Global warming is caused when greenhouse gasses accumulate in the atmosphere and force the earth to trap excessive amounts of the sun’s heat, causing the earth to warm. Carbon Dioxide (CO2) is one of the main greenhouse gasses, but others exist such as methane produced from landfills, and nitrous oxide. C02 is released as a result of the burning of forests and fossil fuels such as coal, oil, and gas in order to create power for transportation, industry, and electricity generation.
The heating of the globe will have catastrophic consequences for humans and the other species that inhabit this earth if nothing is done to change our fossil fuel consumption patterns. Some effects already seen today include, more intense storms (link to “hurricanes and GW PDF fact sheet”) because of warmer ocean waters, loss of substantial amounts of glacier and snow cover at the Polar Regions resulting in sea level rise, ecosystem change as a result of drought and climate changes, and alterations of life history events in organisms. To read more about current impacts go to the EPA impact site.
The National Wildlife Federation has created an Arkansas Specific fact sheet that talks about many of the specific consequences wildlife and humans face, as a result of global warming. Solutions for Arkansans are addressed as well.
Central to life for humanity, wildlife, plants and insects, etc is water. Of all the current conservation issues facing the Arkansas Wildlife Federation, the Governor, the state legislature, and of course, the citizens of Arkansas is the preservation of water quality and the development and establishment of a state water plan. Arkansas must begin immediately to protect water resources from pollution and misuse by counties, cities, local communities, land developers, manufacturers and others. Throughout this section on “Current Issues” that discusses significant environmental issues that impact wildlife, wildlife habitat, clean air, healthy forest and our environment, water is central to every issue such as: Grand Prairie, Arkansas River, Corps Reform, Extraordinary Resource Waters, water pollution from the construction of the coal-fired generating plant in Hempstead County, pollution of the Ouachita River from the insertion of the pipeline, and the most dangerous and damaging impact on Arkansas water resources – natural gas drilling.
Hydraulic fracturing is a common technique used to stimulate the production of natural gas. Typically, fluids are injected underground at high pressures, the formations fracture, and the natural gas flows more freely out of the formation. Some of the injected fluids remain trapped underground. A number of these fluids, such as diesel fuel, qualify as hazardous materials and carcinogens, and are toxic enough to contaminate groundwater resources. There are a number of cases in the U.S. where hydraulic fracturing is the prime suspect in incidences of impaired or polluted drinking water. In Alabama, Colorado, New Mexico, Virginia, West Virginia and Wyoming, incidents have been recorded in which residents have reported changes in water quality or quantity following fracturing operations of gas wells near their homes. Such cases are now being reported in Boone County, Arkansas. Despite the widespread use of the practice, and the risks hydraulic fracturing poses to human health and safe drinking water supplies, the U.S. Environmental Protection Agency (“EPA”) does not regulate the injection of fracturing fluids under the Safe Drinking Water Act. The oil and gas industry is the only industry in America that is allowed by EPA to inject known hazardous materials – unchecked — directly into or adjacent to underground drinking water supplies. In our state, it is estimated from the first 1000 natural gas wells drilled in Arkansas, over four (4) billions gallons of these gas well fluids have been dumped on surface lands. To gain the enormity of this potential environmental nightmare, the natural gas industry has projected they will drill over 10,000 natural gas wells in the state. In Arkansas, the vast majority of these toxic fluids are trucked off site and dumped on surface lands. ADEQ has information records of where these dump sites are located. Thus, Arkansas has limited protection of water quality or water resources from the Environmental Protection Agency, ADEQ, Arkansas Department of Pollution Control and Ecology and now AGFC which recently leased 11,500 acres of the Petti Jean and Gulf Mountain Wildlife Management Areas for a $29.5 million payoff and 20% percent of the royalties.
You can not discuss any environmental issues without discussing their impact on Arkansas’ water quality and resources. Throughout its 172 years history, Arkansas has been fortunate to have abundant water resources with over 9000 miles of streams with 17 river waterways, at least 12 or more lakes, and numerous creeks too many to count. Arkansas is known for its water abundance which attracts millions of visitors annually who contribute over $5 billion dollars to the state economy and generate over 65000 jobs in the tourism industry. Arkansas is well known as a hunting and fishing paradise that attracts over one million hunters and anglers who spend at least $1 billion in Arkansas. Arkansas can not afford to endanger its most important natural resource – abundant water quality and quantity.
