ML043280682

Request for Concurrence - Biological Assessment for Point Beach Nuclear Plant, Units 1 and 2 License Renewal

ML043280682
Person / Time
Site:	Point Beach
Issue date:	11/22/2004
From:	Kuo P NRC/NRR/DRIP/RLEP
To:	James Smith US Dept of Interior, Fish & Wildlife Service
Imboden S, NRR/DRIP/RLEP, 415-2462
References
Download: ML043280682 (16)

Text

November 22, 2004 Ms. Janet Smith Field Supervisor U.S. Fish and Wildlife Service Green Bay ES Field Office 2661 Scott Tower Drive New Franken, WI 54229-9565

SUBJECT:

REQUEST FOR CONCURRENCE - BIOLOGICAL ASSESSMENT FOR POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL

Dear Ms. Smith:

The U.S. Nuclear Regulatory Commission (NRC) has prepared the enclosed biological assessment (BA) to evaluate whether the proposed renewal of the Point Beach Nuclear Plant, Units 1 and 2 (PBNP) operating licenses for a period of an additional 20 years would have adverse effects on listed species. The proposed action (license renewal) is not a major construction activity. PBNP is located on the western shore of Lake Michigan in Manitowoc County, Wisconsin, approximately 48 km (30 mi) southeast of Green Bay and 24 km (15 mi) north-northeast of Manitowoc.

By letter dated May 5, 2004, to the U.S. Fish and Wildlife Service (FWS), the NRC requested a list of Federally threatened or endangered species that may be in the vicinity of PBNP and its associated transmission lines. In a letter dated August 5, 2004, the FWS provided a list of Federally threatened or endangered species. The FWS stated that no Federally-listed threatened or endangered species, proposed species, candidate species, or proposed critical habitat occur at the PBNP site, but that beach habitat near PBNP could be suitable nesting habitat for piping plover (Charadrius melodus) at some time in the future. The NRC staff has also included in its evaluation three other potentially-occurring Federally-listed species.

In addition the staff also contacted the National Oceanic and Atmospheric Administration -

Fisheries (NOAA Fisheries) by letter dated May 12, 2004, requesting a list of Federally threatened or endangered aquatic species that may be in the vicinity of PBNP. NOAA Fisheries did not respond to the May 12, 2004, letter.

The staff has determined that license renewal for PBNP may affect, but is not likely to adversely affect the bald eagle and the piping plover, and will have no effect on the dwarf lake iris and the dune or Pitchers thistle.

We are requesting your concurrence with our determination. In reaching our conclusion, the NRC staff relied on information provided by the applicant, on literature research and interviews with experts, and on information provided by FWS.

J. Smith If you have any questions regarding this Biological Assessment or the staffs request, please contact Ms. Stacey Imboden, Environmental Project Manager, at 301-415-2462 or via e-mail at sxf@nrc.gov.

Sincerely,

/RA/

Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-266 and 50-301

Enclosure:

As stated cc w/encl.: See next page

1. Ltr to: J. Smith w/Biological Assessment, Svc. List: ML043280682 E:\\Filenet\\ML043280682.wpd OFFICE LA:RLEP GS:RLEP PM:RLEP SC:RLEP PD:RLEP NAME Ehylton CGuerrero SImboden AKugler PTKuo DATE 11/19/04 11/19/04 11/18/04 11/19/04 11/22/04

Point Beach Nuclear Plant, Units 1 and 2 cc:

Jonathan Rogoff, Esq.

Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Mr. F. D. Kuester President and Chief Operating Officer WE Generation 231 West Michigan Street Milwaukee, WI 53201 Regulatory Affairs Manager Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Ken Duveneck Town Chairman Town of Two Creeks 13017 State Highway 42 Mishicot, WI 54228 Chairman Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 Mr. Jeffrey Kitsembel Electric Division Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Nuclear Asset Manager Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, WI 53201 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Site Director of Operations Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Dennis L. Koehl Site Vice President Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Kenneth Westlake Chief, Environmental Planning and Evaluation Branch U.S. EPA Mail Code B-195 77 W. Jackson Blvd.

