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March 22, 2017 Submitted Via Electronic Mail And March 22, 2017 Submitted via electronic mail and U.S. Mail Sarah McRae Aquatic Endangered Species Biologist U.S. Fish & Wildlife Service, Southeast Region PO Box 33726 Raleigh, NC 27636-3726 [email protected] Re: Updated Best Available Science for Neuse River Waterdog (Necturus lewisi) Dear Ms. McRae, I am writing on behalf of the Center for Biological Diversity (“Center”) to provide additional information on the status of the Neuse River waterdog (Necturus lewisi), which is scheduled to receive an Endangered Species Act 12-month finding in 2017. The Center is a national, nonprofit organization with more than 1.2 million members and supporters who are dedicated to protecting and restoring endangered species and their habitats through science, policy, education, advocacy, and environmental law. The Neuse River waterdog is a rare and significant part of North Carolina’s— indeed the United States’—natural heritage. It is only known from the Neuse and Tar-Pamlico River systems in the Piedmont and Coastal Plain regions of North Carolina (AmphibiaWeb 2017). The best available science indicates that the species is in decline and facing current and mounting threats including habitat loss, pollution, overutilization, and climate change. Existing regulatory mechanisms are inadequate to protect the Neuse River waterdog from these threats and ensure its future existence. Consequently, it is imperative that the U.S. Fish and Wildlife Service (“Service”) protect the species under the Endangered Species Act. This letter provides recent, relevant scientific studies as well as newly identified threats within the species’ range, which is meant to supplement information provided in a petition to list the species submitted in 2010 and already before the agency.1 1 Center for Biological Diversity, Petition to List 404 Aquatic, Riparian and Wetland Species from the Southeastern United States as Threatened or Endangered under the Endangered Species Act 6–33, 723–729 (April 20, 2010), available at I. Habitat Destruction Neuse River waterdogs are impacted by habitat loss and degradation in the river systems where they are found. They use different types of habitat at different developmental stages; thus a diverse array of microhabitat is required to support healthy populations. Juvenile waterdogs shelter under granite boulders on sand and gravel substrates, and at an eastern Piedmont site they also use leaf beds in the early spring (AmphibiaWeb 2017). Adult waterdogs are permanently aquatic and are generally found in backwaters off the main current (AmphibiaWeb 2017). They prefer sandy or muddy substrates (AmphibiaWeb 2017). They are most commonly found in streams greater than 15 meters wide and 1 meter deep, with flow rates greater than 10 cubic meters per second (AmphibiaWeb 2017). They have also been found in areas with clay or hard soil substrates and leaf beds (AmphibiaWeb 2017). Within waterways, Neuse River waterdogs are distributed throughout larger headwater streams to coastal streams up to the point of saltwater intrusion (AmphibiaWeb 2017). Neuse River waterdog habitat is threatened primarily by damming and channelization of streams, as well as degradation from urban, industrial, and agricultural pollution. The following subsections address each of these threats in detail. a. Dams and Channelization Dams and channelization cause significant, negative impacts to aquatic environments, and thus threaten the Neuse River waterdog. There are numerous dams in North Carolina and in the species’ range. According to the U.S. Army Corps of Engineers’ National Inventory of Dams, there are 3,444 dams in North Carolina (USACOE undated). The Corps ranks 1,448 dams as having a high hazard potential and 599 dams as having a significant hazard potential (USACOE undated). The hazard potential classification is intended to rank dams in terms of potential downstream losses—including environmental losses—if the dam should fail or be improperly operated (USACOE undated). These rankings are significantly lower than neighboring South Carolina, which has 2,444 total dams with 209 ranking with a high hazard potential and 480 ranking with a significant hazard potential (USACOE undated). There are 28 dams on the Neuse River and its major tributaries, 11 on the Tar River and its tributaries, and 5 on the Pamlico River (USACOE undated). All dams have complex impacts on waterways, including significant impacts on natural stream flows by reducing the amount of water available through evaporative loss, storage, and releases (Baer and Ingle 2016 at 38). Water releases may also be irregular. For instance, hydropower dams release water http://www.biologicaldiversity.org/programs/biodiversity/1000_species/the_southeast_freshw