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Home My WebLink About20021139 Ver 2 _USFWS comments _20180911ua FTM &AVTLIHIFE United States Department of the InteriorSERVIUE FISH AND WILDLIFE SERVICE Asheville Field Office 160 Zillicoa StreetFl Asheville, North Carolina 28801 September 11, 2018 Bryan Roden -Reynolds USACE Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Dear Mr. Roden -Reynolds: Subject: Smith Reynolds Airport Expansion Project; Forsyth County, North Carolina Log No. 4-2-17-417 The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public notice and associated materials issued August 24, 2018. The Service provided scoping comments directly to the Applicant June and September, 2017. We submit the following comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). Project Description According to the information provided, the proposed airport expansion project would occur on 94 acres in Winston-Salem, North Carolina. The project aims to satisfy modern FAA standards and to improve safety and the overall efficiency of the development. Specifically, the Airport Commission of Forsyth County proposes to 1) expand Taxilane L, Runway 22, and existing maintenance facilities; 2) clear obstructions (terrain and vegetation) within a 24.2 acre Object - Free Area; and 3) install a haul road and erosion control basin (to be converted for stormwater management post -construction). The proposed activities would impact approximately 43% of onsite streams and 63% of onsite wetlands, resulting in fill of 4,079 linear feet of perennial stream and fill of 1.13 acres of wetlands (headwater forest and bottomland hardwood). The Applicant proposes to mitigate for stream and wetland impacts at a 1:1 ratio via NCDMS In -Lieu fee program. The public notice indicates that sufficient mitigation credits from private mitigation banks within the watershed were not available within the watershed at the time of the Applicant's request. Federally Listed Endangered and Threatened Species According to Service records, suitable summer roosting habitat may be present in the project area for the federally threatened northern long-eared bat (Myotis septentrionalis). However, the final 4(d) rule (effective as of February 16, 2016), exempts incidental take of northern long-eared bat associated with activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150 feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on the information provided, the project (which may or may not require tree clearing) would occur at a location where any incidental take that may result from associated activities is exempt under the 4(d) rule. Although not required, we encourage you to avoid any associated tree clearing activities during the maternity roosting season from May 15 — August 15 if possible. The permit application indicated that suitable habitat was identified within the project area for the federally endangered small-anthered bittercress (Cardamine micrathera), but that surveys conducted in March and April 2014 did not detect this species. While historic records for this riparian plant occur in Forsyth County, North Carolina, current records are known only from the Dan River basin which is outside of the project area. Based on the information provided, the Service does not have any concerns for any other federally protected species. Please be aware that obligations under section 7 of the Act must be reconsidered if. (1) new information reveals impacts of this identified action that may affect listed species or critical habitat in a manner not previously considered, (2) this action is subsequently modified in a manner that was not considered in this review, or (3) a new species is listed or critical habitat is determined that may be affected by the identified action. Compensatory Mitigation In the interest of protecting natural resources, every effort should be made to avoid/minimize impacts to streams and wetlands. The Applicant should be aware that effective July 1, 2018, the NCDMS fee schedule has been modified. The Airport Commission of Forsyth County proposes to mitigate for impacts to streams and wetlands at a 1:1 ratio via NCDMS In -Lieu Fee Program. We believe that the stream and wetland assessment forms (NCSAM and NCWAM) support the need for at least a 2:1 mitigation ratio. Approximately 33% of proposed stream impacts (1,363 linear feet) are represented by an overall "high" NCSAM rating. In the event that sufficient mitigation credits are not available with the project's watershed and the Applicant resorts to permittee -responsible mitigation, we request that that a complete mitigation plan be submitted to this office for review. The Service maintains that compensatory mitigation should be provided within the watershed where impacts originate (03040101). Erosion and Sediment Control Measures to control sediment and erosion should be installed before any ground -disturbing activities occur. Instream work (e.g. haul road culverts) should occur under dry conditions utilizing a temporary diversion/pump-around system. Grading and backfilling should be minimized, and existing native vegetation should be retained (if possible) to maintain riparian cover for fish and wildlife. Disturbed areas should be revegetated with native grass and tree species. Ground disturbance should be limited to what will be stabilized quickly, preferably by the end of the workday. Natural fiber matting (coir) should be used for erosion control as synthetic netting can trap animals and persist in the environment beyond its intended purpose. 2 Impervious Surfaces and Low -Impact Development The Service is concerned about the potential stormwater-mediated impacts to streams and wetlands onsite. Where detention ponds are used, storm -water outlets should drain through a vegetated area prior to reaching any natural stream or wetland area. Detention structures should be designed to allow for the slow discharge of storm water, attenuating the potential adverse effects of storm -water surges; thermal spikes; and sediment, nutrient, and chemical discharges. Since the purpose of storm -water -control is to protect streams and wetlands, no storm -water -control measures or best management practices should be installed within any stream (perennial or intermittent) or wetland. We recommend that retention ponds be located at least 750 feet from wetlands to minimize hydrologic disturbance and ecological function. We also recommend that consideration be given to the use of pervious materials (i.e., pervious concrete, interlocking/open paving blocks, etc.) for the construction of roads, driveways, sidewalks, etc. Pervious surfaces minimize changes to the hydrology of the watershed and can be used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and store heat and allow the cooler soil below to cool the pavement. Additionally, pervious concrete requires less maintenance and is less susceptible to freeze/thaw cracking due to large voids within the concrete. The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future correspondence concerning this project, please reference our Log Number 4-2-17-417. Sincerely, - - original signed - - Janet Mizzi Field Supervisor Ex: Mark Davidson; Airport Commission of Forsyth County Clement Riddle; CWE Kaylie