20121074 Ver 1_More Info Received_20130211

ECS CAROLINAS, LLP
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"Setting the Standard for Service"
Geotechnical • Construction Materials • Environmental • Facilities NC Registered Engineering Firm F -1078
February 8, 2013
Mr John Thomas
U S Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Reference Response to January 14 and 16, 2013 U S Army Corps of
Proposed Ashley Furniture Mid - Atlantic Manufacturing and
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
Dear Mr Thomas.
neer Letters
'9.g�0W� Do
11, FEB 1 1 2013
NR- WATE=R cwAlL rY
1..1 _1_ .
ECS Carolinas, LLP (ECS) received letters from the U S Army Corps of Engineers dated
January 14 and 16, 2013 The purpose of your letters were to provide comments received
in response to the Public Notice dated December 6, 2012 and to request that additional
information be submitted to continue the review of the permit request ECS, on behalf of
the applicant Ashley Furniture Industries, Inc (Ashley), Is pleased to address the concerns
identified In the following letters
1) January 14, 2013 letter regarding comments from the North Carolina Wildlife
Resources Commission (WRC)
2) January 14, 2013 letter regarding comments from the U S Fish and Wildlife
Service (FWS)
3) January 16, 2013 letter regarding comments from adjacent property owners
Copies of the letters are included as attachments
1) January 14, 2013 Letter from the NC WRC
Comment: 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 resources would be minimized to
the maximum practicable extent possible
Response: Ashley has evaluated numerous alternatives to the proposed project Two
of these alternatives include expansion of the current facility to the north While these
alternatives would result in less streamtwetland Impacts, they were determined to not be
economically feasible when compared to the preferred alternative Increases In
development and maintenance costs would range from $138,212,382 to $174,223,259
to expand the facility to the north, when compared to the preferred alternative
4811 Koger Boulevard • Greensboro, NC 27407 • T 336- 856 -7150 • F 336 -856 -7160 www ecsiimited com
ECS Carolinas, LLP • ECS Florida, LLC • ECS Mid - Atlantic, LLC • ECS Southeast, LLC ECS Texas, LLP

Response to January 14 and 16, 2013 U S Army Corps of Engineer Letters
Proposed Ashley Furniture Mid - Atlantic Manufacturing and D►stnbutron Center
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
February 8, 2013
Comment: The applicant indicates a need for nearly 2,000 employee parking spaces
If streams or wetlands will be impacted by the construction of these parking spaces, we
question whether some of these impacts could be avoided or minimized to the maximum
extent possible by constructing a parking deck
Response: Ashley has investigated the construction of a parking deck for employee
parking Ashley has concluded that an employee parking deck is not a cost - effective
option for addressing its needs because entrance and exit areas, turning lanes, stair
wells, and lighting requirements limit the additional spaces gained by constructing a
parking deck The result is that the parking ramp must cover a larger footprint or must
be constructed higher, with greater numbers of levels Depending on soil conditions, the
soils may not support such a structure
Comment: 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 treatment of pollutants associated
with stormwater runoff
Response During the proposed site development, riparian buffers outside the limits of
disturbance will be not altered Future and additional impacts to streams, wetlands and
riparian buffers are not anticipated and /or being proposed at this time
Comment: All remaining wetlands and streams on the site should be protected from
additional impacts by placing them in a permanent easement to prohibit filling, draining,
flooding and excavation
Response: Ashley will be providing funds for compensatory mitigation for wetland acres
lost Moreover, current and future laws along with their associated permitting processes
provide adequate protection of the public's interest Additionally, Ashley has gone to
great lengths to (i) minimize all impacts in its planned development of the site, (ii) hire
experts, at substantial expense, to ensure compliance with all state and federal
regulations, (iii) strictly adhere to the permitting process and (m) cooperate with all
regulatory agencies involved Under the totality of these circumstances, it appears that
a mandated easement is excessive and unnecessary
Comment: Stormwater management structures should be designed to mimic the
hydrograph consistent with an impervious coverage of less than 10% Structures should
be located outside the riparian buffers and wetlands 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

Response to January 14 and 16, 2013 U S Army Corps of Engineer Letters
Proposed Ashley Furniture Mid - Atlantic Manufacturing and D►stnbuhon Center
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
February 8, 2013
Response: Stormwater management structures are being designed in accordance with
applicable state regulations and the conditions issued in the 401 Water Quality
Certification Native vegetation will be planted around the perimeter of the stormwater
detention ponds where appropriate and applicable
Comment: 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
Response: Non - invasive native species will be utilized within the areas of impact and
re- vegetation where appropriate and applicable
Comment: 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
of aquatic resources including the destruction of spawning habitat, suffocation of eggs
and closing of gills of aquatic species
Response: Sediment erosion controls will be installed prior to land clearing and /or
construction The measures will be regularly inspected and properly maintained
throughout land disturbance activities
2) January 14, 2013 Letter from the FWS
Comment: Federally Listed Endangered and Threatened Species Act
Response We concur with your opinion that no federally listed species or their habitats
occur on the subject site and that the requirements under Section 7 of the Endangered
Species Act are fulfilled Obligations under Section 7 of the Endangered Species Act will
be reconsidered if (1) new information reveals impacts of this identified action that may
affect listed species or critical habitat in a manner nor previously considered (2) this
action is subsequently modified in a manner that was not considered in this review, or
(3) a new species is listed or critical habitat is determined that may be affected by the
identified action
Comment: Stream and Wetland Buffers
Response: Erosion and sediment control measures will be installed prior to land
disturbance activities They will be properly maintained and regularly inspected during
land disturbance activities including clearing and grading Non - invasive native species
will be utilized within the areas of impact and re- vegetation where appropriate and
applicable Fescue based mixtures will be avoided to the most practical extent possible
During the proposed site development, riparian buffers outside the limits of disturbance

