20210927 Ver 1_WRC Comments_20210928

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: Emily Thompson
US Army Corps of Engineers, Wilmington District
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division

DATE: September 15, 2021

SUBJECT: US Marine Corps Air Station Cherry Point, Slocum Road Improvements, Craven
County, North Carolina.
SAW-2021-00067

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
application with regard to impacts on fish and wildlife resources. The project site is located within
forested areas and riparian corridors associated with Slocum Creek and Unnamed Tributary to Slocum
Creek along Alexander Road and Slocum Road on the eastern and western sides of Slocum Creek. Our
comments are provided in accordance with provisions of the Coastal Area Management Act (G.S. 113A-
100 through 113A-128), as amended, Sections 401 and 404 of the Clean Water Act, as amended, the
Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.), the Magnuson-Stevens Fishery
Conservation and Management Act (FCMA), as amended (16 U.S.C. 1801 et seq.), and the Migratory
Bird Treaty Act (16 U.S.C. 703-712 et seq.).

The US Marine Corps Air Station (US MCAS) Cherry Point is seeking US Army Corps of Engineers
(USACE) authorization to fill 6.13 acres of wetlands, 0.12 acre of jurisdiction tributaries, and 242’ of
stream associated with relocating and widening Slocum Road from two to four lanes with an additional
concrete two-lane bridge with pedestrian lane over Slocum Creek. The 64-acre project area for Project
P134 will also serve as the improved Entry Control Facility for MCAS Cherry Point. To minimize
impacts to streams and wetlands, the preferred alternative was shifted to the south as much as practicable
with the utilization of existing roadway corridors. Retaining walls are incorporated to tighten fill slopes
and prevent erosion into wetlands. Proposed bridge abutments were designed to entirely span coastal
wetlands with alignment of the new parallel bridge as close as possible to the existing Slocum Road
bridge. Compensatory mitigation in the form of payment into the NC Division of Mitigation Services In-
Lieu Fee Program is proposed for the impacts proposed.

Page 2

The NCWRC has reviewed the project proposal and has the following comments and recommendations
based on information provide in the public notice:

• Riparian wetlands perform invaluable functions to aquatic resources and their habitats.
Stormwater treatment, runoff filtration, bank stabilization, nutrient removal, and
terrestrial wildlife corridors are all benefits of riparian wetlands. Avoidance and
minimization of impacts to these areas should be exhibited to the greatest extent
practicable with appropriate mitigation as necessary. Any permitted activity in these areas
should address direct impacts to the wetlands as well as impairment of adjacent wetland
functions.

• Information regarding wetland surveys and assessment should be provided. It is
recommended the applicant use the NC Stream Assessment Method (NCSAM) and the
NC Wetlands Assessment Method (NCWAM) to determine the quality of wetlands
impacted by the proposal. Mitigation ratios should be based on the quality of wetlands
impacted.

• Sediment and erosion control measures should be installed prior to any land clearing or
construction. 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 materials with movable joints
between the vertical and horizontal twines. Silt fencing or similar materials that have
been reinforced with plastic or metal mesh should be avoided as they impede the
movement of terrestrial wildlife species. All sediment and erosion control 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.

• Measures to mitigate secondary and cumulative impacts can be found in NCWRC’s
Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to
Aquatic and Terrestrial Wildlife Resources and Water Quality (August 2002;
http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_GuidanceMemorandu
mforSecondaryandCumulativeImpacts.pdf). Conservation easements on adjacent
wetlands would minimize future impacts to Slocum Creek’s riparian habitats in the
immediate area.

In addition to the comments above regarding wetland fill, the following are site specific and standard
recommendations for bridge replacement and construction projects:

− Slocum Creek is designated a Primary Nursery Area (PNA) by the NCWRC. PNAs are
defined as those areas inhabited by the embryonic, larval or juvenile life stages of marine
or estuarine fish or crustacean species due to favorable physical, chemical or biological
factors. As a designated PNA, this waterbody provides an important rearing area for this
variety of estuarine fishes and invertebrates that need relatively undisturbed habitats.
Therefore, stream crossing guidelines for anadromous fish passage should be followed to
maintain or improve aquatic passage. To minimize impacts to this resource during
construction, no in-water work should occur within Slocum Creek or the connected
floodplain from February 15 – September 30.

− Bridge deck drains should not discharge directly into the stream.

Page 3

− Live concrete should not be allowed to contact the water in or entering into the stream.

− If temporary access roads or detours are constructed, they should be removed back to
original ground elevations immediately upon the completion of the project. Disturbed
areas should be seeded or mulched to stabilize the soil and native tree species should be
planted with a spacing of not more than 10’x10’. If possible, when using temporary
structures, the area should be cleared but not grubbed. Clearing the area with chain saws,
mowers, bush-hogs, or other mechanized equipment and leaving the stumps and root mat
intact, allows the area to revegetate naturally and minimizes disturbed soil.

− A clear bank (riprap free) area of at least 10 feet should remain on each side of the stream
underneath the bridge.

− Temporary or permanent herbaceous vegetation should be planted on all bare soil within
15 days of ground disturbing activities to provide long-term erosion control. Non-
invasive species with wildlife benefits are recommended.

− Heavy equipment should be operated from the bank or on top of structure rather than in
stream channels in order to minimize sedimentation and reduce the likelihood of
introducing pollutants into streams.

− Only clean, sediment-free rock should be used as temporary fill (causeways), and should
be removed without excessive disturbance of the natural stream bottom when
construction is completed.

− During subsurface investigations, equipment should be inspected daily and maintained to
prevent contamination of surface waters from leaking fuels, lubricants, hydraulic fluids,
or other toxic materials.

The NCWRC appreciates the opportunity to review and comment on this public notice. If you need
further assistance or additional information, please contact me at [phone] or at
[e-mail]