20100127 Ver 1_WRC Comments_20100319

E0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Ian McMillan, 401 Certification Unit
NC Division of Water Quality
FROM: Ron Linville, Regional Coordinator
Habitat Conservation Program
DATE: March 19, 2010
SUBJECT: Husgvarna Corporate Headquarters, Unnamed Tributary Long Creek,
DWQ No. 20100127, Mecklenburg County
The applicant proposes develop the referenced commercial site. Biologists with the North Carolina
Wildlife Resources Commission are familiar with habitat values in the area. These comments are
provided in accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as
amended; 16 U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through
113A-10; NCAC 25).
The project is indicted to impact 0.19 acres of wetland and 148 linear feet of intermittent stream channel.
These impacts are indicated as necessary to develop the headquarters. Mitigation is proposed through
payment to in-lieu fee program ((NC Ecosystem Enhancement Program). No listed species are indicated
for the site and stormwater measures are indicated.
Based on our review of the submittal, we will not object to the project. The following suggestions are
provided for consideration in protecting habitats in the area:
1. Where practicable, streams should remain exposed and vegetated with native riparian plants.
When practicable, streams that may be impacted now or by future development should be
assessed for possible relocation using state-of-the-art natural channel design methodologies.
Where any culverts are installed, they should provide aquatic life passage. Generally,
culverts 48" or larger should be buried a foot into the streambed. Culverts less than 48"
should be buried to a depth equal to or greater than 20% their size to allow for aquatic life
passage. These measurements need to be based on natural thalweg depths. Aquatic life
passage should be assured during low flow or drought conditions. Any riprap used should
not interfere with aquatic life movement during low flows.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
Husqvama HDQTRS Page 2 March 19, 2010
Where practicable and as mentioned above, streams should be rerouted using natural channel
methodologies. Remaining jurisdictional waters and wetlands should be buffered, either
through protection or provision of undisturbed forested buffer zones. Buffers should be
permanently preserved as common contiguous forest areas. For streams that do not support
federally listed threatened or endangered aquatic species, we recommend 50' intermittent and
100' perennial stream buffers. Maximum available buffers should be provided. Community
walking trails may be placed in the buffer zone providing they are kept away from water
edges to the maximum extent practicable and the buffer widths do not exceed minimum
width requirements specified in the Americans with Disabilities Act (ADA).
4. Stringent erosion control measures should be installed where soil is disturbed and maintained
until project completion. Sediment and erosion control measures should adhere to the design
standards for sensitive watersheds (15A NCAC 4B .0024) where appropriate.
5. If any concrete will be used in jurisdictional waters, work should be accomplished so that wet
concrete does not contact wetlands or water while curing.
6. To replace some lost wooded habitats, stormwater ponds should have shaded perimeters (see
attachment) instead of being grassed or riprapped. This will reduce temperature elevations to
waters and restore some habitat values to the site, especially for songbirds. In addition,
forested buffers may help reduce use of the area by nuisance non-migratory geese that prefer
manicured grassed areas.
Thank you for the opportunity to review and comment on this project during the early planning stages. If
you have any questions regarding these comments, please contact me at 336-769-9453.
Attachment: Piedmont Stormwater Pond Planting Recommendations
E-copy: Alan Johnson, DWQ-WSRO
Steve Chapin, USACOE-ARO
Leonard Rindner, Environmental Planning Consultant
Husgvarna HDQTRS Page 3 March 19, 2010
Piedmont Stormwater Pond Planting Recommendations
Instead of using the typical fescue grasses or exotic plant species, the following mixtures should be
considered for lower elevation stormwater ponds and mine sites:
Spring/Summer Mixture, May 1 - Sept. 15 Fall/Winter Mixture, Sept. 15 - April 30
Browntop millet 20 lbs/a
Kobe lespedeza 20 lbs/a
Shrub lespedeza 1 lb/a
Switchgrass* 5lb/a
Winter Wheat 120 lbs/a
Kobe lespedeza 20 lbs/a
Shrub lespedeza 1 lb/a
Switchgrass* 51b/ac
Add to fall or spring plantings: `Tioga' Deertongue (Panicum clandestinum) at a rate of 7 lbs. Pure Live
Seeds (PLS) per acre.
* When possible on slopes less than 3:1 use Switchgrass instead of lespedezas and on slopes greater than 3:1 use
Orchard Grass or Creeping Red Fescue. Other native species may be appropriate depending on soil, slope, and
region. Korean lespedeza may be appropriate in colder geophysical areas. We do not recommend Sericea
lespedeza. Although agriculturally used plants are included herein, native plants and warm season grasses are
preferred and recommended over exotic plants.
Add one of the following to the above mixture:
Creeping Red Fescue 5 lbs/acre
Ladino Clover** 5 lbs/acre
Atlantic Coastal Panic Grass 5 lbs/acre (PLS)
Alfalfa** 5 lbs/acre (requires fertilizer containing Boron)
** Lime & fertilize disturbed areas according to NRCS soil test results and follow planting guidelines as appropriate
and necessary. Depending on elevation and region, other native species may be appropriate. Note that mowing
should be limited to late winter or early spring. Mowing should only occur as needed to prevent unwanted tree
growth on a 2-3 year schedule.
The provision of shade around impounded waters can significantly reduce thermal impacts. Trees and
shrubs (1 year bare root seedlings) should be planted randomly at a minimal rate of 100 trees per acre on
the top and upper portions of the structure and at a minimal rate of 150 per acre around the normal water
elevation and littoral shelf area. The following list of tree species may assist in providing habitat benefits:
Loblolly Pine* Red Cedar Black Gum American Holly Dogwood
Hickory Sumac White Oak Willow Oak Red Maple**
Viburnum Green Ash Ironwood Black Cherry Persimmon
Water Oak Spice Bush Willow (sp) Serviceberry Red Oak
Swamp Chestnut Silky Dogwood
Other species may be utilized depending on site requirements and native plant availability. Pines* should not
exceed 15% of the reforestation. No more than 20% of the tree species will be of a single species. An 80% success
rate is acceptable over five years. Large or fast growing trees like Sycamore and Maple** may not be appropriate
near detention facility dams. Note: Non-native plants included in this list are routinely considered beneficial and/or
agriculturally established non-natives. They have been included as they are readily available commercially and they
do not exhibit many of the negative attributes of other non-natives that tend to spread or inhibit native plant
propagation and survival.