HomeMy WebLinkAbout20100988 Ver 2_Other Agency Comments_20120425DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON NORTH CAROLINA 28403 1343
REPLY TO
ATTENTION April 24 2012
ATTENTION OF
Regulatory Division
Action ID SAW 2010 00636
Greensboro Auto Auction, Inc
Mr H Dean Green
3907 West Wendover Avenue
Greensboro North Carolina 27409
Dear Mr Green
10- oggg v&
om VX61 - WA-i.. * r &
Reference is made to your DA permit issued on September 16 2011, for impacts to 295
linear feet of stream channel subject to our regulatory authority pursuant to Section 404 of the
Clean Water associated with the Greensboro Auto Auction Expansion Protect Reference is also
made to our subsequent DA public notice dated February 23, 2012, for an additional 319 linear feet
of stream impacts associated with an expansion of the existing Greensboro Auto Auction, the
redevelopment of an existing 30,000 square foot building in conjunction with a 10,000 square feet
building addition on a 26 5 acre tract in Greensboro Guilford County, North Carolina
After review of your proposal we received comments from the US Fish and Wildlife
Service (FWS), the North Carolina Wildlife Resources Commission ( NCWRC) The North
Carolina State Historic Preservation Office (SHPO) and The North Carolina Department of
Environment and Natural Resources Division of Water Quality (DWQ) The SHPO indicated in
their letter that they are aware of no historic resources which would be affected by the project "
The FWS stated that the project would have minimal adverse impacts to fish and wildlife
resources' however the NCWRC expressed concerns about the cumulative impacts to aquatic
resources as a result of the fill and increased impervious surfaces They also requested that the
applicant consider the alternative of constructing a parking deck In addition the DWQ has
concerns about the purpose of the project the number of parking spaces required, and the
minimization of impacts
We share those concerns and accordingly request you provide the following information
Based upon your present proposal it appears that there are no avoidance and/or
minimization measures taken to eliminate and/or reduce impacts to jurisdictional waters
subject to our regulatory authority Please discuss all avoidance and minimization measures
used during the planning phases and the resulting redu ion in aquatic impacts Specifically,
you need to address the construction of retaining wall oving the
loading deck to add spaces D
APR 95 ?012
D-NR WATEp QUr�LITY
Wetlands & Stomm..#
2 Reference is made to the attached email dated April 9 2012, between Mrs Jean B Gibby
of Raleigh Regulatory Field Office and Ms Virginia Spillman, Stormwater Engineering
Supervisor with the City of Greensboro, addressing the City of Greensboro s parking
regulations for restaurants and universities This document indicates that the city s
requirement is one parking space per 100 square feet of gross floor area when the principal
use is a restaurant With regard to universities the city's requirement is one space per 300
square foot of office space and 7 spaces per classroom However, it doesn't appear that the
number of spaces which you have requested a total of 541 spaces is justified based upon
the regulations Please clarify /explain your need for the number of requested spaces and
how your request complies with the city's regulations
Reference is made to the meeting between Mr Andrew Williams of our Raleigh Field
Office staff you, Mr Doug Parrish, your agents, Mr Mike and David Brame and Ms Sue
Homewood with the NC Division of Water Quality on December 1, 2011 and subsequent
meeting with me and Mr Parrish on April 20, 2012 During those meetings we requested a
letter from Kaplan to provide documentation supporting the need of the proposed building
expansion and the current need for the additional parking spaces when the proposed
building is in the University's 10 year plan as needs and requirements can easily change
over a period of time Please note that it might be very difficult to authorize fill for a
speculative need 10 years, in advance as it will be difficult to document compliance with the
404(b)(1) Guidelines for avoidance and minimization
We are forwarding a copy of these letters for your review, consideration and comment We request
that you respond to this office in writing on or before May 24, 2012 addressing not only our
concerns but those expressed by NCWRC and DWQ In the event that we do not receive your
written response we will administratively close your file until the requested information is
provided
If you have any questions or concerns, please contact Mr Thomas Brown at (919) 554
4884, Extension 22 or at the letterhead address
Sincerely
Thomas Brown
Regulatory Specialist
Raleigh Regulatory Field Office
2
Attachment
Copy with attachments
Ms Karen Higgins
NCDENR — Webscape Unite
1650 Mail Service Center
Raleigh NC 27699 1650
Mr Bruce Nooe
CPT Engineering & Surveying Inc
4400 Tymng Street
High Point North Carolina 27265
3