August 26, Dear Ms. Tharratt:

Transcription

1 August 26, 2013 Ms. Susie Tharratt Recovery Permit Coordinator Carlsbad Fish and Wildlife Office 2177 Salk Avenue, Suite 250 Carlsbad, California Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch, City of Newport Beach and Unincorporated Orange County, Orange County, California. Permit Number TE Dear Ms. Tharratt: This report is intended to fulfill reporting requirements in accordance with the Section 10(a)(1)(A) permit and also to provide a summary of focused trapping surveys for the Pacific pocket mouse (Perognathus longimembris pacificus [PPM]) for the Newport Banning Ranch property (Project Site). This report includes the survey methods and results; Figures (Appendix A); Photo Plates (Appendix B); and U.S. Fish and Wildlife Service Correspondence and Telephone Conversation Dates (Appendix C). Dudek wildlife biologist Philippe J. Vergne (permit number TE ) submitted a Notification of Pacific Pocket Mouse Surveys Newport Banning Ranch Project, Orange County, California to U.S. Fish and Wildlife Service (USFWS) Carlsbad office recovery permit coordinator Ms. Susie Tharratt on June 6, Survey approval was received from the USFWS Carlsbad office via from Ms. Susie Tharratt on the same date. This report documents the results of focused trapping surveys for PPM for the Newport Banning Ranch propoerty, located in the City of Newport Beach and unincorporated Orange County, California. The surveys were performed by Dudek wildlife biologist Philippe J. Vergne (permit number TE ). Surveys focused on the determination of presence/absence for the federally listed endangered Pacific pocket mouse (Perognathus longimembris pacificus) in accordance with the permit protocol. A total of 621 traps were set within five areas throughout the approximately 401-acre

2 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch Project Site. Non-listed North American deermouse (Peromyscus maniculatus), Western harvest mouse (Reithrodontomys megalotis), and roof rat (Rattus rattus) were detected. PROJECT LOCATION The Project Site is located in the City of Newport Beach and unincorporated Orange County, California, on the southwestern boundary of the City of Costa Mesa and east of the City of Huntington Beach, Appendix A Figure 1. The Project Site is bordered by commercial and residential development in the City of Costa Mesa on the east, the Pacific Coast Highway and residential properties within the City of Newport Beach on the south, the Santa Ana River and the U.S. Army Corps of Engineers (USACE) wetlands restoration area on the west, and Talbert Regional Park on the north. The Pacific Ocean is 289 meters (947 feet) to the southwest of the Project Site at its closest point. The Project Site is located on the U.S. Geological Survey (USGS) 7.5 minute map, Newport Beach quadrangle, in section 1 of Range 10 West and Township 6 South, Appendix A Figure 1. The entire Project Site, which comprises approximately 401 acres, is situated on the western edge of a coastal terrace overlooking the Santa Ana River, with adjacent bluffs, arroyos, and lowlands that include a floodplain and tidal influence channel and associated wetlands. EXISTING CONDITIONS Currently, the entire Project Site is occupied by an oil facility operated by West Newport Oil Company. The lowlands occupy mostly the northwestern portion of the Project Site, adjacent to the Santa Ana River and the U.S. Army Corps of Engineers (USACE) wetlands restoration area. The topography within the survey area is generally flat level to gently sloping ground. According to the U.S. Department of Agriculture Natural Resource Conservation Service (NRCS 2012), upland soils within the Project Site are predominantly well-drained loams of the following series: Bolsa Silt loam; Capistrano sandy loam, 9 15% slopes; Marina loamy sand, 2 9% slopes; Myford sandy loam, 0 2% slopes; Myford sandy loam, 2 9% slopes; and Myford sandy loam, 2 9% slopes, eroded (NRCS 2012). Fifty-four vegetation communities or land covers were identified on the proposed Project Site by Dudek (2012) in earlier surveys. These communities include native upland communities, riparian and wetland communities, and non-native land covers or communities. Vegetation within PPM survey areas were disturbed annual grasslands with sparse remnant scrub. 2 August 2013

