20072160 Ver 1_WRC Comments_20080318

~ North Carolina Wildlife Resources Commission ~
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT
Cyndi Karoly, 401 Certification Unit
NC Division of Water Quality
Ron Linville Re Tonal Coordinator 1~
g
Habitat Conservation Program
March 18, 2008
Smith Reynolds Airport Runway Safety Area Extension Project, Brushy Creek
and Unnamed Tributary thereof, DWQ No. 20072160, Forsyth County
~.~
MAR 2 ~ 2008
DENR • WATER nuAUll'
WETLANDS AND STORLAWATER BRANCH
The applicant proposes extend an existing airport runway located in Winston-Salem. Biologists
with the North Carolina Wildlife Resources Commission are familiar with habitat values in the
area. Biologists with the North Carolina Wildlife Resources Commission (NCWRC) are familiar
with habitat values in the area. The NCWRC is authorized to comment and make
recommendations which relate to the impacts of this project on fish and wildlife pursuant to
Clean Water Act of 1977, North Carolina Environmental Policy Act, US National Environmental
Policy Act, Endangered Species Act (16 U. S. C. 1531-1543; 87 Stat 884), the Fish and Wildlife
Coordination Act {48 Stat. 401, as amended; 16 U.S.C. 661-667d) and/or Federal License of
Water Resource Project Act (Federal Power Act-16 U.S.C. 791 a et seq.) as applicable.
The applicant is amending their previous plan to culvert streams for the runway extension. The
new plan is to relocate Streams 1 & 2. Stream 1 will be relocated east of its original location
while Stream 2 will be relocated to the south. The primary reason for the change to relocation is
indicated to be costs. Unavoidable impacts will still occur to 1,547 linear feet of jurisdictional
stream and 0.061 acres of wetland.
We agree that stream relocation is better from both environmental and cost perspectives.
Previously, visual habitat evaluations found that threatened and endangered species are not
likely; however, habitat for the Brook floater, Alasmidonta varicosa (NCE/FSC} may be present.
Although we concur that relocation is the best option, our recommendations of January 4, 2008
should still be evaluated for this project by the US Army Corps of Engineers and the NC
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Kaleigh, Nc: l /~yy-i /L i
Telephone: [phone] Fax: [phone]

Smith Reynolds Runway IP MOD -Page 2 - March 18, 2008
Division of Water Quality. They should be implemented where appropriate. For this current
modification, we are providing the following information and recommendations:
Since suitable habitat for listed aquatic species is indicated, Qresence or absence determinations
by professional biologists (certified by American Fishery Society, The Wildlife Society or their
equal) should be accomplished prior to issuance of any 404 Permits or 401 Certifications. If
listed or rare species are found above, within, or below the work area, licensed professional
biologists should relocate individuals before work begins and provide subsequent relocations
after inclement weather events occur that may move relocated specimens. Generally, it is better
to move mussels upstream instead of downstream unless poor habitat values preclude upstream
use of the species.
Stream relocations should include provision of ample, storm and flood water accessible
floodplains. Stringent erosion control measures should be used for the relocation project.
Disturbed streams should be planted with autochthonous (native) plants like silky dogwood, red
maple, silky willow, tag alder, black willow, river birch, or similar native woody shrubs or trees.
If plant height is a safety concern or issue, judicious select cutting and pruning of large trees are
acceptable practices providing a strong shrub/herb community is maintained.
Stormwater management is an essential component of protecting and/or restoring urban aquatic
habitats degraded by urban channel modifications, exasperated stormwater hydrographs, and
pollutants. Hydro_graph restoration and maintenance plus state-of--the-art natural channel design
and construction should be provided onsite to improve aquatic habitats and protect npartan
buffers. Stormwater management should be provided on the airport for emergency spill
containment as well as to ameliorate exasperated runoff Low Impact Development (LID)
techniques are recommended for this publicly funded project. LID practices can be evaluated
and reviewed at: w~~_~y ic~win~actdcti~cl~n~ent.or~„ http `_wuu.cpa~=~~~~;~~~c~~y~`r~s_lid;`lidrlatl._pdf~
and http_w~}_~~~.5tc~rmwatcrcrnt~r,n~.U~.
We do not concur with using Ecosystem Enhancement Program (EEP) funds for mitigation out
side this community. There are many streams in Forsyth County that are diminished and
impaired. If possible, regulatory agencies should stipulate that these EEP funds will be used for
projects within Winston-Salem and/or Forsyth County as municipalities within the County
continue to significantly develop, annex and sprawl. Without adequate water quality safeguards,
aquatic and terrestrial habitat destruction and diminishment will continue unabated.
Thank you for the opportunity to review and comment on this project during the early planning
stages. If you have any questions regarding these comments, please contact me at 336-769-9453.
E-copy: Sue Homewood, DWQ-WSRO
John Thomas, USACOE-RRO
Monte Matthews, USACOE-RRO
Marla Chambers, NCWRC
Becky Fox, USEPA