20081565 Ver 2_WRC Comments_20191025

Good afternoon,

Please see the attached recommendations. Thank you,

Olivia

Olivia Munzer

Western Piedmont Habitat Conservation Coordinator

Certified Wildlife Biologist ®

NC Wildlife Resources Commission

Rogers Depot, 1718 NC Hwy 56 West

Creedmoor, NC 27522

Office: 919.707.0364 // Cell: 336.269.0074

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�L] North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
24 October 2019
Mr. Perry Isner
Wetlands & Waters, Inc.
328 East Broad Street, Suite D
Statesville, NC 28677
SUBJECT: Pre -Construction Notification for the Colonial Crossing Development, Iredell County,
North Carolina. USACE Action ID: SAW-2008-0295; DEQ No. 20081565v2.
Dear Mr. Isner,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of LGI Homes NC, LLC, Wetlands & Waters, Inc. has submitted a Pre -Construction
Notification (PCN) application for the Colonial Crossing Development located southeast of East Monbo
Road and south-southwest of Zion Wesley Road in Troutman, Iredell County, North Carolina. A
residential development is proposed for the 198.32-acre site, which is primarily forested, vacant land.
Hicks Creek and its unnamed tributaries flow through the site; Hicks Creek in the Catawba River basin is
classified as a Water Supply IV stream by NC Division of Water Resources (NCDWR). The proposed
project would result in 436 linear feet (If) of permanent impacts and 1901f of temporary impacts to
streams.
We have no known records of the federal and state -listed species at or near the site. The United States Fish
and Wildlife Service (USFWS) lists the federally and state threatened dwarf -flowered heartleaf (Hexastylis
naniflora) as having potential to occur within the project area if suitable habitat occurs. We recommend
contacting the U.S. Fish and Wildlife Service at [phone] to ensure that any issues related to this
species are addressed. If potential suitable habitat occurs onsite, surveys for protected plant species should be
conducted during the appropriate timeframe. The lack of records from the site does not imply or confirm the
absence of federal or rare, threatened, or endangered species. An on -site survey is the only means to
determine if the proposed project may impact federal or state rare, threatened, or endangered species.
We have concerns for the amount of permanent impacts to streams and we would like to see impacts
further minimized. We offer the applicant the following recommendations to minimize impacts to aquatic
and terrestrial wildlife resources.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Colonial Crossing
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Use bridges for all permanent roadway crossings of streams to eliminate the need to fill and
culvert. Consider moving the road crossing (culvert B) further downstream to avoid crossing two
streams and to have a shorter road connection between the two residential areas.
If culverts are used in permanent streams, the culvert must be designed to allow for aquatic life
and fish passage. Generally, the culvert or pipe invert should be buried at least 1 foot below the
natural streambed (measured from the natural thalweg depth). If multiple barrels are required,
barrels other than the base flow barrel(s) should be placed on or near stream bankfull or
floodplain bench elevation (similar to Lyonsfield design). These should be reconnected to
floodplain benches as appropriate. This may be accomplished by utilizing sills on the upstream
and downstream ends to restrict or divert flow to the base flow barrel(s). Silled barrels should be
filled with sediment so as not to entrap wildlife or support mosquito breeding conditions.
Sufficient water depth should be provided in the base flow barrel(s) during low flows to
accommodate fish movement. If culverts are longer than 40-50 linear feet, alternating or notched
baffles should be installed in a manner that mimics existing stream pattern. This should enhance
aquatic life passage: 1) by depositing sediments in the barrel, 2) by maintaining channel depth
and flow regimes, and 3) by providing resting places for fish and other aquatic organisms. In
essence, base flow barrel(s) should provide a continuum of water depth and channel width
without substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment whenever possible to
avoid channel realignment. Widening the stream channel must be avoided. Stream channel
widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be
professionally designed, sized, and installed.
2. Maintain or establish a minimum 100-foot native, undisturbed forested buffer along each side of
perennial streams and 50-foot native, undisturbed forested buffer along each side of 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. Also,
wide riparian buffers are helpful in maintaining stability of stream banks and for treatment of
pollutants associated with urban stormwater.
3. We prefer using directional boring to cross streams. If trenching is determined to be the only
viable method, every effort should be made to ensure that impacts to in -stream features are
minimized and stable upon completion of the project. Open -trench crossings have been found to
increase the likelihood for future lateral movement of the stream (which could undercut or erode
around the utility line), and the correction of such problems could result in costly future
maintenance and devastating impacts to natural resources. Therefore, as much work as possible
should be accomplished in the dry, and the amount of disturbance should not exceed what can be
successfully stabilized by the end of the workday. In -stream work should consider forecasted
high -flow events.
4. Stream crossings should be near perpendicular (75' to 105°). For stream crossing for SSMH-48
to SSMH-49 and SSMH-82 to SSMH-83, consider moving the stream crossings to avoid areas
where the stream meander and to reduce stream impacts. At current location of the sewer line,
stream velocities may cause streambank erosion and scour holes. Avoid areas of noticeable

