20060645 Ver 2_WRC Comments_20110722

North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: John Thomas, US Army Corps of Engineers
Raleigh Regulatory Field Office
Sue Homewood, 401 Certification Unit
NC Division of Water Quality
FROM: Ron Linville, Regional Coordinator
Habitat Conservation Program
DATE: July 22, 2011
SUBJECT: Duke Energy - Craig Road Landfill NCDWQ No: 20060645v2, Section 404/401 Individual
Permit/Certification, Stokes County
Duke Energy proposes to expand an existing landfill used for the disposal of coal combustion products. Biologists
with the North Carolina Wildlife Resources Commission (NCWRC) are familiar with habitat values in the area.
These comments are provided in accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat.
401, as amended; 16 U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through
113A-10; NCAC 25).
The project is indicated to prefer Alternative C which will provide 23.6 years of disposal capacity. Jurisdictional
impacts associate with this alternative are 0.27 acres of wetlands and 4,662 linear feet of stream. Mitigation is
proposed through payment to the North Carolina Ecosystem Enhancement Program (EEP). The landfill area drains
into Belews Lake (previously East Belews, Belews and West Belews Creeks) which flows a short distance in a
remnant segment of Belews Creek to the Dan River after discharge from the dam. Elevated water temperatures are
known to be associated with Belews Lake. The Dan River is a water supply watershed.
The Dan River and the animals that live in the river are public resources of high value. Dan River aquatic habitat is
considered by the Natural Heritage Program to be a significant natural heritage area, and the Non-Game Section of
the NCWRC has identified this river as one of six high priority areas for long term conservation. The Dan River
supports a variety of fish species including largemouth bass, sunfishes, catfishes, minnows and darters. Some
species from the river are host species for the James spinymussel (Pleurobema collina), a federally listed
Endangered mussel Records exist for the presence of several state and federal listed species in Stokes County and
the Dan River. The following list includes Endangered (E), Threatened (T), Significantly Rare (SR) and Species of
Concern (SC) found in the river basin:
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: ;919) 707-0220 • Fax: [phone]
Craig Road Landfill Expansion Page 2 July 22, 2011
Common Name Scientific Name State Status Federal Status

Freshwater Fishes
Bigeye jumprock (Scartomyzon ariommus) SC -
Cutlips minnow (Exoglossum mwcillingua) E -
Orangefin madtom (Notorus gilberti) E SC
Riverweed darter (Etheostoma podostemone) SC -
Roanoke hogsucker (Hypentelium roanokense) SR -
Rustyside sucker (Thoburnia hamiltoni) E -
Mollusks
Green floater (Lasmigona subviridis) E SC
James spin.ymussel (Pleurobema collina) E E
Notched rainbow (Villosa constricts) SR -
Based on our review of the application, we will not object to the project or the proposed mitigation providing that
project proponents take precautionary measures to protect the Dan River and its aquatic resources from direct and
indirect impacts.
We offer the following recommendations for the Corps 404 Individual Permit and the NCDWQ 401 Certification as
well as other required approvals and permits:
Where practicable, streams should be relocated using natural channel (bioengineering) design
methodologies and state-of-the-art stream designs. Streams that are sunlit with woody buffers provide
significantly more biodiversity. Buried streams are essentially devoid of beneficial functions and
wildlife. Where the relocation and day lighting of streams is not possible, waters should be diverted in
a manner so that waters cannot mix with disposed materials. We concur with the US Fish and Wildlife
Service's recommendation (Ratzlaff, June 27, 2011) of 2:1 minimum mitigation for project impacts
although onsite mitigation is preferred and recommended if possible.
2. Top soils and riparian soils should be stockpiled for any stream relocations and for final site closure to
the maximum extent practicable. Other overburden materials should be used for interim coverage as
required pursuant to applicable landfill permit conditions.
To the extent practicable, stormwater management and hydrologic control measures should be
provided to maintain current hydrographic conditions upon closure of each landfill phase. The
expansion should be phased (incremental smaller areas instead the entire site) to minimize the amount
of disturbed area and to maximize re-use of top soils and riparian soils. Although some overlap is
likely, phases should be completed before starting a new phase. For example, top soils removed from
portions of the northern area of the expansion should be stored and then used to provide final cover for
the existing landfill while future phased expansions should be handled similarly.