Response to January 14 and 16, 2013 U S Army Corps of Engineer Letters
Proposed Ashley Furniture Mid-Atlantic Manufacturing and Distnbubon Center
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
February 8, 2013
will not be altered Future and additional impacts to streams, wetlands and riparian
buffers are not anticipated and /or being proposed at this time
Comment: Stream Crossings — Roads
Response: Stream and wetland road and /or utility crossings are not being proposed by
the project The proposed project has been designed to avoid and minimize stream and
wetland road /utility crossings to the maximum extent possible
Comment: Storm -water Management
Response: Stormwater management structures will be designed in accordance with
applicable state regulations and the conditions issued in the 401 Water Quality
Certification The stormwater management structures will not be located in streams,
wetlands and /or their respective riparian buffers
Comment: Invasive Exotic Species
Response Non - invasive native species will be utilized within the areas of impact and re-
vegetation where appropriate and applicable
Comment: Mitigation
Response: Mitigation for the proposed wetland impacts is based on the
quality /functionality of the wetlands being impacted Mr Thomas recommended that the
North Carolina Wetland Assessment Model (NCWAM) be used to establish mitigation
ratios (1 1 mitigation ratio for low quality wetlands and a 2 1 mitigation ratio for high
quality wetlands) Approximately 1 057 acres of wetlands, which will be impacted by the
project, have been assessed using NCWAM and determined to be low quality In
addition to the NCWAM determinations, numerous site visits have revealed that within
the 1 057 acres of low quality wetlands vegetative diversity and habitat is extremely low
and or limited by monocultures of species, invasive /exotic species being dominant within
their vegetative strata and /or limited tree strata with none to few trees having greater
than a six inch breast height diameter In addition, the low quality wetlands have been
previously and severely altered from anthropogenic practices including mowing, use of
herbicides and land disturbance activities including excavation, clearing and grading
One of the low quality wetlands is a remnant of a retention basin and the others have
been heavily impacted with rip rap Based on the findings of NCWAM, observations
from numerous site visits and the mitigation discussions with Mr Thomas, the mitigation
plan proposes a 2 1 mitigation ratio for high quality wetlands and a 1 1 mitigation ratio for
low quality wetlands

Response to January 14 and 16, 2013 U S Army Corps of Engineer Letters
Proposed Ashley Furniture Mid- Atlantic Manufactunng and Distnbution Center
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
February 8, 2013
3) January 16, 2013 Letter from Adjacent Property Owners
Comment: Concerns pertaining to stormwater runoff
Response: The proposed project will treat and manage stormwater in accordance with
applicable state regulations and the conditions issued in the 401 Water Quality
Certification Stormwater management will be enhanced and more effective following
the development of the site In addition, an erosion and sediment control plan is being
designed in accordance with applicable state regulations The sediment and erosion
control plan must be approved by the Division of Energy, Mineral and Land Resources
prior to any land disturbance activities The sediment and erosion control measures will
be regularly inspected and properly maintained throughout land disturbance activities
Riparian buffers on streams and wetlands outside the limits of disturbance are not being
altered
Comment: Concerns pertaining to water quality of surface and subsurface waters
Response: All of the wastewater generated within the facility will be discharged and
treated by the Davie County sewer system It should be noted that the furniture industry
is not a water - intensive industry and that all of the water used in the facility will be
discharged to the sanitary sewer system in compliance with all regulations of the State of
North Carolina Ashley is required to and will comply with all appropriate regulations of
the U S Environmental Protection Agency (EPA) and the Resource Conservation and
Recovery Act (RCRA) pertaining to the generation, transportation, disposal and storage
of solid waste and their removal from the site It should be noted that Ashley's
generation of solid waste is minimal, if any
Comment: Concerns pertaining to potential noise and light impact to area
Response: Operational noises beyond the property line will not be significant An
increase in average daily traffic in the vicinity of the project site is anticipated on a
localized level due to commuters to /from the expanded facility However, these
increases will be (i) sporadic, (u) should not significantly impact the noise levels of
surrounding properties and (m) will occur even if this permit is not granted It should be
noted that this site was already zoned to permit Ashley's intended use before this
property was purchased and before this permit application was submitted It is also our
understanding that Ashley's intended use of this site was a permitted use under zoning
laws in existence at or before the time the neighboring property parcels were purchased
Nevertheless, the design of Ashley's proposed layout places the expansion the greatest
distance from all neighboring properties (approximately 2,000 feet) All other
alternatives would place the expanded building much closer to the property lines and
closer to neighboring properties In addition, existing vegetative buffers are established
around the Ashley property that will not be disturbed during the proposed project The
established vegetative buffers will reduce noise travel to adjacent properties It should
be mentioned that a cigarette manufacturer and tobacco distribution company occupied
the site as an industrial facility prior to Ashley's occupancy of the site, over a year ago

Response to January 14 and 16, 2013 U S Army Corps of Engineer Letters
Proposed Ashley Furniture Mid - Atlantic Manufactunng and D►stnbubon Center
916 Baltimore Road
Advance, Davie County, North Carolina
ECS Project No 09- 21106A
February 8, 2013
Therefore, the overall and long term noise and light levels would be expected to be
consistent with those previously experienced from the former occupants of the site and
the historical use of the site as a manufacturing and distribution facility
Closing
Based on the information outlined above and in the previous Individual Permit
Application, it is the opinion of ECS that all requirements have been fulfilled and we
recommend that the permit be issued
Please contact us at (336) 856 -7150 if you have any questions concerning this letter or if
you need additional information
Sincerely,
Bradley S Luckey
Environmental Project Manager
CC Ms Karen Higgins
NCDENR -DWQ
1650 Mail Service Center
Raleigh, NC 27699
Michael T Brame, PWS
Environmental Principal
Attachments — January 14, 2013 Letter (WRC)
January 14, 2013 Letter (FWS)
January 16, 2012 Letter (Adjacent Property Owners)

