DRAFT ENVIRONMENTAL ASSESSMENT

Issuance of a Right-of-Way Permit for a 0.5-Mile Road Segment to Annova LNG Common Infrastructure, LLC

Boca Chica Tract Lower Rio Grande Valley National Wildlife Refuge Cameron County, Texas 78521

August 2019

Table of Contents

1.0 PURPOSE OF AND NEED FOR PROPOSED ACTION ...... 1 Introduction ...... 1 Location ...... 1 Background ...... 1 Refuge Overview ...... 1 Description of the Existing Access Road through Refuge Property ...... 3 Consultation between the Service and Annova...... 3 Purpose of the Action ...... 4 Need for the Action ...... 6 Regulatory Compliance ...... 8 Scoping/Public Involvement ...... 10 2.0 DESCRIPTION OF ALTERNATIVES...... 10 2.1 Alternative A – No Action - Deny the Permit ...... 13 2.2 Alternative B – Proposed Action - Issue the Permit ...... 16 3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...... 18 3.1 Physical Environment ...... 19 3.2 Biological Environment ...... 26 3.3 Human Environment ...... 36 3.4 Assessment of Cumulative Impacts...... 38 3.5 Environmental Justice ...... 39 3.6 Indian Trust Assets ...... 39 3.7 Unavoidable Adverse Effects ...... 39 3.8 Irreversible and Irretrievable Commitment of Resources ...... 39 3.9 Summary of Environmental Consequences ...... 40 4.0 CONSULTATION, COORDINATION, AND DOCUMENT PREPARATION ...... 41 5.0 REFERENCES ...... 41

Figures

Figure 1. Location of Existing Access Road ...... 2 Figure 2. Access Road Alternatives Identified for Detailed Analysis ...... 5 Figure 3. Land Ownership ...... 7 Figure 4. Proposed Access Road Cross-Section ...... 12 Figure 5. Mapped Soil Types within Access Road Survey Corridors ...... 21 Figure 6. Waters of the U.S. within Access Road Survey Corridors ...... 24 Figure 7. Habitat Types within Access Road Survey Corridors ...... 28

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas ii

Tables

Table 1. Potential Impacts to Waters of the U.S...... 25 Table 2. Mapped Habitat Types ...... 26 Table 3. Potential Impacts to Habitat Types for Alternative A – No Action ...... 29 Table 4. Potential Impacts to Habitat Types along Alternative B – Proposed Action ...... 30 Table 5. Listed and Candidate Species within the Survey Corridors ...... 31 Table 6. Community Profile for Access Road Vicinity ...... 37 Table 7. Summary of Environmental Effects by Alternative ...... 40

Acronyms and Abbreviations

Acronym or Definition or Meaning Abbreviation Annova LNG Brownsville A, LLC; Annova LNG Brownsville B, Annova LLC; and Annova LNG Brownsville C, LLC (collectively) B&A Blanton & Associates, Inc. BND Brownsville Navigation District BSC Brownsville Ship Channel CFR Code of Federal Regulations DMPA Dredged material placement area EA Environmental Assessment FERC Federal Energy Regulatory Commission FERC application Application for Authorization Under Section 3 of the Natural Gas Act LNG Liquefied natural gas LNG Project Annova LNG Brownsville Project LOD Limits of disturbance mmhos/cm milliMhos per centimeter NEPA National Environmental Policy Act NHL National Historic Landmark NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NRHP National Register of Historic Places NWR National Wildlife Refuge Refuge System National Wildlife Refuge System refuge Lower Rio Grande Valley National Wildlife Refuge Service United States Fish and Wildlife Service SH State Highway SHPO State Historic Preservation Officer THC Texas Historical Commission TPWD Texas Parks and Wildlife Department USACE United States Army Corps of Engineers U.S.C. United States Code

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas iii

1.0 PURPOSE OF AND NEED FOR PROPOSED ACTION

Introduction

The United States Fish and Wildlife Service (Service) is proposing the issuance of a right-of-way (ROW) permit for construction and use of an access road on the Boca Chica Tract of the Service’s Lower Rio Grande Valley National Wildlife Refuge (NWR or refuge) in Cameron County, Texas to Annova Liquefied Natural Gas (LNG) Common Infrastructure, LLC; Annova LNG Brownsville A, LLC; Annova LNG Brownsville B, LLC; and Annova LNG Brownsville C, LLC (collectively, Annova). If approved, this request for a 25-year term ROW permit would be processed in accordance with 50 CFR § 29.21. In addition, a special use permit (SUP) would be issued for short-term road construction activities. The proposed project is the construction, and use of a road segment on the refuge as part of the main access route for construction and operation of the proposed Annova LNG Brownsville Project (LNG Project).

Location

The existing access road is located off State Highway (SH) 4, approximately 6.5 miles east of the U.S. Border Patrol Fort Brown Checkpoint Facility (25.9623°N, -97.2837°W) (WGS84). From SH 4, the road extends northward for approximately 0.5 miles across Service property on the Boca Chica Tract of the refuge, and then continues on Brownsville Navigation District (BND) property for approximately 2.5 miles to Annova’s LNG Project site, the Brownsville Ship Channel (BSC), and various dredged material placement areas (DMPAs). Figure 1 shows the location of the existing unpaved access road between SH 4 and the LNG Project site and the BSC.

Background

This Environmental Assessment (EA) is being prepared to evaluate the effects associated with the Service’s proposal to issue a ROW permit to allow Annova to improve, and use an existing access road through the refuge, and complies with the National Environmental Policy Act (NEPA) in accordance with Council on Environmental Quality regulations [40 Code of Federal Regulations (CFR) 1500-1509], and Department of the Interior (516 DM 8) and Service (550 FW 3) policies. See the regulatory compliance section below for a list of additional regulations with which this EA complies.

Refuge Overview Refuge history can be found in the Service’s Final Lower Rio Grande Valley and Santa Ana National Wildlife Refuges Comprehensive Conservation Plan (Service 1997). The refuge was established in 1979 when the Service initiated a long-term program of acquiring Lower Rio Grande Valley lands for inclusion in the National Wildlife Refuge System (Refuge System). The program was designed to protect existing native habitats and to reclaim acquired agricultural lands in order to re-establish a riparian corridor for plants and wildlife. Land acquisition continues to be the emphasis for the Lower Rio Grande Valley NWR land protection program. Of the 132,500 acres proposed for acquisition, over 90,000 acres are currently under refuge management in more than 125 tracts.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 1

Figure 1. Location of Existing Access Road Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 2

The stated purpose of the refuge is “...for the development, advancement, management, conservation, and protection of fish and wildlife resources...” [16 U.S. Code (U.S.C.) 742f(a)(4)]; and “...for the benefit of the United States Fish and Wildlife Service, in performing its activities and services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, or condition of servitude...” [16 U.S.C. f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. 742(a)-754, as amended)].

The refuge’s Boca Chica Tract encompasses over 11,000 acres, extending inland from Boca Chica Beach on the Gulf of Mexico westward for approximately 10 miles along the Rio Grande and SH 4. This tract, as well as adjacent areas, support important wildlife habitats that include coastal salt prairie, beachfront and dunes, saline flats, mangrove marshes, shallow bays, and lomas (clay dunes) covered in thornshrub vegetation (Service 2017b).

Description of the Existing Access Road through Refuge Property The existing access road off SH 4 is an unpaved, packed dirt road that ranges from approximately 30 to 50 feet wide and extends for 0.5 miles (2.5 acres) through refuge property. Along the route are areas wider than 50 feet where disturbances such as equipment and materials storage have occurred. The access road is maintained by grading multiple times each year, particularly after rainfall events that make the road muddy and difficult to travel. Low areas in the road are filled periodically with caliche, and fill material is frequently stockpiled near the SH 4 entrance.

The existing access road is closed to public vehicle traffic by a locked gate at SH 4. Current users of the road include:

• Service personnel to access the Boca Chica Tract of the refuge and the adjacent Loma Ecological Preserve, which is land owned by the BND and leased by the Service; • BND and its contractors to access BND lands for various activities such as security patrols, road maintenance, and levee work at dredged material placement areas (DMPA) along the BSC; • U.S. Border Patrol for law enforcement activities; • Annova and its contractors to access the proposed LNG Project site for various survey work; and • Other construction personnel.

Consultation between the Service and Annova In April 2019, the Federal Energy Regulatory Commission (FERC) published the Environmental Impact Statement (EIS), including evaluation of the environmental effects for construction and operation of the Annova LNG Project site.

In consultation with the Service in 2015 and 2016, Annova identified alternative routes to provide access from SH 4 to their LNG Project site. The access road alternatives reflect possible modifications to minimize potential impacts on wildlife movement through the area and were incorporated into Annova’s FERC application. On July 13, 2016, Annova filed an Application for Authorization Under Section 3 of the Natural Gas Act (FERC application) with the Secretary of FERC to site, construct, and operate new liquefaction and export facilities located on the BSC in Cameron County, Texas (Docket Number CP16-48-000). Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 3

The Service came to Annova with a proposal to allow access through the refuge in an effort to minimize impacts to environmental resources, particularly dense thornshrub communities on Loma de la Jauja (clay dune) that may provide suitable habitat for the federally endangered ocelot. In the FERC Application, Annova evaluated access road alternatives. Annova’s initial proposed access road route was Access Road Alternative 1 (Proposed Access Road 1, in this EA), which is located entirely on BND property, thereby avoiding the refuge (Figure 2). Proposed Access Road 1 largely follows the existing packed dirt road from the LNG Project site, but the southern 1.6-mile section diverges from the existing road. In this southern section, Proposed Access Road 1 parallels the north side of Loma de la Jauja before crossing the loma to connect to SH 4. Annova’s Access Road Alternative 2 (Proposed Access Road 2, in this EA), which the Service proposed for evaluation, is collocated with the existing packed dirt road the entire distance from the LNG Project site to SH 4, including the 0.5-mile segment through the refuge.

Purpose of the Action

The purpose of the Service’s Proposed Action is to issue a ROW permit to allow for a 0.5-mile segment of the main access road to the future site of Annova’s proposed LNG Project site to go through the refuge while limiting impacts to wildlife and habitat on the refuge and adjacent properties.