4. Leachate should be properly collected and treated pursuant to National Pollutant Discharge
Elimination System (NPDES) requirements of the Clean Water Act to avoid impacts to surface waters
and aquatic habitats from any acute or chronic hazards associated with power production byproducts.
To the extent practicable for piping remaining streams for any needed road crossings, culverts 48"
diameter or larger should be buried a foot into the streambed. Culverts less than 48" diameter should
be buried to a depth equal to or greater than 20% their size to allow for aquatic life passage. These
measurements should be based on natural thalweg depths. Aquatic life passage should be assured
during low flow or drought conditions. Any riprap used should not interfere with aquatic life
movement during low flows. If any concrete will be used, work should be accomplished so that wet
concrete does not contact jurisdictional waters.
Craig Road Landfill Expansion Page 3 July 22, 2011
Any relocated streams and remaining jurisdictional waters (including wetlands) on the site should be
buffered through protection or provision of undisturbed herbaceous or forested buffer zones. Buffers
should be permanently preserved as contiguous habitats whenever practicable. For streams that do not
support federally listed threatened or endangered aquatic species, we recommend 50' intermittent and
100' perennial stream buffers. Maximum available buffers should be provided to the extent possible.
Disturbed or restored streambanks should be planted with autochthonous (native) plants like silky
dogwood, paw paw, red maple, silky willow, tag alder, black willow, sycamore, river birch, or other
native woody species.
7. Sediment and erosion control measures should adhere to the design standards for the watershed
classification; however, more stringent requirements for sensitive watersheds (15A NCAC 4B .0124)
are preferred. As indicated previously, to the extent practicable, the project should be accomplished in
phases with each phase being completely stabilized before beginning another phase.
8. Only autochthonous (native) plants should be used for site stabilization and reclamation. Duke Energy
should coordinate final site conditions with professional wildlife biologists from this agency
(NCNVRC). It is our understanding that the completed landfill cannot support forested habitats due to
regulatory and environmental protection requirements.
9. Establishment and systematic maintenance of prairie or early succession habitats for the completed
landfill is recommended. This should provide considerable small game and small bird habitats which
have been diminished in the piedmont due to urbanization, clean farming and forestry practices.
Please see planting regimes attached.
10. If practicable, small wetlands (watering holes) or ephemeral pools beneficial to species such as the
American woodcock, rabbits, frogs, salamanders, wild turkey and quail should be dispersed throughout
the surface of each completed phase throughout the landfill. To help reduce elevation of surface water
temperatures, herbaceous buffers should be provided to reduce exposure of these areas to sunlight.
11. Mowing or prescribed burning to maintain prairie or early successional habitats should only occur in
early spring after winter cover needs are diminished and before nesting activities begin.
12. When the landfill sections are completed, Duke Energy should provide the landfill for use as publicly
accessible Game Lands (or Registered Lands) with the NCWRC. This could provide approximately
155 acres of hunting opportunities. If this is not possible, the land should be available for activities
such as bird watching, hiking, etc.
Thank you for the opportunity to review and comment on this project during the early planning stages. Again,
please note that biologists with this agency are available for site evaluations and habitat consultations. If you have
any questions regarding these comments, please contact me at 336-769-9453.
Attachment: Recommendations of Piedmont Prairie Restoration and Creation
Seed Mixes for Revegetating Disturbed Sites
E-copy: Ian McMillan, NCDWQ
Hugh Jernigan, NCDSW
Allan Ratzlaff. USFWS-ARO
Chris Kreh, Kin Hodges, NCWRC
Craig Road Landfill Expansion Page 4 July 22, 2011
Recommendations of Piedmont Prairie Restoration and Creation
Laura M. Fogo, Private Lands Biologist, US Fish and Wildlife Service
RESTORATION
If you discover a potential prairie remnant, it is recommended that you reestablish fire into the
ecosystem and thin the site depending on your goals for prairie, savannah, or woodland. Thinning a site
will allow sunlight to reach the forest floor to encourage herbaceous plants to grow. Your native
understory vegetation may already be there and it may not be necessary to plant. See Piedmont Prairies
and a Partnership, to reference associated community types to look for.
