20052116 Ver 4_WRC comments_20190124

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Jean Gibby
U.S. Army Corps of Engineers
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 24 January 2019
SUBJECT: Individual Permit for Caleb's Creek Mixed -Use Development Roads and Sanitary Sewer
Lines; Forsyth County; USACE Action ID: SAW -2015-01697; DEQ Project No.
20052116x4.
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 (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
Wetlands & Waters, Inc, on behalf of BOMA North Carolina, LLC, has submitted an Individual Permit
application for the road and sanitary sewer crossings for the Caleb's Creek mixed-use development.
Caleb's Creek is located on approximately 875 acres located south of Interstate 40 and on both sides of
Teague Road in Kernersville, Forsyth County, North Carolina. The proposed project consists of mixed-
use development, residential, commercial/office areas, public school, and large amenity center. A total of
185 acres are proposed as common, passive -use open space, which will include 5.7 miles of greenway
walking trails and 3.4 miles of greenway biking trails.
Abbotts Creek and the unnamed tributaries to Abbotts Creek occur in Yadkin — Pee Dee River basin.
Abbotts Creek is classified as a Water Supply III stream by N.C. Division of Water Resources
(NCDWR). The installation of culverts for 6 road crossings would impact 557 linear feet (If) of
intermittent and perennial unnamed tributaries of Abbotts Creek. Construction of the sanitary sewer lines
would temporarily impact an additional 5001f of Abbotts Creek and its unnamed tributaries; the project
would have 14 sanitary sewer line crossings. The applicant proposes box culverts to be sized in
consideration of the natural stream design, to construct sills to allow for aquatic life passage, and
upgraded culverts will also allow for aquatic life passage.
We have no known records for federal or state rare, threatened, or endangered species at or within the
vicinity of the site. However, the lack of records from the site does not imply or confirm the absence of
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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USACE Action ID: SAW -2015-01697
federal or state -listed species. An on-site survey is the only definitive means to determine if the proposed
project would impact rare, threatened, or endangered species.
We offer the following recommendations minimize impacts to aquatic and terrestrial wildlife resources.
1. We recommend reducing the number of utility line crossings. Based upon the overview figure of
the Draft Preferred Alternative, we have the following suggestions.
a. The applicant should provide a more detailed figure of the proposed road and utility line
crossings with existing infrastructure and waters of the U.S.
b. U-3 and U-4 cross the wetlands and stream twice; potentially extend RM -5 southward by
running the utility line closer to the development and avoid the wetland/stream complex.
Consider connecting the sewer line from CO -6 to RM -5; thereby avoiding impacts from
U-4.
c. Connect RL -16 and AM directly to the existing sanitary sewer line and avoid the U-12
crossing.
d. It is unclear why U-10 crosses a stream. It seems unnecessary to have U-11 if U-5
extends from the existing sanitary sewer line to RL -2 and RM -1, which do not impact
streams.
e. Consider co -locating R-9 and U-9, and U-11 and R-11, if the above cannot be considered.
f. Consider extending U-1 across the intermittent stream instead of the perennial stream by
locating it slightly farther north.
2. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer
areas. Manholes or similar access structures should not be allowed within buffer areas. Stream
crossings should be near perpendicular (75° to 105°) to stream flow. We recommend a minimum
100 -foot undisturbed buffer for perennial streams and a 50 -foot undisturbed buffer for
intermittent streams and wetlands.
3. The directional bore stream crossing method should be used for utility crossings rather than open -
cut stream crossing method to prevent the likelihood of future lateral movement of the stream,
causing undercutting or erosion around the utility line. The open -cut stream crossing method
should only be used when water level is low and stream flow is minimal.
4. We are pleased to see the applicant is designing the culverts to allow for aquatic life passage.
Consider also using bottomless culverts or bridges for all permanent roadway crossings of
streams and associated wetlands to eliminate the need to fill and culvert, where practicable.
If multiple barrels are required, barrels other than the base flow barrel(s) should be placed on or
near stream bankfull or floodplain bench elevation (similar to Lyonsfield design). These should
be reconnected to floodplain benches as appropriate. This may be accomplished by utilizing sills
on the upstream and downstream ends to restrict or divert flow to the base flow barrel(s). Silled
barrels should be filled with sediment so as not to entrap wildlife or support mosquito breeding
conditions. Sufficient water depth should be provided in the base flow barrel(s) during low flows
to accommodate fish movement. If culverts are longer than 40-50 linear feet, alternating or
notched baffles should be installed in a manner that mimics existing stream pattern. This should
enhance aquatic life passage: 1) by depositing sediments in the barrel, 2) by maintaining channel
depth and flow regimes, and 3) by providing resting places for fish and other aquatic organisms.
In essence, base flow barrel(s) should provide a continuum of water depth and channel width
without substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.

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Culverts or pipes should be situated along the existing channel alignment whenever possible to
avoid channel realignment. Widening the stream channel must be avoided. Stream channel
widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
5. The applicant should avoid the removal of large trees at the edges of construction corridors. Due
to the decline in bat populations, tees should not be removed during the maternity roosting season
for bats (May 15 — August 15). Also, clearing of the rights-of-way (ROW) should be avoided
during the migratory bird nesting season, roughly March to August.
6. Disturbed areas should be reseeded with native seed mixtures that are beneficial to wildlife. The
applicant should consider planting native, wildflower seed mixes and plants that will create
pollinator habitat, which would also improve the aesthetics of the ROW. Bermudagrass, redtop,
tall fescue, and lespedeza, which are invasive and/or non-native species, should not be used and
thee species provide little benefit to wildlife.
7. 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 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
have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
The NCWRC encourages the applicant to consider additional measures to protect wildlife species in
developing landscapes. The NCWRC's Guidance Memorandum to Address and Mitigate Secondary and
Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water Quality details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
htt2://www.ncwildlife.org/portals/O/Conserving/documents/2002 GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002).
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or olivia.munzerkncwildlife.org.
ec: Sue Homewood, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service
Kory Reimann, BOMA North Carolina, LLC
Meagan Jolly, Wetlands & Waters, Inc.