November 13, 2017

Dear Pramilla,

After a review of the data available about the Valley Lateral Project, including the
Environmental Assessment as well as a review of the project site based on already documented
information, the two federally listed bat species that could be directly and indirectly impacted by
the project are the Indiana Bat (Myotis sodalis) and the Northern long-eared bat (Myotis
septentrionalis).

Without detailed field surveys, if both species are present at the site direct impacts could occur to
known roost trees or hibernacula if work is done during periods of use. To avoid these direct
impacts, timing restrictions for tree removal should be followed according to the United States
Fish and Wildlife Service (USFWS) guidelines, during a period when these species are
hibernating (October 1 March 31) and restricted to trees greater than 5 inches in diameter. The
available data show Indiana bats are present at the site, and Millennium LLC intends to comply
with timing restrictions for tree removal.

Indiana bats are both federally and state endangered in New York state, with the primary threats
including disturbance mainly to hibernacula, and loss of forested summer habitat. They
primarily roost under the bark of dead or dying trees but have also been known to roost under
loose bark of live trees like shagbark hickory.

Northern long-eared bats are listed as both federally and state threatened in New York state with
their main threat being White Nose Syndrome. Northern long-eared bats are less habitat-selective
than Indiana bats and forage in dense forests, roosting by day beneath the loose bark of trees or
in tree crevices

Based on the data for this site, the Indiana bat may be more affected by indirect impacts of this
project due to temporary or permanent loss, degradation, and/or fragmentation of suitable
habitat. However, to properly assess these indirect impacts independent detailed field surveys
(including acoustics, mist netting and radio telemetry), according to USFWS, Indiana bat survey
guidelines should be followed. Indiana bats could be using this site as summer foraging and
roosting habitat or fall foraging habitat before going into their hibernacula. Though apparently no
known hibernacula were found in the project site and within the .25-mile buffer around
hibernacula entranceway, it would be important to assess if this site is within 10 miles of any
Indiana Bat hibernacula and if it is fall foraging habitat for these bats.

KEEPING NEW JERSEYS WILDLIFE IN OUR FUTURE.

PO BOX 420 | 501 E. STATE STREET | MAIL CODE 501-03 | TRENTON, NJ 08625-0420 | 609-984-6012
WWW.C ONSERVEWILDLIFENJ.ORG
It would be valuable to conduct these surveys to properly identify: 1) current and potential roost
trees, 2) foraging range within the site to understand the impact of habitat loss on foraging, 3)
and fall usage at site to assess if potential fall foraging habitat.

I would recommend following proper timing restrictions for tree clearing to avoid direct impacts
and a more detailed field survey to properly assess indirect impacts. For more information or if
you have any questions, please contact me at 908-892-9993 or
Stephanie.feigin@conservewildlifenj.org.

Sincerely,

Stephanie Feigin
Wildlife Ecologist
Conserve Wildlife Foundation of New Jersey

KEEPING NEW JERSEYS WILDLIFE IN OUR FUTURE.

PO BOX 420 | 501 E. STATE STREET | MAIL CODE 501-03 | TRENTON, NJ 08625-0420 | 609-984-6012
WWW.C ONSERVEWILDLIFENJ.ORG