20010263 Ver 1_COMPLETE FILE_20010316

City
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Water Resources Administration
16ID63
October 17, 2001
Mr. S. Kenneth Jolly
U.S. Army Corps of Engineers
Attention: Mr. John Thomas
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road
Raleigh, NC 27615
D
Re: Regulatory Division Action ID No. 200120540 -
Greensboro Stormwater Treatment Wetland
Dear Mr. Thomas:
This letter is in response to your letter of October 1, 2001 concerning Regulatory Division
Action ID No. 200120540. We are providing below the City of Greensboro (City)'s responses to
the concerns discussed in your letter, for your consideration.
a. Alternatives Analysis:
City acknowledges that the 555 upland BMPs (stormwater ponds or wetlands) upstream of
intermittent streams or 238 BMPs in the intermittent stream reaches are not fully comparable
with the proposed stormwater treatment wetland project to provide a similar level of water
quality treatment benefits. A more appropriate number of upland BMPs in the areas
upstream of intermittent streams, to provide benefits comparable to the proposed 20-acre
wetland, would be 90 based on a typical drainage area of 15 acres (as stated in our June 1,
2001 letter) and a BMP surface area to drainage area ratio of 1.5% required for a 50%
impervious catchment.
The surface area of BMPs in the upland BMPs would only be about 0.22 acre (1.5% of 15-
acre drainage area) rather than 1 acre suggested by the EPA, and 90 of them would be needed
to be comparable with a 20-acre wetland. The estimated cost of the 90 BMPs would be,
therefore, about $7,200,000 rather than the $2,400,000 suggested by the EPA in their letter.
If BMPs located in the intermittent stream reaches are considered, the typical drainage
area (as stated in our June 1, 2001 letter) is about 35 acres requiring a BMP surface area
(1.5% of drainage area) of about 0.5 acre. To provide benefits comparable to the proposed
20-acre wetland, 40 BMPs would be needed. At a unit cost of $150,000, the cost of the
BMPs in the intermittent reaches would be $6,000,000.
Another way of looking at the number of BMPs required in the upland areas would be to
consider the number required to fully treat a combined drainage area equal to the total
drainage area of 1,333 acres that can potentially be fully treated (based on a ratio of 1.5%
ratio of BMP surface area to the drainage area) by the proposed 20-acre wetland. It means
773 P.O. Box 3136 • Greensboro, NC 27402-3136 • Telephone [phone] - Fax [phone]
that about 90 BMPs treating 15-acre catchments (upstream of intermittent streams) or about
40 BMPs treating 35-acre catchments (in the intermittent stream reaches) would be needed to
match the 1,333 acres that could be fully treated by a well-designed 20-acre off-line wetland.
The estimated unit costs of $80,000 and $150,000 for BMPs are for 15-acre drainage area
(0.22-acre BMP) and for 35-acre drainage area (0.5-acre BMP) respectively, including the
cost of undeveloped land required for the BMP. If the land is developed, as it typically is in
the South Buffalo Creek watershed, the costs would be significantly higher due to the higher
value of the properties and the need for some demolition and disposal work to make the
property suitable for BMP retrofits.
It can be seen from the above analysis that the minimum cost of providing upland BMPs in
the highly urbanized South Buffalo Creek watershed would range between $6,000,000 and
$7,200,000. This is significantly (6 to 7.2 times) higher than the cost of the City's proposed
off-line stormwater treatment wetland project. Due to the high cost of this alternative and the
extreme difficulty, if not impossibility, of acquiring as many as 90 sites (with multiple private
owners at each site) at the right locations (right drainage area and right topography for BMP
development) in the highly developed watershed makes the upland BMPs alternative
economically prohibitive and administratively impractical to implement.
We wish to reiterate a comment we made in our earlier letter of response dated June 1, 01
regarding BMPs in intermittent stream reaches. In addition to the prohibitively higher cost
and administrative nightmare of acquiring multiple sites with multiple property-owners at
each site, intermittent streams would likely be deemed to be jurisdictional waters of the US,
thus requiring multiple time-consuming regulatory permits and certifications for the multiple
BMPs at separate locations. We believe that one larger project in a strategic and practical
location is much more desirable and practical to implement and maintain.
We also wish to bring to your attention the fact that 83% of the cost of the proposed project is
being funded with a grant from the North Carolina Clean Water Management Trust Fund
(CWMTF). North Carolina and the CWMTF are committed to fund sound projects that
protect and improve water quality. Further, the State's Division of Water Quality has issued
its 401 Water Quality Certification for the proposed project indicating their agreement with
this innovative approach for urban watersheds like South Buffalo Creek.
As a condition in the Agreement for the CWMTF funding for the project, a permanent
conservation easement for the wetland BMP facility would be deeded to the State. If multiple
BMPs were to be developed instead of one larger one, the multiple conservation easements
required would present a significant administrative problem for the City and the State. In
addition, maintenance by the City of one or a few larger BMPs would be much more
manageable and practical than a multitude of small BMPs scattered over the watershed.
b. Compliance with NPDES MS4 Permit:
The City of Greensboro has implemented and continues to implement a comprehensive and
exemplary program of urban stormwater quality improvement under its NPDES Municipal
Separate Storm Sewer (MS4) Discharge Permit, since the beginning of the permitted program
on December 30, 1994. The MS4 permit issued by the North Carolina State requires the City
to implement programs aimed at improving the stormwater quality to EPA's "maximum
extent practicable (MEP)." While there are no numerical water quality standards
specified in the permit for the City's stormwater discharges, the City has responsibly and
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proactively addressed EPA's MEP standard. The City has been and is making significant
efforts through its Stormwater Management Program to minimize pollution of stormwater
runoff at its source in concert with enhancing water quality in streams through the installation
of various types of BMPs. The major elements of the program that have been and are
being implemented as a part of the City's initiatives to minimize pollution of the
stormwater discharges to "the maximum extent practicable," to meet the requirements
of the NPDES MS4 Discharge Permit are:
• Comprehensive Inventory of the Stormwater Conveyance Systems (storm sewers and
open streams, both natural and manmade) in the City jurisdictional areas, to facilitate
tracking of pollutants, drainage system master planning, and BMPs.
• Public Education program to raise the awareness of citizens about the pollution of
stormwater and the steps the citizens could take to minimize the pollution.
• Identification and Disconnection of Illicit Connections of non-stormwater sources of
pollution to receiving waters.
• Street Sweeping and Cleaning Operations to keep litter and trash from running off into
the storm sewer systems and to respond to and assist in the cleaning of automotive-
related spills before they runoff into the stormwater conveyance system.
• Loose Leaves Collection program in the fall season to prevent excessive organic loading
of the streams with leaves.
• Erosion and Sediment Control program to minimize the runoff of construction-related
sediment into streams.
• Implementation of a new citywide Stream Buffer Ordinance to maintain vegetated
stream buffers along streams during development of properties.
• Water Quality Monitoring at the end (outfalls) of selected storm sewer pipes
representative of drainage from various land uses, to monitor the water quality and assist
with BMP selection.
• Stream Corridor Reforestation program to develop vegetative buffers along streams
located within City properties, and Stream Restoration program to restore streams in
City properties to natural conditions including vegetative buffers to minimize pollution
including channel erosion.
With the implementation of the comprehensive program of initiatives listed above, the City
strongly believes that it has successfully complied with the requirements of the NPDES MS4
Stormwater Discharge Permit. In support of this claim, we are attaching herewith a copy of a
letter from Mr. Bradley Bennett, permit administrator of the North Carolina State Division of
Water Quality, to Mr. John Thomas of the Corps of Engineers. The letter testifies to the
effective compliance achieved by the City's Stormwater Program with the State's
requirements.
In spite of the aforementioned initiatives implemented by the City, monitoring of the water
quality at the representative storm sewer outfalls (end of pipe) indicates the existence of some
pollutants in the stormwater that is inherent in urban runoff, as also was found in EPA's
NURP study. It is with the intent to further minimize the pollutants carried by the uban
runoff and per the MEP standard, that the City has been planning to implement regional off
line BMPs at selected strategic locations in the watersheds to remove the pollutants from
stream flows. The proposed Stormwater Treatment Wetland project for South Buffalo Creek
is planned to be one of such BMPs. We also invite you and the EPA to visit our expansive
Stormwater Management Internet web site at www.ci.greensboro.nc.us/stormwater for more
information on our local programs.
c. Off-line treatment systems in the floodplain:
We respectfully submit that the proposed wetland project is designed to function as an
off-line treatment system. The treatment is designed to take place in the floodplain of South
Buffalo Creek wherein a riverine wetland environment will enable treatment of the
stormwater conveyed by the creek. The design of the water level control gate proposed to be
installed in the bottom of the stream channel is intended to avoid the undesirable features of
an on-line treatment BMP. The gate is expressly designed not to be a fixed structure
permanently backing up water in the stream. It will be a unique bottom-hinged gate that will
be raised only for short time periods when rainfall occurs, to divert the stormwater in the
stream to the off-line treatment wetland on the floodplain. Following the key function of
diverting the initial stormwater runoff on to the floodplain, the gate will be automatically
lowered to lay flat at the stream bottom level offering no obstruction to the stream flow,
essentially leaving the natural regime of the stream unchanged. This innovative system will
effectively reconnect the stream with its floodplain, and thereby promote improved water
quality based on natural treatment mechanisms.
The other type of off-line treatment systems suggested by the EPA and referenced in your
letter would involve hundreds of small BMPs at the storm sewer outfalls and small natural
stream tributaries (likely to be waters of the US). For reasons similar to the upland BMPs
discussed in item a. above, acquisition of the multiple properties and the construction costs of
the large number of BMPs would be administratively impractical and cost-prohibitive.
Furthermore, unless the off-line BMPs are provided at all the sewer outfalls including those
along all stream tributaries (waters of the US), only a limited fraction of the total runoff from
the watershed can be captured and treated on the floodplain of the main South Buffalo Creek.
To provide a perspective of the problem, there are 118 storm sewer outfalls along the South
Buffalo Creek (excluding its tributaries) from the head of the stream up to the location of the
proposed project, where BMPs would need to be provided. Cost estimates for these BMPs,
based on similar considerations as for the upland BMPs, would be of the order of $9,440,00
assuming a low average unit cost of $80,000 (including property acquisition) per BMP at the
outfall of pipes that range in size from. 12 to 66 inches. The cost of BMPs on small stream
tributaries contributory to the South Buffalo Creek would be an additional significant cost.
In this context, we would like to add that the City, in fact, is very open in its comprehensive
planning to the concept of providing BMPs at the storm sewer outfalls on the floodplains of
creeks, wherever it is cost-effective and practical. For example, the City is now actively
considering the provision of wet pond or wetland BMPs at selected storm sewer outfalls on
the floodplain properties that the City owns (as a part of its greenway corridor system) along
the North Buffalo Creek. Since the City owns these properties, the cost of the BMPs would
be much less than those that could potentially be provided along the South Buffalo Creek (as
the EPA is suggesting), where the private properties would have to be acquired from the
owners at a significant cost. The City is planning to apply, in December 2001, for an
additional partnering grant from the North Carolina Clean Water Management Trust Fund to
help finance the provision of BMPs at selected storm sewer outfalls on the North Buffalo
Creek. Since these properties are City-owned, it is our understanding from the Clean Water
Management Trust Fund that the process of required conservation easement is much simpler
than if private properties are involved.
Concerning the feasibility of providing an "off-line treatment pond" on the floodplain of the
South Buffalo Creek at the proposed project site, suggested in EPA's letter, it should be noted
that the wide floodplain on the north side of the creek does not receive runoff from any storm
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sewer system or a stream tributary. It receives only local runoff from the adjacent Interstate
40 and its embankment. Hence no significant stormwater runoff can be treated with such a
facility. Similar situations exist in floodplain areas along several other segments of the creek,
where development-free floodplain areas may be seen from aerial photos or maps as stated in
the EPA's letter.
d. Additional Comments:
The site of the proposed project is currently zoned for light industrial land use. If the
proposed water quality improvement project is not implemented at this site, the resulting "no
action" option effectively means continued urbanization along this section of the stream and
floodplain. The result would be additional degradation of the stream water quality and
impacts to the existing jurisdictional wetlands due to the additional urban industrial
development. The City believes that the proposed project will not only preempt such urban
development and associated adverse impacts to water quality in this location, but also would
provide the opportunity to develop the site as a nature park with environmental education
facilities that the City intends to add in the next phase of the project. The overall result of the
project would be to significantly enhance the aquatic and terrestrial life in the stream corridor
environment and to provide environmental education to the City's residents.
We would be pleased to meet with the Army Corps of Engineers and the EPA to answer any
additional questions or to discuss the above responses in more detail. The City shares the
same goals as the Corps and EPA to protect the water resources, enhance water quality, and
restore degraded urban streams.
We appreciate your consideration of the City's responses provided above and issuing the
required Section 404 permit at your earliest convenience. Thank you.
Sincerely yours,
CITY OF GREENSBORO
Stormwater Management Division
LOS
Scott D. Bryant, M.S., P.E., NSPE
Manager & Chief Engineer
AM- National Society of
Professional Engineerse
Signatory, NSPE Licensed Member
Cc: John Dorney, NC Division of Water Quality
Bradley Bennett, NC Division of Water Quality
Allan Williams, P.E., City of Greensboro, Department of Water Resources
Ann Mayson, J.D., City of Greensboro Legal Department
Shastri Annambhotla, Ph.D., P.E., City of Greensboro, Stormwater Management
Tori Small, P.E., City of Greensboro, Stormwater Management
David Phlegar, City of Greensboro, Stormwater Management
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Michael F. Easley
Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
October 16, 2001
John Thomas
Raleigh Regulatory Office
US Army Corps of Engineers
6508 Falls of the Neuse Road, Suite 120
Raleigh, NC 27615
Subject: South Buffalo Creek Stormwater Wetland Project - Greensboro, NC
Dear Mr. Thomas:
The City of Greensboro is working with your office and EPA Region 4 on the above referenced project. In this
review process it is our understanding that the Corps of Engineers and the EPA have requested information
concerning the City of Greensboro's compliance with their stormwater NPDES permit (NCS0000248). As the
agency responsible for administering this permit, the City has requested that we provide you with input on their
permitted activities under this program.
The City of Greensboro has been covered under a NPDES stormwater permit since December 1999. This permit
requires the implementation, by the City, of a comprehensive stormwater quality management program. This
program includes components for public education and outreach, illicit discharge detection and removal,
construction site runoff control, stormwater control for commercial, residential and industrial areas, and monitoring
and inspection activities to support the overall program. The City of Greensboro has effectively implemented all of
these stormwater programs and continues to enhance their stormwater activities toward the stated NPDES goal of
controlling pollutants discharged to the maximum extent practicable. We feel that the City has established a very
proactive program for stormwater management and does an effective job of prioritizing activities and efforts to
protect and enhance water quality through their programs.
Our assessment of the City's overall NPDES stormwater program is that they are in compliance with the conditions
of their permit and the City's programs continue to be innovative and effective in stormwater management and
water quality protection. If you have any questions or need additional information, please feel free to contact me at
[phone] ext. 525.
Sincerely,
original signed by Bradley Bennett
Bradley Bennett
Stormwater and General Permits Unit
Cc: Scott Bryant, Greensboro Stormwater Management
John Dorney, DWQ Wetlands Unit
Corey Basinger, DWQ Winston-Salem Regional Office
D
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
1 800 623-7748
REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
October 1, 2001
Regulatory Division
Action ID No. 200120540
Mr. Scott Bryant
City of Greensboro
Stormwater Management Division
Post Office Box 3136
Greensboro, North Carolina 27402-3136

a e !_ . ._

Dear Mr. Bryant:
By public notice of March 13, 2001, we announced your application for a Department of
the Army permit to authorize the discharge of fill resulting in impacts to approximately 0.23 acre
(including approximately 150 linear feet of stream habitat) of the jurisdictional waters of South
Buffalo Creek. This discharge of fill is associated with plans for the proposed construction of a
stormwater treatment wetland system located off of Rehobeth Church Road and the intersection
of I-40 and Freeman Mill Road, in Greensboro, Guilford County, North Carolina.
After review of your alternatives analysis submitted on August 20, 2001, the U.S.
Environmental Protection Agency (EPA) responded by letter dated August 20, 2001, a copy of
which is enclosed for your consideration and response. The EPA continues to request denial of
your permit request, specifically with regards to the following concerns:
a. The alternative analysis you provided is not appropriate because the referenced
alternatives are not comparable to the proposed South Buffalo Creek stormwater project. In the
analysis, the project is compared to treatment for the entire 13 square mile upstream basin. The
alternative of constructing 555 upland ponds or 238 ponds in intermittent streams will achieve
significantly different levels of water quality treatment and flood reduction than the proposed 34-
acre in-stream treatment area. The EPA suggested that comparable projects would include
construction of 30 upland storm ponds or wetlands. Of course, this makes a big difference in the
economic and practicality of a high ground alternative to the project (i.e. estimated 2.4 million
dollars for a comparable project as opposed to 44.0 million dollars as you suggested for treatment
of the 13 square mile upstream basin).
b. The City of Greensboro (City) is currently operating under an existing National
Pollutant Discharge Elimination System (NPDES) MS4 permit. The EPA requested information
that demonstrates an acceptable level of compliance for the discharges in the South Buffalo

Printed on 9 Recycled Paper
Creek watershed with the city's NPDES MS4 permit and with the North Carolina (State)
environmental standards. It is their contention that if the discharges into South Buffalo Creek are
not in compliance with the existing MS4 permit or State standards; then the violations should be
corrected at the point of the discharge. These violations should be brought into compliance
before there is any discussion of downstream stormwater treatment located within waters of the
United States.
c. The EPA states, with reference to information that they have on the South Buffalo
Creek basin, that there is undeveloped acreage within the floodplain of the basin. Floodplain
acquisition and the use of well-planned, off-line systems is an alternative to the proposed project.
The EPA states that they have not received adequate information that this is not a practical
alternative.
In summary, the EPA continues to recommend that your permit be denied. We share the
concerns of EPA regarding alternatives, and acknowledge that these concerns have not been
satisfactorily addressed. We believe that you have not provided sufficient information to support
your determination that there is no less damaging alternative that could meet the project's
purpose and need (i.e., treat the "first flush" of stormwater from upstream), and accordingly, the
project does not comply with the Section 404(b)(1) Guidelines.
Your response to the concerns discussed above should be forwarded to us by
October 16, 2001. A copy of your response should be sent to the North Carolina Division of
Water Quality to enable them to adequately evaluate your application for a Water Quality
Certification pursuant to Section 401 of the Clean Water Act.
If you have questions, please do not hesitate to contact Mr. John Thomas, Raleigh
Regulatory Field Office, Regulatory Division, telephone [phone].
Sincerely,
S. Kenneth Jolly
Chief, Raleigh Regulatory
Field Office
Enclosure
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Copies Furnished:
Mr. William L. Cox, Chief
Wetlands Section - Region IV
Water Management Division
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
Mr. John Dorney
NCDENR
Division of Water Quality
Wetlands / 401 Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Dr. Garland Pardue
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, North Carolina 27636
Mr. Todd Ball
E.C.E.C., Inc.
4016 Wood Valley Drive
Aiken, South Carolina 29803
Ms. Chrys Baggett
State Clearinghouse
1302 Mail Service Center
Raleigh, North Carolina 27699-1302
Ms. Danielle Pender
North Carolina Wildlife Resources Commission
1142 I-85 Service Road
Creedmore, North Carolina 27615
Cit3
June 1, 2001
US Army Corps of Engineers
Attention: Mr. John Thomas
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road
Raleigh, NC 27615
RE: Regulatory Division Action ID No. 200120540
Dear Mr. Thomas:

This letter is in response to your letter of May 10, 2001 concerning the City of Greensboro's
application for 404 Permit for Stormwater Treatment Wetland project in Greensboro -
Regulatory Division ID No. 200120540. We are submitting the City of Greensboro (City)'s
responses as follows. The numbering of the responses below corresponds to the numbering (a, b,
c etc.) of comments made in your letter to facilitate your review.
(a) Alternatives Analysis: City has conducted, during the last two years, a careful and
comprehensive analysis and evaluation of alternative options for improving water quality in
South Buffalo Creek. As a part of the City's initiatives, City has completed in November
2000, through its consultant Dewberry & Davis, Incorporated (DDI), a "Stormwater Master
Planning" study project covering most of the South Buffalo Creek watershed to identify
options for achieving improvements in stream water quality and water quantity (flood peak)
controls. The City is, in fact, currently pursuing several complementary approaches to
achieve improved water quality in various streams in the City in general and in South Buffalo
Creek in particular. These include:
1. Alternatives to Proposed Project: The "Stormwater Master Planning" study cited above
has identified two potential options, in addition to the subject South Buffalo Creek .
wetland project, for water quality BMPs in the South Buffalo Creek watershed. Attached,
for your information, is a key map (Exhibit 1) and a tabulation (Exhibit 2) of identified
BMP sites excerpted from the study report. (If you desire additional information from the
report, we will be glad to furnish them for your information and review).
As you may see from the tabulation, two water quality BMP options, in addition to the
subject project, are identified. They are: (1) Retrofit of existing Hungry Fisherman Lake
on the South Buffalo Creek near Norwalk Street (receiving drainage from the upper 5.7
square miles), and (2) An in-stream water quality/flood control pond on Twin Lakes
Tributary of South Buffalo Creek at a location where the drainage area of the Twin Lakes
sub-watershed is 560 acres. While these are options for water quality BMPs, they
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realistically are not alternatives to the proposed project. Rather, they potentially
complement the functions of the proposed project, since the proposed wetland area is
only 20 acres which is small relative to the drainage area (13 square miles) at the project
site. Additional BMPs in the upstream areas of the watershed, supplementing the
proposed project, would be required to effectively improve the quality of the large
volume of stormwater runoff from the 13 square miles. City has carefully considered the
two additional BMP projects as potential complementary elements in the comprehensive
plan for improving water quality in South Buffalo Creek. At this time, however, City
cannot act on either of them for the following reasons. The Hungry Fisherman Lake, a
flood detention lake believed to have been built in the 1970s and now heavily silted up, is
being considered by the Piedmont Triad Airport Authority as potential wetland
development site for mitigating the wetland loss associated with the proposed
construction of a third runway (for the proposed FedEx facility). The retrofit is expected
to provide about 10 acres of additional wetlands. If the Airport Authority proceeds with
the development of the wetland, it would still serve the City's intended function of water
quality improvement in South Buffalo Creek. City has conveyed its desire to the Airport
Authority through its consultant to participate in the development of an optimal facility
retrofit design to achieve water quality improvement in the stream and some flood
detention (to reduce the flood peak and associated downstream stream erosion). City
considers that implementation of the pond BMP on the Twin Lakes Tributary by the City
is impractical, because the privately-held Koury Corporation that owns the property on
which the pond would potentially be located is currently planning to implement a stream
restoration and wetland development project at that site. The wetland and stream
restoration is planned as mitigation for stream and wetland impacts caused by a different
project of Koury in a proximate area. Again, Koury's proposed stream restoration and
wetland project would serve to improve the water quality in the Twin Lakes tributary and
thereby contribute to the improvement in the South Buffalo Creek water quality.
As part of the Stormwater Master Planning study, City has also studied the feasibility of
alternative BMPs in the upland areas in the watershed. Information on the streams, storm
drainage infrastructure, and planimetrics of the City (obtained from year 2000 mapping
and infrastructure inventory) were used in the evaluation. A copy of the map showing
these features in the South Buffalo Creek watershed is enclosed as Exhibit 3 for your
review and information. As you may appreciate from the Exhibit 3, the nearly built-out
condition in the highly urbanized South Buffalo Creek watershed does not allow adequate
space for the numerous small BPMs that would be needed in the upland areas to treat the
urban stormwater runoff over the full watershed. However, to evaluate all potential
alternatives, we have examined two different scenarios for locating BMPs in the upland
areas of the watershed, as alternatives to the proposed project (to be supplemented in
phases by additional regional projects in the watershed such as the potential retrofit to the
Hungry Fisherman Lake):
The first potential alternative is to provide water quality BMPs (ponds or wetland
treatment facilities) in the upland areas upstream of intermittent streams only to
minimize effects on the regulated waters. The drainage area at the head of an intermittent
stream typically is between 5 and 40 acres in the Greensboro area. This estimate (with an
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average value of 15 acres) has been confirmed in a sampling of data obtained in a stream
classification study of the Horsepen Creek watershed recently completed by the City with
involvement from the State Division of Water Quality and researchers at North Carolina
State University. A BMP located at such a point on the stream would therefore be able to
treat stormwater runoff from a relatively small area. A catchment (or drainage) area of 15
acres for a typical potential BMP in the most upland areas in the watershed is used in this
analysis. The number of such BMPs required in the upland areas to provide water quality
treatment for the same drainage area as the 13 square mile (8,320 acres) drainage area at
the proposed project site would, therefore, be (8,320/15) = 555. As can be appreciated
from an examination of the attached map of the South Buffalo Creek watershed, such a
large number of sites are not available in the nearly built-out watershed without acquiring
numerous properties and demolishing many existing structures. The cost of each of these
BMPs, including the property, and the construction cost including mobilization and
demobilization by the construction contractor, is estimated at $80,000. The estimated
total construction cost for the 555 BMPs would be $44 million, an exorbitant cost
compared to an estimated $2 million for two innovative regional BMPs (including
$1 million for the current project and an additional $1 million for an additional regional
BMP such as retrofitting the Hungry Fisherman Lake). Even if properties were available,
acquiring such a large number of properties in any reasonable period would be next to
impossible, apart from the massive disruption caused to the multitude of property owners.
In addition, there would very likely be a fair acreage of wetlands that would be impacted
by such a large number of BMPs. Long-term maintenance of these BMPs by the City
would be extremely expensive and unmanageable. In light of the above considerations,
this alternative is not considered a practical one.
The second potential alternative examined was to locate the BMPs in the intermittent
stream portions of the upland areas. In Greensboro, the drainage area at the downstream
end of an intermittent stream (head of perennial stream) typically is between 20 and 50
acres with an average of 35 acres, also confirmed in a sampling of data in the stream
classification study by the City. The number of BMPs required to treat stormwater runoff
from individual drainage areas of an average 35 acres, for treating runoff from 13 square
miles is (8,320/35) = 238. Estimated cost of the 238 BMPs, based on an estimated
$150,000 per BMP, would be approximately $36 million, again an exorbitant cost
compared to the two innovative regional facilities. This alternative has the same
disadvantages as the first one above. Additionally, it would also result in impacts to
considerable length of regulated (intermittent) streams and adjacent wetlands. Because of
topographic limitations (generally rolling terrain) in the upper reaches of watersheds in
Greensboro, the upland BMPs would most likely be permanent wet detention ponds, each
impacting an estimated 300 feet of stream length. The 300 feet of impacted stream length
is based on a 230 feet segment of stream inundated in the pond and an additional 70 feet
required for the pond structure and some grading at the head of the pond. The estimate of
230 feet is based on pond area/drainage ratio of 1.73% required for a 50% built-upon area
watershed according to NC State's guidelines for water quality wet ponds, and a 2:1
length/width (aspect) ratio of the pond surface. The estimated total stream length
impacted due to 238 ponds would, therefore, be (238000) = 71,400 feet, which is several
times that of the stream length in the proposed project. The proposed regional wetland
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project, in contrast, does not involve permanent inundation of the stream or significant
changes to the regime of the stream channel because of the unique design of the proposed
water level control gate.
It should also be noted that in either of the two alternatives discussed above, the
stormwater runoff from the entire 13 square mile drainage area cannot be physically
captured in upland BMPs, because some drainage areas adjacent to perennial streams
would drain directly to the perennial streams as non-point diffuse flow. Hence, it is
realistically not possible to capture and treat in upland BMPs the entire runoff from the
heavily urbanized 13 square mile drainage area.
Based on the above analyses, City has concluded that both the above alternatives are
unrealistically expensive and more environmentally damaging and disruptive to the
community in comparison with the proposed innovative project. Therefore, the
alternatives are not considered as viable and superior to the currently proposed project.
City respectfully submits that we have demonstrated, with supporting detailed
quantitative information (provided above), that the proposed proiect is the least
environmentally damaging and most practicable alternative.
2. Stream restoration projects in degraded segments of streams. These projects are
expected to significantly reduce sediment and associated pollution in streams. City has
and is exploring all avenues for implementing stream restoration projects. Through NC
Department of Transportation's stream mitigation program, two stream restoration
projects have already been completed and an additional one is in progress in the South
Buffalo Creek watershed. Seven additional projects, including four in South Buffalo
Creek watershed are currently in planning and design phases of implementation through
the North Carolina Wetland Restoration Program agency.
3. Establishment of streamside vegetative buffers for up to 50 feet on each bank. City's
current phase of a major buffer re-establishment project includes 32,054 linear feet of
streams in the South Buffalo Creek watershed as a part of 57,700 linear feet of various
streams in the City. The vegetative buffers would include deep-rooted shade trees along
the stream to stabilize the stream banks and provide shade to the waters in the stream,
both of which would significantly enhance the water quality and aquatic and terrestrial
habitat in the stream corridor. Additional buffer establishment along more stream .
segments is planned for the future. These improvements are a part of the City's overall
plans and initiatives to control stream pollution and improve water quality.
4. Ordinance requiring buffers in new developments has been put in place by the City to
protect streams and their water quality. This existing stormwater management ordinance
requires that new property developments provide vegetative buffers along all perennial
streams in the city. The width of the buffers is 50 feet from the top of each bank for
streams other than those in the water supply watersheds. The buffer requirements for
streams in the water supply watersheds are even more stringent and up to 100 feet.
4
Based on the above alternatives analysis and City's additional initiatives, we believe that we
have demonstrated that the proposed project offers the greatest value to enhancing the
stream water quality with the least amount of environmental damage among the
options available at this time, given the existing conditions in the highly urbanized South
Buffalo Creek watershed.
(b) Minimization of Wetland Losses: In developing plans and designs for the proposed project,
City made special efforts to minimize wetland losses. As one of the first tasks in the project,
City had the existing wetlands on the project site delineated as a part of the field survey by
City's wetland consultant, The Triangle Group. One of the main objectives of the delineation
was to avoid or minimize the impact to the existing wetlands in planning for and designing
the project elements. In designing the plan layout of the constructed features such as the
water control structure and earth berms, special steps were taken to minimize their
encroachment on the small wetland areas that were in the proximity of those structures. Also,
the streamside shallow berms are laid out in such a way that the construction involved in
building those would not cause any disturbance, such as incidental filling, in the adjacent
main wetland bodies. Construction specifications will also be written to help ensure that the
existing wetlands would not be impacted.
As for using the existing wetlands for treating stormwater (water flowing in the creek), we
respectfully suggest that the contribution of the existing wetlands to the treatment of
stormwater carried in the stream is not significantly different from the natural conditions that
typically exist in a riverine system, wherein the wetlands in the floodplain treat stormwater
runoff by removing pollutants before the water is carried downstream in the stream channel.
If the South Buffalo Creek were not historically straightened and deepened, the floodplain
wetlands adjacent to a much shallower stream channel that used to exist would have been
treating the stormwater much the same way as in the proposed project, although in a more
natural manner.
The proposed project would also serve to foreclose potential commercial/light industrial
development (for which the property is currently zoned) in the floodplain area adjacent to the
existing wetlands, and prevent potential impacts to the wetlands due to pollution from the
direct runoff from such development. The proposed project, on the other hand, provides for
conveying a conservation easement on the entire riparian and wetland area to the State of
North Carolina.
In summary, therefore, the City submits that the project would not cause a loss or adverse
impact to the existing wetlands, except for 0.1 acre of the wetland that will be impacted by
the construction of the water control structure dike and streamside shallow berms. As a
beneficial result, the project will restore a more effectively functioning riparian
floodplain area and likely create additional wetlands.
(c) Only Practical Alternative for Improving Water Quality: City recognizes that the Clean
Water Act (CWA) prohibits the use of waters of the US for wastewater treatment. City
submits, however, that the proposed project is designed to treat stormwater that does not
include any "wastewater" component as might occur in combined sewer systems. The water
5
proposed to be treated for enhancement of quality is essentially stormwater runoff and other
incidental non-stormwater flows that do not significantly impact water quality. These are the
types of flows that are naturally carried by the South Buffalo Creek like any other natural
stream with contiguous wetlands. Also, City suggests that the proposed project is not an "in-
stream" treatment system in the conventional sense of creating a permanent impoundment on
the stream with a fixed dam structure. The project proposes using an innovative and
operationally flexible (bottom-hinged) water level control gate (normally resting horizontally
on the floor of the stream channel) that allows the stream flow to occur unimpeded for most
of the time in a given year. The gate will be actuated only during and for short periods (of
less than 2 days) following rainfall events that are less intense than an approximately 1.5 year
recurrence event (that produces bank-full discharge) to raise the water surface to the
floodplain level. During dry periods (no rain and only base flow in the stream) as well as
during large rainfall (more than 1.5 year recurrence) periods producing more than bank-full
flows, the gate will be in the resting horizontal position allowing unimpeded stream flow and
aquatic movement. Therefore, the stream channel regime would not be significantly affected
by the innovative project construction and operations.
As stated in item (a) above, City has investigated all alternative projects and concluded that
this project is the only practicable alternative to improve the water quality in the urbanized
South Buffalo Creek. Several additional initiatives that the City is already planning or
implementing are also described in item (a) above. Other potential projects, such as
Retrofitting Hungry Fisherman Lake in the upper reach of South Buffalo Creek, that might
become practicable in the future would complement the functions of the proposed project as
additional elements in a comprehensive overall plan to improve the water quality in the South
Buffalo Creek. But they are truly not alternatives to the currently proposed project.
(d) Complementing City NPDES MS4 Permit and Cape Fear Basinwide Water Quality
Management Plan: City's NPDES MS4 Permit authorizes the City of Greensboro to
discharge stormwater from its municipal separate storm sewer system to receiving waters
within the upper Cape Fear River Basin. The discharges consist of stormwater runoff from
the City areas, certain treated discharges from individual facilities with independent NPDES
discharge permits and other incidental non-stormwater flows that do not significantly impact
water quality. The required NPDES stormwater management program includes the following
key components :
• Education, training and outreach program
• Implementation of measures to prevent non-stormwater discharges, illicit connections,
spills and illegal dumping into the storm sewer system
• Monitoring and assessment of the effectiveness of the various elements of the stormwater
management program
• Implementation and management of the stormwater program such that the discharge of
pollutants from the storm sewer system is controlled to the maximum extent practicable.
The Cape Fear Basinwide Water Quality Management Plan is the State of North Carolina's
plan for water quality improvement in the streams consistent with the Clean Water Act. The
plan has identified on its 303(d) list the South Buffalo Creek as an impaired stream. The plan
6
has emphasized the need for the local governments to take steps to improve the water quality
in the streams. City of Greensboro intends to do its part in this effort.
One of the objectives of the proposed Stormwater Treatment Wetland project, therefore, is to
complement City's stormwater management efforts under the NPDES MS4 program by
additionally removing pollutants in the stream flows. The intended result of the stormwater
management program, complemented by the proposed project is enhanced water quality in
the South Buffalo Creek and other downstream receiving waters.
For the reasons detailed above and because funding for all potential projects would not be
available at one time, it is unrealistic for the City, and for that matter for any agency, to plan
and implement all elements of an overall water quality improvement plan. Although it might
seem like a "piecemeal" approach, it is really the only practical and realistic phased
approach for implementing the multiple elements in a comprehensive plan. Likewise,
application for regulatory permits by the City can be made only as realistic and
implementable project plans can be developed. It needs to be emphasized again that the City
has a comprehensive vision and plan as evidenced by the "Stormwater Master Planning"
study recently completed for South Buffalo Creek. However, stormwater management
BMPs can be realistically implemented only in a phased approach.
(e) Net Impact to Waters of the US: As stated in item (c) above, City submits that the
innovative water control structure proposed in the project would enable South Buffalo Creek
to function in the natural condition, except for periodic gate operations for short duration.
Therefore, the impacts to the stream will be limited to the 150 linear feet of the creek on
which the water control structure would be located.
South Buffalo Creek is so straightened and incised (due to channelizing and dredging in the
historical past) that the existing floodplain has not been functioning naturally in processing
the floodwaters by removing sediment and other pollutants. Except for extreme flood events,
the creek does not overflow onto the floodplain. The proposed project would thus simulate
a more natural flooding regime and use the existing floodplain (wetlands and non-
wetlands) more effectively. It would reestablish a connection of the stream channel with its
floodplain including the wetlands. It would result in a more effectively functioning riparian
area, so that the pollutants in the stream are more naturally treated in the riparian vegetation
and the wetlands on the floodplain by the more frequent flooding, as it used to before the
creek was straightened and deepened. It should also be noted that the stormwater that would
be directed on to the floodplain wetland is the same water that flows in the creek now, and
detention of the water in the riparian floodplain is the best way to remove sediment, nutrients
and other pollutants. Hence, the effects of the flow on the existing wetland following the
project implementation would generally be similar in nature to the natural conditions that
existed before the creek was straightened and deepened. The actual impacts to the existing
wetland would therefore be confined to approximately 0.1 acre due to the proposed fill for
the water control structure dike. Thus, the combined impact would, indeed, be limited to a
total (wetland and stream) area of 0.23 acre.
7
City plans to monitor the water quality in the stream before, during, and after implementation
of the project. The City has contracted with the North Carolina Water Resources Research
Institute to conduct a study of the "Functional Capacity Assessment of a Floodplain
Stormwater Treatment Wetland, Greensboro, NC" that includes a water quality monitoring
program, using the staff and expertise of the North Carolina State University in Raleigh. City
staff will also participate in the monitoring program, as needed. Preparations for pre-project
monitoring are currently underway.
Miscellaneous Additional Issues: We would like to also address the other comments and
concerns raised in your letter and the EPA's letter, in the following paragraphs.
EPA has stated, and you conveyed in your letter, "that they have concerns that this project
may result in substantial and unacceptable adverse impacts to aquatic resources of national
importance." City would like to bring to your attention that the South Buffalo Creek is a
polluted urban stream and listed in the North Carolina State's 303(d) list as an impaired
stream. City has good knowledge of the condition of the stream and the aquatic resources in
it based on site visits and continual stream monitoring. City's biological monitoring of the
stream suggests that the stream is classified as biologically "poor" using North Carolina's
standard rating system. Based on that knowledge, City submits to you that there are no
unique aquatic resources in the creek including the stream channel and its floodplain that
could be characterized as "aquatic resources of national importance." Also, in the current
conditions, the jurisdictional wetlands located on the floodplain are mostly fed by the
stormwater runoff from the adjacent highway (Interstate 40) and the entrance ramp to it from
the Freeman Mill Road to the north, and the streets in the mobile home park to the south. The
runoff from major highways tends to carry road-related pollutants in fairly high
concentrations, and the major part of the existing wetland (located on the north floodplain) is
currently receiving such drainage. The quality of stormwater in the South Buffalo Creek that
would be directed on to the floodplain wetlands in the proposed project will likely be better
than that currently draining to the existing wetland. The project's impacts to the existing
wetlands should be no worse than in the current conditions. Therefore, City submits that
there will be no substantial and adverse impacts to the aquatic resources in the waters,
and also that the characterization of the aquatic resources in this segment of the stream
as being "of national importance" is without basis and not consistent with site-specific
conditions.
EPA expressed concern that "such treatment areas which are utilized to treat the first flush
may sequester heavy metals, other toxic pollutants, and nutrients in the sediment, which may
be released at a later date, causing catastrophic adverse impacts downstream. Likewise, in-
stream facilities such as the one proposed may not contribute any significant improvement in
fecal coliform levels, and to the contrary, may actually result in increased numbers of fecal
coliform bacteria due to use by waterfowl." City responds to that concern by stating that the
literature on the subject of pollutant removal capability of wetlands generally indicates that
wetlands are quite effective in removing the pollutants through filtering action, biotic uptake
and chemical reactions in the soil in the root zone of the plants in the wetland. For example,
the table in the attached Exhibit 4 excerpted from the publication "Design of Stormwater
Wetland Systems," (by Thomas R. Schueler, Anacosta Restoration Team, Department of
Environmental Programs, Metropolitan Washington Council of Governments, 1992),
summarizes the projected rates of pollutant removal rates for adequately designed wetlands.
It indicates significant removals of pollutants, including bacteria. The present project may not
achieve the high removal rates projected in the table because of the large drainage area
relative to the wetland area; nevertheless, it should be expected to result in improvement to
the water quality in the South Buffalo Creek. Sequestering and subsequent release of
pollutants is not a valid concern since the process of inundating the floodplain with
stormwater runoff and subsequent release of the water to the creek channel would be a
recurring event (every time rainfall occurs). Such operations would not allow the
sequestering of pollutants for any significant period and subsequent release in high
concentrations. Regarding the concern about the contribution of waterfowl to bacteria, it
should be noted that the proposed wetland is not designed to be a "surface flow" type of
wetland with permanent standing water. The periodic flooding of the floodplain with the
water from the creek would tend to maintain the groundwater table high, but would not create
permanent ponding of water. Hence, the likelihood of significant increase in waterfowl and
associated bacterial contribution is very low. Furthermore, even if an increase in waterfowl in
the created wetland were postulated, the contribution from that source in the 17 acres
(addition to the existing 3.1 acres) of wetland would be insignificantly small in comparison
with the bacterial load contributed by all other sources in the 13 square mile (8,320 acre)
urban watershed. City, therefore, respectfully suggests that the concern expressed by the
EPA is unfounded, and that no adverse impacts to the downstream creek segment
should be expected to occur. Contrary to the concern, downstream sections should benefit
from improved water quality obtained through the treatment in the proposed floodplain
wetland.
We believe that we have adequately addressed the issues stated in your letter and the
concerns expressed by the EPA. We also believe that we have demonstrated that the
proposed innovative project is the best alternative available to improve water quality in
the South Buffalo Creek with the least environmental impacts. In view of the nearly
built-out urban watershed of the South Buffalo Creek and the demonstrated fact that
the proposed project is the best alternative available, we request you to consider the
project as an exceptional case and grant the City the Army Corps of Engineers' 404
Permit.
Thank you for your consideration of the City's application and the information provided in
this letter. Should you need any clarification of the information provided in this letter or
additional information, please do not hesitate to contact me at [phone] or Dr. Shastri
Annambhotla at [phone].
Sincerely yours,
CITY OF GREENSBORO
Scott D. Bryant, M.S., P.E., NSPE
Manager & Chief Engineer, Stormwater Management Division
9
Cc: John Dorney, NC Division of Water Quality
Allan Williams, P.E., Greensboro Water Resources Director
Shastri Annambhotla, Ph.D., P.E., Greensboro Stormwater Management Division
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EXHlBfT ,Z_ A

