20081199 Ver 1_WRC Comments_20081014

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9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Steve Chapin, USACOE
Asheville Regulatory Field Office
FROM: Ron Linville, Regional Coordinator ZWW
Habitat Conservation Program
DATE: October 14, 2008
SUBJECT: Girl Scouts of America (GSA) Environmental Academy at Oak Springs, Unnamed
Tributary South Yadkin, Iredell County
The applicant proposes to create a 23.42 acre lake. Biologists with the North Carolina Wildlife Resources
Commission (NCWRC) 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 700 acre GSA facility is proposed to impact approximately 3,993.02 linear feet of perennial stream
with stream damming and inundation. The proposed lake is indicated to be a critical component for water
based outdoor recreation and environmental education curriculums associated with the proposed regional
Girl Scout Environmental Academy. The impoundment will provide irrigation for gardening and
orchards, habitat for migratory waterfowl, plus recreational activities including swimming, kayaking,
canoeing and sail boating. These activities are elements required for the Girl Scouts Safety-Wise
program. Alternatives to this impoundment are indicated as unacceptable due to safety as well as
operational concerns and needs. A site visit was conducted by this office on August 28, 2008. The site is
near a NC Significant Natural Heritage Area (Allison Woods, SNHA # 32) and the entire site is an
original NCWRC Cooperative Upland habitat Restoration and Enhancement (CURE) property.
During our site visit, our investigation found that the stream to be inundated is substantially incised and
subsequently significantly impaired. We discussed stream mitigation opportunities at an old pond site
that could enhance stream environs as well as provide ancillary wetland (salamander/reptile) habitats.
This site is south of the proposed equestrian center. Permanent protection and management of the large
wetland south of the encampment area was also discussed. Additionally, we discussed NCWRC
recreational and wildlife curriculum opportunities, including Becoming an Outdoor Woman (BOW),
Project WILD, Carolina Anglers Teach Children How (CATCH), Hunter & Boating Education, and
Outdoor Skills programs. We discussed opportunities to continue managing portions of the area for
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
GSA Env. Academy @ Oak Springs -Page 2 - October 14, 2008
upland species under the NCWRC CURE program and the establishment of warm season grasses
(piedmont prairie plants) instead of fescue lawns. Wildlife management benefits of the NCWRC
Registered Lands program were discussed. Additionally, the Wildlife Conservation Land (House Bill
1889) and Stewardship Plans (NC Forestry) that could enhance biodiversity were mentioned. We also
mentioned educational and recreational opportunities that could be provided in conjunction with the
National Shooting Sports Foundation and National Rifle Association since a portion of the site had been
an established shooting range.
Based on our site visit and review of the Section 404 submittal, we will not object to the impoundment.
The following non-prioritized recommendations are provided to the US Army Corps, the NC Division of
Water Quality, and the GSA for educational, regulatory, and natural resource considerations:
Mitigation ratios should consider current poor aquatic habitat values of this stream and
benefits associated with the impoundment and other basin improvements to the watershed
and to GSA environmental education curriculums.
2. The impoundment discharge should be monitored to ensure that discharge waters will not
exceed the temperature standard for piedmont streams.
3. A minimum flow release as determined by the NC Division of Water Resources (DWR)
should be provided by design and construction so that aquatic life impacts below the dam will
be minimized. If DWR does not set a minimum flow regime, the minimum 7Q10 should be
maintained or inflow should equal outflow at all times in the stream below the dam to protect
downstream habitats.
4. Unless otherwise stipulated by regulatory agencies, discharge flows and temperatures should
be routinely monitored and compared to inflow waters to ensure compliance.
5. If practicable, the discharge should be aerated to enhance dissolved oxygen levels.
6. Stream buffers, and littoral shelves (around the lake) should be provided as shrubby or
forested areas to the extent practicable and permanently protected with conservation
easements or deed restrictions. Maximum available forested buffers should be provided and
protected along remaining streams. Existing wetland habitats should be preserved and/or
enhanced as they provide essential habitats for amphibians, reptiles, small mammals and
songbirds. Again, these habitats should be well buffered. For watersheds that do not support
federally listed threatened or endangered species, we recommend minimum 50' intermittent
and 100' perennial undisturbed forested buffers. Maximum available forested buffers should
be provided.
Conversion of maintained grassed areas to warm-season prairie fields can greatly improve
benefits to wildlife, especially smaller game species like rabbit and quail (see attached US
Fish & Wildlife Service prairie plant document). These areas can improve songbird, small
game and reptile habitats. Managed mowing schedules and timber harvests can provide
early successional habitats that can significantly enhance species diversity. Properly
managed as green spaces, fields and forested tracts can benefit water quality as well as
promote aquatic and terrestrial environs on the environmental camp facility.
