20191706 Ver 1_USFWS Letter Signed Line 470 Phase 1_20191212

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2� United States Department of the Interior
FISH AND WILDLIFE SERVICE
�gRCH 3 �aA9 Asheville Field Office
I �F
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801
August 7, 2019
Mr. Christopher Kul
Environmental Scientist- Kleinfelder
8933 Western Way, Suite 12
Jacksonville, Florida 32256
Dear Mr. Kul:
Subject: Federally Listed Species Assessment, Piedmont Natural Gas (PNG) Proposed Phase I
of Line 470 Natural Gas Pipeline Replacement Project, in Mecklenburg County,
North Carolina
Dear Mr. Kul:
On July 16, 2019, we received (via e-mail) a copy of your letter requesting our review and
comments on the subject project. We have reviewed the information you presented and are
providing the following comments in accordance with the provisions of the National
Environmental Policy Act (42 U.S.C.§4321 et seq.) (NEPA); the Fish and Wildlife Coordination
Act, as amended (16 U.S.C. 661667e), and section 7 of the Endangered Species Act of 1973, as
amended (16 U.S.C. 15311543) (Act).
According to the information that you presented, PNG is proposing to replace about 2.63-miles of
the existing Line 372 with a 20-inch gas steel transmission pipeline. Replacement of the existing
pipeline will require the clearing of a 65-feet to 80-feet wide construction corridor. After
construction, a 35-feet to 50-feet wide permanent maintenance easement will be maintained. The
remaining temporary construction corridor will be allowed to regenerate naturally. The project
area/proposed corridor for the pipeline is public and privately owned lands consisting of urban
developed areas, and forested areas. The entire project areas is adjacent to Coffey Creek and
appears to cross multiple wetlands and un-named tributaries to Coffey Creek. Your letter did not
include specific information regarding impacts to aquatic resources. The purpose for the pipeline
replacement is to increase system capacity and ensure pipeline integrity.
Federally Listed Species The project site contains suitable summer maternity roosting habitat
for northern long-eared bat (Myotis septentrionalis) which is currently federally listed as a
threatened species. Though the project site contains suitable summer maternity roosting habitat
for northern long-eared bat, we concur with your conclusion that no known hibernacula occurs

