20120047 Ver 1_More Info Received_20120202

Strickland, Bev
From: McHenry, David G.
Sent: Thursday, February O2.2O123:S4PM
To: Sthnk|and, Bev; Tasha McCormick (tasha1mnnonnink@usano. army. mi|); Homowood, Sue
Subject: University Nissan, OVVQ 20120047. Watauga 'wrccomments
Attachments: UnivoshyNissan_OVVQ 2O12OO47_wot|and fills and UT South Fork New Rivo(_VVRC
nommontsdon
Please accept these comments.
Thanks
Dave
Email corresponclence to ancl from this sencler is stibject to the N.C. Ptiblic Recorcis Law ancl may be, clisclosec] to thircl parties.

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
February 2, 2012
Ms. Tasha McCormick
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
Mr. Ian McMillan
NCDENR, Division of Water Quality, 401 Unit
1628 Mail Service Center
Raleigh, North Carolina 27699 -1628
SUBJECT: University Nissan 404/401 Application, Watauga
DWQ No. 20120047
Dear Ms. McCormick and Mr. McMillan:
Mr. Chris Welborne with University Nissan requested a permit to permanently fill about 0.46 acre of wetlands
and 245 feet of an intermittent tributary to the South Fork New River. Comments from the Commission on
this permit action are offered for your consideration under provisions of the Clean Water Act of 1977 (33
U.S.C. 466 et. seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 -
667d).
The streams on the property appear too small to support fish. The South Fork New River downstream of the
site supports trout and other sensitive species such as the Kanawha darter. Therefore, it is important that
erosion controls be effective with this project. We do not believe it is necessary to avoid the stream work
during the trout spawning moratorium provided the temporary stream flow by -pass is functioning during the
excavation and culvert installation.
We support the construction of the stormwater treatment unit, but suggest considering an improvement to
reduce the potential thermal impacts of this project on aquatic habitat. Specifically, a few tall growing trees
should be planted along the southern side of the rock -lined detention basin to provide summer -time shade.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

University Nissan Page 2 February 2, 2012
Watauga
Run -off from summer storms should be warm here following construction of the new paved and building
areas. Shade may help reduce any additional warming in the treatment unit.
We believe that additional compensatory mitigation is warranted for the wetland impacts, particularly wetland
W -1. Our staff regrets being unable to visit the site to assess the condition of wetland WI, which we also
understand is an old sediment basin. Nevertheless, cattail marshes similar to W -1 are typically good habitat
for small mammals and a variety of birds. Moreover, non - riverine wetlands of this type are particularly rare
in the mountains, which may be partly why the NCEEP cannot mitigate them in -kind in this catalog unit. The
need to mitigate for the W -1 impact with riverine wetland credits supports a higher than 1:1 ratio. We
recommend that either a 2:1 ratio be apply to W -1 or additional justification for a lower ratio be obtained (Le.
contaminant data, NCWAM scores,..).
In addition to considering the preceding comments, as applicable, we recommend attaching the following
conditions to the permit /certification to help conserve fish and wildlife habitats, particularly during
construction:
Sediment and erosion control measures for sensitive watersheds (15A NCAC 4B .0124) must be used
and maintained until all disturbed soils are permanently stabilized. All bare soil shall be seeded as
soon as possible after ground disturbance and erosion control matting used with seeding on disturbed
stream banks. Matting should be secured with stakes or, wherever possible, live stakes of native
trees. Tall fescue must not be used along streams.
2. Stream channel excavation shall be conducted in the dry using sandbags or other temporary diversion
structures.
3. Stormwater detention basins should be shaded to reduce the warming of downstream receiving waters
that support trout.
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 452-
2546 extension 24 if you have any questions about these comments.
Sincerely,
ff� .
Dave McHenry
Mountain Region Coordinator
Habitat Conservation Program
cc: Mr. Sue Homewood, NC Division of Water Quality
Mr. John Vilas, ENV Environmental Consulting Services, Inc.