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA'28403 -1343
January 14, 2013
Regulatory DivisionA1200A
Action ID: SAW -2412 -01900
Mr. Michael Moran
Ashley Fu niture4ndustries, Inc.
OneAshley Way
Arcadia, WI 54612
,DearVr. Moran:
Bypublic notice of December 6, 2012, we,announced your application fora Department of
the Army (DA) permit to authorize permanent discharge of fill impacts to 316 linear feet of
jurisdictional'stream channels and 4.089 acres of jurisdictional forested wetlands adjacent to
,Buffalo�Creek, associated-with the proposed expansion of your existing,warefiouse and
manufacturing facilities located off of 916 Baltimore Road, wesvof Advance, in Davie. County,
North Carolina.
After review of your proposal, the North Carolina Wildlife Resources Commission,(WRC)
submitted co ments,and recommendations by letter dated January 4, 2013, a copy of which is
enclosed for your consideration and response.
Your response to the WRC's- colrunents and recommendations,should be provided to the,
Raleigh Regulatory Field Office, in writing, no later than February 11, 2013, so we can continue
the timely processing of your application. You should contact ,Mr. John Thomas at.919 -554-
4884 extension 25 if you have any.questions regarding this process.
Sincerel ,
d
o ` homas
egulatory Project Manager
Raleigh Field Office
Enclosure

Copy Fumished (w /o enclosure):
Ms.'Shari L. Bryant
NC Wildlife Resources Commission
Division of Inland Fisheries
Raleigh, North Carolina 27699
Copy Furnished (w /enclosure):
Mr. Michael T. Brame
ECS Carolinas, ILLP'
4811 Koger Boulevard
Greensboro, NC 27407
E

orth Carolina Wildlife Resources Commiscinlh n
voruon iviyers, executive Director
MEMORANDUM
TO: John Thomas, Raleigh Regulatory Field'Office
U.S. Army Corps of Engineers
FROM: Shari L. Bryant, Piedmont Region Coordinator ..8As -Aak �
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,
sublect,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 StitutekG.S. 11`3 -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 induitrial
facility that includes maintenance garage with fuel storage area, warehouse/storage buildings,, and a
warehouse/inanufacturing facility are located on the site. The proposed expansion includes construction of
2,304,100 square foot building addition, tractor - trailer loading and parking areas, access road, railroad spur,
and,stoimwater ponds. The- facility will be expanded in four ,phases. The purpose of the project into develop
a state -of- the- art, facility to meet present and future needs. Mitigation for the projecfineludes,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.
Accoidung,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,hesiiate to
L -Mug rwuress: envision or miana Yisheries - 1721 Mail Service Center - Raleigh, NC 27699 -1721
Telephone: (919),707-0220 - Fax: [phone]

Page 2
4 January 2013 r
'
{ � J
Ashley Furnituie 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
h vious surfaces may exacerbate channel degradation and sedi ment,impacts to stream ecosystems due to
increased stormwater runoff and elevated flooding. In addition, pollutants (6.g, sediment, heavyanetals,
pesticides, and'fertilizers) washed from roads and developed Iaudscapes can adversely, affect and extirpate
species downstream.
According to Table I in the Practical Alternative Analysis, the, two alteinatives'that expand the
facility to the north would result in less than 0.2 acres of wetland-* mpact and no stream impact We
recommend one of these two alternatives since'inipacts to aquatic anflerrestrial 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,ofthese4mpacts could be
avoided or minimized by constructing a parking.deck.
2' For remaining streams, maintain a 100- footuiidisturbed, native, forested buffer along perennial streams,
and a 50 -foot buffer along intermittent streams and wetlands. Maintaining undisturbed, foiested buffers
along these areas will minimize impacts to aquatic and terrestrial wildlife'resources „water quality, and
aquatic habitat both within and down m strea of the project area. In i addii6%, wide riparian buffer`s are
helpful,in maintainingtstability of stream banks and for,treahnent 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 nunnnize thermal
pollution, and provide essential summer and winter habitats.
5. Use landscaping that consists of non- invasive native species and L'ow'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 destiuciion 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.brvantgg!u wildlife org.
ec• Sue Homewood (DWQ ID #: 20121074)

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS,OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403 -1343
January 14, 2013
Regulatory Division/1200A
Action ID: SAW -2012 -01900
Mr. Michael Moran
Ashley Furniture Industries, Inc.
OneAshley Way
Arcadia, WI 54612
Dear Mr. Moran:
By public notice of.December 6, 2012, we announced your application for a Department of
the Army (DA) permit to authorize permanent discharge of fill impacts to 316 linear feet of
jurisdictional stream channels-and 4.089,acres of jurisdictional forested wetlands adjacent to
Buffalo Creek, associated with the proposed expansion of your exison&warehouse and
manufacturing facilities located off of 916 Baltimore Road, west ofAdvance, in Davie County,,
North Carolina.
After review of your proposal, the United States Fish and Wildlife Service;(FWS) submitted
comments and recommeridations,by letter dated January 3, 2013,-,a copy of which is enclosed for
_your consideration and response.
Your response -to the FWS's comments and recommendations should be provided to the
Raleigh Regulatory Field Office, in writing, no later than February 11, 2013, to we can continue
the timely processing of your application. You should contact Mr. John Thomas at 919-554 -
4884,extension 25 if you have any questions regarding this process.
Sincerely,
J-
o i homas
Raleigh Regulatory
Field Office
Enclosure

Copy Furnished (w /o enclosure):
Mr. Brian Cole
US Fish and Wildlife`Service
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
Copy Furnished (w /enclosure):
Mr. Michael T. Brame
ECS Carolinas, LLP
4811 Kopr Boulevard
Greensboro, NC 27407
2