Annova’s final access road would be approximately 44 feet wide, which include two 12-foot- wide paved travel lanes and a 10-foot-wide gravel shoulder on each side. An additional 46.5 feet on either side of the road is needed to increase the road elevation above the 100-year floodplain; construction activities would disturb an additional 10 feet on either side of the road. In total, Annova’s access road would result in a 157-foot-wide (0.5 miles, 10 acres of refuge property) corridor for construction called the limit of disturbance (LOD) and a 137-foot-wide (0.5 miles, 8.5 acres of refuge property) LOD during operation. Further details and a typical cross-section of the proposed access road are provided in the alternatives analysis in Section 2.0 of this EA. The LNG Project site is projected to be in operation for a minimum of 25 years, the proposed ROW permit would be for a term of 25 years.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 4

Figure 2. Access Road Alternatives Identified for Detailed Analysis Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 5

Need for the Action

The Proposed Action is to needed to prevent fragmentation and destruction of an undisturbed area that has the habitat necessary to support threatened and endangered species, primarily the ocelot (Leopardus pardalis) and jaguarundi (Herpailurus yagouaroundi cacomitli), which are both federally listed as endangered.

The BSC and active DMPAs restrict vehicle access routes to Annova’s LNG Project site to the north and west, tidal flats and the Loma Ecological Preserve to the east and south, and refuge lands to the south (Figure 3). Among other duties, the refuge is tasked with protecting and conserving existing native habitats. Primary habitats in the vicinity of the existing packed dirt road discussed in this EA include native coastal salt prairie, emergent wetlands in lower areas, and dense thornshrub on Loma de la Jauja to the west of the existing access road and on smaller lomas to the east of the access road. In addition, wind-tidal flats associated with South Bay and within the Loma Ecological Preserve are nearby to the east, and the Rio Grande and associated riparian corridor are nearby to the south, which support a diversity of wildlife.

If the ROW permit is not approved, Annova will need to avoid refuge property by constructing and operating Proposed Access Road 1, which would be a total length of 3.3 miles, 1.6 miles of which would be new road construction through Loma de la Jauja. This would destroy undisturbed coastal salt prairie, wetland, and rare dense thornshrub habitats, which would further disturb and fragment habitat with previously documented ocelot activity, instead of constructing Proposed Access Road 2, which would be entirely collocated with an existing road. Urbanization, oil and gas project development, and other threats are reducing the availability of suitable habitat and migration corridors in south Texas for the endangered ocelot. Habitat loss and fragmentation in Texas, especially along the Rio Grande, critically threaten the long-term survival of the ocelot (Service 1990).

The Service has no jurisdiction over the BND lands Proposed Access Road 1 may be built on, but is providing analysis of the associated effects to fully demonstrate and compare the possible environmental consequences of the denial or issuance of a ROW permit to Annova. Using the analysis in this EA, the Service will decide if there would be any significant effects associated with the Proposed Action Alternative that would require the preparation of an Environmental Impact Statement, or decide to prepare a Finding of No Significant Impact for the Proposed Action Alternative if selected.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 6

Figure 3. Land Ownership Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 7

Regulatory Compliance

National wildlife refuges are guided by the mission and goals of the Refuge System, the purposes of an individual refuge, Service policy, and laws and international treaties. Relevant guidance includes the Refuge System Administration Act of 1966, as amended by the Refuge System Improvement Act of 1997, Refuge Recreation Act of 1962, the Service Manual, the Refuge Manual, and selected portions of the Code of Federal Regulations.

The mission of the Refuge System is:

“... to administer a national network of lands and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans” (National Wildlife Refuge System Improvement Act of 1997, Public Law 105-57).

The goals of the Refuge System are to:

• conserve a diversity of fish, wildlife, and plants and their habitats, including species that are endangered or threatened with becoming endangered; • develop and maintain a network of habitats for migratory birds, anadromous and interjurisdictional fish, and marine mammal populations that is strategically distributed and carefully managed to meet important life history needs of these species across their ranges; • conserve those ecosystems, plant communities, wetlands of national or international significance, and landscapes and seascapes that are unique, rare, declining, or underrepresented in existing protection efforts; • provide and enhance opportunities to participate in compatible wildlife-dependent recreation (hunting, fishing, wildlife observation and photography, and environmental education and interpretation); and • foster understanding and instill appreciation of the diversity and interconnectedness of fish, wildlife, and plants and their habitats (Service 2018).

The Refuge System Improvement Act of 1997 provides guidelines and directives for the administration and management of all areas in the Refuge System. It states that national wildlife refuges must be protected from incompatible or harmful human activities to ensure that people can enjoy Refuge System lands and waters. Before activities or uses are allowed on a national wildlife refuge, the uses must be found to be compatible. A compatible use “…will not materially interfere with or detract from the fulfillment of the mission of the Refuge System or the purposes of the refuges.” In addition, “wildlife-dependent recreational uses may be authorized on a refuge when they are compatible and not inconsistent with public safety.” The Act also recognized that wildlife-dependent recreational uses involving hunting, fishing, wildlife observation, photography, environmental education and interpretation, when determined to be compatible with the mission of the Refuge System and purposes of the refuges, are legitimate and appropriate public uses of the Refuge System, and they shall receive priority consideration in planning and management.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 8

This EA represents compliance with the applicable Federal statutes, regulations, Executive Orders, and other compliance documents, including the following:

• Administrative Procedures Act (5 U.S.C. 551-559, 701-706, and 801-808), as amended • American Indian Religious Freedom Act of 1978 (42 U.S.C. 1996) • Antiquities Act of 1906 (16 U.S.C. 431-433) • Archaeological Resources Protection Act of 1979 (16 U.S.C. 470) • Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d), as amended • Clean Air Act of 1972, as amended (42 U.S.C. 7401 et seq.) • Clean Water Act of 1972, as amended (33 U.S.C. 1251 et seq.) • Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) • Executive Order 12898, Federal Action Alternatives to Address Environmental Justice in Minority Populations and Low-Income Populations, 1994. • Executive Order 13112, Invasive Species (issued in February 1999) • Fish and Wildlife Coordination Act of 1958, as amended (16 U.S.C. 661 et seq.) • Fish and Wildlife Improvement Act of 1978 (16 U.S.C. 7421) • Floodplain Management (Executive Order 11988) • Migratory Bird Treaty Act (16 U.S.C. 703-712), as amended • National Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee, as amended; Public Law 89-669) • NEPA of 1969, as amended (42 U.S.C. 4321 et seq.) • Regulations for Implementing the Procedural Provisions of NEPA (40 CFR 1500 et seq.) • National Historic Preservation Act of 1966, as amended (16 U.S.C. 470 et seq.) • Native American Graves Protection and Repatriation Act of 1990 (25 U.S.C. 3001 et seq.) • Protection and Enhancement of the Cultural Environment (Executive Order 11593) • Protection of Wetlands (Executive Order 11990) • National Pollutant Discharge Elimination System, as amended (33 U.S.C. 1251 et seq.) • Soil and Water Conservation Act of 1977 (16 U.S.C. 2001-2009), as amended • U.S. Fish and Wildlife Service Manual 601 FW 3, Biological Integrity, Diversity, and Environmental Health

Further, this EA reflects compliance with applicable State of Texas and local regulations, statutes, policies, and standards for conserving the environment and environmental resources such as water and air quality, endangered plants and animals, and cultural resources.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 9

Scoping/Public Involvement

Scoping is an early and open process to determine the issues and alternatives to be addressed in the NEPA process. As part of the FERC application process for the LNG Project, Annova participated in a public scoping meeting on August 23, 2015, and following the scoping meeting, Annova submitted draft Resource Reports that addressed public comments. The FERC posted the draft Resource Reports on their docket, which is publicly available information through the FERC Online eLibrary. These were incorporated into the Resource Report for the final application. Annova’s final FERC application addressed and described the access road alternatives including the one through the refuge being analyzed in this EA. The Service also used resource reports provided by Annova in the completion of this EA.

The public, agencies, and interested groups traditionally associated with the lands of the refuge will have an opportunity to review and comment on this EA. No further scoping was conducted for this proposed ROW beyond scoping conducted in relation the Annova LNG Brownville Project EIS. This EA will be made available for a 30-day period to agencies and other interested publics.

2.0 DESCRIPTION OF ALTERNATIVES

NEPA requires federal agencies to consider a reasonable range of alternatives that meet the purpose of and need for a proposed action. When the Service is presented with a permit application, the range of alternatives for consideration is limited to two alternatives – issue the permit or deny the permit. In this EA, Alternative A represents the No Action Alternative (denying the permit) and Alternative B represents the Proposed Action (issuing the permit). This chapter presents the alternatives considered for the construction and use of the access road project and the potential environmental impacts associated with each of the alternatives. Under Alternative A, Annova would construct the Proposed Access Road 1, and under Alternative B Annova would be issued a ROW permit, which would allow it to construct Proposed Access Road 2 through the refuge.

The descriptions of the alternatives address the roads south of a point of convergence to SH 4 (Figure 2). Because the new construction portion of Proposed Access Road 1 does not follow an existing road, Annova conducted surveys within a 500-foot-wide survey corridor to allow flexibility in routing the road. Because Proposed Access Road 2 is collocated with the existing packed dirt road and the purpose is to maximize the use of this disturbed area, Annova surveyed a narrower corridor, which was 300 feet wide.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 10

Under both alternatives, Annova would use an access road for both construction and operation of the LNG Project. The final main road would be designed as follows under both alternatives. The final road would be paved and approximately 44 feet wide. The road width is the result of several factors, including increasing the road elevation from existing grade to stay above the 100-year floodplain and Cameron County standard specifications for rural roads more than 2 miles in length. Annova anticipates regular industrial truck traffic would require two 12-foot-wide paved travel lanes to accommodate tractor-trailer traffic in both directions. To prevent potential safety hazards, each side of the road would also have a 10-foot-wide gravel shoulder able to accommodate a disabled tractor-trailer without blocking incoming or outgoing road traffic. In accordance with Cameron County specifications, the rise-to-run ratio required for a 100-year flood event and corresponding drainage and drainage structures result in an additional width of 46.5 feet on either side of the road. Construction activities would disturb 10 feet on either side of the road. In total, this would result in a 157-foot-wide LOD for construction and a 137-foot-wide LOD during operation for the length of the road. Figure 4 shows a typical cross-section of the proposed road, as provided by Annova.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 11

Figure 4. Proposed Access Road Cross-Section Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 12

2.1 Alternative A – No Action - Deny the Permit

Under Alternative A, the No Action Alternative, the Service would deny the ROW permit, and Annova would not be allowed to use the existing access road or construct a new road through the refuge; however, this does not mean that the LNG Project and access road would not be constructed. The primary difference between this alternative and the Proposed Action is that the access road would be routed around the refuge. Current management of the refuge would continue unchanged. Maintenance (grading multiple times each year) of the existing packed dirt road would continue, and the road would remain closed to public vehicle access and continue to be used by Service personnel, BND, U.S. Border Patrol, and other Service-approved users.