CREATION/REESTABLISHMENT OF A NATIVE PRAIRIE
Seed Source: Try to obtain local genotypes of native plant material to reestablish a prairie. I only
recommend buying seed from outside NC if it's a creation project or the local genotypes are not available
or present. There is limited availability of NC grass seed from nursery growers. There are commercial
nurseries that provide local plants and seed. If you have the time and want only local seed sources, it will
take more effort. For large scale restoration, some projects may want to go ahead and purchase seeds. It
is agreed by the partnership to collect local seed from remnant sites and roadside populations for trying to
restore remnant prairies. Planting associated prairie species provides habitat for migratory songbirds and
other early successional wildlife dependant species.
Native Warm Season Grasses (NWSG): Attached are commercial native seed sources and
planting guides to establish NWSG prepared by Bob Glennon, USFWS. He mentions applying fertilizer
the year after it is established. These grasses are fertilized to grow hay (forage) for cows as far as a
productivity production, however, it will encourage undesirable weedy competition. It has been
recommended only to lime according to your soil's needs. These grasses are native and grow on poor
sites anyway and are not used to having good nutrients. I would re-evaluate after a year and
establishment.
Remember that it may take at least two years to see good results on the NWSG. Bob has done a
great job on explaining methods: using a seed drill, calibrations, seeding depths, etc. Follow his
instructions. Ahen planting, drilling is best, but if you cannot, broad cast and run a cultapacker over it.
You can plant the different ones at the same time (except gama) and place them in the appropriate seed
boxes in the no-till drill. You put the fluffy-chaffy ones, big blue, little blue, and Indian grass in the
chaffy seed box and plant 1/4" seed depth. The small box is used for smooth grass seeds like switch grass
and gama. He said to make a separate pass for the gama grass at 1" seed depth.
Planting t_imes: For NWSG, it is recommended, to plant in the fall after Thanksgiving, after the
first killing frost (Oct. 31 Piedmont-Nov. Coast) until the last killing frost in the spring (March 15 on the
coast, April I for most of the state, April 15 in the west). As soon as you have the site prepared, you
might want to plant winter annuals such as winter wheat, barley, and ryegrass grain. Be cautious planting
ryegrass, because it may re-seed and cause competition the next spring. NWSG's require to be pre-
chilled in moist conditions at least two weeks at 40 degrees F (stratification). So November planting is
fine.
There are some exceptions for planting in the spring before May. The exception is if you have not
eradicated all the non-natives or fescue. If you plant in the spring, you run the risk of loosing the new
seedlings to drought. If you plant in the winter, it will give the grasses time to establish a root system to
Craig Road Landfill Expansion Page 5 July 22, 2011
be better prepared for potential dry times in spring or summer. It may be possible to apply herbicide on
fescue in the spring, then plant immediately.
Forbs associated with Piedmont Prairies: Attached is a list of forbs for propagation compiled by
members of the partnership derived from the "Vascular Flora of Piedmont Prairies: Evidence from
Several Prairie Remnants" by Davis, et al. 2002. This document establishes a good baseline of Piedmont
prairie vegetation for reestablishment and identification. Please notify me or Moni Bates, NC Plant
Conservation Program, if you are interested in seed collection and propagation.
Recommended Prairie Mixture: Below is a mixture recommended based on the list mentioned
above for planting five warm season grasses: big blue stem, little blue stem, Indian grass, gama grass and
switch grass (see rates below). When you mix it and add native wildflowers, it will make your project
more diverse and more like a natural prairie community.
For starting over, I recommend planting at 6-8 pounds per acre of the following mixture of NWSG:
1 pound of a switch grass (Panicum virgatum) (Plateau will injure), or
P. anceps = Beaked Panicum, P. clandestinum = Deertongue,
2 pounds of big blue stem
2 pounds of little blue stem
2 pounds of Indian Grass
1 pound of Gama grass (Plateau will injure)
(Note: For forage production, higher rates are recommended).
A mixture that is compatible with Plateau or herbicides with the same chemical:
3 pounds of big blue stem
2 pounds of little blue stem
3 pounds of Indian Grass
For wildflowers: plant 1 pound per acre and mix it with the grass. I picked the following:
Butterfly milkweed, Purple coneflower, Coreopsis lanceolata, Coreopsis tinctoria (annual), Rough
blazing star (Liatris aspera) and black-eyed susan (Rudbeckia hirta).
