ ( 15 iti1 .. `i . 1' /. .e.. • 1 �• �a (.S+• <Ket ./+i i�kl4 y�f- li e r !r . - 1lr) lrfla(.�[rt wq •(r/ l,f r.•yr)y r\I ,'♦ •,\joa♦} Vr •i ti•I Y xl a irr�iJ//..'arJl/ Ya\l ii \t�i}Ya iAf♦b(i �Z f\ C��a Y5^.l ai' 5r N ♦ Z){`i i.. •al{iA-a.}{)rrq i'J\ J•IViI 111jiia K(•1 �'{.%.r l , as ) Nu`R avY/\ i', •i Lhi` Y •t _{ h% . i•1 '�{ S Ai). i a fR CY 4-P/R• 5,.•q i a f ( .1r it n 13 aY it ♦. 0. -• e-,3'?fib �-�['•.�` fi`?` E,_ � ms.st I •':••* -i'.r a t. ICJ i,_ --\'mo°w � - a .1e S x.+:� Kam- ♦ i_ ,. - . �e.i 6' T•CC_# - L 1•V• e .. -.�.` 1 4 sc 4 II ..%7 " t eta / r//r r ! _. 1 v '� . Vie. i1� • J•.a f G' :I . is T -. ♦ . .� :q ` . £+ r ' I 1 �4 -•-- S : aI 11 \ a ♦ —:--' a ' r 1 `i J ..•'-- . 5•� �lit•:.N's1'i::. _ • 1'. b i I P Y! ( %.rl/"rte r n ♦tiR mJl4 /'f ��i:. �4.1. [)y 2 ,a 1 iYr` r Y1�r�9 ,I :� `s W' '2 I,,b i ^,,:v 1 3 ♦! r� v♦.! Y1 J a 4Y's..fi lriissY� � In: a P'V A :iL w .J. .i • _ ♦ .\: i �. l' t •S ^TI 1. R� ♦ rsi i,�4� Ce.Y .1 6w �. tY {1.)/ }i ♦,3 ll.I (ui� 1�+1I ' 11/'i Mlasl )VL S.. .} M1 • 1l I t'Y` IYIY /_� O f' I ! T a r-,2--- r t1 -�� / r ♦ '' £h� / ll ♦ati" 1{ h/ /,si �.r Y. ( t re r/♦•. F w I • i • • f .' • r' t .GA .< ..rl •. A� t'A e t• t ey v s ` •` z .yam 1 '` .t o x.f. e i.' t �'e''. ^` Liryry l./i+(C G 1 r y L ` }p^ {s ♦ 9W• • A i �'�':S T v� C •,'.'. t4- -w ) ' ` `4tl.i` .•L 1 S. Y 1 � T [ J n l� QarC-'t4�iie. ,+♦t'♦�'AI M1L� wn,n u ••' s : ] r / : "�• .S-.: ` ..�., .ak fC: @�•��..� f9r'iy. y . + 4a YVC _ ♦f . -mf- r` ,. . F^- ; 'r `>'/'YzYktCL v x • `F:r: r rJ'. v y! -} - a• ♦Cl ♦�' \ ` Cd ).: n w1 ll �l�•r a ' iii !�` y i\r [�` Y.�s, vPC\ M�'•F!• S i`u'4nav �: R _v -ay ♦Y�. (� i�~4 • 4�.,• -. l `6 ) -._G} .r 7 EI } ' a r r Aa a of Yf •f4 �+y Li4 2 ff' L F de i- •i'. C J^/ "11111 i6 k�a. Y I! +4 J+n , - .� 1 a w. .ar .-? ; K"gi4 t.t:4 •¢': l 1f«t !}1 �rSLV.�l i�.�M1^�to aJ♦eS a~wj iF[,aaifa M1yri q ` .j-) /1' 1 r f ' +?a y..` f L .wY'.`n . , -- _ e ♦ {,�N�e. arj 4r [il. •I2 4 � F<" c + 1 -'- - ^'r ,;-'c ♦ ..` IC i Li �7 V 4 �♦ , L 1 - n ah s: ar t`} .111 : i • I BSLIST AS OF JUNE 1, 2002 0 FOR THE WILSON SPRINGS FIELDS & FOREST (Site of Proposed BIT Park) ■ Sp = Spring, Su = Summer, F= Fall, W = Winter. . BOLD = Partners-Jn-Flight SPECIES OF CONCERN in Central Hardwoods region nesting or probably nesting in the park ■ * = annual rate of decline at least 1.5 % range wide in USGS North American Breeding Bird Survey 1966-1999 . This is a list -in -progress. Species andsa_sons will change as more data is collected. For more information, contact Mike Mlodinow 443-2663. Pied -billed Grebe Sp *American Bittern Sp Great Blue Heron Sp, Su Green Heron Sp, Su Black-cr: Night -heron Sp Turkey Vulture Sp, Su, F, W Black Vulture Sp Canada goose Sp Wood Duck Sp, Su, F Gadwall Sp, F, W American Wigeon W Mallard Sp, Su, F, W Blue -Winged Teal Sp, F Northern Shoveler W Green -Winged Teal Sp, F, W Bald Eagle W .Cooper's Hawk Sp, F Red -shouldered Hawk Sp Red -t Hawk Sp, Su, F, W American Kestrel Sp *Northern Bobwhite Sp,Su Sora Sp Killdeer Sp Spotted Sandpiper Sp Rock Dove Sp Mourning Dove Sp,Su *Black -billed Cuckoo Sp *Yellow -b. Cuckoo Sp,Su Great Homed Owl Sp *Common Nighthawk Sp Barred Owl Sp *Chimney Swift Sp Ruby-th. Hummingbird Sp *Belted Kingfisher Sp,Su Red -bellied Woodpecker Sp Downy Woodpecker Sp,Su *Northern Flicker Sp *Olive -sided Flycatcher Sp Scissor -t. Flycatcher Sp,Su *L. Shrike (season?) White -eyed Vireo Sp,Su *Bell's Vireo Sp, Su Blue -headed Vireo Sp Warbling vireo Sp Red -eyed Vireo Sp Blue Jay Sp,Su American Crow Sp,Su Fish Crow Sp Purple Martin Sp - Tree Swallow Sp No. R. -w. Swallow Sp,Su, F Barn Swallow Sp,Su Carolina Chickadee Sp,Su Tufted Titmouse Sp,Su White -breasted Nuthatch Sp Carolina Wren Sp,Su House Wren Sp Sedge Wren Sp, F, W Marsh Wren Sp, F, W Ruby -crowned Kinglet Sp Blue -g. Gnatcatcher Sp,Su Eastern Bluebird Sp Swainson's Thrush Sp American Robin Sp Gray Catbird Sp Northern Mockingbird Sp,Su *Brown Thrasher Sp European Starling Sp Cedar Waxwing Sp, Su Tennessee Warbler Sp Orange -crowned Warbler Sp Nashville Warbler Sp Yellow Warbler Sp Magnolia Warbler Sp Yellow-ru. Warbler Sp, F, W Black-th. Green Warbler Sp Mourning Warbler Sp Com.Yellowthroat Sp, Sri, F Wilson's Warbler Sp Yellow-br. Chat Sp, Su Summer Tanager Sp *Eastern Towhee Sp Chipping Sparrow Sp Clay -colored Sparrow Sp *Field Sparrow Sp, Su. *Lark Sparrow Sp Savannah Sparrow Sp *Grasshopper Sparrow Sp *Henslowrs Sparrow Sp, Su Le conte'S"Sparrow Sp, W Fox Sparrow Sp, W Song Sparrow Sp, F, .W Lincoln's Sparrow Sp Swamp Sparrow Sp, F, W White-th. Sparrow Sp, F, W *White -crowned Sparrow Sp Dark -eyed Junco Sp No. Cardinal Sp, SuF, W Rose -breasted Grosbeak Sp Blue Grosbeak Sp,Su Indigo Bunting.Sp, Su *Painted Bunting Sp, Su *Dickcissel Sp, Su Red -Winged Blackbird Sp,Su *East. Meadowlark Sp, Sit *Common Grackle Sp,Su Br. -headed Cowbird Sp,Su *Orchard Oriole Sp Baltimore Oriole Sp House Finch Sp American Goldfinch Sp,Su httn://nw-ar.com/mudwotnnerrPubnaTk/btnaTk bird list.html 9/18/02 Bird List for Wilson Jpnngs news of roresi *E. Wood -Pewee Sp Yellow-th. Warbler Sp Alder Flycatcher Sp Pine. W arbler Sp Willow Flycatcher Sp, Su Palm Warbler Sp Least Flycatcher.Sp Bl: and-Wh. Warbler Sp,Su Eastem.Phoebe Sp American Redstart Sp Great Cr. Flycatcher Sp Ovenbird Sp Eastern Kingbird Sp Northern Waterthrush Sp Back I Home httn://nw-ar.com/mudwomnerc/htnark/btnark bird list.html 9/18/02 • 1 • 0 WILSON SPRINGS BIOLOGICAL ISSUES • . Biologically speaking, the 289 acres at Wilson Springs were originally a prairie with distinctive upland and lowland characteristics. Relatively dry terrestrial habitat occupies a small portion of the southern uplands along Moore Lane, with elevations similar to those along the 1- 540 bypass. Most of the remainder of the apparently terrestrial habitat is a seasonal wetland at the lower elevations associated with Clabber Creek and its tributaries. This seasonal wetland has been converted to fescue pasture, but it retains ecological indicators different than those of typical upland terrestrial habitats. WETLANDS Perennial wetlands are associated with Wilson Springs, Clabber Creek, and its tributaries. Wilson Springs supports a population of the rare Arkansas Darter (Etheostoma cragint). The U.S. Fish and Wildlife Service has reported that this darter is in jeopardy across its range due to decline in groundwater that replenishes spring -fed habitats. In October 1999 it was designated a candidate species for listing.under the Endangered Species Act. • Seasonal wetlands are associated with grassy fields that are wet during part of the year. Perennial wetlands have certain legal protections, but seasonal wetlands have little or none; they constitute the single most endangered habitat type in northwest Arkansas. Both wetland types are associated with prairie habitat that was once widespread in northwest Arkansas. The grasslands at Wilson Springs'were part of the region's original prairies., • These fields are marked by low "prairie mounds." These grasslands are deceptively dry during low rainfall periods. However, the water table in the area is high; it takes only modest amounts of rainfall to nurture shallow, seasonally wet habitat (with its associated plants and animals). Seasonal wetlands form on clay -rich soils in the saucer -like depressions between these • roughly conical mounds. These mounds have been greatly reduced through years of plowing, but are still visible in the fields and in aerial photographs. Biologically -speaking, the seasonal 'wetlands can be delineated in a number of ways. The • following conditions have been documented in the old prairie grasslands at Wilson Springs: a Numerous, widespread mud chimneys of the endemic Ozark Burrowing Crayfish (Procambarus liberorum) that withstands dry periods by burrowing into the water table just below the surface. o Hydrophilic plants like Prairie Cordgrass (Spartina pectinatq) are present, though much reduced because of aggressive drainage and conversion to non-native fescue grasses. Also present are shrubs like Buttonbush (Cephalanthtis occidentalis) and Swamp Dogwood (Corms obliqua). a Stands of various semi -aquatic plants are common, especially Sedges (Cyperus species) that require water and dryness during part of their annual life cycle. a Damp prairie species like Sawtooth Sunflower (Helianthus grosseserratus) are present and form extensive stands. a Marshland birds —such as the small rail, Sora (Porzana carolina) and larger species like American Bittern (Botaurus lendginosus)-are present during migration and are included among more than 125 bird species documented by volunteers. In summary, there is a strong positive correlation between biodiversity and presence of water. Wilson Springs supports a high biodiversity as a result of the high water table and presence of water on the surface much of the year. CI Wilson Springs also provides economically valuable ecological services by. acting like a natural detention area to slow the return of rainwater from the adjoining impervious surfaces such as businesses along 1-540, plus I-540 itself and associated roads. Both wetland types also serve as purifiers of storm water runoff coming from these impervious surfaces. Fayetteville is under mandate of the EPA Phase II storm water regulations that require the City to undertake positive actions to improve water quality by addressing the fate of storm water. Preserving the critical ecological values of both types of wetlands at Wilson Springs could allow the City to obtain credit for taking positive actions to preserve both seasonal and perennial wetlands —essentially, all of the lowlands -within the 289 acres. PRISTINE ISSUE Critics of preservation efforts have stated that Wilson Springs isn't pristine; that is, it has little in common with places like the Buffalo National River that have been little altered from the natural state. However, no one favoring preservation has made the claim that Wilson Springs is pristine. Support for preservation rests on unique biological assets that have survived even after fundamental land use changes including long term farming, ditching Clabber Creek, and converting native grasslands to fescue. Some botanical remnants of the original prairie ecosystem, such as Big Bluestein Grass (Andropogon Gerard:) have survived and could form a core for a future habitat restoration. A relatively large group of grassland bird species that are declining range -wide in North America occur within the 289 acres. Notable among them is the rare Henslow's Sparrow (Ammodramus henslowi:) whose only known Arkansas nesting site is in these seasonally wet fields. The 289 acres aren't pristine, but they are diverse. The area isn't pristine in terms of noise levels,either because of its location along 1-540. There is a lot of traffic noise at times, but at other times the noise level is no worse than it is in much of Fayetteville along I-540, College Avenue, Crossover/265, etc. The noise and lack of being pristine has not deterred joggers, walkers, golfers (on adjoining Razorback Country Club), and birders. Nor has it discouraged occupation of private homes, churches, and small businesses along Dean Solomon Road. It hasn't deterred Audubon Arkansas from offering to join Arkansas Game & Fish Commission and establish a nature center on the site. WHAT'S AT STAKE, BIOLOGICALLY -SPEAKING As far as we know, the seasonal wetlands and associated grasslands at Wilson Springs constitute the single largest remaining block of such habitat in the region that is under public ownership, and can therefore be managed for public (as opposed to private) purposes. (The approximately 300 acres acquired by Fayetteville for its proposed west wastewater treatment plant also features prairie mounds and seasonally wet habitat. It may therefore provide a second opportunity to protect this habitat type.) While the number of acres is still relatively small, its situation adjacent the University of Arkansas and within a community of citizens with a more than average interest in biology and ecology provides an opportunity to study, preserve, restore, and last but not least, educate students and private citizens about a biologically important heritage that deserves our support and protection. Prepared by biologists Joseph C. Neal (ioecneal@iuno.com) and Andrea Radwell (aradwell@uark.edu) —Draft of August 28, 2002 Wetlands