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field gifice
16o ztllicoa street
Asheville, North Carolina 28801
January 3, 2013
Mr. Jol homas
ui T
US Army Corps of Engineers coy
Raleigh - Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
This is the report of the U.S.`Fish and Wildlife Service,and.the Department of the Interior on the
U.S. Army Corps of Engineers' •(Corps) public notice,(PN) of an application for an individual,
permit submitted by Ashley Furniture Industries, Inc., to expand their existing warehouse and
manufacturing facility located at 916 Baltimoie Road, Advance, North Carolina. Information for
this report is-based on a review of the public notice issued by the Corps. t This,reportis submitted
in accordance with,the provisions of,the National, Environmental Policy Act; Fishand-Wildlife
Coordination Act, as,amended'(16 U.S.C. 661- 667e); and,section,7.ofthe Endangered Species
Act of 1973, as amended (16 U.S.C. 1531- 1543),(Act).
Project Descriptions The applicant is proposing to,expand the,existing facility by constructing a
2,304,100 syuare,foot building addition, a tractor trailer loading/parking,area, access'roads, a!
railroad spur,'and storm water ponds. A portion of the site is,currently deyeloped,with about 1.7
million square feet of industrial structures. The remarnider o£ the 667 -acre site is;undeveloped
and consists of forested;areas aud,,open+pasture. To complete ihe,construction of the proposed
facility expansi6n, the applicant, is,proposmg to,permanently impact,about -316 linear; feet of
m
strea channel and about 4.089; acres,of wetlands.
Federally Listed Endangered and Threatened'Sn6cies
According to our `records'and a review of the 1nforn aiion'you provided, no` federally listed
species or their habitats occur on the subject site. Therefore, we believe the requirements under
section 7 of the,Endangered Species Act are fulfilled. However, obligations under section 7 of
the Endangered, Species Actmust be reconsidered if: (1) inew- information- reveals,impacts of this
identified action that may-affect listed'species or` critical habitatin a maruier not'previously
considered, (2) this action,is subsequently modified in a manner Thai was not considered in this
review, or (3) a new species,is listed or critical habitat is determined ihatmay be affected by the
identified action.
Stream and Wetland Buffers
Because there are numerous streams and wetlands within the project area,,we want to emphasize
that stringent measures -to control sediment and 'erosion shouldibe, implemented,pri-P r to any
ground disturbance and should be maintained throughout project construction: Disturbed areas
should be reseeded with seed mixtures that are beneficial to wildlife. Fescue- base&mixtures
should be avoided. Native annual,small grains,appropriate for the season are preferred and
recommended. Also, perimeter erosion - control devices should be installed prior to any

Yti9t, tir 'y
i
Stream Crossings - Roads
We recommend avoiding,and minimizing the number of stream/Wetland crossings. Use bridges
(sized so as not to constrict'the,active channel and-iii consideration of floodflows) for'all
permanent roadway crossings ,.of streams and, associated wetlands. We recommend the use of
spanning structures because they minimize impacts to aquatic resources, allow, for the movement
of aquatic organisms, and eliminate the need to -fill andtmstall culverts. All streanrcrossings
shouldbe -made-perpendicular;to- the,- stream -in- areas - where - banks- are- stable- (i.e.; riffle- reaches).
If culverts are4ie only option, we,suggest,using bottomless,culverts, or squash pipes, embedded
within the channel substrate. � Any type.of,culvert that is -used should be designed to allow for the
passage of fish and other aquatic life. Culverts,shoul'd.be sized to acconunodate the movement
of debris and bed material within a channel during a bank -full event. We recommend the use of
multiple barrels (other than the base, -flow barrel),,placed, on or, near, stream bank -frill or
floodplain bench elevation in, order to, accommodateffloodwaters within the ,stream corridor.
These should be recoimected to floodplaiwbenches ,asi'appropriate. This may be accomplished
by'using sills on the upstream end to restrict or divert,flow to the base -flow barrel(s). Sinfftcient
water depth should be maintained in the base -flow barrel during4ow-flows to accommodate fish
movement. Culvert length should be minimized to the extent possible:
During both utility and road construction activities,Requipment should be kept out of streams by
operating from the banks -in a fashion that minimizes disturbance to woody vegetation.
Equipment should be inspected daily and should be maintained in order to prevent the
contamination of surface waters from leakingifuels, lubricants, hydraulic fluids, ,or other toxic
materials. All fuels, lubricants, and other toxic materials should be stored-outside the riparian
area of the stream, in a location where the material can,be contained. Equipment, should be
checked for leaks of hydraulic fluids, cooling system liquids, and fuel and should be, cleaned
before- fording any stream. In addition,,all fueling,operations,should be accomplished at least
200 feet away from,streams:and wetlands "or outside the 100 -,yearifloodplain (whichever -is
greater). '
Storm -water Management
An increase in development (residential,.commercial, and industrial).results in a concomitant
increase hi impervious surface,area and thus ,a similar relational 'increase in storm' -water runoff.
Impervious.surfaces (such as,roofs, road's; and,parking,lots) collect pathogens; metals,,sediment,
and chemical pollutants and quickly transmit them (via storm -water runoff) to receiving waters.
According to the Envh-onmental Protection Agency, this nonpoint- source pollution is one of the
major threats to wateuquality in the United, States,, posing one of the, greatest threats to aquatic
life, and is linked to chronic and acute' illnesses in lnumanl,,populations,from expo sure, through
drinking water and contact recreation. Increased storm -water runoff also directly damages
aquatic.and riparian habitat, causing stream -bank and stream- channel scouring. In addition,
impervious surfaces reduce groundwater recharge, resulting in even, lower than expected stream
flows during drought periods that can induce potentially:catastrophic effects for fish,.niussels and
other aquatic'life.
Best management practices can reduce, but riot eliminate, pollutant loadings of common
storm -water pollutants. Designs that collect runoff and allow it to infiltrate the soil have the
3

