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Perkiomen Creek Sewer Line Expansion

July 12, 2013
Pennsylvania Fish and Boat Commission
Attn: Mr. Chris Urban, Chief Natural Diversity Section
Headquarters – Harrisburg
450 Robinson Lane
Bellefonte, PA 16823-9620
Re: Perkiomen Creek Paralleling Interceptor Project-Middle Interceptor Line
Dear Mr. Urban,
It was a pleasure speaking with you the other day about the above captioned 537 Plan issue and subsequent Eastern Red belly Turtle Habitat Assessment.  
The Delaware Riverkeeper Network (DRN) has reviewed the Trident Environmental Consultant’ June 2013 report entitled Eastern Redbelly Turtle Habitat Suitability Assessment (herein “the Report”) prepared for Bursich Associates, Inc.  We have several concerns regarding the conclusion Trident reached and the rational they used to reach those conclusions and the information that they appear to have relied upon.
The Footprint for Alternatives 1, 1c and 3
A significant issue for DRN is in the delineation of the footprint of each Alternative (1, 1c and 3) that Trident used in the foundation for many of their assertions and conclusion.  Trident references Doe Run at the northern terminus of this project and a shaley hillside to the southern end and discusses that different Alternatives will impact these two areas in different ways.  The reality is that both Doe Run and the shaley hillside will be equally impacted whichever Alternative is selected because they are within a common footprint of all three Alternatives (Please Attachment 1 - 2012 Act 537 Update Overview of Alternatives, dated 10-11-2012).  
This error/inconsistency is important to note in that Trident states (Section 7.0, Pg. 6) “the results of the habitat assessment were used to determine whether or not the alternative areas contain the potential to impose adverse impacts to habitat suitable for the eastern red belly turtle.”   The impacts on Doe Run and the shaley hillside will be impacted by each alternative equally so should either be equally weighted in the assessment or removed from the assessment altogether so as not to mislead.
The “shaley hillside” is a previously disturbed area where the Lower Interceptor was constructed and is the future connect point for the Middle Interceptor once completed.   This location, like Doe Run, will be impacted regardless of which Alternative is chosen.
Furthermore, Trident’s continual reference to this shaley hillside as being a suitable redbelly turtle habitat is conflicting to the information sited by their own 2009 Presence/Absence Report that deemed the “shaley hillside” submarginal due to its lack of “optimal soil and its prevalence of shale and stone.”
Trident continues to state that a “manicured lawn is also present on a residential property southwest of Arcola Road Bridge” on the Upper Providence side that would be considered suitable redbelly turtle habitat.  DRN would like to point out again; that this area too will be equally impacted whether Alternative 1, 1c or 3 is chosen.  Furthermore, this manicured lawn is the only opened area on the Upper Providence side and measures approximately 150 linear feet (lf).  The manicured lawns on the Lower Providence side is over 3000 lf.  When the Report generally states “there is a presen(ce)” for an impact on both sides of the creek without clarifying or quantifying where that impact is and how much of an impact, it leaves the potential for huge differences in linear feet and/or acreage and does not paint a clear picture of what alternative will have a greater impact.
Suitable habitat for Alternatives 1, 1c and 3
The Report states (Section 4.0, Pg. 4) that the Upper Providence side of the Perkiomen Creek (Alternative 3 and the side where the existing sewer line runs) has no wetlands or permanent water courses.  The Report notes that the Upper Providence side does consist of “steep slopes”, “shaley hillsides,” “craggy swales with no permanent surface water or aquatic conditions“, “deciduous upland forests” (canopy and lack of sun exposure), dense ground cover” (not easily traversed by turtles), preventable cobble and stony alluvium soil, a lack of observable aquatic vegetation, and a peripheral craggy substrate – all of which are not generally suitable for nesting habitat, overwintering, basking or aquatic habitat for the red belly turtle.   
Conversely, on the Lower Providence Township side (Alternatives 1 and 1c), Trident Reports an “absences of steep slopes” “the presences of mow, manicured lawns,” sun exposure, and both loam soil ad Rowland silt soil; all of which is stated as generally suitable habitat. 
Further, missing from Trident’s characterization of the Lower Providence side is the presence of wetlands, wetland plants and numerous basking sites with downed trees along the creek periphery which supports aquatic vegetation all within the vicinity of the nesting habitat.  Trident also lacked in the description in Hoy Park (Lower Providence side), which includes the presence of wetlands, ponds and the soft muddy basin; all within 1000 feet of the proposed project site.
Based on other historic observations (Section 2.0, Pg. 3, Rhoads and Block 2007), red belly turtles have been observed in the Perkiomen and Skippack Creeks.  Further, Trident does state (Section 9.0 Conclusion, Pg. 9) that “Based on potential impacts to suitable habitat areas, PAF&BC may request further evaluation to determine if eastern redbelly turtles are utilizing this portion of the Perkiomen Creek or identified nesting area.”  The DRN concurs with this recommendation and urges the PAF&BC to require those further studies.  We urge PAF&BC to give direct instructions for the consultant that performs those studies to clearly and accurately differentiate the footprints of each of the identified Alternatives using GPS coordinateness of all red belly habitat and nesting habitat observer as per PAF&BC requirements stated in your April 16, 2013 letter (see “minimum requirements, Pg. 2). Additionally requested in the April 16 letter was colored photographs.  The Report received by DRN and the public had only black and white pictures significantly preventing an accurate assessment of that element of the Report they were trying to convey.  Each of these components were in fact requested by the April PAF&BC letter.  We ask that you instruct that any future report will be deemed “incomplete” if the “minimum requirements” are not met.