Under Alternative A, Annova would construct a new 1.6-mile paved road (Proposed Access Road 1) from SH 4 to the point of convergence in previously undisturbed habitat. This would require clearing, grading, and filling within a 157-foot-wide LOD on adjacent property, which avoids refuge property, but which would directly impact an estimated 31 acres of native habitats on the adjacent property. Proposed Access Road 1 would parallel the north side of Loma de la Jauja before crossing the loma to connect to SH 4 (Figure 2). These actions would affect 5.1 acres of dense thornshrub, which is the preferred habitat type for ocelots, 2 acres of moderately dense thornshrub, 1.4 acres of wetland habitats, and 23 acres of other native habitat primarily coastal salt prairie (Figure 2).

The 0.4-mile longer distance of Proposed Access Road 1 from SH 4 would require more total acreage than Alternative B for construction and would increase adverse impacts on habitats, including wetlands. Although Alternative A would not require a permit from the Service, it would involve greenfield construction in previously undisturbed areas and increase the potential for additional impacts to threatened and endangered species through habitat fragmentation associated with the clearing and maintenance of the new road.

In addition to existing traffic (unknown, but estimated at approximately 10 vehicle trips per month) on the existing packed dirt road for Service and other approved users, which would continue under this alternative, new traffic would utilize Proposed Access Road 1 to access the Annova LNG Project.

Under Alternative A, no new construction, increased traffic, or additional destruction of habitat would occur on the refuge. The addition of a new paved road through previously undisturbed habitat, off the refuge, may alter wildlife movement in the area and could result in loss of wildlife through vehicular collisions including the federally endangered ocelot. In addition, human disturbance, including noise and artificial lighting during construction, could further discourage ocelot use of the area.

Road ROW Under Alternative A, a ROW permit would be denied, and Annova would not use or improve the existing packed dirt road through refuge property. Annova would work with BND to secure access to their facility from SH 4 for construction and operations. This alternative may minimally decrease the potential for vehicular collisions with wildlife because it provides for a slightly shorter total distance traveled on SH 4, which has a higher speed limit. Vehicular collisions are a primary cause of ocelot mortality (Haines et al. 2005).

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 13

From the point of convergence, Annova would construct Proposed Access Road 1, which would be approximately 1.6 miles long, 44 feet wide including two 12-foot-wide paved travel lanes to accommodate tractor-trailer traffic in both directions and a 10-foot-wide gravel shoulder on each side to accommodate a disabled tractor-trailer. An additional 46.5 feet on either side of the road is needed to increase the road elevation above the 100-year floodplain and to provide for adequate drainage; construction activities would disturb an additional 10 feet on either side of the access road. In total, Proposed Access Road 1 would result in a 157-foot-wide corridor for construction called the LOD and a 137-foot-wide LOD access road corridor during operation.

To minimize the potential for vehicular collisions with wildlife Annova would incorporate wildlife crossings, and mandate a speed limit of 25 miles per hour on the Proposed Access Road 1. The wildlife crossings would be similar in design to crossings installed at Laguna Atascosa NWR and as approved by Ecological Services a division of the Service. Each crossing would have a minimum opening height of 4 to 6 feet and a width of 5 feet or greater with fencing on both sides to funnel wildlife to the crossings.

Road Construction Phase Under Alternative A, Annova plans to initiate road construction as soon as practicable following issuance of the FERC Order Granting Authorization under Section 3 of the Natural Gas Act. Annova would mobilize crews for site preparation activities and begin construction of the permanent main access road off SH 4. Annova would construct Proposed Access Road 1 within the 500-foot-wide survey corridor but most likely within the LOD as shown in Figure 6 (pg 24), through rare and undisturbed ocelot habitat. The exact timing and duration of the permanent road construction have not been established. Annova anticipates that construction would commence in the first quarter of 2020, including construction of Proposed Access Road 1. Full commercial operations are anticipated to begin in 2024.

The anticipated daily traffic would vary during construction. The estimated average daily worker commute traffic on Proposed Access Road 1 would consist of approximately 500 trips during peak conditions. Annova plans to stagger starting times by one hour so that no more than half of the construction workforce would arrive and depart during the peak commute hour on SH 4, while half would arrive outside the peak commute hour to minimize traffic congestion. The peak construction workforce would occur during the middle of the 4-year construction schedule. The estimated daily construction schedule would be 7:00 am to 6:00 pm, although final daily schedules are subject to change.

During construction, vehicles would consist of personal vehicles, trucks, and heavy haul trucks, some of which would be permitted as overweight, above 80,000 pounds. Heavy trucks would deliver fill, concrete, equipment, and other materials to the site, and carry away refuse and equipment, as needed. The heavy truck trips are typically concentrated during the initial phase of construction during site preparation and fill. Concrete trucks would comprise a large portion of the initial heavy truck trips. The count represents a midpoint in the construction and actual counts would vary by month and year.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 14

Monitoring & Inspection Under Alternative A, Annova would have at least one full-time environmental inspector dedicated to the LNG Project to ensure that construction activities comply with all applicable requirements. Duties would include but not be limited to verifying the limits of approved work areas and access roads; marking sensitive resource areas; ensuring protective measures to prevent impacts on sensitive resources are followed; ensure sediment and erosion control measures are in appropriate locations, functioning properly, and repaired within 24 hours; ensuring dewatering and water discharge activities do not result in scouring, sedimentation, or erosion of sensitive resources; providing oversight to ensure corrective actions are implemented properly; and overseeing site stabilization and cleanup.

During operations, Annova would perform periodic checks to ensure water is not standing for more than 10 days at wildlife crossings, and periodically use trail cameras to monitor the use of wildlife crossings.

Operation and Maintenance Under Alternative A, after construction of the LNG Project and Proposed Access Road 1, operation and maintenance would initially require approximately 115 personnel to perform operations, security, management, and administrative functions, which would increase over time up to 165 personnel for the life of the LNG Project. Early staffing plans assume that the liquefaction facility would operate 24 hours a day, 7 days a week, for a minimum of 25 years.

The anticipated daily traffic during operation on the access road would consist of approximately 115 trips in the morning and the evening. Annova anticipates that approximately 20 percent of the workforce would carpool to minimize traffic. Heavy truck trips to and from the site during operation would be minimal, and aside from trash collection, would occur only on an as-needed basis. During operations, vehicles would primarily consist of personal vehicles and trucks and waste removal trucks. Heavy trucks below the threshold for oversize and overweight permits would be the majority of the periodic heavy truck traffic along Proposed Access Road 1 during operations.

Long-term maintenance of the access road must be carried out to maintain safety. Under Alternative A, a new currently unmaintained road would need to be constructed from SH 4 to the point of convergence, causing more disturbance to wildlife than would occur in Alternative B. The disturbance to wildlife would increase overall in the area because regular maintenance (mowing) would occur on the previously undisturbed new route and also continue on the existing packed dirt road (mowing, grading) through refuge property.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 15

2.2 Alternative B – Proposed Action - Issue the Permit

Under Alternative B, the Proposed Action Alternative, the Service would issue a 25-year ROW permit governing design and granting access to Annova to approximately 0.5 miles of Proposed Access Road 2 through the refuge. A SUP would allow for the temporary improvement of the existing packed dirt road (temporary access road), construction of a final permanent road, and access through the refuge until the issuance of a ROW permit. Under Alternative B, Annova would construct Proposed Access Road 2, which is similar in design to the road under Alternative A, except Proposed Access Road 2, starting at SH 4 to the point of convergence would be 1.2 miles long and occupy less acreage. Alternative B would keep traffic traveling to the LNG Project on the higher speed SH 4 for an additional 0.85 miles, which may slightly increase the potential for wildlife-vehicle collisions on SH 4.

Proposed Access Road 2 is preferred because it minimizes potential impacts to the federally endangered ocelots’ preferred habitat (i.e., dense thornshrub vegetation communities) and waters of the U.S., including wetlands. Proposed Access Road 2 minimizes impacts due to its location and because it maximizes use of the existing, disturbed packed dirt road. For the length of Proposed Access Road 2 from the point of convergence to SH 4, these impacts would affect 0 acres of dense thornshrub, 3 acres of moderately dense thornshrub, less than 0.1 acres of wetland habitats, and 15 acres of other native habitat primarily coastal salt prairie and existing packed dirt road. Alternative B would directly affect a total of 23 acres, approximately 10 acres of which would be on refuge property (Table 4, pg. 33).

Road ROW A ROW permit and SUP would be approved, and Annova would construct Proposed Access Road 2 off SH 4 (Boca Chica Boulevard) as the access road for both construction and operation of the LNG Project.

Initially, an existing packed dirt road would be improved to provide temporary access until construction of the final access road is complete. The final road would be constructed in the same manner and to the same design in both alternatives except Proposed Access Road 2 would be shorter and affect less acreage. This would result in a 157-foot-wide LOD (0.5 miles, 10 acres of refuge property) corridor for construction and a 137-foot-wide (0.5 miles, 8.5 acres of refuge property) LOD access road corridor during operation.

This alternative may minimally increase the potential for vehicular collisions because it provides for a longer total distance traveled on SH 4, which has a higher speed limit. To minimize the potential for vehicular collisions with wildlife, the Service would require incorporating “wildlife crossing” signage and traffic calming into road design in addition to the 25 mph speed limit and wildlife crossings mentioned in Alternative A. One wildlife crossing may be installed on the refuge.

Road Construction Phase Initially, the existing packed dirt road would be improved to a temporary access road which includes widening to a width of approximately 40 feet where required, and the addition of rock as necessary to support heavy haul traffic until construction of the final access road is complete.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 16

The temporary access road would parallel and partially overlay the existing graded but unpaved packed dirt road as the width varies.

Annova would then construct the final access road adjacent to, and partially overlaying on, the temporary access road within the 300-foot-wide survey corridor, with the centerline, determined during final engineering for specific land requirements and to minimize impacts, but most likely within the 157-foot-wide LOD shown in Figure 6. The 300-foot-wide survey corridor enables the non-overlapping portion of the permanent access road to be placed on either side of the existing packed dirt road, as needed to minimize impacts to sensitive habitats. Upon completion of Proposed Access Road 2, any portion of the existing packed dirt road or temporary access road outside the 137-foot permanent LOD would be decompacted, graded to maintain sheet flow, and restored with native vegetation to coastal salt prairie habitat as a non-maintained area.

Construction timelines and vehicle use would be similar to those described in Alternative A. No chemicals or hazardous materials would be staged on the refuge.

The following actions would be implemented to reduce or eliminate the potential likelihood of adverse effects to threatened and endangered species, resident wildlife, and migratory birds and their habitats.

• Construction activities, particularly vegetation disturbance, would be planned to avoid the nesting season for aplomado falcons (Falco femoralis septentrionalis) as well as for other migratory and resident birds (March 15–August 15). • Construction would be conducted only during daylight hours to reduce the chance of affecting ocelots traveling nocturnally. • Refuge staff would educate contractors on safe speeds for vehicles and ocelot identification so they can be better aware of possible ocelot presence and keep mortality and disturbance risks low. Refuge law enforcement may monitor vehicle speeds on Proposed Access Road 2.

