20191369 Ver 1_WRC Comments_20191105

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: David Shaeffer
U.S. Army Corps of Engineers
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation Division
DATE: 05 November 2019
SUBJECT: Public Notice for Gaston County Landfill Expansion, Gaston County, North Carolina.
Corps Action ID #: SAW-2018-00053.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
public notice. Our comments are provided in accordance with provisions of the Clean Water Act of 1977
(as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), and
North Carolina General Statutes (G.S. 113-131 et seq.).
Gaston County Department of Public Works proposes to permanently impact 1,881.5 linear feet of
jurisdictional stream channel and 0.40 acre of jurisdictional impoundments associated with the expansion
of an existing landfill located on a 424-acre tract. The purpose of the project is to provide municipal solid
waste capacity to serve growth and development over at least the next 20 years. The proposed mitigation
includes payment to N.C. Division of Mitigation Services.
Unnamed tributaries to the South Fork Catawba River in the Catawba River basin flow through the site.
There are records for the state significantly rare seagreen darter (Etheostoma thalassinum) downstream of
the site.
Should the permit be issued, we offer the following comments and recommendations to minimize impacts
to aquatic and terrestrial wildlife resources.
For any undisturbed streams remaining on the site, establish or maintain a minimum 100-foot
undisturbed, native, forested buffer for perennial streams and a minimum 50-foot undisturbed, native,
forested buffer for intermittent streams and wetlands. Maintaining undisturbed, forested buffers
along these areas will minimize impacts to aquatic and terrestrial wildlife resources, water quality,
and aquatic habitat both within and downstream of the site. In addition, wide riparian buffers are
helpful in maintaining stability of stream banks and for treatment of pollutants associated with
stormwater runoff.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
05 November 2019
Gaston County Landfill
Corps Action ID#: SAW-2018-00053
2. As development in the watershed occurs, the 100-year floodplain elevation may change.
Construction of future phases of the landfill should avoid construction or fill in the 100-year
floodplain. Construction or fill in the floodplain increases the potential for flooding and interferes
with the natural hydrologic process of the waterways. It also disrupts the continuity of migration
corridors for wildlife.
3. Measures should be installed to prevent leachate from entering groundwater or surface waters. We
suggest periodic monitoring for waste pollutants in South Fork Catawba River downstream of the
landfill. If waste pollutants are found downstream, then measures should be implemented to identify
the source and contain the pollutants.
4. Where feasible, stockpile top soils for final site reclamation. However, excavated materials should
not be stockpiled where sediment will erode to surface waters.
5. Consider using native seed mixtures (e.g., native warm season grasses) that are beneficial to wildlife
in the reclamation plan. Specifically, this project would be ideal for planting native, wildflower seed
mixes that will create pollinator habitat within the project boundary. Avoid using Bermudagrass,
redtop, tall fescue, and lespedeza, which are invasive and/or non-native and provide little benefit to
wildlife.
6. Sediment and erosion control measures should be installed prior to any land clearing or construction.
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 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.
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or olivia.munzer(abncwildlife.org.
ec: Sue Homewood, NCDWR