20181638 Ver 3_combined WRC Comments_20200110

Homewood, Sue
From: Munzer, Olivia
Sent: Friday, January 10, 2020 9:08 AM
To: Homewood, Sue
Subject: FW: MVP Southgate NCWRC Comments
Attachments: WRC Scoping Comments MVP Southgate 8-29-18.pdf, WRC Comments MVP
Southgate 8-10-18 final.pdf, NCWRC comments on MVP Southgate DEIS 9-16-19.pdf
Good morning Sue. Happy New Year to you.
Here are two scoping letters — one with more detail, and the comments on the DEIS. Have a great weekend.
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
From: Stancil, Vann F <[e-mail]>
Sent: Thursday, January 09, 2020 4:35 PM
To: Munzer, Olivia <[e-mail]>
Subject: RE: MVP Southgate NCWRC Comments
Hey Olivia, here are 2 comments letters: original scoping and a letter that was sent 3 weeks earlier that is more
detailed.
From: Munzer, Olivia <[e-mail]>
Sent: Thursday, January 09, 2020 4:06 PM
To: Stancil, Vann F <[e-mail]>
Subject: MVP Southgate NCWRC Comments
Vann,
Sue Homewood is looking for our original scoping comments on MVP. I have our comments on the DEIS, but do we have
any other comments? Thanks
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
Rogers Depot
1718 NC Hwy 56 W
Creedmoor, NC 27522
Office: 919-707-0364
Cell: 336-269-0074
[e-mail]
www.ncwildlife.org
13 In n LOW
1

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

MEMORANDUM

TO: Megan Stahl, Permitting Coordinator
MVP Southgate

FROM: Vann Stancil
Research Coordinator
Habitat Conservation Division

DATE: August 10, 2018

SUBJECT: Comments on proposed route and species surveys for MVP Southgate Project,
Rockingham and Alamance counties.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have met with
representatives of the MVP Southgate Project and have reviewed the proposed project
description. Comments are provided in accordance with provisions of the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina
Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25) and North Carolina
General Statutes (G.S. 113-131 et seq.).

The MVP Southgate Project is an interstate natural gas pipeline project that will extend
approximately 72 miles from Pittsylvania County, Virginia to delivery points in North Carolina.
Approximately 46 miles of the pipeline will traverse the Dan and Haw river basins in
Rockingham and Alamance counties. The project will terminate in Alamance County on the east
side of the Haw River between Graham and Swepsonville. The applicant has provided detailed
information on the current proposed pipeline route and has requested information to guide
aquatic and terrestrial surveys for this project.

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August 10, 2018
MVP Southgate

The NCWRC has reviewed the MVP Southgate route. In general, we have identified locations
where impacts can be lessened by reducing the number of stream crossings, following existing
rights-of-way (ROW), reducing fragmentation of forested blocks, and reducing impacts to
riparian zones. Locations of stream crossings are based on GIS stream layers; on-the-ground
surveys may reveal that actual stream locations differ from what is shown on maps. We have the
following specific concerns and recommendations about the current pipeline route:

Rockingham County

• The route crosses Cascade Creek in NC beside an existing utility ROW that is cleared
along the riparian zone. There are records for the Federal Endangered Roanoke Logperch
and other rare aquatic species in the North Carolina portion of Cascade Creek. Given the
high quality of the aquatic community in Cascade Creek, we recommend that horizontal
directional drilling (HDD) or conventional bore be used to cross this waterbody.

• The route crosses Rock Creek three times near its confluence with the Dan River and the
route does not follow the existing ROW. Following the existing ROW would result in
one creek crossing and less forest fragmentation. We recommend that the route be
modified to reduce forest fragmentation so that Rock Creek is only crossed once,
preferably along the existing ROW.
• Town Creek is crossed twice, the southern crossing is not along the existing ROW. If the
MVP Southgate route followed the existing ROW, it would still cross Town Creek twice,
but forest fragmentation would be reduced. Another alternative is to move the route
farther east and avoid crossing Town Creek altogether, but this option could result in
more forest fragmentation.

