20220143 Ver 1_WRC Comments_20220316

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
MEMORANDUM
TO:
FROM:
Cameron Ingram, Executive Director
Collen Cohn
401 & Buffer Permitting Branch
NCDEQ — Division of Water Resources
Gabriela Garrison
Eastern Piedmont Coordinator
Habitat Conservation
DATE: March 16, 2022
SUBJECT: Comments for Floyd Landing, Johnston County, DEQ Project No. 2022-0143.
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.).
Floyd Landing Holdings, LLC proposes to construct a residential community with single family homes,
townhomes, and associated infrastructure. The proposed project is located west of Highway 70 Business,
northwest of its intersection with M Durwood Stephenson Parkway in Smithfield. Wetland impacts
include 0.006 and 0.107 acres of temporary and permanent impact, respectively. Stream impacts include
10 and 258 linear feet of temporary and permanent impact, respectively. Lastly, buffer impacts include
18,624 square feet of permanent Zone 1 Buffer and 9,754 square feet of permanent Zone 2 Buffer.
Aerial images and maps indicate Reedy Branch and Swift Creek flow west of the proposed project site.
There are records for the following imperiled, aquatic species downstream of the site in Swift Creek: the
federally and state -endangered, dwarf wedgemussel (Alasmidonta heterodon); the federally threatened,
Neuse River waterdog (Necturus lewisi), yellow lance (Elliptio lanceolata), and Atlantic pigtoe
(Fusconaia masoni); the state -threatened, eastern lampmussel (Lampsilis radiata), triangle floater
(Alasmidonta undulata), notched rainbow (Villosa constricta), and creeper (Strophitus undulatus); and the
state -special concern, Roanoke slabshell (Elliptio roanokensis). In addition, this section of Swift Creek
has been classified by the U.S. Fish & Wildlife Service (USFWS) as critical habitat for the Neuse River
waterdog, yellow lance, and Atlantic pigtoe. Due to the presence of federally listed species and critical
habitat, John Ellis and/or Kathy Matthews with the USFWS must be contacted: john [e-mail],
kathryn_matthews@fws. gov.
The NCWRC is very concerned with potentially adverse ecological impacts resulting from project
construction and riparian habitat loss in this highly sensitive area. Placing fill in aquatic systems or
constructing within riparian buffers can alter hydrology, resulting in significant negative impacts to
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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DEQ Project No. 2022-0143
downstream areas and eliminating aquatic and terrestrial wildlife habitat. Additional impervious surface
in developing areas 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 bedload
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 aquatic species downstream. Lastly, riparian habitat and floodplains are extremely valuable for
conveying flood waters, thereby reducing the severity and frequency of large flooding events. This
important feature has become increasingly significant as severe storm events have become more prevalent
in recent years. The following recommendations will minimize impacts to aquatic and terrestrial wildlife
resources:
1. Due to the presences of federally listed species in Swift Creek, 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 minimize impacts to aquatic and terrestrial wildlife resources. Wide riparian
buffers are helpful in maintaining stream bank stability. In addition, these buffers provide a
travel corridor for terrestrial 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. Depending on slope and terrain,
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 armored 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 functions 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. Wetland and
riparian areas that are disturbed should be reseeded within 10 days with a native seed mix
appropriate for wetlands and/or riparian areas.
4. Use non-invasive, native species and Low Impact Development (LID) technology in
landscaping. Using LID technology in landscaping will not only help maintain 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 from driveways and other parking areas. Additional alternatives include narrower
roads, swales versus curbs/gutters, and permeable surfaces such as turf stone, brick, and
cobblestone. Compared to conventional developments, implementing appropriate LID

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DEQ Project No. 2022-0143
techniques can be more cost-effective, provide space -saving advantages, reduce runoff, and
protect water quality (Roseen et al. 2011). The NCWRC's Green Growth Toolbox
(http://www.ncwildlife.org/Conserving/Programs/GreenGrowth Toolbox.aspx) provides
information on nature -friendly planning.
5. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re -seeded with native seed mixtures that are beneficial to wildlife. Avoid fescue -
based mixtures as fescue 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 forage and
shelter for numerous species of bees, butterflies, moths, and birds. Where feasible, use
woody debris and logs from cleared areas to establish brush piles adjacent to cleared rights -
of -way to improve habitat. Where applicable, allowing utility corridor areas to re -vegetate
into a brush/scrub habitat would maximize benefits to wildlife. For areas adjacent to
residential communities, a native shrub/grass option may also be beneficial.
6. Sediment and erosion control measures should be installed prior to 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 materials 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 aquatic resources
including destruction of spawning habitat, suffocation of eggs, and clogging 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 Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002
GuidanceMemorandumforSecondaryandCumulativelmpacts.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 Commonwealth University, and
Antioch University New England.