HomeMy WebLinkAbout20241275 Ver 1_Scalesville Rd T & E Survey_20240922Freshwater Mussel Survey Report
Replacement of Bridge No. 18
Haw River on SR 1002 (Scalesville Road)
WBS Element # 17BP.7.R.139
Rockingham County, North Carolina
Prepared For:
RH
4
F 4 L
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NC Department of Transportation
Raleigh, North Carolina
Contact Person:
Jared Gray
Biological Surveys Group
North Carolina Department of Transportation
jgraykncdot. gov
1598 Mail Service Center
Raleigh NC 27699-1598
December 2, 2019
Prepared by:
324 Blackwell Street, Suite 1200
Durham NC, 27701
Contact Person:
Tom Dickinson
tom.dickinson2threeoaksengineering.com
919-732-1300
Table of Contents
1.0 Introduction.......................................................................................................................... 1
2.0 Waters Impacted.................................................................................................................. 1
2.1. 303(d) Classification........................................................................................................ 1
2.2. NPDES discharges........................................................................................................... 2
3.0 Target Federally Proposed Species Description.................................................................. 2
3.1. Fusconaia masoni (Atlantic Pigtoe)................................................................................. 2
3.1.1. Species Characteristics.............................................................................................. 2
3.1.2. Distribution and Habitat Requirements.................................................................... 2
3.1.3. Threats to Species..................................................................................................... 3
3.1.4. Designated Critical Habitat....................................................................................... 4
4.0 Survey Efforts...................................................................................................................... 5
4.1. Stream Conditions at Time of Survey: Haw River.......................................................... 5
4.1.1. Mussel Surveys......................................................................................................... 6
5.0 Results..................................................................................................................................6
6.0 Discussion/Conclusions....................................................................................................... 6
7.0 Literature Cited.................................................................................................................... 8
Appendix A. Figures:
Figure 1: Project Vicinity & Survey Reach
Figure 2: NCNHP Element Occurrence
Figure 3: 303(d) Listed Streams and NPDES Discharges
1.0 INTRODUCTION
The North Carolina Department of Transportation (NCDOT) proposes the replacement of Bridge
No. 18 over the Haw River on SR 1002 (Scalesville Road) in Rockingham County (WBS 9
17BP.7.R.139; Appendix A, Figure 1). The project will cross the Haw River of the Cape Fear
River basin. The Federally Endangered Roanoke Logperch (Percina rex) and James
Spinymussel (Parvaspina collina, JSM [formerly Pleurobema collina (Perkins et al. 2017)]) are
listed by the U.S. Fish and Wildlife Service (USFWS) for Rockingham County; however, as
these species are only known to occur in the Roanoke River basin in North Carolina, they are not
further addressed in this report. The Atlantic Pigtoe (Fusconaia masoni), which is known to
occur in the Cape Fear River Basin, was proposed for listing under the Endangered Species Act
(ESA) as a Threatened Species with a Section 4(d) Rule and Critical Habitat Designation on
October 11, 2018 (USFWS 2018).
Table 1 lists the nearest element occurrence (EO) for targeted species in approximate river miles
(RM) from the project crossing. Data are from the NC Natural Heritage Program database
(NCNHP 2019) most recently updated in October 2019 (Figure 2).
Table 1—Element Occurrence
Distance
from
EO
crossing
First
Last
EO
Species Name
EO ID
Waterbody
(RM)
Observed
Observed
Status*
Figure
New Hope
Atlantic Pigtoe
25468
>50
June 2005
August 2018
2
Creek
As part of the federal permitting process that requires an evaluation of potential project -related
impacts to federally protected species, Three Oaks Engineering (Three Oaks) was contracted by
NCDOT to conduct freshwater mussel surveys targeting Atlantic Pigtoe.
2.0 WATERS IMPACTED
Haw River is located in the Haw subbasin (HUC9 03030002) of the Cape Fear River basin. The
Haw River flows approximately 76 RM from the subject bridge to Jordan Lake.
2.1. 303(d) Classification
Haw River is on the North Carolina Department of Environmental Quality (NCDEQ, formerly
known as the NC Department of Environment and Natural Resources (NCDENR)) - Division of
Water Resources 2018 Final 303(d) list of impaired streams. The listed region of Haw River is
approximately 5.6 RM downstream the subject bridge and begins at SR 2426 and includes 7.3
RM to Troublesome Creek at US-29. It is impaired due to exceeding levels for Copper (Figure
3).