3 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch BACKGROUND INFORMATION Pacific Pocket Mouse The pacific pocket mouse (PPM) is a federally endangered species and a California state species of special concern that is endemic to coastal southern California (USFWS 2010 and CDFG 2011). The species was thought to have been extinct since the last sighting was in The species was rediscovered in 1993 when a population of 25 to 36 individuals was found at the Dana Point Headlands, Orange County, California (Brylski 1993) and the species was emergency listed as endangered by the U.S. Fish and Wildlife Service (USFWS 2010). PPM is one of 16 recognized subspecies of the little pocket mouse (Perognathus longimembris; Williams et al. 1993). The breeding season extends from the beginning of April to the end of August, but this is highly dependent on temperature and rainfall (U.S. Marine Corps [USMC] 2007). PPM is restricted to the coastal plain and historically was found between El Segundo in Los Angeles County and the Tijuana River Valley on the U.S. and northern Baja California, Mexico. It has been reliably recorded within 2.5 miles of the coast (USFWS 2010). The closest documented historical and current records for PPM relative to the Newport Banning Ranch site are: Spyglass Hill in Newport Beach approximately 5 miles southeast of Newport Banning Ranch, which was developed in 1972; the Clifton/Wilmington area in Los Angeles County approximately 23 miles northwest of Newport Banning Ranch; and Dana Point Headlands approximately 18 miles southeast of Newport Banning Ranch (USFWS 2010). As of 2010, at least 82 PPM assessments have been conducted from Los Angeles County south to the U.S./Mexico border since it was emergency listed in 1992 and only the four sites noted above are currently known to have extant populations. PPM was thought to mostly occur in fine, sandy soils within coastal scrub, coastal strand, coastal dunes, and river alluvium (USFWS 2010). However, it has been found in a broader range of soils, including loamy sand, sandy loam, loam, clay loam, and terrace escarpments where fine sandy soils were not available (USFWS 2010). It appears to occur in areas with moderate shrub cover, but also with some openness for foraging (USFWS 2010). The density of the herbaceous cover (grasses and forbs) at ground level, however, may be a more important factor for PPM occurrence than density of shrub cover, with the species avoiding areas with dense grasses and forbs (USFWS 2010). 3 August 2013

4 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch PPM individuals have been observed to be most active on the surface (and thus detectable through live-trapping) during the months of April through mid-september. However, their surface activity periods can be quite variable from year to year and site to site. Summer dormancy has been observed as early as mid-june and July, and may be related to low precipitation and associated low plant and seed production (USFWS 2010). For this reason, detectability can also vary. PPM feed primarily on the seeds of grasses and forbs, occasionally eating vegetation and insects. The species has a high metabolic rate and caches seeds in burrows for use during winter hibernation. Hibernation generally lasts from September through April. PPM will feed on cached seeds during periods of hibernation in contrast to storing fat. The primary cause of this species decline is attributed to the cumulative loss of appropriate habitat and isolation of fragmented meta-populations due to urban and agricultural development (Spencer 2005). PREVIOUS PPM STUDIES ON NEWPORT BANNING RANCH LSA Associates, Inc. conducted small mammal live-trapping on the Newport Banning Ranch in June (3 consecutive nights) and September (2 consecutive nights) in 1995 totaling 1,522 trap nights (Erickson 1995). Traplines were concentrated in the upland portions of the Project Site. Five rodent species were captured, including Western harvest mouse (Reithrodontomys megalotis; 22 captures), North American deermouse (Peromyscus maniculatus; 112 captures), cactus deermouse (Peromyscus eremicus; 1 capture), roof rat (Rattus rattus; 6 captures), and house mouse (Mus musculus; 12 captures), the latter two of which are non-native, invasive species associated with urban development. Both the Western harvest mouse and North American deermouse are also common in urbanized areas. PPM was not trapped, and notably, the California pocket mouse (Chaetodipus californicus), which is fairly common in coastal scrub in Orange County, was not captured. Erickson (1995) indicated in the 1995 report, that surveys for PPM in 1990 were also negative. METHODOLOGY Habitat Assessment The areas identified as having PPM potential were walked and field reviewed by USFWS representatives William B. Miller and Christine Medak of the USFWS, and Dudek project coordinator ecologist for the Newport Banning Ranch John Davis IV, and Philippe J. Vergne on May 6, Based on the habitat conditions (i.e. vegetation and soils) examined during the survey and input from the USFWS, a focused trapping methodology was derived and submitted 4 August 2013

