The URL can be used to link to this page

Home My WebLink About20200009 Ver 1_WRC Comments_20200203Strickland, Bev From: Munzer, Olivia Sent: Monday, February 3, 2020 4:42 PM To: Shaeffer, David Leigh (Dave) CIV USARMY CESAW (USA) Cc: Meagan Jolly; Johnson, Alan; Bowers, Todd; Hamstead, Byron (byron_hamstead@fws.gov) Subject: NCWRC Comments - The Parking Spot Waiver - Mecklenburg Attachments: NCWRC Comments - SAW-2016-00724 The Parking Spot - Mecklenburg.pdf Dave, Please see the attached comments. I included my questions/concerns that I emailed about last week into the letter. Thanks Olivia Munzer Western Piedmont Habitat Conservation Coordinator NC Wildlife Resources Commission Rogers Depot 1718 NC Hwy 56 W Creedmoor, NC 27522 Office: 919-707-0364 Cell: 336-269-0074 olivia.munzer@ncwildlife.org www.ncwildlife.org a 91 12 =2. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. 1 9 North Carolina Wildlife Resources Commission 0 Gordon Myers, Executive Director 03 February 2020 Mr. David Shaeffer U.S. Army Corps of Engineers Charlotte Regulatory Office 8430 University Executive Park Drive, Suite 611 Charlotte, North Carolina 28262 SUBJECT: Pre -Construction Notification for the Parking Spot - Charlotte, Mecklenburg County, North Carolina. USACE Action ID: SAW-2016-00724; DEQ No. 20190813. Dear Mr. Schaeffer, 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 Parking Spot, Wetlands and Waters, Inc. has submitted a Pre -Construction Notification (PCN) application for The Parking Spot — Charlotte located at 6210 Wilkinson Boulevard in Charlotte, Mecklenburg County, North Carolina. Unnamed tributaries of Ticer Branch in the Catawba River Basin flow through the site. In 2017, the applicant was approved to impacts 138 linear feet (If) of streams. The current application requests to permanently impact 2081f of streams, resulting in a total of 3461f of streams for the entire project. The applicant indicates the purpose and need of the project is to provide short- and long-term parking to meet the demand for parking facility services near the Charlotte -Douglas International Airport. We have no current records of the federal and state rare, threatened, or endangered species at or near the site. The lack of records from the site does not imply or confirm the absence of federal or state rare, threatened, and endangered species. An on -site survey is the only means to determine if the proposed project may impact federal or state rare, threatened, or endangered species. Based on the information provided in the PCN application, we hesitate to agree with the request for a waiver of the 300-foot limit on impacts to the stream. Please see the following questions or concerns regarding the project. 1. The applicant could build a parking deck or underground parking rather than impacting the streams for surface parking. Alternatively, impacts to the streams could also be avoided by developing a nearby parcel that could be serviced with the shuttle. Demand for airport parking is Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Page 2 03 February 2020 The Parking Spot USACE Action ID: SAW-2016-00724 likely to continue as the Charlotte region grows. A parking deck or alternative could fulfill the current and potential needs of the applicant while also minimizing or avoiding proposed and potential future impacts to waters. Additionally, the applicant could consider an exit/entrance onto the I-85 Service Road instead of building another road on the east side of the development. 2. According to the pre -application meeting, the parking facility was initially designed to maximize developable area, which would have required an Individual Permit. The applicant states that the current design allows for them to proceed under a Nationwide Permit; however, the cumulative impacts are greater than 3001f. 3. Prior to development in 2017, the area surrounding the stream was forested. The September 2017 aerial photographs show the parcel is cleared, except for the stream and a small buffer. Based on the NC SAM form and aerial photographs, The Parking Spot development in 2017 is likely the reason for the stream scoring as low quality in the NC SAM form. 4. Development impacts are occurring throughout North Carolina at unprecedented rates. Water quality issues already exist due to "sprawl" around urbanized areas. Increased population and development impacts are causing unmitigated loss of stream headwaters and forested ecosystems through "site stripping" practices that pipe and pave geologically and biologically functioning ecosystems without consideration of direct and indirect impacts to our environment. Placing fill in aquatic resources can alter hydrology, result in significant negative impacts to downstream areas, and eliminate aquatic and terrestrial wildlife habitat in Ticer Branch. Additional impervious surface results in an increase in stormwater runoff that can exert significant impacts on stream morphology. This will cause further degradation of aquatic habitat through accelerated stream bank erosion, channel and bedload changes, altered substrates, and scouring of the stream channel. In addition, pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed landscapes can adversely affect and extirpate species downstream. Intermittent streams play an important ecological and hydrological influence on downstream ecosystems by controlling the input of sediment, water, woody debris, and nutrients (Reid and Ziemer 1994). The unnamed tributary at the site is also a headwater stream. Headwater streams can significantly reduce nutrient export to rivers (Alexander et al. 2000; Peterson et al. 2001) and the condition of the stream in the lower reaches is closely dependent on the condition in the headwaters (Vannote et al. 1980). We have concerns regarding the direct and cumulative impacts on aquatic resources. Additional impervious surface results in an increase in stormwater runoff that can exert significant impacts on stream morphology and hydrology. This will cause further degradation of aquatic habitat through accelerated stream bank erosion, channel and bedload changes, altered substrates, and scouring of the stream channel. In addition, pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed landscapes can adversely affect and extirpate species downstream. Thank you for the opportunity to provide input for this project. If I can provide further assistance, please call (919) 707-0364 or email olivia.munzer(a'ncwildlife.org. Sincerely, Page 3 03 February 2020 The Parking Spot USACE Action ID: SAW-2016-00724 Olivia Munzer Western Piedmont Habitat Conservation Coordinator Habitat Conservation Program Literature Alexander, R. B., R. A. Smith, and G. E. Schwarz. 2000. Effect of stream channel size on the delivery of nitrogen to Gulf of Mexico. Nature 403:758-761. Peterson, B. J., W. M. Wollheim, P. J. Mulholland, J. R. Webster, J. L. Meyer, J. L. Tank, E. Marti, W. B. Bowden, H. M. Valett, A. E. Hershey, W. H. McDowell, W. K. Dodds, S. K. Hamilton, S. Gregory, and D. D. Morrall. 2001. Control of nitrogen export from watersheds by headwater streams. Science 292:86-90. Reid, L.M. and R.R. Ziemer. 1994. Evaluating the Biological Significance of Intermittent Streams. Accessed on 01 October 2019. Available at https://www.fs.fed.us/ps3y/publications/reid/21ntermitStr.htm U.S. Environmental Protection Agency. 2013. Streams. Accessed on 05 November 2019. Available at https:Harchive.epa.gov/water/archive/web/html/streams.html. Vannote, R. L., G. W. Mineshell, K. W. Cummins, J. R. Sedell, and C. E. Cushings. 1980. The river continuum concept. Canadian Journal of Fisheries and Aquatic Sciences 37:130-137. ec: Alan Johnson, N.C. Division of Water Resources Byron Hamstead, U.S. Fish and Wildlife Service Todd Bowers, U.S. Environmental Protection Agency Megan Jolly, Wetlands & Waters, Inc.