ML26006A060

SNC to NMFS, Request for Concurrence and Biological Assessment

ML26006A060
Person / Time
Site:	Hatch
Issue date:	01/05/2026
From:	Delano J Southern Nuclear Operating Co
To:	Alvarez M Office of Nuclear Material Safety and Safeguards, US Dept of Commerce, National Marine Fisheries Service
References
ENV-26-0105
Download: ML26006A060 (0)

Text

Environmental Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 January 5, 2026 Via Email Docket Nos.: 50-321 ENV-26-0105 50-366 Melissa Alvarez, Section 7 Team Lead NMFS Southeast Regional Office National Marine Fisheries Service 263 13th Avenue South St. Petersburg, FL 33701

SUBJECT:

REQUEST FOR CONCURRENCE WITH ENDANGERED SPECIES ACT DETERMINATIONS FOR EDWIN I. HATCH, UNITS 1 AND 2, PROPOSED SUBSEQUENT LICENSE RENEWAL IN APPLING COUNTY, GEORGIA (IPAC PROJECT CODE: 2026-0023060)

Dear Melissa Alvarez:

With this letter, Southern Nuclear Operating Co., Inc. (SNC), acting as a non-federal representative (NFR) designated by the U.S. Nuclear Regulatory Commission (NRC), requests the National Marine Fisheries Services (NMFS) written concurrence with the biological determinations pursuant to Section 7 of the Endangered Species Act of 1973, as amended (ESA), concerning federally listed or proposed to be listed species that may be affected by the proposed Federal action on the Hatch Nuclear Plant (HNP), Units 1 and 2, site in Appling County, Georgia. This letter includes information explaining and supporting this request.

Proposed Federal Action HNP includes two boiling-water reactors. SNC is the licensee and operator of HNP Units 1 and 2 pursuant to NRC operating licenses (OLs) DPR-57 and NPF-5, respectively. HNP is located in Appling County, Georgia, approximately 11 miles north of Baxley, Georgia. The HNP site consists of approximately 2,244 acres (908 hectares) of which approximately 300 acres (121 hectares) along the Altamaha River are dedicated to the plant and associated facilities. The nuclear power station, associated infrastructure, and the operational site boundary are in Appling County. A portion of the overall, non-operational property, is also located in Toombs County, Georgia.

The NRCs Federal action is to decide whether to subsequently renew the HNP, Units 1 and 2, renewed facility operating licenses for an additional 20 years of operation. SNC initiated the proposed Federal action by submitting an application (Agencywide Documents Access and Management System) (ADAMS) Package Accession No. ML25135A390 for subsequent license renewal for HNP, Units 1 and 2. The existing HNP, Units 1 and 2, renewed facility operating licenses (DPR-57 for Unit 1, NPF-5 for Unit 2) have expiration dates of August 6, 2034 (Unit 1),

and June 13, 2038 (Unit 2). If the NRC were to subsequently renew these licenses, SNC would

NMFS ENV-26-0105 Page 2 be authorized to operate HNP, Units 1 and 2, until August 6, 2054, and June 12, 2058, respectively.

Biological Assessment for HNP, Units 1 and 2, Subsequent License Renewal In support of its environmental review of the HNP, Units 1 and 2, subsequent license renewal application, the NRC is preparing a draft supplemental environmental assessment (EA) to comply with the National Environmental Policy Act of 1969, as amended (NEPA), and the NRCs regulations at Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental protection regulations for domestic licensing and related regulatory functions, that implement NEPA. This EA will address the environmental impacts of the proposed action and reasonable alternatives to the proposed action.

In support of this concurrence request, the SNC is providing the NMFS with a copy of the biological assessment (as enclosure) and the HNP Subsequent License Renewal Application, Appendix E - Applicants Environmental Report (as virtual enclosure), prepared in support of the renewal application. Information relevant to this concurrence request can be found in the biological assessment and following sections of the Environmental Report:

• Section 2.1 describes the HNP proposed action.

• Section 2.2 describes HNP maintenance, inspection, and refueling activities.

• Section 2.6.1 - 2.6.3 describes the alternatives evaluation process, alternative energy sources, and alternatives for reducing adverse impacts.

• Section 3.6.1 describes surface water resources for the action area.

• Section 3.7 describes terrestrial and aquatic resources for the action area.

• Section 4.2.4 describes species and critical habitat under jurisdiction of the United States Fish and Wildlife Service.

• Section 4.2.5 describes species and critical habitat under jurisdiction of the NMFS.

• Section 4.7.5 describes cumulative effects on ecological resources.

• Section 7.2 describes the alternatives analysis.

Request for Concurrence Consistent with Title 50 of the Code of Federal Regulations (50 CFR) 402.12, Biological assessments, acting as the project NFR, SNC requests your written concurrence with its determinations in the biological assessment prepared for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 Continued Operations Under Subsequent License Renewal Operating License that the proposed action is not likely to adversely affect the following listed species: Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus) and shortnose sturgeon (Acipenser brevirostrum).

SNC also determined in the biological assessment that the proposed action is not likely to

NMFS ENV-26-0105 Page 3 adversely affect critical habitat for the Atlantic sturgeon. SNC welcomes any comments that the NMFS may have on this species or the impact assessments.

Please provide your response electronically to the following email addresses:

lrgrisso@southernco.com; EndangeredSpecies@nrc.gov; and Shannon.Healy@nrc.gov.

If you have any questions regarding the information in this letter, please contact me by phone at 205.992.5419.

Sincerely, James M. DeLano, P.E.

Environmental Affairs Manager Enclosure(s):

1. Biological Assessment Edwin I. Hatch Nuclear Plant, Units 1 and 2 Continued Operations Under Subsequent License Renewal Operating License

2. HNP Subsequent License Renewal Application, Appendix E, Applicants Environmental Report (ML25135A392) (https://www.nrc.gov/docs/ML2513/ML25135A392.pdf)

Cc:

NRC Project Manager (Safety Review), NRR-DNRL NRC Project Manager (Environmental Review), NRR-DNRL NRC Environmental Scientist, NMSS-REFS SNC RType: CCSLR1.001 JMDELANO Digitally signed by JMDELANO Date: 2026.01.05 14:43:40

-06'00'

Biological Assessment Edwin I. Hatch Nuclear Plant, Units 1 and 2 Continued Operations Under Subsequent License Renewal Operating License

Biological Assessment Edwin I. Hatch Nuclear Plant, Units 1 and 2 Continued Operations Under Subsequent License Renewal Operating License Nos. DPR-57 and NPF-5 January 2026 Docket Nos. 50-321 and 50-366 U.S. Nuclear Regulatory Commission Rockville, Maryland Prepared by:

Southern Nuclear Operating Company, Non-Federal Representative

Table of Contents 1.0 Introduction............................................................................................................................... 1 2.0 Background/History................................................................................................................... 1 3.0 Proposed Action........................................................................................................................ 3 4.0 Action Area................................................................................................................................ 3 5.0 Federally Listed Species............................................................................................................. 4 5.1 Terrestrial Species...................................................................................................................... 5 5.1.1 Tricolored bat................................................................................................................. 5 5.1.1.1 Tricolored Bat Status in the Area of Concern.......................................................... 8 5.1.2 Red-cockaded woodpecker............................................................................................ 8 5.1.2.1 Red-cockaded Woodpecker Status in the Area of Concern..................................... 9 5.1.3 Eastern indigo snake....................................................................................................... 9 5.1.3.1 Eastern Indigo Snake Status in the Area of Concern..............................................10 5.1.4 Southern Hognose Snake..............................................................................................10 5.1.5 Monarch Butterfly.........................................................................................................10 5.1.5.1 Monarch butterfly Status in the Area of Concern...................................................10 5.2 Aquatic Species.....................................................................................................................11 5.2.1 Altamaha spinymussel...................................................................................................11 5.2.1.1 Altamaha spinymussel and Status in the Area of Concern.....................................12 5.2.2 Atlantic sturgeon...........................................................................................................13 5.2.2.1 Atlantic sturgeon and Status in Area of Concern...................................................14 5.2.3 Shortnose sturgeon.......................................................................................................15 6.0 Federally Designated Critical Habitat.......................................................................................18 7.0 Effects of Proposed Action.......................................................................................................20 7.1 Aquatic Species Potential Effects.........................................................................................20 7.1.1 Dredging and Sediment Contamination........................................................................20 7.1.2 Entrainment and Impingement.....................................................................................22 7.1.3 Thermal Effects.............................................................................................................25

7.1.4 Habitat Fragmentation..................................................................................................27 7.1.5 Trophic Interactions.......................................................................................................27 7.2 Terrestrial Species Potential Effects.....................................................................................28 7.2.1 Forestry Management................................................................................................... 29 7.2.2 Infrastructure Maintenance..........................................................................................30 7.3 Critical Habitat Potential Effects...........................................................................................30 8.0 Mitigation Strategies................................................................................................................33 9.0 Cumulative Effects....................................................................................................................34 10.0 Conclusions.............................................................................................................................35 11.0 Literature Cited.......................................................................................................................36 List of Tables Table 1. Federal Protected Species of Concern in Action Area....................................................... 5 Table 2. Status Summary of Population Units of the Altamaha Spinymussel............................... 11 Table 3. Physical or Biological Features of South Atlantic DPS Atlantic Sturgeon Critical Habitat19 Table 4. Effect Determinations for Federally Listed Species Under U.S. Fish and Wildlife Service Jurisdiction for HNP License Renewal........................................................................................... 32 Table 5. Effect Determination for Federally Listed Species Under National Marine Fisheries Service Jurisdiction for HNP License Renewal............................................................................... 33 List of Figures Figure 1. Project Vicinity Figure 2. USGS Topographical Map Figure 3. ESA Action Area Figure 4. Site Features Figure 5. Altamaha Spinymussel Critical Habitat Unit 2 List of Appendices Appendix A. Protected Species Documentation

Abbreviations, Acronyms, and Symbols bta best technology available

°C degrees Celsius cca candidate conservation agreement cm centimeters csm conceptual site model dbh diameter at breast height DO dissolved oxygen DPS Distinct Population Segment ER Environmental Report ESA Endangered Species Act of 1973, as amended

°F degrees Fahrenheit GA EPD Georgia Environmental Protection Division GDNR Georgia Department of Natural Resources GPC Georgia Power Company GTTCA Gopher Tortoise Candidate Conservation Agreement HNP Hatch Nuclear Plant in inches IPaC Information for Planning and Consultation m

meter(s) mg/L milligrams per liter mm millimeters msl mean sea level MW megawatts NFR non-federal representative NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission OL operating license PBFs physical or biological features

PCEs primary constituent elements ppt parts per trillion rm river mile SARBO South Atlantic Regional Biological Opinion SLR subsequent license renewal SNC Southern Nuclear Operating Co., Inc SPEO subsequent period of extended operation spp species UGA University of Georgia USACE United States Army Corps of Engineers USFWS United States Fish and Wildlife Service UTM Upland Testing Manual WNS white-nosed-syndrome WRD Wildlife Resources Division yoy young-of-year

1 1.0 Introduction Southern Nuclear Operating Co., Inc. (SNC), acting as a non-federal representative (NFR) designated by the U.S. Nuclear Regulatory Commission (NRC), prepared this biological assessment to comply with provisions of Section 7 of the Endangered Species Act of 1973, as amended (ESA), in support of the NRCs request to initiate informal consultation with the National Marine Fisheries Services (NMFS) and U.S. Fish and Wildlife Service (USFWS) under Section 7 of the ESA for subsequent license renewal (SLR) for continued operations of the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 located approximately 11 miles north of Baxley, Georgia (Figures 1 and 2).

2.0 Background/History On August 31, 2000, in conjunction with the license renewal application for HNP, NRC staff submitted a biological assessment to NMFS for the federally endangered shortnose sturgeon (Acipenser brevirostrum) (NRC, 2000). On July 9, 2004, the NRC (2004) submitted a revised biological assessment concluding that HNP may affect the shortnose sturgeon, and that the effects are discountable and extremely unlikely to occur, and, therefore, not likely to adversely affect the species. Subsequently, the U.S. Army Corps of Engineers (USACE) sent a letter dated May 19, 2005, requesting ESA Section 7 consultation on the issuance of a permit to conduct maintenance dredging of the Altamaha River intake structure sat HNP and requested NMFS's concurrence with its determination that periodic maintenance dredging at HNP was not likely to adversely affect the shortnose sturgeon. Because NMFS believed that periodic maintenance dredging is interrelated to the operation of the plant, it combined these two activities into one consultation.

In a letter dated August 10, 2005, NMFS found that chances of impinging juvenile and adult shortnose sturgeon on the intake trash racks or entraining short nose sturgeon eggs or larvae in the cooling water intakes are discountable and that the effects of discharging heated effluent and dredging operations on shortnose sturgeon are insignificant. NMFS concurred with the USACE and NRC staff that continued operation of HNP with periodic maintenance dredging is not likely to adversely affect shortnose sturgeon.

On October 11, 2011, USFWS listed the Altamaha spinymussel (Elliptio spinosa) as endangered and designated its critical habitat. The listing announcement identified several sources of stress associated with operating HNP that might adversely affect the Altamaha spinymussel population. Designated critical habitat for Altamaha spinymussel is excluded in the river section

2 immediately upstream of the US Highway 1 bridge to approximately 1.1 miles downstream of HNP. Thus, there is no critical habitat for the species present within the HNP action area.

On August 7, 2013, the NRC submitted a biological assessment for Altamaha spinymussel. The document addressed whether the operation of HNP, including the proposed license amendment, has potential to affect the Altamaha spinymussel and its designated critical habitat. The assessment was submitted to USFWS, requesting concurrence. The NRC staff concluded that the continued operation of HNP may affect, but is not likely to jeopardize, the continued existence of the Altamaha spinymussel, and that any possible adverse effects would accrue primarily through direct mortality caused by entrainment and impingement of larvae and juveniles of its unknown host fish species, although the effects are probably discountable.

The staff also concluded that operation of HNP would have no effect on designated critical habitat of the Altamaha spinymussel.

In 2015, SNC submitted a permit application to the USACE requesting authorization to continue annual maintenance dredging at the HNP intake structure. As part of this permit approval process, a biological assessment was prepared for the shortnose sturgeon and Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus), which was listed under the ESA on February 6, 2012, that is specific to the proposed maintenance dredging at HNP. Based on available species data, including life history and information specific to the Altamaha River and permit conditions developed specifically to protect these species through prior USACE and NMFS coordination, the biological assessment concluded that the proposed continuation of maintenance dredging at HNP may affect, but is not likely to adversely affect, the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel.

