Proposed listing of the Atlantic pigtoe
In December 2018, NCASI submitted comments to the U.S. Fish and Wildlife Service (Service) in response to proposed listing of the Atlantic pigtoe (Fusconaia masoni), a freshwater mussel now only found in Virginia and North Carolina, in the Tar, Neuse, James, Chowan, Roanoke, Cape Fear, and Yadkin-Pee Dee River basins. The Service states that the Atlantic pigtoe “currently has reduced adaptive potential due to limited representation (compared with historical representation) in seven river basins and three physiographic regions” (83 Fed. Reg. 51573). The proposed rule indicates habitat degradation as the most significant threat to the species. Although the Service recognized that forested landscapes are protective of water quality and stream function, they also stated that forestry activities can have effects on small streams and that “clearing of large areas of forested wetlands and riparian systems can eliminate shade provided by these canopies, exposing streams to more sunlight and increasing the instream water temperature” (83 Fed. Reg. 51575).
The summary of NCASI technical comments on the proposed Atlantic pigtoe listing follows:
On October 11, 2018, the U.S. Fish and Wildlife Service (hereafter, Service) published a proposal to list the Atlantic pigtoe (Fusconaia masoni), a freshwater mussel found in Virginia and North Carolina, as a threatened species under the Endangered Species Act (Act; 83 Fed. Reg. 51570–51609). Private managed forests represent a dominant land use in the southeastern United States, and within the range of the Atlantic pigtoe. In the proposed rule, the Service recognized that “managed forested watersheds tend to have more natural watershed functions and better water quality than other land uses” (83 Fed. Reg. 51575). However, the Service also described some concerns related to potential effect of forestry activities on characteristics of streams. Forestry activities in the United States are conducted under a comprehensive program of state-approved best management practices (BMPs) designed to protect water quality and habitat for aquatic organisms. Rigorous, ongoing efforts to monitor forestry BMPs continually and consistently document that implementation rates are high so that risks to water quality from forestry activities are low both nationally and in this species’ range. Although BMPs are voluntary, they are required for landowners that are certified under various forest certification standards, such as the Sustainable Forestry Initiative, American Tree Farm System and Forest Stewardship Council. A large body of scientific literature confirms that properly implemented forestry BMPs are effective at protecting water quality and in-stream habitat conditions. Considerable research also indicates that silvicultural practices implemented with BMPs protect aquatic species.
In the proposed rule, the Service has recognized contributions of forestry BMPs to conserving the Atlantic pigtoe. We concur with this assessment, and note that by describing the benefits of BMPs for water quality and encouraging their continued use, the proposed rule provides a clear, actionable and scientifically sound approach for conserving this species.