When developing and customizing a seed mixture, I recommend checking the local county plant
species list (if there is one) and Vascular Plants of the Carolinas for species diversity, as well as
consulting with botanists. The NC Botanical Garden is a good reference and has a native seed source list
of local commercial growers.
Figure 1. Listed rare vascular plant species associated with Piedmont prairies and associated
communities (not all inclusive)
Common Name Scientific Name Status
Schweinitz's sunflower Helianthus schweinitzii Federally Endangered
smooth coneflower Echinacea laevi ata Federally Endangered
Georgia aster Sym hyotrichum eor ianum Federal Species of Concern
Carolina birdfoot-trefoil Lotus helleri Federal Species of Concern
Tall larkspur Delphinium exaltatum Federal Species of Concern
Butner Barbara's buttons Marshallia s 1 Federal Species of Concern
Heller's rabbit tobacco Gna halium helleri Significantly rare-Proposed
Craig Road Landfill Expansion Page 6 July 22, 2011
Carolina thistle Cirsium carolinianus Significantly rare-Proposed
Sessile Tick-trefoil Desmodium sessilifolium Significantly rare-Proposed
Carolina thistle Cirsium carolinianum Significantly rare-Proposed
Thick-pod white wild indigo Baptisia alba Significantly rare-Proposed
Thin-pod white wild indigo Baptisia albescens Significantly rare-Proposed
Smooth sunflower Helianthus laevigatus Significantly rare-Proposed
Earle's blazing star Liatris s uarrulosa Significantly rare-Proposed
Southeastern bold goldenrod Solidago ri ida ss labrata Significantly rare-Proposed
Prairie dock Sil hium terebinthinaceum Significantly rare-Proposed
Glade wild quinine Parthenium auriculatum Significantly rare-Threatened
Figure 2. NC Partners In Flight Priority Bird Species associated with prairie/grassland, shrub-scrub, and
savanna habitats (not all inclusive)
Prairie/Grassland Shrub-scrub Pine savanna
Henslow's sparrow Prairie warbler Red-cockaded woodpecker
Bachman's sparrow American woodcock Bachman's sparrow
Northern bobwhite Northern bobwhite Brown-headed nuthatch
Loggerhead shrike Field sparrow Henslow's sparrow
Short-eared owl (winter, pb) Eastern towhee Northern bobwhite
Barn owl Orchard oriole Summer tanager
Northern harrier (winter) Yellow-breasted chat American kestrel
Grasshopper sparrow Gray catbird Red-headed woodpecker
Eastern kingbird Common yellowthroat Northern flicker
Eastern meadowlark Brown thrasher Chuck will's wido
w

Sedge wren (winter)
White-eyed vireo _
_
Whip-poor-will
Dickcissel Willow flycatcher
Bobolink (migrant, pb) Vesper sparrow (winter)
Horned lark (winter, b) Loggerhead shrike
Barn owl
NC sources are: Garrett Wildflower seed farm 919-818-4309 (Don Lee) www.ernstseed.com Adams
Briscoe & Sharpe Bro. for Americas Indian grass from Georgia. Contact NC Botanical Garden and ask
for their nursery list. Additional North Carolina native prairie plant information may be obtained by
contacting the Mecklenburg County Park and Recreation Department at 704-336-8798 or 704-432-1391.
Craig Road Landfill Expansion Page 7
Seed Mixes for Revegetating Disturbed Sites
Basic Mix
July 22, 2011
Oats (Mar-Jun), Wheat (Jul-Nov), or Rye Grain (Dec-Feb) 1-2 bags / ac $ 5-10 bag
Red Clover Trifolium pratense 10 lbs / acre $ 3 / lb
Creeping Red Fescue Festuca rubra 20 lbs / acre $ 2-3 / lb
-The Basic Mix can be sown on disturbed sites in the mountains and upper piedmont year round but
spring or fall seeding will result in a better stand. It is important to use all of the components of the Basic
Mix. The cover crop grain & legume provide rapid green-up while the creeping red fescue is developing.
These components can be obtained locally.
- Grains like oats, wheat, and rye may be sold by weight (pounds) or by volume (bushels).
To simplify things, this mix recommends 1 - 2 BAGS of grain rather than pounds or bushels. With this
mix, 1 bag or about 50 - 60 lbs per acre should be adequate for most sites, but where slope or soil
conditions warrant, increase grain amounts to 100 - 120 lbs (use 2 bags).