5 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch to the USFWS for approval. The trapping methodology eventually underwent modifications and was approved by the USFWS prior to initiation of surveys. correspondence and telephone conversation dates are provided in Appendix C. A reconnaissance-level survey of the Project Site was conducted by Dudek biologist Phil Behrends, Ph.D. for suitable habitat for the PPM. Dr. Behrends possesses a state of California Memorandum of Understanding and possessed a federal permit (TE ) authorizing work on the PPM. Dr. Behrends is a mammal specialist with 34 years of experience with heteromyid rodents (pocket mice and kangaroo rats) and a recognized expert by the USFWS. The reconnaissance survey was conducted on July 23, Since the Project Site is approximately 400 acres in size, the reconnaissance survey entailed inspecting representative areas of the Project Site that, based on vegetation communities, have at least some potential to support the PPM, including open coastal scrubs, grassland, and ruderal communities underlain by sandy loam soils (Dudek 2012a). Based on the survey the vegetation communities most suitable for PPM on the Project Site are annual grassland and disturbed scrubs on gentle slopes, and most of the on-foot inspection was spent in these communities. Two areas were identified has having relatively higher potential for PPM; sites B and C identified in Appendix A Figure 2. Soils Soils in all trapping locations were sandy loam. Vegetation Vegetation in all areas was dominated by disturbed annual grasslands with remnant areas of scrub. The scrub is composed of sparse to moderately dense coastal sage scrub. Dominant species in these vegetation communities are red brome (Bromus madritensis ssp. rubens), common Mediterranean grass (Schismus barbatus), longbeak stork s bill (Erodium botrys), soft brome (Bromus hordeaceus), rat-tail fescue (Festuca myuros), clustered tarweed (Deinandra fasciculata), wild oat (Avena fatua), black mustard (Brassica nigra), coastal sagebrush (Artemisia californica), Eastern Mojave buckwheat (Eriogonum fasciculatum), coyotebrush (Baccharis pilularis), and common deerweed (Acmispon glaber). Selection of Trapping Areas 5 August 2013

6 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch Per the surveys described above and the site visit and acceptance of the trapping methodology by the USFWS all the areas with potential for PPM occupancy on site were trapped. Qualifications and Permits of PPM Biologist Philippe J. Vergne holds a U.S. Fish and Wildlife Service permit to trap and handle the Pacific pocket mouse (Perognathus longimembris pacificus), Stephens kangaroo rat (Dipodomys stephensi) and San Bernardino kangaroo rat (Dipodomys merriami parvus), and to conduct field studies on sensitive small mammals in Southern California (TE ), a California Department of Fish and Wildlife (CDFW) Memorandum of Understanding for above mentioned species and the Mohave ground squirrel (Spermophilus (Xerospermophilus) mohavensis), Los Angeles pocket mouse (Perognathus longimembris brevinasus), Palms Springs pocket mouse (Perognathus longimembris bangsi), Palm Springs ground squirrel (Spermophilus tereticaudus chlorus), white-eared pocket mouse (Perognathus alticola alticola), Jacumba pocket mouse (Perognathus longimembris internationalis), north-western San Diego pocket mouse (Chaetodipus fallax fallax), and Dulzura pocket mouse (Chaetodipus californicus femoralis), and a CDFW collection permit. Trapping Methodology Focused surveys for PPM were conducted by Philippe J. Vergne, according to USFWS protocols. The current protocol calls for five nights of trapping per sample area, conducted when the animal is active above ground (at night), unless the targeted animal is captured (USFWS 1998). Based on informal consultation with the USFWS and the site visit the following areas and trapping densities were targeted for the protocol PPM survey on the Project Site, as shown in Appendix A Figure 2. Due to the number of traps required, two 5-day trapping sessions were required. The two 5-night trapping sessions were conducted between July 18 and July 28, A total of ten nights of trapping, or 3,105 trap nights, was expended in order to survey the 6.75 acres of potential PPM habitat within Areas A through E. Trapping density averaged 92 traps per acre. Focused surveys followed the provisions and protocols stated in Philippe J. Vergne s Endangered and Threatened Species Permit TE issued by the USFWS and CDFW Memorandum of Understanding and collection permit. These provisions and protocols are summarized as follows: 1. PPM shall be held for up to 10 minutes and then released at the capture site. 6 August 2013