Key to a Healthy Economy America's wetlands provide something for everyone --they protect. our communities from flooding, filter dangerous pollutants from our drinking.. water and. provide life -sustaining habitat to. Irreplaceable fish and wildlife. The benefits of wettands.are incalculable., both for oureconomy-and our environment, yet: more than 120;00O acres of wetlands continue to be destroyed every year. (U.S. Fist ant Wildlife Service; Wetland Stattsand Trends Report, 1997). More than half of the :wetlands4wthe lower 48 states that'were present when European settlers arrived have already been Wetlands protect Our Families From Floods Wetlands can be the first line of defense against flooding. Justask Loulsville, Ky., . schoolteacher Doris Wilson, who hadn't been flooded after 20 years In her home -- until last year. The summer after a neighboring, developer destroyed a nearby wetland, her yard flooded,even though It wasn't raining. When It.did rain, three feet of water forced her from her home for two months. Like sponges, wetlands•soak up rain and store excess floodwater runoff, thew slowly release flood waters back Into streams, lakes, and groundwater. • One acre of wetlands stores up to 1.5 million gallons -of flood. water. Those states.that.have lost 80 percent or more of their wetlands -- Ohlo, Kentucky, California, and Missouri — have experienced the most severe flooding over the past four years. Wetlands Purify Water Wetlands come in many forts --swamps, bogs, estuaries, prairie potholes -- but all dean our water. people living near South Carolina's Congaree Bottomland Swamp don't take that for granted. Without the wetland, which acts as a natural iilter.removing sediment and toxic substances, the community would have to build a. 5 -million -dollar water treatment facility. And relying on chemicals and treatment plants, to dean our water doesn't always work. In 1995,k the largest waterborne disease outbreak In modem U. S. History sickened more than 900.000 people In Milwaukee and killed 104. Less than a year later, the same dicer killed 19 people in. Las Vegas. One Solution? Preserve more.wetlands to shield. our drinking, water sources. • Wetlands are Home to Fish, Shellfish, and Wildlife btln.//www.sierraclub.rnQ/wetlandc/facbcheets/value.asn 9/9/02 Many fish and waterfowl species are born in wetlands. The U.S. Fish and Wildlife. Service estimates that up to 43% of America's threatened and endangered species need wetlands for their survival. For many animals, such as the wood duck, alligator, and heron, wetlands are • primary habitat for part of the year. The destruction of wetlands threatens the viability of America's $45 billion commercial fishing Industry. The National Marine Fisheries Service scientists estimate that nearly 70% of the annual commercial fish catch depends upon Inshore -wetland habitats. Wetlands Provide a Wealth of Recreational Opportunities According to the EPA, poor water quality threatens America's $380 billion recreational/tourism Industry. Beaches, lakes; and rivers are the most popular destinations. Americans count on wetlands for many other popular activities such as fishing, hunting, hiking, boating, birdwatching, and. wildlife viewing_ A.1995 study by the..EPA shows that 50 million people spend $10 billion each year observing and photographing wetlands -dependent bUds..And. roughly 3 milion waterfowl over$600.migbn•annually In pursuit of wetlands -dependent birds. Wetlands are Worth More Protected than Destroyed Currently, our laws offer limited protection for wetlands under the Clean Water Act. We must strengthen wetlands protections to safeguard these precious places, • Photo courtesy Join and Karen Hollngsworth, USFWS bttn://www.cierraclub.are/wetlanda/factaheeta/valu&am, 9/9/02 I C� . . . . - . I - ..: �. . ec •ti .- of I. I. • . • • n i I • I J • . .- • I • I 'J. •p •q I •a• • • • •- • . .s u- Wetlands help prevent flooding. Although the true value of wetlands. cannot be. put lath a dollar figure, Americans should be aware of the societal and economic benefits of wetlands. Wetlands are crucial for clean water, servingas a natural filter absorbing water -borne pollutants and damaging nutrients before the water enters our rivers, takes, and streams. Clean water is Important to Americans. For example,'when choosing a.place to live, Money Magazine readers ranked "Clean Water+'as the top concern In .all but. one year.since 1990. Wetlands.also. protectus.fmmfioodingeACILAs nurseries for fish, shellfish, provide homes for wildlife, and create recreational opportunities for allof us. Wetlands protect our families and our property from flooding • Wetlands act like sponges, soaking up rain and storing floodwater runoff. Wetlands • slowly release flood waters back into streams, lakes, and groundwater; making • flooding impacts less damaging. One acre of wetlands can store more than 360,000 gallons of water if flooded to a. depth of one. foot. States that have lost 80% or more of thetr'wetlands, (Ohio, Kentucky, California, and Missouri, for example), have experienced the worst flooding -lathe last four years. Wetlands save billions of dollars In property damage by absorbing flood waters and serving as buffers during coastal stomis_.The. National. Weather Service estimates annual flooding costs are up to $3.1 billion per year. Flood damage has tripled In constant dollars since- 1950. • Destroying wetlands and converting the land to agriculture Increases water runoff from fields by 200 to 400 percent. Conversion to roads and pavement Increases runoff even more (Scientific Assessment and Strategy Team, 1994). Wetlands removapolutants from runoff and keep clean waters dean. • Studies have shown that natural wetlands filter out pollution and remove sediment from surface water. Wetlands act as nurseries for fish, shellfish, and provide homes for wildlife • Most fish and waterfowl species are born In wetlands. The U.S. Fish and Wildlife Service estimates that up to 43% of the threatened and endangered species need wetlands for their survival. For many other animals, such as the wood duck, alligator, • and heron, wetlands are primary habitats. For others, (more than half of the nation's migratory birds), wetlands provide Important seasonal habitats where food, water, and cover are plentiful (Academy of Natural Sciences). htbn://www.s ierraclub.ors/wetlandn/factaheetc/nmtect.alat • 9/9/02 L� • Fishing Is big business In this country. The destruction of wetlands threatens the viability of the $45 billion commercial fishing industry. The National Marine Fisheries Service scientists estimate. that nearly 70% of the annual commercial fish catch depends upon Inshore -wetland habitats. • Nowhere in the nation is the link between wetland habitatand fish production more obvious than in the Gulf of Mexico, where National Marine Fisheries Service scientists estimate that 98% of the harvest comes from. inshore, wetlands -dependent fish and shellfish. Gulf shrimp head the list of the region's wetland dependent species according to the EPA. • Nearly one. out of every three shellfish beds were closed or restricted during 1994 (EPA, 1996) due to pollution and habitat destruction. Wetlands create recreational opportunities for wildlife watching, fishing, canoeing, and hunting • Wetlands are nature's efficient pollution fighters, helping keep our waters dean. Because of their position between water and land, wetlands provide a buffer zone that Intercepts polluted runoff before it contaminates lakes, rivers, and coastal waters. • Poor water quality threatens the $380 billion recreational/tourism industry, whose most popular destinations are beaches, lakes, and rivers (EPA, 1996). In 1995, coastal and Great Lakes beaches were closed or had advisories posted warning against swimming on more than 3,522 occasions (NRDC, 1996). [Wetlands for clean Water, 3]. • Wetlandsarecritically important to maintaining healthy fisheries. Fishing has always • been a favorite outdoor recreational pastime for Americans. Over 49 million Americans spend $24 billion a year on sportfishing, for striped bass, flounder, trout and other species., • Wetlands -provide opportunities. for popular activities such as hiking, fishing, and boating. For example,. an estimated 50 million people spend approximately $10 billion e yftar observing and photographing wetlands -dependent birds (EPA, 1995). ., .. •"bucks and other birds that depend on clean water and wetlands also generate economic activity for the'recreation.and tourism industry. Roughly -3 million waterfowl hunters spend over $600 million annually In pursuit of wetlands -dependent birds (EPA, 1995)• Currently,.congress offers limited protection.for.wetlands under. the Clean Water Act. However, a 1997 survey by. the U.S. Fish and Wildlife Service reports:that•roughly 3,30,-000 acres of wetlands are being destroyed annually. Thus, it is clear that..Congress must' strengthen clean water and wetlands protection programs in order to preserve and protect our•vaiva6le remaining wetlands. C1 httn://www.cierraclub.nra/wettandsthctckeetc/nratecta.qn . 9/9/02 • • Supreme Court Removes Wetlands Protections •On January 9, 2001 the United States Supreme Court dealt a heavy blow to the nation's • wetlands protection program with its decision In Solid Waste Agency of Northern Cook County (SWANCC).v..U.S. Army Corps of Engineers. The Court ruled that the Army Corps had improperly denied the waste authorities' proposal to build a landfill in a system of ponds that provided habitat for migrating birds. The Court held that the Corps lacks authority to assert .jurisdiction over isolated waters based on their. use by migratory birds. In addition, the Court held that Congress had not Intended. the Corps' Clean Water Act authority to apply to the breadth of Isolated waters as defined In the Corps' regulations. The Sierra Club strongly disagrees with the Court's decision, and concurs with Justice Stevens' view that the majority of Justices Ignored both legal precedent and the Intentot Congress to provide protection of all Isolated wetlands. As a result of the ruling, the northern Illinois solid waste authoritles.a nd.their supporters to the litigation -- the National Association of Homebuilders, the American Farm Bureau Federation, the Defenders of Property Rights, and the Pacific Legal Foundation - have managed to sabotage the nation's wetlands protections by severely undermining the federal governments ability to protect valuable prairie potholes, vernal pools, swamps and bogs from being turned Into waste pits and parking lots. Not only does this decision seriously compromise the protection of migratory bird, habitat,. but it handicaps local efforts to safeguard wetlands In order to restore water quality, prevent fboding.and protect other critical habitat. The ruling.couid also compromise other federal water quality programs. The ruling certainly will place a new burden on the states, which- rely to varying degrees on federal wetlands protections to help purify waterquality, retain floodwaters and provide habitat protection functions that benefit their citizens. Developers wilt be arguing that much as 50%.of our nation's valuable wetlands can now be destroyed without even getting a permit. The full impact on the ground will vary widely from state to •state and wilt largiey be determined by future court, cases, but some early estimates of the Impact in the state of Wisconsin range as high as 80% of their wetlands are no longer protected. ' EPA and Army Corps Interpretation The Sierra Club concurs with the legal interpretation that the EPA and the Army Corps Issued, on January 22, 2001. We believe that their conclusions as to which "waters of the United States' remain subject to the permitting requirements of Section 404 of the Clean Water Act is soundly reasone4. In summary, the agencieshave-fbund.that all navigable andinterstate waters, all tribufar)es of those waters, all Impoundments that are not isolated, and all wetlands adjacent to those waters, remain protected under the Ad:. Other waters which may no longer be protected Include: Intrastate lakes, rivers, streams (Including Intermittent streams), mudflats, saadflats, wetlands, sloughs, prairie potholes, wet meadows,. playalakes, or natural ponds. The agencies have determined, however, that only those isolated waters