20180537 Ver 2_WRC Comments_20180926

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
September 26, 2018
Mr. William Elliott
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: PSNC M-64 Gas Pipeline Project Phase II -A
UT Holland Creek, Rutherford County
Dear Mr. Elliott:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application for impacts associated with the M-64 Phase II -A Pipeline Project, which include 50 ft
of temporary impact for an open cut crossing on an unnamed tributary (UT) to Holland Creek in
Rutherford 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 construct 6 miles of gas pipeline within the current road right-of-way (ROW).
The line crosses multiple streams in the Broad River basin, including Hollands Creek, Catheys
Creek, and unnamed tributaries. Wild trout would not be impacted by project activities, and a
trout moratorium is not needed.
The pipeline will be installed via trench cut through the UT to Hollands Creek. Three other
streams will be crossed via directional bore, avoiding stream impacts. Stream banks will be
restored to original contours. The final ROW will be 50 ft wide, but a ROW of 30 ft will be
maintained on the UT to Hollands Creeek. According to Mark Davis with Vaughn and Melton,
where directional boring will take place, riparian vegetation will not be disturbed except for a
potential 3-4 ft cleared trail during the process; after the boring takes place, a 50 -ft undisturbed
buffer will be maintained on these stream crossings.
We strongly recommend that PSNC use native grasses and herbaceous plants in their permanent
seeding specifications. The US Fish and Wildlife Service (USFWS) urged PSNC to incorporate
pollinator species into their plantings and provided specific planting recommendations. More
utility line projects are incorporating native pollinators into their plantings; for example, the
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

PSNC M-64 Phase II -A Page 2 September 26, 2018
Rutherford County
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-projects-and-
initiatives/atlantic-coast-pipeline/ferc-filings-and-information).
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. Stream banks should be stabilized with matting, temporary seed, and a native riparian
mix. We recommend that the native riparian mix also be applied 50 ft landward from the
stream.
4. Matting used for stabilization should be free of nylon or plastic mesh, as this type of
netting frequently entangles wildlife and is slow to degrade resulting in a hazard that may
last for years.
5. Any ROW vegetation maintenance work should generally be avoided between April 1
and October 1 to minimize impacts to ground nesting birds.
6. ROW maintenance on stream banks should be performed by hand, cutting woody
vegetation to allow resprouting. ROW maintenance through wetlands should also be
done by hand, avoiding the use of heavy machinery.
7. 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
[phone] if you have any questions.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
Ec: Bryan Tompkins, US Fish and Wildlife Service
Amy Annino, NC Division of Water Resources
Mark Davis, Vaughn & Melton