Chicago, IL 60604 Mr. Fred Emerson Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. James E. Knorr 6610 Nuclear Road Two Rivers, WI 54241

Point Beach Nuclear Plant, Units 1 and 2 cc: Mr. Nick Niederlander Lester Public Library 1001 Adams Street Two Rivers, WI 54241

Biological Assessment Point Beach Nuclear Plant License Renewal Review November 2004 Docket Numbers 50-266 50-301 U.S. Nuclear Regulatory Commission Rockville, Maryland 1.0 Introduction The U.S. Nuclear Regulatory Commission (NRC) issues operating licenses for domestic nuclear power plants in accordance with the provisions of the Atomic Energy Act of 1954, as amended, and NRC implementing regulations. The purpose and need for the proposed action (that is, renewal of an operating license) is to provide an option that allows electric power generation to continue beyond the term of the current nuclear power plant operating license, so future generating needs can be met if the operator and State regulatory agencies pursue that option.

Wisconsin Electric Power Company (WEPCO) owns Point Beach Nuclear Plant, Units 1 and 2 (PBNP), and Nuclear Management Company, LLC (NMC) operates PBNP. WEPCO is doing business as We Energies, and is a wholly owned subsidiary of Wisconsin Energy Corporation.

In August 2000, WEPCO transferred operating authority for PBNP to NMC (NMC 2004). NMC has prepared an environmental report in conjunction with its application for renewal of the PBNP operating licenses, as provided for by the following NRC regulations:

Title 10, Energy, Code of Federal Regulations (CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Section 54.23, Contents of Application -

Environmental Information (10 CFR 54.23).

Title 10, Energy, CFR Part 51, Environmental Protection Requirements for Domestic Licensing and Related Regulatory Functions, Section 51.53, Postconstruction Environmental Reports, Subsection 51.53(c), Operating License Renewal Stage [10 CFR 51.53(c)].

The NRC is reviewing an application submitted by NMC (the applicant) for the renewal of the operating licenses for PBNP for a period of an additional 20 years. There will be no major construction, refurbishment, or replacement activities associated with this action. This biological assessment examines the potential effects of the continued operation of PBNP on four Federally-listed species that could occur within the PBNP site, near the site, or along its associated transmission line rights-of-way (ROWs) pursuant to Section 7(a)(2) of the Endangered Species Act.

In a letter dated May 5, 2004 (NRC 2004), the NRC requested that the U.S. Fish and Wildlife Service (FWS) provide lists of Federally-listed endangered or threatened species and information on protected, proposed, and candidate species, as well as any designated critical habitat, that may be in the vicinity of PBNP and its associated transmission line ROWs. In a response dated August 5, 2004 (FWS 2004a), the FWS Green Bay Field Office noted that beach habitat near PBNP could be suitable nesting habitat for piping plover (Charadrius melodus) at some time in the future. Three other potentially-occurring Federally-listed species were identified by NRC staff and are included in this assessment.

2.0 Proposed Action The proposed action is the renewal of the operating licenses for PBNP. The plant is located on the western shore of Lake Michigan in Manitowoc County, Wisconsin, approximately 48 km (30 mi) southeast of Green Bay and 24 km (15 mi) north-northeast of Manitowoc (Figure 1)

Figure 1. Location of PBNP.

(NMC 2004). The current operating license for Unit 1 expires on October 5, 2010, and for Unit 2 on March 8, 2013. NMC has submitted an application to the NRC to renew these operating licenses for an additional 20 years of operation (i.e., until October 5, 2030, for Unit 1 and March 8, 2033 for Unit 2). The renewed licenses, if issued, will be effective from their date of issuance until 20 years after the expiration date of the current operating licenses.

3.0 Environmental Setting 3.1 Aquatic Resources Impacts on Federally-listed terrestrial threatened or endangered species that could potentially occur as a result of continued operation of the plant cooling water system during the renewal period are outlined in this section.

