20191283 Ver 1_WRC Comments_20191014

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
14 October 2019
Mr. David Hamilton
Arcadis G&M of North Carolina
7029 Albert Pick Road, Suite 101
Greensboro, North Carolina 27409
SUBJECT: Pre -Construction Notification for the Birch Creek Sewer Improvements Phases I & II,
Greensboro, Guilford County, North Carolina. DEQ No. 20191283.
Dear Mr. Hamilton,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of the City of Greensboro, Arcadis has submitted a Pre -Construction Notification (PCN)
application for the Birch Creek Sewer Improvements Phase I and II to be located near the intersection of
Birch Creek Road and U.S. Highway 70 in Greensboro, Guilford County, North Carolina. The site
consists of undeveloped, wooded lands and wetlands, rural residential land, agricultural land, and existing
rights -of -way (ROW).
The sewer line will cross unnamed tributaries to Little Alamance Creek and wetlands. The proposed
project would permanently impact 0.512 acres of wetlands and 80 linear feet (If) of streams, and
temporarily impact 1551f of streams for the installation of the sewer line. Little Alamance Creek is
classified as a Water Supply IV and Nutrient Sensitive Waters by the NC Division of Water Resources
(NCDWR).
We have records of the state special concern Greensboro burrowing crayfish (Cambarus catagius) adjacent to
the site. The full extent of this crayfish's distribution in this watershed is unknown due to lack of targeted
surveys. 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
United States Fish and Wildlife Service (USFWS) lists the federally and state endangered Schweinitz's
sunflower (Helianthus schweinitzii) and federally threatened small whorled pogonia (Isotria medeoloides) as
having potential to occur within the site if suitable habitat is present. The lack of records from the project
area does not imply or confirm the absence of federal or state -listed species. An on -site survey is the only
definitive means to determine if the proposed project would impact rare, threatened, or endangered species.
Guilford County Open Spaces occur near the site.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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NCDEQ Number: 20191283
We offer the applicant the following recommendations to minimize impacts to aquatic and terrestrial
wildlife resources.
1. We request site inspections for the Greensboro burrowing crayfish. We have included an
information sheet on preliminary site inspections for this species. Please notify Brena Jones, Central
Aquatic Wildlife Diversity Coordinator ([e-mail], 919-707-0369), if any potential
Greensboro burrowing crayfish or burrows are located.
2. Sewer lines should be installed in existing ROW (e.g., roadways) where feasible. If sewer lines
are installed adjacent to stream channels, then a minimum 100-foot setback for perennial streams
and a 50-foot setback for intermittent streams and wetlands should be maintained between the
stream bank or wetland and the sewer line. New sewer lines that parallel existing sewer lines that
are within the minimum setbacks listed above should be installed upslope (away from the stream)
of the existing sewer line and constructed of ductile iron or other substance of equal durability.
Manholes or similar access structures should not be allowed within buffer areas or in wetlands.
We are pleased to see that horizontal boring and jacking will be used when feasible. However, if
directional boring cannot be used on all streams and trenching is determined to be the only viable
method, every effort should be made to ensure that impacts to in -stream features are minimized
and stable upon completion of the project. Open -trench crossings have been found to increase the
likelihood for future lateral movement of the stream (which could undercut or erode around the
utility line), and the correction of such problems could result in costly future maintenance and
devastating impacts to natural resources. Therefore, as much work as possible should be
accomplished in the dry, and the amount of disturbance should not exceed what can be
successfully stabilized by the end of the workday. In -stream work should consider forecasted
high -flow events.
4. Stream crossings should be near perpendicular (75' to 105°) to stream flow and should be
monitored at least every three months for maintenance needs during the first 24 months and then
annually thereafter. Sewer lines associated with crossing areas should be maintained and
operated at all times to prevent the discharge to land or surface waters.
5. Pesticides, fertilizers, and other chemicals should not be used in wetland areas or near streams.
Pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed
landscapes can adversely affect and extirpate species downstream.
6. All mechanized equipment operated near surface waters should be inspected and maintained
regularly to prevent contamination from fuels, lubricants, hydraulic fluids or other toxic
materials.
7. Avoid the removal of large trees at the edges of construction corridors. Due to the decline in bat
populations, avoid tree clearing activities during the maternity roosting season for bats (May 15 —
August 15). Minimize corridor maintenance and prohibit mowing between April 1 and October 1
to minimize impacts to nesting wildlife.
8. The applicant should consider using native seed mixtures and plants, including pollinator species,
that are beneficial to wildlife for revegetating disturbed areas. Avoid using redtop, tall fescue,
and lespedeza, which are invasive and/or non-native and provide little benefit to wildlife.
Consider an alternative mix of red clover, creeping red fescue, and a grain, such as oats, wheat, or
rye. Please contact NCWRC for a list of suitable native plants.
9. Sediment and erosion control measures should use advanced methods and installed prior to any
land -disturbing activity. The use of biodegradable and wildlife -friendly sediment and erosion
control devices is strongly recommended. Silt fencing, fiber rolls and/or other products should
have loose -weave netting that is made of natural fiber materials with movable joints between the

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Birch Creek Sewer Line Improvements
NCDEQ Number: 20191283
vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. 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.
Specifically, we have concerns for the secondary and cumulative impacts from the project on rare,
threatened, and endangered species resulting from future population growth, increase in impervious
surface, and water demand. We recommend the City of Greensboro consider green planning, which
allows for growth while conserving wildlife and natural resources. The NCWRC Green Growth Toolbox
program provides technical guidance, habitat conservation recommendations, and datasets to assist
communities in green planning
(hllp://www.ncwildlife.org/Conservin /g Programs/GreenGrowthToolbox.aspx).
Thank you for the opportunity to provide input for this project. If I can provide further assistance, please
call [phone] or email olivia.munzerkncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature Cited
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.
ec: Sue Homewood, N.C. Division of Water Resources
John Ellis, U.S. Fish and Wildlife Service
David Bailey, U.S. Army Corps of Engineers
Brena Jones, NCWRC
City of Greensboro, Jay Guffey