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HomeMy WebLinkAboutNCWRC Comments -SAW-2020-00491 - Back Creek Interceptor ImprovNorth Carolina Wildlife Resources Commission 9 Cameron Ingram, Executive Director Via email 14 March 2023 Ms. Aliisa Harjuniemi Carolina Wetland Services, Inc. 550 Westinghouse Blvd Charlotte, North Carolina 28273 SUBJECT: Pre -Construction Notification for the Back Creek Interceptor Improvements in Harrisburg, Cabarrus and Mecklenburg Counties, North Carolina. USACE Action ID: SAW-2020-00491; DEQ No. 20200927v2. Dear Ms. Harjuniemi, 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 Water and Sewer Authority of Cabarrus County, Carolina Wetland Services, Inc. has submitted a Pre -Construction Notification (PCN) application for the Back Creek Interceptor Improvements located along Back Creek in Harrisburg in Cabarrus and Mecklenburg counties, North Carolina. The 4-mile gravity sewer interceptor will extend from the confluence of Back Creek with Fuda Creek in Cabarrus County to the Charlotte Water Back Creek Pump Station in Mecklenburg County. The new gravity sewer line will parallel the existing sewer lines in the existing easement. Back Creek and its unnamed tributaries flow through the site. Back Creek in the Yadkin -Pee Dee River Basin is classified as a Class C stream by the NC Division of Water Resources. The applicant requests to permanently impact 1.143 acres of wetland and 200 linear feet of streams, and temporarily impact 2.228 acres of wetland and 454 linear feet of streams. NCWRC has records of the state endangered Carolina creekshell (Villosa vaughaniana) within Back Creek. The lack of records from the site does not imply or confirm the absence of federal or state -listed species. An on -site survey is the only means to determine if the proposed project may impact federal or state rare, threatened, or endangered species. The U.S. Fish and Wildlife Service lists the federally and state endangered Schweinitz's sunflower (Helianthus schweinitzii) and Michaux's sumac (Rhus michauxii); proposed endangered tricolored bat (Perimyotis subflavus); threatened smooth coneflower (Echinacea laevigata); and candidate monarch butterfly (Danaus plexippus) as having potential to occur within the project area if suitable habitat occurs. We recommend contacting the U.S. Fish and Wildlife Service. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Page 2 14 March 2023 Back Creek Interceptor Improvements USACE Action ID: SAW-2020-00491 We have concerns for the number of impacts the project will have on wetlands and streams. We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife resources: Minimize the number of impacts to wetlands and streams either by reducing the number of crossing or utilizing jack and bore. However, if jack and boring cannot be used on all 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. During construction, equipment should not be staged in stream channels, riparian buffers, or wetlands. 2. Conduct manual clearing of vegetation in wetlands and disallow the use of heavy, tracked equipment. Leave vegetation where it falls rather than using heavy equipment to remove trees and other downed vegetation, which can further damage wetlands. Clearly mark the boundary for hand clearing. 3. Removal of vegetation in wetlands and streams should be minimized. 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. 4. Prior to construction in perennial streams, surveys for state -listed mussel surveys should be conducted 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. If state -protected species are found in the project area, the mussels should be relocated to suitable habitat above the project area. Also immediately contact Brena Jones, the Central Aquatic Wildlife Diversity Research Coordinator, at 919-707-0369 or brena.jones@ncwildlife.org if protected mussel species are found during surveys. 5. Maintain a minimum 100-foot native, undisturbed forested buffer along each side of perennial streams and 50-foot native, undisturbed forested buffer along each side of intermittent streams and wetlands. 6. Non-native plants should not be used for seeding disturbed areas. Specifically, avoid using Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-native. A list of alternatives to non-native species has been attached. Alternatively, use a grain, such as oats, wheat, or rye for temporary cover and native seed mixes for permeant seeding. We recommend planting native, wildflower seed mixes that will create pollinator habitat within the project boundary. 7. Since state -listed species are known to occur in the watershed, stringent sediment and erosion control measures installed prior to any land -disturbing activity. Incorporate the following elements into erosion and sediment control plans: minimize clearing and grading, protect waterways, phase construction for larger construction sites (>25 acres), stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish appropriate perimeter controls, employ advanced settling devices, implement a certified contractors program, and regularly inspect erosion control measures. Ensure all silt fencing is removed once vegetation has reestablished and soils have stabilized. Page 3 14 March 2023 Back Creek Interceptor Improvements USACE Action ID: SAW-2020-00491 8. Avoid tree clearing activities during the maternity roosting season for bats (May 15 — August 15) because of the decline in populations of several tree -roosting bat species, including tricolored bat. 9. Erosion control matting made of plastic mesh or twine should not be used within the project area because it can injure or kill wildlife. Thank you for the opportunity to provide input for this project. If I can provide further assistance, please call (336) 336-0074 or email olivia.munzergncwildlife.org. Sincerely, Olivia Munzer Western Piedmont Habitat Conservation Coordinator Habitat Conservation Program Ec: Krysta Stygar, USACE Andrew Pitner, NCDWR Brena Jones, NCWRC Byron Hamstead, USFWS Page 4 14 March 2023 Back Creek Interceptor Improvements USACE Action ID: SAW-2020-00491 ec: Steve Kichefski, U.S. Army Corps of Engineers Doug Perez, N.C. Division of Water Resources Byron Hamstead, U.S. Fish and Wildlife Service RECOMMENDED NATIVE ALTERNATIVES FOR NON-NATIVE GRASSES IN NORTH CAROLINA" (Species are appropriate for all geographic regions unless otherwise indicated) NON-NATIVE SPECIES NATIVE SPECIES Big bluestem Andropogon gerardii Little bluestem Schizachyrium scoparium Indiangrass Sorghastrum nutans Crownvetch Switchgrass Panicum virgatum Centipede Beaked panicgrass Panicum anceps Bermuda Purpletop Tridens flavus Roundheaded bushclover Lespedeza capitata Deer tongue Dicanthelium clandestinum Sensitive partridge pea Chamaecrista nictitans Partridge pea Chamaecrista asciculata Big bluestem Andropogon gerardii Little bluestem Schizachyrium scoparium Indiangrass Sorghastrum nutans Switchgrass Panicum virgatum Kentucky bluegrass Beaked panicgrass Panicum anceps Tall fescue Purpletop Tridens flavus Sudangrass Broomsedge Andropogon virginicus Deer tongue Dicanthelium clandestinum Canadian wildrye Elymus canadensis Virginia wildrye Elymus virginicus Sensitive partridge pea Chamaecrista nictitans Partridge pea Chamaecrista asciculata Switchgrass Panicum virgatum Splitbeard bluestem Andropogon ternarius Sericea lespedeza Beggarlice Desmodium spp. Kobe lespedeza Deer tongue Dicanthelium clandestinum Sensitive partridge pea Chamaecrista nictitans Partridge pea Chamaecrista asciculata NC Native Plant Recommendations **A recommended revegetation/stabilization mix would ideally include a combination of the species listed in this table. In addition, please note that additional consideration may be needed in areas that are (highly) erodible and/or have sloped terrain. The following species could be included in all regions for additional stabilization and wildlife benefit: Black-eyed susan: Plains coreopsis: Lance -leaved coreopsis: Narrow -leaved sunflower: Created October 2018 Rudbeckia hirta Coreopsis tinctoria Coreopsis lanceolata Helianthus angustifolius