20161153 Ver 1_WRC Comments_20161209

EJ North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Karen Higgins
401 Wetlands Unit
NC Division of Water Resources
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 9 December 2016
SUBJECT: Mr. Steven Hankins, Clemmons TC, LLC
Individual 404 Permit Application
Proposed Clemmons Town Center
Clemmons, Forsyth County
DEQ -WR Project No. 20161153
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject
document and we are familiar with the habitat values of the area. Our comments are provided in
accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661-667e) and the North Carolina General Statutes (G.S. 113-131 et seq.).
Pilot Environmental, Inc. requested an Individual 404 Permit on behalf of the applicant, Mr.
Steven Hankins of Clemmons TC, LLC. The applicant proposes to construct a lifestyle shopping
center on an approximately 16.3 -acre tract located north of Interstate 40 and west of Lewisville-
Clemmons Road in Clemmons, Forsyth County. The proposed project would include four multi-
story buildings, associated parking areas, maintained landscaped areas, associated stormwater
retention devices, and the extension of Jessie Lane. The proposed project would result in
permanent impacts of 0.105 acres of wetlands, of which 0.0167 acres would be the conversion of
forested wetlands to emergent wetlands, and 636.7 linear feet of permanent impacts to streams.
Mitigation for the project includes purchase of stream and wetland mitigation credits through the
NC Division of Mitigation Services. The applicant proposes to also purchase 65 linear feet of
stream and 2,366 square feet of wetland mitigation credits for impacts associated with the
development of the Clemmons Town Center Apartments south of the project site. The proposed
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Clemmons Town Center Page 2 December 9, 2016
Forsyth County
mitigation would total 677.1 linear feet of stream mitigation credits and 0.2477 acres of wetland
mitigation credits.
The streams on the project site flow into a manmade lake, which is one of several created along
an unnamed tributary to Johnson Creek in the Yadkin -Pee Dee River basin; we noted the IP
application incorrectly states the receiving water is West Fork Deep River rather than Johnson
Creek. Johnson Creek is classified as a Water Supply IV (WS -IV) stream by N.C. Division of
Water Resources. We have no records of any state rare or listed species on or adjacent to the site.
We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife
resources:
1. The culverts should be designed to allow passage of aquatic life. Culverts less than 48
inches in diameter should be buried to a depth equal to or greater than 20% of their size.
These measurements should be based on natural thalweg depths. Aquatic life passage
should be assured during low flow or drought conditions. The riprap dissipaters should
allow clear passage for aquatic life by not blocking the outlet or inlet of the culvert and
should be at least equivalent to the bank -full width of the stream. Measures to avoid or
minimize impacts to streams and wetlands should be implemented during construction.
2. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial
streams, and a 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.
3. 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%. Consider
underground parking or parking structures instead of a surface lot.
4. Use non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native species instead of ornamentals should reduce 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. 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. Additional alternatives include narrower roads, swales versus curbs/gutters, and
permeable surfaces such as turf stone, brick, and cobblestone.
5. 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.

Clemmons Town Center Page 3 December 9, 2016
Forsyth County
6. As this is a currently a partially -forested parcel, we strongly suggest that as much natural
vegetation be left undisturbed as possible in order to conserve habitat for wildlife.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] or olivia.munzer&ncwildlife.org if there are any questions about these
comments.
ec: John Thomas, US Army Corps of Engineers