At this time, Arkansas does not have a comprehensive state water plan that promotes and protects this abundant natural resource. There are different state agencies such as the Arkansas Game and Fish Commission and the Arkansas Pollution Control and Ecology Commission and the Arkansas Department of Environmental Quality who have developed components of a state water plan, but do not represent a comprehensive state water plan. The Arkansas Wildlife Federation is urging Governor Mike Beebe to create a “Governor’s Commission on Developing a Comprehensive Water Plan” similar to the “Governor’s Commission on Global Warming.” AWF will work with other conservation groups and organizations, Governor Mike Beebe and the state legislature to promote this legislation for the 2009 Arkansas Legislative session. The Arkansas Wildlife Federation is committed to the preservation and protection of water quality and establishing a comprehensive state water plan. Water resources are the very substance of life and critical for present and future generation.
Natural gas consists of combustible hydrocarbons which are gaseous at ordinary temperatures and pressures and have essentially the same origin as fluid hydrocarbons. Methane (also called marsh gas) and ethane are commonly the chief constituents. Most natural gases usually contain small and variable quantities of carbon dioxide, carbon monoxide, sulfur dioxide, hydrogen sulfide, nitrogen, hydrogen, and oxygen. In the absence of sulfurous compounds, natural gas is colorless, nearly odorless, and, when mixed in certain proportions with air, is highly explosive. An odorant is added before gas is sold to the public to aid in detection of gas leaks. Natural gas is commonly discussed as either “wet” or “dry” gas. Wet gas contains some of the heavier fluid hydrocarbons as vapor, is commonly associated with petroleum, and is valuable because of the extractable hydrocarbon liquids it contains. Most gas from oil fields in southern Arkansas is of this type. Dry gas differs from wet gas in that it does not carry appreciable amounts of the heavier hydrocarbons as vapor. The gas of the Arkoma basin in west-central Arkansas is of this type. Natural gas was first discovered in 1887 at Fort Smith, but commercial development did not begin until 1902 when two gas wells were completed near Mansfield, Sebastian County. The Fayetteville Shale Formation is the current focus of a regional shale-gas exploration and development program within the eastern Arkoma Basin and Mississippi Embayment regions of Arkansas.
The Arkansas Wildlife Federation has strong reservations and concerns about natural gas drilling in Arkansas because of its potential negative impact on wildlife, wildlife habitat and the environment. When natural gas wells are drilled in Arkansas, it typically takes 5 million gallons of water to fracture these wells which produce highly polluted water – unfit for human or animal consumption. Additionally, at each well drilling site there is a pit for highly toxic pollutants called oil sludge and mud used in the drilling process. The Arkansas Department of Environment Quality (ADEQ), the state agency charged with the responsibility “to protect Arkansas’ priceless natural resources – its air, water and land – from the threat of pollution,” does not adequately monitor or inspect these natural gas well drilling sites. Presently, over 1000 natural gas wells have been drilled in the Fayetteville Shale Formation and an additional 5000 natural gas wells drilled in the Arkoma Basin Shale Formation. By best estimates, ADEQ has inspected less than five percent of these wells to assure these gas drilling companies comply with state and federal environmental regulations. It is 95 % self regulated by the natural gas companies conducting the drilling activities. There are limited safeguards where these drilling fluids (5 million gallons per well) are dumped. It has been stated that over 85 % of these fluids are dumped on surface land generally unknown to ADEQ. ADEQ issues general permits to allow the trucking companies to dispose of these polluted fluids wherever they can arrange to dump. Billions of gallons of water are being utilized by these natural gas drilling companies which is already causing problems in water quality and quantity in many counties in the state. In Boone County Arkansas, farmers and land owners are reporting an alarming number of dry wells which have only occurred after extensive use of ground water used in fracturing in this natural gas drilling process.
The board of directors of the Arkansas Wildlife Federation is not opposed to natural gas drilling. AWF is concerned and keeps a close eye on any activities that could potentially disturb, damage, or impair wildlife and wildlife habitat, wildlife managed areas, and outdoor recreational areas purchased with state or federal funds “for the maximum enjoyment for the people.” AWF urges Arkansas hunters, anglers, canoeist, hikers, mountain climbers and all other outdoor enthusiasts to hold any entities accountable for the destruction of Arkansas’ natural resources, wildlife and wildlife habitat as well as recreational areas for the potential pollution of our forest environment. AWF is committed to protecting and preserving Arkansas natural resources, wildlife and wildlife habitat for future generations.
