programmatic biological opinion - fort benning · 2020. 2. 27. · fort benning's conservation...
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Programmatic Biological Opinion
Fort Benning's Conservation and Crediting Program for the Red-cockaded
Woodpecker (Picoides borealis) Through Off-Post Conservation and
Management of the Longleaf Pine Ecosystem
FWS Log#: 04EG 1000-2018-F-2869
Prepared for:
U.S. Fish and Wildlife Service Ecological Services - West Georgia Sub-Office
Columbus, Georgia 31995
By:
U.S. Fish and Wildlife Service Ecological Services- Raleigh Field Office
Raleigh, North Carolina 27606
1-,/21 /1013 Pete Benjamin, eld Supervisor Date Ecological Services U.S. Fish and Wildlife Service, Raleigh Field Office
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TABLE OF CONTENTS
CONSULTATION HISTORY ...................................................................................................................................... iii BIOLOGICAL OPINION ............................................................................................................................................ 1 1. INTRODUCTION ............................................................................................................................................ 1 2. PROPOSED ACTION ....................................................................................................................................... 2
2.1. Action Area ................................................................................................................................................. 3
2.2. On-Post Action Area ................................................................................................................................... 3
2.3. Off-Post Action Area ................................................................................................................................... 3
2.4. Tiered Consultation/Implementation Process ............................................................................................ 4
2.5. Off-Post Land Conservation Initiatives ....................................................................................................... 5
2.6. Off-Post Habitat Management Plan Requirements .................................................................................... 7
2.7. Red-cockaded Woodpecker Framework ..................................................................................................... 7
2.8. Interrelated and Interdependent Actions ................................................................................................. 18
2.9. Tables and Figures for Proposed Action ................................................................................................... 18 3. STATUS OF SPECIES ..................................................................................................................................... 20
3.1. Species Description ................................................................................................................................... 21
3.2. Life History ................................................................................................................................................ 21
3.3. Population Dynamics ................................................................................................................................ 22
3.4. Numbers, Reproduction, and Distribution ................................................................................................ 25
3.5. Conservation Needs and Threats .............................................................................................................. 26 4. ENVIRONMENTAL BASELINE ....................................................................................................................... 26
4.1. Action Area Numbers, Reproduction, and Distribution ............................................................................ 27
4.2. Action Area Conservation Needs and Threats .......................................................................................... 28
4.3. Tables and Figures for Environmental Baseline ........................................................................................ 32 5. EFFECTS OF THE ACTION ............................................................................................................................. 33
5.1. Effects of Ft. Benning’s Conservation and Crediting Program for the ...................................................... 33
Red-cockaded woodpecker Through Off-Post Conservation and Management of the Longleaf Pine Ecosystem .. 33 6. CUMULATIVE EFFECTS ................................................................................................................................ 38 7. CONCLUSION .............................................................................................................................................. 39 8. INCIDENTAL TAKE STATEMENT ................................................................................................................... 43
8.1. Amount or Extent of Take ......................................................................................................................... 44 9. CONSERVATION RECOMMENDATIONS ....................................................................................................... 45 10. REINITIATION NOTICE ................................................................................................................................. 46 11. LITERATURE CITED ...................................................................................................................................... 46
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CONSULTATION HISTORY
This section lists key events and correspondence during the course of this consultation. A
complete administrative record of this consultation is on file in the Service’s West Georgia
Sub-Office.
1994-22-September The U.S. Fish and Wildlife Service (Service) determined that military
training and related management activities at Fort Benning Army
Installation (Ft. Benning/Installation) were likely to jeopardize the
continued existence of the red-cockaded woodpecker (RCW) on Ft.
Benning.
2001-14 August Ft. Benning’s first Integrated Natural Resources Management Plan
(INRMP) was provided to the Service, followed with a request from Ft.
Benning on 22 August 2001 to initiate formal consultation on the INRMP
and associated Endangered Species Management Plans (ESMP), including
the RCW ESMP.
2002-27-September The Service approved Ft. Benning’s INRMP and ESMP which
implemented the 1996 Army RCW Guidelines and relieved Ft. Benning of
the Jeopardy Opinion issued in 1994 (FWS Log Number 99-0620).
2004-12-March Ft. Benning provided a Biological Assessment (BA) of the Construction,
Operation and Maintenance of a Proposed Digital Multipurpose Range
Complex (DMPRC).
2004-22- July The Service issued a final Biological Opinion (BO) on the DMPRC (FWS
Log No: 03-0584) which authorized incidental take for nine RCW groups
that were anticipated to be adversely impacted by the proposed action.
2007-13-April Ft. Benning provided a BA of the Base Realignment and Closure (BRAC)
Transformation and requested initiation of formal consultation.
2007-20-August The Service issued a final BO on BRAC Transformation (FWS Log No:
07-FA-0954) which resulted in 32 RCW groups anticipated to be
adversely impacted by the proposed action.
2008-27-October Ft. Benning provided a BA of the Maneuver Center of Excellence and
requested initiation of formal consultation.
2009-29-May The Service issued a final BO on the Maneuver Center of Excellence
(FWS Log Number 2009-FA-0118) which authorized incidental take for
81 RCW groups that were anticipated to be adversely impacted by the
proposed action.
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2014-09-April The Service issued general ACUB expansion concurrence letter (FWS
Log Number # 2014-CPA-0468).
2014-20-November The Service approved Ft. Benning’s RCW Endangered Species
Management Component (ESMC), which implemented the 2007 Army
RCW Guidelines (Service Log Number 2014-F-1128).
2015-11-September The Service issued a final BO on Enhanced Training at Ft. Benning (FWS
Log Number FF04EG1000-2015-F-0833).
2016-14-July Ft. Benning sent the Service a letter requesting concurrence on specific
ACUB expansion for 8,884 Acres.
2016-01-August The Service issued the specific 8,884-acre ACUB expansion concurrence
letter (FWS Log Number # 04EG1000-2016-CPA-0676).
2017-14-December Army Headquarters Installation Management Command (HQ-IMCOM),
Army Environmental Center (AEC), and Ft. Benning met with the Service
to discuss the development of the Programmatic BA (PBA), coupled with
discussions about the species dynamics of the RCW, so as to enhance the
development of the compensatory mitigation proposal.
2018-13-June Ft. Benning and AEC met with the Service to address comments and
revisions identified in the Draft PBA.
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BIOLOGICAL OPINION
1. INTRODUCTION
A biological opinion (BO) is the document that states the opinion of the U.S. Fish and Wildlife
Service (Service) under the Endangered Species Act of 1973, as amended (ESA), as to whether a
Federal action is likely to:
jeopardize the continued existence of species listed as endangered or threatened; or
result in the destruction or adverse modification of designated critical habitat.
The Federal action addressed in this BO is the Fort Benning Army Installation’s (Ft. Benning
/Installation) proposed Conservation and Crediting Program for the Red-cockaded Woodpecker
(Picoides borealis) Through Off-Post Conservation and Management of the Longleaf Pine
Ecosystem (the Action). This Programmatic Biological Opinion (PBO) considers the effects of
the Action on red-cockaded woodpeckers. The Action does not affect designated critical habitat;
therefore, this BO does not further address critical habitat.
A BO evaluates the effects of a Federal action along with those resulting from interrelated and
interdependent actions, and from non-Federal actions unrelated to the proposed Action
(cumulative effects), relative to the status of listed species and the status of designated critical
habitat. A Service opinion that concludes that a proposed Federal action is not likely to
jeopardize species and is not likely to destroy or adversely modify critical habitat fulfills the
Federal agency’s responsibilities under §7(a)(2) of the ESA. In this BO, only the jeopardy
definition is relevant, because the Action does not affect designated critical habitat. “Jeopardize
the continued existence” means to engage in an action that reasonably would be expected,
directly or indirectly, to reduce appreciably the likelihood of both the survival and recovery of a
listed species in the wild by reducing the reproduction, numbers, or distribution of that species
(50 CFR §402.02). The basis of our opinion for red-cockaded woodpeckers is developed by
considering the status of the species, its environmental baseline, the effects of the Action, and
cumulative effects.
The gopher tortoise (Gopherus polyphemus) is a federal candidate species that occurs on Ft.
Benning and lands containing suitable habitat adjacent to and near the Installation. The Service
and Department of Defense conferred on the Gopher Tortoise Conservation and Crediting
Strategy in 2017, with a framework similar to the one for this Conservation and Crediting
Program for the Red-cockaded Woodpecker. The Service rendered a conference opinion on the
gopher tortoise strategy on December 15, 2017. The Army’s ACUB partners will conduct
gopher tortoise surveys on ACUB properties identified under the RCW conservation and
crediting program. Where tortoises are detected, Ft. Benning will initiate the Tier 2 Conference
process outlined in the Department of Defense Gopher Tortoise Conservation and Crediting
Strategy to establish and maintain gopher tortoise conservation areas on ACUB properties as
appropriate to support Mission requirements.
A Conference Opinion (CO) is equivalent to a BO, but addresses species that are not yet listed
under the Endangered Species Act (ESA) and/or proposed critical habitats not yet designated.
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Therefore, the ESA prohibitions against jeopardy, adverse modification, and taking do not yet
apply. The Service may adopt a CO as a BO if and when the evaluated species/critical habitat are
listed/designated and while the action agency's discretion and involvement in the action continue.
This BO uses hierarchical numeric section headings. Primary (level-1) sections are labeled
sequentially with a single digit (e.g., 2. PROPOSED ACTION). Secondary (level-2) sections
within each primary section are labeled with two digits (e.g., 2.1. Action Area), and so on for
level-3 sections etc.
2. PROPOSED ACTION
The federal action for the purposes of this PBO, and initiating formal consultation under Section
7(a)(2) of the ESA, is the Army/Ft. Benning’s Conservation and Crediting Program for the
Red-cockaded Woodpecker (Picoides borealis) (RCW) Through Off-Post Conservation and
Management of the Longleaf Pine Ecosystem within Ft. Benning’s approved Army Compatible
Use Buffer (ACUB) Priority Areas (PA); hereafter referred to as the Ft. Benning RCW
Conservation and Crediting Program or Program.
Off-Post conservation of the RCW will occur on individual properties or conservation areas,
where a conservation area may be comprised of multiple and adjoining individual properties, and
includes the subsequent establishment and use of generated conservation values to offset any
adverse effects of military training, facilities development or specific forest management
practice, through a Programmatic Compensatory Mitigation Program.
This Action establishes a vehicle whereby Ft. Benning, in collaboration with the Service, will
seek to:
identify, acquire, enhance, reintroduce, and perform or support other conservation
activities (e.g. land protection, habitat management, species monitoring, etc.) that will
contribute to the conservation of ESA-listed species on individual properties and
conservation areas off of the Installation to generate “conservation credits,” and
utilize those conservation credits to offset any adverse effects to listed species of current
or future military installation-related training and other activities for the purpose of
ensuring that such activities can proceed without restrictions pertaining to listed species,
in compliance with Section 7(a)(2) of the ESA.
The analysis contained in the PBA and this Programmatic Biological Opinion (PBO) constitutes
Tier 1 of a two-tiered process. Tier 1 evaluates the effects of the proposed action at the program
level; establishes coordination, evaluation, monitoring and reporting requirements; and
determines whether the proposed action would be likely to jeopardize the continued existence of
listed species. The Tier 2 reviews will include analysis of beneficial effects from off-Post
conservation (Tier 2A), as well as project-specific jeopardy determinations developed in the
context of the environmental baseline recorded in the PBO, and include individual incidental
take statements documenting the “take” on-Post (Tier 2B).
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The proposed action would provide Ft. Benning with more flexibility to conduct training,
multiple-use natural resource management and infrastructure development (Army/Ft. Benning
2018). The Installation proposes that as conservation areas are formalized in the Tier 2 reviews,
their intent is that all incidental take for those geographic areas will eventually be fully offset via
the off-Post conservation actions and metrics identified within this PBO. Spatial distribution of
breeding groups and their territories is important to species viability, including groups on the
installation. Moving forward, Tier 2 actions will need to take into account the environmental
baseline established in previous consultations.
It is important to note that the program and processes identified in the PBA are tools that can be
utilized as part of ESA compliance for Ft. Benning. All actions on Ft. Benning will be evaluated
with standard section 7 methodologies and consultation to determine, define, and evaluate effects
to listed species. If during those standard and established processes it is determined that
compensatory mitigation is the preferred conservation measure then the process defined herein
will be utilized to provide the necessary conservation offset.
The PBA describes the proposed Conservation and Crediting Program as being comprised of two
tiers. The first tier is the programmatic section 7 consultation, to result in the issuance of a
programmatic biological opinion (PBO) that establishes the outline and formalizes the process
for streamlining consultation for second tier (Tier 2) activities. Tier 2 actions either add
conservation value/credits or will require incidental take of RCWs and associated debiting of
credits. Ft. Benning will develop individual action program reviews that will be tiered to the
PBO, which is consistent with the provisions of programmatic consultations. The tiered approach
allows the identification and consideration of site-specific information necessary to support both
an analysis of the effects of the Tier 2A and associated Tier 2B action, and the preparation of the
incidental take statement covering take associated with both the mission and conservation
activities identified in the project review.
2.1. Action Area
For purposes of consultation under ESA §7, the action area is defined as “all areas to be affected
directly or indirectly by the Federal action and not merely the immediate area involved in the
action” (50 CFR §402.02). The “Action Area” for this consultation includes the On-Post Action
Area and the Off-Post Action Area.
2.2. On-Post Action Area
The action area “on” Ft. Benning is defined by the geographic boundaries of known suitable and
occupied RCW PBGs in which military training, construction, operations, maintenance, and
recreation are identified to occur that may affect the RCW. For the purposes of this BO, we
include and analyze habitat occurring on Ft. Benning. However, Ft. Benning and the Service will
identify and evaluate the individual RCW PBG’s actually affected in the tiered site- or project-
specific consultations pursuant to the issuance of this PBO.
2.3. Off-Post Action Area
The action area “off” Ft. Benning is defined by the fullest geographic extent with the potential
for RCWs which contribute to the Installation’s Primary Recovery Population. This includes all
known and potential sites suitable now and in the future for the RCW in relation to habitat,
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natural population expansion numbers, and reintroduction, inside the Ft. Benning approved
ACUB PA boundaries. Ft. Benning and the Service will identify and evaluate the individual
conservation areas affected in tiered site- or project-specific consultations pursuant to the
issuance of this PBO.
2.4. Tiered Consultation/Implementation Process
2.4.1. Two-tiered implementation approach
Implementing this Action utilizes a two-tiered, programmatic approach pursuant to section 7(a)
(2) of the ESA, as further defined below. Ft. Benning will develop individual action program
reviews tiered to the PBO. The tiered approach allows the identification and consideration of
site-specific information necessary to support both an analysis of the effects of the Tier 2 A and
associated Tier 2B action, and the preparation of the incidental take statement (ITS) covering
take associated with both the mission and conservation activities identified in the project review.
(i). Tier 1 is addressed in the PBA and this PBO. Tier 1 analyzes the action as a whole for
beneficial and adverse effects to RCWs to determine whether the action is likely to jeopardize
the continued existence of these species. As necessary for the duration of the action, Ft. Benning
and the Service will review the progress of the action, considering (a) monitoring results
provided through annual reporting, and (b) best available data about the status of the species, to
determine whether conditions warrant reinitiating consultation. Final establishment of Tier 1
occurs with Service issuance of this PBO.
(ii). Tier 2 is the individual project level review and analysis, when requested by the Installation
pursuant to the Tier 1 PBO. Projects include both those that create conservation value/credits
(Tier 2A) and those that seek to apply such value/credits (Tier 2B) to offset adverse effects of
identified actions on the installation. If the project is fully consistent with the programmatic
action, the Service will rely on the findings of the Tier 1 PBO to formulate a project-specific
ITS, if take is reasonably certain to occur.
2.4.2. Consultation Implementation process outline
The following sections outline the process that Ft. Benning and the Service will use to implement
this conservation program, ensure ESA compliance is achieved, and species conservation metrics
are met in an efficient and timely manner.
(i). As the first step toward completion of this Tier 1 Consultation, Ft. Benning submitted their
PBA (this proposed Action) to initiate formal consultation.
(ii). The Service, pursuant to the ESA, will issue this PBO, analyzing the action and the process
of implementation as a whole, and thus finalizing the Tier 1 consultation.
(iii). As Tier 2A “Credit Actions” are identified or conservation milestones are met off-Post, Ft.
Benning will initiate a formal review request to the Service pursuant to the Tier 1 PBO. At a
minimum, the request shall include spatial information (maps or Geospatial Information Systems
(GIS) products), real property information (deed or easement), an individual property or
conservation area-specific habitat management plan, long-term management assurance (per
Army Authorities), summary of documentation surveys to date (habitat and species),
documentation of successful reintroduction of a new population or improved status of an existing
population (if applicable), and an assessment of conservation value (credits) generated.
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(iv). The Service will review the information submitted by Ft. Benning in “(iii)” above to ensure
it is consistent with the Tier 1 PBO. The Service will provide concurrence generating the
identified conservation/credit value or non-concurrence with comments to the request within 30
days of receipt.
(v). As Tier 2B “Offset/Debit Actions” are identified on-Post, the Installation will initiate a
formal review request to the Service pursuant to the Tier 1 PBO. At a minimum, the request shall
include spatial information (maps or GIS), summary of surveys to date (habitat and species), an
assessment of conservation value impacted (debits), and which corresponding “conservation
credit/value” generated in Step “(iv)” are proposed as the offset.
(vi). The Service will review the information submitted by Ft. Benning in “(v)” above to ensure
it is consistent with the Tier 1 PBO. The Service will then provide concurrence or non-
concurrence with comments to the request within 90 days of receipt.
(vii). The Service will maintain the administrative record for each conservation area, containing
all documents, including Tier 2A requests for the creation of the area and Tier 2B requests for
use of conservation credit/value from the area. The Service will also maintain a current summary
of credits and debits by conservation area/action, as well as copies of all monitoring reports.
(viii). Tier 2A and Tier 2B actions can be conducted or requested simultaneously or combined at
any time to ensure a sufficient conservation balance to meet the necessary offset. If combined,
both the Installation and the Service will ensure documents clearly articulate the intent and
individuality of each area for appropriate review and accounting.
2.5. Off-Post Land Conservation Initiatives
The Army has several authorities that allow them to invest and collaborate with eligible entities
for the conservation and management of land off-Post. These are usually through a partner via a
cooperative agreement undertaken on the Army’s behalf. While there are two main authorities
described below, this consultation is not limited to them alone. Ft. Benning and the Army will
explore and utilize any current or future authorities that result in in-perpetuity conservation and
management for the RCW that generate conservation value, as described later within this PBO.
The Installation explains in its PBA that the intent is to utilize these and other authorities to
ensure legal real estate interest and financial assurances are provided to maintain natural resource
durability for use as compensatory mitigation.
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2.5.1 10 USC 2684a “Agreements to Limit Encroachments and Other
Constraints on Military Training, Testing, and Operations.”
(i). The ACUB program operates under this authority.
(ii). Section (a) states that the Secretary of Defense or the Secretary of a military department may
enter into an agreement with an eligible entity or entities described in subsection (b) to address
the use or development of real property in the vicinity of, or ecologically related to, a military
installation or military airspace for purposes of—limiting any development or use of the property
that would be incompatible with the mission of the installation; preserving habitat on the
property in a manner that— is compatible with environmental requirements; and may eliminate
or relieve current or anticipated environmental restrictions that would or might otherwise restrict,
impede, or otherwise interfere, whether directly or indirectly, with current or anticipated military
training, testing, or operations on the installation.
(iii). Section (d)(2) requires that property or interests may not be acquired pursuant to the
agreement unless the owner of the property or interests consents to the acquisition.
(iv). Section (d)(3) states that an agreement may provide for the management of natural
resources on, and the monitoring and enforcement of any right, title, real property in which the
Secretary concerned acquires any right, title, or interest in accordance with this subsection and
for the payment by the United States of all or a portion of the costs of such natural resource
management and monitoring and enforcement if the Secretary concerned determines that there is
a demonstrated need to preserve or restore habitat.
(v). More details can be found in the full Code. However, the above provide the main framework
and concepts related to this authority.
2.5.2 16 USC 670 “Sikes Act”
(i). Specifically 16 USC 670c-1, section titled “Cooperative and Interagency Agreements for
Land Management on Installations.”
(ii). Section (a) states that a Secretary of a military department may enter into cooperative
agreements with States, local governments, Indian tribes, nongovernmental organizations, and
individuals, and into interagency agreements with the heads of other Federal departments and
agencies, to provide for the following: The maintenance and improvement of natural resources
located off of a military installation or State-owned National Guard installation if the purpose of
the cooperative agreement or interagency agreement is to relieve or eliminate current or
anticipated challenges that could restrict, impede, or otherwise interfere with, whether directly or
indirectly, current or anticipated military activities.
(iii). Section (b)(2)(a) states that for these Off-Post agreements, funds may be paid in a lump sum
and may include an amount intended to cover the future costs of the natural resource
maintenance and improvement activities provided for under the agreement. Such funds may be
placed by the recipient in an interest-bearing or other investment account, with resulting interest
or income being applied for the same purposes as the principal.
(iv). More details can be found in the full Code.
2.5.3. Ft. Benning and the Army intended to use these and other appropriate authorities to seek out,
identify, acquire, enhance, reintroduce, and perform or support other conservation activities that
will contribute to the conservation of the RCW off-Post contributing to the Installation’s Primary
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Core Population to generate conservation value and credit. Properties and investments will be
evaluated individually based on their potential to support and achieve the conservation metrics
outlined later in this PBO.
2.6. Off-Post Habitat Management Plan Requirements
This section identifies the mandatory Property and conservation area’s Specific Habitat
Management Plan (Plan) outline and requirements to maintain and enhance natural resource
durability toward compensatory mitigation for the target species and habitats. The Army’s
Headquarters, Installation Management Command (IMCOM) has approved an overarching
Comprehensive ACUB Land Management Plan (TNC 2017) which will serve as the
management plan for any individual properties or conservation areas and must guide and align
any other management plans for ACUB properties which are proposed for use in compensatory
mitigation. Below are the topics the Plan addresses.
2.6.1. Army and Service Approvals
(i). Plan is developed by the Partner/Cooperator Landowner, then reviewed and mutually
approved by Ft. Benning, IMCOM and the Service during the Tier 2A project reviews.
(ii). Management plans will be reviewed annually for operation and effect and revised as needed,
any major revisions will require the approval of both the Service and Ft. Benning.
(iii). Management plans shall be revised, updated, and re-approved by the Service and the
Installation at least every 10 years. Basic management plan components are outlined in Table 2-
1.
2.7. Red-cockaded Woodpecker Framework
The Installation and the Service recognize that multiple factors go into determining both the
aggregate mitigation potential (e.g., the prospective enhancement and improvement of RCW
demographic viability) of qualifying ACUB properties, defined herein as RCW Conservation
Values, and the degree to which the use of such mitigation identified in future Tier 2
consultations will be required. Furthermore, effective evaluation cannot identify and quantify
mitigation potential in the abstract. The nature, magnitude and duration of potential impacts to
RCW on Ft. Benning will have the potential to affect mitigation values provided by the ACUB
landscape largely due to the Installation’s impacts to potential RCW habitat use on both the
Installation itself and on the ACUB properties. Additionally, the aggregate RCW Conservation
Values provided by qualifying ACUB properties will be subject to change as a result of
subsequent additions to the set of qualifying properties, as additional properties are acquired or
put under conservation management and funded as previously described. External factors, such
as growth and distribution of the collective Installation and ACUB RCW population and suitable
RCW habitat, climactic variability, and the risk of stochastic events such as catastrophic fire or
natural weather/climate events may affect the potential distribution over the ACUB landscape of
future PBGs.
For all of these reasons, Ft. Benning and the Service anticipate that the determination of
available RCW Conservation Values will be an iterative process requiring periodic re-
examination and re-evaluation. This process will begin with the execution of the PBA and the
application of the methodologies and metrics outlined in Section 2.4.5 below to determine RCW
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Conservation Values (the number of future RCW PBGs; Net Present Conservation Value) for
use as mitigation in future Installation consultations. Assessment techniques may include
Pattern-Oriented Modeling (POM), Landscape Equivalency Analysis (LEA), other modeling and
GIS work products.
Previous modeling exercises completed in 2013 analyzed theoretical RCW occupancy of a
“max” and “corridor” ACUB protected and managed landscape along with a best and worst case
RCW population inside the Ft. Benning boundary. The modeling predicted a significant increase
in PBGs due to the addition of habitat on ACUB properties for all scenarios (ESM Inc. 2013).
An action proponent would need to test additional modeling scenarios when impact analyses
suggests demographic isolation is likely to occur between the Ft. Benning and ACUB properties,
or within the Ft. Benning boundary, or if it is determined that the anticipated amount and nature
of take might compromise recovery, even with the projected conservation values attributed to the
ACUB landscape. Army analysis will make initial determination on need to test additional
modeling scenarios and the Service will review those analyses through Tier 2 consultations as
described in this PBO.
2.7.1 Initial Identification of Available RCW Conservation Values
Ft. Benning developed a baseline habitat expansion process that was approved by the Service on
April 9, 2014 (FWS Log # 2014-CPA-0468). Ft. Benning’s July 14, 2016 letter identified an
approximately 11,061-acre area within the Chattahoochee Fall Line Wildlife Management Area
and ACUB boundary, to be considered as prospective baseline ecosystem service habitat for the
Installation for future use. Of this total, Ft. Benning estimated that about 8,894 acres are suitable
for restoration as fire-maintained, longleaf-dominated RCW habitat. In the Service’s August 1,
2016 letter, the Service determined that Ft. Benning’s review and analysis of its 8,894-acre
ACUB habitat expansion met the criteria outlined in the Installation’s baseline habitat expansion
process. Ft. Benning and the Service agree that these 8,894 acres of ACUB land, represents an
initial pool of RCW Conservation Values that can be evaluated for available PBGs for use as
offsets. We base this conclusion on the prior determination that the lands in question were
contiguously adjacent to Ft. Benning, protected against adverse land uses in perpetuity, were
subject to appropriate management plans, and had funding assurances in place (Service 2016;
FWS Log #2016-CPA-0676). This initial RCW Conservation Values determination will be
subject to re-evaluation as defined in the Tier 1 PBA and the Tier 1 PBO once issued.
2.7.2. Basis for Advance Credit Accrual
Generally, the Installation’s success in producing ecologically favorable forest stand structure
provides a basis for concluding that, with funding and management assurances, qualifying
properties or conservation areas can be managed to provide habitat for RCW in the future, given
those lands have the requisite soils and hydrology to establish good quality RCW habitat on off-
Post acreage within 3 miles of the installation boundary or on properties or conservation areas
which are contiguously adjacent to Fort Benning through adjacent connections to other
properties or conservation areas. Further, qualifying ACUB lands have the potential to provide
new capacity for RCW population growth and expansion. This, combined with artificial
recruitment capabilities through the installation of artificial cavities and the translocation of
RCWs, is the foundation of this consultation. Translocation will not be considered until suitable
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habitat on recruitment sites is sufficient to support demographically connected PBGs.
Additionally any translocation conducted would be in accordance with the Service’s Section
10(a)(1)(A) permitting process of which has already been evaluated in 2003 for incidental take
under a Service BO on the permitting process (Service 2003b).
2.7.3. Advance Credit Analysis
Through this Strategy, available mitigation will be determined based on habitat type and age.
