20021139 Ver 2_NCWRC Comments_20180924

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
24 September 2018
Mr. Bryan Roden -Reynolds
Regulatory Project Manager
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, NC 28262
Subject: Individual Permit Application for the Smith Reynolds Airport Expansion Project, Forsyth
County; USACE Action ID SAW -2017-01312.
Dear Mr. Roden -Reynolds,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
Individual Permit (IP) application. 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.).
The Airport Commission of Forsyth County proposes to expand within the boundaries of Smith Reynolds
Airport in Winston-Salem, Forsyth County, North Carolina. The proposed project would entail the 1,650 -
foot extension of Taxilane L; new aircraft maintenance, repair and overhaul (MRO) facilities; MRO auto
parking and apron expansion; Runway 15-33 obstruction removal; Runway 22 safety area extension; new
haul road; and construction of an erosion control/stormwater basin. The proposed project would impact
approximately 1. 13 acres of wetlands and 4,079 linear feet of streams.
Bushy Fork and its unnamed tributaries flow through the site. Brushy Fork in the Yadkin River basin is
classified as a Class C stream by the NC Division of Water Resources. We have no records of federally
or state -protected species at or adjacent to the site; however, the lack of records does not imply or confirm
the absence of federal or state -listed species. Clearwater Environmental Consultants, Inc. (CEC)
conducted a federal threatened and endangered species review and habitat assessment for the site. CEC
did not observe suitable habitat for and/or individuals of red -cockaded woodpecker (Picoides borealis;
federally endangered), small-anthered bittercress (Cardamine micranthera; federally endangered), bog
turtle (Clemmys muhlenbergii; federally threatened S/A), northern cup plant (Silphium perfoliatum; state
threatened), or purple fringeless orchid (Platanthera peramooena; state threatened). CEC included the
brook floater (Alasmidonta varicose), a federal at -risk species and state endangered mollusk, as having
the potential to occur at the site, but CEC did not report their results of the surveys and habitat assessment
for this species in the report. NCWRC has an information gap for the state special concern Greensboro
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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burrowing crayfish (Cambarus catagius) and state significantly rare Carolina ladle crayfish (Cambarus
davidi) in Forsyth County. T.R. Russ, the NCWRC foothills aquatic diversity coordinator, is requesting
crayfish surveys or for NCWRC to survey the site. Contact Mr. Russ at 828.803.6035 or
thomas.russgncwildlife.org to coordinate crayfish surveys.
As indicated in our scoping comments (NCWRC 16 June 2017), we have concerns regarding the amount
of impacts to wetlands and streams and its effects on aquatic ecosystems. Please see the following
comments on the IP:
Development impacts are occurring throughout North Carolina at unprecedented rates. Water
quality issues already exist due to "sprawl" around urbanized areas. Increased population and
development impacts are causing unmitigated loss of stream headwaters and forested ecosystems
through "site stripping" practices that pipe and pave geologically and biologically functioning
ecosystems without consideration of direct and indirect impacts to our environment. Headwater
streams, such as these, can significantly reduce nutrient export to rivers (Alexander et al. 2000;
Peterson et al. 200 1) and the condition of the stream in the lower reaches is closely dependent on
the condition in the headwaters (Vannote et al. 1980).
The IP indicates the dredge and fill of streams and wetlands will have minor to no effects on
aquatic organisms, physical and chemical characteristics of the aquatic ecosystem, and wetlands.
However, the dredge and fill of wetlands and streams can have significant adverse direct and
indirect impacts on aquatic ecosystems. According to the NC Stream Assessment Method
(NCSAM) forms included in the IP, the streams to be filled have a functional rating of high or
medium. In general, 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.
2. NCSAM forms were not completed for Impacts #15 and #16. We recommend these forms be
completed for these two streams or explain the absence of the forms. Impact #16 is from the fill
of 671f of stream and Impact #15 is the fill of 5261f of stream for the construction of an Erosion
Control/Future Stormwater Basin.
3. Minimize impacts to streams and wetlands by redesigning aspects of the project. We understand
Federal Aviation Administration and other limitations can guide development at an airport.
However, alternatives for different configurations of the project were not provided in the IP. For
example, consider relocating the erosion control/stormwater basin or MRO facilities and parking
to reduce impacts to streams and wetlands.
4. We recommend a bottomless culvert or bridge rather than a circular culvert.
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%.
6. Sediment and erosion control measures should be installed prior to any land clearing or
construction. 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 or similar materials that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife

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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 review and comment on this project. If I can be of further assistance or
free technical guidance, please contact me at [phone] or olivia.munzer&ncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Ec: T.R. Russ, NCWRC
Mark Davidson, Airport Commission of Forsyth County
R. Clement Riddle, CEC
Sue Homewood, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service