20200694 Ver 1_C.5j WRC Comments_20200526

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

MEMORANDUM

TO: Ward Marotti, Senior Scientist
WK Dickson & Co., Inc.

FROM: Gabriela Garrison
Eastern Piedmont Coordinator
Habitat Conservation

DATE: January 22, 2018

SUBJECT: Request for Environmental Scoping for the Fayetteville Public Works Commission, Big
Rockfish and Stewarts Creek Outfalls, Cumberland County.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113-131 et seq.).

The Fayetteville Public Works Commission proposes to create outfalls along Stewarts Creek to serve
Annexation Areas 32 and 34 in Fayetteville. The Rockfish outfall will extend into Areas 32 and 34,
parallel to Stewarts Creek. Additional lateral collection lines will be installed within both Areas.
Construction of these outfalls would avoid the need for a regional lift station and force main. The outfalls
will also potentially eliminate six lift stations and provide future opportunities to serve portions of Hoke
County currently without public sewer.

Stewarts Creek is a tributary to Rockfish Creek in the Cape Fear River basin. There are records for the
state-significantly rare, Sandhills spiny crayfish (Cambarus hystricosus) in both Stewarts and Rockfish
Creek. In addition, the Natural Heritage Natural Area, Rockfish Creek Corridor, is located within the
proposed outfalls, downstream of the Annexation Areas.

The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC’s Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources. The Green Growth Toolbox
(http://216.27.39.101/greengrowth/) also provides information on nature-friendly planning.

The following recommendations will minimize impacts to aquatic and terrestrial resources:
Page 2

January 22, 2018
Fayetteville PWC Rockfish Creek Outfalls

1. Maintain a minimum 100-foot undisturbed, native, forested buffer along perennial streams,
and a minimum 50-foot buffer along intermittent streams and wetlands. Maintaining
undisturbed, forested buffers along these areas will minimize impacts to aquatic and
terrestrial wildlife resources. Wide riparian buffers are helpful in maintaining stream bank
stability. In addition, these buffers provide a travel corridor for wildlife species. Measures to
avoid or minimize impacts to wetlands should be implemented. In addition to providing
wildlife habitat, wetland areas perform important functions of flood control and water quality
protection.
2. All utility crossings should be kept to a minimum and use existing rights-of-way when
feasible. The directional bore (locating utilities beneath the riverbed and avoiding impacts to
the stream and buffer) stream crossing method should be used for utility crossings wherever
practicable; the open cut stream crossing method should only be used when water level is low
and stream flow is minimal. Stream crossings should be near perpendicular (75o to 105o) to
stream flow and monitored at least every three months for maintenance needs during the first
24 months of the project and then annually thereafter.
3. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re-seeded with seed mixtures that are beneficial to wildlife. Avoid fescue-based
mixtures as fescue is invasive and provides little benefit to wildlife. Native, annual small
grains appropriate for the season are preferred and recommended. Pollinator mixes are
commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths and birds. Where feasible, use woody debris and logs from corridor
clearing to establish brush piles and downed logs adjacent to the cleared right-of-way to
improve habitat for wildlife. 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 also be beneficial.
4. Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of ROWs within 100 feet of perennial streams and 50 feet of intermittent
streams, or within floodplains and wetlands associated with these streams.
5. Incorporate the following elements into erosion and sediment control plans: minimize
clearing and grading, protect waterways, phase construction for larger construction sites (>25
acres), stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish
appropriate perimeter controls, use advanced settling devices, implement a certified
contractors program and regularly inspect erosion control measures.

6. Sediment and erosion control measures should be 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 vertical
and horizontal twines. Silt fencing and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.

Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or [e-mail].