The Installation’s PBA and this PBO assign increasingly greater mitigation value for
demonstrated management success as forest stands age, basal area measurements, and other
habitat values attain expressed desired conditions and provide foraging, nesting and occupied
fully restored habitat. This dynamic (increasing mitigation value is realized as habitat values
increase through management) is likewise consistent with the increasing conservation investment
associated with the acquisition and funding of habitat development activities, and the protection
from inconsistent management activities over time. The conservative design encourages ongoing
commitment to habitat management, and promotes restoration and management on a broader
landscape level. As a result, the framework provides for increased potential stability for the Ft.
Benning RCW population and increased flexibility for military Mission requirements.
2.7.4. Basis for Conservation Values
RCW recovery is dependent upon the availability and distribution of suitable forested habitat for
foraging, nesting and dispersal. To aid land managers in reaching RCW recovery goals, the
Service developed management standards as guidance in analyzing foraging and nesting habitat.
These standards aim to provide not only foraging and nesting habitat but also all desired future
conditions for RCWs, including mature stands of pine with an open canopy, low densities of
small pines, minimal or no hardwood or pine midstory, few or no overstory hardwoods, with
abundant groundcovers consisting of native bunchgrasses and forbs.
The actualization of these standards is dependent on space, time, and management success.
Some of the habitat standards are primarily dependent upon management success (e.g.,
ecologically suitable fire frequency, tree species and size, midstory requirements, ground cover,
etc.) making the RCW a conservation dependent/reliant species. Implementation of approved
management plans makes it reasonably certain that these RCW habitat criteria will be achieved
over time, as has been consistently demonstrated on numerous landscapes within the RCW
range, including on Ft. Benning.
With land management continuing to meet the standardized guidelines, the realization of future
foraging suitability and ultimately occupation of suitable habitat by RCWs is time dependent;
thus, it will be reasonably possible to predict when potential areas that are unsuitable or marginal
for foraging will become suitable. The distribution of future potential and suitable nesting
habitat across the landscape will then enable us to predict what specific areas are and will be
capable of supporting future RCW clusters at any particular point in time. The recognition that
achieving suitable habitat for nesting is also primarily a matter of time (tree age and diameter)
provides another time-step on the way to producing occupied habitat. Thus, with continued
appropriate management on qualifying ACUB lands, areas can be classified as: 1) Future
potential habitat: having potential to grow ecologically suited pine tree species but is currently
10
unsuitable and marginal habitat (currently unsuitable for RCW except possibly for dispersal),
typically 0-29 years of age; 2) Foraging habitat: including currently suitable foraging habitat, as
defined by metrics within the Service’s Foraging Habitat Assessment (FHA) management
standards and the acreage recommendations provided (Service 2003a), typically 30-59 years of
age; 3) Nesting habitat: including unoccupied but suitable nesting habitat, which must also
include suitable foraging habitat, defined by FHA standards with the addition of cavity tree
requirements (i.e., candidate trees available for either artificial cavity installation or natural
cavity excavation) (Service 2003a), typically 60+ years of age; and 4) Occupied fully restored
habitat: restored and managed suitable habitat supporting active PBGs (thus, both nesting and
foraging habitat).
The value to RCWs for each of these habitat categories increases as habitat transitions from
future potential habitat, to foraging habitat, to nesting habitat, to occupied fully restored habitat.
Similarly, the conservation investment increases as the habitat transitions due to land acquisition
costs, land management costs, and lost opportunity costs aggregating over time. Financial
investments and management costs yield conservation values to RCWs in terms of (1)
acquisition of potentially suitable RCW habitat, (2) institution and perpetual funding of
management regimes appropriate to development of RCW habitat values, and (3) the protection
of acquired lands in perpetuity, which provide mitigation values to RCWs. Further, the precept
that RCW habitat values increase based on continued forest growth and development is
supported by the recognition that as forest lands are managed for RCWs instead of for economic
returns from timber value, the increasing value the timber represents can be quantified as lost
opportunity costs (Drier 2005).
Based on the reasoning above, this framework utilizes the conservation benchmarks of future
potential, foraging, nesting, and occupied fully restored habitat types to quantify the current
mitigation value to RCWs of qualifying ACUB properties at any particular point in time.
2.7.5. Methodology for Calculating “Net Present Conservation Value”
(NPCV) Credits
When considering the three categories of suitable habitat (foraging, nesting and occupied fully
restored habitat), the current RCW conservation value of qualifying ACUB properties can be
described based on the aggregate acreage of each of those habitat categories. Thus, considering
each category in the context of conservation milestones and valuing each in such a manner is
reasonable. There are four supporting factors that the Service and the Installation considered to
assign percentage values to each milestone to ensure consistency with commensurate surrogates.
The first factor considered is that habitat conditions in the RCW Recovery Plan are generally
described in 1/3’s over the time span of 100 years:
Essentially about 30 years to grow suitable foraging habitat,
30 years as suitable foraging habitat,
and then 30 years plus as suitable nesting habitat.
The second factor is consistent with other mitigation valuations whereas approximately 50% of
the value is realized at the establishment of a conservation area and the remaining 50% is
realized when the area meets expressed desired future conditions (e.g., Recovery Standard;
11
Service 2003a). Values identified in this action are overall less and can thus be considered more
conservative. The third factor is the concept of lost opportunity cost which recognizes that the
further along a given acreage (type/age) is in the restoration process; the more valuable the
associated suitable RCW habitat would be in the context of supporting RCW foraging and
realizing future PBGs. As such, this factor accounts for, the increasing opportunity costs that
would be lost in foregoing other potential forest management scenarios (Drier et al. 2009; Glenn
et al. 2012) that could otherwise generate increased timber revenues. The fourth factor relates to
evaluating the actual and estimated cost of Ft. Benning’s ACUB program area as a whole. Based
on the existing Ft. Benning ACUB Priority Area 1 Goal of 40K acres, it is estimated that a total
$100M investment would secure protection of 40K acres. Through a collaborative effort with
partners, the Installation has determined that the Army’s interest in perpetual management of
those ACUB acres would cost approximately $500K annually which would be funded from the
interest generated from a long-term management fund. As a sum total, 100 years of management
in Army’s interest would expend $50M. In sum, the total investment would be $150M with 2/3
for protection and 1/3 for management. The ratios established in the Installation’s PBA and this
PBO establish a conservative approach when considering the nature of financial investments,
with a maximum of only 50% of the credit value afforded at the point in which a 65% investment
has been made (see Table 2-2).
Determining a precise fractional value for developing RCW habitat is challenging, although the
different concepts of mitigation values identified above (habitat values increase with age class,
conservation investments in acquisition and management increase over time, and timber
management values partially foregone increase with time) all support the concept. Acquisition
of lands with restoration and recovery standard potential, habitat protection, and a commitment
to restoration are the keys and essential steps for the entire process. Without the available lands
dedicated to conservation, the recovery landscape would not expand and land manager’s
prospects of attaining other milestone/metrics would be minimal. Accordingly, acquisition and
commitment of unforested or non-pine dominated lands toward future potential habitat generates
35% the total available credit for a tract. An additional 15% of the total available credit for a
tract is awarded if the lands conserved are existing pine dominated forestlands. To determine
“pine-dominated forest lands,” stands will be evaluated in a manner similar to that currently
utilized on Ft. Benning, the criteria of which are further described in Ft. Benning’s PBA as
Appendix B. The value of the earliest category that can serve as habitat for RCW foraging is
assigned a value of 15% and then another 15% value is assigned when restoration to nesting
habitat standards is achieved. Finally, the remaining 20% conservation/credit value is generated
and attained when habitat is fully restored and occupied by RCWs. This system generates an
incentivized program whereby continued achievement of milestones generates releases of
additional conservation value. In applying these concepts, a value for mitigation purposes can
then be calculated using the following proportional values per unit area:
Potentially-suitable, Unforested or Non-pine Dominated ACUB Lands = 0.35
Pine Dominated ACUB Lands = 0.15
Foraging Habitat Standard Achieved = 0.15
Nesting Habitat Standard Achieved = 0.15
Fully Restored/Occupied Habitat = 0.20
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To determine the mitigation value of the qualifying ACUB landscape, the acreage of each of the
first four habitat types (as described above) will be assessed and summed for all qualifying
properties. The current acreage of each of the first four habitat types will then be multiplied by
the corresponding proportional value (above), and then divided by 200, the approximate acreage
required to support a PBG (Service 2003a) unless further refined based on quantified site specific
conditions such as the Fort Benning Modified or Revised Standard for Managed Stability. This
yields the maximum available mitigation value for unoccupied habitat for consideration related
to any actions requiring mitigation and subsequent consultation of qualifying ACUB lands in
terms of PBGs at any given time. For occupied habitat, the PBG present will be considered as a
full offset independent of the acreage attributed to the active PBG. These processes will allow
Ft. Benning and the Service to reassess available conservation value periodically using this
framework, through continued evaluation of tracts as necessary to determine when stand age and
habitat reach milestones and conservation values released.
A sample calculation for these type actions, accounting for 10,000 acres of future potential
or suitable habitat, could be as follows:
5,000 acres potentially-suitable,
unforested or non-pine dominated: 5,000 X 0.35 = 1750 / 200 = 8.75 PBG
2,600 acres pine dominated: 2,600 X 0.50 = 1,300 / 200 = 6.5 PBG
1,400 acres foraging habitat: 1,400 X 0.65 = 910 / 200 = 4.55 PBG
500 acres nesting habitat: 500 X 0.80 = 400 / 200 = 2 PBG
500 acres occupied habitat with 3 active clusters = 3 PBG
TOTAL PBG = 24.8 PBG (24 NPCV PBG Credits available for consultation)
2.7.6. Evaluation of Conservation Values
Habitat suitability and prospective presence of future PBGs including physical and genetic
connectivity will be verified periodically. Evaluation methods will include population
monitoring within existing groups and application of landscape equivalency analysis (LEA)
criteria or similar techniques to measure the future population’s ability to fill demographic
vacancies. This will allow evaluation of the results of the framework application and identify
course corrections if necessary. As deemed necessary, evaluations will be conducted on five-
year intervals, as well as in the course of future section 7(a) (2) consultations in which LEA, or a
LEA-type analysis, is agreed to be appropriate. In the event that the model results indicate fewer
future PBGs than previously calculated through the methods above, the Service and Ft. Benning
will meet to discuss how the Installation should to proceed.
2.7.7. Adjustment of RCW Conservation Values in Subsequent
Consultations
As previously discussed, proposed project impacts on the installation may have effects on
available RCW Conservation Values on ACUB properties that Ft. Benning might use as
mitigation. Accordingly, Ft. Benning and the Service may consider the potential need to
recalculate available RCW Conservation Values whenever we may anticipate their use as
mitigation. Recalculation of available RCW Conservation Values (utilizing LEA or another
methodology) may not necessarily be required for all consultations in which Ft. Benning
proposes to use ACUB mitigation. For example, a consultation involving small-scale impacts, or
13
for a project that would not result in a high level of habitat fragmentation (and associated loss of
neighborhood-level demographic connectivity) may not require recalculation. Ft. Benning and
the Service will determine if recalculation of RCW Conservation Values is necessary through
Tier 2 consultations.
2.7.8. Tracking and Documenting Consumption of RCW
Conservation Values
A credit register of available (unutilized) RCW Conservation Values and of Conservation Values
that have been utilized as mitigation in consultations will be established for qualifying ACUB
properties and will be maintained by both Ft. Benning and the Service. As RCW Conservation
Values are utilized to offset Installation RCW impacts, the register will be adjusted to reflect
both the application of RCW Conservation Values as mitigation and remaining, unutilized
Conservation Values. Following such consultations, Ft. Benning will advise the Service in a
timely manner of the aggregate consumption of RCW Conservation Values and of the remaining
balance of unutilized Conservation Values.
Ft. Benning will update the register periodically thru formal or informal consultations to reflect
changes to RCW Conservation Values through the addition of new qualifying properties or other
factors that would result in beneficial or adverse impacts to RCW, either on or off the
Installation. The principal mechanism anticipated for updating the register to reflect available
(both new and previously existing but unutilized) RCW Conservation Values is through the
evaluation of available RCW Conservation Values as such values are proposed for use in
subsequent consultations.
2.7.9. Tracking Habitat Development Against Conservation Value
Long-term nesting and foraging habitat monitoring and reporting are critical for assessing
progress toward, and then maintenance of, the desired future condition of the off-site RCW
habitat (Costa et al. 2012). It is also critical to evaluating the premises upon which RCW
Conservation Values have been documented and utilized as mitigation. Monitoring will be
pursued at the individual property and conservation area and timber stand level. Habitat
development should proceed over time as expected and follow the estimated timeline for
restoration specified in each property and conservation areas specific Management Plan.
2.7.10. Monitoring Requirements
Potential habitat on conservation areas will be monitored in the same manner as on the
Installation to determine that pine stand grow-in and habitat development are proceeding on
schedule and are not delayed due to improper management, climatic variables, or for other
reasons. All RCW cluster and foraging habitat monitoring will follow guidelines established in
the 2003 Red-cockaded Woodpecker (Picoides borealis) Recovery Plan: Second Revision
(Recovery Plan) (Service 2003) or future revised edition of the Recovery Plan. Habitat variables
and conditions to be monitored and the specific methods and schedules for monitoring them will
be identified in each property or conservation area’s specific management plan (Costa et al.
2012).
Once RCW presence is documented on an ACUB property, population monitoring will be
critical for assessing progress toward, and then maintenance of, each property or conservation
14
area’s population goal. All RCW population monitoring will follow guidelines established in the
Recovery Plan (Service 2003a) and the Army Guidelines (U.S. Army 2007). Red-cockaded
woodpecker population monitoring involves measuring a range of variables related to both
habitat quality and RCW demographic parameters. Activities include, but are not limited to;
assessing cavity numbers and suitability, examining hardwood midstory conditions, small-
diameter pine stem densities, cluster and cavity activity checks, nesting season monitoring (e.g.,
banding nestlings, determining number of PBGs and fledglings, etc.) and translocation success.
Using the Recovery Plan standard guidance on RCW monitoring activities, each property or
conservation area’s specific management plan will specify how they will be accomplished, e.g.,
by census vs. sampling, within the framework of available guidance.
2.7.11. Reporting Requirements
Ft. Benning, in cooperation with partner landowners holding interest in properties with Army
Contingent Rights established, will provide the Service with a report for each ACUB property or
conservation area every five years. Initially, and until RCWs are established on a property or
conservation area, this report will summarize the progress and implementation of the habitat
restoration component of that property or conservation area’s management plan. Ft. Benning, in
cooperation with the Service will design a standardized habitat restoration report to streamline
status recording for all conservation properties. This report will be vital for informing both the
Army and Service on whether habitat restoration benchmarks and timelines are being achieved
(Costa et al. 2012). Once the first RCW occupy an ACUB property (basically indicating that
habitat restoration has been accomplished or is at least well advanced), the new RCW population
will at a minimum be incorporated into the installation’s annual report to the Service: the U.S.
Fish and Wildlife Service Regional Annual Red-cockaded Woodpecker Property Data Report
(Annual RCW Property Report).
2.7.12. Adaptive Management
To ensure that desired RCW habitat values are achieved on ACUB properties, land management
must be adaptive; that is, the response of natural systems to management actions must be
monitored and subsequent management actions modified accordingly. Adaptive management
and an ecosystem-based approach to natural resource management in general are not achievable
without monitoring. The results of monitoring must translate into information that land
managers can use to craft appropriate management responses to changing resource conditions.
In keeping with an adaptive management approach to natural resource management,
management plans for ACUB properties should be updated as often as necessary to incorporate
changes in environmental resources, management practices, regulatory requirements, or
scientific research and advancements (Army/Ft. Benning 2015).
(i). Verifying credits earned
Credits will be proposed and verified for use and accrual via the Tier 2A process for each
individual property or conservation area for which credit accrual is desired. This process will be
in the form of a comprehensive report containing all the necessary information identified in the
previous sections, prepared by Ft. Benning and submitted to the Service for review. Credits will
be released as soon as the metrics identified above have been met and the Tier 2A request has
been approved. Based on the most recent forest inventory data and any updates as a result of
forest stand improvement actions, an analysis will be completed to determine the acreages of
15
habitat [future potential (both pine and non-pine dominated), foraging and nesting habitat], at the
stand level, which will be used to determine Credit calculations.
For Credits to be calculated at the future potential habitat rate, a determination shall be made as
to whether a given stand is pine or non-pine dominated. Calculations for foraging and nesting
habitat will utilize the Ft. Benning Modified Standard for Managed Stability (FBMSMS)
(Army/Ft. Benning 2018). As such, for credits to be calculated at the foraging habitat rate, any
individual stand must be at least 30 years of age and the average basal area of pines ≥10 inches
diameter-at-breast-height (dbh) must be at least 30 square feet (ft2)/acre. In addition, average
basal area of pines < 10 inches dbh must be less than 20 ft2/acre and hardwood midstory, if
present, must be sparse and less than seven feet in height. For credits to be calculated at the
nesting habitat rate a partition(s) will be delineated and an FHA will be completed. The FHA
will need to demonstrate that all RCW partition variables established for the FBMSMS are met,
to include habitat connectivity standards for the given property or conservation area(s) analyzed
in Tier 2 consultations in order to demonstrate ability for supporting future PBGs with not less
than three existing or future neighbors within a 1.25-mile radius, to allow the nesting habitat rate
to be defined in terms of credits. Credits calculated at the fully restored and occupied habitat rate
shall be dependent upon PBG occupancy of a delineated partition. Stands will be mapped in GIS
after Service review and distributed to both parties. Table 2-3 identifies milestones for credit
release. Requests for credit accrual can occur indefinitely but will be appropriately timed with
milestone achievements for each property or conservation area. Re-verification may also be
requested to further document conservation lift (how the beneficial action has improved the
recovery landscape for the listed species) and population expansion to receive the full credit for
expansions and enhancements, subject to additional Tier 2A requests.
(ii). Credit Accounting
The Service will maintain a comprehensive and updated record of the conservation value/credits
earned by the Installation throughout the implementation of this process. Since the Service
review and concurrence of credits earned is a Tier 2A project review to the Tier 1 PBO, this will
aid in both documentation of the credits and adherence to the PBO in a seamless manner and
provide a single point of accounting. Ft. Benning will also maintain a comprehensive and
updated record of the conservation value/credits earned by the Installation throughout the
implementation of this process to ensure dual accounting to minimize potential errors in tracking.
2.7.13. Debit Quantification, Verification, and Accounting
(i). Quantifying debits
The qualifying ACUB properties provide substantial conservation benefits to the Ft. Benning
Primary Core Recovery Population RCWs, expressed in this consultation as RCW Conservation
Values. It is unlikely but not inconceivable that any single consultation would exhaust available
Conservation Values. When RCW Conservation Values are proposed for use in consultation, Ft.
Benning will evaluate the effects of the action no differently than any other consultation. Effects
will be evaluated and summarized to determine the amount and extent of “take” that is expected.
Some PBG’s will be removed completely due to construction projects and/or other installation
activities where the ecosystem is impacted to the point that RCW can no longer persist in that
area. These will be the simplest projects to evaluate as incidental take will be directly correlated
to an off-Post earned PBG to serve as the offset. As it relates to these types of complete removal
16
“takes,” the cumulative effects of all actions shall not result in less than 250 occupied PBGs
associated with the Ft. Benning Primary Core Recovery Population on- and off-Post, at any
given point in time. A population size of 250 PBGs is sufficient to withstand extinction threats
from environmental uncertainty, demographic uncertainty, and inbreeding depression (Service
2003a).
There are also RCW “takes” that are calculated and modeled that do not degrade the ecosystem
to the point that RCW do not continue to persist. The easiest example is the calculated reduction
of foraging habitat that results in “take;” however, in high-quality habitat it is well documented
that even at below-Service recovery standard foraging habitat partition acreages, RCWs often
persist on the landscape relatively unaffected and therefore are not truly “taken.” In this instance
the taken PBG will be offset with an off-Post PBG as in the permanent take scenario, however
that take will in essence be held in escrow for a period of not less than one but no more than five
years, as determined based on Tier 2 Consultation. The Army and the Service recognize and
anticipate that more significant habitat removals would likely require longer monitoring periods
to confirm PBG retention in these scenarios. The on-Post “take” will then be monitored and if
that PBG persists for the period of years identified in the Tier 2 Consultation then it will no
longer be considered taken and the escrowed PBG will be returned to the overall balance of
available PBG’s for use as mitigation.
Generation of the conservation value will be presented in a Tier 2A project review documenting
the appropriate value earned, and offset use may then be requested in a Tier 2B debiting project
submitted to the Service for review – both pursuant to the Tier 1 PBO. Conservation value
generation and use may be completed in a single document with clear accounting of both as
described in this document.
(ii). Debit accounting
The Service will maintain a comprehensive and updated record of the debits (take) generated by
the Installation throughout the implementation of this process. Since the Service review and
concurrence of a credit offset of debits is a Tier 2B project review to the Tier 1 PBO, this will aid
in both documentation of the debits and adherence to the PBO in a seamless manner, and provide
a single point of accounting.
2.7.14. Credit Stacking
The ecological communities being conserved both on and off-Post support or have the potential
to support several native proposed, candidate and federally listed species with overlapping
occurrence ranges. Where consultations involving these species arise, credit calculations for each
species will be accounted for separately as a standalone analysis for that individual species
initially. Species overlap will then be determined utilizing mapping techniques to determine
individual species and “stacked” credit acres available. For each conservation area there may be
multiple combinations of individual and stacked credits depending on species status and extent.
Individual species credit acres will be correlated to individual species debit acres as previously
described for RCW in the fore-mentioned sections. Stacked credits can also be correlated to
stacked debits as long as the extent and analysis of each species in the stacked credit aligns with
the debit. Another option is to decouple or unstack, “stacked credits” for use in offsetting debits
of an individual species. In this event the other species contained in the stacked credit will no
17
longer to be able to be used for compensatory mitigation. This reduces the potential for double
dipping and or double counting of the same credit-acre more than once. In all cases where
stacked credits and debits are generated or used, additional due diligence and scrutiny in
accounting is necessary to preserve an accurate balance.
2.7.15. Credit Accounting with Multiple Investors
Conservation value for RCW mitigation may only be accrued for that portion of the ecological
lift (the additional overall ecological increase realized in species numbers or habitat acres above
a defined current condition or baseline) underwritten by investments of Ft. Benning and their
partners whose funding sources allow use of their funds for mitigation by the Installation. Ft.
Benning will coordinate with any partners on the use of their funding towards mitigation to be
used by Ft. Benning. A letter of intent and action will be completed by each partner documenting
the full transfer of all conservation value/credit generated by their actions/investments that will
be assigned to Ft. Benning for use as compensatory mitigation. To prevent “augmentation of
appropriations”—e.g., the unauthorized transfer of funds between appropriations, none of the
Service grants under ESA Section 6 may be used for mitigation. However, other federal funds
may be used as long as they meet the intent of the following:
A federal agency may not augment its appropriation from, or transfer funds to, sources
external to the appropriation per se without specific statutory authority. The rule against
augmentation is derived primarily from the “purpose statute” and the “miscellaneous
receipts statute,” where appropriated funds may be used only for their intended purposes
(31 U.S.C.1301 (d)).
The objective of the rule is to prevent a Federal agency from undercutting the Congressional
power of the purse by circuitously exceeding the amount that Congress has appropriated for a
specific activity. Any comingling of federal funds on properties or projects will need to be
evaluated individually based on their root statutory authority and appropriation.
Portioning of an ecological lift and the associated conservation value/credit generated according
to financial contributions avoids the difficulty of determining the actual ecological lift
attributable to each funding source, action, and acquisition. Because there are so many sources of
funding for conservation, and these funds have been intermingled and the conservation actions
distributed within and between multiple sites for multiple years, Ft. Benning and partner’s
proportion of the total funds expended on a given site will be used as a surrogate for ecological
lift. As legally permitted, in some scenarios a partner may choose to defer or transfer all or a
portion of the ecological lift, and the associated value/credit attributed to their contribution, to
Ft. Benning for use in consultations.
A sample calculation for these types of actions/accounting could be as follows and would then be
subject to considerations contained herein and the conservation value calculation in 2.7.4:
1) 3,500 Acre Fee Simple Acquisition: $5,000,000 Ft. Benning + $1,000,000 ACUB Partner
+ $1,000,000 Service Section 6 Grant = $7,000,000 total.
2) Long Term Management of 3,500 Acres = $1,000,000 Ft. Benning total.
3) Proportion Assigned to Ft. Benning = $7,000,000/$8,000,000 = 0.875 (8.75%)
18
4) Area that will not support habitat (3,500 Acres total – 500 Acres wetland) = 3,000 Acres
that will support future habitat.
5) Total Credits = 3,000 acres for Ft. Benning Credits = 0.875 x 3,000 = 2,625.0 acres
2.8. Interrelated and Interdependent Actions
A BO evaluates the effects of a proposed Federal action. For purposes of consultation under ESA
§7, the effects of a Federal action on listed species or critical habitat include the direct and
indirect effects of the action, plus the effects of interrelated or interdependent actions. “Indirect
effects are those that are caused by the proposed action and are later in time, but still are
reasonably certain to occur. Interrelated actions are those that are part of a larger action and
depend on the larger action for their justification. Interdependent actions are those that have no
independent utility apart from the action under consideration” (50 CFR §402.02).
In its request for consultation, the Army/Ft. Benning did not describe, and the Service is not
aware of, any interrelated or interdependent actions to the Action. Therefore, this BO does not
further address the topic of interrelated or interdependent actions.
2.9. Tables and Figures for Proposed Action
Table 2-1: Site-Specific Habitat Management Plan Outline
Goals and Objectives
1. Goals
a. Objectives to achieve goals
b. Metrics to measure success
Compatible Land Uses
i Must define a list and/or limitations to be compatible
Incompatible Land Uses
i. Define a list of incompatible uses
Prescribed Rx Burning
i. Dormant and growing season burns
ii. Two- and three-year fire return interval upon initial introduction of Rx fire
iii. Burn units and maps
iv. Firebreak construction and maintenance
v. Unique or sensitive considerations (e.g., reducing smoke and preventing
burning out of prescription)
Invasive Species Management
i. Animals targeted
a. Trapping
b. Shooting
c. Exclusion
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ii. Plants targeted
a. Hand removal specs
b. Mechanical removal specs
c. Herbicide use
Habitat Enhancement and Monitoring
i. Species used
ii. Planting methods
iii. Monitoring method
a. Items measured
b. Frequency
c. Statistics used
Species Enhancement and Monitoring
i. Reintroduction methodology
a. Translocation
ii. Population monitoring method
a. Items measured
b. Frequency
c. Statistics used
Other Federally Listed, Candidate, or Proposed Species
i. Identify other ESA-regulated species present and methodologies for minimizing
effects on them while maximizing collective benefit.
Adaptive Management
i. Describe how adaptive management will be employed to facilitate
implementation of the plan.
Budget and Implementation
i. Establish the process for identifying costs and securing funding assurances for
anticipated costs for the near term (ten year) restoration actions and perpetual
annual management requirements.
Reporting
i. Partner reporting process and timeline for adverse impacts (trespass, wildfire,
species harm, etc.).
ii. Partner reporting process and timeline for significant events (species survey,
translocation, research completion, education outreach events, etc.).
iii. Partner(s) providing ACUB Annual Report(s) to the Army prior to or upon the
Army established suspense date each year.
iv. Army/Ft. Benning consolidates with partner(s) for reporting to Service within
90 days of receipt of ACUB Annual Report by providing written report.