Monitoring & Inspection In addition to monitoring activities described in Alternative A, a biological monitor for the refuge would assist in ensuring that project activities stay in compliance with all environmental regulations, laws and provisions during the construction phase. They would conduct biological surveys as needed, supervise the clearing of any vegetation, and monitor work areas and adjacent habitats on a daily basis to: (a) document all activities pertaining to biological resources; (b) provide regular updates to the refuge manager; (c) provide refuge manager daily reports; (d) notify the refuge manager immediately if unauthorized impacts to biological resources occur, and; (e) advise contractors, as needed, to ensure effective implementation of biological mitigation measures for specific site conditions.

Operation and Maintenance Traffic types and frequency would be the same in Alternative B as in Alternative A. In Alternative B Annova would be solely responsible for maintaining the ROW at regular intervals, which would reduce overall costs to the refuge. Increased traffic levels may raise the possibility for the introduction of invasive species in either Alternative, but costs for their control would be greater for the refuge in Alternative B.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 17

In this alternative, access to the ROW road would be controlled via a gate located at the intersection of SH 4 and Proposed Access Road 2 to reduce criminal activity and human-caused wildlife disturbance. No other ancillary structures or lighting would be installed on the road except for a lit entrance sign and necessary regulatory and traffic signs.

Under Alternative B, the final design of Proposed Access Road 2 would in the long-term result in reduced disturbance to wildlife. Regular maintenance would only take place on one road in an area that already receives regular human-caused disturbance as opposed to Alternative A where two areas would be disturbed.

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

This chapter describes, analyzes and discusses the existing conditions of environmental resources and the potential environmental effects or consequences on each affected resource that can be reasonably expected by implementation of the following alternatives described in Chapter 2.0 and shown in Figure 2:

• Alternative A – No Action - Deny the Permit • Alternative B – Proposed Action - Issue the Permit

The existing conditions information focuses on the segments of each access road route that are relevant to the Service’s analysis. The Service’s analysis focuses on the access road segments beginning at SH 4 and ending where the two access roads converge north of the refuge, as shown in Figure 2. The analysis of Alternative A addresses Proposed Access Road 1 south of the point of convergence to SH 4, all of which is outside refuge property. The analysis of Alternative B addresses Proposed Access Road 2 south of the point of convergence to SH 4, which includes a section on BND property and a 0.5-mile section through refuge property. From the point of convergence northeast to Annova’s LNG Project site, both potential routes follow the existing packed dirt road and have the same existing conditions and potential impacts. Furthermore, the Alternatives described in this EA do not affect the proposed access road between the point of convergence and the LNG Project site, and FERC has analyzed the entire LNG Project including the proposed access road through the refuge as part of the agency’s ongoing NEPA process. Therefore, the Service’s analysis does not include the access road segment from the point of convergence northeast to the LNG Project site.

Much of the information and quantities provided in this section are based on various documents, information, and resource reports prepared by Annova as part of the ongoing FERC NEPA process for the LNG Project. Because Proposed Access Road 1 off refuge property does not follow an existing road, Annova conducted surveys for various resources within a 500-foot-wide survey corridor to allow flexibility in routing the road to avoid and minimize impacts to sensitive resources. Since Proposed Access Road 2 through the refuge follows the existing packed dirt road and the purpose is to maximize the use of the already disturbed area of the road, Annova surveyed a narrower corridor, which was 300-feet-wide.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 18

The survey corridors are located on the South Texas Coastal Plain in an area of minimal topographic relief. The 0.5-mile segment of access road through the refuge follows an existing packed dirt road that is located near the west end of the Boca Chica Tract. Within the Boca Chica Tract, the road crosses generally flat terrain at about 5 feet in elevation. It begins to rise gradually to about 10 feet in elevation near the northern refuge boundary as the road crosses the eastern edge of Loma de la Jauja.

The following sections in this chapter provide a brief description of the affected resources in the proposed area and impacts of the alternatives on those resources. An analysis of the effects of the management actions has been conducted on the physical environment (air quality, soils, and water resources and quality); biological environment (vegetation, wildlife, and threatened and endangered species); and human environment (cultural, socioeconomic, and aesthetic and visual resources). As discussed earlier in this document, if the proposed action is not approved, Annova would need to construct a new access road off refuge property to connect to SH 4.

The direct, indirect, and cumulative impacts of each alternative are considered.

• Direct effects are the impacts that would be caused by the alternative at the same time and place as the action. • Indirect effects are impacts that occur later in time or distance from the triggering action. • Cumulative effects are incremental impacts resulting from other past, present, and reasonably foreseeable future actions, including those taken by federal and non-federal agencies, as well as undertaken by private individuals. Cumulative impacts may result from singularly minor but collectively significant actions taking place over a period of time.

Each resource and the direct and indirect effects of this project are discussed below.

3.1 Physical Environment

Air Quality Cameron County is located in the Brownsville-Laredo Intra-State Air Quality Control Region. An Air Quality Control Region is a federally designated area required to meet and maintain air quality standards (42 U.S.C. §7407). Cameron County is designated as in attainment for all criteria air pollutants with National Ambient Air Quality Standards.

Alternative A – No Action - Deny the Permit Under Alternative A, the Service would not allow Annova to improve and use the existing packed dirt road through refuge property. Current maintenance trends (grading multiple times each year) would continue, and the existing packed dirt road would remain closed to public vehicle access and continue to be used by Service personnel, BND, U.S. Border Patrol, and other Service-approved users. Continued use of the existing packed dirt road under Alternative A is expected to have minor and localized indirect impacts on air quality from the stirring or dust.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 19

Under Alternative A, Annova would construct Proposed Access Road 1, new road construction from SH 4 to the point of convergence, off the refuge, which may result in short-term direct impacts to air quality from increases in fugitive dust and emissions produced by heavy equipment and increased traffic during construction, which would reduce air quality. However, these emissions would be reduced during operation because the roadway would be paved and traffic volumes would decrease. During construction of the LNG Project, an estimated 500 daily trips may occur during peak workforce numbers and 260 daily trips during operations. Potential impacts to air quality because of emissions would be unnoticeable during the operation and maintenance phase of the access road. Long-term impacts from vehicle emissions would be negligibly lower in this alternative due to the shorter total distance vehicles would have to travel from SH 4 to the LNG Project site.

Alternative B – Proposed Action - Issue the Permit Under Alternative B, Annova would construct Proposed Access Road 2 through refuge property. Similar to Alternative A, Alternative B may result in short-term impacts to air quality from dust and emissions produced by heavy equipment and other vehicles during temporary road construction, permanent road construction, and restoration efforts for the abandoned portions of the temporary access road. Emissions would be reduced during operations because the roadway would be paved and traffic volumes would decrease, but they would be negligibly higher than Alternative A because of the slightly longer overall travel distance. Overall impacts to air quality are expected to be similar under either alternative, as an access road would be built under either alternative in the same general area. Similar to Alternative A, potential impacts to air quality, because of vehicle, emissions would be unnoticeable during the operation and maintenance phase of Proposed Access Road 2 because vehicle trips would occur spread throughout the day.

Soils The survey corridors are located in the South Texas Coastal Plain. The surficial geology is comprised of Quaternary Holocene sediments consisting of alluvium of the Rio Grande Valley and coastal deposits of deltaic, tidal-flat, beach, barrier island, lagoon, estuary, and dune environments (Page et al. 2005). The soils along the potential access roads are mainly mapped as Sejita silty clay loam, with Point Isabel clay loam mapped along lomas (Figure 5) (U.S. Department of Agriculture 1977).

Sejita and similar soils make up 90 percent of the mapped unit for Sejita Silty Clay Loam soil. Parent material is Quaternary-age loamy aeolian deposits and/or alluvium. These soils are found on tidal flats and where slopes are 0 to 1 percent. There are no restrictive layers within the 60 inches of the representative profile for this soil unit. The saturated zone is at the ground surface. These soils are poorly drained, experience occasional ponding but do not flood, and are classified as hydric. These soils are in wind erodibility group 8, indicating low wind erosion potential. The Ksat (ease with which pores in a saturated soil matrix transmit water) is moderately high, and available water storage in the profile is very low indicating low revegetation potential. These soils are strongly saline, with a sodium adsorption ratio maximum of 40.0 millimhos per centimeter (mmhos/cm). The risk of corrosion from the soil is high for uncoated steel and moderate for concrete.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 20

Figure 5. Mapped Soil Types within Access Road Survey Corridors Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 21

Point Isabel clay loam and similar soils make up 85 percent of the mapped unit for Point Isabel clay loam soil. Parent material is Quaternary-age clayey aeolian deposits. These soils are found on dunes where slopes are 1 to 8 percent, and they are typically present on the lomas in the vicinity of the potential access roads. No restrictive layers are present in this mapped unit, and the depth to the saturated zone was not encountered within the 65 inches of the representative profile for this soil unit. These soils are classified as well drained. They do not experience frequent flooding or ponding, nor are they classified as hydric. They have very high runoff potential and severe compaction potential. These soils are in wind erodibility group 4L, indicating moderate wind erosion potential, which influences revegetation potential. For these soils, the Ksat is moderately low to moderately high, and available water storage is low. This map unit is moderately saline to strongly saline, and the soils have a sodium adsorption ratio maximum of 20.0 mmhos/cm in the profile. The risk of corrosion from the soil is high for uncoated steel and moderate for concrete.

Alternative A – No Action - Deny the Permit Under Alternative A, the existing packed dirt road through refuge property would not be improved or used for Annova’s LNG Project. To keep the existing packed dirt road accessible to current users, grading would be performed multiple times each year to repair ruts and potholes; however, no major soil disturbance or erosional impacts are anticipated outside the existing road.

Under Alternative A, Annova would construct Proposed Access Road 1, new construction off the refuge, which would require clearing, grading, and filling within a 157-foot-wide LOD along Proposed Access Road 1 in previously undisturbed areas. During and immediately after construction, exposed soils would be susceptible to erosion by wind and runoff; these effects would be minimized by the use of best management practices to control erosion and provide stabilization. Overall, impacts to soils are expected to be minor, localized, and short-term on the refuge, but moderate and long-term off the refuge.

