<html xmlns="http://www.w3.org/1999/xhtml">
<head>
<meta name="pdf:PDFVersion" content="1.4">
<meta name="xmp:CreatorTool" content="HP PDF Formatter version 3.2.0.539">
<meta name="pdf:hasXFA" content="false">
<meta name="access_permission:modify_annotations" content="true">
<meta name="dcterms:created" content="2008-03-18T14:29:06Z">
<meta name="dcterms:modified" content="2008-03-18T14:29:09Z">
<meta name="dc:format" content="application/pdf; version=1.4">
<meta name="pdf:docinfo:creator_tool" content="HP PDF Formatter version 3.2.0.539">
<meta name="access_permission:fill_in_form" content="true">
<meta name="pdf:docinfo:modified" content="2008-03-18T14:29:09Z">
<meta name="pdf:hasCollection" content="false">
<meta name="pdf:encrypted" content="false">
<meta name="xmp:CreateDate" content="2008-03-18T14:29:06Z">
<meta name="Content-Length" content="2686979">
<meta name="pdf:hasMarkedContent" content="false">
<meta name="Content-Type" content="application/pdf">
<meta name="access_permission:can_print_faithful" content="true">
<meta name="xmp:ModifyDate" content="2008-03-18T14:29:09Z">
<meta name="xmp:MetadataDate" content="2008-03-18T14:29:09Z">
<meta name="pdf:producer" content="Adobe PDF Library 5.0">
<meta name="access_permission:extract_for_accessibility" content="true">
<meta name="access_permission:assemble_document" content="true">
<meta name="xmpTPg:NPages" content="12">
<meta name="pdf:hasXMP" content="true">
<meta name="access_permission:extract_content" content="true">
<meta name="access_permission:can_print" content="true">
<meta name="X-TIKA:Parsed-By" content="org.apache.tika.parser.DefaultParser">
<meta name="X-TIKA:Parsed-By" content="org.apache.tika.parser.pdf.PDFParser">
<meta name="access_permission:can_modify" content="true">
<meta name="pdf:docinfo:producer" content="Adobe PDF Library 5.0">
<meta name="pdf:docinfo:created" content="2008-03-18T14:29:06Z">
<title></title>
</head>
<body><div class="page"><p></p>
<div class="ocr">United States Department of the Interior

FISH AND WILDLIFE SERVICE
911 NE 11" Avenue
Portland, Oregon 97232-4181

IN REPLY TO:
FWS/RI/AES

Kenneth Seeley, Chief, Environmental Services
United States Department of Agriculture
Animal and Plant Health Inspection Service
4700 River Road

Riverdale, Maryland 20737

Dear Mr. Seeley:

This responds to your letter, dated September 27, 2007, requesting Fish and Wildlife Service concurrence
that the United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service's
(APHIS) proposed permit program for the movement of baled garbage and regulated domestic garbage
from Hawaii to Washington, Oregon, and Idaho for disposal at landfills is not likely to adversely affect
federally endangered or threatened species or designated critical habitat. This response was prepared in
accordance with the requirements of section 7 of the Endangered Species Act of 1973 (ESA) as amended.

As described in the September 2007 Biological Assessment (BA) and in the February 11, 2008, final BA
for the proposed action, APHIS proposes to issue permits after compliance agreements between APHIS,
the State of Hawaii, the States of Washington, Idaho, or Oregon, and specific applicants are agreed upon
and signed in accordance with APHIS regulations (7 C.F.R. § 330.400). These regulations allow garbage
from Hawaii to be moved to the continental United States if it is compressed, packaged, shipped and
disposed of in a manner that the APHIS administrator determines is adequate to prevent the introduction
or dissemination of plant or animal pests, and is moved in compliance with all applicable laws for
environmental protection.

Based on the enclosed assumptions and analysis, we concur with your finding that the proposed action
may effect, but is not likely to adversely affect, the following species: the Columbian white-tailed deer
(Odocoileus virginianus leucurus), Canada lynx (Lynx canadensis), grizzly bear (Ursus arctos horribilis),
northern Idaho ground squirrel (Spermophilus brunneus brunneus), woodland caribou (Rangifer tarandus
caribou), gray wolf (Canis lupus), pygmy rabbit (Columbia River distinct population segment)
(Brachylagus idahoensis), and the bull trout (Salvelinus confluentus). No critical habitat is likely to be
affected by the proposed action.