The USACE initiated a Section 7 consultation with the NMFS and USFWS as part of its review of this permit application. In a letter dated January 26, 2016, USFWS concurred with the USACEs determination with regards to the Altamaha spinymussel. In a letter dated January 29, 2016, the NMFS provided recommendations as follows: (1) restricting in-water work to daylight hours from April 16 to August 31 of each year and utilizing appropriate in-water turbidity and sedimentation control measures during dredging operations; (2) implementation of measures to avoid and minimize entrainment of fish in dredging equipment; and (3) providing additional treatment of effluent before it enters the Altamaha River unless SNC demonstrates the proposed treatment sufficiently filters pollutants or sediment particles prior to the water entering the river.

In 2021, a joint application for a USACE/State of Georgia Marshland Protection permit, revocable license agreement and request for water quality certification for the intake structure maintenance dredging renewal permit was submitted. Both the GA EPD, as part of the HNP National Pollutant Discharge Elimination System (NPDES) permit renewal, and the USACE, as

3 part of the dredging permit re-issuance, performed Section 7 consultations with the NMFS. The GA EPD provided the permit application to both NMFS and USFWS. In an email dated April 20, 2022, the USFWS responded that it did not have any comments. In a letter dated June 28, 2022, the NMFS recommended no control measures. With respect to dredging activities, the USACE determined that HNP activities were consistent with the 2020 SARBO and relied on that opinion to issue the HNP dredge permit (NOAA, 2020).

Under HNP's current USACE dredging permit (No. SAS-1994-03873), HNP follows all applicable Project Design Criteria in the 2020 South Atlantic Regional Biological Opinion (SARBO). These include general equipment specific, and sturgeon Project Design Criteria for the future protection of the Atlantic sturgeon and shortnose sturgeon (NOAA, 2020).

Most recently, the NRC notified the NMFS and USFWS via letter on July 8, 2025, that SNC has been designated as an NFR for the HNP SLR. SNC contacted the NMFS and USFWS via email on July 31, 2025, and requested those agencies provide any documentation or steps that may be needed as part of the biological assessment process.

3.0 Proposed Action SNC is the licensee and operator of HNP pursuant to NRC operating licenses (OLs) DPR-57 and NPF-5, respectively. The OLs were initially renewed in 2002. The current Unit 1 OL will expire at midnight on August 6, 2034, and the current Unit 2 OL will expire at midnight on June 13, 2038.

The SLR would allow an additional 20 years of operation for Unit 1 and Unit 2, with expiration occurring at midnight on August 6, 2054, and at midnight on June 13, 2058, respectively.

The proposed action is for the NRC to renew the HNP OLs for an additional 20 years. SNC has prepared an Environmental Report (ER) that provides detailed information regarding landscape features, operations, monitoring, and other features associated with HNP including detailed alternatives analysis. Refer to Section 7.2 of the ER for alternatives that were considered including the processes used to identify and select the proposed action.

4.0 Action Area The implementing regulations for ESA Section 7 define action area to mean all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The action area effectively bounds the analysis of federally listed species and critical habitats because only species and habitats that occur within the action area may be affected by the Federal action.

4 In Section 3.7.3.1.1 of the ER, the ESA action area is described as including:

HNP site: the terrestrial region of the action area consists of 2,244 acres of the HNP site.

The site consists of woody wetlands, which are the largest land use/land cover category within the HNP site boundary, covering approximately 52 percent of the site; evergreen forest is the next largest land use/land cover category, accounting for approximately 22 percent of the site; this is followed by developed areas (open space/low/medium/high intensity) at approximately 13 percent. The remaining ten land use/land cover categories account for approximately 12 percent of the site.

Altamaha River: The aquatic region of the action area includes the entire width of the Altamaha River from the USACE permitted maintenance dredging area located 900 linear feet upstream of the cooling water intake, downstream to the modeled thermal impact zone as defined by the GA EPD accepted model. The approved thermal mixing zone is defined as extending 914 feet downstream from the discharge and 262 feet across at the downstream extent.

This characterization of the action area as shown in Figure 3 remains relevant to the present consultation request. The ER describes the HNP site in detail including operation, monitoring, and maintenance efforts (Section 2.2), as well as land use and vegetation communities, geology, and wildlife (Sections 3.0 and 4.0). Figure 4 provides the location of relevant site features including the intake structure dredging area, dredge spoils and upland dewatering area including the outfall channel, discharge structure, and locations of Unit 1 and 2. Refer to Figure 3.1-1 in the ER for additional information regarding the plant layout and Section 3.0 for detailed discussions regarding the affected environment.

5.0 Federally Listed Species Pursuant to section 7 of the ESA, as amended, on July 7, 2025, the NRC staff consulted the USFWS Information for Planning and Consultation (IPaC) website regarding species of concern near HNP and requested a list of protected species through that website. The USFWS provided information on federally listed endangered or threatened species, as well as on proposed species that may occur in the HNP action area. Based on the IPaC query, the USFWS regulated federally listed species of concern with potential to occur in the action area are Altamaha spinymussel, red-cockaded woodpecker (Dryobates borealis), eastern indigo snake (Drymarchon couperi), southern hognose snake (Heterodon simus), monarch butterfly (Danaus plexippus), and tricolored bat (Perimyotis subflavus). The Atlantic sturgeon and shortnose sturgeon, which are within NMFS jurisdiction, are also federally listed species of concern for the action area. Table 1 provides a list of federally listed species of concern within the action area.

5 Table 1. Federal Protected Species of Concern in Action Area Species Federal Status*

Habitat Mammals tricolored bat Perimyotis subflavus PE Open forests with large trees and woodland edges; roost in tree foliage; hibernate in caves or mines with high humidity Birds red-cockaded woodpecker Dryobates borealis E

Nest in mature pine with low understory vegetation

(<1.5m); forage in pine and pine hardwood stands >30 years of age, preferably >10 dbh.

Fishes Atlantic sturgeon, South Atlantic DPS Acipenser oxyrinchus oxyrinchus E

Atlantic seaboard rivers and estuaries.

shortnose sturgeon Acipenser brevirostrum E

Atlantic seaboard rivers and estuaries.

Insects monarch butterfly Danaus plexippus PT Open fields and meadows with milkweed (Asclepias spp.)

Mussels Altamaha spinymussel Elliptio spinosa E

Fine to very coarse sand in sand bars with swift currents.

Reptiles eastern indigo snake Drymarchon couperi T

During winter, den in xeric sandridge habitat preferred by gopher tortoise; during warm months, forage in creek bottoms, upland forest, and agricultural fields.

southern hognose snake Heterodon simus PT Sand hills, fallow fields, and longleaf pine-turkey oak communities E = Endangered; T = Threatened; PE = Proposed Endangered; PT = Proposed Threatened 5.1 Terrestrial Species 5.1.1 Tricolored bat The tricolored bat is listed as a proposed endangered species under the ESA. The tricolored bat is a small insectivorous bat which is found in the eastern United States. This species range is throughout Georgia, and it makes use of a wide variety of habitats across its range including open forests, woodland edges, bridges, culverts, abandoned structures, and other habitat types. The tricolored can be identified by its tricolored fur, which is dark at the base, lighter in the middle, and dark at the tip (Barbour and Davis, 1969). Males and females are colored alike, but females are

6 typically larger than males (LaVal and LaVal, 1980).

Due to a marked decline in the population of tricolored in the United States (primarily due to white-nosed-syndrome [WNS]), in September 2022 the USFWS proposed to list the tricolored bat as endangered. The final rule for listing was expected in 2024 but appears to have been postponed indefinitely. In Georgia, the tricolored bat is listed as a species of concern by the Georgia Department of Natural Resources (GDNR), with populations in the northern portion of the state experiencing severe declines while coastal plain populations seem more stable by comparison.

The tricolored bat can be found throughout the eastern United States from Canada to Florida and west to New Mexico. In Georgia, tricolored bat can be found throughout the entire state in part since they make use of a wide variety of habitat types and structures for spring, summer, and fall roosting. Prior to the onset of WNS, tricolored bats were considered abundant across the landscape within their range (Cheng et al., 2021). Numerous studies have documented the range-wide decline of tricolored bats, which is primarily driven by WNS (USFWS, 2021).

During the spring, summer, and fall, tricolored bats primarily roost among live and dead leaf material found in live or recently dead hardwood trees. In the coastal plain areas, tricolored bats have been found roosting in Spanish moss (USFWS, 2021). The tricolored bat will make use of a wide variety of habitat types and structures for roosting, including mixed pine-hardwood forests, riparian areas, culverts, bridges, abandoned structures, live and dead leaf clusters, and many other structures. Female tricolored bats exhibit high site fidelity, returning to the same roost sites year after year (USFWS, 2021). Males roost singly and females form maternity colonies (Perry and Thill, 2007). Females give birth between May and July typically having two pups (Harvey et al., 2011). Tricolored bat maternity colonies typically consist of multiple roosts located near one another, and on average females change roosts between 1.2 and 7 days (Veilleux and Veilleux, 2004).

During winter, tricolored bats primarily hibernate in caves and mines (Harvey et al., 1999);

however, tricolored bats can also be found hibernating in culverts (Lutsch, 2019), abandoned water wells (Sasse et al., 2011), and in tree cavities (Newman, 2020). In the northern parts of their range, tricolored bats are commonly the first to arrive in caves in the fall and the last to leave in the spring (LaVal and LaVal, 1980). Compared to northern populations, southern populations of tricolored bat may exhibit shorter periods of hibernation (Stevens et al., 2020). In fact, some individuals may remain active throughout the winter if conditions are mild enough. For cave hibernating populations, tricolored bats are typically found in the warmest parts of the cave roosting singly or in small groups (Barbour and Davis, 1969).

7 Tricolored bats are considered opportunistic feeders and consume a wide variety of insects from caddisflies (Trichoptera), moths (Lepidoptera), beetles (Coleoptera), wasps and flying ants (Hymenoptera), true bugs (Homoptera) and flies (Diptera) (USFWS, 2021). Tricolored bats will forage anywhere from just above the ground to above the tree canopy throughout the night, depending on where the prey base is most concentrated (USFWS, 2021). In addition, tricolored bats commonly forage over water as well as along forest edges. Foraging ranges vary between males and females, with females averaging approximately 4.3 kilometers (2.7 miles) and males averaging 11.4 kilometers (7.1 miles) (USFWS, 2021).

Since the outbreak of WNS, the USFWS has coordinated with states, federal agencies, tribes, conservation organizations, and scientific institutions on how to manage the disease. Following the goals outlined in the White-nose Syndrome Response Plan, USFWS has provided $20 million in funding through grants for research and in response to the disease. Bat species affected by WNS include gray bat (Myotis grisescens), Indiana bat (M. sodalis), northern long-eared bat (M.

septentrionalis), eastern small-footed bat (M. leibii), big brown bat (Eptesicus fuscus), tricolored bat, and little brown bat (M. lucifugus). Due to the impacts of this disease on northern long-eared bat populations, attention on reducing other impacts and threats has become more crucial in hopes that bats emerging from WNS infected caves will have what they need to survive.

Wind turbine related mortality is another threat affecting tricolored bat populations. Bats migrating across the landscape at night strike wind turbines which leads to approximately 3,227 tricolored bat fatalities annually (Udell et al., 2022). As wind power generation increases in certain parts of the United States, this threat will continue to affect migrating bats including the tricolored bat.

While climate change is commonly recognized as a threat to bat species including the tricolored bat, the magnitude, direction, and seasonality of climate change is unknown making it difficult to assess how it will affect tricolored bat throughout its range (USFWS, 2021). Whether it is decoupling of predator-prey interactions, abrupt modifications to hibernation conditions, and/or the introduction to additional viruses, diseases, and/or pathogens, overall, it is believed that the effects of climate change are not positive for tricolored bat making it an additional threat at the population level (Jones and Rebelo, 2013).

Loss of habitat is also considered a threat to tricolored bats. Loss of non-winter roosting habitat can result in longer flight distances between roosting and foraging areas which could increase the risk to predation as well as overall increase in energy expenditure for tricolored bats. In addition, if tree clearing occurs during the pup rearing season, direct mortality to maternity colonies could occur (USFWS, 2021). In addition, in agriculturally dominated landscapes, tree clearing can have a disproportionately higher adverse impact to tricolored bat than a

8 comparable tree loss in a heavily forested area (USFWS, 2021). Winter habitat loss could include modification of cave openings/entrances and any influences that affect the microclimate conditions within cave ecosystems.

5.1.1.1 Tricolored Bat Status in the Area of Concern In October 2024, the USFWS established a voluntary environmental review process for the northern long-eared bat and tricolored bat that established various activity management zones.

In Georgia these three management zones are: Hibernating, Zone 1 Year-round Active, and Zone 2 Year-round Active. The HNP action area is within the Zone 1 Year-round Active range. Year-round Active Management Zone 1 entails potential hibernation in trees when the temperature drops below 40°F, therefore there are recommended tree-clearing restrictions during December 15 - February 15, as well as during the maternity season May 1 - July 15 (USFWS, 2024).

5.1.2 Red-cockaded woodpecker The red-cockaded woodpecker is threatened under the ESA and is under the jurisdiction of USFWS. The red-cockaded woodpecker is approximately 7 inches long with a wingspan of about 15 inches. The birds back is barred with black and white horizontal stripes, and a black cap and nape (the back of the neck) that encircle large white cheek patches (NC, 2023). Red-cockaded woodpeckers make their homes in mature pine forests. While other woodpeckers bore out cavities in dead trees where the wood is rotten and soft, the red-cockaded woodpecker is the only one which excavates cavities that are exclusively in living pine trees. The species prefers longleaf pines (Pinus palustris) but uses other species of southern pine. Cavities are excavated in mature pines generally more than 80 years old. The older pines favored by red-cockaded woodpeckers often suffer from a fungus called red heart disease, which attacks the center of the trunk, and causes the inner wood - the heartwood - to become soft. Cavity excavation takes 1 to 6 years. The aggregate of cavity trees is called a cluster and may include 1 to 20, or more, cavity trees on 3 to 60 acres. The average cluster is about 10 acres. Cavity trees that are being actively used have numerous small resin wells that exude sap (USFWS, 2023a).

The primary threat for these birds is habitat destruction. The overall number of older pines and the size of the forests have both decreased. The remaining forestland is highly fragmented, making it hard for new generations of birds to find suitable sites. Regular fires help maintain open forests the birds prefer; fire suppression has had a detrimental effect on the red-cockaded population (NC, 2023).

Red-cockaded woodpeckers occupy a patchy distribution in the states of Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Texas, and Virginia.

9 5.1.2.1 Red-cockaded Woodpecker Status in the Area of Concern According to USFWS, the current known range of the red-cockaded woodpecker overlaps with the action area (USFWS, 2023a). The species is known to occur in the Moody Forest WMA adjacent to HNP (Georgia Department of Natural Resources, personal communication, October 2025).

