20231624 Ver 1_WRC Comments sent to Applicant_20240110

Baker, Caroline D
From: Tillery, Julia A CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, January 16, 2024 9:21 AM
To: Thomas, Zachary T
Subject: [External] FW: NCWRC Comments - SAW-2022-01307 - Morgan Creek Interceptor
Replacement - Orange Co.
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Julia Tillery
Regulatory Specialist, Raleigh Regulatory Field Office
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Email: Julia.A.Tillerv(@usace.armv.mil
From: Munzer, Olivia <[e-mail]>
Sent: Wednesday, January 10, 2024 10:10 AM
To: [e-mail]
Cc: Tillery, Julia A CIV USARMY CESAW (USA) <[e-mail]>; Myers, Joseph M
<[e-mail]>; Ellis, John <[e-mail]>
Subject: [Non-DoD Source] NCWRC Comments - SAW-2022-01307 - Morgan Creek Interceptor Replacement - Orange Co.
Good morning Ms. Reusche,
Please see the following comments:
• We have records of the state endangered and federal proposed endangered tricolored bat (Perimyotis
subflavus) near the project. Therefore, we recommend tree clearing activities occur outside the active
season (April 1 to November 14).
We have recent records of the state endangered southern anemone (Anemone berlandieri) and state
significantly rare large witch -alder (Fothergilla major). We recommend avoiding any impacts to these plant
species. We also recommend using native plants for disturbed areas; we recommend coordinating with
the NC Botanical Gardens. Avoid using invasive and/or non-native species such as Bermudagrass, redtop,
tall fescue, and lespedeza. 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.
• We reviewed the Freshwater Mussel Survey Report. We have no additional comments or
recommendations.
• We recommend the stream is crossed using horizontal directional drilling or jack and boring. However, if
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. The
stream should be restored to its natural function. Native vegetation, state-of-the-art natural channel
design, and restoration techniques should be used for stream stabilization at stream crossings.
• The project is within the Morgan Creek Bluffs and Laurel Hill Natural Heritage Natural Area and in the North
Carolina Botanical Garden and William Lanier Hunt Arboretum Managed Areas. We recommend further
minimizingthe impact to the riparian buffer. Maintain or establish 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.
• Erosion control matting made of plastic mesh or twine should not be used within the project area because
it can injure or kill wildlife.
Thankyou,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
Rogers Depot
1718 NC Hwy 56 W
Creedmoor, NC 27522
Office: 919-707-4056 (note new number)
Cell: 336-269-0074
[e-mail]
www.ncwildlife.org
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