20
Table 2-2: Estimated cost of Ft. Benning’s ACUB program
Army anticipated cost of protecting 40,000 acres in the ACUB area = $100,000,000.
Management cost to the Army (with partner contributions) = $500,000/year; Funded
from the interest generated from a long-term management fund.
Cost of 100 years of management in Army’s interest = $50,000,000 ($500,000/year X
100 years).
Total investment by the Army = $150,000,000; 2/3 going toward protection; 1/3 going
toward management.
Army accrues 50% of credit value counted as conservation for RCW at the point in
time when the Army has made 65% monetary investment.
Table 2-3: Red-cockaded Woodpecker Credit Release Schedule for Conservation
Milestones
Event or Milestone Credit Release
Administrative: Purchase of
Easement or Property in Fee Title No RCW Credit Earned or Released
Administrative: Approved Habitat
Management Plan No RCW Credit Earned or Released
Administrative: Funded MED,
Stewardship Endowment, or
Sufficient Management Assurance
1st Phased Release:
35% Value/Credit Earned & Released for unforested
or non-pine dominated ACUB Lands
Additional 15% Value/Credit Earned & Released for
pine dominated ACUB Lands
Habitat Milestone 1 Achieved
(Foraging Habitat) 2nd Release: 15% Value/Credit Earned & Released
Habitat Milestone 2 Achieved
(Nesting Habitat) 3rd Release: 15% Value/Credit Earned & Released
Population Expansion Successful
(PBG Established) 3th Release: 20% Value/Credit Earned & Released
3. STATUS OF SPECIES
This section summarizes best available data about the biology and current condition of red-
cockaded woodpeckers (Picoides borealis) throughout its range that are relevant to formulating
21
an opinion about the Action. The Service published its decision to list red-cockaded
woodpeckers as endangered on October 13, 1970 (35 FR 16047).
3.1. Species Description
The RCW is a small woodpecker, measuring about 7 inches in length, with a wingspan of about
15 inches, and weighing about 1.7 ounces (47 grams; Service 2018). Its back is barred with
black and white horizontal stripes, and is distinguished from other woodpeckers by a black cap
and nape that encircle large white cheek patches. Adult males possess a tiny red streak or tuft of
feathers, the cockade, in the black cap near each ear and white cheek patch. The small cockade
usually is covered by the black crown, except when protruded during excitement, and is not
readily visible except upon close examination or capture. Adult males and females are not
readily distinguishable in the field. Juvenile males have a red crown patch until the first molt,
which can be distinguished from the black crown of juvenile females (Service 2018).
The RCW occurs primarily in pine and pine-hardwood forests of the piedmont and coastal plain
of 11 southern/southeastern states, including Alabama, Arkansas, Florida, Georgia, Louisiana,
Mississippi, North Carolina, Oklahoma, South Carolina, Texas, and Virginia (Barron et al.
2015).
3.2. Life History
The RCW is a territorial, non-migratory, cooperative breeding species (Lennartz et al. 1987;
Walters et al. 1988), and the only North American woodpecker that exclusively excavates its
cavities for roosting and nesting in living pines. Each group member has its own cavity,
although there may be multiple cavities in a cavity tree. RCW chip bark and maintain resin wells
on the bole around the cavity where the fresh flow of sticky resin is a deterrent against predatory
snakes (Rudolph et al. 1990) and indicates an active cavity tree. The aggregate of cavity trees,
surrounded by a 200-foot, forested buffer, is called a cluster (Walters 1990). Cavities within a
cluster may be complete or under construction (starts) and either active, inactive or abandoned.
Clusters with one or more active cavity tree are considered as active RCW clusters.
The RCW lives in social units called groups. This cooperative unit consists of a single male or a
monogamous breeding pair, offspring of the current year, and 0–4 adult helpers (Walters 1990).
Helpers typically are male offspring from previous breeding seasons that assist the breeding pair
by incubating eggs, feeding the young, excavating cavities, and defending the territory (Ligon
1970, Lennartz et al. 1987, Walters et al. 1988). Some large populations have instances,
although very infrequent, of female helpers (Walters 1990; DeLotelle and Epting 1992; Bowman
et al. 1998). Clusters only occupied by a single adult male are classified as single bird groups,
while an adult male and female with or without helpers occupying the same cluster is classified
as a potential breeding group (PBG).
The RCW is territorial and each group defends its home range from adjacent groups (Hooper et
al. 1982; Ligon 1970). The defended territory includes habitat used for cavity trees and foraging.
RCW feed mostly on a variety of arthropods, particularly ants and wood roaches, by foraging
predominately on and under the bark of larger and older living pines (Hooper 1996; Hanula and
Franzreb 1998). Males tend to forage in crowns and branches, while females commonly forage
22
on the trunk. Dead and dying pines are important temporary sources of prey, and hardwoods are
used occasionally. Group members forage together each day in parts of their territory.
RCW have large home ranges relative to their body size. RCW tend to forage within 0.5 miles
of their cluster. RCW groups forage within a home range that is highly variable, from as little as
86 acres to as much as 556 acres (Conner et al. 2001; Service 2003a). Home range size is
variable within and between populations, but tends to reflect foraging habitat quantity and
quality, boundaries of adjacent RCW territories, and possibly cavity tree resource availability
(Conner et al. 2001; Service 2003a).
Because of the foraging behavior of RCW, a 0.5-mile radius is used to establish survey areas to
identify any unknown RCW clusters that may be affected prior to clearing or removing any
potential RCW habitat. The 0.5-mile survey area provides a high probability that any unknown
clusters will be identified that potentially use habitat within the area to be affected. This is based
on RCW foraging ecology and behavior, the limitations of natural cavities to population growth
at Ft. Benning, the ecology of RCW population growth via the formation of new clusters/groups,
and relationship of habitat used for foraging within 0.5 miles of a cluster center.
A 0.5-mile radius circle around a cluster center encompassed an average of 91% of the actual
home ranges of RCW groups in a North Carolina study (Convery and Walters 2003). Thus,
unknown Ft. Benning clusters identified by surveys within 0.5 miles of the edge of clearing or
construction likely will have the vast majority of their foraging habitat somewhere within this
0.5-mile area.
3.3. Population Dynamics
The RCW is long-lived, with individuals frequently living up to 10 years or longer. For a bird of
its size residing in temperate regions, the RCW exhibits exceptionally high survival rates.
Survival rates of adult male helpers and breeders generally are about 5 percent higher than that of
breeding females. There is distinct geographic variation in survival; survival rates are about 75
percent for males and 70 percent for females in the northern, inland population in the North
Carolina Sandhills, about 80 percent and 75 percent respectively in coastal populations in North
Carolina, and 86 percent and 80 percent respectively in central Florida. Such an association
between increased survival and reduced fecundity is common in animal life histories. Annual
variation in adult survival within populations is sufficiently small that it can largely be attributed
to random chance rather than changes in environmental conditions (Walters et al. 1988). This
level of variation can have large effects in small populations, however, and it appears that there
are occasional poor years in which survival is substantially reduced. Also, some populations are
vulnerable to periodic catastrophic mortality due to hurricanes. With survival rates as high as
these, it comes as no surprise that some individuals live to old ages. A captive female lived to 17
years (J. Jackson, pers. comm.), and a male in the North Carolina Sandhills lived to 16 years of
age in the wild (J. Carter III, pers. comm.).
Survival during the first year is more prone to underestimation than survival at subsequent ages,
due to the greater possibility of dispersal out of the sampling area. Nevertheless, it is quite clear
that survival rates are much lower during the first year than thereafter. Overall the mortality
pattern is fairly typical of cooperatively breeding avian species. It is characterized by relatively
23
low survival during the first year, especially of dispersers; relatively high survival of breeders
and helpers; and senescence at the end of the life span. Compared to non-cooperative species,
survival of both juveniles and adults is high, and the life span is long.
Pairs are highly monogamous and about 90 percent of PBGs nest each year during the April to
July nesting season. Females usually lay three or four eggs in the cavity of the adult male. The
short incubation period lasts approximately 10 days, and eggs hatch asynchronously. Normally,
one brood is produced as a result of one or perhaps two nesting attempts involving only two
parents. Most groups that attempt nesting fledge young, as nest failure rates are low for a species
in the temperate zone, although fairly typical for a primary cavity nester (Martin and Li 1992,
Martin 1995). Nestlings fledge after 24 to 29 days, although all nestlings rarely survive to
fledglings. Partial brood loss of nestlings is common in RCW, although number of hatchlings
successfully fledged tends to increase with group size. Also, older and more experienced
breeders have greater reproductive success (number of fledglings), which is maximized at about
seven years of age, after which it declines sharply at nine or greater years of age (Reed and
Walters 1996). About 20 percent of nests will fail completely, without producing a single
fledgling. Groups with helpers experience whole brood loss less frequently than breeding groups
without helpers. Renesting rates are geographically and annually variable. In good years, up to
30 percent of breeding groups will renest. Productivity of the second nesting is lower. Nest
predation, nest desertion, and loss of nest cavities to cavity kleptoparasites appear to be the
primary causes of nest failure. Failure rate is higher during the egg stage than during the nestling
stage, which suggests that nest desertion, rather than nest predation or loss of cavities to
kleptoparasites, is the major cause of failure (Ricklefs 1969). The relative frequencies of these
three causes of nest loss have never been measured directly, however. Nest predation rates may
be lower than in other cavity nesters because of the protection provided by the resin barrier
around the cavity, which clearly interferes with climbing by snakes (Rudolph et al. 1990).
Subadult/juvenile females from the current year breeding season normally disperse prior to the
next breeding season, or are driven from the group's territory by the group (see Walters et al.
1988, for additional sociobiological/cooperative breeding information). Juvenile females remain
at their natal territory to assume the breeding vacancy of the female only when the breeding male
dies and the breeding female disperses or dies. Breeding females will disperse, creating a
breeding vacancy, when her male offspring inherit the male breeding position (incest avoidance).
Dispersing juvenile females move to nearby RCW territories in search of a breeding vacancy.
These females either become breeders in a territory, or floaters among more than one territory
where they are not associated with a single group.
Juvenile males remain in their natal territory or disperse. Those that remain become helpers or,
if the breeding male dies before the next breeding season, breeders. Dispersing juvenile males
search for positions as breeders in nearby territories where they become either breeders, helpers,
or floaters. Most adult male helpers remain on their natal territory as helpers, where about 15
percent will inherit the territory as a breeding male in any given year. Some adult helpers
disperse to other territories becoming breeders, solitary males, helpers, or floaters. However,
breeding males are highly territorial and most will remain even without a breeding female. In
contrast, about 10 percent of breeding females will break the pair-bond between breeding
24
seasons and disperse to another territory as a breeder with a different male (Walters 1988;
Daniels and Walters 2000).
New groups on new territories arise by two processes, pioneering and budding (Hooper 1983).
Pioneering is the occupation of vacant habitat by construction of a new cavity tree cluster, which
is rare. Budding is the splitting of a territory, and the cavity tree cluster within it, into two.
Budding is common in many other cooperative breeders, and is more common than pioneering in
RCW, since the new territory contains cavities from the outset. The available data indicate that
budding indeed is more common than pioneering, and that pioneering is quite rare.
Given the preceding description of population dynamics, the key to conserving fully functioning
RCW populations is identifying and protecting delineated populations. Larger populations are
more resilient. The Draft Species Status Assessment (SSA) for the RCW (Service 2018) defined
a RCW demographic population as the aggregation of RCW clusters/territories where a breeding
vacancy at any territory is likely to be replaced by RCW from a territory within the delineated
population. Because of this definition, dispersal is a critical factor in delineating demographic
populations, particularly dispersal to fill breeding vacancies.
RCW dispersal distances and social, environmental, and genetic factors affecting dispersal have
been evaluated most extensively by data from long-term studies of a virtually completely banded
population in the North Carolina Sandhills and Marine Corps Base Camp Lejeune (e.g. Walters
et al. 1988, Walters et al. 1992, Daniels and Walters 2000, Pasinelli and Walters 2002, Pasinelli
et al. 2004, Kesler et al. 2010). Overall, median dispersal distances of juvenile males, helper
males, juvenile females, and helper females, respective, were 2.94 (1.83), 1.27 (0.79), 3.31
(2.06), and 1.88 (1.17) kilometers (miles) (Kesler et al. 2010). Dispersal events were movements
by territorial non-breeders to a new territory where a breeding position was acquired the
following breeding season.
The SSA establishes a juvenile female dispersal distance metric to delineate demographic
populations. Helper males, when present, commonly acquire the breeding vacancy created by the
death of the breeding male. Juvenile females do not replace the breeding female, their mother, on
their natal territory. Juvenile females disperse except in rare instances when they remain as
nonbreeding helpers. Thus, the continuity of potential breeding pairs at territories is most
sensitive to effective dispersal of juvenile females, although the smaller class of floater females
may also fill breeding vacancies. Female juvenile RCWs disperse following extraterritorial
forays from their natal territory to explore and interact with other groups, with maximum foray
distances from six to nine kilometers (Kesler et al. 2010). Juvenile females also are more
sensitive to crossing open nonforest gaps (water, fields, etc.) during dispersal. Gaps greater than
150 meters are not absolute barriers during forays, but the probability of crossing diminishes
substantially (Walters et al. 2011).
Because forays greater than six kilometers are rare for female juvenile RCWs, RCW
demographic populations are delineated as the aggregation of RCW clusters/territories ≤ six
kilometers from other nearest neighbor active clusters/territories within the delineated
population. This six-kilometer function corresponds with the perceptual distance, derived from
the same data, at which juvenile females will compete for or acquire a breeding vacancy in the
25
RCW Decision Support System (DSS) spatially explicit individual-based population simulation
model by Walters et al. (2011) and other derived RCW population models (e.g. Bruggeman et al.
2014).
3.4. Numbers, Reproduction, and Distribution
Species-wide, the population trend of the RCW is increasing. In 1993/1994, the range-wide
population was estimated at 4,694 active clusters; in 2006 it was 6,105. The Service estimated
that the number of active clusters reached 7,800 by 2018. Of the 40 primary core, secondary
core, and essential support recovery populations, 36 (90 percent) were either stable or increasing
based on the average annual growth (number of active clusters) during the most recent 5-year
growth period (2002-2007) for which data is available. Only four (10 percent) populations had a
declining trend: Central Florida Panhandle Primary Core (-0.1 percent), St. Sebastian River
Essential Support (-3.0 percent), Three Lakes Essential Support (-1.7 percent), and Oakmulgee
Secondary Core (-4.0 percent). The average annual percent growth of 16 (44 percent) of the 36
stable or increasing recovery populations met or exceeded the 5 percent annual growth objective
in the Recovery Plan. Of the 11 recovery units, only the Upper East Gulf Coastal Plain had a net
declining 5-year trend due to the declining population in the Oakmulgee Ranger District,
Talladega National Forest.
Although some recovery populations are composed of one or more properties (e.g., because the
properties are adjacent to one another), most recovery populations (64%) are located on one
property/ownership. The RCW Recovery Plan identifies 63 properties involved in recovery:
26 primary core (PC), 14 secondary core (SC) and 23 essential support (ES). At a property level
as of 2007, 16 (25 percent) had a net five-year declining trend.
Large recovery populations remain rare. Of the 63 recovery properties, only six (15 percent)
exceed 250 active clusters. Sixty-eight percent (10 populations) consist of less 100 or fewer
active clusters, and 43 percent (nine populations) have less than 50 active clusters. The number
of active clusters or PBGs on each property and designated recovery population occur at
different densities and aggregations in response to the configuration of the property, available
habitat, and the location of unsuitable habitat. Red cockaded woodpecker clusters and
aggregations within and among properties may or may not actually represent a demographically
functional RCW population under current conditions. Furthermore, some populations may
remain subdivided at recovery. The extent that PBGs are spatially aggregated will affect
population viability and persistence. Comprehensive spatial and GIS assessments of PBG
aggregations, fragmentation, and population structure are not available for most properties and
populations. However, several trends and patterns are evident. At least 10 of the 40 recovery
populations are appreciably fragmented under current and likely future, conditions.
At least four primary core recovery populations are currently subdivided and likely will remain
so at recovery. The Central Florida Panhandle Primary Core population, the largest, is comprised
of four properties where most RCWs reside in the Apalachicola Ranger District (RD) and
Wakulla Ranger District of the Apalachicola National Forest. The Wakulla RD and Apalachicola
RD are separated by the Ochlockonee River and private lands, for a distance of least five miles
that may limit RCW dispersal (James et al. 1997). Potential breeding groups in the two districts
are highly unlikely to be demographically isolated, but demographic function may be
26
compromised. If so, the Central Florida Panhandle Primary Core population at recovery, with at
least 1,000 PBGs, may function as one or more subdivided populations. Demographic and
environmental stochasticity is not expected to pose any viability risk, but the ability of this
recovery population to retain genetic variation will be less than anticipated.
An analysis of 2007 RCW data from 121 properties with RCWs submitting reports via the
Annual RCW Report illustrates the status of the species at the property scale for recovery as well
as populations not designated for recovery. Although a few large populations exist on individual
properties, most (74 percent) property populations are small, much more vulnerable populations
of 50 or fewer active clusters.
3.5. Conservation Needs and Threats
In spite of the relatively small size of most populations, the RCWs conservation needs have been
remarkably consistent through time and when applied, the status of RCWs has been steadily
improving since the early 1990s. This steady increase can be attributed to various factors,
including aggressive prescribed burning programs, artificial cavity provisioning and regional
translocation cooperatives and strategies (Costa and DeLotelle 2006).
Primary threats to species viability for RCWs all have the same basic cause: lack of suitable
habitat in fire-maintained ecosystems. On public and private lands, the quantity and quality of
RCW habitat are greatly affected by past and current fire suppression and detrimental
silvicultural practices (Ligon et al. 1986, 1991, Baker 1995, Cely and Ferral 1995, Masters et al.
1995, Conner et al. 2001).
Serious threats stemming from this lack of suitable habitat include: (1) insufficient numbers of
cavities and continuing net loss of cavity trees (Costa and Escano 1989, James 1995, Hardesty et
al. 1995), (2) habitat fragmentation and its effects on genetic variation, dispersal and
demography (Conner and Rudolph 1991), (3) lack of good quality foraging habitat (Walters et al.
2000, James et al. 2001), and (4) fundamental risks of extinction inherent to critically small
populations from random demographic, environmental, genetic, and catastrophic events (Shaffer
1981, 1987).
Red-cockaded woodpecker population size is significantly limited by the availability of cavity
trees and suitable, stable clusters. The natural growing season fire regime has been lost due to
fire suppression and landscape alterations that have altered the availability of lightning-
flammable fine plant litter fuels. In the absence of prescribed fire, fire intolerant hardwoods
survive and grow to midstory or higher levels in the forest canopy. Red-cockaded woodpecker’s
being sensitive to midstory hardwood encroachment, will abandon their cavities and clusters due
to hardwood encroachment (Conner and O’Halloran 1987; Costa and Escano 1989).
4. ENVIRONMENTAL BASELINE
This section is an analysis of the effects of past and ongoing human and natural factors leading to
the current status of the red-cockaded woodpecker, its habitat, and ecosystem within the Action
27
Area. The environmental baseline is a “snapshot” of the species’ health in the Action Area at the
time of the consultation, and does not include the effects of the Action under review.
4.1. Action Area Numbers, Reproduction, and Distribution
All RCW cavity trees on Ft. Benning are located and mapped using a Geographical Positioning
System and data are maintained in ArcView™ and Access™ databases. These data are updated
annually based on results of the spring cluster inspections. Data for new trees are added as the
trees are discovered.
Fort Benning’s personnel have surveyed all of the Installation for RCWs, including the A20 and
K15 dudded impact areas. The Installation documents that the K15 dudded impact area was
surveyed aerially in 2009, of which four active clusters were identified. Of the 75 known clusters
in A20 that have been identified, there are 67 clusters that are currently manageable. One cluster
(A20-47) is located in an area also deemed too hazardous by the Army’s Explosive Ordinance
Disposal (EOD) experts and will never be accessible from the ground, managed, or counted.
There are an additional seven clusters that are currently inaccessible due to potentially hazardous
conditions. These clusters may again be accessible at some point in the future, but currently are
not being managed or counted.
After an assessment of Unexploded Ordinance (UXO) potential by EOD experts was conducted,
three clusters located on the periphery of A20 impact area were added as manageable clusters in
2002 (Service 2002). An additional 11 - A20 clusters were added to management that could be
counted towards the population recovery goal as a result of the Digital Multipurpose Range
Complex (DMPRC) BO (Service 2004). In 2009, 36 clusters from the remaining pool of
accessible A20 clusters were added that could be counted toward the Installation’s recovery goal
as a result of the Maneuver Center of Excellence (MCoE) BO (Service 2009). Although the total
number of manageable clusters in the A20 dudded impact is currently 67, in any given year only
50 (3 + 11 + 36 = 50) of the A20 clusters with PBGs are counted towards the Installation’s 351
PBG recovery goal per the 2009 MCoE BO (Service 2009).
The total number of incidental take authorizations that have been issued for all RCW clusters
located outside of the dudded impact areas due to the DMPRC, Base Realignment And Closure
(BRAC), MCoE, Supplemental MCoE, and firing range M6 BOs, collectively, were 101 clusters.
Incidental take actually occurred for seven of the clusters (IT was authorized for cavity tree
removal (harm)). A net total of 30 incidental take authorizations were removed through formal
consultation with the Service under the Enhanced Training BO (Service 2015). After
consultation with the Service in December of 2017, the Service concurred with Ft. Benning’s
five-year post-project monitoring analysis that incidental take authorizations for nine clusters
were no longer needed. Thus, 55 existing clusters remain today that are currently covered under
incidental take authorizations (101 - 7 - 30 - 9 = 55). These 55 clusters (54 active, one inactive)
still persist on the landscape and are currently being managed. Appendix 4 of the ESMC 2018
Update summarizes all incidental take authorizations, past and present, which have been issued
for RCW clusters on Ft. Benning, as well as the current cluster status.
Upon the Installation’s completion of their 2017 annual RCW nesting season monitoring, a total
of 402 manageable clusters were identified on Ft. Benning (400 active and two inactive). This
28
number includes all manageable clusters in A20, as well as all clusters still covered under
incidental take authorizations. Of these 400 active clusters, the Installation reported 387 were
found to be PBGs, eight were solitary groups, and five were considered captured clusters
(Appendix 5 in the 2018 Update). The Installation currently supports 410 active clusters and 392
PBGs, which surpasses the Installation’s recovery goal (Widener, pers. Comm. 2019).
The numbers above are further broken down for manageable clusters in A20 as follows: 67 were
identified as active (64 PBGs, two solitary groups, one captured cluster) and 0 were inactive.
Only 50 of these PBGs can be counted towards the Installation’s population recovery goal. At
the time of PBA submission, clusters covered by incidental take authorizations and therefore not
counted towards recovery were as follows for the 55 taken clusters: 54 were identified as active
(52 PBGs, two captured clusters) and one was inactive.
Excluding all clusters within the A20 dudded impact area and all groups covered by incidental
take authorizations, there were 280 manageable clusters (279 active and one inactive) remaining.
Of these active clusters, the Installation reported 271 were identified as PBGs (six were occupied
by solitary males, and two were captured clusters). All of these clusters count toward Ft.
Benning’s population recovery goal. By adding the 50 PBGs in A20 that can be counted towards
recovery to the remaining 271 PBGs not covered by incidental take, the total of PBGs that were
counted towards recovery was 321 PBGs.
While this PBO was being drafted, Ft. Benning submitted a request on 22 February 2019 to
remove incidental take authorization covering 54 of the 55 active RCW clusters “taken.” On
April 3, 2019 the Service acknowledged the request, and following review of the data determined
it was appropriate to remove incidental take status (FWS Log# 2019-I-1218). Ft. Benning also
submitted a request during PBO drafting to modify the installation’s RCW monitoring program
resulting from the removal of 54 incidental takes and reported that Ft. Benning currently has 410
active clusters and 392 PBGs, exceeding the installation’s recovery goal of 351 PBGs (FWS
Log# 04EG1000-2019-I-1217).
The Installation’s RCW population has demonstrated significant growth over the past 20 years
(Figure 2-1). However, there are currently no active clusters known to exist on private lands in
close proximity to Ft. Benning. For years now, Ft. Benning and the Service have been concerned
about a potential bottleneck in available RCW foraging habitat related to forest health that could
occur if loblolly pine mortality exceeds replacement rates by either loblolly or longleaf pine
(Army/ Ft. Benning 2015). On Ft. Benning, RCWs are found predominantly in loblolly pines.
Approximately 63% of natural cavity trees are loblolly, 32% are longleaf and 5% are shortleaf
(P. echinata).
4.2. Action Area Conservation Needs and Threats
The narrative below is adapted from the Ft. Benning ESMC 2018 Update (Army/ Ft. Benning
2018a), Appendix 6: Analysis of the Number of Red-cockaded Woodpecker Clusters Required to
Achieve 350 Potential Breeding (Costa, 2013) and the Service’s September 26, 2018
accompanying biological opinion for the ESMC 2018 Update.
29
Based on previous calculations, it was assumed that Ft. Benning would require 421 territories to
harbor 351 PBGs. The purpose of this analysis was to update the numbers of territories and
active clusters required for Ft. Benning to reach recovery based on current Ft. Benning data
supported by similar data from all recovered primary core and one other large population (Ft.
Stewart [Army Installation]). It is known that as RCW populations expand toward their “carrying
capacity” (based on one territory per 150 acres on Ft. Benning) the percentages of unoccupied
(i.e., inactive) clusters, captured clusters and clusters occupied by solitary birds decrease. This
relationship, i.e., low percentages of non-PBG territories at “carrying capacity,” appears to hold
true regardless of population size if habitat is suitable, including availability of suitable cavities.
However, populations undergoing expansion, particularly rapid growth, may have rather large
percentages of solitary male groups. With a basic understanding of current RCW populations and
their management, the reason for the low percentage of non-PBG territories at property carrying
capacity becomes apparent.
Presently, all RCW populations occur on isolated habitat islands ranging in size from less than
2,000 to over 250,000 acres. Based on forest type and current habitat conditions, these islands
can and do support RCW populations of various sizes. Via strategic and effective population and
habitat management, expansion of these populations, regardless of their size, has become routine,
predictable and successful. Even the smallest populations (at or around 10 territories) can be and
are being expanded and maintained as stable with focused management (Letcher et al. 1998, and
Costa and Daniels 2004). Indeed numerous (n=6) new populations have been reintroduced into
suitable habitat and are similarly stable and/or expanding. At carrying capacity (one RCW group
per 70 to 300 acres depending on habitat) and with normal annual recruitment, it appears
uncommon for suitable territories, in any population of about 10 groups or larger, to remain
unoccupied or in a solitary bird status for any significant length of time, e.g., beyond two
dispersal seasons. With normal levels of annual recruitment, suitable unoccupied natural (old
trees) or artificial (recruitment clusters) nesting habitat and breeding vacancies are quickly filled.
This is not surprising even in small populations given that offspring have few options to find
suitable habitat off-property.
The relatively high-observed subadult mortality rates (i.e., birds not seen again in the study
area/population during their first potential breeding season) previously documented in RCWs
(see Walters et al. 1988) likely reflects that annual natality (recruitment) typically exceeds
mortality within most populations. Therefore, “surplus” birds are destined to “float” or disperse
(from the property), thereby exposing themselves to risks of predation and exposure.
