20200990 Ver 1_NCWRC Comments_20200819

Strickland, Bev
From: Munzer, Olivia
Sent: Wednesday, August 19, 2020 10:50 AM
To: [e-mail]
Cc: Hamstead, Byron ([e-mail]); Johnson, Alan; Roden Reynolds, Bryan
K CIV (US); Jones, Brena K.; [e-mail]
Subject: NCWRC Comments - PNG Prospect Church Project - Stanly
Attachments: NCWRC Comments - PNG Prospect Church Replacement -Stanly.pdf
Good morning,
Please see the attached comments. Thanks
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
Rogers Depot
1718 NC Hwy 56 W
Creedmoor, NC 27522
Office: 919-707-0364
Cell: 336-269-0074
[e-mail]
www.ncwildlife.org
13 =2b
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
1

1�1 North Carolina Wildlife Resources Commission 0
Cameron Ingram, Executive Director
19 August 2020
Mr. Dan Zurlo
WK Dickson
1213 W. Morehead Street
Charlotte, NC 28208
SUBJECT: Pre -Construction Notification for the Piedmont Natural Gas Prospect Church (Airport)
Road Replacement Line, Albermarle, Stanly County, North Carolina. DEQ No.
20200990.
Dear Mr. Zurlo,
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 Piedmont Natural Gas (PNG), WK Dickson has submitted a Pre -Construction
Notification (PCN) application for the PNG Prospect Church (Airport) Road Replacement Line in
Albemarle, Stanly County, North Carolina. Much of the pipeline extends along Prospect Church
Road/Airport Road from US Highway 52 to Ridge Street. PNG plans on installing a new, upgraded
natural gas pipeline distribution network. The project would temporarily impact 0.047 acres of wetland
and permanently impact 0.048 acres of wetland by converting bottomland hardwood forest to herbaceous
wetland in permanent easements. The project would temporarily impact 86 linear feet of streams.
The pipeline will cross Little Long Creek, unnamed tributaries to Little Long Creek, and unnamed
tributaries to Mountain Creek in the Yadkin -Pee Dee River Basin. Little Long Creek and Mountain
Creek are classified as Class C streams by the NC Division of Water Resources (NCDWR). Downstream
of the project, Mountain Creek is classified as a Water Supply IV stream and it is on the State's Final
2018 303(d) list of impaired waters.
We have records for the state significantly rare Eastern Creekshell (Villosa delumbis) downstream of the
proposed project. The lack of records does not preclude the potential for a rare, threatened, or endangered
species to occur within the project area. An on -site survey is the only defmitive means to determine whether
a listed or proposed species is on the site and if it would be impacted by the project.
We offer the applicant the following recommendations to minimize impacts to aquatic and terrestrial
wildlife resources.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

19 August 2020
PNG Prospect Church Rd
DEQ No: 20200990
Page 2
NCWRC Comments
1. We request trenchless construction methods to be used for the crossing of Little Long Creek. If
open -trench crossing is conducted across Little Long Creek, we request surveys for state -
listed mussel surveys prior to construction. Surveys should be completed within the instream
work area and 50 meters above and 100 meters below the work area. Any protected species
surveys should be conducted by biologists with both state and federal endangered species permits.
Please contact Brena Jones, the Central Aquatic Wildlife Diversity Research Coordinator, at 919-
707-0369 or [e-mail] for further information on surveys and relocation.
2. If directional drilling or jack and bore cannot be used on 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.
Streams should be restored to their natural function. Native vegetation, state-of-the-art natural
channel design, and restoration techniques should be used for stream stabilization at stream
crossings.
3. 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.
4. If utility lines parallel any streams, the edge of the construction corridor should be located a
minimum of 100 feet from perennial streams and a 50 feet for intermittent streams and wetlands.
Forested riparian buffers provide habitat areas for aquatic and terrestrial wildlife species and
travel corridors for terrestrial wildlife. In addition, forested riparian buffers protect water quality
by stabilizing stream banks and filtering stormwater runoff.
5. 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.
6. Due to the decline in populations of most bat species, avoid the removal of large trees at the site.
Avoid tree clearing activities during the maternity roosting season for bats (May 15 — August 15).
Additionally, we recommend avoiding clearing or maintenance activities during the migratory
bird nesting season, roughly March to August.
7. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas; the easement would be ideal for creating pollinator habitat. Avoid using
Bermudagrass, 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. Invasive species control should occur regularly,
including prior to construction if present. Invasive species outcompete native plants and provide
minimal benefit to wildlife.
8. Stringent 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 that has been reinforced with plastic or metal mesh should be

19 August 2020
PNG Prospect Church Rd
DEQ No: 20200990
Page 3
NCWRC Comments
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.
9. Ensure all silt fencing is removed once vegetation has reestablished and soils have stabilized.
Thank you for the opportunity to provide input for this project. If I can provide further assistance or free
technical guidance, please call [phone] or email olivia.munzerkncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Bryan Roden -Reynolds, U.S. Army Corps of Engineers
Alan Johnson, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service
Brena Jones, NCWRC
Randy Webb, PNG