7 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch 2. All traps shall be located in areas that best typify PPM habitat. 3. Trapping shall continue for a minimum of five consecutive nights, unless the targeted species are captured inch specially modified Sherman live traps will be used. Traps shall be checked twice per night, once at midnight and once at sunrise. 5. Trapping shall not occur if the nightly low temperature is forecast to be below 50 degrees Fahrenheit and/or if extended wind, rain, fog, or other inclement weather make (or have made) conditions unsuitable for trapping, or unduly jeopardize the lives of PPM. 6. PPM shall not be marked by mutilation (toe-clipping, ear clipping) or invasive techniques (PIT-tagging), or by other marking schemes as the purpose of the surveys is to determine presence or absence, not re-capture rates. 7. The Carlsbad USFWS office shall be notified within 48 hours if a previously unknown population of PPM is discovered. 8. PPM shall not be translocated. Trapping Areas At all sites, traps were placed approximately seven meters apart, in a grid fashion, throughout suitable PPM habitat. Traps were set prior to sunset, checked twice and closed or removed during the sunrise trap check. The areas surveyed and sites selected for trapping are summarized in Table 1, and shown in Figure 2. 7 August 2013

8 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch Table 1 Selected Pacific Pocket Mouse Trapping Areas Site Location Site Acreage Number of Traps A B C D E TOTAL RESULTS No PPM was captured, nor PPM sign observed on Newport Banning Ranch. Results of the focused trapping survey are provided in Table 2. Table 2 Focused Trapping Results for the Newport Banning Ranch Trapping Survey Number of Traps Number of Days Trapped Number of Trap Nights PEMA REMA RARA Trap Area A 86 5 (session 2) B (session 1) 1, C 65 5 (session 2) D 82 5 (session 2) E 55 5 (session 2) TOTAL , NOTES: M- = mammal PEMA = North American deermouse (Peromyscus maniculatus) REME = Western harvest mouse (Reithrodontomys megalotis) RARA = black rat (Rattus rattus) CONCLUSION Based on the results of this trap survey, previous trapping efforts, marginal to poor quality habitat on-site for PPM, and the distance to the nearest known occurrence, PPM are determined to be absent from the Project Site. 8 August 2013

9 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch No PPM were captured during the course of the current survey nor during the previous surveys and the areas that were trapped were the only ones that were thought to have some potential by the USFWS. The project footprint is not currently occupied by PPM. There will be no impacts to PPM occupied habitat due to project implementation. No PPM were captured by LSA and this more recent and focused survey also did not find PPM; therefore, the likelihood that PPM occurs on site given survey results and location to known habitat (urban habitat between the two site), there is no very little (or no) chance that PPM would naturally recolonize this site. No future surveys shall be required. CERTIFICATION Banning Ranch Trapping Survey I hereby certify that the statements furnished above and in the attached exhibits present data and information required for this biological evaluation, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief. This report was prepared in accordance with professional requirements and recommended protocols for small mammal trapping studies. Sincerely, Philippe J. Vergne Wildlife Biologist Att.: Appendix A Figures Appendix B Photo Plates Appendix C U.S. Fish and Wildlife Service Data Sheets Appendix D U.S. Fish and Wildlife Service Correspondence and Telephone Conversation Dates cc: Michael Mohler, Newport Banning Ranch LLC 9 August 2013