Lake Michigan is the source of water for the cooling and auxiliary water systems at PBNP, which operates as a once-through cooling plant. Water from Lake Michigan reaches PBNP through a submerged offshore intake. Water returns to Lake Michigan through a surface shoreline discharge. The system removes waste heat from the condensers as well as other plant equipment and discharges water through separate flumes for each unit.

At peak capacity, water is circulated at a maximum rate of 22 m3/s (783 ft3/s) through each condenser and then returned to the lake. The water withdrawn for these systems flows first through the intake structure to the forebay, then to the condensers and other equipment.

Auxiliary water systems include service water and fire protection.

In May 2001, the intake structure was reconfigured to resolve a bird mortality issue. The modified structure stands approximately 3.4 m (11 ft) above the lake floor, has an outside diameter of about 33 m (110 ft), and has an inside chamber with a diameter of 18 m (60 ft).

The top is covered with a steel superstructure and a trash rack made of high-density polyethylene having approximately 18-cm by 45-cm (7-in. by 18-in.) openings (NMC 2001).

Water enters the chamber through the trash rack as well as through void spaces around the limestone blocks and through 76-cm (30-in.) pipes that penetrate the blocks in a ring about 1.5 m (5 ft) above the lakebed. The pipes are covered with 3-cm by 5-cm (1.2-in. by 2-in.) bar gratings to prevent debris and large fish from entering the intake system.

3.2 Terrestrial Resources The PBNP site is located on 510 ha (1260 ac) on the shore of Lake Michigan (NMC 2004). The site and surrounding area consist primarily of agricultural land and forest. Approximately 42 ha (104 ac) of the property are devoted to industrial use. The site consists of land leased for farming and woodlots up to 19 ha (47 ac) in size. The woodlots occupy a total of about 40 ha (100 ac), making up about 9 percent of the PBNP property. The plant communities here include a variety of trees such as aspen (Populus tremuloides), blue beech (Fagus grandifolia),

hemlock (Tsuga canadensis), and maple (Acer) species forming the overstory (AEC 1972).

The woodlots are maintained in a natural state and provide food, cover, and nesting sites for a variety of wildlife.

The terrestrial wildlife that occurs at PBNP site and surrounding areas is typical of that found in similar habitats throughout Wisconsin (AEC 1972). Common mammals include white-tailed deer (Odocoileus virginianus), cottontail rabbit (Sylvilagus floridanus), raccoon (Procyon lotor),

gray fox (Urocyon cineroargenteus), gray squirrel (Sciurus carolinensis), eastern chipmunk (Tamias striatus), and masked shrew (Sorex cinereus). Upland birds that occur on the property include ring-necked pheasant (Phasianus colchicus), wild turkey (Meleagris gallopavo),

American goldfinch (Carduelis tristis), eastern bluebird (Sialia sialia), blue jay (Cyanocitta cristata), and eastern meadowlark (Sturnella magna). Several waterfowl also occur here, including the Canada goose (Branta canadensis) and the wood duck (Aix sponsa). Additionally, the site is occupied by several common amphibians and reptiles such as the tiger salamander (Ambystoma tigrinum), northern leopard frog (Rana pipiens), American toad (Bufo americanus),

and the painted turtle (Chrysemys picta).

The PBNP property contains about 3 km (2 mi) of Lake Michigan shoreline. The shoreline here consists of mostly narrow, bare beaches ranging from 6 m to 15 m (20 ft to 50 ft) wide that extend from the waters edge to low bluffs created by years of erosion. Riprap has been placed along the edges of the bluffs to reduce erosion, which had been occurring at the rate of 0.8 m to 1.5 m (2.5 ft to 5 ft) per year (AEC 1972). The shoreline on the PBNP property does not contain any sand dunes.

In its Environmental Report, the applicant identified three 345-kilovolt (kV) transmission lines that connect PBNP to the power grid (Figure 2) (NMC 2004). A fourth 345-kV line connects the Kewaunee Nuclear Power Plant to the substation at PBNP. Currently the four lines are owned and maintained by the American Transmission Company (ATC). The transmission lines are described below and each corridors characteristics are shown in Table 1.