Additionally, if the capacity of the property/habitat to support RCWs (either naturally via old
trees or artificially via recruitment clusters) is limited, the opportunities for surplus birds to
pioneer or occupy recruitment clusters is also limited and again their options are to float or
disperse, increasing the probability of mortality. However, when nesting habitat is available it is
often quickly occupied which is why presently so many populations are rapidly increasing. These
landscape, habitat and ecological conditions all support the concept that under normal
circumstances a sufficient pool of subadults is annually available to either support population
expansion or maintain population stability in populations at carrying capacity if managed,
suitable habitat is available.
30
In determining the number of total territories required at recovery to achieve their designated
PBG goal, some populations have incorrectly used their current number of recruitment clusters in
their calculations. This practice may result in an inflated measure of a managed property’s
carrying capacity. Ft. Benning considered this factor when preparing the ESMC 2018 Update.
At carrying capacity, there will be no recruitment clusters once all territories are occupied.
Summarizing Ft. Benning’s data in context, on average, at any given time in recovered and large
populations approximately 7% of territories will be unoccupied, solitary males will occupy 2%,
neighboring woodpecker groups will capture 3% and 88% will be occupied by PBGs. Therefore,
based on the averages, to achieve a population goal of 350 PBGs, 398 “managed” or suitable
territories would be required. However, based on Ft. Benning specific data, only 390 managed
clusters would be required because 90%, not 88% (the average of the six populations), of
managed clusters harbor PBGs.
Ft. Benning’s ESMC recognizes the vulnerability that habitat fragmentation poses to RCW
populations including the potential to interrupt natural dispersal. Fragmentation has occurred
both among groups within a population and among populations, with serious consequences for
red-cockaded woodpeckers (Service 2003). The ESMC directs managers to minimize habitat
fragmentation by providing RCW habitat adjacent to and contiguous with the cluster “…to the
maximum extent possible.”
Conservation Needs – Off-Post Action Area
In addition to outlining RCW conservation objectives on post, the Ft. Benning ESMC refers to
the ACUB and Demographic Conservation Area (DCA) programs as approaches for expanding
the population into unoccupied and potentially suitable habitat off post. The ACUB program was
previously focused on preventing incompatible development and encouraging general habitat
conservation near Ft. Benning, rather than establishing RCW habitat and management off-Post.
The Nature Conservancy and partners, by way of Army-funded acquisition of both conservation
easements and fee title purchases; emphasizing RCW conservation, implement the ACUB
program.
Ft. Benning is implementing an Off-Post RCW Plan (Appendix 2 of the ESMC 2018 Update)
that aims to secure property interests, assure long-term management, and restore and conserve
habitat for the RCW in the region around Ft. Benning. This plan is written to comply with
Service guidelines for including off-Post properties as part of Ft. Benning's recovery baseline
landscape. The Off-Post RCW Plan points out that Ft. Benning’s ACUB program currently
protects over 27,000 acres of land east and north of the Installation and that another 10,000+
acres are potentially available for future protection. The ESMC identifies an 8,884-acre
component of the Chattahoochee Fall Line Wildlife Management Area as a major new addition
to the Installation’s RCW baseline acreage through the ACUB program (see Figure 2-2 below).
Ft. Benning’s Off-Post RCW Conservation Plan was prepared in 2010 to meet requirements
outlined in the MCOE BA (Ft. Benning 2008) and associated biological opinion (Service 2009).
The program prioritizes ACUB advisory, prioritization and approval processes to address
identified RCW conservation objectives. Conservation approaches designed in compliance with
31
the Plan are submitted to the Service for comment and approval. Landscape condition analysis
as part of the Off-Post RCW Plan suggested that over 4,000 acres of land east of the Installation
in the ACUB program possessed conditions where “...restored habitat would have a good to
excellent chance of adding to the stability of Fort Benning’s Primary Core Recovery Population,
based on a 3-mile RCW dispersal distance.”
The Off-Post RCW Plan established a system for categorizing properties being considered for
inclusion in the ACUB program based on a tract’s proximity to currently active RCW groups,
current habitat conditions, and capacity for supporting new groups. The Off-Post Plan defines
highly “aggregated clusters” as five or more clusters occurring within a 1.25-mile radius.
Clusters with 2.6 to 4.6 active clusters within 1.25 miles were considered to be have “moderate”
aggregation. Densities of 2.5 or fewer active clusters within 1.25 miles were considered
“sparse.” Cluster densities in this last category are more vulnerable to abandonment because of
lack of emigration/ immigration (Conner and Rudolph 1991).
The management objective for the Ft. Benning RCW Conservation and Crediting Program
requires that qualifying Ft. Benning ACUB properties establish habitat suitable for RCW
occupancy and ultimately the establishment of PBGs. At this time, however, although the
ACUB landscape is being managed to restore suitable RCW habitat, a considerable amount of
additional time will be required before most of the Off-Post lands are capable of supporting
PBGs.
It is likely that section 7 consultations involving the use of this PBA will occur prior to the
establishment of PBGs on ACUB properties. Accordingly, establishment of this ACUB program
will be recognized as a “beneficial action” (in the context of a net benefit to RCW recovery)
taken by Ft. Benning prior to consultation, and the habitat values occurring on ACUB properties
at the time of such consultations (including any functions and values actually provided to and
utilized by RCW at that time) will be included within the environmental baseline for such
consultations. Ft. Benning, in conjunction with the Service and ACUB Partners, will identify the
anticipated future habitat values that are expected to support future PBGs (expressed as RCW
Conservation Values). These Conservation Values will be utilized as offsetting mitigation.
They will thus be assessed in the effects analysis as an associated effect of the proposed action
under Tier 2 consultation. As described above, any real-time conservation benefits provided by
qualifying ACUB properties to RCW will be identified and described in the environmental
baseline for the consultation.
The Off-Post RCW Plan acknowledges sensitivity of dispersing juvenile female RCWs to large
open areas. Female juvenile RCWs disperse following extraterritorial forays from their natal
territory to explore and interact with other groups, with maximum foray distances from six to
nine km (Kesler et al. 2010). While gaps greater than 150 meters are not absolute barriers to
forays by young female RCWs, the probability of crossing diminishes substantially (Walters et
al. 2011).
The ACUB parcels within the east and northeast periphery of the installation are patchily
distributed on the landscape. The Off-Post RCW Plan describes “adjacent habitat” as any parcel
within three miles of an existing RCW cluster that has potential foraging or nesting habitat. The
32
Off-Post RCW Plan states that parcels within three miles of highly aggregated woodpecker
groups are considered demographically and genetically connected.
The Installation (excluding the ACUB tracts) conservation needs are met by the traditional
management applications that have been conducted for several decades. Specifically, the
Installation should continue to deploy the management goals and objectives as described in their
INRMP. This includes but is not limited to: (1) application and control of fire as a means to
further develop the desired future condition for the Installation’s pine/grass ecosystems, which at
a minimum, supports both RCW clusters and foraging habitat, (2) protection and development of
large, mature longleaf pines throughout the landscape, (3) protection and maintenance of existing
RCW cavities and judicious provisioning of artificial cavities to ensure all clusters maintain a
minimum of four suitable cavities, (4) restoration and maintenance of sufficient habitat quality
and quantity to support the RCW population necessary for recovery on Ft. Benning, (5) limited
provisioning of sufficient recruitment clusters in locations chosen to enhance the spatial
arrangement of groups, and (6) continued monitoring of those clusters still covered by incidental
take authorizations to validate persistence and reproductive health so they can again count
towards the Installation’s population recovery goal of 351 Potential Breeding Groups (PBG(s)).
4.3. Tables and Figures for Environmental Baseline
Figure 2-1: Ft. Benning RCW Active Clusters and PBG’s 1997-2016
Figure 2-2: Ft. Benning and nearby ACUB/ecological service properties 2019
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5. EFFECTS OF THE ACTION
This section analyzes the direct and indirect effects of the Action on the red-cockaded
woodpecker, which includes the direct and indirect effects of interrelated and interdependent
actions that will be added to the environmental baseline (50 C.F.R. § 402.02). Direct effects are
caused by the Action and occur at the same time and place. Indirect effects are caused by the
Action, but are later in time and reasonably certain to occur. Our analyses are organized
according to the description of the Action in section 2 of this BO.
5.1. Effects of Ft. Benning’s Conservation and Crediting Program for the
Red-cockaded woodpecker Through Off-Post Conservation and Management of
the Longleaf Pine Ecosystem
5.1.1. Factors Considered
In analyzing the effects of the action, the Service “will give appropriate consideration to any
beneficial actions taken by the Federal agency, including any actions taken prior to the initiation
of consultation” 50 C.F.R. § 402.14(g) (8). The PBA describes the proposed Conservation and
Crediting Program as being comprised of two tiers. The first tier is the programmatic section 7
consultation, to result in the issuance of a programmatic biological opinion (PBO) that
establishes the outline and formalizes the process for streamlining consultation for second tier
34
(Tier 2) activities. Tier 2 actions either add conservation value/credits or will require incidental
take of RCWs and associated debiting of credits. Tier 2A activities are future actions that
involve habitat acquisition and/or securing management on existing or future protected
properties – regenerating/restoring native, on-site pine species, understory, stand protection, re-
establishing fire regimens, etc. that promote establishment of conservation credits off Post. Tier
2B activities are future activities that will involve incidental take of individual birds, clusters, or
sufficient habitat to result in loss of a woodpecker group(s) on Post.
We consider a RCW population or subpopulation within the Ft. Benning primary core recovery
population to be biologically functioning when population growth, persistence, and demographic
and genetic connectivity are predicted to remain viable over time. The RCW Recovery Plan
(Service 2003) has defined the number of active clusters that must be persistent on each property
before each subpopulation (neighborhood) is deemed viable. The Ft. Benning primary core
recovery population must support 351 PBGs (or 382 total active clusters) which are not
dependent on the provisioning of artificial nest cavities to maintain population size in order to
delist the RCW. Each group should be managed to persist in an area of at least 200 acres. The
population must be demographically and genetically functioning to be considered for delisting.
Proximity of action
Actions carried out to achieve the objectives of the Ft. Benning crediting program will be
focused on expanding the recovery landscape to include off-Post properties or conservation areas
for the Ft. Benning primary core RCW population. Program properties or conservation areas
acquired and managed under the Program will have the requisite soils and hydrology to establish
good quality RCW habitat on off-Post acreage within 3 miles of the installation boundary or on
acreage contiguously adjacent to Ft. Benning through adjacent connections to other properties or
conservation areas managed for RCW habitat on Ft. Benning and/or on nearby ACUB properties.
Since the purpose of the program is to promote growth of the Ft. Benning primary core RCW
population, selection of properties for inclusion would need to demonstrate that parcels meet
specific conditions to ensure that their management for RCW conservation achieves the
expressed recovery objectives. Specifically, properties need to be close enough to flourishing
populations on Ft. Benning and ACUB lands to ensure that new groups that form on acquired
lands are demographically and genetically connected to the greater population. The program
includes a process for determining this connectivity, or ecological functioning of identified target
properties. Properties are selected by size, location, presence of current and potential nesting and
foraging habitat, and ownership based on analyses of Geospatial Information System (GIS) data
layers (e.g., current and potential vegetation and RCW cluster proximity).
Distribution
The Conservation and Crediting Program processes for selecting properties for conservation take
into account that the spatial distribution and aggregation of RCW groups are vital to the
persistence and ecological function of populations. The ability for breeders to be replaced if they
die or if other RCWs in their group disperse is essential. Knowledge of demographic needs of
the species is based on research conducted on the dispersal of RCWs of both sexes from their
35
natal group or group territories to other groups in which they may compete for breeding
vacancies. For example, dispersing juvenile and helper males in North Carolina study areas
rarely traveled more than two miles from their natal territories (Daniels 1997; Walters et al.
1988). Juvenile females from the same study areas are capable of longer forays, becoming
breeders in clusters up to 3.7 miles away (Walters et al. 2008). In western Florida, from a study
with a smaller number of observations, adults dispersed an average distance of 1.1 miles,
juvenile females 2.0 miles, and juvenile males 5.0 miles (Hardesty et al. 1997).
Adaptive management within the Conservation and Crediting Program will need to adjust
specifically to address the population dynamics unique to RCWs. These include the spatially
fixed distribution of territories in association with the limited availability of cavity trees and
clusters, the replacement of breeders in territorial groups by helpers in the same territory, and the
dispersal behavior of RCWs from other territories competing for the breeding vacancy at
available clusters. Reduction in population size is governed more by the number and location of
suitable territories for PBGs with helpers than a reduction in individual survival and
reproduction, which tends to affect group size (Walters 1991).
Prospective Conservation and Crediting Program properties within the project area will exhibit a
range of land uses including stands of native pine species (longleaf, shortleaf, loblolly, slash,
etc.) and related forest types that can be managed through stand treatments to create RCW
habitat interspersed with acreages of non-habitat or dispersal habitat (e.g., shorter rotation pine
forests, agricultural fields, residential communities, highway rights of way, etc.). Project
proponents may use landscape equivalency analysis and pattern-oriented modelling (LEA/POM)
to determine the effects of gaps on the landscape as they affect the ecological function of
acquisitions as conservation offsets and recovery actions. POM uses observed spatially explicit
landscape and individual RCW patterns to reduce uncertainties in the model parameters by
comparing the ability of many different individually based, spatially explicit population models
(IB-SEPMs) to produce observed patterns (Bruggeman et al. 2007). The LEA/POM system was
specifically developed to perform more detailed analyses on simulating RCW dispersal across a
heterogeneous landscape, anticipating the presence of suitable and unsuitable habitat. LEA may
also be used to evaluate how rates of RCW recruitment and migration change across the spatially
explicit landscape with changes in habitat.
Doug Bruggeman and Michael Jones (Bruggeman and Jones 2008) noted the importance of
taking into consideration the change in spatial distribution of ecological resources when
conducting habitat trades involving RCWs. IB-SEPMs have modeled how breeding group
spatial distribution and density can affect gene flow, genetic drift, inbreeding and persistence in
response to demographic and environmental stochasticity and habitat fragmentation (Letcher et
al. 1998, Daniels et al. 2000, Walters et al. 2002, Bruggeman and Jones 2008, Bruggeman et al.
2010).
The value of applying these more rigorous forms of analyses increases with the amount of
habitat that would be lost, in smaller versus larger populations, as percent (per unit area) of
fragmentation increases, as patches of non-foraging, forested habitat, e.g., regeneration harvest,
or non-forested lands become more non-linear in shape.
36
Timing
Stand age, tree size and availability of mature or old growth pines within properties are among
the most important factors determining when a property can contribute to the ecological
functioning of the RCW landscape. Suitable foraging habitat for RCWs may develop when pine
stands reach 30 years of age, depending on site productivity. However, RCWs generally do not
excavate cavities until trees are over 60 years of age. Ft. Benning may find it useful to conduct
LEA/POM in more complex assessments to quantify changes in landscape structure and how
they affect RCW abundance and genetic patterns (e.g. SERDP 2012). Therefore, readiness of
properties in terms of suitability as foraging and nesting habitat and time to maturity will be
thoroughly assessed in the application of the program.
Duration
Properties that are accepted through the Conservation and Crediting Program framework and are
demonstrated to adequately support ecological function may be considered part of the Ft.
Benning primary core recovery landscape. RCW groups that are supported on these properties
may be considered part of the recovery population. Long-term costs will be funded by a non-
wasting endowment or other “in perpetuity” funding mechanism or agreements with Partners to
take-on financial responsibilities for assuring perpetual management. Approval by the Service to
accept RCW conservation values identified through the Conservation and Crediting Program will
be contingent on legal and financial documents that define and assign responsibilities, provide
for protection of habitat in perpetuity, and define and finance management activities.
The RCW is currently the only federal listed species addressed in this consultation and is the
only species being evaluated for direct or indirect effects from the Action under formal
consultation at this time. During implementation of actions pursuant to this Action, if it becomes
evident that the Action may affect other federally listed, proposed, or candidate species; such
effects will be site specific, and will be addressed through subsequent Tier 2 or independent
conferences/consultations. Activities conducted on or off of Ft. Benning outside of acreages
considered RCW habitat (non-RCW habitat may include open fields, hardwood bottoms, rivers,
lakes, etc.) will have no effect on the RCW. Within acreage considered as habitat for the RCW,
activities that occur in unoccupied or unsuitable habitat will not adversely affect the RCW and
therefore do not require the implementation of any conservation measures. However, protection
and management of unoccupied and currently unsuitable habitat within those acreages which
could be considered habitat for the RCW is the main factor considered to provide beneficial
effects as an offset to adverse effects on the Installation.
5.1.2. Analyses for the Effects of the Action
To determine the effects of this action, the Installation compared the predicted difference in
conditions relevant to the RCW between the future with and the future without the Action. The
Action is a programmatic conservation and crediting framework that contributes to the
conservation of the RCW. The program would encourage the performance of proactive
conservation actions off-Post to help increase the species throughout the Ft. Benning recovery
population range. This is completed while preserving Ft. Benning’s mission capabilities and
providing the Installation with regulatory certainty for their actions under the ESA. The
37
conservation and crediting framework establishes a process for targeting conservation
investments on non-military lands to establish “conservation/credit values” that will provide for
regulatory offsets for impacts to the RCW for current or future Installation activities - yet to be
fully defined - that may affect the species. Accordingly, site-specific activities are unable to be
addressed herein. Therefore, there cannot be an evaluation of the effects of the action using site-
specific data. Instead, the Installation and the Service evaluated the effects of the action for
implementation of the conservation and crediting framework as a whole and programmatically.
The conservation and crediting framework requires that transactions result in a conservation
offset to the species and those recruitment groups/territories are demographically connected to
others in the Ft. Benning primary core population. Therefore, the action is likely to expand
suitable habitat conditions and populations of the RCW, resulting in expanded benefits to the Ft.
Benning recovery population as a whole.
Effects to gopher tortoise (Gopherus polyphemus) in relation to conservation area development
and conservation offsets have already been evaluated in the Tier 1 Framework Programmatic
Conference Opinion for the Department of Defense Gopher Tortoise Conservation & Crediting
Strategy, December 15, 2017. If surveys detect gopher tortoise on ACUB lands identified and
acquired under this RCW Conservation Program, Ft. Benning will initiate the Tier 2 Conference
process identified in the above-referenced Tier 1 Gopher Tortoise Conference Opinion for the
establishment and management of a GT conservation area as appropriate to support Mission
requirements.
Other federally listed species (endangered, threatened, or proposed) may become known or may
become present on individual ACUB properties throughout time. This assessment does not
evaluate effects of off-Post management actions on those species, as we have no way to predict
their presence until property-specific information is evaluated as part of the acquisition process.
Therefore, effects to other federally listed species will occur as part of the Tier 2 Formal
Consultation process.
The previously discussed Ft. Benning section 7 consultations contain a wealth of information
identifying and analyzing the effects for both military training and land management activities
that are hereby incorporated by reference. Given the extensive discussion in these referenced
consultations, the effects sections of this PBA are limited to effects specific to this action that are
not covered in the reference consultations.
Establishment of the Conservation and Crediting Program has the potential to both positively and
negatively affect the Ft. Benning primary core recovery population. Tier 2B actions have the
potential to eliminate habitat supporting numerous RCW groups. Such actions may fragment
habitat resulting in reproductive isolation and creating barriers to dispersing RCWs seeking
breeding vacancies where neighborhood groups have lost breeders. Demographic connectivity
among on-Post woodpecker groups may be reduced. Where there is significant fragmentation, a
population becomes more vulnerable to inbreeding depression, which in turn increases the
potential extirpation of the affected population.
Conversely, the Program would encourage the Army/Ft. Benning to focus resources supporting
ACUB Partners managing adjacent or contiguously adjacent ACUB lands in support of
38
ecologically critical habitat goals necessary to add new RCW PBGs into the Ft. Benning primary
core recovery landscape. In lieu of reliable funding sources, adherence to well-developed
management plans and availability of effective staff and resources, the likelihood that ACUB
properties would be managed successfully for RCW conservation is less certain. The
conservation and crediting framework identifies measurable objectives that can be counted
toward offsetting impacts to existing groups on Post.
Project proponents will select the appropriate assessment process to evaluate current RCW
population status and landscape gaps and their effects on ecological function in Tier 2A and 2B
analyses. Assessment techniques may include GIS work products, Pattern-Oriented Modeling
(POM), Landscape Equivalency Analysis (LEA), or other method. The method selected will
need to be sufficient to capture the effects of the Tier 2 action being considered. This will ensure
that the potential fragmentation effects mentioned above are effectively mitigated. These
proactive management actions have the potential to add managed habitat to the Ft. Benning
primary core landscape, expanding the land base supporting RCWs and making the primary core
population more resilient. Expanding conservation activities, e.g. ecologically appropriate fire
management, restoration of native pine overstory species and associated understory diversity,
etc., onto ACUB lands could provide favorable conditions for many rare species and candidates
for Federal listing under the ESA and directly support efforts which may preclude the need for
new species listings.
6. CUMULATIVE EFFECTS
For purposes of consultation under ESA §7, cumulative effects are those caused by future state,
tribal, local, or private actions that are reasonably certain to occur in the Action Area. Future
Federal actions that are unrelated to the proposed action are not considered, because they require
separate consultation under §7 of the ESA.
Timber management practices and development on non-Federal lands in the action area are the
most likely cumulative effects involving RCWs. In the past, non-federal landowners were
reluctant to engage in management activities that benefit RCWs, because they feared future
restrictions on land use. Landowners harvested pine timber on short rotations to preclude
utilization and occupation by RCWs. Without periodic prescribed burning or other active habitat
management methods in pine habitat, hardwood midstory will continue to encroach into
prospective RCW habitat. These conditions have deleterious effects on other rare and endemic
native plant and animal species associated with longleaf pine ecosystems. Presently, there are no
known RCW groups off-post that are demographically connected with Ft. Benning groups.
The Service and Ft. Benning are working closely with state and local governments and with non-
governmental organizations within the Action Area to plan and implement programs for more
effective protection and conservation of longleaf pine ecosystems and longleaf pine dependent
species on public and private lands. Research institutions, non-governmental organizations, and
state and local governments are all serving important planning, monitoring, and research
functions. These parties are both independently and cooperatively advancing the basic science
and practical knowledge necessary to achieve habitat enhancement and landscape-scale
39
conservation. These parties are also assisting with permitting functions, public outreach, and
education.
Because of the Conservation and Crediting Program, we expect that future state, tribal, local, and
private actions will help to make significant progress in accomplishing objectives that are
important to local and range-wide RCW conservation. These efforts are critical components of
the shared local, state, and federal strategy, implemented via the Ft. Benning ACUB and newly
designated Sentinel Landscape program, to address existing and future threats, and thereby
achieve long-term persistence and recovery of the RCW and other threatened, endangered and at-
risk species. The existence of a proactive conservation program like this in the region should
encourage other non-federal entities to participate or engage in similar supporting activities
within the area as well.
7. CONCLUSION
In this section, we summarize and interpret the findings of the previous sections (status, baseline,
effects, and cumulative effects) relative to the purpose of a BO under §7(a)(2) of the ESA, which
is to determine whether a Federal action is likely to:
a) jeopardize the continued existence of species listed as endangered or threatened; or
b) result in the destruction or adverse modification of designated critical habitat.
“Jeopardize the continued existence” means to engage in an action that reasonably would be
expected, directly or indirectly, to reduce appreciably the likelihood of both the survival and
recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of
that species (50 CFR §402.02).
Status
Overall, range-wide RCW population numbers are increasing. From 1993 through 2006, the
range-wide RCW population estimates were 4,694 active clusters to 6,105, respectively (Draft
RCW Species Status Assessment 2018). Approximately 36 of the 40 (90%) primary core,
secondary core and essential support RCW recovery populations were either stable or increasing.
Between 2002 and 2007, only four (10%) of the populations were in decline. Large recovery
populations remain rare with only six (15%) exceeding 250 active clusters. Generally, the status
of RCWs has been consistently improving since the early 1990’s.
The Ft. Benning Primary Core Recovery Population is one of 13 primary core recovery
populations and one of two primary cores in the Sandhills Ecoregion (the other being the NC
Sandhills Primary Core Population centered on Ft. Bragg, North Carolina). The Recovery Plan
discusses the importance of inland populations due to the inherent vulnerability of coastal
populations to hurricanes and other large wind events and the need to recover the species as
quickly as possible. Out of 124 RCW populations analyzed in the Draft RCW Species Status
Assessment, the Ft. Benning primary core was one of three characterized as having high
resilience. Only two other populations were classified as high (Francis Marion National Forest-
Bonneau Ferry WMA-Santee Coastal Reserve and Ft. Stewart) and three others were identified
40
as having very high resilience (Apalachicola National Forest-St. Marks NWR-Tate's Hell State
Forest, North Carolina Sandhills and Eglin Air Force Base).
Baseline
Ft. Benning currently has 410 active clusters and 392 PBGs, exceeding the installation’s
recovery goal of 351 PBGs. From data collected between 2009 and 2013, the Installation’s data
reveal the sum average of potential breeding groups was 92%. Across the Installation (± 80,000
acres of manageable RCW habitat), RCW distribution is generally balanced among four habitat
management units. The units are broken down according to land use, accessibility, and RCW
demographics. The conservation needs for RCWs across the Installation are being met, primarily
by implementing the Installation’s INRMP. Threats to RCWs at the population level are
minimal; pine tree species conversion is likely the most apparent challenge (i.e., converting off-
site pine species to site appropriate species - e.g., loblolly pine to longleaf pine where
appropriate).
Effects
This Programmatic Biological Opinion caps off Tier 1 of a two-tiered section 7 consultation
process as outlined in Ft. Benning’s PBA. Tier 1 is a review of the conceptual proposed RCW
credit and debit process as a whole to consider potential beneficial and adverse effects to the
RCW created by the program and determine whether the action is likely to jeopardize the
continued existence of this species. Tier 2 of Ft. Benning’s Conservation and Crediting Program
for the RCW would be the implementation of the program at the project level.
Ft. Benning’s Conservation and Crediting Program for the RCW includes two Action
components that are reasonably certain to affect the Installation’s RCWs: Tier 2A “Credit
Actions” and Tier 2B “Offset/Debit Actions.” Tier 2A “Credit Actions” are individual project-
level activities that are proposed for Off-Post conservation areas designed to establish new
recruitment clusters, future PBGs and supporting nesting/foraging habitat. Management
practices for the involved conservation areas would be directed by site-specific plans that adapt
recovery standard guidelines to optimize local conditions.
The physical backbone for Tier 2A conservation actions is the ACUB properties primarily east
and northeast of the Installation. In the PBA, Ft. Benning and the Service identified 8,894 acres
of ACUB land as the initial location to begin developing Tier 2A credits. Ft. Benning’s “Off-
Post RCW Conservation Plan” indicates that approximately 23,000 additional acres (including
about 17,000 acres of “satellite” parcels) occurs in the east and northeast ACUB areas.
Potential neighborhood/population level impacts will be assessed for each proposed Tier 2B
debit action. Tier 2B debits will result in a reduction of RCW cluster and territory densities in
On-Post populations. However, at the conclusion of projects involving a Tier 2B debit, few if
any clusters within the On-Post populations, not covered with incidental take, will have less than
three neighbors within a 1.25-mile radius. Additional POM and LEA modeling will be
recommended where initial project analyses suggest impacts may result in demographic
isolation.
