20021769 Ver 3_More Info Received_20080721

O2.- 17(o9 vcr-,3
Subject: [Fwd: Re: [Fwd: SEPA review DWQ# 14002 - Southern Pines Res.]]
From: Cyndi Karoly <[e-mail]>
Date: Mon, 21 Jul 2008 15:32:01 -0400
To: Bev Strickland <[e-mail]>
Subject: Re: [Fwd: SEPA review DWQ# 14002 - Southern Pines Res.]
From: Eric Fleek <[e-mail]>
Date: Mon, 21 Jul 2008 14:45:40 -0400
To: Hannah Stallings <Hannah. Stallings@ ncmail.net>, Nora Deamer <[e-mail]>
CC: Cyndi Karoly <[e-mail]>
OK, I looked at their invertebrate sample (Appendix F) as well as their supporting
collection methods, results, and site photos and here are my comments:
Here is how they sampled: "*/using a dip net in several locations along the reach and
examining the contents of each sample of aquatic species, including invertebrates,
salamanders, and fish... sample locations were chosen randomly along the stream reach and a
variety of habitats were sampled including sluggish water, pools and a shallow run..._only
the portion of the UT located on the project site was evaluated-/*"
This is a very, very cursory type of invertebrate sampling and is nowhere close to
accurately describing the invertebrate diversity that is likely present along a
representative segment of this UT. Looking at the photos, (particularly #'s 3-6), this is
the kind of stream (for this region) that would likely support between 25-45 total taxa and
not the "two aquatic worms, 1 juvenile crayfish" that they collected.
As they note, "/*only the portion of the UT located on the project site was evaluated*/",
this is of course irrelevant since the effects of the dam (in the form of lowered or no
flows) will be transmitted downstream to where (as they note), the habitat improves.
Moreover, they sampled where it appears the habitat was the worst. Had they more intensively
sampled the downstream segments where the habitat was better, the diversity (even with their
very cursory methods) would have been much, much higher than what they found. But what is
most important, is that regardless of where they sampled, the methods they used are
unsuitable for collecting a representative sample of the benthic macroinvertebrate community
Therefore, when they say :"/*Based on stream sampling results and observations during
several visits to the project sites, the onsite reach of the UT to Horse Creek supports only
a low density of a few aquatic and semi-aquatic species and does not provide suitable
habitat for sensitive invertebrate species, freshwater mussels., or fish. -The condition of
the stream indicates that amore formal benthological survey is unnecessary, as it wold
likely yield similar results-*/" that is an indefensible statement based on the extreme
shortcomings of the 1) collection method, and 2) the amount of reach actually sample. In
addition, there is no mention on how the material retained in the net was sorted/picked in
the field, nor was their any mention of net mesh size. So, if they only examined the
material from the nets in their hands (and not on bright-white background separated from the
organic debris, or field-preserving the material to bring back to the lab for sorting) they
missed small to medium sized-taxa. In addition, if the mesh size of the net was excessively
large, they simply did not collect many taxa as they would pass through the net. and this of
course does not even include the lack of any microscope-aided sorting/identification in the
lab which of course would have yielded more taxa. In short, these methods are extremely
problematic and the conclusions they make based on these very cursory collections are not
defensible.
At any rate, if they have agreed to a minimum release, or if we are going to require it
regardless of what they want, I am OK with leaving these results as is. However, if they are