5to rmwater Problems and Solutions in Sou th Buffalo Subwatershed 1
No. Problem

1 Hungry Fisherman Flood Control/ Retrofit lake to increase Stnictural Detailed' Wp only =
Lake presently Water Quality retention time and storage and $0.437 million
provides little flood volume and water quality Regulatory WQ $ Flood
control/ WO benefits monitoring Control =
$0.841 million
2 Flooding to many Flood Control/ Acquire or elevate floodprone Non- Detailed' Acquire =
homes between Merritt Mitigation homes and/or build flood wall Structural $3.3 million
Dr. and Holden Rd. and Elevate =
along South Buffalo Structural $0.9 million
Creek Flood Wall =
$0.819 million
3 Flooding to apartments Mitigation Acquire floodprone buildings Non- Detailed' Acquire =
along Maplewood Lane Structural $6.1 million
along South Buffalo
Creek
4 Stream bank erosion Stream Stream restoration Structural Summary' Project
along Tributaries 1 and Restoration techniques and water quality and Dependent
2 monitodn Re ulato
5 Overland flow near Flood Control Replace existing culvert with Structural Detailed' $1.43 million
Wendover Av. along larger culvert
Tributary B
6 Flooding to homes Flood Control Replace existing culvert with Structural Summary' $0.626 million
upstream of Norfolk larger culvert and add
Railroad, Market Street additional culvert
and Tower Road along
Tributary A
7 Flooding to roads and Flood Control Additional culverts Structural Summary' $0.496 million
homes upstream of I-
40 and Fairfax Road
along Tributary 2
8 Flooding over Boston Flood Control Additional culvert Structural Summary' $0.103 million
Road from South
Buffalo Creek
9 Flooding over Flood Control Additional culvert Structural Summary' Open Cut =
Wendover Ave. and to $0.550 million
several homes along Jacked =
South Buffalo Creek $0.147 million
10 Flooding over Merritt Flood Control Additional relief culvert' Structural Summary Not
Drive along South (currently being conducted applicable
Buffalo Creek b C'
$13.446
million
maximum
'ADOendix B contains addition al information on t hese Droiects.

ter
Stormwater Problems and Solutions in Sou th Buffalo Subwatershed 2

1 Flooding near Pinecroft Flood Control Add new relief culvert Structural Detailed* $0.202 million
Rd. along Twin Lakes
Tributary
2 Flooding upstream and Flood Control Replace existing culvert with Structural Detailed* $0.073 million
over Oak Street along larger culvert
Tributary 3
3 Flooding to Industrial Flood Control/ Floodwall and floodproofing Structural Detailed* Floodwall =
Avenue businesses Mitigation and Non- $3.04 million
along South Buffalo structural Floodproof 2
Creek $1.6 million
4 Stream bank erosion Stream Stream restoration Structural Summary* Project
along Tributary 3 Restoration techniques and water quality and Dependent
monitoring Regulatory
5 Flooding at Freeman Flood Control / City is going to build a Structural Summary Not
Mill and 1-40 along Water Quality wetland. Water quality and applicable
South Buffalo Creek monitoring should be Regulatory
City's Wetland Area conducted
6 Flooding upstream of Flood Control Add two new culverts or one Structural Summary* 2 culverts =
High Point Rd. along continuous culvert $0.314 million
South Buffalo Creek 1 culvert=
$2.51 million
7 Water quality and Flood Control / New pond in vicinity of Structural Summary* $0.460 million
flooding on upper Water Quality junction of tributaries and and
reach of Twin Lakes water quality monitoring Regulatory
Tributary
8 Water quality and Flood Control / Retrofit Twin Lakes for more Structural Summary* Would
flooding at Twin Lakes Water Quality storage and longer retention and require more
along Twin Lakes time and water quality Regulatory detailed study
Tributary monitoring
9 Flooded homes Flood Control Add two new culverts Structural Summary* $1.094 million
upstream of Freeman
Mill Rd. and 1-40 along
South Buffalo Creek
10 Flooding at Strip Mall Flood Control Channelize South Buffalo Structural Summary* $2.021 million
and homes around of Creek and enlarge bridge
Randleman Rd. along opening.
South Buffalo Creek
Total $9.400 million
ffama?amum]
*ADoendix B contains addition al information on t hese oroiects.
EXHIBIT
,
Chapter 4: Pollutant Removal Capability of Stormwater Wetlands
Table 6
Projected Long Term Pollutant Removal Rates
for Stormwater Wetlands in the
Mid-Atlantic Region a,
Pollutant Removal Rate (%)
Total Suspended Solids 75%
Total Phosphorus 45%
Total Nitrogen 25%
Organic Carbon' 15%
Lead 75%
Zinc 50%
Bacteria 2 log reduction
Notes: (a) Removal rates apply to stormwater wetlands sized as shown in
Section 5.1. Removal rates for pocket wetlands may be lower.
These are projected rates, and have not been confirmed by actual
monitoring.
(b) Includes five-day, BOD, Total Organic Carbon or Chemical
Oxygen Demand.
(c) Phosphorus and nitrogen removal in pond/wetland systems
(Design No. 2) are higher due to the effect of the pool. P removal
of 65% and N removal of 40% are likely.
30
F WAIF f -
?D?O R pG Michael F. Easley
Governor
( r Sherri Evans-Stanton, Acting Secretary
Department of Environment and Natural Resources
Kerr T. Stevens
Division of Water Quality
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS CERTIFICATION is issued in conformity with the requirements of Section 401 Public
Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of
Water Quality (DWQ) Regulations 'in 15 NCAC 2H, Section .0500. It is issued to City of
Greensboro resulting in 0.23 acres of wetland impact and 150 linear feet of perennial stream
impact in Guilford County pursuant to an application filed on the 14TH day of March, 2001 to
construct a concrete water control gate structure and associated riprap in order to install an
inflatable structure within South Buffalo Creek to reconnect stormwater flows with the existing,
natural floodplain.
The application provides adequate assurance that the discharge of fill material into the
waters of South Buffalo Creek in conjunction with the proposed development will not result in a
violation of applicable Water Quality Standards and discharge guidelines. Therefore, the State
of North Carolina certifies that this activity will not violate the applicable portions of Sections 301,
302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in accordance with the application
and conditions hereinafter set forth.
This approval is only valid for the purpose and design that you submitted in your
application, as described in the Public Notice. If you change your project, you must notify us and
send us a new application for a new certification. If the property is sold, the new owner must be
given a copy of the Certification and approval letter and is thereby responsible for complying with
all conditions. If total wetland fills for this project (now or in the future) exceed one acre or total
perennial stream impact exceeds 150 feet, compensatory mitigation may be required as
described in 15A NCAC 2H .0506 (h) (6) and (7). For this approval to be valid, you must follow
the conditions listed below. In addition, you should get any other federal, state or local permits
before you go ahead with your project including (but not limited to) Sediment and Erosion
control, Coastal Stormwater, Non-discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. Appropriate sediment and erosion control practices which equal or exceed those outlined in the
most recent version of two manuals, either the "North Carolina Sediment and Erosion Control
Planning and Design Manual" or the "North Carolina Surface Mining Manual" (available from the
Division of Land Resources in the DEHNR Regional or Central Offices). The control practices
shall be utilized to prevent exceedances of the appropriate turbidity water quality standard (50
NTUs in all fresh water streams and rivers not designated as trout waters; 25 NTUs in all lakes
and reservoirs, and all saltwater classes; and 10 NTUs in trout waters);
2. All sediment and erosion control measures placed in wetlands or waters shall be removed and
the natural grade restored after the Division of Land Resources has released the project;
3. Measures shall be taken to prevent live or fresh concrete from coming into contact with
waters of the state until the concrete has hardened;
4. Should waste or borrow sites be located in wetlands or other waters, compensatory mitigation
will be required since it is a direct impact from road construction activities;
5. DWQ shall be copied on an wetland floodplain monitoring plan to determine and then ameligrate
any adverse impacts to wetlands or floodplains on this site. The plan must receive written DWQ
approval before construction begins.
N d hiR
Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621
Wetlands/401 Unit: [phone]
Fax: [phone]

Michael F. Easley
Governor
Sherri Evans-Stanton, Acting Secretary
Department of Environment and Natural Resources
Kerr T. Stevens
Division of Water Quality
May 3, 2001
Mr. Scott Bryant
City of Greensboro, Manager & Chief Engineer
Stormwater Management Division
401 Balton Avenue
Greensboro, NC 27406
Dear Mr. Bryant:
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act,
Proposed stormwater treatment wetland system
WQC Project #010263 COE # 200120540
Guilford County
Attached hereto is a copy of Certification No.3320 issued to the City of Greensboro dated
May 3, 2000.
If we can be of further assistance, do not hesitate to contact us.
Frce s
Attachments
,7
cc: Wilmington District Corps of Engineers
Corps of Engineers Raleigh Field Office
Winston-Salem DWQ Regional Office
Doug Huggett, Division of Coastal Management
File Copy
Central Files
Steve Kroeger
Bill Cox; EPA-Region IV
711.
A .,
'I??I`ti
Division of Water Quality 1621 Mail Service Center Raleigh; NC 27699-1621
Wetlands/401 Unit: [phone]
Fax: [phone]
iiif
WA
OT ?i4QG
00
o ?
Violations of any condition herein set forth shall result in revocation of this Certification and
may result in criminal and/or civil penalties. This Certification shall become null and void unless the
above conditions are made conditions of the Federal 404 and/or coastal Area Management Act
Permit. This Certification shall expire upon expiration of the 404 or CAMA permit.
If this Certification is unacceptable to you have the right to an adjudicatory hearing upon written
request within sixty (60) days following receipt of this Certification. This request must be in the form
of a written petition conforming to Chapter 150B of the North Carolina General Statutes and filed
with the Office of Administrative Hearings, P.O. Box 27447, Raleigh, N.C. 27611-7447. If
modifications are made to an original Certification, you have the right to an adjudicatory hearing on
the modifications upon written request within sixty (60) days following receipt of the Certification.
Unless such demands are made, this Certification shall be final and binding.
This the 1 ST day of May 2000
DIVISIO OF WATER QUALITY
t `
r Stevens
WQC# 3320
ARA
O'
ER
Michael F. Easley -
Governor
Sherri Evans-Stanton, Acting Secretary
Department of Environment and Natural Resources
Kerr T. Stevens
Division of Water Quality
Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621
Wetlands/401 Unit: [phone]
Fax: [phone]
?OF W A T ARP
O G
co
o ?
DWQ Project No.: County:
Applicant:
Date of Issuance of 401 Water Quality Certification:
Certificate of Completion
Upon completion of all work approved within the 401 Water Quality Certification or
applicable Buffer Rules, and any subsequent modifications, the applicant is required to
return this certificate to the 401/Wetlands Unit, North Carolina Division of Water Quality,
1621 Mail Service Center, Raleigh, NC, 27699-1621.This form may be returned to DWQ by
the applicant, the applicant's authorized agent, or the project engineer.lt is not necessary to
send certificates from all of these.
Applicant's Certification
I, , hereby state that, to the best of my abilities,
due care and diligence was used in the observation of the construction such that the
construction was observed to be built within substantial compliance and intent of the 401
Water Quality Certification and Buffer Rules, the approved plans and specifications, and
other supporting materials.
Signature: Date:
Agent's Certification
I, , hereby state that, to the best of my abilities,
due care and diligence was used in the observation of the construction such that the
construction was observed to be built within substantial compliance and intent of the 401
Water Quality Certification and Buffer Rules, the approved plans and specifications, and
other supporting materials.
Signature: Date:
if this project was designed by a Certified Professional
I, , as a duly registered Professional
(i.e., Engineer, Landscape Architect, Surveyor, ect.) in the State of North Carolina, having
been authorized to observe (periodically, weekly, full time) the construction of the project,
for the Permittee hereby state that, to the best of my abilities, due care and diligence was
used in the observation of the construction such that the construction was observed to be
built within substantial compliance and intent of the 401 Water Quality Certification and
Buffer Rules, the approved plans and specifications, and other supporting materials.
Signature Registration No. Date
Gw
ME
Michael F. Easle;
Governor '
Sherri Evans-Stanton, Acting Secretary
Department of Environment and Natural Resources
Kerr T. Stevens
Division of Water Quality
Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621
Wetlands/401 Unit: [phone]
Fax: [phone]
Re: 010263, City of Greensboro Stormwater Wetland, Guilford
Subject: Re: 010263, City of Greensboro Stormwater Wetland, Guilford
Date: Mon, 16 Apr 200108:22:35 -0400
From: John Dorney <[e-mail]>
To: Jennifer Frye <[e-mail]>
CC: Cyndi Karoly <[e-mail]>, Steve Kroeger <[e-mail]>
i agree. thankx
p.s. what epa thinks is not relevant to us - let them comment as they will
on this (and other!) projects. we need to do (with the 401 program) what
our rules and common sense tells us.
Jennifer Frye wrote:
> Hello all,
> My staff report is completed for this project -
> Given EPA's recent stance on stormwater treatment facilities on line - I
> don't know how this project will be affected. It really is not the same
> as a wet detention pond on line. John, you should be receiving a copy
> of a letter from G-boro to Tommy regarding the EPA's letter - dated
> April 5 - you may have it alread .
> _ _ 6 2 evt 61WI.,'Y
> verall, I think the project is a good idea - it has potential. Since
> South Buffalo Creek is in such a degraded state, I can't see that
> exploring this will hurt. (Provided that the existing and restored
> wetlands don't get choked with sediment from the stormflow.)
> Thanks,
> Jen
> Jennifer Serafin Frye
> Division of Water Quality
> NC Department of Environment and Natural Resources
> Winston-Salem Regional Office
> Winston-Salem, NC 27107
> Voice: 336-771-4608 ext. 275 Fax: [phone]
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City of Greensboro
North Carolina
February 8, 2001
Mr. John Thomas
US Army Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road, Suite 120
Raleigh, NC 27615
RE: 404 Permit Application
Stormwater Treatment Wetland
South Buffalo Creek
Greensboro, NC
Dear Mr. Thomas:
RECEIVED
FEB 1 4 2001
Regulatory Branch

MR 1 2 200!

Attached is the City of Greensboro's application for the Army Corps Permit for
construction of the proposed "Stormwater Treatment Wetland" project on the floodplain
of South Buffalo Creek near the intersection of Interstate 40 and Freeman Mill Road in
Greensboro, NC. The permit application is supplemented by the attached "Project
Information" document.
Thank you again for our December 13th meeting to discuss this important project. The
City believes the project will be an important step in improving the condition of South
Buffalo Creek.
Sincerely,
CITY OF GREENSBORO
Scott D. Bryant, PE
Manager and Chief Engineer, Stormwater Management Division
CC: Mr. John Dorney, NC Division of Water Quality (permit application package)
Mr. Allan Williams, PE, City of Greensboro
Dr. Shastri Annambhotla, PhD, PE, City of Greensboro
Dr. Douglas Frederick, PhD, The Triangle Group (permit application package)
640 P.O. Box 3136 • Greensboro, NC 27402-3136 • www.ci.greensboro.nc.us • [phone] • TTY# 333-6930
a
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT OMs APPROVAL. NO. 0710.003
fm aw 328) Expires Otto w Ion
Public reportseug q, , , for this collection of hdormstbn is awdnrated to average 6 hours per response. broWwq"t*res for reviawil Instntotions.
Swching exiegnp tea 40tereee, fm*wft end rrtektalre 141 the data needed and comple ft end ravbwing the coraadon of III IN rtatfen. Send
comrsnea rsgardh Ift bnrdsn estinlMle w any OdW aspect of this coYeadon of information, b rq "0900dera for reduoft tl la burdw to
Dembnent of 0efewee. Washlrgta Heedwu w"w sbeMwDlrsatorats 0f IrlfOfmatlori00entlanaend Reports 1215 Jefferson DevisFEghway. Suke.
1204, Adnpton. VA 22202430ZI wA to the Office of Management and Sudgat. Paperwork Reduction Ptojeat f0710.0=, Wes*MM, DC
20803. Meaaw DO NO RETURN Year farm t0 dtiter of those addressee. CompMtad appgcaftm motet be a dmtittod to the Ola at EnpMwr having.
lWadiodOn owr tfN lesnlon of ttts proposed eedvkty.
PRIVACY ACT STATEMENT
AuthOriry: 33 USC 401. Section 10: 1413, Section 404. Principal Purpose-. These laws rsqulre pennite wjdwrbft siadvidse In, or affschfag,
neWpbie waters of the United States. the discharge of dredged or fig material Into waters of the United states. and the transportation of dredged
material for the purpose of dumping it km ocean waters. Rwdr,* Uses. Infors, provided on this farm will be used in walwo ttg the application
for a permit: Dbok s : Olsolowre of requested iefarrnadon Is voluntary. If Informadon b not provided. however. the peedt appllaadion cannot be
proomaw nor can a Pon* be issued.
One set of WOW drawiwge or good reprodudbie copies Whlah show the 10eatson and character of the proposed activity must be attaohed to this
aWdaden laws awnpb drawings wW kwbuadoml and bs suhn9tted to the Olatriot Engineer having jutisdietion over the location of the proposed
acdvlty. An applcation that Is not o0mpdeted in full wit be returned.