Alternative B – Proposed Action - Issue the Permit Under Alternative B, Annova would construct a temporary access road (rock) and Proposed Access Road 2 (permanently paved), collocated with the existing packed dirt road through the refuge, which would require clearing, grading, and filling within a 157-foot-wide LOD. The remaining portions of the existing packed road and temporary access road outside of the 137- foot-wide ROW would be decompacted and graded to allow for sheet flow and the restoration of native coastal prairie habitat. This would disturb soils outside the existing packed dirt road, and as in Alternative A, exposed soils would be susceptible to erosion. Erosion would be minimized by best management practices, and overall impacts to soils are expected to be minor and localized while impacts to soils under the new road construction would be long-term, and short- term for the restored portions of the existing and temporary access road. After construction, the Proposed Access Road 2 (paved) would reduce the amount of exposed soils and erosion potential compared to the existing packed dirt road.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 22

Water Resources and Quality

Groundwater Resources The principal coastal lowlands aquifer system in South Texas is the Gulf Coast Aquifer, which stretches from Florida to Mexico along the Gulf of Mexico. The aquifer continues southeast as it increases in thickness beneath the Project site and into the Gulf of Mexico. The Gulf Coast Aquifer is separated into six permeability zones (Ryder 1996): the Catahoula restricted Aquifer, the Jasper Aquifer-Oakville Sandstone, the Burkeville Confining System, the Evangeline Aquifer-Goliad Sand/Fleming Sand, the Chicot Aquifer, and the Jackson Group. In the vicinity of the study corridors, the Evangeline Aquifer is approximately 200 to 300 feet below ground surface, and the Chicot Aquifer is just beneath ground surface (Black & Veatch 2016). The Chicot Aquifer is considered saline and not suitable for potable use in this area. The Evangeline and Chicot aquifers provide a majority of the groundwater used in Cameron County; however, because the quality of groundwater in the area does not meet Texas Department of Health standards, the Rio Grande supplies most of the water used in Cameron County and the surrounding counties that make up the Lower Rio Grande Valley; specifically, over 97 percent of the water consumed in the Lower Rio Grande Valley comes from surface water [Texas Water Development Board 1990, Paine 2000].

Surface Water Resources The survey corridors are in the South Laguna Madre watershed [United States Geological Survey Hydrologic Unit Code 12110208], which extends 59 miles southward from the Laguna Madre’s northern mudflats to within 3 miles of the Mexican border and opens into the Gulf of Mexico through the Brazos Santiago Pass (Onuf 2002). The watershed encompasses four counties. Freshwater inflow events to the system are limited due to the arid conditions of the watershed. The relatively flat topography surrounding the BSC results in drainage into the BSC from South Bay and Bahia Grande. The historic average annual rainfall for the Brownsville area is approximately 27.4 inches (National Oceanic and Atmospheric Administration 2014).

Blanton & Associates, Inc. (B&A), on behalf of Annova, conducted wetland determinations/delineations in the survey corridors in accordance with the 1987 USACE Wetland Delineation Manual (Environmental Laboratory 1987) and the November 2010 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain Region (Version 2.0) (USACE 2010). In the area between the survey corridors, approximate wetland boundaries were mapped using aerial photo interpretation. In total, approximately 16 acres of potential waters of the U.S. were mapped, all of which are emergent wetland. The extent of wetlands mapped in and between the survey corridors is shown in Figure 6.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 23

Figure 6. Waters of the U.S. within Access Road Survey Corridors Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 24

Alternative A – No Action - Deny the Permit Under Alternative A, the existing packed dirt road through the refuge would not be improved but would continue to be utilized and maintained for current users (unknown, but estimated at approximately 10 vehicle trips per month). Annova would construct Proposed Access Road 1, new construction off the refuge. Proposed Access Road 1 is not expected to affect groundwater resources. It would destroy and adversely affect approximately 1.4 acres of emergent wetland from SH 4 to the point of convergence within the 157-foot LOD for construction (Table 1, Figure 6). Wetland impacts would be addressed and mitigated for as part of the USACE’s review and permitting of Annova’s LNG Project under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. Under both alternatives, stormwater discharges would be regulated by the National Pollutant Discharge Elimination System standards.

Table 1. Potential Impacts to Waters of the U.S. Alternative A – No Action/ Alternative B – Proposed Deny the Permit Action/ Issue the Permit Waters of the Area on Area on Area Area U.S. Type Refuge Refuge Impacted Impacted Property Property (acres) (acres) (acres) (acres) Emergent 1.4 0 < 0.1 < 0.1 Wetland Note: Identified impacts are for segments of each access road route that are relevant to the Service’s analysis. The relevant segments begin at SH 4 and end where the two access roads converge north of the refuge (Figure 2). The Service’s decision for the proposed action does not affect the proposed access road between that point of convergence and Annova’s LNG Project site.

Alternative B – Proposed Action - Issue the Permit Under Alternative B, Annova would construct Proposed Access Road 2 through the refuge and use it during construction and operation of the LNG Project. Alternative B is not expected to affect groundwater resources, but it may result in adverse impacts to less than 0.1 acres of emergent wetland that is located in a depression paralleling SH 4 (Table 1, Figure 6). Compared to Alternative A, Alternative B would affect a much smaller area of wetlands. Like Alternative A, the wetland impacts would be addressed and mitigated for as part of the USACE’s review and permitting of Annova’s LNG Project under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. The potential for spills of contaminants including sewage, oils, lubricants, and fuels exists under both alternatives, but under Alternative B, those spills would adversely affect refuge resources directly. Impacts to water resources are expected to be minor and localized under this alternative.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 25

3.2 Biological Environment

Vegetation/Wildlife Habitat B&A, on behalf of Annova, mapped the habitat types present in and between the survey corridors using a combination of field investigations and aerial photography interpretation. Five habitat types were mapped, including barren (i.e., existing dirt roads), emergent wetland, dense and moderately dense thornshrub, and other native habitats (Table 2). Figure 7 shows the extent of each habitat type in the survey corridors. The following sections describe each habitat type.

Table 2. Mapped Habitat Types Total Area Percent of Total Habitat Type (acres) Area Barren (Existing Dirt 7 2% Road) Emergent Wetland 16 5% Dense Thornshrub 104 32% Moderately Dense 53 17% Thornshrub Other Native Habitat 143 44% Total 323 100%

Barren The existing unpaved packed dirt road within the survey corridor is designated as barren. The existing road generally ranges from about 30 to 50 feet wide through refuge property. Areas wider than 50 feet are present where equipment and materials storage or other disturbances have occurred.

Emergent Wetland Approximately 16 acres of emergent wetlands were mapped, much of which occurs in the Proposed Access Road 1 survey corridor (Figure 6). One area of emergent wetland was identified in the Proposed Access Road 2 survey corridor; this wetland is located in a linear depression that parallels SH 4.

Wetlands mapped in and between the survey corridors mainly occur in depressions and are surrounded by uplands. These wetlands tend to be dry for parts of the year, but water collects in them during periods of rainfall or coastal flooding, as evidenced by observed soil cracking in most of the depressions. A large wetland area in the Proposed Access Road 1 survey corridor includes a ponded area and adjacent salt flat that based on review of historic aerial photography and topographic maps appear to have once been hydrologically connected to tidal waters but have been disconnected from tidal influence by the construction of a nearby DMPA. These wetlands are generally saline due to the closed nature of the systems (i.e., no brackish or saltwater exchange and little freshwater inflow). Common plant species observed in wetlands include saltwort (Batis maritima), shoregrass [Distichlis littoralis (SYN=Monanthochloe littoralis)], saltgrass (Distichlis spicata), Berlandier wolfberry (Lycium berlandieri), sea blite (Suaeda linearis), glassworts (Salicornia spp.), sea ox-eye daisy (Borrichia frutescens), tornillo (Prosopis reptans), leatherleaf (Maytenus phyllanthoides), cenicilla (Sesuvium portulacastrum), and sea purslane (S. verrucosum).

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 26

Dense Thornshrub The highest portions of Loma de la Jauja support a dense and diverse thornshrub community that encompasses approximately 104 acres in and between the survey corridors (see Figure 7). Dominant tree and shrub species within this habitat type include Texas ebony (Ebenopsis ebano), granjeno (Celtis pallida), lime prickly-ash (Zanthoxylum fagara), honey mesquite (Prosopis glandulosa), desert yaupon (Schaefferia cuneifolia), lotebush (Ziziphus obtusifolia), and coma (Sideroxylon celastrinum). Other common woody plant species include coyotillo (Karwinskia humboldtiana), Texas lantana (Lantana horrida), Berlandier fiddlewood (Citharexylum berlandieri), Spanish dagger (Yucca treculeana), few-flower climbing-dalea (Dalea scandens var. pauciflora), and goatbush (Castela texana). Common vines include cow-itch vine (Cissus incisa), old-man’s beard (Clematis drummondii), and threadvine (Cynanchum barbigerum). Herbaceous species cover is sparse under the dense canopy of the loma shrublands; however, in clearings and loma edges, common herbs include hierba del soldado (Waltheria indica), Tamaulipan mistflower (Tamaulipa azurea), Lozano’s false indian mallow (Allowissadula lozanii), Cuban germander (Teucrium cubense), tropical sage (Salvia coccinia), guineagrass (Urochloa maxima), big sacaton (Sporobolus wrightii), and smutgrass (Sporobolus indicus).

Moderately Dense Thornshrub Moderately dense thornshrub is a matrix of grassland and shrubland and is mapped along the lower slopes of Loma de la Jauja. Dominant plant species include big sacaton, guineagrass, whiplash pappusgrass (Pappophorum vaginatum), silver bluestem (Bothriochloa laguroides), short-spike windmillgrass (Chloris x subdolichostachya), hooded windmillgrass (C. cucullata), and multi- flower false rhodesgrass (Trichloris pluriflora), with buffelgrass (Pennisetum ciliare) common along the disturbed roadside. Other common herbaceous plants typical of this vegetation community include hierba del soldado, white mistflower (Fleischmannia incarnata), blue mistflower (Chromolaena odorata), false ragweed (Parthenium hysterophorus), goldenweed (Isocoma drummondii), and Tamaulipan mistflower. Common shrub species include honey mesquite, Spanish dagger, Berlandier fiddlewood, Texas lantana, Texas pricklypear (Opuntia engelmannii var. lindheimeri), lotebush, lime prickly-ash, granjeno, coma, tasajillo (Cylindropuntia leptocaulis), and coyotillo.

