20031524 Ver 1_Other Agency Comments_20040116

® North Carolina Wildlife Resources Commission
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: John Dorney, Supervisor
Wetlands/401 Water Quality Certification Unit
DIN'sion of Water Quality
FROM: Shari L. Bryant, Piedmont Region Coordinator -
Habitat Conservation Program
DATE: 16 January 2004
SUBJECT: Pre-Construction Notification Application for Mark Ellington - Dove Road Subdivision,
Oxford, Granville County, North Carolina. DWQ ID: 031524
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document, and we are familiar with the habitat values of the area. Our comments are provided in
accordance with provisions of the Clean Water Act of 1977 (as amended), the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), and North Carolina General Statutes
(G.S. 113-131 et seq.).
The applicant is proposing to impact 330 linear feet (if) of perennial stream channel that flow to
Fishing Creek in the Tar-Pamlico River basin and is proposing to fill 0.02 acres of wetlands. The purpose
of this project is for access and development of single family residences. The previous property owner
relocated approximately 290 If of the perennial stream channel for road construction and to create better
building lots. Although there are no records for threatened or endangered species in Fishing Creek, there
are records for several threatened or endangered species including the federal and state endangered dwarf
wedgemussel (Alasmidonta heterodon) in the Tar River.
We appreciate the efforts the applicant has taken to minimize impacts to this perennial stream by
planning to restore the riparian buffer by replanting native trees. However, we are concerned that the
relocated section of stream may be unstable as indicated by the note "stabilize areas of bare rock and soil"
on the Riparian Buffer Restoration Plan.
We provide the following recommendations to further reduce impacts to fish and wildlife
resources.
1. Restore the stream channel (pattern, profile and dimension) and riparian buffer, to its original
location. If it not possible to restore the stream to its original channel (e.g., Lot 20 is already
developed), the relocated section of stream should be stabilized, preferably with natural
stabilization methods, to minimize bank erosion and downstream sedimentation. 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.
Mailing Address; Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] ext. 281 • Fax: [phone]

Page 2
16 January 2004
Dove Road Subdivision
NCDWQ No. 031524
2. Lot 22 should be included in the riparian restoration plan if the riparian buffer on this lot is not
forested. In order to minimize stream impacts, while retaining some measure of wildlife habitat,
we typically recommend a 100-foot undisturbed, native, forested buffer along perennial streams,
and a 50-foot buffer along intermittent streams and wetlands. Maintaining undisturbed, forested
buffers along these areas will minimize impacts to fish and wildlife resources, water quality,
aquatic habitat both within and downstream of the project area. In addition, wide riparian buffers
are helpful in maintaining stability of stream banks and for treatment of pollutants associated with
urban stormwater. Whereas, a grassed buffer, particularly fescue, is a vegetated buffer it will not
provide the necessary and highly valuable functions as discussed for forested buffers.
3. Lot 22 should be included in the deed notification (Riparian Buffer Restoration Plan Notes, #8) to
protect the riparian buffer on this lot. We further recommend adding to the deed notification that
mowing or clearing within the buffer area be prohibited.
4. If culverts must be used, the culvert should be designed to allow passage of aquatic organisms.
Generally, this means that the culvert or pipe invert is buried at least one foot below the natural
streambed. If multiple cells are required, the second and/or third cells should be placed so that
their bottoms are at stream bankfull stage. This will allow sufficient water depth in the culvert or
pipe during normal flows to accommodate movements of aquatic organisms. If culverts are long
and sufficient slope exists, baffle systems are recommended to trap gravel and provide resting
areas for fish and other aquatic organisms. If multiple pipes or cells are used, at least one pipe or
box should be designed to remain dry during normal flows to allow for wildlife passage. In
addition, culverts or pipes should be situated so that no channel realignment or widening is
required. Widening of the stream channel at the inlet or outlet of structures usually causes a
decrease in water velocity causing sediment deposition that will require future maintenance.
Finally, riprap should not be placed on the streambed.
5. Concrete is toxic to aquatic life and should not be allowed to come in contact with surface waters
until cured.
6. The construction of roadways and other impervious surfaces in new neighborhoods can produce
short-term direct impacts as well as long-term cumulative effects. Multiple studies have shown
that stream degradation occurs at 10% impervious (Schueler 1994; Arnold and Gibbons 1996;
Doll et al. 2000; Mallin et al. 2000; May and Horner 2000; Stewart et al. 2000; Paul and Meyer
2001). To adequately protect streams, it is suggested that impervious surface is limited to less
than 10% (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al. 2000; May
and Horner 2000; Stewart et al. 2000; Paul and Meyer 2001). Alternatively, provide for sufficient
open space to effectively reduce impervious surface so that predevelopment hydrographic
conditions are maintained. To achieve no net change in the hydrology of the watershed, we
recommend installation of grassed swales in place of curb and gutter and on-site stormwater
management (i.e. bioretention areas). Information on innovative stormwater and low impact
design (LID) ideas may be obtained at www.lowimpactdevelgpment.org (accessed October
2003).
7. We recommend that landscaping consist of non-invasive native species and LID technology.
Using native species instead of ornamentals should provide benefits by reducing the need for
fertilizers, herbicides, and pesticides. Additionally, native species should require less water.
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.

