20111103 Ver 1_WRC Comments_20120131

Strickland, Bev
From: Mcmillan, Ian
Sent: Tuesday, January 31, 2012 8:47 AM
To: Strickland, Bev; Dennison, Laurie
Subject: FW: American Towers, LLC - Carteret County
Attachments: 404-401-CD—American Towers_NCWRC.pdf
10t[47►11190656 x1
E -mail correspondence to and from this address may be subject to the
North Carolina Public Records La-,i- and may he disclosed to third parties.
From: Dunn, Maria T.
Sent: Monday, January 30, 2012 3:12 PM
To: christine .w.wicker(a)usace.army.mil; Rynas, Stephen; Mcmillan, Ian
Subject: American Towers, LLC - Carteret County
Good afternoon,
Please accept the attached as comments on the above project from NCWRC.
If you have any questions, please call.
Thank you.
Maria
Maria T. Dunn NE Permit Coordinator
North Carolina Wildlife Po-sources Conuiiission
943 Washington Square Mall, Washington, NC 27889
[phone] / www.ncwildlife.or
Email corresEcrr,.lence to and from this senc:l c is srthject to the N.C. Prihlic Recorc:is Law and may he cEisclose {:I to thirc:l parties.

9 North Carolina Wildlife Resources Commission 9
Gordon S. Myers, Executive Director
MEMORANDUM
TO: Christy Wicker
US Army Corps of Engineers
And
Ian McMillan
NC Division of Water Quality
And
Stephen Rynas
NC Division of Coastal Management
�F.riCtii -T-1�/iFlM)
FROM: Maria T. Dunn, Northeast Permit Coordinator
Habitat Conservation Program
DATE: January 30, 2012
SUBJECT: Comments on Proposed 1.04 acres wetland fill for 250 Feet Tall Telecommunications
Tower for American Towers, LLC, Carteret County, North Carolina.
SAW 2010 -01235
DWQ No. 20111103
DCM # 20110192
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
public notice and permit applications with regard to impacts on fish and wildlife resources. The project
site is located approximately 1.5 miles southwest of the intersection of Hibbs Road and US Hwy 70 in
Newport, NC. Our comments are provided in accordance with provisions of the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.), Sections 401 and 404 of the Clean
Water Act (as amended), and Coastal Area Management Act (G.S. 113A -100 through 113A -128), as
amended.
The applicant, American Towers, LLC, proposes to discharge fill material into 1.04 acres of
wetlands abutting an unnamed tributary to Bogue Sound, and 30 linear feet of a Relatively Permanent
Water (RPW) associated with the proposed unmanned wireless telecommunications facility. The fill is to
accommodate a 4,469' long by 20' wide access road within a 30'easement. An 80' by 80' gravel- covered,
fenced compound will house a 250' self - supporting lattice tower and a 20' by 11'5" equipment building.
All areas within the 30' access road easement and 100' by 100' leased tower area will be cleared of
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

American Towers, LLC 2 January 30, 2012
Carteret County, NC
vegetation and maintained. To maintain hydrology between wetlands, an 18" diameter culvert is proposed
within the area of the access road that crosses the RPW. The applicant has provided various alternatives
that explored lease options on other parcels. These alternatives were not successful due to increased
wetland impacts or lack of cooperation with the property owner. To mitigate for proposed wetland
impacts, the applicant proposes to purchase 2.08 acres of wetland credits.
The NCWRC has reviewed the documentation and is concerned with the amount of proposed
wetland fill. We understand several parcels were investigated, but believe further minimization of impacts
can be demonstrated prior to mitigation. The owner of the preferred property has requested the tower be
placed at the back of the property. This has necessitated a very long access road. To minimize impacts the
access road has on wetlands, other parcels can be explored, the road can be shortened and the tower
moved closer to the highway, or the road can be reduced in width. A reduction in road width within
wetland areas would significantly minimize total wetland impacts. The maximum road width in wetlands
should be the minimum width necessary for a single lane of vehicles and equipment transport. In addition
to road width reduction, regular vegetation maintenance within the easement could be reduced from the
proposed 30' width. Any vegetation maintenance should be conducted so as not to compact soils and
should avoid chemical discharge into wetlands.
We appreciate the opportunity to review and comment on this project. If you need further
assistance or additional information, please contact me by phone at (252) 948 -3916 or email at
maria. dunn @ncwildlife. org