Table 1.

PBNP Transmission Line Rights-of-Way Substation Rights-of-Way Number of Lines kV Approximate Length Approximate Width Approximate Area km (mi) m (ft) ha (ac)

Granville L-111 1

345 32.0 20.0 67 220 210 530 Arcadian L-121 1

345 29.0 18.0 67 220 190 480 North Appleton L-151 1

345 47.5 29.7 67 220 320 790 PBNP Q-303 1

345 9.0 5.6 67 220 61 150 Source: NMC 2004 Each ROW is 67 m (220 ft) wide. Figure 2 shows the transmission system for PBNP. For the specific purpose of connecting PBNP to the power grid, ATC has a total of 118 km (73.3 mi) of transmission lines occupying approximately 791 ha (1955 ac) of easement (NMC 2004). The ROWs pass through land that is primarily rolling hills covered in forest and farmland. These ROWs pass through rural areas with low population densities. The lines cross numerous State and Federal highways, including Wisconsin Highways 42 and 147 and Interstate 43.

Figure 2. PBNP transmission lines.

ROWs that pass through farmland generally continue to be managed as such. ATC plans to maintain these lines indefinitely as they are an integral part of the larger transmission system.

These transmission lines are expected to remain a permanent part of the regional transmission system after decommissioning of PBNP.

ATC implements the ROW inspection and maintenance program for PBNP-associated transmission lines (ATC 2004). ATC manages transmission line ROWs using a wire zone/border zone concept. The wire zone is directly below the transmission lines and vegetation is primarily low growing forbs and grasses. The border zone extends from the wire zone to the edge of the ROW and woody species less than 5 m (15 ft) tall provide a transition to the surrounding habitats. Vegetation management activities may include tractor mowing, manual chainsaw clearing, and application of herbicides by a state-licensed, commercial applicator. Trimming is usually performed every 5 to 7 years, depending on the growth rates of vegetation in a given area. ATC recognizes that transmission line ROWs provide ancillary compatible uses including wildlife habitat, biodiversity corridors, recreation, and aesthetics.

ATC practices a vegetation management program that utilizes physical, chemical, and biological treatments to promote stable, diverse, low-growing plant communities in a way that promotes wildlife habitat and reduces environmental impacts.

4.0 Assessment of Federally-Listed Species There are no Federally-listed threatened or endangered aquatic species known to occur at the PBNP site or on habitat crossed by the associated transmission line ROWs (NMC 2004). There are four Federally-listed threatened or endangered terrestrial species that have been identified by the staff as potentially occurring in the vicinity of PBNP and its associated transmission lines.

Three species have been recorded in Manitowoc County: the bald eagle (Haliaeetus leucocephalus), the piping plover (Charadrius melodus), and the dune or Pitchers thistle (Cirsium pitcheri) (WDNR 2004). The dwarf lake iris (Iris lacustris), also a Federally-listed species, has been recorded in Brown County, which is traversed by a PBNP transmission line.

Table 2 presents those Federally and State-listed species that have been recorded in Brown and Manitowoc Counties and could potentially occur on the PBNP site or transmission line ROWs, if suitable habitat were available.

Table 2.

Terrestrial Species Listed as Endangered or Threatened by the FWS and that Occur or Potentially Occur Within the PBNP Site or the Associated Transmission Line Rights-of-Way Scientific Name Common Name Federal Status(a)

Birds Haliaeetus leucocephalus bald eagle T

Charadrius melodus piping plover E

Plants Cirsium pitcheri dune (or Pitchers) thistle T

Iris lacustris dwarf lake iris T

(a) E = endangered, T = threatened. Sources: FWS 2004b.

