20201051 Ver 1_WRC Comments_20200917

Strickland, Bev
From: Munzer, Olivia
Sent: Thursday, September 17, 2020 3:24 PM
To: [e-mail]
Cc: Roden Reynolds, Bryan K CIV (US); Johnson, Alan; Jones, Brena K.
Subject: NCWRC Comments- 853W Zone Improvements - Waterline PCN
Attachments: NCWRC Comments -853W Zone Improv Waterline PCN.pdf
Mr. May,
Please see the attached comments. Thank you,
Olivia
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.or>;
0 91 M 102J,
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
1

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
17 September 2020
Mr. Philip May
Carolina Ecosystems, Inc.
2040 NC 42 West
Clayton, North Carolina 27520
SUBJECT: Pre -Construction Notification for the 853 W. Zone Improvements, Monroe, Union
County, North Carolina. DEQ No. 20201051.
Dear Mr. May,
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 Union County, Carolina Wetlands Inc. and Black & Veatch have submitted a Pre -
Construction Notification (PCN) application for the 853 W Zone Improvement, which is an
approximately 5.1-mile waterline project. The project will extend from the intersection of Haywood
Road and Secrest Short Cut Road to near the intersection of N. Rocky River Road and Price Short Cut
Road in Monroe, Union County. The alignment runs primarily along roads in subdivisions, farm fields,
and some forested areas. The purpose of the project is to improve hydraulics from the Watkins Pump
Station into the County's exiting distribution system and to convey water from a proposed Water
Treatment Plant to the existing service area.
The waterline would cross unnamed tributaries of South Fork Crooked Creek; and Stewarts Creek, Dry Fork,
Bearskin Creek, and their unnamed tributaries in the Yadkin -Pee Dee River basin. The project would
temporarily impact 396 linear feet (If) of streams and permanently impact 421 if of streams; and
temporarily impact 0.187 acres (ac) of wetlands and permanently convert 0.074 ac of forested wetlands.
We have known records of the federal and state endangered Schweinitz's sunflower (Helianthus
schweinitzii); state endangered Carolina Creekshell (Villosa vaughaniana) and Savannah Lilliput (Toxolasma
pullus); state threatened thick -pod white wild indigo (Baptisia alba) and federal candidate Georgia aster
(Symphyotrichium georgianum); state special concern Carolina Darter (Etheostoma collis) and Carolina
birdfoot-trefoil (Acmispon helleri); and state significantly rare Eastern Creekshell (V.. delumbis) and terrestrial
water-starwort (Callitriche terrestis) within or near the project area. We recommend contacting the U.S.
Fish and Wildlife Service at [phone] to ensure that any issues related to federally protected species are
addressed.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
17 September 2020
853W Zone Improvements
DEQ No. 20201051
We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife resources.
We request directional drilling is used for the installation of the water lines that cross perennial
streams, but at least for crossing Bearskin Creek. We are concerned with the increased
sedimentation and erosion, as well as direct habitat destruction and species mortality, an open
trench crossing could cause within these streams. Also, open trench crossings increase the
likelihood for future lateral movement of the stream, which could undercut or erode around the
utility line. Fixing future erosion will cost Union County time and money (i.e., materials,
permitting, potential mussel surveys, etc.). To reduce any potential inadvertent releases, we
recommend developing a directional drill procedure and fluid control plan. In general, we
recommend the use of turbidity curtains to reduce the risk of sediment flowing downstream.
If open -cut trenching occurs to cross Bearskin Creek, we request surveys for state -listed mussels.
Surveys should be conducted 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. Minimize the impacts to streams and wetlands to the greatest extent possible. All stream
crossings should be near perpendicular (75o to 105o) to stream flow.
We recommend a minimum 100-foot setback for perennial streams and a 50-foot setback for
intermittent streams and wetlands.
4. Avoid the removal of large trees at the edges of construction corridors. Due to the decline in
populations of most bat populations, avoid tree clearing activities during the maternity roosting
season for bats (May 15 — August 15). Minimize corridor maintenance and prohibit mowing
between April 1 and October 1 to minimize impacts to nesting wildlife.
5. During construction, equipment should not be staged in stream channels or riparian buffers.
6. 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.
7. Instream work should consider forecasted high -flow events with consideration to an increase of
impermeable surfaces from development served by this sewer line.
8. Consider using state-of-the-art natural channel design and restoration techniques. Disturbed
stream banks and wetlands should be restored to original contours and re -vegetated with native
plant species immediately after construction.
9. Monitoring is recommended to ensure successful channel and bank stabilization and vegetation
growth. We recommend monitoring the site once per year during the growing season for three
years or three bankfull events. Invasive species control should occur regularly, including prior to
construction if present. Invasive species outcompete native plants and provide minimal benefit to
wildlife.
10. We are pleased to see that native seed mix will be used to stabilize the channel banks. We
recommend using native, wildflower seed mix for the entire utility corridor to 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.

Page 3
17 September 2020
853W Zone Improvements
DEQ No. 20201051
I I . Sediment and erosion control measures should be installed prior to any land -disturbing activity.
Banks should be stabilized and sediment barriers installed as soon as possible, but at least within
24 hours. Ensure sedimentation and erosion control fences are removed after revegetation and
stabilization have occurred to reduce impacts to wildlife movements.
12. Stringent sediment and erosion control measures should use advanced methods and 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 avoided as it impedes 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.
We have concerns for the secondary and cumulative impacts from the project on rare, threatened, and
endangered species, including those that occur in South Fork Crooked Creek, resulting from future
population growth, increase in impervious surface, and water demand. The project may also increase
sedimentation and erosion of streams in the Yadkin -Pee Dee River basin.
The NCWRC encourages the applicant to consider additional measures to protect wildlife species in
developing landscapes. More detailed information on each of these measures and supporting literature
can be found in 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/O/Conserving/documents/2002 GuidanceMemorandumforSecondgaan
dCumulativelmpacts.pdf).
We recommend Union County considers green planning, which allows for growth while conserving
wildlife and natural resources. The NCWRC Green Growth Toolbox program provides technical
guidance, habitat conservation recommendations, and datasets to assist communities in green planning
(http://www.ncwildlife.org/Conserving/Programs/GreenGrowthToolbox.aspx). NCWRC can provide
workshops and training to the planning department and other interested parties.
Thank you for the opportunity to provide input for this project. If I can provide further assistance or
provide free technical guidance, please call [phone] or email olivia.munzer(&ncwildlife.org.
Sincerely,
M"'Iffia
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Bryan Roden -Reynolds, USACE
Alan Johnson, NCDWR
Brena Jones, NCWRC