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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2.2. NPDES discharges
The closest permitted NPDES discharge is on Haw River approximately 5.0 RM downstream
from the study area (USEPA 2019); NCDENR Division of Park and Recreation (NPDES Permit
9 NC0046019) (Figure 3).
3.0 TARGET FEDERALLY PROPOSED SPECIES DESCRIPTION
3.1. Fusconaia masoni (Atlantic Pigtoe)
3.1.1. Species Characteristics
The Atlantic Pigtoe was described by Conrad (1834) from the Savannah River in Augusta,
Georgia. Although larger specimens exist, the Atlantic Pigtoe seldom exceeds 50 mm (2 inches)
in length. This species is tall relative to its length, except in headwater stream reaches where
specimens may be elongated. The hinge ligament is relatively short and prominent. The
periostracum is normally brownish, has a parchment texture, and young individuals may have
greenish rays across the entire shell surface. The posterior ridge is biangulate. The interdentum
in the left valve is broad and flat. The anterior half of the valve is thickened compared with the
posterior half and when fresh, the nacre in the anterior half of the shell tends to be salmon
colored, while nacre in the posterior half tends to be more iridescent. The shell has full
dentation. In addition to simple papillae, branched and arborescent papillae are often seen on the
incurrent aperture. In females, salmon colored demibranchs are often seen during the spawning
season. When fully gravid, females use all four demibranchs to brood glochidia (VDGIF 2014).
The Atlantic Pigtoe is a tachytictic (short-term) breeder, brooding young in early spring and
releasing glochidia in early summer. The Bluegill (Lepomis macrochirus) and Shield Darter
(Percina peltata) have been identified as potential fish hosts for this species (O'Dee and Waters
2000). Additional research has found Rosefin Shiner (Lythrurus ardens), Creek Chub (Semotilus
atromaculatus), and Longnose Dace (Rhynichthys cataractae) are also suitable hosts (Wolf
2012). Eads and Levine (2011) found White Shiner (Luxilus albeolus), Satinfin Shiner
(Cyprinella analostana), Bluehead Chub (Nocomis leptocephalus), Rosyside Dace (Clinostomus
funduloides), Pinewoods Shiner (Lythrurus matutinus), Creek Chub, Swallowtail Shiner
(Notropis procne), and Mountain Redbelly Dace (Chrosomus oreas) to also be suitable hosts for
Atlantic Pigtoe.
3.1.2. Distribution and Habitat Requirements
Johnson (1970) reported the range of the Atlantic Pigtoe extended from the Ogeechee River
Basin in Georgia north to the James River Basin in Virginia; however, recent curation of the H.
D. Athearn collection uncovered valid specimens from the Altamaha River in Georgia (Sarah
McRae, USFWS, personal communication). It is presumed extirpated from the Catawba River
Basin in North and South Carolina south to the Altamaha River Basin (USFWS 2019). The
general pattern of its current distribution indicates that the species is currently limited to
headwater areas of drainages and most populations are represented by few individuals. In North
Carolina, aside from the Waccamaw River, it was once found in every Atlantic Slope river basin.
Except for the Tar River, it is no longer found in the mainstem of the rivers within its historic
1713P.7.R.139 Haw River Mussel Survey Report November 2019
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range (Savidge et al. 2011). It is listed as Endangered in Georgia, South Carolina, and North
Carolina, and as Threatened in Virginia. It has a NatureServe rank of G2 (imperiled).
The Atlantic Pigtoe has been found in multiple physiographic provinces, from the foothills of the
Appalachian Mountains, through the Piedmont and into the Coastal Plain, in streams less than
one meter wide to large rivers. The preferred habitat is a substrate composed of gravel and
coarse sand, usually at the base of riffles; however, it can be found in a variety of other substrates
and lotic habitat conditions.
