20110260 Ver 1_WRC Comments_20110509

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K? North Carolina Wildlife Resources Commission 0
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: 9 May 2011
SUBJECT: Public Notice for University of North Carolina at Chapel Hill for Construction of
Carolina North, Orange County, North Carolina. Corps Action ID #: SAW-2010-01840
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), 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.).
The applicant proposes to permanently impact 552 linear feet of stream channel and 2.142 acres
of wetlands, and temporarily impact 70 linear feet of stream channel. The project will be developed in
two phases. Phase I includes permanent impact to 0.005 acre of wetlands and temporary impact to 10 feet
of stream. All remaining impacts are proposed for Phase II. The purpose of the project is to construct
Carolina North, an expansion of the existing campus to accommodate academic research, service, and
outreach programs that support the University's mission. Mitigation for the project includes payment into
the N.C. Ecosystem Enhancement Program.
Bolin Creek, Crow Branch and Booker Creek or their tributaries flow through the project
boundaries. All streams are located in the Cape Fear River basin and within the B.E. Jordan Reservoir
watershed. The applicant states wetlands within the project boundaries are located in forested areas near
streams or within the old pre-regulatory municipal landfill.
The University proposes to develop approximately 228 acres of the 947 acre property over the
next 50 years. The current use of the property is the Horace Williams Airport; however, the site also was
used as a municipal landfill and a portion of the site was used for disposing of chemical waste from the
University's research activities. That material has been removed and on-going groundwater remediation
and monitoring continues. The remainder of the property is upland forest.
The applicant evaluated two alternative locations to Carolina North. Alternative Area 1 and
Alternative Area 2 are located southeast of the existing campus. Alternative Area 1 is located adjacent to
the Jordan Lake Natural Areas Macrosite. Portions of Alternative Area 2 are within the Jordan Lake
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
Page 2
9 May 2011
Carolina North
Corps Action ID No.: SAW-2010-01840
Natural Areas Macrosite. In addition, it appears Alternative Area 2 is located adjacent to NCWRC game
lands. We support the preferred alternative location site - Carolina North. As proposed, construction on
the Carolina North site will impact lands that are primarily disturbed and there are no rare, threatened or
endangered species, Significant Natural Heritage Areas, or NCWRC game lands within or adjacent to the
proposed site.
In addition to avoiding and minimizing impacts to forested areas, wetlands, and streams, the
applicant is proposing several other measures to reduce impacts to aquatic and terrestrial wildlife
resources. We are pleased to see the applicant is proposing to cluster development on already disturbed
areas, construct highly efficient buildings, use parking decks, optimize solar gain, protect open space,
develop integrated stormwater management (e.g., bioretention, stormwater wetlands, and cisterns), and
use reclaimed water.
Should the permit be issued, we offer the following recommendations to further minimize
impacts to aquatic and terrestrial wildlife resources.
1. Maintain 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 aquatic and terrestrial wildlife resources, water quality, and aquatic habitat
both within and downstream of the project area. In addition, wide riparian buffers are helpful in
maintaining stability of stream banks and for treatment of pollutants associated with stormwater
runoff. 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.
2. Protect all remaining wetlands and streams on the site by placing them in a permanent conservation
easement to prohibit filling, draining, flooding, and excavation.
3. Culverts should be designed to allow passage of aquatic life.
4. Locate sewers and other utilities as far away from streams as functionally possible and minimize
stream crossings. It is preferable that sewers be located outside the riparian buffers as detailed in #1.
5. For greenways, porous pavement materials are preferred over asphalt. Porous pavement facilitates
infiltration of stormwater as opposed to the direct runoff produced from asphalt.
6. Use landscaping that consists of non-invasive native species. Using native species instead of
ornamentals should provide benefits by reducing the need for water, fertilizers, and pesticides.
7. Sediment and erosion control measures should be installed prior to any land clearing or construction.
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.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
ec: Ian McMillan (DWQ ID # 20110260)