This letter concludes our consultation on the proposed action. If you have any questions regarding this
response, please contact Daniel Brown of this office at (503) 231-6281.

Sincerely,

That 2%

Assistant Regional Director, Ecological Services

AMERICA
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Enclosure |

Fish and Wildlife Service Findings of Concurrence regarding the Effect on Listed
Species of APHIS’s Proposed Permitting of Plastic-baled Garbage Transfer from
Hawaii to Landfills in Oregon, Idaho, and Washington

Prepared by Daniel Brown, U.S. Fish and Wildlife Service, Region 1

Summary

APHIS has proposed a program of issuing Compliance Agreements/permits to applicants
for the purpose of moving garbage from Hawaii to Washington, Oregon, and Idaho
landfills via the Columbia River. Three specific landfill sites have been identified, one in
each state, as likely recipients of the garbage. However, during the life of the program,
any of 14 existing landfills in these three states (see Figure | of the Biological
Assessment) may accept regulated garbage. In addition, any new landfills that come
on-line are potential recipients.

In the original September 2007, Biological Assessment (BA) and in the February 11,
2008, final BA for the proposed action, APHIS attempted to address all possible effects
of the proposed action on endangered and threatened species programmatically. This
approach involved the use of several assumptions. As part of the proposed action,
APHIS intends to conduct a compliance review in advance of renewing each signed
agreement every 3 years. In accordance with the implementing regulations for section 7
of the Endangered Species Act (ESA), APHIS will reinitiate consultation if any
assumption is violated or the proposed action changes in a manner that may result in an
effect to listed species or critical habitat that was not considered in this review.

The Plant Protection and Quarantine Division (PPQ) of APHIS will provide an annual
report to the Fish and Wildlife Service (FWS) for three consecutive years, starting at the
end of the first year in which baled garbage shipments from Hawaii commence. These
reports will address compliance agreement activities, include a summary of any incidents
documented on the bale manifests, and any PPQ-defined significant pest found in
association with the movement of baled garbage from Hawaii. If within those three
years, no PPQ-defined significant pests are found in association with the movement of
baled garbage, then PPQ will no longer prepare an annual report, unless formally
requested to do so by the FWS. However, the PPQ will notify the FWS within 3 business
days of any known release of any pest or unwanted organisms caused by the proposed
action.

The following discussion summarizes the analysis of potential effects to listed species
caused by the proposed action.
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Principal Findings

The potential for release of pest organisms from garbage spills or of “hitchhiking”
organisms during transfer is unlikely for the reasons discussed under the “Overarching
Assumptions” section below. The unlikely event of any releases/spills would be
addressed as an emergency spill response, as appropriate. Monitoring efforts by APHIS
will also minimize the risk of unwanted organism (hitchhiker) releases from the vessels
transferring garbage.

The landfills where the Hawalian garbage will be deposited are not parties to the
Compliance Agreements/permits, nor do landfill operations constitute actions that are
interrelated or interdependent to the proposed action, Although landfill operators are
subject to the provisions of the ESA, the effects of landfill operations to listed resources
are not addressed here.

The risk of fuel leaks from tugs and barges was analyzed in the BA. Based on that
analysis, the FWS has determined that toxicity effects to listed fish from the routine
leakage of fuel or oil into the Columbia River or adjacent coastal waters are not likely to
be measurable or detectable, so the potential for adverse effects to listed fish and seabirds
or their critical habitat from the routine leakage of fuel or oil caused by the proposed
barging of Hawaiian garbage up the Columbia River or adjacent coastal waters is
considered to be insignificant.

The risk of copper leaching from anti-hullfouling treatments applied to tug and barge
hulls was analyzed in the BA. It was determined that toxicity effects to listed fish from
copper leaching into the Columbia River are not expected, so the potential for adverse
effects to listed fish or their critical habitat due to copper leaching caused by the proposed
barging of garbage up the Columbia River is considered to be discountable.

