20080928 Ver 1_WRC Comments_20080721

North Carolina Wildlife Resources Commission 9
MEMORANDUM
TO: Cyndi Karoly
NC DENRJDWQ
and
Stephen Rynas
Federal Consistency Coordinator
NC DENR/DCM
FROM: Molly Ellwood
Southeastern Permit Coordinator
Habitat Conservation Program
DATE: July 21, 2008
RE: K2 Range Modernization, MCB Camp Lejeune, Onslow County; DWQ#08-0928/
DCM#20080077
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
application for impacts to wildlife and fishery resources. 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 et. seq.),
and Sections 401 and 404 of the Clean Water Act (as amended).
The Unites States Marine Corps (USMC) proposes to modernize the K2 ranges by mechanically clearing,
cutting, and filling 12.32 acres of §404 wetlands, and 141.5 if of intermittent stream. Temporary impacts
to approximately 39.74 acres of §404 wetlands is proposed for the removal of unexploded ordinance.
Mitigation for proposed impacts will be through the use of the Greater Sandy Run Area (GSRA) Wetland
Mitigation Bank for the 12.32 acres of permanent impacts and no mitigation is proposed for stream
impacts, as they are stated as being to degraded, intermittent streams.
The NCWRC is pleased to learn that this project will reduce the amount of public trust waters that
currently fall within the stated SDZ. Information provided indicates that the proposed wetland fill will not
have a significant adverse impact upon the wildlife and fisheries resources. Though there is not significant
adverse impact from the proposed project, the NCWRC continues to not support the filling of wetlands to
generate high ground for development. It appears from the provided narrative that the alternative with the
least impacts while still meeting the USMC's objectives has been selected, and we hope that future phases
of this project will continue to avoid and minimize wetland impacts to the greatest extent possible.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
K2 Range Realignment, Onslow County
July 21, 2008
While proposed mitigation through the GSRA Wetland Mitigation Bank is acceptable for the 12.32 acres
of wetland impacts, we strongly encourage the USMC to explore mitigation for the 141.5 if of impacts to
the intermittent stream as well. Along with mitigation for all permanent impacts, we also request that the
USMC provide NCWRC information on the amount of unused wetland credits within the GSRA Wetland
Mitigation Bank. Understanding the amount of available credits assists with the NCWRC's ability to
evaluate the mitigation proposed for this and future projects.
Thank you for the opportunity to review and comment on this application. If you have any questions or
require additional information regarding these comments, please call me at [phone].
ec: Joanne Steenhuis, NCDWQ
Brad Shaver, USACE