20181041 Ver 1_WRC Comments_20180830

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
30 August 2018
Mr. Brad Luckey
Pilot Environmental, Inc.
P.O. Box 128
Kernersville, North Carolina 27285
SUBJECT: Pre -Construction Notification for the Cambridge Park (Turner Road), Alamance County,
North Carolina. USACE Action ID: SAW -2017-02329; DEQ No. 20181080.
Dear Mr. Luckey,
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.).
On behalf of Desco Mebane Partners LLC, Pilot Environmental, Inc. has submitted a Pre -Construction
Notification (PCN) application for the Cambridge Park (Turner Road) project in Mebane, Alamance
County, North Carolina. Cambridge Park is a residential subdivision that will be developed in eight
phases. Phase I A is fully designed and will consist of 65 residential lots, one stormwater retention pond,
associated roads, and sewer/water infrastructure. The project will permanently impact 114 linear feet (If)
of perennial streams and temporarily impact 441f of perennial streams. The sewer and water crossings
will be bored beneath the Little Haw Creek and an unnamed tributary to Little Haw Creek.
The Little Haw Creek and its unnamed tributaries occur on the site. The Little Haw Creek in the Cape
Fear River basin is classified as a Water Supply V and Nutrient Sensitive Water by the NC Division of
Water Resources (NC DWR). We have no current records of federal or state rare, threatened, or species on
or adjacent to the site. An on-site survey is the only definitive means to determine if the proposed project
would impact rare, threatened, or endangered species.
We have concerns that the proposed residential subdivision will have 37% impervious surface, resulting
in an increase in sedimentation and stormwater around the headwaters of the Little Haw Creek. The Little
Haw Creek drains to the Haw River upstream of areas inhabited by the federal and state endangered Cape
Fear shiner (Notropis mekistocholas). Headwater streams can significantly reduce nutrient export to
rivers (Alexander et al. 2000; Peterson et al. 2001) and the condition of the stream in the lower reaches is
closely dependent on the condition in the headwaters (Vannote et al. 1980). Furthermore, placing fill in
aquatic resources can alter hydrology, result in significant negative impacts to downstream areas, and
eliminate aquatic and terrestrial wildlife habitat.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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We also offer the applicant the following general recommendations to minimize impacts to aquatic and
terrestrial wildlife resources.
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.
Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment
of pollutants associated with urban stormwater.
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 passage of aquatic organisms; access the floodplain; and designed and installed
to maintain dimension, pattern, and profile of the stream. We also recommend bottomless
culverts and floodplain culverts.
3. Avoid the removal of large trees at the site. Avoid tree clearing activities during the maternity
roosting season for bats (May 15 — August 15).
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/Conservin /g Programs/GreenGrowthToglbox.aspx).
5. 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%. We recommend
stormwater wetlands or the use of another LID technology. If a stormwater pond is used, plant
trees and shrubs around the pond. 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.
6. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas and landscaping, specifically native, wildlife seed mixes that will create pollinator
habitat. Avoid using Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or
non-native and provide little benefit to wildlife. Consider an alternative mix of red clover,
creeping red fescue, and a grain, such as oats, wheat, or rye. Also avoid using invasive, non-
native landscaping plants, such as privet and nandina
(http://www.ncwildflower.org/plant galleries/invasives_list).
7. Use stringent sedimentation and erosion control measures to mitigate stormwater and erosion
impacts. 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. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment loads can

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USACE Action ID: SAW -2017-02329
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 provide input for this project. If I can provide further assistance or
provide free technical guidance, please call [phone] or email olivia.munzerkncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature
Alexander, R. B., R. A. Smith, and G. E. Schwarz. 2000. Effect of stream channel size on the
delivery of nitrogen to Gulf of Mexico. Nature 403:758-761.
Peterson, B. J., W. M. Wollheim, P. J. Mulholland, J. R. Webster, J. L. Meyer, J. L. Tank, E. Marti, W. B.
Bowden, H. M. Valett, A. E. Hershey, W. H. McDowell, W. K. Dodds, S. K. Hamilton, S.
Gregory, and D. D. Morrall. 2001. Control of nitrogen export from watersheds by headwater
streams. Science 292:86-90.
Vannote, R. L., G. W. Mineshell, K. W. Cummins, J. R. Sedell, and C. E. Cushings. 1980. The river
continuum concept. Canadian Journal of Fisheries and Aquatic Sciences 37:130-137.
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: David Bailey, U.S. Army Corps of Engineers
Sue Homewood, N.C. DWR
John Ellis, U.S. Fish and Wildlife Service
Brena Jones, NCWRC