20181393 Ver 1_NC WRC Comments_20181115

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Suzanne Herron, P.E., CPESC
Energy Land & Infrastructure, PLLC
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 15 November 2018
SUBJECT: Pre -Construction Notification for the Piedmont Natural Gas — Line 446 Belews Creek
Gas Line Project; Guilford, Rockingham, and Stokes Counties. USACE Action ID:
SAW -2018-00885; DEQ No. 20181393.
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.).
Energy Land & Infrastructure, on behalf of Piedmont Natural Gas (PNG), has submitted a Pre -
Construction Notification application for the Line 446 Belews Creek Gas Line project in Stokes,
Rockingham, and Guilford counties, North Carolina. The approximately 9 -mile natural gas pipeline will
be installed within a new permanent easement, which will mostly be 60 feet wide. The pipeline project
will originate at the Duke Energy Corporation (Duke) Belews Creek Steam Plant in Stokes County
(36.278139°N, 80.055796°W) and terminate at the proposed regulator station site at Walter Combs Way
in Guilford County (36.237654°N, 79.922224°W).
The pipeline would cross unnamed tributaries (UTs) to Belews Creek, UTs to Hogans Creek, a UT to
Little Hogans Creek, UT to Troublesome Creek, Troublesome Creek, and a UT to Haw River. UTs to
Belews Creek, Little Hogans Creek, and Hogans Creek occur within the Roanoke River basin.
Troublesome and its UTs, and the UT to Haw River are in the Cape Fear River basin. The project would
temporarily impact 1,193.2 linear feet of streams and permanently impact 0.48 acres of forested wetlands
by their conversion to non -forested wetlands.
No protected/managed lands, conservation easements, or high-quality natural communities occur within
the proposed project area; however, the Troublesome Creek/Ogbums Crossroads Alluvial Forests Natural
Heritage Natural Area (NHNA), Rock Branch Mesic Mixed Hardwood Forest NHNA, Haw River Skunk
Cabbage Patch NHNA, and Haw River Bur -Reed Floodplain occur within the vicinity of the proposed
pipeline. We have records for the state endangered green floater (Lasmigona subviridis), state threatened
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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15 November 2018
PNG Line 446 Belews Creek Gas Line
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notched rainbow (Villosa constricta), state special concern Carolina darter (Etheostoma collis) and North
Carolina spiny crayfish (Orconectes carolinensis), and state significantly rare riverweed darter
(Etheostoma podostemone) within the vicinity of the project. As indicated in the PCN application, Dial
Cordy and Associates, Inc. conducted a federal threatened and endangered species survey and no
occurrences of small -whorled pogonia (Isotria medeoloides), smooth coneflower (Echinacea laevigata),
or Schweinitz's sunflower (Helianthus schweinitzii) were documented in the project area.
If the permit is issued, the NCWRC offers the following general recommendations to minimize impacts to
aquatic and terrestrial wildlife resources.
Ensure compliance with the Belews Lake Shoreline Management Guidelines.
2. 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.
3. We are pleased to see HDD will occur at Belews Lake and boring will occur along some of the
streams, including Troublesome Creek. We recommend the work area for the HDD and boring
remain outside the riparian buffers and equipment should not be staged in stream channels or
riparian buffers during construction.
4. NCWRC is pleased the pipeline will be co -located with the existing Duke overhead line right-of-
way (ROW) along much of the pipeline. However, we recommend avoiding or minimizing forest
fragmentation by moving the pipeline closer to the Duke ROW near the Belews Creek Steam
Station (18+00 to 37+00) and east side of Belews Lake (56+00 to 80+00), if possible.
5. Trenches left open during project construction can trap or injure wildlife. We recommend closing
trenches at the end of each day or conduct sweeps of trenches to clear wildlife at least once in the
morning prior to construction.
6. Avoid using Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-
native and provide little benefit to wildlife. Consider using native seed mixtures that are
beneficial to wildlife to revegetate upland disturbed areas. Specifically, this project would be
ideal for planting native, wildflower seed mixes that will create pollinator habitat within the
project boundary. Pollinators are some insects (i.e., bees, moths, and butterflies) and birds that
play an important role in the reproduction of flowering plants, which produce many fruits and
vegetables. Habitat loss, disease, and other environmental changes have caused a decline in
pollinators.
7. Avoid equipment maintenance in the immediate vicinity of streams and wetlands, make stream
and wetland crossings as narrow as possible, minimize stream bank disturbance, and right -of way
(ROW) maintenance on stream banks and in wetlands should be conducted by hand so woody
vegetation can resprout.
8. Pesticides, fertilizers, and other chemicals should not be used near wetlands or streams.
9. Avoid the removal of large trees or snags at the edges of construction corridors. Due to the
decline in bat populations, tree clearing activities should be avoided during the maternity roosting
season for bats (May 15 — August 15).
10. Stream banks should be stabilized, and sediment barriers installed as soon as possible, but at least
within 24 hours.
11. After construction, the natural dimension, pattern, and profile of the streams should be restored
using state-of-the-art natural channel design and restoration techniques. We are pleased to see

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15 November 2018
PNG Line 446 Belews Creek Gas Line
Stokes, Rockingham, and Guilford Counties
riparian and wetland disturbed areas will be re -seeded with native seed mixtures. Monitoring is
recommended to ensure successful channel and bank stabilization and vegetation growth.
Invasive species control should occur regularly, including prior to construction.
12. Minimize ROW maintenance and prohibit mowing between April 1 and October 1 to minimize
impacts to ground -nesting birds. We suggest a maintenance schedule that incorporates a portion
of the area (e.g., one-third of the area) each year.
13. Ensure the HDD Inadvertent Release Documentation is completed for all releases and contractors
adhere to the HDD Contingency Plan.
14. 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 matting 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
entangles wildlife and is slow to degrade, resulting in a hazard that may last for years.
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(i�ncwildlif M.
ec: David Bailey, USACE
Sue Homewood, NCDWR
Bryon Hamstead, USFWS
Alicia DePalma, PNG
William T. Russ, NCWRC
Brena Jones, NCWRC
Andrea Leslie, NCWRC