20070298 Ver 1_WRC Comments_20070319

North Carolina Wildlife Resources Commission
Richard B. Hamilton, Executive Director
MEMORANDUM
To: Cyndi Karoly
NC DENR/DWQ
From: Steven H. Everhart, PhD
Southeastern Permit Coordinator
Habitat Conservation Program

Date: March 19, 2007
RE: D. Ralph Huff, III -Huff Property, Onslow Co., 401/404 Application DWQ # 20070298
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
application for impacts to wildlife and fishery resources. 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.),
and Sections 401 and 404 of the Clean Water Act (as amended).
The project is located west of NC 210, just south of its intersection with Old Folkstone Rd. (SR 1518), in
Onslow County. The property consists of approximately 161.4 acres including approximately 66.3 acres
of wetlands. Land use in the vicinity includes undeveloped, residential, and commercial. The subject
property is currently undeveloped.
The applicants propose to impact approximately 0.49 acre of wetlands through filling/culverting to
construct a main access road and provide infrastructure for a residential (single and multi-family)
subdivision. The applicants propose to mitigate for wetland impacts by on-site preservation of all
remaining wetlands and buy-in to the NC EEP.
We have the following concerns/recommendations:
• Where standard culverts are used, we recommend they are embedded sufficiently to allow for the
passage and settlement of aquatic organisms and they be of sufficient size and number to
maintain hydrologic connectivity among wetlands. We do not support the filling of wetlands or
streams for road crossings as this practice destroys wetland connectivity.
• Although the applicant has eliminated several wetland impacts by the use of bridges, the
placement of the main access road results in the filling of 0.49 acre (475 linear feet) of wetland.
This does not represent the least environmentally damaging alternative for this access. We
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

D. Ralph Huff, III Property 2 March 19, 2007
recommend and support relocation of the main access to northern property boundary. This
alternative provides the least environmental impact to wetlands.
• We recommend that utility crossings of wetlands be made using directional bore methods rather
than trenching, unless they are suspended above the wetlands.
• We recommend that all remaining wetlands on-site are preserved in perpetuity through
conservation easement using existing USACE guidance. This guidance prohibits: cutting,
pruning, mowing, or burning of vegetation; construction of any kind; use of herbicides; any land
disturbing activities; dumping or storing of soil, trash, or other waste; and the pasturing, grazing
or watering of animals, or any other agricultural or horticultural purpose within wetlands, without
exclusion of any parcel.
• We recommend that, if required, those wetlands being purchased through NC EEP buy-in be of
equal or higher functional value to those impacted.
• There also appear to be impacts associated with the multi-family cluster north of the proposed
wetland fill area that are not addressed in the application.
Thank you for the opportunity to review and comment on this application. If you have any questions or
require additional information regarding these comments, please call me at [phone].
CC: Joanne Steenhuis, NCDWQ
Brad E. Shaver, USACE