HNP participates in the Red-cockaded Woodpecker Safe Harbor Agreement with the GADNR, with a zero baseline. This effort coincides with the habitat management for the Gopher Tortoise Candidate Conservation Agreement (GTCCA).

5.1.3 Eastern indigo snake The eastern indigo snake is threatened under the ESA and is under the jurisdiction of USFWS.

The nonvenomous eastern indigo snake is the largest snake in North America, growing up to 9 feet long. Its iridescent blue-black scales glisten in the sunlight; a coral hue tints its chin, throat, and cheeks. The indigo snakes diet of animals is varied, but it prefers feeding on other snakes (USFWS, 2023b).

The eastern indigo snake prefers longleaf pine forest that once covered Florida, Georgia, Alabama, and Mississippi, where it shelters in gopher tortoise burrows to nest and breed.

Development and agriculture land use consumed 97 percent of the natural longleaf pine forests in the Southeast. In 1978, the USFWS listed the eastern indigo snake as threatened under the ESA. The ESA provided funding through grants to partners and states for land protection and conservation, monitoring and research, outreach and education, and a reintroduction program.

But the loss of habitat from development, pesticides, climate change, and disease still beleaguer the indigo snake. The invasive Burmese python spreads a lung parasite that is potentially deadly to them, and an intestinal parasite sickens the snake if it is otherwise stressed. Indigo snakes are frequently killed crossing roads, as they range over hundreds, and even thousands, of acres, foraging for food and looking for mates (USFWS, 2023b).

5.1.3.1 Eastern Indigo Snake Status in the Area of Concern According to the USFWS, the current known range of the eastern indigo snake overlaps with the action area (USFWS, 2023b). According to GDNR, there have been documented occurrences of eastern indigo snake within about three miles of HNP (Georgia Department of Natural Resources, personal communication, October 2025).

5.1.4 Southern hognose snake The southern hognose snake is a proposed threatened species under the ESA. This nonvenomous snake is generally short and stout, being the smallest member of its genus (Heterodon), attaining a length of less than 2 feet. It is also characterized by a sharply upturned

10 and keeled snout. The snakes dorsal pattern consists of a beige or tan ground color with three longitudinal rows of dark brown blotches outlined in black. A light orange to tan stripe runs down the center of its back. The southern hognose snake utilizes its unique snout to burrow through the sand to hunt toads which almost exclusively make up this species diet (USFWS, 2024b).

The southern hognose snake is endemic to the Coastal Plain of the Southeastern U.S., where this species is known to have occurred in parts of Alabama, Florida, Georgia, North Carolina, and South Carolina. It is believed to likely be extirpated in Alabama and Mississippi. Within this region, it is most frequently associated with xeric, well-drained sandy soils. These environments are typically dominated by longleaf pine and scrub oaks, such as turkey oak, with wiregrass a component of the groundcover (USFWS, 2024b). Factors thought to contribute to the disappearance or decline of this species are habitat loss, road mortality, invasive species (i.e.,

fire ants and feral hogs), climate change, pet trade, and disease (USFWS, 2024b).

5.1.4.1 Southern Hognose Snake Status in Area of Concern According to the USFWS, the current known range of the southern hognose snake overlaps with the action area, although Toombs and Appling counties do not have known records of occurrence of this secretive species (USFWS, 2024b). This species occupies upland habitat similar to that of the eastern indigo snake. Based on the documented occurrences of the eastern indigo snake approximately 3 miles from HNP as noted in Section 5.1.4.1, the southern hognose snake is also expected to occur within the vicinity of HNP.

5.1.5 Monarch Butterfly The monarch butterfly is a proposed threatened species under the ESA. Adult monarch butterflies are large and conspicuous, with bright orange wings surrounded by a black border and covered with black veins. The black border has a double row of white spots, present on the upper side of the wings. Adult monarchs feed on the nectar of many flowers during breeding and migration, but they only lay eggs on milkweed (Asclepias spp.) plants. For overwintering monarchs, habitat with a specific microclimate is needed for protection from the elements, as well as moderate temperatures to avoid freezing. Monarch butterflies require healthy and abundant milkweed plants for laying eggs on and as a food source for larvae or caterpillars. By consuming milkweed plants, monarchs obtain toxins, called cardenolides, that provide a defense against predators. Additionally, nectar from flowers is needed for adults throughout the breeding season, migration, and overwintering. Monarchs are native to North and South America but have since spread to many other locations where milkweed and suitable temperatures exist (USFWS, 2023k).

11 5.1.5.1 Monarch Status in the Area of Concern According to the USFWS, the current known range of the monarch butterfly extends across the contiguous U.S. and overlaps with the action area (USFWS, 2023c). In the southeast region of the U.S. including Georgia, monarch butterflies can be observed from April to May during their spring migration and from August to October during their fall migration (Xerces Society, 2018). Potential habitat for this species within the HNP action area is primarily associated with maintained transmission line easements that provide habitat for a variety of Asclepias species. These easements are periodically maintained through mowing.

5.2 Aquatic Species 5.2.1 Altamaha spinymussel The Altamaha spinymussel, an endemic to Georgias Altamaha River basin, is listed as endangered under the ESA and is managed under the jurisdiction of USFWS. The historical distribution for this species was restricted to the Coastal Plain portion of the Altamaha River and the lower portions of its three main tributaries, the Ohoopee, Ocmulgee, and Oconee Rivers.

The species has apparently been extirpated from the Oconee River and lower reaches of the Altamaha River and now survives only in the Ocmulgee and Upper Altamaha Rivers (USFWS, 2024a). It is thought the last live specimens in the Oconee River were observed in the mid-1960s (Johnson 1970). Generally, there has been a significant decrease in the population of this species combined with a reduction in distribution in the Altamaha River with most occurrences limited to the lower Ocmulgee River and upper reaches of the Altamaha River upstream of Highway 301, which crosses the river between Jesup and Ludowici, Georgia downriver of HNP.

In an updated species status analysis (USFWS 2024a), it was noted that no live specimens have been collected since 2011. Table 2 below provides the most current status summary of population units for this species (USFWS, 2024a).

Table 2. Status Summary of Population Units of the Altamaha Spinymussel Population Last Observation Current Resiliency Status Oconee River Historical; 1964 (60 years)

Presumed Extirpated Ohoopee River 2005 (20 years)

Low Ocmulgee/Altamaha Rivers 2011 (14 years)

Moderate Lower Altamaha River Historical; 1990s (25+ years)

Presumed Extirpated

12 Altamaha spinymussels are found in association with stable, coarse to fine grained sandy sediments of sandbars, sloughs, and mid-channel bars in areas of swiftly flowing water, although they sometimes occur in sloughs that form between an exposed sandbar and the bank.

Adults are not as sessile or sedentary as most freshwater mussels. They apparently move about their sandbar habitat but are often found buried 2 to 4 inches (in) below the sandbar surface.

The mussels large spines are presumably used to anchor it to the shifting sand of sandbars within swiftly flowing rivers.

Adults have a rhomboid to triangular shell that reach a maximum length of about 11 centimeters (cm) or 4.3 in and the shells have one to five straight or crooked spines that may reach lengths of 1.0 to 2.5 cm (0.39 to 0.98 in) in a single row roughly parallel to the posterior ridge. They burrow about 5 to 10 cm (2 to 4 in) into the substrate and pump water through their gills to obtain oxygen and food and rid themselves of waste products. They filter phytoplankton, zooplankton, suspended bacteria, other microorganisms, particulates, and dissolved organic matter from the water and in doing so can clarify the water in the stream or river.

Freshwater mussels can have long life spans but there have been no detailed studies regarding the life cycle of the Altamaha spinymussel. The USFWS (2024a) notes that the lifespan of the Altamaha spinymussel is unknown but other species in this genus are known to have a maximum age range of 14 to 57 years and based on this data it can be presumed that the expected timeframe to complete three generations for the Altamaha spinymussel is 42 years.

Reproduction and early life history have also not been thoroughly established for this species and much of its lifecycle is understood through studies of related species of the same genus.

Reproduction is thought to occur in spring. Males release sperm in the water column where it is then drawn in by females. Fertilization is internal, and females brood the larvae, which are called glochidia. Females release mature glochidia into the water column, perhaps in May or June. To survive, the glochidia must find and attach to specific host fish species. Currently the host species for the Altamaha spinymussel is unknown. After some period of attachment to the host(s), the immature mussels release and move to the bottom to begin a benthic existence, provided they find suitable habitat. The juvenile mussels on the bottom use the foot to extract and feed on bacteria, algae, and detritus in the sediment.

Threats to the species are various with a focus on non-point sources such as runoff from agricultural fields/operations, mining, industrial operations, and other disturbance activities.

This runoff can include soil, herbicides, nutrients, and other materials that lead to water quality impairment including substantial sediment deposition, an increase in suspended solids, and other factors that may affect the species ability to feed and reproduce (Goldsmith et al., 2021).

Other factors potentially affecting this species include drought, climate change, surface water demands, and land use practices/changes.

13 5.2.1.1 Altamaha spinymussel and Status in the Area of Concern The current known range of the Altamaha spinymussel overlaps with the action area per the most recent IPaC review. Established critical habitat for this species, which excludes the HNP action area, is designated within the Altamaha River. The habitat exclusion zone described in Section 2.0 begins immediately upstream of the US Highway 1 bridge and extends to approximately 1.1 miles downstream of HNP. No live specimens of this species have been observed since 2011 across its known range.

The Candidate Conservation Agreement (CCA) for Mollusks in the Altamaha River Basin, a joint effort of the USFWS, GDNR, and Georgia Power Company, established mussel monitoring locations at multiple locations in Georgia including the Altamaha River in the vicinity of HNP.

Sampling in 2024 by the Georgia Wildlife Resources Division (WRD) included four sites in the vicinity of HNP (WRD, 2024). The Altamaha spinymussel was not detected during sampling.

5.2.2 Atlantic sturgeon, South Atlantic DPS The Atlantic sturgeon is endangered under the ESA and managed under the jurisdiction of National Marine Fisheries Service (NMFS). Atlantic sturgeon can grow to approximately 16 feet long and can weigh up to 800 pounds. They are bluish-black or olive brown dorsally (on their back) with paler sides and a white belly. They have five major rows of dermal scutes, or bony plates, along the length of their body. Atlantic sturgeon are slow-growing and late-maturing and reach up to 60 years of age. Atlantic sturgeon live in rivers and coastal waters from Canada to Florida. Hatched in the freshwater of rivers, Atlantic sturgeon head out to sea as sub-adults, and return to their birthplace to spawn, or lay eggs, when they reach adulthood (NOAA, 2023).

The South Atlantic DPS of the Atlantic sturgeon was listed for Federal protection by the NMFS on February 6, 2012 (77 FR 5913). The Atlantic sturgeon is a member of the family Acipenseridae, which is a long-lived group of ancient anadromous and freshwater fishes.

Historically, the Atlantic sturgeon was present in 38 rivers in the U.S., ranging from St. Croix Island, Maine to the Saint Johns River in Florida. Historical spawning populations were confirmed in 35 of the rivers. Currently, Atlantic sturgeon populations are present in 35 rivers and spawning occurs in less than 20 rivers (ASSRT, 2007).

Although the life history of the Atlantic sturgeon has been studied intensely since the 1970s, important aspects of the life history are still unknown. Generally, the Atlantic sturgeon is anadromous and spends the majority of its life in marine waters, but it reproduces in freshwater habitats. Spawning is believed to occur in flowing water between the salt wedge and the fall line of large rivers. Spawning adults generally migrate upriver during the spring in southern rivers. A fall-spawning migration also may occur in some southern rivers (ASSRT, 2007). This appears to have first been reported by Smith (1985) who documented the occurrence of a fall run of fish that were in spawning condition in the south. Smith et al. (1984) note that the fall-

14 run fish are typically smaller than those caught in the spring. Collins et al. (2000) provided additional evidence of a fall spawning period in the Ashepoo, Combahee, and Edisto river basins in South Carolina. This finding was based on movements of two male fish that spent the summer in the lower Edisto River and then moved upriver to river mile (rm) 118 during October 1998. In addition, a female Atlantic sturgeon that had recently spawned was captured near rm 35 of the Edisto River in the fall during this study; however, no spawning sites were confirmed.

As discussed below in the status of the Atlantic sturgeon in the Altamaha River section, more recent studies conducted at the University of Georgia (UGA) have documented spawning movements of the Atlantic sturgeon within the Altamaha River.

Spawning habitat includes moderately flowing water in deep parts of large rivers. Eggs are highly adhesive and are deposited on bottom substrate, usually on hard surfaces such as cobble.

Hatching occurs within approximately 94 to 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> after egg deposition at temperatures of 20°C and 18°C, respectively. Embryos (age 1 to 8 days old) tend to seek cover and stay near the river bottom after hatching (Kynard and Horgan, 2002). When the yolk-sac larval stage is complete (after 8 to 12 days), the larvae move downstream over a 6-to 12-day period to rearing grounds. Larvae are demersal and stay near the bottom of the water column (ASSRT, 2007).

During the first half of their migration, movement is limited to the night; during the day, they use the bottom (e.g., a gravel matrix) as refugia. As the larvae develop further, migration occurs during both the day and the night (Kynard and Horgan, 2002). Juvenile sturgeon eventually arrive in estuarine waters, where they remain for months or years. Subadults and adults live in coastal waters and estuaries when not spawning, generally in shallow water (30 to 150 feet deep) near shore areas dominated by gravel and sand substrates. Atlantic sturgeons are benthic feeders and typically forage on benthic invertebrates such as crustaceans, worms, and mollusks.

The primary threats currently facing Atlantic sturgeon are entanglement in fishing gear, habitat degradation, habitat impediments (such as dams and other barriers), and vessel strikes (NOAA, 2023; 77 FR 5913).

5.2.2.1 Atlantic sturgeon, South Atlantic DPS and Status in Area of Concern The current known range of the Atlantic sturgeon (South Atlantic DPS) overlaps with the action area (NOAA, 2023). The Altamaha River is believed to support the largest population of this species in the southeast. The Warnell School of Forestry and Natural Resources at UGA has conducted various studies regarding the Atlantic sturgeon including multi-year telemetry studies within the Altamaha River. These studies have focused on both juvenile and adult Atlantic sturgeon.

