20171396 Ver 1_WRC Comments_20171201

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Joey Lawler, PWS
Project Manager
S&ME
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 01 December 2017
SUBJECT: Pre -Construction Notification for the PSCN Energy - Cliffside Lateral Pipeline Project;
Cleveland and Rutherford Counties. DEQ No. 20171396.
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) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
S&ME, on behalf of PSNC Energy (PSNC), has submitted a Pre -Construction Notification application for
the Cliffside Lateral pipeline project in Rutherford and Cleveland counties, North Carolina. The
approximately 7 -mile natural gas pipeline will be installed within a new permanent easement, which will
mostly be 50 feet wide. The pipeline project will originate at PSNC's T-001 transmission line west of
Trinity Grove Church Road in Mooresboro, Cleveland County (35.268065°N, 81.715901°W) and will
terminate at the Duke Energy Cliffside Plant in Rutherford County (35.214355°N, 81.763555°W).
The pipeline would cross Grog Creek and its unnamed tributaries (UTs), Second Broad River and its UTs,
Broad River and its UTs, and an UT to Riddles Creek within the Broad River basin. The NC Division of
Water Resources (NCDWR) classifies the Second Broad River, Broad River, Riddles Creek, and Grog
Creek as Water Supply IV streams.
No protected/managed lands, conservation easements, or high-quality natural communities occur within
the proposed project area; however, a Dry-Mesic Basic Oak -Hickory Forest natural community occurs
within 500 feet of the proposed pipeline. We have records for the federal species of concern and state
significantly rare (SR) Carolina foothills crayfish (Cambarus johni); and state SR quillback (Carpoides
cyprinus) and seagreen darter (Etheostoma thalassinum) in the Second Broad River and/or Broad River.
Records of plant species near the proposed pipeline include the federally threatened and state threatened
dwarf -flowered heartleaf (Hexastylis naniflora); state endangered single -flowered sandwort (Mononeuria
uniflora); state threatened horned bladderwort (Utricularia cornuta); and state species of special concern
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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O1 December 2017
PSNC Cliffside Lateral Pipeline Project
Cleveland and Rutherford Counties
(vulnerable) Pursh's wild -petunia (Ruellia purshiana). The U.S. Fish and Wildlife Service (USFWS) lists
the threatened northern long-eared bat (Myotis septentrionalis) as potentially occurring within or adjacent
to the project area if suitable habitat occurs. As indicated in the PCN application, S&ME has already
coordinated with the USFWS on federally -protected species that are documented within the project area.
If the permit is issued, the NCWRC offers the following general recommendations to minimize impacts to
aquatic and terrestrial wildlife resources.
1. Maintain or establish a minimum 100 -foot native forested buffer along each side of perennial
streams and 50 -foot native forested buffer along each side of intermittent streams and wetlands.
2. We are pleased to see horizontal directional drilling (HDD) will be used at the Second Broad and
Broad River crossings and the Best Management Practices implemented during construction at
the stream crossings. We would prefer the work area for the HDD remain outside the riparian
buffers and equipment should not be staged in stream channels or riparian buffers during
construction.
3. We are pleased to see riparian and wetland disturbed areas will be re -seeded with native seed
mixtures. If possible, avoid using Bermudagrass, redtop, tall fescue, and lespedeza, which are
invasive and/or non-native and provide little benefit to wildlife.
4. S&ME states restoration sites will be monitored until herbaceous vegetation reaches 80%
coverage. Manage non-native, invasive species by pretreating the project site prior to
construction, preventing spread during construction, and control non-native, invasive species
throughout the monitoring period.
5. Avoid the removal of large trees at the edges of construction corridors. Tree clearing activities
should not occur during the maternity roosting season for bats (May 15 — August 15). Minimize
corridor maintenance and prohibit mowing between April 1 and October 1 to minimize impacts to
nesting wildlife.
6. Sediment and erosion control measures should be installed prior to any land -disturbing activity.
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.
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: David Brown, USACE
Alan Johnson, NCDWR
Bryan Tompkins, USFWS
William T. Russ, NCWRC
Andrea Leslie, NCWRC