1.  DEIS P-273 -- "The Roanoke logperch is the only federally protected species known to occur within the project area. According to the Virginia DGIF, constructing the Smith Mountain Project displaced over 85 miles of what it believes was former habitat in the center of the Roanoke logperch range, including portions of the Roanoke, Pigg, and Blackwater rivers, as well as Gills Creek. Currently, the species exists only in isolated populations, in tributary streams not influenced by the operation of the project."

On 13 April 2007, the USFWS commented to the FERC: "The entire length of currently occupied Roanoke logperch habitat in the upper Roanoke and Pigg Rivers is approximately 139 stream kilometers (USFWS 1992). Smith Mountain and Leesville Lake dams and reservoirs have displaced over 100 stream kilometers of what is believed to be former habitat in the center of the Roanoke logperch range. These dams also serve to physically and genetically isolate populations in the upper Roanoke, Pigg, and middle Roanoke Rivers. We believe there is a clear nexus between these dams and reservoirs and the listing of this species [Emphasis added].

On 3 March 2008, the USFWS commented to the FERC: "Based on the project location and ongoing operations, the Service believes that this project is not currently adversely affecting federally listed species or adversely modifying critical habitat [Emphasis added].  Therefore, no further Section 7 consultation is required with the Fish and Wildlife Service.  Should project plans change, or if additional information on the distribution of listed or proposed species becomes available, this determination may be reconsidered.

These two USFWS positions are diametrically opposed and the DEIS fails to discuss or offer explanation to resolve the differences.   Logperch survey results showed than isolated populations exist both above and below the project in tributaries that are unaffected by project operations.  Below the project, in the mainstem of the Staunton River (Roanoke), Logperch may exist, but none were captured in the surveys.  Clearly the Logperch inhabited the Staunton River prior to the project, as evidenced by the isolated populations that exist in the Otter River and Goose Creek.

2.  DEIS P-293 -- "While we [FERC Staff] do not necessarily disagree with the benefits of a natural flow regime, we find no basis for expecting that a natural flow regime would enhance populations of rare/declining native species, including Roanoke Logperch."

TCRC again notes that the DEIS conclusion is unsupported, as evidenced by the isolated populations that exist in the Otter River and Goose Creek, which are unregulated naturally flowing tributaries.

3.  DEIS P-274 -- "In addition, implementing the proposed plan would facilitate the enhancement of logperch habitat that may be affected by the continued operation of the Project. Reintroducing logperch to previously occupied habitat, as well as augmenting existing populations would help expand the current range of the species and facilitate the recovery of the species [Emphasis added].  … In section 3.3.5.2, Threatened and Endangered Species, Environmental Effects, we identified potential projects to include (a) reintroduction efforts (i.e., propagation, stocking, and monitoring), (b) augmenting existing populations, (c) funding a full-time fishery biologist to implement logperch restoration activities (e.g., streambank rehabilitation, riparian revegetation, channel engineering, livestock fencing and crossings, developing alternative livestock water sources, and nutrient management), (d) funding to provide a 25 percent landowner cost share for on-going stream restoration projects, (e)  dam removal projects on tributaries, (f) addressing sediment sources for the Pigg River, and (g) implementing the Pigg River TMDL." 

TCRC notes that the DEIS failed to consider reintroduction of the Logperch in the Staunton River.  Perhaps this is because project operations still create a hostile environment (e.g. autocycle operations and the regulated augmented flow regime of HL_9.  TCRC notes that the project has retained over 80,000 acre feet of sediment, which undoubtedly reduced sediment in the Staunton River and likely created extremely suitable substrate conditions in the river.  The DEIS should discuss and consider species reintroduction into the Staunton.

Summary of TCRC Recommendations

The DEIS should modify the Roanoke Logperch management plan to include reintroduction into its previously occupied habitat in the Staunton River and determine if continued project autocycle operations and proposed the flow regime are inhibiting influences.