8. Conservation easements of 200 to 300 feet next to waters are indicated. Possible stream
protections and buffer easements may be provided on adjoining properties. To the maximum
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extent possible, stream and wetland mitigation, including protective covenants (easements)
and stream restorations/enhancements should be provided onsite and within the same sub
basin to enhance and restore aquatic and terrestrial wildlife habitats. An onsite and local area
mitigation strategy is preferred over payment to the NC Ecosystem Enhancement Program.
Such a strategy should prolong the life of the impoundment and provide improved aquatic
environs.
9. Although not recommended, a walking trail may be placed in stream and wetland buffer
zones providing it is kept away from waters 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). Crossings should be accomplished by bridging instead of culverting,
especially on perennial waters.
10. All work should be accomplished so that wet concrete does not contact jurisdictional waters.
11. Heavy equipment should be operated from high ground instead of in channel to minimize
buffer zone impacts and sedimentation as well as reduce the likelihood of introducing
petroleum pollutants to waters.
12. Stringent erosion control measures should be installed and maintained where soil is disturbed.
13. As mentioned previously, littoral shelves and native vegetation should be provided along the
impoundment shoreline for shoreline stability, safety, shading and habitat. Avoiding and
minimizing manicured lawn and shoreline connectivity through the provision of woody
buffers may help deter use of grassed areas by Canada geese although management of geese
and other waterfowl for aesthetic, health and safety reasons may still be necessary and
prudent.
14. Non-native plants or invasive plants should not be used for the project. Invasive and non-
native plants should be controlled and eliminated where possible although typical agricultural
crops are acceptable for CURE and typical farming practices.
15. Only native piedmont species should be stocked in the impoundment. As of July 1, 2005,
anyone stocking inland fishing waters with fish, mollusks or crustaceans must obtain a
stocking permit issued by the NCWRC pursuant to 15A NCAC I OC .0209.
16. If desired for educational and management purposes or if required by local, state or federal
agencies, stormwater management strategies that maintain pre development hydrograph
conditions are recommended. This office routinely recommends Low Impact Development
(LID). Information on LID practices can be found at www.lowimpactdevelopment.org,
http://www.stormwatercenter.net/ and http://www.epa.gov/owow/nps/lips/lid/lidnatl.pdf. These
measures should not be installed in jurisdictional waters.
17. The use of motorized equipment and boat fuel ing/maintenance facilities as well as fertilizers
and other chemicals near the lake and around the shoreline and buffer zones should be strictly
controlled so as not to cause direct or ancillary pollutant issues. Petroleum spill containment
equipment/materials should be readily available at the GSA facilities.
18. Project proponents should contact the NC Division of Land Quality to determine if a dam
safety review and permit is appropriate or required.
GSA Env. Academy @ Oak Springs -Page 4 - October 14, 2008
19. The existing southeastern pond is providing wildlife diversity and aquatic species habitats.
Restoration of this pond to a stream environ with associated seasonal wetland pockets would
provide similar benefits and provide onsite mitigation. Conversion to a stream/wetland
complex should be done in a manner to reduce erosion and sedimentation below the existing
pond site. Any stream and wetland restoration or mitigation should use state-of-the-art
natural design (bioengineering) and construction techniques. This stream and wetland
restoration option should be evaluated further.
20. The eastern wetland should be preserved and actively maintained to preserve and enhance its
wetland characteristics: This may require removal of some high water usage trees like red
maple plus actively monitoring and managing site hydrology.
Although not directly associated with this Clean Water Act permit; but due to previous and potential
upland habitat enhancements on the site, we recommend project proponents contact Mr. Chris Kreh,
District-7 Wildlife biologist at 336-386-0892 to discuss opportunities within our CURE program. In
addition, project proponents can contact Ms. Kelly Hughes, NCWRC Forest Stewardship Biologist at
828-651-8380 to discuss native plants and prairie habitats. Ms. Lori Williams, Non Game Biologist can
be contacted at 828-684-0358 to discuss coordination and implementation of wildlife monitoring
(including amphibian and possibly reptile) programs. These activities can provide information to help
educate students about native species as well as provide information for inclusion in our non game
databases. Educational and survey opportunities could include frog call identification, salamander cover
board surveys, dip-netting surveys, cover tin surveys (for reptiles), and surveys for various other wildlife
species.
