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t9 FISH AND WILDLIFE SERVICE 'may*
Pacific Islands Fish and Wildlife Office
300 Ala Moana Boulevard, Room 3-122
Honolulu, Hawaii 96850
In Reply Refer To: MAR 0 6 2017
01 EPIF00-2017-TA-0155
Mr. Michael Yee
Planning Director
74-5044 Ane Keohokalole Hwy
Kailua-Kona, Hawaii 96740
Subject: Technical Assistance for the Construction of a Telecommunication Facility,
Consisting of a 60-foot Monopalm and Related Infrastructure in Waikoloa,
County of Hawaii.
Dear Mr Yee:
The U.S. Fish and Wildlife Service (Service)received your correspondence on February 16,
2017, requesting review of a proposed 60-foot monopalm (associated with infrastructure),
proposed by Verizon Wireless in Waikoloa(Tax Map Key: 6-8-002:031). The Service offers the
following comments to assist you in your planning process so that impacts to trust resources can
be avoided through site preparation, construction, and operation. Our comments are provided
under the authorities of the Endangered Species Act of 1973 (ESA), as amended (16 U.S.0 1531
et seq.).
Based on information you provided in the Use Permit Application and pertinent information in
our files, including data compiled by the Hawaii Biodiversity and Mapping Project, there are five
listed animal species in the vicinity of the project area: The federally endangered Hawaiian hoary
bat (Lasiurus cinereus seinotus), Hawaiian hawk(Buteo solitarius), the Hawaiian petrel
(Pterodroina sandwichensis),band-rumped storm-petrel (Oceanodroina castro), and the
threatened Newell's shearwater (Puffinus auricularis newelli), may transit the project area flying
to upland breeding colonies. There are also two endangered insects, the yellow-faced bee
(Hylaeus spp.) and the Blackburn's sphinx moth (Manduca blackburni).
The Service recommends the following measures to avoid and minimize project impacts to the
following listed species:
Hawaiian hoary bat
The endangered Hawaiian hoary bat may be present within the proposed project area. The
Hawaiian hoary bat roosts in both exotic and native woody vegetation and will leave young
unattended in "nursery" trees and shrubs when they forage. If trees or shrubs suitable for bat
SCANNED
MAR - 9 017
By: 110296
Mr. Michael Yee 2
roosting are cleared during the pupping season, there is a risk that young bats could inadvertently
be harmed or killed. To minimize impacts to the endangered Hawaiian hoary bat, woody plants
greater than 15 feet (4.6 meters)tall should not be disturbed, removed, or trimmed during the bat
birthing and pup rearing season (June 1 through September 15). Additionally, Hawaiian hoary
bats forage for insects from as low as three feet to higher than 500 feet(152 meters) above the
ground. When barbed wire is used in fencing, Hawaiian hoary bats can become entangled.
Therefore, the Service recommends barbed wire not be used for fencing.
Hawaiian hawk
The Hawaiian hawk is known to occur across a broad range of forest habitats throughout the
Island of Hawaii. Loud, irregular and unpredictable activities, such as using heavy equipment or
building a structure, near an endangered Hawaiian hawk nest may cause nest failure.
Harassment of Hawaiian hawk nesting sites can alter feeding and breeding patterns or result in
nest or chick abandonment. Nest disturbance can also increase exposure of chicks and juveniles
to inclement weather or predators. Ground clearing or construction should not occur within
1,600 feet of any Hawaiian hawk nest during the Hawaiian hawk breeding season (March
through September). If work must be conducted during the March through September Hawaiian
hawk breeding season, a qualified ornithologist should conduct a nest search of the project
footprint and surrounding areas immediately prior to the start of construction activities. Pre-
disturbance surveys for Hawaiian hawks are only valid for 14 days. If disturbance for the
specific location does not occur within 14 days of the survey, another survey will be conducted.
