20071576 Ver 1_Other Agency Comments_20071029

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FAX COVER
NC Wildlife Resources Commission
Habifat Conservation Program
P. O. Box 129
Sedalia, NC 27342-0129
Date 10129!07
Number of pages including cover sheet 4
To: Mr. Andrew Williams
From: Shari Bryant
Phone 919-8Tfi-8449 Phone
Fax Phone [phone] Fax Phone
CC:
336149 7625
33fi-449-7625
REMARKS:
^ Urgent ^ For your review ^ Reply ASAP ^ Piease comment
Corps Action iD#: 2007-03073-201 - Atamance West, Aiamance County
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~ North Carolina Wildlife Resources Commission
Fred A. Harris, Interim Executive Director
MEMORANDUM
TO. Mr. Andrew Williams, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator .~QJ,,~,,,,,'~ ~~.,r..~
Habitat Conservatton Program iiiiii
DATE: 29 October 2007
Sl:_TBJECT: Public Notice for Alamance Grassing, LLC for Construction of Alamance West,
Alamance County, North Carolina. Corps Action ID No. 2007-03073-241
Biologists with the North Carolina Wildlife Resources Commission {NCWRC) have reviewed the
subject document and we are familiar with the habitat values of the area. 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; l6 U.S.C. 661-667d), and North Carolina General Statutes (G.S. 113-131
et sec}.}.
The applicant proposes to construct a commercial/retail facility. The project will permanently
impact 1.75 acres of jurisdictional shrub/scrub riparian wetlands and 2,077 linear feet of stream channel.
In addition, the applicant is applying for authorization for a small {4.41 acre) wetland impact that has
already occurred. The impacts would result from a proposed road crossing and lot f iI for retail buildings
and parking. The applicant proposes to mitigate at a 1:1 ratio for impacts to wetlands and stream
channels with important function by payment into the North Carolina Ecosystem Enhancement Program.
In addition, the applicant proposes to preserve through a restrictive covenant the remaining jurisdictional
wetlands (1.89 acres), streams (2,5141inear feet) and riparian areas (buffers) on the site.
Urmamed tributaries to Back Greek in the Cape Fear River basin flow through the site. There are
records for state special concern four-toed salamander {Hemidactylium scutatum) near the project site.
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 resowces can alter hydrology, result in
significarn 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. Likewise, 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.
This area is experiencing rapid urban growth and changes in land use from a primarily forested
area to an urban landscape may exacerbate channel degradation and sediment impacts to stream
Mailing Address: Division of Inland Fisheries 172I Mail Service Center Raleigh, NC 27699-1721
Telephone: (919} 707-0220 Faa: [phone]
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29 October 2007
Atamance West
Corps Action ID #: 2007-03073-201
ecosystems due to increased stormwater runoff and elevated flooding. Multiple studies have shown that
stream degradation occurs at IO% impervious (Schueler 1994; Arnold and Gibbons 1996; Doll et al.
2000; Mallin et al. 2000; May and Horner 2000; Stewart et ai. 2000; Paul and Meyer 2001).
Should the permit be issued, we recommend the following conditions be incorporated to further
minimize impacts to aquatic and terrestrial wildlife resources.
1. To minimize additional stream impacts, while retaining some measure of wildlife habitat, we
recommend a I00-foot undisturbed, native, forested buffer along perennial streams, and a 50-foot
buffer along intermittent streams and wetlands. Maintaining undistwbed, 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.. In addition, wide riparian buffers
are helpful in maintaining stability of stream banks and for treatment of pollutants associated with
stormwater runoff.' Whereas, a grassed buffer= Particularly fescue, is a vegetated buffer but will
not Provide the necessary and highly valuable fianctio~ as discussed for forested buffers.
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_
3. Stormwater control structures should be designed to achieve no net change in the hydrology of
the watershed Additionally, trees and shrubs should be planted around the upper third of the
stormwater detention pond, excluding the dam, to provide habitat benefits that offset those
functions lost by development, partially restore aquatic habitats, reduce exposure of the water
surface to sunlight thereby minimizing thermal pollution, and provide essential summer and
winter habitats.
4. Locate sewers and other utilities as far away from streams as functionally passible and minimize
stream crossings. It is preferable that sewers be located outside the riparian buffers.
5. Any landscaping should consist of noninvasive 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 L1D technology in landscaping will
not only help to maintain the predevelopment hydrologic regime, but also enhance the aesthetic
and habitat value of the site.
6. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained. Excessive
silt and sediment loads can have numerous detrimental effects an 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-?625.
Literature cited
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage---the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258.
Doll, B. A., D. E. Wise-Frederick, C. M. Buckner, S. D. Wilkerson, W. A. Harman, and R. E. Smith.
2004. Hydraulic geometry relationships for urban streams throughout the piedmont of North
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29 October 2007
Alamance West
Corps Action ID #: 2007-03073-201
Carolina. Pages 299-304 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proeeedings of the
American Water Resources Association International Conference on riparian ecology and
management in multi-land use watersheds, Portland, Oregon.
Mallin, M. A., K. E. Williams, E. C. Esham, and R. P. Lowe. 2000. Effect of human development on
bacteriological water quality in coastal watersheds. Ecological Applications 10(4):1047•-1056.
May, C. W. and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on stream-
riparian ecosystems..Pages 281 286 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings
of the American Water Resources Association International Conference on riparian ecology and
management in multi-land use watersheds, Portland, Oregon.
Paul, M. J., and J. L. Meyer. 200 i. Streams in the urban landscape. Annual Review of Ecology and
Systematics 32:333-365.
Schueler, T. 1994. The importance of imperviousness. Watexshed Protection Techniques. 1(3):100-
111.
Stewart, J. S., D. M. Downes, L. Wang, J. A. Wieri, and R. Bannerman. 2000. In£Iuenccs of riparian
corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. 3. Wigington, Jr. and
R. L. Beschta, eds. Proceedings of the American Water Resources Association International
Conference on riparian ecology and management in multi-land use watersheds, Portland, Oregon.
cc; Gyndi Karoly, DWQ
ec: Corey Oakley, WRC
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