1. APPLICATION NO. 2. FIELD OFFICE CODE 3. DATE RECEIVED 4. DATE APPLICATION COMPLEri

a. APPucmrs NAME CITY OF GREENSBORO
CONTACT: SCOTT ER, STbRMWATERRMGMT DIVISION
ENGINE S. AUTHORIZED AGENT'S NAME AND TITLE /mtOrnrke r,reutw9
N/A
6. APPLICANT'S ADORM
401 PATTON AVENIIF
GREENSBORO, NC 27406 9. AGENT'S ADDRESS

N/A
7AC!LICANTIS PHONE NOS.
W/AREA CODE 10, A(3EW_'S PHONE MO S. WIARSA QODF____
_
e. Residence tJ IA
b. Business [phone] a. Residence
b. &nineas
N/A
11. STATEMENT OF AUTHOft RATiON
i hereby authorize, to act In my behalf as my agent In the processing of this. application and'.
furnish, upon request, Supplemental information in support of ties permit application.
N/A
APPLICANT'S SIGNATURE DATE
NAME, LOCATION AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE to" wwauuftuj
STORMWATER TREATMENT WETLAND
13. NAME OF WATERBODY, IF KNOWN Avw w w 14. PROJECT STREET ADDRESS w*pm.m
SOUTH BUFFALO CREEK
1S. LOCATION OF PROJECT
GUILFORD
COUNTY
NC
STATE
Ia. OTHER LOCATION DESCRIPTIONS.. IF KNOWN, mrkwtmxwnw
PROPOSED PROJECT IS LOCATED ON ±34 ACRES OF PROPERTY JUST DOWNSTREAM OF THE SOUTH B? FALO
CREEK INTERSECTION AND FREEMAN MILL RD INTERSECTION AND..UPSTREAM OF THE CREEK.WL I=
17. DIRECTIONS TO THE SITE EASTBOUND BRIDGE
ON I-85 IN GREENSBORO, TAKE EXIT 122 REHOBETH CHURCH RD. GO NORTH ON REHOBETH CHURCH
RD STAY ON REHOBETH CHURCH RD UNTIL IT DEAD ENDS (APPROX. 3/4 MILE). PROJECT IS ON
RIGHT.
18, Nature of Acttvtty (oaor~ a poses Amv" ea h+e..N
PLEASE SEE ATTACHED "PROJECT INFORMATION' DOCUMENT. SPECIFICALLY SECTIONS
1:2, 1.6, AND 1.7.

1 Si. Project Futpoae lonails M.?wir erpr'.rsaf abprghat, arslnsasaelsns+
PLEASE SEE ATTACHED "PROJECT INFORMATION" DOCUMENT. SPECIFICALLY, SECTION 1.2.
UBE 869298 29-22 IF DREDOED AND/QR FfLL tYIATERraL is TO BE DiBCMARQED
20. Ressonls) for Discharge
PLEASE SEE ATTACHED "PROJECT INFORMATION" DOCUMENT. SPECIFICALLY,SECTION 1'.7.
21. Type(s) of Materiel Being Discharged and the Amount of Each Type In Cubic Yards
PLEASE SEE ATTACHED "PROJECT INFORMATION" DOCUMENT. SPECIFICALLY, SECTION 1.7.
22. Surface, Aral In Aare of Wetlands or Other Waters Filled &wA w&"
PLEASE SEE..ATTACHED "PROJECT INFORMATION" DOCUMENT. SPECIFICALLY, SECTION 1.7.
23. Is Any Portion of the Work Already Complete? Yes ...... No . y IF YES. DESCRIBE THE COMPLETED WORK
24. Addresses of Adjoining Property Owners, Lessees. Etc., Whose Property Adjoins the Waterbody (If more than can be, entered here,
please attach a supplemantai "0.
PLEASE SEE ATTACHED "PROJECT INFORMATION" DOCUMENT. SPECIFICALLY, SECTION 5.
28. List of Other Certifications at ApprovaWOeniais Raceived from other Federal, State or Local Agencies for Work Described in This Application.
AGENCY TYPE APPROVAL' IDENTIFICATION NUMBER DATE APPLIED DATE APPROVED DATE DENIED
NONE
"Would Include but is not restricted to zoning, building and flood plain permits
26. Application Is hereby made for a permit or permits to. authorize the work described In this application. I certify that the information in this
application is complete and sot wan. I bmthff owWy that I poseess the authority to undertake the work described herein or am acting as the
duly =no a '""
2 7 Z?ci
SIGNATURE OF LICANT PATE SIGNATURE OF AGENT DATE
The application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by s duly
canto l=d agent It the statement In block 11 has been filled out and signed.
18 U.S.C. Section 1001 provkba that: Whoever, In any- manner within the jurisdiction Of any department or agency of the United Ststes
www?ngly' and willfully faNlfift oonoeals. of covers up any trick, scheme, or disguises a material fact or makes any false. fictitious or
frauQUient statementa• or rspresentstions or makes or uses any false writing or document knowing same to contain any false, fiotttlous or
frauduMm Itstsmantsorentry, shall be fined not more, than 810,000 or Imprisoned not more than five years or troth.
•u4XM199"21?-Nara^0 m a
City of Greensboro
Stormwater Treatment Wetland
PROJECT INFORMATION
Project Description
1.1 Location
The proposed Stormwater Treatment Wetland project is located in the headwaters of the Cape
Fear River Basin, in the south-central part of the City of Greensboro. The wetland will be
constructed on approximately 34 acres of property located on the South Buffalo Creek just
downstream of the intersection with Freeman Mill Road (US 220) and upstream of the
intersection with the Interstate 40 eastbound bridge. Almost all of the project area is within
existing Federal Emergency Management Agency (FEMA) designated Special Flood Hazard
Area.
1.2 Purpose of Project
The waters of the Cape Fear River Basin originate largely in Guilford County. The quality of the
water and stream habitat downstream of Guilford County are directly impacted by stormwater
draining the urbanized areas. The City's vision is to enhance the quality of waters in South
Buffalo Creek, a headwater stream in the Cape Fear Basin, by constructing the proposed
Stormwater Treatment Wetland to treat the "first flush" of stormwater runoff from the upstream
drainage area. Funding for this project will come from a grant awarded by the NC Clean Water
Management Trust Fund supplemented by City funds. This project will serve to complement the
City's NPDES Stormwater Discharge Permit and the objectives of the Cape Fear Basinwide
Water Quality Management Plan, published by the NC Department of Environment and Natural
Resources. Also, this project consists of stormwater management techniques unique to the North
Carolina Piedmont region as described below in section 1.6, Project Features. A secondary
benefit of the project will be to provide environmental educational and recreational opportunities
in the future potential additions to the project features. It is anticipated that construction work
will begin on the wetland in the Fall of 2001 and be completed within one year.
1.3 Existing Site Conditions
The majority of the project site (approximately 30 acres of the 34-acre site) is one tract currently
undeveloped (except for two highway billboard lease areas near the I-40 right-of-way) and is
Stormwater Treatment Wetland - Project Information Page 1 of 16
City of Greensboro, NC
zoned for "light industrial" use. However, the remaining portion of the project site will include
portions of properties that have been developed. An existing mobile home park, single family
residential unit, and a couple of industrial businesses are located along the southern portion of
the project. Approximately 2,500 feet of South Buffalo Creek, which at one time was re-routed
by the US Army Corps of Engineers, is located on the project site. Almost all of the site area is
located in the FEMA 100-year floodplain.
1.4 Existing Vegetation and Soils
The existing vegetation on the project site is bottomland hardwoods. Dominant tree species on
the wetter portions of the site include: green ash Fraxinus pennsylvanica, black willow Salix
nigra, sweetgum Liquidambar styraciflua, boxelder Acer negundo, silver maple Acer
saccharinum, hackberry Celtis occidentalis, water oak Quercus nigra, and red maple Acer
rubrum. Understory species include poison ivy Toxicodendron radicans, blackberry Rubus
argutus, Virginia creeper Parthenocissus quinquefolia, silky dogwood Cornus ammomum, and
jewelweed Impatians capensis. Species found on the higher areas include: willow oak Quercus
phellos, black cherry Prunus serotina, flowering dogwood Cornus florida, Yellow poplar
Liriodendron tupipifera, paw paw Asimina triloba, sycamore Platanus occidentalis, Southern
sugar maple, Acer barbatum, black walnut Juglans nigra and American beech Fagus
grandifolia.
The bottomland forest is approximately 40 years old and fully stocked except for several
blowdown areas which resulted from past storms. There is no evidence of significant cutting
since the entire forest was. regenerated around 1960.
The alteration of hydrology has caused changes in vegetation and soils on the site. Because the
hydrological alteration and stream channelization occurred many years ago, the site has become
drier and allowed some upland tree and shrub species to become established on the higher areas
about 40 years ago. The higher areas include the creek levee which is primarily the result of
creek dredging and low ridges on the floodplain that are remnant levees along old river channels
and sloughs. The upland species that have become established on these areas include yellow
poplar, American beech, dogwood, black cherry, southern sugar maple and others.
The primary soil on this floodplain site is Chewacla silty loam which is a hydric soil but may
have upland inclusions, particularly when hydrology has been altered. The silt component
contributes to moisture retention and saturated conditions during much of the year. Because the
creek's hydrology was altered many years ago, the soils have dried out and in many areas no
Stormwater Treatment Wetland - Project Information Page 2 of 16
City of Greensboro, NC
longer show hydric characteristics. A recent jurisdictional wetland determination of the site
showed just over 3 acres of wetlands which is just a fraction of the floodplain area and reflects a
gradual change in soil moisture and anaerobic conditions and resulting hydric characteristics
over the years. A goal of this project is to restore the floodplain functionality and its integral
relationship to the stream channel.
Please see Appendix C for the complete vegetation report prepared by The Triangle Group, a
consultant to the City.
1.5 Summary of Condition of South Buffalo Creek at Project Site
South Buffalo Creek at the project site is in poor condition primarily because of the following
reasons. Firstly, the watershed the creek drains is heavily urbanized including residential,
commercial and industrial uses. Secondly, South Buffalo Creek has been extensively disturbed
in the past by dredging and straightening which has altered the hydrology of the creek and the
functioning of the floodplain containing the project site. Thirdly, there are many areas along the
creek without a vegetated riparian buffer.
The following sections summarize recent assessments of the physical, chemical, biological, and
habitat condition of South Buffalo Creek in the vicinity of the project. For more detail data,
please refer to Appendix G.
1. S.1 Physical
An urbanized watershed and. past channelization activities have severely altered the natural
characteristics of the creek. When a creek is straightened and dredged, downcutting is
accelerated because of the increased speed and energy that the modified creek has. This
results in accelerated bank erosion along with the increased incising. Now the natural stream
bed is 10-15 feet below the natural floodplain. Over much of the creek length in the project
area, the creek has reached bedrock so further downcutting should be slowed or stopped.
However, bank erosion and resulting sedimentation may continue and affect areas
downstream.
The creek is now much deeper and incised than it was historically so the natural periodic
inundation of the floodplain occurs less often and the flooding is,of shorter duration. Some
areas of the floodplain are no longer wetlands because of the change in flooding regime.
Most storm events do not result in the creek overflowing onto the floodplain. It is only the
Stormwater Treatment Wetland - Project Information Page 3 of 16
City of Greensboro, NC
rare severe flood event that inundates the floodplain. Much of the wetness in the soils is due'
to rainfall and overland flow and not to natural overbank flooding by South Buffalo Creek
1.5.2 Chemical
Ambient water quality data from July 1999 to February 2000 are presented for sampling
sites on South Buffalo Creek located both upstream and downstream of the proposed project
location (Merritt Drive and Randleman Road, respectively). Based on the City of
Greensboro's Water Quality Index (WQI), water quality at both sites was variable based on
the time of year and localized influences. Ratings for both sites generally ranged from
"Poor" to "Good" during spring and summer months, and "Good" to "Excellent/Good"
during fall and winter months. The Merritt Drive site had a consistently lower rating than
the downstream Randleman Road site. In most instances, this lower rating could be
attributed to higher turbidity resulting from local highway and other construction projects.
Other common parameters that exceeded the WQI's "watch" and "action" limits at these
locations were fecal coliform, metals, alkalinity, and hardness.
1. 5.3 Biological
Microinvertebrate and fish sampling was conducted near the project vicinity.
1.5.3.1 Macroinvertebrates
Benthic macroinvertebrates were recently collected in South Buffalo Creek during both
1999 and 2000. Sites upstream and downstream of the proposed project location were
sampled during 1999, with an additional site at the proposed project location sampled
during 2000. All collections were made following the NCDENR Standard Operating
Procedures, Biological Monitoring (1997). Bioclassification of the benthic
macroinvertebrate communities during both years at all sampling locations, including
the proposed project location, were rated "Poor" by the NCDENR Standard Qualitative
Method (1997) and North Carolina Biotic Index (1997).
1.5.3.2 Fish
Stream fishes were sampled in late April 1999 at a location approximately one mile
downstream of the proposed project location. Of the 440 individual fish collected, 419
were classified as "tolerant". Although 12 species of fish were collected, the sample
was numerically dominated by only three species, including Redbreast Sunfish Lepomis
auritus, Red Shiner Cyprinella lutrensis, and Mosquitofish Gambusia holbrooki, which
accounted for 92% of the total fish collected. The fish community in this area of South
Stormwater Treatment Wetland - Project Information Page 4 of 16
City of Greensboro, NC
Buffalo Creek was rated "Poor" with a rating value of 28 based on the North Carolina
Index of Biotic Integrity.
1.5.4 Habitat
Stream habitat characteristics on South Buffalo Creek at and near the proposed project
location were analyzed during Summer 2000 using the North Carolina Division of Water
Quality Biological Assessment Unit's stream habitat assessment guidelines. Four sites,
including one upstream and two downstream of the project location, were rated from 47 to
62 on a scale of 100. Habitat quality decreased as the assessment progressed downstream.
In general, this stream consists of poor habitat due to past channelization, lack of riparian
vegetation, excessive sedimentation, and moderate to severe erosion as a result of urban
stormwater influences.
1.6 Project Features
The main features of the stormwater treatment wetland are highlighted below. Please see Figure
2 of Appendix B for the location of these features.
1.61 Water Control Structure
The water control structure serves to control the water level of the wetland. The primary
objective of the structure is to capture the "first flush" of polluted stormwater runoff carried
by South Buffalo Creek. An additional objective is to periodically inundate the wetland, as
needed, during long drought periods to maintain the desirable hydrology of the wetland.
The structure consists of a 40-foot wide 12-foot high bottom-hinged gate that is attached to a
concrete structure formed to the stream geometry and an earthern dike constructed on the
floodplain. The total structure length perpendicular to the direction of stream channel flow
measures approximately 440 feet. The gate will be designed to raise (by use of inflatable air
bladders) when there is an increase in stream stage, indicating rainfall in the upper
watershed. With storm events exceeding the 2-year flows, the dike will be overtopped. To
allow for this overtopping, a toe ditch has been designed to convey the overflow to the
stream channel. Also, the dike and overflow ditch will be lined with turf reinforcement
matting and will be maintained with a vigorous grass cover. For more detailed information
on the water control structure and how it operates, see Appendix D.
1.6.2 Stream Berms and Openings
Shallow berms will be placed along a portion of the South Buffalo Creek channel within the
project area. They will be constructed parallel to the stream channel where the stream bank
top elevation is lower than the wetland temporary impoundment elevation of 741 feet.
Stormwater Treatment Wetland - Project Information Page S of 16
City of Greensboro, NC
These berms will be set at elevation at 740.8 feet and where possible, will be constructed so
there is no disturbance within 15 feet of the stream channel. These berms serve to detain the
initial portion of the "first flush" stormwater runoff in the wetland area. Studies indicate
that the initial portion of stormwater runoff has the highest concentration levels of
pollutants. When the water control structure is raised, the stormwater captured in the stream
channel will flow over the berms into the wetland area within a time frame of 4 to 24 hours
depending on the rainfall intensity. A sensor placed in the wetland will trigger the gate to
lower when the wetland impoundment elevation equals 741 feet. To minimize the stream
impoundment time, the gate will be set to lower after 24 hours in the raised position even if
the wetland is not full. Release pipes will slowly release the captured water within a period
of 48 hours. Where the stream bank is higher than the 741 elevation, several openings will
be graded in the stream bank to the elevation of 740.8 feet. These openings will allow
captured stormwater in the stream channel to flow into the wetland areas.
1. 6.3 Potential Future Floatables Collection System
A potential option for future construction is a system to trap floatables at the upstream end
of the project area. Removing floatables from streams is one objective of the City's NPDES
Stormwater Permit, and will improve the aesthetics of the wetland and the downstream
channel. The City has contacted a vendor of a floatable collection system to see if this is a
viable option for the City. The City will evaluate any flow backup problems or health
hazards of collecting floatables prior to implementation.
1.64 Potential Future Environmental Education and Recreational Opportunities
A secondary function of the proposed wetland is to provide environmental education and
recreational opportunities for the public. The City envisions an educational center that will
display educational props for stormwater management, wetlands, streams, etc. The City
Parks and Recreation Department will be involved in planning for walking trails and
boardwalks around and through the wetland area. A children's play area may be
incorporated to enhance the existing play area used primarily by the adjacent mobile home
community.
1. 6.5 Tree Replanting Areas
In areas where the City will need to disturb the existing ground cover and existing cleared
areas on the south side of South Buffalo, the City proposes to replant hardwood trees where
possible. Bottomland hardwood tree species proposed for planting include: green ash,
boxelder, will oak, water oak, river birch, cottonwood and others as available. The City
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City of Greensboro, NC
proposes hand planting using 1-year-old seedlings at a rate of 726 trees per acre or an 8x10
ft. spacing. The City is proposing 7 acres of replanting.
1.7 Proposed Construction
To construct the innovative water control structure the creek will have to be temporarily
rerouted in a diversion channel. The total stream disturbance during construction is
approximately 275 feet. Once completed, the concrete structure and associated rip rap will
cover approximately 150 feet of stream channel. The remaining portion of the disturbed
channel (approximately 125 feet) will be reworked to the original stream geometry using
bioengineering techniques to restore the stream channel banks.
To provide necessary openings in the stream bank to allow stormwater to flow into the
wetland, two areas (a total of approximately 75 linear feet of stream bank) will need to be
excavated to an elevation of 740.8 ft. The stream bottom elevation in the area of the
proposed openings is around 732 ft.
The City proposes to temporarily relocate several of the mobile homes to grade adjacent to
the mobile home park. Grading will be done to extend the wetland boundary away from the
existing homes and to provide for maintenance access. It is proposed at this time that once
the grading is completed, the relocated mobile homes will be moved back to their original
spot.
A total of approximately 0.1 acres in three existing wetland areas will be filled during
project construction. Two areas will be disturbed during construction of the water control
structure dike. Approximately 3,000 ft2 of one area and 250 ft2 of the other area will be
filled in with suitable clay fill material for the dike. Approximately 250 ft2 of another
wetland area will be filled in with suitable clay material for construction of the shallow berm
that parallels the creek.
1.8 Operation and Maintenance of Wetland
The City will be responsible for operating and maintaining the wetland. Following are the main
items:
• Periodic inspection of the water control structure by a qualified professional. This will
involve inspecting for blockages, structure deterioration, mechanical works, erosion, etc.
• Periodic inspection of the stormwater wetland area for vegetation mortality, sediment and
debris accumulation, proper detention, etc.
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City of Greensboro, NC
• Routine maintenance to the mechanical and electrical system of the gate.
• Removal of debris- from the floatable collection system (if constructed).
• Periodic mowing of water control structure dike and stream berms.
• Maintenance and operation of educational and recreational facilities.
1.9 Functional Capacity Assessment of Stormwater Treatment Wetland
The City has a contract with the Water Resource Research Institute (WRRI) to assess the
functional capacity of this regional Stormwater Treatment Wetland Project. This assessment will
provide valuable information to gage the degree of success of a stormwater wetland to /
effectively function as a regional Best Management Practice as well as to evaluate the
environmental effects of the wetland. Field data on water quality and other environmental
parameters will be collected and analyzed for the conditions before, during, and after
construction of the wetland (3-5 years total).
2 Analysis of Alternatives
2.1 Alternatives Evaluated
Stormwater treatment of the South Buffalo Creek is highly desirable because:
• South Buffalo Creek has been seriously degraded by urbanization and channel
modifications.
• South Buffalo Creek is included on the NC DENR 303(d) List as an "impaired" stream.
• The stormwater runoff from this watershed is a source of drinking water-supply to
downstream communities.
• Improved quality of streams in Greensboro is a priority of the community
As summarized in the following subsections, this project is the best solution for improving the
water quality downstream. With the watershed almost developed out and the floodplain areas
now rapidly developing, the City and State Clean Water Management Trust Fund cannot afford
to delay action on this project.
2. 1.1 Alternative Areas for "Regional" Stormwater Control
There are very few sites available in the urbanized South Buffalo Watershed to provide
stormwater treatment to existing development. Although this project will create more than
20 acres of wetland, it does not have the volume for treating the first one inch of rainfall
over the watershed as described in section 4.1. To increase the amount of runoff treated
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City of Greensboro, NC
from this watershed, the City envisions proposing similar stormwater controls in the few
undeveloped areas remaining along South Buffalo Creek large enough to be effective in
providing regional stormwater treatment. The only practical option upstream of the
proposed project is the existing Hungry Fisherman Pond. This pond is located just
downstream of the confluence of South Buffalo Tributary A and South Buffalo Creek. The
amount of land available in this area for stormwater management (this pond currently serves
as a quantity control) is limited. However, it is envisioned that a project to modify the Pond
site for quality control will serve to complement the proposed Stormwater Treatment
Wetland Project in treating the watershed first flush.
2.1.2 Site Specific Controls
To push treatment controls further up in the watershed would require a much greater number
of controls to accomplish the same treatment quantity that this wetland will provide. With
the majority of the watershed already developed, this alternative is impractical. It should be
noted that the City has an aggressive public education and awareness program to help
address non-point source pollution.
2.1.3 "Do Nothing" Alternative
To not improve the quality of City streams would be in conflict with the City's NPDES
Stormwater Permit, the Upper Cape Fear Basin water quality objectives, and the goals of the
Federal Clean Water Act. This project will help improve the quality of South Buffalo
Creek.
2.2 Rationale for the Choice of Current Project
As discussed in the previous section, a regional type control is the only rational means for
treating stormwater runoff from existing development in the urban watershed. This site was
chosen for the following reasons. Firstly, the majority of the proposed wetland site is currently
owned by one individual and is undeveloped. Except for the mobile home park and the two
billboards along the interstate, there is no other existing development that will need to be
removed. Secondly, the City is trying to restore wetlands that once existed in the floodplain
prior to channelization of the stream in this area and upstream development. Thirdly, the City is
trying to preserve the 100-year floodplain from further development. The City's ordinance,
based on FEMA standards, allows the 100-year floodplain to be filled (up to the floodway
limits). This project will maintain low lying areas for flood expansion. With downstream
industries experiencing flooding, maintaining the upstream floodplain is an important step in
proactive floodplain management. And finally, the City is confident that the project design and
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City of Greensboro, NC
operations will minimize the impact to the existing stream characteristics, wetland areas and
floodplain vegetation.
3 Avoidance and Minimization
3.1 Avoidance of Significant Impacts
The City and stakeholders have been careful in the design of the proposed wetland to minimize
disturbance of existing stream channel and wetlands.
• The City is using the inflatable gate for water control to minimize impacts to the existing
stream flow regime. Except for the few hours (maximum of 24 hours) necessary to inundate
the wetland during a rain event, the gate will be in the lowered position.
• The treatment of stormwater is designed to occur in the floodplain of the creek. As noted
above, after the initial period of inundation, the creek will be allowed to flow in its natural
regime while the captured stormwater is treated by the contiguous wetlands.
• As summarized in Section 1.7, only 275 feet of stream channel disturbance will be required
to construct the water control structure. The gate structure will be designed to fit the existing
channel geometry with as natural "look" as possible.
• Where shallow berms are required along the stream channel to detain stormwater in the
wetland, they will be constructed 15 feet away from the stream channel bank.
• The water control dike is designed with a downstream toe ditch to direct flows back into the
stream in order to minimize further erosion to the already incised stream channel.
• Except for the 0.1 acre of wetlands impacted by the proposed land disturbance, the 3 acres of
existing wetlands on the project site will remain as wetlands. This project will provide the
hydrologic characteristics necessary to restore the floodplain wetlands that existed prior to
channelization of South Buffalo.
• Tree planting areas are proposed along areas of the creek bank where there is currently no
trees to help stabilize the stream channel.
3.2 Historical, Cultural and Archeological Resources
The City has a requested the NC Historic Preservation Office for information on any historical,
cultural and/or archeological resources that may be present at the project location.
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City of Greensboro, NC
3.3 Endangered Species
On January 3, 2001, the Natural Heritage Program reported that they had no record of rare
species, significant natural communities, or priority natural areas at the proposed site or within
two miles of the site.
4 Hydrologic Impacts
4.1 Detention of First Flush Runoff
It is documented that the highest pollutant concentrations are typically observed in the initial
portion of stormwater runoff. Therefore, Stormwater Best Management Practices (BMPs) used
to treat stormwater runoff are generally designed to treat the initial portion, or "first flush" of
stormwater runoff. The NC Division of Water Quality "Stormwater Best Management
Practices" manual generally requires the runoff from a one-inch rainfall to be treated.
The design of the stormwater treatment wetland targets treatment of the initial stormwater runoff
conveyed by South Buffalo Creek. The volume that is available in the wetland is approximately
30 acre-feet. According to calculations made using HEC-HMS (Army Corps of Engineers
Hydrologic Engineering Center - Hydrologic Modeling System), the volume of a 1 inch (24-
hour duration) storm event distributed over the entire drainage area to the wetland is
approximately 200 acre-feet. To make the wetland most effective, it is designed (i.e. the shallow
berm system) to detain and treat the first portion (up to its volume capacity) of any storm event.
Again, the assumption is that the initial portion contains the highest concentration of pollutants.
Figure 1 below shows the runoff hydrograph resulting from a one inch 24-hour duration storm
event over the upstream drainage area. The volume under the "Runoff Treated" portion of the
hydrograph curve represents the portion of the runoff detained in the wetland. As mentioned in
section 2.1.1, the City will review other projects in the South Buffalo Watershed to increase the
volume of runoff treated.
4.2 Effects on Downstream Flows
For all periods before and after such wetland inundation operations, the gate will remain in its
horizontal (fully open) position on the floor in the water control structure, allowing unobstructed
flow in the creek. As indicated by the Water Level Control Operations document in Appendix D,
the gate will be designed to raise when an increase in water level is detected (indicating runoff
conveyance). The gate will remain raised until the wetland is inundated to an elevation of 741
feet or for 24 hours, which ever comes first. During the time when the gate is raising or is raised,
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City of Greensboro, NC
Figure 1. Runoff Hydrograph of One Inch Storm Event at Stormwater Wetland Site
Hydrograph for Proposed Wetland Site
(1 inch of rain over 24 hrs.)
600 -
-- --- -- ----- -
-
500 -
-
400 ---