A study by Ingram and Peterson (2016) focused on the movement of adult Atlantic sturgeon within the Altamaha River from 2011 to 2014. Telemetry data documented that Atlantic sturgeon are present within the Altamaha River. The study shows that spawning Atlantic

15 sturgeon within the Altamaha River adhered to one of two distinct patterns of upriver migration. These spawners exhibited either a spring two-step migration or a fall one-step migration. One-step individuals (62-64% of tracked spawners) began their upriver migration from coastal estuarine habitat to the tributary reaches of the Ocmulgee and Oconee Rivers (above their confluence at rm 129) in late August to early September. These individuals exhibited no staging or resting behavior during their upriver migration. In contrast, two-step individuals (36-38% of tracked spawners) began their upriver migration in the spring or early summer and exhibited a mid-river staging pattern between the head of tide and the confluence of the Ocmulgee and Oconee Rivers where the Altamaha River is formed. Following this summer holding pattern, these individuals migrated above the confluence in late August and early September. Individuals within both spawning groups remained near or above the confluence throughout the fall before returning downriver (below HNP) by late November to early January.

The data indicates that Atlantic sturgeon are within this reach of the river, either staged or in transit, beginning in late April-early May and continuing into late December-early January. The sturgeon exhibiting a two-step spawning pattern could potentially be holding in the vicinity of HNP during the summer (late April-early May to late August-early September). The majority of the spawning Atlantic sturgeon within the Altamaha River utilize a one-step upriver migration and do not hold in the vicinity of HNP. The data indicates that all spawning fish have moved back down river, away from HNP by early January.

A more recent study by Fox and Peterson (2019) focused on the movement of juvenile sturgeon.

Within the Altamaha River, telemetry studies were conducted between river mile (rm) 6.2 to 18.6, which is downstream (southeast) of the area of concern.

In summary, telemetry data has documented the presence of Atlantic sturgeon in the Altamaha River. HNP is located at approximately rm 112. Data indicates that Atlantic sturgeon are within this reach of the river beginning in August and continuing into late December to early January.

The sturgeon are not holding in the vicinity of HNP but are moving their way upstream to spawning grounds or back down river; data indicate that all spawning fish have moved back down river by early January. The Atlantic sturgeon spawning grounds in the Altamaha River are located upstream of HNP. Available capture data indicates that juvenile Atlantic sturgeon have moved downriver to the Altamaha sound by the end of July as the juveniles live below the head of tide during years 1 to 3 of their lifespan (Fox & Peterson 2019).

5.2.3 Shortnose sturgeon The shortnose sturgeon was listed as an endangered species on March 11, 1967, under the Endangered Species Preservation Act (SSRT, 2010).

Shortnose sturgeon can grow to approximately 4.5 feet long and weigh up to 60 pounds. They are yellowish-brown and generally have a black head, back, and sides. Their bellies are white to yellow. They have five major rows of scutes along the length of their body and a protruding

16 snout with four barbels (fleshy, whisker-like projections) (NOAA, 2023).

Like the Atlantic sturgeon, the shortnose sturgeon is also a member of the Acipenseridae family.

Historically, the shortnose sturgeon was found in larger freshwater rivers, estuaries, and the sea along the eastern coast of North America. Their occurrence is thought to have ranged from as far north as the St. Johns River, New Brunswick, Canada to as far south as the Indian River, Florida. Current population data indicates that the southern range for the species now only extends to the St. Johns River, Florida.

While the shortnose sturgeon and Atlantic sturgeon overlap in much of their range, the Atlantic sturgeon spends a larger portion of its life in the ocean. In riverine environments, utilization of habitat, food resources, and spawning ground appears to overlap between the two species; however, historic data as well as more recent studies conducted discussed below indicate that shortnose sturgeon generally spawn earlier than Atlantic sturgeon.

Previous studies documented 19 distinct populations of the shortnose sturgeon inhabiting Atlantic coast rivers; however, more recent studies and data analysis, including telemetry and genetic studies, have provided additional information supporting coastal migrations between adjacent rivers (SSRT, 2010). Most shortnose sturgeon populations have their greatest abundance in the estuary portion of their respective river (Weber 1996).

The shortnose sturgeon migrates upstream to freshwater habitats upgradient of the salt wedge for spawning. Following spawning, they return to the estuaries and spend much of their lives near the freshwater/saltwater interface. Fresh tidewaters and oligohaline areas serve as nurseries for shortnose sturgeon (Flournoy et al., 1992).

Spawning patterns appear to differ by region with shortnose sturgeon in northern rivers beginning to move upstream in the spring and southern river populations beginning to move upstream late winter into early spring. Studies by Buckley and Kynard (1985), have identified three migration patterns within Massachusetts rivers. The patterns include short one-step, long one-step, and short two-step. As the names indicate, the short one-step individuals migrate for a few weeks in spring prior to spawning. The long one-step individuals migrate in late winter/early spring before spawning and the short two-step individuals have a long fall migration leaving fish near spawning areas for overwintering followed by a short migration and spawning.

Shortnose sturgeon eggs are demersal and adhesive after fertilization, sinking quickly and adhering to sticks, stones, gravel, and rubble on the stream bottom. Studies indicate that the incubation period for fertilized eggs varies based on water temperature with the hatching period ranging from 8 days in water temperatures of 17°C (Buckley and Kynard, 1981) to 13 days in water temperatures ranging from 8°C to 12°C (Meehan, 1910). Within 8 to 12 days after hatching, larvae quickly develop morphological features such as fins that accommodate

17 movement associated with juveniles and adult sturgeon and that allow the larvae to utilize external food sources. With the ability to utilize food sources other than the yolk-sac, behavior patterns change such as the utilization of substrate for cover and foraging (SSRT, 2010). As the juveniles mature, they migrate downstream toward the salt wedge and estuaries.

A number of studies have been conducted on the young-of-year (YOY) juveniles in an effort to determine habitat utilization and overall movement. In general, these studies indicate that YOY have specific salinity tolerances and tend to remain in freshwater environments upstream of the salt wedge. They utilize intermediate to deep water habitats within freshwater systems and remain above the salt wedge for approximately one year. As their body size increases, there is a corresponding increase in salinity tolerance (SSRT, 2010). Studies by Flournoy et al. (1992) and Collins et al. (2002) on southern rivers indicates that one year old shortnose sturgeon begin to make seasonal migrations like adults.

The most significant threats to the species are dams that block access to spawning areas or lower parts of rivers, poor water quality, dredging, water withdrawals from rivers, and unintended catch in some commercial fisheries (NOAA, 2023).

5.2.3.1 Shortnose sturgeon and Status in Area of Concern The current known range of the shortnose sturgeon overlaps with the action area. Shortnose sturgeon were collected during source-water riverine sampling in the vicinity of HNP between 1972 and 1975. Subsequent studies have generated population estimates within the Altamaha River ranging from 400 to 6,320 individuals. Abundance studies (Bednarski et al., 2013) documented that the Altamaha River population is the largest south of the Delaware River.

Recently, the shortnose population within the Altamaha River is estimated at approximately 2,218 individuals consisting predominantly of adults (Ingram et al., 2020).

Historic studies within the Altamaha River have documented the presence of spawning adults, eggs, and juveniles within the river. Within the Altamaha River, capture data indicates that primary shortnose sturgeon habitat includes the lower 25 rm of the river, which is tidally influenced (Flournoy et al., 1992; Rogers and Weber, 1994). Deeper water within the main channel of the river near the salt wedge appears to be utilized by the shortnose sturgeon during the summer (Rogers and Weber, 1995).

Various studies indicate that multiple substrates including boulders and coarse sand are used for spawning with actual spawning locations varying based on yearly conditions within the river.

Previously, studies indicated that a single-step migration pattern was followed by shortnose sturgeon in the Altamaha River; however, some suggested a pre-spawn fall migration may also occur within the river (SSRT, 2010). Multiple studies over the prior 10 to 30 years indicate that spawning likely occurs from January to March when water temperatures reach approximately 10°C (Heidt and Gilbert, 1978; Rogers and Weber, 1995; and DeVries, 2006).

18 Ingram and Peterson (2018) conducted a three-year detailed telemetry study of the shortnose sturgeon within the Altamaha River. The study focused on the movement of adult shortnose sturgeon within the Altamaha River from 2011 to 2014. Telemetry data documented that shortnose sturgeon are present within the Altamaha River. HNP is located at approximately rm 112. Data indicates that shortnose sturgeon adults move upstream to spawn beginning in mid to late December and move back down river by April. The spawning shortnose sturgeon within the Altamaha River display a single-step migration with no resting or staging period. Spawning grounds are located upstream of HNP and generally includes the area near the confluence of the Ocmulgee and Oconee Rivers and the upper reaches of the Altamaha River. Juveniles begin to move downstream in March and tend to have moved down river shortly following the end of spawning in April.

6.0 Federally Designated Critical Habitat Critical habitat represents the habitat that contains the physical or biological features (PBFs) essential to the conservation of the listed species and that may require special management considerations or protection. The USFWS designated critical habitat in the Upper Altamaha River for the Altamaha spinymussel both above HNP (from the confluence of the Ocmulgee and Oconee Rivers downstream to the U.S. Route 1 crossing) and below HNP (from the western edge of the Moody Forest downstream to the confluence of the Altamaha and Ohoopee Rivers).

This section of critical habitat is referred to as Altamaha spinymussel critical habitat Unit 2. The Altamaha River portion of the action area is not within the Unit 2 designated critical habitat or any other designated critical habitat for the Altamaha spinymussel as shown on Figure 5.

In 2017, the NMFS designated critical habitat for all five DPSs of the Atlantic sturgeon (82 FR 39160). Critical habitat within the area of concern is associated with the South Atlantic DPS. In this final rule, the NMFS identified four PBFs that support successful sturgeon reproduction and recruitment (see Table 3). PBFs are those features that are essential to support the life-history needs of the species, including, but not limited to, water characteristics, soil type, geological features, sites, prey, vegetation, symbiotic species, or other features (50 CFR 424.02).

19 Table 3. Physical or Biological Features of South Atlantic DPS Atlantic Sturgeon Critical Habitat (82 FR 39160)

PBF Description PBF 1 Hard bottom substrate (e.g., rock, cobble, gravel, limestone, boulder, etc.) in low salinity waters ( i.e., 0.0-0.5 ppt range) for settlement of fertilized eggs and refuge, growth, and development of early life stages PBF 2 Aquatic habitat inclusive of waters with a gradual downstream gradient of 0.5 up to as high as 30 ppt and soft substrate (e.g., sand, mud) between the river mouths and spawning sites for juvenile foraging and physiological development PBF 3 Water of appropriate depth and absent physical barriers to passage (e.g., locks, dams, thermal plumes, turbidity, sound, reservoirs, gear, etc.) between the river mouth and spawning sites necessary to support:

(1) Unimpeded movement of adults to and from spawning sites; (2) seasonal and physiologically dependent movement of juvenile Atlantic sturgeon to appropriate salinity zones within the river estuary; and (3) staging, resting, or holding of subadults and spawning condition adults.

Water depths in main river channels must also be deep enough (at least 1.2 m) to ensure continuous flow in the main channel at all times when any sturgeon life stage would be in the river PBF 4 Water quality conditions, especially in the bottom meter of the water column, between the river mouths and spawning sites with temperature and oxygen values that support:

(1) Spawning; (2) annual and inter-annual adult, subadult, larval, and juvenile survival; and (3) larval, juvenile, and subadult growth, development, and recruitment.

Appropriate temperature and oxygen values will vary interdependently, and depending on salinity in a particular habitat. For example, 6.0 mg/L DO or greater likely supports juvenile rearing habitat, whereas DO less than 5.0 mg/L for longer than 30 days is less likely to support rearing when water temperature is greater than 25 °C. In temperatures greater than 26 °C, DO greater than 4.3 mg/L is needed to protect survival and growth. Temperatures of 13 to 26 °C likely support spawning habitat The HNP action area overlaps with South Atlantic Critical Habitat Unit 5 which includes the main stem Oconee River from Sinclair Dam downstream to the confluence with the Ocmulgee River, the main stem Ocmulgee River from Juliette Dam downstream to the confluence with the

20 Oconee River, and the main stem Altamaha River from the confluence of the Oconee River and Ocmulgee River downstream to rm 0.

7.0 Effects of Proposed Action This section describes the potential effects of the proposed action on the Altamaha spinymussel, shortnose sturgeon, and the Atlantic sturgeon. Potential effects to designated critical habitat for the Atlantic sturgeon and Altamaha spinymussel is also evaluated for the HNP action area. Potential stressors that these species could experience from the SLR are the same for all three of these species. In addition to these aquatic species, potential effects are also considered for the red-cockaded woodpecker, eastern indigo snake, monarch butterfly, and tricolored bat.

7.1 Aquatic Species Potential Effects 7.1.1 Dredging and Sediment Contamination SNC holds an individual dredging permit for the Plant Hatch intake structure, which was issued on May 2, 2022, and is valid for 10 years. The USACE conducted ESA consultation with the USFWS and NMFS as part of the dredging permit evaluation.

The dredging permit incorporates applicable project design criteria protective measures specific to the Atlantic and Shortnose sturgeon from the 2020 SARBO prepared by the NMFS. While these project design criteria are focused on the sturgeon species, they are also relatable to the Altamaha spinymussel.

SNC maintains an internal contractor coordination briefing to insure that USACE permit requirements are met and that U.S. Coast Guard navigation rules are followed while a third-party contractor performs dredging activities.

The GA EPD issued a CWA Section 401 Water Quality Certification on May 2, 2022, for HNP intake structure dredging activities consistent with USACE Permit No. SAS-1994-03873. The Section 401 certification requires implementation of BMPs for in-water use to prevent degradation of water quality downstream. More specifically, the BMPs must minimize TSS and sedimentation for work conducted within a state water or within delineated wetland boundaries.

Accordingly, it is concluded that dredging and sediment contamination may affect but is not likely to adversely affect the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel but would be insignificant because they would not be able to be meaningfully measured, detected, or evaluated.

21 7.1.2 Entrainment and Impingement Cooling water withdrawal from the Altamaha River has the potential to impact fishes, mussels, and other aquatic organisms through entrainment and impingement. Generally, species vulnerability to impingement and entrainment is due to a mix of life history, biological, and physical factors such as habitat preference, water column distribution, reproductive behavior, and waterbody hydraulics, and is not necessarily a function of abundance or species present in the source water. Small-sized juvenile life stages are more susceptible to entrainment due to shape characteristics and swimming ability. Studies have shown that a few species tend to dominate impingement and entrainment losses.

Based broadly in scientific literature, life stages of fish species most vulnerable to entrainment at the HNP intake may be expected to include fish eggs and larvae (from the source water drift) since they are very small and unable to swim out of water currents. The glochidia (larvae) of mussels are not expected to comprise a significant component of entrainment. Given the importance of proximity between mussels and intake hydraulic zones of influence, limited time and distance of viability, high rates of mortality, and differences in susceptibility between host generalists and specialists, entrainment of listed mussel glochidia should be considered a low risk impact pathway.

