20190143 Ver 1_WRC Comments_20190306

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
06 March 2019
Mr. Thomas Perdue
MacConnell & Associates, PC
1101 Nowell Road, Suite 118
Raleigh, North Carolina 27607
SUBJECT: Pre -Construction Notification for the Lodges at Chapel Hill, Orange County, North
Carolina. USACE Action ID: SAW -2007-00939; DEQ No. 20190143.
Dear Mr. Perdue,
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.).
MacConnell & Associates, PC has submitted a Pre -Construction Notification (PCN) application for the
Lodges at Chapel Hill project in Chapel Hill, Orange County, North Carolina. The site is currently an
undeveloped wooded land in a low-density residential area. West Price Creek in the Cape Fear River
basin flows through the northern portion of the site. The project proposes to construct a road to the
planned neighborhood by crossing West Branch Price Creek with an aluminum box culvert. The project
would permanently impact 0.37 acre of wetlands and 60 linear feet of stream.
We have current records of the state endangered Savannah lilliput (Toxolasma pullus) within the watershed.
The lack of records from the project area does not imply or confirm the absence of federal or state -listed
species. An on-site survey during the appropriate survey period is the only definitive means to determine if
the proposed project would impact rare, threatened, or endangered species. An Orange County Open Space
occurs east of the project and the CPF/University Lake Aquatic Habitat Natural Heritage Natural Area occurs
downstream of the project.
We offer the applicant the following recommendations to minimize impacts to aquatic and terrestrial
wildlife resources.
Prior to construction, we are requesting surveys for state -listed mussel surveys within the
instream work area and 50 meters above and 100 meters below the work area. Any protected
species surveys should be conducted by biologists with both state and federal endangered species
permits. If state -protected species are found in the project area, the mussels should be relocated
to suitable habitat above the project area. Please immediately contact Brena Jones, the Central
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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USACE Action ID: SAW -2007-00939
Aquatic Wildlife Diversity Research Coordinator, at 919-707-0369 or
brenaJonesAncwildlife.org if protected mussel species are found during surveys.
2. 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.
The culvert must be designed to allow for aquatic life and fish passage. Generally, the culvert or
pipe invert should be buried at least 1 foot below the natural streambed (measured from the
natural thalweg depth). 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.
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.
Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be
professionally designed, sized, and installed.
4. Due to the decline in bat populations, avoid the removal of large trees at the site. Avoid tree
clearing activities during the maternity roosting season for bats (May 15 — August 15).
Additionally, we recommend avoiding clearing activities during the migratory bird nesting
season, roughly March to August.
5. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas and landscaping, including pollinator species. 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 (i.e., privet and nandina).
For a list of non-native species, visit http://www.ncwildflower.org/plant galleries/invasives_list.
6. 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. These measures should be

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The Lodges at Chapel Hill
USACE Action ID: SAW -2007-00939
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.
Thank you for the opportunity to provide input for this project. If I can provide further assistance or free
technical guidance, please call [phone] or email olivia.munzer cr,ncwildlife.org.
Sincerely,
C2�1-�
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Samantha Dailey, U.S. Army Corps of Engineers
Karen Higgens, N.C. Division of Water Resources
John Ellis, U.S. Fish and Wildlife Service