300
o
U.
200
I
100
M UMNOW
0

10:00 11:30 13:00 14:30 16:00 17:30 19:00
Time (minutes)
1-Inflow hydrograph -0-Runoff Treated
a minimum flow quantity will be released to the downstream, to maintain minimum base flow as
indicated by local stream gaging stations. Due to the nature of the gate operations, the relatively
small flow volume that is captured by the wetland, and the release of a minimum flow during
impoundment, minimal effects are expected to the downstream flow regime.
4.3 Effects on Upstream Flood Elevations
The City has performed a preliminary analysis of the effects that the proposed construction will
have on upstream flood elevations. HEC-RAS (River Analysis System) computer program was
used to compute the pre- and post-project flood profiles of the 10-year, 50-year, 100-year and
500-year storm events in the vicinity of the project. In general, the project will have little effect
on the flood levels. The maximum increase is experienced in the 10-year event where the flood
level increased 0.29 feet at the water control location. Please see Appendix E for more detailed
information regarding the preliminary analysis.
With fill proposed in the designated FEMA floodway, a Conditional Letter of Map Revision
(CLOMR) will be submitted to FEMA for their review and approval.
4.4 Effects on Groundwater
Operations of the water control structure for capturing and treating the "first flush" of stormwater
conveyed by the South Buffalo Creek would entail inundating the floodplain wetland during
rainfall events. Additionally, maintenance of the wetland hydrology during long-duration
drought conditions may also require inundating the wetland on a periodic basis. These operations
Stormwater Treatment Wetland - Project Information Page 12 of 16
City of Greensboro, NC
would tend to recharge the groundwater and raise the groundwater table locally in the project
area. The proposed wetland inundation elevation is approximately 741 feet, and the grade
elevation in the wetland area generally varies from 738 to 741 feet.
The effect of the groundwater recharge and associated rise in the water table in the project area is
to attenuate, to a limited degree, the flood peak in the hydrograph resulting from rainstorms. To
the extent of the reduction in the peak flood, it would result in reduced downstream flood
elevations and channel bank erosion. Thus, the effect is a positive one and helps counter the
undesirable effects of urbanization in the watershed.
The topography of the land surrounding the wetland project site consists of rolling terrain, with
the natural grade elevations rising fairly steeply outward from the fringe of the wetland.
Therefore, although the level of the groundwater table in the wetland area might rise up to 741
feet, its effect on the water table in the adjacent properties would be limited to a transitional rise
for a short distance from the boundary of the wetland. Since the groundwater table generally
slopes down from the adjacent higher ground toward the low-lying floodplain wetland site, the
rise in groundwater table in the wetland area would have insignificant effect on the adjacent
properties.
As described in Section 1.9, monitoring of the groundwater table is planned for existing and
post-project operational conditions along a representative transect across the project site. The
data that would be acquired would provide better quantitative information.
4.5 Effects on Adjacent Properties
As stated in section 4.3, the City does not expect this project to increase the flooding potential of
the adjacent properties during major storm events. There are several minor drainage systems
located on the adjacent mobile home property that discharge to the wetland area. Elevations of
the upstream inlet structures are higher than the wetland impoundment elevation and computed
10-year elevation of South Buffalo Creek.
4.6 Effects on Sediment Transport in South Buffalo Creek
At the project location, South Buffalo Creek drains a 13 square mile watershed. The soils in the
watershed are generally fine-grained soils, mostly clays and silts. The sediment carried by the
runoff and transported by the creek is, therefore, predominantly in the form of suspended load.
The fine sediment carried as suspended load does not settle out easily without a long detention
time in a large settling basin.
Stormwater Treatment Wetland - Project Information Page 13 of 16
City of Greensboro, NC
The water control operations in the wetland, described in Section 1.6, would backup water in the
South Buffalo Creek channel up to an approximate elevation of 741 feet during all rainfall
events. However, the duration of the backup of water caused by the raised gate in the water
control structure would be limited to less than 24 hours, and in most cases likely to be less than 6
hours because of the short duration rainstorms that typically occur in Greensboro. Thus, the
backup of water in the stream channel would occur only for a very short duration (maximum 24
hours) during each rain event. During such short periods, enough detention time is not available
for the sediment to settle to the bottom of the stream channel. Even if a small amount gets
deposited in the short period, the sediment would be expected to resuspend and transported
downstream by the normal stream flow and velocity conditions that would occur following the
lowering of the gate. Therefore, quasi-equilibrium conditions would be attained in the stream
segment in the project reach and some distance upstream of it, such that the natural regime of the
stream channel would remain materially unaffected.
5 Property Acquisition
5.1 Property Owners
The property owners that will be involved in the land purchase or easement acquisition with the
City and those adjacent to the project are listed in Appendix F.
5.2 Proposed Acquisition of Properties/Conservation Easements
The City proposes to acquire approximately 34 acres of land through fee-simple acquisition or
conservation easements. Figure 3 of Appendix B shows existing and proposed property lines
and conservation easements.
6 Environmental Impacts
6.1 Impact on Existing Vegetation and Wetlands
As indicated in the Vegetation Report, Appendix C, prepared by Triangle consultants, the
inundation of the should have minimal effects on the hardwood-dominated bottomlands of the
project area. That is, with the periodic flooding (each runoff producing rainfall events) and
detention time of 24-48 hours, there should be no detrimental effects to the overall ecological
integrity of the site.
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City of Greensboro, NC
6.2 Impacts on Existing Stream Channels
With the proposed project there will be minor modifications to existing stream channels. South
Buffalo Creek and an unnamed tributary which flows through the southwestern portion of the
project area are impacted as described below.
6 2.1 South Buffalo Creek
Approximately 275 feet of South Buffalo Creek will be modified for the construction of the
water control structure. Included is the minimum length required to re-route the stream
during construction and the 150 feet that will be covered by the water control structure and
associated rip rap protection areas. A low flow concrete causeway is existing in the stream
channel. It is assumed that the causeway was constructed for access to the highway
billboards.
A portion of the stream channel bank will need to be cut down 1-2 feet to an elevation of
740.8. The current stream bottom elevation is approximately 730 feet.
62.2 Unnamed Tributary to South Buffalo Creek
The unnamed tributary that exists on the site will need to modified (culverted or flattened
with rip rap) to allow access to the water control structure from the south side.
Approximately 20 feet of stream channel will be impacted.
6.3 Impacts on Adjacent Properties
The City does not anticipate impacts to adjacent property owners. As described in Section 1.7,
several mobile homes may need to be temporarily relocated for grading. The grading is being
done to provide some distance between the wetland edge and the mobile homes. A complaint
usually associated with wetlands is the stereotypical undesirable habitat. By not maintaining a
permanent pool, it is believed that mosquitoes and other undesirable habitat will be less of an
issue. By creating a public park and recreational area and by planting trees, the impact should be
positive not negative.
6.4 Impacts on Existing Land Use
The majority of the project area is existing FEMA regulatory floodplain. This proposed
construction will maintain the floodplain areas and the entire project site will be maintained by a
conservation easement once completed. The City believes that this project will allow this land
to restore and maintain its natural function as a floodplain; a much needed asset to the urban
environment.
Stormwater Treatment Wetland - Project Information Page 15 of 16
City of Greensboro, NC

6.5 Environmental Benefits
The following environmental benefits will be gained:
1. Creation of approximately 21 acres of wetlands
2. Stormwater treatment of "first flush" of runoff from upstream drainage area
3. Rise in the existing water table of the floodplain
4. Tree re-planting in areas adjacent to stream channel that are currently devoid of trees
5. Environmental Center designed for environmental education (future proposed)
6.6 Recreational Benefits
1. Scenic walking trails for public use
2. Educational signs that highlight points of environmental interest in the wetland area (future
proposed)
3. Natural playground area for public use (future proposed)
6.7 Net Gains in Benefits/No need for Mitigation
This project will provide a net gain in environmental benefits and benefits to the City and region
as a whole. Careful planning has yielded a design that minimizes impacts to jurisdictional waters
and wetlands, while providing major benefits to stream quality. Therefore, no mitigation is
proposed.
Stormwater Treatment Wetland - Project Information Page 16 of 16
City of Greensboro, NC

APPENDIX A
City of Greensboro
Stormwater Treatment Wetland
MAIN FEATURES OF WETLAND'
SITE AREA: 34 ACRES
STORMWATER TREATMENT WETLAND AREA: 21 ACRES
STORMWATER TREATMENT WETLAND TEMPORARY IMPOUNDMENT ELEVATION: 741 FEET
DRAINAGE AREA TO WETLAND: 13 SQUARE MILES
EXISTING WETLAND AREAS ON SITE: 3.1 ACRES
DISTURBED AREA: 12 ACRES
TREE PLANTING AREA: 7 ACRES
EXISTING WETLANDS THAT WILL BE IMPACTED BY LAND DISTURBANCE: < 0.1 ACRES
LENGTH OF STREAM CHANNEL (SOUTH BUFFALO) DISTURBED: 275 FEET
APPENDIX B
FIGURE 1: VICINITY MAP
FIGURE 2: PROJECT PLAN
FIGURE 3: PROPOSED PROPERTY/EASEMENT ACQUISITION MAP

