20170130 Ver 1_WRC Comments_20170227

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Jean Gibby
Raleigh Regulatory Field Office
United States Army Corps of Engineers
FROM: Olivia Munzer�
Western Piedmont Coordinator "
Habitat Conservation
DATE: 27 February 2017
SUBJECT: Pre -Construction Notification for the I-85 Business Park - Sanitary Sewer Improvements;
Davidson County; DEQ Project No. 20170130.
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), 16 U.S.C.
661-667d), and North Carolina General Statutes (G. S. 113-131 et seq.).
Carolina Ecosystems, Inc., on behalf of Davis -Martin -Powell & Associates, Inc. and Davidson County,
has submitted a Pre -Construction Notification (PCN) application for the I-85 Business Park — Sanitary
Sewer Improvements Project in Linwood, Davidson County, North Carolina. The project involves the
construction of a force main that connects the proposed I-85 Business Park pump station to an existing
pump station located approximately 5.3 miles north of I-85, and the construction of a permanent
maintenance access road to the I-85 Business Park pump station. The proposed project would impact a
total of 1.04 acres of wetland, of which 0.65 acres are temporary, and a total of 584 linear feet (If) of
streams, of which 541 if are temporary.
The proposed project crosses unnamed tributaries to South Potts Creek, unnamed tributaries to North
Potts Creek, North Potts Creek, unnamed tributaries to Swearing Creek, and Swearing Creek. South Potts
Creek, North Potts Creek, and Swearing Creek occur in the Yadkin River basin and are classified as a
Class C streams by N.C. Division of Water Resources (NCDWR).
We have records for the eastern lampshell (Lampsilis radiata), a state threatened species, in the Yadkin
River near the project area. N.C. Agricultural Development and Farmland Preservation Trust Fund
Easements lie adjacent to the proposed project. Searing Creek Swamp Forest Natural Area occurs along
Swearing Creek downstream of the project area. Linwood Game Land and High Rock Reservoir
Wetlands Natural Area occur along the Yadkin River south of the proposed project. A current record of a
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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27 February 2017
I-85 Business Park — Sanitary Sewer Improvements
DEQ Project No. 20170130
northern -long eared bat (Myotis septentrionalis), a federally threatened and state significantly rare
species, occurs in Davidson County with no specific location provided. Therefore, the northern long-
eared bat may be present within or adjacent to the site. As such, consultation with the USFWS may be
required. For more information, please see
haps://www.fws.gov/Midwest/endangered/mammals/nleb/index.html or contact the USFWS at (828)
258-3939 to ensure that potential issues related to this species are addressed.
We offer the following recommendations to 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 terrestrial wildlife
resources, water quality, and aquatic habitat both within and downstream of the project area.
Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment
of pollutants associated with urban stormwater.
2. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer
areas. All utility crossings should be kept to a minimum, which includes careful routing design
and the combination of utility crossings into the same right-of-way (provided there is not a safety
issue). The directional bore (installation of utilities beneath the riverbed, avoiding impacts to the
stream and buffer) stream crossing method should be used for utility crossings wherever
practicable, and the open cut stream crossing method should only be used when water level is low
and stream flow is minimal. Manholes or similar access structures should not be allowed within
buffer areas. Stream crossings should be near perpendicular (750 to 105°) to stream flow. We
recommend a minimum 100 -foot setback for perennial streams and a 50 -foot setback for
intermittent streams and wetlands.
3. Reduce the number of stream crossings to avoid or minimize impacts. After construction,
disturbed stream banks and wetlands should be restored to original contours and re -vegetated
with native plant materials. Riprap may be used to stabilize the bank in the area of the ordinary
high water stage and vegetation (bioengineering) should be used above this stage. Riprap should
not be placed on the streambed.
4. Avoid removal of large trees at the edges of the construction corridor. Disturbed areas should be
re -seeded with seed mixtures that are beneficial to wildlife. Avoid fescue -based mixtures because
fescue is invasive and provides little benefit to wildlife. Native, annual small grains appropriate
for the season are preferred and recommended. Where feasible, use woody 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. 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. Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to minimize
impacts to nesting wildlife. The NCWRC recommends 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. Avoid using herbicides within 100 feet of perennial streams and 50
feet of intermittent streams, or within floodplains or wetlands associated with these streams.
6. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate
the need to fill and culvert, where practicable. If culverts must be used, the culvert should be
designed to allow aquatic life passage. Fords may be appropriate and preferred for intermittent
stream crossings or where crossings will be used only once or twice a year. For fords, crossings
in riffles are preferred with the banks lowered upstream and downstream of the crossing.
Stabilize the stream bottom with geo-textile fabric and rock; concrete should not be used for bed
stabilization.

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27 February 2017
I-85 Business Park — Sanitary Sewer Improvements
DEQ Project No. 20170130
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. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment loads can
have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
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:
htip://www.ncwildlife.org_/portals/0/Conserving/documents/2002_ GuidanceMemorandumforSecondaryan
dCumulativeImpacts.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 olivia.munzer&ncwildlife.org.
ec: Karen Higgens, NCDWR
Allen Ratzlaff, U.S. Fish and Wildlife Service
W. Thomas Russ, NCWRC