20220493 Ver 2_PCN Cover Letter_20220324 (2)_20220421

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March 24, 2022
North Carolina Department of Environmental Quality
Division of Water Resources
401 & Buffer Permitting
217 West Jones Street
Raleigh, NC 27603
Subject: Request for Buffer Authorization
Duke Energy Progress
Poole Road Distribution Line Extension
Wake County, NC
Dear Sir or Madam,
AECOM
5438 Wade Park Boulevard, Suite 200
Raleigh, North Carolina 27607
www.aecom.com
BY DEQ EDOCS
On behalf of the Duke Energy, AECOM is requesting a Buffer Authorization for the above
referenced project. The subject property is located within the Neuse Watershed (HUC
030202011102). AECOM conducted a field -delineation of the subject parcel. The project
requires tree clearing and hazard tree trimming within 50 feet of three waterbodies that are
subject to the Neuse River Basin: Nutrient Sensitive Waters Management Strategy., Protection
and Maintenance of Existing Riparian Buffers (15A NCAC 02B .0714).
The project will not temporarily or permanently discharge dredged or fill materials into wetlands
or streams. As such, no written authorization for a USACE Nationwide Permit 57 or associated
DWR 404 Water Quality Certification is required.
In addition to the electronic PCN, the following information is provided to facilitate your review,
along with several referenced figures and photographs.
Project Description
The project improvements will include developing a new utility corridor, replacing poles,
overhead lines and guys, and tree trimming along an existing utility right-of-way. The maximum
tree width clearing is 30 feet wide. All tree clearing will be conducted by hand and the stumps
will remain in place. No grubbing or grading is proposed. Construction matting will be placed
within wetlands to minimize soil disturbance. No instream work is proposed. Erosion and
sediment control measures will be installed. All poles or aerial infrastructure will not be installed
within 10 feet of a waterbody.
Waterbodies Subject to 15A NCAC 02B .0714 within the Project Site
AECOM field delineated three waterbodies subject to the Neuse Riparian Buffer Rules (Stream
SA - Marks Creek, Stream SB -UT to Lake Myra / Marks Creek, and Lake Myra) (Figure 4). All
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three of these waterbodies are depicted on both the USGS Knightdale topographic quadrangle
map and the 1970 NRCS Wake County Soil Survey (Figure 2 and Figure 8).
Beginning from north to south along the proposed project corridor, the project will
perpendicularly cross stream SB (Buffer Impact Site 1) (Figure 4). This stream was
characterized as perennial, and flows into a forested wetland that abuts Lake Myra (Photos 3
and 4). The channel loses definition shortly after entering this inundated wetland area.
Lake Myra is located in the central portion of the study area (Photo 8) (Figure 4). The project will
require tree clearing parallel to this Lake. Buffer Impact Site 2 would be for tree clearing
associated with the installation of a pole and new utility lines within Zone 1 of Lake Myra (Photo
7). Buffer Impact Site 3 would be for the trimming of tree limbs that extend into Zone 2 of Myra
Lake (Photo 9). Buffer Impact Site 4 would be for tree clearing within Zones 1 and 2 of Lake Myra
associated with the replacement of an existing pole, the installation of a new pole, and new utility
lines (Photo 10).
Marks Creek (stream SA) is located in the southern portion of the project site (Figure 4). The
project would both cross this stream perpendicularly through an existing maintained easement
(Photos 11 and 14), as well as requiring tree clearing parallel to this stream within Zone 1 and
Zone 2 (Photo 16) (Buffer Impact Site 5). Within the maintained easement tree limb trimming
would occur.
Per the table of uses in 15A NCAC 02B .0714(11), the perpendicular stream crossings are an
Allowable Use (pp)(i), the parallel tree clearing within Zone 2 are an Allowable Use (qq)(i), and the
parallel tree clearing within Zone 1 are an Allowable Use Upon Authorization (qq)(ii). Table 1
details the Buffer Impact Sites and their table of uses.