10 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch LITERATURE CITED Behrends, P Pacific Pocket Mouse Habitat Assessment for Newport Banning Ranch. Dudek. Brylski, P A focused survey for the Pacific pocket mouse (Perognathus longimembris pacificus) on the Dana Point Headlands, Orange County, California. Prepared for EDAW, Inc., Irvine, California. CDFG (California Department of Fish and Game) Special Animals List. Biogeographic Data Branch California Natural Diversity Database. January Dudek 2012a. Grassland Assessment and Vegetation Mapping Survey Report for the Newport Banning Ranch. Dudek 2012b. Pacific Pocket Mouse Habitat Assessment for Newport Banning Ranch. Prepared for Michael Mohler, Newport Banning Ranch, LLC. September 25, EDAW (EDAW, Inc.) day summary report of focused surveys for the Pacific pocket mouse (Perognathus longimembris pacificus) for the Marine Corps Base Camp Pendleton Programmatic Sites Grow-the-Force Project. ENVIRA (ENVIRA Consulting) Focused Presence/Absence Surveys for the federally listed endangered Pacific Pocket Mouse (Perognathus longimembris pacificus) and Stephens Kangaroo Rat (Dipodomys stephensi) for the Grow the Force Permanent Bed- Down Facilities Project on Marine Corps Base Camp Pendleton, San Diego County, California. September. Erickson, R Banning Ranch Rodent Trapping. Letter report prepared by LSA Associates, Inc. for Leonard Anderson. Meserve, P. L Habitat and resource utilization by rodents of a California coastal sage scrub community. Journal of Animal Ecology 46: Montgomery, S. J Results of habitat assessment and live-trapping survey for the federally endangered Pacific pocket mouse (Perognathus longimembris pacificus) at the 47.7-acre Ramblas de las Flores site, in Rancho Santa Fe, California. Prepared for Crown Taylor, Las Vegas, Nevada. 10 August 2013

11 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch Montgomery, S. J Trapping and habitat assessment for the Pacific pocket mouse (Perognathus longimembris pacificus) in the North Torrey Pines Bridge Replacement Project Area, San Diego County, California. Prepared for Lettieri-McIntyre and Assoc., San Diego, CA. Spencer, W. D Recovery research for the endangered Pacific pocket mouse: an overview of collaborative studies. USDA Forest Service General Technical Report PSW-GTR-195. Spencer, W. and C. Schaefer Pacific pocket mouse studies program: phase I report. Prepared for the Foothill/Eastern Transportation Corridors Agency and U.S. Fish and Wildlife Service, 64 pp + Appendices. USFWS (U.S. Fish and Wildlife Service) Pacific Pocket Mouse (Perognathus longimembris pacificus) 5-Year Review: Summary and Evaluation. Carlsbad Fish and Wildlife Office Carlsbad, California. URS (URS Corporation) Pacific Mouse 5-Year Distribution Survey for Camp Pendleton Marine Corps Base Edson Range USDA-NRCS (United States Department of Agriculture-National Resources Conservation Service) Web Soil Survey. National Cooperative Soil Survey. Accessed USGS (U.S. Geological Survey) and Pacific Pocket Mouse Surveys and Monitoring Plan for Camp Pendleton Marine Corps Base. USMC (U.S. Marine Corps) Integrated Natural Resources Management Plan, Marine Corps Base Camp Pendleton. March. Vergne, P. J Trapping studies for federally endangered Pacific Pocket Mouse (PPM) on Camp Pendleton Marine Corps Base for Double Track Project. Vergne, P. J Trapping studies for federally endangered Pacific Pocket Mouse (PPM) on Camp Pendleton Marine Corps Base for BMI Project Iron Mountain. Vergne, P. J Trapping studies for federally endangered Pacific Pocket Mouse (PPM) on SFNS Railroad Right of Way. 11 August 2013

