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HomeMy WebLinkAbout20071840 Ver 1_Information Letter_20071213C~ ~ ~~D ~--~) CP 5 ~~ ~'~~ ~~ ., { .~ ~~ ~1P . ~r f __ T- ~~ .~ ~ f ~,?: V;~ `~ ~lv ._ .~_ :s-'kr ate- ~_ -.- - 4 - ~ -`~ ~ North Carolina Wildlife Resources Commission ~ TO: John T. Thomas, Jr., NCDOT Coordinator Raleigh Regulatory Field Office, USAGE FROM: Marla Chambers, Western NCDOT Permit Coordinator ~"~'- ~~-a mom, Habitat Conservation Program, NCWRC DATE: December 13, 2007 SUBJECT: Review of NCDOT's request for a Section 404 Permit to replace Bridge No. 60 on NC 8/89 over Dan River, Stokes County, North Carolina. TIP No. B-4281. North Carolina Department of Transportation (NCDOT) has requested a Section 404 Permit from the U.S. Army Corps of Engineers (USAGE). Staff biologists with the North Carolina Wildlife Resources Commission (NCWRC) have participated in on-site field meetings on Feb. 25, 2004 and Oct. 2, 2006 and a phone conference on Oct. 25, 2007 and have reviewed the information provided. These comments are provided in accordance with the provisions of the National Environmental Policy Act (42 U.S.C. 4332(2)(c)) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). The NCDOT proposes to replace Bridge No. 60 on NC 8/89 over Dan River with a new bridge just north of the existing structure. Traffic will be maintained on the existing bridge during construction. A total of 33 linear feet of permanent impacts for bank stabilization and 0.04 acres of temporary fill impacts for two work bridges, one of which spans the entire 130-foot width of the river, and two negative pressure rings to remove existing bents in the river are proposed. No new bents will be placed in the water. Buck Island Creek and an unnamed tributary to Dan River in the project area will not be impacted. The Dan River, WS-V waters, is designated an Aquatic Significant Natural Heritage Area by the Natural Heritage Program. The federal and state Endangered James spineymussel (Pleurobema collina) has been found at the project location as well as upstream and downstream of the site. The state rank (S1) and global rank (Gl) for this species indicates it is "critically imperiled" in North Carolina and globally. Another state listed mussel, the notched rainbow (Villosa Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721 Telephone: (919) 707-0220 Fax: (919) 707-0028 B-4281, Bridge No. 60 Dan River, Stokes Co. - 2 - December 13, 2007 constricta), state Special Concern (SC), has been observed in the area. State and federally listed fish species found in the project vicinity include the orangefin madtom (Noturus gilberti), Federal Species of Concern and state Endangered; the bigeye jumprock (Scartomyzon ariommum), state Threatened; the riverweed darter (Etheostoma podostemone), state Special Concern; and the Roanoke hogsucker (Hypentelium roanokenese), state Significantly Rare. The Dan River has a rare and highly diverse assemblage of fish, including several listed as Priority Species in the North Carolina Wildlife Action Plan (NCWAP). In 2001 Congress developed new conservation funding legislation, the Wildlife Conservation and Restoration Program and the State Wildlife Grants Program, which required states to develop a Wildlife Action Plan by October 2005. The funding was intended to target species in the greatest need of conservation, species indicative of the diversity and health of the state's wildlife, and species with low and declining populations, as deemed appropriate by the states' fish and wildlife agencies. In addition to the federal and state listed species above, Priority Species occurring in the Dan River in the project vicinity include snail bullhead (Ameiurus brunneus), Johnny darter (Etheostoma nigrum), glassy darter (E. vitreum), and the v-lip (or suckermouth) redhorse (Moxostoma papillosum). The Dan River also supports an excellent smallmouth bass (Micropterus dolomieu) sport fishery in the project vicinity. Other popular sport fish in the area include the following sunfish: redbreast sunfish (Lepomis auritus), bluegill (L. macrochirus) and pumpkinseed (L. gibbosus). In our scoping comments dated Aug. 10, 2004, we requested the standard in-water work moratorium from May 1 to July 15 to protect the egg and fry stage of smallmouth bass, sunfish and many of the listed species of the project area. This moratorium is included as a commitment in NCDOT's "green sheets" in the Categorical Exclusion document dated July 2005. However, after collecting additional information and upon further investigation of the spawning periods for the area's non-game fish species, we recommended to NCDOT that the in-stream work moratorium extend from February 1 to June 30, which are the moratorium dates that have been used previously within the Dan River watershed for other land-disturbing projects. While these moratorium dates provide less protection for smallmouth bass and sunfish, they provide appropriate protection for the species in greatest need of conservation. This change in moratorium dates was relayed to NCDOT at the field meeting on Oct. 2, 2006 and via email Oct. 20, 2006. NCWRC always has been, and continues to be, willing to work with NCDOT on a case by case basis regarding moratoria when special circumstances arise. We take into consideration the potential impact of specific activities, timing, and the environmental conditions at the time (weather, stream flow, etc.). We believe a project should be completed and the area stabilized as quickly as possible to minimize the duration and severity of impacts to the resources and do not intend to cause needless delays. We believe that with proper planning, scheduling, and coordination with NCWRC and other resource agencies that delays and added costs are unlikely. However, subsequent conversations with the US Fish and Wildlife Service (USFWS) and NCDOT regarding project commitments that will come from the Section 7 consultation process may eliminate the need for the recommended moratorium. While we are aware of some of the measures proposed, final commitments have yet to be determined. Since many of these measures are expected to minimize siltation, habitat disturbance, and in-water work, we will not B-4281, Bridge No. 60 Dan River, Stokes Co. - 3 - December 13, 2007 pursue the in-water moratorium as a permit condition, provided adequate protection of sensitive fishery resources is provided. However, we do request that NCDOT and their contractor make every effort in planning and scheduling this project to avoid and minimize in-water work and other activities that could have detrimental effects on sensitive fish species during the spawning period. We believe that state agencies should make all reasonable efforts to avoid and minimize adverse impacts to North Carolina's sensitive resources, including state and federally listed species, NCWAP Priority Species, and rare habitats and assemblages of species. Several fish species found in the project vicinity are only found in the Dan River drainage and no where else on the planet. Several are intolerant of pollution and siltation. Many of the species have a life expectancy in the two to four year range, potentially making the loss of one year of spawning a significant impact to the population. That's particularly important, especially considering natural events, such as flooding and the recent drought, that can also have a negative impact on fish reproduction and survival. Another important consideration is that the reproductive cycle of freshwater mussels usually requires a fish host; often the mussel species is limited to specific fish species as hosts. It is just as vital to protect the fish known as hosts to the James spineymussel as to protect the mussel itself. In-water work increases siltation and habitat disturbance and provides an opportunity for other pollutants to be introduced at a time when fish tend to be most vulnerable. A spread sheet has been provided to NCDOT and the permitting agencies with details regarding fish and mussel species in the area. Another recommendation we made previously pertained to incorporating a canoe access into the project plans. However, it was determined that public access is available in the vicinity at Hanging Rock State Park and we informed NCDOT that we would no longer be pursuing access at this site. tl~'~ii'''~fi~~'~+~~~I .. ~, of 1~, S web'e~~e'v~'K~'^~ai~'~car~c~r~"fir a~~,~:..`II~~tE't~i~~sed. The Restoration Plan in the permit application is somewhat confusing, indicating certain impacted areas are expected to recover naturally. We would like to stress the importance of quickly re-vegetating any area where the vegetation has been removed, damaged, or otherwise absent, as arguably the best method of minimizing sediment entering the waterway. Planting trees along disturbed areas of the river bank is another important measure to stabilize the banks and provide long term benefits to aquatic and terrestrial wildlife. NCWRC can concur with the issuance of Section 404 and 401 permits provided that the following conditions are implemented: 1. At a minimum, sediment and erosion control measures should adhere to the design standards for sensitive watersheds and be strictly maintained until project completion. ~'~ Temporary or permanent herbaceous vegetation should be planted on all bare soil as soon as possible and within 21 calendar days of completion of permanent or temporary ground disturbing activities to provide long-term erosion control. B-4281, Bridge No. 60 Dan River, Stokes Co. - 4 - December 13, 2007 ~~ Tall fescue should not be used in riparian areas. We encourage NCDOT to utilize onsite native vegetation and materials for bank stabilization when practicable. Erosion control matting should be used in riparian areas (streambanks) and any disturbed steep slopes, instead of straw mulch, and well anchored with 12" staples, wooden survey stakes, or live stakes. ~_ Stormwater should be directed to buffer areas or retention basins and should not be routed directly into the river. ` `~,5_-:, Only clean, sediment-free rock should be used as temporary fill (causeways), and should be removed without excessive disturbance of the natural stream bottom when construction is completed. 6: ~ Discharge of materials into the river from demolition of the old bridge should be avoided as much as practicable. Any materials that inadvertently reach the river should be removed. ~~9. The natural dimension, pattern, and profile of the river above and below the crossing ~, should not be modified by widening the channel or changing the depth of the river. . ~, r o," ~ ~-~-~ ~ ~ Removal of vegetation in riparian areas should be minimized. Native trees and shrubs w ~ ~ 3 should be planted along the banks to reestablish the riparian zone and to provide long- term erosion control. ~` Grading and backfilling should be minimized, and tree and shrub growth should be retained if possible to ensure long term availability of shoreline cover for fish and wildlife. Backfill materials should be obtained from upland sites. '~A,, Riprap placed for bank stabilization should be limited to the bank below the high water mark, and vegetation should be used for stabilization above the high water elevation. "gY'I: If concrete will be used during construction, work must be accomplished so that wet (uncured) concrete does not contact surface waters. This will lessen the chance of altering the water chemistry and causing a fish kill. ~, Discharging hydroseeding mixtures and washing out hydroseeders and other equipment in or adjacent to surface waters is strictly prohibited. X1`3,. Heavy equipment should be operated from the bank rather than in the channel whenever possible in order to minimize sedimentation and reduce the likelihood of introducing other pollutants into the river. All mechanized equipment operated near surface waters should be inspected and maintained regularly to prevent contamination of surface waters from fuels, lubricants, hydraulic fluids or other toxic materials. ~4. The existing roadway that is to be eliminated should be removed back to original ground elevations and the natural floodplain elevations and functions should be restored. B-4281, Bridge No. 60 Dan River, Stokes Co. - 5 - December 13, 2007 Disturbed areas should be seeded or mulched to stabilize the soil and native tree species should be planted with a spacing of not more than 10'x10'. Thank you for the opportunity to review and comment on this project. If you have any questions regarding these comments, please contact me at (704) 984-1070. cc: Marella Buncick, USFWS Sue Homewood, NCDWQ David Wainwright, NCDWQ Angie Rogers, NCNHP relocation, stabilization activities (e.g., cement walls, rip-rap, crib walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed, plans and profiles showing the linear footprint for both the original and relocated streams must be included. To calculate acreage, multiply length X width and then divide by 43,560. Stream Impact Average Im act P Number Stream Perennial or Stream Length Area of (indicate on Name Type of Impact Intermittent? Width (linear Impact map) Before feet) (acres) Im act Temporary Work Bridge Permanent Bank Stabilization Temporary Negative Pressure Site an Riv r er nnial 130 0.02 Temporary Work it 4 Dan fiver Bridge P rennial 130 2 0. Total Stream Im act b len hand acres a 103 0.06 6. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic Ocean and any. other water of the U.S.). Open water impacts include, but are not limited to fill, excavation, dredging, flooding, drainage, bulkheads, etc. Open Water Impact Site Number (indicate on ma Name of Waterbody (if applicable) T e of hn act ~ P Type of Waterbody lake and es ( , P tuary, sound, bay, ocean, etc.) Area of Impact (acres) NA NA NA NA 0.00 NA NA NA NA 0.00 NA NA NA NA 0.00 Total Open Water Impact (acres) NA 7. List the cumulative impact to all Waters of the U.S. resulting from the project: Stream Impact (acres): 0.06 Wetland Impact (acres): 0.00 Open Water Impact (acres): 0.00 Total Impact to Waters of the U.S. (acres) ~ 0.06 Total Stream Impact (linear feet): 103.00 Page 4 of 8 Avoidance/Minimizati ;,n: • Bridge No. 60 will span the Dan River. • In-stream activity will be limited only to the areas shown on the plan sheets. • Removal of the existing bents will take place when water flow level is at a minimum point allowable within the project schedule and will be done in such a manner to minimize disturbance to the streambed. • Deck drains will not be allowed to discharge directly into stream. • A preformed scour hole is to be located on the northwest side of the Dan River. • The use of temporary work bridges in lieu of causeways to construct proposed bridge. • Temporary construction impacts due to erosion and sedimentation will be minimized through implementation of stringent erosion control methods and use of Best Management Practices (BMPs). • Design Standards for Sensitive Watersheds will be used. • The existing bridge will serve as an on-site detour during construction of the new bridge. • The area along the bank of Buck Island Creek will be protected during construction and no access will be allowed in this area. • The Contractor may perform clearing operations, but not grubbing operations until immediately prior to beginning grading operations. • Stilling basins will be used to hold water impacted by bridge construction activities. The stilling basins will be located upgradient and on the southwest side of the project area. Compensatory Miti ation: No compensatory mitigation is proposed for the 33-feet of stream impacts because the impacts are for bank stabilization and there will be no loss of aquatic use to the Dan River. MORATORIUM In an email dated October 20, 2006, the North Carolina Wildlife Resource Commission (NCWRC) requested a moratorium for the Dan River from February 1 to June 30 to protect the spawning periods for sensitive non-game fish species that are present. Also, in the Section 7 Consultation field meeting on August 1, 2007, and in a follow up email the NCWRC recommended an in-water work moratorium to protect smallmouth bass, sunfish, and other listed species in the project area. However, these species are not afforded federal or state protection in Waters of the U.S in NC. Additionally, the in-water construction phase of the proposed project will not significantly affect the above mentioned fish species. In fact, imposing a moratorium for these species will result an increase of $327,000 in construction costs and at least a 6 month delay of the project completion, resulting in a longer sustained effect on the environment. Therefore, the NCDOT does not believe this moratorium is warranted and does not propose to adhere to it. SCHEDULE The project calls for a letting of April 15, 2008 with a date of availability of May 27, 2008. Permits are needed by the review date of February 26, 2008. It is expected that the contractor will choose to start construction as soon as possible. 5 PROJECT COMMITMENTS Stokes County NC8/89 Bridge No. 60 over Dan River Federal-Aid Project No. BRSTP-008(4) State Project No: WBS 33621.1.1 T.I.P. No. B-4281 In addition to the standard Nationwide Permit #23 Conditions, the General Nationwide Permit Conditions, Section 404 Only Conditions, Regional Conditions, State Consistency Conditions, NCDOT's Guidelines for Best Management Practices for Protection of Surface Waters, NCDOT's Guidelines for Best Management Practices for Construction and Maintenance Activities, General Certifications, and Section 401 Conditions of Certification, this project will require formal consultation with the US Fish and Wildlife Service (USFWS) to address impacts to the Endangered James spinymussel (Pleurobema collina). Additional special commitments will follow the consultation. The following are special commitments known and agreed to by NCDOT at this phase of the project development. Project Development & Environmental Analysis Branch (PD&EAI: A formal Consultation with the USFWS in compliance with Section (7a) of the Endangered Species Act of 1973 will follow this CE document in order to more closely identify the specific course of action necessary to minimize impacts to the endangered James spinymussel species. PD&EA and Construction Office, Division 9: The Dan River in the project area is classified as WS-V waters and is in the Roanoke River Basin. NC Wildlife Resources Commission (NCWRC) commented that the Dan River supports a fishery, which includes smallmouth bass, sunfish, and several federal and state listed species. NCWRC recommends an in-stream moratorium from May 1 to July 15 to protect the egg and fry stage of the smallmouth bass, sunfish, and many of the listed species. Structure Design Unit, Construction Office, Division 9: During final design all practical considerations will be given to avoid placing a bent in the water of the Dan River by spanning the entire river. Should a bent be necessary, construction will be accomplished so wet concrete does not contact water entering or flowing in the river. Categorical Exclusion July 2005 Green Sheet Sheet 1 of 4 Dan River, Stokes Co. , NC Freshwater Mussels -State and Federal listings are from the Natural Heritage Program list of the rare animals species of North Carolina 2006 NOTE: The James spinymussel and the notched rainbow have been found at, above, and below the NC 8/89 bridge impact area Common mussels without status (not listed below) are also found around the bridge area, as well as throughout the Dan Basin. Lasmigona subviridis, has been found in many locations in the Dan River in Stokes County and ray be present in project vicinity. Alasimidonta undulata, Alasmidonta varicosa, Fusconaia masoni, Strophitus undulatus have been found in the Dan/Roanoke River Basin, but not near the project site. Rare mussels are difficult to detect because of their low density, seasonal and reproductive behavior, and burrowing in the substrate. So,if there has been a historical observation and a mussel is not detected in a current survey, their presence from their area is not precluded. State* Scientific Name Common Name Status Lasmigona subviridi ~ ~ Green floater SE n~- i mss, Pleurobema collina James spinymussel SE ~, 1 Villosa contricta Notched rainbow SC Alasmidonta undulata ' ~' ~ Triangle floater ST N r~ t Alasmidonta varicosa ~^;' ~,~~ Brook floater SE Fusconaia masoni Atlantic pigtoe SE Strophitus undulatus Creeper ST Fed"" WAP Status Priority Species Host Fish FSC Yes Reported as direct development (no host fish) FE Yes „ Satinfin shiner =Mountain redbelly dace ~ Bluehead chub Central stoneroller Rosefin shiner n/a Yes ~ Fantail darter .. Johnny darter? n/a Yes „Largemouth bass -White sucker FSC Yes (Margined madtom FSC Yes ~ Bluegill ~C-S#~iei~-d~er n/a Yes .Largemouth bass ~ Creek chub ~ S~e##+e-s+~trter i Bluegill Notes Upstream of project site Juveniles have been found to transform in greatest number on bluehead chub ~ x;. ~r~e~ A~' *ST=state threatened; SE=state endangered;SC=state concern "*n/a=not applicable, no federal status; FSC=Federal species of Concern; FE=Federal Endangered Niles ant bblagv mmdled from JenY'ns, R. E. , ant N. M. Burkhead. 1993. Freshwala Ilshes d Vrginia. American Flshenes Society Bdhesda, MaMaM. Tolerance Ratinpsfrom DWG SIaMaN Op«alinp Procedure Bldopical Monil«irp, Strea m Community Assessment hogram, Auwsl t, 2006, 51pp. Stale ant Federd StaNS xe hom Nduml Hengate Program Llsl of the rare animal species of North Carolina Fiahaa• Fishes Ihal are present in the xea but rat listed in this Marl include bdh smdlmoulh ant largemouth bass, az well az other tyces of sunfish. There is an acme fishery in the Dan River la smdlmoulh bazs. largertaulh bass, sunish. Many of the fish sDedaz xe probably aesenl throughout the Dan Riva in a mNlnaous fashion ant re1uN imlaled to the sm all xeaz Irom the aea sa mde0 Many of minrows in thegemJ ms glmaomus, lux4us, Noloryls, ant PMrJnus will use Nommis leplacephalus (bluehead chu b) nests to spawn. s,mda Collactad State Fad WAP PrionN