20061168 Ver 2_WRC Comments_20070626

~~ North Carolina Wildlife Resources Commission ~
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Steve Chapin, Permit Coordinator
Asheville Office, U. S. Army Corps of Engineers
Cyndi Karoly, 401 Certification Unit
NC Division of Water Quality
FROM: Ron Linville, Regional Coordinator
Habitat Conservation Program
DATE: June 20, 2007
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SUBJECT: Carolina Golf Club, DWQ No. 20061168 version 2, Mecklenburg County
The applicant is requesting a letter of concurrence from the North Carolina Wildlife Resources Commission
(NCWRC) to obtain a 404 permit from the U.S. Army Corps of Engineers. The NCWRC has reviewed information
provided by the applicant and field biologists on our staff are familiar with habitat values of the project area. These
comments are provided in accordance with 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 proposed project is to restore 2091 linear feet of stream and preserve 1000 linear feet of stream to partially
mitigate for 252 linear feet of stream impacts associated with an irrigation impoundment. Historical records were
found for the Carolina elktce, Alasmidonta robusta (Extinct) and the Carolina heelsplitter, Lasmigona decorata
(NCE, FE) for the general area; however, federally threatened and endangered species are no longer known for the
area. No listed animal species are indicated for the immediate area.
We will not object to the project. The following non-prioritized golf course recommendations are provided for your
consideration (as appropriate and/or applicable) during the permitting and certification process:
In order to protect nesting birds, land clearing and forestry activities should be avoided during May
through mid-July to minimize nest destruction and nestling mortality.
Impoundments should be no larger than needed to support the project. Impoundments must have a
minimum flow releases (equal to or greater than the 7Q10) to preserve and maintain downstream
aquatic habitats. As appropriate, NC Division of Land Resources dam safety requirements must be
satisfactorily resolved.
Secondary impacts to wetlands and streams should be minimized by provision of adequate buffers.
We routinely recommend minimum fifty foot intermittent and hundred foot perennial buffers in
watersheds that do not have federally threatened and endangered species. These buffers should be
doubled for watersheds with threatened and endangered species. Maximum available undisturbed
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Faz: [phone]

Carolina Golf Club -Page 2 -
June 20, 2007
woody buffer zones are recommended. Buffers should be maintained as undisturbed forested areas set
aside as permanently protected conservation easements.
To the maximum extent possible, wildlife corridors should be maintained to ensure aquatic and
terrestrial wildlife habitat connectivity.
Instead of using culverts, the project should maximize the use of bridges. If any culverts are permitted,
culverts 48 inches diameter or larger should be buried a foot into the streambed. Culverts less than 48
inches diameter should be buried to a depth equal to or greater than 20% their size to allow for aquatic
life passage. These measurements must be based on natural thalweg depths. Where multiple barrel
culverts are permitted, a base flow barrel must be provided as indicted above. Stormwater conveyance
barrels must be placed on the active floodplain bench elevation to receive and convey stormwater.
These elevated barrels must be connected to the active floodplain benches in a manner to maintain a
continuous base flow channel with natural channel dimensions and provide terrestrial wildlife passage.
6. No floodplain fill should be permitted along jurisdictional waters or wetlands. To the maximum extent
possible, floodplains should be maintained as natural undisturbed areas to preserve stormwater storage,
protect stream integrity and offset habitat losses. Please refer to federal Executive Order 11988 for
additional guidance concerning regulated streams.
7. Utility lines should be placed along the edge of floodplains instead of next to streams to the maximum
extent practicable.
8. Relocated or restored streams must be geomorphically stabile and biologically functional. Restored
streams should be provided by using state-of--the-art natural stream design methodologies. Stability
and habitat monitoring should be provided as routinely required in 404 Permits and 401 Certifications.
Buffers along restored and jurisdictional streams should be permanently preserved and protected
through enforceable conservation easements. Conservation easements should be placed on all buffers
along all jurisdictional waters and wetlands within entire developments, not just on golf courses.
9. To the extent possible, stormwater management for imperviousness on the site, including public and
private structures and infrastructure, should maintain or closely mimic natural runoff and hydrograph
conditions within the watersheds. If impervious area exceeds ten (10) percent, stormwater
management strategies that maintain pre development hydrograph conditions are recommended.
Information on LID practices and measures can be found at ~~~tiw.luwiiiipactdr`elopnicnl.or;,
blip:/l~ww.cp~i.go~~`o~~owinps Iid-liilt<<itl,pdf and litt~~/ww~w sloru~tiralcrcent~r.uct%. A
comprehensive stormwater management plan is recommended to preserve hydrograph conditions to
protect area streams from degradation. Imperviousness exceeding six (6) percent without stormwater
management negatively impacts aquatic environments. Pre and post development runoff and recharge
conditions should be retained to the maximum extent practicable. Stormwater controls outlined by the
US Environmental Protection Agency in their Low Impact Development manual (EPA Document #
841-B-00-002 and 841-B-00-003) may be appropriate. Such measures can significantly reduce
environmental impacts. These measures should include, but not be limited to, off-line naturalized
stormwater ponds or wetlands, avoidance of curb and gutter discharges, minimizing road building and
road widths as well as the provision of rain gardens, grass swells, bio-retention, pervious pavement,
and the protection of naturally forested drainage ways and floodplains.
10. If stormwater ponds or wetlands will be required or provided, autochthonous plantings should be used
around them (except for the dam) for shading to offset thermal impacts to waters as well as to mitigate
for impacts to indigenous wildlife species.
11. Many agricultural and golf course chemicals (e.g. herbicide, pesticide, and fertilizer) are water soluble
easily transported through subsurface flow, and highly toxic to aquatic life. Integrated Pest
Management practices should be fully implemented for golf course maintenance and operations. Bio-
retention or LID methodologies are preferred. Irrigation waters should be recycled to the maximum