3.1.3. Threats to Species
The cumulative effects of several factors, including sedimentation, point and non -point
discharge, stream modification (e.g., impoundment, channelization), coupled with the apparent
restricted range, are believed to have contributed to the decline of this species throughout its
range (USFWS 1990). When mussel populations are reduced to a small number of individuals
and are restricted to short reaches of isolated streams, they are extremely vulnerable to
extirpation from a single catastrophic event or activity (Strayer et al. 1996). Catastrophic events
may consist of natural events such as flooding or drought, as well as human influenced events,
such as toxic spills.
Siltation resulting from improper erosion control of various land usage, including agriculture,
silviculture, and development activities, has been recognized as a major contributing factor to
degradation of mussel populations (USFWS 1996). Siltation has been documented to be
extremely detrimental to mussel populations by degrading substrate and water quality, increasing
potential exposure to other pollutants, and by directly smothering mussels (Ellis 1936, Marking
and Bills 1979). Sediment accumulations of less than I inch have been shown to cause high
mortality in most mussel species (Ellis 1936).
Sewage treatment effluent has been documented to significantly affect the diversity and
abundance of mussel fauna (Goudreau et al. 1988). Goudreau et al. (1988) found that recovery
of mussel populations might not occur for up to two miles below points of chlorinated sewage
effluent. The impact of impoundments on freshwater mussels has been well -documented
(USFWS 1992, Neves 1993). Construction of dams transforms lotic habitats into lentic habitats,
which results in changes with aquatic community composition. These changes associated with
inundation adversely affect both adult and juvenile mussels as well as fish community structure,
which could eliminate possible fish hosts for glochidia (Fuller 1974).
The introduction of exotic species, such as the Asian Clam (Corbicula fluminea) and Zebra
Mussel (Dreissena polymorpha), has also been shown to pose significant threats to native
freshwater mussels. The Asian Clam is now established in most of the major river systems in the
United States (Fuller and Powell 1973) including those streams still supporting surviving
populations of the Atlantic Pigtoe. Concern has been raised over competitive interactions for
space, food, and oxygen between this species and native mussels, possibly at the juvenile stages
(Neves and Widlak 1987, Alderman 1997). The Asian Clam is common to abundant within the
Haw River. The Zebra Mussel, native to the drainage basins of the Black, Caspian, and Aral
Seas, is an exotic freshwater mussel that was introduced into the Great Lakes in the 1980s and
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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has rapidly expanded its range into the surrounding river basins, including those of the South
Atlantic Slope (O'Neill and MacNeill 1991). This species competes for food resources and
space with native mussels and is expected to contribute to the extinction of at least 20 freshwater
mussel species if it becomes established throughout most of the eastern United States (USFWS
1992). This species has not been recorded in the Cape Fear River Basin.
Atlantic Pigtoe appears to be particularly sensitive to pollutants and requires clean, oxygen -rich
water for all stages of life. All the remaining Atlantic Pigtoe populations are generally small in
numbers and restricted to short reaches of isolated streams. The low numbers of individuals and
the restricted range of most of the surviving populations make them extremely vulnerable to
extirpation from a single catastrophic event.
3.1.4. Designated Critical Habitat
As mentioned in Section 1.0, the Atlantic Pigtoe is proposed for listing under the Endangered
Species Act (ESA) as a Threatened Species with Section 4(d) Rule and Critical Habitat
Designation. In accordance with Section 4 of the ESA, Critical Habitat for listed species consists
of:
(1) The specific areas within the geographical area occupied by the species at the time it is
listed, in which are found those physical or biological features (constituent elements) that
are:
a. essential to the conservation of the species, and
b. which may require special management considerations or protection
(2) Specific areas outside the geographical area occupied by the species at the time it is listed
in accordance with the provisions of Section 4 of the Act, upon a determination by the
Secretary that such areas are "essential for the conservation of the species."
