20001195 Ver 17_WRC Comments_20200317

0 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
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TO: Davide Shaeffer
U.S. Army Corps of Engineers
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 17 March 2020
SUBJECT: Public Notice for the Charlotte Douglas International Airport Expansion
Individual Permit, Charlotte, Mecklenburg County, North Carolina. USACE
Action ID: SAW-2018-001071; DEQ No. 20191585.
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.).
On behalf of the City of Charlotte -Aviation Department, HDR has submitted an Individual
Permit application for the Charlotte Douglas International Airport (CLT) Expansion Project in
Charlotte, Mecklenburg County, North Carolina. CLT proposes to permanently impact 12,480
linear feet (If) of jurisdictional streams and 5.89 acres of wetlands, and temporarily impact 7841f
of streams. Projects that would impact waters of the U.S. include a deicing pad and south
crossfield taxiway; road realignments; stormwater in -line detention basins in Ticer Branch and
Coffey Creek; North End Around Taxiway; airport overlook relocation; private access drive; a
parallel runway and associated taxiway enhancement; and south ramp expansion.
We have no known current records of the federal or state rare, threatened, or endangered species at
or adjacent to the airport. Although we have no known current records of federally or state -listed
rare, threatened, or endangered species within or adjacent to the site, the lack of records from the
project area does not imply or confirm the absence of state -listed species. An on -site survey is the
only definitive means to determine if the proposed project would impact state -listed rare, threatened,
or endangered species.
We hesitate to agree with the amount of proposed impacts to the streams and wetlands. We have
the following recommendations for minimization and/or avoidance of impacts.
1. It is unclear as to why Duke Energy requires an exclusive driveway. The proposed impact is
207 If. The size of the impacts seems unnecessary for a small access road; please state the
reason for such a large culvert and why the existing culverts are not used. Figure 6-2 of the
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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17 March 2020
CLT IP Public Notice
USACE Action ID: SAW-2018-01071
Environmental Assessment (EA) shows an existing 54-foot 48" RCP already occurs near the
proposed crossing, and another culvert occurs upstream of the proposed stream crossing
near the proposed Private Access Drive.
2. We recommend the Old Dowd Road is relocated along Sears Road and then crosses the
railroad tracks further to the west in order to avoid impacts to waters of the U.S. If the road
cannot be relocated, we recommend reducing the length of the culvert to the greatest extent
possible.
3. Stream 25 is rated High according to NCSAM. The NCWRC prefers stream daylighting.
Rather than piping the stream, we suggest relocating the stream channel around the Deicing
Pad using natural channel design methods, if feasible. Stream daylighting can reduce the
risk of flooding, restore water quality and aquatic habitat, and reduce future costs associated
with repairing aging pipes.
4. With the information provided, we prefer the detention basins are off-line, especially since
the streams are rated High according to NCSAM. It is unclear on the effectiveness of these
in -line detention areas during higher flood events (i.e., 100-year flood) and the potential for
increased sedimentation, erosion, and water quality of the streams; the frequency and
intensity of flood events continue to increase with urbanization and climate change.
The EA indicates that stormwater quality treatment areas would be in upland areas; please
depict these on the figures as well as current stormwater detention areas. It seems that the
current stormwater detention areas could be expanded, or off-line detention areas could be
constructed in the forested areas near the streams.
5. We do not recommend burying RCBCs if slopes of culverts are greater than 2% due to
concerns of headcutting.
Should the permit be issued, we offer the applicant the additional general recommendations to
minimize impacts to aquatic and terrestrial wildlife resources.
1. 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.
2. Due to the decline in bat populations, avoid tree clearing activities during the maternity
roosting season for bats (May 15 — August 15).
3. Disturbed areas should be re -seeded with native seed mixtures. Avoid lespedeza and
fescue -based mixtures, which are nonnative and/or invasive. Native, annual small grains
appropriate for the season are preferred and recommended.
4. 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.

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17 March 2020
CLT IP Public Notice
USACE Action ID: SAW-2018-01071
Thank you for the opportunity to provide input for this project. If I can provide further
assistance or provide free technical guidance, please call [phone] or email
olivia.munzer&ncwildlife. orb.
cc: Alan Johnson, N.C. Division of Water Resources (NCDWR)
Todd Bowers, Environmental Protection Agency
Byron Hamstead, U.S. Fish and Wildlife Service
Sue Homewood, NCDWR
Kelly Thames, HDR