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24 October 2019
Colonial Crossing
Iredell County
increase in channel width, meadering, steeply sloped channel banks, and lack of vegetation; these
characteristics can indicate existing or potential channel widening or movement.
Streams should be restored to their natural function. Native vegetation, state-of-the-art natural
channel design, and restoration techniques should be used for stream stabilization at stream
crossings. Crossings should be monitored at least every three months for maintenance needs
during the first 24 months and then annually thereafter. Sewer lines associated with crossing
areas should be maintained and operated at all times to prevent the discharge to land or surface
waters.
6. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas and landscaping, including pollinator species. Avoid using Bermudagrass, redtop,
tall fescue, and lespedeza, which are invasive and/or non-native and provide little benefit to
wildlife. Consider an alternative mix of red clover, creeping red fescue, and a grain, such as oats,
wheat, or rye. Also avoid using invasive, non-native landscaping plants (i.e., privet and nandina).
For a list of non-native species, visit http://www.ncwildflower.org//plant izalleries/invasives_list.
7. The size of the stormwater BMP can further be minimized by implementing Low Impact
Development (LID) technology. 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. LID techniques include tree box filters/flow through planters, rain gardens, and other
bioretention areas that can collect stormwater from driveways and parking areas. Additional
alternatives include narrower roads, swales versus curbs/gutters, and permeable surfaces such as
turf stone, brick, and cobblestone. Compared to conventional developments, implementing
appropriate LID techniques can be more cost-effective, provide space -saving advantages,
reduce runoff, protect water quality, and increase property values (Roseen et al. 2011).
Also, NCWRC's Green Growth Toolbox provides information on nature -friendly planning
(http: //www.ncwildlife. oriz/Conserviniz/Pro grams/GreenGrowthToglbox. aspx).
8. Grassed swales shall be used in place of curb and gutter for new developments, except in areas
with >5% slope. Check dams, level spreaders, and other associated best management practices
shall be used to minimize the effect of stormwater runoff entering the riparian buffer areas. In
areas where slopes exceed 5%, stormwater collected in piped conveyance systems shall be
directed away from surface waters and best management practices shall be employed at both the
intake and the outlet areas.
9. Due to the decline in bat populations, avoid the removal of large trees at the site. Avoid tree
clearing activities during the maternity roosting season for bats (May 15 — August 15).
Additionally, we recommend avoiding clearing activities during the migratory bird nesting
season, roughly March to August.
10. We recommend not clearing the entire site, but rather maintaining the maximum amount of native
vegetation as possible and minimizing site disturbance.
11. 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 that has been reinforced with plastic or metal mesh should be
avoided as it impedes the movement of terrestrial wildlife species. 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.

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Colonial Crossing
Iredell County
Thank you for the opportunity to provide input for this project. If I can provide further assistance or free
technical guidance, please call [phone] or email olivia.munzer cr,ncwildlife.org.
Sincerely,
al
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature
Roseen, R. M., T. V. Janeski, J. J. Houle, M. H. Simpson, and J. Gunderson. 2011. Forging the Link:
Linking the Economic Benefits of Low Impact Development and Community Decisions.
University of New Hampshire Stormwater Center, Virginia Commonwealth University, and
Antioch University New England.
ec: Catherine Janiczak, U.S. Army Corps of Engineers
Alan Johnson, N.C. Division of Water Resources
Byron Hamstead, U.S. Fish and Wildlife Service