Other Native Habitats Other native habitats occur on uplands throughout the mapped area and can generally be described as coastal prairie habitat. The species composition of these areas varies based on elevation, with the prevalence of halophytic (salt-loving) plant species increasing at lower elevations. This may be due to soil salinity, water table levels, soil drainage capability, or a combination of these factors. At higher elevations, the coastal prairie community exhibits a plant community of forbs and grasses scattered woody shrubs, including leatherleaf, camphor daisy (Rayjacksonia phyllocephala), tornillo, sea ox-eye daisy, and whorled dropseed (Sporobolus pyramidatus). Larger woody plants include scattered honey mesquite, Texas pricklypear, Spanish dagger, and tasajillo. At lower elevations within this habitat type, the presence of sea ox-eye daisy, shoregrass, sea blite, and glasswort increases.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 27

Figure 7. Habitat Types within Access Road Survey Corridors Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 28

Alternative A – No Action - Deny the Permit Under Alternative A, no impacts to vegetation on refuge property are expected. However, Annova would construct Proposed Access Road 1 off the refuge, which would destroy habitat as shown in Table 3. Figure 7 shows the 157-foot LOD in relation to vegetation/wildlife habitats. Long-term impacts to vegetation and habitat off the refuge would total 17 acres including 5.1 acres of dense thornshrub because regrowth is expected to take several years.

Table 3. Potential Impacts to Habitat Types for Alternative A – No Action Alternative A – No Alternative A – No Action/ Action/ Long-Term Impacts Short-Term Impacts Habitat Type Area on Area on Total Refuge Total Area Refuge Area Property (acres) Property (acres) (acres) (acres) Barren (Existing Dirt 0 0 0 0 Road) Emergent Wetlands 1.4 0 0.6 0 Dense Thornshrub 5.1 0 5.1 0 Moderately Dense 2 0 0.9 0 Thornshrub Other Native Habitat 23 0 10.4 0 Total 31.5 0 17 0 Note: Identified impacts are for segments of each access road route that are relevant to the Service’s analysis. The relevant segments begin at SH 4 and end where the two access roads converge north of the refuge (Figure 2). The Service’s decision for the proposed action does not affect the proposed access road between that point of convergence and Annova’s LNG Project site.

Alternative B – Proposed Action - Issue the Permit As shown in Figure 7 and in Table 4, Alternative B, which entails constructing Proposed Access Road 2 through the refuge, and the subsequent restoration of any remaining portions of the temporary access road to a natural setting, would avoid dense thornshrub habitats off-refuge and would have minimal impacts on wetlands (less than 0.1 acre). Overall impacts to vegetation communities and wildlife habitats would also be reduced compared to Alternative A because of the shorter distance of the road and smaller acreage of rare habitat types removed.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 29

Table 4. Potential Impacts to Habitat Types along Alternative B – Proposed Action Alternative B – Proposed Alternative B – Proposed Action / Short-Term Action / Long-Term Impacts Impacts Habitat Type Area on Area on Total Refuge Total Area Refuge Area Property (acres) Property (acres) (acres) (acres) Barren (Existing Dirt 5 2.5 ~5 ~1.25 Road) Emergent Wetlands <0.1 <0.1 < 0.1 < 0.1 Dense Thornshrub 0 0 0 0 Moderately Dense 3 0 ~2 0 Thornshrub Other Native Habitat 15 7.5 ~10 4.4 Total 23 10 ~17 ~5.25 Note: Identified impacts are for segments of each access road route that are relevant to the Service’s analysis. The relevant segments begin at SH 4 and end where the two access roads converge north of the refuge (Figure 2). The Service’s decision for the proposed action does not affect the proposed access road between that point of convergence and Annova’s LNG Project site.

Threatened and Endangered Species The Service’s list of threatened, endangered, and candidate species in Cameron County (Service 2017c) and the National Marine Fisheries Service’s (NMFS) list of threatened, endangered, and candidate species in Texas (NMFS 2017) include 21 federally listed threatened or endangered species and 1 candidate for federal listing. The species that have the potential to be affected during access road construction, along with their listing status and a summary of their preferred habitats, are listed in Table 5. No designated critical habitat is located in or adjacent to the survey corridors. Designated critical habitat for the piping plover is located in the unvegetated flats associated with South Bay approximately 2 miles to the east.

Based on habitat assessments conducted by B&A in March–April 2017, potential habitat for five of the listed species is present in or adjacent to the survey corridors: northern aplomado falcon, ocelot, jaguarundi, South Texas ambrosia (Ambrosia cheiranthifolia), and Texas ayenia (Ayenia limitaris) (Table 5). The following summarizes the results of on-site habitat assessments for those five species.

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Table 5. Listed and Candidate Species within the Survey Corridors Habitat Present In or Adjacent to Access Road Corridor? Listing Preferred Habitat Alternative Listed Species Jurisdiction Alternative B Status Summary A Proposed No Action - Action - Issue Deny the the Permit Permit Birds Northern aplomado Open plains with Yes Yes falcon Endangered Service scattered (in and (in and Falco femoralis shrubs/trees adjacent) adjacent) septentrionalis Mammals Yes Ocelot Yes Endangered Service Dense thornshrub (in and Leopardus pardalis (adjacent) adjacent) Gulf Coast jaguarundi Yes Yes Herpailurus Endangered Service Dense thornshrub (in and (adjacent) yagouaroundi cacomitli adjacent) Flowering Plants Native grasslands or South Texas ambrosia openings in Yes Yes Ambrosia Endangered Service mesquite (in and (in and cheiranthifolia shrublands; sandy adjacent) adjacent) clay and loam soils Mesquite and subtropical, mixed Yes Yes Texas ayenia riparian woodlands; Endangered Service (in and (in and Ayenia limitaris well-drained, sandy adjacent) adjacent) to silty clay and loam soils Sources: NMFS 2017, Service2017c

Northern Aplomado Falcon In Cameron County, northern aplomado falcons use open coastal prairie habitat and typically nest in stick platforms built by other raptors and corvids (Campbell 2003). Nests have been found in Spanish dagger, honey mesquite, Texas ebony, and other tree species, as well as on artificial structures such as electric transmission poles.

The open coastal salt prairie along the existing packed dirt road provides foraging habitat for aplomado falcons, and aplomado falcons have been observed in the immediate vicinity (Texas Parks and Wildlife Department [TPWD] 2015, eBird 2015, observations by B&A biologists 2014-2015). Scattered trees within the coastal salt prairie habitat and along lomas provide potential nesting sites; however, no aplomado falcon nests have been documented in or adjacent to the existing packed dirt road. The nearest known nest site is within 1 mile of the existing packed dirt road. There are at least two artificial nest platforms on the Service’s Boca Chica Tract within 0.5 miles of the existing packed dirt road, which may be used by aplomado falcons. Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 31

Ocelot and Jaguarundi Ocelots and jaguarundis prefer dense thornshrub habitats with high canopy cover and shrub density (TPWD 2013; Tewes and Grassman 2005; Service 1990, 2013, 2016). Jaguarundis will also use bunchgrass pastures adjacent to dense woody cover (Service 2013). During dispersal, both species are expected to travel across open areas with little to no shrub cover (Service 2013, 2016).

The last confirmed sighting of jaguarundi in Texas was documented in the Brownsville area in 1986, and no known jaguarundi populations currently exist in Texas. The nearest known jaguarundis are found over 100 miles from Cameron County in Nuevo Leon, Mexico (Service 2013). The nearest known breeding population of ocelots to the Boca Chica Tract is located several miles to the north at the Laguna Atascosa NWR. The Boca Chica Tract is within dispersal distance of that population, and in 1998 B&A trapped, radio-collared, and tracked a young male ocelot in and around the Boca Chica Tract. The ocelot was captured on an unnamed loma located between SH 4 and the BSC about two miles from the Boca Chica Tract, and between April and June 1998, the ocelot used lomas and other brushy areas surrounding the existing packed dirt road area, including Loma de la Jauja. The ocelot was last recorded several miles north of the Boca Chica Tract near Laguna Atascosa NWR (B&A 2003). No ocelots have been documented in the immediate vicinity since 1998.

As shown in Figure 7, dense thornshrub associated with Loma de la Jauja occurs in the Proposed Access Road 1 survey corridor off the refuge. This vegetation community also occurs on other nearby lomas and in patches along the Rio Grande. No dense thornshrub habitat is mapped within the Proposed Access Road 2 survey corridor, as Annova shifted the survey corridor so that the western edge is at the edge of the existing packed dirt road thereby avoiding the loma.

South Texas Ambrosia and Texas Ayenia South Texas ambrosia was known to occur historically in Cameron County but not within the Service’s Boca Chica Tract (TPWD 2015). The species has not been documented in Cameron County for over 70 years and is currently thought to be limited to Nueces and Kleberg Counties well to the north (Service 1994, 2010a). It grows at low elevations in prairies or savannahs on heavy soils ranging from clay loams to sandy loams (Service 1994). Associated native grass species include Texas grama (Bouteloua rigidiseta), buffalograss (Buchloe dactyloides), Texas wintergrass (Stipa leucotricha), and tobosa (Hilaria mutica). Native woody plant associates include honey mesquite, huisache (Acacia farnesiana), huisachillo (A. schaffneri), brasil (Condalia hookeri), granjeno, and lotebush.

Texas ayenia is known to occur in limited populations in Cameron, Hidalgo, and Willacy Counties, with the nearest known population being approximately 30 miles northwest of the Boca Chica Tract of the refuge (Service 2010b, TPWD 2015). It grows at low elevations in dense, relatively moist, subtropical riparian woodlands and at the edge of thickets located on well-drained, calcareous sandy loams, fine sandy loams, and clays of the Hidalgo, Willacy, Mercedes, and Raymondville soil series (Service 1994, Poole et al. 2007). This plant is associated with the Texas Ebony-Anacua plant community, which includes such other species as coma, brasil, honey mesquite, lotebush, granjeno, lime prickly-ash, and snake-eyes (Phaulothamnus spinescens).

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Of the vegetation communities in the survey corridors, the loma vegetation (i.e., dense and moderately dense thornshrub) provides potential, although marginal, habitat for South Texas ambrosia and Texas ayenia (see locations of these habitat types in Figure 7). Neither of these species has been documented on Point Isabel clay loam, and neither species was observed by B&A during pedestrian surveys along Loma de la Jauja and other lomas in the area. Based on the habitat assessment and surveys, South Texas ambrosia and Texas ayenia have not been documented in the survey corridors.

Alternative A – No Action - Deny the Permit Under Alternative A, the existing habitat conditions would be maintained along the existing packed dirt road resulting in no new impacts to endangered species on refuge property. However, construction and operation of Proposed Access Road 1 would result in habitat loss and potential effects to listed species off refuge property. Vegetation clearing for construction of Proposed Access Road 1 could cause the loss of foraging habitat and potential nesting sites for the northern aplomado falcon. During both the construction and operation phases, human disturbance may cause northern aplomado falcons to be flushed from the area and displaced, expend additional energy, and may interrupt foraging or roosting. Northern aplomado falcons are fairly intolerant of human activities and expected to avoid areas where construction and operation activities occur. Noise from construction and operation of Proposed Access Road 1 is expected to have minimal effects on aplomado falcons, and the potential for vehicle collisions is expected to be low. Construction activates would avoid work during nesting season.