Yankura; CWE Sue Homewood; NCDWR Olivia Munzer; NCWRC 3 ua FTM &AVTLIHIFE United States Department of the InteriorSERVIUE FISH AND WILDLIFE SERVICE Asheville Field Office 160 Zillicoa StreetFl Asheville, North Carolina 28801 September 11, 2018 Bryan Roden -Reynolds USACE Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Dear Mr. Roden -Reynolds: Subject: Smith Reynolds Airport Expansion Project; Forsyth County, North Carolina Log No. 4-2-17-417 The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public notice and associated materials issued August 24, 2018. The Service provided scoping comments directly to the Applicant June and September, 2017. We submit the following comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). Project Description According to the information provided, the proposed airport expansion project would occur on 94 acres in Winston-Salem, North Carolina. The project aims to satisfy modern FAA standards and to improve safety and the overall efficiency of the development. Specifically, the Airport Commission of Forsyth County proposes to 1) expand Taxilane L, Runway 22, and existing maintenance facilities; 2) clear obstructions (terrain and vegetation) within a 24.2 acre Object - Free Area; and 3) install a haul road and erosion control basin (to be converted for stormwater management post -construction). The proposed activities would impact approximately 43% of onsite streams and 63% of onsite wetlands, resulting in fill of 4,079 linear feet of perennial stream and fill of 1.13 acres of wetlands (headwater forest and bottomland hardwood). The Applicant proposes to mitigate for stream and wetland impacts at a 1:1 ratio via NCDMS In -Lieu fee program. The public notice indicates that sufficient mitigation credits from private mitigation banks within the watershed were not available within the watershed at the time of the Applicant's request. Federally Listed Endangered and Threatened Species According to Service records, suitable summer roosting habitat may be present in the project area for the federally threatened northern long-eared bat (Myotis septentrionalis). However, the final 4(d) rule (effective as of February 16, 2016), exempts incidental take of northern long-eared bat associated with activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150 feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on the information provided, the project (which may or may not require tree clearing) would occur at a location where any incidental take that may result from associated activities is exempt under the 4(d) rule. Although not required, we encourage you to avoid any associated tree clearing activities during the maternity roosting season from May 15 — August 15 if possible. The permit application indicated that suitable habitat was identified within the project area for the federally endangered small-anthered bittercress (Cardamine micrathera), but that surveys conducted in March and April 2014 did not detect this species. While historic records for this riparian plant occur in Forsyth County, North Carolina, current records are known only from the Dan River basin which is outside of the project area. Based on the information provided, the Service does not have any concerns for any other federally protected species. Please be aware that obligations under section 7 of the Act must be reconsidered if. (1) new information reveals impacts of this identified action that may affect listed species or critical habitat in a manner not previously considered, (2) this action is subsequently modified in a manner that was not considered in this review, or (3) a new species is listed or critical habitat is determined that may be affected by the identified action. Compensatory Mitigation In the interest of protecting natural resources, every effort should be made to avoid/minimize impacts to streams and wetlands. The Applicant should be aware that effective July 1, 2018, the NCDMS fee schedule has been modified. The Airport Commission of Forsyth County proposes to mitigate for impacts to streams and wetlands at a 1:1 ratio via NCDMS In -Lieu Fee Program. We believe that the stream and wetland assessment forms (NCSAM and NCWAM) support the need for at least a 2:1 mitigation ratio. Approximately 33% of proposed stream impacts (1,363 linear feet) are represented by an overall "high" NCSAM rating. In the event that sufficient mitigation credits are not available with the project's watershed and the Applicant resorts to permittee -responsible mitigation, we request that that a complete mitigation plan be submitted to this office for review. The Service maintains that compensatory mitigation should be provided within the watershed where impacts originate (03040101). Erosion and Sediment Control Measures to control sediment and erosion should be installed before any ground -disturbing activities occur. Instream work (e.g. haul road culverts) should occur under dry conditions utilizing a temporary diversion/pump-around system. Grading and backfilling should be minimized, and existing native vegetation should be retained (if possible) to maintain riparian cover for fish and wildlife. Disturbed areas should be revegetated with native grass and tree species. Ground disturbance should be limited to what will be stabilized quickly, preferably by the end of the workday. Natural fiber matting (coir) should be used for erosion control as synthetic netting can trap animals and persist in the environment beyond its intended purpose. 2 Impervious Surfaces and Low -Impact Development The Service is concerned about the potential stormwater-mediated impacts to streams and wetlands onsite. Where detention ponds are used, storm -water outlets should drain through a vegetated area prior to reaching any natural stream or wetland area. Detention structures should be designed to allow for the slow discharge of storm water, attenuating the potential adverse effects of storm -water surges; thermal spikes; and sediment, nutrient, and chemical discharges. Since the purpose of storm -water -control is to protect streams and wetlands, no storm -water -control measures or best management practices should be installed within any stream (perennial or intermittent) or wetland. We recommend that retention ponds be located at least 750 feet from wetlands to minimize hydrologic disturbance and ecological function. We also recommend that consideration be given to the use of pervious materials (i.e., pervious concrete, interlocking/open paving blocks, etc.) for the construction of roads, driveways, sidewalks, etc. Pervious surfaces minimize changes to the hydrology of the watershed and can be used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and store heat and allow the cooler soil below to cool the pavement. Additionally, pervious concrete requires less maintenance and is less susceptible to freeze/thaw cracking due to large voids within the concrete. The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future correspondence concerning this project, please reference our Log Number 4-2-17-417. Sincerely, - - original signed - - Janet Mizzi Field Supervisor Ex: Mark Davidson; Airport Commission of Forsyth County Clement Riddle; CWE Kaylie Yankura; CWE Sue Homewood; NCDWR Olivia Munzer; NCWRC 3