Hawaiian petrel,Newell's shearwater, and band-rumped storm petrel
Hawaiian seabirds may traverse the project area at night during the breeding season. Outdoor
lighting could result in seabird disorientation, fallout, and injury or mortality. Seabirds are
attracted to lights and after circling the lights they may collide with nearby wires, buildings, or
other structures or they may land on the ground due to exhaustion. Downed seabirds are subject
to increased mortality due to collision with automobiles, starvation, and predation by dogs, cats,
and other predators. Young birds (fledglings) traversing the project area between September 15
and December 1.5, in their first flights from their mountain nests to the sea, are particularly
vulnerable. To minimize potential project impacts to seabirds during their breeding season, all
outdoor lights should be fully shielded so the bulb can only be seen from below bulb height and
only used when necessary. Automatic motion sensor switches and controls should be installed
on all outdoor lights or lights should be turned off when human activity is not occurring in the
lighted area. Any increase in night-time lighting, particularly during each year's peak fallout
period (September 15 through December 15), could result in seabird injury or mortality.
Nighttime construction should be avoided during the seabird fledging period, September 15
through December 15.
Yellow-faced Bees
Habitat destruction and modification and land use conversion leads to fragmentation of foraging
and nesting areas of these yellow-faced bee species. Habitat destruction and modification by
nonnative plants adversely impact native Hawaiian plant species by modifying the availability of
light, altering soil-water regimes, modifying nutrient cycling, altering the fire characteristics
(increasing the fire cycle), and ultimately converting native dominated plant communities to
nonnative plant communities; such habitat destruction and modification result in removal of food
sources and nesting sites for the listed yellow-faced bee. To minimize potential adverse effects
Mr. Michael Yee 3
to these species, we recommend you restrict vehicle use to existing roads and trails. If vegetation
must be cut or removed from an area outside existing developed ground, a survey should be
conducted on the proposed project site for Hylaeus nests and avoid disturbance to the nest site.
Avoid cutting or removing plants in the Sida genus (ilima). Restore cleared areas using native
vegetation where possible.
Blackburn's sphinx moth
The Blackburn's sphinx moth occur on the islands of Maui, Lanai, Kahoolawe, and the Island of
Hawaii. The adult moth feeds on nectar from native plants including beach morning glory
(Ipomoea pes-caprae), iliee (Plumbago zeylanica), maiapilo (Capparis sandwichiana).
Blackburn's sphinx moth larvae feed upon non-native tree tobacco (Nicotiana glauca), which
occupies disturbed areas such as open fields and roadway margins, and the native aiea
(Nothocestrum spp.). We recommend that a biologist with Blackburn's sphinx moth experience
survey the project area for the presence of adult and larval host plants. To pupate, Blackburn's
sphinx moth larvae burrow into the soil near host plants and can remain in a state of torpor for up
to a year (or more) before emerging from the soil. To minimize the potential for the project to
adversely impact the Blackburn's sphinx moth, host plants should not be cut or removed and the
soil within 33 feet(10 meters) of the host plants should not be disturbed. If occupied host plants
are found within the project area, we recommend you contact us as soon as possible so we may
assist you with additional measures to avoid impacts to this species in your project description.
If the proposed project requires gravel or dirt fill to be used at the location, the Service
recommends getting the fill from a source that is certified weed free or a plant survey be
conducted around the area where the fill will be extracted. The survey is a measure to avoid
spreading non-native tree tobacco and other invasive plant species from where the fill is removed
to the proposed project area. Non-native tree tobacco and other invasive species seeds could be
found in the fill and unknowingly spread to the project area thus attracting Blackburn's sphinx
moth to the project site and increasing the risk of future take.
Thank you for participating with us in the protection of our endangered species. If you have any
further questions or concerns regarding this consultation, please contact Eldridge Naboa, Fish
and Wildlife Biologist, 808-792-9451, e-mail: eldridge_naboa@fws.gov. When referring to this
project, please include this reference number: 01EPIF00-2017-TA-0155.
Sincerely,
M chelle Bogardus
Island Team Manager
Maui Nui and Hawaii Island