20171275 Ver 1_WRC Comments_20171103

Burdette, Jennifer a
From: Munzer, Olivia
Sent: Friday, November 03, 2017 5:13 PM
To: [e-mail]
Cc: John Ellis; Burdette, Jennifer a; Dailey, Samantha J CIV USARMY CESAW (US)
Subject: Preservation Forest Lane PCN (SAW -2010-00568) - Orange - NCWRC Comments
Attachments: 20171275 -Orange - Preservation Forest Lane Dev PCN_NCWRC Comments.pdf
Mr. Oliver,
Please see the attached comments regarding the Heirs of Arthur Plambeck — Preservation Forest Lane Project. Please let
me know if you have questions. Thank you and have a good weekend.
Olivia
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Certified Wildlife Biologist
NC Wildlife Resources Commission
Sykes Depot, 2430 Turner Rd.
Mebane, NC 27302
Office: 336.290.0056 H Cell: 336.269.0074
olivia.munzer(@,,ncwildlife.org
www.ncwildlife.or
0 W 1 0
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
3 November 2017
Mr. Chris Oliver, PE
Summit Design and Engineering Services
504 Meadowland Drive
Hillsborough, North Carolina 27278
SUBJECT: Pre -Construction Notification for the Heirs of Arthur Plambeck — Preservation Forest
Lane Project, Orange County, North Carolina. USACE ID: SAW -2010-00568, DEQ No.
20171275.
Dear Mr. Butler,
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.).
Summit Design and Engineering Services, on behalf of Charles Plambeck, has submitted a Pre -
Construction Notification (PCN) application for the Heirs of Arthur Plambeck — Preservation Forest Lane
Project located off the southern terminus of Bradford Ridge Road in Bingham Township, Orange County,
North Carolina. A Nationwide Permit 29 was issued by the U.S. Army Corps of Engineers (USACE) on
17 May 2010 (SAW -2010-00568) and this PCN is a request for a renewal. The purpose of the project is
to construct a 12 -foot (ft) wide gravel road to access all the lots within the residential development,
resulting in the installation of two 36 -inch culverts into an unnamed tributary of Cane Creek. The
proposed project would impact 95 ft of the perennial stream and 4,059 square feet (sf) of Zone 1 and
2,401 sf of Zone 2 riparian buffer.
The unnamed tributary to Cane Creek in the Cape Fear River basin is classified as a Water Supply II
stream, High Quality Water, and Nutrient Sensitive Water by the N.C. Division of Water Resources
(NCDWR). We have records of the federal species of concern (FSC) and state special concern Carolina
darter (Etheostoma collis) and state threatened Creeper (Strophitus undulatus) within Cane Creek. Within
the vicinity of the site, we have records for the FSC and state significantly rare (SSR) Torrey's mountain -
mint (Pycnanthemum torreyi), SSR warbling vireo (Vireo gilvus), and the state threatened bald eagle
(Haliaeetus leucocephalus), which is also federally protected by the Bald and Golden Eagle Protection
Action. The U.S. Fish and Wildlife Service (USFWS) lists the federally endangered dwarf wedgemussel
(Alasmidonta heterodon), smooth coneflower (Echinacea laevigata) and Michaux's sumac (Rhus
michauxii) as having potential to occur within or adjacent to the site if suitable habitat is present. We
recommend contacting the USFWS at [phone] to ensure that any issues related to these species are
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Orange County
addressed. The lack of records from the site does not imply or confirm the absence of federal or state -
listed species or state Species of Greatest Conservation Need listed in the 2015 State Wildlife Action Plan
(hM2://www.ncwildlife.org/plan). An on-site survey is the only definitive means to determine if the
proposed project would impact rare, threatened, and endangered species
The NCWRC offers the following recommendations to minimize impacts to aquatic and terrestrial
wildlife resources:
We prefer a minimum 100 -foot undisturbed, native, forested buffer is maintained 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.
2. Each lot should be surveyed prior to development for wetlands and streams to ensure there are no
additional impacts to surface waters. In addition to providing wildlife habitat, wetland areas and
streams aid in flood control and water quality protection.
Consider avoiding or further minimizing the amount of impacts to the stream by building a bridge
rather than a culvert. 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, pollutants (e.g., sediment, heavy metals, pesticides,
and fertilizers) washed from developed landscapes can adversely affect and extirpate species
downstream.
If culverts must be used, the culvert should be designed to allow aquatic life passage. 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. Any riprap used should not interfere with aquatic life movement during low flow.
4. 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 provides information on nature -friendly planning
(http://www.ncwildlife.org/Conserving/Programs/GreenGrowthToolbox. aspx).
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,

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Orange County
reduce exposure of the water surface to sunlight to minimize thermal pollution, and provide
essential summer and winter habitats.
6. Grassed swales shall be used in place of curb and gutter for new developments, except in areas
with >5% slope. Check dams, level spreaders, and other associated best management practices
shall be used to minimize the effect of stormwater runoff entering the riparian buffer areas. In
areas where slopes exceed 5%, stormwater collected in piped conveyance systems shall be
directed away from surface waters and best management practices shall be employed at both the
intake and the outlet areas. Clustering development away from riparian areas will also allow for
greater stream protection.
7. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer
areas. All utility crossings should be kept to a minimum, which includes careful routing design
and the combination of utility crossings into the same right-of-way (provided there is not a safety
issue).
8. 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.
9. Erosion and sediment control measures should conform to the High Quality Water Zones
standards stipulated in the NC Department of Environmental Quality Erosion and Sediment
Control Plan (hlt2s://deg.nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-
land-permit-guidance/erosion-sediment-control-planning-design-manual). 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.
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.munzerkncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program

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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.
cc: Jennifer Burdette, NCDWR
Samantha Dailey, USACE
John Ellis, USFWS