20201252 Ver 1_WRC Comments_20210302

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
MEMORANDUM

TO: Rick Trone
401 & Buffer Permitting Branch
NCDEQ – Division of Water Resources

FROM: Gabriela Garrison
Eastern Piedmont Coordinator
Habitat Conservation

DATE: March 2, 2021

SUBJECT: Comments for McKenzie Meadows Development, Wake County, DE Q Project No. 2020-
1252.

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113 -131 et seq.).

Carolina Land Group, LLC proposes to construct a mixed, single and multi-family residential
development and associated infrastructure, including roads, stormwater control measures and ut ility
improvements. Wetland impacts include 0.071 and 0.198 acres of temporary and permanent impact,
respectively. Stream impacts include 51 linear feet of permanent stream impact. Lastly, buffer impact
includes 3,203 square feet of permanent Zone 1 Buffer and 2,342 square feet of permanent Zone 2 Buffer.
The work will occur along Old Zebulon Road, southwest of its intersection with Wendell Boulevard,
northeast of Wendell.

Aerial images and maps indicate a tributary to Little River flows south of the proposed project site. There
are records for the following rare, aquatic species downstream of the subject property in the Little River:
the federal and state-endangered, dwarf wedgemussel (Alasmidonta heterodon); the federal at-risk species
and state-endangered, Atlantic pigtoe (Fusconaia masoni); the federal at-risk species and state-special
concern, Neuse River waterdog (Necturus lewisi); the state-endangered, green floater (Lasmigona
subviridis); the state-threatened, notched rainbow (Villosa constricta); and the state-significantly rare,
northern lance (Elliptio fisheriana).

The NCWRC is concerned with potentially adverse ecological impacts resulting from project
construction. Placing fill in aquatic systems can alter hydrology, result in significant negative impacts to
downstream areas and eliminate aquatic and terrestrial wildlife habitat. Additional impervious surface in
developing ar eas results in increased stormwater runoff that can impact stream morphology. This will
cause further degradation of aquatic habitat through accelerated stream bank erosion, channel and b edload
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changes, altered substrates and scouring of stream channels. In addition, pollutants (e.g., sediment, heavy
metals, pesticides and fertilizers) washed from developed landscapes can adversely affect and extirpate
species downstream. The following recommendations will minimize impacts to aquatic and terrestrial
wildlife resources:

1. Due to the presence of the federal and state-endangered, dwarf wedgemussel, downstream of
the site, maintain a minimum 200-foot undisturbed, native, forested buffer along perennial
streams, and a minimum 100-foot buffer along intermittent streams and wetlands.
Maintaining undisturbed, forested buffers along these areas will minim ize impacts to aquatic
and terrestrial wildlife resources. Wide riparian buffers are helpful in maintaini ng stream
bank stability. In addition, these buffers prov ide a travel corridor for wildlife species. Lay
down and staging areas should be located outside wetland areas and at least 200 feet from
stream banks.
2. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert, where practicable. If culverts must be used, the culvert
should be designed to allow passage of aquatic organisms. Culverts 48 inches in diameter or
larger should be buried one foot into the streambed. Culverts less than 48 inches in diameter
should be buried to a depth equal to or greater than 20% of their size. These measurements
should 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 flow.
o Riprap should only be placed on the stream banks and not in the stream channel.
In circumstances where there are unavoidable erosive outlet velocities, we
recommend utilizing a designed plunge pool or armor ed scour hole. This type of
designed outlet protection will have a smaller footprint and should utilize an
outlet sill to maintain the appropriate water surface elevation throughout the
protection measure.
3. Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functi ons of flood control and
water quality protection. If necessary, crossings should only be at the narrowest point of
wetland areas. In all forested wetlands, clearing should be done by hand.
4. Use non-invasive, native species and Low Impact Development (LID) technology in
landscaping. Using LID technology in landscaping will not only help m aintain the
predevelopment hydrologic regime but also enhance the aesthetic and habitat value of the
site. LID techniques include permeable pavement and bioretention areas that collect
stormwater f rom driveways and other parking areas. Additional alternatives include narrower
r oads, swales versus curbs/gutters and permeable surfaces such as turf stone, brick and
cobblestone. Compared to conventional developments, implementing appropriate LID
techniques can be more cost-effective, provide space-saving advantages, reduce runoff and
protect water quality (Roseen et al. 2011). Th e NCWRC’s Green Growth Toolbox
(http://www.ncwildlife.org/Conserving/Programs/GreenGrowth Toolbox.aspx) provides
information on nature-friendly planning.
5. If applicable, the directional bore (locating utilities beneath the riverbed and avoiding impacts
to the stream and buffer) stream crossing method should be used f or utility crossings
wherever practicable; the open cut stream crossing method should only be used when water
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level is low and stream flow is minimal. Stream crossings should be near perpendicular (75o
to 105o) to stream flow.
6. Avoid the removal of large trees at the edges of construction corr idors. Disturbed areas
should be re-seeded with seed mixtures that are benef icial to wildlife. Avoid fescue-based
mixtures as f escue is invasive and provides little benefit to wildlife. The NCWRC strongly
recommends against the use of Sericea lespedeza (Lespedeza cuneata) as a stabilizing
groundcover . This is an egregious and invasive, non-native species that is very hard to
eradicate. Native, annual small grains appropriate for the season are preferred and
recommended. Pollinator seed mixes are commercially available and provide f orage and
shelter for numerous species of bees, butt erflies, moths and birds. Where feasible, use woody
debris and logs from cleared areas to establish brush piles adjacent to cleared rights-of -way
(ROW) to improve habitat. Allowing utility corridor areas to re-vegetate into a brush/scrub
habitat would maximize benefits to wildlife. For areas adjacent to residential areas, a native
shrub/grass option may also be beneficial.
7. Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of ROWs within 100 feet of perennial streams and 50 feet of intermittent
streams, or within floodplains and wetlands associated with these streams.
8. Sediment and erosion control measures should be installed prior t o any land-disturbing
activity. The use of biodegradable and wildlife-friendly sediment and erosion control devices
is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose-
weave netting that is made of natural fiber mat erials with movable joints between the vertical
and horizontal twines. Silt fencing and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aqu atic resources
including destruction of spawning habitat, suffocation of eggs and clogg ing of gills.

The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC’s Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aqu atic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/docu ments/2002_
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf ) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources.

Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or [e-mail].

Literature Cited

Roseen, R. M., T. V. Janeski, J. J. Houle, M. H. Simpson, and J. Gunderson. 2011. Forging the Link:
Linking the Economic Benefits of Low Impact Development and Community Decisions.
University of New Hampshire Stormwater Center, Virginia Commonwealt h University, and
Antioch University New England.