Mr. Kul - Kleinfelder
within '/4-mile of the site and no known summer roost trees occur within 150-feet of the site. The
nearest known record for this species is about 50-miles from the project site. According to the
new 4(d) rule implemented for the listing of northern long-eared bat, a cutting moratorium of
June 1-July 31 is recommended within areas of habitat for this species. Because: 1) the project
site is over 50-miles away from the nearest known occurrence; and 2) there is a large amount of
suitable habitat in close proximity to the site and in the surrounding area, we believe any take
associated with this project is discountable and a "may affect — but not likely to adversely affect"
determination is appropriate for this project. We recommend the. cutting moratorium of June 1-
July 31 be implemented into the plans if possible. Though a "not likely to adversely affect"
determination would not be dependent on this action, the cutting moratorium is a measure that
can be implemented to further reduce the probability of "take" of this species. Further, we do
not believe the project will adversely affect any other federally listed species that are known to
occur in Mecklenburg County. Therefore, we believe the requirements under section 7 of the
Act are fulfilled. However, obligations under section 7 of the Act must be reconsidered if: (1)
new information reveals impacts of this identified action that may affect listed species or critical
habitat in a manner not previously considered, (2) this action is subsequently modified in a
manner that was not considered in this review, or (3) a new species is listed or critical habitat is
determined that may be affected by the identified action.
Utility Line Crossings - In the interest of reducing impacts to natural resources, utility crossings
(i.e., sewer, gas, and water lines) should be kept to a minimum, and all utility infrastructure
(including manholes) should be kept out of riparian buffer areas. We recommend that PSNC
assess every stream and wetland crossing associated with the project for HDD installation.
If directional boring cannot be used and trenching is determined to be the only viable method,
every effort should be made to ensure that impacts to instream features are minimized and stable
upon completion of the project. Our past experiences with opentrench crossings indicate that
this technique increases 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. Instream work should
avoid the spring fishspawning season and should consider forecasted highflow events.
Regardless of the crossing method, all utility lines should cross streams perpendicularly. We
strongly encourage that a qualified biologist monitor the work area until the work is complete in
order to identify any additional onsite impactminimization measures. The Service may be
available to assist you in this effort. To determine if any maintenance is required, the work site
should be monitored at least every 3 months during the first 24 months and annually thereafter.
Moreover, we recommend the development of a riparian monitoring and maintenance program
that would outline procedures for the prompt stabilization of streambanks near the utility
crossing (should any streambank erosion or destabilization occur) throughout the life of this
project.
Project Recommendations - We are concerned about the introduction and spread of invasive
exotic species in association with the proposed project. Without active management, including
the revegetation of disturbed areas with native species, project corridors will likely be sources of
(and corridors for) the movement of invasive exotic plant species. Exotic species are a major
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Mr. Kul - Kleinfelder
contributor to species depletion and extinction; second only to habitat loss. Exotics are a factor
contributing to the endangered or threatened status of more than 40 percent of the animals and
plants on the Federal List of Endangered and Threatened Wildlife and Plants.' It is estimated
that at least 4,000 exotic plant species and 2,300 exotic animal species are now established in the
United States, costing more than $130 billion a year to control.2 Additionally, the
U.S. Government has many programs and laws in place to combat invasive species (see
www. invasivespecies.gov). Specifically, Section 2(a)(3) of Executive Order 13112 - Invasive
Species (February 3, 1999) directs federal agencies to "not authorize, fund, or carry out actions
that it believes are likely to cause or promote the introduction or spread of invasive species in the
United States or elsewhere." Despite their short-term erosion -control benefits, many exotic
species used in soil stabilization seed mixes are persistent once they are established, thereby
preventing the reestablishment of native vegetation. Many of these exotic plants are also
aggressive invaders of nearby natural areas, where they are capable of displacing
already -established native species. Therefore, we strongly recommend that only species native
to the natural communities within the project area be used in association with all aspects of this
prof ect.
We also recommend that seeds for native plants that are beneficial to pollinators be included in
the seed mixes. Pollinators, such as most bees, some birds and bats, or other insects, including
moths and butterflies, play a crucial role in the reproduction of flowering plants and in the
production of most fruits and vegetables. Over 75 percent of flowering plants and about
75 percent of crops are pollinated by these pollinators.. A recent study of the status of pollinators
in North America by the National Academy of Sciences found that populations of honey bees
(which are not native to North America) and many wild pollinators are declining. Declines in
wild pollinators area result of loss, degradation, and fragmentation of habitat and disease; while
declines in honey bees has also been linked to disease. Because loss of habitat and diminished
native food sources have decreased the populations and diversity of pollinators throughout the
country, we recommend that development projects be sited in areas that are previously disturbed
(fallow fields, closed industrial sites, etc.) or sites that do not impact mature forests, streams, or
wetlands. To offset the overall impacts of development and/or to increase the habitat and species
diversity within the project area, we further recommend the following measures be implemented
into project design:
1. Throughout the site, sow native seed mixes with plant species that are beneficial to
pollinators. Taller -growing pollinator plant species should be planted around the
periphery of the site and anywhere on the site where mowing can be restricted during
the summer months. Taller plants, not mowed during the summer, would provide
benefits to pollinators, habitat to ground-nesting/feeding birds, and cover for small
mammals. Low-growing/groundcover native species should be planted in areas that
need to be maintained. This would provide benefits to pollinators while also
1D.S. Wilcove, D. Rothstein, J. Dubow, A. Phillips, and E.,Losos. 1998. Quantifying threats to imperiled species in
the United States. BioScience 48:607-615.
ID. Pimentel, L. Lach, R. Zuniga, and D. Morrison. 2000. Environmental and economic costs of nonindigenous
species in the United States. BioScience 50:53-65.
ILists of invasive exotic plants can be found at http://www.tneppc.org/and http://www. invasive. org/eastern/srs/
(exotic wildlife links) on the Internet.

Mr. Kul - Kleinfelder
minimizing the amount of maintenance, such as mowing and herbicide treatment.
Using a seed mix that includes milkweed species (milkweed is an important host plant
for monarch butterflies) is especially beneficial.
Additional information regarding plant species, seed mixes, and pollinator habitat
requirements can be provided upon request. Attachment 1 and Attachment 2 of this
letter includes a sample upland and riparian seed mix that can be used in conjunction
with a fast growing erosion control seed mix for overall soil stability and pollinator
benefits.
2. Implement a mowing and maintenance program that restricts mowing during the
summer months. Mowing at the site should be restricted to the smallest area possible
to manage the edges of the easement for early successional habitat. We recommend
that PNG evaluate its maintenance plan to target ecological/habitat benefits to other
wildlife species, especially pollinators and birds that require early successional
habitats. One of the best ways to accomplish this objective is to use Integrated
Vegetation Management (IVM) practice using low -volume herbicide applications
when planning management activities. Pollinator nest sites in ROWS managed with
IVM practices have been found to contain about 30% more pollinator nesting sites and
species richness than traditionally mowed maintenance areas. Aside from removing
problem vegetation, the primary focus should be placed on establishing compact
flowering shrubs and managing for native grasses and wildflowers. The overall
objective is to reach a sustainable level of grasses, forbs, and flowering shrubs
(wherever feasible) throughout the project area.
3. Provide nesting sites for pollinator species. Different pollinators have different
needs for nesting sites. Therefore, we recommend maintaining the utility right-of-way
to support a diverse array of habitats to accommodate varied pollinators, from
hummingbirds to butterflies to bees. Hummingbirds typically nest in trees or shrubs
while many butterflies lay eggs on specific host plants. Most bees nest in the ground
and in wood or dry plant stems. For additional information and actions that can be
taken to benefit pollinators please visit the following Web site:
http: //Www.f,vs.gov/pollinators/pollinatorpages/yourhelp. html.
We appreciate the opportunity to provide these comments. If we can be of assistance or if you
have any questions, please contact Mr. Bryan Tompkins of our staff at 828/258-3939, Ext. 240.
In any future correspondence concerning this project, please reference our Log Number
4-2-19-306.
Sincerely,
Jnet �Mizz2i
Field Supervisor
Ld