-The perennial grass will establish within the first year and is the key to good site stabilization. Creeping
red fescue has a wide range of adaptation when used for erosion control along roads and highways; cuts,
fills, and other disturbed areas; and for stream and channel bank stabilization. It thrives in sun or shade,
and is drought-resistant after establishment.
For permanent seeding of harsh dry sites, Hard Fescue Festuca 10 lbs /acre $ 3 / lb
brevipila (syn. trachyphylla) can be added to the Basic Mix
Application Notes
- Disturbed sites with loose soils can usually be sown without extensive seedbed preparation if seeded as
soon as the other work is completed.
- Where necessary, prepare seedbed with conventional farm equipment (tractor and disk), or the soil
surface can be bladed and then tracked with a bulldozer. Hydro-seeding can be used with the Basic Mix
for slopes where equipment access is difficult.
- Red fescue is adapted to sandy and acid soils so extensive soil amendments are usually not needed. On
poor and subsoil sites, a low nitrogen fertilizer such as 5-10-10 may be required.
- If required, apply any necessary soil amendments, then drill or broadcast the seed mix.
- The larger cover crop grains can be sown separately first and covered lightly to prevent loss of seed
from wildlife such as turkeys and doves.
-The rest of the seed mix should then be sown, but not covered with soil. It is better to firm the small seed
into the soil than to try to cover it.
- Culti-pack conventional seedbeds to ensure good seed-to-soil contact. Tracked sites will fill in on their
own from rainfall.
Craig Road Landfill Expansion Page 8 July 22, 2011
- Apply straw mulch at a minimum of 15 bales per acre to help enhance soil moisture as well as hold the
soil in place until the seed germinates. Use higher rates as site conditions warrant.
- If the site calls for it, biodegradable natural fiber matting is recommended over plastic matting or
matting that contains strands of plastic that can entrap small animals.
- Monitor the site until the perennial grass component is fully established. Mature stands of the Basic Mix
are short-statured and will not require mowing. The seeded mix should persist for many years, but will
eventually yield to developing successional species in the seed bank.
Adding Native Species
- Some projects specify a preference for native plant species or actually require their use. Native
wildflowers and grasses can be added to the Basic Mix to beautify and diversify the site, and provide food
and cover for wildlife such as wild turkey, bobwhite quail, and songbirds.
- The following table contains native species that are easy, proven performers that have been used
successfully on stream restoration areas as well as dryer upland sites. The first four wildflowers will come
on well the first year; the three grasses may take two to three years to develop good sized clumps.
- These seeds are reasonably priced as natives go and can be ordered from a reputable seed dealer. Using
all seven will provide maximum diversity as well as added site stabilization but any additions will be
beneficial. For sources, refer to Wildlife Seed List at
http://www.ncwildlife.org/Wildlife Species Con/WSC WPM.htm.
- Mixes with native seed can be culti-packed or tracked in with a bulldozer; hydro-seeding is apparently
not recommended. Mixes with mainly wildflowers can be sown in early fall.
Note - when adding native Panicum. grass seed, sow the mix in late fall, winter, or early spring to subject
the seed to cool, moist soil conditions necessary to break seed dormancy. Sowing during the warmer
months may delay Panicum germination, until the following year, and some seed may be lost in the
interim.
- For information on each native species listed here, visit http://plants.usda.gov/; type in the scientific
name in the search box. Note - adding natives will increase the height of the resulting stands, providing
good wildlife habitat. Frequent mowing destroys food & cover and is not recommended. Mow once every
few years, in late winter, only if absolutely necessary to remove encroaching woody vegetation.
Native species - add to Basic Mix at 1-2 lbs / acre
Black Eyed Susan Rudbeckia hirta $ 16 / lb
Showy Partridge Pea Chamaecrista (Cassia) fasiculata $ 14 / lb
Showy Bidens Bidens aristosa $ 16 / lb
Lanced-leaved Coreopsis Coreopsis lanceolata $ 14 / lb
Deertongue Dicanthelium (Panicum) clandestinum `Tioga' $ 12 / lb
Switchgrass Panicum virgatum `Blackwell', `Cave-in-Rock', `Kanlow' $ 8/lb
Big Bluestein Andropogon gerardii $ 10 / lb
NC WRC/2010