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Home My WebLink About20191305 Ver 1_More Info Received_20191030arc ENVIRONMENTAL INC. October 30, 2019 Ms. Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program North Carolina Wildlife Resources Commission 1721 Mail Service Center Raleigh, NC 27699-1721 RE: Highlands Retail Development Project Cherrywood Drive at U.S. Highway 64 East Highlands, North Carolina UT to Big Creek, Macon County USACE: SAW-2019-01407 NCDEQ Project I.D. 20191305, Version 1 Dear Ms. Leslie, In reference to your letter to Mr. David Brown of the U.S. Army Corps of Engineers, Regulatory Branch dated October 15, 2019 regarding the Highlands Retail Development Project located on Cherrywood Drive at U.S. Highway 64 East, Highlands, NC, please find responses to your comments from the developer regarding your departments recommendations to minimize impacts to fish and wildlife resources. The comments below are a follow up to telephone discussed between you and Mr. Jeremy Cobb of The Broadway Group, Developer regarding your recommendations. Be vigilant with sediment and erosion control during site staging, construction, and cleanup. We ask that disturbed areas be stabilized on a tighter timeframe than that in the regulation to minimize risk of sediment loss, namely, that the disturbed areas be seeded, mulched and/or matted as soon as possible, preferably at the end of each work day; at a minimum, disturbed areas should be stabilized within five working days or seven calendar days, whichever is shorter. The developer stated they can comply with your recommendation. Further, they changed the stabilization timeline on the ESPC plans (sheets 5-7) to be 5 working or 7 calendar days. It was noted if a rain event was expected, the site would be stabilized prior to that rain event. ARC Environmental, Inc. P.O. Box 190, Brownsboro, AL 35741 (PH) 256-536-2884 (FAX) 256-536-2328 www.arcco.org 2. Any matting used on site should be free of nylon mesh; nylon mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for years. The developer stated they can comply with your recommendation. A note was added to sheets 5-7. 3. We recommend against using RCP culverts, as RCP is smooth and is less likely to hold stream substrate and provide for movement of aquatic organisms like fish and salamanders. The developer stated they can comply with your recommendation. Further, the developer changed the RCP culverts to CMP. 4. In -stream activities should be avoided between October 15 and April 15 in order to minimize impacts to Brook Trout spawning. The developer stated they can comply with your recommendation and are aware of the trout spawning season moratorium, and added a note to sheets 5-7. 5. The stream should not be excavated except in the immediate vicinity of the utility and road crossing locations. The developer stated they can comply with your recommendation and no excavations are planned except for as shown on the plans. 6. Manage stormwater from the site in order to mimic a hydrograph consistent with an impervious coverage of less than 10%. Incorporate Low Impact Development (LID) techniques in site design. Ensure that stormwater management controls temperature, releasing cool water downstream. The developer stated they can comply with your recommendation. The flows due to the increased impervious area are detained to meet the preconstruction condition (Impervious Area < 10%) for all storm events by the use of an underground detention chamber system. Because this is an underground system, the temperature of the stored water will be cooler when it is discharged. 7. Use non-invasive native species and LID technology in landscaping. Using native species instead of ornamentals should reduce the need for water, fertilizers and pesticides. 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. The developer stated they can comply with your recommendation. Non-invasive native grasses are planned for temporary and permanent stabilization. 8. Maintain a minimum of a 30-ft undisturbed, native, forested buffer along all streams and wetlands on the property. Maintaining undisturbed, forested buffers will minimize impacts to aquatic and terrestrial wildlife resources, water quality, and aquatic habitat both within and downstream of the project area. Wide riparian buffers are helpful in maintaining stability of stream banks and for treatment of pollutants associated with ARC Environmental, Inc. P.O. Box 190, Brownsboro, AL 35741 (PH) 256-536-2884 (FAX) 256-536-2328 www.arcco.org urban stormwater. In addition, these buffers will provide an adequate travel corridor for wildlife species. The developer stated they can comply with your recommendation. The buffers are proposed to be maintained in the natural condition, except as permitted for installation of driveway crossing and culvert installation as shown on the plans. 9. We recommend maintaining undeveloped parts of the parcel as forested habitat and conserving these areas as green space. The developer stated they can comply with your recommendation. Undeveloped parts of the site are proposed to be left in their natural state. Should you have questions or concerns, please do not hesitate to contact me at (256) 536- 2884. Sincerely, �eCll Project Manager ARC Environmental, Inc. P.O. Box 190 Brownsboro, AL 35741 mcampbel I(aarcco.org Phone: (256) 536-2884 cc: Mr. David Brown, U.S. Army Corps of Engineers, Regulatory Branch Mr. Andrew Moore, NC Division of Water Resources Mrs. Kelly Steele, The Broadway Group Mr. Jeremy Cobb, The Broadway Group Mr. Alan Campbell, ARC Environmental, Inc. ARC Environmental, Inc. P.O. Box 190, Brownsboro, AL 35741 (PH) 256-536-2884 (FAX) 256-536-2328 www.arcco.org