Table 1. Buffer Impact Sites and Table of Uses per 15A NCAC 02B .0714(11)
Buffer
Impact Site #
Buffer
Zone
Impact Type
Impact
Area (sq ft)
Table of
Uses
Allowable
Allowable Upon
Authorization
Site 1
Zone 1
Perpendicular
1440
pp(i)
X
Site 1
Zone 2
Perpendicular
1698
pp(i)
X
Site 2
Zone 1
Parallel
1554
qq(ii)
X
Site 2
Zone 2
Parallel
592
qq(i)
X
Site 3
Zone 1
Parallel
0
N/A
N/A
N/A
Site 3
Zone 2
Parallel
54
qq(i)
X
Site 4
Zone 1
Parallel
703
gq(ii)
X
Site 4
Zone 2
Parallel
485
qq(i)
X
Site 5
Zone 1
Perpendicular
1881
pp(i)
X
Site 5
Zone 2
Perpendicular
686
pp(i)
X
Site 5
Zone 1
Parallel
823
gq(ii)
j
X
Site 5
Zone 2
Parallel
1736
qq(i)
I X
AECOM also delineated an intermittent stream (stream SC) in the central portion of the project
site (Photos 5 and 6) (Figure 4). The project will cross this stream perpendicularly. This stream
does not appear on either the USGS Knightdale topographic quadrangle map and the 1970
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NRCS Wake County Soil Survey (Figure 2 and Figure 8). As such it would not be subject to 15A
NCAC 02B .0714.
Threatened and Endangered Species
AECOM obtained federally listed endangered and threatened species data from the USFWS
IPaC list (Table 2) which generates a list of species and other resources that are known or
expected to be within or near the study area. In addition, the NCNHP Data Explorer website was
used to generate a list of known element occurrences within one -mile of the proposed project.
For each listed species included in the IPaC list, a discussion of the presence or absence of
habitat is included below along with the Biological Determination rendered based on survey
results in the study area.
Table 2. IPaC List of Federally Protected Species for the Study Area
Federal
Habitat
Biological
Scientific Name
Common Name
Status
Present
Determination
Vertebrate:
Picoides borealis =
Red -cockaded
Dryobates
E
No
No Effect
Woodpecker
borealis
Invertebrate:
Alasmidonta
Dwarf wedgemussel
E
No
No Effect
heterodon
Vascular Plant:
Rhus michauxii
Michaux's Sumac
E
Yes
No Effect
T - Threatened
E - Endangered
Red -cockaded woodpecker - No Habitat Observed
USFWS Recommended Survey Window: year round; April 1 through July 31 (optimal)
Biological Conclusion: No Effect
The red -cockaded woodpecker (RCW) typically occupies open, mature stands of
southern pines, particularly longleaf pine (Pinus palustris), for foraging and
nesting/roosting habitat. The RCW excavates cavities for nesting and roosting in living
pine trees, aged 60 years or older, and which are contiguous with pine stands at least 30
years of age to provide foraging habitat. The foraging range of the RCW is normally no
more than 0.5 mile. The USFWS RCW Recovery Plan outlines specific requirements for
RCW foraging and nesting habitat (USFWS, 2003). These requirements include, but are
not limited to, little or no hardwood and/or pine midstory, pine stands of at least 30 years
of age, and total stand basal area (BA) should be no higher than 80 square feet per acre.
A pedestrian survey conducted by AECOM biologists in March 2021 characterized the
forested areas adjacent to the study area as containing hardwoods and juvenile pine
trees and does not support habitat for Red -cockaded woodpecker. A review of NCNHP
records, accessed on March 10, 2021, indicate one known historic occurrence of RCW
within one -mile of the study area in January of 1977.