Potential impacts to the ocelot and jaguarundi from construction of Proposed Access road 1 include loss of dense thornshrub habitat, as well as human disturbance and potential for vehicle collisions. Under Alternative A, approximately 5.1 acres of dense thornshrub habitat would be cleared from Loma de la Jauja, which would fragment habitat patches on Loma de la Jauja causing moderate, localized adverse impacts. In addition, human disturbance, including noise and artificial lighting, could further discourage ocelot and jaguarundi use of the area during project construction. Lighting is expected to be minimized during operations so the long-term impact would be reduced.

In addition to current traffic levels (unknown, but estimated at approximately 10 vehicle trips per month) on the existing packed dirt road for Service and other approved uses, which would continue under this alternative, new traffic would utilize Proposed Access Road 1 to access the Annova LNG Project site. The addition of a new road off refuge may increase the potential for collisions and associated ocelot injury or mortality. Annova has proposed to minimize the potential for wildlife-vehicle collisions by incorporating wildlife crossings (culverts) and associated fencing into the road design and mandating a speed limit of 25 miles per hour on the access road.

Alternative B – Proposed Action - Issue the Permit As with Alternative A, Alternative B would result in potential impacts to endangered species, including habitat loss, human disturbance, and potential for vehicular collisions. An Intra-Service Section 7 Biological Evaluation found the construction of Proposed Access Road 2 through the refuge “May affect, but is not likely to adversely affect species/adversely modify critical habitat” (Service 2019) for the five species potentially located in the project area.

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Under Alternative B, the existing habitat conditions on the refuge would be altered; however, impacts to sensitive habitat availability would be less than Alternative A because this alternative would primarily alter barren (packed dirt road) and coastal salt prairie habitat. The anticipated effects of construction and operation of Proposed Access Road 2 through the refuge on northern aplomado falcons would be similar to Alternative A, although the reduced habitat loss (18 versus 31 acres (7.5 on refuge)) would have a corresponding decrease in potential adverse impacts to this species. For ocelot and jaguarundi, habitat loss would be reduced under Alternative B because it avoids dense thornshrub habitats and maximizes road construction on already disturbed areas. In addition, this alternative avoids crossing Loma de la Jauja.

Human disturbance impacts from construction and operation of the access road are expected to be similar for the two alternatives. Under Alternative B, the potential for vehicular collisions and associated ocelot injury or mortality is expected to be less than for Alternative A. This is due to (1) the concentration of traffic onto one road, instead of multiple roads, and (2) the location of the access road adjacent to, rather than across, Loma de la Jauja. Annova would work with the Service to minimize the potential for vehicular collision by incorporating, wildlife crossings (culverts) and associated fencing, signage, traffic calming into the road design, mandating a speed limit of 25 miles per hour on the access road, avoiding construction work during nesting season, and limiting construction activities to daylight hours only.

Other Wildlife The wide variety of habitats present in south Texas allows for great wildlife diversity. Approximately 700 species of vertebrates have been recorded in the region (Jahrsdoerfer and Leslie 1988), including species also found in Mexico and Central America, the southwestern desert, the Gulf Coast, and southeast Texas (Blair 1950). Some species found in south Texas are not found anywhere else in the U.S., including the ocelot, jaguarundi, blue spiny lizard (Sceloporus cyanogenys), and 21 bird species found in Mexico and Central America that reach the northern limits of their ranges in the Lower Rio Grande Valley (Jahrsdoerfer and Leslie 1988).

Species lists have been recorded for the refuge and include 24 amphibians, 34 fish, 56 mammals, 50 reptiles, and over 400 birds (Service 2012). A wide variety of wildlife are expected to utilize the various habitat types present in the survey corridors, but these habitat types are not unique to the survey corridors and are found throughout the Boca Chica Tract and on adjacent properties.

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Alternative A – No Action - Deny the Permit Under Alternative A, the existing habitat conditions on refuge property would be maintained. However, habitat loss associated with construction of Proposed Access Road 1 would reduce the available habitats for wildlife species in the immediate vicinity (Table 3). This includes moderate adverse impacts to dense thornshrub communities that may provide habitat for the endangered ocelot, as well as small mammals, birds, and other wildlife. Increased disturbance from noise would affect out to a distance of one mile from Proposed Access Road 1 during construction and to a lesser extent during operations resulting in increased flushing and avoidance by wildlife species. The addition of Proposed Access Road 1 through previously undisturbed habitat may alter wildlife movement in the area and could result in loss of wildlife through vehicular collisions. However, this alternative may lower the potential for vehicular collisions on SH 4 because it minimizes the distance traveled on SH 4, which has a higher speed limit, as well as provides for the shortest total travel distance from SH 4. Direct mortality of wildlife during construction may be higher in the short term under Alternative A because the activity would take place in previously undisturbed areas where wildlife is less accustomed to human-caused disturbance.

Annova would incorporate wildlife crossings (culverts), and mandate a speed limit of 25 miles per hour on Proposed Access Road 1 to help minimize the potential for wildlife-vehicle collisions.

Alternative B – Proposed Action - Issue the Permit Under Alternative B, wildlife habitat loss would occur on the refuge, but overall impacts to dense thornshrub, wetlands, and other native habitats that support wildlife would be reduced compared to Alternative A (Table 3 & 4 and Figure 7). In addition, dense thornshrub habitat patches on Loma de la Jauja would not be fragmented under this alternative. Disturbance to wildlife from noise would be lower in Alternative B because traffic would be concentrated onto one road, instead of multiple roads, in an area which currently has a higher level of disturbance from existing traffic where wildlife that is sensitive to noise and human presence would likely already avoid or limit exposure to the area. This alternative would keep traffic traveling to the LNG Project site on the higher speed SH 4 for an additional 0.85 miles, which may slightly increase the potential for vehicular collisions on the highway. Traffic levels during operations and construction are expected to be the same under both alternatives. In addition to the steps taken to reduce wildlife collisions in Alternative A, the refuge would require incorporating traffic calming into the road design, educating construction and maintenance personnel about wildlife collisions, installing “Wildlife Crossing” signage, and limiting construction activities to daylight hours to further minimize the potential for wildlife-vehicle collisions.

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3.3 Human Environment

Cultural Resources B&A conducted cultural resources surveys in accordance with compliance requirements under Section 106 of the National Historic Preservation Act (NHPA) with FERC as the lead federal agency, as well as the Antiquities Code of Texas. As part of these compliance efforts, B&A conducted archeological investigations within the respective survey corridors from the point of convergence to SH 4. These investigations are described in two reports (B&A 2015, 2017) that were submitted to the Texas Historical Commission (THC)/State Historic Preservation Office (SHPO) for review and concurrence under Section 106 of the NHPA. A brief summary of investigations is provided below.

Based on a review of the THC’s online Texas Archeological Sites Atlas, no previously documented archeological sites are located within the survey corridors. B&A conducted an intensive archeological survey of the survey corridors, with surface and subsurface investigations as necessary based on field conditions, in accordance with appropriate research methods (developed pursuant to 13 Texas Administrative Code 26.21(d)).

Transects were walked and visually inspected at 30-meter intervals in addition to systematic shovel testing. Along the Proposed Access Road 1 survey corridor, 38 shovel tests were excavated. Within the Proposed Access Road 2 survey corridor, 36 shovel tests were excavated, 19 of which were located on refuge property. No new archeological sites were mapped in the survey corridors; however, in areas that contain dense mature thornshrub habitats, survey was limited to areas that could be accessed without disturbing the brush. The areas that were not investigated in the Proposed Access Road 1 survey corridor should be subject to archeological survey before the proposed project proceeds in those localities. In addition to the archeological survey, the Annova team conducted a non-archeological historic resources survey of the survey corridors. No non-archeological historic resources were located within the survey corridors. These determinations were coordinated with the THC/SHPO under Section 106 of the NHPA, and the SHPO concurred with the determinations by letter dated May 4, 2017.

Alternative A – No Action - Deny the Permit Under Alternative A, there are no anticipated direct or indirect impacts to cultural resources on refuge property, as current conditions would be maintained and no new ground disturbance would occur. No impacts to cultural resources are currently expected along Proposed Access Road 1 because no cultural resources have been found in those areas during on-site surveys. However, dense thornshrub areas within the 157-foot LOD would need to be surveyed for archeological resources before construction of the road proceeds.

Alternative B – Proposed Action - Issue the Permit Under Alternative B, no impacts to cultural resources would occur, as no cultural resources were found within the Proposed Access Road 2 survey corridor during on-site surveys. For this alternative, all areas have been surveyed.

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Socioeconomic Resources The U.S. Census Bureau data were utilized to create a profile of the community living in the vicinity of the alternative access road survey corridors. While the survey corridors are located on refuge property and BND property, there are residential areas along SH 4 in the vicinity. Table 6 provides a summary of the community profile.

Table 6. Community Profile for Access Road Vicinity Percent Speaks Median Annual Percent Total Spanish, Speaks Location Household Hispanic or Population English Not Well or Income Latino Not At All Texas 24,985,749 $54,727 37.6% 7.0% Cameron County, Texas 382,336 $34,578 88.1% 17.2% Census Tract 127, 5,263 $31,221 94.5% 25.1% Cameron County, Texas Block Group 2, Census 570 $31,131 81.3% 15.6% Tract 127 Source: U.S. Census Bureau 2018a, 2018b, 2018c

Overall, the community in the vicinity of the survey corridors (i.e., in Block Group 2 of Census Tract 127) is demographically similar to Cameron County as a whole. Cameron County has a lower median household income than the state of Texas as a whole and has a significantly higher proportion of the population that is Hispanic or Latino (Table 6).

Alternative A – No Action - Deny the Permit Construction and maintenance of Proposed Access Road 1 would have a positive impact on the local economy because of spending by Annova related to short-term construction activities and long-term maintenance activities for the road.

Alternative B – Proposed Action - Issue the Permit Construction of Proposed Access Road 2 would have a similar positive impact on the economy to Alternative A.

Visitor Services/Activities Currently, there is no vehicle access for the public to the existing access road, and no visitor services or activities are provided in this part of the refuge. The tract is open to the public via foot traffic but receives minimal use. The primary visitor use of this tract involves wildlife observation of migratory birds during the fall and spring migration that is most likely to take place from SH 4. Neither alternative would have any impacts on visitor services programming activities.

Aesthetic and Visual Resources Alternative A – No Action - Deny the Permit Under Alternative A, there would be little change to the existing visual landscape. Proposed Access Road 1 would not introduce a visual contrast for visitors observing the refuge from SH 4 because the view of the road and associated traffic would be blocked by Loma de la Jauja.

