20200734 Ver 1_WRC Comments_20200626

Strickland, Bev
From:
Leslie, Andrea J
Sent:
Friday, June 26, 2020 6:28 PM
To:
Brandee Boggs(Bra [e-mail])
Cc:
Annino, Amy M; Brad Luckey
Subject:
Westminster Solar - NCWRC comments
Attachments:
WestminsterSolar_UTSecondBroad &BigCampCr_Rutherford_WRCComments.pdf
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Hi Brandee,
Attached are NCWRC's comments on Westminster Solar.
Andrea
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-803-6054 (office)
828-400-4223 (cell)
www.ncwildlife.org
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1

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 26, 2020
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Westminster Solar
UT to Second Broad River & UT to Big Camp Cr, Rutherford County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert and riprap 146 ft of an unnamed tributary (UT) to Big Camp Creek and an
UT to the Second Broad River in Rutherford County. Our comments on this application are
offered for your consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466
et. seq.) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667d).
Wild trout reproduction should not be impacted by project activities, and a trout moratorium is
not needed for the project. Carolina Foothills Crayfish (Cambarus johni, NC Significantly Rare)
is found in the project vicinity.
The application proposes to establish a large solar facility on 1,195 acres. The two culverts
would be placed in order to develop the site and provide post -construction access. Details are
not provided on the type of culvert to be used, but the disturbed channels will be restored to pre -
construction contours, matted, and livestaked. Work will be done in the dry. A riprap energy
dissipator will be installed below each culvert.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -channel work should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up. Disturbed
areas along streams should be seeded, mulched and/or matted as soon as possible, preferably
at the end of each work day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Westminster Solar Page 2 June 26, 2020
Cleghorn Cr, Rutherford County
2. Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
3. We recommend against installing riprap dissipators, given the low slopes of the streams.
4. We recommend against using HDPE for culverts, as this slick material is less likely to hold
stream substrate and provide for movement of aquatic organisms like fish and salamanders.
5. Maintain or establish a minimum 100-foot undisturbed, native forested buffer along each side
of perennial streams and 50-foot undisturbed, native forested buffer along each side of
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.
6. If site and/or transmission line maintenance is needed, avoid mowing between April 1 and
October 1 to minimize impacts to nesting wildlife. We suggest a maintenance schedule that
incorporates a portion of the area (e.g., one-third of the area) each year. Pesticides,
fertilizers, and other chemicals should not be used in wetland areas or near streams.
7. If pesticides or chemicals will be used for site maintenance, stormwater runoff from the site
should be directed to bioretention areas prior to discharge to streams or wetlands; this will
provide additional protection for water quality and aquatic and terrestrial wildlife habitats.
8. It is especially portant to ensure that sediment and erosion control measures are installed
prior to any land clearing or construction. 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. We strongly recommend incorporating a native pollinator mix on site, which can provide
pollinator habitat and ultimately reduce maintenance costs. See the attached "North Carolina
Technical Guidance for Native Plantings on Solar Sites" for planting recommendations.
10. We recommend that a wildlife -friendly buffer outside of the solar array be planted with a mix
of native warm season grasses and shrubs such as dogwood, button bush, and berry bushes.
See the list of recommended plants in the guidance document referenced in #5 above.
11. Develop a decommissioning plan that identifies the parry responsible for decommissioning
the facility and the conditions under which decommissioning will occur. In addition, the plan
should include that all equipment is removed from the site and the land restored to pre -
construction conditions.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Brad Luckey, Pilot Environmental
Amy Annino, NC Division of Water Resources