20200155 Ver 1_PCN Form Submission_20200127

DWR
mrlslon of Water Resources
Pre -Construction Notification (PCN) Form
September 29, 2018 Ver 3
Initial Review
Has this project met the requirements for acceptance in to the review process?*
r Yes
r No
Is this project a public transportation project?*
G Yes r No
Change only if needed.
BIMS # Assigned
20200155
Is a payment required for this project?*
r No payment required
r Fee received
r Fee needed - send electronic notification
Reviewing Office *
Asheville Regional Office - [phone]
Information for Initial Review
1a. Name of project:
Ashworth Road Shooting Range
1a. Who is the Primary Contact?*
Steven Bailey
1b. Primary Contact Email:*
[e-mail]
Date Submitted
1 /27/2020
Nearest Body of Water
North Muddy Creek
Basin
Catawba
Water Classification
C
Site Coordinates
Latitude:
35.63232
A. Processing Information
County (or Counties) where the project is located:
McDowell
Is this project a public transportation project?*
r Yes r No
Longitude:
-82.00588
1a. Type(s) of approval sought from the Corps:
W Section 404 Permit (wetlands, streams and waters, Clean Water Act)
r Section 10 Permit (navigable waters, tidal waters, Rivers and Harbors Act)
1b. What type(s) of permit(s) do you wish to seek authorization?
* Nationwide Permit (NWP)
* Regional General Permit (RGP)
7 Standard (IP)
Version#*
1
What amout is owed?*
IT $240.00
r $570.00
Select Project Reviewer*
Amy Annino:eads\amannino
1c. Primary Contact Phone:*
[phone]
L.1

1c. Has the NWP or GP number been verified by the Corps?
r Yes r No
Nationwide Permit (NWP) Number:
NWP Numbers (for multiple NWPS):
1d. Type(s) of approval sought from the DWR:
W 401 Water Quality Certification - Regular
r Non-404 Jurisdictional General Permit
r Individual Permit
39 - Commercial/Institutional Developments
le. Is this notification solely for the record because written approval is not required?
For the record only for DWR401 Certification:
For the record only for Corps Permit:
F 401 Water Quality Certification - E)press
F Riparian Buffer Authorization
1f. Is this an after -the -fact permit application?*
r Yes IT No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
r Yes r No
1g. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
r Yes r No
Acceptance Letter Attachment
1h. lathe project located in any of NC's twenty coastal counties?
r Yes r No
1j. Is the project located in a designated trout watershed?
r Yes IT No
B. Applicant Information
1d. Who is applying for the permit?
r Owner W Applicant (other than owner)
le. Is there an Agent/Consultant for this project?*
r Yes r No
2. Owner Information
2a. Name(s) on recorded deed:
County of McDowell
2b. Deed book and page no.:
DB 825 PG 736
2c. Responsible party:
2d.Address
Street Address
100 Spaulding Road, Suite 1
Address Line 2
aty
Marion
Postal / Zip Cate
28752
2e. Telephone Number:
[phone]
2g. Email Address:*
[e-mail]
3. Applicant Information (if different from owner)
State / Province / Region
NC
Country
USA
2f. Fax Number:
r Yes r No
r Yes r No
3a. Name:
North Carolina Wildlife Resources Commission

3b. Business Name:
3c.Address
Street Address
1718 NC 56
Address Line 2
City
State / Province / legion
Creedmoor
NC
Postal / Zip Code
Country
27522
USA
3d. Telephone Number:
3e. Fax Number:
[phone]
3f. Email Address:*
[e-mail]
4. Agent/Consultant (if applicable)
4a. Name:
Steven Bailey
4b. Business Name:
North Carolina Wildlife Resources Commission
4c.Address
Street Address
1718 NC 56
Address Une 2
City
State / Province / legion
Creedmoor
NC
Postal / Zip Code
Country
27522
USA
4d. Telephone Number: 4e. Fax Number:
[phone]
4f. Email Address:*
[e-mail]
Agent Authorization Letter*
McDowell Agent.pdf 27.24KB
C. Project Information and Prior Project History
C^U
1. Project Information
1b. Subdivision name:
(if appropriate)
1c. Nearest municipality/ town:
Marion
2. Project Identification
2a. Property Identification Number:
2b. Property size:
160900579508
267
2c. Project Address
Street Address
Ashworth Road
Address Line 2
City
State / Province / Region
Marion
NC
Postal / Zip lode
Country
28752
3. Surface Waters
3a. Name of the nearest body of water to proposed project:
North Muddy Creek
3b. Water Resources Classification of nearest receiving water:*
C