These materials were prepared by David Carruth, Attorney for Save the Ouachita, former president and long time member of the AWF Board of Directors and current member of the National Wildlife Federation Board of Directors. He is a farmer, successful attorney, and avid duckhunter.
El Dorado Chemical Company, Lion Oil Refinery, Chemtura (formerly Great Lakes Chemical Company) and the city of El Dorado through its Water Utilities Commission propose to construct a wastewater pipeline to discharge up to 20 million gallons of waste or sewer water per day into the Ouachita River just downsteam from the Thatcher Lock and Dam. Save the Ouachita, a local organization of sportsmen and women committed to protecting the lower Ouachita, has joined with the Arkansas Wildlife Federation in opposing the pipeline. If constructed, the pipeline will discharge up to 900 gallons per day of solid human and industrial waste along with up to 580 gallons of Ammonia Nitrogen into the river. Other chemicals and the maximum amount that would be dumped into the river each day would be 13.73 pounds of cyanide, 792.86 pounds of chromium, 147.51 pounds of zinc, 285.52 pounds of nickel, 13.2 pounds of selenium, 4.46 pounds of Cadmium and a third of a pound of Mercury. The greatest impact of this discharge would be in Felsenthal Reservoir which is also known as Lake Jack Lee.
Lake Jack Lee currently experiences a proliferation of aquatic plant growth in the summer months which, when they begin to decay, results in a loss of oxygen in the water. Fish kills are common due to these low dissolved oxygen levels, and many parts of Lake Jack Lee are inaccessible to fishermen due to the plant growth. Nutrients from the pipeline will only compound this problem.
The lower Ouachita and Lake Jack Lee are two of the few streams in Arkansas that are subject to a mercury advisory. Due to high levels of mercury children, pregnant women and the elderly are advised not to eat fish caught from the lower Ouachita. The pipeline would only add to this problem.
The concept of a jointly used pipeline is unique to Arkansas and has never been done before. Objections to the pipeline have been made to the Arkansas Department of Environmental Quality and Pollution Control and Ecology Commission to no avail. This is issue of great importance to Arkansas’ conservation community because of the potential environmental damage to the lower Ouachita.
These materials were prepared by Dick Broach, retired Deputy Director of the Arkansas Game and Fish Commission, member of the Yellow Creek Hunting Club and active in the state and federal legal actions against SWEPCO to build a coal-fired plant in Hempstead County, and a former member of the AWF Board of Directors.
Southwestern Electric Power Company is seeking to construct a 600 megawatt coal-fired base load generating facility in Hempstead County, adjacent to the environmentally unique and ecologically sensitive Little River Bottom area. This area includes Grassy Lake, a 3500 acre natural cypress swamp often described as the jewel of the Natural State. These wetlands support nationally significant nesting colonies of wading and water birds including the endangered Wood Stork and the American Bald Eagle. The largest breeding population of American Alligators in Arkansas is found in this complex.
Coal-fired generating plants produce about 1/2 of our nations electricity and are the single largest source of air pollution in the United States. Pollutants from Mercury, Carbon Monoxide, Carbon Dioxide, Nitrogen Oxides, Sulfur Dioxide and various volatile organic compounds are pumped in to our atmosphere in staggering quantities. The Hempstead County facility would release some 5,280,000 tons of Carbon Dioxide per year in to our air. These figures would double with installation of a proposed second plant at the Hempstead site (the United States Supreme Court as of April 2007, has identified Carbon Dioxide, the main greenhouse gas responsible for global warming, as a pollutant under the auspices of the Federal Clean Air Act).
Coal-fired power plants are our greatest source of Mercury pollution. Some 1,000 plus plants in the US annually burn one billion tons of coal and release some 44 metric tons of mercury, a powerful neurotoxin, in to our air. The cost of operating these plants in terms of public health alone is overwhelming and is morally unconscionable. Arkansas Wildlife Federation has resolved to join Intervenors from Hempstead County and other state and national conservation groups and agencies in expressing strong opposition to the proposed coal-fired facility in Hempstead County, Arkansas.
ERW protections are in danger of being removed. To learn more about which waterways are protected and what the protection status means go here.
