The James River Association (JRA) supports the "Freshwater Mussel Guidelines for Virginia" issued by the Virginia Department of Wildlife Resources. These guidelines highlight the necessary considerations for safeguarding freshwater mussel species and their habitats in the state. JRA acknowledges the importance of these guidelines for project applicants and consultants involved in activities impacting waterways in Virginia.

The guidelines provide a clear and detailed framework for conducting freshwater mussel surveys and relocations, particularly for small construction projects with short durations. The attention to suitable habitat, project footprint, and potential impacts on listed species highlights the current minimum best practices for these species, and the emphasis on coordination with relevant authorities, such as DWR and the U.S. Fish and Wildlife Service (FWS), ensures compliance with federal and state laws and promotes responsible environmental practices.

The incorporation of general life history information about freshwater mussels, including their role as sedentary filter-feeders and indicators of water quality, adds further helpful context to the document. Understanding the reproductive categories, spawning periods, and ecological significance of these species enhances awareness among project applicants and consultants.

Thank you for the consideration of these comments.