12 Recovery Permit Coordinator Subject: 90-Day Protocol Survey Report for the Federally-Listed Pacific Pocket Mouse on the Newport Banning Ranch Vergne, P. J Assessment for Pacific Pocket Mouse and Stephens Kangaroo Rat Along San Luis Rey River, San Diego County, California. Vergne, P. J Assessment for Pacific Pocket Mouse INS Border Project, San Diego County, California. Vergne, P. J Trapping studies for federally endangered Pacific Pocket Mouse (PPM) on Camp Pendleton Marine Corps Base. Williams et al. (Williams, D.F., H.H. Genoways, and J.K. Braun) Taxonomy. In Biology of the Heteromyidae, edited by H.H. Genoways and J.H. Brown, Special Publication No. 10 of the American Society of Mammalogists. 12 August 2013

13 APPENDIX A Figures

14 Project Site? 55? 1 Date: 8/27/ Created by: slucarelli - Last saved by: slucarelli - Path: \\dudek-files\gisdata\projects\j01\mapdoc\maps\pocket Mouse\Fig1_Project_Vicinity.mxd ³ 1 L o s A n g e l e s O r a n g e Feet 0 1,000 2,000 S a n B e r n a r d i n o R i v e r s i d e inch = 2,000 feet S a n D i e g o Service Layer Credits: Copyright: 2013 National Geographic Society, i-cubed Copyright: 2013 Esri NEWPORT BANNING RANCH Figure 1 Site Location 2013 Pacific Pocket Mouse Trapping Survey

15 Banning Ranch Oil Field Joint Ownership Oil Facilities Areas Not Subject to Oil Field/Site Vegetation Maintenance Program Trap Area A Acres B Acres C Acres D Acres E Acres Traps by Area A - 86 Traps B Traps C - 65 Traps D - 82 Traps Date: 8/27/ Created by: slucarelli - Last saved by: slucarelli - Path: \\dudek-files\gisdata\projects\j01\mapdoc\maps\pocket Mouse\Fig2_Proposed_Trapping_PPM.mxd E - 55 Traps ³ 0 Feet inch = 207 feet SOURCE: Dudek (2013) Aerial provided by Fusco Engineering NEWPORT BANNING RANCH Figure 2 Trapping Locations for the Pacific Pocket Mouse 2013 Pacific Pocket Mouse Trapping Survey

16 APPENDIX B Photo Plates

17 Appendix B Photo Plates Newport Banning Ranch Overview of Trapping Area A Newport Banning Ranch Overview of western edge of Trapping Area B B-1 August 2013

18 Appendix B Photo Plates Newport Banning Ranch Overview of Trapping Areas C and D Newport Banning Ranch Looking towards Trapping Area E from C B-2 August 2013

19

20 APPENDIX C U.S. Fish and Wildlife Service Correspondence and Telephone Conversations

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22 Page 1 of 1 8/26/2013 MailMeter Archive - Individual Search and Retrieval From: philippe vergne Sent: Thursday, June 06, 2013, (7:56:04 AM) To: john davis Received: Thursday, June 06, 2013, (7:55:52 AM) Cc: Bcc: Subject: Attachments: Fwd: PPM -----Original Message----- From: Philippe Vergne < phvergne@aol.com> To: susie_tharratt < susie_tharratt@fws.gov> Sent: Thu, Jun 6, :55 am Subject: Re: PPM Attached is the 10 day notification for the Huntington Beach PPM trapping. I was waiting from a response from Will on methodology prior to sending you the request Original Message----- From: Tharratt, Susie < susie_tharratt@fws.gov > To: Miller, William < william_b_miller@fws.gov > ; Philippe Vergne < phvergne@aol.com > Cc: Jonathan Snyder < jonathan_d_snyder@fws.gov > ; Christine Medak < christine_medak@fws.gov > Sent: Thu, Jun 6, :38 am Subject: Re: PPM Will and Philippe, Thank you for coordinating regarding Newport Banning Ranch site and the proposed trapping under the 10(a)(1) (A) permit, TE I am requesting that Philippee submits via separate to me the 15-day n otification to conduct activities pursuant to this permit at specific location. This makes a more clean and clear record. The notice should include approximate dates, number of trap nights and personnel, and reference the appropriate TE number/s, in addition to providing the required map, and brief description of methodology to be used. Philippe can begin trapping prior to the 15-day period, as Will Miller of the CFWO has already provided concurrence on the proposed trapping plan. Thank you. Susie Search criteria: