20200035 Ver 1_WRC Comments_20201009

Strickland, Bev
From: Munzer, Olivia
Sent: Friday, October 9, 2020 2:53 PM
To: Tugwell, Todd J CIV USARMY CESAW (US); Kim Browning; Davis, Erin B; Crocker,
Lindsay; [e-mail]; Jeff Keaton; John Hutton; Dow, Jeremiah J
Cc: Wilson, Travis W.; Cox, David R.; Jones, Brena K.; Wells, Emily N
Subject: Liberty Rock Mitigation Site - Randolph County
Attachments: IMG_0604jpg; IMG_0610jpg; IMG_0626jpg; IMG_0630jpg
Follow Up Flag: Follow up
Flag Status: Completed
0
NCWRC wanted to discuss the recent mussel survey results and some concerns, but so everyone is on the same page,
here is some background.
In February during the site visit to Liberty Rock Mitigation Site, I noted a lot of mussels in the Rocky River and provided a
few pictures to our aquatic diversity biologist, Brena Jones. I had reservations with the plan for restoration rather than
enhancement— not only were there abundant mussels in the stream, but in in portions of the stream, the instream
habitat is decent, the stream has some sinuosity, and it has access to the floodplain; there are definitely areas that need
stabilization and impacts from cattle is evident (see attached photos for those who haven't been there). In February,
Brena conducted preliminary surveys to assess the presence of state -listed species and habitat quality. A cursory survey
found 3 species of native crayfish, 3 native snail species, and 3 native mussels species, including the eastern creekshell
(Villoso delumbis), which is listed as a state significantly rare mussel and a Species of Greatest Conservation Need
(SGCN). She noted a fair amount of good quality sand/cobble substrate in runs and riffles. In an email in April, she
indicated that there were potential for other rare species and more individuals, so she suggested surveys. NCWRC's
initial recommendation was to avoid disturbance of the instream habitats, to stabilize any actively eroding banks, and to
re-establish native riparian vegetation where absent. However, we were told that DMS plans are to relocate the stream
or abandon the project, so WRC agreed to assist in developing a plan for aquatic species protection and relocation.
Brena suggested relocation of any mussels upstream of the site.
Last week, Chris Sheats, a permitted aquatic biologist with SEPI, conducted mussel surveys. The surveys were visual
rather than snorkeling surveys, but significant individuals were easily detected. He found the restoration reach of the
Rocky River, as well as upstream and downstream of the reach, has healthy populations of mussels. He found high
numbers of eastern creekshell and notched rainbow that are actively reproducing; both had gravid females and young
individuals. In her region, Brena does not often come across gravid notched rainbow. Here are the mussel species he
found:
Species Name
Common name
State Listing
Villoso delumbis
Eastern creekshell
Significantly Rare, SGCN
Villoso constricto
Notched rainbow
Threatened, SGCN
Elliptio complanata
Eastern elliptio
Uniomerus carolinianus
Florida pondhorn
Pyganodon cataracta
Eastern floater
Based upon this new information, NCWRC has concerns with the restoration of this reach. First off, the presence of a
large numbers of reproducing rare mussels suggests the stream does not need restoration but rather protection from
further degradation. The sheer numbers of the rare mussels would make relocation difficult, and the area to put the

mussels upstream is limited due to a beaver impoundment. Furthermore, we are concerned that construction of the
reach will cause sedimentation that would affect the healthy mussel populations downstream, especially during rain
events until the area is completely stabilized.
NCWRC thinks the enhancement of the reach, and the mitigation project as a whole, is crucial to the protection of the
aquatic community, instream habitat, and prevent any further degradation of water quality. It seems incongruous to
walk away from this project and for the cattle to continue accessing the stream, thereby, impacting the rare mussels,
stream structure, and water quality, then only come back years from now to conduct restoration but have potentially
lost the rare mussel community. We recommend providing a better mitigation ratio for fencing out the cows, stabilizing
actively eroding bank, and planting the buffer.
We would like to further discuss this project. Please let me know if we can have a call in the next couple of weeks.
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
Rogers Depot
1718 NC Hwy 56 W
Creedmoor, NC 27522
Office: 919-707-0364
Cell: 336-269-0074
[e-mail]>;
www.ncwildlife.or>;
0 10 n 102J,
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

,P
K