The major issues facing ERW streams are primarily coming from city and county governments and land developers who wish to build dams on these scenic streams under the guise of needing more water resources to support population and commercial growth.
However, AWF has resisted all attempts by various city and county governments as well as land developers to place dams on any ERW designated stream. Actually, many city and county governments who have sought to place these dams on the ERW steams are being used by land developers who want to build “water front” lots to attract wealthy retires and wealthy individuals from big cities around the state to “build their second homes” on these lake front sites. City and County governments with the support of land developers have appealed to the Arkansas Congressional leadership to change the designation of some of these ERW streams to allow for dam construction. These city and counties governments use the same old “excuse” that they are “running out of water” and this restricts commercial and population growth. AWF has repeatedly challenged such assertion because typically these same cities and counties have no “water resources plans” or demonstrated any commitment to explore other potential water resources that are available. AWF is committed to keeping these unique scenic “extraordinary water resources” free flowing and unencumbered by dams or commercial development that would pollute and destroy some of Arkansas’ most prized natural resources. Unless you have floated the Buffalo River, or fly fished on Lee Creek, or canoed on the Strawberry River, or boated with your family on Lake Ouachita, or bass fished at Greers Ferry Reservoir, or trout fished on the Little Red River, or picnic at a family reunion at Bull Shoals – you have missed some of the treasured outdoors experiences in Arkansas. As long as there is an Arkansas Wildlife Federation, AWF will oppose any efforts to dam or impede these extraordinary water resources for present and future generations of Arkansans.
In an effort to protect these resources for the benefit of future generations, conservation groups all across the US began collectively pursuing a strategy that, as we enter this new century, would lead to reforming the corps. On June 2-4, 2000, at New Orleans University, within site of a levee that failed during Katrina, National Wildlife Federation conducted a CR strategy meeting along with over 60 organizations. At the 2002 NWF Annual Meeting in DC, Arkansas Wildlife Federation introduced Resolution 12 titled, “Reforming the US Army Corps of Engineers” which was passed unanimously and NWF followed by setting up a Steering Committee that has evolved into a 130 member Network. Non-profit groups may join at no cost.
Our primary function is sharing helpful information through a smart approach, while at the same time asking member groups to encourage their elected officials in Congress to support Corps Reform legislation from time to time. To find more information on how to join, contacts, member organizations, and fact sheets, go here.
Corp Reform Links
National Environmental Policy Act: 42 USC 4321-4347 is the cornerstone of federal resource management.
Engineering Regulations guide : How the Corps is suppose to conduct project studies.
US Environmental Protection Agency: The EPA plays a key role in water resources management
The Data Quality Act passed in 2001 sets the standard for Corps studies and allows groups to petition an agency to correct data that they think is inaccurate. One of the most useful documents for anyone interested in Corps of Engineer activities is EP 1165-2-1 Digest of Water Resources Policies and Authorities. It includes 24 different chapters, each dealing with some facet of Corps management policy. To track how Corps studies are being influenced by lobbyist/special interests or political contributions, go to Center for Public Integrity web site.
The Arkansas River is a work in progress and has been since the U.S. Army Corps of Engineers, aided and abetted by local chambers of commerce along the Arkansas river, began to thump the tubs for the McClellan-Kerr Arkansas River Navigation System (MKARNS). The promotion of the project is standard operating procedure (SOP) and began with the promise of economic development and job creation. I’m sure you know the drill – right out of an old movie. “Field of Dreams.” Build it and they will come! Promises were made such as river (barge) traffic will increase transportation capacity and promote a competitive advantage for shipping commodities up and down the system. In the 40′s and 50′s no one could have predicted the present energy crunch, and of course, that reality throws a monkey wrench in the equation. The system was completed in the 1950′s and has been going full blast at about 25% capacity for more than fifty years. Ironically, the major cargo is not commodities as originally promoted, but is principally sand, gravel, rock and other cargo to keep the system operational. The predicted traffic in shipping commodities has not materialized, and they are being transported by truck. Admittedly, one would assume that barge transportation would provide cost benefits over trucking over the interstate system for producers. But this has not come to pass. Barge traffic in commodities didn’t materialize. An article entitled “Slack Times at Slackwater Harbor “ appeared in the Arkansas Democrat-Gazette, July 27, 2003, deriding the intermodal facility at Little Rock for its lack of activity. A similar facility is presently being proposed for the Russellville area. It has been pointed out by the Arkansas Wildlife Federation at public hearings on this proposed project that existing intermodal facilities at Fort Smith, Van Buren and Little Rock are sadly underutilized and to add another such system at this time makes no economic sense at all.