Bald Eagle (Haliaeetus leucocephalus)

The bald eagle is Federally-listed as threatened in the lower 48 states (FWS 2004b). This species is a large raptor that is found along the coastline around lakes and rivers. Eagles generally nest in tall trees or on cliff faces near water and away from human disturbance. No bald eagle nesting occurs on the plant site and none have been observed to forage in the vicinity of the plant (We Energies 2004a). The transmission lines extend for the most part to the west, away from Lake Michigan and bald eagle foraging habitat.

For these reasons, the staff has determined that continued operation of PBNP over the 20-year license renewal period may affect, but is not likely to adversely affect the bald eagle.

Piping Plover (Charadrius melodus)

The piping plover is Federally-listed as endangered in the Great Lakes region (FWS 2004b).

Piping plovers breed only in three North American geographic regions: the Atlantic coast, the Northern Great Plains, and the Great Lakes. Great Lakes piping plovers breed along sparsely vegetated beaches, cobble pans, and sand spits along the shoreline. The FWS defines their essential breeding habitat as greater than 7 m (23 ft) wide beach, greater than 0.4 km (0.25 mi) of shoreline length, dune area of 1.95 ha (4.82 ac), patches of cobble or degree cover, and areas of beach with up to 50 percent of vegetation cover (FWS 2004b). The stretch of shoreline nearest to PBNP that is designated as critical breeding habitat is at Point Beach State Forest, approximately 5 km (3 mi) to the southeast, where about 13 km (8 mi) of shoreline have been designated as suitable, although there are no records of breeding at this location (FWS 2004c). The only breeding plovers known within Wisconsin in recent years are along the shores of Lake Superior (WDNR 2004).

We Energies conducted an initial piping plover suitability assessment of their Lake Michigan property on October 1, 2004. The assessment concluded that portions of the shoreline appear to be suitable nesting habitat (We Energies 2004b). Based on this result, a series of recommendations was presented:

No measures should be taken to enhance habitat suitability, A piping plover breeding census should be conducted annually between June 1 and June 15 using the International Piping Plover Breeding Census guidelines, and an individual census report should be completed each year, The FWS Green Bay Field Office and the Wisconsin Department of Natural Resources Bureau of Endangered Resources should be contacted on the day that nesting piping plovers are discovered on the site, and We Energies will collaborate with the above-mentioned agency staffs to determine beach access, nesting habitat protection, and monitoring requirements.

In correspondence dated November 5, 2004, We Energies agreed to implement these recommendations (We Energies 2004c). In addition, NMC restricts unauthorized public access to the Lake Michigan beach area of the PBNP site with a line of boulders at the north and south boundaries, buoy markers off the shoreline to mark restricted waters, and twenty-four hour security personnel surveillance. For these reasons, the staff has determined that continued operation of PBNP over the 20-year license renewal period may affect, but is not likely to adversely affect the piping plover.

Dune or Pitchers Thistle (Circium pitcheri)

The dune or Pitchers thistle is Federally-listed as threatened over its entire range (FWS 2004b). The preferred site for the dune or Pitchers thistle is an area between a sandy beach and a fully vegetated dune next to the shorelines of the Great Lakes (WDNR 2004). The primary threats to the species are disturbance through recreational activities (ATV use, trampling, etc.) and overstory encroachment (NatureServe 2004). Although no suitable habitat for this species has been identified at the PBNP site or along associated transmission line corridors, beach habitat is protected. NMC restricts unauthorized public access to the Lake Michigan beach area of the PBNP site with a line of boulders at the north and south boundaries, buoy markers off the shoreline to mark restricted waters, and twenty-four hour security personnel surveillance.

For these reasons, the staff has determined that continued operation of PBNP over the 20-year license renewal period will have no effect on the Pitchers thistle.

Dwarf Lake Iris (Iris lacutris)

The dwarf lake iris is Federally-listed as threatened over its entire range (FWS 2004b). The dwarf lake iris is endemic to the northern shores of Lake Michigan and Lake Huron. This species is found in association with the Niagara Escarpment, a limestone formation that extends from the Door Peninsula to the north of the PBNP site through Michigan and Ontario to New York. In Wisconsin the dwarf lake iris is found on the northwestern shore of Lake Michigan and the eastern shore of Green Bay in Brown and Door counties (WDNR 2004). The primary threat to this species is habitat degradation due to overstory encroachment (NatureServe 2004). This species apparently thrives with frequent natural disturbance and does not appear to be detrimentally impacted by human disturbance and is reported to do well in old-field conditions (NatureServe 2004). Although this species has not been recorded at the PBNP site or along associated transmission line corridors, potential beach habitat is protected.