,, N\ ��
htlp : //www.ncwildlife.org/pg07 wildl ifespeciescon /pg7c3_iinpacts.pdf.
Invasive Exotic Species
We are concerned with the introduction and spread of invasive exotic species in association,with
the proposed project. Without active management, including the revegetation of disturbed areas
with native species, the project area will likely be a source for the movement of invasive exotic
plant species. Exotic species areaa major contributor to species depletion and extinction, second
only-to-habitat -loss. Exotics -are -a factor - ,contributing -to, the - endangered- or- threatenedstatus of—
more than 40 percent of the animals, and -plants on the Federal List of Lndangered and
Threatened Wildlife and Plants.7 It is estimated that,at least °4,000 exotic plant species and 2,300
exotic animal species are now established in the,United Statep, costing more than $130 billion a
year to control.8 Additionally, the U.S. Government has many programs and laws hi place to
combat invasive species (see www. invasivespecies.gov) and'thus cannot spend money to counter
these efforts. Specifically, Section 2(a)(3) of Executive,-Order 13112 - Invasive Species
(February'3, 1999) direct's federal agencies to "not authorize; fund, �or cany out actions that it
believes are likely to cause or promote�the introduction or-spread of invasive species in the
United States or elsewhere." Despite their short -term erosion - control benefits, many exotic
species used in soil stabilization seed mixes are persistent.once they are established, thereby
preventing the reestablishment of native vegetation. Many,of these,exotics_plants9 are also
aggressive invaders of nearby natural areas, where they are capable of'displacing already
established native species; Therefore, we strongly recommend that only native plant species be
used in association with all aspects of tlus project.
Miti tion – The applicant'is proposing to mitigate for impacts to the 3161f of stream channel
and 4.08 -acres of wetlands by making a payment into the North Carolina Ecosystem
Enhancement Program. Though,we agree with the majority of the proposed mitigation package,
we generally recommend that a 2:1 ratio be used to calculate the payment amount for all impacts
to wetlands: We recommend that an-,additional. 1.05-acre of wetland mitigation credits will be
necessary to adequately compensate for the direct impacts this project will have on aquatic
resources. Therefore, we believe the total required credits necessary to mitigate the wetland
impacts should be 8.17- acres.
We appreciate the opportunity to provide, these, comments. If we can be of assistance, or if you
have any questions, please do not hesitate to contact,Mr. Bryan Tompkins of our staff at
828/258 -3939, Ext. 240. In any future coirespondeiice�concerning this project, please reference
our Log Number 4 -2 -13 -021.
Sincerely,
- - original signed - -
Milcove, D. S., D. Rothstein, J. Dubow, A. Phillips, and E. Losos. 1998. Quantifying threats to imperiled species
in the United States, BioScience.48:607 -615.
8Pimentel, D., L. Lach, R. Zunigs, and D. Morrison 2000. Environmental and economic costs of nonindigenous
species in the United States. BioScience 50:53 -65.
9 Lists of invasive exotic plants can be found at hap.-Avww tneppao)g/ and hup.-Mvww. invasive. o g/eastern/srs/on
the Internet.
5

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403=1343
January-16, 2013
Regulatory Division
Action ID. SAW- 2012- 0190.0
Mr. Michael Moran
Ashley Furniture Industries, Inc
One Ashley Way
Arcadia, WI 54612
Dear Mr- Moran:
By public notice of-D&bmber 6, 2012, we announced your application for a Department of
the Army (DA) permit to authorize permanent discharge of fill impacts to 316 linear feet of
jurisdictional stream channels and 4,089 acres of jurisdictional forested wetlands, adjacent to
Buffalo Creek, associated with,the proposed expansion of your - existing warehouse and
manufacturing facilities located off of 916 Baltimore Road, west of Advance, in Davie County.
North Carolina.
After review of your proposal, adjacent property owners to your existingwarehouse and
manufacturing facilities in Davie County submitted comments and recommendations by letters,
dated and received during the public notice period. A copy of each of these letters is enclosed for
your consideration and response. The comments and recommendations of each of the letters are
similar.- Therefore, we are sending them to -you as single attachment for your review and
combined response to these similar concerns Specifically you should address in your written
response the,following concerns:
1. concerns pertaining to stormwater runoff
2. concerns,pertamirig to water` quali ty of surface and subsurface waters
3. concerns pertaining to potential noise and light impact to area
Your response.to these comments and recommendations should be provided to the Raleigh
Regulatory Field Office, in writing, no later than - February 11, 2013, so we can continue the
timely processing of your application. You should contact Mr. John Thomas at 919 - 554 -4884
extension 25 if you have any questions fegarding this process

Enclosures
Copy Furnished- (w /enclosures)
ECS,Carolinas, LLP
Attn: Michael T. Brame
481 T Koger Boulevard
Greensboro, NC 27407
Sincerely,
r
/ohn Thomas
Regulatory Project Manager
Raleigh Field Office

Bobby Cundiff and Margaret J ,Nance
113 Wellesborough Road
Winston- Salem, NC 27104
December 22, 2012
Mr Michael Moran
Ashley Furniture Industries, Inc
One Ashley Way
Arcadia, WI 54612
Mr John Thomas
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC, 27587
Nis Karen Higgins
NC Division of Water Quality
1650 Mail Service "Center
Raleigh, NC 27699_
Re: Corps Action ID #SAW- 2012 -01900 r
Dear Mr Moran, Mr. Thomas and Ms . Higgins
RECEIVE:
DEC 2 4 2012
RALEIGH RtGULATORY
FIELD OFFICE
We recently received a Public Notice dated December 6, 2012 referenced as SAW- 2012 -01900
describing the Davie County expansion project of Ashley Furniture Industries, Inc. (Ashley). The Public
Notice requires an unreasonable comment deadline of January 7, 2013 Adequate and timely studies
and reports have not been provided to us to adequately assess the impact to our property My Wife and
I own lot 2 in the Baltimore Trails subdivision totaling about-10 acres with approximately 825 linear feet
bordering the Ashley,property with about 300 linear feet of Buffalo Creek (creek collecting run =off from
the Ashley property) flowing Through oui property Our land and creek will be one of the first non
Ashley properties affected by the changes requested in the Public Notice.
At this time, we (others may have similar or additional questions) request the following.
1. Change the comment deadline of January 7, 2013 to a date (at least a three month delay) when
we will have ample Information and time to understand the, requested changes.
2. A comprehensive study and report detailing the impact (both physical and financial) to our
property of all Ashley changes We do not' have the expertise or financial resources to research
all the possible impacts It appears such study-is complete based on the following quote taken
from the Public Notice The-Public Notice under Evaluation page 7 reads "The benefit which
reasonably_ nay -be expected to accrue from the proposal must be balanced against Its
reasonably foreseeable detriments"
3., Will th�re_be routine testing of water (both above and below ground) from the Ashley property
,to other properties by -an independent firm,to test Tor toxic materials?
4. Wiii there be a vegetation buffer zone to protect surrounding residential properties from noises,
sounds etc.?

