20080499 Ver 3_NCWRC Comments_20150831

9 North Carolina Wildlife Resources Commission If
Gordon Myers, Executive Director
MEMORANDUM
TO: David E. Bailey, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Western Piedmont Coordinator
Habitat Conservation Division
DATE: 31 August 2015
SUBJECT: Public Notice for TDO Land Holdings, LLC for Phase II of Triad Business Park, Guilford
County, North Carolina. Corps Action ID #: SAW- 2013 -00556
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661- 667e), and
North Carolina General Statutes (G. S. 113 -13 1 et seq.).
The applicant proposes to permanently impact 190 linear feet of stream channel and 0.59 acre of
wetlands, and temporarily impact 45 linear feet of stream channel and 0.06 acre of wetlands to construct a
road crossing for Phase II of the Triad Business Park (TBP). If authorized, cumulative impacts for Phases I
and II of the TBP include permanent impacts to 415 linear feet of stream channel, 0.78 acre of wetlands, and
0.22 acre of open waters, and temporary impacts to 369 linear feet of stream channel and 0.56 acre of
wetlands. Additional impacts to streams and wetlands for future development of Phase II of the TBP are not
anticipated. Impacts are proposed to be compensated through payment to the N.C. Division of Mitigation
Services; a 2:1 mitigation ratio is proposed for the permanent stream and wetland impacts.
Unnamed tributaries to West Fork Deep River in the Cape Fear River basin flow through the site.
The U.S. Fish and Wildlife Service recently listed the Northern long -eared bat (Myotis septentrionalis) as
threatened under the Endangered Species Act. The Northern long -eared bat may be present within or in the
vicinity of the project site. Therefore, the project may impact this species and consultation with the U.S. Fish
and Wildlife Service may be required. For more information, please see
httn: / /www.fws.2ov /midwest /endangered/ mammals /nleb /Interim4dRuIeKevNLEB.html or contact the U.S.
Fish and Wildlife Service at (919) 856 -4520 to ensure that any issues related to this species are addressed.
We hesitate to concur with the piping of stream channels due to the potential for long -term and
cumulative impacts. Stream piping and placing fill in aquatic resources can alter hydrology, result in
significant negative impacts to downstream areas, and eliminate aquatic and terrestrial wildlife habitat.
Stream piping reduces the infiltration of stormwater and associated pollutants, as well as the dissipation of
stream energy. In addition, we hesitate to concur with the filling of wetlands due to their wildlife habitat
value and the well -known beneficial functions they provide for flood control and water quality protection.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Page 2
31 August 2015
Triad Business Park — Phase II
Corps Action ID No.: SAW- 2013 -00556
Although the proposed project is for a road crossing, the lots within Phase II of the TBP will be
developed in the future. Changes in land use and increases in impervious surfaces may exacerbate channel
degradation and sediment impacts to stream ecosystems due to increased stormwater runoff and elevated
flooding. Pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from roads and
developed landscapes can adversely affect and extirpate species downstream.
Should the permit be issued, we offer the following recommendations to minimize impacts to aquatic
and terrestrial wildlife resources.
1. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a
minimum 50 -foot buffer along intermittent streams and wetlands. Maintaining undisturbed, forested
buffers along these areas will minimize impacts to aquatic and terrestrial wildlife resources, water
quality, and aquatic habitat both within and downstream of the project area. Also, wide riparian buffers
are helpful in maintaining stability of stream banks, for treatment of pollutants associated with urban
stormwater, and provide a travel corridor for wildlife species.
2. Avoid development and fill in the 100 -year floodplain. Development and fill in the floodplain increases
the potential for flooding and interferes with the natural hydrologic process of the waterways. It also
disrupts the continuity of migration corridors for wildlife.
3. Limit impervious surface to less than 10% or use stormwater control measures to mimic the hydrograph
consistent with an impervious coverage of less than 10 %.
4. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer areas. The
directional bore (installation of utilities beneath the riverbed, avoiding impacts to the stream and buffer)
stream crossing method should be used for utility crossings wherever practicable. The open cut stream
crossing method should be used only when water level is low and stream flow is minimal. Maintain a
minimum 100 -foot setback on perennial streams and a 50 -foot setback on intermittent streams.
Pesticides should not be used for maintenance of rights -of -way within 100 feet of perennial streams and
50 feet of intermittent streams, or within floodplains and wetlands associated with these streams
5. Use landscaping that consists of non - invasive native species and Low Impact Development (LID)
technology. Using native species instead of ornamentals should provide benefits by reducing the need
for water, fertilizers, and pesticides. 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.
6. 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 that has been reinforced with plastic or metal mesh should be avoided as it impedes the
movement of terrestrial wildlife species. These 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.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at (336) 449 -7625 or shari.bryant(&ncwildlife.org.
ec: Sue Homewood, NCDWR (DWR ID: 20150740)