ater_extinction_crisis/pdfs/SEPetition.pdf. 2 of 19 when they are generating power and release much smaller amounts when they are not (Baer and Ingle 2016 at 38). Although dams regulated by the Federal Energy Regulatory Commission (FERC) must obtain licenses with set conditions to generate hydroelectricity, these licenses were often granted before the importance of river-flow protection was recognized (Baer and Ingle 2016 at 38). Because Neuse River waterdogs have specific preferences regarding the size, depth, and flow of the waterways they inhabit, existing dam’s impacts to flow continue to threaten the species survival. Low or irregular flows caused by dams are particularly concerning in light of projected increasing temperatures and rain variability due to global climate change and projected human population growth (Carter et al. 2014 at 403, 405–406), which could lead to limited water availability for the species. Dams also significantly alter aquatic environments, leading to negative impacts on species. Specifically, they can change water quality via shifts in temperature, pH, turbidity, and dissolved oxygen. Impoundments can alter physical and chemical water qualities including dissolved oxygen and water temperature, which in turn affects the ecosystems below them (Lessard and Hayes 2003 at 722). Temperature is a crucial physical property of flowing water because of its significance to all freshwater organisms (Webb et al. 2008 at 902). For instance, elevated temperatures can increase wildlife metabolic rates, creating a need for increased levels of food quantity and quality for the wildlife to survive (Lessard and Hayes 2003 at 722). Species that need cold water are also negatively impacted by increased water temperatures (Lessard and Hayes at 722). Because the Neuse River waterdog’s activity levels can be impacted by water temperature (AmphibiaWeb 2017), these impacts should be considered a threat to the species. Dams can also cause channel incision, the general lowering of a streambed over time (Castro 2003 at 2; Simon and Rinaldi 2006 at 375). Incision is of particular concern in areas with soft, erodible sediments. Typically the channel below the dam will become deeper and the banks will collapse as the channel grows wider and shallower as sediment is transferred downstream. Increased erosion and sedimentation associated with channel incision can drive extensive destruction and degradation of stream corridor habitats, leading to reduced habitat heterogeneity, greater temporal instability, reduced stream-floodplain interaction, and shifts in fish community structure (Shields et al. 1994, entire; Shields et al. 1998, entire). Incised streams are also likely to demonstrate water quality degradation with levels of turbidity and solids 2–3 times higher than non-incised streams (Shields et al. 2010, entire). They may also demonstrate increased “flashiness,” dramatic fluctuation in flow between dry and wet weather (Shields et al. 2010, entire). These changes make incised channel habitat “inferior” to channels not impacted by incision, with fewer types of habitat (Shields et al. 1994 at 48–52). Dams in the Neuse River waterdog’s range likely cause these types of changes to sediment and water flow, which 3 of 19 could contribute to declines in waterdog populations that depend on specific sediment and flow conditions. Dam failure or reckless removal of existing dams may also threaten waterdog populations if not completed with caution and active monitoring. North Carolina has one of the highest densities of small dams in the U.S. (Sherman 2013 at i). As many smaller dams become structurally unsound, they are being removed. For species like the Neuse River waterdog, which have specific habitat requirements related to water depth, flow, and quality, sudden changes caused by dam removal could be devastating. For instance, dams tend to cause upstream sediment storage, which is then released downstream (Doyle et al. 2005 at 229; Sherman 2013 at 11–12). These sediments may be contaminated in areas where dams were built in urbanized areas for industrial purposes (Sherman 2013 at 12). If a sediment release were to flow over active waterdog habitat, it would essentially evict the species by completely engulfing the leaf litter, boulders, and gravel it uses for sheltering. This would expose the waterdog to predation and disrupt essential feeding and breeding activities. Thus, while dam removal can return some aspects of aquatic ecosystems such as water flow to their pre-dam state, there is also potential for it to cause “irreversible degradation to specific ecosystem attributes” if removal is not designed to minimize negative impacts and maximize ecosystem recovery (Doyle et al. 2005 at 241–242). Likewise, these threats exist if a dam were to fail. The
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