3c. What river basin(s) is your project located in?*
Catawba
3d. Please provide the 12-digit HUC in which the project is located.
030501010601
4. Project Description and History
4a. Describe the existing conditions on the site and the general land use in the vicinityof the project at the time of this application:*
The McDowell County property is currently forest with a small portion of the tract being part of the Muddy Creek Flood Impoundment 2C. The site is accessed from Ashworth Road via a
60' right of way that was deeded to the County with the property. There is an existing soil drive Within the right of way but it is not passable due to a washed out culvert adjacent to 1-40
and a washed out bridge crossing Muddy Creek at the County property line. The right of way is the legal access route that the County has to access the property. Interstate 40 lies to
the north of the property. Wooded land lies to the vast and south. On the east is some wooded land, the Muddy Creek 2C impoundment, a church, and parcel that is partly cleared.
4b. Have Corps permits or DWR certifications been obtained for this project (including all prior phases) in the past?*
r Yes r No r Unknown
4d. Attach an 8 1/2 X 11 excerpt from the most recent version of the USGS topographic map indicating the location of the project site. (for DWR)
USGS West Marion.pdf
4.68MB
4e. Attach an 8 1/2 X 11 excerpt from the most recent version of the published County NRCS Soil Survey map depicting the project site. (for DWR)
Ashworth Soils Map.pdf 1.23MB
4f. List the total estimated acreage of all existing wetlands on the property:
4g. List the total estimated linear feet of all existing streams on the property:
4000
4h. Explain the purpose of the proposed project:*
McDowell County and the NC Wildlife Resources Commission plan to construct a public shooting range on a parcel of land owned by the County off of Ashworth Road. The site is
planned to be accessed via a road constructed within a 60' right-of-way granted to the County. The right-of-way is the only legal access the County has to the property. There is an
existing soil road within the right-of-way. The proposed range area is upland and will not impact any streams or wetland. The access road will impact two streams and a wetland area.
One stream impact will be to replace a 30" metal culvert that we blown out in recent storms. The culvert crossing will be lengthened to allow for a two lane road and to allow the road
elevation to be raised. The second stream impact is where the road crosses North Muddy Creek. There is a bridge at this location but one abutment of the bridge failed and caused the
bridge to collapse. The stream will be temporarily impacted to allow construction access to the far bank of the creek to construct a new bridge. A wetland adjacent to the road at the
bridge will be filled to allow the road elevation to be raised.
41. Describe the overall project in detail, including indirect impacts and the type of equipment to be used:*
An excavator will be used to excavate for and install a 96" corrugated aluminum pipe culvert with headwalls. Dump trucks, bulldozers and excavators will be used to backfill the culvert
and place rip rap on the slopes of the fill. Silt fence will be installed around the disturbed areas.
At North Muddy Creek, an excavator will be used to remove the existing bridge. The excavator install temporary culverts in the creek and backfill to create a construction access to the
south side of the creek. Excavators and pile driving equipment will be used to construct the end bents and wing walls for the new bridge. After the end bents and wing walls are
complete, the temporary culverts will be removed. Then the bridge will be set.
4j. Please upload project drawings for the proposed project.
Ashworth wetland draWngs.pdf 4.14MB
5. Jurisdictional Determinations
5a. Have the wetlands or streams been delineated on the property or proposed impact areas?*
r Yes
Comments:
SAW-2018-1117
r No
5b. If the Corps made a jurisdictional determination, what type of determination was made?*
r Preliminary r Approved r Not Verified r Unknown r N/A
Corps AID Number:
SAW-2018-1117
5c. If 5a is yes, who delineated the jurisdictional areas?
Name (if known): Kevin Ferguson
Agency/Consultant Company: ECS
Other:
r Unknown
5d. List the dates of the Corp jurisdiction determination or State determination if a determination was made bythe Corps or DWR
5d1. Jurisdictional determination upload
McDowell USACE PJD.pdf
850.05KB
6. Future Project Plans