• There is an intermittent stream in the Town Creek watershed located between SR 1978
and SR 1979. The MVP Southgate route crosses it five times, as does the existing
ROW. Four of the five current crossings are shared with the existing ROW. The route
could be modified slightly to reduce the number of crossings from five to three. At the
southernmost crossing of this intermittent stream, the pipeline diverges from the existing
ROW and crosses a forested area north of SR 1980 and west of SR 1979. The proposed
route continues to cross a forested block between SR 1982 and SR 1941 before it
eventually reconnects with the existing ROW prior to crossing Wolf Island Creek. The
preferred route would be to continue co-location with the existing ROW in this area.

• The pipeline route crosses an unnamed tributary to Wolf Island Creek two times on the
north side of the Wolf Island Creek crossing. The Piedmont Land Conservancy controls
an easement for a parcel on the west side of the unnamed tributary near the pipeline
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August 10, 2018
MVP Southgate

location. The route could be modified to reduce the number of crossings along this
unnamed tributary. There are records for the Federal Endangered Roanoke Logperch and
other rare aquatic species in Wolf Island Creek. Given the high quality of the aquatic
community in Wolf Island Creek, we recommend that HDD or conventional bore be used
to cross this waterbody.

• The proposed route deviates from the existing ROW and crosses a forested area spanning
from U.S. Highway 158 south to Daisy Drive east of Reidsville. Forest fragmentation
could be reduced if the route followed the existing ROW on the west side to SR 2579.
This could also shorten the length of the route.

• Forest fragmentation could also be reduced by following the existing ROW near the SR
2588 crossing.

• East of Williamsburg between SR 2571 and NC Highway 150, the pipeline crosses a
large forested area with intermittent agricultural lands, Hogans Creek, and its unnamed
tributaries. We prefer the pipeline to be co-located with the existing ROW.

Alamance County

• The pipeline crosses a forested area located south-southwest of SR 1594 and northwest of
SR 1595 near Burlington. Forested fragmentation could be reduced by continuing to
collocate the line southward until the existing east-west ROW (36.16604 N, -79.48789
W) and co-locate the line with the existing ROW eastward to SR 1595. Alternatively, the
pipeline could extend to the southernmost end of the agricultural field south of the pond
(36.1745 N, -79.48869 W), then continue south-southeast to SR 1595.

• After crossing SR 1598, the proposed route deviates from the existing ROW. The
proposed pipeline is also only 700 feet south of a NC Division of Mitigation Services
easement. A new pipeline corridor south of the mitigation project may reduce the
effectiveness of the mitigation project. Forest fragmentation could be reduced if the route
followed the existing ROW across SR 1601. This could also shorten the length of the
route.
• There are records for Eastern Lampmussel (Lampsilis radiata) in Deep Creek upstream
from the proposed crossing location. Therefore, we recommend that HDD or
conventional bore be considered for crossing this waterbody.

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August 10, 2018
MVP Southgate

• The Stony Creek Natural Heritage Natural Area occurs near the pipeline centerline on the
east side of Stony Creek Reservoir. We recommend stringent erosion and sedimentation
controls if the pipeline route remains close this natural area.

• The proposed route bisects a large forested block where it crosses Boyds Creek.
Alternative routes may reduce forest fragmentation.

• The proposed route is within 250’ of the Haw River south of US 70 and also north of I-
40. The route is within 150’ of the Haw River south of I-40 and within 200’ north of NC
54 near the end of the route. We recommend examining alternative routes farther east
that will be located farther from the Haw River. If alternative routes are not practical,
when the route parallels the Haw River, it should be located farther away from the river
to maintain the riparian zone and reduce forest fragmentation.

NCWRC offers the following comments regarding aquatic surveys:

• NCWRC requests freshwater mussel surveys for the following streams in the Dan River
basin: Cascade Creek, Dan River, Hogans Creek, Jones Creek, Lick Fork Creek, Machine
Creek, Rock Creek, Town Creek, and Wolf Island Creek. Please notify T. R. Russ,
Foothills Region Aquatic Wildlife Diversity Coordinator ([e-mail],
928-803-6035), of the dates when sampling will occur in Dan River basin waterbodies.

• In the Haw River basin, freshwater mussel surveys should be conducted in all perennial
streams first order and higher. Using the current route shapefile, this would include
Boyds Creek, Deep Creek, Giles Creek, Stony Creek, and 4 unnamed tributaries to the
Haw River. Using the current shapefile, these 4 unnamed tributary crossings are located
at 36.17242, -79.48576; 36.22968, -79.5274; 36.24187, -79.53111; and 36.2643, -
79.55023.

