20072046 Ver 1_Other Agency Comments_20080123

~ North Carolina Wildlife Resources Commission
MEMORANDUM
To:
From:
Date:
RE:
Ian McMillan
NC DENR/DWQ
~~~~~,~,
Molly Ellwood
Southeastern Permit Coordinator
Habitat Conservation Program
January 23, 2008
Brunswick Forest Subdivision Phases 3 and 5, DWQ# 07-2046
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed
the subject application for impacts to wildlife and fishery resources and conducted a site visit on
January 18 and 22, 2008. 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).
This project is part of phases 3 and 5 of development within the Brunswick Forest Subdivision
off of Hwy 17 S in Leland. Overall impacts listed in the permit tota10.386 acres of § 404
wetlands and 152 linear feet of stream. These impacts are to be mitigated by buying into the
NCEEP for the restoration of 0.5 acres of riparian wetlands. Other mitigation proposed in the
permit is to preserve wetlands that occur on individual lots within these two phases of
development.
The primary purpose of this project is to construct six road crossings to access platted parcels for
a total of 516 single-family residencies, as well as an 18 hole golf course.
We have the following concerns:
• Concurrent with requests by USACE and DWQ for maps showing sewer lines, all
approved wetlands, streams, or any other waters of the State as overlays on the complete
site plan with all phases of development, we would also like to see maps depicting all
stormwater and amenity ponds with overlays of all phases of development and approved
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

«,:~.„;„,,.,,„ Ro",~ c.,.oo+,.,,„r,,.,o„,o„, n.,,:o,.«grunswick Forest Phases 3 & 5
January-1-423, 2008
wetland delineations. Stormwater pond locations should also be accompanied by state
stormwater permit numbers.
Proposed stream impact # 1 is already in place and being regularly used. Permanent riprap
has been placed along the stream edge, impacting part of the proposed 105 if of stream
impacts. Impacts to Mallory Creek on the south side of Low Country Boulevard have not
been accounted for in the permit application and need to be listed in sections 4 and 6.
Site visits show that utilities have been installed in areas of phase 3, though temporary
impacts have not be depicted on any maps nor included within the permit application, and
no permits are known to have been issued for these impacts.
Ponds along the proposed golf course have been constructed in close proximity to
wetlands and to depths below that of the wetlands, subsequently draining these wetlands.
This is in violation of §404 of the Clean Water Act as well as state wetland standards
15A NCAC 02B .0231(b) which requires that:
(5) Hydrological conditions necessary to support the biological and physical
characteristics naturally present in wetlands shall be protected to prevent adverse
impacts on:
(A) Water currents, sedimentation or erosion problems.
(F) The water levels or elevation.
Road impacts to the 235.02 acres of wetlands that are being regularly crossed to access
the southern part of phase 3 and other upland development south of phase 5 have not
been shown or included with in the permit application. No prior permits are known to
have been issued in reference to this road crossing.
According to the map provided there are wetland impacts that are not accounted for
within sections 3 and 6 of the permit application. Impacts are shown in many of the lots
in both phases 3 and 5. All impacts should be included within the permit application as
well as the mitigation for these impacts.
Past, current and future phases of development need to be shown so that road connections
can be verified for applicability. Without a connection to another phase of development,
wetland impact #6 is currently not needed and should be modified or removed to
eliminate the need for this impact.
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 (910)
796-7240.
CC: Kim Garvey, USACE
Chad Coburn, NCDWQ