The risk of listed species being killed or injured by trucks and on rails by trains
transporting garbage was also examined in the BA. While there may be a measurable
risk of vehicular impacts causing harm to listed species on roadways in the action area,
the extremely low risk probability of an adverse interaction with a truck associated with
the proposed action cannot be meaningfully evaluated.

Overarching Assumptions

The return of barges to Hawaii is considered an interrelated action to the proposed action
only if there is a resulting increase in barge traffic.

The BA proposes to use tugs and barges that already travel to Hawaii loaded with
construction or other materials and would be returning to the mainland United States
empty regardless of whether this proposed action is approved by APHIS.
</div>

</div>
<div class="page"><p></p>
<div class="ocr">No significant increase in barge traffic across the Pacific Ocean is expected from this
action because it is not cost-effective to send additional empty barges to Hawaii simply
for the purpose of picking up baled garbage to return to the mainland..

The development, expansion, operations, and maintenance of landfills that would receive
the subject garbage are not considered interrelated or interdependent actions to the
proposed action because such activities are independent of the proposed action,

Any new or expanded landfill operations will require separate ESA compliance, as
appropriate.

APHIS will only issue Compliance Agreements/permits for transferring Hawaiian
garbage to landfills in Oregon, Washington, and Idaho. According to Figure | of the BA,
14 landfills can receive baled garbage under this program.

Regulated (domestic) garbage refers to articles generated in Hawaii that are restricted
from movement to the continental United States under various quarantine regulations
established to prevent the spread of plant pests (including insects, disease, and weeds)
into areas where the pests are not prevalent.

Barges will gain entry to the mainland only through navigable portions of the Columbia
River.

The transport of Hawaiian garbage up the Columbia River is expected to involve an
increase of no more than 100 trips per year.

All garbage staging areas will consist of an asphalt or concrete surface.

No new railways or roads will be constructed. Only currently established transportation
routes will be used.

In the unlikely scenario that all terrestrial transport of garbage were by rail, this would
result in a less than | percent increase in number of railcars per year in Oregon and
Washington, and a 3 percent increase in number of railcars per year in Idaho.

In the unlikely scenario that all terrestrial transport of garbage were by truck, this would
result in a 0.2, 0.1, and 0.5 percent increase in number of truck/highway freight traffic per
year in Oregon, Washington, and Idaho respectively (based on a total of 14,706 added
trips to the tri-State area).

APHIS will authorize (permit) this activity through two Compliance Agreements/permits:
one for the handling of garbage in Hawaii and one for handling it at its destination at a
Oregon, Washington, or Idaho landfill.

The term of the proposed action is for the foreseeable future.
</div>

</div>
<div class="page"><p></p>
<div class="ocr">The term of an individual Compliance Agreement/permit is expected to be 3 years unless
renewed.

All Compliance Agreements/permits will be done in a manner consistent with APHIS
regulations: “7 CFR part 330.402 Garbage generated in Hawaii” and subject to
termination per “7 CFR part 330.403 Garbage generated in Hawaii.”

Risk of Pest or Unwanted Organism Release from Baled Garbage

The risk that pests or other unwanted organisms would be released to the mainland during
the term of the proposed action, and in turn result in a likelihood of adverse effects to
listed species and/ or critical habitat, is considered insignificant for the following reasons:

Prior to being sorted, household chemical waste comprises only 0.3% of Hawaiian solid
municipal waste. Any pests or other organisms that remain in the baled garbage would
be subjected to the compression, baling, and wrapping processes, which result in crushing
and oxygen deprivation of any affected organisms.

Bales wrapped to the point of being airtight become anoxic within several days. Pre-
shipment staging and subsequent shipment will deprive affected organisms of oxygen for
between two and three weeks. Because the potential quantity of household chemical
wastes being present in the bales is very low, combined with the low probability of a
bale-rupturing barge accident, it is very unlikely that there would be an effect on water
quality in the mainstream Columbia River.

Upon arrival at the landfill destination, the bales will be loaded to an asphalt or concrete-
based staging area, where they may remain for a few weeks before being loaded to trucks
or rail cars and sent to the landfill. Once placed in the landfill, they will be covered with
six inches of dirt on that same day and will be buried by 7 feet of material within a short
time of their arrival.