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CITY OF GREENSBORO
SOUTH BUFFALO CREEK STORMWATER PROJECT
Vegetation Report
September 1, 2000
During July 2000, a vegetation survey and evaluation was conducted at the South Buffalo
Creek Stormwater Project site, City of Greensboro. The purpose of the work was to
sample and characterize the overstory and understory species found naturally at the site
and to project the effects of flooding on vegetation following implementation of the
South Buffalo Creek Stormwater Retention Project.
Vegetation was sampled using twelve (12); 1/10 acre (37 ft radius) plots systematically
and uniformly distributed across the site (See Project Map). At each one-tenth acre plot
(37 ft. radius), overstory trees were identified by species and diameter at breast height
(DBH) was measured to the nearest 1.0 inch. Subcanopy trees, shrubs, vines and herbs
were identified to species and average canopy coverage (%) was estimated. Total basal
area for trees was calculated by plot on a per acre basis and as an average for the tract.
Basal area per acre for canopy tree species, frequency of occurrence (%) and wetland
indicator status were summarized (See Plant Community Monitoring Data Sheets). Also
summarized was canopy coverage for understory plants by species, frequency of
occurrence and wetland indicator status.
The South Buffalo Creek site supports a typical Piedmont Floodplain forest composed of
hardwood species moderately tolerant of flooding. The site has significant surface
elevational variation that provides a variety of site and soil conditions that contribute to
changes in species dominance. Based on an Ecological Zonation Classification (Wharton
et al, 1982), this tract would be classified as Zone III - wet flats, bank-edge strips, low
levees and semi-permanently flooded areas with soil saturation for up to 40 percent of the
year, Zone IV - flats and terraces of low relief including "hummocky terrain" and levees
with soils saturated up to 20 percent of the year and Zone V - floodplains and higher
terraces with soils saturated from 0 - 20 percent of the year. Based on our wetland
delineation and vegetation survey, we estimate that the area of these ecological zones on
the South Buffalo Creek site is as follows: Zone III - 30 percent, Zone IV - 60 percent
and Zone V - 10 percent.
Predominate species characteristically found in Zone III habitats include: silver maple
(Acer saccharinum), black willow (Salix nigra), boxelder (Acer negundo) and green ash
(Fraxinus pennsylvanica), Zone IV - green ash, red maple (Acer rubrum), hackberry
(Celtis occidentalis), elm (Ulmus spp.), sweetgum (Liquidambar styraciflua) and water
oak (Quercus nigra), Zone V - willow oak (Quercus phellos), yellow poplar
(Liriodendron tulipifera), paw paw (Asimina triloba), sycamore (Platanus occidentalis)
and dogwood (Corpus florida).
The present vegetation on the South Buffalo Creek site is a result of past natural and
man-caused disturbances. Dredging and straightening of the creek has had a major
influence on the vegetation on the site. Past dredging has lowered the water table and has
contributed to making the site drier and reducing the duration of flooding. This has
resulted in more mesic species becoming established on the floodplain including
sycamore, black walnut (Juglans nigra), black cherry (Prunus serotina), dogwood and
southern sugar maple (Acer barbatum) to become established.
Improvements to I-40 including rerouting of South Buffalo Creek and significant
development upstream have also altered the natural hydrology, flooding regimes and
vegetation development patterns at the site. Recent road building associated with
billboard construction has also resulted in impeded drainage across the site, which will
affect vegetation in the long term.
Following is an analysis of the vegetation data collected at the South Buffalo Creek site
during July:
Overstory Species - Total basal area for trees based on sample plots ranged from 14.10
to 231.58 ft2 / acre with an average for the tract of 116.58 ft2 / acre (See Plant
Community Monitoring Data). This range reflects scattered natural openings within the
tract resulting from past windthrow of individual trees and groups of trees plus other
natural mortality. Windthrow is the most important natural disturbance factor in
bottomlands in the South and can initiate early succession, promote vertical stratification
within the stand and result in multiple age-class distribution. On average, the tract is
fully stocked with canopy trees primarily of the same age class and any openings are
regenerating with desirable hardwoods.
The dominant tree species on this tract, based on basal area are: green ash (58.04 ft2 /
acre), sycamore (14.20 ft2 / acre), sweetgum (13.06 ft2 / acre), hackberry (11.29 ft2 /
acre) and willow oak (9.02 ft2 / acre) (See Plant Community Monitoring Data). Green
ash had the highest frequency of occurrence at 100 percent followed by boxelder (83.33
percent), American elm (Ulmus Americana) (58.58.33 percent), sweetgum (50 percent),
and red maple, sycamore and willow oak (41.67 percent).
Wetland indicator status for the dominate trees were either Facultative Wet (FACW) -
species occurring on average 67 percent in wetlands and 33 percent in uplands and
Facultative (FAC) - species occurring equally in wetlands and uplands.
Understory Species - The most common understory species found on the site based on
average coverage and frequency of occurrence were: poison ivy (Toxicodendron
radicans) (FAC), blackberry (Rubus argutus) (FAC), Virginia creeper (Parthenocissus
quiquefolia) (FAC), boxelder (FACW), silky dogwood (Corpus ammomum) (FACW),
jewelweed (Impatians capensis) (OBL), elderberry (Sambucus canadensis) (FAC),
greenbriar (Smilax spp.) (FAC) and Japanese honeysuckle (Lonicera japonica) (FAC).
Most of these species are found equally in wetlands and uplands with the exception of
silky dogwood, boxelder and jewelweed. These latter species are typically found in
jurisdictional wetland areas. All the understory species were characteristic of Ecological
Zones III, IV and V.
Vegetative Flooding Tolerance - The distribution of vegetation in a floodplain is
dependent on at least three aspects of anaerobic conditions:
1. The presence and intense selective power of anaerobic conditions generated by
the hydroperiod on the floodplain.
2. The anaerobic gradient, varying in space and time across the floodplain due to
microelevational relief, the soil mosaic, and the hydroperiod: and
3. The tolerances of the plant species to this gradient.
Anaerobiosis (lack of oxygen) is the primary factor controlling vegetation composition
and. distribution across a floodplain. It is not the availability of water in the floodplain but
rather the unavailability of oxygen due to the presence of water (Wharton et al, 1982).
Plants have developed varying tolerances to anaerobic conditions and therefore, there is a
predictable distribution of species across a floodplain gradient. Knowing the natural
tolerances of species to flooding and thus to anaerobic conditions can be useful in
predicting the effects of flooding on species survival and growth.
The abilities of plant species to restore and maintain a stressed root system and survive
and grow in flooded conditions lie on a continuum:
1. Very Tolerant - primary root maintenance, secondary and adventitious root
growth
2. Moderately Tolerant - primary root deterioration, adventitious root growth
3. Intolerant - primary root deterioration, no adventitious root growth
The species recorded in our sampling of South Buffalo Creek would be classified as
moderately tolerant (Zones III and IV) or intolerant (Zone V).
The primary factors that influence vegetation survival and growth during flooding
conditions include: the timing, depth and duration of flooding. Regional precipitation
and local weather patterns plus watershed size, floodplain size and topographic variation
and drainage rates can also contribute to flooding effects. Flooding duration is especially
important. The majority of bottomland species will not survive more than 2 years of
continuous flooding (Broadfoot and Williston, 1973). An increase in the dissolved
oxygen concentration through rainfall, or via moving water and lower water temperatures
can moderate the detrimental effects of flooding. The effects of flooding are most critical
during the growing season, particularly during the period of leaf out. Floodwaters can
cause anoxia, mechanical damage and silt deposition on the leaves, which can have
detrimental effects on the vegetation. Floods during the dormant season (winter) have
relatively little effect on the physiology and survival of floodplain tree species. There is a
greater effect on understory vegetation because of the potential for total inundation and
because these species typically have shallower root systems.
Currently, the floodplain on South Buffalo Creek floods periodically and only for brief
periods. Water does not normally stand on the site for extensive periods of time. The
nonwetland areas in particular, show evidence that water does not remain for long
periods. Even the wetland areas are dry for much of the year.
With the planned storm water detention facility in place, there will be increased flooding
but unless the water is held for long periods, there should be negligible effects on the
overstory trees. There may be effects on the less flood tolerant understory species
especially if there is total inundation during the growing season. There should be little or
no effect on the understory species during the dormant season.
Conclusions and Recommendations - This vegetation survey showed that the natural
vegetation on the South Buffalo Creek site is characteristic of bottomlands in the vicinity.
The site is composed of native tree species and an under story mixture of both native
species and exotics. Vegetation is found across an ecological zonation gradient, based on
flooding occurrence (%) during the year. We predict that approximately 70% of the site
will flood for up to 20% of the year (Zones IV and V), while 30% of the site (Zone III)
will flood >20% of the year. Most of the jurisdictional wetland areas, which are
dominated by green ash trees in the canopy, are found within Zone III.
The planned stormwater detention facility will cause an increase in flooding of the site in
extent, depth and duration. However, this flooding as currently planned should have
minor effects on the vegetation community. The planned periodic, shallow inundation of
2-5 days following minor storm events will not kill or significantly affect the health of
the tree species either during the dormant or growing season. Some understory species
may be affected during the growing season if completely inundated. However, with the
current plans to drain the site within several days, there should be no detrimental effects
to the overall ecological integrity of the site. In fact, eliminating some of the poison ivy,
Japanese honeysuckle and Microstegium will be a positive effect. Alternation of short
duration flooding followed by complete drain-out will result in the least negative effects
to vegetation. The interval between flooding events should be 3-4 days for best results.
However, periodic longer flooding (5 - 15 + days) following larger rainfall events should
not negatively affect the woody vegetation. Hardwood-dominated bottomlands such as
South Buffalo Creek would be negatively affected by flooding only if the duration of
inundation was several months during the growing season.
To provide long-term protection to South Buffalo Creek, following implementation of
this stormwater project, all riparian areas along the creek should be replanted with
hardwood trees. Currently, most of the bottomland corridor is forested. However, at the
upstream project limit, where South Buffalo Creek crosses under I-40, there are open
areas that should be planted with bottomland hardwood tree species including but not
limited to: green ash, boxelder, willow oak, water oak, river birch, cottonwood and others
as available. We recommend planting be done by hand using 1-year-old seedlings at a
rate of 726 trees per acre or an 8 x 10 ft. spacing. Any trees lost as result of natural
mortality or flooding should be replaced with some or all of the above species as
available.
References:
Broadfoot, W.M. and H.L. Williston. 1973. Flooding effects on southern forests.
J. Forestry 71(9): 584-587.
Huffman, R.T., and S. W. Forsythe. 1981. Bottomland hardwood forest communities
and their relation to anaerobic soil conditions. Pages 187-196. In: J.R. Clark and J.
Benforado, eds. Wetlands of bottomland hardwood forests. Proceedings of a workshop on
bottomland hardwood forest wetlands of the Southeastern United States held at Lake
Lanier, GA, June 1-5, 1980. Developments in Agriculture and Managed Forest Ecology,
Vol 11, Elsevier Scientific Publ. Co., New York.
Wharton, C.H.., W.M. Kitchens and T.W. Sipe. 1982. The ecology of bottomland
hardwood swamps. U S Fish and Wildlife Service. FWS/OBS-81/37, 1 34 pp.
APPENDIX D
WATER LEVEL CONTROL OPERATIONS
Draft 1
November 28, 2000
City of Greensboro
Stormwater Treatment Wetland
WATER LEVEL CONTROL OPERATIONS
Objectives: The primary objective of the water level control operations is to capture and
treat a reasonable amount of the "first flush" stormwater runoff carried by the South
Buffalo Creek due to rainfall anywhere in the watershed upstream of the wetland site. An
additional objective is to periodically inundate the floodplain wetland, as needed, during
long drought periods to maintain the desirable hydrology of the wetland.
Method: Water level control will be done using a 40-foot long and 12-foot high bottom-
hinged steel gate installed in a concrete water control structure located in the South
Buffalo Creek near the downstream boundary of the property. The gate will be designed
to operate automatically according to prescribed operating rules, using programmable
logic controllers (PLC). The signal to the PLCs, that will serve as the basis for the gate
position control, will come from a water level sensor that will be installed in the South
Buffalo Creek upstream of the water control structure. Manual override of the automatic
operations will also be provided for in the design to accommodate unusual situations and
to provide operational flexibility. Raising and lowering of the gate will be actuated by
pneumatic regulation of the pressure in inflatable rubber/kevlar air bladders housed undet
the gate. The gate will typically be down (fully open) to allow for the normal and
unobstructed stream flow.
Operational Procedure: The following are the procedures proposed for incorporation in
the programmable logic controllers (PLC) controlling the gate operations. These
procedures may be adjusted based on operating experience gained during the first few
months or years of operations.
(A) Normal Operations:
1. An increase in the creek water level of 0.05 foot or more in a 15-minute period, as
detected by the water level sensor, will be the criterion for detecting the first flush
runoff. During dry periods with base flow in the creek, as long as the water level
sensor does not detect an increase in water level of 0.05 foot or more in a 15-minute
period, the gate will rest flat on the concrete floor of the water control structure.
2. When the water level sensor detects an increase of 0.05 foot or more in a 15-minute
period, the event will be interpreted by the PLC as the beginning of the runoff
hydrograph in the creek due to rainfall somewhere in the watershed. This data signal
to the PLCs will cause the gate to be raised to the appropriate elevation that will
inundate the creek and floodplain wetland to an elevation of 741 feet. With the
passage of the variable flows in the creek (in the runoff hydrograph), the gate position
(crest level) will be automatically adjusted by the PLC to maintain the inundation
elevation of 741 feet. The shallow berms, with top elevation of 740.8 feet, located
along and on the top of the creek's banks will be overtopped and will act as weirs to
pass the water to the wetland on the floodplain until the water elevation in the
wetland rises to 741 feet. It is estimated that it will take up to 4 hours for the wetland
to be inundated up to an elevation approaching 741 feet. The PLC will be
programmed to lower the gate to the horizontal resting position after that time of
inundation of the wetland. The small openings in the shallow dikes along the creek
banks will automatically drain the water inundated in the wetland in about 24 to 48
hours following the inundation. This will allow time for the (poor quality) "first
flush" stormwater to be treated in the wetland before being discharged to the creek.
The gate operation will be programmed such that minimum downstream releases are
maintained throughout the gate operation periods to support biological life in South
Buffalo Creek downstream of the wetland.
3. During heavy rainfall events (large flows in the creek), the water level upstream of
the gate is also affected by the tail water level in the creek downstream of the gate in
addition to the discharge. During those events, the gate elevation will be
automatically controlled and adjusted (in steps of 0.1 foot) by the PLC such that the
inundation elevation in the creek upstream of the gate will be maintained at
approximately 741 feet. In the limit, when the bank-full flow is approached, the gate
would have been lowered to its horizontal resting position, and the water control
structure would function as an open channel connecting the upstream and
downstream creek reaches. At some flood discharge between the bank-full and 2-year
recurrence flows, the upstream water level rises above the top of water control
structure dike (741 feet elevation). For flood flows above that value, the flow in the
creek would pass partly through the structure and partly over the dike. The flow over
the dike segments on the left and right overbanks of the creek will be collected and
conveyed to the creek channel through the ditches downstream of the toe of the dike.
4. It can be seen from the above that most of the time, the creek would be flowing in its
natural condition without any long-term backup or obstruction in the creek. The only
times when the gate will be raised, and that too for less than 24-hour duration, will be
during the initial portion of a rainfall event to capture and treat the first flush of
runoff. The minimal accumulation of sediment that might occur during these short
periods would be flushed out during the subsequent natural flood flows in the creek.
Therefore, the gate operations would have negligible impact on the natural flow
regime in the creek, while providing the significant benefit of floodplain wetland
creation/restoration.
(B) Drought Conditions:
1. Groundwater observation wells will be installed in the wetland area to observe the
groundwater table levels. During a long-duration drought, if the water table drops
below a pre-determined "trigger" elevation that could affect the wetland hydrology to
2
the detriment of the wetland vegetation, the gate will be raised to inundate the
wetland for periods of up to 48 hours to recharge the ground water table. The
inundation procedure may need to be repeated a few times, depending on the severity
of the drought. It is currently envisioned that such events would be rare, and manually
controlled operations would be performed. However, provisions will be made in the
control system of the gate to accommodate future automation of the gate operation
actuated by a signal from a water level sensor installed in one of the groundwater
observation wells.
2. The gate operations that may be required due to long drought periods is anticipated to
be very rare. In such events, the duration of gate operation will be short, anticipated to.
be less than 48 hours at one time. During drought conditions, the flow in the creek
typically carries very little sediment and the potential for sediment accumulation is
minimal. Therefore, the gate and the water control structure would have negligible
impact on the natural flow regime in the creek.
APPENDIX E
PRELIMINARY ANALYSIS OF FLOOD PROFILES
City of Greensboro
Stormwater Treatment Wetland
PRELIMINARY ANALYSIS OF FLOOD PROFILES
Objective: With modifications to the existing FEMA regulated floodway of South
Buffalo Creek proposed by this project, water surface profiles of flood events were
calculated to determine if increases in flood levels can be expected after development.
Method: The HEC-RAS (Hydrologic Engineering Center - River Analysis System)
computer program was used to calculate water surface profiles. The program requires
geometric (stream cross sections, culvert opening, etc.) and flow data to compute water
surface profiles by use of hydraulic equations. The geometric data used for the model is
based on the field data recently obtained through the city's stormwater conveyance
system inventory project and the preliminary stormwater wetland plans. Flow data was
taken from the original FEMA Flood Insurance Study (mid 1980's). The 10-year, 50-
year, 100-year and 500-year storm flood flows were modeled through the existing and the
proposed geometric conditions. The study analyzes the portion of South Buffalo just
upstream of the I-40 eastbound bridge (just downstream of the project area) to
approximately 1500 feet upstream of the Freeman Mill culvert. The output of the models
were compared.
Findings: Attached are the graphical and tabular output of the water surface profiles. In
general, the project will have little effect on the water surface profiles. For the 100-year
event, the flood profile for the proposed condition is essentially equal to the profile of the
existing condition. For the 10-year event, the flood profile is slightly higher in the
proposed condition (0.29 feet maximum difference). This increase may be due to the fact
that the presence of the dike in the floodplain has more influence on the water surface
elevations for smaller flows. Above the 10-year event, the dike appears to have little or
no influence.
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APPENDIX F
ADJACENT PROPERTY OWNERS
Miller Earnest W
1401 Sunset Dr
Greensboro NC 27408
Essex Village Park L P
C/O Essex Investment Group
100 Corpoate Woods Suite 300
Rochester NY 14623
Pemberton Cathy W., Carl G. Pemberton III & Cynthia L. Pemberton
2805 Litchfield Dr
Browns Summit NC 27214
Burnham Ricky A & Debra Jean
5193 Blakeshire Rd
Greensboro NC 27406
Thomas Julius G. Jr
211 S. Chapman St
Greensboro NC 27403
Mayberry J N
1410 Corregidor St
Greensboro NC 27406
Perdue Brothers Inc.
3500 - B Rehobeth Church Rd
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 154
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 155
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 156
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 157
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 158
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 159
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 161
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 162
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 163
Greensboro NC 27406
Resident
3215 Rehobeth Church
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 164
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 165
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 166
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 167
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 169
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 170
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 173
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 178
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 176
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 177
Greensboro NC 27406
Resident
3219 Rehobeth Church
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 171
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 180
Greensboro NC 27406
Resident
1702 Earl Dr
Greensboro NC 27406
Resident
724 Creek Ridge Rd
lot 172
Greensboro NC 27406
Carolina Harvest Church
C/O Jeff Caske
8205 Birchdale Dr
Greensboro NC 27455
JA6
c?l?eL?;?eo? nJG Z 74is- ¢99 ?
APPENDIX G
SOUTH BUFFALO CREEK CONDITION ASSESSMENT
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Sketch Draw a sketch of Sampling Reach indicating areas sampled.
2 kicks
3 sweeps
leaf-pack
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Visual (10 min)

Comments:
Number of Photos: I Ook C sta,,1 C J - o 'n fry rn
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Stream Name SCXnnA. OOP t.a EEk, Location T?iVa l+. q?MENT FA-<-jTjrj
Site ID: Stream Class
Lat: - Lon : River Basin
Investigators K. Cat i DYG S Date: < uL to Zooo Time: Db
Weather Conditions: r. "`'"?'
Now Past 24 hours Air Temp. Z°F

storm ea rain)
?-
--'' ?"
Heavy rain last 7 days? t?
stead rain
showers (intermittent) /
cloud cover (percent)
clear sunny
Riparian Zone/ Predominant Land use Bank Erosion (looking downstream)
In-stream
Features -Forest Commercial
-Agricultural 2! Residential Let ht
Severe RiSevere
-Industrial -Park -Heavy _Heavy
-Mixed -Other -Moderate -Moderate
-Minor Minor
Canopy Cover: None -None
-Partly open
Partly shaded 1( Shaded -
4N
- `
Stream Width S -R)
m
Channelized )-Yes No Channel Width 10-11 m

? High Water Mark _A m
Dam Present -Yes
No
Stream Depth
Flow Conditions: Riffle m
-High -Medium Low Pool m
Velocity m/sec
Riparian ?I99,,dicate the dominant type and record dominant species present
Vegetation X_Trees -Shrubs -Grass -Mowed
I8 meter buffer) dominantspecies
Water Quality Temperature: ;Z5,6 'C Dissolved Oxygen: of mgll
Specific pH: -7,31 su
Conductance: x2)5 µmhosrcm
T
id

TDS: , a y I urb
ity:_-NTU
INORGANIC SUBSTRATE COMPONENTS
(should add un to 100%)
Substrate
Tv e. Diameter % Composition in
Sampling Reach
Boulder > 256 mm (10 in)
Cobble 64-256 mm (2S - 10 in.) S
Gravel 2.64 mm 0.1- 2.5 in)
Sand 0.06.2mm (ari ) 5
Silt 0.004-0.06 mm 05
A