41
The PBO establishes the rationale for calculating “Net Present Conservation Value” (NPCV) for
Tier 2 Actions. The value on Off-Post property is assigned following proportional values per
unit area:
Potentially-suitable, Unforested or Non-pine Dominated ACUB Lands = 0.35
Pine Dominated ACUB Lands = 0.15
Foraging Habitat Standard Achieved = 0.15
Nesting Habitat Standard Achieved = 0.15
Fully Restored/Occupied Habitat = 0.20
Given the relatively underdeveloped ecological pine forest conditions on ACUB properties in the
initial suite of parcels (8,894 acres), the starting available NPCV could be as little as 15 PBG
Credits, assuming the majority of the involved acreage could potentially be managed for RCW
recovery. Theoretically, within 30+ years, this block of parcels could represent as much as 28.9
PBG Credits if we determine that the entirety has attained foraging habitat standard metrics.
The PBA acknowledges that the distribution of future potential and suitable nesting habitat
across the landscape, on and off-Post will determine what specific areas are and will be capable
of supporting future RCW clusters at any particular point in time. Future Tier 2B actions have
the potential to result in habitat fragmentation, reproductive isolation, and create barriers to
RCW movement associated with construction and operation of new facilities. These effects may
extend beyond the directly affected RCW group or groups and involve numerous adjacent
clusters at the neighborhood level.
Ft. Benning’s PBA states that “…the determination of available RCW Conservation Values will
be an iterative process requiring periodic re-examination and re-evaluation.” Specific
opportunities to reassess Net Present Conservation Values, demographic connectivity and the
status of the affected population include when a Tier 2A or 2B action is proposed and when
ACUB property monitoring detects relevant changes in ecological conditions. The need to re-
evaluate NPCV and connectivity will vary depending on degree of impacts associated with a Tier
2B action. Small projects limited to foraging partition or group level impact are not expected to
require particularly detailed examination. Large-scale projects may need to be assessed through
Landscape Equivalency Analysis, Pattern-oriented Modeling or comparable analyses.
A specific level of impacts has not been identified in the Conservation and Crediting Program
that elicits when a Tier 2 project should require application of POM/LEA to clarify project
impacts. The parameters and concepts considered for RCW project analysis are: (1) foraging
partition, (2) group, (3) neighborhood, (4) population, and (5) recovery unit. Depending on the
results of the previous level, additional analyses may or may not be necessary. The need for
more rigorous analyses increases where impacts are anticipated at the neighborhood level and
above.
Depending on project scale, location, size and timing of identified credit actions, compensatory
mitigation for impacts risk not sufficiently accounting for how ecological resources are allocated
within the Action Area (Bruggeman and Jones 2008). The application of IB-SEPMs for RCW
conservation has been used to analyze how density and spatial distribution of breeding groups
42
can affect gene flow, genetic drift, inbreeding, and population persistence in response to
demographic and environmental stochasticity and habitat fragmentation (Letcher et al. 1998,
Daniels et al. 2000, Walters et al. 2002, Bruggeman and Jones 2008, Bruggeman et al. 2010).
The PBA states that “[i]t is unlikely but not inconceivable that any single consultation would
exhaust available Conservation Values.” Biological assessments submitted by Ft. Benning for
Tier 2B projects will follow standard, existing section 7 processes and timeframes identified in
this PBO. Some PBG’s will be removed completely due to construction projects and/ or other
installation activities where the ecosystem is altered to the degree that RCW can no longer
persist on that acreage. However, those impacts will be offset through the program. In sum,
implementation of the Ft. Benning Conservation and Crediting Program is expected to provide a
system whereby the installation’s recovery goal of 351 PBGs can be met for the foreseeable
future, while ensuring that at no point in time would the population support fewer than 250
extant PBGs including on and off-Post.
Cumulative Effects
Timber management practices and development on non-Federal lands in the action area are the
most likely cumulative effects involving RCWs. Implementing the Ft. Benning Conservation
and Crediting Program is expected to have a positive effect on RCWs on the landscape, since the
program incentivizes forest management practices that benefit the species. The amount or extent
of these benefits in terms of land area made suitable habitat, number of additional PBGs added,
connectivity established within cluster aggregations, etc. cannot be determined at this time.
Opinion
The process of calculating NPCV that sums to a total number across Off-Post properties provides
a useful index to account for the benefits accrued through Ft. Benning’s Conservation and
Crediting Program for the RCW. However, a PBG Credit gained through the Program is not
spatially referenced and would not represent a current or future Off-Post PBG independent of an
appropriate process for determining the demographic and genetic services the credit may
provide. The validity of a PBG credit would need to correspond with spatially explicit partition-
level conditions. A partition-level assessment of habitat conditions would reflect, for actual
partitions, conditions when suitable for foraging, suitable for artificial cavities and potential
recruitment, and suitable for natural cavities/nesting.
A partition-level assessment of habitat suitability expressed as the number of partitions by these
conditions, even without actual PBG occupancy, would more closely estimate the number of
future PBGs. The proposed system of potential and suitable habitat metrics provides a coarse
metric to track habitat restoration progress across Off-Post properties. The proposed system or
an alternative partition-level system assessment of habitat suitability may not be sufficient,
without other analyses, to assess the extent that Off-Post conservation values minimize or offset
adverse impacts to PBGs on the installation during a future formal consultation.
In the Program’s implementation, the accrual of NPCV would promote expansion of ecologically
beneficial conditions into the Off-Post Action Area as efficiently as possible. Within the initial
43
30 to 60 years, the extent of Tier 2B impacts would be limited based on the Program, since little
acreage within available individual properties and conservation areas possess pine forest old
enough or in the desired species to provide RCW habitat. The program’s incremental
accumulation of NPCV will allow for modulation of Tier 2B impacts.
Tier 2 reviews will need to consider the importance of group densities and distribution, effects of
gaps as barriers to dispersal, current and future number of PBGs and time frames within which
impacts occur and how much time will be required to return to the original baseline. In
executing Ft. Benning’s Conservation and Crediting Program for the RCW, if there are enough
impacts, either through a single large project or by the accrued effects of several smaller projects,
the number of extant PBGs may be reduced to, or fall below the Ft. Benning Primary Core
Recovery Population Goal. The Program enables the U.S. Army/Ft. Benning and the Service to
use the appropriate course of analyses, including pattern-oriented modelling and landscape
equivalency analysis to determine how long it would take to re-attain the recovery goal. The
conservation actions and procedures established through this Conservation and Crediting
Program provide reasonable assurances of producing a RCW population that sustainably meets
or exceeds the Ft. Benning population recovery goal. Although there may be temporary
reductions in PBGs as training activities occur and habitat off base matures, the goal is to always
return to the recovery goal of meeting or exceeding 350 PBGs.
After reviewing the current status of the species, the environmental baseline for the Action Area,
the effects of the Action and the cumulative effects, it is the Service’s biological opinion that the
Action is not likely to jeopardize the continued existence of red cockaded woodpeckers.
8. INCIDENTAL TAKE STATEMENT
ESA §9(a)(1) and regulations issued under §4(d) prohibit the take of endangered and threatened
fish and wildlife species without special exemption. The term “take” in the ESA means “to
harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in
any such conduct” (ESA §3). In regulations at 50 CFR §17.3, the Service further defines:
“harass” as “an intentional or negligent act or omission which creates the likelihood of
injury to wildlife by annoying it to such an extent as to significantly disrupt normal
behavioral patterns which include, but are not limited to, breeding, feeding, or
sheltering;”
“harm” as “an act which actually kills or injures wildlife. Such act may include
significant habitat modification or degradation where it actually kills or injures wildlife
by significantly impairing essential behavioral patterns, including breeding, feeding or
sheltering;” and
“incidental take” as “any taking otherwise prohibited, if such taking is incidental to, and
not the purpose of, the carrying out of an otherwise lawful activity.”
Under the terms of ESA §7(b)(4) and §7(o)(2), taking that is incidental to and not intended as
part of the agency action is not considered prohibited, provided that such taking is in compliance
with the terms and conditions of an incidental take statement (ITS).
44
The Action evaluated in this BO meets the regulatory definition of a “framework programmatic
action” (50 CFR §402.02) for purposes of an ITS, which is a Federal action that approves a
framework for the development of future action(s) that are authorized, funded, or carried out at a
later time, and are subject to further §7 consultation. Any take of a listed species would not occur
unless and until those future action(s) are authorized, funded, or carried out. An ITS is not
required for a framework programmatic action at the programmatic level, and any incidental take
resulting from any action subsequently authorized, funded, or carried out under the program is
addressed in subsequent §7 consultation (50 CFR §402.14(i)(6)). As appropriate and considering
best available data at the time, the Service may rely on the conclusion(s) of this BO in
responding to a consultation request for future U.S. Army/Ft. Benning actions that are consistent
with this programmatic Action, and as necessary, provide project-level ITSs.
This BO evaluated effects of the Action on the red-cockaded woodpecker (Picoides borealis =
Dryobates borealis), which is also protected under the Migratory Bird Treaty Act, and
determined that incidental take of this species is reasonably certain to occur. The amount and
extent of incidental take expected to occur will be specifically addressed at the project level,
when future Tier 2 actions are analyzed.
8.1. Amount or Extent of Take
In meeting the provisions for incidental take in Section 7(b)(4) of the Act, the Service has
reviewed the best available information relevant to this proposed action. Based on this review,
the Service believes that implementation of Ft. Benning’s Conservation and Crediting Program
for the RCW may be beneficial to the conservation of the RCW with possible significant
deleterious impacts to the species at the group, cluster, partition, or neighborhood levels
associated with Tier 2B actions, later in time. Activities necessary for the maintenance of
suitable and potentially suitable nesting, foraging or dispersal habitat such as prescribed burning
and cluster management (cavity provisioning and installation of cavity entrance restrictors) have
the potential to injure or kill individual RCWs (stuck inside cavities) or deny use of cavities
(cavity trees being lost due to fire management actions). Cluster management and translocation
of individual RCWs would be carried out by wildlife biologists who hold the necessary State and
Service recovery permits to conduct these activities. Cluster preparation for fire management on
ACUB properties would be similar as for clusters on Ft. Benning, e.g., fuels are burned away
from cavity trees most at risk of sap burn prior to prescribed burns. Note that these clusters,
groups and foraging partitions do not currently exist.
The Service acknowledges the possibility that management, research, and monitoring activities
for the RCW could result in a low incidence of take. Most of these activities would be
undertaken by property managers, landowners, consulting biologists or academic researchers
who would be fully covered under Section 10(a)(1)(A) permits, which are the subject of separate
actions. However, the loss of RCW cavity trees as a result of prescribed burning is an exception.
The Service expects that conservation actions outlined and detailed in the proposed Ft. Benning
Conservation and Crediting Program for the RCW have the potential to expand RCW population
size and distribution in the Action Area. The proposed action also has the potential to alter RCW
group and territory distribution in the recovery landscape for Ft. Benning's Primary Core
Recovery Population, which could affect RCW demographic and genetic function. Effects
45
associated with prospective changes will be subject to future section 7 consultations where
incidental take is anticipated. Although the exact number of individual RCWs, groups or
neighborhoods involved in such future actions could not be predicted at present, the Service’s
expectation would be that the Ft. Benning Conservation and Crediting Program would eventually
result in an overall net gain of RCW groups on the landscape.
Upon locating a dead, injured, or sick individual of an endangered or threatened species, initial
notification must be made to the West Georgia Field Office. Additional notification must be
made to the Athens, Georgia, Ecological Services Field Office. Care should be taken in handling
sick or injured individuals and in the preservation of specimens in the best possible state for later
analysis of cause of death or injury. All procedural and reporting requirements as outlined in the
Service’s region-wide biological opinion on monitoring and management (Service 2003b) will
be followed.
9. CONSERVATION RECOMMENDATIONS
§7(a)(1) of the ESA directs Federal agencies to use their authorities to further the purposes of the
ESA by conducting conservation programs for the benefit of endangered and threatened species.
Conservation recommendations are discretionary activities that an action agency may undertake
to avoid or minimize the adverse effects of a proposed action, implement recovery plans, or
develop information that is useful for the conservation of listed species. The Service offers the
following recommendations that are relevant to the listed species addressed in this BO and that
we believe are consistent with the authorities of the U.S. Army/Ft. Benning.
Avoid damaging, destroying, or felling pine trees in size and age classes that
serve as foraging or potential nesting substrate and minimize tree loss
throughout all RCW habitat management areas on Program properties or
conservation areas, except as prescribed silviculturally in management plans to
enhance RCW habitat. Ensure, via all management plans and contracts or
agreements for management, that specific emphasis is placed on the importance
of protecting all natural and artificial RCW cavity trees, as well as other old-
growth and flat-top pines as potential cavity trees.
Following prescribed burning activities and wildfires, all managed RCW
clusters will be inspected by the landowner or party responsible for RCW
management on the property. If any RCW suitable cavities are found to be
damaged to the point that they can no longer be used, the landowner or party
responsible for RCW management will replace each damaged cavity by
creating an artificial cavity in close proximity as soon as qualified personnel
can be mobilized and on the site, unless damage from natural or man-made
disaster has impacted the cluster to a level where doing so is not possible.
As properties are added to the Ft. Benning ACUB landscape, document the
present condition of native grass and forb groundcover within clusters and core
46
foraging areas of recruitment territories. This process could involve: (a)
development of a standardized method of describing the quality, quantity and
distribution of native grass and forb groundcovers that are associated with the
good quality habitat for the RCW, and/or (b) establishment and documentation
of permanent photo plots, focusing on the state of ground cover within clusters
In order for the Service to be kept informed of actions minimizing or avoiding adverse effects or
benefiting listed species or their habitats, the Service requests notification of implementation of
any conservation recommendations.
10. REINITIATION NOTICE
Formal consultation for the Action considered in this BO is concluded. Reinitiating consultation
is required if the U.S. Army/Ft. Benning retains discretionary involvement or control over the
Action (or is authorized by law) when:
a. the amount or extent of incidental take is exceeded;
b. new information reveals that the Action may affect listed species or designated critical
habitat in a manner or to an extent not considered in this BO;
c. the Action is modified in a manner that causes effects to listed species or designated
critical habitat not considered in this BO; or
d. a new species is listed or critical habitat designated that the Action may affect.
In instances where the amount or extent of incidental take is exceeded, the U.S. Army/ Ft.
Benning is required to immediately request a reinitiation of formal consultation.
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1
Final Programmatic Biological Assessment
Fort Benning’s Conservation and Crediting Program for the Red-cockaded
Woodpecker (Picoides borealis) Through Off-Post Conservation and
Management of the Longleaf Pine Ecosystem
Location:
U.S. Army Fort Benning
Chattahoochee, Marion, Muscogee, Taylor and Talbot Counties, Georgia
&
Russell County, Alabama
21 August 2018
Submitted by: U.S. Army
Fort Benning, Georgia
Submitted to: U.S. Fish and Wildlife Service
Ecological Services Field Office – Athens, Georgia
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Table of Contents
1. Introduction……………………………………………………………………3
2. Description of the Proposed Action…………………………………………..8
3. Description of the Action Area……………………………………………… 25
4. Status of the Species in the Action Area……………………………………..26
5. Environmental Baseline……………………………………………………....32
6. Effects of the Action…………………………………………………………..33
7. Conclusion and Determination………………………………………………38
8. Literature Citied……………………………………………………………...40
9. Appendices.…………………………………………………………………....44
Appendix A – Glossary of Terms………………………………………44
Appendix B – Pine Dominated Forest Land Evaluation Criteria……46
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1 Introduction
The federal action for the purposes of this Programmatic Biological Assessment (PBA), and
initiating Formal Consultation under Section 7(a)(2) of the Endangered Species Act (ESA) [16 U.S.C. § 1531-1544], is Fort Benning’s Conservation and Crediting Program for the Red-
cockaded Woodpecker (Picoides borealis) (RCW) Through Off-Post Conservation and
Management of the Longleaf Pine Ecosystem. This includes the establishment and management
of RCW Conservation Areas and the subsequent use of generated conservation value to offset the
effects of military training through a Programmatic Compensatory Mitigation Program. This
action establishes a vehicle where by Fort Benning, in collaboration with the U.S. Fish &
Wildlife Service (USFWS), will seek to (a) identify, acquire, enhance, reintroduce, and perform
or support other conservation activities, in Fort Benning’s approved Army Compatible Use
Buffer (ACUB) Priority Areas (PA), that will contribute to the conservation of ESA-listed
species off of Fort Benning to generate “Conservation Credits”, and (b) utilize those
conservation credits to offset the effects to listed species of current or future military installation-
related training and other activities for the purpose of ensuring that such activities can proceed
without restrictions pertaining to listed species, in compliance with Section 7(a)(2) of the ESA.
The intent of this PBA is to support analysis and issuance of a Programmatic Biological Opinion
(PBO) evaluating the effects to listed species from the proposed action as Tier 1 in a two-tier
process. The application of accrued “conservation credits” will be executed through site-specific
Tier 2 project reviews to the anticipated PBO. The Tier 2 reviews will include a jeopardy
determination mirroring the PBO, and include an individual Incidental Take Statement
documenting the “take” on-Post and its beneficial offset from off-Post conservation. This
assessment’s relationship to existing Section 7 Consultations, is a follow-on to remove
conservation measures and offset incidental take, which have resulted in restrictions on training,
natural resource management, construction and use of otherwise lawful activities. As areas are
formalized in the Tier 2 reviews, the intent is that all incidental take for those geographic areas
will be fully offset via the off-Post conservation actions and metrics identified within this PBA.
Upon approval of Tier 2 actions to this consultation by USFWS, tracking and reporting of
incidental take pursuant to all other consultations for those individual areas and PBG’s will be
superseded and no longer warranted since in perpetuity offsets are the keystone metric described.
SPECIES CONSIDERED
Red-cockaded Woodpecker (Picoides borealis) (RCW) Federally Endangered
Gopher Tortoise (Gopherus polyphemus) (GT) Federal Candidate
Effects to GT in relation to conservation area development and conservation offsets have already been evaluated in the Tier 1 Framework Programmatic Conference
Opinion for the Department of Defense Gopher Tortoise Conservation & Crediting
Strategy, 07 November 2017. Presence of GT on ACUB lands identified and acquired
under this RCW Framework will follow the Tier 2 Conference process identified in the
above Tier 1 GT Conference Opinion for the establishment and management of GT
conservation areas.
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Other Federally Listed/Considered Species (Endangered, Threatened, Candidate, or Proposed)
May be or may become present on individual ACUB properties throughout time. This
assessment does not evaluate effects of off-Post management actions on those species as
there is no way to know their presence until property specific information becomes
available as part of the acquisition process. Therefore, effects to other federally listed
species will be assessed in the Tier 2 Consultation process identified in this assessment.
FORT BENNING DESCRIPTION
The Department of Defense’s military mission at Fort Benning is “The Maneuver Center of
Excellence and Fort Benning provide trained and combat–ready Soldiers and leaders; develop
the doctrine and capabilities of the Maneuver Force and individual Soldier; and provide a world-
class quality of life for our Soldiers, civilians, and Army families to ensure our Army’s
Maneuver Force remains the world’s premier combat force ready to "Win in a Complex
World."” The Fort Benning Army Installation is located in the southeastern United States. It lies
south and east of the cities of Columbus, Georgia, and Phenix City, Alabama (Figure 1). The
installation occupies 182,000 acres; approximately 170,000 acres of which are in Muscogee and
Chattahoochee Counties, Georgia, and approximately 12,000 acres are in Russell County,
Alabama. The Chattahoochee River meanders through the western part of the Installation and
separates the Georgia and Alabama portions.
Fort Benning’s primary military activities include: training entry-level Soldiers, providing the
Nation’s primary facility for training the U.S. Army Infantry and Armor, conducting Airborne
and Ranger candidate training, hosting the Western Hemisphere Institute for Security
Cooperation and the Army’s Noncommissioned Officer Academy, and providing a power
projection platform for rapid deployment. Besides its resident training units, Fort Benning also is
home to a number of tenant units that conduct much of their training at the installation. Tenant
units include the Task Force 1st Battalion, 28th Infantry Regiment, 1st Security Force Assistance
Brigade, 14th Combat Support Hospital, Army Marksmanship Unit and the 3rd Battalion 75th
Ranger Regiment, as well as the 75th Ranger regimental headquarters. Over 14,000 Soldiers call
Fort Benning home.
The types of training and the requirements of units present at the Installation affect the nature
and extent of natural resource impacts at Fort Benning. Impacts result from direct removal of or
damage to vegetation, digging activities, ground disturbance from vehicles, use of obscurant
smoke and teargas-like agents, and munitions detonation. The mechanized forces in particular,
which use vehicles that include the M1A1 Main Battle Tank and the M2A2 Bradley Fighting
Vehicle, can produce adverse direct and indirect impacts to natural resources. Often these
impacts are related to soil disturbance and movement that may result in soil erosion and stream
sedimentation. Fort Benning has numerous ranges, eight of which can accommodate fire from
mechanized vehicles, and ten impact areas that can accommodate a variety of munitions. Cleared
areas include firing points, bivouac sites, landing zones (landing strips and pads) for fixed and
rotary-wing aircraft, and drop zones for airborne training. Projected training, proposed future
range improvements, and upkeep and maintenance of so many training assets necessitate a close
integration with the resource management strategies specified in this management plan to ensure
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a sustainable training environment. Figure 2 depicts the locations and proximity ranges,
airfields, training areas (TAs), impact areas, and other facilities on Fort Benning.
Current species management on Fort Benning is accomplished through the implementation of the
Fort Benning Integrated Natural Resource Management Plan (Benning, 2016), its appendices and
other interrelated management plans such as but not limited to: Endangered Species Management
Components, Forestry Management Plan, Integrated Wildland Fire Management Plan, Pest
Management Plan, and Range Complex Master Plan. Several Endangered Species Section 7
Biological Opinions and Concurrence Letters have been issued by the USFWS listed in the
consultation history section below.
Even with the management and compliance requirements of the aforementioned documents,
considerable restrictions remain on current and future military training in forested habitats. For
more comprehensive and detailed information on these requirements and management plan
objectives, please reference these documents directly.
Figure 1: Fort Benning Geographic Location and General Features Map.
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Figure 2: Fort Benning Training Land Use Map.
CONSULTATION HISTORY
22 September 1994 USFWS determined that military training and related management
activities at Fort Benning were likely to jeopardize the continued existence
of the RCW on Fort Benning.
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14 August 2001 Fort Benning’s first Integrated Natural Resources Management Plan
(INRMP) was provided to USFWS, followed with a request from Fort
Benning on 22 August 2001 to initiate Formal Consultation on the INRMP
and associated Endangered Species Management Plans (ESMP), including
the RCW ESMP.
27 September 2002 USFWS approved Fort Benning’s INRMP and ESMPs which
implemented the 1996 Army RCW Guidelines and relieved Fort Benning
of the Jeopardy Opinion issued in 1994. (FWS Log Number 99-0620)
12 March 2004 Fort Benning Provided a Biological Assessment of the Construction,
Operation and Maintenance of a Proposed Digital Multipurpose Range
Complex (DMPRC).
22 July 2004 USFWS Issues Final Biological Opinion on DMPRC (FWS Log No: 03-
0584)
13 April 2007 Fort Benning Provided a Biological Assessment of the Base Realignment
and Closure (BRAC) Transformation and Requested Initiation of Formal
Consultation.
20 August 2007 USFWS Issues Final Biological Opinion on BRAC Transformation. (FWS
Log No: 07-FA-0954)
27 October 2008 Fort Benning Provided a Biological Assessment of the Maneuver Center
of Excellence and Requested Initiation of Formal Consultation.
29 May 2009 USFWS Issues Final Biological Opinion on Maneuver Center of
Excellence at Fort Benning. (Consultation # 2009-FA-0118)
09 April 2014 USFWS Issued General ACUB Expansion Concurrence Letter
(Consultation# 2014-CPA-0468)
20 November 2014 USFWS Approved Fort Benning’s RCW Endangered Species
Management Component (ESMC) which implemented 2007 Army RCW
Guidelines. (USFWS Log # 2014-F-1128)
11 September 2015 USFWS Issues Final Biological Opinion on Enhanced Training at Fort
Benning. (Consultation # FF04EG1000-2015-F-0833)
14 July 2016 Fort Benning Letter Requested USFWS Concurrence on Specific ACUB
Expansion for 8,884 Acres
01 August 2016 USFWS Issued Specific 8,884 Acre ACUB Expansion Concurrence Letter
(Consultation# 04EG1000-2016-CPA-0676)
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14 December 2017 HQ-IMCOM, AEC, and Fort Benning met with the USFWS to discuss
development and species dynamics related to compensatory mitigation
elements and PBA development supporting formal consultation.
13 June 2018 AEC and Fort Benning met with the USFWS to address comments and
revisions identified in the Draft PBA.
2 Description of the Proposed Action
GENERAL DESCRIPTION
The federal action for the purposes of this PBA, and initiating formal consultation under Section
7(a)(2) of the ESA, is Fort Benning’s Conservation and Crediting Program for the Red-cockaded
Woodpecker (Picoides borealis) (RCW) Through Off-Post Conservation and Management of the
Longleaf Pine Ecosystem within Fort Benning’s approved Army Compatible Use Buffer
(ACUB) Priority Areas (PA).Off-Post conservation of the RCW will occur on individual
properties and/or conservation areas, where a conservation area may be comprised of multiple
and adjoining individual properties, and includes the subsequent establishment and use of
generated conservation values to offset any adverse effects of military training through a
Programmatic Compensatory Mitigation Program.
This action establishes a vehicle whereby Fort Benning, in collaboration with the USFWS, will
seek to (a) identify, acquire, enhance, reintroduce, and perform or support other conservation
activities (e.g. land protection, habitat management, species monitoring, etc.) that will contribute
to the conservation of ESA-listed species on individual properties and/or conservation areas off
of Fort Benning to generate “Conservation Credits”, and (b) utilize those conservation credits to
offset any adverse effects to listed species of current or future military installation-related
training and other activities for the purpose of ensuring that such activities can proceed without
restrictions pertaining to listed species, in compliance with Section 7(a)(2) of the ESA.
The intent of this PBA is to support analysis and issuance of a Programmatic Biological Opinion
(PBO) evaluating the effects to listed species from the proposed action as Tier 1 in a two-tier
process. The application of accrued “conservation credits” will be executed through site-specific
Tier 2 project reviews to the anticipated PBO. The Tier 2 reviews will include a jeopardy
determination mirroring the PBO, and include an individual Incidental Take Statement
documenting the “take” on-Post and its beneficial offset from off-Post conservation. This
assessment’s relationship to existing Section 7 Consultations, is a follow-on to remove
conservation measures and offset incidental take, which result in restrictions on training, natural
resources management, construction and use of otherwise lawful activities (Benning, 2018). As
areas are formalized in the Tier 2 reviews, the intent is that all incidental take for those
geographic areas will be fully offset via the off-Post conservation actions and metrics identified
within this PBA. Upon approval of Tier 2 actions to this consultation by USFWS, tracking and
reporting of incidental take pursuant to all other consultations for those individual areas and
PBG’s will be superseded and no longer warranted since in perpetuity offsets are the keystone
metric.
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It is important to note that the program and processes identified in this PBA is a tool that can be
utilized as part of ESA compliance for Fort Benning. All actions on Fort Benning will be
evaluated with standard Section 7 methodologies and consultation to determine, define, and
evaluate effects to listed species. If during those standard and established processes it is
determined that compensatory mitigation is the preferred conservation measure then the process
defined herein will be utilized to provide the necessary conservation offset.