6a. Is this a phased project?*
r Yes r No
Are anyother NWP(s), regional general permit(s), or individual permits(s) used, or intended to be used, to authorize any part of the proposed projector related activity?
There are no other NWP, regional general permits, or individual permits expected to be needed with this project. The access road beyond the North Muddy Creek crossing and the
range site is all on upland land.
D. Proposed Impacts Inventory
1. Impacts Summary
la. Where are the impacts associated with your project? (check all that apply):
W Wetlands W Streams -tributaries r Buffers
r Open Waters r Pond Construction
2. Wetland Impacts
a. Site #*(?) 2a1 Reason (?) 2b. Impact type*(?) 2c. Type of W. 2d. W. name* 2e. Forested* 2f. Type of 2g. Impact
Jurisdicition*(?) area*
n act Area #2 Fill for bridge abutment P Flood lain Pool W1 Yes Both 0.015
P 9 P
(acres)
2g. Total Temporary Wetland Impact
0.000
2g. Total Wetland Impact
0.015
2h. Comments:
3. Stream Impacts
2g. Total Permanent Wetland Impact
0.015
3a. Reason for impact (?)
3b.lmpact type *
3c. Type of impact*
3d. S. name *
3e. Stream Type*
of
3gSwidth *
3h. Impact(?)
[3f.Type
urisdiction*
length*
S1
Impact Area #1 - Road
P
Permanent
Culvert
UT to North Mudd Creek
Y
Perennial
Both
10
33
Crossing - 96" Culvert
Average (feet)
(lirxarfeet)
g2
Impact Area #1 - Road
Temporary
Other
UT to North Muddy Creek
Perennial
Both
10
17
Crossing
Average (feet)
(linearfeet)
S3
Impact - Road
Temporary
Workpad/Causeway
North Muddy Creek
Perennial
Both
t;;Tnearfeet)]_
Crossing ridge
31. Total jurisdictional ditch impact in square feet:
0
3i. Total permanent stream impacts: 3i. Total temporary stream impacts:
33 67
3i. Total stream and ditch impacts:
100
3j. Comments:
There was an existing 24" culvert at Impact Area #1. The location where the culvert was located has not been included in the impacts. Temporary
impacts will be brought back to pre -construction elevations and the stream banks will be stabilized.
E. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing the project:
The proposed access road is being constructed within a right-of-way which is the only legal access to the County parcel. At Impact Area #1, there was
a 24" culvert that was washed out in storms last year. The newculvert crossing will be installed in the same general area. The newculvert will be
downstream from the existing culvert to allowthe road to be centered in the ROW and to keep the fill slopes out of wetland S1 and S2. Headwalls are
used on each end of the 96" culvert to minimize the length and impacts to the wetlands and streams. The proposed road is only 18' wide, the minimum
WRC will consider for twa way traffic. At Impact Area #2 a bridge is proposed to replace the existing bridge. The bridge and road will be raised to an
elevation above the existing bridge to reduce road overtopping. The bridge will be lengthened and will rest on concrete abutments instead of on the
stream bank like the prior bridge. Wingwalls are used on each end of the abutments to reduce impacts. 2:1 fill slopes have been used to minimize the
area of disturbance. Temporary culverts are needed to cross North Muddy Creek to install the abutment on the far side of the creek, as there is no
other access to that side of the creek. A 24" culvert will be installed in the floodplain area to connect the floodplain where an existing culvert will be
removed.
1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques

Silt fence has been used along the sides of the of the impacts to prevent sediment from leaving the site.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State?
r Yes r No
2b. If this project DOES NOT require Compensatory Mitigation, explain why:
Wetland impacts are less than 0.1 acre and stream impacts are less than 150 If.
F. Stormwater Management and Diffuse Flow Plan (required by DWR)
1. Diffuse Flow Plan
1a. Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules?
r Yes r No
If no, explain why:
This site located in the Catawba River basin.
2. Stormwater Management Plan
2a. Is this a NCDOT project subject to compliance with NCDOT's Individual NPDES permit NCS000250?*
r Yes r No
2b. Does this project meet the requirements for low density projects as defined in 15A NCAC 02H .1003(2)?
r Yes r No
Comments:
G. Supplementary Information 6
1. Environmental Documentation
1a. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land?*
r Yes r No
1b. If you answered "yes" to the above, does the project require preparation of an environmental document pursuant to the requirements of the National or State (North Carolina)
Environmental Policy Act (NEPA/SEPA)?*
r Yes r No
Comments:
The site is more than 1 mile from HQW waters, it does not drain to OWR waters or trout waters, and has less than 500' of stream impact.
2. Violations (DWR Requirement)
2a. Is the site in violation of DWR Water Quality Certification Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 211.1300), or DWR Surface Water or Wetland Standards or
Riparian Buffer Rules (15A NCAC 2B .0200)? *
r Yes r No
3. Cumulative Impacts (DWR Requirement)
3a. Will this project result in additional development, which could impact nearby downstream water quality?*
r Yes r No
3b. If you answered "no," provide a short narrative description.
We have reviewed the "Draft Internal Policy, Cumulative impacts and the 401 Water Quality Certification and Isolated Wetlands Programs' document
prepared by the NC Division of Water Quality on April 10, 2004, version 2.1. The draft states that publicly funded developments may or may not result
in cumulative impacts. For instance, the development of a regional, public park or new library is unlikely to result in cumulative impacts. The Ashworth
Road Shooting Range project will be an institutional development and will not result in additional development that could impact downstream water
quality and therefore it is unlikely to result in cumulative impacts. We anticipate that the DWR will advise us if any additional information is needed.
4. Sewage Disposal (DWR Requirement)
4a. Is sewage disposal required by DWR for this project?*
r Yes r Nor WA
4b. Describe, in detail, the treatment methods and dispositions (non -discharge or discharge) of wastewater generated from the proposed project. If the wastewater will be treated
at a treatment plant, list the capacity available at that plant.
We plan to construct an on -site septic (non -discharge) system for restrooms within a range office. The on -site system will be permitted through the
local health department. The area for the ground absorption system and repair areas have not been identified yet. The on -site septic system has not
been designed yet. It will be located in upland areas.

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or habitat?*
r Yes r No
5b. Have you checked with the USFWS concerning Endangered Species Act impacts?*
r Yes r No
5c. If yes, indicate the USFWS Field Office you have contacted.
Asheville
5d. Is another Federal agency involved?*
r Yes r No
5e. Is this a DOT project located within Division's 1-8?
r Yes r No
5f. Will you cut any trees in order to conduct the work in waters of the U.S.?
r Yes r No
5g. Does this project involve bridge maintenance or removal?
r Yes r No
5g(1). If yes, have you inspected the bridge for signs of bat use such as staining, guano, bats, etc.?
r Yes r No
If you answered "Yes" to 5g(1), did you discover any signs of bat use?
r Yes r No r Unknown
5h. Does this project involve the construction/installation of a wind turbine(s)?'
r Yes r No
r Unknown
51. Does this project involve (1) blasting, and/or (2) other percussive activities that will be conducted by machines, such as jackhammers, mechanized pile drivers, etc.?
r Yes r No
If yes, please provide details to include type of percussive activity, purpose, duration, and specific location of this activity on the property.
Pile driving information - Ashworth.pdf 40.26KB
5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat?
ECS Southeast, LLP contacted the Asheville Field Office of the US Fish and Wildlife Office for consultation regarding impact to Endangered Species
and Designated Critical Habitat. A copy of the USFWS letter dated 12/12/2017 is attached.
Consultation Documentation Upload
USFWS response - Ashworth Road Range Site.pdf 106.14KB
NC Natural Heritage Program Letter - Ashworth.pdf 755.32KB
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as an Essential Fish Habitat?*
r Yes r No
6b. What data sources did you use to determine whether your site would impact an Essential Fish Habitat?*
NOAA Essential Fish Habitat (EFH) Mapper
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation status?*
r Yes r No
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?*
Consultation with NC Department of Natural and Cultural Resources - State Historic Preservation Office. Letter Dated December 8, 2017.
7c. Historic or Prehistoric Information Upload
SHPOletter- Ashworth Road.pdf 160.58KB
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain?*
r Yes r No
8b. If yes, explain how project meets FEMA requirements:
No building structures will be built within the 100-year floodplain. The only development activity occurring within the 100-year floodplain will
construction of the access road including fill, installation of culverts and headwalls, and construction of the bridge crossing. The activity within the
floodplain will be permitted by the McDowell County Floodplain Administrator. A no -rise study is being performed for the bridge crossing at this time.
8c. What source(s) did you use to make the floodplain determination?*
Flood Insurance Rate Map #3710160800J Dated 10/2/2008
Miscellaneous v

