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10 December 2024 Page 2 NCWRC Comments <br />Bully Self Storage <br />Orange County <br /> <br /> <br />should be surveyed for wetlands and streams to ensure there are no impacts to surface waters. <br />Furthermore, we offer the following preliminary recommendations with the intent to minimize impacts to <br />aquatic and terrestrial wildlife resources: <br />1. In the Section Vegetated Buffers (Page 6), the Applicant states they chose native plants species <br />for their vegetated buffers. However, Ilex cornuta (Dwarf Burford Holly), Ligustrum sinense <br />(Variegated ligustrum), Prunus laurocerasus (Schipka Luarel), Ilex crenata (Heller Holly), and <br />Thuja standishii (Green Giant Arborvitae) are non-native and/or invasive species. Avoid using <br />invasive, non-native plants in seed mixtures or landscaping plants <br />(http://www.ncwildflower.org/plant_galleries/invasives_list). Also, do not use non-native and/or <br />invasive species such as Sudangrass, Kobe lespedeza, lespedeza, tall fescue, or other non-native <br />species for temporary or permanent seeding. Alternatively, use grains, such as oats, wheat, or rye <br />for temporary cover and native seed mixes for permeant seeding. <br />A list of alternatives to non-native species has been attached. We recommend planting native, <br />wildflower seed mixes that will create pollinator habitat within the project boundary as well as <br />planting native trees and shrubs in landscaping. Native trees and shrubs can be found at native <br />plant nurseries throughout NC, and lists of native plants can be found https://ncwildflower.org/ <br />and https://nc.audubon.org/birdfriendlynativeplantslists. <br />2. Maintain a minimum 100-foot undisturbed, native, forested buffer along perennial streams, and a <br />minimum 50-foot buffer along intermittent streams and wetlands. Maintaining undisturbed, <br />forested buffers along these areas will minimize impacts to aquatic and terrestrial wildlife <br />resources, water quality, and aquatic habitat both within and downstream of the project area. <br />Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment <br />of pollutants associated with urban stormwater. <br />3. We recommend minimizing clearing of living, dying, or dead mature trees, particularly if they are <br />hardwoods, and avoid tree clearing activities during the activity period for tricolored bats (April 1 <br />– November 14), a state endangered and federally proposed endangered species. Any existing <br />culverts greater than 3 feet wide and bridges within or adjacent to the project should be surveyed <br />for bats within 15 days of construction. Surveys should be conducted in accordance with the <br />National White-nose Syndrome Decontamination Protocol and the U.S. Fish and Wildlife Service <br />Range-wide Indiana Bat & Northern Long-Eared Bat Survey Guidelines. <br />4. During heavy rains, the stormwater will still run off the roofs and compacted roads. We <br />recommend installing rain gardens or other bioretention structures to reduce water runoff and soil <br />erosion. Also, additional information on LID can be found at the NC State University LID guide: <br />https://www.uni-groupusa.org/PDF/NC_LID_Guidebook.pdf. NCWRC’s Green Growth <br />Toolbox provides information on nature-friendly planning <br />(http://www.ncwildlife.org/Conserving/Programs/GreenGrowthToolbox.aspx). <br />5. Consider using wildlife friendly outdoor lighting since light pollution can impact the circadian <br />rhythms of animals, disrupt behavior, cause injury, or death. Lights should only be on when <br />needed; use lights only where necessary; lights should have wavelength greater than 560 nm <br />emissions (i.e., narrow-spectrum LEDs or low-pressure sodium); mount the fixture as low as <br />possible; use the lowest wattage necessary; and lights should be fully shielded. <br />6. Erosion control matting made of plastic mesh or twine should not be used within the project area <br />because it can injure or kill wildlife. <br />Based upon the information provided, it is unlikely the project will adversely impact state protected <br />species or critical habitats. If I can be of additional assistance, please call (336) 269-0074 or email <br />olivia.munzer@ncwildlife.org. <br />182