20170991 Ver 1_WRC Comments_20170915

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
August 23, 2017
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: PSNC 2.6 Mile Pipeline Project
UTs to French Broad River & Wetlands, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application
for impacts associated with the PSNC 2.6 Mile Pipeline Project, which include 230 ft of temporary
impact to three unnamed tributaries (UTs) to the French Broad River, as well as 0.04 acre of temporary
and 0.09 acre of permanent wetland impact in Buncombe County. Our comments on this application are
offered for your consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.)
and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
PSNC intends to place 2.6 miles of new gas pipeline within a new permanent 50 -ft wide easement, with
an additional 25 -ft wide temporary workspace. The line crosses three UTs to the French Broad River,
Lake Julian, and two wetlands. Wild trout would not be impacted by project activities, and a trout
moratorium is not needed.
The pipeline will be installed via trench cut in the wetlands and on one stream crossing. Lake Julian will
be crossed with horizontal directional drilling, avoiding direct channel disturbance. Two streams may be
impacted with temporary bridge mats. Wetlands will be crossed with equipment mats, wetland vegetation
cut at ground level, and where practicable, wetland topsoil will be set aside during trenching for
replacement afterwards and the wetland and 10 -ft buffer outside of the wetland replanted with a native
wetland seed mix. The stream will be trenched in the dry, with flows pumped around the work area.
Stream substrate will be applied on the streambed. Banks will be restored to pre -construction contours,
and coir matting and a cover crop and riparian mix applied to the banks and 10 feet landward from the top
of the banks.
In our February 24, 2017 comments, we recommended that fescue -based seed mixtures be avoided, as
fescue is invasive and provides little benefit to wildlife; the permanent upland seeding specifications are
not provided in the application. We strongly recommend that PSNC use native grasses and herbaceous
plants in their permanent seeding specifications. In their March 10, 2017 comments, the US Fish and
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

PSNC 2.6 -mile Pipeline Project Page 2 August 23, 2017
Buncombe County
Wildlife Service (USFWS) urged PSNC to incorporate pollinator species into their plantings; we
recommend that PSNC work with USFWS on specific planting recommendations.
The native riparian mix will also be planted 50 ft landward from the bank.
We offer the following recommendations to minimize impacts to terrestrial and aquatic wildlife:
1. Avoid equipment maintenance in the immediate vicinity of streams, make stream crossings as
narrow as possible, minimize stream bank disturbance, avoid spraying of herbicides, and cut
woody vegetation so that stumps can resprout.
2. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. 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.
3. For the trench cut in the stream, the top 6-12 inches of stream substrate should be stockpiled and
kept saturated during pipe installation, to be replaced once the pipe is installed.
4. We recommend that the native riparian mix be planted 50 ft landward from all stream banks that
are disturbed.
5. Matting used for stabilization should be free of nylon or plastic mesh, as this mesh netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
6. Any right-of-way vegetation maintenance work should generally be avoided between April 1 and
October 1 to minimize impacts to ground nesting birds.
7. Where feasible, work within the existing easement to minimize impacts to terrestrial wildlife
habitat. Avoid the removal of large trees at the edges of easement corridors. Use woody debris
and logs from any corridor clearing to establish brush piles and downed logs adjacent to the
cleared right-of-way to improve habitat for wildlife.
8. Re -seed all disturbed areas with seed mixtures that are beneficial to wildlife; avoid fescue based
mixtures because fescue is invasive and provides little benefit to wildlife. Native mixes of
grasses and herbaceous plants that emphasize pollinator species are 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.
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 558-
6011 if you have any questions.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Ec: Bryan Tompkins, US Fish and Wildlife Service
Zan Price, NC Division of Water Resources
Joey Lawler, S&ME