NMC restricts unauthorized public access to the Lake Michigan beach area of the PBNP site with a line of boulders at the north and south boundaries, buoy markers off the shoreline to mark restricted waters, and twenty-four hour security personnel surveillance.

For these reasons, the staff has determined that continued operation of PBNP over the 20-year license renewal period will have no effect on the dwarf lake iris.

5.0 Conclusions The NRC staff has evaluated the potential impacts of an additional 20 years of continued PBNP operation on four species that are Federally-listed as threatened or endangered and have the potential to occur at the PBNP site or along its associated transmission line corridors. Although none of the four species are known to occur at the site or along transmission line corridors, NMC and ATC have developed and implemented procedures to protect wildlife and habitat.

The staff has determined that license renewal for PBNP may affect, but is not likely to adversely affect the bald eagle and the piping plover, and will have no effect on the dwarf lake iris and the dune or Pitchers thistle.

6.0 References 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

Atomic Energy Act of 1954. 42 United States Code (USC) 2011, et seq.

American Transmission Company (ATC). 2004. Routine Right-of-Way Maintenance. Accessed at: http://www.atcllc.com/projects_rightofway.shtml. on November 8, 2004.

NatureServe 2004. NatureServe Explorer: an Online Encyclopedia of Life. Version 3.1, NatureServe, Arlington, Virginia. Accessed at http://www.natureserve.org. on November 9, 2004.

Nuclear Management Company, LLC (NMC). 2004. Point Beach Nuclear Plant Operating License Renewal Application Environmental Report. Mishicot, Wisconsin. February 2004.

U.S. Atomic Energy Commission (AEC). 1972. Final Environmental Statement Related to Operation of Point Beach Nuclear Plant Units 1 and 2, Docket Nos. 50-266 and 50-301.

Directorate of Licensing. Washington, DC.

U.S. Fish and Wildlife Service (FWS). 2004a. Letter from U.S. Fish and Wildlife Service to Nuclear Regulatory Commission.

Subject:

Response to the May 5, 2004 NRC staff letter requesting information regarding threatened and endangered species in the vicinity of the PBNP. (August 5, 2004).

U.S. Fish and Wildlife Service (FWS). 2004b. Species Information, Threatened and Endangered Animals and Plants website. Accessed at http://endangered.fws.gov/wildlife.html.

on August 2, 2004 through September 23, 2004.

U.S. Fish and Wildlife Service (FWS). 2004c. All About Piping Plovers. Accessed at http://plover.fws.gov/facts.html on November 9, 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004. Letter from Nuclear Regulatory Commission to U.S. Fish and Wildlife Service.

Subject:

Request for information regarding threatened and endangered species in the vicinity of PBNP. (May 5, 2004).

We Energies. 2004a. Letter from We Energies Senior Terrestrial Ecologist, Dr. N. Cutright, to Nuclear Management Company Vice President.

Subject:

Response to U.S. Fish and Wildlife Service Letter. (May 12, 2004).

We Energies. 2004b. Piping plover Habitat on We Energies Property Near the Point Beach Nuclear Plant. Performed by Dr. N. Cutright, (October 15, 2004).

We Energies. 2004c. Letter from We Energies to Nuclear Regulatory Commission.

Subject:

Implementation of Piping Plover Habitat Survey Recommendations. (November 5, 2004).

Wisconsin Department of Natural Resources (WDNR). 2004. Wisconsin State Threatened and Endangered Species website. Accessed at:

http://www.dnr.state.wi.us/org/land/er/working_list/taxalists/TandE.asp on May 5, 2004.