20201177 Ver 1_WRC Comments_20201008

Strickland, Bev
From: Munzer, Olivia
Sent: Thursday, October 8, 2020 4:54 PM
To: [e-mail]
Cc: Roden Reynolds, Bryan K CIV (US); Hamstead, Byron A; Russ, W. Thomas; Johnson,
Alan
Subject: NCWRC Comments - SAW-2020-01307 Unity Classical Charter School PCN
Attachments: NCWRC Comments - SAW-2020-01307 Unity Classical Charter School PCN.pdf
Mr. lagnocco,
Please see the attached comments from NCWRC. Let me know if you have questions or need any further guidance.
Olivia
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
NC Wildlife Resources Commission
Rogers Depot
1718 NC Hwy 56 W
Creedmoor, NC 27522
Office: 919-707-0364
Cell: 336-269-0074
[e-mail]>;
www.ncwildlife.org
13 91 n Lm%J
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
1

IQ North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
08 October 2020
Mr. Michael Iagnocco
STV Engineers, Inc.
900 W. Trade Street
Suite 715
Charlotte, NC 28202
SUBJECT: Pre -Construction Notification for the Unity Classical Charter School in Charlotte,
Mecklenburg County, North Carolina. DEQ No. 20201177; USACE Action ID No.
SAW-2020-01307.
Dear Mr. Iagnocco,
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 Performance Charter School Development, LLC, STV Engineers, Inc. has submitted a Pre -
Construction Notification (PCN) application for the Unity Classical Charter School in Charlotte,
Mecklenburg County, North Carolina. The proposed charter school is on an approximately 14.2-acre site
located east of Steele Creek Road and west of Jerpoint Abby Drive. The site consists of primarily single-
family residences, undeveloped misted pine/hardwood forests, and a right -of way. The project would
permanently impact 170 linear feet of an intermittent stream, which would be relocated onsite and an
additional 245 linear feet of headwater channel will be created to improve the stream channel.
Unnamed tributaries of Walker Branch occur within the site. Waller Branch is classified as a Class C
stream by the NC Division of Water Resources (NCDWR). We have records for the state endangered
Carolina creekshell (Villosa vaughaniana), state threatened notched rainbow (V. constricta), state special
concern Carolina darter (Etheostoma collis), and state significantly rare eastern creekshell (V. delumbis) in
Walker Branch and its tributaries. The United States Fish and Wildlife Service (USFWS) lists the federally
endangered Schweinitz's sunflower (Helianthus schweinitzii), Michaux's sumac (Rhus michauxii), and
smooh coneflower (Echinacea laevigata) 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 these species are addressed. The lack of records does not preclude the potential for a
rare, threatened, or endangered species to occur within the project area. An on -site survey is the only
definitive means to determine whether a listed or proposed species is on the site and if it would be impacted
by the project.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

08 October 2020
Unity Classical Charter School
USACE Action ID: SAW-2020-01307
Page 2
NCWRC Comments
We offer the applicant the following recommendations to minimize impacts to aquatic and terrestrial
wildlife resources.
1. Due to the presence of state endangered, threatened, and rare species, we recommend the following
minimization and avoidance measures:
a. Stringent sediment and erosion control measures should be installed prior to any land -disturbing
activity.
b. 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.
c. An effective stormwater management plan should be developed for the site.
d. All mechanized equipment operated near surface waters should be inspected and maintained
regularly to prevent contamination from fuels, lubricants, hydraulic fluids or other toxic
materials.
e. 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.
2. Monitoring is recommended to ensure successful channel and bank stabilization and vegetation
growth. A monitoring plan should be developed, and it should detail success criteria to ensure the
stream channel remains stable, and the riparian buffers are successfully re -vegetated with native,
woody species. Invasive species control should occur regularly, including prior to construction if
present. Invasive species outcompete native plants and provide minimal benefit to wildlife.
Monitoring the site should occur once per year during the growing season for at least three years or
three bankfull events. We recommend the planting list is diverse and consists of species typically
found in that natural vegetation community, as described by M.P. Schafale in The Guide To The
Natural Communities of North Carolina, Fourth Approximation
(https://www.ncOp.org/references/Op-publications/fourth-approximation-descriptions).
Also, if used as mitigation, we question whether these areas should be placed in a conservation
easement to protect them in perpetuity to prevent additional impacts to either the stream channel or
riparian buffers.
3. If pesticides or chemicals will be used for site maintenance, stormwater runoff from the site should be
funneled to bio-retention areas prior to discharge to streams or wetlands. Pesticides, fertilizers, and
other chemicals should not be used in wetland areas or near streams even if they are labeled as
water/wetland friendly.
4. Due to the decline in populations of most bat species, avoid the removal of large trees at the site.
Avoid tree clearing activities during the maternity roosting season for bats (May 15 — August 15).
Use non-invasive native species and Low Impact Development (LID) technology in landscaping.
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
permeable pavement and 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, increase property values,
provide space -saving advantages, reduce runoff, and protect water quality (Roseen et al. 2011).
Also, additional information on LID can be found at the NC State University LID guide:
http://www.onsiteconsortium.org/npsdeal/NC_LID_Guidebook.pdf. NCWRC's Green Growth
Toolbox provides information on nature -friendly planning
(http://www.ncwildlife.org/Conservin /g Programs/GreenGrowthToolbox.aspx).

08 October 2020
Unity Classical Charter School
USACE Action ID: SAW-2020-01307
Page 3
NCWRC Comments
6. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas; the project would be ideal for creating pollinator habitat. 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. Avoid using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.org//plant ,galleries/invasives_list).
7. 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.
8. Ensure all silt fencing is removed once vegetation has reestablished and soils have stabilized.
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.munzerkncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature Cited
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. Available at:
https://owl.cwp.or mdocs-posts/roseen-et-al-2011-forging-the-link/.
ec: Bryan Roden -Reynolds, U.S. Army Corps of Engineers
Alan Johnson, NCDWR
W. Thomas Russ, NCWRC
Byron Hamstead, USFWS