On October 11, 2018, USFWS proposed the Atlantic Pigtoe as a Threatened species under the
ESA. Critical habitat designation provided at that time (CFR Vol. 52 No. 186) consists of the
following:
• Unit 1 - 29 river mi (46.7 river km) of Craig Creek in Craig and Botetourt Counties,
Virginia
• Unit 2 - 1 mile (1.6-km) of Mill Creek in Bath County, Virginia
• Unit 3 - 3 miles (4.8-km) of the Middle James River in Fluvanna and Buckingham
Counties, Virginia
• Unit 4 - 50 river miles (80.5 river km) of the Nottoway River in Nottoway, Lunenburg,
Brunswick, Dinwiddie, and Greenville Counties, Virginia
• Unit 5 - 5 miles (8 km) of the Meherrin River in Brunswick County, Virginia
• Unit 6 - 7 miles (11.3 km) of the Dan River in Pittsylvania County, Virginia and
Rockingham County, North Carolina
• Unit 7 - 12 miles (19.3 km) of Aarons Creek in Granville County, North Carolina and
along the Mecklenburg County -Halifax County line in Virginia and North Carolina
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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• Unit 8 - 85 miles (136.8 km) of the mainstem of the upper and middle Tar River as well
as several tributaries (Bear Swamp Creek, Crooked Creek, Cub Creek, and Shelton
Creek), in Granville, Vance, Franklin, and Nash Counties, North Carolina
• Unit 9 - 8 miles (93.3-km) of Sandy/Swift Creek in Vance, Warren, Franklin, and Nash
Counties, North Carolina
• Unit 10 - 85 miles (136.8 km) in Fishing Creek, Little Fishing Creek, Shocco Creek, and
Maple Branch located in Warren, Halifax, Franklin, and Nash Counties, North Carolina
• Unit 11 - 30 miles (48.3 km) of the Lower Tar River and Fishing Creek in Edgecombe
County, North Carolina
• Unit 12 - 60 river miles (95 river km) in four subunits including Flat River, Little River,
Eno River, and the Upper Eno River in Durham, Orange, and Person Counties, North
Carolina
• Unit 13 - 61 river miles (98.2 river km) in five subunits including Swift Creek, Middle
Creek, Upper Little River, Middle Little River, and Contentnea Creek, in Johnston,
Wake, and Wilson Counties, North Carolina
• Unit 14 - 6 miles (9.7 km) of habitat in New Hope Creek in Orange County, North
Carolina
• Unit 15 - 10 river miles (16.1 river km) in Randolph County, North Carolina, including
the mainstem Deep River as well as Richland Creek and Brush Creek
• Unit 16 - 40 miles (64.4 km) of Little River in Randolph and Montgomery Counties,
North Carolina
The project crossing is located greater than 50 RM upstream from proposed critical habitat Unit
14 in New Hope Creek (Figure 2).
4.0 SURVEY EFFORTS
Surveys were conducted by Three Oaks personnel Tom Dickinson (Permit # 19-ES00343) and
Nathan Howell on November 22, 2019.
4.1. Stream Conditions at Time of Survey: Haw River
Habitat was characterized primarily by slow moving run, with slack water areas behind sandbars
and woody debris accumulations. Sandbars and woody debris also created areas of restricted
flow and associated riffle habitats. The channel ranged from 25 to 35 feet wide with banks up to
six feet high that were variably stable to eroded. Substrate was dominated by unconsolidated
sand, much of it presenting as unstable and shifting. Portions of run habitat contained coarse
sand and pebble with areas of hardpan clay. Banks were composed primarily of soft clay and
rootmats. A wide, mature forested buffer surrounded the surveyed reach.
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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4.1.1. Mussel Surveys
Mussel surveys were conducted from approximately 1,312 ft (400 meters) downstream of the
respective bridge crossing to approximately 328 ft (100 meters) upstream of the crossing for a
distance of approximately 1,640 ft (500 meters) (Figure 1). Areas of appropriate habitat were
searched, with a concentration on the stable habitats preferred by the target species. The survey
team spread out across the creek into survey lanes. Visual surveys were conducted using glass
bottom view buckets (bathyscopes). Tactile methods were employed, particularly in
streambanks under submerged rootmats. All freshwater bivalves were recorded and returned to
the substrate. Timed survey efforts provided Catch Per Unit Effort (CPUE) data for each
species. Relative abundance for freshwater snails and freshwater clam species were estimated
using the following criteria:
➢ (VA) Very abundant > 30 per square meter
➢ (A) Abundant 16-30 per square meter
➢ (C) Common 6-15 per square meter
➢ (U) Uncommon 3-5 per square meter
➢ (R) Rare 1-2 per square meter
➢ (P-) Ancillary adjective "Patchy" indicates an uneven distribution of the species within the
sampled site.