• If the pipeline route crosses one of these streams more than once, surveys should be
conducted at each crossing location. If the current proposed route changes to include
new stream crossings, additional sites may require surveys.

• Preliminary mussel surveys are needed to determine appropriate pipeline crossing
methods and crossing locations. If any live mussels are collected, a second mussel
survey will be needed prior to pipeline installation to relocate mussels that may be
impacted by pipeline construction activities.

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August 10, 2018
MVP Southgate

• Preliminary mussel surveys should extend 100 meters upstream and 300 meters
downstream of the proposed crossing location.

• Habitat data, depth, substrate, habitat type (riffle, run, pool) should be mapped for each
survey reach. Survey reaches should be divided into 20-meter sections to better
determine areas of high mussel densities for crossing locations.

• Surveys for the Greensboro Burrowing Crayfish, Cambarus catagius, should be
conducted in work areas within 200 ft of any mapped stream, both intermittent and
perennial in the Haw River basin. Effort should cover all areas which will be excavated
(i.e., for pipeline burial) as well as 25 feet on either side to allow for equipment
space. Work pads for HDD access and conventional boring should also be included,
along with any other areas where ground disturbance may lead to crayfish mortality
through burrow destruction and crushing. If there are signs of burrowing crayfish activity
(holes), burrows should be investigated, and inhabitants relocated.

• The Greensboro Burrowing Crayfish has been found in all types of soils from sandy
loams to hard clay and burrows are not usually directly associated with any drainage or
stream flow (McGrath 1994). The species has never been found in any flowing water.
The full extent of its distribution in this watershed is unknown due to lack of targeted
surveys. Please notify Brena Jones, Central Aquatic Wildlife Diversity Coordinator
([e-mail], 919-707-0369), if any Greensboro Burrowing Crayfish are
located.

• For burrowing crayfish surveys, we recommend using a device called a Yabby Pump to
remove the crayfish from its burrow. This devise is far less invasive and labor-intensive
than excavating burrows. We can provide additional information on the device, including
photos and demonstrations, as needed.

• We recommend conducting burrowing crayfish surveys during winter months when
burrows are more likely to be visible and water tables are typically higher. Collected
crayfish should be identified, photographed, and relocated to suitable habitat nearby that
will not be impacted by pipeline construction activities.

• No targeted surveys for Greensboro Burrowing Crayfish are needed in the Dan River
basin; this endemic species is only known from the upper Cape Fear and a portion of the
Yadkin-Pee Dee basins. However, if any crayfish burrows or tunnels are observed in the
Dan River basin tributaries, they should be surveyed using the techniques described for
Haw River basin surveys.
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August 10, 2018
MVP Southgate

• Stream crayfish surveys should be conducted in all first to third order streams in the Dan
and Haw river basins. These surveys should include 20 kicks into a seine approximately
8 feet wide. The area upstream of the seine should be disturbed by flipping rocks or
kicking under banks or root wads to dislodge crayfish. The primary purpose of these
surveys is to determine abundance and distribution of the Carolina Ladle Crayfish,
Cambarus davidi, but other crayfish species may also be encountered. Collected crayfish
should be identified, photographed, and enumerated. Seining effort should be spaced to
include the 400-meter mussel survey area that extends above and below the proposed
crossing location.

• No targeted fish surveys are necessary, but any state listed, federal listed, or Species of
Greatest Conservation Need (SGCN) as listed in the 2015 NC Wildlife Action Plan that
are encountered during surveys for freshwater mussels or crayfish should be denoted.

• If temporary dams are used for stream crossings, any aquatic species (fish, crayfish,
mussels, reptiles and amphibians) found within the temporary dam footprint and
dewatered area should be removed and relocated to suitable habitat away from the
construction area.