Page 3
16 January 2004
Dove Road Subdivision
NCDWQ No. 031524
8. We recommend that the following measures be incorporated into the erosion and sediment
control plan (see Brown and Caraco 2000 for additional information).
a) Minimize clearing and grading and only perform these operations in the context of an overall
stream protection strategy.
b) Protect waterways by preventing clearing adjacent to waterways, and stabilize drainage ways.
c) Phase construction for larger construction sites (?25 acres) to reduce the time and area that
disturbed soils are exposed.
d) Stabilize soils as rapidly as possible (<2 weeks) by establishing a grass or mulch cover.
e) Protect steep slopes, and avoid clearing or grading existing steep slopes as much as possible.
f) Establish appropriate perimeter controls at the edge of construction sites to retain or filter
concentrated runoff from relatively short distances before it leaves the site.
g) Employ advanced settling devices that contain design features which include wet or dry
storage volume, perforated risers, better internal geometry, use of baffles, skimmers and other
outlet devices, gentler side-slopes, and multiple cell construction. The system should be
designed to protect against storm events of variable sizes, including the 100-yr storm event.
h) Utilize LID technologies in design such as the distributed control approach, where the post
development excess runoff volume is retained in discrete units throughout the site to emulate
the predevelopment hydrologic regime (Prince George's County DER 1999). Management
of both runoff volume and peak runoff rate would be included in the design.
i) Maintain predevelopment flow rates during and after construction.
j) Implement a certified contractors program so trained and experienced contractors are on-site
and oversee installation and maintenance of BMPs.
k) Sedimentation impacts should be minimized by regular inspection of erosion control
measures, and sediment control devices should be maintained in good and effective condition
at all times. Erosion and sediment controls should be reassessed after storms. The incorrect
installation of erosion control structures and those not properly maintained can result in
sedimentation impacts to nearby streams and wetlands.
1) Utilize onsite vegetation and materials for bank stabilization, minimize the use of riprap (or
hard stabilization methods), and maximize the use of native vegetation for stabilization and
shade. We request that matting along with vegetation be used to stabilize the side slopes
adjacent to wetlands to prevent soil erosion into these sensitive areas.
Thank you for the opportunity to provide input during the planning stages for this project. If we
can be of further assistance, please contact our office at [phone].
Literature Cited:
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage-the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258.
Brown, W., and D. Caraco. 2000. Muddy water in - muddy water out? Watershed Protection
Techniques 2(3):393-403.
Doll, B. A., D. E. Wise-Frederick, C. M. Buckner, S. D. Wilkerson, W. A. Harman, and R. E. Smith.
2000. Hydraulic geometry relationships for urban streams throughout the piedmont of North
Carolina. Pages 299-304 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings of the
American Water Resources Association International Conference on riparian ecology and
management in multi-land use watersheds, Portland, Oregon.

Page 4
16 January 2004
Dove Road Subdivision
NCDWQ No. 031524
Mallin, M. A., K. E. Williams, E. C. Esham, and R. P. Lowe. 2000. Effect of human development on
bacteriological water quality in coastal watersheds. Ecological Applications 10(4):1047-1056.
May, C. W. and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on stream-
riparian ecosystems. Pages 281-286 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings
of the American Water Resources Association International Conference on riparian ecology and
management in multi-land use watersheds, Portland, Oregon.
Paul, M. J., and J. L. Meyer. 2001. Streams in the urban landscape. Annual Review of Ecology and
Systematics 32:333-365.
Prince George's County, Maryland. 1999. Low-impact development hydrologic analysis. Department of
Environmental Resources, Prince George's County, Maryland.
Schueler, T. 1994. The importance of imperviousness. Watershed Protection Techniques. 1(3):100-
111.
Stewart, J. S., D. M. Downes, L. Wang, J. A. Wierl, and R. Bannerman. 2000. Influences of riparian
corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J. Wigington, Jr. and
R. L. Beschta, eds. Proceedings of the American Water Resources Association International
Conference on riparian ecology and management in multi-land use watersheds, Portland, Oregon.
cc: Andrea Wade, USACOE
E-mail: Steve Mitchell, DWQ
Sarah McRae, NHP
Angie Rodgers, WRC