20052116 Ver 3_WRC Comments_20171113

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
13 November 2017
Mr. Perry Isner
Wetlands & Waters, Inc.
2712 Minden Road
Pleasant Garden, North Carolina 27313
SUBJECT: Pre -Construction Notification for Caleb's Creek Mixed -Use Development; Forsyth
County; USACE Action ID: SAW -2015-01697; DEQ Project No. 200521160.
Dear Mr. Isner,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
Wetlands & Waters, Inc, on behalf of BOMA North Carolina, LLC, has submitted a revised Pre -
Construction Notification (PCN) application for a mixed-use development on approximately 875 acres
located south of Interstate 40 and on both sides of Teague Road in Kernersville, Forsyth County, North
Carolina. The proposed project consists of mixed-use development, residential, commercial/office areas,
public school, and large amenity center. A total of 185 acres are proposed as common, passive -use open
space, which will include 5.7 miles of greenway walking trails and 3.4 miles of greenway biking trails.
The revised PCN is for dam rehabilitation and public thoroughfare roads (Nationwide Permit 3 and 14,
respectively).
The dam rehabilitation would permanently impact approximately 350 linear feet (lf) of a perennial
unnamed tributary to Abbotts Creek and 0.75 acres of several impoundments for the improvements to the
outlets, spillways, and intake of associated dams. The project would also permanently impact 365 if of
Abbotts Creek and its unnamed tributaries and 0.046 acres of wetlands for the installation of culverts for
the roads. Abbotts Creek and the unnamed tributaries to Abbotts Creek occur in Yadkin — Pee Dee River
basin. Abbotts Creek is classified as a Water Supply III stream by N.C. Division of Water Resources
(NCDWR).
We have no known records for federal or state rare, threatened, or endangered species at or within the
vicinity of the site. However, the lack of records from the site does not imply or confirm the absence of
federal or state -listed species or state Species of Greatest Conservation Need listed in the 2015 State
Wildlife Action Plan(http://www.ncwildlife.org//plan). An on-site survey is the only definitive means to
determine if the proposed project would impact rare, threatened, or endangered species.
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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USACE Action ID: SAW -2015-01697
We offer the following recommendations 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 and for treatment
of pollutants associated with urban stormwater.
2. Minimize or avoid further impacts to streams and wetlands. Placing fill in aquatic resources can
alter hydrology, result in significant negative impacts to downstream areas, and eliminate aquatic
and terrestrial wildlife habitat. Additional impervious surface results in an increase in stormwater
runoff that can exert significant impacts on 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.
3. 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 aquatic life passage. 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.
4. Consider removing all or some of the existing dams and restore the stream to its natural
hydrological function by using state-of-the-art natural channel design and restoration techniques.
The restoration of the stream may be used as mitigation to offset impacts from the proposed
development.
5. If the dams are not removed, we recommend the dams be designed to maintain an instream flow
regime appropriate for the stream. Furthermore, plant only native, submerged aquatic vegetation
in the impoundments.
6. Concrete is toxic to aquatic life and should not be allowed to come into contact with surface
waters until cured.
7. 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 can collect stormwater from driveways and
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 techniques can be more cost-effective, provide
space -saving advantages, reduce runoff, and protect water quality (Roseen et al. 2011).
Also, NCWRC's Green Growth Toolbox provides information on nature -friendly planning.
(http://www.ncwildlife.org/Conservin Programs/GreenGrowthToglbox.aspx)
8. 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%. Where feasible, trees and
shrubs should be planted around stormwater ponds, or implement LID techniques. This would
provide habitat benefits that offset those functions lost by development, partially restore aquatic
habitats, reduce exposure of the water surface to sunlight to minimize thermal pollution, and
provide essential summer and winter habitats.
9. Avoid the removal of large trees at the edges of construction corridors. Re -seed disturbed areas
with seed mixtures that are beneficial to wildlife. Consider planting native, wildflower seed

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Caleb's Creek Mixed -Use Development
USACE Action ID: SAW -2015-01697
mixes and plants that will create pollinator habitat. Avoid fescue -based mixtures because fescue
is invasive and provides little benefit to wildlife.
10. Design the trails to reduce impact on environmentally sensitive areas, such as wetlands and
streams. The trails should be located outside the stream buffer (see Recommendation #2) and
they should be surfaced with pervious materials. Avoid or minimize fragmentation of wildlife
habitat. Further information can be found at hitps://www.railstotrails.orgibuild-trails/trail-
building-toolbox/trail-building-and-design/developing-trails-in-sensitive-areas/.
11. 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.
The NCWRC encourages the applicant to consider additional measures to protect 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 details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
htt 2://www.ncwildlife.org/portals/0/Conserving/documents/2002_ GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002).
Thank you for the opportunity to comment on this permit application. Further information on native
plants, environmental friendly developments, and other free technical guidance from the NCWRC, please
contact me at [phone] or olivia.munzer(&ncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
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.
ec: Sue Homewood, NCDWR
Jean Gibby, U.S. Army Corps of Engineers
Byron Hamstead, U.S. Fish and Wildlife Service
Kory Reimann, BOMA North Carolina, LLC