on fu 1W :"t,
mu bt?-
Ambient Water Quality Conditions, 1999-2000
South Buffalo Creek at Merritt Dr.
Date 7/22/99 9/20/99 11/10/99 2/17/00 3/15/00 5/10/00 7/12/00 9/12/00 Mean
Time
Cadmium mg/I
Copper mg/I
Lead mg/I
Zinc mg/I
Alkalinity mg/I
BOD mg/I
COD mg/I
Fecal Coliform CFU/100ml
hardness mg/I
Nitrate Nitrogen mg/I
Nitrite Nitrogen mg/I
TDS mg/I
TSS mg/I
TKN mg/I
T. Phosphorus mg/I
pH su
Temperature Celsius
DO mg/I
DO Saturation %
Turbidity NTU
Conductivity mmhos/cm
14:26 11:50 10:45 13:25 10:55 11:07 13:40 11:50
0.00018 0.00005 0.00004 0.00009 0.00011 0.00007 0.00006 0.00004 0.00008
0.009 0.005 0.003 0.004 0.009 0.003 0.002 0.002 0.005
0.0071 0.0018 0.0012 0.0022 0.0072 0.0015 0.0002 0.0006 0.0029
0.032 0.011 0.007 0.019 0.026 0.006 0.006 0.005 0.014
27.0 54.5 83.6 52.9 64.7 79.9 64.6 29.2 57.4
2.1 2.0 2.2 2.0 2.4 2.0 3.7 2.2 2.3
20.0 20.0 20.0 20.0 22.4 20.0 24.7 20.0 20.9
3900.0 1100.0 84.0 240.0 5100.0 2300.0 2800.0 880.0 2050.5
38.0 65.0 90.0 59.2 83.0 76.2 71.2 85.0 71.8
0.5 0.48 0.1 0.8 0.2 0.4 0.1 0.1 0.3
0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1
74.0 134 178.0 153.0 174.0 134.0 107.0 120.0 134.3
40.0 21.0 4.0 7.0 76.0 18.0 7.0 3.0 22.1
0.8 0.5 0.5 0.9 0.8 0.5 0.5 0.5 0.6
0.1 0.06 0.1 0.0 0.2 0.1 0.1 0.0 0.1
6.5 6.6 6.7 6.9 7.4 6.7 7.3 7.5 6.9
27.8 18.2 13.8 8.3 10.9 21.6 23.6 22.5 18.3
6.3 8.5 8.3 11.1 6.5 7.3, 5.4 8.1 7.7
80.7 78.2 98.4 59.8 81.8 64.7 95.5 79.9
191.0 74.6 26.0 49.1 194.0 26.7 7.0 16.6 73.1
100.0 206.0 219.0 245.0 230.0 223.0 219.0 207.0 206.1
Ambient Water Quality Conditions, 1999-2000
South Buffalo Creek at Randleman Rd.
Date 7/22/99 9/20/99 11/10/99 2/17/00 3/15/00 5/10/00 7/12/00 9/12/00 Mean
Time 15:15 12:15 11:11 13:50 11:18 11:31 14:15 12:25
Cadmium mg/I 0.00013 0.00011 0.00004 0.00011 0.00009 0.00004 0.00007 0.00004 0.00007
Copper mg/I 0.006 0.004 0.002 0.004 0.003 0.002 0.002 0.003 0.003
Lead mg/I 0.0026 0.0008 0.0003 0.0015 0.0008 0.0006 0.0003 0.0003 0.0009
Zinc mg/I 0.016 0.006 0.005 0.013 0.005 0.005 0.005 0.005 0.008
Alkalinity mg/I 34.6 57.6 76.0 57.5 84.0 67.2 67.4 41.2 61.1
BOD mg/I 2.0 2.0 6.4 2.0 3.0 2.0 2.2 2.0 2.7
COD mg/I 20.0 20.0 20.0 20.0 20.0 20.0 40.2 20.0 22.5
Fecal Coliform CFU/100m1 2400.0 290 30.0 2400.0 550.0 410.0 1500.0 440.0 1104.3
hardness mg/I 42.0 67.5 105.0 62.4 93.0 72.6 65.0 121.0 80.1
Nitrate Nitrogen mg/I 0.4 0.41 0.2 0.8 0.4 0.3 0.2 0.1 0.3
Nitrite Nitrogen mg/I 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1
TDS mg/I 90.0 126 196.0 140.0 172.0 140.0 123.0 142.0 143.3
TSS mg/I 22.0 5.0 5.0 1.0 3.0 1.0 1.0 0.1 4.7
TKN mg/I 0.9 0.5 0.5 0.9 0.5 0.5 0.5 0.5 0.6
T. Phosphorus mg/I 0.1 0.03 0.0 0.0 0.0 0.1 0.0 0.0 0.0
pH su 6.6 6.7 6.8 7.0 7.4 6.8 7.9 7.5 7.1
Temperature Celsius 28.9 18.1 15.4 9.4 11.2 21.0 24.3 22.1 18.8
DO mg/I 6.5 7.4 9.4 11.1 9.7 6.8 6.5 6.6 8.0
DO Saturation % 73.2 87.1 96.8 88.5 75.5 79.1 76.1 82.3
Turbidity NTU 77.2 19.8 8.7 32.5 13.4 12.0 4.7 9.4 22.2
Conductivity mmhos/cm 118.0 207.0 240.0 265.0 264.0 239.0 238.0 234.0 225.6,
12/19/00 Macroinvertebrate Species List
STREAM: South Buffalo Creek
SITE: Merritt Drive
BASIN: SB1
Collection Date: 9/13/99
Collectors: Kim Yandora Roy Graham
Order Familv Genus Species Tv No. Abundance
Arnynocnoboemoa trponaemaae trpobdella sp. 8 5 L
Decapoda Cambaridae 7.5 3 C
Ephemeroptera Baetidae Baetis intercalaris 4.99 18 A
Odonata Coenagrionidae Argia sp. 8.17 1 R
Megaloptera Corydalidae Corydalus cornutus 5.16 1 R
Trichoptera Hydropsychidae Cheumatopsyche sp. 6.22 27 A
Trichoptera Hydropsychidae Hydropsyche betteni gp. 7.78 14 A
Coleoptera Dryopidae Helichus basa/is 4.63 1 R
Coleoptera Elmidae Stenelmis sp. 5.1 5 C
Diptera Chironomidae Cricotopus sp. 7 1 R
Diptera Chironomidae Dicrotendipes sp. 8.1 2 R
Diptera Chironomidae Polypedilum illinoense 9 2 R
Diptera Chironomidae Rheocricotopus robacki 7.28 2 R
Diptera Chironomidae Thienemannimyia gp. 8.42 6 C
Diptera Tipulidae Tipula sp. 7.33 3 C
Total # of Organisms 91
Total Taxa 15
Total EPT 3
EPT Abundance 32
NCBI 6.63
Bioclassifcation Poor
Habitat Score 73
City of Greensboro 1999 Macroinvertebrate Species List Storm Water Services
STREAM: South Buffalo Creek
SITE: Randleman Road
BASIN: S62
Collection Date: 13-Sep-99
Collectors: Kim Yandora David Phlegar
Roy Graham Larry Archer
Order Family Genus Species Tv No. Abundance
Veneroida Corbiculidae Corbicula fluminea 6.12 14 A
Decapoda Cambaridae 7.5 3 C
Odonata Calopterygidae Calopteryx sp. 7.78 3 C
Odonata Coenagrionidae Argia sp. 8.17 27 A
Odonata Corduliidae Macromia sp. 6.16 3 C
Odonata Gomphidae Progomphus obscurus 8.22 4 C
Trichoptera Hydropsychidae Cheumatopsyche sp. 6.22 4 C
Coleoptera Dryopidae Helichus basa/is 4.63 1 R
Diptera Chironomidae Cricotopus sp. 7 1 R
Diptera Chironomidae Nanocladius sp. 7.07 2 R
Diptera Chironomidae Polypedilum convictum 4.93 1 R
Diptera Chironomidae Polypedilum halterale 7.31 5 C
Diptera Chironomidae Polypedilum illinoense 9 3 C
Diptera Chironomidae Rheocricotopus robacki 7.28 3 C
Diptera Chironomidae Tanytarsus sp. 6.76 1 R
Diptera Chironomidae Thienemannimyia gp. 8.42 2 R
Total # of Organisms 77
Total Taxa 16
Total EPT 1
EPT Abndance 4
NCBI 7.2
Bioclassifcation POOR
Habitat Score 58
12/19/00
Macroinvertebrate Species List
STREAM: South Buffalo Creek
SITE: McConnell Avenue
BASIN: S64
Collection Date: 9/21/99
Collectors: Kim Yandora Roy Graham
Peter Schneider Larry Archer
Order Family Genus Species Tv No. Abundance
Veneroida Corbiculidae Corbicu/a fluminea 6.12 13 A
Haplotaxida Enchytraeidae 9.84 1 R
Haplotaxida Naididae 8 1 R
Isopoda Asellidae Caecidotea sp. 9.11 1 R
Ephemeroptera Baetidae Baetis intercalaris 4.99 4 C
Odonata Calopterygidae Calopteryx sp. 7.78 5 C
Odonata Coenagrionidae 9 7 C
Odonata Coenagrionidae Argia sp. 8.17 9 C
Odonata Corduliidae Macromia sp. 6.16 1 R
Odonata Gomphidae Gomphus sp. 5.8 1 R
Odonata Gomphidae Progomphus obscurus 8.22 17 A
Trichoptera Hydropsychidae Cheumatopsyche sp. 6.22 34 A
Trichoptera Hydropsychidae Hydropsyche sp. 5 1 R
Trichoptera Philopotamidae Chimarra aterrima 2.76 1 R
Coleoptera Elmidae Stenelmis sp. 5.1 3 C
Diptera Chironomidae Ablabesmyia mallochi 7.19 3 C
Diptera Chironomidae Cricotopus sp. 7 19 A
Diptera Chironomidae Parametriocnemus lundbecki 3.65 1 R
Diptera Chironomidae Phaenopsectra sp., 6.5 1 R
Diptera Chironomidae Polypedilum convictum 4.93 4 C
Diptera Chironomidae Polypedilum halterale 7.31 6 C
Diptera Chironomidae Polypedilum illinoense 9 10 A
Diptera Chironomidae Rheocricotopus robacki 7.28 20 A
Diptera Chironomidae Rheotanytarsus sp. 5.89 10 A
Diptera Chironomidae Tanytarsus sp. 6.76 13 A
Diptera Chironomidae Thienemannimyia gp. 8.42 4 C
Diptera Chironomidae Zavrelia sp. 5.3 1 R
Total # of Organisms 191
Total Taxa 27
Total EPT 4
EPT Abndance 40
NCBI 6.97
Bioclassifcation POOR
Habitat Score 47
Preliminary Bioclassification Summary Table
Benthic Macroinvertebrates, collected Summer 2000
Total Biotic Biotic
Taxa Total No. EPT Index EPT Index
Site ID Stream Location Richness Abund. EPT Abund. Value Score Score Bioclassif.
BAC1 Big Alamance Cr. Alamance Church Rd. at Coble Rd. 54 590 14 439 5.7 2.4 4 Good-Fair
BMR1 Mile Run Gillespie Golf Course 37 205 4 55 7.11 1 2 Poor
BRC1 RM Ryan Creek Behind 2426 Randleman Road 50 891 6 615 6.82 1.4 2 Fair
BSB1 S. Buffalo Creek Upstream of Merritt Drive ISM site. 54 590 3 235 7.55 1 1 Poor
BS61 BT S. Buffalo Creek Big Tree Way (Park) 43 250 3 48 7.15 1 2 Poor
BS62MV S. Buffalo Creek Meadowview Ave. 41 271 3 110 7.56 1 1 Poor
BSB2RM S. Buffalo Creek Randleman Rd. 35 309 3 177 6.99 1 2 Poor
BSB2RR S. Buffalo Creek Rolling Roads Park 39 244 3 59 7.13 1 2 Poor
BSB2W1L S. Buffalo Creek Proposed Constructed Wetland Site 39 233 4 99 7.33 1 2 Poor
BSB3RR S. Buffalo Creek Railroad Trestle at Thurston Road. 34 150 4 50 6.95 1 2 Poor
BS134 S. Buffalo Creek McConnell Rd. 44 294 7 103 6.77 1.4 2 Fair
RPC1BM Polecat Creek Branson Mill Rd. 47 537 10 347 5.03 2 5 Fair
RSC01 LB Sandy Creek Low Bridge Road, Randolph CO. 65 1195 21 936 4.68 3 5 Good
U
North Carolina DWQ Fish Community Collection CC `aum 99-Ti
f?o ?- 2$ 3iuCias:; pc r
G
..._.... Shuck Units i31 score 5t;au:, [CA SR 3300 Shock Our

....t:r:h;• LiUIL'rilRC.1 '1Ji?ath
s.r. i;? 3ubbasln 2 Depth
I'ata 61.2799 Drainage
Elevation
Latin Nerne
%H 5..!. I r.r
f----- VJater'Oizlity Data V I-
.t.-t Dis. ` ?23.8 Temceratw 20,4 Conductance 226
Water Clarity Turbid
Tmpn.-- Status M-Year BI NUm?C$r Exotic
Catostomidae Erimyzon oblongus Omnivore No Inter.
?
Gentrarchtdae Lepornisaur'ttus insectivore Yes Toi, jC4
Centrarchtdae Lepomis cyanellus insectivore Yes Toi, ' 7 Yes
a_rtt,-archidae Lepomisgibbt;sus insec4iv-cre Yes Inter. a t
Carwarctiidae?- Lepornis macrochirus Insectivore Yes Inter. 5
C:enirarc tidae Lepomis sp. Insectivore No fol. ` i 'Yes
Gantrarchidae Micropterus salmoides Pisclvase No Inter. 2
Cypnnidae Cyprinellat,utrensis Insectivore Yes To-1 . 80 Yes
C )rnif?ae Norris leptocephatus Omnivore No Inter.
Ictalundae Ameiuru$ nebulosus Omnivore' No 001, ' i
Ictalur=dae Ameiurus piatycephalus Insectivore No Tol. " S
Percicae Etheostoma olmstedi Specialized Insectivore No Into(. 1 "
°c3ecnidae Gambusia holbrooki Insectivore Yes Tot. ' 21
North Carolina Fish Metrics Value Score
No of iiGC7 StiJrS: 1 (::nties < IG rpCClCS SIQTC 3 ranges < rG SpCC:C5 ACC?fC ` ttf[t M' .I:e:;--7CS i? 3
ta.:+f tisn ... ,. __ Score I rxngcs' 3115 tish Sco 3 senses <4jf (ieh Score r: tgc:>= :. I 6,01 =0 >
Nil, of datl :+C _ Scare I f'1n.S"C5 <0.) darters Scorc 3 ranges < 1.7 darters Scott, 5 r:l:d1C, >-t 1.:1:'.crj i I
No. of Sunfish and trout- Score I : 0 to 2 Score 3: 3 to 4 Score S : 5 and Ctrca:er - 3
No, of ?::t a Cf __ &orc I ranges < I suckers Score 3 rant g,°Cs < 2.3 suckcm Score ! cunt e, >=2,3 stick-crs l I
No. of Intolerant %r?WeS- Score I : U to t) Senfe s : 1 And Greeter 0 I
17- of toicrant lids- Scofc i .. 9 to <20- Score 1: 20 to 45 Score t : >45 te. I!?11 95 I
of omnivares;.Pied),„,,,, Score 1 :>45 to WO Score 1 ; 0 to S Score : y25 wi 45 S,:ora 5: >5 to try 1 1 '
'tt of insectiVOres (Piece)- Score I : >9a - to 100 Score I : 0 to 60 Score 3: >60 to -'S S,:ore 5 : >75 to 95 4:3 €
%, of pi sci vores- Score I : 0 to <t Score 3 . I to t Score 5 : >2 to 100 0.5 I
°t of diseased ti sit- Scoire S - 0 to 2 Score 3 : >2 to 5 Score : >S to 100 015 5
of species with multiple agc groups,,,,_,_ Score t : 0 to <40 Score 3 : 40 to 60 Scorer >ffx ro iW 50 3
CPUE: 14,1 No. Exotic Fish: r 88 No. Exotic ?•ec es:
Field Notes:
Collectors= Hale. MacPherson. Medlin. Tracy (plus Gretnsboro'.s Stdrrawamt staff •- P. Schrmder & P LiLneschl
Subsuate. = sand. 'lay
Runs, no rilflca. masts, clay bunks. no canopy
Sec:hl druth = SQ cm.
No seine USccl
Sampled for r,(xl ((.:(tiny( ratim:al tsestle stckc Industrial r1 acttuc from SOU=h Eim•Fngcne Sirces x, I'laue:tUrt Road).
y

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
March 7, 2001
IN REPLY REFER TO
Regulatory Division
Action ID No. 200120540
Mr. John Dorney
Water Quality Section
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Dear Mr. Dorney:

Enclosed is the application of the City of Greensboro's Storm water Management Division
for Department of the Army (DA) authorization and a State Water Quality Certification for the
proposed discharge of fill material into the stream channel and adjacent wetlands of South
Buffalo Creek associated with the proposed construction of a stormwater treatment wetland
system located off of Rehobeth Church Road at the intersection of I-40 and Freeman Mill Road,
in Greensboro, Guilford County, North Carolina. The proposed work would result in impacts to
approximately 0.23 acre of jurisdictional waters of the United States, including approximately
150 linear feet of stream channel. Your receipt of this letter verifies your acceptance of a valid
request for certification in accordance with Section 325.2(b)(ii) of our administrative regulations.
We are considering authorizing the proposed activity pursuant to Section 404 of the
Clean Water Act, and we have determined that a water quality certification is required under the
provisions of Section 401 of the same law. A Department of the Army permit will not be granted
until the certification has been obtained or waived.
In accordance with our administrative regulations, in most cases, 60 days after receipt of
a request for certification is a reasonable time for State action. Therefore, if you have not acted
on the request, or asked for an extension of time, by May 7, 2001, the District Engineer will
deem that waiver has occurred.

If you have questions, please do not hesitate to contact Mr. John Thomas, Raleigh
Regulatory Field Office, telephone [phone].
Sincerely,
?.
?f Z&6
S. Kenneth Jolly
Chief, Raleigh Regulatory
Field Office
Enclosure
Copy Furnished (without enclosure):
Mr. Doug Huggett
Division of Coastal Management
North Carolina Department of
Environment and Natural Resources
1638 Mail Service Center
Raleigh, North Carolina 27699-1638
5433
ww ?? CITY OF GREENSBORO
P.O.60X3136
G NORTH' CAROLINA GREENSBORO, NC 27402-3136
1808
March 7, 2001?
State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality - Wetlands/401 Unit
Attention: Mr. John Dorney
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Re: Application Fee for $01 Water Quality Certification
DWQ# 010263: Stormwater Treatment Wetland Project in Greensboro
Dear Mr. Dorney:
In reference to your letter dated February 22, 2001 addressed to Mr. Scott Bryant
regarding the subject project, we are enclosing a check for $475 toward the application
fee for 401 certification for Greensboro's Stormwater Treatment Wetland project: DW #
010263.
We would appreciate your prompt review of the City's application. Please call me at 336-
373-2494 or e-mail to [e-mail], if there are any
questions concerning the application. Thank you.
Sincerely,
CITY OF GREENSBORO
f&4. J4??
V. S. Shastri Annambhotla, Ph.D.,PE
Stormwater Engineering Specialist
Water Resources Department
Cc: Scott Bryant, PE
Mike Cramer
Jeremy Thomas, EI

f as3 to
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael Easley, Governor
William Ross, Secretary
Kerr T. Stevens, Director
Scott D. Bryant
City of Greensboro Stormwater Division
PO Box 3136
Greensboro, NC 27402-3136
Dear Mr. Bryant:
e??
AWOMM"
NC ENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 22, 2001
DWQ# 010263

On February 22, 2001, your application for 401 Water Quality Certification for a
project in Guilford County was received by the N.C. Division of Water Quality. Please
note that beginning January 1, 1999, the N.C. General Assembly passed legislation
requiring payment of a fee for all 401 applications. Your application is being placed on
hold since no payment was received with the package. The fee for applications is $200
for projects impacting less than an acre of wetland and less than 150 linear feet of
streams. For projects impacting one or more acres of wetland or 150 or more feet of
streams, the fee is $475. In order for DWQ to review and process your request, you must
send a check in the appropriate amount made payable to the N.C. Division of Water
Quality.
Please call Robert Ridings or Cyndi Karoly at 919-733-1786 or visit our web site
at http://h2o.enr.state.nc.us/ncwetlands if you have any questions regarding this fee.
cc:
letter.
Also, please take note that our address has changed, as seen on the bottom of this
Central Files
File Copy

Wetlands/401 Unit 2321 Crabtree Blvd. Suite 250 Raleigh, North Carolina 27604
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post consumer paper
t

