20170688 Ver 1_WRC Comments_20170717

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Aaron Moses
Heath and Associates
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 17 July 2017
SUBJECT: Pre -Construction Notification for the Lexington -Belmont Road Project; Davidson
County; DEQ Project No. 20170760.
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.).
Heath and Associates, Inc., on behalf of the City of Lexington, has submitted a Pre -Construction
Notification (PCN) application for the Belmont Road Project in Lexington, Davidson County, North
Carolina. The project involves the construction of natural gas pipeline that extends from the intersection
of Junior Order Home Road and New Jersey Church Road westward for approximately 3.9 miles to the
south side of Belmont Road. The project would be installed primarily along road and railroad easements.
The proposed project would temporarily impact a total of 0.0035 acres of wetland and 93 linear feet (If)
of streams.
The proposed project crosses an unnamed tributary to Yadkin River (High Rock Lake), an unnamed
tributary to North Potts Creek, North Potts Creek, Swearing Creek, an unnamed tributary to Swearing
Creek, and an unnamed tributary to Tar Creek in the Yadkin River basin. North Potts Creek, Swearing
Creek, and Tar Creek are classified as a Class C streams by N.C. Division of Water Resources (NCDWR)
and the Yadkin River is classified as a Water Supply -V river by NCDWR.
We have records for the eastern lampshell (Lampsilis radiata), a state threatened species, in the Yadkin
River near the project area. 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 northern -long eared bat
(Myotis septentrionalis), a federally threatened and state significantly rare species, occurs in Davidson
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Lexington — Belmont Road Natural Gas Project
DEQ Project No. 20170760
County with no specific location provided. Therefore, we recommend avoid tree clearing during the
maternity roosting season for bats (May 15 — August 15).
We prefer directional boring of the stream crossing to reduce the impacts to aquatic and terrestrial
resources. We offer the following recommendations to further 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. 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.
3. Pipelines 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. Stream
crossings should be near perpendicular (75° 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.
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.
Stringent sediment and erosion control measures should be implemented prior to any land
clearing or construction and maintained throughout project 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:
http://www.ncwildlife.org/portals/O/Conserving/documents/2002 GuidanceMemorandumforSecondq
dCumulativeImpacts.pdf (August 2002). In addition, the Green Growth Toolbox provides information on

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17 July 2017
Lexington — Belmont Road Natural Gas Project
DEQ Project No. 20170760
nature -friendly planning: http://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(c-r�,ncwildlife.org.
ec: Sue Homewood, NCDWR
Byron Hamstead, United States Fish and Wildlife Service
Jean Gibby, United States Army Corps of Engineers