listed above that only ailed Interstate commerce by virtue of.their-use as habitat by migratory birds are - certainly no longer considered.'waters of.the United -States'. Theagencles left room.for case - by -case determination that isolated wetlands continue to be protected if their use, degradation, or destruction could affect other 'waters of the United States' or if they support other activities that have an interstate commerce connection, including recreation, fishing and Industrial use. Now What? The Sierra Club Is promoting both immediate and longer -term steps to confront the new • challenges created by the SWANCC decision. hftn://www.seITaCh1b.0TQ/hth1Q0l .aa 9/9/02 Short-term damage control • Section 404 program: The Sierra.. Club urges full application of CWA protections to • wetlands provided under the EPA and Army Corps' legal interpretation. We encourage our members to communicate with the.Army Corps Districts to develop and apply guidance fully consistent with the interpretation, and to ensure that case.by-case discretion is property applied. • Existing state programs that protect isolated wetlands: The Sierra Club is supporting states' efforts to shoulder the full regulatory burden to protect Isolated wetlands. Members of Congress should be urged to providenew funding to enable the.states fo handle these new responsibilities. • We are encouraging state legislators to adopt new wetlands protection programs where they are currently lacking, and to seek federal funding to support the development of those programs. Long-term solutions The Sierra Club strongly believes that Congress can no longer ignore the need for comprehensive Clean Water Act protection of wetlands. Even before the SWANCC decision curtailed the Section 404 program, we have urged Congress to clarify That Clean Water Act protections of wetlands should apply to all activities that would damage.or degrade all . wetlands. Now, more than ever, it is necessary for Congress to act to make clear that the nation Is.committed.to comprehensive wetlands protection. Some have hailed the recently released U.S. Fish and Wlldllfe.Service figures showing a decline. over the 1986 to 1997 period..to an.average_annual loss of only about 60,000 acres. The Sierra Club does not see that number as cause for celebration, when President George Bush Senior committed, over 10 years ago, to halting the net loss of wetlands and achieving net restoration! - • httn:/lwww:cievnclukom/vetlandslnewclan4 01.arn ... 9/9102 • PV �i. American Bird Conservany. `s_' - 8816 Mariehester, suite 135,• ?tom Brentwood, Missouri 63144 jRtzgemldtBobcbIrds.arg JAF coordinates blionse d ervatian p adrvrhes is th Genial Hardwoods g( r...`>s,,:.; and wake witth teehnical staff across Ilie'i `'.'` region to strengthen the biological foundo- Lion upon which good conservation eRDrts P •= are based. She served as the MidwesYa Partners in Flight Coordinator for Ave ''ye`ois. 7,.; $North American Bird Conservation Initiative Coordinator:' . . ; Division of Bird Habitat Coraervalla 't T:.... USFWS . . 4401 N. Fairfax Dr. krlington, Virginia 22203 "Wildlife Biologist Robenf_Ford@hys.gov • USDA Forest Service, Ouachita National IPF is a Wildlife Biologist for the Division of Forest lird Habitat Conservation with the US Fish • P.O. Box 2255 rndSMldliM Service in Arlington Virginia Waldron, Arkansas 72958 I Is primarily as staff for the North jnealGfs.fed.us can Bird Conservation Initiative .. JCN is an Arkansas native, coauthor of 4ABCI) and provides technical assistance to Arkansas Birds (University of Arkansas Press, rint Vensures and for the North American 1986), and a wildlife biologist for the USDA letlands Conservation Ad.Forest Service, Ouachita National Forest. ervation A�w regions al Hardwoods :eph C. Neal** MISSL`UW KANNL a V. Of 84�v�(vrt»,a Xe/CIL The Central Hardwoods Bird Conservation Region (BCR) contains over 15 percent of the world's Eastern Wood -Pewees, Acadian Flycatchers, Blue -gray Gnatcatchers, Blue -winged Warblers, Yellow -throated Warblers, Prairie Warblers. Louisiana Waterthrushes, and Summer Tanagers: approximately 20 percent of the world's population of Worm - eating Warblers and Field Sparrows: 28 percent of Kentucky Warblers; and a whopping 35 percent of the U U global population of Whip -poor - wills. Many species reach their breeding -range center of abundance in the Central Hardwoods. This BC straddles the Mississippi River about midway between the Canadian border and the Gulf of Mexico, where it marks a transition zone between the grasslands of the Midwest and the forests of the Southeast. Prairies, shrub -prairies, glades, barrens, savannas, wetlands, and forest occur here. Historically, the varied habitats supported an avifauna that included Greater Prairie -Chickens and Carolina Parakeets. Today, species like Henslow's Sparrow, Prairie Warbler, and Cerulean Warbler are regular, albeit uncommon, breeding birds. Furthermore, important habitat for migratory shorebirds, waterfowl, and other wetland -associated species can be found in habitats related to the Mississippi, Missouri, Tennessee, and Ohio River systems. Ecology Two ecologically similar physio- graphic areas comprise this BCR: the Ozark Highlands:to the west of the Mississippi River and the Interior Low Plateaus'to the east. A shallow sea covered this BCR during. the Paleozoic Era, but a series of uplifts and subsequent erosion have, over time, produced a topography that is gently rolling in some places and mountainous in others. • Grasslands, oak -hickory, and oak - hickory -pine forests slowly devel- oped after the retreat of the last ice age, roughly 8,000 to 10,000 years ago. The composition of native plant communities was largely the product of soils and bedrock, topog- raphy, and exposure to sun and wind in hilly and mountainous areas. Prairies, pine savannas; • glades, and barrens (grassy areas with shrubs and scattered small • trees) typically occurred on less steep terrain and on drier, west- and • southwest -facing slopes where a lack of moisture limited tree growth. Fires of both human and natural origin were a somewhat common occurrence in the BCR. Variations in both frequency and intensity of fires, and differences in the time of year when forests burned, greatly impacted the struc- ture of the vegetation across large landscapes, and influenced the bird communities accordingly. Upland -forest types vary according to aspect and topography; oak -hicko- ry forests and savannas cover drier uplands, Shortleaf Pine is found on more xeric sites with thin and sandy soils, and beech -maple -magnolia forests persist in the more mesic ravines of Arkansas' Boston Mountains. The largest expanses of upland forest in the mid-continent are found in the Central Hardwoods and host several forest, species of conservation concern, such as Cerulean and Worm -eating Warblers. The large floodplains of the Mississippi.. Ohio, Missouri, and Tennessee Rivers support a variety of wetland communities that include wet meadows, shrub swamp, and bottomland hardwood forests. Although these habitats EI have been significantly reduced since European settlement, these floodplains still provide important habitat for breeding and migratory shorebirds, waders, and waterfowl. The region's smaller rivers often are partly spring -fed, typically have steeper gradients than the region's major rivers, and are characterized by strings of riffles and pools with rocky substrates. Water levels can rise and fail rapidly, with the rush- ing water scouring out vegetation in their relatively narrow floodplains. Habitat for early -successional forest birds like Yellow -breasted .Chat and• White -eyed Vireo is created as a result. Cane thickets were once a common component of the stream - side vegetation, and where they are still extant on the Ozark side of the BCR, they continue to provide habi- tat for the now rare Swainson's Warbler. Conservation Issues and Actions By the early 1900s, virtually all of the original forest in the Central Hardwoods had been logged. Although much of the forest eventu- ally regenerated and most of the species of trees and understory plants are the same as those found here decades ago, the structure of the forests has changed. Many sites have experienced repeated harvest, and marketable tree species have been removed without planned regeneration. Fire suppression has resulted in a loss of savanna and • open woodland habitats, and it is implicated in problems with oak CENTRAL HARDWOODS BCR 155 Speciesqpf Concern 4; In the early 1990s, Partners in Flight (PIF) began Swainson's Warbler*** to develop a species -assessment process that Prairie Warbler* ranks each species of North American breeding Wood Thrush** and wintering birds based upon seven measures 'Bell's Vireo of their "vulnerability" to extinction. The process Keny! assumes that species with relatively small global .).ouisiana" populations, small breeding and non -breeding 'Whip -pool ranges, serious threats to their habitat in breeding field S • an or non -breeding areas, and declining populations Yellow=thri are more susceptible than relatively abundant \.A Acadian Fl species whose populations are more widespread American t and whose habitat -needs are less demanding. See'' . Brown-hea <wwwpartnersirt i ht.o for more information. regarding the species -assessment proms . ' The species -assessment process has helped to'" .� identify species of conservation concern for each Cu dcock** I Nuthatch* (extirpated) Be//'f 1/a P rothonotary Warbler** F White -e edViieo Y ow-breaste ha ' -j BCR and PIF planning unit in North America.;' Tier 11 Species are then divided into tiers: Tier I species Brown:j are those that rank relatively high in terms oft , Chimne their vulnerability and can be found in a BCR or _ „Easton other planning unit in manageable numbers;, er.. .:Grass`ho 'II species are those of moderate concern, with 1. INoither subset IIA including those that have population T4�llgw_'t, centers of.abundance in the BCR and whpge.poa 4 Blue," ulation trends have declined or not been ade-, Easteth quately measured; IIB denotes species j'th larg4WGr4#C3_ percentages of their populations breed' g,.itt'the 1Be1' It BCR; and IIC includes species not meett,g the East .. criteria for the other tier designations, burv+ith threats to their populations or habitats` erg. In addition to regional lists, the spede3 assess—^ h merit ranks also have been used to develop.a*; national WatchList of North American buds of * ' global conservation concern. Several Watchlist Chuck -v species are among the species of conservation. Yellow -ti concern in the Central Hardwoods region. Those Summer That rank as species of extremely high priority on the Watchlist are indicated with ***; those of Tier IIC species: . 4 modeately high priority with **; and those of Bewickts Wren (note: if sub -populations were moderate priority with *. 