NORTH AMERICAN BUTTERFLY ASSOCIATION St. Louis Chapter January 5, 2001 By Fax to: (314) 331-8741 and Hand Delivered U. S. Army Corps of Engineers Attn: CEMVS-CO-F (Michael Ricketts) 1222 Spruce Street St. Louis, Mo. 63103-2833 Re: Corps File No. 200008910 Public Notice P-2259 Holnam, Inc./Proposed Cement Kiln, Quarry, and Harbor Dear Mr. Ricketts: The North American Butterfly Association is a national organization dedicated to the non-consumptive enjoyment of butterflies, education and conservation. NABA-St. Louis is asking the Corps of Engineers to deny the application submitted by Holnam, Inc., a U.S. subsidiary of the multinational Swiss company Holderbank Financiere Glaris. The public interest is not served by the proposed project. In addition, a federally listed endangered species of dragonfly, the Hine's Emerald (Somatochlora hineana), found in Reynolds County, Missouri, could possibly be found on the Holnam site, because its habitat is located on the Holnam site. This species is discussed in more detail below. In the alternative, NABA-St. Louis is requesting that the Corps of Engineers conduct a thorough environmental survey of the wildlife and habitat on the proposed site and study the cumulative as well as the individual impacts that this proposed project would have on habitat, wildlife (including insects in general and butterflies and dragonflies in particular), air quality and water quality, and to prepare an Environmental Impact Statement. Also in the alternative, NABA-St. Louis is requesting that the Corps of Engineers hold a public hearing on Holnam's application, so that environmental concerns, which are largely ignored in the Corps' Public Notice, can be adequately addressed in a public forum where a formal record of such concerns and objections can be made. Finally, NABA-St. Louis is requesting that the Corps of Engineers stay all activities currently being conducted by Holnam under Nationwide Permit 14 (i.e., construction of the access road and related quarrying). The site in question has never been adequately surveyed to determine the species that breed there and/or migrate through the property. A review of Holnam's application (which shall include references to the Companion Report and Wetlands Report prepared by Holnam's consultants) does not indicate what field work or field surveys were conducted, by whom such field work was conducted, nor at what times of year. There is little, if any, reference to insects, and none at all to butterflies and dragonflies. The habitat on the property is diverse: flood plain wetlands on Lee Island, wetlands along Isle du Bois Creek, upland wetlands, caves, glades, springs, streams, and seeps, ravines, and hollows, plus the incredible fact that the entire 4000 acre tract is almost entirely wooded. This site is the largest tract of contiguous forest along the Mississippi River in Missouri and the largest tract of contiguous forest in eastern Missouri outside the Mark Twain National Forest. Such diverse, pristine habitat would have a rich biodiversity. The property has not been fragmented by agriculture or development of any kind. There are no clearcuts in the forest. There is no road system (only one short gravel road exists on the entire 4000 acres). In short, it is a unique habitat, especially being located so close to a major metropolitan area. The importance of an undisturbed 4000 acre tract of land cannot be overstated. On such a tract of land will be found an abundance, in both variety and number, of nectaring plants and host plants. In addition, the site offers a wide variety of habitats so that a similarly wide variety of butterflies would be found there. Almost every butterfly species regularly found in the St. Louis area should be found on this property. A copy of the NABA-St. Louis Butterfly Checklist is enclosed. Butterflies are dependent on two types of flora: a host plant, and nectaring plants. In Missouri, our native butterflies would use the following types of host plants (this list is not exhaustive): Larval Host Plant Butterfly Species Oaks & Hickories Banded Hairstreak Oaks