20160285 Ver 1_WRC Comments_20160422

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: James Lastinger
Raleigh Regulatory Field Office
US Army Corps of Engineers
FROM: Gabriela Garrison
Eastern Piedmont Coordinator
Habitat Conservation
DATE: April 22, 2016
SUBJECT: Public Notice for K. Hovnanian Homes of North Carolina, Inc. for the Construction of
the Oak Pointe Residential Subdivision, Wake County, North Carolina. Corps Action
ID 9: SAW -2016-00095
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), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e) and North
Carolina General Statutes (G.S. 113-131 et seq.).
The applicant proposes to permanently impact 0.97 acres of wetlands and 377 linear feet of stream for the
construction of the Oak Pointe residential subdivision, a 94 -lot development with associated
infrastructure. The proposed project would be approximately 58 acres in size and located along the south
side of Old Jenks Road, before its intersection with Castleberg Road in Wake County. Mitigation for the
project includes the purchase of riparian wetland and stream mitigation credits through the NC Division
of Mitigation Services.
The site drains to Beaver Creek in the Cape Fear River Basin. Beaver Creek drains into the B. Everett
Jordan Reservoir, which supports a diverse fishery including sunfish (Lepomis spp.), crappie (Pomoxis
spp.), catfish (ktalurus spp.), largemouth bass (Micropterus salmoides), white bass (Morone chrysops)
and striped bass (Morone saxatilis). Listed terrestrial species in the area include the state -threatened bald
eagle (Haliaeetus leucocephalus). The NC Natural Heritage Program's Natural Area, Beaver Creek
Floodplain, is located downstream of the project site.
The NCWRC hesitates to concur with the filling of wetlands due to wildlife habitat value and the
beneficial functions they provide for flood control and water quality protection. 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. In addition, pollutants (e.g.,
sediment, heavy metals, pesticides and fertilizers) washed from roads and developed landscapes can
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
April 22, 2016
Oak Pointe Residential Subdivision
Corps Action ID No.: SAW -2016-00095
adversely affect and extirpate species downstream. If the permit is approved, the NCWRC offers the
following recommendations to minimize impacts to aquatic and terrestrial wildlife resources:
I. Stormwater control structures should be designed to achieve no net change in the hydrology of the
watershed. In addition, trees and shrubs should be planted around the stormwater detention pond(s)
to provide habitat benefits that offset those functions lost by development, to include partially
restoring aquatic habitats, reducing exposure of the water surface to sunlight thereby minimizing
thermal pollution and providing essential summer and winter habitats.
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 aquatic life passage. Fords may be appropriate and preferred for intermittent stream crossings
or where crossings will be used only once or twice a year. For fords, crossings in riffles are preferred
with the banks lowered upstream and downstream of the crossing. Stabilize the stream bottom with
geo-textile fabric and rock; concrete should not be used for bed stabilization.
3. Avoid the removal of large trees at the edges of the construction corridor. 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. Avoid fescue -based mixtures as fescue is invasive and provides little
benefit to wildlife. A list of wildlife -friendly plants is available upon request. 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.
4. 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. Excessive silt and sediment loads can have detrimental
effects on aquatic resources including destruction of spawning habitat, suffocation of eggs and
clogging of gills.
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:
htlp://www.ncwildlife.org_/portals/0/Conserving/documents/2002_ GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002). In addition, the Green Growth Toolbox provides information
on nature -friendly planning: hqp://www.ncwildlife.org/Conservin /g Programs/GreenGrowthToolbox.aspx.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or gabriela.garrisonkncwildlife.org.
ec: Karen Higgins, NCDWR