19930818 Ver 2_Other Agency Comments_20061207

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DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
IN REPLY REFER TO
Regulatory Division
Action ID. SAW-2006-20191-292
December 6, 2006
Wake County Department of Environmental Services D ~~ ~~~~ D
Solid Waste Division
Attn: Mr. James Reynolds, Solid Waste Director per 'j ~,QQ6
PO Box 550
Raleigh, North Carolina 27602 ~ ~
Dear Mr. Reynolds:
Reference our September 21, 2006, Public Notice for the proposed impacts associated with
the construction of the South Wake Municipal Solid Waste Landfill in Holly Springs, Wake
County, North Carolina. Impacts associated with the project included 6.73-acres of jurisdictional
wetlands, 0.15-acre of non jurisdictional isolated wetlands, 2,561 linear feet of streams having
important aquatic functions, and 937 linear feet of streams lacking important aquatic functions. All
streams and adjacent wetlands within the proposed project site drain to Little Branch in the Cape
Fear River Basin.
After review of your proposal, a letter dated October 12, 2006, was received from the
North Carolina Wildlife Resources Commission. The letter raises concerns regarding the filling of
wetlands and piping of streams, and suggested several measures to further reduce the impact of the
proposed work. Included within these measures are items such as the possible use of bridges,
maintaining forested buffers on streams, proper installation of culverts, sediment and erosion
control, protection of remaining wetlands and streams, and submittal of a compensatory mitigation
plan. We are forwarding a copy of this letter for your review and consideration.
In addition, Environmental Justice may be a concern for the proposed site selection. While
you have provided documentation which might alleviate these concerns, it appears that the data
used is now outdated. Please conduct a proper Environmental Justice analysis as outlined in the
Executive Order 12898 that was directed through the Environmental Protection Agency using data
obtained from the 2000 census.
Also, additional information is required on the overall site selection process. Please
summarize and forward any supporting documentation on cost analysis, environmental issues, or
other contributing factors for this decision.

If possible, please provide a response to these issues within 30 days. If you have any
questions or concerns, please contact Mr. Monte Matthews at [phone] x30 or at the
letterhead address.
Sincerely,
lv \~ ~~~~
Jean B. Manuele
Chief, Raleigh Regulatory
Field Office
Attachments
copy with attachments:
Ms. Cyndi Karoly
NCDWQ
1650 Mail Service Center
Raleigh, NC 27699-1650

G~~~~~

t EGu~ ~~'u~Y rih i D OFFICE
~ North Carolina wildlife Resources Commission ~
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Mr. Monte Matthews, U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
FROM: Shari L. B~nt, Pibd om nt Region Coordinator
Habitat Conservation Program
DATE: 12 October 2006
SUBJECT: Public Notice for Wake County Department of Environmental Services, Solid Waste
Division -South Wake Municipal Solid Waste Landfill, Wake County, North Carolina.
Corps Action ID No.: SAW-2006-20191-292
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document and an on-site visit was conducted on 24 July 2006. Our comments are provided in
accordance with provisions of the Clean Water Act of 1977 (as amended), Fish and Wildlife Coordination
Act (4$ Stat. 401, as amended; 16 U.S.C. 661-667d), and North Carolina General Statutes (G.S. 113-131
et seq.),
The applicant proposes to place fill material into 6.73 acres of jurisdictional wetlands, 0.15 acre
of non jurisdictional wetlands, 2,561 Linear feet of stream channel having important aquatic functions, and
9371inear feet of stream channel lacking important aquatic functions. These impacts are associated with
construction of the South Wake Municipal Solid Waste Landfill in Holly Springs. Mitigation for wetland
and stream channel impacts includes payment into the North Carolina Ecosystem Enhancement Program
and possibly on-site preservation of a third-order stream and associated stream buffers that include
isolated bottomland hardwood forest wetlands and wooded floodplain areas.
The site drains to Little Branch, a tributary to Shearon-Harris Reservoir in the Cape Fear River
basin. Shearon-Harris Reservoir supports a diverse fishery including sunfish (Lepomis spp.), crappie
(Pomoxis spp.), catfish (Ictalurus spp.), and largemouth bass (Micropterus salmoides).
We hesitate to concur with the piping of any stream due to the potential negative impacts to
downstream areas and the elimination of aquatic and terrestrial wildlife habitat. Stream piping reduces
the infiltration of stormwater and associated pollutants, as well as the dissipation of stream energy,
Culverting a stream and placing it underground removes both aquatic and terrestrial habitat. Existing uses
by wildlife are lost and future opportunities to improve aquatic diversity are precluded. Additionally, we
are concerned about impacts to wetlands due to their wildlife habitat value and the well-known beneficial
functions these areas provide for flood control and water quality protection.
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

Page 2
" ~ 12 October 2006
South Wake Municipal Solid Waste Landfill
Corps Aetion ID #: SAW-2006-20191-292
Should the permit be issued, we recommend the following conditions be incorporated into the
permit to further minimize impacts to aquatic and terrestrial wildlife resources.
1. To minimize additional stream impacts, while retaining some measure of wildlife habitat, we
recommend a minimum 100-foot undisturbed, native, forested buffer along perennial streams, and
a 50-foot buffer along 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 both within and downstream of the project area. In addition, wide
riparian buffers are helpful in maintaining stability of stream banks and for treatment of pollutants
associated with stormwater runoff. Whereas, a grassed buffer, particularly fescue, is a vegetated
buffer but will not provide the necessary and highly valuable functions as discussed for forested
buffers.
2. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate
the need to fill and culvert, where practicable. If culverts must be used, the culvert should be
designed to allow passage of aquatic organisms. Generally, this means that the culvert or pipe
invert is buried at least one foot below the natural streambed. If multiple cells are required, the
second and/or third cells should be placed so that their bottoms are at stream bankfull stage. This
will allow sufficient water depth in the culvert or pipe during normal flows to accommodate
movements of aquatic organisms. If culverts are long and sufficient slope exists, baffle systems
are recommended to trap gravel and provide resting areas for f sh and other aquatic organisms. If
multiple pipes or cells are used, at least one pipe or box should be designed to remain dry during
normal flows tv allow for wildlife passage. In addition, culverts or pipes should be situated so
that no channel realignment or widening is required. Widening of the stream channel at the inlet
or outlet of structures usually causes a decrease in water velocity causing sediment deposition that
will require future maintenance. Finally, riprap should not be placed on the streambed.
3. Remaining wetlands and streams on the site should be protected from additional impacts by
placing them in a permanent conservation easement to prohibit filling, draining, flooding, and
excavation.
4. Specialized efforts and techniques should be implemented to reduce sediment runoff from
construction activities. 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.
5. A detailed mitigation plan should be submitted and approved before impacts occur.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
cc: Cyndi Karoly, DWQ
ec: Mark Bowers, USFWS