20130732 Ver 1_WRC Comments_20130815

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Amanda Fuemmeler, Asheville Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 15 August 2013
SUBJECT: Public Notice for Norfolk Southern Railway Company for Construction of an Intermodal
Facility at Charlotte International Airport, Charlotte, Mecklenburg County, North
Carolina. Corps Action ID #: SAW- 2013 -00433
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661- 667e),
and North Carolina General Statutes (G.S. 113 -131 et seq.).
The project has resulted in impacts to 1,807 linear feet of stream channel. In 2012, Norfolk
Southern began construction on the Charlotte Intermodal Facility (IMF) on property leased from
Charlotte Douglas International Airport under Department of the Army Section 404 Permit Number 2006-
32521 -360. The permit authorized placement of fill into 22,559 linear feet of streams, 1.148 acres of
wetlands, and 7.522 acres of ponds. In 2013, Norfolk Southern discovered approximately 1,807 linear
feet of stream channel within the project boundaries were not included in the impact area of the Airport's
permit. The purpose of the project is to meet interstate rail transportation demand, including demand for
rail/truck intermodal transportation in the Charlotte region. Norfolk Southern proposes a mitigation ratio
of 1:1, and will compensate for impacts by payment into the N.C. Ecosystem Enhancement Program.
Beaverdam Creek, Coffey Creek, and Ticer Creek in the Catawba River basin flow through the
project boundaries. According to information provided in the public notice, the impacted streams are first
order headwater tributaries and were identified as intermittent streams.
We are concerned this is an after - the -fact permit application; however, the project was
constructed in an area that has been highly impacted by the airport. Our primary concerns are that the
culverts were designed to provide aquatic life passage and stormwater from impervious surfaces are
sufficiently managed to minimize downstream degradation of water quality and aquatic habitat. Should
the permit be issued, we offer the following recommendations to minimize impacts to aquatic and
terrestrial wildlife resources.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Page 2
15 August 2013
Norfolk Southern Railway IMF
Corps Action ID No.: SAW- 2013 -00433
1. Culverts 48 inches in diameter or larger should be buried one foot into the streambed. Culverts less
than 48 inches in diameter should be buried to a depth equal to or greater than 20% of their size.
These measurements should be based on natural thalweg depths. Aquatic life passage should be
assured during low flow or drought conditions. Any riprap used should not interfere with aquatic life
movement during low flow.
2. Limit impervious surface to less than 10% of the site or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10 %. Trees and shrubs should be
planted around any stormwater detention ponds, excluding the dam. This would provide habitat
benefits that offset those functions lost by development, partially restore aquatic habitats, reduce
exposure of the water surface to sunlight to minimize thermal pollution, and provide essential summer
and winter habitats.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at (336) 449 -7625 or shari.baant(&ncwildlife.org.
ec: Karen Higgins, NCDWR
Alan Johnson, NCDWR