Mr. Kul - Kleinfelder
Field Supervisor
Attachment 1— Sample Upland Meadow Seed Mix for NC Piedmont
This is an example upland pollinator seed mix that is suitable for the project site. This list is not
an all-inclusive list nor does a pollinator planting project need to include all of these species. I
can help to customize a seed mix for the project area which could decrease costs if requested.
20% Indiangrass, NC Ecotype (Sorghastrum nutans, NC Ecotype)
18% Beaked Panicgrass, SC Ecotype (Panicum anceps, SC Ecotype)
14% Little Bluestein, Piedmont NC Ecotype (Schizachyrium scoparium, Piedmont NC
Eco e
10% Virginia Wildrye, PA Ecotype (Elymus virginicus, PA Ecotype)
6% Purpletop Southeastern VA Ecotype (Tridens flavus, Southeastern VA Ecotype)
3% Bigtop Lovegrass, VA Ecotype (Eragrostis hirsuta, VA Ecotype)
3% Blackeyed Susan, Coastal Plain NC Ecotype (Rudbeckia hirta, Coastal Plain NC
Ecotype)
2.5% Sensitive Pea, NC Ecotype (Chamaecrista nictitans, NC Ecotype)
2% Lanceleaf Coreopsis Coastal Plain NC Ecotype (Coreopsis lanceolata, Coastal Plain
NC Ecotype)
2% Spiked Wild Indigo, NC Ecotype (Baptisia albescens, NC Ecotype)
2% Winter Bentgrass, NC Ecotype (Agrostis hyemalis, NC Ecotype)
2% Slender Bushclover, VA Ecotype (Lespedeza virginica, VA Ecotype)
2% Scaly Blazing Star, VA Ecotype (Liatris squarrosa, VA Ecotype)
2% Appalachian Beardtongue, SC Ecotype (Penstemon laevigatus, SC Ecotype)
2% Wild Quinine NC Ecotype (Parthenium integrifolium, NC Ecotype)
2% Slender Indiangrass, NC Ecotype (Sorghastrum elliottii, NC Ecotype)
1% Grassleaf Blazing Star NC Ecotype (Liatris graminifolia (L. pilosa), NC Ecotype)
1% Mistflower, VA Ecotype (Eupatorium coelestinum (Conoclinium c.), VA Ecotype)
1% Splitbeard Bluestein, VA Ecotype (Andropogon ternarius, VA Ecotype)
1% Spotted Beebalm Coastal Plain SC Ecotype (Monarda punctata, Coastal Plain SC
Ecotype)
1% Orange Coneflower, Northern VA Ecotype (Rudbeckia fulgida var. f ilgida, Northern
VA Ecotype)
0.5% Late Purple Aster, NC Ecotype (Aster patens, NC Ecotype)
0.5% Wild Indigo Coastal Plain SC Ecotype (Baptisia tinctoria, Coastal Plain SC
Ecotype)
0.5% Anise Goldenrod, GA Ecotype (Solidago odora, GA Ecotype)
0.5% Gray Goldenrod, VA Ecotype (Solidago nemoralis, VA Ecotype)
0.5% Swamp (Narrowleaf) Sunflower, Coastal Plain NC Ecotype (Helianthus
angustifolius, Coastal Plain NC Ecotype)
Total: 100%
5

Mr. Kul - Kleinfelder
Attachment 2 — Sample Riparian Area Seed Mix
• Agrostis perennans
Autumn bentgrass
11%
• Andropogon gerardii
Big Bluestein
7%
• Elymus canadensis
Canada wild rye
2%
• Elymus virginicus
Virginia wild rye
15%
• Juncus effusus
Soft Rush
4%
• Panicum virgatum
Switchgrass
11 %
• Schizachyrium
scoparium
Little Bluestein
5%
• Sorghastrum nutans
Indiangrass
6%
• Tridens flavus
Purple top
1%
• Tripsacum dactyloides
Eastern Gamagrass
6%
• Achillea millefolium
Common yarrow
3%
• Asclepias tuberosa
Butterfly weed
1%
• Bidens aristosa
Bidens
3%
• Chamaecrista fasciculata
Partridge pea
2%
• Coreopsis lanceolata
Lanceleaf Coreopsis
7%
• Echinacea purpurea
Cone flower
1%
• Gaillardia pulchella
Indian blanket
2%
• Helianthus angustifolius
Swamp sunflower
1%
• Helianthus maximilianii
Maximilian's sunflower
1%
• Monarda punctata
Spotted beebalm
1 %
• Rudbeckia hirta
Blackeyed Susan
7%
• Senna hebecarpa
Wild senna
1%
• Symphyotrichum
pilosum
Heather aster
1%
• Verbena hastata
Blue vervain.
1%
Total 100%