In addition to literature-based information sources, a substantial amount of information is known about species and life stages in the vicinity of HNP that are susceptible to entrainment and impingement based on results from intensive site studies. Entrainment studies were conducted at the HNP intake in 1974, 1975, 1976, 1979, and 1980. Impingement studies were also performed there in 1975, 1976, 1977, 1979, and 1980.

In the 1980 entrainment survey, two sampling stations were used to collect the diel entrainment samples. One station was located in front of the intake structure; the second station was located across the Altamaha River. Samples were collected using a Wildco No. 25 twin 0.5 m-diameter plankton net with a mesh size of 0.760 microns. Sample duration was determined by measuring the river velocity with a General Oceanics Digital Flowmeter, Model 2030 MKII, and with a calibrated curve, a time factor was obtained allowing for a filtering of approximately 500 cubic meters (m3) of water through the net. The volume of water filtered through the net was determined with the use of a permanently fixed General Oceanics, Model 2030 R2 flowmeter in the net. Samples were preserved in 10 percent formalin solution and taken to the Environmental Affairs Center in Decatur, Georgia, for identification. Physiochemical data were taken at the beginning of the day sample and at the end of the night sample. Dissolved oxygen (DO) concentration and air and water temperatures were measured with a Yellow Springs Instrument Company oxygen meter, Model 57. Specific conductance was measured with a Yellow Springs Instrument Company S-CT meter, Model 33, and pH was measured with an Orion Research Analyzer, Model 399A.

22 Densities for each fish taxa collected were calculated as follows: the total number of individuals in each taxa was divided by the volume of river water filtered during day and night sampling to obtain the densities for each sample; the estimated densities for each month were obtained by averaging the densities for all samples taken during the month; estimates of total numbers of fish eggs and fish in the vicinity of the plant were obtained by multiplying the average monthly densities by total monthly river discharge using United States Geological Survey data for the Altamaha River near Baxley. The percent of river discharge entrained was calculated using total monthly discharged numbers and the total volume of water pumped each month. The estimated number of each taxa entrained as calculated by multiplying densities by the number of individuals in the vicinity of the plant by the percent of river discharge entrained.

The hydrodynamic effects of the HNP river intake structure upon the Altamaha River were determined at river elevations 19.7 m (64.6 feet) estimated for 21.5 m (70.6 feet). Velocity profiles (at river elevation 19.7 m) were measured in seven 26 m sections of the river at 0.2, 0.6, and 0.8 of the depth in each section.

A total of 25 fish eggs and 442 fish (including juveniles and adults) were collected in the eight-month survey. Specimens were not collected in the February samples. Most specimens, including 24 eggs and 380 fish, were collected at night.

The family Cyprinidae were the most abundant with 128 fish, comprising 29 percent of the total number of fish collected. The next most abundant families were Castostomidae, with 101 fish (22.9 percent) and the Centrarchidae, with 78 fish (17.6 percent). The least abundant family was the Soleidae with one fish (0.2 percent). The family Clupeidae was represented by 48 fish (10.9 percent), of which American shad (Alosa sapidissima) comprised 10.4 percent (46 fish). Eleven American shad eggs were collected, equaling 44 percent of the total number of eggs collected.

For the 1980 impingement survey, one sampling station located in the intake structure was used to collect the impingement samples. Samples were collected by inserting a wire basket with a 3/8-inch mesh size into the screen backwash sluiceway. Each sample lasted approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with exception to the April and July surveys, which lasted approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Samples were preserved in 10 percent formalin solution and taken to the Environmental Affairs Center in Decatur, Georgia, to be identified, enumerated, weighed, and measured.

Most species collected in entrainment sampling at HNP during these studies were represented in Cyprinidae, Ictaluridae, and Centrarchidae. Those species represent some of the most popular recreational species in the region, including redbreast sunfish, largemouth bass, crappie, and channel catfish. Species in entrainment samples that represent common forage minnow species included silvery minnow and coastal shiner. Although a broad diversity of species that live in or seasonally utilize habitats in the vicinity of HNP, the rate of impingement is very low based on studies there. The entrainment estimates assume a uniform distribution of

23 fish eggs and larvae, while the cross-section measurements suggest that the greater densities would occur in the channel furthest from the intake.

Twenty-two species representing 10 families, plus three taxa represented by specimens that were unidentifiable to species, were impinged during the 5 years of study between 1975 and 1980. The numbers of species impinged each study year ranged from five to six species.

Hogchoker (Trinectes maculatus) was the most abundant and the only species collected consistently each year. The increased velocity at the bottom of the intake structure (caused by the intake pumps) may, to some degree, explain why the majority of the fish impinged were hogchoker, a bottom dweller. Low intake velocities and site location are probably the primary factors resulting in low numbers of impinged fish overall.

Only six species were impinged in HNP samples in the 1980 survey. Bowfin (Amia calva) and channel catfish (Ictalurus punctatus) were the largest specimens measuring 81.6 millimeters (mm) and 203 mm, respectively. The length range for all other impinged species ranged from 43 to 115 mm, indicating mostly juvenile life stages for those species. The impingement data for the 5 years indicate that impingement losses at HNP are extremely low and that the plant does not create a significant environmental effect.

Intake structures may have direct and indirect impacts on native freshwater mussels. CCA surveys for mollusks conducted by GA WRD in 2021 and 2023 detected 10 species of mussels including: Altamaha arcmussel (Alasmidonta arcula), Altamaha slabshell (Elliptio hopetonensis),

variable spike (Elliptio icterina), Altamaha lance (Elliptio shepardiana), Altamaha pocketbook (Lampsilis dolabraeformis), inflated floater (Pyganodon gibbosa), rayed pink fatmucket (Lampsilis splendida), eastern creekshell (Villosa delumbis), paper pondshell (Utterbackia imbecillis), and Georgia elephantear (Elliptio dariensis). The Altamaha arcmussel is listed as state threatened. The CCA survey conducted by GA WRD in the vicinity of HNP in 2024 detected 9 species of mussels, adding Carolina lance (Elliptio angustata) and eastern floater (Pyganodon cataracta), not seen in previous surveys, but finding no Altamaha arcmussels at the sample sites. Based on numerous impingement studies conducted throughout the U.S., mussels are most often absent from impingement collections and, when present, consist of low numbers of thinly shelled, common species.

HNP employs a closed-loop or closed-cycle recirculating cooling system which minimizes the amount of surface water that must be withdrawn from the Altamaha River for operations, which in turn reduces impingement and entrainment relative to once-through cooling systems.

The average approach velocity at the vertical traveling screen is 0.31 ft/s, which is generally slow enough for most fishes to escape this current, except for very small or larval fishes. HNP has the best technology available (BTA) required by Section 316(b) of the Clean Water Act (CWA), minimizing impact on aquatic life.

24 Based on decades of studies, the evidence overwhelmingly suggests that intakes do not generally reduce fish populations. As such, entrainment and impingement of listed mussel host species alone would not constitute a substantial risk to the fish species or the listed mussel.

Accordingly, entrainment and impingement may affect but is not likely to adversely affect the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel.

7.1.3 Thermal Effects HNP has two boiling water reactor units (Units 1 and 2) with a nominal rating of approximately 1,848 megawatts (MW). Both units use closed-cycle cooling via mechanical draft cooling towers.

The excess heat produced by HNP's two nuclear units is absorbed by cooling water flowing through the condensers and the service water system. Main condenser cooling is provided by mechanical draft cooling towers.

Cooling water discharge (cooling tower blowdown) from both units is returned to the Altamaha River at a common point (31.937870°, -82.340353°) on the west bank of the Altamaha River at Outfall 001 and 002, which are submerged structures (Figure 4). The point of discharge is approximately 1,260 feet down-river from the intake structure and approximately 4 feet below the surface when the river is at its lowest level.

An instream temperature study of the Altamaha River at HNP was conducted by Alabama Power Company (2024). The required methods and means utilized to perform the instream temperature study, summer and winter surveys, are specified in Part III.C.7 of NPDES Permit No.

GA0004120.

In the vicinity of HNP, a designated segment of the Altamaha River was monitored for both instream water temperature and the cooling water discharge (effluent) for two consecutive days during the winter period (October to March) and two consecutive days during the summer period (April to September). HNP maintained the temperature around the anticipated maximum effluent rate and heat load for the plant.

Water temperature in the river was measured at parallel transects that were spaced 100 feet apart and perpendicular to river flow. Transects began 100 feet upstream of Outfall 001/002 and continued to 1100 feet downstream of Outfall 001/002. A transect was also established at the extent of the thermal mixing zone (914 feet downstream of Outfall 001/002).

The study can be summarized with the following findings:

• Regardless of the season, Altamaha River instream water temperatures did not exceed the 5F delta water quality standard or the 90F maximum water quality standard.

• The observed thermal mixing zone for both seasons was within the 914 ft regulatory mixing zone boundary established by Georgia EPD in the NPDES permit. The larger of the two thermal plumes was observed during the winter and encompassed an area

25 approximately 250 ft wide and 700 ft downstream of the plant outfall.

• The smaller mixing zone identified during the study is likely attributable to the specific stream flows observed during the study periods and the corresponding differences in ambient river temperatures.

As referenced in Sections 5.2.2.1 and 5.2.3.1 above, telemetry data documents that shortnose and Atlantic sturgeon have been documented in the Altamaha River, including the reach within the HNP area of concern. The time of year in which they are present varies by species, life cycle stage (adult or juvenile), and spawning patterns. Generally, data indicates that either the shortnose or Atlantic sturgeon could be present within the Altamaha River area of concern from January to December of a given year.

Results of the winter temperature monitoring indicate that water temperatures upstream of the HNP outfall ranged from approximately 53.8°F to 57.8°F with variations due to water depth and position across the river channel. The maximum recorded water temperature downstream of the outfall was 57.8°F, which was also the maximum water temperature recorded upstream of the outfall. Compared across water depths and channel location, the maximum temperature represented an approximate 1.4°F change from the mean ambient temperature at the upstream sampling transect.

Results of the summer temperature monitoring, indicate that water temperatures upstream of the HNP outfall ranged from approximately 83.6 °F to 87.9°F with variations due to water depth and position across the river channel. The maximum recorded water temperature downstream of the outfall was 87.9°F, which was also the maximum water temperature recorded upstream of the outfall. Compared across water depths and channel location, the maximum temperature represented an approximate 1°F change from the mean ambient temperature at the upstream sampling transect.

In-situ temperature monitoring indicates that during both winter and summer sampling, the maximum observed water temperature downstream of the outfall is the same as the maximum observed temperature upstream (reference temperature) of the outfall. Results indicate the range of naturally varying stream flow and ambient water temperatures as similar to mixing zone temperature range. When considering the mean temperatures measured among different depth strata and channel locations (1.4°F in winter and 1°F in summer) throughout the study area, mixing zone temperature complied with applicable water temperature criteria and was the same as maximum temperature measured upstream of the outfall and therefore likely negligible in effect. The maximum area of thermal plume occurrence was observed in winter and was detectable in an area approximately 250 ft wide (estimated ~47 percent of total river width) located on the south side of the study area. Maximum river depth in areas beyond the temperature plume ranged to 8 ft in the summer survey and to 15 ft deep in the winter survey.

26 When considering the comparable mixing zone and ambient temperatures throughout the study area depth profile and relatively small area of plume, mixing zone temperature is not likely to affect aquatic biota and a zone of fish passage is maintained.

Accordingly, it is concluded that thermal effects may affect, but are not likely to adversely affect the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel and would be insignificant because effects would not be able to be meaningfully measured, detected, or evaluated.

7.1.4 Habitat Fragmentation Fragmentation of habitat in rivers can substantially reduce biodiversity and alter ecosystem function (Doi, 2009). In small populations, habitat fragmentation can increase the vulnerability species to disease, human-caused disturbance, habitat modification, and demographic accidents and can lead to population declines, abnormal population structure, and eventual extinction (Dodd, 1990).

The USFWS (2011) explained that the exclusion of critical habitat designation in the stretch of river that includes HNP is because that reach does not include some primary constituent elements (PCEs) of habitat necessary to support the species. The USFWS (2011) identifies two reasons that the stretch does not include PCEs necessary for the Altamaha spinymussel:

(1) Dredging for intake pipes at Plant Hatch, which destabilizes the river channel and banks, sandbar, slough, and mid-channel-island habitats and disrupts the movement of coarse-to-fine sand substrates with low to moderate amounts of fine sediment; and (2) Thermal discharges from Plant Hatch that reduce water quality.

These effects could fragment the habitat of Altamaha spinymussels by diminishing the distribution of larvae attached to fish hosts. Subsequent thermal studies as discussed in Section 7.1.3 document that thermal effects associated with the cooling water outfall at HNP are insignificant.

NRC staff previously examined these effects in association with the July 13, 2013, HNP biological assessment for the Altamaha spinymussel and found them insignificant or discountable. No new information is available to alter this assessment.

Telemetry studies for both the shortnose sturgeon and Atlantic sturgeon document that these species migrate upstream and downstream of the HNP aquatic ESA action area and their movements have not been impeded by long-term, ongoing actions at HNP that are associated with the proposed action.

Accordingly, it is concluded that habitat fragmentation may affect but is not likely to adversely

27 affect the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel would be insignificant because they would not be able to be meaningfully measured, detected, or evaluated.

7.1.5 Trophic Interactions SNC (2012) states that the hydraulic entrainment would be about 11 percent of the river flow passing the plant under minimum flow conditions without a license amendment to revise the minimum water level for the plant service water system and ultimate heat sink from 60.7 feet to 60.5 feet mean seal level. With the license amendment, entertainment is approximately 11.5 percent of river flow passing the plant under minimum flow conditions. Along with the water, potential food of aquatic listed species would also be entrained and removed from the river under those conditions. NRC completed an Environmental Assessment and issued a Finding of No Significant Impact for the above mentioned license amendment (NRC, 2014), which concluded that the proposed action would have no significant effect on the quality of the human environment, and have no significant impacts on surface water or groundwater resources, no significant effects on aquatic resources, and no adverse effects on terrestrial species or habitats. Also, the action is not likely to adversely affect any endangered species or affect critical habitat.

Adult Altamaha spinymussels filter phytoplankton, zooplankton, suspended bacteria, other microorganisms, particulates, and dissolved organic matter from the water, although which of these they use for nutrition is not presently clear. Assuming the entrainment rate of these potential foods equals the hydraulic entrainment rate, and, assuming worst case entrainment rate (minimum river flow and plant withdrawal with the license amendment), about 11.5 percent of these potential food sources would be removed. Smaller phytoplankton and suspended bacteria populations would recover quickly. The USFWS did not identify food as a limiting resource for the adult mussels, which are most likely to be limited by other adverse habitat modifications.

