20100988 Ver 1_WRC Comments_20110601

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Andrew Williams, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 1 June 2011
SUBJECT: Public Notice for Mr. H. Dean Green, Greensboro Auto Auction, LLC for Expansion of
Greensboro Auto Auction and Redevelopment and New Development on an Adjacent
Tract, Greensboro, Guilford County, North Carolina. Corps Action ID #: SAW-2010-
00636
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d),
and North Carolina General Statutes (G.S. 113-131 et seq.).
The applicant proposes to permanently impact 295 linear feet of jurisdictional stream channel for
expansion of Greensboro Auto Auction, and re-development and new development on an adjacent tract.
Previous impacts include permanent impacts to 75 linear feet of stream channel, temporary impacts to 40
linear feet of stream channel, and permanent impacts to 2.8 acres of waters/wetlands. The purpose of the
project is to accommodate anticipated increased traffic volumes associated with the expansion of the
existing Greensboro Auto Auction, the redevelopment of an existing 30,000 square foot building, and the
demolition of a 21,500 square foot building in conjunction with new development in the area. Mitigation
for the project includes payment into the N.C. Ecosystem Enhancement Program.
The proposed project will impact an unnamed tributary to South Buffalo Creek in the Cape Fear
River Basin. South Buffalo Creek is on the State's 2010 303(d) list of impaired streams. Sheet 2 of 6 in
the public notice shows the proposed project also will impact floodplain areas on the site. Although the
approximately 26-acre site is developed and contains existing structures, aerial photography of the area
shows there are grassed and forested areas on the site.
According to the public notice, one structure will be remodeled for Kaplan University and will
include the addition of 290 parking spaces. An existing structure will be demolished and used for parking
for a proposed retail restaurant. Additional parking for Greensboro Auto Auction will be constructed on
the southern portion of the site. In addition, a 12-foot right turn lane with curb and gutter, grass strip and
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
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1 June 2011
Greensboro Auto Auction
Corps Action ID No.: SAW-2010-00636
concrete sidewalk is proposed along West Wendover Avenue. Impacts to streams will result from piping
for construction of the proposed turn lane and parking spaces.
On Sheet 6 of 6, the parking summary states an additional 300 spaces for car storage only;
additional 1162 spaces for car storage (occasionally used for employee (shuttle service) and overflow
customer parking) add 20 accessible spaces at the auto auction building; and additional 294 spaces
(includes 7 accessible spaces at existing building) for Kaplan University. Also included is a note that
states: no new buildings proposed; demolition of the existing Evergreens building and the buildings at
4015 and 4017 W. Wendover Avenue.
We have several comments and concerns regarding the proposed project:
• It appears direct impacts to aquatic resources will result from construction of the right turn lane
and 290 parking spaces for Kaplan University. We question whether some of these impacts could
be avoided or minimized by constructing a parking deck to accommodate Kaplan University's
need for additional parking spaces.
• According to Sheet 6 of 6, it appears all but one building will be demolished on the site and no
new buildings are proposed. If the remaining building will be used by Kaplan University, it is
unclear where the proposed retail restaurant will be located. We are concerned about
constructing parking spaces for a non-existent or proposed future structure.
It appears the proposed project will replace most of grassed and forested areas on the site with
impervious surface. We are concerned about the cumulative impacts to aquatic resources as a
result of fill in the floodplain, piping of the unnamed tributary, and increased stormwater runoff
from the additional impervious surface at the site. While we recognize this area is already highly
urbanized, additional impacts such as those proposed for this project have the potential to result in
further degradation of water quality and aquatic habitat in a watershed that already is listed as
impaired.
We hesitate to concur with the filling of stream channels due to the potential for long-term and
cumulative impacts. Placing fill in aquatic resources can alter hydrology, result in significant negative
impacts to downstream areas, and eliminate aquatic and terrestrial wildlife habitat. Increases in
impervious surfaces may exacerbate channel degradation and sediment impacts to stream ecosystems due
to increased stormwater runoff and elevated flooding. In addition, pollutants (e.g., sediment, heavy
metals, pesticides, and fertilizers) washed from roads and developed landscapes can adversely affect and
extirpate species downstream.
Protecting wide forested riparian corridors, the 100-year floodplain, and managing stormwater in
development areas are essential to protect water quality and aquatic and terrestrial wildlife habitat in
developing landscapes. Therefore, we offer the following recommendations to minimize impacts to
aquatic and terrestrial wildlife resources.
1. Consider using parking decks to minimize the impervious surface footprint while providing needed
parking space. This is particularly important for those areas that will directly impact streams,
wetlands, or floodplains.
2. Construct parking areas only for those facilities that currently exist and the need for the parking or
additional parking has been documented. We do not support constructing parking spaces in
anticipation of future buildings or businesses.
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1 June 2011
Greensboro Auto Auction
Corps Action ID No.: SAW-2010-00636
3. Maintain a 100-foot undisturbed, native, forested buffer along perennial streams, and a 50-foot buffer
along intermittent streams and wetlands. Maintaining undisturbed, forested buffers along these areas
will minimize impacts to aquatic and terrestrial wildlife resources, water quality, and aquatic habitat
both within and downstream of the project area. In addition, wide riparian buffers are helpful in
maintaining stability of stream banks and for treatment of pollutants associated with stormwater
runoff. Whereas, a grassed buffer, particularly fescue, is a vegetated buffer but will not provide the
necessary and highly valuable functions as discussed for forested buffers.
4. Avoid development and fill in the 100-year floodplain. Development and fill in the floodplain
increases the potential for flooding and interferes with the natural hydrologic process of the
waterways.
Limit impervious surface to less than 10% of the site or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. For any stormwater detention
ponds, trees and shrubs should be planted around the pond, excluding the dam, to provide habitat
benefits that offset those functions lost by development, partially restore aquatic habitats, reduce
exposure of the water surface to sunlight thereby minimizing thermal pollution, and provide essential
summer and winter habitats.
6. Use landscaping that consists of non-invasive native species and Low Impact Development (LID)
technology. Using native species instead of ornamentals should provide benefits by reducing the
need for water, fertilizers, and pesticides. Using LID technology in landscaping will not only help
maintain the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.
7. Sediment and erosion control measures should be installed prior to any land clearing or construction.
These measures should be routinely inspected and properly maintained. Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
Thank you for the opportunity to comment on this project. If we can provide further assistance,
please contact our office at [phone].
ec: Ian McMillan, DWQ