If bales are punctured or torn open during handling, they will be re-wrapped or patched,
depending upon the severity of the puncture, according to the detailed requirements
outlined in the compliance agreements to restore their airtight condition.

The worst case scenario analysis for barge and rail accidents estimated that the mean
number of years to the first bale-rupturing barge accident was 645 years, with only a 5
percent chance of a rupture happening within 34 years. The mean number of years to the
first bale-rupturing rail accident was estimated to be 1,429 years, with only a 5 percent
chance of a rupture accident happening within 74 years. The mean number of years to
the first bale-rupturing accident for trucks was 2,222 years. For all options, the risk of
catastrophic rupture of bales is low, less than | percent (Note: This figure was
specifically calculated for the Idaho proposal, which considered 360,000 tons of garbage
annually being transferred into landfills; this amount is more than the estimated amount
of garbage to be placed in Oregon, Idaho, and Washington landfills.)
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Because spills are very unlikely to occur, consideration of environmental contamination
due to spills will be addressed as an emergency spill response, and, if appropriate,
emergency consultation under section 7(a)(2) of the ESA.

Risk of Pest or Unwanted Organism Release from Barges or Tugs

If APHIS, their applicants and agents carry out the proposed monitoring, reporting and
treatment of pest/unwanted organisms, as discussed in the BA and below, the risk of
release of unwanted hitchhiking organisms from the vessels (e.g., ballast, hull, external
surfaces) appears to be discountable.

Ballast

APHIS has determined that there will be no effect to listed species or critical habitat from
ballast water discharge. Tug ballast water is drawn from the sea and discharged at sea.
Barges are ballasted only during the loading and unloading phase alongside the dock. No
ballast water is carried in the barge ballast tanks for the voyage across the ocean.

Hull-Fouling

APHIS has determined that there will be no effect to listed species or critical habitat due
to “Hull Fouling” (e.g., unwanted organisms) due to current measures employed to
minimize adherence of hull-fouling organisms. Some of the hull treatments include
copper oxide, known to be toxic to fish. Leaching in the water column is not thought to
be a concern, but accumulation in the sediment could be problematic over time. Risk of
effects due to copper-leaching is addressed below.

Hitchhiker Organisms

External surfaces of wrapped bales will be monitored and certified free of unwanted
organisms such as snails and slugs prior to loading and unloading barges. Responsible
parties will be identified in each Compliance Agreement/permit. APHIS expects that
monitoring will be sufficient to prevent movement of unwanted organisms.

Included in all Compliance Agreements/permits will be a requirement that the
responsible party/hauling company provide inspection at each trans-loading location as
well as at the final off-loading point. The hauling company is required by the
Compliance Agreement/permit to ship bales that do not carry hitchhiker organisms. Ifa
mollusk is found on a pallet or bale at any of the inspection points on the mainland, the
company is required under the Compliance Agreement/permit to separate the bale on a
solid, flat, impervious surface made of asphalt or concrete, circle the bale with salt, and
contact local PPQ immediately so that proper action can be taken to mitigate any
potential pest risk. The Compliance Agreement/permit also requires that the staging area
for bales in Hawaii as well as on the mainland be a solid, flat, impervious surface made
of asphalt or concrete.
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Before handling and transport of Hawaiian Municipal Solid Waste (MSW) bales,
company employees are required to be trained in various procedures for complying with
the Compliance Agreement/permit, including training on identifying Hawaiian plant
pests. If a company is found to be in violation of any part of the Compliance
Agreement/permit, then the Compliance Agreement/permit may be cancelled in
accordance with 7 CFR 330.403(d).

Generic Compliance Agreement’permit terms related to activities in Hawaii:

« The responsible party/company will ensure that the Staging Area is kept clean and
free of loose garbage and soil. The Staging Area shall be clearly marked and
physically separated from the Transport Area.

