20170905 Ver 1_WRC Comments_20170814

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
14 August 2017
Mr. Wyatt Brown
Brown's Environmental Group, Inc.
242 Batten Farm Road
Selma, NC 27576
SUBJECT: Pre -Construction Notification for the Graham Drive Inn Road Crossing, Alamance
County, North Carolina. DEQ No. 20170905.
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
Brown's Environmental Group, Inc., on behalf of the I-40 Drive Inn, LLC, has submitted a Pre -
Construction Notification application for the Graham Drive Inn located north of Interstate 40 and east of
Jimmie Kerr Road in Graham, Alamance County, North Carolina. The project will require a three -lane
road for fire rescue, parking, concession stand, and other associated appurtenant. The proposed project
will result inl46 linear feet (If) of permeant impacts to an unnamed tributary of Back Creek and 0.09
acres of impacts to wetlands.
Back Creek is in the Cape Fear River basin and it is classified as a Class C and Nutrient Sensitive Water
by the N.C. Division of Water Resources (NCDWR). We have records of the state significantly rare
eastern creekshell (Villosa delumbis) in Back Creek near the site and helicta satyr (Neonympha helicta) in
Alamance.
Therefore, we offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife
resources:
Consider avoiding or further minimizing the amount of impacts to wetlands and streams. Placing
fill in aquatic resources can alter hydrology, result in significant negative impacts to downstream
areas, and eliminate aquatic and terrestrial wildlife habitat. Additional impervious surface results
in an increase in stormwater runoff that can exert significant impacts on stream morphology.
This will cause further degradation of aquatic habitat through accelerated stream bank erosion,
channel and bedload changes, altered substrates, and scouring of the stream channel. In addition,
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed
landscapes can adversely affect and extirpate species downstream.
2. 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 aquatic life passage. Any riprap used should not interfere with aquatic life
movement during low flow. If sufficient slope exists, baffle systems are recommended to trap
gravel and provide resting areas for fish and other aquatic organisms. Culverts or pipes should be
situated so no channel realignment or widening is required. Widening of the stream channel at
the inlet or outlet of structures usually causes a decrease in water velocity causing sediment
deposition that will require future maintenance.
3. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a
minimum 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.
4. Avoid development and fill in the 100 -year floodplain. Development and fill in the floodplain
increases the potential for flooding and interferes with the natural hydrologic process of the
waterways.
5. Use non-invasive native species and Low Impact Development (LID) technology in landscaping.
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. LID techniques include
permeable pavement and bioretention areas that can collect stormwater from driveways and
parking areas. Additional alternatives include narrower roads, swales versus curbs/gutters and
permeable surfaces such as turf stone, brick, and cobblestone. Compared to conventional
developments, implementing appropriate LID techniques can be more cost-effective,
provide space -saving advantages, reduce runoff, and protect water quality (Roseen et al.
2011). Also, NCWRC's Green Growth Toolbox
(htlp://www.ncwildlife.org/Conservin /g Programs/GreenGrowthToplbox.aspx) provides
information on nature -friendly planning.
6. 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%. Where feasible, trees and
shrubs should be planted around stormwater ponds, or use LID techniques. This would provide
habitat benefits that offset those functions lost by development, partially restore aquatic habitats,
reduce exposure of the water surface to sunlight to minimize thermal pollution, and provide
essential summer and winter habitats.
7. Re -seed disturbed areas with native seed mixtures and plants that are beneficial to wildlife.
Avoid fescue -based mixtures because fescue is invasive and provides little benefit to wildlife.
8. Sediment and erosion control measures should be installed prior to any land -disturbing
activity. 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. Excessive silt and
sediment loads can have detrimental effects on aquatic resources including destruction of
spawning habitat, suffocation of eggs, and clogging of gills.

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Thank you for the opportunity to comment on this permit application. Further information on native
plants and free technical guidance from the NCWRC, please contact me at [phone] or
olivia.munzer&ncwildlife. org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature Cited
Roseen, R. M., T. V. Janeski, J. J. Houle, M. H. Simpson, and J. Gunderson. 2011. Forging the Link:
Linking the Economic Benefits of Low Impact Development and Community Decisions.
University of New Hampshire Stormwater Center, Virginia Commonwealth University, and
Antioch University New England.
ec: Sue Homewood, NCDWR
Byron Hamstead, USFWS
David Bailey, USACE
Brena Jones, NCWRC