NCWRC offers the following comments regarding surveys for terrestrial species:

Bats

NCWRC received the revised study plan for bat surveys dated 23 July 2018. We concur with the
presence/probable absence survey methodology as described within the bat survey plan.
However, we recommend the following changes and/or additions to the proposed survey sites, if
landowner access is feasible:

• NC-SB01 – Map 1: Shift the survey block south approximately 0.3 km to include the
creeks (Dry Creek and unnamed tributaries) that flow into the Dan River. In this area,
Dry Creek and its unnamed tributaries flow through a large forested area.
• NC-SB04 – Map 5: Include forested area above this block near TA-RO-105.
• NC-SB06 – Map 7: Area north of this block seems less fragmented and potentially better
habitat, especially on the west side of the pipeline ROW. Consider adding a survey block
or extending the survey block to include this area.
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August 10, 2018
MVP Southgate

• NC SB08 – Map 8 & 9: There is more forested habitat and less agriculture north of TA-
RO-140 to about TA-RO-133 than seen in the current survey block. Consider adding or
substituting this area for NC SB08.
• NC SB15 – Map 15 & 16: Some of the industrial/highway areas in this block could be
omitted. Consider starting the survey block around Stone Street/NC HWY 1935 and
extend it farther south towards the end of the line. This would provide more options for
good net sites, especially along the Haw River and its tributaries.
In the study plan, ESI requests concurrence that the project area may be cleared at any time of
the year without restriction unless a federally-listed bat roost is found in the project
vicinity. NCWRC prefers the avoidance of mature tree clearing activities during the maternity
roosting season (May 15 – August 15), if ESI finds state-listed bat species.

Reptiles and Amphibians

Jeff Hall, the Reptile and Amphibian Conservation Biologist for NCWRC, has requested a
desktop review of the MVP Southgate pipeline corridor to identify potential suitable habitat for
four-toed salamanders and mole salamanders. Jeff Hall will review the findings and identify a
subset of potentially suitable habitats to be surveyed for these salamander species.

Birds

Co-locating of the proposed pipeline with other linear projects reduces the fragmentation of
forests. Many forest birds that breed in North Carolina are sensitive to habitat patch size. As
patch size decreases and more edges are created, nest parasitism and nest predation increase.
Fragmentation also impacts important ecosystem function, such as decreased forest biomass and
nutrient cycling, thereby reducing abundance, biodiversity, persistence, and movement of
wildlife (Haddad et al. 2015). The effects of fragmentation increase over time and the smaller
and more isolated fragments are impacted most (Haddad et al. 2015). To reduce impacts of
forest fragmentation on birds, we recommend limiting the number of large forested patches
bisected by the pipeline.

Migratory birds and their eggs are protected from “take” by the Migratory Bird Treaty Act of
1918. Therefore, we recommend avoiding any clearing activities during the migratory bird
nesting season, roughly March to August, or conduct surveys for active nests prior to
construction to avoid “taking” migratory birds, which includes wounding or killing.
We recommend surveys for active colonial nesting birds (i.e., rooker y) and bald eagle nests
within 0.5 miles of the pipeline corridor. Aerial surveys for bald eagle nests and colonial nesting
birds should be conducted during winter months when deciduous trees have shed their leaves. If
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August 10, 2018
MVP Southgate

active rookeries are located, construction activities should not occur within 0.5-mile of each
rookery from February 15 - July 31. Therefore, any construction activities begun prior to
February 15th should cease by February 15th, allowing the birds to return to their rookeries with
no added disturbance. We recommend adhering to the U.S. Fish and Wildlife National Bald
Eagle Management Guidelines for high disturbance activities if nests occur within 0.5 miles of
project activities.

Thank you for the opportunity to review and comment on this project. If the NCWRC can be of
further assistance, please contact Olivia Munzer at [phone] and
[e-mail] or me at [phone] and [e-mail].

Literature Cited

Haddad, N.M, L.A. Brudvig, J. Clobert, K.F. Davies, A. Gonzalez, R.D. Holt, T.E. Lovejoy, J.O.
Sexton, M.P. Austin, C.D. Collins, W.M. Cook, E.I. Damschen, R.M. Ewers, B.L. Foster,
C.N. Jenkins, A.J. King, W.F. Laurance, D.J. Levey, C.R. Margules, B.A. Melbourne,
A.O. Nicholls, J.L. Orrock, D. Song, and J.R. Townshend. 2015. Habitat Fragmentation
and its Lasting Impact on Earth’s Ecosystems. Science Advances 1:e1500052.

McGrath, C. 1994. Status survey for the Greensboro burrowing crayfish. Proceedings of the
annual conference, Southeastern Association of Game and Fish Commissioners, 48: 343–
349.