« Operational procedures pertinent to the Staging and Transport areas shall be
posted in a location visible to all company personnel and authorized
representatives.

e The company shall develop and enforce plans for pest exclusion and eradication
programs to control pests that may be attracted to the bales in the staging and
loading area (e.g., rodents, birds, mollusks, etc.), These plans shall be submitted
for approval by the PPQ in Honolulu, Hawaii.

e Company personnel or their authorized representative shall conduct an inspection
of each bale upon placement onto the barge. Bales shall be inspected for any
punctures, ruptures, or tears and external contaminants (e.g., soil, garbage,
mollusks) upon placement onto the barge. The date and identification of the
personnel responsible for the inspection and authorization for forward movement
shall be indicated in the bale manifest.

Generic Compliance Agreement/permit terms related to mainland activities:

e The staging and transport areas shall be kept clean and free of loose garbage and
soil. The areas will be controlled for birds, rodents, mollusks, and any other pests
that may be attracted to the bales.

* All garbage and regulated (domestic) garbage must be protected from birds,
rodents, and mollusks during staging and transport. The bales of garbage and
regulated (domestic) garbage will be isolated from close proximity to exposed
fresh fruits, plants, or other activities that may attract hitchhiking plant pests.
Barriers will be erected if this occurs due to unusual and unavoidable
circumstances if the operations cannot be moved.

e Ifbales are palletized, each pallet will be inspected thoroughly to ensure no
hitchhiking mollusks are present. Pallets found to contain hitchhiking mollusks
will be separated immediately, The infested pallets will be safeguarded within a
circle of salt on a level, solid, and impervious surface of asphalt or cement, and
the local PPQ will be notified promptly.

In two, site-specific Pest Risk Assessments for movement of Hawaiian MSW (Municipal
Solid Waste) to Oregon and to Idaho, the PPQ’s Center for Plant Health Science and
Technology concluded that "if the planned procedures were followed, transportation of
</div>

</div>
<div class="page"><p></p>
<div class="ocr">baled Hawaiian MSW posed an insignificant risk of pest establishment. The reasons
given to support this finding included exclusion of most yard and agricultural waste from
the pathway, to greatly reduce the presence of potential plant pests or propagules in the
bales; the inability of insects, mollusks, and most pathogens to survive in the bales under
anoxic conditions; and the establishment of pathway procedures (monitoring during
transport) to protect against escapes via accidental ruptures and punctures during
handling and transport.

The PPQ also conducts compliance checks, and with most new operations, those checks
are more intensive and frequent at the beginning of the program. These checks provide
an opportunity to address any concerns and ensure that the company is meeting the
standards set forth in the Compliance Agreement/permit. If the company is operating
according to the Compliance Agreement/permit, then PPQ compliance checks become
less frequent. The frequency of those checks will be determined by the PPQ locally.

Risk of Chemical Contamination from Barges

APHIS has determined, for the reasons discussed below, that routine leakage of fuel or
oil into the Columbia River and coastal waters from barges carrying Hawaiian garbage is
extremely unlikely to occur at concentrations that are toxic to listed fish or birds.
Therefore, such effects are considered discountable.

APHIS calculated likely fuel oil spill concentrations into the Columbia River from
normal barge towing operations by comparing minimum and average water discharge
from McNary Dam to average mg/L/hr diesel fuel discharge rate. The resulting average
concentrations of 0.04 mg/L/hr (minimum water discharge) and 0.006 mg/L/hr (average
yearly water discharge), when compared to the 48-hour Daphnia ECso value of 1.43
mg/L, fall well below a toxicity value for Daphnia. APHIS concluded that this is an
extremely conservative estimate of toxicity risk to fish and seabirds since the analysis
considers concentrations in discharged water only, which compared to the entire volume
of water in the Columbia River (and nearby ocean waters) is small, and because
invertebrates such as Daphnia are typically more sensitive than vertebrates (fish and
birds).

EPA recommends using a 0.01 factor of the lowest resident species EC/LC50 value
which in this case (0.0143) would approximate the calculated exposure concentrations at
a minimum discharge from the dam but would be an order of magnitude below potential
levels at the average yearly discharge.

The following basic assumptions are considered relative to the potential risk of direct or
indirect toxicity to fish due to routine leakage of fuel or oil from the proposed action in
the Columbia River and coastal waters:

Due to the limited amount of tug traffic associated with the proposed action, the
probability of aggregate spill effects to listed species due to routine fuel oil leakage from
</div>

</div>
<div class="page"><p></p>
<div class="ocr">tugs involved in the proposed action cannot be meaningfully evaluated and are therefore
considered discountable.