Comments
Miscellaneous attachments not previously requested.
Signature
® By checking the box and signing below, I certify that:
• I have given true, accurate, and complete information on this form;
• I agree that submission of this PCN form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act');
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act');
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND
• I intend to electronically sign and submit the PCN form.
cull Name:
Steven P. Bailey
Signature
¢— Cam--. 16"Z— Y
Date
1 /27/2020

AgentAuthorizationFormPropertyLegalDescription:LotNo.DeedBook:ParcelID:160900579508736CountyMcDowellStreetAddress:AshworthRoadPropertyOwner:CountyofMcDowellPropertyOwner:Theundersigned,registeredpropertyownersoftheabovenotedproperty,doherebyauthorizeStevenBailey(Contractor/Agent)ofNorthCarolinalWildlifeResourcesCommissiontoactonmybehalfandtakeallactionsnecessaryfortheprocessing,issuanceandacceptanceofthispermitorcertificationandanyandallstandardandspecialconditionsattached.PropertyOwner’sAddress(ifdifferentthanabove):60EastCourtStreet,Marion,NC28752Telephone:[phone]Weherebycertifytheaboveinformationsubmittedinthisapplicationistrueandaccuratetothebestofourknowledge:NameSignaturePlanNo.825Page:/1Name//-ZoMaaayDateDate
Soil Map—McDowell County, North Carolina
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
1/24/2020
Page 1 of 339420003942500394300039435003944000394450039450003942000394250039430003943500394400039445003945000406400406900407400407900408400408900409400409900410400410900411400
406400 406900 407400 407900 408400 408900 409400 409900 410400 410900 411400
35° 38' 46'' N 82° 2' 6'' W35° 38' 46'' N81° 58' 37'' W35° 36' 56'' N
82° 2' 6'' W35° 36' 56'' N
81° 58' 37'' WN
Map projection: Web Mercator Corner coordinates: WGS84 Edge tics: UTM Zone 17N WGS84
0 1000 2000 4000 6000
Feet
0 350 700 1400 2100
Meters
Map Scale: 1:24,000 if printed on A landscape (11" x 8.5") sheet.
MAP LEGEND MAP INFORMATION
Area of Interest (AOI)
Area of Interest (AOI)
Soils
Soil Map Unit Polygons
Soil Map Unit Lines
Soil Map Unit Points
Special Point Features
Blowout
Borrow Pit
Clay Spot
Closed Depression
Gravel Pit
Gravelly Spot
Landfill
Lava Flow
Marsh or swamp
Mine or Quarry
Miscellaneous Water
Perennial Water
Rock Outcrop
Saline Spot
Sandy Spot
Severely Eroded Spot
Sinkhole
Slide or Slip
Sodic Spot
Spoil Area
Stony Spot
Very Stony Spot
Wet Spot
Other
Special Line Features
Water Features
Streams and Canals
Transportation
Rails
Interstate Highways
US Routes
Major Roads
Local Roads
Background
Aerial Photography
The soil surveys that comprise your AOI were mapped at
1:24,000.
Please rely on the bar scale on each map sheet for map
measurements.
Source of Map: Natural Resources Conservation Service
Web Soil Survey URL:
Coordinate System: Web Mercator (EPSG:3857)
Maps from the Web Soil Survey are based on the Web Mercator
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Albers equal-area conic projection, should be used if more
accurate calculations of distance or area are required.
This product is generated from the USDA-NRCS certified data as
of the version date(s) listed below.
Soil Survey Area: McDowell County, North Carolina
Survey Area Data: Version 20, Sep 16, 2019
Soil map units are labeled (as space allows) for map scales
1:50,000 or larger.
Date(s) aerial images were photographed: Dec 2, 2010—Nov 9,
2017
The orthophoto or other base map on which the soil lines were
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor
shifting of map unit boundaries may be evident.
Soil Map—McDowell County, North Carolina
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
1/24/2020
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Ashworth Road Shooting Range 

Driven piles are planned as part of the foundation for the new bridge at Impact Area #2.  The existing 
soils near the ground surface at the bridge are not suitable for a spread footing design.  Piles are needed 
to provide adequate support to the bridge structure. 

