20121074 Ver 1_WRC Comments_20130104

lrz.�A' North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: John Thomas, Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator �1
Habitat Conservation Program
DATE: 4 January 2013
SUBJECT: Public Notice for Ashley Furniture Industries, Inc, for Proposed Ashley Furniture Mid -
Atlantic Manufacturing and Distribution Center, Davie County, North Carolina. Corps
Action ID #: SAW- 2012 -01900
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document. Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661- 667e), and
North Carolina General Statutes (G.S. 113 -131 et seq.).
The applicant proposes to permanently impact 222 linear feet of perennial stream, 94 linear feet of
intermittent stream, and 4.089 acres of wetlands for expansion of an existing facility. Currently an industrial
facility that includes maintenance garage with fuel storage area, warehouse /storage buildings, and a
warehouse /manufacturing facility are located on the site. The proposed expansion includes construction of a
2,304,100 square foot building addition, tractor - trailer loading and parking areas, access road, railroad spur,
and stormwater ponds. The facility will be expanded in four phases. The purpose of the project is to develop
a state -of -the -art facility to meet present and future needs. Mitigation for the project includes payment into
the N.C. Ecosystem Enhancement Program; the proposed mitigation ratio for streams and high quality
wetlands is 2:1, and 1:1 for low quality wetlands.
Unnamed tributaries to Buffalo Creek in the Yadkin -Pee Dee River basin flow through the site.
According to information provided in the Public Notice, the undeveloped portion of 667.63 acre tract is
comprised of pasture and forest; the site does not contain any 100 -year floodplain areas.
The applicant evaluated 16 alternatives including no- build, adding a second story, moving some
operations to another location, demolishing the existing facilities and rebuilding a new facility, and
expanding or adding to the existing facility in each direction (i.e., north, south, east, and west). The preferred
alternative is linear expansion to the west. This alternative was selected because it limited the environmental
impact of the project and the costs of development, production and operation.
We hesitate to concur with the filling of wetlands due to their wildlife habitat value and the well -
known beneficial functions they provide for flood control and water quality protection. We also hesitate to
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Page 2
4 January 2013
Ashley Furniture Industries, Inc.
Corps Action ID No.: SAW - 2012 -01900
concur with the piping of stream channels due to the potential for long -term and cumulative impacts. Stream
piping and placing fill in aquatic resources can result in significant negative impacts to downstream areas and
eliminate aquatic and terrestrial wildlife habitat. Stream piping reduces infiltration of stormwater and
associated pollutants, as well as the dissipation of stream energy. In addition, we are concerned about the
impacts of development on aquatic and terrestrial wildlife resources. Changes in land use and 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.
According to Table 1 in the Practical Alternative Analysis, the two alternatives that expand the
facility to the north would result in less than 0.2 acres of wetland impact and no stream impact. We
recommend one of these two alternatives since impacts to aquatic and terrestrial wildlife resources would be
minimized to the maximum extent practicable. However, should the permit be issued for the preferred
alternative, we offer the following comments or recommendations:
1. The applicant indicates a need for nearly 2,000 employee parking spaces. If streams or wetlands will be
impacted by construction of these parking spaces, we question whether some of these impacts could be
avoided or minimized by constructing a parking deck.
2. For remaining streams, 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.
3. All remaining wetlands and streams on the site should be protected from additional impacts by placing
them in a permanent conservation easement to prohibit filling, draining, flooding, and excavation.
4. Stormwater management structures should be designed to mimic the hydrograph consistent with an
impervious coverage of less than 10 %. Structures should be located outside of riparian buffers and
wetland areas. For stormwater detention ponds, trees and shrubs should be planted around the pond,
excluding the dam. This would provide habitat benefits that offset those functions lost by development,
partially restore aquatic habitats, reduce exposure of the water surface to sunlight to minimize thermal
pollution, and provide essential summer and winter habitats.
5. 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.
6. 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 (336) 449 -7625 or shari.bryant(a,ncwildlife.org.
ec: Sue Homewood (DWQ ID #: 20121074)