Carolina Golf Club -Page 3 -
June 20, 2007
extent possible. No stormwater or other direct discharges to waters should be allowed. All irrigation
and stormwater should be treated through bio-retention measures. The size, location and adequacy of
any proposed bio-retention facilities, interceptor drains and wetlands should be documented and
thoroughly evaluated during site planning and permidcertifigtion approvals by the US Army Corps of
Engineers, the NC Division of Land Resowces and the NC Division of Water Quality.
12. Where flyways must be cleared around or over jurisdictional waters and buffers, removal of riparian
plants should be minimized. Large or tall tree removal should be limited to preserve the integrity of
the riparian buffer zone. Smaller plantings should be maintained as buffers to provide contiguous
relatively undisturbed habitats. Judicious plant removal may be needed; however, buffer zone
management should be a water quality management priority for golf course operations.
13. The golf course should be designed and managed to meet minimum environmental protection or
certification standards developed for Audubon International's Cooperative Sanctuary or the National
Wildlife Federation. Additional golf course design and development information may be obtained
from National Wildlife Federation at Y~ttP:~;~k,w~wa_n~~f_or;;; or Audubon International at
l~t~: %~u~~ w_~-udtthoninll _gr~~oir~ur~5!acss!~ol f~.lllm.
14. Project proponents may wish to contact the US Fish and Wildlife Service to discuss funding
opportunities under the Neotropical Migratory Bird Conservation Act of 2000 (P.L. 106-247). The act
provides grants to Latin America, the Caribbean and the United States for the conservation of
Neotropical migratory birds that winter south of the border and summer in North America. The law
encourages habitat protection, education, researching, monitoring, and capacity building to provide for
the long-term protection of Neotropical migratory birds.
We hope these general recommendations may be helpful during the permitting process. Additional information
about preserving ecosystem integrity can be found at our website,
Yit_tp: 'www.ri~wildli('e.or >I ~~~U % WildlilcSpeciesCon~~7c~ irn~cts.~: h1 addition, excellent nifonnation about
the importance of protecting headwater streams can be found at htt~: r~o«~t~.si~,n;~cluh ~~r~~'Step_e-
Sierra"i~2tl~~~c.b°~,?t3dac:Stt52t, Whcr Rivcrs,ArcB~rn,~xll~.
Thank you for the opportunity to review and comment on this project. If you have any questions regarding these
comments, please contact me at 336/769-9453.
E-copy: Allan Johnson, DWQ-MRO