Therefore, the effect of entrainment on food of adult mussels is insignificant. The juvenile mussels on the bottom use the foot to extract and feed on bacteria, algae, and detritus in the sediment.

These benthic food sources would not be adversely affected by upstream entrainment, so the effect of entrainment of potential food on juvenile mussels is also insignificant.

Both the shortnose sturgeon and Atlantic sturgeon are primarily bottom feeders. Typical food sources include invertebrates, mollusks, worms, crustaceans, insect larvae, and some vegetation. Data indicate that impingement losses at HNP are extremely low and should have an discountable effect on trophic factors for the listed sturgeon species.

28 Accordingly, it is concluded that habitat trophic interactions may affect but are not likely to adversely affect the Atlantic sturgeon, shortnose sturgeon, and Altamaha spinymussel and would be discountable and/or insignificant.

7.2 Terrestrial Species Potential Effects No SLR-related, ground-disturbing activities or changes in operational practices have been identified that would involve disturbing terrestrial habitat. Any ongoing plant operational and maintenance activities during the SLR (e.g., repair of existing buildings, roadways, parking lots, piping, fencing and security-related structures) would likely be confined to previously disturbed areas of the site and are expected to have minimal impact on terrestrial resources.

Via letter dated August 8, 2024, in association with early coordination for the SLR, the USFWS noted that the Service does not anticipate that project operations or relicensing will impact terrestrial species (Eastern Indigo Snake, Red-cockaded woodpecker, Whooping Crane, or Monarch Butterfly) or the Pondberry. The updated IPaC that was generated on July 7, 2025 and December 4, 2025, did not identify pondberry (Lindera melissifolia) or whooping crane as a federally listed species of potential concern within the HNP ESA action area. The updated IPaC did add tricolored bat and southern hognose snake, which were not addressed in the August 8, 2024, correspondence from USFWS. Refer to Appendix A for the most recent IPaC list.

These on-going operations may affect but are not likely to adversely affect the species listed in the USFWS correspondence. The tricolored bat would also not be affected by direct SLR operations; however, indirectly the species could be affected by general land use practices and is discussed below. Accordingly, it is concluded that forestry management effects may affect but are not likely to adversely affect the tricolored bat.

7.2.1 Forestry Management As part of ongoing land management including implementing the GTCCA, SNC conducts forestry practices including thinning and burning. Forestry management practices are not within the scope of the SLR and will be conducted independent of the proposed action. This action is being documented within the biological assessment as it occurs within the overall HNP property. The tricolored bat utilizes a variety of habitats including planted pine, mixed pine hardwood, and other contiguous wooded areas that provide both foraging and roosting habitat. WNS and not loss of habitat has been documented as the largest potential threat to this species; however, on October 15, 2024, the USFWS implemented a voluntary review process for development projects potentially affecting the northern long-eared bat and the tricolored bat. The HNP ESA action area is located within the Zone 1 Year-round zone for the tricolored bat. The USFWS has developed recommended voluntary restrictions on clearing bat habitat from May 15 to July 31 (non-volant pup season for tricolored bat) and December 15 to February 15 (winter torpor) for this zone.

29 Within forestry management areas, efforts will be made to follow these guidelines but factors such as weather, contractor availability, and others could require tree clearing during these periods. Accordingly, it is concluded that forestry management effects on the tricolored bat may affect but are not likely to adversely affect this species.

The GTCCA forestry management practices generally are beneficial to the eastern indigo snake, southern hognose snake, and red-cockaded woodpecker as they create and maintain habitat diversity and development that is specific to these species. These beneficial outcomes may affect but are not likely to adversely affect the eastern indigo snake and red-cockaded woodpecker.

7.2.2 Infrastructure Maintenance Multiple transmission lines operated and maintained by GPC are located within the ESA action area. Figure 2.2-2 in Section 2.2.6 of the ER denotes the location of HNP in-scope transmission lines. Those transmission lines are predominantly located within existing developed areas including switchyards and paved areas associated with Units 1 and 2. Other than an isolated approximately 190 foot long existing mowed and maintained area which is surrounded by developed areas, the in-scope transmission lines span man-made structures. Management of the in-scope transmission lines will continue to maintain the small vegetated area through mowing and or other practices as required. Due to its maintained condition and absence of adjacent habitat, the vegetated area provides low-quality potential habitat for the monarch butterfly. No trees are located within this area.

Accordingly, it is concluded that infrastructure maintenance effects on the tricolored bat would be insignificant because they would not be able to be meaningfully measured, detected, or evaluated.

Maintaining the isolated vegetated area associated with the in-scope transmission lines may beneficial to the monarch butterfly by providing prairie-like habitat and may affect but is not likely to adversely affect this species.

7.2.3 Behavioral Changes The potential to cause behavioral changes or other effects for terrestrial listed species of potential occurrence has been evaluated. Example potential activities/actions that could affect these species are noise generated by HNP operations, increased potential for vehicle collisions, and general changes in behavior.

Existing typical operation noise levels should not change as a result of the HNP SLR. The eastern indigo snake, southern hognose snake, and adult monarch butterflies cannot hear sound but can sense vibrations. Section 4.2.1 of the ER notes that no ground-disturbing activities that have the potential to increase noise levels at the HNP site are anticipated during the proposed SPEO (subsequent period of extend operation). As such, elevated vibration and/or

30 noise levels that would be of particular concern, including disruption of wildlife behavioral patterns, is not expected.

Bat species, including the tricolored bat are sensitive to noise as well as changes in light (Stone, et al., 2015). Section 4.2.4.7 of the ER addresses potential behavioral changes for the tricolored bat including noise and notes that No construction, ground-disturbing activities, or license-related refurbishment activities have been identified or proposed at the HNP site during the SPEO. Any bat species, if present on the HNP site, has likely already acclimated to the noise, vibration, and general human disturbances associated with site maintenance, infrastructure repairs, and other site activities. Moreover, the undisturbed, forested areas surrounding the structures likely provide more suitable habitat; hence, it is unlikely that tricolored bats would establish a colony in the man-made structures at HNP. As such, behavioral changes from refurbishment and/or construction activities to tricolored bats during the SPEO are unlikely.

The nearest known population of red-cockaded woodpeckers is located approximately 1 mile southeast of the HNP operational area (Georgia Department of Natural Resources, personal communication, October 2025). At that distance and in consideration that no construction, ground-disturbing activities, or license related refurbishment activities have been identified or proposed on the HNP site, there should be no measurable changes in noise for red-cockaded woodpeckers associated with HNP operations.

The SLR does include lighting modernization. These updates would likely be noticeable from the Altamaha River and other areas surrounding the HNP action area ;however, the changes would not alter the characteristics of the existing plant lighting and behavioral changes as a result of modernization efforts are unlikely to induce behavioral changes in the tricolored bat.

No new road construction is associated with the HNP and posted speed limits within property will remain unchanged in association with the SLR. As such, the potential for vehicle collisions with wildlife should not change from existing conditions.

Accordingly, it is concluded that behavior change effects may affect but is not likely to adversely affect the tricolored bat, red-cockaded woodpecker, eastern indigo snake, southern hognose snake, and monarch butterfly. In addition to the analysis above, a Determination Key (DKey) was completed for the tricolored bat using the IPaC regulatory review tool. A DKey is not currently available on IPaC for any of the other species considered in this biological assessment.

The DKey results, which are provided in Appendix A, determined that the overall action may affect but is not likely to adversely affect the tricolored bat.

7.3 Critical Habitat Potential Effects

31 Critical habitat for the Altamaha spinymussel is located 0.4-mile upstream and 0.75-mile downstream of the ESA aquatic action area. No project actions are proposed within the critical habitat for this species. Potential downstream effects include thermal, habitat fragmentation, trophic interactions, entrainment and impingement, and dredging and sediment contamination.

Each of these is evaluated above and individually or in aggregate, these effects are insignificant and will have no adverse effect on critical habitat for the Altamaha spinymussel.

Critical habitat for the South Atlantic DPS of the Atlantic sturgeon overlaps with the aquatic ESA action area for HNP. The critical habitat designation for this species identified four PBFs (see Table 3) that are essential to support the life-history needs of the species.

PBF 1 is associated with a hard bottom substrate and other factors. A Tier I analysis conducted within the dredging area indicates the majority of the substrate is sand in the ESA action area. PBF 2 is associated with suitable soft substrates between river mouths and spawning sites. The reach of the Altamaha River within the ESA action area appears to be predominantly sand and 40+ years of dredging at HNP has not altered this substrate. PBF 3 is associated with maintaining appropriate water depths and the absence of physical passage barriers. HNP actions do not decrease the water depth within the river and prior to subsequent sediment redeposition in the vicinity of the intake structure, actually deepen the river. Temperature studies in both the summer and winter document that water temperature changes below the HNP outfall do not exceed observed upstream (above the outfall) maximum water temperatures and the temperature change below the outfall in comparison to mean conditions above the outfall does not exceed 1.4°F, which is minimal and is unlikely to alter sturgeon movements. No passage barriers are presented by the proposed action as evidenced by prior telemetry studies. PBF 4 is related to water quality conditions including temperature. Temperature studies conducted in 2024 document that HNP is operating within permit requirements and associated effects are insignificant.

The proposed action will have no effect on critical habitat PBFs 1 and 2 for the Atlantic sturgeon. The proposed action may affect but is not likely adversely affect critical habitat PBFs 3 and 4 for the Atlantic sturgeon but would be insignificant. Therefore, the overall effect to Atlantic sturgeon critical habitat by HNP activities would be may affect but are not likely to adversely affect Atlantic sturgeon critical habitat. Refer to Tables 4 and 5 below for a summary of potential effects on federal listed species and critical habitat.

32 Table 4. Effect Determinations for Federally Listed Species Under U.S. Fish and Wildlife Service Jurisdiction for HNP License Renewal Species or Critical Habitat Federal Status (a)

Summary of Effects ESA Effect Determination (b) tricolored bat Perimyotis subflavus PE Potential temporary loss of foraging habitat resulting from forestry management practices NLAA red-cockaded woodpecker Picoides borealis T

Species not found in Action Area. Forestry management under GTCCA likely to improve potential habitat with Action Area NLAA eastern indigo snake Drymarchon couperi T

Species not found in Action Area. Forestry management under GTCCA likely to improve potential habitat with Action Area NLAA southern hognose snake Heterodon simus PT Species not found in Action Area. Forestry management under GTCCA likely to improve potential habitat with Action Area NLAA monarch butterfly Danaus plexippus PT Species not found in Action Area NLAA Altamaha spinymussel Elliptio spinosa E

Species not found in Action Area NLAA Altamaha spinymussel critical habitat Unit 2 Critical Habitat is excluded from the HNP ESA Action Area Critical habitat not found in Action Area NE (a)

(b)

Indicates protection status under the ESA. E = federal endangered; T = federal threatened; PE = federal proposed endangered; and PT = federal proposed threatened.

NRC makes effect determinations for federally listed species in accordance with the language and definitions specified in the USFWS and NMFS Endangered Species Consultation Handbook (USFWS and NMFS 1998). NE = no effect and NLAA = may affect but is not likely to adversely affect.

33 Table 5. Effect Determination for Federally Listed Species Under National Marine Fisheries Service Jurisdiction for HNP License Renewal Species or Critical Habitat Federal Status (a)

Summary of Effects ESA Effect Determination (b)

Atlantic sturgeon, South Atlantic DPS Acipenser oxyrinchus E

Intake structure maintenance dredging and intake/discharge of cooling water pose insignificant effects NLAA Atlantic sturgeon critical habitat ESA action area overlaps South Atlantic DPS critical habitat Unit 4 critical habitat within Action Area NLAA shortnose sturgeon Acipenser brevirostrum E

Intake structure maintenance dredging and intake/discharge of cooling water pose insignificant effects NLAA (a)

(b)

Indicates protection status under the ESA. E = federal endangered; T = federal threatened; PE = federal proposed endangered; and PT = federal proposed threatened.

NRC makes effect determinations for federally listed species in accordance with the language and definitions specified in the USFWS and NMFS Endangered Species Consultation Handbook (USFWS and NMFS, 1998). NE = no effect and NLAA = may affect but is not likely to adversely affect.

8.0 Mitigation Strategies and Conservation Measures SNC has adopted and implemented multiple mitigation strategies intended to avoid and minimize potential effects to federal listed species. Among these are:

• Adoption of SARBO design criteria in association with ongoing maintenance dredging.

• HNP participates in the Red-cockaded Woodpecker Safe Harbor Agreement with the GA DNR that prescribes habitat management activities suitable for this species. This effort coincides with the habitat management for the GTCCA. With this effort, suitable habitat management may result in the expansion of the Moody Forest population onto HNP land.

• Conservation efforts for the eastern indigo snake coincide with the habitat management for the GTCCA. The GTCCA was initially developed in December 2008; Georgia Power Company (GPC) became a signatory in 2018. The agreement requires an annual

34 assessment report from GPC to document conservation activities occurring within the gopher tortoises non-federally listed range. The assessment report includes activities completed on an annual basis for the period covering October 1-September 30.

Management activities that are undertaken at HNP to enhance gopher tortoise habitat include prescribed burning, mid-story removal, pine stand thinning, and longleaf pine planting to benefit nesting success. Further, meso-mammal predators are removed from some gopher tortoise habitat.

• HNP maintains a Biodiversity Initiatives Plan that includes timber and wildlife management strategies. Further, HNP is specifically being managed for conservation of the longleaf pine system, which includes planting longleaf pine seedlings in appropriate areas. Longleaf pine management is being conducted by The Nature Conservancy and the GA DNR in Moody Forest, which is adjacent to the HNP site.

9.0 Cumulative Effects Cumulative effects are those effects of future State or private activities, not involving Federal activities, that are reasonably certain to occur within the action area of the Federal action subject to consultation (50 CFR 402.02). When formulating biological opinions during formal Section 7 consultation, the Services consider cumulative effects when determining the likelihood of jeopardy or adverse modification. During informal consultation, A Federal Agency need only consider cumulative effects under the ESA in the biological assessment if listed species would be adversely affected by the proposed action and formal Section 7 consultation is necessary. Because it was concluded earlier in this biological assessment that the proposed license renewal is not likely to adversely affect the species listed in Table 1, consideration of cumulative effects is not required.

10.0 Conclusions Based on SNCs analysis as the NFR and input by NRC staff presented in this biological assessment, SNC makes the following conclusions.

Aquatic Species Atlantic and Shortnose Sturgeons The proposed action may affect but is not likely to adversely affect the Atlantic sturgeon and shortnose sturgeon. Studies including telemetry tracking of Atlantic sturgeons, temperature and entrainment studies within the ESA aquatic action area, implementation of permit conditions developed specifically to protect these species through prior USACE and NMFS coordination, and analysis associated with 40+ years of operations at HNP (with no proposed

35 changes associated with the SLR) support that potential effects associated with the proposed action would be insignificant or discountable.

