20040930 Ver 1_WRC Comments_20040608

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_K01 North Carolina Wildlife Resources Commission 0
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Amanda Jones, Permit Coordinator
Asheville Office, U.S. Army Corps of Engineers WETLANDS / 401 GROUP
John Dorney, Chief, 401 Certification Unit JUN O S 2004
NC Division of Water Quality
FROM: Ron Linville, Regional Coordinator WATER QUALITY SECTION
Habitat Conservation Program
DATE: June 7, 2004
SUBJECT: Individual 404 Permit, Action ID No. 200430969, Statesville Municipal Airport Runway
No. 28 Extension, Unnamed Tributaries Third Creek, Iredell County
The City of Statesville is requesting a letter of concurrence from the North Carolina Wildlife Resources
Commission (NCWRC) to obtain a 404 Individual Permit (IP) from the U.S. Army Corps of Engineers. It
is likely that a NC Division of Water Quality 401 Certification should be needed. The NCWRC has
reviewed information provided by the applicant, and field biologists on our staff are familiar with habitat
values of the project area. These comments are provided in accordance with provisions of the Clean Water
Act of 1977 (33 U.S.C. 466 et. seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661-667d).
Impacts are proposed to 1,128 linear feet of stream channels associated with the extension of Runway 28.
Roughly 796 linear feet of perennial stream will be culverted (Impact area 1) for the runway. Roughly 332
linear feet of perennial stream will be piped (Impact area 2) to relocate Airport Road (SRI 379). The road
relocation is necessary due to runway extension. These streams are considered intact ecosystems with wide
riparian buffers, stable bed/banks, and contain benthic macroinvertebrates. Previous jurisdictional water
impacts have occurred to 141 linear feet of an unnamed tributary of Back Creek (Impact area 3) for a
localizes airport antenna system. The applicant proposes to use Back Creek and other tributaries on the
airport property for mitigation. No mitigation plan is indicated. It is unknown who will move the state
road or if there may be unknown impacts or additional permits needed.
Aquatic and terrestrial habitats will be diminished due to the project impacts to streams, riparian corridors
and wooded areas. Wide riparian buffers provide substantial benefits to water quality. Forested buffers
provide aquatic habitat benefits and upland habitat values. Direct and indirect impacts should be
anticipated for this project due to loss of habitats and increased imperviousness. Information about
cumulative and secondary habitat impacts from urbanization can be found at
littp://Ai-NN-NN-.iicwildlife.org/pgO7 WildlifeSpcciesCon/pg7c3 impacts 0f.
Based on our review of the submittal and our knowledge of the area, we will not object to issuance of the
404 permit or 401 certification providing the following recommendations are included in the project and
project mitigation:

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Statesville Airport, 3 June 7, 2004
Runway 28
Piedmont Stormwater Pond and Mine Planting Recommendations
Instead of using the typical fescue grasses or exotic plant species, the following mixtures should be
considered for lower elevation stormwater ponds and mine sites:
Spring/Summer Mixture, May 1- Sept. 15 Fall/Winter Mixture, Sept. 15 - April 30
Statesville Airport, 2 June 7, 2004
Runway 28
1. Prior to issuance of any permits/certifications, the alternative of relocating the perennial
streams and their associated buffers should be thoroughly investigated. Any relocated streams
must be accomplished using state-of-the-art bioengineering design and construction standards.
2. If stream relocation is not an option, a mitigation plan should be provided to and approved by
resource/regulatory agencies prior to 404 and 401 issuance. The mitigation plan should meet
minimum mitigation requirements for the US Army Corps of Engineers and the NC Division
of Water Quality. If degraded streams are present in the area that can be successfully
restored, the streams and wide undisturbed buffers should be restored. Lost
riparian/floodplain woodlands and buffers should be fully mitigated on a minimum acre per
acre basig.
3. Proposed stream mitigation/restoration activities must meet state-of-the-art bioengineering
design and construction standards. Mitigation should be in-kind and in the same subbasin.
4. Stream buffers and woodland mitigation areas should be permanently protected through deed
restrictions, conservation easements, or other legal methodologies.
5. Stormwater management from increased impervious roadway and runway areas must be
provided to maintain pre and post hydrographic conditions to the maximum extent possible.
Low Impact Development (LID) techniques are reconunended and encouraged. Information
on LID practices and measures can be found at A%NN Nc IoNN impactdet-elopment.orQ. If
stormwater ponds or stormwater wetlands are needed, the attached plant recommendations
should be considered during stormwater management planning activities.
6. To the extent practicable, only native indigenous plant species should be used for the project.
7. If piping must occur, culvert lengths should be kept to the minimum possible. Culverts 48
inches diameter or larger should be buried a foot into the streambed. Culverts less than 48
inches diameter should be buried to a depth equal to or greater than 20% their size to allow
for aquatic life passage. These measurements must be based on natural thalweg depths.
8. Due to the large size of the project, stringent erosion control measures should be installed
where soil is disturbed and maintained until project completion. Building the project in
phases and stabilizing and vegetating each phase prior to additional disturbance is preferred.
Thank you for the opportunity to review and comment on this project. If you have any questions regarding
these comments, please contact me at 336/769-9453.
Attachment: Piedmont Stormwater Pond and Mine Planting Recommendations
Cc: Alan Johnston, DWQ-MRO
Sarah McRae, NHP
Marella Buncick, USFWS-Asheville
Denise Moldenhauer, USFWS-Asheville
Marla Chambers, WRC