Page 2 of 3
We desire to be amiable neighbors, but we must demand that our property be safe from any and all
actions undertaken, by Ashley We believe North Carolina °antl Davie County fobs -are very important to
our state, community and economy, but-individual property rights and values must'be protected. If such
rights are not protected for each individual ultimately they are lost by all.
Thank you for your attention to this letter
Very truly yours,
1�afrgarft ante
tAlAle-e'
ce
Copies to
Honorable Richard Burr
United States Senator
2000 West First Street, Suite 508
Winston - Salem, NC27104
Honorable Kay -Hagan
United States Senator
701 Green Valley Road, Suite 201
Greensboro, NC 27408
Honorable Virgirua Foxx
House of Representatives
6000 Meadowbrook Mall, Suite 3
Clemmons, NC 27012
Honorable Julia C Howard
NC House of Representatives
16 W. Jones Street, Room 1106
Raleigh, NC 27601

Page,3,of 3
Honorable Andrew C. Brock
INC,Senator
300 N, Salisbury Street, Room 623
Raleigh, NC- 27.603
Honorable Robert Wisecarvef
Chairman of Davie County Board of Commissioners
38$ Fork Bixby xoad
Advance,,NC'27006
Ms, Beth Dirks
Manger,of Davie County
123-S Main Street
- Mocksville, NC,27028
All members -of Baltimore Trails HOA
By e-mail

December 31, 2012
Mr. Michael Moran
Ashley Furniture Industries, Inc.
One Ashley Way
Arcadia, WI 54612
Mr. John Thomas
Raleigh Regulatory Field,Office
3331 Heritage Trade Drive, Suite 10.5
Wake Forest,, NC 27587
Ms. Karen Higgins
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699
Re: Corps Action ID #SAW -2612 -01900
Dear Mr.,Moran, Mr. Thomas and Ms. Higgins:
We recently - received a Public Notice dated December 6, 2012,referenced as SAW= 2012 -01900
describing the Davie County expansion project of Ashley Furniture Industries,_ Inc. (Ashley). The
Public Notice-requires an,unreasonable comment deadline of January 7, 2013. Adequate and
timeiy studies and reports,have not been provided to us to adequately assess the impact
to our property. My wife and I own Lot #5 in'the Baltimore Trails subdivision totaling nearly 20
acres of which border the Ashley property. Buffalo Creek (a creek collecting run -off from the
Ashley'property) flows.through our property connecting with Dutchman's Creek and eventually
emptying into High Rock Lake. Our land; of which we have built a home and barn forour horses
and pool, along with,a,deep water well for our consumption, and creek will be one of the non
Ashley properties affected by the changes requested in the Public Notice. We are -one of four
properties that the road -to our homes crosses over Buffalo Creek,and during-heavy rains the
creek has significantly risen. At one time before a new culvert was installed the creek had
crested. We have alot of money invested in our home and land and our development is home
to others who also have alot invested.
At this time we and others who may have similar or additional questions request the following:
1) Change the comment deadline of January 7, 2013 to a elate (at least a three month delay)
when we will have ample information and time to understand the requested changes.
1
LLE 4 2013
Richard and7oann,Kohl
352 Baltimore Trails Lane
Advance, NC 27006
December 31, 2012
Mr. Michael Moran
Ashley Furniture Industries, Inc.
One Ashley Way
Arcadia, WI 54612
Mr. John Thomas
Raleigh Regulatory Field,Office
3331 Heritage Trade Drive, Suite 10.5
Wake Forest,, NC 27587
Ms. Karen Higgins
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699
Re: Corps Action ID #SAW -2612 -01900
Dear Mr.,Moran, Mr. Thomas and Ms. Higgins:
We recently - received a Public Notice dated December 6, 2012,referenced as SAW= 2012 -01900
describing the Davie County expansion project of Ashley Furniture Industries,_ Inc. (Ashley). The
Public Notice-requires an,unreasonable comment deadline of January 7, 2013. Adequate and
timeiy studies and reports,have not been provided to us to adequately assess the impact
to our property. My wife and I own Lot #5 in'the Baltimore Trails subdivision totaling nearly 20
acres of which border the Ashley property. Buffalo Creek (a creek collecting run -off from the
Ashley'property) flows.through our property connecting with Dutchman's Creek and eventually
emptying into High Rock Lake. Our land; of which we have built a home and barn forour horses
and pool, along with,a,deep water well for our consumption, and creek will be one of the non
Ashley properties affected by the changes requested in the Public Notice. We are -one of four
properties that the road -to our homes crosses over Buffalo Creek,and during-heavy rains the
creek has significantly risen. At one time before a new culvert was installed the creek had
crested. We have alot of money invested in our home and land and our development is home
to others who also have alot invested.
At this time we and others who may have similar or additional questions request the following:
1) Change the comment deadline of January 7, 2013 to a elate (at least a three month delay)
when we will have ample information and time to understand the requested changes.
1

2) A comprehensive study and report detailing the impact (both physical and financial) to
our property of all Ashley changes. We do not,have the.expertise,or financial resources io
research all the possible impacts. It appears such study iscompletely'based on the following
quote taken from the Public- Notice. The Public- Notice under-Evaluation page 7 reads "The
benefit which reasonably may be expected to accrue from the proposal must be balanced
against it's reasonably foreseeable detriments ".
3) Wdl'there be toxic materials affecting both the creek water and underground water
sources?
4) Will there be routine testing of water (both above,and below ground) from the Ashely
property to other properties by an independent firm to test for toxic materials?
5) Will there be a vegetation buffer zonetto protect surrounding residential properties from
noises, sounds and lighting?
6) Will there be fumes from any toxic materials?
7) We understand,that there will be paving done for parking lots and concern arises from
that.
8) We have read of wetlands being built over regarding Ashley Furniture.in Madison, WI
creating flooding. Once all,thls�is approved there will be no furning.back. Th_e value of our
property and safety must be taken into consideration.
We desire to be amiable neighbors, but we must demand that our property be safe from-any
and all actions undertaken byAshiey. We believe North Carolina and, Davie County jobs are
very important to °our state, community and economy, but individual property rights and values
must be protected. if such sights are not protected for each individual ultimately they are lost
by all
Thank you for your attention to this matter.
Yours truly,
Richard Kohl
336 -940 -5729
Copies to:
Honorable,Richard Burr
United States Senator
2000 West First Street, Sutie #508
Winston - Salem, NC 27104
Honorable Kay Hagan
United States;Senator
Green Valley Road, Suite #201
Greensboro, NC 27408
2

