Draft terrestrial resources biological assessment


Interdependent and Interrelated Actions



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2.3 Interdependent and Interrelated Actions


Interdependent actions are defined as having no independent utility apart from the proposed action (50 C.F.R. §402.02). Interrelated actions are part of a larger action and depend on the larger action for their justification (50 C.F.R. §402.02). The proposed action is not part of a larger action, so has no identified interrelated effects.
As discussed in Section 2.2.1, the JTA phase is proposed for construction regardless of the alternative selected (including the No Build Alternative); as such, it is considered to have independent utility from the larger project described. Consequently, the JTA phase is considered an interdependent action. Because the effects of the JTA phase are a subset of the Build Alternative and Design Option selected, this analysis evaluates such effects alongside, but separate from, the larger Alternatives under consideration.

2.4 Mitigation and Monitoring


Project activities will require mitigation and monitoring regardless of the Alternative selected. Mitigation will be required for removal or disturbance to VPCs and DCH for flora and fauna species. Mitigation will include the use of BMPs according to ODOT standards and those required in the USFWS’ Programmatic Formal Consultation on the US Fish and Wildlife Service’s Vernal Pool Conservation Strategy for Jackson County, Oregon (USFWS 2011). Further discussion of BMPs is provided in Section 6.0of this Assessment.
Monitoring will be required during construction to avoid and minimize impacts to vernal pool habitats within the regulated work area. Monitoring will comply with ODOT templates and be submitted to the DEQ and the DSL.
A project-specific on-site restoration planting plan will be developed consistent with ODOT site restoration guidance during the FEIS, following selection of a Preferred Alternative. Monitoring of site restoration areas will be detailed in the plan, including annual reporting requirements, native species mix compliance, and noxious weed control requirements.

2.5 Project Area and Action Area


The “project area” is defined herein as all areas where project activities will occur and is alternately described as the “footprint” of all proposed activities. Specifically, the project footprint, as depicted in Figure 2-4, includes all areas where construction will occur, both new construction and improvements to existing infrastructure; staging areas or other material storage areas; and stormwater facilities and infrastructure, including new treatment facilities and updates to existing infrastructure. The project footprint, in which all direct effects will be assessed, is approximately 462 acres. The project footprint, for purposes of this BA, is a conservatively estimated area of impact that assumes that the Build Alternative with the greatest impacts will be forwarded from the DEIS as the Preferred Alternative and the Design Option with the greatest area of impact will be selected. While this is not likely to occur, by

FIGURE 2-4: OREGON HIGHWAY 62 PROJECT LOCATION, FOOTPRINT AND ACTION AREA LIMITS

assessing impacts based on this assumption, actual project impacts will be less than assessed in this document. The project footprint does not include offsite mitigation areas as proposed by ODOT and USFWS. Currently, negotiations between ODOT and local landowners are occurring to establish these mitigation site. Locations of the sites have not been disclosed and therefore could not be evaluated under this BA (ODOT, 2011).


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 C.F.R. 402.02). As such, the proposed action area includes all areas identified in the project area, but also areas with potential for impacts from unintended consequences due to construction related activities (direct and indirect actions on the immediate environment). The project action area established for this BA totals approximately 5,004 acres, andis defined by the following impacts:


  • Potential impacts from sedimentation and erosion;

  • Potential impacts from hazardous materials spills;

  • Potential impacts from the introduction or spread of noxious weeds;

  • Potential impacts from stormwater sources;

  • Potential impacts from off-site vernal pool mitigation banks, once identified by ODOT;

  • Potential impacts from project related development and conversion of existing land use; and,

  • Potential impacts from construction related noise.

Potential impacts from erosion and sedimentation and the potential for contaminant spills can result in impacts outside the project construction footprint during precipitation events. The severity of these impacts would depend entirely on the nature, quantity, and duration of the contaminants introduced into uncontrolled runoff or other hydrologic releases into adjacent or downstream vegetative communities. VPCs, due to their limited tolerance to changes in quantity and water quality within the hydrologic regime, are particularly vulnerable. Construction of stormwater treatment systems, as required under ODOT standard specifications for all new impervious surfaces, may potentially alter the hydrologic regime of adjacent VPCs, either through the addition of or removal of existing contributory sources (surficial runoff). While these impacts may potentially be acute to existing VPCs, they are limited in geographic range, and thus not considered in setting the limits of the action area.



Impacts from the spread of noxious weeds may potentially occur during clearing or grading activities and / or the importation of unsterilized fill material for roadway embankments. Adherence to ODOT standard specifications for use of fill material and control of noxious weeds will be required before, during, and after construction activities. Impacts from the spread of noxious weeds may also be limited in geographic extent within the region due to seed dispersal and areas suitable for propagation of non-native species. This factor was not considered in the setting of the action area boundary due to this limitation.
Impacts from project related development and changes to existing land use within the surrounding region are expected to be minimal. The Build Alternative, including the JTA Phase of the bypass, is a limited access roadway designed to reduce congestion from an existing local highway. Improvement in regional access would have slight effects on existing development. Small scale commercial development (mostly as in-fill and small retail stores) and residential development around Medford, White City, Eagle Point, Shady Cove, and outlying rural areas is anticipated to occur (URS 2011). The JTA design options would have the potential to indirectly and directly convert most land to a non-farm use. As the City of Medford currently incorporates a large commercial and retail zone, with mostly destination type use, secondary development of large commercial areas is not anticipated. The Jackson County Planning Department has stated that the amount of capacity for additional residential development is limited under current zoning laws. While implementation of the project may increase the speed at which full build out of the area occurs, the extent of development is not anticipated to change (URS 2011).
Project related noise impacts are anticipated to be temporary in nature and confined to times when construction is occurring. Following ODOT guidance (ODOT 2008a), it is estimated that noise related impacts due to construction activities would affect the terrestrial environment up to 0.25 mile from the edge of the project footprint. Given that this is the widest area of impact to the existing environment, this distance was used to determine the extent of the action area boundary. While impacts to noise are not expected to impact VPFS or flora species under consideration in this BA, the extent of noise effects on the surrounding environment provide the most conservative estimate for consideration.



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