20072161 Ver 1_WRC Comments_20080201

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MEMORANDUM
TO: Ms. Amanda Jones
U.S. Army Crops of Engineers, Regulatory Branch
151 Patton Ave., Room 208
Asheville, North Carolina 28801-5006
Mr. Ian McMillan
NCDENR, Division of Water Quality
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
FROM: James Padgett, North Carolina Natural Heritage Program
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SUBJECT: Rutherford Electric Membership Corporation Nationwide Permit
Application. Womack Road to Pea Ridge substation line, Polk County
DWQ No. 07-2161
Our database indicates that the proposed project, an existing two-mile transmission line
right-of--way, transects Mills Bridge Natural Area, a Regionally Significant Natural
Heritage Area (SNHA), located in eastern Polk County, just south of the Green River on
adjacent slopes. Sections of Mills Bridge Natural Area contain small patches of Basic
Mesic Forest (Piedmont subtype), which provides habitat for several known occurrences
of special status plant species. Basic Mesic Forest is an uncommon natural community
type in North Carolina occurring in scattered localities in the Piedmont along stream
bottomlands and adjacent slopes associated with basic or circumneutral soils.. This
SNHA contains the largest known population of Allegheny spurge. (Pachysandra
procumbens) from the eight known in the state, all of which occur within Polk County.
Whorled horsebalm (Collinsonia verticillata) is also present. It's range, four counties in
NC and SC total of about 50 known populations globally. Pink thoroughwort
(Eupatorium incanatum) is also known to occur within the Basic Mesic Forest. Pink
thoroughwort is more likely to also occur within the project area, as it favors more open
sunny areas of habitat, though this has not yet been documented.
The following special status plant species and community types have been documented
within the Mills Bridge Natural Area:
Species
Status Rank
State/Federal NC Global
Allegheny spurge (Pachysandra procumbens) SR-P/na S 1 G4/GS
Whorled horse balm( Collinsonia verticillata) SR-T/na S2 G3
Pink thoroughwort (Eupatorium incanatum) SR-P/na S2 GS
Basic Mesic Forest na/na S2 GST3
*An explanation of statuses and ranks is given on subsequent pages.
FEB 1 2008
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It is also worth noting that butternut (Juglans cinerea), a NC Watch List species, is
known from Mill Bridge Natural Area and could occur within the project area, especially
along the hillside and floodplain near the Green River. Butternut has undergone declined
in recent years due to butternut canker associated with several fungi. Future efforts to
identify and avoid butternut are advisable.
It is not likely that work performed on the existing transmission right-of--way will impact
the known special status species, as they are found in a very specific community type
located west of the current project area. However, additional occurrences could
potentially occur within the project area along the Green River. We recommend special
planning and care to avoid or minimize impacts to Significant Natural Heritage Areas,
high quality natural communities, and rare species populations. Surveys should be
conducted for the species indicated above if suitable habitat is present within the project
areas. If rare species are encountered during surveys, we request that information about
these occurrences be submitted to NC Natural Heritage Program at the address shown on
our letterhead. Your stated plans regarding the use of natural vegetation along the stream
corridors is also advisable to retain and reduce runoff and erosion which could negatively
impact aquatic organisms.
You may wish to check the Natural Heritage Program database online at:
http://www.ncnhp.org and click on the link `heritage data' for a list of rare plant, animals,
and natural communities known from the Pea Ridge quad map or from Polk County. For
more detailed information regarding specific occurrences of known rare plants and
animals, please contact the Natural Heritage Program in Raleigh at: [phone]
(plants) or [phone] (animals).
Please do not hesitate to call me at [phone] if you have any questions of need
additional information.
Sincerel~,__~
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James Padgett, Biologist/Botanist
North Carolina Natural Heritage Program
CC: Judd Wortman, Rutherford Electric Membership Corporation
Dave McHenry, Wildlife Resources Commission, Mountain Regional
Coordinator, Habitat Conservation Program

EXPLANATION OF STATUS AND RANK CODES
N.C. Status:
E = Endangered
T= Threatened
SC =Special Concern
C = Candidate
SR =Significantly Rare
The statuses used for plants are determined by the Plant Conservation Program, The
North Carolina Department of Agriculture, and The North Carolina Natural Heritage
Program (NC NHP). Any collections from the wild of Endangered, Threatened, or
Special Concern plant species are regulated by law. The Candidate and Significantly
Rare are designated statuses used by the NC NHP, which indicate a need for plant
population monitoring and possible conservation for species currently listed as
Endangered, Threatened, or Special Concern.
U.S. Status:
E = Endangered. A plant in danger of extinction throughout all or a significant part of
it=s range.
T = Threatened. A plant that is likely to become an Endangered species in the near
future throughout all of it=s range or a significant part of it.
FSC =Federal Species of Concern. Replaces the former "Category 2" Candidate status
used by the U. S. Fish and Wildlife Service. These are plants, which have some evidence
of vulnerability, but there is not enough data to support a listing of Endangered or
Threatened. FSC has no official status.
N.C. Rank:
S 1 =Critically imperiled in North Carolina because of extreme rarity or due to some
factor making it vulnerable to extirpation from the state. Typically 1 to 5 known
populations.
S2 =Imperiled in North Carolina because of rarity, or due to some factor making it
vulnerable to extirpation from the state. Typically 6-20 known populations.
S3 =Rare or uncommon in North Carolina. Typically 21-100 known populations.
SH = Of historical occurrence in north Carolina, not having been seen or verified in
more than 20 years, and suspected to still be extant.
Global Rank:
Gl =Critically imperiled globally because of extreme rarity or due to some factor
making it especially vulnerable to extinction throughout its range. Typically less that 5
known occurrence globally.
G2 =Imperiled globally because of rarity, or due to some factor making it vulnerable to
extinction throughout its range. Typically 6-20 known occurrences globally.
G3 =Either very rare and local throughout its range or found locally (even abundant in
some locations) in a restricted range or due to some factor making it vulnerable to
extinction throughout its range. Typically 21 -100 occurrences globally.

G4 =Apparently secure globally, though it may be rare in parts of its range, especially
peripheral parts of the range.
GS =Demonstrably secure globally, though it may be rare in parts of its range,
especially, peripheral parts of the range.
Q =Questionable taxonomic assignment.
T =The rank of a subspecies or variety. Example being: G4T1 would apply to a
subspecies or a variety of a species with an overall rank of G4, but with the subspecies
the warranting rank is G1.
? =Unranked or rank uncertain.
U =Possibly in peril range-wide, but status is uncertain.
An S or G rank involving two numbers indicates uncertainty of rank. For example, a
G2G3 rank indicates that the species appears to warrant either a G2 or a G3 ranking, but
existing data is not sufficient to allow a determination to be made.

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Figure 1. Map of the proposed project area. The blue triangles indicated a documented
occurrence of a rare plant and the green square represents a documents occurrence of a
community type. The dark outlined area represents Mills Bridge Natural Area.