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HomeMy WebLinkAbout20221617 Ver 1_WRC Comments_20221215NORTH 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: December 15, 2022 SUBJECT: Individual Permit Application for Eastfield Development, Johnston County, North Carolina (DEQ Project No. 2022-1617). 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.). Adventure Development proposes to construct the Eastfield Mixed -use Development. The proposed project area is approximately 348 acres and located east of the intersection of NC Highway 70 and Interstate 95, south of Selma. Currently, the project site consists of mixed hardwoods, agricultural fields, utility easements, and buildings. Proposed project work includes road construction, utility installation, and site grading for future residential, commercial, and industrial use. Permanent project impacts from the Eastfield Development include the following: 151 linear feet of stream channel loss, 4.092 acres of wetland loss, and 1.024 acre of ditch loss. Temporary impacts include 30 linear feet of stream channel. Permanent buffer impacts include 6,414 square feet in Zone 1 and 5,011 square feet in Zone 2. Aerial images and maps indicate Bawdy Swamp and unnamed tributaries to Mocassin Creek bisect the proposed project 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 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. Forest fragmentation is a serious concern as outlying areas of Smithfield and Selma remain predominantly rural. Reduction of habitat due to fragmentation has severe impacts on wildlife populations, including Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Page 2 December 15, 2022 Eastfield Development IP Application deleterious effects on reproduction and migration. Small patches of forest often become degraded and provide little or no value to remaining wildlife. In addition, as healthy ecosystems are disturbed and minimized, invasive plant species become established and create monocultures in areas that previously hosted diverse and intricate natural communities. As such, the NCWRC offers the following guidance and recommendations to minimize impacts to aquatic and terrestrial wildlife resources: 1. The NCWRC recommends maintaining 100-foot, native, forested buffers on all perennial streams and 50-foot, forested buffers on all intermittent steams. 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 sell 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, forested buffers 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 declining populations of 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 recommends 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. og v/digital/collection/ l6062co119/id/232781. 4. Recreational areas and trails in open spaces should be located outside forested, riparian buffers and surfaced with pervious materials. Further information can be found here: https://www.railstotrails.org/build-trails/trail-building-toolbox/trail-building-and-design/developing- trails -in -sensitive -areas/. 5. 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. 6. The NCWRC strongly encourages the use of native vegetation in public areas and rights -of -way. In efforts to restore diversity and ecosystem functionality in a highly fragmented landscape, please also consider revegetating residential and commercial 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: https://ncbg.unc.edg/wp-content/uploads/sites/963/2019/08/NativePlantsWoody_pd£ 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 available upon request. Page 3 December 15, 2022 Eastfield Development IP Application 7. Please confirm that all contractors and landscapers have been educated on proper herbicide use and protocol. In areas where native vegetation will be installed, please post signage to ensure 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. 8. 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_ GuidanceMemorandumforSecondgaandCumulativeImpacts.pdf) details measures to minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources. In addition, please consider following guidance found in the Green Growth Toolbox: https://www.ncwlldlife.org/conserving/rograms/Green-Growth-Toolbox. This is a guide specifically designed for local governments to conserve natural resources while sustaining economic growth. An applicable strategy for the Eastfield Mixed -use Development would include creating higher density areas of residential and commercial development in order to leave larger areas of green space and recreational areas. Thank you for the opportunity to review and comment on this project. If I can be of further assistance, please contact me at (910) 409-7350 or gabriela.garrisonkncwildlife.org. Page 4 December 15, 2022 Eastfield Development IP Application Table: Wildlife -friendly stabilizing groundcover. lblac cost/lb Proso or Brown Top Millet Austrian Winter Pea or Iron Clay* Buckwheat Durana Clover Black-eyed Susan P urp letop Beaked Panicgrass Wild Rye* Carthage Switch Grass Partridge Pea Ragweed 30 0.88 $26.40 1.1 $11.00 0.88 $35.20 8.33 $41.65 22 $22.00 22 $110.00 19.8 $79.20 6.6 $33.00 6.6 $26.40 6.6 $19.80 13.33 $13.33 10 40 5 1 5 4 5 4 3 1 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 Ibs.