North Carolina Wildlife Resources Commission. 2015. North Carolina Wildlife Action Plan.
Raleigh, NC

ec: Olivia Munzer, NCWRC
Brena Jones, NCWRC
T. R. Russ, NCWRC
Jeff Hall, NCWRC
Katherine Caldwell, NCWRC
John Ellis, USFWS
Sarah McRae, USFWS
Kathy Matthews, USFWS
Judy Ratcliffe, NCNHP

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

MEMORANDUM

TO: Lyn Hardison, Environmental Assistance and SEPA Coordinator
NCDEQ Division of Environmental Assistance and Customer Services

FROM: Vann Stancil
Research Coordinator
Habitat Conservation Division

DATE: August 29, 2018

SUBJECT: Scoping comments for MVP Southgate Project Notice of Intent to prepare an EIS, including
route alternatives, Rockingham and Alamance counties.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the Notice
of Intent to prepare an Environmental Impact Statement (EIS) for the MVP Southgate Project. NCWRC
biologists have previously met with representatives of the MVP Southgate Project and have reviewed the
proposed project description. Comments are provided in accordance with provisions of the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina
Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25) and North Carolina General
Statutes (G.S. 113-131 et seq.).

The MVP Southgate Project is an interstate natural gas pipeline project that will extend approximately 72
miles from Pittsylvania County, Virginia to delivery points in North Carolina. Approximately 46 miles of
the 24” diameter natural gas transmission pipeline will traverse Rockingham and Alamance counties. The
project will interconnect with and receive gas from the Mountain Valley Pipeline near Chatham, Virginia
and the East Tennessee Natural Gas mainline near Eden, NC. The project will terminate in Alamance
County on the east side of the Haw River between Graham and Swepsonville.

The MVP Southgate pipeline will traverse parts of the Dan and Haw river basins. Several rare,
threatened, and endangered species are found in this region of the state, including the Federal Endangered
Roanoke Logperch (Percina rex). NCWRC previously provided comments to the applicant on the
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August 29, 2018
MVP Southgate

proposed route and aquatic and terrestrial species surveys in a letter dated August 10, 2018. NCWRC
biologists will continue to work with the applicant to assess route alternatives, species surveys, and best
practices to minimize impacts to aquatic and terrestrial species and their habitats prior to, during, and after
pipeline construction.

The request for scoping comments includes four alternative pipeline routes in Alamance County: Sandy
Cross Road Alternative, Alamance Eastern Alternative, Alamance Southern Alternative, and the Duke
Powerline Alternative. In general, when assessing pipeline routes and their potential impacts on aquatic
and terrestrial wildlife resources, we look for routes where impacts can be lessened by reducing the
number of stream crossings, following existing rights-of-way (ROW), reducing fragmentation of forested
blocks, and minimizing impacts to riparian zones. Without GIS layers of the pipeline route alternatives,
we cannot adequately compare the environmental impacts of the alternatives with the preferred route and
recommend a route. We have the following specific comments about the pipeline alternative routes:

• For the Duke Power Alternative, the MVP Southgate pipeline is co-located with an existing Duke
Energy transmission line and other ROW for approximately 3.8 miles. This alternative has merit
because it avoids new forest fragmentation south-southwest of SR 1594 by co-locating the
pipeline along an existing ROW. It also avoids fragmentation of a forest located southwest of SR
1602.

• The Sandy Cross Road Alternative appears to avoid the forest fragmentation caused by the
preferred route where it crosses Boyds Creek.

• At 9.6 miles, the Alamance Eastern Alternative is double the length of the preferred pipeline
route. This alternative will reduce some of the Haw River riparian zone impacts associated with
the preferred route between US 70 and I-40.

• The Alamance Southern Alternative will also reduce some of the Haw River riparian zone
impacts but will likely cross Back Creek once or twice.

Thank you for the opportunity to review and comment on this project. If the NCWRC can be of further
assistance, please contact Olivia Munzer at [phone] and [e-mail] or me at
[phone] and [e-mail].

ec: Olivia Munzer, NCWRC
Brena Jones, NCWRC
T. R. Russ, NCWRC
John Ellis, USFWS
Judy Ratcliffe, NCNHP