We estimate that duration of pile driving will be two weeks or less.  Piles will be driven on both sides of 
the creek, under each abutment. 

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary Susi H. Hamilton Deputy Secretary Kevin Cherry
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

December 8, 2017

Kevin Ferguson [e-mail]
ECS Southeast, LLP
9001 Glenwood Avenue
Raleigh, NC 27617

Re: McDowell Shooting Range, Marion, McDowell County, ECS Project No. 49:5541, ER 17-2903
Dear Mr. Ferguson:
Thank you for your letter of November 20, 2017, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation’s Regulations for Compliance with Section 106 codified at 36
CFR Part 800.

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill-Earley, environmental review coordinator, at 919-807-6579 or
[e-mail]. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,

Ramona M. Bartos

NCNHDE-4878
December 12, 2017
Kevin Ferguson
ECS Southeast, LLP
9001 Glenwood Avenue
Raleigh, NC 27617
RE: McDowell Shooting Range; 49:5541
Dear Kevin Ferguson:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
A query of the NCNHP database, based on the project area mapped with your request, indicates that there are
no records for rare species, important natural communities, natural areas, or conservation/managed areas
within the proposed project boundary, or within a one-mile radius of the project boundary.
Please note that although there may be no documentation of natural heritage elements within or near the project
boundary, it does not imply or confirm their absence; the area may not have been surveyed. The results of this
query should not be substituted for field surveys where suitable habitat exists. In the event that rare species are
found within the project area, please contact the NCNHP so that we may update our records.
Please also note that natural heritage element data are maintained for the purposes of conservation planning,
project review, and scientific research, and are not intended for use as the primary criteria for regulatory
decisions. Information provided by the NCNHP database may not be published without prior written notification
to the NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of
NCNHP data may also not be redistributed without permission.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at [e-mail] or 919.707.8603.
Sincerely,
NC Natural Heritage Program

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801

December 12, 2017

Mr. Kevin Ferguson
Mr. W. Brandon Fulton
ECS Southeast, LLP
4811 Koger Blvd.
Greensboro, North Carolina 27407

Dear Mr. Ferguson and Mr. Fulton:

Subject: Proposed McDowell Shooting Range, Ashworth Road and Interstate 40, Marion,
McDowell County, North Carolina (ECS Project No: 49:5541)

We received your letter of November 20, 2017 (received via email on that same date), requesting
our comments on the subject project. The following comments are provided in accordance with
the provisions of the National Environmental Policy Act (42 U.S.C.§4321 et seq.) and section 7
of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).

Stream and Wetland Buffers – As noted in your letter, there is a perennial stream (North Muddy
Creek) within the project boundary – a permit from the U.S. Army Corps of Engineers may be
necessary to impact this feature. Natural, forested riparian buffers are critical to the health of
aquatic ecosystems. They accomplish the following:

1. catch and filter runoff, thereby helping to prevent nonpoint-source pollutants
from reaching streams;
2. enhance the in-stream processing of both point- and nonpoint-source
pollutants;
3. act as “sponges” by absorbing runoff (which reduces the severity of floods)
and by allowing runoff to infiltrate and recharge groundwater levels (which
maintains stream flows during dry periods);
4. catch and help prevent excess woody debris from entering the stream and
creating logjams;
5. stabilize stream banks and maintain natural channel morphology;
2

6. provide coarse woody debris for habitat structure and most of the dissolved
organic carbon and other nutrients necessary for the aquatic food web; and
7. maintain air and water temperatures around the stream.

Forested riparian buffers (a minimum 50 feet wide along intermittent streams and 100 feet wide
along perennial streams [or the full extent of the 100-year floodplain, whichever is greater])
should be created and/or maintained along all aquatic areas. Impervious surfaces, ditches, pipes,
roads, utility lines (sewer, water, gas, transmission, etc.), and other infrastructures that require
maintained, cleared rights-of-way and/or compromise the functions and values of the forested
buffers should not occur within these riparian areas.

