20081163 Ver 1_WRC Comments_20080814

M
0 North Carolina Wildlife Resources Commission 0
MEMORANDUM
TO: Cyndi Karoly, 401 Oversight and Express Permits Unit
Division of Water Quality
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 14 August 2008
SUBJECT: Pre-construction Notification Application for Rakestraw Investment Company, Inc.,
Mayo Forest, Rockingham County, North Carolina. DWQ ID: 08-1163.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our 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. 661-667d),
North Carolina General Statutes (G.S. 113-131 et seq.), and North Carolina Administrative Code 15A
NCAC 101.0102,
The applicant proposes to impact 144 linear feet of perennial stream channel and 131 linear feet
of intermittent stream channel for construction of road, driveway and septic line crossings in a proposed
residential subdivision. Lot sizes will be 1 acre or greater. Based on information provided in the
application, it appears a 50-foot riparian buffer will be maintained along stream channels.
The proposed project will impact an unnamed tributary Mayo Creek in the Roanoke River basin.
There are records for the federal and state endangered James spinymussel (Pleurobema collina), the
federal endangered and state significantly rare Roanoke logperch (Percina rex), the federal species of
concern and state endangered green floater (Lasmigona subvirdis), and the state special concern notched
rainbow (Villosa constricta) in Mayo River.
We are concerned about the impacts of development on James spinymussel and Roanoke
logperch and their habitat in Mayo River downstream of the project. Changes in land use from a
primarily forested area to an urban landscape 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 urban landscapes can
adversely affect and extirpate species downstream of developed areas.
Should the permit be issued, we recommend the following conditions be incorporated to further
minimize impacts to aquatic and terrestrial wildlife resources.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
TelPnhnnP! (919)707-0??0 • Fax- (919)7(17-n0?R
Page 2
14 August 2008
Mayo Forest
DWQ ID: 08-1163
Maintain a 200-foot undisturbed, native, forested buffer along perennial streams, and a 100-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. In addition, wide riparian buffers are helpful
in maintaining stability of stream banks and for treatment of pollutants associated with stormwater
runoff. Whereas, a grassed buffer, particularly fescue, is a vegetated buffer but will not provide the
necessary and highly valuable functions as discussed for forested buffers.
2. All remaining wetlands and streams on the site should be protected from additional impacts by
placing them in a permanent conservation easement to prohibit filling, draining, flooding, and
excavation.
3. 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 passage of aquatic organisms.
4. New developments exceeding 6% imperviousness should include stormwater controls designed to
replicate and maintain the hydrographic condition at the site prior to the change in landscape.
5. Locate sewers and other utilities as far away from streams as functionally possible and minimize
stream crossings. It is preferable that sewers be located outside the riparian buffers as detailed in #1.
6. 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. 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.
7. Sediment and erosion controls measures should be installed prior to any land clearing or construction.
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.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
cc: Andrew Williams, USACE
cc: Dale Suiter, USFWS
Rob Nichols, WRC