20080965 Ver 1_WRC Comments_20080626

PJUN 2 6 2008
DENR - WATER QUALITY
WETLANDS AND STORMWATER BRANCH
North Carolina Wildlife Resources Commission P
MEMORANDUM
TO: Steve Chapin, USACOE
Asheville Regulatory Field Office
FROM: Ron Linville Regional Coordinator Z
Habitat Conservation Program
DATE: June 24, 2008
SUBJECT: Crate & Barrel Distribution Center, Unnamed Tributaries Larkard Creek, NCDWQ No.
2008-0965, Lincoln County
The applicant proposes to build warehouse and retail outlet. Biologists with the North Carolina Wildlife
Resources Commission are familiar with habitat values in the area. These comments are provided in
accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10;
NCAC 25).
The project will build an 800,000 square foot warehouse with retail outlet and office spaces. Total
jurisdictional impacts to the 98 acre site will include 800 linear feet of intermittent stream, 50 linear feet
of perennial stream and 0.021 acre of wetland. No sports fisheries or listed species are indicated for the
area.
Based on our review of the submittal, we will not object to the project's impacts providing the following
recommendations are implemented where practicable and as specifically applicable to the project:
1. Stringent erosion control measures should be installed where soil is disturbed and maintained.
Stormwater management should be required that maintains pre development hydrograph
conditions to ensure the integrity of the restored/enhanced stream reaches as well as to protect
downstream aquatic habitats. Low Impact Development (LID) methodologies are strongly
urged and recommended for high density developments. Information on LID practices can be
found at www.lowimpactdcve1o ment.org, http, -w\-u,,cpa:gov_%o«'o«' tlp_s lid%licinatl iff and
httD://NA-ww.storn «atercenter. net/. We generally do not support conversion of jurisdictional
waters to stormwater or erosion control treatment facilities.
3. To reduce unnecessary imperviousness, we recommend local waivers be obtained to reduce
the size and number of non-essential (non LID) parking lot tree islands and to reduce the
number of parking spaces. Such a waiver should be provided by local governments if the
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NU 2 /bvv-I /21
Telephone: [phone] • Fax: [phone]
Crate & Barrel Warehouse -Page 2 -
June 24, 2008
waivers will provide improved forested buffers beneficial to aquatic species and water
quality.
4. Stream relocations are generally encouraged over piping streams, especially for perennial
headwaters. State-of-the-art natural channel designs and techniques should be used for any
stream restoration/enhancement activities.
5. Generally for stream crossings, spanning bridges are recommended for all floodplains and
associated wetlands to eliminate the need to fill and culvert active streams and floodplains.
Floodplain capacities and floodplain functions should be maintained with bridges and
culverts. If culverts must be used, culverts should be designed and constructed to ensure
passage of aquatic organisms. Culverts should be as short as possible and culverts should not
be used for non essential or non linear crossing purposes. Culverts 48" diameter or larger
should be buried at least a foot (12") below the streambed. Culverts less than 48" diameter
should be buried to a depth equal to or greater than twenty (20) percent of their diameter.
Depth of burial must be based on the stream's natural thalweg depth. Where mussel host fish
are present, passage is critical to promoting habitat integrity instead of allowing habitat
fragmentation. Culverts should be aligned and situated so that no channel realignment or
widening is required unless such modification will improve natural conditions. Widening of
the stream channel at the inlet or outlet of the culvert structure causes a decrease in water
depth and velocity causing sedimentation impacts and reduction of aquatic passage. Flat
concrete aprons between wing-walls must not be used. Riprap must not be placed in the
streambed unless absolutely necessary and if used in channel, it must provide natural channel
dimensions. If multiple barrels are needed, base flow barrels should be installed as indicated
above while additional barrels should be placed with floors located at the active floodplain or
bank full elevation. These elevated barrels should be connected to the active floodplain or
bank full benches to ensure natural stream dimensions for the base flow channel with
sufficient water depth during low flows and drought conditions to accommodate normally
anticipated aquatic movement. If culverts are long and/or sufficient slopes exist, alternating
baffles should be provided in the base flow barrel in a manner to conform to channel bends
upstream and downstream, to mimic natural meanders, to prevent upstream scour and
downstream deposition, to move and contain typical bed load materials, and to provide
resting areas for aquatic species. When multiple barrels are used, at least one barrel should
be designed and constructed with a floor material easily used for terrestrial wildlife passage.
6. Remaining jurisdictional waters and wetlands should be buffered, either through protection or
provision of undisturbed forested buffer zones. Buffers should be permanently preserved as
common contiguous forest areas instead of being subdivided. For streams that do not
support federally listed threatened or endangered aquatic species, we recommend 50'
intermittent and 100' perennial stream buffers. Irregardless, maximum available buffers
should be provided. These buffers should remain undisturbed to the maximum extent
practicable. Although not recommended, a walking trail may be placed in the buffer zone
providing it is kept away from streams to the maximum extent practicable, it is pervious, and
its width does not exceed minimum width requirements specified in the Americans with
Disabilities Act (ADA).
7. If any concrete will be used, work must be accomplished so that wet concrete does not
contact stream water.
Crate & Barrel Warehouse -Page 3 -
June 24, 2008
8. Whenever possible, heavy equipment should be operated from the bank rather than in the
stream channel in order to minimize sedimentation and reduce the likelihood of introducing
other pollutants into the stream.
9. Temporary or permanent native herbaceous vegetation should be established on all bare soil
within five (5) days of ground disturbing activities in the buffer to provide long-term erosion
control. Only autochthonous plants should be used for stream restoration and buffer areas.
Natural fiber matting is recommended over plastic matting that can impinge and entrap small
animals. Onsite vegetation and materials may be used for stream bank stabilization when
practicable.
Permanently protecting forested stream buffers is essential to the maintenance of aquatic habitats.
According to US Army Corps, the establishment and maintenance of riparian areas can be required by the
district engineer as compensatory mitigation, to help ensure that the NWP activity results in minimal
individual and cumulative adverse effects on the aquatic environment. Compensatory mitigation projects
can include areas that are not waters of the United States, as long as the mitigation is directly related to
the impacts of the proposed work on such waters and appropriate to the scope and degree of those
impacts. Riparian areas are integral components of streams and other open waters, and are essential for
their ecological integrity and functioning. The establishment and maintenance of riparian areas as
compensatory mitigation for activities authorized by NWPs and other types of permits also helps advance
the objective of the Clean Water Act, which is to "restore and maintain the chemical, physical, and
biological integrity of the Nation's waters."
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: Allan Johnson, DWQ-MRO