Barge traffic on the Columbia River is estimated to increase only 1 percent (100 barges
per year) as a result of this proposed action.

The estimated amount of fuel loss from a single tug is considered conservative. Estimates
were based on economic considerations for an acceptable loss of fuel and were
considered to occur during the entire five-day trip.

The calculation of cfs, based solely on outflow discharge rates from the McNary Dam,
does not consider the volume of water already below the dam which would substantially
increase the volume available for dilution.

The calculations assume that the entire length of the Columbia River has the same flow
rate. Dams located downstream of the McNary Dam, as well as numerous tributaries that
drain into the Columbia River would be expected to dilute oil below the calculated
values.

The calculations assume that the diesel fuel will be uniformly mixed within the water
column which will not be the case since diesel fuel density (0.827 mg/mL) is less than
water, The lighter diesel fuel will remain at the surface of the water column where the
more toxic components will be lost through evaporation and other biotic and abiotic
pathways.

The comparison of toxicity values expressed as (mg/L) to a rate expressed as (mg/L/hr)
creates uncertainty in calculating risk. The concentration per hour calculated for this
exercise would never be realized in the Columbia River or nearby coastal waters.
Making a comparison to toxicity values expressed over 48 to 96 hr is overly conservative
and does not represent actual exposure scenarios.

Risk of Copper Exposure to Listed Salmonids from Barges Containing Hawaiian
Garbage

Several published articles have documented copper-related impacts to the olfaction
response of salmonids that could result in sublethal adverse effects. A recent overview of
these effects resulted in the establishment of proposed benchmark concentrations that
provide threshold concentrations above which dissolved copper concentrations could be
expected to impact olfaction and behavior (Hecht et a/., 2007). Biologically relevant
benchmark concentrations to unexposed salmonids were calculated to range from 0.59 to
2.1 ug/L. This range was used as the effects endpoint for this assessment since it is the
most sensitive compared to other endpoints that have been documented in other studies.

APHIS provided an extremely conservative exposure analysis that assumes (1) a
relatively high rate of leaching would occur uniformly across the entire surface area of
the largest possible barge that could be used, (2) that the leaching is occurring into a
</div>

</div>
<div class="page"><p></p>
<div class="ocr">comparatively small water body than would occur at an actual port without any flow, and
(3) that 100% of the copper is bioavailable and in the dissolved phase which would not be
the case in natural waters. Based on a 400 M L volume and a barge with a bottom
surface area of 4,179 sq meters that discharges 50 pg Cu/ cm*/day of copper, the
estimated copper concentration in the water column adjacent to a barge would be 0.52
pg/L. This value is below the threshold range of 0.59 and 2.0 pg/L which suggests the
risk of copper to salmonids is low. Due to the limited amount of tug traffic associated
with the proposed action, the probability of aggregate effects of hull leaching to listed
salmonids due to routine fuel oil leakage from tugs involved in the proposed action
cannot be meaningfully evaluated. Therefore, these effects are considered discountable.

Based on this assessment, APHIS determined that anti-hullfouling treatments may affect,
but are not likely to adversely affect, listed salmonids in the Columbia River. The
potential for measurable adverse effects to listed salmonids from a worst case scenario
concentration of copper leaching from project-related barges into the Columbia River is
insignificant because a conservative estimate of exposure concentrations appears to be
well below expected benchmark concentrations for adverse olfactory response in
salmonids. In addition, the use of such treatments is intended to prevent invasive species
from being carried into the Columbia River.

Risk of Truck and/ or Rail Impact Injuries to Listed Species

In the unlikely scenario that all terrestrial transport of baled garbage is done by truck, the
number of additional trucks is expected to increase over the existing condition by no
more than ' percent in any state.

