NCWRC Comments -Clarke Creek Greenway Phase A - Cabarrus.pdf

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Via Email

08 March 2024

Mr. Taylor Kiker
Kimley Horn and Associates
200 South Tryon Street, Suite 200
Charlotte, NC 28202

Mr. George Berger
City of Concord
35 Cabarrus Ave. W
Concord, NC 28025

SUBJECT: Preconstruction Notification Permit Application for the Clarke Creek Greenway Phase A
Project in Concord, Cabarrus County, North Carolina. DEQ No. 20240276.

Dear Messrs. Kiker and Berger,

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 Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
Kimley Horn and Associates, on behalf of the City of Concord, has submitted Preconstruction
Notification (PCN) Permit Application for the Clarke Creek Greenway Phase A along Clarke Creek in
Cabarrus County, North Carolina. The 1.5-mile multi-use trail will extend from the future Jim Ramseur
Park and Cox Mill Elementary School north to the Allen Mills neighborhood.
The greenway will permanently impact 198 linear feet of Clarke Creek, and permanently impact 0.05 acre
and temporarily impact 0.28 acre of wetlands. Clarke Creek is in the Yadkin-Pee Dee River basin. As
indicated in NCWRC’s comments on the Jim Ramseur Park (31 May 2023), the Clarke Creek Heronry
Natural Heritage Natural Area occurs within the project site; natural areas are sites with special
biodiversity significance. We have a record of a colonial waterbird nesting site, which is considered
important animal assemblages in North Carolina, occurs within the vicinity of the site. Also, occurrences
of Piedmont/Mountain Semipermanent Impoundment of Shrub Subtype, Piedmont Marsh Subtype, and
Open Water Subtype Natural Communities, which are rare or high-quality natural communities, is
documented on or near the site. We recommend avoiding impacting these the natural communities.
08 March 2024 Page 2 NCWRC Comments
Clarke Creek Greenway PCN
DEQ No. 20240276
Pedestrian surveys conducted by Kimley Horn and Associates indicated federally threatened or
endangered species did not occur within the project boundary. The state endangered tricolored bat
(Perimyotis subflavus) is listed by the US Fish and Wildlife Service as proposed endangered. If tricolored
bat is listed prior to construction of the project, we recommend contacting the U.S. Fish and Wildlife
Service at [phone] to ensure that any issues related to this species are addressed.
We offer the following comments and recommendations to minimize impacts to aquatic and terrestrial
wildlife resources:
1. We recommend surveys for active colonial nesting birds (i.e., rookeries) in and adjacent to the
project. If active rookeries are located, any construction activities should not occur within 0.5-
mile of each rookery from February 15-July 31, and any trees with a nest should not be removed.
2. We recommend not clearing the entire site, but rather maintaining the maximum amount of native
vegetation.
3. Avoid removing large, mature hardwood trees, either alive, dying, or dead because tricolored bats
use these trees for roosting during the active period (April 1 to November 14). Overall, avoid tree
clearing activities during the active period.
4. Native plants should be used for seeding disturbed areas. Specifically, avoid using Bermudagrass,
redtop, tall fescue, and lespedeza, which are invasive and/or non-native. A list of alternatives to
non-native species has been attached. Grains, such as oats, wheat, or rye can also be used for
temporary cover and native seed mixes for permeant seeding. We recommend planting native,
wildflower seed mixes that will create pollinator habitat within the project boundary.
5. Stringent sediment and erosion control measures should be implemented and installed prior to
any land-disturbing activity.
6. Erosion control matting made of plastic mesh or twine should not be used within the project area
because it can injury or kill wildlife.
Thank you for the opportunity to provide input for this project. If I can provide further assistance, please
call [phone] or email [e-mail].

Sincerely,

Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program

ec: Ms. Amber Lipsky, U.S. Army Corps of Engineers
Stephanie Goss, NCDWR
Byron Hamstead, USFWS
David McHenry, NCWRC

RECOMMENDED NATIVE ALTERNATIVES FOR NON-NATIVE GRASSES IN
NORTH CAROLINA**
(Species are appropriate for all geographic regions unless otherwise indicated)

NON-NATIVE SPECIES NATIVE SPECIES
Big bluestem Andropogon gerardii
Little bluestem Schizachyrium scoparium
Indiangrass Sorghastrum nutans
Crownvetch Switchgrass Panicum virgatum
Centipede Beaked panicgrass Panicum anceps
Bermuda Purpletop Tridens flavus
Roundheaded bushclover Lespedeza capitata
Deer tongue Dicanthelium clandestinum
Sensitive partridge pea Chamaecrista nictitans
Partridge pea Chamaecrista fasciculata
Big bluestem Andropogon gerardii
Little bluestem Schizachyrium scoparium
Indiangrass Sorghastrum nutans
Switchgrass Panicum virgatum
Kentucky bluegrass Beaked panicgrass Panicum anceps
Tall fescue Purpletop Tridens flavus
Sudangrass Broomsedge Andropogon virginicus
Deer tongue Dicanthelium clandestinum
Canadian wildrye Elymus canadensis
Virginia wildrye Elymus virginicus
Sensitive partridge pea Chamaecrista nictitans
Partridge pea Chamaecrista fasciculata
Switchgrass Panicum virgatum
Splitbeard bluestem Andropogon ternarius
Sericea lespedeza Beggarlice Desmodium spp.
Kobe lespedeza Deer tongue Dicanthelium clandestinum
Sensitive partridge pea Chamaecrista nictitans
Partridge pea Chamaecrista fasciculata

NC Native Plant Recommendations
**A recommended revegetation/stabilization mix would ideally include a combination
of the species listed in this table. In addition, please note that additional consideration
may be needed in areas that are (highly) erodible and/or have sloped terrain. The
following species could be included in all regions for additional stabilization and
wildlife benefit:

Black-eyed susan: Rudbeckia hirta
Plains coreopsis: Coreopsis tinctoria
Lance-leaved coreopsis: Coreopsis lanceolata
Narrow-leaved sunflower: Helianthus angustifolius

Created October 2018