White M Hairstreak Rotting leaves Red-banded Hairstreak Hackberries Common Snout, Hackberry, Question Mark Elms Eastern Comma Redbud Henry's Elfin American Holly Henry's Elfin European Buckthorn Henry's Elfin Blueberries Henry's Elfin Willows Viceroy, Red-spotted Purple, Mourning Cloak Poplars Viceroy, Red-spotted Purple Plums and Cherries Viceroy, Red-spotted Purple Pawpaws Zebra Swallowtail Pipevine Pipevine Swallowtail Spicebush Spicebush Swallowtail Sassafras Spicebush Swallowtail Parsley Family Black Swallowtail Prickly Ash & Hoptree Giant Swallowtail Wild Black Cherry Tiger Swallowtail Tulip Tree Tiger Swallowtail Sunflowers Gorgone Checkerspot, Silvery Checkerspot Asters Pearl Crescent Milkweeds Monarch Violets Great Spangled Fritillary Plantains Buckeye Gerardias Buckeye Thistles Painted Lady Nettles Red Admiral, Eastern Comma Sennas Sleepy Orange, Cloudless Sulphur False Indigo, Lead Plant Southern Dogface Rock Cresses Olympia Marble, Falcate Orangetip Docks American, Bronze and Gray Copper Grasses Skipper species in general (Sources: Butterfly Gardening and Conservation, Dave Tylka, Missouri Dept. of Conservation pamphlet, one of which is enclosed; Butterflies through Binoculars: the East, Jeffrey Glassberg, 1999). Skippers, a large family of butterflies, are in decline. Skippers breed on grasses. The presence of an undisturbed 4000 acre tract is likely to have an abundant and thriving population of skippers. That would be exceedingly rare for the metropolitan St. Louis area, where skippers have decreased dramatically as a result of habitat loss and pesticides/herbicides. In addition, Duke's Skipper, which we have located in only one spot in the metropolitan St. Louis area, may be present, because its habitat is wetlands. Other wetlands butterfly species would be Dion Skipper, American Copper and Bronze Copper, all of which are increasingly difficult to find in the St. Louis area because wetlands are fast disappearing. Some butterfly species have short flights only once a year, such as Falcate Orangetip, Olympia Marble, and Henry's Elfin, which fly in the early spring. Other butterfly species are multi-brooded. To conduct a thorough survey of butterfly species on the site, it would be necessary to check the site weekly or bi-weekly from mid-April through mid-October. There is one federally listed Endangered Species of dragonfly that could be found on the site: Hine's Emerald (Somatochlora hineana). Until recently, it was thought to inhabit only four states: Illinois, Indiana, Ohio and Wisconsin. A diligent search for dragonfly species throughout Missouri by Linden Trial, an employee of the Missouri Department of Conservation, revealed a Hines Emerald in Reynolds County, very close to Ste. Genevieve County. That information came to light after the dragonfly was declared endangered by the Fish & Wildlife Service on January 26, 1995. 1 The Hines' Emerald is a dragonfly that inhabits wetlands and streams in the vicinity of LIMESTONE BEDROCK. As Holnam makes abundantly clear in its Companion Report, there is a large quantity of limestone bedrock on the property, as well as wetlands and a rich water system including Isle du Bois Creek, springs, streams, and seeps. This adds up to the perfect habitat for Hine's Emerald. The Holnam property is the perfect habitat needed by the Hine's Emerald: Seasonally dry marshy fens, with sheets of water seeping through plants, especially spring-fed seepages over limestone bedrock, often shown by marl (calcium carbonate) deposits. Narrow-leaved cattails or sedges and stonewort algae often present. (Dragonflies through Binoculars: A Field Guide to Dragonflies of North America, Sidney W. Dunkle, 2000, p. 161). According to the U.S. Fish and Wildlife Service, the habitat of Hines Emerald in Illinois consists of "wetlands with small, calcareous or underlying limestone bedrock, and shallow, spring-fed streams that drain into wet meadows and cattail marshes." (Final Rule of the Dept. of the Interior for Hine's Emerald, Federal Register, January 26, 1995 (Vol. 60, No. 17) at p. 2 - enclosed.) Its habitat in Wisconsin