HomeMy WebLinkAbout20120077 Ver 1_More Info Letter_20120426MCR�
North Carolina Department of Environment and Natural Resources
Beverly Ea-es Perdue
Governor
Division of Water Quality
Charlac IA/aklld P E
Director
Aprii 26 2012
Mr Eric r'x ye- Project Manage -
U S Army Corps of Engineers
Raleigh Reg»la+ory Field Office
3331 Heritage Trade Drive Suite 105
Wake Forest NC 27587
Subject Property Del -Webb Active Adult Community
Dear Mr Alsmeyer
DPP Freeman
�
eGletdry
DWQ Project # 12 0077
Durham County
On April 3 2012 the N C Division of Water Quality (DWQ) received a notice from the U S
Army Corps of Engineers (USACE) requesting comments for the proposed Del Webb Active
Adult Community in Durham NC DWQ believes the adverse effects will be more than minimal
for the following reasons
• The total proposed permanent stream impacts for the project are 512 linear feet including
250 linear feet of perennial stream impacts and 262 linear feet of intermittent stream
impacts
• In addition to the proposed permanent stream impacts 0 621 acres of wetlands will be
permanently impacted, including both 404 and isolated wetlands and 186 487 square feet
of protected riparian buffer will be impacted including both Zone 1 and Zone 2
• The project is located in the Neuse River Watershed Nutrient Sensitive Waters and the
proposed imperviousness is 45%
• Aquatic Life DWQ conducted stream determinations on this property on four (4)
separate occasions During these site inspections it was observed that perennial streams
supported aquatic life including caddisflies amphipods isopods amphibian
and fish While the intermittent streams did not appear to support the same diversity of
aquatic life as the perennial streams amphipods isopods and amphibians were observed
in these channels [Note Benthic macro invertebrates were indentified using a rapid
visual method (e g flipping rocks and /or leaf packs) no dip nets or kick nets were used
The actual diversity of aquatic life may be higher than what was observed since all types
of benthic habitats were not captured during the rapid sample ]
Wetlands Buffers Stormwater — Compliance and Permitting (Webscape) Unit
1650 Mad Service Center Raleigh North Carolina 276991650 One
Location 512 N Salisbury St Raleigh North Carolina 27604 NorthCarohna
Phone 919-807 water FAX 919807-6494 � ullul f "�
Internet www ncwaterauahly oro l V/ bi 69
An Equal Opportunity 1 Affirmative Action Employer
Del Webb Active Adult Community
Page 2 or .3
Rpril26 2012
• Nutrient Sensitive Waters It has been demonstrated that the small size of intermittent
streams ensures a large amount of water /stream floor substrate contact This contact
rerio ,ves nitrogen from stormlvater rupoft through nitrification and derutritication
(Mulholland et al 2001 Peterson et al 200 1) while perennial streams use denitrification
almost exclusively Sweeny (USFWS 2000) has calculated that if the nutrient reauction
functions of intermittent and small perennial streams were removed (streams filled) it
would be nearly impossible to successfully implement a nutrient reduction strategy in a
watershed Wallace (USFWS 2000) has also found that intermittent and small perennial
streams streams are a mayor source (nearlv half) of organic carbon (food) to aquatic
ecosystems (up to 1 kg carbon exported downstream/ in of stream)
• Miti ag tion As was presented to the North Carolina Water Quality Committee of the
Environmental Management Commission on November 12 2008 intermittent streams
support aquatic life and thus they fall within the Division of Water Quality s (DWQ)
mission to protect the propagation of aquatic life Accordingly DWQ requires mitigation
for stream impacts with a cumulative total or greater than 150 linear feet of intermittent
and/or perennial streams This requirement is applied to all streams including those not
subject to jurisdiction under Section 404 (such as isolated streams)
Thank you for your consideration If you have any questions please contact Ian McMillan in our
Central Office at (919) 807 6364 or Lauren Witherspoon in our Raleigh Regional Office at (919)
791 4200
Sincerely
" 44-4-,
Karen Higgins Supervisor
Wetlands, Buffers Stormwater Compliance
and Permitting (Webscape) Unit
KAH/ijm
cc Jean Gibby Field Chief USACE Raleigh Regulatory Field Office (via email)
Lauren Witherspoon DWQ Raleigh Regional Office
Debbie Edwards S &EC, P A 11010 Raven Ridge Road Raleigh NC 27614
Jeff Garnett EPA Sam Nunn Federal Center, 61 Forsyth Street SW Atlanta GA 30303
File Copy
Filename 120077De1 _WebbActiveAdultCommumty( Durham )Commenting_Letter_USACE_(3) docx
Del Webb Active Adult Community
Page 3 of 3
April 26 2012
Literature Cited
Mulholland P J J L Tank D M Sanzone B J Peterson W Wolheim J R Webster and J L Meyer
2001 Ammonium uptake length in a small forested stream determined by 15N t-acer and ammonium
enrichment experiments Verh Internat Verein Limnol 27 1320 1325
Peterson B J W M Wolheim P J Mulholland J R Webster J L Meyer J L Tank E Marti W B
Bowden H M Valett A E Hershey W H McDowell W K Dodds S K Hamilton S Gregory
D D N4orra'l 2001 Control of nluogcn export f-ort dace ,heds b./ headiiator "trear►-is SCILrtL.,
292 86 90
USFWS 2000 The value of headwater streams results of a workshop State College Pennsylvania April
13 1999 State College PA