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3940 GLENBROOK DRIVE PO BOX 1066 HAILEY, ID 83333

PHONE 208-788-3456 FAX 208-788-2082

July 30, 2008

Ms. Barbara Douglas Endangered Species Biologist U.S. Fish & Wildlife Service Field Office 694 Beverly Pike Elkins, WV 26241

Subject: 113733 TrAILCo Salamander (Plethodon nettingi) Biological Assessment for the Trans- Allegheny Interstate Line (TrAIL) 500 kV Transmission Line In West Virginia.

Dear Ms. Douglas:

POWER Engineers, Inc. (POWER) is providing this letter report documenting the results of Dr. Thomas Pauley’s Cheat Mountain Salamander (Plethodon nettingi) investigations conducted in November 2007 and January 2008 along potentially suitable sections of the proposed Trans-Allegheny Interstate Line (TrAIL) 500 kV transmission line corridor. You had requested that POWER conduct a study of the status of this federally threatened species within the project area, and POWER contracted with Dr. Pauley to evaluate the status and potential for occurrence of this species based on his extensive research background and qualifications. The results of Dr. Pauley’s investigations are provided below following a brief project background. Please note that Dr. Pauley’s study areas covered both Segments 1 and 2 of the proposed TrAIL corridor.

Project Background and Methodology

Within West Virginia the proposed TrAIL project consists of a new 500 kV transmission line, to be located within a 200ft-wide right-of-way crossing portions of Monongalia, Marion, Taylor, Preston, Tucker, Grant, Hardy, and Hampshire Counties. This cleared right-of-way will be located within a 2,200 foot wide corridor for which TrAILCo, a subsidiary of Allegheny Energy, Inc., submitted its application for a Certificate of Public Convenience and Necessity (CPCN) to the West Virginia Public Service Commission (WV PSC) in the fall of 2007. WV PSC’s CPCN approval for this project is expected on August 4, 2008. Additional TrAIL project components are located within Pennsylvania and Virginia, and include additional 500 kV right-of-way, three short 138 kV transmission loops, and two new electric substations in Pennsylvania, and 500 kV right-of-way and expansion of an existing electric substation in Virginia.

IF ENCLOSURES ARE NOT AS NOTED, PLEASE NOTIFY US AT ONCE.

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POWER contracted with Dr. Pauley to conduct the Cheat Mountain Salamander studies as part of a comprehensive endangered and threatened species assessment required for the successful permitting of the project. In order to assess its status Dr. Pauley examined the scientific literature and his own extensive research of this species, and conducted a series of ground surveys along the proposed corridor. He presented the results of his 2007-2008 investigations as follows:

Dr. Pauley’s 2007 Report

After studying the proposed route of the TrAIL project I divided that part of the corridor closest to the range of the Cheat Mountain Salamander into eight areas. During my 31 years of field studies on the Cheat Mountain Salamander, I have either conducted habitat assessments or field inventories for Cheat Mountain Salamanders in four of these eight areas. Below I describe three of these areas and my assessment of the status of Cheat Mountain Salamanders in each. I did not find typical Cheat Mountain Salamander habitat (Pauley 2005, 2007) in any sites that I have examined. I also determined that the nearest known location of Cheat Mountain Salamanders to the proposed project is approximately six miles south of the northern rim of Blackwater River Canyon located on , Tucker County.

Corridor Habitat Assessment Areas

Area 1 Location: This area extends from Leadmine Run east to U.S. Route 219.

Habitat Assessment Results: Mixed forest

Inventories for Salamanders: None

Recommendation: I do not recommend an inventory.

Area 2

Location: This area extends from U.S. Route 219 east to County Road 93.

Habitat Assessment Results: Mixed deciduous forest

Inventories for Salamanders: None

Recommendation: I do not recommend an inventory.

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Area 6

Location: This area is south of WV Route 93 and covers the entire distance along the Elder Swamp.

Habitat Assessment Results: Mixed deciduous forest

Inventories for Salamanders: I have conducted inventories at three sites in this area.

Recommendation: I do not recommend additional studies here.

Dr. Pauley’s 2008 Report

In my report to Power Engineers dated November 9, 2007, I divided the section of the proposed TrAIL corridor closest to the range of the Cheat Mountain Salamander into eight areas. In that report, I eliminated Areas 1, 2, and 6 as potential Cheat Mountain Salamander habitat based on previous studies of the Cheat Mountain Salamander in those areas. In five areas: Area 3, 4, 5, 7, and 8, I had not conducted previous studies and suggested that those sites be examined. These areas were examined in January 2008, and below are my habitat assessments of those areas.