We applaud efforts being made by the GSA for this Environmental Academy that will provide sound
environmental stewardship and environmental education as well as other outdoor recreation amenities.
We appreciate their cooperation and leadership in providing a wide array of opportunities while
enhancing and protecting local ecosystems.
Thank you for the opportunity to review and comment on this project during the early planning stages. If
regulatory agencies have any questions regarding these comments or if this office can assist the GSA with
project planning and implementation, please contact me at 336-769-9453.
Attachment: Recommendations of Piedmont Prairie Restoration and Creation
E-copy: Allan Johnson, DWQ-MRO
Chris Kreh, Lori Williams, Kelly Hughes, NCWRC
Laura Fogo, USFWS
Sally Daley, Damon Scott, GSA Hornets' Nest Council
GSA Env. Academy @ Oak Springs -Page 5 - October 14, 2008
Recommendations of Piedmont Prairie Restoration and Creation
Laura M. Fogo, Private Lands Biologist, US Fish and Wildlife Service
RESTORATION
If you discover a potential prairie remnant, it is recommended that you reestablish fire
into the ecosystem and thin the site depending on your goals for prairie, savannah, or woodland.
Thinning a site will allow sunlight to reach the forest floor to encourage herbaceous plants to
grow. Your native understory vegetation may already be there and it may not be necessary to
plant. See Piedmont Prairies and a Partnership, to reference associated community types to look
for.
CREATION/REESTABLISHMENT OF A NATIVE PRAIRIE
Seed Source: Try to obtain local genotypes of native plant material to reestablish a
prairie. I only recommend buying seed from outside NC if it's a creation project or the local
genotypes are not available or present. There is limited availability of NC grass seed from
nursery growers. There are commercial nurseries that provide local plants and seed. If you have
the time and want only local seed sources, it will take more effort. For large scale restoration,
some projects may want to go ahead and purchase seeds. It is agreed by the partnership to
collect local seed from remnant sites and roadside populations for trying to restore remnant
prairies. Planting associated prairie species provides habitat for migratory songbirds and other
early successional wildlife dependant species.
Native Warm Season Grasses (NWSG): Attached are commercial native seed sources
and planting guides to establish NWSG prepared by Bob Glennon, USFWS. He mentions
applying fertilizer the year after it is established. These grasses are fertilized to grow hay
(forage) for cows as far as a productivity production, however, it will encourage undesirable
weedy competition. It has been recommended only to lime according to your soil's needs.
These grasses are native and grow on poor sites anyway and are not used to having good
nutrients. I would re-evaluate after a year and establishment.
Remember that it may take at least two years to see good results on the NWSG. Bob has
done a great job on explaining methods: using a seed drill, calibrations, seeding depths, etc.
Follow his instructions. When planting, drilling is best, but if you cannot, broad cast and run a
cultapacker over it. You can plant the different ones at the same time (except gama) and place
them in the appropriate seed boxes in the no-till drill. You put the fluffy-chaffy ones, big blue,
little blue, and Indian grass in the chaffy seed box and plant 1/4" seed depth. The small box is
used for smooth grass seeds like switch grass and gama. He said to make a separate pass for the
gama grass at 1 " seed depth.
Planting times: For NWSG, it is recommended, to plant in the fall after Thanksgiving,
after the first killing frost (Oct. 31 Piedmont-Nov. Coast) until the last killing frost in the spring
(March 15 on the coast, April 1 for most of the state, April 15 in the west). As soon as you have
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the site prepared, you might want to plant winter annuals such as winter wheat, barley, and
ryegrass grain. Be cautious planting ryegrass, because it may re-seed and cause competition the
next spring. NWSG's require to be pre-chilled in moist conditions at least two weeks at 40
degrees F (stratification). So November planting is fine.
There are some exceptions for planting in the spring before May. The exception is if you have
not eradicated all the non-natives or fescue. If you plant in the spring, you run the risk of loosing
the new seedlings to drought. If you plant in the winter, it will give the grasses time to establish
a root system to be better prepared for potential dry times in spring or summer. It may be
possible to apply herbicide on fescue in the spring, then plant immediately.
Forbs associated with Piedmont Prairies: Attached is a list of forbs for propagation
compiled by members of the partnership derived from the "Vascular Flora of Piedmont Prairies:
Evidence from Several Prairie Remnants" by Davis, et al. 2002. This document establishes a
good baseline of Piedmont prairie vegetation for reestablishment and identification. Please
notify me or Moni Bates, NC Plant Conservation Program, if you are interested in seed
collection and propagation.
