20150994 Ver 3_WRC Comments_20170207

� North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
February 7, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: PSNC Line T-01 Replacement Project Phase II
Polk, Rutherford, and Cleveland Counties
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application for impacts associated with the T-01 Phase II Pipeline Replacement Project, which
include 11,113 ft of temporary and 30 ft of permanent stream impact, as well as 2.4 acres of
temporary and 0.4 acre of permanent wetland impact in Polk, Rutherford, and Cleveland
Counties. Our comments on this application are offered for your consideration under provisions
of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act
(48 Stat. 401, as amended; 16 U.S.C. 661-667d).
PSNC intends to replace 48 miles of gas pipeline in or adjacent to existing easements. Seventy-
seven percent of the line would be within an existing right-of-way (ROW). Twenty-three
percent of the line would be new ROW, most of this in order to avoid the town of Boiling
Springs and the Tryon Equestrian Center. The line crosses multiple streams in Polk, Rutherford,
and Cleveland Counties in the Broad River basin. Wild trout would not be impacted by project
activities, and a trout moratorium is not needed. The line crosses a number of streams with
significant aquatic resources and notable adjacent features, including the following:
1. Green River in Polk County. The Green River hosts the Seagreen Darter [Etheostoma
thalassinum, NC Significantly Rare (SR)] and Carolina Foothills Crayfish (Cambarus johni,
NC SR).
2. Broad River in Rutherford County, which hosts Seagreen Darter (NC SR) and Carolina
Foothills Crayfish (NC SR).
3. Floyds Creek in Rutherford County, which hosts Carolina Foothills Crayfish (NC SR).
4. Sandy Run/Cliffside Natural Area, a designated natural area by the NC Natural Heritage
Program. This natural area roughly follows the boundary of a population of Dwarf -flowered
Heartleaf (Hexastylis naniflora, US and NC Threatened).
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Polk, Rutherford, Cleveland Counties
5. Beaverdam Creek in Cleveland County, which also hosts Carolina Foothills Crayfish (NC
SR).
The pipeline will be installed via trench cut in most wetlands and streams. The Green River,
Broad River, Second Broad River, First Broad River, Buffalo Creek, and Beason Creek will all
be crossed with horizontal directional drilling, avoiding direct channel disturbance. Wetlands
will be crossed with equipment mats, wetland vegetation cut at ground level, and where
practicable, wetland topsoil will be set aside during trenching for replacement afterwards and the
wetland and 10 -ft buffer outside of the wetland replanted with a native wetland seed mix.
Streams will be trenched in the dry, with flows pumped around the work area. The top 6-12
inches of stream substrate will be stockpiled and kept saturated during pipe installation, to be
replaced once the pipe is installed. Banks will be restored to pre -construction contours, and coir
matting and a cover crop and riparian mix applied to the banks. The native riparian mix will also
be planted 50 ft landward from the bank.
The final ROW will be 50 ft wide. However, the proposed construction corridor is 95 to 110 ft
in upland areas and 80 ft in stream and wetland areas in order to allow adequate space for the
pipe replacement. A 50 -ft workspace was required for Phase I of the PSNC T-01 pipeline
replacement project, and it is unclear why an 80 -ft width of stream/wetland impact is needed to
install a 24 -inch pipe.
In addition, the stream impact table names 11,113 ft of temporary impact, and each specific
impact ranges from 8 to 367 ft, with many greater than 80 feet in width. We understand that
some crossings will not be perpendicular and will require additional width of stream. It appears,
however, that the temporary impact length accounts for the entire length of the stream that is in
the construction corridor, and a majority of the `impact length' may only be riparian clearing and
soil disturbance, not actual channel disturbance. Therefore, the length of actual channel
disturbance is unclear.
In our April 20, 2016 comments, we recommended that fescue -based seed mixtures be avoided,
as fescue is invasive and provides little benefit to wildlife; the permanent upland seeding
specifications provided for this project are Tall Fescue -based. We strongly recommend that
PSNC use native grasses and herbaceous plants in their permanent seeding specifications. The
US Fish and Wildlife Service (USFWS) urged PSNC to incorporate pollinator species into their
plantings and provided specific planting recommendations. More utility line projects are
incorporating native pollinators into their plantings; for example, the Atlantic Coast Pipeline has
proposed regionally tailored native seed mixes that incorporate pollinator species (see
https://www.dom.com/about-us/news-center/natural- _gas-projects-and-initiatives/atlantic-coast-
pipeline/ferc-filings-and-information). NCWRC can work with the USFWS and PSNC to
customize a seed mix for the project.
We offer the following recommendations to minimize impacts to terrestrial and aquatic wildlife:
1. Avoid equipment maintenance in the immediate vicinity of streams, make stream
crossings as narrow as possible, minimize stream bank disturbance, avoid spraying of
herbicides, and cut woody vegetation so that stumps can resprout.
2. Sediment and erosion controls measures should be installed prior to any land clearing or

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Polk, Rutherford, Cleveland Counties
construction. These measures should be routinely inspected and properly maintained.
Excessive silt and sediment loads can have numerous detrimental effects on aquatic
resources including destruction of spawning habitat, suffocation of eggs, and clogging of
gills of aquatic species.
3. Matting used for stabilization should be free of nylon or plastic mesh, as this mesh
netting frequently entangles wildlife and is slow to degrade resulting in a hazard that may
last for years.
4. Any ROW vegetation maintenance work should generally be avoided between April 1
and October 1 to minimize impacts to ground nesting birds.
5. Where feasible, work within the existing easement to minimize impacts to terrestrial
wildlife habitat. Avoid the removal of large trees at the edges of easement corridors. Use
woody debris and logs from any corridor clearing to establish brush piles and downed
logs adjacent to the cleared right-of-way to improve habitat for wildlife.
6. Re -seed all disturbed areas with seed mixtures that are beneficial to wildlife; avoid fescue
based mixtures because fescue is invasive and provides little benefit to wildlife. Native
mixes of grasses and herbaceous plants that emphasize pollinator species are
recommended. Allowing the corridor area to re -vegetate into a brush/scrub habitat would
maximize benefits to wildlife. For areas adjacent to residential areas, a native shrub/grass
option may be beneficial.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Ec: Olivia Munzer, NCWRC
Bryan Tompkins, US Fish and Wildlife Service
Andrew Moore, NC Division of Water Resources
Joey Lawler, S&ME