20221447 Ver 1_WRC Comments_20221123

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sue Homewood
Division of Water Resources
N.C. Department of Environmental Quality
FROM: Gabriela Garrison
Eastern Piedmont Coordinator
�i�.W
Habitat Conservation
DATE: November 23, 2022
SUBJECT: Individual Permit Application for Veridea Development, Wake County, North Carolina
(SAW-2010-01907).
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; I NCAC 25), and North Carolina General Statutes (G.S. 113-131 et seq.).
RXR Len Apex Owner, LLC (RXR) proposes to construct the Veridea Mixed -use, Commercial
Residential Development (Veridea). The proposed project area is approximately 1,092 acres and located
on the west side of NC Highway 55, primarily between US Highway 1 and NC Highway 540, in the
Town of Apex (Apex). Currently, the project site consists of woodlands, agricultural fields, and
residential homesteads. Existing zoning allows for 8,000 dwelling units, 3.5 million square feet of retail
and commercial uses, and 12 million square feet of office and industrial uses. A minimum 100-acre area
will be dedicated as part of Apex's Resource Conservation Area (RCA). In addition, a minimum 150-
acre area will be recreation and open space. Aerial images and maps indicate Little Branch, Big Branch,
and associated tributaries bisect the proposed project area.
Permanent project impacts from Veridea include the following: 1.092 acre (4,798 linear feet) of
stream channel loss; 0.820 acre of wetland loss, and 0.343 acre of open water loss. Temporary
impacts include the following: 0.318 acre (1,182 linear feet) of stream channel and 0.025 acre of
wetlands. The installation of utility infrastructure and establishment of permanently maintained
utility corridors will result in the permanent conversion of 0.02 acre of forested wetlands to
herbaceous wetlands.
There are no current records for rare, endangered, or threatened species onsite. However, lack of records
is not indicative of species absence, rather lack of extensive species survey effort throughout the area.
The NCWRC is concerned with potentially adverse ecological impacts resulting from project
construction. Placing fill in aquatic systems can alter hydrology, result in significant negative impacts to
downstream areas, and eliminate aquatic and terrestrial wildlife habitat. Additional impervious surface in
developing areas results in increased stormwater runoff that can impact stream morphology. This will
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
November 23, 2022
Veridea Development
IP Application
cause further degradation of aquatic habitat through accelerated stream bank erosion, channel, and
bedload changes, altered substrates and scouring of the stream channel. In addition, pollutants (e.g.,
sediment, heavy metals, pesticides, and fertilizers) washed from developed landscapes can adversely
affect and extirpate species downstream.
Forest fragmentation is a serious concern as outlying areas of Apex, Cary, and Holly Springs remain
predominantly rural. Reduction of habitat due to fragmentation has severe impacts on wildlife
populations, including deleterious effects on reproduction and migration. Small patches of forest often
become degraded and provide little or no value to remaining wildlife. In addition, as healthy ecosystems
are disturbed and minimized, invasive plant species become established and create monocultures in areas
that previously hosted diverse and intricate natural communities. As such, the NCWRC offers the
following guidance and recommendations to minimize impacts to aquatic and terrestrial wildlife
resources:
I. The NCWRC recommends maintaining 100-foot, native, forested buffers on all perennial streams and
50-foot, forested buffers on all intermittent steams. If wooded buffers do not exist, these areas should
be revegetated or allowed to naturally revegetate to increase functionality. Periodic checks should be
established to ensure invasive species are not growing in areas that have been disturbed during
construction. Wooded buffers include a combination of native trees, shrubs, perennials, and warm
season grasses. There are local nurseries that specifically sell native vegetation suitable for riparian
areas. Non-native grassed buffers, particularly fescue, do not provide the necessary and highly
valuable functions that forested buffers provide, including refugia and travel corridors for terrestrial
wildlife species. In addition, forested buffers protect water quality by stabilizing stream banks and
filtering stormwater, including sediment, nutrients, pesticides, and other material found in runoff.
2. Small, isolated wetlands are not protected by state and federal regulations but provide critical
breeding habitat for declining populations of amphibians. These areas are important for the
protection of biodiversity, groundwater recharge, and reducing sedimentation and pollution into
streams and rivers. These wetlands are considered an imperiled habitat in the 2015 North Carolina
Wildlife Action Plan(http://www.ncwildlife.org/plan). As such, the NCWRC recommends
maintaining a 150-foot forested buffer around all small, isolated wetlands.
3. The NCWRC recommends the use of Low Impact Development (LID) technology and effective
stormwater management strategies. Possible suggestions include engineered stormwater wetlands,
bioswales, and permeable pavement. Information on other LID techniques can be found in `Low
Impact Development, A Guidebook for North Carolina':
https:Hdigital.ncdcr. og v/digital/collection/ I6062co119/id/232781.
4. Recreational areas and trails in open spaces should be located outside forested, riparian buffers and
surfaced with pervious materials. Further information can be found here:
https://www.railstotrails.org/build-trails/trail-building-toolbox/trail-building-and-design/developing-
trails -in -sensitive -areas/.
Avoid the removal of large trees at the edges of construction corridors. Disturbed areas where
stabilization is needed should be re -seeded with seed mixtures that are beneficial to wildlife - see
attached Table. The NCWRC strongly recommends against the use of fescue -based mixtures and
Sericea lespedeza (Lespedeza cuneata) as stabilizing groundcover. Sericea lespedeza in particular is
an egregious and invasive, non-native species that spreads easily and is very hard to eradicate.
Native, annual small grains appropriate for the season are preferred and recommended. Pollinator
mixes are commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths, and birds. Using native species instead of ornamentals should reduce the need for
water, fertilizers, and pesticides, as well as preserve the natural integrity of the ecosystem.