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Dwarf wedgemussel -Potential Suitable Habitat Observed
USFWS Recommended Survey Window: year round
Biological Conclusion: No Effect
The dwarf wedgemussel is a small bivalve, rarely exceeding 45 mm in length. This mussel
is somewhat of a generalist, known to inhabit streams less than five meters wide to large
rivers up to 100 meters wide. It is found in a variety of substrate types and flow
conditions. The dwarf wedgemussel is known to inhabit hydrologically stable areas. They
have been found in both shallow water and water depths up to 25 feet. A pedestrian
survey conducted by AECOM biologists in March 2021 characterized the streams within
the study area as small reaches containing a sandy or silt dominated substrate with
substantial sediment aggregation and is not suitable for the dwarf wedgemussel. A
review of NCNHP records, accessed on March 10, 2021, indicate no known occurrence
of dwarf wedgemussel within one -mile of the study area.
Michaux's sumac - Potential Habitat
USFWS optimal survey window: May -October
Biological Conclusion: No Effect
Michaux's sumac, endemic to the inner Coastal Plain and lower Piedmont, grows in sandy
or rocky, open, upland woods on acidic or circumneutral, well -drained sands or sandy
loam soils with low cation exchange capacities. The species is also found on sandy or
submesic loamy swales and depressions in the fall line Sandhills region as well as in
openings along the rim of Carolina bays; maintained railroad, roadside, power line, and
utility rights -of -way; areas where forest canopies have been opened up by blowdowns
and/or storm damage; small wildlife food plots; abandoned building sites; under sparse
to moderately dense pine or pine/hardwood canopies; and in and along edges of other
artificially maintained clearings undergoing natural succession. In the central Piedmont,
it occurs on clayey soils derived from mafic rocks. The plant is shade intolerant and,
therefore, grows best where disturbance (e.g., mowing, clearing, grazing, periodic fire)
maintains its open habitat. A pedestrian survey conducted by AECOM biologists on June
15, 2021 observed potential habitat for Michaux's sumac within the overhead powerline
easement and roadside, but no species of sumac were observed during the survey. A
review of NCNHP records, accessed on March 10, 2021, indicate two known
occurrences of Michaux's sumac within one -mile of the study area in July of 2011 and
May of 2017.
Cultural Resources
AECOM archaeologist Matthew Jorgenson submitted a request for background information to
the North Carolina Office of State Archaeology (OSA) for the project and the OSA provided
information for the request via email on April 15, 2021. Further, AECOM archaeologist Peter
Sittig consulted data maintained by the North Carolina State Historic Preservation Office (SHPO)
on April 26, 2021. These tasks were performed to gain information about previously recorded
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archaeological sites (OSA) and historic resources (SHPO) within a 0.5-mile radius of the project
area.
No archaeological sites are recorded within the project area. One site, 31 WA1639, is recorded
in a wooded area approximately 0.5-miles from the northern end of the current project area as
a late -nineteenth to mid -twentieth century historic site. The site is not eligible for the National
Register of Historic Places (NRHP).
Two historic resources (WA1997 and WA1998) are recorded within and immediately adjacent to
the project area (Error! Reference source not found.). The Lake Myra Complex (WA1997)
consists of multiple structures and the Lake Myra dam, which has not been evaluated for NRHP
eligibility. The mill was commissioned to be built in 1777 and appears on an 1871 map of Wake
County as "N. Price's Mill." In 1940 the dam was improved with concrete to raise the lake level.
The second resource, the C.M. Martin House (WA 1998), is a ca. 1925 craftsman style residence
within and immediately adjacent to the project area. The Martin House has not been evaluated
for NRHP eligibility.
Neither of these resources would be directly impacted by the project.
Closing
AECOM appreciates your review of this request for a Buffer Authorization, and look forward to
your approval at your earliest convenience. Please contact me at [e-mail]
or [phone] to discuss the project or address any questions you may have. If you would
like, we can also arrange a site visit to the project site.
AECOM Technical Services, Inc.
Charles Benton, PWS
Senior Environmental Scientist
Project Manager
[e-mail]
cc: Jamie Bobbitt, Duke Energy Progress
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