There have been numerous other miscalculations on MKARNS by the Corps such as the need to add Montgomery Point Lock and Dam to the system to correct a flaw that developed where the river runs into the Mississippi River. A miscalculation on flood easements needed when the river floods adjacent farmlands and stands for prolonged periods of time has caused discontent on the part of farmers along the river. At the present time, there is a proposal by the corps to deepen the present 9 foot channel to 12 feet, the entire length of the river. The purpose of this enlargement is to allow deeper draft barges to carry heavier loads of sand, gravel, rock and other materials up and down the river. In our opinion, there are other problems with MKARNS, but this will give you some idea of the arrogance of the U.S. Corps of Engineer when it comes to water development projects.
The White River/Grand Prairie Irrigation project is still on hold for now. The injunction issued by the Honorable William R. Wilson under the Endangered Species Act remains in effect. Judge Wilson was fairly specific in issuing the injunction in pointing out what the Corps of Engineers and the U. S. Fish and Wildlife Service need to do to comply with the Endangered Species Act. First, he ordered that more study should be conducted around the pump station site to determine if the Ivory-billed Woodpecker would be effected by construction or operation of the pump and initial part of the delivery system. Second, Judge Wilson found that the Corps should study those parts of the river basin which were effected by “significant” water withdrawals impacting trees 12” inches in diameter at breast height (dbh) or greater.
The Corps and the WRID recently announced that the studies which they claim will satisfy the requirements of the ESA have been done. They announced that they have studied around the pump station and, while finding some nesting cavities that could be Ivory-billed Woodpecker nests, they found no evidence of the Ivory Billed Woodpecker. They further said that an area across from the pump station was studied to determine the impact to bottomland hardwoods, particularly trees 12” dbh or greater. The announcement concluded by saying this report would be presented to Judge Wilson “in the next couple of months”. The Corps and the WRID were confident that the injunction would be lifted and construction on the pump station re-started.
In 2006, the Arkansas Legislative Council directed the Arkansas Natural Resources Commission to take another look at the costs of the White River/Grand Prairie Irrigation Project. All parties, including the Corps and The Natural Resources Commission, agreed that the costs had increased from the $319 million figure from 1999. Some officials commented that it might be as high as $700 million but wanted the Natural Resources Commission to engage an “independent evaluation of the costs” in order to provide a true and clear picture of the costs. The legislature was adamant that the study be independent and objected and directed The Natural Resources Commission to spend up to $250,000.00 if necessary to commission such a study.
Earlier this year, the WRID and The Natural Resources Commission announced that the study had been conducted and the costs had increased. This supposedly independent study said the costs had increased from between $390 million to as high as $435 million. The study was done by an economics professor at the University of Arkansas. He stated that the study was done by taking the Corps numbers from 1999 and adjusting them for inflation. No effort was made to determine if the Corps numbers from 1999 were accurate or if the cost estimate included everything that needed to be included. The author went on to state that even with the elevated cost, the project was still feasible because of the increase in the price of farm commodities resulting in higher farm gross income. However, the study was not independent and did not meet the mandate of the Legislative Council. It remains to be seen if that body will hold The Natural Resources Commission’s feet to the fire and demand the study.
Because it is clear the costs have increased, The Natural Resources Commission submitted legislation to the General Assembly in the 2007 session asking that a measure be put on the 2008 General Election ballot increasing their bonding authority from $300 million to $600 million in General Obligation Bonds and allowing them to issue up to $100 million of these bonds without legislative authority. This $100 million would be earmarked solely for irrigation projects, i.e. Grand Prairie, Bayou Meto, Beouff-Tensas and others. The measure passed and is slated for the 2008 ballot.
On the federal level the U. S. House of Representatives did not include any money for the White River/Grand Prairie Irrigation Project. The Senate version does include money for the project and the matter now goes to the Joint Budget Conference Committee for the differences to be worked out. In years past the amount that makes it into the final appropriation is either less than the Senate amount or completely eliminated.