We further request that the additional studies assess the impacts of the anticipated construction sites of each of the three Alternatives.  There will be construction access and station areas for equipment and stock piling.  Those sites will be in different locations based on the alternative chosen.  What will the temporary and permanent impacts of those areas?  Tree clearing, erosion, soil compaction, etc.  How will those areas be restored?  If trees are cut down, will native species of equal carbon sequestration potential need to be replanted?
7.0 Habitat Assessment Methodology
The Report states that nests are typically found with loamy soils and ample sun where there is a “sufficient basking areas and a permanent source of water,” along with wetlands and wetland plant communities.  Again, the Lower Providence Township side consists of all those features where the Upper Providence side has a much more limited selection.  Yet the Report fails to mention that the Lower Providence side (Alternative 1 and 1c) has wetlands and such vegetation (See pictures as Attachment 2) -- where as the Upper Providence side, within the footprint of Alternative 3, has NO wetlands! 
The ground cover listed in this section comparing the trees and vegetation common to both the Upper and Lower Providence sides also appears to be inaccurate  in description where as  the Lower Providence consists of violets, Jack in the Pulpits and the various types of ferns mentioned.  Local residents report that they have never observed theses species on the Upper Providence side in the footprint of Alternative 3.  DRN is concerned that Trident might be lumping the presence of these species in both the Upper and Lower in error.
If the sewer line is moved to the Lower Providence side for Alternatives 1 or 1c, the aquatic impact during the two deep water (“major crossings” according to the Army Corp of Engineers) would have an adverse impact on both the overwintering turtles and the aquatic habitat.  While the stated reason for this study was to determine the impacts for the proposed alternatives, the impacts for these two major creek crossings as a result of Alternatives 1 or 1c selection, do not appear in this assessment.
Section 8.0 Habitat Evaluation
Trident determined that there is “potential redbelly turtle nesting habitat…in select open, upland locations in both Upper and Lower Providence Townships within and outside the three alternative locations.”  DRN is concerned that this Report does not paint a true picture of which areas are being assessed and how much actual area will be impacted. 
In this section it further states that “aside from Skippack Creek and Doe Run, there are no suitable watercourses along the Perkiomen Creek to support aquatic migration of red belly turtle.”  Considering that we have already established that it is misleading and inaccurate to assess Doe Run because the impacts will be the same whichever Alternative is chosen, then the Skippack is the only location within the study area that has suitable water courses.  Those areas would not be impacted if Alternative 3 was selected and will only be impacted if Alternative 1 or 1c is chosen.
Does the PAF&BC require a wetland delineation conducted by a certified wetland specialist as part of this permitting/approval process?  One of the area residents reported that there was a wetland survey on the Lower Providence side approximately 5 years ago and a vernal pool was identified.  Wouldn’t these areas be providing additional preferred habitat for the red belly?  Would that not be a suitable water course?  The Report does state there are no wetlands on the Upper Providence side – only intermittent/non perennial drainage swales, craggy substrate/debris, and present moveable barriers.  Wouldn’t the wetlands and the Skippack Creek both located on the Lower Providence side substantiate why there would be a greater potential loss of habitat if Alternative 1 or 1c were selected?
The Report also states that “habitat destruction and pollution have almost eliminated this species (redbelly turtle) from... (The Delaware River and its major tributaries).”  DRN urges the PAF&BC to limit that destruction by denying a permit/approval for Alternatives 1 or 1c since that would require a 20 foot trench under the Perkiomen Creek and would adversely impact the Skippack - especially when a logical alternative is available (Alternative 3 would be confined in the same trench as the existing sewer line within the steep, shaley slope and would not cross over the Perkiomen Creek - twice).
Section 8.1 and 8.2 Arcola 1 and Arcola 1c Potential Project Impacts
These two sections re-state what DRN believes to be in-accurate and misleading information pertaining to the Doe Run crossing by stating that Alternative 1 and Alternative 1c will “traverse through suitable eastern red belly turtle habitat.”  Yet, in Section 8.3, when referencing impacts of the Alternative 3, Trident makes no statement of a negative impact to the redbelly when Alternative 3 traverses the same tributary – Doe Run.  Trident only states that that same Doe Run crossing “contain the potential to host overwintering eastern red belly turtles.”  If all three Alternatives would be taking the identical routes, how can two of the three result in damaging impacts and not the third?
Finally, Trident’s conclusion (Section 9.0, Pg. 9) states that Alternative 3, “will impact suitable aquatic habitat along the entire length of the alternative,  DRN respectfully disagrees with this conclusion based on Trident’s own Report stating that (Section 4.0, Pg. 4)  the Upper Providence side of the Perkiomen (Alternative 3 and the side where the existing sewer line runs) consists of “steep slopes”, “shaley hillsides,” “craggy swales with no permanent surface water or aquatic conditions“, “deciduous upland forests” (canopy and lack of sun exposure)  no wetlands, dense ground cover” (not easily traversed by turtles)  preventable cobble and stony alluvium soil, with lack of observable aquatic vegetation and a peripheral craggy substrate–all of which are not suitable for aquatic, hibernation or nesting red belly turtle habitat.
Conversely, with the exclusion of the shared impact areas of the single manicured lawn of the Upper Providence side, Doe Run and the shaley hillside, there appears to be a greater amount of vulnerable redbelly turtle habitat subject to destruction on the Lower providence Township side where Alternatives 1 and 1c are being proposed.
DRN thanks you for your assessment of our observation and we look forward to hearing from you.
Fred Stine, Citizen Action Coordinator
Cc: Jennifer Fields, PADEP
PA Fish and Game
PA Department of Conservation and Natural Resources
US Fish and Wildlife Service