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Alternative B – Proposed Action - Issue the Permit Under Alternative B, Proposed Access Road 2 is not expected to significantly increase the visual contrast for visitors of the area from what is present under existing conditions. The road would be raised, but would not have aboveground ancillary facilities except for a gate and intermittent fencing associated with wildlife crossings. Proposed Access Road 2 would be collocated with the existing road, which currently has a gate and is clearly visible from SH 4.

3.4 Assessment of Cumulative Impacts

A cumulative impact is defined as an impact on the environment that results from the incremental impact of the Proposed Action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such other actions. Cumulative impacts can result from individually minor, but collectively significant, actions taking place over a period of time (40 CFR 1508.7).

Cumulative impacts are the overall net effects on a resource that arise from multiple actions. Impacts can “accumulate” spatially when different actions affect different areas of the same resource. They can also accumulate over the course of time from actions in the past, the present, and the future. Occasionally, different actions counterbalance one another, partially canceling out each other’s effects on a resource. However, more typically, multiple effects add up, with each additional action contributing an incremental impact on the resource.

Future activities related to the SpaceX Texas Project launch facility in the vicinity of the refuge would produce short-term high levels of noise that would disturb wildlife. Increased traffic from personnel and spectator presence may increase the potential for vehicular collisions as analyzed in the Final Environmental Impact Statement SpaceX Texas Launch Site (May 2015).

Three LNG projects are currently engaged in the FERC application process along the BSC. The facilities, pipelines, utilities, widened roads, their associated shipping and vehicle traffic and potential population increases would result in adverse impacts to local habitats and wildlife. Refer to chapter 4.13 of the Rio Grande LNG Project Final Environmental Impact Statement (FEIS) Volume I (Docket Nos. CP16-454-000, CP16-455-000), issued by FERC in April 2019, and chapter 4.13 of the Annova LNG Brownsville Project FEIS Volume I (Docket No. CP16- 480-000), issued by FERC in April 2019 for discussions of cumulative impacts in the area of the BSC relating to LNG projects, oil and gas activities, utilities, and other sources.

The Annova LNG Brownsville Project FEIS determined that the LNG Project may affect, and is likely to adversely affect two federally listed species, the ocelot and Gulf Coast jaguarondi. The Service through the Endangered Species Act Section 7 consultation process and a Biological Opinion would recommend voluntary and require reasonable and prudent measures to avoid and minimize impacts to the two species. Measures would likely include the setting aside of conservation easements, land acquisition, cat corridors, wildlife crossings, minimized lighting, contractor education, environmental monitors, funding translocations, and thronscrub restoration.

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Areas around the refuge have a high potential for urban and/or industrial development. This type of development results in habitat fragmentation, which could cumulatively impact the area’s natural resources. The development of the Annova LNG Project and access road would likely occur whether or not the refuge issues the ROW permit. The refuge’s proposed action (to issue the ROW permit) is intended to minimize further habitat fragmentation and is incrementally negligible when compared to the other activities occurring in the area. The Proposed Action is likely to result in minor positive cumulative impacts in the local area by protecting preferred ocelot habitat types.

3.5 Environmental Justice

Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority and Low- Income Populations; February 11, 1994) was designed to focus the attention of federal agencies on the environmental and human health conditions of minority and low-income populations, with the goal of achieving environmental protection for all communities. The order directed federal agencies to develop environmental justice strategies to aid in identifying and addressing disproportionately high and adverse human health and environmental effects of their programs, policies, and activities on minority and low-income populations. The order is intended to promote nondiscrimination in federal programs substantially affecting human health and the environment and to provide minority and low-income communities with access to public information and opportunities for participation in matters related to human health and the environment.

None of the alternatives described in this EA would disproportionately place any adverse environmental, economic, social, or health impacts on minority and low-income populations.

3.6 Indian Trust Assets

No Indian Trust Assets have been identified in the refuge. There are no reservations or ceded lands present. Because resources are not believed to be present, no impacts are anticipated to result from implementation of either alternative described in the EA.

3.7 Unavoidable Adverse Effects

There would be some habitat loss and short-term disturbance to resident wildlife, but these impacts are expected to be minimal.

3.8 Irreversible and Irretrievable Commitment of Resources

Irreversible and irretrievable resource commitments are related to the use of nonrenewable resources and the effects that this use could have on future generations. Irreversible effects primarily result from the use or destruction of specific resources that cannot be replaced within a reasonable time frame, such as energy or minerals. Irretrievable resource commitments involve the loss in value of an affected resource that cannot be restored as a result of the action, such as extinction of a threatened or endangered species or the disturbance of a cultural resource. None of the alternatives would result in a large commitment of nonrenewable resources.

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3.9 Summary of Environmental Consequences

Table 7 provides a summary of environmental consequences.

Table 7. Summary of Environmental Effects by Alternative Alternative B Alternative A Environmental Resource Proposed Action – Issue the No Action – Deny the Permit Permit Minor adverse impacts Impacts to Air Quality Same as Alternative A. anticipated. Some impacts likely to continue Localized impacts to surface Impacts to Soils on refuge; Moderate adverse soils; Minor adverse impacts impacts anticipated off refuge. anticipated. Minor adverse impacts to water quality or quantity off refuge. No impacts to wetlands along Minor adverse impacts to water Impacts to Water Quality existing access road on refuge quality or quantity. Loss of < 0.1 and Quantity property, but loss of acre of emergent wetland on approximately 1.4 acres of refuge property. emergent wetland on adjacent property. No adverse impacts to habitat on refuge property. Moderate Minor adverse impacts from loss Impacts on adverse impacts from loss of of emergent wetland (< 0.1 acre); Vegetation/Wildlife emergent wetland (1.4 acres) and no dense thornshrub would be Habitat dense thornshrub (5.1 acres) on lost. adjacent property. Minimal impacts likely to continue along existing access Minor adverse impacts from loss road on refuge property. of ~18 acres of habitat in Impacts on Wildlife Moderate adverse impacts from detailed analysis area, ~7.5 acres loss of 31 acres of habitat on of which is on refuge property. adjacent property. Moderate adverse impacts from Minor adverse impacts; no dense habitat loss for northern thornshrub vegetation (ocelot Impacts on Threatened and aplomado falcon, ocelot, and habitat) would be lost. Potential Endangered Species jaguarundi. Potential for for vehicular collisions for vehicular collisions for ocelot. ocelot. Impacts on Cultural No cultural resources present; no Same as Alternative A. Resources impacts. Impacts on Socioeconomic Potential beneficial benefit to Same as Alternative A. Resources local economy. Existing road currently bisects Impacts on Aesthetic and Minimal impacts to visual habitat, but minimal impacts to Visual Resources resources. visual resources.

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4.0 CONSULTATION, COORDINATION, AND DOCUMENT PREPARATION

Bryan Winton, Refuge Manager, Service, Lower Rio Grande Valley NWR, Alamo, TX. Chris Perez, Wildlife Biologist, Service, South Texas Refuge Complex, Alamo, TX.

Other Contributors/Reviewers included:

Carol Torrez, Chief, Branch of Planning, Service Division of Realty, Albuquerque, NM. Monica Kimbrough, Assistant Refuge Supervisor, Service Division of Refuges, Albuquerque, NM. Anibal Vazquez, Natural Resources Planner, Branch of Planning, Albuquerque, NM.

Agencies and Individuals Consulted in the Preparation of this Document Include:

Blanton & Associates, Austin, TX Ecology & Environment, Inc., Houston, TX

5.0 REFERENCES

Black & Veatch. 2016. Geotechnical Investigation Report, Annova LNG Brownsville Project. Document Number 183169‐STDY‐0006. March 21, 2016.

Blanton & Associates, Inc. (B&A). 2003. Annual trapping surveys – 1998-2002 for the endangered ocelot and jaguarundi, Port of Brownsville proposed international crossing.

______. 2015. Draft Intensive Cultural Resources Investigations of the Annova LNG Brownsville Project, Cameron County, Texas. Prepared by J. M. Sanchez, J. J. Dowling, A. S. Burden, and T. B. Griffith. Prepared for Ecology & Environment, Inc. Principal Investigator, T. B. Griffith. Texas Antiquities Permit No. 7040. July 2015.

______. 2017. Draft Addendum Report, Intensive Archeological Survey of Access Road Alternative 2, Annova LNG Brownsville Project, Cameron County, Texas. Prepared by T. B. Griffith and J. M. Sanchez. Prepared for Ecology & Environment, Inc. Principal Investigator, T. B. Griffith, Ph.D. Texas Antiquities Permit No. 7040. May 2017.

Blair, W. F. 1950. The Biotic Provinces of Texas. Texas Journal of Science. Pp. 93-117.

Campbell, L. 2003. Endangered and threatened animals of Texas, their life history and management. Texas Parks and Wildlife Division. Austin. eBird. 2015. Range and point maps. http://ebird.org/ebird/map.

Environmental Laboratory. 1987. Corps of Engineers wetlands delineation manual, Technical Report Y-87-1 (on-line edition), U.S. Army Corps of Engineers Waterways Experiment Station, Vicksburg, Mississippi. Accessed November 2014.

Draft Environmental Assessment – Issuance of a Right-of-Way Permit, Annova LNG, LLC; Boca Chica Tract of the Lower Rio Grande Valley National Wildlife Refuge, Cameron County, Texas 41

Federal Aviation Administration (FAA). 2014. Final Environmental Impact Statement SpaceX Texas Launch Site. Prepared by: Federal Aviation Administration Office of Commercial Space Transportation.

Federal Energy Regulatory Commission (FERC), Office of Energy Projects. 2019. Annova LNG Brownsville Project Final Environmental Impact Statement Volume I. Available at https://www.ferc.gov/industries/gas/enviro/eis/2019/04-19-19-FEIS.asp.

Federal Energy Regulatory Commission (FERC), Office of Energy Projects. 2019. Rio Grande LNG Project Final Environmental Impact Statement Volume I. Available at https://www.ferc.gov/industries/gas/enviro/eis/2019/04-26-19-FEIS.asp.

Haines, A. M., M. E. Tewes, L. L. Laack, W. E. Grant, and J. Young. 2005. Evaluating recovery strategies for an ocelot (Leopardus pardalis) population in the United States. Biological Conservation 126:512-522.

Jahrsdoerfer, S. E. and D. M. Leslie, Jr. 1988. Tamaulipan brushland of the Lower Rio Grande Valley of South Texas: description, human impacts, and management options. U.S. Fish and Wildlife Service, Biological Report 88(36).

National Marine Fisheries Service (NMFS). 2017. Texas’ threatened and endangered species and critical habitat designations. NOAA Fisheries Southeast Region Protected Resources Division. Available at http://sero.nmfs.noaa.gov/protected_resources/section_7/threatened_endangered/. Accessed March 2017.

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