4 n assessed in the same manner as full species, Tier I species: , Greater Prairie- Chicken*** (extirpated) Red -cockaded Woodpecker*** (extirpated) Swallow-tailed Kite*** (extirpated) Cerulean Warbler*'* Worm -eating Warbler"* Bachman§ Sparrow*** Blue -winged Warbler* Henslow's Sparrow"** the eastern subspecies of Bewick§ Wren would classify under.Tier I for the Central Hardwoods and would rank as extremely high priority on the national Watchligt.) Dickrdssel Painted Bunting Sedge Wren Upland Sandpiper Bobolink PHOTO BY CLAYTON FERRELL• USFWS. C bird conservation: regions • Greater Prairie -Chicken, a species once common in the northwestern subregions of the Ozarks and Interior Low Plateaus, has long since vanished, and species like Prairie Warbler, Field Sparrow, and Northern Bobwhite have experi- enced steep and significant declines. Fairly large expanses of glade - savanna -forest mosaics still persist in the White River region of south- western Missouri and northwestern Arkansas, but the region is urbaniz- ing rapidly (a result, for example, of the growth in popularity of Branson; Missouri, as a tourist and retirement destination). This is the only region of the BCR consistently inhabited by Greater Roadrunner and Painted Bunting. ' The large rivers that pass through the Central Hardwoods'BCR (i.e., the Missouri, Mississippi, Ohio, and Tennessee) have all been impound - Prairie Warblers, which depend on glades, barrens, and other disturbance -dependent habitats, have declined significantly across the BCR. This photo is From the Cheatham County Wildlife Management Area in Tennessee in May 1993. ed, and the diverse wetlands of their bottomlands are inundated or altered as a result. However, several projects that have enhanced and, restored existing wetland habitats have been enacted by local conser- vation partnerships, many of which arose under the auspices of the North American Waterfowl Management Plan. Managed wet- lands, where water levels can be manipulated mechanically, now play an important role in the provision of sufficient habitat for migrating shorebirds and waterfowl. Increasingly, land managers are. recognizing the need to coordinate flooding and drawdowns with the migration chronology of the wet-. land birds dependent upon them. Organized efforts to promote awareness of bird conservation issues and to gamer support for conservation effort's are now under- way. Specific sites or geographic areas within the BCR that harbor large concentrations of wetland birds or relatively large populations of birds of national or global con- servation concern have now, been identified by American Bird Conservancy through the Important Bird Areas (IBA) program. It is hoped that local constituencies of birders will adopt these sites and speak up for their protection. Personnel from both national and state Audubon offices also are work- ing to promote the IBA program and foster this pride -of -ownership approach to conservation. More on the IBA program can be found at both organizations' web sites; avu•w.abcbirds.org> and <www atidubon.org>. BCR-wide, the bird conservation community is becoming more focused and coordinated than ever hcfore. A Steering Committee corn - prised of representatives from feder- al and state land -managing agencies Gc ^ Aft•l ..i./Y; 1 L.ra r • Y < • :k �. A•4^•Fa."^'--T�.�711ti'a L.. t�'i.l. K'aY^0. m%.i `,c. - •'^.. . a: +. ^! w. w �..�.'.'•al'.=" va `' motif \ .• � l �NJFsT•..-�e's t s" , . � •�J-a 1 r•a �,;,. • ' A : s4 �" '..LY�°'y�—wf , i_. L�C•l; wj•!`l.i �_.�•�YT� •n •� ''Y ..L-.•-a-� /�•�n: ✓. n{ F :YJ•S'v,}l Il • ••.. •1- a • \ vii. !/.l\ Y •.':vk\ w Y r - w. ♦ I{. - • l' .-�"�R�.T6t1�.•4• � ��//l ( /lam I a a� P%ptFre .f r3f• ,.4 .�� . , Ft _ tf`. •FiY� Za.�Y �� •,�e//♦• rf•Cf. �1 �R, ,.'J ,i � �•. I a a� . r. `, i'• Y �b�L"'�•"r`r4Ya^ �L,!'v .r � Y \V�� n L �. • a=• r D > � •4i�ai4 /F'/ Ra�^1 r.JYsy `� I`k • •l ••[.. � 1 fi i, Y •..I •- '-'.... yw� .ir .vany f1 ��a�al s.'-' Y i•vC� �. yl =• K 1` ,}I aYO t. a l'Li - y 111 � ftM •R33Y.-- ..ice _F J •.^ a .. jt/•/Z/Z+ • y' .L' .K_.�`'�L� _ �� .k• YF ejYS _ice �ILC `_`.�e' , ��.a • wry. _ _ f 4 • 4/ Cr♦ ♦ i 'L!w+['(i r vj i r• • : : va n . Sn Yn r♦ 1 c♦ 1j I t [ .. ww : • y • - it -s A Y•.- f v v }\=Ptie?!4".- sn:v.!\i.a.. ^. •.:' .- ii . ,: L' IA:,'. 14. ]FLnslow's Sparrow (Amnuxlranws uslutvil) is receiving increased utiny despite its unobtrusive plumage and modest song. Recent popu- lation declines and significant ongoing changes in distribution have called spe- cial attention to this species, while grass- land birds as a group have entered the collective conservation consciousness. This sparrow was discovered in Kentucky by John James Audubon in 1820, and was later named for ' Cambridge University botany professor Reverend John Stevens Henslow. But even 164 years after its discovery the "whys and wherefores of population fluctuation, or perhaps more accurately the long-term gradual but consistent population decline in the Henslows Sparrow throughout its range, are very poorly understood, and the species .remains somewhat of an enigma' (Knapton 1984). Today. another 18 years have passed and much more is known about both the breeding and wintering biology of the species, but questions remain as to its overall population trend and the meaning of observed distribu- tion changes. One of the Ammodramus group of seven sparrows distinguished by large heads, short tails, and generally drab but ,intricately -patterned plumages, the Henslowl; Sparrow has much in com- mon with its congeners Grasshopper. Bairdk, and Le Conte?; Sparrows. A *George M. Sutton Avian Research Center P.O. Box 2007 Bartlesville, OK 74005-2007 dreinking@ou.edu DLR has been conducting bonding and inventory projects and research on grass- land birds. He is the coordinator of the Oklahoma Breeding Bird Atlas, serves on the Oklahoma Bird Records Committee, and is the president•elect of the Oklahoma Ornithological Society. Sort, spiky tail, upperparts streaked with browns and rufous, a bully wash and dark streaking on the breast, and a large, flat head are all characteristics shared to some extent by these species. Henslowrs Sparrows show more rufous on the upperparts and wings than the other species and have an olive-green head and nape. The song of this sparrow is at once easy to miss and yet easy to hear after it is learned because of the persistence with which it is given. A dry, insect-like, two -syllable is -UK is repeat- edly broadcast from the tops of tail grasses or forbs throughout the day and even during the nighttime hours of the breeding season, when most other species are rather quiet (Walk et aL 2000). Taxonomy and Distribution Three subspecies of. Henslow Sparrow have been proposed. The nominate form, sometimes called the western Henslow § Sparrow was recorded as breeding from eastern South Dakota through the upper Midwest and south through central Kansas, central Missouri, northern Kentucky and north eastern Texas (American Ornithologists'1 Union 1957). The eastern form, A. It. susurrans, was said to breed from central New York south to North Carolina (American Ornithologists' Union 1957). Bull (1974) did not consider this eastern form as separate from the nominate form; regardless, it exists only in small numbers (Rosenbutg and Wells 1995, Wells and Rosenberg 1999). A third pro- posed subspecies, A h. houstonensis, was later described from a small population in Houston, Texas, but has been rejected as a separate subspecies and is now extirpated (Arnold 1983, Pruitt 1996). Students of the Henslow k Sparrow have long commented on their uncer- tainty of its distribution. A. Sidney Hyde (1939) wrote, "Its susceptibility to alter- ations in the environment, its apparently innate tendency toward irregularity in occurrence, and its great seclusiveness •bine to make impossible the full interpretation of the historical record. Hyde goes on to note that the first authenticated breeding records in the Northeast and Midwest. generally occurred earliest in states with extensive coastal marshes and prairies, and occurred later in states that were at one time almost entirely forested. Clearing of these extensive forests created habitat for Henslowb.. Sparrows In the nine- teenth century. Broad patterns of habitat change undoubtedly continue to influ- . ence Henslow § Sparrow distribution The map on page i't* snows tree approximate current distribution of Henslow >; Sparrow The northwestern and eastern portions of the breeding. range have contracted in recent years (American Ondthologfsts' Union 1998). No recent evidence of nesting in South Dakota exists (South Dakota Ornithologists' Union 1991, Peterson 1995), and nesting reports from Minnesota have become scarce in recent years (Hanson 1994). Hensoowk Sparrow is extirpated from much of New England (Smith 1992, Pruitt 1996). Other states within its historic breeding range also have shown declines in distri button and population (e.g., Illinois; see Population Trends). mn r=Re of •Usually shy and hard to see, a Henslow's Sparrow is much more visible with its head thrown back, proclaiming its territory with an insect.like song. This bird was at the Taberville Prairie Wildlife Area In southwestern Missouri in June 1996. • A CLOSER LOOK: HENSLOW'S SPARROW 147 0 � winter runga fl This map for Henslow's Sparrow includes breeding and wintering ranges; as well as areas where the species has been extirpated. From data taken from the Breeding Sir Survey (1966.1999), Henslow's Sparrow is extirpated from much of New England a is apparently declining in much of Wisconsin, Michigan, Pennsylvania, and New Yoi Populations, however, may be increasing in Indiana, Kentucky, Ohio, Missouri, Kans and Oklahoma (Sauer et al. 2000). Oklahoma during the 1990s. Recent breeding season reports from southeast - em Nebraska have pushed westward the known breeding range of this species (Grzybowski 1998, 1999). HenslowSparrows winter primarily in coastal states from South Carolina to Texas. Winier distribution of the spar- row has been less well studied than breeding -season distribution, but recent .(forts have provided insights. Banding returns in Alabama indicate that individ- ials are site -faithful within a winter sea- • son, but that they may not return to th same area in subsequent winters • (Plentovich et al. 1998). Numbers of Henslow§ Sparrows wintering in South Carolina have declined substantially since the period 70 to.115 years ago (McNair and Post 2000), perhaps paral- leling the decline of breeding.popule- tions in the Northeast that may have wintered in South Carolina. Even within the known breeding and wintering range of Henslow'; Sparrow, distribution may be localized and fluid from one year to the next because of this species' particu- lar habitat requirements. HEgg nd Mona emRenslows is titatof the Sparrow has been described as weedy or grassy fields and meadows (Hyde 1939). Numerous studies have called attention to several important habitat characteris- tics. including tall, dense grass, a well- developed litter layer, standing dead veg- etation, and relatively little woody vege- tauon (Wiens 1969, Robins 1971, Zimmerman 1988, Herkert 1994 and 1998, Herkert and Glass 1999, Winter et al. 2000. Reinking et al. 2000). This favored vegetation -structure usually results from two or more years of idle management after a disturbance such as fire or grazing. Relatively large areas of suitable habitat also are needed for an area to be occupied, a phenomenon known as area sensitivity (Herkert 1994, Winter and Faaborg 1999). Although Henslowls Sparrows may occasionally be found in small habitat patches, the minimum size of an area needed to consistently support Henslowl; Sparrows has been variously tenoned to be_ fmm 7� 140 to more than 2-50 a andmay vary with the make-up of the surrounding landscape. In western portions of the HenslovA Sparrow range, such as the Flint Hills of Kansas and northeastern Oklahoma, extensive native grasslands remain unplowed. In such areas, it is possible that smaller patches of suitable habitat may be occupied because the area sur- rounding the patch is still grassland; even if it is not of the minimum height and density needed to support nesting Henslowk Sparrows. In isolated prairies such as those found in Illinois, where the surrounding landscape consists of unsuitable habitat such as agricultural fields planted in cam or soybeans, larger Lsatches of suitable habitat `r1 ≤T or an c ) may be ncc c area fibionsistcntly occupied (Hcrkcn 1998). Several studies have noted greater Henslow's Sparrow density [1 • . •.•- :. 1 .. .. .. :' I ,.. ';.. • I.;:.r:.• .I - .I . .i 4 .. 1• i I i. •.a - 1.. • ,�,� O�L'f- fffrrp�,trsfa>Cy f�, IG{r�iG A Henslow's Sparrow nest islusuolly situated by the base of a thick clump of gross. Three to five eggs are incubated by the female for about 11 days. After hatching, young are tended by both adults for nine to 10 days until fledging. These Henslow's Sparrows, nearly ready to fledge at the Tallgrass Prairie Preserve; in Oklahoma, were being monitored and banded by researchers. studies, respectively. Evidence of active nests during the period of May through early August sug- gests the likelihood of double brooding, but studies of marked individuals are needed to confirm this probability. Nest parasitism of Henslowls Sparrows by Brown -headed Cowbirds has been noted in a handful of cases (Friedmann 1963, Friedmann and Kiff 1985), but occurred in fewer than 10 percent of 22 nests monitored in Oklahoma (Reinking et al. 2000) and in five percent of 59 nests monitored in Missouri (Winter 1999). Population Trends The specific habitat requirements of Henslows, Sparrows, together with the dynamic nature of their preferred habi- tat, results in highly localized and vari- able distribution of this species from year to year..Population estimation and systematic monitoring of Henslowrs . Sparrows on a regional or range -wide . scale is therefore problematic. Most available data come from the Nonh American Breeding Bird Survey (Peterjohn 1994), an annual, continent - wide effort to survey about 3,500 road- side mutes for birds during the breeding season. As mentioned above, dramatic changes took place in the habitat of east- ern North America during the nine- teenth century, probably increasing the Henslow's Sparrow population. By the time the Breeding Bird Survey began in 1966, populations had fallen well below this historic high, due once again to . large-scale changes in habitat during the. twentieth century (Pruitt 1996). Since 1966, the localized nature of Henslow� Sparrow populations and the resulting small number of survey routes which contain this species have made accurate population -trend estimation difficult. During the period 1966 through 1999, Breeding Bird Survey data for Henslow>; Sparrows have shown an average annual decline of about eight percent per year survey -wide (Sauer et al. 2000). Henslow's Sparrow is extirpated from much of New England, and is apparent- ly declining in much of Wisconsin, Michigan, Pennsylvania, and New mow§ Sparrow been relatively well studied in Illinois, where habitat changes have clearly affected its popula- tion. During the eighteenth century, Henslowa Sparrow was considered abundant in Illinois (Herkert 1991, 1994). As recently as the 1950s, it was considered common in northeastern Illinois (Ford 1956).. Surveys conducted between 1957 and 1979 suggested a 94 percent decline in the Illinois Henslow�s Sparrow population (Herkert 1994). Grassland habitat in Illinois declined 65 percent to 75 percent during this same time -period. Results from the Illinois Spring Bird Count (a standardized annu- al survey in each of Illinois' counties) show a 78 percent decline in the Henslowa Sparrow population from 1975-1995 (Herken 1997). Henslow's Sparrows now occur locally and some- what sporadically in Illinois, and gener- ally only in grasslands larger than 250 acres, even though apparently suitable. habitat is present in smaller grasslands (Herkert 1994). Some recent increases in the Illinois population appear to be the result of land being enrolled in the Conservation Reserve Program (Herkert 1997). Farther west, Henslow's Sparrow pop- ulations appear to be stable or increas- ing in Kansas and Oklahoma. Substantial populations exist in Kansas on Konza Prairie Research Natural Area and on Fort Riley Military Reservation, both near Manhattan (Pruitt 1996). The Nature Conservancy's Tallgrass Prairie Preserve near Pawhuska is home to the largest and most stable population in Oklahoma. Although the Henslow'; Sparrow population here may be only recently established, as was the preserve (in 1989), habitat management in this 37,000 -acre conservation area favors Hcnslow§.Sparrows, and promises the potential for maintaining substantial numbers of this species in Oklahoma. Additional breeding -season sightings recorded during surveys in 1996 CI 0 0 showed Henslow§ Sparrows to be pres- ent in six counties in northeastern Oklahoma (Reinking et a).. 2000). The widespread and substantial decline of Henslowt Sparrows across much of its range resulted in a petition being submitted to list the species under the Endangered Species Act, which prompted Pruites (1996) status-aSsess- - men of the species. Due to evidence of •increasing'populadons in several parts of the Henslows Sparrow range (such as Indiana, Kansas, Kentucky, Ohio, and Oklahoma), the petition request was found to be unwarranted (Department of the Interior 1998). one of HenslowW Sparrow only many species whose range and popula-. don dynamics are not well enough understood. continued participation by alders in projects such as the Breeding _ iuvey and breeding bird atlas efforts is critical to our understanding of the whys and whenfores of population Jluctuadon? and will help to determine whether or not future generations of birders will enjoy the same diversity of • bird life that we often take for granted today. Acknowledgments Numerous field personnel over many years have painstakingly collected data on nesting Henslowes Sparrows, and birders have contributed greatly to our understanding of this species through participation in the Breeding Bird Survey and other projects. I thank my uncle, Kee Hollings, for introducing me to binding, and for later showing me my lust Henslowk Sparrow on 6 July 1985 at Mora'Prairie in MISSOUrI. David improve the manu- script. helped ' script Literature Cited .merican Ornithologists' Union. 1957. The A.O.U. Check -list of North American Birds. The American Ornithologists' Union. The Lord Baltimore Press, inc., Baltimore, MD. 691 pp. —. 1998. The A.O.U. Check -list of North American Birds. The American Ornithologists' Union, Washington, D.C. 829 pp. Arnold, K A. 1983. A new subspecies of He sslowk Sparrow (Ammodramus hetsslowii). Auk 100:504-505. Bull, J. 1974. Birds of New York State. Doubleday/Natural History Press, Garden Cit)c NY. Department of the Interior. 1998. Endangered and threatened wildlife and plants; 90 -day finding for a ped- don to list the Hensloww Sparrow as threatened. Federal Register 63:48162- 48164. Ford, E. R. 1956. Birds of the Chicago region. Chicago Acad Sci., Special Pub. No. 12, Chicago. Friedmann, H. 1963. Host relations of the parasitic cowbirds. U. S. Nat Mus. Bull. 233. Washington, D.C. 276 pp. Friedmann. H., and L F. Kill. 1985. The parasitic cowbirds and their hosts. Prot. Western Found. of Wit ZooL 2(4). 304 pp. Goard, D. M. 1974. Henslowk Sparrow in Oklahoma. Bull. Oklahoma Ornithol. Soc. 12:57-60. Grrybowsld, J. A. 1998. Southern Great Plains region Field Notes 52:474. • 1999. Southern Great Plains region North American Birds 53:405. Hanson, L G. 1994. The Henslow's Sparrow (Ammodramus hcnslowfi) of Minnesota population status and breeding habitat analysis. MS. Thesis, Central Michigan Univ, Mount Pleasant 39 pp. Herkert,J. R. 1991. Prairie birds of Illinois: population response to two centuries of habitat change. Illinois Nat Mist. Sum Bull. 34:393-399. 1994. Status and habitat selection of the Henslowk Sparrow' in Illinois. • Wilson Bulletin. 106:35-45. 1997. Population trends of the Henslowk Sparrow in relation to the Conservation Reserve Program in Illinois, 1975-1995.J. Field. Ontitltal. 68:235-244. • . 1998. Effects of management prac- tices on grassland birds: HenslovA Sparrow Northern Prairie Wildlife Research Center, Jamestown, ND. Jamestown, ND: Northern Prairie Wildlife Research Center Home Page. <http://ivwwnpwrc.usgs.gov/TtSm1t fl1t- eratr/grasbitdlhenslows/henslaws. htrnu (Version 17 Feb 2000). and W.D. Glass. 1999 Henslow>: Sparrow response to prescribed fire in an Illinois prairie remnant Studies in Avian Biology 19: 160-164. Hyde, A. 5. 1939. The life history of Henslow's Sparrow, Passe herbulus hetssloivii (Audubon). Mus. of Zool. Misc. Pub!. No. 41. University. of Michigan Press, Ann Arbor. Knapton, R. W. 1984. The Henslowb Sparrow in Ontario: a historical per- spective. Ontario Binds 2:70-74. McNair, D. B. and W. Post. 2000. Historical winter status of three upland Ammodramus sparrows in South Carolina Studies in Avian Blol. 2132-38. Petetjohn, B. G. 1994. The North American Breeding Bird Survey. Binding 26:386-398. Peterson. Richard A. 1995. The South Dakota Breeding Bird Atlas. South Dakota Ornithologists' Union. 276pp. Plentovieh, S. M., N. R. Holler, and G. E. Hill. 1998. Site fidelity of wintering Henslowk Sparrows. J. Field Ornithol. 69:486-490. Pruitt, L 1996. Henslowt Sparrow status assessment U.S. Fish and Wildlife Service. Fort Snelling, MN. 113 pp. Reinking, D. L, and D. P. Hendricks. 1993. Occurrence and nesting of Hcnslows Sparrow in Oklahoma. Bull. Oklahoma Ornithol. Soc. 26:33-36. D. A. Wiedenfeld, D. H. Wolfe, and R.W. Rolrrbough, Jr. 2000: Distribution, habitat use, and nesting success of Henslow's Sparrow in Oklahoma. Prairie Naturalist. 32:219-232. Rcrhins, J. D. 1971. A study of Henslowt Sparrow in.Michigan. Wilson Bulletin. 83:39-48. Rnscnhurg, K. V., and J. V. Wclls. 1995. Imporiancc of geographic arras to r , 1 Tours ap,• 200.E neouupieal migrant birds in the ••8 • g • Northeast. Report submitted to U. S. Fish and Wildlife Service. Region 5. Hadley, Massachusetts. Apr 27 to May. 11 - Wales & Norfolk Sauer, J. R, J. E. Hines,!. Thomas, J. Bird die mtwnaus o(W" the plains SMuslim d Nmf* Fallon, and G. Gough. 2000. The l-566 g r, CCelticBBird Than, rd (44)•1165664545 709; (Iud+@celdtrounm8uk North American Breeding Bird Survey, May 19 to Jun 1 - Finland & North Norway Results and Analysis 1966 - 1999. km 50 tdBoo breeding rain dpi In the Lod ofthe MWr* Soo Version 98.1, USGS Patuxent Wildlife a 11 iMal guide; warnt"a yc Research Center, Laurel, Maryland. . � a rt (800)3t Hat; (415)7884000; Smith, C. R 1992. Henslow•s Sparrow, .` May 20 to 26 - Presqu'lle, Ontario Ammodramus ltenslowii. Pages 315-330 A trip tin newt bedma with aetarn bader a m in K. J. Schneider and D. M. Pence, WgMy a se habitat of this pcni'°W'r part 150 B1* eds. Migratory nongame binds ofman-Nature 1aitl L Holidays, (BBB) 305-3955; (613) 531 4105; agement concern in the Northeast. U.S. Aug 4 to 18 - Cruise Alaska to Siberia Dept. Inter., Fish and Wildl. Sere, . , _ ]Wd the nibUOBs, die Akmim cub Bering W aM AMK ind and Newton Comer, Massachusetts. tt¢wfassantdarin pmmmm aryat AeA taddes Swengel, S. R. 1996. Management Clipper C�>�e. (800) 814.9393, x441#,apenyomtsxam Oct 6 to responses of.three species of declining w 12 Brazil Special to ribalgExpedition ha sparrows in tallgrass prairie. Birz! am io 1996. madam a p-• ' me. Consery internal. 6:241-253. Siemer Iliad 'Btcom Ve(800) 451.321; (415) 788.4000; ttd®a� Wiser, D. W. 1990. Henslow•s Sparrow in Octnortheast Oklahoma. Bull Oklahoma On14 i 28 - Costa Rica Survey •'F Join field otNtholom at gi7bmtgttmo research stationfor"° mta-oermg Ornithol. Soc. 23:9-12. - • , dun climb Imo toMhOls Hod high irmwim fm fubumus fdtdlot• Holbrook1are Walk, J. W., E. L Kershner, and R. E. t*.. t �p hoibroomwtd...-- 451-1111,1, Warner. 2000. Nocturnal singing in � _ October & November - Two Trips to Australia . • grassland birds. Wiilson.Bulletiri.TWoaHoreable15•dur.mpsOfferV"meetpmiemIn 112:289-292. - "�,;, coe dwodd's mot fowesdng bbdiog desbxd m. . 1999•Nature 7Fard Holidays, (888) 305-3955; (613) 531410 Wells, J.V., and K.V. Rosenberg . 5; lofo®aanaeaatd.xm . Grassland bird conservation in north- Oct 30 to Nov 15 - New Zealand eastern North America. Studies in - R. SeeudgwaWetc+sotdweddlghdulWexexpertlodgvWeS ' Avian Biology 19: 72-80. :lath bat °a"rt"s Wdudfng pdtglc U1% Wiens, J. A 1969. An approach to the mot" to (7o7) 795-7547, CostaSorsRica oYW=x study of ecological relationships Dec S to 14 - Cruise Rica & Panama Canal f9 ps Bird Dadmfiv*and and tegmo, MarawN Cam VIM Rd 'a. among grassland birds. Ornithol. aaraaodabmapw sxessdtbsntaaaawfJbgmft®y . i 6amponropat Winter, M. 1999. Nesting biology of 3 : clipper CruiseIlse, (800) 8149393, x441#, aperry®mal oom Monogr. No. 8.93 pp dickcisseis and Henslows sparrows t southeastern Missouri prairie frag- Dry Tortugas - 4 trips in April and May tents. Wilson Bulletin. 111:515-527. pt NatureTotal, ( 36}1360 fm0gdf oet Pacific Northwest Pelagic Trips and J. Faaborg. 1999. Patterns of area sensitivity in grassland -nesting the Bird 6tdde,Y50) s44W6; fl d c= birds. Consent Bioi. 13:1424-1436. Ne fouCO, dl a dNand Br. Columbia, Newfoundland Nova Scotia —., D. H. Johnson, and J. Faaborg. ' , ,. .. oases loan, The. (615) 292.2739; chm*96ioLeam 2000. Evidence for edge effects on Hawaii - The Big Island • multiple levels in tallgtass prairie. Hawatlpoien & 'tralk (800) 4641993,thk@ wafl•fonscorn Condor 102:256-266. D(iiIII) r Central Oregon 8 scheduled trips t paradise BlrNoy (p41) 408-1753: Zimmerman, J.L .1988. Breeding season .≥,_ -` FkmoomaWwmepmydbm*fir io_rmdm habitat selection by the Henslow's rv„r„s s "y�ryutiam wdidmtl[y)aartelfamABA member Sparrow (Amrnodramas heuslawll) in atrd&e arw.wae :c tr TourcompaWmpayABna tw_Mhsl hreKh ABA puddpa t Kansas Wilson Bulletin 100:17-24. hriaiii r r r • WWW. AMER I CANB I RD ING.ORG - 153 SW WILSON SPRING TASK FORCE HYDROLOGY REPORT- ' DUANE WOLTJEN The delineated wetland (DW) receives critical water supply from Wilson Springs, other groundwater (water table), and surface water from surrounding land draining to the DW. The surface water is runoff from atmospheric precipitation. It flows on the surface and through the top -soil and vegetation. Small amounts percolate through the clay sub -soils to the water table. Groundwater migrates downhill toward the DW, Clabber Creek, and Wilson Springs, etc., but the recharging area for Wilson Springs and the DW are not defined by any research done to date. Higher ground to the southeast is off of the tract, but it is very likely the source of groundwater charging the springs and contributing to the wetlands supply. The future supply and quality of this water is not assured regardless of measures taken on the tract Groundwater is usually found in the water table generally below the top -soils, generally at the greatest depth below the surface on hill tops. It exits to the surface, at stream level, •springs and seeps, etc. The depth below the surface fluctuates over time, rising in wet • periods and dropping in dry periods. Twelve test pits dug with a backhoe by Grubbs, Hoskyn, Barton, and Wyatt, Inc. in proposed street rights -of -way in March of 2000, and April and July of 1999, indicate the water. table is at a depth of 2 to more than 7 feet • below the surface at the pits. Top -soils and vegetation may or may not have been soggy at the time these pits were dug, but no note was made of this in the field logs. "Observations made on at least 7 trips to the property from mid February to early June (of 2002) revealed all lowlands indicated on Map 1 to inundated with water regardless of whether land was classified by the US Army Corps of Engineers as wetlands or not."(Appendix, Radwell, page 3). Soil types in the lowlands suggest surface water "perches" on the low permeability clay sub -soils. Runoff distribution patterns remain generally consistent over time as runoff moves down hill unless the path is modified. Therefore, any particular portion of the DW receives a more or less consistent portion of the runoff from all precipitation events. The DW has developed as a function of these water distribution patterns. To protect and sustain the DW, It is necessary to avoid significant alteration of distribution patterns, or diversion of water to or away from the DW. Structures built in the watershed can disrupt the established distribution of rung thereby modifying the degree of wetness of affected portions of the wetland. Roads and • 0 x„ buildings, ditches or swales, surface topography or soil compaction can change the runoff pattern. • These structures can cause harmful changes in the DW unless corrective measures are taken. Structure variations such as pervious paving, curb -less streets, soil/aggregate filtration beds, and vegetated swales, etc., have been suggested as means to lessen changes to the runoff patterns. Pervious pavement, usually'used to provide surface water and nutrients to individual trees, is probably too expensive and difficult to maintain to look like a real street (weeds). Also, it's capacity to carry the loads imposed on motor vehicle streets or parking lots needs affirmation. Streets and Drainage •The street sub -grade investigations for street design, done by Grubbs, Hoskyn, Barton & Wyatt, Inc„ for the City, were reviewed by Duane Woltjen with Mr. John Hoskyn on. September 5, 2002. The reports shows the use of compacted "hillside fill" (a select clay and gravel mix) to a depth of 2.0 to 2.5 feet below top -soils in the sub -grade is necessary to support the pavement to achieve design load capacity because the native soil is too plastic and lacking in bearing strength. The existing sub -grade soils are replaced with the hillside fill. This is called an undercut sub -grade. It is a common technique in the region. • Compacted fill will be much less permeable than the native non -compacted soils. Therefore, the undercut sub -grade can be expected to impede permeable flow of water moving through the sub -soil when the fill is within the water table. As another alternative, the "hillside" fill could be replaced by 3"to 4" crushed rock, but it will eventually become clogged and fail as a conduit for water. Without corrective measures, even curbless grade level streets are a barrier to surface flow because the crown of the pavement is nearly 6 inches high for a 24 foot wide pavement The aggregate below the pavement contains much fine material. It is highly compacted and contiguous to the compacted sub -grade material. With preventing changes to the DW from concentrated or diverted runoff and maintaining existing flow to the DW as the goals, several wide-ranging ideas were explored by Mr. Hoskyn and. myself. We agreed the most simple, probably lowest cost, most reliable, and always maintainable design would have ditching on both sides of roads, culverts at frequent intervals to carry water to the downhill side of the road, and a filtering catch basins below each.culvert. These basins would be elongated along a contour line and have a level out -flow lip in order to redistribute the water flow transversely across the hillside. These simple, • 0 0 economical catch basins would be in the open where they can be easily monitored, • corrected and maintained. Mr. Hoskyn did not foresee any need to modify their reports because of the projected changes in drainage structures and street designs discussed. Mr. Hoskyn very generously spent two hours of his professional time. without charge, and offered to contribute more if needed. Buildings Large buildings will require the use of foundation piers especially in the lowlands, and removal of top -soil for poured concrete floors at ground level. Similarly to street undercut sub -grades, the removal of top -soil and replacement/compaction of the soil as well as footing walls will disrupt the natural flow of runoff through the top -soil and focus flows as they go around buildings. Piers will not have a significant impact in this regard on surface or groundwater because they are relatively small in size and relatively widely spaced. Focused runoff needs to be re -distributed the same as for roads and parking lots. Catch basins as suggested for the streets could be a good solution. I-540 Drainage • Some drainage from I-540, Shiloh Drive, and AR 112 enters the tract. The quality of this water is never pristine, and it is always subject to hazardous material spills of great magnitude. The Wilson Springs Branch is clearly critical habitat for the protected Arkansas Darter. Some drainage from I-540 enters the property through a 40 inch culvert immediately adjacent (8 feet to the south) to the 24 inch pipe carrying Wilson Springs flow from a source under Shiloh Drive. The water from the spring turns immediately toward and empties into the plunge basin at the outlet of the drainage culvert. It follows that a hazardous spill on the highway or Shiloh could be introduced into the spring branch at the immediate upstream end of the branch. Arkansas Darter would have no refuge in such an event. Fisheries biologists fear any modification to divert road drainage from the upper portions of the spring branch could impair the welfare of the Arkansas Darter and modify the DW. However, they realize that if nothing is done, sooner or later the practically inevitable disaster spill will happen, and the Arkansas Darter in this location (one of three known in Arkansas) could be history. The Arkansas Darter is also found in Colorado, Kansas, Missouri and Oklahoma I recommend prompt action to get control ingress of I-540 runoff into the DW, and particularly the Wilson Springs Branch. HazMat Teams should be made aware now of the need to protect the Wilson Spring Branch with appropriate priority. In some cases, I 0 their action could be as simple as blocking the inlets to the drainage culvert until the material is recovered. A permanent solution is virtually mandatory. Delineation of Wetlands The Wilson Springs tract lowlands are mostly fescue hay fields at present. Previously, soybeans were cultivated as long as twenty years ago according to observers. Prior to that some individuals believe it was mostly wheat fields. The land has been grazed by cattle in recent times. The presence of prairie mounds, certain hydrophytic prairie flora and fauna, and hydric soils are indicators of the pre -cultivation state. Such lands are called mesic-wet prairie or seasonal wetland (Terrestrial Natural Communities of Missouri, MDNR, 1985). Seismically inactive faults are known on the site. The site host, candidate rare and endangered species including the Arkansas Darter and Henslow's Sparrow, as well as many bird species with declining populations. (See Appendix, Joseph Neal.) An extensive inventory of flora and fauna has not been completed , The delineated wetlands were defined using procedures and criteria developed by the U.S: Army Corps of Engineers respective to enforcement of provisions of the Federal Water Pollution Control Act (33 U.S.C. 1344) including Section 404 which authorizes the Secretary of the Army, acting through the Chief of Engineers, to issue permits for the discharge of dredged or fill material into the waters of the United States, including wetlands. These procedures are found in the Corp's 1987 Wetlands Delineation Manual and updates. Some states and communities use standards accepted by the Corps, which have broader definitions of wetlands than the Corps. According to the Corps, a wetland is present when hydrophytic vegetation, hydric soil, and wetland hydrology, all three, are present. The absence of one or more indicators under normal circumstances precludes the presence of a wetland for the Corps purposes. The Corps prescribes methods of determination for Atypical (non -normal) Situations in Part IV, Section F. In case of an Atypical Situation, the manual prescribes procedures to find clues determining the true conditions for each element of determination. For example, an atypical situation is present when the site has been recently modified in a way that redirects runoff, beavers build a dam, vegetation is removed, etc. "Recently" is not defined, but the advent of sod -busting agriculture in Arkansas is a very recent event in terms of natural history. Hydric soils are produced when water saturates the top -soil for extensive periods (approximately 30 days or more) sufficient to produce an anaerobic condition and accompanying chemical reactions such as the formation of iron or manganese concretions.. S • • When such saturation occurs for sufficient time during the growing season, plants that adapt or are at home in this environment thrive. Those that do not tend to perish. Such • thriving plants are hydric vegetation. When water inundation present, the "hydrology" is obvious and certain. Otherwise the determination of hydrology is based on the presence of indicators of graded reliability. To delineate the wetland per the Corps manual, EGIS dug 75 test pits 12" diameter and 16" deep in locations dispersed effectively all over the entire tract. There is no location shown on the report map for holes 74 and 75. Their report states, "Approximately 75% of the site contains soils which are hydric or could contain hydric inclusions." Hydric soils are reported In the logs at all holes except 11,22,38,39,40, and 42, or 80% of the holes indicated hydric soils. A long edge of the delineated wetland is a straight line running north and south directly downhill parallel to and just a few feet east of the fiber optics line. Test pits on the east side of the fiber optic line were positive for all three indicators, but holes just west of the line and approximately lateral to the positive pits were lacking in one determinant, hydrology. The presence of "hydrology" was determined by the presence or absence of "oxidizing rhizospheres" in most pits. "Oxidizing rhizospheres", i.e., roots of hydrophilic plants that emit oxygen into surrounding soil, were absent from pits west of the line. It is important to know that the pits west of the line are in the fescue cultivated plantation. It Is Illogical to accept this line as the true boundary of the DW. How is it that (80%) of the logs report hydric soils if the hydrology does not exist under normal circumstances? Should remnants of hydric vegetation be logically expected in fields