20050578 Ver 1_WRC Comments_20050629

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®l~torth Carolina ~r~Iildlife Resources Commission
Richard B. Hamilton, Executive Director
MEMORANDUM
TO: Ms. Andrea Wade, Raleigh Regulatory Field Office p ~~~~~
U.S. Army Corps of E~ ecrs ~'
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FROM: hari L. Bryant, Pickimont Region Coordinator JUN ~ ~ 2005
Habitat Conservation Program
DEER - ~vATt~T3 ~i.',',I.11 y
DATE: 27 June 2005 t~ETCq~,'os~'DS~e"``~;Y,~7ER~HAh~CH
SUBJECT: Public Notice far Pennybyrn at Maryficld for Construction of Pennybyrn at Maryfield
Retirement Community, Guilford County, North Carolina. Action ID No. 200120668
Biologists with the North Carolina Wildlife Resources Commission (NCtiVRC) have reviewed the
subject document and we arc familiar ~+ith the habitat values of the area. Our comments arc 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. 661-667d), and Noah Carolina General Statutes (G.S. 113-131
et seq.).
The applicant proposes to relocate and baclcfill S06 linear feet of stream channel. The stream
channel will be diverted into a pipe that discharges to a stormwater system. In addition, the project will
impact 0.09 acre of forested wetland outside the property boundary. The purpose of the project is to
expand an existing retirement community that will include construction of independent living apartments,
community center and associated parking lots and roadways. Thrcc unnamed tributaries flow through the
northern boundary of the project site into wetlands adjacent to dre City of High Point municipal reservoir.
The mitigation plan includes payment into the North Carolina Ecosystem Enhancement Program to
restore 7S9 linear feet of stream ehanrel and 0.09 acre of riparian wetlands.
The City of High Point municipal reservoir is an impoundment of Deep River in the Cape Fear
River basin. There arc records for the state special concern Greensboro burrowing crayfish (Cambarus
catagius) near the project sites Additionally, the reservoir supports a diverse fishery including largemouth
bass (Micropterus salmoides), crappie (Pomoxis spp.), sunfish (Lepomis spp.), catfish (Ictalurus spp.) and
striped bass {Morone saxatilis).
We are concerned about downstream water quality and aquatic habitat. Stream piping and
placing fill in aquatic resources can result in significant negative impacts to downstream areas and
eliminate fish and wildlife habitat. Stream piping reduces the infiltration of stormwater and associated
pollutants, as well as the dissipation of stream energy. Piping a stream and placing it underground
obviously removes both aquatic and terrestrial habitat. Likewise we hesitate to concur with the filling of
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center • Raleigh, NC 27699-1721
TeIephon.: [phone] Fax: [phone]

Page 2
27 Junc 2005
Pennybyrn at Dlaryfield
Action ID No. 200120663
wetlands due to their wildlife habitat value and the well-known beneficial functions that they provide for
flood control and water quality protection. In addition, multiple studies have shown that stream
degradation occurs at 10% impervious (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000;
Mallin et al. 2000; May~and Horner 2000; Stevrart et al. 2000; Paul and Mcycr 2001). Changes in land
use from a primarily forested area to an urban landscape may exacerbate channel degradation and
sediment impacts to stream ecosystems due to increased stormwater runoff and elevated flooding.
We feel that compensatory mitigation should include payment into NCEEP for 2:1 wetland
restoration unless other mitigation measures (e.g., preservation of remaining wetlands within the
development) are proposed to be equivalent to 2:1. Additionally, mitigation for stream impacts should be
consistent with the compensatory mitigation ratios outlined in The Stream Mitigation Guidelines (April
2003).
We will not object to the project provided the following conditions arc incorporated into the
permit to reduce impacts to fish and wildlife resources.
1. To minimize additional stream impacts, while retaining some measure of wildlife habitat, we
recommend that a 100-foot undisturbed, native, forested buffer along perecucial streams, and a SO-
foot buffer along intermittent streams and wetlands. Maintaining undisturbed, forested buffers
along these areas will minimize impacts to fish and wildlife resources, water quality, and aquatic
habitat both within and downstream of the project area. In addition, wide riparian buffers arc
helpful in maintaining stability of stream banks and for treatment of pollutants associated with
stormwater runoff. ~'ti/hcrcas, a grassed buffer, particularly fescue, is a vegetated buffer but will
not provide the necessary and highly valuable functions as discussed for forested buffers.
2. We recommend that all remaining wetlands and streams on the site should be protected from
additional impacts by placing them in a permanent conservation casement to prohibit filling,
draining, flooding, and excavation.
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 passage of aquatic organisms. Generally, this means that the culvert or pipe
invert is buried at least one foot below the natural streambed. If multiple cells are required, the
second and/or third cells should be placed so that their bottoms are at stream bankfull stage. This
will allow sufficient water depth in tlce culvert or pipe during normal flows to accommodate
movements of aquatic organisms. If culverts are long and sufficient slope exists, baffle systems
are recommended to trap gravel and provide resting areas for fish and other aquatic organisms. If
multiple pipes or cells are used, at [cast ono pipe or box should be designed to remain dry during
normal flows to allow far wildlife passage. In addition, culverts or pipes should be situated so
that no channel realignment or widening is required. 1`Jidcning of the stream channel at the inlet
or outlet of structures usually causes a decrease in water velocity causing sediment deposition that
will require future maintenance. Finally, riprap should not be placed on d~c streambed.
4. To adequately protect streams, it is suggested that impervious surface is limited to less than 10%.
Suggested examples to accomplish the <10% impervious goal are using conventional designs at n
level of <10% imperviousnevs or using conservation clusters with higher densities, with dedicated
open space and other stormwater control measures to mimic the hydrograph consistent with an
impervious coverage of less than 10%.
S. Locate sewers and other utilities as far away from creeks as functionally possible and minimize
stream crossings. It is preferable that sewers be located outside the riparian buffers.

Pago 3
27 June 2005
Pennybyrn at Maryfield
Action ID No. 200120668
6. We recommend that landscaping consist of non-invasive native species and LID technology.
Using native species instead of ornamentals should provide benefits by reducing the need for
fertilizers, herbicides, and pesticides. Additionally, native species should require Iess water.
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.
7. Specialized efforts and techniques arc implemented to reduce sediment runoff from construction
activities. 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.
8. A mitigation plan should be submitted and approved before impacts occur.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
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.
2000. Hydraulic geometry relationships for urban streams tfuoughout the piedmont of North
Carolina. Pages 299-304 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.
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. 2001. Streams in the urban landscape. Annual Review of Ecology and
Systematics 32:333-365.
Schueler, T. 1994. The importance of imperviousness. Watershed Protection Techniques. 1(3):100-
111.
Stewart, J. S., D. M. Downes, L. Wan„ J. A. Wierl, and R. Bannerman. 2000. Influences of riparian
corridors on aquatic biota in agricultural watersheds. Pages 209-214 i~: 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.
cc: Cyndi Karoly, DWQ