20070128 Ver 1_WRC Comments_20081110

® North Carolina Wildlife Resources Commission
Gordon S. Myers, Executive Director
MEMORANDUM
TO: Ms. Emily R. Burton, Wilmington District
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 10 November 2008
SUBJECT: Public Notice for Plantation Investors, LLC for Construction of a Roadway and Sewer
Line for Mid-South Club, Moore County, North Carolina. Corps Action ID #: SAW-
2007-00490
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), Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), North Carolina General Statutes (G.S. 113-131 et
seq.), and North Carolina Administrative Code 15A NCAC 10I.0102.
The applicant proposes to discharge fill material into 0.126 acres of wetlands and is seeking after-
the-fact authorization for impacts to 0.04 acres of fill material. The impacts are associated with roadway
construction and sewer line installation in Mid-South Club, an existing residential community and golf
club. The purpose of the proposed project is to access an approximately 100-acre tract to provide
additional residential development. The applicant proposes mitigation for wetland impacts by providing
payment into the North Carolina Ecosystem Enhancement Program
The proposed project is located on an unnamed tributary to Aberdeen Creek in the Lumber River
basin. There are records for the federal and state endangered red-cockaded woodpecker near the project
area. According to information provided in the public notice, red-cockaded woodpecker foraging
partitions associated with Southern Pines-Pinehurst (SOPI) clusters 97 and 109 are present within the
project area; it is believed that both clusters are inactive. We suggest the applicant coordinate with the
U.S. Fish and Wildlife Service regarding potential impacts to red-cockaded woodpecker and its habitat.
Should the permit be issued, we offer the following recommendations to further minimize
impacts to aquatic and terrestrial wildlife resources.
A supplemental red-cockaded woodpecker survey should be conducted to ensure that no new,
undiscovered active cavity trees are present within the project area. Also, we request that the
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
Page 2
10 November 2008
Mid-South Club
Corps Action ID#: SAW-2007-00490
applicant leave as many mature pine trees as possible and preserve the existing red-cockaded
woodpecker cavity trees, if possible.
Maintain 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 aquatic and terrestrial wildlife resources, water quality, and
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
stormwater runoff. Whereas, a grassed buffer, particularly fescue, is a vegetated buffer but will
not provide the necessary and highly valuable functions as discussed for forested buffers.
3. All remaining wetlands and streams on the site should be protected from additional impacts by
placing them in a permanent conservation easement to prohibit filling, draining, flooding, and
excavation.
4. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate
the need to fill and culvert, where practicable. If culverts must be used, the culvert should be
designed to allow passage of aquatic organisms.
5. New developments exceeding 10% imperviousness should include stormwater controls designed
to replicate and maintain the hydrographic condition at the site prior to the change in landscape.
6. Locate sewers and other utilities as far away from streams as functionally possible and minimize
stream crossings. It is preferable that sewers be located outside the riparian buffers as detailed in
#2.
7. Landscaping should consist of non-invasive native species and Low Impact Development (LID)
technology. Using native species instead of ornamentals should provide benefits by reducing the
need for water, fertilizers, and pesticides. 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.
8. 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.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
cc: Cyndi Karoly, DWQ
ec: Jenna Begier, WRC