5.0 RESULTS
A total of 5.7 person hours of survey time were spent in the reach, with the Eastern Elliptio being
the only mussel species found (Table 2). Mussels were located in low abundance, primarily near
the upstream and downstream extent of the reach. Other mollusk species found included the
invasive Asian Clam.
Table 2. CPUE for Freshwater Mussels in the Haw River
Scientific Name
I Common Name
# live
Abundance / CPUE
Freshwater Mussels
CPUE
Elli do com lanata
Eastern Elli do
34
6/hr
Freshwater Snails and Clams
Relative Abundance
Corbicula uminea
I Asian Clam
—
U
6.0 DISCUSSION/CONCLUSIONS
The Atlantic Pigtoe was not found during the surveys, and records for this species occur well
downstream of the project (Section 1.0).
While the Atlantic Pigtoe is not currently federally protected, and no biological conclusion is
necessary at the time of the writing of this report, if the species were to receive federal
protection, the appropriate biological conclusion is as follows:
Biological Conclusion Atlantic Pigtoe: May Affect Not Likely To Adversely Affect
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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17BP.7.R.139 Haw River Mussel Survey Report November 2019
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7.0 LITERATURE CITED
Alderman, J.M. 1997. Monitoring the Swift Creek freshwater mussel community. Pages 98-107
in K.S. Cummings, A.C. Buchanan, C.A. Mayer, and T.J. Naimo, eds. 1997.
Conservation and Management of Freshwater Mussels II Initiatives for the future.
Proceedings of a UMRCC symposium, 16-18 October 1995, St. Louis, Missouri. Upper
Mississippi River Conservation Committee, Rock Island Ilinois. 293 pp.
Conrad, T.A. 1834. New freshwater shells of the United States, with coloured illustrations; and a
monograph of the genus Anculotus of Say; also a synopsis of the American naiades. J.
Dobson, 108 Chestnut Street, Philadelphia, Pennsylvania. 1-76, 8 pls.
Eads, C.B. and J.F. Levine. 2011. Refinement of Growout Techniques for Four Freshwater
Mussel Species. Final Report submitted to NC Wildlife Resources Commission, Raleigh,
NC. 15pp.
Ellis, M.M. 1936. Erosion silt as a factor in aquatic environments. Ecology. 17:29-42.
Fuller, S.L.H. 1974. Clams and mussels (Mollusca: Bivalvia). Pages 215-273, inC.W. Hart and
S.L.H. Fuller eds. Pollution Ecology of Freshwater Invertebrates. Academic Press, New
York.
Fuller, S.L.H., and C.E. Powell. 1973. Range extensions of Corbicula manilensis (Philippi) in
the Atlantic drainage of the United States. Natilus. 87(2):59.
Goudreau, S.E., R.J. Neves, and R.J. Sheehan. 1988. Effects of sewage treatment effluents on
mollusks and fish of the Clinch River in Tazewell County, Virginia. Final Rep., U.S. Fish
and Wildl. Serv. 128 pp.
Johnson, R. I. 1970. The systematics and zoogeography of the Unionidae (Mollusca:Bivalvia) of
the southern Atlantic Slope region. Bull. Mus. Comp. Zool. 140(6):263-449.
Marking, L.L., and T.D. Bills. 1979. Acute effects of silt and sand sedimentation on freshwater
mussels. Pp. 204-211 in J.L. Rasmussen, ed. Proc. of the UMRCC symposium on the
Upper Mississippi River bivalve mollusks. UMRCC. Rock Island IL. 270 pp.
McRae, Sarah. 2017. Fish and Wildlife Biologist, U.S. Fish and Wildlife Service. Raleigh, NC.
Personal communication regarding target species.
NatureServe. 2015. NatureServe Explorer: An online encyclopedia of life [web application].
Neves, R.J. 1993. A state of the Unionids address. Pp. 1-10 in K.S. Cummings, A.C. Buchanan,
and L.M. Kooch, eds. Proc. of the UMRCC symposium on the Conservation and
Management of Freshwater Mussels. UMRCC. Rock Island IL.189 pp.
17BP.7.R.139 Haw River Mussel Survey Report November 2019
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Neves, R.J., and J.C. Widlak. 1987. Habitat ecology of juvenile freshwater mussels (Bivalvia:
Unionidae) in a headwater stream in Virginia. Amer. Malacol. Bull. 1(5):1-7.