Altamaha Spinymussel The proposed action may affect but is not likely to adversely affect the Altamaha spinymussel.

Analysis determined that the potential effects of dredging and sediment contamination, entrainment and impingement of host species, trophic interactions, thermal changes, and habitat fragmentation are insignificant or discountable Designated Critical Habitat The proposed action would not result in habitat alterations that may affect PBFs `1 through 4 of the critical habitat of the Atlantic sturgeon in the South Atlantic DPS. Though no alterations to critical habitat are proposed, HNP activities including maintenance dredging, which will occur within the critical habitat; therefore, HNP activities may affect but are not likely to adversely affect Atlantic sturgeon critical habitat. All effects to the critical habitat of the Atlantic sturgeon resulting from SLR are discountable and insignificant.

The proposed action is not located within Unit 2 of the critical habitat for the Altamaha spinymussel and would have no effect on the designated critical habitat for this species. The proposed action would not alter any physical or biological features of or reduce the conservation value of the critical habitat; therefore, no effect would occur to critical habitat for this species.

Terrestrial Species Non-bat Species The proposed action may affect but is not likely to adversely affect the eastern indigo snake, southern hognose snake, red-cockaded woodpecker, or monarch butterfly. Early coordination for the SLR was conducted with the USFWS and via letter dated August 8, 2024, the USFWS noted that the Service does not anticipate that project operations or relicensing will impact terrestrial species (Eastern Indigo Snake, Red-cockaded woodpecker, Whooping Crane, or Monarch Butterfly) or the Pondberry. The southern hognose snake was not addressed in the referenced USFWS correspondence as this species was not proposed for listing at that time.

Coordination with the USFWS, the implementation of management practices established in the GTCCA which is beneficial to the eastern indigo snake, southern hognose snake, and red-cockaded woodpecker, and that the proposed action includes no changes in terrestrial operations supports the may affect but not likely to adversely affect determinations for these species.

Ongoing long-term maintenance of a small, isolated approximatley 190 linear foot reach of in-scope transmission line easement and other out-of-scope transmission line easements within

36 the HNP action area are beneficial to the monarch butterfly in that potential habitat for Asclepias species, which are critical for the monarch butterfly lifecycle, is maintained. This beneficial outcome may affect but is not likely to adversely affect the monarch butterfly. All potential effects to the species listed in the USFWS correspondence and associated with the proposed action would be insignificant, discountable, or beneficial.

Tricolored Bat The proposed action may affect but is not likely to adversely affect the tricolored bat, a proposed endangered species. Forestry management practices within the ESA terrestrial action area would occur independently of the proposed action and include thinning and burning of pine dominated areas to promote habitat improvements for the gopher tortoise and other species including the red-cockaded woodpecker, southern hognose snake, and eastern indigo snake. Efforts will be made to implement voluntary recommended tricolored bat Zone 1 Year-round active clearing restrictions during pupping and torpor periods. All other potential effects associated with the proposed action would be insignificant or discountable.

11.0 Literature Cited Alabama Power Company. 2024. Edwin I. Hatch Nuclear Plant Baxley, Georgia Instream Temperature Study. Report to Southern Nuclear Operating Company.

Atlantic Sturgeon Status Review Team. 2007. Status Review of Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus). Report to National Marine Fisheries, Northeast Regional Office.

February 23, 2007. 174 pp.

Barbour, R.W. and W.H. Davis. 1969. Bats of America. The University Press of Kentucky, Lexington, Kentucky.

Bednaski, M.S., and D.L. Peterson. 2013. Abundance and size structure of shortnose sturgeon Acipenser brevirostrum in the Altamaha River, Georgia. Transactions of the American Fisheries Society. 142:1444-1452.

Buckley, J., and B. Kynard. 1981. Spawning and rearing of shortnose sturgeon from the Connecticut River. Progressive Fish Culturist 43:74-76.

Buckley, J., and B. Kynard. 1985. Yearly movements of shortnose sturgeon in the Connecticut River. Transactions of the American Fisheries Society 114:813-820.

Cheng, T.L, Reichard, J.D., Coleman, J.T., Weller, T.J., Thogmartin, W.E., Reichart, B.E., and Frick, W.F. 2021. The scope and severity of white-nose syndrome on hibernating bats in North America. Conservation Biology, 35(5), 1586-1597.

Collins, M.R., T.I.J. Smith, W.C. Post, and O. Pashuk. 2000. Habitat utilization and biological

37 characteristics of adult shortnose sturgeon in two South Carolina rivers. Transactions of the American Fisheries Society 129:982-988.

Collins, M.R., W.C. Post, D.C. Russ, and T.I.J. Smith. 2002. Habitat use and movements of juvenile shortnose sturgeon in the Savannah River, Georgia-South Carolina. Transactions of the American Fisheries Society 131:975-979.

DeVries, R.J. 2006. Population dynamics, movements, and spawning habitat of the shortnose sturgeon, Acipenser brevirostrum, in the Altamaha River system, Georgia. M.S. Thesis, University of Georgia, Athens, Georgia. 103 pp.

Dodd, C.K., Jr. 1990. Effects of Habitat Fragmentation on a Stream-dwelling Species, the Flattened Muck Turtle Sternotherus depressus. Biological conservations. 54(1):33-45.

Doi, H. 2009. Spatial Patterns of Autochthonous and Allochthonous Resources in Aquatic food Webs. Population Ecology. 50:57-64.

Flournoy, P.H., S.G. Rogers, and P.S. Crawford. 1992. Restoration of shortnose sturgeon in the Altamaha River, Georgia. Final Report to the U.S. Fish and Wildlife Service, Atlanta, Georgia.

Fox, A.G., and D.L. Peterson. 2019. Movement and out-migration of juvenile Atlantic Sturgeon in Georgia, USA. Transactions of the American Fisheries Society, 148:952-962.

Georgia Wildlife Resources Division. 2024. Candidate Conservation Agreement (CCA) for Mollusks of the Altamaha River Basin, Georgia 2024 Summary of Work.

Goldsmith, A. M., F.H. Jaber, H. Ahmari, and C.R. Randklev. 2021. Clearing up cloudy waters: a review of sediment impacts to unionid freshwater mussels. Environmental Reviews 29(1):100-108.

Harvey, M. J., J. S. Altenbach, T. L. Best. 1999. Bats of the United States. Arkansas Game and Fish Commission and in cooperation with Ashville Field Office, USFWS.

Harvey, M. J., J. S. Altenbach, T. L. Best. 2011. Bats of the United States and Canada. The John Hopkins University Press. 174 p.

Heidt, A.R., and R.J. Gilbert. 1978. The shortnose sturgeon in the Altamaha River drainage, Georgia. Pages 54-60 in R.R. Odum and L. Landers, editors. Proceedings of the rare and endangered wildlife symposium. Georgia Department of Natural Resources, Game and Fish Division, Technical Bulletin WL 4, Athens, Georgia.

Ingram, E.C., and D.L. Peterson. 2016. Annual Spawning Migrations of Adult Atlantic Sturgeon in the Altamaha River, Georgia. Marine and Coastal Fisheries: Dynamics, Management, and Ecosystem Science 8:595-606.

38 Ingram, E.C., D.L. Peterson, and A.G. Fox. 2020. Abundance of Endangered Shortnose Sturgeon (Acipenser brevirostrum) in the Altamaha River, Georgia. Fishery Bulletin, 118: 198-204.

Johnson, R.I. 1970a. The systematics and zoogeography of the Unionidae (Mollusca: Bivalvia) of the southern Atlantic slope region. Bulletin of the Museum of Comparative Zoology, Harvard University 140(6):263-449.

Kynard, B. and M. Horgan. 2002. Ontogenetic behavior and migration of Atlantic sturgeon, Acipenser oxyrinchus oxyrinchus, and shortnose sturgeon, A. brevirostrum, with notes on social behavior. Environmental Biology of Fishes 63:137-150.

LaVal, R., and M.L. LaVal. 1980. Ecological studies and management of Missouri bats, with emphasis on cave-dwelling species. Terrestrial Report 8. Missouri Department of Conservation, Jefferson City, USA.

Logan, Dennis. July 2013. Biological Assessment for Altamaha Spinymussel (Elliptic spinosa)

Edwin I. Hatch Nuclear Plant, Units 1 and 2, Appling County, Georgia. U.S. Nuclear Regulatory Commission, Rockville, Maryland.

Meehan, W.E. 1910. Experiments in sturgeon culture. Transactions of the American Fisheries Society 39:85-91.

National White-nose Syndrome Response Team. <https://www.whitenosesyndrome.org/>

(accessed August 6, 2025).

NC 2023. (The Nature Conservancy). Red-cockaded woodpecker. Retrieved from

<https://www.nature.org/en-us/get-involved/how-to-help/animals-we-protect/red-cockadedwoodpecker/#:~:text=The%20red%2Dcockaded%20woodpecker%20 has%20been%20on%20the%20endangered%20species,the%20forests%20have%20 both%20decreased>

Newman, B.A. 2020. Winter torpor and roosting ecology of tri-colored bats (Perimyotis subflavus) in trees and bridges 2009. Roosting and Foraging Ecology of Forest Bats in the Southern Appalachian Mountains. A Dissertation, Wildlife and Fisheries Biology Graduate School Clemson University.

NOAA. 2020. (National Oceanic and Atmospheric Administration). South Atlantic Regional Biological Opinion for Dredging and Material Placement Activities in the Southeast United States. Retrieved from https://www.sad.usace.army.mil/Missions/Civil-Works/SARBO/.

NOAA. 2023d. Atlantic Sturgeon. Retrieved from<https://www.fisheries.noaa.gov/species/atlantic-sturgeon>

NOAA. 2025. Atlantic Sturgeon. Retrieved from (https://www.fisheries.noaa.gov/species/atlanticsturgeon)

39 NRC. 2000. Biological Assessment of the Potential Impact on Shortnose Sturgeon Resulting from A Modification of the Dredging Footprint Edwin I. Hatch Nuclear Plant, Units 1 and 2.

NRC. 2004. Biological Assessment of the Potential Impact on Shortnose Sturgeon Resulting from An Additional 20 Years of Operation of the Edwin I. Hatch Nuclear Plant, Units 1 and 2.

NRC. 2014. Environmental Assessment and Finding of No Significant Impact Related to the Proposed License Amendment to Revise the Minimum Water Level in the Plant Service Water System Pump Well.

Perry, R.W., and R.E. Thill. 2007. Roost selection by male and female northern long-eared bats in pine-dominated landscape. Forest Ecology and Management 247:220-226.

Rogers, S.G., and W. Weber. 1994. Occurrence of shortnose sturgeon (Acipenser brevirostrum) in the Ogeechee-Canoochee River system, Georgia during the summer of 1993. Final Report to the Nature Conservancy of Georgia, U.S. Army, Atlanta, Georgia.

Rogers, S.G., and W. Weber. 1995. Movements of shortnose sturgeon in the Altamaha River system, Georgia. Contributions Series #57. Coastal Resources Division, Georgia Department of Natural Resources, Brunswick, Georgia.

Rowe, Matthew. May 2024. Candidate Conservation Agreement (CCA) for Mollusks of the Altamaha River Basin, Georgia 2024 Summary of Work. Georgia Department of Natural Resources, Wildlife Resources Division. 41 pp.

Sasse, D.B. D.A. Saugey, and D.R. England. 2011. Winter roosting behavior of Rafinesques big-eared bat in southwestern Arkansas. Pp. 123-128 in Loeb, S.C; Lacki, M.J.; Miller, D.A. (editors).

Conservation and management of easter big-eared bats: a symposium. Gen. Tech. Rep. 145.

Ashville, N.C: U.S. Department of Agriculture, Forest Service, Southern Research Station. 157 pp.

Shortnose Sturgeon Status Review Team. 2010. A Biological Assessment of shortnose sturgeon (Acipenser brevirostrum). Report to National Marine Fisheries Service, Northeast Regional Office. November 1, 2010. 417 pp.

Smith, T.I.J. 1985. The fishery, biology, and management of Atlantic sturgeon, Acipenser oxyrinchus, in North America. Environmental Biology of Fishes 14(1):61-72.

Stevens, R.D., C.J., Garcia, M.A. Madden, B.B. Gregory, and R.W. Perry. 2020. Seasonal Changes in the Active Bat Community of Kisatchie National Forest, Louisiana. Southeastern Naturalist 19(3):524-536.

Stone, E.L., S. Harris, G. Jones. 2015. Impacts of artificial lighting on bats: a review of challenges and solutions. Mamilian Biology. May 2015, pp 213-219.

U.S. Fish and Wildlife Service (USFWS). 2011. Endangered and Threatened Wildlife and Plants;

40 Endangered Status for the Altamaha Spinymussel and Designation of Critical Habitat; Final Rule.

Federal Register 76(196):62928-62960.

U.S. Fish and Wildlife Service (USFWS). 2021. Species Status Assessment Report for the Tricolored Bat (Perimyotis subflavus), Version 1.1. December 2021. Hadley, MA.

U.S. Fish and Wildlife Service (UFWS). 2023a. Red-cockaded Woodpecker Map. Retrieved from

<https://www.fws.gov/species/red%E2%80%90cockaded%E2%80%90woodpecker%E2%80%9 0picoides%E2%80%90borealis/map> (accessed November 28, 2023).

U.S. Fish and Wildlife Service (UFWS). 2023b. Eastern indigo snake. Retrieved from

<https://www.fws.gov/story/2023-07/eastern-indigo-snake#:~:text=The%20docile%20and%20nonvenomous%20eastern,chin%2C%20throat%2C%20 and%20cheeks> (accessed August 14, 2023).

U.S. Fish and Wildlife Service (UFWS). 2023c. Monarch butterfly. Retrieved from

<https://www.fws.gov/species/monarchdanaus-plexippus> (accessed August 11, 2023).

U.S. Fish and Wildlife Service (USFWS). 2024a. Altamaha Spinymussel (Elliptio spinosa) 5-Year Status Review: Summary and Evaluation. March 2024. Athens. GA.

U.S. Fish and Wildlife Service (UFWS). 2024b. Southern hognose snake. Retrieved from

< https://ecos.fws.gov/ecp/species/3248> (accessed December 17, 2025).

Veilleux, E.A., and S.L. Veilleux. 2004. Tree-roosting ecology of reproductive female eastern pipistrelles, Pipistrellus subflavus, in Indiana. Journal of Mammalogy 84(3):1068-1075.

