20031189 Ver 1_Other Agency Comments_20031017

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® North Carolina Wildlife Resources Commission
Charles R. Fullwood, Executive Director
MEMORANDUM *MODS 1401 ?7,80Up
TO: John Dorney, Wetland Scientist OCT Y x 2003
Wetlands/401 Water Quality Certification Unit
DiXision of Water Quality wAO
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FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 15 October 2003
SUBJECT: Pre-construction Notification Application for Centex Homes, Newell Property,
Union County, North Carolina. DWQ ID: 031189
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 Clean Water Act of 1977 (as
amended), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667d), North Carolina General Statutes (G. S. 113-131 et seq.), and the North Carolina
Administrative Code 15A NCAC 10I.0102.
The applicant proposes to impact 147 linear feet (If) of perennial stream channel, 381 if
of intermittent stream channel, and 0.034 acre of temporary impacts to wetlands in the Catawba
River watershed for construction of a residential subdivision. Total impervious surface will be
20-25%. The applicant indicates that extensive buffers have been maintained to the maximum
extent practicable on all channels and that deed notifications will be placed on all sites that have
regulated channels or wetlands and that detention is provided on the property.
The project will impact tributaries of Price Mill Creek. There are records for the federal
special concern and state endangered Carolina creekshell (Villosa vauguaniana), the federal and
state special concern Carolina darter (Etheostoma collis) in Price Mill Creek and records for the
state special concern notched rainbow (Villosa constricta) in East Fork Twelvemile Creek. We
are concerned with the impacts of this project on the sensitive species in this area.
Due to the presence of the Carolina creekshell, we recommend that aquatic surveys be
conducted on perennial streams 100 meters upstream of the proposed crossing, within the
proposed crossing, and 300 meters downstream from the proposed perennial stream project
crossings. Surveys should be conducted by biologists with both state and federal endangered
Mailing Address: Division of Inland Fisheries - 1721 Mail Service Center - Raleigh, North Carolina 27699-1721
Telephone: [phone] ext. 281 Fax: [phone]
I
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NCDWQ No. 031189
species permits. Qualitative mussel sampling should be conducted by visual (snorkel, SCUBA,
or view scope) and tactile surveys and should be conducted during the period 1 April to 31
October. These surveys should be timed to provide catch-per-unit effort (CPUE). Specimens
should be documented for identification confirmation with color digital photographs in JPEG
format. The resource agencies should be provided a complete compilation of the results of the
survey. If species with federal protection status are encountered, sampling activities should
cease and findings should be immediately reported to the USFWS at [phone] and Ryan
Heise of the NCWRC at [phone].
Should it be determined that listed species will not be directly impacted, we recommend
that the following conditions be incorporated into the permit to reduce impacts to aquatic and
terrestrial wildlife resources.
1. We recommend that remaining wetlands and streams on the site be protected from
additional impacts by placing them in a permanent conservation easement, and by
recording preserved areas on deeds. We recommend that these areas are preserved in
perpetuity via donation of the easement to a land trust or similar entity and that property
owners be informed of preservation status.
2. In order to minimize stream impacts, while retaining some measure of wildlife habitat,
we 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 will minimize impacts to fish and wildlife resources,
water quality, aquatic habitat both within and downstream of the project area, and help
prevent the extirpation of endangered and threatened species. In addition, wide riparian
buffers are helpful in maintaining stability of stream banks and for treatment of pollutants
associated with urban stormwater. 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.
3. 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 bankf ill 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 fish 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 to 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.
4. Concrete is toxic to aquatic life and should not be allowed to come in contact with
surface waters until cured.
5. The construction of roadways and other impervious surfaces in new neighborhoods can
produce short-term direct impacts as well as long-term cumulative effects. Multiple
studies have shown that stream degradation occurs at 10% impervious (Schueler 1994;
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NCDWQ No. 031189
Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al. 2000; May and Horner 2000;
Stewart et al. 2000; Paul and Meyer 2001). To adequately protect streams, it is suggested
that impervious surface is limited to less than 10% (Schueler 1994; Arnold and Gibbons
1996; Doll et al. 2000; Mallin et al. 2000; May and Horner 2000; Stewart et al. 2000;
Paul and Meyer 2001). Alternatively, provide for sufficient open space to effectively
reduce impervious surface so that predevelopment hydrographic conditions are
maintained. To achieve no net change in the hydrology of the watershed, we recommend
installation of grassed swales in place of curb and gutter and on-site stormwater
management (i.e. bioretention areas). Many of these recommendations have been applied
in Maryland in efforts to protect the Chesapeake Bay from water quality degradation
(MDE 2000). Information on innovative stormwater and low impact design (LID) ideas
may be obtained at www.lowimpactdevelopment.ora (accessed October 2003).
The N. C. Department of Transportation (NCDOT) has issued road guidelines that allow
for the reduction in street widths when compared to standard secondary road guidelines.