Habitat assessments at these five areas were based on known habitat characteristics of Cheat Mountain Salamanders described by Pauley (2005; 2007). Pauley depicted the habitat as forests above 2,000 ft in elevation in the northern part of the range and 3,500 ft in the southern part of the range. Such forests are dominated by Red Spruce () and Yellow (), and a liverwort (Bazzania trilobata)) occurs on the forest floor. Such habitats are associated with emergent rocks, boulder fields, or narrow ravines lined with Great Rhododendron (Rhododendron maximum) (Pauley 2007).

It should be noted that the known total range of the Cheat Mountain Salamander extends from a northern terminus at Blackwater River Canyon (Tucker County) to approximately 57 miles south to on Cheat Mountain (Pocahontas County). In the north (the area nearest the proposed TrAIL corridor), the known range extends south from the northern rim of Blackwater River Canyon to Cheat Mountain where it stops at Thorny Flat (Pocahontas County) and from Blackwater River Canyon southeast to the at Dolly Sods (Tucker and Grant Counties) where it continues south along the Allegheny Front and Spruce Mountain to Spruce Knob (Pendleton County). South of Barton Knob on Cheat Mountain (Randolph County), the range becomes narrow and is confined to Cheat Mountain (Pocahontas County) to the west and Back Allegheny Mountain (Pocahontas County) to the east (Pauley 2008a).

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Corridor Habitat Assessment Areas

Area 3 Location: This area extends from County Road 93 east to West Virginia Route 90. I had not previously examined the habitat or conducted salamander inventories between the Western Maryland Railroad at Beechwood and West Virginia Route 90 so I recommended a habitat assessment in this area.

Habitat Assessment Results: Forest in this region is composed of deciduous species including Red Maple (Acer rubrum), Wild Black Cherry (Prunus serotina), and Black Birch (). The forest floor is open with ferns, mostly Spinulose Shield Fern (Dryopteris spinulosa), and a variety of moss species. There were numerous rocks and logs on the forest floor.

Inventories for Salamanders: Based on these habitat characteristics, I do not recommend on-site inventories for Cheat Mountain Salamanders.

Area 4 Location: This area extends from West Virginia Route 90 east to Grant/Tucker county line. Because I had not examined the habitat or conducted salamander inventories between West Virginia Route 90 and the Grant/Tucker county line, I recommended a habitat assessment in this area.

Habitat Assessment Results: Forest canopy consists of Red Maple (Acer rubrum) and American () and is dominated by a large field that most likely is the remains of an old stripmine. Forest floor is open and without Bazzania trilobata.

Inventories for Salamanders: Based on these habitat characteristics, I do not recommend on-site inventories for Cheat Mountain Salamanders.

Area 5 Location: This area extends from the Grant/Tucker County line east to West Virginia Route 93 at Elder Swamp. Since I had not examined the habitat or conducted salamander inventories on Timberman Ridge at site of the proposed transmission line, I recommended a habitat assessment on Timberman Ridge.

Habitat Assessment Results: Forest in this area is also comprised of a variety of deciduous species dominated by Red Maple (Acer rubrum) and Wild Black Cherry (Prunus serotina). There were also scattered Yellow Birch (Prunus alleghaniensis). Forest floor is open and without Bazzania trilobata.

Inventories for Salamanders: Based on these habitat characteristics, I do not recommend on-site inventories for Cheat Mountain Salamanders.

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Area 7 Location: This area extends from West Virginia Route 93 west of the Grant/Tucker County line east to the substation at Mount Storm Lake. I had not examined the habitat or conducted salamander inventories in this area so I recommended a habitat assessment be conducted.

Habitat Assessment Results: Forest here was composed of the same deciduous species observed in other areas but with Quaking Aspen (Populus tremuloides) and scattered Eastern Hemlock ()

Inventories for Salamanders: Based on these habitat characteristics, I do not recommend on-site inventories for Cheat Mountain Salamanders.

Area 8 Location: This area extends from the substation to the Allegheny Front. I previously examined the habitat at Pigeonroost but not where the proposed line crosses the Allegheny Front. Although the habitat at Pigeonroost is a mixed deciduous forest, I thought it was important to examine all areas along the Allegheny Front for Cheat Mountain Salamanders before any disturbance.

Habitat Assessment Results: Much of the proposed line follows an existing line. Forest canopy trees here consist of Red (Quercus rubra), Wild Black Cherry (Prunus serotina), American Beech (Fagus grandifolia), and Red Maple (Acer rubrum). Forest floor is open with rocks and logs but without Bazzania trilobata.

Inventories for Salamanders: Based on these habitat characteristics, I do not recommend on-site inventories for Cheat Mountain Salamanders.

Distribution of Salamanders in the Study Area.

