20160450 Ver 1_WRC Comments_20160620

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: John Policarpo
Wilmington Regulatory Field Office
US Army Corps of Engineers
FROM: Gabriela Garrison
Eastern Piedmont Coordinator
Habitat Conservation
DATE: June 20, 2016
SUBJECT: Public Notice for Piedmont Natural Gas for the Construction of a 4.7 -mile Natural Gas
Distribution Pipeline, Robeson County, North Carolina. Corps Action ID 9: SAW -2016-
00586.
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), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e) and North
Carolina General Statutes (G.S. 113-131 et seq.).
The applicant proposes to clear approximately 1.96 acres of palustrine, forested wetlands in order to
construct a 0.96 -mile section of natural gas pipeline. The overall pipeline is 4.7 miles long and located
within an existing utility line right-of-way (ROW) and new alignment; it will be constructed through pine
plantation, hardwood forests and both residential and agricultural areas. The pipeline ROW will include a
30 -foot wide maintained ROW and a 20 -foot wide temporary construction easement. The proposed line
will be an upgrade from 3 -inch pipeline to 8 -inch pipeline and will service new commercial and industrial
developments being built in the area. Mitigation for the project includes the purchase of mitigation bank
credits from the Stone Farm Regional Mitigation Bank at a 1:1 ratio. The western -most portion of the
pipeline ROW is located northeast of the intersection of Russell and Lombardy Village Roads and travels
east-northeast to Ireland Road, where it will reconnect with an existing pipeline, northeast of St. Pauls in
Robeson County.
The site drains to Big Marsh Swamp in the Lumber River Basin. The NC Natural Heritage Program's
Natural Area, Big Marsh Swamp, is located downstream of the project site.
The NCWRC hesitates to concur with the conversion of wetlands due to changes and potential loss of
wildlife habitat. If the permit is approved, the NCWRC offers the following recommendations to
minimize impacts to aquatic and terrestrial wildlife resources:
1. Avoid the removal of large trees at the edges of construction corridors. Where feasible, use woody
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
June 20, 2016
PNG Pipeline, St. Pauls
Corps Action ID No.: SAW -2016-00586
debris and logs from corridor clearing to establish brush piles and downed logs adjacent to the cleared
right-of-way to improve habitat for wildlife.
2. Re -seed all disturbed areas 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. 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 be beneficial.
Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to minimize
impacts to nesting wildlife. We suggest 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 every 3 or 4
years. Pesticides should never be used in wetland areas or near streams.
4. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a 50 -
foot buffer along intermittent streams and wetlands. Maintaining undisturbed, forested buffers along
these areas will minimize impacts to aquatic and terrestrial wildlife resources, water quality and
aquatic habitat both within and downstream of the project area. If the pipeline's project path parallels
any streams, the edge of the construction corridor should be located a minimum of 100 feet from the
stream bank.
5. Where feasible, wetland areas should be spanned. In addition to providing wildlife habitat, wetland
areas perform important functions of flood control and water quality protection. Temporarily
disturbed wetland areas should be returned to original soils and contours, reseeded with annual small
grains appropriate for the season (e.g. oats, millet, rye, or wheat) and allowed to revert to natural
wetland vegetation.
6. Sediment and erosion control measures should be installed prior to any land clearing or construction.
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 that has been reinforced with plastic or metal mesh should be avoided as it impedes 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 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 Quality details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
htlp://www.ncwildlife.org_/portals/0/Conserving/documents/2002_ GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002). In addition, the Green Growth Toolbox provides information
on nature -friendly planning: hqp://www.ncwildlife.org/Conservin /g Programs/GreenGrowthToolbox.aspx.
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 gabriela.garrisonkncwildlife.org.
ec: Karen Higgins, NCDWR