Recommended Prairie Mixture: Below is a mixture recommended based on the list
mentioned above for planting five warm season grasses: big blue stem, little blue stem, Indian
grass, gama grass and switch grass (see rates below). When you mix it and add native
wildflowers, it will make your project more diverse and more like a natural prairie community.
For starting over, I recommend planting at 6-8 pounds per acre of the following mixture of
NWSG:
1 pound of a switch grass (Panicum virgatum) (Plateau will injure), or
P. anceps = Beaked Panicum, P. clandestinum = Deertongue,
2 pounds of big blue stem
2 pounds of little blue stem
2 pounds of Indian Grass
1 pound of Gama grass (Plateau will injure)
(Note: For forage production, higher rates are recommended).
A mixture that is compatible with Plateau or herbicides with the same chemical:
3 pounds of big blue stem
2 pounds of little blue stem
3 pounds of Indian Grass
For wildflowers: plant 1 pound per acre and mix it with the grass. I picked the following:
Butterfly milkweed, Purple coneflower, Coreopsis lanceolata, Coreopsis tinctoria (annual),
Rough blazing star (Liatris aspera) and black-eyed susan (Rudbeckia hirta).
When developing and customizing a seed mixture, I recommend checking the local
county plant species list (if there is one) and Vascular Plants of the Carolinas for species
diversity, as well as consulting with botanists. The NC Botanical Garden is a good reference and
has a native seed source list of local commercial growers.
GSA Env. Academy @ Oak Springs -Page 7 - October 14, 2008
Figure 1. Listed rare vascular plant species associated with Piedmont prairies and associated
communities (not all inclusive)
Common Name Scientific Name Status
Schweinitz's sunflower Helianthus schweinitzii Federally Endangered
smooth coneflower Echinacea laevi ata Federally Endangered
Georgia aster S h otrichum eor ianum Federal Species of Concern
Carolina birdfoot-trefoil Lotus helleri Federal Species of Concern
Tall larkspur Delphinium exaltatum Federal Species of Concern
Butner Barbara's buttons Marshallia s 1 Federal Species of Concern
Heller's rabbit tobacco Gna halium helleri Significantly rare-Proposed
Carolina thistle Cirsium carolinianus Significantly rare-Proposed
Sessile Tick-trefoil Desmodium sessilifolium Significantly rare-Proposed
Carolina thistle Cirsium carolinianum Significantly rare-Proposed
Thick-pod white wild indigo Ba tisia alba Significantly rare-Proposed
Thin-pod white wild indigo Ba tisia albescens Significantly rare-Proposed
Smooth sunflower Helianthus laevi atus Significantly rare-Proposed
Earle's blazing star Liatris s uarrulosa Significantly rare-Proposed
Southeastern bold goldenrod Solida o ri ida ss labrata Significantly rare-Proposed
Prairie dock Sil hium terebinthinaceum Significantly rare-Proposed
Glade wild quinine Parthenium auriculatum Significantly rare-Threatened
Figure 2. NC Partners In Flight Priority Bird Species associated with prairie/grassland, shrub-
scrub, and savanna habitats (not all inclusive)
Prairie/Grassland Shrub-scrub Pine savanna
Henslow's sparrow Prairie warbler Red-cockaded woodpecker
Bachman's sparrow American woodcock Bachman's sparrow
Northern bobwhite Northern bobwhite Brown-headed nuthatch
Loggerhead shrike Fields arrow Henslow's sparrow
Short-eared owl (winter, b) Eastern towhee Northern bobwhite
Barn owl Orchard oriole Summer tanager
Northern harrier (winter) Yellow-breasted chat American kestrel
Grasshopper sparrow Gray catbird Red-headed woodpecker
Eastern kingbird Common ellowthroat Northern flicker
Eastern meadowlark Brown thrasher Chuck will's widow
Sedge wren (winter) White-eyed vireo Whip-poor-will
Dickcissel Willow fl catcher
Bobolink (migrant, b) Ves er s arrow (winter)
Horned lark (winter, b) Loggerhead shrike
Barn owl
NC sources are: Garrett Wildflower seed farm 919-818-4309 (Don Lee) www.ernstseed.com Adams Briscoe &
Sharpe Bro. for Americas Indian grass from Georgia. Contact NC Botanical Garden and ask for their nursery list.
Plant information may be obtained by contacting Mr. Don Serriff at 704-336-8798 or 704-432-1391 with the
Mecklenburg County Park and Recreation Department.