Tolarana Ralf ScienlHic Name Common Nema Status Statue SQecba N( W1YG1 Soewning Dates Tamps lPaak Tamol Ameiurus lxumeus Bnail bNlhead 5 Yes Intermediate MayJUre Ameivrus platymphaNS Flat Wllhead 1 2 4 5 Tderenl June-JWy 21-24C Campasloma anamalum r'CentrN Slonaoller 1 3 4 5 Intermediate April)-May 1S26C Cdasfomous camrtarsoni '~Yyhite sucker 3 5 Tderanl March-July 1523 CAnoslomus NnMlfoFles Rosyside dam 3 4 6 Intermediate AprLLJUre 12-25C CypMeNa analmfane ~Satinlin shlna 1 2 4 6 Tderenl JunnJUly Efheosloma llebedae' -Fantail darter 7 2 3 A 6 Tderenl April-May 1524 Etheoslama ngruma .Johnny dater' present lhraughoul Dan Vas intamedlate ApN-Jure 1525C Efheosloma podosfemale Rivervread dada 1 2 4 5 SC Na Ves Intolerant Mxch-May 17-20C Efheoslana vlmum Glassy dada 2 Ves Inlamedlala February-A«il 10.19 Hypa4eFlm njpxans Northern hogsucker 1 4 5 Intermediate ApN-May 11-23C HyDeNelvm rpanokense Roamke Mgsucka 4 5 SR Na Ves Intermediate Mxch-ADrll 1420C Leportls auNUS Redbreast sunfish 1 3 1 5 Tdaanl May-August 1528(20-28t Leponla pibbasus Pumpkinseed 5 Intamedlaie May-August 1528, vxiable Lepomis macrpchlus &uegWl 5 Intemediate May-September 1525,vaiade WxArs abedus Whlle stirrer 7 2 4 5 Intemediate MayJUly 17-24C Luxlus mrasinus Crescent shine 7 3 4 5 Intamedlale MayJUre 17-25C Lyihmms ardens .Rosdln shlna 1 2 4 5 Intemediate ApN-June 12-25C MoxwtanaeMAnmxn Golden redhase 1 4 5 Intemediate ApN-May 10.22C Moxaslame papAbsum V-I prsuckermoulh redhase 6 Yes Intamedlale ApN-July Nw 'a kptp4uphalu5 v&uehead chub 1 2 3 4 5 Intermediate MayJum 12-25C Naanas2rlep BuIIMW 4 5 Intermedlate MayJure 1S23C Nofropis chdAicus Redllp sNrer 1 3 4 5 Intermediate MayJUre 17-20 Ndrpps hWwnius Scetlail shine present Woughaut Dan Intermediate ApN-JUre NDhpp's proaa SwdlaNall shiner presenltMougMut Dan Intemediate MayJUly -25C Ndurus p/beni Orangdln madlom 5 3E FSC Yes Intderant ApN-May to June 17-20 IJa'urus inspnis ,Margined madlom 1 3 4 5 Intemediate MayJure 17-23 Percma nevirenses Chainback darter' 2 5 Intolerant Mxch-June 12-16C Pemlre roanoka Roanoke loner 1 2 4 5 Intolerant Apra-Jure -12C Phoxirxu aeas ~Mounldn redbdlytlxe 3 Intermdflale ApN-Jure 1425C Srart«nyton alplllmu5 Sigeye lumprock 1 4 5 T Na Yes Intolerant Febmary-Mann 2-17C Scertomyton cervlnus BlackOPumxoU 1 0. 6 Intolerant 0.pNJUre 1423 Sempfilus airanaalafus ~ Creek cFUb 3 Tdaanl MacMMay 1S77C Lfa ~taPgv omar S7 yrs? TMugn declinira, Removed from NHP WatMlid in 2006 S7 yrs 7-4 yrs Occurdes dear streams, intolerant d lumid'ry ant siltation max t7 years max 2-3 yrs 3-0 Yrs 34 yrs ThrlVCS in Gear, undlted 6 sllphlly s9ted streams. 2-3 Vrs ax 4 Yrs Onry in Dan drainage. Larger populallon in deazer streams. Ilkdy 2-3 yn Usually oNV taunt In unsllled shifllrg sent, SUCK as saMbxs or sent flats 10 tts Regarded as iddaaN of pollgtion, allaibn & channel modillcatnn 45 yrs? Only In Dan drainage, InlolaaN gf silldion max 8 ax 8 11 3 yrs ax. 4 Yrs ax 2-3 yes - l 1 71 tts 6Yrs ~~5w ~"<,P1 lj Yl~~ r its-Y, ~r~'tY r'4 . / ( 3 yis Algae, daN material,ant detklus cam«ises lxge pgnion of diet, chub poWlallpns are more delaEl ndear 5lreams(Sun carrot peMhaie lhroughluN E'ly alp ere caA Iqr on rodsin sad invent) 5 Ks ? Lives in usually clear streams. max. 5 Yrs 3 yrs 3 yrs 4 yrs ax 3 yrs AvddS modaalely & ne~vly silted areas. max. 3 Yrs uses Nuehead Mub nest for spawning 57yrs Only In Dan drainage Rare•unwmmon. Siltaton probably caumd extapallon of some poWlalipre. 3,47 yrs Only In Roarake, Tar 8 Neuse (iNmNew R. ). Lives in generdlYdea large streams & rivers r Ethemfana flabbedare, tartlet) dance, d under IaxonomlNgaxlk study eM may show to be a dfdind subspecies of E. llabbeAare in the DeNRonaoke hash ' Ethemfana rrprum, the lohnrry done, Is dMicull to dislirgulsh from E(heas(oma dmsled ant requkes funkier sWdy. sPerdna Ne/sense, the chaiMack dance, helae 2001, was considered to be PercNa pelota, the shldd darter. The Shield dance is nowlhe Chainbackdana when lound in the ROZnoke. Tar, and Neuse Basins 1 Rohe F 1993 al NCB~89 bridge t ~ ~ ~ ~ ~'v 2 Museum Catalagged Records 2001 lust upstream gf NC flreA brdge 3 M C t l d R d 2001 s f NC fl~89 b id l I di G k . ~ ~ 4~ r~^~ ~~ ~ p useum a a ogge ecor s up ream o r ge a n an ee ( ~ ~ , ti ~ 4 Rohe el N 93 ant Museum Records upshe rn 2 5 upsheam hom NC8/89 SMuseum Catalogped Records vat ous years 1647489,92.93,991-7 miles downstream ~ ~ 4 f . /;~ flxs `~ V .~ ( ~-r~i ~' r ~ ~/ L Olha