Salamanders I observed in the general area near and on the proposed TrAIL corridor during previous inventories included:

Eastern Red-back Salamanders (Plethodon cinereus) – 5 individuals Allegheny Mountain Dusky Salamanders (Desmognathus ochrophaeus) – 5 individuals Wehrle’s Salamanders (Plethodon wehrlei) – 2 individuals Northern Slimy Salamander (Plethodon glutinosus) – one individual Four-toed Salamander (Hemidactylium scutatum) – one individuals

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No salamanders were observed at several sites in this area during these previous inventories. These species and Cheat Mountain Salamanders belong to family Plethodontidae which are lungless salamanders. They respire though their skin and the lining of their mouths. In addition, they, like all amphibians, are ectothermic (“cold-blooded”). These two characteristics restrict many species to cool, moist habitats. All of these species have been found to occur in sympatry with Cheat Mountain Salamanders (Pauley 2008b). Two of these, Red-backed Salamanders and Allegheny Mountain Dusky Salamanders, are abundant within the Cheat Mountain Salamander range and have been shown to be competitors with Cheat Mountain Salamanders for food, nesting sites, and moist spots (Pauley 2005). Red- backed Salamanders and Allegheny Mountain Dusky Salamanders have large ranges that extend over several states suggesting that both are more successful than Cheat Mountain Salamanders in occupying areas with varying abiotic and biotic factors. Given these characteristics, it is not uncommon for these two sympatric species of Cheat Mountain Salamanders to be found in habitats and areas where Cheat Mountain Salamanders do not occur.

Pauley (2008a) stated that typical Cheat Mountain Salamander habitat does not extend beyond the northern rim of Blackwater River Canyon. While there are numerous red spruce stands, most are xeric in nature. Pauley examined 114 sites on the northern sections of Canaan, Backbone, Cabin, and Allegheny Front mountains. At several of these 114 sites, especially on Cabin Mountain and Allegheny Front, he reported few to no salamanders and he attributed this to extremely dry conditions. Some of this area was burned to the bedrock during the early 1900s and has never regained enough soil to support lungless salamanders such as Cheat Mountain Salamanders (Allard and Leonard, 1952; T.K. Pauley, 2008b).

While previous studies indicate that Cheat Mountain Salamanders do not appear north of the northern rim of Blackwater River Canyon, the high level of activity with windpower construction and other activities that could impact sensitive species makes it necessary to investigate all areas within the Cheat Mountain range of West Virginia to ensure that there is not an isolated colony of Cheat Mountain Salamanders in this area. This is particularly true along the Allegheny Front.

POWER Conclusion

Dr. Pauley’s 2007-2008 habitat assessments within Segments 1 and 2 of the proposed TrAIL corridor were conducted in response to his study efforts recommended above, and in response to USFWS’ specific requests. On basis of his field investigations, previous research, and literature survey, it does not appear that the proposed TrAIL corridor and adjoining areas support Cheat Mountain Salamander habitat, or fall within the known areas of occurrence for this threatened species. As stated by Dr.Pauley, in the area nearest the proposed TrAIL corridor, the known range extends south from the northern rim of Blackwater River Canyon. The latter is located between 3.5 to 4 miles from the corridor edge. As a result, no Cheat Mountain Salamanders are expected to occur within the TrAIL project area, and the proposed TrAIL project is not expected to have adverse impacts on this species.

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As a result, POWER respectfully requests a determination that the project is not likely to adversely affect the Cheat Mountain Salamanders. As always, give me a call at (208) 721- 7659, or reach me at [email protected], if you have any questions or comments regarding this study or any other TrAIL permitting issues.

Sincerely,

Jon Wiese

c: H. Kauffman (TC) G. Hassler (KCC) B. Williams (KCC) K. Kurchev (KCC) J. Monday (KCC) B. Sargent (WV DNR) T. Pauley J. Knight (POWER) B. Berkebile (POWER) K. Lincoln (POWER) H. Cunha (POWER) L. Askew (POWER) K. Kefer (POWER)

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Literature Cited

Allard, H.A. and E.C. Leonard. 1952. The Canaan and Stony River Valleys of West Virginia, their former magnificent spruce forests, their vegetation and floristics today. Castanea 17:1-60.

Pauley, T.K. 2005. Reflections Upon Amphibian Conservation. In Amphibian Declines: The Conservation Status of the United States Species. M.J. Lannoo, Editor. University of California Press, Berkeley, California. Chapter 40, Pp. 277-281.

Pauley, T.K. 2007. Amphibians in the Drainage. West Virginia University Press (In Press).

Pauley, T.K. 2008a. Revised notes on the range of the Cheat Mountain Salamander, Plethodon nettingi, (Amphibia: Caudata). Proceedings of the West Virginia Academy of Science (In Press).

Pauley, T.K. 2008b. The Appalachian Inferno: Historical Causes for the Disjunct Distribution of Plethodon nettingi (Cheat Mountain Salamander). Northeastern Naturalist (In Press).

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