Stream Crossings - Bridges or spanning structures should be used for all permanent roadway
crossings of streams and associated wetlands. Structures should span the channel and the
floodplain in order to minimize impacts to aquatic resources, allow for the movement of aquatic
and terrestrial organisms, and eliminate the need to place fill in streams and floodplains.

Bridges should be designed and constructed so that no piers or bents are placed in the stream,
approaches and abutments do not constrict the stream channel, and the crossing is perpendicular
to the stream. Spanning some or all of the floodplain allows the stream to access its floodplain
and dissipate energy during high flows and also provides for terrestrial wildlife passage. When
bank stabilization is necessary, we recommend that the use of riprap be minimized and that a
riprap-free buffer zone be maintained under the bridge to allow for wildlife movement. If fill in
the floodplain is necessary, floodplain culverts should be added through the fill to allow the
stream access to the floodplain during high flows.

If bridges are not possible and culverts are the only option, we suggest using bottomless culverts.
Bottomless culverts preserve the natural stream substrate, create less disturbance during
construction and provide a more natural post-construction channel. Culverts should be
sufficiently sized to mimic natural stream functions and habitats located at the crossing site;
allow for water depth, volume (flow), and velocity levels that will permit aquatic organism
passage; and accommodate the movement of debris and bed material during bank-full events.
Widening the stream channel must be avoided.

In the event that a traditional culvert is the only option, the culvert design should provide for a
minimum water depth in the structure during low-flow/dry periods. Sufficient water depth
should be maintained in all flow regimes so as to accommodate both the upstream and
downstream movement of aquatic species. Water depth inside the culvert must be adequate for
fish to be completely immersed and all other aquatic life to move freely. The culvert should be
designed and installed at the same slope as the stream grade to maintain an acceptable water
velocity for aquatic life passage and for stream substrate characteristics to be retained within the
culvert.

Where feasible, we recommend the use of multiple barrels, in addition to the low-flow barrel, to
accommodate flood flows. Floodplain barrels should be placed on or near stream bank-full or
floodplain bench elevation and discharge onto floodplain benches. Where appropriate, install
sills on the upstream end of floodplain barrels to restrict or divert the base stream flow to a
3

single barrel. If the culvert is longer than 40 linear feet, alternating or notched baffles should be
installed in a manner that mimics the existing stream pattern. This will enhance the passage of
aquatic life by: (1) depositing and retaining sediment in the barrel, (2) maintaining channel
depth and flow regimes, and (3) providing resting places for fish and other aquatic organisms.

Measures to control sediment and erosion should be installed before any ground-disturbing
activities occur. Grading and backfilling should be minimized, and existing native vegetation
should be retained (if possible) to maintain riparian cover for fish and wildlife. Disturbed areas
should be revegetated with native grass and tree species as soon as the project is completed.

The proper planning, design, and installation of stream crossings provide year-round passage for
aquatic organisms and preserve healthy streams. We recommend the following Web site for
additional information regarding stream-crossing activities:

http://www.stream.fs.fed.us/fishxing/pointers.html.

Federally Listed Endangered and Threatened Species - Because the entire project is more than
17 miles from nearest known northern long-eared bat maternity site or hibernacula and there is
suitable habitat in the surrounding area, the low probability/amount of “take” occurring as a
result of this project is discountable and we believe this project is “not likely to adversely
affect” this species. Though the project will result in the removal/loss of very little suitable
northern long-eared bat habitat, and the probability of bats using the project area is very low,
we recommend all tree felling occur before May 15 (or after August 15) to further lessen the
likelihood of the proposed project adversely affecting this species. Our concurrence with a
“not likely to adversely affect” determination is not dependent on this action - the cutting
moratorium is a measure that can be implemented to further reduce the probability of “take” of
this species. Obligations under section 7 of the Endangered Species 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.

We appreciate the opportunity to provide these comments and request that you continue to
keep us informed as to the progress of this proposed project. If we can be of assistance or if
you have any questions, please contact Mr. Allen Ratzlaff of our staff at 828/258-3939, Ext.
229. In any future correspondence concerning this project, please reference our Log Number
4-2-18-064.

E-Copy: Andrea Leslie, North Carolina Wildlife Resources Commission,
[e-mail]