In the unlikely scenario that all terrestrial transport of baled garbage is done by rail, the
number of rail cars is expected to increase over the existing condition by no more than 3
percent in any state. However, the proposed action is more likely to result in train length
increases rather than in new trains, and the proposed action is unlikely to be the sole
purpose for any rail traffic. Therefore, while there may be a measurable risk of train
strikes causing harm to listed species, the risk of an adverse interaction with a train that
has the sole purpose of implementing the proposed action is considered highly unlikely,
and therefore, discountable.

Columbian White-tailed Deer

This species is a narrow endemic occurring only along the north bank of the Columbia
River, northwest of Cathlamet, Washington. There are no railroad lines in this area and
no proposed project-related permits or agreements are expected to involve this area.
Columbian white-tailed deer mortalities due to vehicle interactions are known from along
State Highway 4. While there may be a measurable risk of vehicular impacts causing
harm to Columbia white-tailed deer, the risk of an adverse interaction with a truck
associated with the proposed action is considered highly unlikely, and therefore,
discountable because no vehicular garbage transport caused by the proposed action is
likely to occur in areas occupied by the deer.
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Woodland Caribou

The U.S. range of the woodland caribou has been reduced to a small area of eastern
Washington and northern Idaho on either side of the international border area bounded by
the Columbia River and Kootenay River. There are no freight rail lines in the area.

There are currently no proposed project-related permits or agreements that are expected

to involve this area. The only highway in the species’ range is in Canada. Therefore, it is
highly unlikely that the proposed action will result in any truck traffic in the U.S. range of
the woodland caribou.

Northern Idaho Ground Squirrel

The current distribution of the northern Idaho ground squirrel is a very small area of
western Idaho. Only a few of the remaining occurrences are adjacent to existing U.S.
Highway 95 and State Highway 55 between New Meadows, McCall and Cascade, Idaho.
While there may be a measurable risk of vehicular impacts causing harm to northern
Idaho ground squirrels, the risk of an adverse interaction with a truck associated with the
proposed action is considered highly unlikely, and therefore, discountable because 99.5%
or more of truck traffic in the State of Idaho will be unrelated to the proposed action.

Pygmy Rabbit

Two highway corridors overlap within the very narrow range of the Columbia Basin DPS
of the pygmy rabbit: Interstate 90 and State Highway 2 run east-west through Grant,
Douglas, and Adams counties, Washington, where the species occurs. Vehicle impacts
are not a primary threat to this species, however, pygmy rabbits may be attracted to
roadside vegetation for forage and/ or shelter. There are currently no proposed project-
related permits or agreements that are likely to involve this area and, currently, there are
no known pygmy rabbits in the wild. Although there could be a potential risk of
vehicular impacts causing harm to pygmy rabbits once they become re-established in the
wild, the risk of an adverse interaction with a truck associated with the proposed action is
considered highly unlikely, and therefore, discountable because 99.5% or more of truck
traffic in the State of Washington will be unrelated to the proposed action.

Gray Wolf

Occasionally a gray wolf is observed in Washington and Oregon. Given their scarcity in
these areas, the risk that a truck associated with the proposed action will kill or injure a
gray wolf is discountable. The risk of a wolf being hit by a truck in Idaho is greater but
still highly unlikely, and therefore, discountable because 99.5% or more of truck traffic in
the State of Idaho will be unrelated to the proposed action. Currently, it is rare for a gray
wolf to be injured or killed via collisions with trucks or cars.

10
</div>

</div>
<div class="page"><p></p>
<div class="ocr">Canada Lynx

Canada lynx occurs throughout the action area for this consultation. Lynx habitat is
associated with higher elevation, isolated patches of boreal forest, and includes dispersal
areas through intervening shrub-steppe, grassland, and low elevation forested or
unforested valleys. Given the nature and location of lynx habitat, it is highly unlikely
that trucks carrying Hawaiian garbage will hit and injure or kill a lynx. Highway
mortality of lynx in lowland areas is rare. For that reason, a truck carrying Hawalian
garbage in low elevation areas in Idaho, Oregon, or Washington is highly unlikely to
encounter a lynx, especially since 99.5% or more of truck traffic in the States of Oregon,
Washington, and Idaho will be unrelated to the proposed action. For these reasons,
adverse effects to the lynx caused by the proposed action are considered highly unlikely
(L.e., discountable).

11
</div>

</div>
</body></html>