20201747 Ver 1_WRC Comments_20210111

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
11 January 2021
Mr. Troy King
Alley, Williams, Carmen & King, Inc.
740 Chapel Hill Road
Burlington, North Carolina 27215
SUBJECT: Pre -Construction Notification for the Cherry Lane Sanitary Sewer Outfall in the City of
Graham, Alamance County, North Carolina. DEQ No. 20201747.
Dear Mr. King,
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 City of Graham, Alley, Williams, Carmen & King, Inc. has submitted a Pre -Construction
Notification (PCN) application for the Cherry Lane Sewer Outfall project in Graham, Alamance County,
North Carolina. Back Creek and its unnamed tributaries in the Cape Fear River basin occur within the
project area. The project will temporarily impact 80 linear feet (If) of Back Creek and permanently
impact 681f of unnamed tributaries of Back Creek. The project will impact 5,280 square feet of Zone 1
and 35,591 square feet of Zone 2 of the buffer.
We have known records the state special concern Greensboro burrowing crayfish (Cambarus catagius) and
state significantly rare eastern creekshell (Villosa delumbis) near the project. Within the Back Creek — Haw
River subbasin, we have records of the state endangered Carolina creekshell (Villosa vaughaniana); state
threatened eastern lampmussel (Lampsilis radiata) and notched rainbow (Villosa constricta); and state
significantly rare Carolina ladle crayfish (Cambarus davidi). The lack of records from the site does not imply
or confirm the absence of federal or state -listed species. An on -site survey during the optimal survey window
is the only means to determine if the proposed project may impact federal or state rare, threatened, or
endangered species.
We request that directional drilling is used for the installation of the sewer lines across Back Creek. We
understand there is an environmental risk and additional cost from directional drilling the sewer lines;
however, the long-term environmental risks appear to be less with directional drilling. 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 the City of Graham time and money spent (i.e.,
materials, permitting, potential mussel surveys, etc.). To reduce any potential inadvertent releases, we
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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11 January 2021
Cherry Lane Sewer Outfall
DEQ No. 20201747
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.
We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife resources
We are concerned that the project may increase sedimentation and erosion of the stream, and the
removal of overstory could increase stream temperatures; therefore, impacting state -listed mussel
species. If open -cut trenching is used, we request surveys for state -listed mussels. 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
brena.jones(a ncwildlife.org for further information on surveys and relocation.
2. We request site inspections for the Greensboro burrowing crayfish. We have included an
information sheet on preliminary site inspections for this species. Please notify Brena Jones if
any potential Greensboro burrowing crayfish or burrows are located.
3. We recommend a minimum 100-foot setback for perennial streams and a 50-foot setback for
intermittent streams and wetlands. Manholes or similar access structures should not be allowed
within buffer areas. Ensure stream crossings are at near perpendicular (900) to stream flow.
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. 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.
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. Re -seed disturbed areas with native seed mixtures that are beneficial to wildlife. Consider
planting native, wildflower seed mixes that will 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. Manage non-native, invasive species
during and after construction.
11. 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.

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11 January 2021
Cherry Lane Sewer Outfall
DEQ No. 20201747
12. Stringent sediment and erosion control measures should be implemented by using 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.
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/0/Conserving/documents/2002_GuidanceMemorandumforSecondguan
dCumulativehnpacts.pdf) .
Specifically, we have concerns for the secondary and cumulative impacts from the project on rare,
threatened, and endangered species resulting from future population growth, increase in impervious
surface, and water demand. We recommend the City of Graham and Alamance County consider 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/Conservin /g 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.munzerAncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: David Bailey, USACE
Sue Homewood, NCDWR
John Ellis, USFWS
Brena Jones, NCWRC

NORTH
CAROLINA
Burrowing Crayfish Preliminary Site Inspection
RESOURCES
COMMISSION
The NC Wildlife Resources Commission (NCWRC) is seeking information on the Greensboro Burrowing Crayfish (GBC;
Cambarus catagius), a rare endemic species and state listed as Special Concern. We are requesting assistance from
consultants and other workers in the field to help identify sites in the permit review process which may have
populations of GBC. This entails simply looking for signs of activity (details below) while you are already on the property.
This may assist both the applicant and NCWRC with a more efficient project review. NCWRC is also interested in
expanding and updating the understanding of GBC distribution and biology.
While walking the property, look for signs of burrowing crayfish activity. This may include entrance holes in the ground
or in the banks/sides of ditches and streams, approximately 1-3" in diameter, or crayfish (photos on pg. 2). Greensboro
Burrowing Crayfish are not currently known to build chimneys at burrow entrances but have been found near other
chimney -building species.
This species does not require flowing surface water and can dig extensive burrows over 4' deep, so they can be found in
lawns or even dirt floors of garages or outbuildings.
If an inspection for crayfish is conducted, please note:
• How much and which portion of the property was inspected and by whom.
• If signs of activity are seen, please make note of where they are. Photographs are welcome.
• If no activity is seen after a targeted inspection, please note that information as well.
Include this information with permit application materials. If signs of burrowing crayfish activity are noted, a follow-up
survey is recommended to determine whether GBC are present. If onsite staff have appropriate permits (state Scientific
Collection Permit for Endangered Species) & expertise, they may conduct the survey. Contact Olivia Munzer with the
NCWRC at [e-mail] with questions.
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Greensboro Burrowing Crayfish Range Map
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Greensboro Burrowing Crayfish, Comborus cotogius (photos by NCWRC)
Examples of crayfish burrow holes
Example of crayfish chimney