Honorable`Virginia Foxor
House of Representatives
6000 Meadowbrook Mail, Suite #3
Clemmons, NC, 27012
Honorable Julia C. Howard
NC`House' of Representatives
16- W. Jones Street, Room #1106
Raleigh, NC-27601

January 4, -2013
Mr John Thomas
US Army,Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage-Trade -Drive Suite 105
Wake Forest, North Carolina 27587
Re: Corps Action -ID# SAW - 2012 -01900
JAN o 7 2013
RALE''C, i 0 R
ri
- �' Advance �NC�7006�799 -I
Ashley Furniture Industries Inc. (916 Baltimore-Rd., Advance, in Davie County, North Carolina), permit
authorization application
Mr. Thomas,
My wife and I are homeowners in the Baltimore Trails subdivision which is located directly behind
Ashley Furniture Industries on Baltimore Road and will be impacted by said company's application for
permit foi permanent impacts to jurisdictional stream channels -and jurisdictional forested wetlands
adjacent to Buffalo Creek and the proposed expansion of their existing warehouse and manufacturing
facilities located off of 916 Baltimore Rd, west of Advance, in Davie County, North Carolina.
1. We are requesting an extension of time to respond and comment to the public notice for the
application from Mr: Michael Moran of Ashley Furniture Industries, Inc. until, at least February
7, 2013. Thiswill allow the public notice to properly recognized, and given the - attention it
deserves by all homeowners and the community and will allow time to prepare and_submit
comments to you regarding -this matter. The request is based on the surreptitious action of
Ashley Furniture to -file for this permit over the Holiday season.
2_ We are requesting a public hearing'to occur Ina Davie County venue that allows for all members
who-wish to attend and comment to -do so. We request a minimum of 60 days notice for the
date and time of the hearing During this hearing we request clear, concise answers alonewith
complete written documentation_to the following topics.
a. Exact Wet Detention Pond design, size and location(s) in regards to Buffalo Creek and /or
any exiting Stream or Wetland type.
b. Design, emergency'plan`and location of the emergency spillway(s).
c. Detailed mapping including size of the conveyance systems from buildings and parking
lots to the wet detention porid(s).
d. Within,the permit request.there is mention of approximately 45 acres in paved parking
lots but no reference,given to the runoff for new or current paved areas. How can a
true storm water runoff assessment be created without these critical figures? We

request complete detailed plans outlining "ALL" paved areas, dimensions and storm
water rundff`collection., -
e. Flow estimates bf Buffalo Creek after all mediation has been completed.
f. Testing policies and procedures for contamination in the holding pond(s), discharge area
and bottom sediment using the toxic characteristic leaching procedure.
g. The Erosion and Sedimentation Control,(E&SC) Plan for"the site.
h. Plans fof_tiie water quality declination, particularly contamination of current aquifers
and Buffalo Creek,water supply for all affected downstream along the Buffalo Creek
during all phases of construction. Buffalo Creek flows into Dutchman Creek which in-
turn flows'into the Yadkin River. There should be established testareas and schedules
to monitor beyond the 401 certification.
i Ashley's plan for contamination testing and,disclosure of local residential well water
duringsconstruction and monitoring for chemical'intrusion once the manufacturing
facility begins operations.
I. The plan for testing surface water contamination to adjacent land from construction or
manufacturing operatlons�that could'impact our Equestrian Developments with'possible
toxic effects on'the horses due,to their feeding on field,grass.
In the application, the statement on page 2 of public notice that "land use in the area around the Ashley
Furniture property is mostly open pasture and forest with FEW rural residential properties...- is amiss
representation. The fact is that Ashley does not recognize or acknowledge the land use in the area
around their property as residential is disturbing. There are 24 lots,with 14 homes in the - Baltimore
Trails-and Baltimore Downs subdivisions. These two subdivisions were platted as such in 2005/2006 and
encompass 247.170 acres directly adjacent to the Ashley property. Not to be,dismissed are the many
homes and farms (both livestock and harvesting) across and alongside Baltimore Rd. and others Located
further down Buffalo Creek.
For these compelling reasons, we ask that we be granted both a public hearing to�discuss our concerns
and be given the opportunity to be heard as a community and to also extend the deadline for comments
to be mailed to no earlier than February 7, 2013.
Sin�\k cerely,
U)5t,
D avid Wittlinger
1: h '-�p
Debora Yennny- Wittlinger
Concerned Homeowners, Baltimore Traits

t
Cc:
North`Carbhna Division of Water Quality Representative'Virginia Foot
1650 Mail Service Center 6000 Meadowbrook Mali, Ste 3
,Raleigh,'NC 27699 -1617 Clemmons, NC'27012
Attn: Ms. Karen Higgins
Representative Julia C. Howard
Senator Richard Burr NC House of Representatives
Urnted,States Senator 16.W. Jones Street, Rm 1106
2000 W. First Street, Ste 508 Raleigh, NC 27601
Winston - Salem; NC 27104
State Senator Andrew C. Brock
Senator Kay Hagan NC Senator
Unites States-Senator 300 N. Salisburytt, Rm 623
701 Green Valley Rd, Ste 201 Raleigh, NC 27603
Greensboro,`NC 27408

JAN 0 0 2013
RALEM -6 ,��� a��tf+; f:7tT 1
FIE, -o OFFICE
January 4, 2013
Mr. John Thomas
Raleigh Regulatory Field.Offlce
3331 Heritage Trade Drive, Suite 105
Wake Forest; -NC, 27587
Dear Mr.,Thomas;
I would like for the Corps of Engineer`s or the proper authority to review the drainage'from the
Ashley property flowing across my property as noted in the area marked on the enclosed map
The-area in question is- marked in yellow. The flow across my property at times is tremendous.
The current has been so strong that Ashley's fence has been pulled away from the poles holding
it. The erosion that has been caused from this drainage has left a ditch that is as much as 20
feet deep The drainage also runs into Bailey Creek which eventually runs in the Yadkin Ricer.
would like-to see Ashley review this area of concern for a better way to handle this run off.
Best regards,
Charles M. Wall
255 Riverstone Trail
Advance,_NC 27.006
336.813.6145