was described as "small, calcareous, marshy streams and associated cattail marshes on dolomite bedrock." (Final Rule, p. 2.) The Companion Report and the Wetlands Report submitted by Holnam establish that the 4,000-acre site in question contains limestone, wetlands, marshes, spring-fed streams, wet meadows, and dolomite glades - all appropriate habitat for the Hine's Emerald. Without doubt, the Holnam site could be classified as CRITICAL HABITAT for this endangered species. In addition, it should be noted that the life cycle of the Hine's Emerald is linked with the crayfish species Cambarus diogenes. It is believed that the larvae of this dragonfly live in holes dug by Cambarus diogenes and that the larvae co-exist with this particular species of crayfish. Therefore, Cambarus diogenes, as well as Hine's Emerald, should be specifically looked for in any environmental survey. Hine's Emerald flies from late May to early September. (Dunkle, p. 161.) According to the U.S. Fish and Wildlife Service, "[t]he greatest threat to the species in Illinois and Wisconsin is habitat destruction and degradation." (Final Rule, p. 7.) The agency then goes on to note: The stream and aquatic habitat of the Hine's emerald dragonfly is within the jurisdiction of the Clean Water Act . . . . Section 404 of the Clean Water Act, which is administered by the U. S. Army Corps of Engineers in conjunction with the U. S. Environmental Protection Agency, established a regulatory program to protect waters of the United States from the adverse effects of filling. . . . (Final Rule, p. 7.) Holnam is asking the Corps to grant a 404 permit so that Holnam can destroy federally protected wetlands. Because those wetlands, Isle du Bois Creek, and the related water system on the Holnam site provide appropriate habitat for the Hine's Emerald, an endangered species found just two counties away, the Corps should deny the 404 permit. Enclosures: The following documents are being submitted along with NABA-St. Louis's public comment: 1. Excerpt about Hine's Emerald from Dragonflies through Binoculars, Sidney W. Dunkle, 2000, cited above. 2. Fact Sheet about Hine's Emerald, U. S. Fish & Wildlife Service. 3. Final Rule of the Dept. of the Interior for Hine's Emerald, Federal Register, January 26, 1995 (Vol. 60, No. 17). 4. "Pond Dragons", Linden Trial, Missouri Conservationist, July 2000. 5. Butterfly Gardening and Conservation, Dave Tylka, Missouri Department of Conservation pamphlet. 6. Butterfly Checklist - St. Louis Area, Jim Ziebol & Yvonne Homeyer, NABA-St. Louis, May 2000. 7. Table 1, "Some Caterpillar Foodplants" from Butterflies through Binoculars: the East, Jeffrey Glassberg, 1999. 8. Excerpt on "Conservation" from Butterflies through Binoculars: the East, Jeffrey Glassberg, 1999. We ask that this letter and the accompanying enclosures be made part of the public record on the Holnam application. Thank you for considering our comments. Very truly yours, Yvonne Homeyer, President St. Louis Chapter, North American Butterfly Association (NABA-St. Louis) 1508 Oriole Lane St. Louis, Mo. 63144 (314) 963-7750 home (314) 863-3321 office cc: Sen. Jean Carnahan Sen. Kit Bond Rep. Richard Gephardt Governor Bob Holden By Fax to (573) 522-6589 Mr. Rick Hansen U.S. Fish and Wildlife Service, Columbia, Mo. By Fax to (573) 876-1914 Dr. Paul McKenzie U.S. Fish and Wildlife Service, Columbia, Mo. By Fax to (573) 876-1914 Ms. Venessa Madden EPA Region 7 By Fax to (913) 551-7066 Mr. Joe Bachant Missouri Department of Conservation By Fax to (573) 526-4495 Mr. Gary Christoff Missouri Department of Conservation By Fax to (573) 526-4495 Mr. Stephen Mahfood, Director Department of Natural Resources By Fax to (573) 751-7627 Ms. Kyra Moore Air Pollution Control Program, DNR By Fax to (573) 751-2706 Ms. Linda Vogt Water Pollution Control Program, DNR By Fax to (573) 526-1146 1Linden Trial should be contacted for further information about this endangered dragonfly species. (Her article about dragonflies of Missouri, "Pond Dragons", Missouri Conservationist, July, 2000, is enclosed with this public comment.) -7-