1) Tiered Consultation/Implementation Process
1. Two-tiered implementation approach
Implementing this action utilizes a two-tiered, programmatic approach pursuant to
section 7(a) (2) of the ESA, which is further defined below. Individual action
program reviews tiered to the PBO, consistent with the provisions of
Programmatic Consultations, will be developed. The tiered approach allows the
identification and consideration of site-specific information necessary to support
both an analysis of the effects of the conjoined action, and the preparation of the
Incidental Take Statement covering take associated with both the mission and
conservation activities identified in the project review.
i. Tier 1 is addressed in this Biological Assessment, which analyzes the
action as a whole for beneficial and adverse effects to RCW to determine
whether the action is likely to jeopardize the continued existence of these
species. As necessary for the duration of the action, Fort Benning and the
USFWS will review the progress of the action, considering (a) monitoring
results provided through annual reporting, and (b) best available data
about the status of the species, to determine whether a reinitiation of
consultation is warranted. Final establishment of Tier 1 occurs when a
PBO is issued by the USFWS.
ii. Tier 2 is the individual project level review and analysis, when requested
by Fort Benning pursuant to the Tier 1 PBO. Projects include both those
that create conservation value/credits (Tier 2A) and those that seek to
apply such value/credits (Tier 2B) to offset adverse effects of identified
actions on the installation. If the project is fully consistent with the
programmatic action, the USFWS will rely on the findings of the Tier 1
PBO to formulate a project-specific Incidental Take Statement, if take is
reasonably certain to occur.
2. Consultation Implementation process outline
The following sections outline the process that Fort Benning and USFWS will use
to implement this conservation program, ensure ESA compliance is achieved, and
species conservation metrics are met in an efficient and timely manner.
i. To initiate Formal Consultation on this action, Fort Benning submits
this Biological Assessment of the proposed action as a first step toward completion of Tier 1 Consultation.
ii. The USFWS, pursuant to the ESA, will issue a Programmatic
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Biological Opinion, analyzing the action and the process of implementation as a whole, and thus finalizing the Tier 1 Consultation.
iii. As Tier 2A “Credit Actions” are identified or conservation milestones are met off-Post, Fort Benning will initiate a formal review request to the USFWS pursuant to the Tier 1 PBO. At a minimum, the request shall include spatial information (maps or GIS), real property information (deed or easement), a property and/or conservation area-specific habitat management plan, long-term management assurance (per Army Authorities), summary of surveys to date documenting (habitat &/or species), documentation of successful reintroduction of a new population or improved status of an existing population (if applicable), and an assessment of conservation value (credits) generated.
iv. The USFWS will review the information submitted by Fort Benning in “iii” above to ensure it is consistent with the Tier 1 PBO. The USFWS will provide concurrence generating the identified conservation/credit value or non-concurrence with comments to the request within 30 days of receipt.
v. As Tier 2B “Offset/Debit Actions” are identified on-Post, Fort Benning
will initiate a formal review request to the USFWS pursuant to the Tier 1 PBO. At a minimum, the request shall include spatial information (maps or GIS), summary of surveys to date (habitat and/or species), an assessment of conservation value impacted (debits), and which corresponding “conservation/credit value” generated in Step “iv” are proposed as the offset.
vi. The USFWS will review the information submitted by Fort Benning in “v” above to ensure it is consistent with the Tier 1 PBO. USFWS will then provide concurrence or non-concurrence with comments to the request within 90 days of receipt.
vii. The USFWS will maintain the administrative record for each
conservation area, containing all documents, including Tier 2A requests for the creation of the area and Tier 2B requests for use of conservation/credit value from the area. The USFWS will also maintain a current summary of credits and debits by conservation area/action, as well as copies of all monitoring reports.
viii. Tier 2A and Tier 2B actions can be conducted or requested simultaneously or combined at any time to ensure a sufficient conservation balance to meet the necessary offset. If combined, both Fort Benning and the USFWS will ensure documents clearly articulate the intent and individuality of each area for appropriate review and accounting.
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2) Off-Post Land Conservation Initiatives
The Army has several authorities that allow us to invest and partner with eligible entities
for the conservation and management of land off-Post. These are almost always through a
partner via a Cooperative Agreement undertaken on the Army’s behalf. While there are
two main authorities described below, this consultation is not limited to them alone. Fort
Benning and the Army will explore and utilize any current or future authorities that result
in in perpetuity conservation and management for the RCW that generate conservation
value, as described later within this BA. The intent is to utilize these and other authorities
to ensure legal real estate interest and financial assurances are provided to maintain
natural resource durability for use as compensatory mitigation.
1. 10 USC 2684a “Agreements to Limit Encroachments and Other Constraints on
Military Training, Testing, and Operations”
i. The ACUB program operates under this authority.
ii. Section (a) states that the Secretary of Defense or the Secretary of a
military department may enter into an agreement with an eligible entity or
entities described in subsection (b) to address the use or development of
real property in the vicinity of, or ecologically related to, a military
installation or military airspace for purposes of—limiting any
development or use of the property that would be incompatible with the
mission of the installation; preserving habitat on the property in a manner
that— is compatible with environmental requirements; and may eliminate
or relieve current or anticipated environmental restrictions that would or
might otherwise restrict, impede, or otherwise interfere, whether directly
or indirectly, with current or anticipated military training, testing, or
operations on the installation.
iii. Section (d) (2) requires that property or interests may not be acquired
pursuant to the agreement unless the owner of the property or interests
consents to the acquisition.
iv. Section (d)(3) states that an agreement may provide for the management
of natural resources on, and the monitoring and enforcement of any right,
title, real property in which the Secretary concerned acquires any right,
title, or interest in accordance with this subsection and for the payment by
the United States of all or a portion of the costs of such natural resource
management and monitoring and enforcement if the Secretary concerned
determines that there is a demonstrated need to preserve or restore habitat.
v. More details can be found in the full Code. However, the above provide
the main framework and concepts related to this authority.
2. 16 USC 670 “Sikes Act”
i. Specifically 16 USC 670c-1, section titled “Cooperative and Interagency
Agreements for Land Management on Installations”
ii. Section (a) states that a Secretary of a military department may enter into
cooperative agreements with States, local governments, Indian tribes,
nongovernmental organizations, and individuals, and into interagency
agreements with the heads of other Federal departments and agencies, to
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provide for the following: The maintenance and improvement of natural
resources located off of a military installation or State-owned National
Guard installation if the purpose of the cooperative agreement or
interagency agreement is to relieve or eliminate current or anticipated
challenges that could restrict, impede, or otherwise interfere with, whether
directly or indirectly, current or anticipated military activities.
iii. Section (b)(2)(a) states that for these off-base agreements, funds may be
paid in a lump sum and may include an amount intended to cover the
future costs of the natural resource maintenance and improvement
activities provided for under the agreement. Such funds may be placed by
the recipient in an interest-bearing or other investment account, with
resulting interest or income being applied for the same purposes as the
principal.
iv. More details can be found in the full Code. However, the above provides
the main framework and concepts related to this authority.
3. Fort Benning and the Army intended to use these and other appropriate authorities
to seek out, identify, acquire, enhance, reintroduce, and perform or support other
conservation activities that will contribute to the conservation of the RCW off-Post
contributing to the Fort Benning Primary Core Population to generate conservation
value and credit. Properties and investments will be evaluated individually based
on their potential to support and achieve the conservation metrics outlined later in
this BA.
3) Off-Post Habitat Management Plan Requirements
This section identifies the mandatory Property and/or conservation area’s Specific
Habitat Management Plan (Plan) outline and requirements to maintain and enhance
natural resource durability toward compensatory mitigation for the target species and
habitats. Headquarters, Installation Management Command (IMCOM) has approved an
overarching Comprehensive ACUB Land Management Plan (TNC, 2018) which may
serve as the management plan for any individual properties and/or conservation areas and
must guide and align any other management plans for ACUB properties which are
proposed for use in compensatory mitigation. The Plan addresses the following topics:
1. Army and USFWS Approvals
i. Plan is developed by the Partner/Cooperator Landowner, then reviewed
and mutually approved by Fort Benning, IMCOM and the USFWS during
the Tier 2A project reviews.
ii. Management plans will be reviewed annually for operation and effect and
revised as needed, any major revisions will require the approval of both
the USFWS and Fort Benning.
iii. Management plans shall be revised, updated, and re-approved by the
USFWS & Fort Benning at least every 10 years.
2. Goals and objectives
i. Goals
a. Objectives to achieve goals
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b. Metrics to measure success
3. Compatible Land Uses
i. Must define a list and or limitations to be compatible.
4. Incompatible Land Uses
i. Define a list of incompatible uses.
5. Prescribed (Rx) Burning
i. Dormant and Growing season objectives
ii. 2-3 Year fire return interval upon initial introduction of Rx fire
iii. Burn units and maps
iv. Firebreak construction/maintenance
v. Unique or sensitive considerations (e.g., reducing smoke and preventing
burning out of prescription)
6. Invasive Species Management
i. Animals targeted
a. Trapping
b. Shooting
c. Exclusion
ii. Plants targeted
a. Hand removal specs
b. Mechanical removal specs
c. Herbicide use
7. Habitat Enhancement and Monitoring
i. Species to be used
ii. Planting methods
iii. Monitoring method
a. Items measured
b. Frequency
c. Statistics used
8. Species Enhancement and Monitoring
i. Reintroduction methodology
a. Translocation
ii. Population monitoring method
a. Items measured
b. Frequency
c. Statistics used
9. Other Federally Listed, Candidate, or Proposed Species
i. Identify other ESA-regulated species present and methodologies for
minimizing effects on them while maximizing collective benefit.
10. Adaptive Management
i. Describe how adaptive management will be employed to facilitate
implementation of the plan
11. Budget and Implementation
i. Establish the process for identifying costs and securing funding assurances
for anticipated costs for near term (10yr) restoration actions and perpetual
annual management requirements
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12. Reporting
i. Partner reporting process and timeline for adverse impacts (trespass,
wildfire, species harm, etc.)
ii. Partner reporting process and timeline for significant events (species
survey, translocation, research completion, education outreach events,
etc.)
iii. Partner(s) providing ACUB Annual Report(s) to the Army prior to or upon
the Army established suspense date each year
iv. Army consolidates with partner(s) for reporting to USFWS within 90 days
of receipt of ACUB Annual Report by providing written report
4) Red Cockaded Woodpecker Framework
Fort Benning and USFWS recognize that multiple factors go into determining both the
aggregate mitigation potential of qualifying ACUB properties, defined herein as RCW
Conservation Values, and the degree to which the use of such mitigation identified in
future Tier 2 Consultations will be required. Furthermore, mitigation potential cannot be
identified and quantified in the abstract; the nature, magnitude and duration of potential
impacts to RCW on Fort Benning will have the potential to affect the mitigation values
provided by the ACUB landscape largely due to the consequences of such Installation
impacts to the potential use by RCW of habitat on both the Installation itself and on the
ACUB properties. Additionally, the aggregate RCW Conservation Values provided by
qualifying ACUB properties will be subject to change as a result of subsequent additions
to the set of qualifying properties, as additional properties are acquired and/or put under
conservation management and funded as previously described. Furthermore, external
factors, such as growth and distribution of the collective Installation and ACUB RCW
population, climactic variability, and the risk of stochastic events such as catastrophic fire
and/or natural weather/climate events may affect the potential distribution over the
ACUB landscape of future PBGs.
For all of these reasons, Fort Benning anticipates that the determination of available
RCW Conservation Values will be an iterative process requiring periodic re-examination
and re-evaluation. This process will begin with the execution of this Programmatic
Biological Assessment and the recognition by USFWS that the number of future RCW
PBGs that the qualifying ACUB lands are capable of supporting, determined through
methodologies including primarily the metrics described in Section 2.4.5 (Net Present
Conservation Value) below, but also Pattern-Oriented Modeling (POM), Landscape
Equivalency Analysis (LEA), other modeling, and/or the use of Geospatial Information
Systems (GIS) as necessary, will be used to determine RCW Conservation Values for use
as mitigation in future Fort Benning consultations. Previous modeling exercises
completed in 2013 analyzed theoretical RCW occupancy of a “max” and “corridor”
ACUB protected and managed landscape along with a best and worst case RCW
population inside the Fort Benning boundary. The modeling predicted a significant
increase in PBGs due to the addition of habitat on ACUB for all scenarios (ESM Inc.,
2013). Additional modeling scenarios may be most warranted when analysis of impacts
suggests demographic isolation is likely to occur between the Fort Benning and ACUB
properties, or within the Fort Benning Boundary, or if the anticipated amount of take is
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determined to potentially jeopardize recovery even with the anticipated conservation
values attributed to the ACUB landscape.
1. Initial Identification of Available RCW Conservation Values
Fort Benning and USFWS agree that the 8,894 acres of lands on ACUB properties
contiguously adjacent to Fort Benning that were accepted by USFWS as additional
to Fort Benning’s baseline RCW habitat represents an initial pool of RCW
Conservation values than can be evaluated for available PGB’s for use as offsets.
That determination is based on the prior determination that the lands in question
were contiguously adjacent to Fort Benning, protected against adverse lands uses
in perpetuity, were subject to appropriate management plans, and had funding
assurances in place (USFWS, 2016). This initial RCW Conservation Values
determination will be subject to re-evaluation as defined in this Tier 1 PBA and
the Tier 1 PBO once issued.
2. Basis for Advance Credit Accrual
Fort Benning’s history of success in managing stand structure development
provides a basis for concluding that, with funding and management assurances,
qualifying ACUB lands can be managed to provide habitat for RCW in the future,
regardless of the current habitat conditions. Further, qualifying ACUB lands
provide new capacity for RCW population growth and expansion. This, combined
with artificial recruitment capabilities through the installation of artificial cavities
and the translocation of RCW, is the foundation of this consultation. In order to
find success in these efforts, translocation will not be considered until suitable
habitat is sufficient to support recruitment clusters. Additionally any translocation
conducted would be in accordance with the USFWS Section 10(a)(1)(A)
Permitting Process of which has already been evaluated in 2003 for incidental take
under a USFWS Biological Opinion on the permitting process (USFWS, 2003b).
3. Advance Credit Analysis
Through this Strategy, available mitigation will be determined based on habitat
type/age. The Programmatic Biological Assessment assigns increasingly greater
mitigation value for demonstrated management success as forest stands age, Basal
Area measurements, and other habitat values come into being and provide
foraging, nesting and occupied fully restored habitat. This dynamic (increasing
mitigation value is realized as habitat values increase through management) is
likewise consistent with the increasing conservation investment associated with the
acquisition and funding of habitat development activities, and the protection from
inconsistent management activities over time. Furthermore, the conservative
design encourages ongoing commitment to habitat management, and encourages
restoration and management on a broader landscape level. As a result, the
framework provides for increased potential stability for the Ft Benning RCW
population.
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4. Basis for Conservation Values
The recovery of the RCW is dependent upon suitable forested RCW habitat for
dispersal, foraging, and nesting. To aid land managers in reaching RCW recovery
goals, the USFWS developed management standards as guidance in analyzing
foraging and nesting habitat. These standards aim to provide not only foraging and
nesting habitat but also all desired future conditions for RCW, including mature
stands of pine with an open canopy, low densities of small pines, minimal or no
hardwood or pine midstory, few or no overstory hardwoods, with abundant
groundcovers consisting of native bunchgrasses and forbs.
The actualization of these standards is dependent on space, time, and management
success. Some of the habitat standards are primarily dependent upon management
success (e.g.., frequent fire, tree species and size, midstory requirements, ground
cover, etc.). Implementation of approved management plans makes it reasonably
certain that these RCW habitat criteria will be achieved over time, as has been
consistently demonstrated on numerous landscapes within the RCW range,
including on Fort Benning.
With land management continuing to meet the standardized guidelines, the
realization of future foraging suitability and ultimately occupation of suitable
habitat by RCW is time dependent; thus, it will be possible to predict when areas
that are unsuitable or marginal for foraging will become suitable. The distribution
of future potential and suitable nesting habitat across the landscape will then
predict what specific areas are and will be capable of supporting future RCW
clusters at any particular point in time. The recognition that achieving suitable
habitat for nesting is also primarily a matter of time (tree age and diameter)
provides another time-step on the way to the development of occupied habitat.
Thus, with continued appropriate management on qualifying ACUB lands, areas
can be classified as: 1) Future potential habitat: including currently unsuitable and
marginal habitat (currently unsuitable for RCW except possibly for dispersal),
typically 0-29 years of age; 2) Foraging habitat: including currently suitable
foraging habitat, as defined by metrics within the USFWS Foraging Habitat
Analysis (FHA) management standards and the acreage recommendations they
provide (USFWS 2003), typically 30-59 years of age; 3) Nesting habitat: including
unoccupied but suitable nesting habitat, which must also include suitable foraging
habitat, defined by FHA standards with the addition of cavity tree requirements
(i.e., candidate trees available for either artificial cavity installation or natural
cavity excavation) (USFWS 2003), typically 60+ years of age; and 4) Occupied
fully restored habitat: restored and managed suitable habitat supporting active
PBGs (thus, both nesting and foraging habitat).
The value to RCW of each of these habitat categories increases as habitat
transitions from future potential habitat, to foraging habitat, to nesting habitat, to
occupied fully restored habitat. Similarly, the conservation investment increases
as the habitat transitions due to land acquisition costs, land management costs, and
lost opportunity costs aggregating over time. Financial investments and
17
management costs yield conservation values to RCW in terms of (1) acquisition of
potentially suitable RCW habitat, (2) institution and perpetual funding of
management regimes appropriate to development of RCW habitat values, and (3)
the protection of acquired lands in perpetuity, all of which provide clear mitigation
values to RCW. Further, the precept that RCW habitat values increase based on
continued forest growth and development is supported by the recognition that as
forest lands are managed for RCW instead of for economic returns from timber
value, the increasing value the timber represents and can be quantified as lost
opportunity costs (Drier 2005).
Based on the foregoing, this framework utilizes the conservation benchmarks of
future potential, foraging, nesting, and occupied fully restored habitat types to
quantify the current mitigation value to RCW of qualifying ACUB properties at
any particular point in time.
5. Methodology for Calculating “Net Present Conservation Value” (NPCV) Credits
When considering the three categories of suitable habitat (foraging, nesting and
occupied fully restored habitat), the current RCW conservation value of qualifying
ACUB properties can be described based on the aggregate acreage of each of those
habitat categories. Thus, considering each category in the context of conservation
milestones and valuing each in such a manner is reasonable. There are four
supporting factors that were considered to assign percentage values to each
milestone to ensure consistency with commensurate surrogates. The first factor
considered is that habitat conditions in the RCW Recovery Plan are generally
described at in 1/3’s over the time span of 100 years. Essentially 30 years to grow
suitable foraging habitat, 30 years as suitable foraging habitat, and then 30 years
plus as suitable nesting habitat. The second factor is consistency with other
mitigation valuations whereas approximately 50% of the value is realized at the
establishment of a conservation area and the remaining 50% is realized when the
area meets the desired future condition. Values identified in this action are overall
less and can thus be considered more conservative. The third factor is the concept
of lost opportunity cost which recognizes that the further along a given acreage
(type/age) is in the restoration process, the more valuable the associated suitable
RCW habitat would be in the context of supporting RCW foraging and realizing
future PBGs. As such, this factor accounts for, the increasing opportunity costs
would be lost in foregoing other potential forest management scenarios (Drier et al.
2004; Glenn et al. 2012) that could otherwise generate increased timber revenues.
The fourth factor relates to evaluating the actual and estimated cost of the Fort
Benning ACUB program area as a whole. Based on the existing Fort Benning
ACUB Priority Area 1 Goal of 40K acres, it is estimated that a total $100M
investment would secure protection of 40K acres. Through a collaborative effort
with partners, Fort Benning has determined that the Army’s interest in perpetual
management of those ACUB acres would cost approximately $500K annually
which would be funded from the interest generated from a long-term management
fund. As a sum total, 100 years of management in Army’s interest would expend
$50M. In sum, the total investment would be $150M with 2/3 for protection and
18
1/3 for management. The ratios established in this PBA establish a conservative
approach when considering the nature of financial investments, with a maximum
of only 50% of the credit value afforded at the point in which a 65% investment
has been made.
Determining a precise fractional value for developing RCW habitat is challenging,
although the different concepts of mitigation values identified above (habitat
values increase with age class, conservation investments in acquisition and
management increase over time, and timber management values foregone increase
with time) all support the concept. Recognizing acquisition of lands with future
potential, habitat protection, and a commitment to restoration is the key and
essential step for the entire process, without the available lands dedicated to
conservation the other milestone/metrics could never be reached or considered.
Therefore, acquisition and commitment of unforested or non-pine dominated lands
toward future potential habitat generates 35% the total available credit for a tract.
An additional 15% of the total available credit for a tract is awarded if the lands
conserved are existing pine dominated forest lands. To determine “pine dominated
forest lands”, stands will be evaluated in a manner similar to that currently utilized
on Fort Benning, the criteria of which is further described in Appendix B. The
value of the earliest category that can serve as habitat for RCW foraging is
assigned a value of 15% and then another 15% value is assigned when restoration
to nesting habitat standards is achieved. Finally the remaining 20%
conservation/credit value is generated and realized when habitat is fully restored
and occupied by RCW. This system generates an incentivized program whereby
continued achievement of milestones generates releases of additional conservation
value. In applying these concepts, a value for mitigation purposes can then be
calculated using the following proportional values per unit area:
Unforested or Non-pine Dominated ACUB Lands = 0.35
Pine Dominated ACUB Lands = 0.15
Foraging Habitat Standard Achieved = 0.15
Nesting Habitat Standard Achieved = 0.15
Fully Restored/Occupied Habitat = 0.20
To determine the mitigation value of the qualifying ACUB landscape, the acreage
of each of the first four habitat types (as described above) will be assessed and
summed for all qualifying properties. The current acreage of each of the first four
habitat types will then be multiplied by the corresponding proportional value
(above), and then divided by 200, the approximate acreage required to support a
PBG (USFWS 2003) unless further refined based on quantified site specific
conditions. This yields the maximum available mitigation value for unoccupied
habitat for consideration related to any actions requiring mitigation and subsequent
consultation of qualifying ACUB lands in terms of PBGs at any given time. For
Occupied habitat, the PBG present will be considered as a full offset independent
of the acreage attributed to the active PBG. These processes will allow Fort
Benning and the USFWS to periodically reassess available conservation value
19
through this framework through continued evaluation of tracts as necessary to
determine when milestones are achieved and conservation value released.
A sample calculation for these type actions, accounting for 10,000 acres of future potential
or suitable habitat, could be as follows:
5,000 acres unforested or non-pine dominated: 5,000 X 0.35 = 1750 / 200 = 8.75 PBG
2,600 acres pine dominated: 2,600 X 0.50 = 1,300 / 200 = 6.5 PBG
1,400 acres foraging habitat: 1,400 X 0.65 = 910 / 200 = 4.55 PBG
500 acres nesting habitat: 500 X 0.80 = 400 / 200 = 2 PBG
500 acres occupied habitat with 3 active clusters = 3 PBG
TOTAL PBG = 24.8 PBG (24 NPCV PBG Credits available for consultation)
6. Evaluation of Conservation Values
The habitat suitability and presence of future PBGs across the ACUB landscape as
well as the physical and genetic connectivity of these newly established habitat
areas with the existing population, will be verified and evaluated periodically
utilizing population monitoring and/or established LEA (landscape equivalency
analysis) criteria, or comparable analyses that provide the same or similar
information. This will allow evaluation of the results of application of the
framework and course corrections if necessary. As deemed necessary, evaluations
will be conducted on five (5) year intervals, as well as in the course of future
Section 7(a) (2) Consultations in which LEA, or a LEA-type analysis, is deemed
appropriate. In the event that the model results indicate fewer future PBGs than
calculated through the methods above, USFWS and Fort Benning will meet to
discuss how to proceed.
7. Adjustment of RCW Conservation Values in Subsequent Consultations
As previously discussed, available RCW Conservation Values may be affected by
the anticipated impacts for which they will be used as mitigation. Accordingly, the
potential need to recalculate available RCW Conservation Values may be
considered whenever their use as mitigation is anticipated. Recalculation of
available RCW Conservation Values (utilizing LEA or another methodology) will
not necessarily be required for all consultations in which mitigation is proposed for
use. For example, a consultation involving impacts that are small, or the location
of which suggests that they are unlikely to substantively affect demographic
connectivity, may not require recalculation. Whether or not recalculation is
required will be determined thru Tier 2 Consultations.
8. Tracking and Documenting Consumption of RCW Conservation Values
A credit register of available (unutilized) RCW Conservation Values and of
Conservation Values that have been utilized as mitigation in consultations will be
established for qualifying ACUB properties and will be maintained by both Fort
Benning & the USFWS. As RCW Conservation Values are utilized to offset
Installation RCW impacts, the register will be adjusted to reflect both the
application of RCW Conservation Values as mitigation and remaining, unutilized
20
Conservation Values. Following such consultations, Fort Benning will advise
USFWS in a timely manner of the aggregate consumption of RCW Conservation
Values and of the remaining balance of unutilized Conservation Values.
Fort Benning may update the register periodically thru formal or informal
consultations to reflect changes to RCW Conservation Values through the addition
of new qualifying properties or other factors which may result in beneficial or
adverse impacts to RCW, either on or off the Installation. Otherwise, the
principal mechanism anticipated for updating the register to reflect available (both
new and previously existing but unutilized) RCW Conservation Values is through
the evaluation of available RCW Conservation Values as such values are proposed
for use in subsequent consultations.
9. Tracking Habitat Development Against Conservation Value
Long-term nesting and foraging habitat monitoring and reporting is critical for
assessing progress toward and then maintenance of the desired future condition of
the off-site RCW habitat (Costa et al. 2012). It is also critical to evaluating the
premises upon which RCW Conservation Values have been documented and
utilized as mitigation. Monitoring will be pursued at the individual property and/or
conservation area and timber stand level. Habitat development should proceed
over time as expected and follow the estimated timeline for restoration specified in
each property and/or conservation areas specific Management Plan.
10. Monitoring Requirements
Potential habitat on conservation areas will be monitored in the same manner as on
Fort Benning to determine that pine stand grow-in and habitat development is
proceeding on schedule and is not delayed due to improper management, climatic
variables, or some other cause. RCW cluster and foraging habitat monitoring will
follow guidelines established in the 2003 Red-cockaded Woodpecker (Picoides
borealis) Recovery Plan: Second Revision (Recovery Plan) (USFWS 2003), or
future revised edition of the Recovery Plan. Habitat variables and conditions to be
monitored and the specific methods and schedules for monitoring them will be
identified in each property and/or conservation areas specific Management Plan
(Costa et al. 2012).
Once RCW presence is known on an ACUB property, population monitoring will
be critical for assessing progress toward and then maintenance of each property
and/or conservation areas population goal. RCW population monitoring will
follow guidelines established in the Recovery Plan (USFWS 2003) and the Army
Guidelines (USDA 2007). RCW population monitoring involves numerous
activities related to both habitat and RCW parameters. Activities include, but are
not limited to; assessing cavity numbers and suitability, examining hardwood
midstory conditions, cluster and cavity activity checks, nesting season monitoring
(e.g., banding nestlings, determining number of PBGs and fledglings) and
translocation success. Although the Recovery Plan provides standard guidance on
all of these monitoring activities, each property or conservation areas specific
21
Management Plan will specify how they will be accomplished, e.g., by census vs.
sampling, within the framework of available guidance and in alignment with the
Recovery Plan.
11. Reporting Requirements
Fort Benning, in cooperation with partner landowners holding interest in properties
with Army Contingent Rights established, will provide USFWS a report for each
ACUB property and/or conservation area every five years. Initially, and until
RCW are established on a property and/or conservation area, this report will
document the status of and summarize the progress and implementation of the
“habitat restoration” component of that property and/or conservation areas
Management Plan. The Army, in cooperation with the Service, will design a
standardized “habitat restoration” report for use on all ACUB properties. This
report will be vital for informing both the Army and USFWS on whether habitat
restoration benchmarks and timelines are being achieved (Costa et al. 2012).
Once the first RCW occupy an ACUB property (basically indicating that habitat
restoration has been accomplished or is at least well advanced), the new RCW
population will as a minimum be incorporated into the installation’s annual report
to the Service: the U.S. Fish and Wildlife Service Regional Annual Red-cockaded
Woodpecker Property Data Report (Annual RCW Report) (Costa et al. 2012).
12. Adaptive Management
To ensure that desired RCW habitat values are achieved on ACUB properties, land
management must be adaptive; that is, the response of natural systems to
management actions must be monitored and subsequent management actions
modified accordingly. Adaptive management and an ecosystem-based approach to
natural resource management in general are not achievable without monitoring.
The results of monitoring must translate into information that land managers can
use to craft appropriate management responses to changing resource conditions. In
keeping with an adaptive management approach to natural resource management,
management plans for ACUB properties should be updated as often as necessary to
incorporate changes in environmental resources, management practices, regulatory
requirements, or scientific research and advancements (Benning, 2015).
ii. Verifying credits earned
Credits will be proposed and verified for use and accrual via the Tier 2A process
for each individual property and/or conservation area for which credit accrual is
desired. This process will be in the form of a comprehensive report containing all
the necessary information identified in the previous sections, prepared by Fort
Benning and submitted to the USFWS for review. Credits will be released as soon
as the metrics identified above have been met and the Tier 2A request has been
approved. Based on the most recent forest inventory data and any updates as a
result of forest stand improvement actions, an analysis will be completed to
determine the acreages of habitat [future potential (both pine and non-pine
dominated), foraging and nesting habitat], at the stand level, which will be used to
determine Credit calculations. For Credits to be calculated at the future potential
22
habitat rate, a determination shall be made as to whether a given stand is pine or
non-pine dominated. Calculations for foraging and nesting habitat will utilize the
Fort Benning Modified Standard for Managed Stability (FBMSMS) (Benning ,
2016). As such, for Credits to be calculated at the foraging habitat rate, any
individual stand must be at least 30 years of age and the average BA2 of pines >10
in. must be at least 30 ft2/acre. In addition, average BA2 of pines < 10 in dbh must
be less than 20 ft2/acre and hardwood midstory, if present, must be sparse and less
than 7 feet in height. For Credits to be calculated at the nesting habitat rate, a
partition(s) will be delineated and an FHA will be completed. The FHA shall
demonstrate that all RCW partition variables established for the FBMSMS have
been met, to include habitat connectivity standards, in order for the nesting habitat
rate to be defined in terms of Credits. Credits calculated at the fully restored and
occupied habitat rate shall be dependent upon PBG occupancy of a delineated
partition. Stands will be mapped in GIS after UFWS review and distributed to
both parties. Table 1 identifies milestones for credit release. Requests for credit
accrual can occur indefinitely but will be appropriately timed with milestone
achievements for each property and/or conservation area. Re-verification can also
occur to further document conservation lift and population expansion to receive
the full credit for expansions and enhancements, subject to additional Tier 2A
requests.
Table 1: Red-Cockaded Woodpecker Credit Release Schedule for Conservation Milestones
Event or Milestone Credit Release
Administrative: Purchase of
Easement or Property in Fee Title No RCW Credit Earned or Released
Administrative: Approved Habitat
Management Plan No RCW Credit Earned or Released
Administrative: Funded MED,
Stewardship Endowment, or
Sufficient Management Assurance
1st Phased Release:
35% Value/Credit Earned & Released for unforested
or non-pine dominated ACUB Lands
Additional 15% Value/Credit Earned & Released for
pine dominated ACUB Lands
Habitat Milestone 1 Achieved
(Foraging Habitat) 2nd Release: 15% Value/Credit Earned & Released
Habitat Milestone 2 Achieved
(Nesting Habitat) 3rd Release: 15% Value/Credit Earned & Released
Population Expansion Successful
(PBG Established) 3th Release: 20% Value/Credit Earned & Released
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iv. Credit Accounting
The USFWS will maintain a comprehensive and updated record of the
conservation value/credits earned by Fort Benning throughout the implementation
of this process. Since the USFWS review and concurrence of credits earned is a
Tier 2A project review to the Tier 1 PBO, this will aid in both documentation of
the credits and adherence to the PBO in a seamless manner and provide a single
point of accounting.
5. Debit Quantification, Verification, and Accounting
i. Quantifying debits
The qualifying ACUB properties provide substantial conservation benefits to Fort
Benning RCW, expressed in this consultation as RCW Conservation Values. It is
unlikely but not inconceivable that any single consultation would exhaust
available Conservation Values. When RCW Conservation Values are proposed
for use in consultation, Fort Benning will evaluate the effects of the action no
differently than any other consultation. Effects will be evaluated and summarized
to determine the amount and extent of “take” that is expected. Some PBG’s will
be removed completely due to construction projects and or other installations
activities where the ecosystem is impacted to the point that RCW can no longer
persist in that area. These are the simplest as it will be directly correlated to an
off-Post earned PBG to serve as the offset. As it relates to these types of complete
removal “take,” the cumulative effects of all actions shall not result in less than
250 occupied PBG’s associated with the Fort Benning Primary Core Recovery
Population on- and off-Post, at any given point in time. A population size of 250
potential breeding groups is sufficient to withstand extinction threats from
environmental uncertainty, demographic uncertainty, and inbreeding depression
(USFWS, 2003a).
There are also RCW “takes” that are calculated and modeled that do not degrade
the ecosystem to the point that RCW do not continue to persist. The easiest
example is the calculated reduction of foraging habitat that results in “take”;
however, in high quality habitat it is well documented that even at below USFWS
recovery standard foraging habitat guidelines, RCWs often persist on the
landscape relatively unaffected and therefore are not truly “taken”. In this instance
the taken PBG will be offset with an off-Post PBG as in the permanent take
scenario, however that take will in essence be held in escrow for a period of not
less than 1 but no more than 3 years, as determined based on Tier 2 Consultation.
The on-Post “take” will then be monitored and if that PBG persists for the period
of years identified in the Tier 2 Consultation then it will no longer be considered
taken and the escrowed PBG will be returned to the overall balance of available
PBG’s for use as mitigation.
Generation of the conservation value will be presented in a Tier 2A project review
documenting the appropriate value earned, and offset use will then be requested in
a Tier 2B debiting project submitted to the USFWS for review both pursuant to
24
the Tier 1 PBO. Conservation value generation and use may be completed in a
single document with clear accounting of both as described in this document.
iii. Debit accounting
The USFWS will maintain a comprehensive and updated record of the debits
(take) generated by Fort Benning throughout the implementation of this process.
Since the USFWS review and concurrence of a credit offset of debits is a Tier 2B
project review to the Tier 1 PBO, this will aid in both documentation of the debits
and adherence to the PBO in a seamless manner, and provide a single point of
accounting.
5) Credit Stacking
The ecosystems being protected and managed are known to and will support multiple
proposed, candidate, and/or federally listed species overlapping to varying extents.
During the credit calculations each species will be accounted for separately first as a
standalone analysis for that individual species. Species overlap will then be determined
utilizing mapping techniques to determine individual and “stacked” credit acres available.
For each conservation area there may be multiple combinations of individual and stacked
credits depending on species status and extent. Individual species credit acres will be
correlated to individual species debit acres as previously described in the fore mentioned
sections. Stacked credits can also be correlated to stacked debits as long as the extent and
analysis of each species in the stacked credit aligns with the debit. Another option is to
decouple or unstack, “stacked credits” for use to offset debits of an individual species. In
this event the other species contained in the stacked credit will no longer to be able to be
used for compensatory mitigation. This alleviates the potential for double dipping and or
double counting of the same credit acre more than once. In all cases where stacked credits
and debits are generated or used, additional due diligence and scrutiny in accounting is
necessary to preserve an accurate balance.
6) Credit Accounting with Multiple Investors
Conservation value for RCW mitigation may only be accrued for that portion of the
ecological lift underwritten by investments of Fort Benning and their partners whose
funding sources allow use of their funds for mitigation by Fort Benning. Fort Benning
will coordinate with any partners on the use of their funding towards mitigation to be
used by Fort Benning. A letter of intent and action will be completed by each partner
documenting the full transfer of all conservation value/credit generated by their
actions/investments will be assigned to Fort Benning for use as compensatory mitigation.
To prevent “augmentation of appropriations” none of the USFWS grants under ESA
Section 6 may be used for mitigation. However, other federal funds may be used as long
as they meet the intent of the following. A federal agency may not augment its
appropriation from, or transfer funds to, sources external to the appropriation per se
without specific statutory authority. The rule against augmentation is derived primarily
from the “purpose statute” and the “miscellaneous receipts statute.” Where appropriated
funds may be used only for their intended purposes (31 U.S.C.1301 (d)). The objective of
the rule is to prevent a Federal agency from undercutting the Congressional power of the
purse by circuitously exceeding the amount that Congress has appropriated for a specific
25
activity. Any comingling of federal funds on properties or projects will need to be
evaluated individually based on their root statutory authority and appropriation.
Portioning of ecological lift and the associated conservation value/credit generated
according to financial contributions avoids the difficulty of determining the actual
ecological lift attributable to each funding source, action, and acquisition. Because there
are so many sources of funding for conservation, and these funds have been intermingled
and the conservation actions distributed within and between multiple sites for multiple
years, Fort Benning and partner’s proportion of the total funds expended on a given site
will be used as a surrogate for ecological lift. As legally permitted, in some scenarios a
partner may choose to defer or transfer all or a portion of the ecological lift, and the
associated value/credit attributed to their contribution, to Fort Benning for use in
consultations.
A sample calculation for these type actions/accounting could be as follows:
1) 3,500 Acre Fee Simple Acquisition: $5,000,000 Fort Benning + $1,000,000
ACUB Partner + $1,000,000 USFWS Section 6 Grant = $7,000,000 total.
2) Long Term Management of 3,500 Acres = $1,000,000 Fort Benning total.
3) Proportion Assigned to Fort Benning = $6,000,000/$8,000,000 = 0.75 (75%)
4) Total Credits = 3,500 acres Fort Benning Assigned Credits = 0.75 x 3,500 =
2,625.0 acres
3 Description of the Action Area
ACTION AREAS
1) On-Post Action Area
The action area “on” Fort Benning is defined by the geographic boundaries of known
suitable and/or occupied RCW PBG’s in which military training, construction,
operations, maintenance, and recreation is identified to occur that may affect the RCW.
For the purposes of this BA, we include and analyze habitat occurring on Fort Benning.
However, the individual RCW PBG’s actually affected will be identified and further
evaluated in the tiered site- or project-specific consultations pursuant to the issuance of a
programmatic biological opinion.
2) Off-Post Action Area
The action area “off” Fort Benning is defined by the fullest geographic extent with the
potential for RCW’s which contribute to the Fort Benning Primary Recovery Population.
This includes all known and potential sites suitable now and in the future for the RCW in
relation to habitat, natural population expansion, and reintroduction, inside the Fort
Benning approved ACUB PA boundaries. . The individual conservation areas actually
affected will be identified and further evaluated in tiered site- or project-specific
consultations pursuant to the issuance of a programmatic biological opinion.
26
4 Status of the Species in the Action Area
STATUS OF THE SPECIES AND CRITICAL HABITAT
This section is derived from information, ideas and text presented in Fort Benning’s Integrated
Natural Resource Management Plan (2018), the RCW Recovery Plan (USFWS 2003), RCW
management guidelines (U.S. Army, 2007), and prior biological opinions (USFWS 2007, 2009).
1) Species Life History
a. Description and Distribution
The RCW is a small woodpecker, measuring about 7 inches in length, with a
wingspan of about 15 inches, and weighing about 1.7 ounces (47 grams; USFWS
2016). Its back is barred with black and white horizontal stripes, and is
distinguished from other woodpeckers by a black cap and nape that encircle large
white cheek patches. Adult males possess a tiny red streak or tuft of feathers, the
cockade, in the black cap near each ear and white cheek patch. The small
cockade usually is covered by the black crown, except when protruded during
excitement, and is not readily visible except upon close examination or capture.
Adult males and females are not readily distinguishable in the field. Juvenile
males have a red crown patch until the first molt, which can be distinguished from
the black crown of juvenile females (USFWS 2016).
The RCW occurs primarily in pine and pine-hardwood forests of the piedmont
and coastal plain of 11 southern/southeastern states, including Alabama,
Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma,
South Carolina, Texas, and Virginia (Barron et al. 2015).
b. Habitat Requirements
The RCW occurs in pine or mixed pine-hardwood forests primarily in the
Piedmont and Coastal Plain of the southeastern United States (Barron et al. 2015).
Forests inhabited by the RCW are fire dependent and have been shaped by
intentional burns set by humans and naturally occurring wildfires. Without fire,
dense understory and midstory vegetation negatively affects establishment of
young pine trees (Stoddard 1962).
The RCW is habitat-specific, needing pine forests for both breeding and foraging.
For nesting and roosting, it requires living mature pine trees. Usually, the trees
chosen for cavity excavation are infected with a heartwood decaying fungus
(Phellinus pini) (Jackson 1977; Conner and Locke 1982). The heartwood
associated with this fungus and typically required for natural cavity excavation is
not generally present in longleaf pine and loblolly pine (Pinus taeda) until 90 to
100 and 75 to 90 years of age, respectively (Clark 1992a; Clark 1992b). Large
trees also are commonly required because RCW construct and place the cavity
entirely within heartwood where pine resin will not flow. Cavity trees are
typically found in groups of 2-10 trees. The RCW prefers areas with an open
understory and may abandon a cavity tree if the midstory approaches cavity
height (Hopkins and Lynn 1971; Van Balen and Doerr 1978; USFS 1979; Locke
et al. 1983; Conner and Rudolph 1989). On Fort Benning, RCWs are found
27
predominantly in loblolly pines. Approximately 63% of natural cavity trees are
loblolly, 32% are longleaf and 5% are shortleaf (P. echinata).
Table 2: Fort Benning RCW Cavity Trees with > 1 Suitable Cavity - 2017
For foraging, RCW require large old pines, low densities of small and medium
pines, sparse or no hardwood midstory, and a bunchgrass and forb groundcover.
A study conducted in the Apalachicola National Forest suggested that understory
characteristics or fire history might be more important than the number or size of
pine trees as a measure of RCW foraging habitat quality (James et al. 1997). This
study found that group size (number of adults), number of eggs laid, and the
number of RCW groups within a 1-mile radius of sample groups all increased
significantly (p = 0.05) with respect to increasing percentage of wiregrass in the
groundcover. The number of adults also increased significantly (p = 0.05) with
respect to increasing occurrence of pine regeneration in the stand, and decreased
significantly (p = 0.05) with respect to the percent gallberry in the groundcover.
Number of adults, eggs, fledglings, and groups all decreased as tree density
increased, but correlations were not significant. They hypothesized that frequent
burning, which increases wiregrass and longleaf regeneration and reduces
gallberry density, may play a role in the cycling of nutrients such as calcium.
Calcium limitation has been shown to limit clutch size in songbirds (Graveland
and Van Gijzen 1994).
Both habitat selection and group fitness are influenced by the structure of the
foraging habitat. Important structural characteristics include (1) a substantial
presence of mature and old pines, (2) minimal hardwood midstory, (3) minimal
pine midstory, (4) minimal or absent hardwood overstory, (5) a low to
intermediate density of small and medium sized pines, and (6) healthy
groundcovers of bunchgrasses and forbs. Thus, the quality of foraging habitat is
defined by habitat structure. Although geographic variation in habitat types exist,
these structural characteristics of good quality habitat remain true for all
geographic regions and habitat types. Previous guidelines stressed quantity of
foraging habitat, as defined by number of medium and large trees (USFWS 2003;
Barron et al. 2015).
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c. Life History/Ecology
The RCW is a territorial, non-migratory, cooperative breeding species (Lennartz
et al. 1987; Walters et al. 1988), and the only North American woodpecker that
exclusively excavates its cavities for roosting and nesting in living pines. Each
group member has its own cavity, although there may be multiple cavities in a
cavity tree. RCW chip bark and maintain resin wells on the bole around the
cavity where the fresh flow of sticky resin is a deterrent against predatory snakes
(Rudolph et al. 1990) and indicates an active cavity tree. The aggregate of cavity
trees, surrounded by a 200-foot, forested buffer, is called a cluster (Walters 1990).
Cavities within a cluster may be complete or under construction (starts) and either
active, inactive or abandoned. Clusters with one or more active cavity tree are
considered as active RCW clusters.
The RCW live in social units called groups. This cooperative unit consists of a
single male or a monogamous breeding pair, offspring of the current year, and 0–
4 adult helpers (Walters 1990). Helpers typically are male offspring from
previous breeding seasons that assist the breeding pair by incubating eggs, feeding
the young, excavating cavities, and defending the territory (Ligon 1970, Lennartz
et al. 1987, Walters et al. 1988). Some large populations have instances, although
very infrequent, of female helpers (Walters 1990; DeLotelle and Epting 1992;
Bowman et al. 1998). Clusters only occupied by a single adult male are classified
as single bird groups, while an adult male and female with or without helpers
occupying the same cluster is classified as a potential breeding group (PBG).
The RCW is territorial and each group defends its home range from adjacent
groups (Hooper et al. 1982; Lignon 1970). The defended territory includes
habitat used for cavity trees and foraging. RCW feed mostly on variety of
arthropods, particularly ants and wood roaches, by foraging predominately on and
under the bark of larger and older living pines (Hooper 1996; Hanula and
Franzreb 1998). Males tend to forage in crowns and branches, while females
commonly forage on the trunk. Dead and dying pines are important temporary
sources of prey, and hardwoods are used occasionally. Group members forage
together each day in parts of their territory.
RCW have large home ranges relative to their body size. RCW tend to forage
within 0.5 miles of their cluster. RCW groups forage within a home range that is
highly variable, from as little as 86 acres to as much as 556 acres (Conner et al.
2001; USFWS 2003). Home range size is variable within and between
populations, but tends to reflect foraging habitat quantity and quality, boundaries
of adjacent RCW territories, and possibly cavity tree resource availability (Conner
et al. 2001; USFWS 2003).
Because of the foraging behavior of RCW, a 0.5-mile radius is used to establish
survey areas to identify any unknown RCW clusters that may be affected prior to
clearing or removing any potential RCW habitat. The 0.5-mile survey area
provides a high probability that any unknown clusters will be identified that
potentially use habitat within the area to be affected. This is based on RCW
29
foraging ecology and behavior, the limitations of natural cavities to population
growth at Fort Benning, the ecology of RCW population growth via the formation
of new clusters/groups, and relationship of habitat used for foraging within 0.5
miles of a cluster center.
A 0.5-mile radius circle around a cluster center encompassed an average of 91%
of the actual home ranges of RCW groups in a North Carolina study (Convery and
Walters 2003). Thus, unknown Fort Benning clusters identified by surveys within
0.5 miles of the edge of clearing or construction likely will have the vast majority
of their foraging habitat somewhere within this 0.5 mile area.
d. Population Dynamics
The RCW is long-lived, with individuals frequently living up to 10 years or
longer. For a bird of its size residing in temperate regions, the RCW exhibits
exceptionally high survival rates. Survival rates of adult male helpers and
breeders generally are about 5 percent higher than that of breeding females.
There is distinct geographic variation in survival; survival rates are about 75
percent for males and 70 percent for females in the northern, inland population in
the North Carolina Sandhills, about 80 percent and 75 percent respectively in
coastal populations in North Carolina, and 86 percent and 80 percent respectively
in central Florida. Such an association between increased survival and reduced
fecundity is common in animal life histories. Annual variation in adult survival
within populations is sufficiently small that it can largely be attributed to random
chance rather than changes in environmental conditions (Walters et al. 1988).
This level of variation can have large effects in small populations, however, and it
appears that there are occasional poor years in which survival is substantially
reduced. Also, some populations are vulnerable to periodic catastrophic mortality
due to hurricanes. With survival rates as high as these, it comes as no surprise
that some individuals live to old ages. A captive female lived to 17 years (J.
Jackson, pers. comm.), and a male in the North Carolina Sandhills lived to 16
years of age in the wild (J. Carter III, pers. comm.).
Survival during the first year is more prone to underestimation than survival at
subsequent ages, due to the greater possibility of dispersal out of the sampling
area. Nevertheless, it is quite clear that survival rates are much lower during the
first year than thereafter. Overall the mortality pattern is fairly typical of
cooperatively breeding avian species. It is characterized by relatively low
survival during the first year, especially of dispersers; relatively high survival of
breeders and helpers; and senescence at the end of the life span. Compared to
non-cooperative species, survival of both juveniles and adults is high, and the life
span is long.
Pairs are highly monogamous, and about 90 percent of PBGs nest each year
during the April to July nesting season. Females usually lay 3 or 4 eggs in the
cavity of the adult male. The short incubation period lasts approximately 10 days,
and eggs hatch asynchronously. Normally, one brood is produced as a result of
30
one or perhaps two nesting attempts involving only two parents. Most groups that
attempt nesting fledge young, as nest failure rates are low for a species in the
temperate zone, although fairly typical for a primary cavity nester (Martin and Li
1992, Martin 1995). Nestlings fledge after 24 to 29 days, although all nestlings
rarely survive to fledglings. Partial brood loss of nestlings is common in RCW,
although number of hatchlings successfully fledged tends to increase with group
size. Also, older and more experienced breeders have greater reproductive
success (number of fledglings), which is maximized at about 7 years of age, after
which it declines sharply at 9 or greater years of age (Reed and Walters 1996).
About 20 percent of nests will fail completely, without producing a single
fledgling. Groups with helpers experience whole brood loss less frequently than
breeding groups without helpers. Renesting rates are geographically and annually
variable. In good years, up to 30 percent of breeding groups will renest.
Productivity of the second nesting is lower. Nest predation, nest desertion, and
loss of nest cavities to cavity kleptoparasites appear to be the primary causes of
nest failure. Failure rate is higher during the egg stage than during the nestling
stage, which suggests that nest desertion, rather than nest predation or loss of
cavities to kleptoparasites, is the major cause of failure (Ricklefs 1969). The
relative frequencies of these three causes of nest loss have never been measured
directly, however. Nest predation rates may be lower than in other cavity nesters
because of the protection provided by the resin barrier around the cavity, which
clearly interferes with climbing by snakes (Rudolph et al. 1990).
Subadult/juvenile females from the current year breeding season normally
disperse prior to the next breeding season, or are driven from the group's territory
by the group (see Walters et al. 1988, for additional sociobiological/cooperative
breeding information). Juvenile females remain at their natal territory to assume
the breeding vacancy of the female only when the breeding male dies and the
breeding female disperses or dies. Breeding females will disperse, creating a
breeding vacancy, when her male offspring inherit the male breeding position
(incest avoidance). Dispersing juvenile females move to nearby RCW territories
in search of a breeding vacancy. These females either become breeders in a
territory, or floaters among more than one territory where they are not associated
with a single group.
Juvenile males remain in their natal territory or disperse. Those that remain
become helpers or, if the breeding male dies before the next breeding season,
breeders. Dispersing juvenile males search for positions as breeders in nearby
territories where they either become breeders, helpers, or floaters. Most adult
male helpers remain on their natal territory as helpers, where about 15 percent
will inherit the territory as a breeding male in any given year. Some adult helpers
disperse to other territories becoming breeders, solitary males, helpers, or floaters.
However, breeding males are highly territorial and most will remain even without
a breeding female. In contrast, about 10 percent of breeding females will break
the pair-bond between breeding seasons and disperse to another territory as a
breeder with a different male (Walters 1988; Daniels and Walters 2000).
31
New groups on new territories arise by two processes, pioneering and budding
(Hooper 1983). Pioneering is the occupation of vacant habitat by construction of
a new cavity tree cluster, which is expected to be rare. Budding is the splitting of
a territory, and the cavity tree cluster within it, into two. Budding is common in
many other cooperative breeders, and might be expected to be more common than
pioneering in RCW, since the new territory contains cavities from the outset. The
available data indicate that budding indeed is more common than pioneering, and
that pioneering is quite rare.
2) Status of the Fort Benning Population
Fort Benning Natural Resources Management Branch personnel have surveyed all
accessible areas of the Installation, including the A20 dudded impact area. As of 2016,
there were 389 active RCW clusters on Fort Benning and 373 Potential Breeding Groups
(PBGs). Sixty-six of the active clusters are located in the A20 dudded impact area,
although only 50 can be counted (USFWS 2009). Three of the clusters on the edge of the
A20 impact area were added to the managed clusters to offset impacts from live fire
ranges elsewhere on the Installation. An additional 11 clusters in A20 were managed as a
result of the DMPRC BO (USFWS 2004) and 36 clusters in A20 were managed as a
result of the MCoE BO (USFWS 2009).
Incidental take authorizations were issued for 101 clusters located outside of the dudded
impact areas due to the DMPRC, BRAC, MCoE, ET, and M06 BOs. Five of those
clusters, which were no longer active, were permanently deleted from management
through informal consultation with USFWS, resulting in 96 clusters with incidental take
coverage (101-5= 96). The Enhanced Training BO resulted in revising take status on a
number of clusters on Fort Benning and reduced take authorizations to a total of 65
clusters (Pending ESMC update and USFWS approval in 2017), although all of those
clusters still persist on the landscape and are being actively managed.
When considering A20 PBGs > 50 and the 65 taken clusters, which cannot be counted
towards recovery even though they still persist, at present there are 303 PBGs (373-65-5)
on Fort Benning that currently count towards recovery (Pending ESMC update and
USFWS approval in 2017).
The Fort Benning RCW population has demonstrated significant growth over the past 20
years (Figure 3). However, there are currently no active clusters known to exist on
private lands in close proximity to Fort Benning. For years now, Fort Benning and
USFWS have been concerned about a potential bottleneck in available RCW foraging
habitat related to forest health that could occur if loblolly pine mortality exceeds
replacement rates by either loblolly or longleaf pine (Benning, 2015)
3) Critical habitat has not been and is not expected to be designated for the RCW. The RCW
Recovery Plan clearly identifies the populations and geographic locations needed to
support and recover the RCW therefore critical habitat designation would appear
redundant. Therefore currently and throughout the life of this programmatic consultation
adverse modification of critical habitat is not anticipated to occur.
32
Figure 3: Fort Benning RCW Active Clusters and PBG’s 1997-2016
5 Environmental Baseline
ENVIRONMENTAL BASELINE
Regulations implementing the ESA (50 CFR 402.02) define the environmental baseline as the
past and present impacts of all federal, state, or private actions and other human activities in the
action area. Also included in the environmental baseline are the anticipated impacts of all
proposed federal projects in the action area that have undergone Section 7 Consultation, and the
impacts of state and private actions which are contemporaneous with the consultation in
progress. The status of the species section and the consultations referenced in the consultation
history section above, contain very detailed descriptions of the environmental baseline for RCW.
These are hereby incorporated by reference to reduce document volume, as there have been no
material changes between then and the time of developing this Biological Assessment.
