20150465 Ver 2_WRC Comments_20221130

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sue Homewood
Division of Water Resources
N.C. Department of Environmental Quality
FROM: Gabriela Garrison
Eastern Piedmont Coordinator
�i�.W
Habitat Conservation
DATE: November 30, 2022
SUBJECT: Individual Permit Application for Novo Nordisk Site Expansion, Johnston County, North
Carolina (SAW-2015-00471).
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.).
Novo Nordisk Pharmaceutical Industries, LP proposes to expand production, packaging, and warehousing
facilities at their finished products facility in Johnston County to manufacture insulin and other
pharmaceutical products. The project area would be graded and balanced to facilitate construction of the
proposed production facilities, fields, and access roads. The existing facility is located at 3612 Powhatan
Road in Clayton.
The site currently contains 3,642 linear feet of stream, 0.83 acre of wetlands, and 0.59 acre of open water.
The wetlands on -site are classified as headwater forest according to the North Carolina Wetland
Assessment Method. Construction of the proposed project would require permanent and temporary
impacts to Waters of the US, including wetlands. Anticipated impacts include 1,642 linear feet of stream
channel and 0.83 acre of vegetated wetlands.
Aerial images indicate tributaries to the Neuse River bisect the proposed project area. There are records
for the following imperiled species downstream of the site in the Neuse River: the state -endangered, green
floater (Lasmigona subviridis); the state -threatened, triangle floater (Alasmidonta undulata), creeper
(Strophitus undulatus), and eastern lampmussel (Lampsilis radiata); and the state -special concern,
Roanoke slabshell (Elliptio roanokensis) and NC spiny crayfish (Faxonius carolinensis). There are no
current records for rare, endangered, or threatened species onsite. However, lack of records is not
indicative of species absence, rather lack of extensive surveying throughout the area.
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
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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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 the stream channel. In addition, pollutants (e.g., sediment,
heavy metals, pesticides, and fertilizers) washed from developed landscapes can adversely affect and
extirpate species downstream. As such, the NCWRC offers the following guidance and recommendations
to minimize impacts to aquatic and terrestrial wildlife resources:
The NCWRC recommends maintaining 100-foot, native, forested buffers on all perennial streams and
50-foot, forested buffers on all intermittent steams where feasible. If wooded buffers do not exist,
these areas should be revegetated or allowed to naturally revegetate to increase functionality.
Periodic checks should be established to ensure invasive species are not growing in areas that have
been disturbed during construction. Wooded buffers include a combination of native trees, shrubs,
perennials, and warm season grasses. There are local nurseries that specifically grow native
vegetation suitable for riparian areas. Non-native grassed buffers, particularly fescue, do not provide
the necessary and highly valuable functions that forested buffers provide, including refugia and travel
corridors for terrestrial wildlife species. In addition, they protect water quality by stabilizing stream
banks and filtering stormwater, including sediment, nutrients, pesticides, and other material found in
runoff.
2. Small, isolated wetlands are not protected by state and federal regulations but provide critical
breeding habitat for many amphibians. These areas are important for the protection of biodiversity,
groundwater recharge, and reducing sedimentation and pollution into streams and rivers. These
wetlands are considered an imperiled habitat in the 2015 North Carolina Wildlife Action Plan
(http://www.ncwildlife.org/plan). As such, the NCWRC continues to encourage maintaining a 150-
foot forested buffer around all small, isolated wetlands.
3. The NCWRC recommends the use of Low Impact Development (LID) technology and effective
stormwater management strategies. Possible suggestions include engineered stormwater wetlands,
bioswales, and permeable pavement. Information on other LID techniques can be found in `Low
Impact Development, A Guidebook for North Carolina':
https:Hdigital.ncdcr.gov/digital/collection/p I6062co119/id/232781.
4. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas where
stabilization is needed should be re -seeded with seed mixtures that are beneficial to wildlife - see
attached Table. The NCWRC strongly recommends against the use of fescue -based mixtures and
Sericea lespedeza (Lespedeza cuneata) as stabilizing groundcover. Sericea lespedeza in particular is
an egregious and invasive, non-native species that spreads easily and is very hard to eradicate.
Native, annual small grains appropriate for the season are preferred and recommended. Pollinator
mixes are commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths, and birds. Using native species instead of ornamentals should reduce the need for
water, fertilizers, and pesticides, as well as preserve the natural integrity of the ecosystem.
5. The NCWRC strongly encourages the use of native vegetation in public areas. In efforts to restore
diversity and ecosystem functionality in a highly fragmented landscape, please consider revegetating
natural and/or open areas with native trees, shrubs, warm season grasses and perennials that are
attractive and valuable to pollinating insects and other wildlife. The following website has a wide
assortment of native vegetation specific to North Carolina: hops://ncbg.unc.edu/w-
content/uploads/sites/963/2019/08/NativePlantsWoody_pdf. In addition, there are numerous local
nurseries that specialize in native plants for both upland and riparian areas. Free technical guidance
from NCWRC biologists is also available upon request.
6. Please confirm that all contractors and landscapers have been educated on proper herbicide use and
protocol. If there are areas where native vegetation will be installed, please post signage to ensure

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that contractors will not spray on or in the vicinity of the vegetation. Staff biologists from NCWRC
monitor numerous sites across the State where contractors and landscapers have unknowingly sprayed
native vegetation because it was not clearly marked. Insecticides and herbicides should not be used
within 100 feet of perennial streams and 50 feet of intermittent streams, or within floodplains and
wetlands associated with these streams.
7. In addition to standard erosion and sediment control measure, 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 materials that
have been reinforced with plastic or metal mesh should be avoided as they impede the movement of
terrestrial wildlife species. Existing DWR 401 certifications state that `erosion control matting that
incorporates plastic mesh and/or plastic twine shall not be used along streambanks or within
wetlands. Exceptions to this condition require application to and written approval from DWR'.
Plastic -free mesh or twine in all erosion control matting should be used in all areas within the project
boundary.
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_
GuidanceMemorandumforSecondMandCumulativeImpacts.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] orgabriela.garrisonkncwildlife.org.

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Table: Wildlife -friendly stabilizing groundcover.
lblac
cost/lb
Proso or Brown Top Millet
30
0.88
$26.40
Austrian Winter Pea or Iron Clay*
10
1.1
$11.00
Buckwheat
40
0.88
$35.20
Durana Clover
5
8.33
$41.65
Black-eyed Susan
1
22
$22.00
P urp letop
5
22
$110.00
Beaked Panicgrass
4
19.8
$79.20
Wild Rye*
5
6.6
$33.00
Carthage Switch Grass
4
6.6
$26.40
Partridge Pea
3
6.6
$19.80
Ragweed
1
13.33
$13.33
Sum $417.98
Prices from Adams Briscoe or Ernst
Ernst Mix NC Steep Slope Mix $993.60 plus cover crop
Other mixes run 700 to $800 without cover.
* During cool season use Austrian Winter Peas and increase Wild Rye to 20 lbs.