This material can be found at hAp://www.doh.dot.state.nc.us/operations/tnd.pdf (accessed
October 2003). In addition, there are site planning practices that, when incorporated with
the above mentioned road building guideline, can further reduce the amount of
impervious surface within a site. We recommend using the document Better Site Design
(Center for Watershed Protection; http://www.cwp.orjz/, accessed October 2003) in
combination with the above NCDOT guidelines to limit impacts.
6. We recommend that landscaping consist of non-invasive native species and LID
technology. Using native species instead of ornamentals should provide benefits by
reducing the need for fertilizers, herbicides, and pesticides. Additionally, native species
should require less water. 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.
7. We recommend that the following measures be incorporated into the erosion and
sediment control plan (see Brown and Caraco 2000 for additional information).
a) Minimize clearing and grading and only perform these operations in the context of an
overall stream protection strategy.
b) Protect waterways by preventing clearing adjacent to waterways, and stabilize
drainage ways.
c) Phase construction for larger construction sites (>25 acres) to reduce the time and
area that disturbed soils are exposed.
d) Stabilize soils as rapidly as possible (<2 weeks) by establishing a grass or mulch
cover.
e) Protect steep slopes, and avoid clearing or grading existing steep slopes as much as
possible.
f) Establish appropriate perimeter controls at the edge of construction sites to retain or
filter concentrated runoff from relatively short distances before it leaves the site.
g) Employ advanced settling devices that contain design features which include wet or
dry storage volume, perforated risers, better internal geometry, use of baffles,
skimmers and other outlet devices, gentler side-slopes, and multiple cell construction.
The system should be designed to protect against storm events of variable sizes,
including the 100-yr storm event.

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NCDWQ No. 031189
h) Utilize LID technologies in design such as the distributed control approach, where the
post development excess runoff volume is retained in discrete units throughout the
site to emulate the predevelopment hydrologic regime (Prince George's County DER
1999). Management of both runoff volume and peak runoff rate would be included in
the design.
i) Maintain predevelopment flow rates during and after construction.
j) Implement a certified contractors program so trained and experienced contractors are
on-site and oversee installation and maintenance of BMPs.
k) Sedimentation impacts should be minimized by regular inspection of erosion control
measures, and sediment control devices should be maintained in good and effective
condition at all times. Erosion and sediment controls should be reassessed after
storms. The incorrect installation of erosion control structures and those not properly
maintained can result in sedimentation impacts to nearby streams and wetlands.
1) Utilize onsite vegetation and materials for bank stabilization, minimize the use of
riprap (or hard stabilization methods), and maximize the use of native vegetation for
stabilization and shade. We request that matting along with vegetation be used to
stabilize the side slopes adjacent to wetlands to prevent soil erosion into these
sensitive areas.
Thank you for the opportunity to provide input during the planning stages for this project.
If we can be of further assistance, please contact our office at [phone].
Literature Cited:
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage-the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258.
Brown, W., and D. Caraco. 2000. Muddy water in - muddy water out? Watershed Protection
Techniques 2(3):393-103.
Doll, B. A., D. E. Wise-Frederick, C. M. Buckner, S. D. Wilkerson, W. A. Harman, and R. E.
Smith. 2000. Hydraulic geometry relationships for urban streams throughout the
piedmont of North Carolina. Pages 299-304 in P. J. Wigington, Jr. and R. L. Beschta,
eds. Proceedings of the American Water Resources Association International Conference
on riparian ecology and management in multi-land use watersheds, Portland, Oregon.
Mallin, M. A., K. E. Williams, E. C. Esham, and R. P. Lowe. 2000. Effect of human
development on bacteriological water quality in coastal watersheds. Ecological
Applications 10(4):1047-1056.
May, C. W. and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on
stream-riparian ecosystems. Pages 281-286 in P. J. Wigington, Jr. and R. L. Beschta,
eds. Proceedings of the American Water Resources Association International Conference
on riparian ecology and management in multi-land use watersheds, Portland, Oregon.
MDE (Maryland Department of the Environment). 2000. 2000 Maryland stormwater design
manual, volumes I and II. Center for Watershed Protection and MDE, Water
Management Administration, Baltimore, Maryland.
http://www.mde.state.md.us/enviromnent/Wma/stormwatermanual/
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NCDWQ No. 031189
Paul, M. J., and J. L. Meyer. 2001. Streams in the urban landscape. Annual Review of Ecology
and Systematics 32:333-365.
Prince George's County, Maryland. 1999. Low-impact development hydrologic analysis.
Department of Environmental Resources, Prince George's County, Maryland.
Schueler, T. 1994. The importance of imperviousness. Watershed Protection Techniques.
1(3):100-111.
Stewart, J. S., D. M. Downes, L. Wang, J. A. Wierl, and R. Bannerman. 2000. Influences of
riparian corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J.
Wigington, Jr. and R. L. Beschta, eds. Proceedings of the American Water Resources
Association International Conference on riparian ecology and management in multi-land
use watersheds, Portland, Oregon.
cc: Todd Tugwell, USACOE
E-mail: Alan Johnson, DWQ
Cindy Karoly, DWQ
Sarah Kopplin, NHP