North Carolina Department of Environmental Quality (NCDEQ) - Division of Water Resources.
2018. 2018 North Carolina 303(d) List.
https:Hfiles.nc.gov/ncdeq/W ater%20Quality/Planning/TMDL/303d/2018/2018-NC-303-
d--List-Final.pdf
North Carolina Natural Heritage Program (NCNHP). 2019. Biotics Database. Division of Land
and Water Stewardship. Department of Natural and Cultural Resources, Raleigh, North
Carolina. July 2019 version.
O'Dee, S.H., and G.T. Waters. 2000. New or confirmed host identification for ten freshwater
mussels. Pp. 77-82 in R.A. Tankersley, D.I. Warmolts, G.T. Waters, B.J. Armitage, P.D.
Johnson, and R.S. Butler (eds.). Freshwater Mollusk Symposia Proceedings Part I.
Proceedings of the Conservation, Captive Care and Propagation of Freshwater Mussels
Symposium. Ohio Biological Survey Special Publication, Columbus.
O'Neill, C.R., Jr., and D.B. MacNeill. 1991. The zebra mussel (Dreissena polymorpha): an
unwelcome North American invader. Sea Grant, Coastal Resources Fact Sheet. New
York Sea Grant Extension. 12 pp.
Savidge, T. W., J. M. Alderman, A. E. Bogan, W. G. Cope, T. E. Dickinson, C. B. Eads,S. J.
Fraley, J. Fridell, M. M. Gangloff, R. J. Heise, J. F. Levine, S. E. McRae, R.B. Nichols,
A. J. Rodgers, A. Van Devender, J. L. Williams and L. L. Zimmerman. 2011. 2010
Reevaluation of Status Listings for Jeopardized Freshwater and Terrestrial Mollusks in
North Carolina. Unpublished report of the Scientific Council on Freshwater and
Teresstrial Mollusks. 177pp.
Strayer, D. L., S. J. Sprague and S. Claypool, 1996. A range -wide assessment of populations of
Alasmidonta heterodon, an endangered freshwater mussel (Bivalvia: Unionidae). J.N.
Am. Benthol. Soc., 15(3):308-317.
U.S. Environmental Protection Agency Office of Water. NPDES facilities by permit type.
NPDESPERMIT_WMERC. Accessed July 2019.
https://watersgeo. epa.gov/arcgi s/rest/services/OW PROGRAM/NPDESPERMIT_WMER
C/MapServer
U.S. Fish and Wildlife Service (USFWS). 1990. James Spinymussel (Pleurobema collina)
Recovery Plan. Newton Corner, Massachusetts, 38 pp.
U.S. Fish and Wildlife Service (USFWS). 1992
southeast United States (The red book).
Endangered Species, Southeast Region.
pp -
17BP.7.R.139 Haw River Mussel Survey Report
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Endangered and Threatened species of the
Prepared by Ecological Services, Div. of
Government Printing Office, Wash. D.C. 1,070
November 2019
Page 9
U.S. Fish and Wildlife Service (USFWS). 1996. Revised Technical/Agency Draft Carolina
Heelsplitter Recovery Plan, Atlanta, GA: 47.
U.S. Fish and Wildlife Service (USFWS). 2018. Endangered and Threatened Wildlife and
Plants; Threatened Species Status with Section 4(d) Rule and Critical Habitat Desgnation
for Atlantic Pigtoe. 50 CFR 17:83 FR 51570, 51570-51609. Docket No. FWS-R4-ES-
2018-0046.
U.S. Fish and Wildlife (USFWS). 2019. Species Status Assessment Report for the Atlantic
Pigtoe (Fusconaia masoni). Version 1.3. April, 2019. Atlanta, GA.
Virginia Department of Game and Inland Fisheries (VDGIF). 2014. Atlantic Pigtoe
Conservation Plan. Bureau of Wildlife Resources. VDGIF, Richmond, VA. 31 pp.
Wolf, E.D. 2012. Propagation, Culture, and Recovery of Species at Risk Atlantic Pigtoe.
Virginia Tech Conservation Management Institute, Project No. 11-108. 55pp.
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APPENDIX A
Figures
17BP.7.R.139 Haw River Mussel Survey Report November 2019
Job# 19-322 Page 11
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