20100899 Ver 3_WRC Comments_20170317

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: David Shaeffer,
Asheville Regulatory Field Office
United States Army Corps of Engineers
FROM: Olivia Munzer
Western Piedmont Coordinator-
Habitat Conservation
DATE: 17 March 2017
SUBJECT: Individual Permit Application for the Clearwater Paper Corporation Facility Expansion,
Cleveland County; USACE Action ID SAW -2010-00061 & SAW -2011-02398, DEQ
Project No. 201008990.
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.).
Clearwater Paper Corporation has submitted and Individual Permit (IP) application for the expansion of
the manufacturing facility and associated infrastructure. The approximately 266 -acre project area is
located north of the United States Highway 74 Shelby Bypass and east of Washburn Switch Road in
Shelby, Cleveland County, North Carolina.
The proposed project would cumulatively impact a total of 1,682 linear feet (If) streams and 0.12 acres of
wetlands, of which 104 if of streams and 0.09 acres of wetlands were impacted during construction of the
existing facility. In -lieu fees for 2,997 if of streams would be paid as mitigation to N.C. Division of
Mitigation Services. The proposed project would impact unnamed tributaries to Bushy Creek, which is a
tributary to the First Broad River in the Broad River basin. Bushy Creek is classified as a Class C stream
by N.C. Division of Water Resources (NCDWR).
We have records for Broad River spiny crayfish (Cambarus spicatus), Carolina foothills crayfish
(Cambarus johni), and seagreen darter (Etheostoma thalassinum) in Bushy Creek. Broad River spiny
crayfish is federal species of concern (FSC) and state species of special concern; Carolina foothills
crayfish is a FSC and state significantly rare (SSR) species; and seagreen darter is a SSR species. As
indicated in the IP application, Clearwater Environmental Consultants, Inc. documented dwarf -flowered
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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17 March 2017
Clearwater Paper Corporation
DEQ Project No. 201008990
heartleaf (Hexastylis nan flora), a federally threatened species, on the property and relocated plants to
areas that would remain unimpacted by the proposed project.
Due to the sensitive resources within the vicinity of the proposed project, we offer the following
recommendations to further minimize impacts to aquatic and terrestrial wildlife resources.
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.
Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. Where feasible, trees and
shrubs should be planted around stormwater ponds. This would provide habitat benefits that
offset those functions lost by development, partially restore aquatic habitats, reduce exposure of
the water surface to sunlight to minimize thermal pollution, and provide essential summer and
winter habitats.
3. Where practicable, bridges should be used for all permanent roadway crossings of streams and
associated wetlands to eliminate the need to fill and culvert. If culverts are used, culverts should
be designed to allow passage of aquatic life during low flow or drought conditions. Culverts 48
inches in diameter or larger should be buried one foot into the streambed. Culverts less
than 48 inches in diameter should be buried to a depth equal to or greater than 20% of their size.
If sufficient slope exists, baffle systems are recommended to trap gravel and provide resting areas
for fish and other aquatic organisms. Culverts or pipes should be situated so no channel
realignment or widening is required. Any riprap used should not interfere with aquatic life
movement during low flow.
4. Use non-invasive native species and Low Impact Development (LID) technology in landscaping.
Using LID technology in landscaping will not only help maintain the predevelopment hydrologic
regime, but also enhance the aesthetic and habitat value of the site. LID techniques include
permeable pavement and bioretention areas that can collect stormwater from driveways and
parking areas. Additional alternatives include narrower roads, swales versus curbs/gutters and
permeable surfaces such as turf stone, brick, and cobblestone.
5. 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.
6. Re -seed disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures because fescue is invasive and provides little benefit to wildlife. Using native species
instead of ornamentals should reduce the need for water, fertilizers, and pesticides. We also urge
the Clearwater Paper Corporation to incorporate pollinator species into their plantings. Further
information and free technical guidance from NCWRC is available upon request.
Sediment and erosion control measures should use advanced methods and 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.

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17 March 2017
Clearwater Paper Corporation
DEQ Project No. 201008990
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(a�ncwildlife.org.
ec: Karen Higgins, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service
W. Thomas Russ, NCWRC