that have been cultivated for 20+ years? The test pits were dug in late August of 2000. Would surface saturation be expected? Many of the pits are located in cultivated areas, but there is no report of applying Atypical Situation procedures. I interviewed Manuel Bame, and Jon Drew Holt, signor of the field logs, of EGIS about this situation and other aspects of their work. Manual Bame did not state Atypical Situation procedures had been used, and he agreed to re -read Section F of Part IV. According to a chronology provided by interested citizens, on March 7, 1990, at a public meeting of the Fayetteville Planning Commission for rezoning the tract, Bob Waldren, a resident living near the site commented "— there is a flooding problem in the area of the of the proposed new industrial park". Jim Simon, another resident who lived near the site, stated, "— the subject property isn't fit for an industrial park because it is swampy". Ed Fedolkey, who lived north of the proposed rezoning mentioned, "—there are flooding 0 problems,—. Their reports are corroborated by the presence of hydric soils all over the lowlands, and hydrophytic vegetation dispersed in the fescue fields. • Research More information should be obtained by additional field research, but enough critical information is already published and presented to determine the development or preservation decisions for this tract. It is well understood that very important lowland habitat is at stake. The Arkansas Darter is heavily weighted for consideration in all development plans, but the Darter as well as many other species may be adversely affected by development. An excellent opportunity should be offered to students of the environment to study the effects of development if it proceeds, or restoration of the natural ecology if it does not. The site should be thoroughly inventoried before development begins and monitored for changes. The recharge area for Wilson Springs should be determined by experienced experts such as Mr. Tom Aley of Protein, Missouri. Dr. Van Brahana, hydrogeologist, University of Arkansas, has suggested this could be an excellent field laboratory for.0 of A students, and he would be willing to work with the city to devise a plan for cooperation. Various student research projects are in progress on the tract. Without the excellent detailed contributions of dedicated students and teachers of the natural sciences, Fayetteville would surely have taken action oblivious to the environmental consequences. Now it is well understood there will certainly be negative environmental consequences if construction is done in the lowlands. Recommendations Recognize that wetlands under the Corps definition could logically exist well beyond the delineated wetlands shown in the EGIS report in view of 80% of test holes reporting "hydric soils", the disparity of "hydrology" reported between test holes east and west of the fiber optic line, and the atypical conditions caused by persistent cultivation. If construction occurs in the lowlands, unusually high construction costs and difficulties because of excessive wetness should be anticipated by the City and disclosed to buyers. Only the southern high ground should be developed. Drainage designs protective of the lowlands should be utilized. The recommended use of the lowlands north and south of Clabber Creek is habitat conservation areas. They should be restored to the natural prairie state. These re - naturalized areas will partly mitigate loss of habitat on adjacent lands where developments such as a sports complex, housing, or commerce/industry are anticipated. They provide high quality runoff to dilute poor quality runoff in the critical Illinois River watershed. Since no delineated wetlands would be impacted, no mitigation would be necessary. Development of a sports complex including the lowlands north of Clabber Creek is feasible, but not recommendable. Potentially, wetness, drainage, mitigation, and runoff water quality would be among very significant cost issues in addition to the loss of habitat Clabber Creek should be allowed to simply revert to the natural state without further manipulation. Wilson Spring branch should be closely monitored to be sure changes in water quality, flow, and erosion do not adversely affect the Arkansas Darter. Wilson Springs Branch should be protected from hazardous I-540 drainage after delineation of the recharge area and evaluation of several means. If any land is sold, it should be with covenants protecting delineated wetlands and lowlands within the 289 acre tract. All developers should be bonded to assure compliance with development regulations protecting this site. Research on the tract site should be encouraged to record the hydrological outcome of development decisions for future guidance. Future issues similar to this one deserve professional environmental studies as well as professional engineering studies. Respectfully submitted, September 18, 2002 Duane W. Woltjen • Appendix Contents Wilson Springs Biological Issues, Joseph C. Neal and Andrea Radwell Wilson Springs Site Status Report, Andrea Radwell, July 9, 2002 References Arkansas Research and Technology Park, Wetland Delineation, EGIS Consulting, Job #1350 Manuel Barne Preliminary Geotechnical Investigation, McClelland Consulting Engineers, Inc., Job # FY903405 Jerry Jansma, March 1990 Street Sub -grade Investigations by Grubbs, Hoskyn, Barton & Wyatt, Inc. Job No. 99-196 Research and Technology Boulevard June, 1999 Job No. 99-262 Technology Drive August,1999 Job No. 00-073 Research and Technology Streets. April, 2000 The Terrestrial Natural Communities of Missouri, 1985, Paul W. Nelson, Missouri Department of Natural Resources. Wetlands Delineation Manual, U.S. Army Corps of Engineers, 1987 C • WILSON SPRING TASK FORCE HYDROLOGY REPORT= GARY COOVER This report is based on a thorough review of existing published information plus numerous conversations with local hydrological and geological professionals. It also contains a brief overview of wetland delineation requirements and methodology, a thorough review of the EGIS Environment Engineering and Construction wetland delineation for the Wilson Springs Business Park site, plus conclusions and recommendations based on a professional review of the available information. Wetlands The federal regulations implementing Section 404 of the Clean Water Act define wetlands as: Those areas that are inundated or saturated by surface or ground water (hydrology) at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation (hydrophytes) typically adapted for life in saturated soil conditions (hydric soils). Wetlands generally include swamps, marshes, bogs, and similar areas (40 CPR 232.2(r)). Jurisdictional wetlands those that are regulated by the U.S. Army Corps of Engineers under Section 404 must exhibit all three characteristics: hydrology, hydrophytes, and hydric soils (USACE 1987). The accepted scientific methodology for examining all three characteristics is presented in the U.S. Army Corps of Engineers (USACE) "Wetlands Delineation Manual" dated 1987. The procedures outlined in this manual were utilized by EGIS Environment Consulting in their September 1999 report of their investigations of 75 sampling areas on site. Although the site has been physically altered in the past by farming, grazing, etc., these alterations took place before the implementation date of the Clean Water Act and therefore do not require any sort of "atypical" wetland delineation methodology. The EGIS report has been approved by the USACE. llvdroloav From the 1987 USACE Wetlands Delineation Manual: "The term "wetland hydrology" encompasses all hydrologic characteristics of areas that are periodically inundated or have soils saturated to the surface at some time during the growing season. Areas with evident characteristics of wetland.hydrology are those where the presence of water has an overriding influence on characteristics of vegetation and soils due to anaerobic and reducing conditions, respectively." The "growing season" is officially defined as that portion of the year when the soil temperature 20 inches below the surface is 41 degrees Fahrenheit. According to the National Resource Conservation Service (NRCS), the growing season for the Fayetteville • area is from late March to early November, for a length of approximately 230 days. The frequency and duration of inundation or soil saturation are important characteristics in separating wetlands from non -wetlands. An area is considered to have wetland hydrology if it is inundated or saturated to the surface continuously for at least 5% of the growing season in most years (50% probability of recurrence). These areas are "wetlands" if they also meet hydrophytic vegetation and hydric soil requirements. The indicators of wetland hydrology are further subdivided into primary and secondary categories. The primaryindicators of wetland hydrology are: 0 Inundated 0 Saturated in Upper 12 inches 0 Water Marks 0 Drift Lines 0 Sediment Deposits 0 Drainage Patterns in Wetlands Only 16 of the 75 sampling locations had primary indicators. In 12 of the sites only one indicator was present, 4 sites had two indicators, none had more than two. At least one indicator must be present to indicate wetland hydrology. The secondary indicators of wetland hydrology are: 0 Oxidized Root Channels in Upper 12 inches 0 Water -Stained Leaves 0 Local Soil Survey Data 0 FAC-Neutral Test (a measurement of hydrophytic plants) 59 sites showed evidence of secondary indicators. One site had 3 indicators, 18 had two indicators, and 40 showed evidence of only one indicator. By far and away the most common indicator was "oxidized root channels in the upper 12 inches". Two indicators are required to indicate wetland hydrology. In several instances, the presence of FAC (facultative) biological species was used to provide the additional secondary indicator. None of the 75 data sampling points were located within obviously inundated areas, however, test pits were dug by EGIS to determine the depth to groundwater or depth to saturated soil. None of the 75 sample pits dug 18 inches deep showed any evidence of groundwater or saturated soils. This is perhaps due to the fact that these pits were dug during the fairly dry August of 1999. Soil boring logs from geotechnical investigations by McClelland Consulting Engineers, Inc., and Grubbs Hoskyn Barton & Wyatt, Inc., at various times of the year in 1990, 2000, and 2001 indicate a groundwater elevation of approximately three feet below the surface for much of the site. The hydrology of the site is mostly characterized as flow -through riverine as opposed to 40 depression outflow. The hydrology originates from a high water table, direct • precipitation, runoff, and possibly occasional overbank flow from Clabber Creek and the two tributaries on site. The Wilson Springs tributary is fed by the Wilson Springs headwaters located approximately 100 feet to the east of the property (and underneath the Shiloh Drive/Interstate 540 interchange), and by runoff from I-540 and its surrounding drainage area. The recharge zone for Wilson Springs has not been determined but is most likely located offsite to the east of the subject property. Bydric Soils The third component of wetland determination, after hydrology and hydrophytic vegetation, is the presence (or not) of hydric soils. Hydric soils are defined as soils that are saturated, flooded or ponded long enough during the growing season at some point in their history to develop anaerobic conditions in the upper part. These soils typically support hydrophytic vegetation. For a soil to be considered saturated, it must either be inundated or the groundwater must be within the root zone, typically 12 inches from the surface. However, not all areas having hydric soils will qualify as wetlands. Only when a hydric soil supports hydrophytic vegetation and the area has indicators of wetland hydrology may the soil be referred to as a "wetland" soil." • Soils from the 75 test pits dug by EGIS were examined for the following hydric soil indicators: 0 Histosol 0 Histic Epipedon 0 Sulfide Odor 0 Aquic Moisture Regime 0 Reducing Conditions 0 Gleyed or Low-Chroma Colors 0 Concretions 0 High Organic Content in Surface Layer in Sandy Soils 0 Organic Streaking. in Sandy Soils 0 Listed on Local Hydric Soils List 0 Listed on National Hydric Soils List Of the soils tested on site, 6 of the 75 samples showed no hydric indicators whatsoever. 