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CITY OF GREENSBORO
P.O. BOX 3136
Greensboro, NC 27402-3136
F
NC DEPT :ENVIRONMENT & NATURAL R Vendor No. 79014 Page I OF I
WATER QUALITY DIVISION Payment Date 43109/01 Bank No. o9
1617 MAIL SERVICE CENTER
RALEIGH NC 27699 1617
L I CHECK NO. 8889 AMOUNT X475.00
DESCRIPTION
APPLICATION FEE FOR 401 WATER
QUALITY CERTIFICATION FOR STORMWATER
TREATMENT WETLAND PROJECT
PO/CO NBR AMOUNT
01-105552 475.00
ACCOUNT NUMBER AMOUNT ACCOUNT NUMBER AMOUNT
2203-6550-031 . 5917 475.00
20th
s
Action ID No. 200120540
DEPARTMENT OF THE ARMY
Wilmington District, Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road, Suite 120
Raleigh, North Carolina 27615-6814
March 13, 2001
PUBLIC NOTICE
Mr. Scott Bryant, City Of Greensboro, Stormwater Management Division, Post Office Box
3136, Greensboro, North Carolina 27402-3136 has requested a Department of the Army (DA)
permit TO AUTHORIZE THE DISCHARGE OF FILL INTO THE'JURISDICTIONAL
WATERS OF SOUTH BUFFALO CREEK ASSOCIATED WITH THE PROPOSED
CONSTRUCTION OF A STORMWATER TREATMENT WETLAND SYSTEM LOCATED
OFF OF REHOBETH CHURCH ROAD AT THE INTERSECTION OF I-40 AND FREEMAN
MILL ROAD, IN GREENSBORO, GUILFORD COUNTY, NORTH CAROLINA.
The following description of the work is taken from data provided by the applicant and
from observations made during a site visit by a representative of the Corps of Engineers. The
project site is a 34-acre tract that includes approximately 2500 linear feet of stream channel
(South Buffalo Creek) and approximately 3.1 acres of wetlands adjacent to South Buffalo Creek.
Plans submitted with the application depict the construction of a 40-foot wide by 12-foot high
water control gate structure within the banks of South Buffalo Creek. To construct the water
control gate structure, South Buffalo Creek will have to be temporarily rerouted into a diversion
channel. The total stream disturbance during construction is approximately 275 linear feet.
Once completed, the concrete water control gate structure and associated rip rap will
permanently impact approximately 150 linear feet (0.14 acre) of the jurisdictional stream channel
of South Buffalo Creek. The remaining portion of the disturbed channel (approximately 125
linear feet) will be restored to the original stream geometry using bioengineering techniques.
The water control gate structure also includes an earthen dike constructed on the adjacent flood
plain of South Buffalo Creek. This dike is comprised of approximately 400 linear feet of fill
within the flood plain, resulting in approximately 3,250 square feet (0.08 acre) of impacts to
jurisdictional wetlands adjacent to South Buffalo Creek. The site's steam banks will be
modified (either excavated or filled) to facilitate storm water flooding (flood elevation of 741 ft.
msl) within adjacent flood plains and jurisdictional wetlands. These stream bank modifications
include fill activities resulting in approximately 250 square feet (0.01 acre) of impacts to
jurisdictional wetlands adjacent to South Buffalo Creek. Permanent road access required for
periodic maintenance of the water control gate structure will result in impacts to approximately
20 linear feet (0.01 acre) of an unnamed tributary of South Buffalo Creek.
Total impacts for the proposed project include the fill of approximately 0.23 acre
(including approximately 150 linear feet of stream habitat) of the jurisdictional waters and
adjacent wetlands of South Buffalo Creek. It should be noted that the hydrology of the site's
2
approximately 2500 linear feet of stream channel and approximately 3.1 acres of wetlands will be
altered (increased flood frequency and duration) by the project's storm water gate structure and
existing stream bank modification. The stated project purpose is to enhance the water quality of
South Buffalo Creek. This is proposed to be accomplished by constructing a Stormwater
Treatment Wetland System designed to treat the "first flush" of stormwater runoff from the
highly developed commercial properties adjacent to the headwaters of South Buffalo Creek. The
City of Greensboro anticipates that the project will provide a net gain in benefit to stream water
quality. Therefore, no mitigation is proposed. Plans showing the work are included with this
public notice. A copy of this public notice can be viewed on our web page at
htlp://www.saw.usace.arm.mil.
The State of North Carolina will review this public notice to determine the need for the
applicant to obtain any required State authorization. No Department of the Army (DA) permit
will be issued until the coordinated State viewpoint on the proposal has been received and
reviewed by this agency, nor will a DA permit be issued until the North Carolina Division of
Water Quality (NCDWQ) has determined the applicability of a Water Quality Certificate as
required by PL 92-500.
This application is being considered pursuant to Section 404 of the Clean Water Act (33
U.S.C. 1344). Any person may request, in writing within the comment period specified in the
notice, that a public hearing be held to consider this application. Requests for public hearing
shall state, with particularity, the reasons for holding a public hearing.
The District Engineer has consulted the latest published version of the National Register
of Historic Places for the presence or absence of registered properties, or properties listed as
being eligible for inclusion therein, and this site is not registered property or property listed as
being eligible for inclusion in the Register. Consultation of the National Register constitutes the
extent of cultural resource investigations by the District Engineer, and he is otherwise unaware of
the presence of such resources. Presently, unknown archeological, scientific, prehistorical, or
historical data may be lost or destroyed by work under the requested permit.
The District Engineer has determined, based on a review of data furnished by the applicant
and onsite observation, that the activity will not affect species, or their critical habitat, designated
as endangered or threatened pursuant to the Endangered Species Act of 1973.
The decision whether to issue a permit will be based on an evaluation of the probable
impacts, including cumulative impacts, of the proposed activity and its intended use on the
public interest. Evaluation of the probable impacts, which the proposed activity may have on the
public interest, requires a careful weighing of all those factors, which become relevant in each
particular case. The benefits, which reasonably may be expected to accrue from the proposal,
must be balanced against its reasonably foreseeable detriments. The decision whether to
authorize a proposal, and if so the conditions under which it will be allowed to occur, are
therefore determined by the outcome of the general balancing process. That decision should
reflect the national concern for both protection and utilization of important resources. All
factors, which may be relevant to the proposal, must be considered including the cumulative
3
effects thereof. Among those are conservation, economics, aesthetics, general environmental
concerns, wetlands, cultural values, fish and wildlife values, flood hazards and flood plain values
(in accordance with Executive Order 11988), land use, navigation, shore erosion and accretion,
recreation, water supply and conservation, water quality, energy needs, safety, food and fiber
production, mineral needs, considerations of property ownership, and, in general, the needs and
welfare of the people. For activities involving the placement of dredged or fill materials in
waters of the United States, a permit will be denied if the discharge that would be authorized by
such permit would not comply with the Environmental Protection Agencies' 404(b)(1)
guidelines. Subject to the preceding sentence and any other applicable guidelines or criteria, a
permit will be granted unless the District Engineer determines that it would be contrary to the
public interest.
The Corps of Engineers is soliciting comments from the public; Federal, State and local
agencies and officials; Indian Tribes and other interested parties in order to consider and evaluate
the impacts of this proposed activity. Any comments received will be considered by the Corps of
Engineers to determine whether to issue, modify, condition or deny a permit for this proposal.
To make this decision, comments are used to assess impacts on endangered species, historic
properties, water quality, general environmental effects and the other public interest factors listed
above. Comments are used in the preparation of an Environmental Assessment (EA) and/or an
Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act
(NEPA). Comments are also used to determine the need for a public hearing and to determine
the overall public interest of the proposed activity.
Generally, the decision whether to issue this Department of the Army (DA) permit will not
be made until the North Carolina Division of Water Quality (NCDWQ) issues, denies, or waives
State certification required by Section 401 of the Clean Water Act. The NCDEM considers
whether or not the proposed activity will comply with Sections 301, 302, 306, and 307 of the
Clean Water Act. The application and this public notice for the Department of the Army (DA)
permit serves as application to the NCDWQ for certification.
Additional information regarding the Clean Water Act certification may be reviewed at the
offices of the North Carolina Division of Water Quality (NCDWQ), Salisbury Street, Archdale
Building, Raleigh, North Carolina. Copies of such materials will be furnished to any person
requesting copies upon payment of reproduction costs.
All persons desiring to make comments regarding the application for Clean Water Act
certification should do so in writing delivered to the North Carolina Division of Water Quality
(NCDWQ), Wetland/401 Unit, 1621 Mail Service Center, Raleigh, North Carolina 27699-1621, on
or before April 6, 2001, Attention: Mr. John Dorney.
Written comments pertinent to the proposed work, as outlined above, will be received in
this office, Attention: Mr. John Thomas, until 4:15 p.m., April 12, 2001, or telephone (919) 876-
8441, Extension 25.
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael Easley, Governor
William Ross, Secretary
Kerr T. Stevens, Director
01?W'A
IT 0 0
A&4;1 2
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 22, 2001
DWQ# 010263
Scott D. Bryant
City of Greensboro Stormwater Division
PO Box 3136
Greensboro, NC 27402-3136
Dear Mr. Bryant:
On February 22, 2001, your application for 401 Water Quality Certification for a
project in Guilford County was received by the N.C. Division of Water Quality. Please
note that beginning January 1, 1999, the N.C. General Assembly passed legislation
requiring payment of a fee for all 401 applications. Your application is being placed on
hold since no payment was received with the package. The fee for applications is $200
for projects impacting less than an acre of wetland and less than 150 linear feet of
streams. For projects impacting one or more acres of wetland or 150 or more feet of
streams, the fee is $475. In order for DWQ to review and process your request, you must
send a check in the appropriate amount made payable to the N.C. Division of Water
Quality.
Please call Robert Ridings or Cyndi Karoly at 919-733-1786 or visit our web site
at http://h2o.enr.state.nc.us/ncwetlands if you have any questions regarding this fee.
letter.
Also, please take note that our address has changed, as seen on the bottom of this
cc: Central Files
File Copy
Porn ey
Wetlands/401 Unit . 2321 Crabtree Blvd. Suite 250 Raleigh, North Carolina 27604
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post consumer paper
North Carolina
Department of Environment and Natural Resources
Division of Coastal Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Donna D. Moffitt, Director
April 3, 2000
MEMORANDUM
TO: Mr.. Kerr T. Stevens
Director
Division of Water Quality
FROM: Douglas V. Huggett
Inland "404" Coordinator
SUBJECT: "404" Project Review
NCDENR
o 3

The attached U.S. Army Corps of Engineers Public Notice for Action No. 200120540dated
March 13, 2001 describing a proposed project by MR. SCOTT BRYANT, CITY OF GREENSBORO-
GUILFORD CO. is being circulated to interested state agencies for comments on applicable Section 404
and/or Section 10 permits.
Please indicate below your agency's position or viewpoint on the proposed project and return this form
by 4/24/2001. If you have any questions regarding the proposed project, please contact me at 733-2293.
When appropriate, in-depth comments with supporting data is requested.
REPLY
Signed
This office supports the project proposal.
No comment.
Comments on this project are attached.
This office objects to the project as proposed.
Date
1638 Mail Service Center, Raleigh, North Carolina 27699-1638
Phone: [phone] \ FAX: [phone] \ Internet: http://dcm2.enr.state.nc.us
AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPER
North Carolina
Department of Environment and Natural Resources
Division of Coastal Management
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Donna D. Moffitt, Director
April 3, 2000
MEMORANDUM
TO: Mr. Kerr T. Stevens
Director
Division of Water Quality
FROM: Douglas V. Huggett
Inland "404" Coordinator
SUBJECT: "404" Project Review
NCDENR
The attached U.S. Army Corps of Engineers Public Notice for Action No. 200120540dated
March 13, 2001 describing a proposed project by MR. SCOTT BRYANT, CITY OF GREENSBORO-
GUILFORD CO. is being circulated to interested state agencies for comments on applicable Section 404
and/or Section 10 permits.
Please indicate below your agency's position or viewpoint on the proposed project and return this form
by 4/2412001. If you have any questions regarding the proposed project, please contact me at 733-2293.
When appropriate, in-depth comments with supporting data is requested.
REPLY
Signed
This office supports the project proposal.
No comment.
Comments on this project are attached.
This office objects to the project as proposed.
Date
1638 Mail Service Center, Raleigh, North Carolina 27699-1638
Phone: [phone] \ FAX: [phone] \ Internet: http://dcm2.enr.state.nc.us
AN EQUAL OPPORTUNrrY \ AFFIRMATWE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPER
r
DEPARTMENT OF THE ARMY
Wilmington District, Corps of Engineers
Raleigh Regulatory Field Office
6508 Falls of the Neuse Road, Suite 120
Raleigh, North Carolina 27615-6814
Action ID No. 200120540
March 13, 2001
PUBLIC NOTICE
Mr. Scott Bryant, City Of Greensboro, Stormwater Management Division, Post Office Box
3136, Greensboro, North Carolina 27402-3136 has requested a Department of the Army (DA)
permit TO AUTHORIZE THE DISCHARGE OF FILL INTO THE JURISDICTIONAL
WATERS OF SOUTH BUFFALO CREEK ASSOCIATED WITH THE PROPOSED
CONSTRUCTION OF A STORMWATER TREATMENT WETLAND SYSTEM LOCATED
OFF OF REHOBETH CHURCH ROAD AT THE INTERSECTION OF I-40 AND FREEMAN
MILL ROAD, IN GREENSBORO, GUILFORD COUNTY, NORTH CAROLINA.
The following description of the work is taken from data provided by the applicant and
from observations made during a site visit by a representative of the Corps of Engineers. The
project site is a 34-acre tract that includes approximately 2500 linear feet of stream channel
(South Buffalo Creek) and approximately 3.1 acres of wetlands adjacent to South Buffalo Creek.
Plans submitted with the application depict the construction of a 40-foot wide by 12-foot high
water control gate structure within the banks of South Buffalo Creek. To construct the water
control gate structure, South Buffalo Creek will have to be temporarily rerouted into a diversion
channel. The total stream disturbance during construction is approximately 275 linear feet.
Once completed, the concrete water control gate structure and associated rip rap will
permanently impact approximately 150 linear feet (0.14 acre) of the jurisdictional stream channel
of South Buffalo Creek. The remaining portion of the disturbed channel (approximately 125
linear feet) will be restored to the original stream geometry using bioengineering techniques.
The water control gate structure also includes an earthen dike constructed on the adjacent flood
plain of South Buffalo Creek. This dike is comprised of approximately 400 linear feet of fill
within the flood plain, resulting in approximately 3,250 square feet (0.08 acre) of impacts to
jurisdictional wetlands adjacent to South Buffalo Creek. The site's stream banks will be
modified (either excavated or filled) to facilitate storm water flooding (flood elevation of 741 ft.
msl) within adjacent flood plains and jurisdictional wetlands. These stream bank modifications
include fill activities resulting in approximately 250 square feet (0.01 acre) of impacts to
jurisdictional wetlands adjacent to South Buffalo Creek. Permanent road access required for
periodic maintenance of the water control gate structure will result in impacts to approximately
20 linear feet (0.01 acre) of an unnamed tributary of South Buffalo Creek.
Total impacts for the proposed project include the fill of approximately 0.23 acre
(including approximately 150 linear feet of stream habitat) of the jurisdictional waters and
adjacent wetlands of South Buffalo Creek. It should be noted that the hydrology of the site's
2
approximately 2500 linear feet of stream channel and approximately 3.1 acres of wetlands will be
altered (increased flood frequency and duration) by the project's storm water gate structure and
existing stream bank modification. The stated project purpose is to enhance the water quality of
South Buffalo Creek. This is proposed to be accomplished by constructing a Stormwater
Treatment Wetland System designed to treat the "first flush" of stormwater runoff from the
highly developed commercial properties adjacent to the headwaters of South Buffalo Creek. The
City of Greensboro anticipates that the project will provide a net gain in benefit to stream water
quality. Therefore, no mitigation is proposed. Plans showing the work are included with this
public notice. A copy of this public notice can be viewed on our web page at
hM://www.saw.usace.pniay.mil.
ThQ State of North Carolina will review this public notice to determine the need for the
applicant to obtain any required Statd authorization. No Department of the Army (DA) permit
will be issued until the coordinated State viewpoint on the proposal has been received and
reviewed by this agency, nor will a DA permit be issued until the North Carolina Division of
Water Quality (NCDWQ) has determined the applicability of a Water Quality Certificate as
required by PL 92-500.
This application is being considered pursuant to Section 404 of the Clean Water Act (33
U.S.C. 1344). Any person may request, in writing within the comment period specified in the
notice, that a public hearing be held to consider this application. Requests for public hearing
shall state, with particularity, the reasons for holding a public hearing.
The District Engineer has consulted the latest published version of the National Register
of Historic Places for the presence or absence of registered properties, or properties listed as
being eligible for inclusion therein, and this site is not registered property or property listed as
being eligible for inclusion in the Register. Consultation of the National Register constitutes the
extent of cultural resource investigations by the District Engineer, and he is otherwise unaware of
the presence of such resources. Presently, unknown archeological, scientific, prehistorical, or
historical data may be lost or destroyed by work under the requested permit.
The District Engineer has determined, based on a review of data furnished by the applicant
and onsite observation, that the activity will not affect species, or their critical habitat, designated
as endangered or threatened pursuant to the Endangered Species Act of 1973.
The decision whether to issue a permit will be based on an evaluation of the probable
impacts, including cumulative impacts, of the proposed activity and its intended use on the
public interest. Evaluation of the probable impacts, which the proposed activity may have on the
public interest, requires a careful weighing of all those factors, which become relevant in each
particular case. The benefits, which reasonably may be expected to accrue from the proposal,
must be balanced against its reasonably foreseeable detriments. The decision whether to
authorize a proposal, and if so the conditions under which it will be allowed to occur, are
therefore determined by the outcome of the general balancing process. That decision should
reflect the national concern for both protection and utilization of important resources. All
factors, which may be relevant to the proposal, must be considered including the cumulative
•
3
effects thereof. Among those are conservation, economics, aesthetics, general environmental
concerns, wetlands, cultural values, fish and wildlife values, flood hazards and flood plain values
(in accordance with Executive Order 11988), land use, navigation, shore erosion and accretion,
recreation, water supply and conservation, water quality, energy needs, safety, food and fiber
production, mineral needs, considerations of property ownership, and, in general, the needs and
welfare of the people. For activities involving the placement of dredged or fill materials in
waters of the United States, a permit will be denied if the discharge that would be authorized by
such permit would riot comply with the Environmental Protection Agencies' 404(b)(1)
guidelines. Subject to the preceding sentence and any other applicable guidelines or criteria, a
permit will be granted unless the District Engineer determines that it would be contrary to the
public interest.
The Corps of Engineers is soliciting comments from the public; Federal, State and local
agencies and officials; Indian Tribes and other interested parties in order to consider and evaluate
the impacts of this proposed activity. Any comments received will be considered by the Corps of
Engineers to determine whether to issue, modify, condition or deny a permit for this proposal.
To make this decision, comments are used to assess impacts on endangered species, historic
properties, water quality, general environmental effects and the other public interest factors listed
above. Comments are used in the preparation of an Environmental Assessment (EA) and/or an
Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act
(NEPA). Comments are also used to determine the need for a public hearing and to determine
the overall public interest of the proposed activity.
Generally, the decision whether to issue this Department of the Army (DA) permit will not
be made until the North Carolina Division of Water Quality (NCDWQ) issues, denies, or waives
State certification required by Section 401 of the Clean Water Act. The NCDEM considers
whether or not the proposed activity will comply with Sections 301, 302, 306, and 307 of the
Clean Water Act. The application and this public notice for the Department of the Army (DA)
permit serves as application to the NCDWQ for certification.
Additional information regarding the Clean Water Act certification may be reviewed at the
offices of the North Carolina Division of Water Quality (NCDWQ), Salisbury Street, Archdale
Building, Raleigh, North Carolina. Copies of such materials will be furnished to any person
requesting copies upon payment of reproduction costs.
All persons desiring to make comments regarding the application for Clean Water Act
certification should do so in writing delivered to the North Carolina Division of Water Quality
(NCDWQ), Wetland/401 Unit, 1621 Mail Service Center, Raleigh, North Carolina 27699-1621, on
or before April 6, 2001, Attention: Mr. John Dorney.
Written comments pertinent to the proposed work, as outlined above, will be received in
this office, Attention: Mr. John Thomas, until 4:15 p.m., April 12, 2001, or telephone (919) 876-
8441, Extension 25.

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o?OF W A rF,?QG g ? Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
>
0 Alan W. Klimek, P.E. Director
Division of Water Quality
June 16, 2005
Mr. David Phlegar, Water Quality Supervisor
City of Greensboro, Stormwater Management. Division
P.O. Box 3136
Greensboro, NC 27402-3136
RE: Groundwater monitoring
Greensboro Stormwater. Management Project on South Buffalo Creek
DWQ # 01-0263; Action I D 200120540
Guilford County
The purpose of the letter is to respond to correspondence from the City of Greensboro
dated May 2, 2005 and our phone conversation yesterday. DWQ. believes that it will not
be necessary to continue the usage and maintenance of Solinst Leveloggers to record
continuous hydrological data since three years worth of continuous hydrological data
has been taken. At this time with regards to future monitoring, DWQ requests that the
City of Greensboro follows the recommendations as'defined by Dr. Jim Gregory of NC
State University:
1. Continue manual water level measurements in the 10 wells at two-week intervals
as the baseline water table data set for comparing long term "before/after' water
table trends.
2. When construction on the water control structure is completed to specifications
and will result in inundation of the floodplain, than re-install at least one automatic
recorder at a representative location to determine the floodwater retention time.
Alternatively, take daily manual measurements for 2-3 days after occasional
rainfall events that produce significant inundation.
Please feel free to call if you have any additional questions.
Sincerely,
'U yi 6JW
VirginirLBake r, E nvironmental Specialist II
Division of Water Quality, Wetlands and Stormwater Branch
CC: File copy
Raleigh Field Office US Army Corps of Engineers
Becky Fox, US Environmental Protection Agency
DWQ Winston-Salem Regional Office
Dr. Jim Gregory, North Carolina State University
401 Oversight/Express Review Permits Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: htt_p :,,h2o.enr.state.nc.us; iicwetlands
N?Orie nnCarolina
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