20150266 Ver 2_WRC Comments_20180302

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
March 2, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Mtn. Electric Cooperative's Sugar Mountain 69 kV Transmission Line
UTs to Leroy Creek and UT to Elk River, Avery County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application for impacts associated with the Sugar Mountain 69 kV Transmission Line Project,
which include 123 ft of two unnamed tributaries (UTs) to Leroy Creek and UT to Elk River. 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).
Mountain Electric Cooperative (MEC) intends to build 4.5 miles of new 69 kV transmission line
with a 75 -ft right-of-way (ROW). Brush and tree debris will be chipped and spread within the
ROW. The ROW will be maintained in early successional habitat. Within 25 ft of streams,
MEC will manually cut woody vegetation, maintaining it at a height of 15 ft. MEC has modified
its plans so that initial stream and wetland impacts have been reduced to three culverts on three
streams. Culverts will be single -barreled corrugated HDPE.
There are Brook Trout, Brown Trout, and Rainbow Trout in the vicinity of the culvert impacts,
and instream activities should be avoided between October 15 and April 15 in order to minimize
impacts to trout spawning. Brook Trout are especially sensitive to sediment impacts, and
vigilant sediment and erosion control are essential to protect this species.
The line crosses through high elevation forested habitats that likely serve as habitat for a number
of Species of Greatest Conservation Need, including the Hermit Thrush [Catharus guttatus, NC
Significantly Rare (SR)], Veery (Catharus fuscenscens), Common Raven (Corvus corax), and
Ruffed Grouse (Bonasa umbellus). Avoiding rock outcrops and cliffs will minimize impacts to
the Common Raven. In addition, it is likely that the line will pass through habitat for Weller's
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

MEC Sugar Mountain 69 kV Transmission Page 2 March 2, 2018
Avery County
Salamander (Plethodon welleri, NC Special Concern) and Northern Pygmy Salamander
(Desmognathus organi, NC SR). Leaving downed woody debris in the ROW can help to lessen
impacts to these rare salamanders.
We strongly recommend that PSNC use native grasses and herbaceous plants in their permanent
seeding specifications. The US Fish and Wildlife Service (USFWS) provided MEC a native seed
mix example that incorporates pollinator species. More utility line projects are incorporating
native pollinators into their plantings; for example, the Atlantic Coast Pipeline has proposed
regionally tailored native seed mixes that incorporate pollinator species (see
https://www.dom.com/about-us/news-center/natural-gas-prof ects-and-initiatives/atlantic-coast-
pipeline/ferc-filings-and-information).
We offer the following recommendations to minimize impacts to terrestrial and aquatic wildlife:
1. Avoid instream activities between October 15 and April 15 to minimize impacts to Brook
Trout, Brown Trout, and Rainbow Trout spawning.
2. In order to protect native Brook Trout in the Leroy Creek area, disturbed areas should be
seeded, mulched and/or matted as soon as possible, preferably at the end of each work
day; at a minimum, disturbed areas should be stabilized within five working d4ys or
seven calendar dam whichever is shorter. The area where these stricter stabilization
standards are used must include all areas of the line south of the western Elk River
crossing and west of Wildcat Creek.
3. 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.
4. Avoid equipment maintenance in the immediate vicinity of streams, make stream
crossings as narrow as possible, and minimize stream bank disturbance.
5. At culvert locations, banks should be restored to pre -construction contours, temporary
seed and matting installed, and a native riparian seed mix applied.
6. 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.
7. Any ROW vegetation maintenance work should generally be avoided between April 1
and October 1 to minimize impacts to ground nesting birds.
8. 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.
9. 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.

MEC Sugar Mountain 69 kV Transmission Page 3 March 2, 2018
Avery County
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Ec: Chris Wood, Lori Williams, Chris Kelly, NCWRC
Bryan Tompkins, US Fish and Wildlife Service
Andrew Moore, NC Division of Water Resources
Carson Dellinger, Environmental Resources of the Carolinas, Inc.