20230094 Ver 1_WRC Comments_20230718

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sue Homewood
Division of Water Resources
N.C. Department of Environmental Quality
FROM: Gabriela Garrison
Eastern Piedmont Coordinator`s "
Habitat Conservation
DATE: July 18, 2023
SUBJECT: Comments for Environmental Review for Sanford Water Filtration Facility 30 MGD
Expansion, Lee County, DEQ Project No. 23-0094.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113-131 et seq.).
Sanford Public Works proposes the following construction at the Sanford Water Filtration Facility to
allow for demands of projected growth in Lee County: a new pump station (adjacent to the existing
Sanford Raw Water Pump Station); a new raw water intake structure in the Cape Fear River; an influent
line from the intake to the new pump station; and an upgraded raw water line from the new pump station
to the existing Water Filtration Facility. Work will occur in existing right-of-ways (ROWS) where
possible. This project is located within Lee County.
The U.S. Fish and Wildlife Service lists the federally proposed, endangered tricolored bat (Perimyotis
subflavus) and candidate monarch butterfly (Danaus plexippus), as potentially occurring at the site if
suitable habitat occurs. Lack of records onsite does not imply or confirm the absence of federal or state -
listed species. An on -site survey is the only definitive means to determine if the proposed project would
impact rare, threatened, or endangered species.
Aerial images and maps indicate the Cape Fear River flows directly east and south of the proposed project
site. There are records for the following imperiled, aquatic species downstream of the site in the Cape
Fear River: the federal and state -endangered, Cape Fear shiner (Notropis mekistocholas); the state -
endangered, yellow lampmussel (Lampsilis cariosa); the state -threatened, eastern lampmussel (Lampsilis
radiata); and the state -special concern, Roanoke slabshell (Elliptio roanokensis). The following
recommendations will minimize impacts to aquatic and terrestrial wildlife resources:
1. Maintain a minimum 100-foot undisturbed, native, forested buffer along perennial streams,
and a minimum 50-foot buffer along intermittent streams and wetlands. Maintaining
undisturbed, forested buffers along these areas will minimize impacts to aquatic and
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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terrestrial wildlife resources. Wide riparian buffers are helpful in maintaining stream bank
stability. In addition, these buffers provide a travel corridor for wildlife species. Lay down
and staging areas should be located outside wetland areas and at least 100 feet from stream
banks.
2. Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and
water quality protection. If necessary, crossings should only be at the narrowest point of
wetland areas. In all forested wetlands, clearing should be done by hand.
3. The directional bore (locating utilities beneath the riverbed and avoiding impacts to the
stream and buffer) stream crossing method should be used for utility crossings wherever
possible; the open cut stream crossing method should only be used when water level is low
and stream flow is minimal. Stream crossings should be near perpendicular (750 to 1050) to
stream flow.
4. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re -seeded with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures as fescue is invasive and provides little benefit to wildlife. Native, annual small
grains appropriate for the season are preferred and recommended. Pollinator mixes are
commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths, and other beneficial insects. Where feasible, use woody debris and logs
from cleared areas to establish brush piles adjacent to the cleared right-of-way to improve
habitat. Allowing the corridor area to re -vegetate into a brush/scrub habitat would maximize
benefits to wildlife. For areas adjacent to residential areas, a native shrub/grass option may
also be beneficial.
5. Due to the decline in populations of tree -roosting bat species, avoid tree clearing activities
during the maternity roosting season for bats (May 15 — August 15), such as the federally
proposed endangered tricolored bat.
6. Minimize corridor maintenance, remove invasive plant species, and prohibit mowing between
April 1 and October 1 to lessen impacts to nesting wildlife. Create a maintenance schedule
that incorporates only a portion of the area (one third of the area, for example) each year
instead of the entire project area every 3 to 4 years. Pesticides (including insecticides and
herbicides) should not be used for maintenance of ROWs within 100 feet of perennial streams
and 50 feet of intermittent streams, or within floodplains and wetlands associated with these
streams.
Sediment and erosion control measures should be 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 and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede 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 aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water

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Sanford Water Filtration Facility 30 MGD Expansion
DEQ Project No. 23-0094
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources; in addition, the Green Growth
Toolbox (https://www.ncwildlife.or conserving/programs/Green-Growth-Toolbox) provides information
on nature -friendly planning that discusses how to address growth while concurrently conserving priority
terrestrial and aquatic habitat.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or [e-mail].