57 samples showed only one indicator (gleyed or low -chrome colors), 1 sample showed evidence of reducing conditions, 8 samples had two indicators (color, odor, or concretions), and 3 samples had three indicators (color, odor, and concretions). No sample showed evidence of more than 3 hydric indicators. Prolonged anaerobic soil conditions cause a chemical reduction of some soil components, • mainly iron oxides and manganese oxides. This can be measured with Munsell Soil Color Charts to determine the extent of "gleying" the segregation or removal of reduced iron and manganese from the soil. Additionally, mineral soils that are alternately saturated and aerated during the year will exhibit spots or blotches called "mottles". The abundance and size of these mottles usually reflect the duration of the saturation period and indicate whether or not the soil is hydric. The EGIS Report lists the soil color and characteristics for each of the 75 sampling locations. Faults The potential existence of ground faults on this site has been raised by certain members of the public. Based on conversations with Wayne Jones, P.E., of McClelland Consulting Engineers, Inc., and Dr. Van Brahana, Geosciences Department, University of Arkansas, there are no active faults within this area; and any faults that do exist were created at the time of the Ozark Uplift several million years ago. These ancient faults'have shown no• recent movement whatsoever, even during the massive New Madrid earthquake of 1811. No fault study is indicated, and there should be no fault -related impediments to building or construction on this site. CONCLUSIONS AND RECOMMENDATIONS Wetlands Delineation • The EGIS report was performed per USACE specifications and represents a rigorous on - site wetlands detemvnation. As far as'5urisdictional wetlands" are concerned, this report should stand as approved by the USACE. Due to the fact that many of the wetland areas are considered very low grade, and many sample points just barely met the criteria for wetlands, these areas could be considered for potential development as long as USACE- approved mitigation is performed elsewhere within the property; Wilson Springs The drainage of I-540 into the Wilson Springs tributary presents a very real opportunity for habitat -damaging pollution. Since re-routing this drainage would be difficult at best, it is recommended that a small constructed wetland be established between the I-540 outfall .pipe and the Wilson Springs tributary to act as a buffer and cleanser for most of the harmful pollutants that could come from I-540. Business Park Development Except for low-grade wetland that could be replaced with mitigation, the majority of the wetland areas should probably remain untouched. As long as existing drainage patterns are substantially maintained, and flows are not concentrated into collection basins and storm sewers, the rest of the site hydrology should remain relatively unchanged. Efforts building foundations as little as possible. BMP's (best management practices) from the • National Pollutant Discharge Elimination System (NPDES) should be applied to all developed rung regardless of tract size. The proposed park development within the area north of Clabber Creek should have minimal hydrologic impact, since playing fields are mostly pervious surfaces. Care should be taken to not concentrate runoff in a way that would have a detrimental effect on the receiving wetland areas. The development plan that proposes impacting 17 acres of delineated "marginal" wetland would provide the best scenario for property development, and the mitigation subsequently improves and creates much better wetland areas elsewhere on the property. Future Research Dr. Van Brahana at the Geosciences Department of the University of Arkansas has expressed genuine interest in developing a program to monitor the development process in order to have quantifiable data about the potential effects of urbanization on the wetland environment. This would provide an excellent opportunity for the City of Fayetteville to work closely with the University of Arkansas to develop future guidelines for eco-sensitive development. • C SOURCES: Wetland Assessment Report, EGIS Environmental Consulting & Construction, Inc., September 1999 Preliminary Geotechnical Investigation, McClelland Consulting Engineers, Inc., 1990 Street Sub -grade Investigations by Grubbs, Hoskyn, Barton & Wyatt, Inc., June, 1999, August 1999, April, 2000 Conversations with: Manual Barnes and Drew Holt, EGIS Environmental Consulting & Construction, Inc. Wayne Jones, P.E., McClelland Consulting Engineers, Inc. Jim Beavers, City Engineer, City of Fayetteville NRCS local office Bruce Manchon, hydrologeologist, Janeil Environmental Solutions Dr. Van Brahana, Department of Geosciences, University of Arkansas CJ C • . . HYDROLOGY SUB -GROUP SUPPORTING DOCUMENTATION Ll • • WILSON SPRINGS BIOLOGICAL ISSUES • .• Biologically speaking, the 289 acres at Wilson Springs were originally a prairie with • distinctive upland and lowland characteristics. Relatively dry terrestrial habitat occupies a small portion of the southern uplands along Moore Lane, with elevations similar to those along the 1- 540 bypass. Most of the'remainder of the apparently terrestrial habitat is a seasonal wetland at the • lower elevations associated with Clabber Creek and its tributaries. This seasonal wetland has been converted to fescue pasture, but it retains ecological indicators different than those of typical • upland terrestrial habitats. WETLANDS Perennial wetlands are associated with Wilson Springs, Clabber Creek, and its tributaries. Wilson Springs supports a population of the rare Arkansas Darter (Etheostoma cragini). The U.S. Fish and Wildlife Service has reported that this darter is in jeopardy across its • range due to decline in groundwater that replenishes spring -fed habitats. In October 1999 it was designated a candidate species for listing under the Endangered Species Act. Seasonal wetlands are associated with grassy fields that. are wet during part of the year. Perennial wetlands have certain legal protections, but seasonal wetlands have little or none; they constitute the single most endangered habitat type in northwest Arkansas. Both wetland types are associated with prairie habitat that was once widespread in northwest Arkansas. The grasslands at Wilson Springs were part of the region's original prairies. These fields are marked by low "prairie mounds." These grasslands are deceptively dry during low rainfall periods. However, the water table in the area is high; it takes only modest amounts of rainfall to nurture shallow, seasonally wet habitat (with its associated plants and animals). • Seasonal wetlands form on clay -rich soils in the saucer -like depressions between these roughly conical mounds. These mounds have been greatly reduced through years of plowing, but are still visible in the.fnelds and in aerial photographs. Biologically -speaking, the seasonal wetlands can be delineated in a number of ways. The following conditions have been documented in the old prairie grasslands at Wilson Springs: a Numerous, widespread mud chimneys of the endemic Ozark Burrowing' Crayfish (Procambarus liberorum) that withstands dry periods by burrowing into the water table just below the surface. o Hydrophilic plants like Prairie Cordgrass (Spartinapectinata) are present, though much reduced because of aggressive drainage and conversion to non-native fescue grasses. Also present are shrubs like Buttonbush (Cephalanthus occidentalis) and Swamp Dogwood (Cornus obliqua), . o Stands of various semi -aquatic plants are common, especially Sedges (Cyperus _ species) that require water and dryness during part of their annual life cycle. o Damp prairie species like Sawtooth Sunflower (Heliannhus grasseserratus) are present and. form extensive stands. o Marshland birds —such as the small rail, Sora (Porzana carolina) and larger species like American Bittern (Boraurus lentiginosus)—are present during migration and are included among more than 125 bird species documented by volunteers. In summary, there is a strong positive correlation between biodiversity and presence of water. Wilson Springs supports a high biodiversity as a result of the high water table and presence of water on the surface much of the year.. • Wilson Springs also provides economically valuable ecological services by acting like a ! ' . natural detention area to slow the return of rainwater from the adjoining impervious surfaces such as businesses along 1-540, plus 1-540 itself and associated roads. Both wetland types also serve as purifiers of storm water runoff coming from these impervious surfaces. Fayetteville is under mandate of the EPA Phase 11 storm water regulations that require the City to undertake positive actions to improve water quality by addressing the fate of storm water. • Preserving the critical ecological values of both types of wetlands at Wilson Springs could allow the City to obtain credit for taking positive actions to preserve both seasonal and perennial wetlands —essentially, all of the lowlands within the 289 acres. PRISTINE ISSUE Critics of preservation efforts have stated that Wilson Springs isn't pristine; that is, it has little in common with places like the Buffalo National River that have been little altered from the natural state. However, no one favoring preservation has made the claim that Wilson Springs is pristine Support for preservation. rests on unique biological assets that have survived even after fundamental land use changes including long term farming, ditching Clabber Creek, and converting native grasslands to fescue. Some botanical 'remnants of the original prairie ecosystem, such as Big Bluestein Grass (Andropogon Gerard!) have survived and could form a core for a future habitat restoration. A relatively large group of grassland bird species that are declining range -wide in North America occur within the 289 acres. Notable among them is the rare Henslow's Sparrow (Ammodramus henslowir) whose only known Arkansas nesting site is in these seasonally wet fields. The 289 acres aren't pristine, but they are diverse. The area isn't pristine in terms of noise levels, either because of its location along I-540. There is a lot of traffic noise at times, but at other times the noise level is no worse than it is in much of Fayetteville along 1-540, College Avenue, Crossover/265, etc. The noise and lack of being pristine has not deterred joggers, walkers, golfers (on adjoining Razorback Country Club), • and birders. Nor has it discouraged occupation of private homes, churches, and small businesses along Dean Solomon Road. It hasn't deterred Audubon Arkansas from offering to join Arkansas Game & Fish Commission and establish a nature center on the site. WHAT'S AT STAKE, BIOLOGICALLY -SPEAKING As far as we know, the seasonal wetlands and associated grasslands at Wilson Springs constitute the single largest remaining block of such habitat in the region that is under. public ownership, and can therefore be managed for public (as opposed to private) purposes. (The approximately 300 acres acquired by Fayetteville for its proposed west wastewater treatment plant also features prairie mounds and seasonally wet habitat It may therefore provide a second opportunity to protect this habitat type.) While the number of acres is still relatively small, its situation adjacent the University of Arkansas and within a community of citizens with a more than average interest in biology and ecology provides an opportunity to study, preserve, restore, and last but not least, educate students and private citizens about a biologically important heritage that deserves our support and protection. Prepared by biologists Joseph C. Neal (ioecneal(Wiuno.com) and Andrea Radwell (aradwell(@uark.edu) —Draft of August 28, 2002 • FAYETTEVII!LE 40 THE CITY OF FAYETTEVILLE. ARKANSAS DEPARTMENTAL CORRESPONDENCE To: Gary Dumas, General Services Director From: Heather Woodruff, City Clerk Date: October 8, 2002 Attached is a copy of the resolution accepting a report of the Wilson Springs Tasks force. The original will be microfilmed and filed with the City Clerk.