The management objective for the Fort Benning RCW Conservation and Crediting Program
requires that qualifying Fort Benning ACUB properties establish habitat suitable for RCW
occupancy and ultimately the establishment of PBGs. At this time, however, although the
ACUB landscape is being managed to restore suitable RCW habitat, additional time will be
required before some of those lands are capable of supporting PBGs. It is likely that Section 7
Consultations involving the use of this Programmatic Biological Assessment will occur prior to
the establishment of PBGs on ACUB properties. Accordingly, establishment of this ACUB
program will be recognized as a “beneficial action” (in the context of a net benefit to RCW
0
50
100
150
200
250
300
350
400
450
Fort Benning Red-Cockaded Woodpecker Active Clusters & Potential Breeding Groups 1997 - 2016
All Manageable Active Clusters
All Manageable PBGs
PBGs (less Take and A20 >50)Counted Toward Recovery
33
recovery) taken by Fort Benning prior to consultation, and the habitat values occurring on ACUB
properties at the time of such consultations (including any functions and values actually provided
to and utilized by RCW at that time) will be included within the environmental baseline for such
consultations. Fort Benning, in conjunction with USFWS and the State, will identify the
anticipated future habitat values that are expected to support future PBGs (expressed as RCW
Conservation Values). These Conservation Values will be utilized as offsetting mitigation.
They will thus be assessed in the effects analysis as an associated effect of the proposed action
under consultation. As described above, any real-time conservation benefits provided by
qualifying ACUB properties to RCW will be identified and described in the environmental
baseline for the consultation.
6 Effects of the Action
EFFECTS
1) Factors Considered
The effects of the action refer to the direct and indirect effects on the species or critical
habitat, together with the effects of other activities that are interrelated or interdependent
with that action, that will be added to the environmental baseline (50 C.F.R. § 402.02).
Direct effects are caused by the action and occur at the same time and place, while
indirect effects are caused by the proposed action at a later point in time and are
reasonably expected to occur. In analyzing the effects of the action, USFWS “will give
appropriate consideration to any beneficial actions taken by the Federal agency, including
any actions taken prior to the initiation of consultation” 50 C.F.R. § 402.14(g) (8).
The RCW is currently the only federal listed species addressed in this consultation and is
the only species being evaluated for direct or indirect effects from the action under formal
consultation at this time. During implementation of actions pursuant to this action, if it
becomes evident that the action may affect other federally listed, proposed, or candidate
species; such effects will be site specific, and will be addressed through subsequent Tier
2 or independent conferences/consultations. Activities conducted on- or off-Post of Fort
Benning outside of acreages which could be considered RCW habitat will have no effect
on the RCW. Within acreage considered as habitat for the RCW, activities that occur in
unoccupied or unsuitable habitat will not adversely affect the RCW and therefore do not
require the implementation of any conservation measures. However, protection and
management of unoccupied and currently unsuitable habitat within those acreages which
could be considered habitat for the RCW is the main factor considered to provide
beneficial effects as an offset to adverse effects on Fort Benning.
2) Analyses for the Effects of the Action
To determine the effects of this action, Fort Benning must compare the predicted
difference in conditions relevant to the RCW between the future with and the future
without the action. The action is a programmatic compensatory mitigation framework
that contributes to the conservation of the RCW by encouraging the performance of
proactive conservation actions off-Post to help increase the species throughout the Ft
Benning recovery population range, while preserving Ft Benning mission capabilities and
providing Ft Benning regulatory certainty for their actions under the ESA. The mitigation
34
framework establishes a process for targeting conservation investments on non-military
lands to establish “conservation value/credits” that will provide for regulatory offsets for
impacts to the RCW for current or future installation activities - yet to be fully defined -
that may affect the species. Accordingly, site-specific activities are unable to be
addressed herein. Therefore, we cannot evaluate the effects of the action using site-
specific data. Instead, we evaluate the effects of the action for implementation of the
mitigation framework as a whole and programmatically. Because the mitigation
framework requires that transactions result in a conservation offset to the species, the
action is likely to expand suitable habitat conditions and populations of the RCW,
resulting in expanded benefits to the Fort Benning recovery population as a whole.
Effects to Gopher Tortoise (Gopherus polyphemus)(GT) in relation to conservation area
development and conservation offsets have already been evaluated in the Tier 1
Framework Programmatic Conference Opinion for the Department of Defense Gopher
Tortoise Conservation & Crediting Strategy, 07 November 2017. If presence of GT on
ACUB lands is identified and acquired under this RCW Conservation Program, Fort
Benning will follow the Tier 2 Conference process identified in the above Tier 1 GT
Conference Opinion for the establishment and management of is as a GT conservation
area as well.
Other federally listed species (Endangered, Threatened, Candidate, or Proposed) may
become known or may be come present on individual ACUB properties throughout time.
This assessment does not evaluate effects of off-Post management actions on those
species as there is no way to predict their presence until property specific information is
evaluated as part of the acquisition process. Therefore, effects to other federally listed
species will occur as part of the Tier 2 Formal Consultation process.
The previously discussed Fort Benning Section 7 Consultations contain a wealth of
information identifying and analyzing the effects for both military training and land
management activities that are hereby incorporated by reference. Given the extensive
discussion in these referenced consultations, the effects sections of this PBA are limited
to effects specific to this action that are not covered in the reference consultations.
1. Beneficial Effects
The mitigation framework will be accomplished through a variety of means,
including the acquisition and dedication of appropriate lands to RCW conservation
and management in perpetuity. This may also include the establishment of
conservation management regimes on lands that previously have been secured by Fort
Benning through conservation easements or other similar mechanisms, which have
not yet been accounted for or included in the conservation baseline of Fort Benning.
It could also include Fort Benning providing funding or other support for
conservation actions on lands owned by third parties, including private, state or
federal land managers. Through land acquisition and management, the action will
conserve and restore important RCW habitat and ultimately populations on lands not
currently under permanent conservation management for this species. Conservation
actions will be focused on places where the best opportunities exist to enhance the
35
Fort Benning RCW recovery population’s conservation through representation,
resiliency, and redundancy, based on the best available science, including an analysis
of existing populations, locations, and habitat conditions. Retaining representation,
resiliency, and redundancy for these species means multiple populations across the
species’ ecological niches and geographic ranges, with the Fort Benning population
being key. Self-sustaining populations distributed across large areas are generally less
vulnerable to extinction compared to small and/or isolated populations. Well-
distributed populations conserved across the available geographic and ecological
gradients make species more resilient in the face of catastrophes or environmental
change. Therefore, expanding the footprint available to establish conservation areas
will be beneficial to the RCW population as a whole. Conservation areas will
establish population strongholds for expansion and interactions of the species in the
areas of greatest conservation benefit to the species. These areas will create
conservation uplift for the RCW, and afford increased resiliency for potential impacts
from stochastic events and/or forest health issues which may occur on- or off-Post.
Active long-term management with frequent prescribed fire, silvicultural and other
measures is required to develop, maintain, and enhance RCW habitat. Otherwise, as
part of natural succession, the habitat degraded by understory overgrowth, loss of
foraging habitat, increased disease susceptibility leading to fragmentation and loss of
function of the Long Leaf Pine and native bunch grass ecosystems the RCW depends
on. Development of habitat management plans which include monitoring and
adaptive management for each conservation area ensures the increase and persistence
of suitable habitat conditions for the RCW.
2. Adverse Effects – Direct
Direct effects from implementing the mitigation framework include any effects that
occur from substituting RCW conservation value/credits for incidental take on Fort
Benning, and the management of these species on off-Post lands. There is potential
for disturbance and possible mortality occurring from natural resource management
actions both on Ft Benning, and off-Post on conservation areas. Although the
management activities seek to improve habitat conditions overall for the RCW, there
could be harm or other take during land clearing with heavy mechanized equipment,
burning, and other habitat management activities. These events are most likely to
occur when: (1) a wildfire or prescribed fire burns too fast and/or hot during a critical
season; or (2) a heavy equipment operator unintentionally and unknowingly gets too
close to or damages a cavity tree. Management of off-Post lands that may affect these
species will be avoided and/or minimized by the generation of property and/or
conservation area specific management plans approved during the Tier 2 project
review process. These plans are required to contain the elements prescribed in
previous sections. The conservation management actions required in these plans are
the same as on-Post management actions identified in the Fort Benning Integrated
Natural Resource management Plan (INRMP). Therefore, these adverse effects will
eventually transition to beneficial effects through improved habitat conditions,
increased foraging opportunities, and establishment of new populations that will be
managed in perpetuity.
36
3. Adverse Effects – Indirect
Activities performed on military installations contain a variety of actions with the
potential to negatively affect RCW, and the potential to result in the incidental take of
these species. Indirect effects from implementing the conservation program are any
effects to the species that may occur on Fort Benning. These effects at the
installation-level (to the species and/or their habitat) can be both beneficial and
adverse. For example, indirect beneficial effects can occur as a by-product from
training (such as when an accidental fire burns through habitat on a range and
maintains open canopies necessary for habitat diversity); additionally, continued
implementation of the INRMP provides for the conservation of RCW populations on
the Installation. Some adverse effects may be minimal, although temporary or long-
term effects could also occur.
Installation activities could include (but are not limited to) vehicle maneuvering
(tracked and wheeled), artillery firing, bivouacking, range construction, and facility
construction, causing indirect environmental impacts such as ground disturbance or
compaction, creation of impervious surfaces, vegetation removal, human disturbance,
noise, vibrations, and smoke/obscurants. These activities could result in injury,
mortality, disturbance, and habitat alteration. Alteration of unoccupied future
potential habitat which degrades or eliminates habitat may preclude the use of those
sites. These effects may result in fragmentation of RCW habitat and breeding groups.
Installation activities may indirectly affect mating, cavity construction, feeding,
natural movements, and gene flow within the population. Separation of group
members, alterations in daily movements or effects on group dynamics or individual
behavior may occur which could lead to decreased reproduction, decreased viability,
increased mortality, or mass dispersal of the group.
The effects of habitat fragmentation, reproductive isolation, and barriers to RCW
movement resulting from construction and operation of certain facilities may extend
effects further away from the affected area to include all RCW found within the group
directly affected by the proposed activities. For construction projects, adverse effects
to RCW may occur in association with both the construction and operation phases of
new facilities.
Operations and maintenance may adversely affect RCW, directly or indirectly.
Invasive species may increase along project corridors as a result of soil disturbance
and other related activities that modify RCW habitat.
Finally, there is also potential for RCW disturbance due to contact with smoke and
obscurants from military training or forest management activities. It is important to
note that some of the adverse effects of land management activities discussed above
will only occur for a short period of time (i.e. land clearing, prescribed burning,
invasive species removal, etc.). These adverse effects will eventually transition to
beneficial effects through improved habitat conditions, increased foraging
opportunities, etc… The establishment of RCW conservation areas and the
37
implementation of the mitigation framework is designed to offset any residual
adverse effects that occur to RCW on the Installation, so that the species population
benefits as a whole.
3) Species’ Response to the Action
Each project under the mitigation framework uses conservation value credits as an offset
to adverse effects; therefore, the action is expected to benefit the Fort Benning RCW
recovery population as a whole and systematically expand and enhance their population
status under the ESA.
4) Modification of Critical Habitat
Critical habitat has not been and is not expected to be designated for the RCW. The RCW
Recovery Plan clearly identifies the populations and geographic locations needed to
support and recover the RCW therefore critical habitat designation would appear
redundant. Therefore currently and throughout the life of this Programmatic Consultation
adverse modification of critical habitat will not occur.
5) Cumulative Effects
Cumulative effects include the effects of future state, tribal, local, or private actions that
are reasonably certain to occur in the action area. Future federal actions that are unrelated
to the proposed action are not considered in this section because they require separate
consultation pursuant to Section 7 of the ESA.
The USFWS is working closely with state and local governments and with non-
governmental organizations to plan and implement programs for more effective
protection and conservation of longleaf pine ecosystems and longleaf pine dependent
species. Research institutions, non-governmental organizations, and state and local
governments are all serving important planning, monitoring, and research functions.
These parties are both independently and cooperatively advancing the basic science and
practical knowledge necessary to achieve habitat enhancement and landscape-scale
conservation. These parties are also assisting with permitting functions, public outreach,
and education.
We expect that future state, tribal, local, and private actions will help to make significant
progress in accomplishing objectives that are important to the local and range-wide
conservation of the RCW. These efforts are critical components of the shared local, state,
and federal strategy, implemented primarily via the Fort Benning ACUB and newly
designated Sentinel Landscape program, to address existing and future threats, and
thereby achieve long-term persistence and recovery of the RCW.
The Fort Benning mitigation concept establishes the framework for evaluating and
determining conservation value/credit for Fort Benning’s conservation actions off-Post
for the RCW, furthering the programs described above. The mitigation framework does
not itself direct or authorize any particular conservation action, but rather establishes the
process within which the conservation value of such actions will be evaluated, and the
manner by which conservation value/credits will be generated for use by Fort Benning.
38
The mitigation framework is intended to significantly advance conservation of the RCW
at a scale that will address those conservation priorities necessary to provide regulatory
certainty to Fort Benning mission in regards to the RCW. In addition to the principal
objectives of the mitigation framework, this action promotes the viable expansion of the
Fort Benning Primary Core Recovery Population of RCW through increased habitat
connectivity and suitability off-Post, through strategically placed and managed areas of
sufficient habitat quality and size in perpetuity. Therefore, the existence of a proactive conservation program like this in the region, should encourage other non-federal entities to participate or engage in similar supporting activities within the area as well.
7 Conclusion & Determination of Effects
CONCLUSION AND DETERMINATION OF EFFECTS
This action is intended to achieve a conservation offset enhancing the status of the RCW, while
providing regulatory certainty to Fort Benning regarding RCW off-Post conservation actions.
This action falls within the definition and prohibition of harm, harassment, wounding, killing,
and habitat destruction under Section 9 of the ESA. The harmful activity considered in this
Biological Assessment shall be incidental take from military training and enhancement, offset by
in perpetuity preservation and management of the RCW and its habitat on public and private
lands. The framework will be accomplished through a variety of means, including the acquisition
and dedication of appropriate lands to RCW conservation and management. This may also
include the establishment of conservation management regimes on lands that will be secured by
Fort Benning through conservation easements or other similar mechanisms, which have not
heretofore been accounted for or included in the conservation baseline of the Fort Benning
Primary Core Recovery Population. Preservation and management on these lands will be
guaranteed in-perpetuity because they will contain conservation easements or fee-simple
purchase of real property interests containing deed restrictions (that will transfer to new owners
in the case of property sales) and sufficient funding or management assurance to ensure long-
term protection and management occur.
The mitigation framework enhances the capacity to implement conservation activities that
support viable populations of the RCW. The proposed action directly addresses impacts on Fort
Benning and conservation actions within the action area, which results in a conservation offset
supporting recovery for the RCW from its current status under the ESA compared to the future
without this action. The practices proposed to enhance and restore the RCW habitats and
populations may also result in harm, harassment, wounding, or killing of the species, but the
identified conservation measure of developing a mutually-approved land management plan for
each conservation area will limit the amount and extent of this effect to be localized and short-
term.
Critical Habitat is not currently and is not expected to be designated for the RCW throughout the
life of this consultation. However, by definition, all actions proposed in this assessment will not
adversely modify or destroy any critical habitat if designated in the future. Land management
activities on conservation areas only occur with the explicit intent of enhancing the habitat and
ecological function of the off-Post conservation areas.
39
In summary, the principal objective of this action is to promote the viable expansion of the Fort
Benning Primary Core Recovery Population of RCW through increased habitat connectivity and
suitability off-Post, through strategically placed and managed areas of sufficient habitat quality
and size in perpetuity. Any adverse effects of the action then become or are completely
substituted with beneficial effects as a keystone principle.
The Army determines that individual activities identified in this Programmatic Biological
Assessment “may adversely affect” the RCW both on Fort Benning and on RCW Conservation
Areas once RCW become present on them.
The Army also recognizes that the implementation of the proposed action as a whole results in
enhanced conservation for the RCW in direct support of the recovery of the species within the Ft
Benning Primary Core Recovery Population through off-Post conservation.
40
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R.C., W. McDearman, and S. Lauerman. 2012. Final draft guidelines for establishment
of demographic conservation areas for red-cockaded woodpeckers on lands surrounding
army installations: a joint Army/U.S. Fish and Wildlife Service agreement.
Bowman, R., D.L. Leonard Jr., L.K. Backus, P.M. Barber, A.R. Mains, L.M. Richman, and D.
Swan. 1998. Demography and habitat characteristics of the red-cockaded woodpecker
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Clark, A., III. 1992a. Heartwood formation and loblolly and longleaf pines for red-cockaded
woodpecker nesting cavities. Proceedings of the Annual Conference of Southeastern
Association of Fish and Wildlife Agencies. 46: 79-87.
Clark, A., III. 1992b. Influence of the tree factors and site formation heartwood in loblolly and
longleaf pine for the red-cockaded woodpecker colonization in the southeast. Final
Report U.S. Forest Service, Southeastern Forest Experiment Station, Athens, Georgia,
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Conner, R.N. and B.A. Locke. 1982. Fungi and red-cockaded woodpecker cavity trees. Wilson
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Conner, R.N., and D.C. Rudolph. 1989. Red-cockaded woodpecker colony status and trends on
the Angelina, Davy Crockett and Sabine National Forests. U.S. For. Serv., Res. Pap.
SO-250, New Orleans, Louisiana.
Conner, R.N. and D.C. Rudolph. 1991. Forest habitat loss, fragmentation, and red-cockaded
woodpeckers. Wilson Bulletin 103:446-457.
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9 Appendices
APPENDIX A – Glossary of Terms
Perpetual Real Estate Protection: An affirmative interest in real property for the purpose of limiting or prohibiting a a certain action or actions.
Perpetual Conservation Management: Long term assurance of management implementation within a set of agreed upon guidelines and metrics in support of a defined conservation goal.
Funding Assurance: A financial assurance that provides sustainable funds to facilitate a desired activity. Examples are: endowments, bonds, state budging authority, etc…
Conservation Credit/Value: A unit of measure defined biologically as a number of individuals or habitat acres established and/or maintained within a defined conservation area for a specific species.
Ecological Lift: The additional overall ecological increase realized in species numbers or habitat acres above a defined current condition or baseline.
Tier 1 Consultation: A Programmatic Section 7 Biological Assessment and Associated Programmatic Biological Opinion covering a federal program which may affect a listed speices.
Tier 2 Consultation: The project and or individual action assessments and reviews conducted under a Tier 1 Programmatic Biological Opinion.
Annual Report: A consolidated report documenting the amount or extent of incidental take, changes in ecological/species condition, or actions taken pursuant to the defined action within a given timeframe.
Conservation Milestone: A biologically defined future condition that guides management actions in efforts to achieve them.
Credit Action: An action to realize and accrue the conservation value/credit earned by reaching a defined conservation milestone.
Qualifying ACUB Properties – Properties with perpetual protection, management and funding assurances in Fort Benning ACUB approved Priority Areas
Cooperator: In the context of this document is defined as the eligible entity to which Fort Benning has a Cooperative Agreement within under the ACUB Program.
Sparse Hardwood Midstory
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Pine dominated: A woodland meeting the assessment and evaluation criteria identified in Appendix B of this document.
Net Present Conservation Value: The amount of conservation value/credit available for a given property by applying all of the metrics defined in the PBA and comparing them to the associated conservation milestones.
46
APPENDIX B – Pine Dominated Forest Land Evaluation Criteria
The following is a list of the forest types followed by their forest type codes.
FOREST TYPE FOREST TYPE CODE Yellow Pine-Cove Hardwood 09
Yellow Pine-Upland Hardwood 10
Yellow Pine-Upland Hardwood-Longleaf Pine Underplant 10U
Longleaf Pine-Hardwood 11
Longleaf Pine-Hardwood-Longleaf Pine Underplant 11U
Shortleaf Pine-Oak 12
Loblolly Pine-Hardwood 13
Loblolly Pine-Hardwood-Longleaf Pine Underplant 13U
Pitch Pine-Oak 15
Longleaf Pine 21
Longleaf Pine Plantation 21P
Longleaf Pine-Scrub Oak Understory 21S
Longleaf Pine-Longleaf Pine Underplant 21U
Slash Pine 22
Slash Pine Plantation 22P
Slash Pine-Longleaf Pine Underplant 22U
Mixed Pine 25
Mixed Pine-Underplant 25U
Mixed Pine-Longleaf 26
Mixed Pine-Longleaf-Longleaf Pine Underplant 26U
Loblolly Pine 31
Loblolly Pine Plantation 31P
Loblolly Pine-Longleaf Pine Underplant 31U
Shortleaf Pine 32
Shortleaf Pine-Longleaf Pine Underplant 32U
Hardwood-Pond Pine 40
Cove Hardwood-Yellow Pine 41
Upland Hardwood-Yellow Pine 42
Southern Red Oak-Yellow Pine 44
Bottomland Hardwood-Yellow Pine 46
Northern Red Oak-Hickory-Yellow Pine 48
Scrub Oak-Yellow Pine 49
Post Oak-Black Oak 51
Chestnut Oak 52
White Oak-Red Oak-Hickory 53
White Oak 54
Northern Red Oak 55
Yellow Poplar-White Oak-Laurel Water Oak 56
Scrub Oak 57
Sweetgum-Yellow Poplar 58
Scarlet Oak 59
Sweetgum 60
47
Sweetgum-Water Oak-Willow Oak 62
Sugarberry-American Elm-Green Ash 63
Laurel Oak-Willow Oak 64
Oak-Hickory 66
Sweetbay-Swamp Tupelo-Red Maple 68
Wildlife Opening 70
Black Ash-American Elm-Red Maple 71
River Birch-Sycamore 72
Blackgum 80
Military 90
Undrained Flatwoods 98
Brush species, Non-stocked with management species 99
Lake 110
River or Stream 140
Public Parks and Cemeteries 210
Transmission Lines 220
Road or Railroad R/W 230
Special Uses 240
Other Non-forest Land 250
No Description 260
Special Timber Management Required 610
Steep Slopes 710
Sensitive Soils 740
Inaccessible Physical Barrier 760
Developed Recreation Sites 801
Administrative Sites 803
These forest types and forest type codes are primarily from the United States
Department of Agriculture, Forest Service, Southern Region, Silvicultural Examination and
Prescription Field Book; however, additional ones were added, and existing codes were changed
where necessary.
*Ft. Benning Modified Forest Type Codes - “U” denotes longleaf pine underplanting and “S”
denotes scrub oak understory.
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The Following are Detailed Descriptions of the Type Codes:
If any one type codes occurs 69.5% of the time, then it is the actual forest type
9--Yellow Pine/Cove Hardwood: This type code has longleaf, slash, mixed pine, mixed
pine/longleaf, loblolly, or shortleaf occurring 49.5-69.4% on the plot
AND
hardwood/pond pine, cove hardwood/yellow pine, bottomland hardwood/yellow pine,
sugarberry/American elm/ green ash, sweetbay/swamp tupelo/red maple, black ash/American
Elm/red maple, river birch/sycamore, or blackgum occurring 29.5-49.4% on the plot.
10—Yellow Pine/Upland Hardwood: This type code has longleaf, slash, mixed pine, mixed
pine/longleaf, loblolly, or shortleaf occurring 49.5-69.4% on the plot
AND
Longleaf or mixed pine/longleaf DOES NOT make up 49.5-69.4 on the plot
or
Shortleaf pine DOES NOT make up 49.5-69.4% on the plot
or
Loblolly pine DOES NOT make up 49.5-69.4% on the plot
AND
Upland hardwood/yellow pine, southern red oak/yellow pine, northern red oak/hickory/yellow
pine, scrub oak/yellow pine, chestnut oak, white oak/red oak/hickory, white oak, northern red
oak, yellow poplar/white oak/laurel oak/water oak, sweetgum/yellow poplar, scarlet oak,
sweetgum, sweetgum/water oak/willow oak, laurel oak/willow oak, or oak/hickory occurs 29.5-
49.4% on the plot
11—Longleaf Pine/Hardwood: This type code has longleaf or mixed pine/longleaf occurring
49.5-69.4% on the plot
AND
Upland hardwood/yellow pine, southern red oak/yellow pine, northern red oak/hickory/yellow
pine, scrub oak/yellow pine, chestnut oak, white oak/red oak/hickory, white oak, northern red
oak, yellow poplar/white oak/laurel oak/water oak, sweetgum/yellow poplar, scarlet oak,
sweetgum, sweetgum/water oak/willow oak, laurel oak/willow oak, or oak/hickory occurring
29.5-49.4% on the plot.
12—Shortleaf Pine/Oak: this type code has shortleaf pine occurring 49.5-69.4% on the plot
AND
southern red oak/yellow pine, northern red oak/hickory/yellow pine, scrub oak/yellow pine,
chestnut oak, white oak/red oak/hickory, white oak, northern red oak, yellow poplar/white
oak/laurel oak/water oak, sweetgum/yellow poplar, scarlet oak, sweetgum/water oak/willow
oak, laurel oak/willow oak, or oak/hickory occurring 29.5-49.4% on the plot.
13—Loblolly Pine/Hardwood: this type code has loblolly pine occurring 49.5-69.4% on the plot
AND
Upland hardwood/yellow pine, southern red oak/yellow pine, northern red oak/hickory/yellow
pine, scrub oak/yellow pine, chestnut oak, white oak/red oak/hickory, white oak, northern red
oak, yellow poplar/white oak/laurel oak/water oak, sweetgum/yellow poplar, scarlet oak,
sweetgum, sweetgum/water oak/willow oak, laurel oak/willow oak, or oak/hickory occurring
29.5-49.4% on the plot.
49
21S: This type code has longleaf pine occurring 49.5-69.4% on the plot
AND
Post oak/Black oak or Scrub oak occurring 29.5-49.4% on the plot
25—Mixed Pine: This type code has slash, loblolly, or shortleaf occurring 49.5-69.4% on the plot
AND
Longleaf occurring 0-29.4% on the plot
26—Mixed Pine with Longleaf: This type code has slash pine, loblolly pine and/or shortleaf pine
occurring 49.5-69.4% on the plot
AND
Longleaf pine occurring 29.5-49.4% on the plot.
42--Upland Hardwood/Yellow Pine: This type code has upland hardwood/yellow pine,
southern red oak/yellow pine, northern red oak/hickory/yellow pine, scrub oak/yellow pine,
chestnut oak, white oak/red oak/hickory, white oak, northern red oak, yellow poplar/white
oak/laurel oak/water oak, sweetgum/yellow poplar, scarlet oak, sweetgum, sweetgum/water
oak/willow oak, laurel oak/willow oak, or oak/hickory occurring 49.5-69.4% on the plot
AND
Longleaf pine, slash pine, loblolly pine, and/or shortleaf pine occurring 29.5-49.4% on the plot.
46—Bottomland Hardwood/Yellow Pine: This type code has hardwood/pond pine, cove
hardwood/yellow pine, bottomland hardwood/yellow pine, sugarberry/American Elm/green
ash, sweetbay/swamp tupelo/red maple, black ash/American Elm/red maple, river
birch/sycamore, and/or blackgum occurring 49.5-69.4% on the plot
AND
Longleaf pine, slash pine, loblolly pine, and/or shortleaf pine occurring 29.5-49.4% on the plot.
Scrub Oak/Yellow Pine: This type code has post oak/black oak and/or scrub oak occurring 49.5-
69.4% on the plot
AND
Slash pine, loblolly pine, and/or shortleaf pine occurring 29.5-49.4% on the plot.
The Following Spreadsheet Provides a Detailed If-Then Usage of the Type Codes
typecode_if_then.xl
sx
