19910326 Ver 1_Fax_19940722

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1VIETgO)R NDUM
TO: Melba McGee
Harrel B. Johnson
FROM
P. 02/05
SUBJECT: Division of Marine Fisheries Review of Take Gaston Pipeline Environmental
Assessment
DATE: July 22, 1994
This agency has reviewed the Final Environmental Assessment of Non-Project Use of
Project Lands. and Waters for the City of Virginia Beach Water Supply Project FERC 2009-003
and have found several sections of the Environmental Assessment that deal with issues that are
pertinent to this agency's jurisdiction which are either incomplete or inadequate. We have
included some discussions of our concerns with these specific issues below.
5.4.5 Endangered Species p.46
Shor-wose Sturgeon
Specifically the E.A. does not consider observations of various projects recently
conducted in North Carolina, especially those conducted within the Cape Fear Drainage.
Neither is there any reference to habitat requirements for this species. Such material is included
in the fishery management plans for sturgeon prepared by the Atlantic States Marine Fisheries
Commission. This agency can supply copies of these materials. Although the shortnose
sturgeon is the only federally listed endangered fish in North Carolina and previously thought
to be extinct in the state (Shwartz and Link 1976) a gravid female sturgeon was caught in
January 1987 in the Brunswick River (Moser et al. 1989). Frequency of occurrence is not
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always a true indicator of abundance. Shortnose sturgeon range from the St. Johns River, New
Brunswick, Canada to the Indian River, Florida (Dadsweil et al. 1984). Although Atlantic
sturgeon is not federally listed as endangered or threatened, Atlantic sturgeons were
recommended as a species of special concern in the United States by Deacon et al. (1979) and
were classified as.vulnerable (Category 2) in North Carolina (Ross et al. 1988). This agency
can provide copies of the above citations.
Stripe?
The Albemarle/Roanoke population of striped bass is one of the last remaining
populations on the Atlantic Coast that is still considered to be unrecovered under the ASMFC
Striped Bass Management Plan. However recent experiments with flow modifications have
brought positive results with one year, 1993, resulting in the highest juvenile abundance index
in the history of sampling this parameter. Preliminary sampling for 1994 indicates that this year
may be even higher. Thus far, the E.A. only addresses impacts of project in relation to the 51
day spawning window. The Roanoke River Flow Committee has recommended the adoption of
both a 76 day window and even a 90 day spawning window. Both the DMF and WRC would
prefer a careful evaluation of a year-round flow regime that is relevant to other fishery resources
as well. Lastly, the recent report to Congress on the Status of Albemarle/Roanoke Striped Bass
Population recommend the need to complete several studies. This list of studies can be furnished
by this agency. Many of these studies would be relevant to the impacts of this project.
Other.Fisheries__Spg cies
The following species of fish are of primary concern to this agency: American shad,

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hickory shad, alewife, blueback herring and white perch. All except white perch are considered
to be anadromous in many systems north of North Carolina. All of the above species have very
specific requirements relative to habitat especially during spawning and flow and stability of
flows during the spawning period are considered to be critical. The specifics of these
parameters for the alosids are outlined in the ASMFC Shad and River Herring Plan, copies of
which can be obtained through this agency. These requirements should be evaluated in concert
with the predicted impacts of the project. Additionally, it should be noted that during the last
meeting of the Technical Committee of the Shad and River Herring Plan that shad and river
herring stocks virtually coastwide have suffered a precipitous decline further increasing, this
agencies concerns over the impact of the project on these fisheries.
Finally this agency has concern over the overall cumulative impacts that will occur
throughout the entire lower basin and the impacts on water quality and habitat squeeze on fishery
resources. There is no doubt that the Roanoke drainage is the dominant system for Albemarle
Sound, which is part of the second largest estuary on the Atlantic Coast. During the last two
decades the Albemarle system has shown significant signs of being stressed. Symptoms of this
stress have manifest themselves in the form of massive blue-green algae blooms resulting from
eutrophication of several tributaries and incidents of anoxia that are thought to be caused by
salinity wedges during low flow periods and droughts. A record of these events and ensuing
investigations and studies can be obtained through the North Carolina Division of Environmental
Management. This agency is of the opinion that in the attempt to do an EIS on this project it
is imperative that an instream flow study for the Roanoke River be completed as part of the EIS.
This agency would consider an EIS that did not include this study to be deficient and inadequate.
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