Bullard Creek WMA Bullard Creek WMA Moody Forest WMA DEENS LANDING BOAT RAMP Savannah National Wildlife Refuge Bullard Creek WMA Moody Forest WMA 103-001 TOOMBS MONTGOMERY TATTNALL JEFF DAVIS APPLING LEGEND HNP SITE CONSERVED LANDS 0

1 2

0.5 Miles SOUTHERN NUCLEAR EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLING AND TOOMBS COUNTIES, GA PROJECT LOCATION 20285-002 FIGURE 1

LEGEND HNP SITE 0

1,500 3,000 750 Feet SOUTHERN NUCLEAR EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLING AND TOOMBS COUNTIES, GA USGS TOPOGRAPHIC MAP 20285-002 FIGURE 2

TOOMBS APPLING LEGEND HNP SITE AQUATIC REGION TERRESTRIAL REGION COUNTY BOUNDARY 0

1,500 3,000 750 Feet SOUTHERN NUCLEAR EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLING AND TOOMBS COUNTIES, GA ESA ACTION AREA MAP 20285-002 FIGURE 3

UNIT 2 UNIT 1 INTAKE STRUCTURE DISCHARGE STRUCTURE DREDGE SPOILS AND UPLAND DEWATERING BASIN TOOMBS APPLING LEGEND HNP SITE OUTFALL CHANNEL DREDGE AREA COUNTY BOUNDARY 0

500 1,000 250 Feet SOUTHERN NUCLEAR EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLING AND TOOMBS COUNTIES, GA SITE FEATURES MAP 20285-002 FIGURE 4

LEGEND HNP SITE UNIT 2 CRITICAL HABITAT (ELLIPTIO SPINOSA)

COUNTY BOUNDARY 0

1 2

0.5 Miles SOUTHERN NUCLEAR EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLING AND TOOMBS COUNTIES, GA ALTAMAHA SPINYMUSSEL (Elliptio spinosa)

HABITAT UNIT 2 20285-002 FIGURE 5

Biological Assessment Edwin I. Hatch Nuclear Plant, Units 1 and 2 Continued Operations Under Subsequent License Renewal Operating License Nos. DPR-57 and NPF-5 APPENDIX A PROTECTED SPECIES DOCUMENTATION

12/04/2025 19:39:32 UTC United States Department of the Interior FISH AND WILDLIFE SERVICE Georgia Ecological Services Field Office 355 East Hancock Avenue Room 320 Athens, GA 30601-2523 Phone: (706) 613-9493 Fax: (706) 613-6059 Email Address: gaes_assistance@fws.gov In Reply Refer To:

Project Code: 2026-0023060 Project Name: Hatch SLR

Subject:

List of threatened and endangered species that may occur in your proposed project location or may be affected by your proposed project To Whom It May Concern:

Thank you for requesting information on federally listed species and important wildlife habitats that may occur in your project area. The U.S. Fish and Wildlife Service (Service) is responsible for managing certain species of wildlife under the Endangered Species Act (ESA) of 1973 as amended (16 USC 1531 et seq.), Migratory Bird Treaty Act (MBTA) as amended (16 USC 701-715), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.)

and Bald and Golden Eagle Protection Act as amended (16 USC 668-668c). We provide the following guidance for understanding which federally protected species and critical habitats may occur within your project area and to recommend conservation measures for your project if you determine those species or designated critical habitats may be affected by the project activities.

Federally-listed Species and Critical Habitat Under the ESA, it is the responsibility of the Federal action agency, their designated non-Federal representative, or a project proponent to determine if a proposed action "may affect" endangered, threatened, or proposed species, or designated critical habitat, and if so, to consult with the Service. Similarly, it is the responsibility of the Federal action agency or project proponent, not the Service, to make no effect determinations. If you determine that your proposed action will have no effect on threatened or endangered species or their respective critical habitat, you do not need to seek concurrence with the Service. Nevertheless, it is a violation of Federal law to harm or harass any federally listed threatened or endangered fish or wildlife species without the appropriate permit. If you need additional guidance to inform your effect determination, please contact the Service.

If you determine that your proposed action may affect federally listed species, please consult with the Service. Through the consultation (for projects seeking Federal funding or permitting) or technical assistance (for non-Federal projects) process, we will work with you to evaluate

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

2 of 9 information contained in a biological assessment or equivalent documents that you provide. If your proposed action is associated with Federal funding or permitting, consultation will occur with the Federal agency under section 7(a)(2) of the ESA. Otherwise, an incidental take permit pursuant to section 10(a) (1)(B) of the ESA (also known as a Habitat Conservation Plan) may be necessary to exempt "take" of federally listed threatened or endangered fish or wildlife species when it cannot be avoided.

Action Area. The scope of ESA compliance includes direct and indirect effects of project activities (e.g., equipment staging areas, offsite borrow material areas, or utility relocations). The "action area" is the spatial extent of an actions direct and indirect modifications or impacts to the land, water, or air (50 CFR 402.02). Large projects may have effects to land, water, or air outside the immediate footprint of the project, and these areas should be included as part of the action area. Effects to land, water, or air outside of a project footprint could include things like lighting, dust, smoke, and noise. To obtain a complete list of species, the action area should be uploaded or drawn in IPaC rather than just the project footprint. Please note that a lead federal agency may consider an action area that excludes portions of the project footprint. In these cases, further coordination with our office may be required to ensure compliance with the ESA. It is the responsibility of the project proponent to coordinate with the lead federal agency to understand the action and action area being reviewed as part of ESA Section 7 consultation.

New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please feel free to contact us if you need more assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. An updated list may be requested through IPaC.

How to Submit a Project Review If your action may affect any federally listed species and you would like technical assistance from our office, please send us a complete project review package. A step-by-step guide is available below and supplemental guidance is available at the Georgia Ecological Services Project Planning and Review page (https://www.fws.gov/office/georgia-ecological-services/

project-planning-review).

Requests for threatened and endangered species project reviews must be submitted to our office using the process described below. All steps must be completed to ensure your project is reviewed by a biologist in our office and you receive a timely response.

Step 1. Request an official species list for your project through IPaC. You have just completed this step.

Step 2. Complete applicable Determination Keys (DKey's, for short)

Step 3. Send your complete project project review package to gaes_assistance@fws.gov for review if no DKey is applicable or certain project components have not been addressed (i.e. a

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

3 of 9 1.

2.

3.

4.

5.

6.

species returned by IPaC does not have a DKey). A complete project review package should include:

A description of the proposed action, including any measures intended to avoid, minimize, or offset effects of the action. The description shall provide sufficient detail to assess the effects of the action on listed species and critical habitat, such as the purpose of the action; duration and timing of the action; location (latitude and longitude); specific activities involving disturbance to land, water, and air, and how they will be carried out; current description of areas to be affected directly or indirectly by the action; and maps, drawings, or similar schematics of the action. Please submit all areas of a project as one single submission and do not separate into smaller components/submissions.

An updated Official Species List and Determination Key results Biological Assessments (may include habitat assessments and information on the presence of listed species in the action area);

Description of effects of the action on species in the action area and, if relevant, effect determinations for species and critical habitat; Conservation measures and any other available information related to the nature and scope of the proposed action relevant to its effects on listed species or designated critical habitat (e.g., management plans related to stormwater, vegetation, erosion and sediment plans).

Visit the Georgia Conservation Planning Toolbox for more information.

In the email subject line, use the following format to include the Project Code from your IPaC species list and the county in which the project is located (Example: Project Code:

2023-0049730 Gwinnett Co.). For Georgia Department of Transportation related projects, please work with the Office of Environmental Services ecologist to determine the appropriate USFWS transportation liaison.

Our team will respond within approximately 30 days of receipt with technical assistance and recommendations.

Wetlands and Floodplains Federal agencies are required to minimize the destruction, loss, or degradation of wetlands and floodplains, and preserve and enhance their natural and beneficial values. These habitats should be conserved through avoidance, or mitigated to ensure that there would be no net loss of wetlands function and value. We encourage you to use the National Wetland Inventory (NWI) maps in conjunction with ground-truthing to identify wetlands occurring in your project area. We also recommend you contact the U.S. Army Corps of Engineers for permitting requirements under section 404 of the Clean Water Act if your proposed action could impact floodplains or wetlands.

Migratory Birds The MBTA prohibits the taking of migratory birds, nests, and eggs, except as permitted by the Services Migratory Birds Program. To minimize the likelihood of adverse impacts to migratory birds, we recommend construction activities occur outside the general bird nesting season from March through August, or that areas proposed for construction during the nesting season be surveyed, and when occupied, avoided until the young have fledged. Information related to

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

4 of 9 industry best practices and migratory birds can be found at the Service's Reducing Impacts to Migratory Birds page.

Bald and Golden Eagles The Service works to manage and conserve both bald eagle and golden eagle populations. We provide guidance on living and working near eagles, updates on the status of the populations of bald and golden eagles, and permits for the take, possession, or transportation of eagles and their parts, nests, and eggs. For more information, please visit the Service's Eagle Management page.

Other Species Considerations Bats. If your species list includes Indiana bat (Myotis sodalis), northern long-eared bat (M.

septentrionalis), or tricolored bat (Perimyotis subflavus) and the project is expected to impact forested habitat, tree clearing should occur outside of the periods when bats may be present and most vulnerable. Federally listed bats could be actively present in forested landscapes from spring through fall of any year. In much of Georgia, our winters are mild enough that tricolored bats are likely active on the landscape to some extent year-round. Pups are incapable of flight and vulnerable to disturbance from the spring to summer. Our recommended seasonal clearing restriction windows depend on species and region in Georgia. Please reach out to us for guidance.

Indiana, northern long-eared, tricolored, and gray (M. grisescens) bats are all known to utilize bridges and culverts in Georgia. If your project includes maintenance, construction, or any other modification or demolition to transportation structures, a qualified individual should complete a survey of these structures for bats and submit your findings via the GADNR Bats in Bridges form in the Survey123 App, free on Apple and Android devices. Please include these findings in any biological assessment(s) or other documentation that is submitted to our office for technical assistance or consultation.

Eastern Indigo Snake. The Standard Protection Measures for the Eastern Indigo Snake (Drymarchon couperi) include educational materials and training that can help protect the species by making staff working on a project site aware of their presence and traits. In Georgia, indigo snakes are closely associated with the state-listed gopher tortoise (Gopherus polyphemus),

a reptile that excavates extensive underground burrows that provide the snake shelter from winter cold and summer desiccation. To assist project proponents in avoiding and minimizing potential impact to the eastern indigo snake, the Service provides the Visual Encounter Survey Protocol for the Eastern Indigo Snake (Drymarchon couperi) in Georgia for project proponents or their designees to evaluate the possible presence of the Eastern indigo snake at a proposed project site.

Solar Energy Development The Recommended Practices for the Responsible Siting and Design of Solar Development in Georgia, Version 2.0 (published in May 2024) are intended to provide voluntary guidance to support consideration of natural resources during the development of photovoltaic solar in Georgia. Furthermore, the Georgia Low Impact Solar Siting Tool (LISST) is also available as a map layer in IPaC (Find it in the Layers Box > Environmental Data) to provide project managers with the data to identify areas that may be preferred for low-impact development. The

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

5 of 9

tool seeks to support the acceleration of large-scale solar development in areas with less impact to the environment.

State Agency Coordination Environmental review staff at the Georgia Department of Natural Resources (GA DNR) Wildlife Conservation Section can assist with information requests and the review of Georgia rare species and natural community data for specific projects or actions within the state. Please visit their Environmental Review page. Additional information that addresses at-risk or high priority natural resources can be found in the Georgia State Wildlife Action Plan, at Georgia Department of Natural Resources, Wildlife Resources Division Biodiversity Portal, Georgia's Natural, Archaeological, and Historic Resources GIS portal pages.

Thank you for your concern for endangered and threatened species. We appreciate your efforts to identify and avoid impacts to listed and sensitive species in your project area. For further consultation on your proposed activity, please email gaes_assistance@fws.gov and reference the project county and your FWS Project Number. This letter constitutes Georgia Ecological Services general comments under the authority of the Endangered Species Act.

Attachment(s):

Official Species List OFFICIAL SPECIES LIST This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

Georgia Ecological Services Field Office 355 East Hancock Avenue Room 320 Athens, GA 30601-2523 (706) 613-9493

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

6 of 9 PROJECT

SUMMARY

Project Code:

2026-0023060 Project Name:

Hatch SLR Project Type:

Power Gen - Nuclear Project

Description:

SLR Project Location:

The approximate location of the project can be viewed in Google Maps: https://

www.google.com/maps/@31.933188,-82.34760252409069,14z Counties: Appling and Toombs counties, Georgia

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

7 of 9 1.

ENDANGERED SPECIES ACT SPECIES There is a total of 6 threatened, endangered, or candidate species on this species list.

Species on this list should be considered in an effects analysis for your project and could include species that exist in another geographic area. For example, certain fish may appear on the species list because a project could affect downstream species.

IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA Fisheries, as USFWS does not have the authority to speak on behalf of NOAA and the Department of Commerce.

See the "Critical habitats" section below for those critical habitats that lie wholly or partially within your project area under this office's jurisdiction. Please contact the designated FWS office if you have questions.

NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the National Oceanic and Atmospheric Administration within the Department of Commerce.

1

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

8 of 9 MAMMALS NAME STATUS Tricolored Bat Perimyotis subflavus No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/10515 Proposed Endangered BIRDS NAME STATUS Red-cockaded Woodpecker Dryobates borealis No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/7614 Threatened REPTILES NAME STATUS Eastern Indigo Snake Drymarchon couperi No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/646 Threatened Southern Hognose Snake Heterodon simus No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/3248 Proposed Threatened CLAMS NAME STATUS Altamaha Spinymussel Elliptio spinosa There is final critical habitat for this species. Your location overlaps the critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/6920 Endangered INSECTS NAME STATUS Monarch Butterfly Danaus plexippus There is proposed critical habitat for this species. Your location does not overlap the critical habitat.

Species profile: https://ecos.fws.gov/ecp/species/9743 Proposed Threatened CRITICAL HABITATS There is 1 critical habitat wholly or partially within your project area under this office's jurisdiction.

NAME STATUS Altamaha Spinymussel Elliptio spinosa https://ecos.fws.gov/ecp/species/6920#crithab Final

Project code: 2026-0023060 12/04/2025 19:39:32 UTC

9 of 9 IPAC USER CONTACT INFORMATION Agency: Private Entity Name:

Mark Ballard Address: 630 Colonial Park Drive City:

Roswell State:

GA Zip:

30075 Email markballard@ecologicalsolutions.net Phone:

4049158823 LEAD AGENCY CONTACT INFORMATION Lead Agency: Nuclear Regulatory Commission

(virtual):

HNP Subsequent License Renewal Application, Appendix E, Applicants Environmental Report (ML25135A392)

(https://www.nrc.gov/docs/ML2513/ML25135A392.pdf)