20091169 Ver 1_WRC Comments_20091116

?1 n69
® North Carolina Wildlife Resources. Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Andrew Williams, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 16 November 2009
SUBJECT: Draft Prospectus for Wildlands Engineering, Inc. for Little Troublesome Creek Stream
Mitigation Bank, Rockingham County, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document and we are familiar with the habitat values of the area. Our comments are provided in
accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C.
661-667d), and North Carolina General Statutes (G.S. 113-131 et seq.).
Wildlands Engineering, Inc proposes to establish the Little Troublesome Creek Stream Mitigation
Bank. Approximately 3,375 linear feet of perennial stream channel would be restored, 987 linear feet of
perennial stream channel would be enhanced, and 500 linear feet of intermittent stream channel would be
preserved. In addition, approximately 29 acres of riparian buffer would be enhanced by removal and
management of invasive species. Riparian buffer widths would range from 50 to 100 feet with minor
encroachments from utility lines. The proposed mitigation ratios are 1:1 for stream restoration, 1.25:1 for
enhancement (level 1), and 5:1 for preservation. Up to 4,965 stream credits would be available with
successful completion of the project. The site would be protected by a permanent conservation easement.
The goals of the bank are to remove nutrients and sediments from the stream, increase dissolved oxygen,
improve stream bank stability and instream habitat, restore terrestrial habitat, and improve aesthetics.
Irvin Creek, Little Troublesome Creek, and unnamed tributaries to these streams flow through the
mitigation bank site. Little Troublesome Creek is a tributary to Haw River in the Cape Fear River basin.
There are records for the state significantly rare Carolina ladle crayfish (Cambarus davidi) in Little
Troublesome Creek.
We offer the following comments and/or recommendations regarding the draft Prospectus:
1. Page 1 states: "The proposed stream restoration designs will primarily include Rosgen Priority
Levels 1 and 2..." Figure 2 shows a forested watershed within the proposed mitigation bank site.
We are concerned about the removal of mature, native trees for construction of the new stream
channel. If Rosgan Priority I stream restoration is proposed as the best method to address water
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
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16 November 2009
Prospectus - Little Troublesome Creek Mitigation Bank
quality issues in the watershed, then the project should be designed to protect as many mature, native
trees as possible. These would provide stream bank stabilization and shade for the new channel.
Also, the design and subsequent construction methods should minimize impacts to the existing
forested areas to the maximum extent possible.
2. Page 1 states: "Riparian buffer enhancement is also part of the Little Troublesome and Irvin Creek
Mitigation Project. Approximately 29 acres of riparian buffer will be enhanced by removal and
management of invasive species while being protected with permanent conservation easements." It
is not clear whether riparian buffer enhancement includes only removal and management of invasive
species, or whether native tree species will be planted as part of the buffer enhancement. If the
existing forested areas will be impacted, then a vegetation planting and monitoring schedule should
be developed.
3. Page 1 states: "In general, buffer widths will range from 50 to 100 feet from the top of the stream
bank with minor encroachments from utility lines." Wider buffers are preferred where possible. We
often recommend a 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 reduces impacts to aquatic and terrestrial wildlife resources, water quality, and aquatic
habitat both within and downstream of the project area. In addition, these buffers provide an
adequate travel corridor for wildlife species.
4. Page 2 states: "The proposed stream and riparian buffer mitigation project described above will
provide numerous ecological benefits within the Cape Fear River Basin. While many of these
benefits are limited to the project area, others, such as pollutant removal and improved aquatic and
terrestrial habitat have more far-reaching effects." While channel restoration that allows the stream
access to its floodplain would provide some nutrient and pollutant removal, it is unclear how
stormwater from upstream (e.g., volume and velocity) will be managed by the proposed stream
restoration and enhancement.
Page 6 states: "Several utility line rights-of-way intersect and run parallel to Irvin Creek and Little
Troublesome Creek and include overhead utility lines, a natural gas pipeline, and a sanitary sewer
line. Habitats within these areas range from moderately to heavily maintained." It is not clear
whether these rights-of-way will be included within the mitigation bank or simply be adjacent land
uses. Regardless, we encourage coordination with the local government or companies that manage
these rights-of-way to make these more wildlife friendly. We offer the following recommendations
for utility line rights-of-way to further improve wildlife habitat:
• Wheat/clover mixes can be planted with the edges maintained in native warm season
grasses for bugging, nesting, and loafing sites. The warm season grasses should be
mixed with other beneficial wildlife plantings (i.e., partridge pea, beggar weed, and
ragweed) to present some variety of food and cover. It is the "step-down" edge effect
from forest to open land that wildlife seem to prefer.
• Where feasible, use woody debris and logs to establish brush piles and downed logs
adjacent to the cleared right-of-way to improve habitat for wildlife.
• Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. We suggest a maintenance schedule that
incorporates only a portion of the area - one third of the area, for example - each year
instead of the entire project every 3 or 4 years.
0 Herbicides and pesticides should not be used in wetland areas or near streams,
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Prospectus - Little Troublesome Creek Mitigation Bank
Thank you for the opportunity to review and comment on this Prospectus. If we can be of further
assistance, please contact our office at [phone].
cc: Howard Hall, USFWS
Kathy Matthews, USEPA
Eric Kulz, DWQ