Page 3
November 23, 2022
Veridea Development
IP Application
6. The NCWRC strongly encourages the use of native vegetation in public areas, rights -of -way, and
RCAs. In efforts to restore diversity and ecosystem functionality in a highly fragmented landscape,
please also consider revegetating residential and commercial areas with native trees, shrubs, warm
season grasses and perennials that are attractive and valuable to pollinating insects and other wildlife.
The following website has a wide assortment of native vegetation specific to North Carolina:
https://ncbg.unc.edg/wp-content/uploads/sites/963/2019/08/NativePlantsWoody_pd£ In addition,
there are numerous local nurseries that specialize in native plants for both upland and riparian areas.
Free technical guidance from NCWRC biologists is available upon request.
7. Please confirm that all contractors and landscapers have been educated on proper herbicide use and
protocol. In areas where native vegetation will be installed, please post signage to ensure that
contractors will not spray on or in the vicinity of the vegetation. Staff biologists from NCWRC
monitor numerous sites across the State where contractors and landscapers have unknowingly sprayed
native vegetation because it was not clearly marked. Insecticides and herbicides should not be used
within 100 feet of perennial streams and 50 feet of intermittent streams, or within floodplains and
wetlands associated with these streams.
8. In addition to standard erosion and sediment control measure, the use of biodegradable and wildlife -
friendly sediment and erosion control devices is strongly recommended. Silt fencing, fiber rolls
and/or other products should have loose -weave netting that is made of natural fiber materials with
movable joints between the vertical and horizontal twines. Silt fencing and similar materials that
have been reinforced with plastic or metal mesh should be avoided as they impede the movement of
terrestrial wildlife species. Existing DWR 401 certifications state that `erosion control matting that
incorporates plastic mesh and/or plastic twine shall not be used along streambanks or within
wetlands. Exceptions to this condition require application to and written approval from DWR'.
Plastic -free mesh or twine in all erosion control matting should be used in all areas within the project
boundary.
The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondMandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources.
In addition, please consider following guidance found in the Green Growth Toolbox:
https://www.ncwildlife.org/conserving/rograms/Green-Growth-Toolbox. This is a guide specifically
designed for local governments to conserve natural resources while sustaining economic growth. An
applicable strategy for the Veridea Development would include creating higher density areas of
residential and commercial development in order to leave larger areas of green space and recreational
areas.
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 gabriela.garrisonkncwildlife.org.

Page 4
November 23, 2022
Veridea Development
IP Application
Table: Wildlife -friendly stabilizing groundcover.
lblac
cost/lb
Proso or Brown Top Millet
30
0.88
$26.40
Austrian Winter Pea or Iron Clay*
10
1.1
$11.00
Buckwheat
40
0.88
$35.20
Durana Clover
5
8.33
$41.65
Black-eyed Susan
1
22
$22.00
P urp letop
5
22
$110.00
Beaked Panicgrass
4
19.8
$79.20
Wild Rye*
5
6.6
$33.00
Carthage Switch Grass
4
6.6
$26.40
Partridge Pea
3
6.6
$19.80
Ragweed
1
13.33
$13.33
Sum $417.98
Prices from Adams Briscoe or Ernst
Ernst Mix NC Steep Slope Mix $993.60 plus cover crop
Other mixes run 700 to $800 without cover.
* During cool season use Austrian Winter Peas and increase Wild Rye to 20 lbs.