While it is on hold, the White River/Grand Prairie Irrigation Project is alive and well and awaiting release from the injunction to move forward. After that, only massive amounts of taxpayer money stand in the way of it being completed.
The Lower White River Navigation Channel Improvement Project
A 250-mile navigation channel is presently maintained on the Lower White. It provides for an 8-foot deep channel to Augusta, Arkansas, and about 4.5 feet to Newport. Since the original project was finished 30 years ago, barge interests and the Corps have been promoting the creation of a nine-foot deep channel, similar to other large navigable waterways. Even though barge traffic is minimal on the river, navigation interests want to spend millions more dollars to make the channel deeper. First, they promoted a plan to dredge the shallow areas. The public and politicians responded quickly and successfully stopped the plan from going through. It was even de-authorized by Congress in 1988.
Then in 1996, the study was re-authorized to examine the potential for deepening the channel through the use of more than a hundred wing dikes scattered at more than 30 locations along the river. The study has received some funding from Congress, but it has often-times slowed because of intense opposition from Arkansans. The expanded navigation project is opposed by virtually every major conservation group and the U.S. Fish & Wildlife Service. Thousands of citizens have signed petitions calling for the de-authorization of this project. On four occasions in the winter and spring of 2001, Arkansas’ state legislators failed to pass bills that would have provided money to construct the deeper channel.
The dikes and some continued dredging would negatively impact wildlife refuges on the river, would impact sloughs and oxbow lakes, and other hydrologic changes would occur. The ecologically valuable habitat of the channel would disappear forever, taking spawning habitat with it. Reduced flooding of bottomland forests, important wetland habitats, will cause drastic changes in plant community structure, thus impacting ducks, fish and other species that depend on these plants. These natural resources are important to a nature based economy in the region contributing millions of dollars annually.
The Grand Prairie Area Demonstration Project is a $319 million dollar irrigation project, which proposes to alleviate pressure on rapidly the declining Alluvial and Sparta aquifers in the Grand Prairie region of Arkansas, through the irrigation of rice farms with surface water from the White River. The project will pump as much as 1.06 billion gallons a day form the white river distributing it to 867 farms through a 650-mile distribution system that includes 184 miles of new canals, 177 miles of new pipeline, and 120 low-water dams. It is not hard to imagine how devastating this project will be to the internationally acclaimed wetlands, and some of the many diverse ecological communities which reside there. The plan does not explore, environmentally sound, less costly alternatives (link to PDF on alternatives to GP) to the issue of the declining aquifers.
Grand Prairie and Effects on Wildlife
Currently White River water contributes immensely to the health and vitality of the ecosystem that exists on the river and within the vast seasonal flood plane. In addition, the water from the White River is the life blood of Cache River and the White River National Wildlife Refuges down stream. Many plants and wildlife which are adapted to the natural flood cycles of the river will be negatively affected as flood water is removed for the project. The Army Corp of Engineers has failed to conduct a thorough analysis of the projects effects on the wildlife in the area, not to mention the recently rediscovered Ivory billed woodpecker.
Based on the current plan the Project will threaten: The largest concentration of mallard ducks in North America, which come to the area to winter, along with numerous species of migratory songbirds, waterfowl, and other birds. In addition a diverse freshwater fishery which includes more than 100 species of fish and more than 30 species of mussels is a risk. The only remaining native population of black bears in Arkansas, the pink mucket Muscle and other threatened species, many non-game wildlife species, including the bobcat, alligator snapping turtle and mink are all at risk from this project.
Grand Prairie Irrigation and the Ivorybill Woodpecker
Following the recent rediscovery of the Ivory billed woodpecker in the Cache River National Wildlife Refuge in 2005, a supplemental Environmental Impact Statement (EIS) has yet be re-administered after the final EIS was conducted in 2001 before the rediscovery of the woodpecker. Even though the Fish and Wildlife Service (FWS) stated in 2001 that water withdrawals could affect overall habitat values, including possible long term changes in species composition throughout the area, they still gave the go ahead to the Corps. In addition a formal endangered species act consultation has not been conducted to asses the impacts that the river withdrawals will have on the Ivory bill. The complaint states that the U.S. Army Corps of Engineers and the U.S. Fish and Wildlife Service violated the Endangered Species Act (ESA) by not completing an adequate survey of the project’s potential impact on the woodpecker and its habitat.