JAN '0 8- 2313
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-January 4, 2013
Mr.,, John Thomas
Raleigh Regulatory Field Office
_3331 Heritage Trade Drive
Suite 105
WakeForest, North Carolina 27587
Re: Army Corps of-Engineers Public Notice
Corps Action ID #SAW - 2012 -01900
Ashley Furniture Industries, Inc.
Dear Mr. Thomas:
�a� ��
JAN 012613
2613
MALE'.: H REGULATORY
FFCUD OFFICE
As home owners living adjacent-to the Ashley Furniture facility in,Advance, North Carolm_ a7,the
cited_Public,Notice raises some mayor concerns both - immediate and for the future.
The - notice states "land use in the area around the,Ashiey,Furniture property -is mostly open
pasture and forest with a few rural residential properties-area in Davie County ".
While there are working farms along'Baltiinore Road, this statement does _not eohvey the fact
that there are,six residential subdivisions which-either face or are contiguous to their property.
We respectively request that the Corps' decision be delayed until after a public hearing can be
held`,to address the impact and to receive input:fiom,owners of surrounding properties on
Ashley's expansion proposal, including but not limited to the-containment of water-runoff,
flooding of and contamination of pasture land, mitigation of noise and light pollution, and traffic
control.
We hereby request that, a public hearing be ,scheduled, with notices of "the hearing being -sent to
all owners of-properties that could be affected by such amexpansion. The proposed expansion is
major and has the potential of negatively affecting both the quality oflife of nearby property
owners, as well as property values -if the-project,is not properly planned and controlled.
Thank you.
Very truly yours,
J. Scott - Vincent
190 Baltimore Downs Road
Advance, NC 27006

December 30, 2012
Mr. John Thomas
US Army Corps of Engineers
Raleigh ReguIatoryTield Office
3331 Heritage Trade-Drive Ste 105
Wake Forest; North Carolina 27587
��a 4 , ]4 Ei- � V EE
JAN o 7 2013
f3a.LMG0 r,EGUL I0RY
FIELD OFF!"
Re: Corps Action-ID# SAW - 2012 -01900
Ashley Furnitum4ndustries Inc. (916 Baltimore Rd, Advance, in Davie County, North Carolina), permit
authorization application to expand-the current facility in Davie County, NC
Mr. Thomas,
My husband and'I, who are homeowners in the Baltimore Trails subdivision which is located directly
behind Ashley Furniture Industries and will be impacted by said company's application for permit to
expand manufacturing facilities, are requesting:
1. An extension of time to respond and comment to the public notice for the application from Mr.
Michael Moran of,Ashley Furniture Industries, Inc. until; at least February 7, 2013, to this public
notice so that we, homeowners and the community, can have time to prepare and submit
comments to you regarding this matter.
Reason for the extension is the public notice was given to us during the inopportune Christmas
holidays, and some homeowners were out of town and/ or busy with family and did -not have
ample time to, respond:
2. -A public hearing be held so that homeowners and community members be given proper notice
and an opportunity to be heard for the following reasons, particularly the detrimental impact the
extension of this-facility will have on health due to water supply contamination, home devalue,
horse health, flooding, schools, farming interests, and livestock.
3. To comply -with the current comment deadline of January 7, 2013 for written comments, the
following are our initial comments to grant a public hearing pertinent to the proposed work:
1. The community-and affected property owners need be given proper notice and an
opportunity to be heard.
2 The threat of water quality declination, particularly contamination of current aquifers and
Buffalo Creek water supply for all affected downstream along the Buffalo Creek during
all phases of construction
3. The likelihood of contamination of well water during construction and monitoring for
chemical intrusion once the manufacturing facility begins operations
1

4. The likelihood of surface water contamination to adjacent land from;construction,or
manufacturing operations that could -impact our Equestrian Developments with possible
toxic effects on the horses due to their"feeding'on field grass.
5. The likelihood of flooding due to fill placement in wetlands. Ashley Furniture Industries
has a history of causing flooding asfliey did in Arcadia, Wisconsin October of 2010.
6. Theincorrect statement on page 2 of public notice that "land use in the area around the
Ashley Furniture property is mostly open pasture and -forest with FEW rural residential
properties.-." The actual fact is that land use in the area around,the Ashley Furniture
property is more than 24 homes and lots in the'Baltirriore Trails and Baltimore Downs
subdivisions directly adjacent to, not including the hundreds of homes and farms across
and alongside Baltimore Rd. and others located further- down Buffalo,Creek.
For these-compelling reasons, we ask,that we be granted a_public hearing to discuss our concerns and be
given the opportunity to be heard and extend the deadline for comments to be mailed no earlier than
February 7, 2013.
Si Wely,auricio Ortega
Concerned homeowners, Baltimore Trails
Cc: North Carolina Division of Water Quality
1650 Mail Service Center
Raleigh, NC-27699-1617
Attn: °Ms.,Karen Higgins
Senatof Richard Burr
United 'States Senator
2000 W. Frst`Street, Ste 508
Winston - Salem, NC 27104
Senator Kay,Hagan
Unites,States Senator
701 Green Valley Rd., Ste 201
Greensboro, NC 27408
Representative Virginia Foxx
6000 Meadowbrook Mall, Ste 3
Clemmons, NC 27012
Representative Julia C. Howard
NC House of Representatives
16-W. Jones Street, Rm 1106
Raleigh, NC 27601

State Senator Andrew C. Brock
NC Senator`
300,N. Salisbury,St, Rm 623
Raleigh; NC 27603

Michael E.,Cook and Malorie:E Cook
Re. Ashley Furniture
Mr- Michael Moran
Ashley Furniture Industries, Inc
One - Ashley Way
Arcadia, WI;64612
Mr John Thomas
John T Thomas JR @usace army mil
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Ms Karen Higgins
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699
Re Corps Action ID #SAW - 2012 -01900
To Whom it May Concern-
January-3, 2013
My wife and I own a home in a large subdivision that adjoins the property of Ashley Furniture
Industries, 916'Baltimore Road, Advance, -North Carolina, 27006. We,have lust recently
become aware of the apphcation,submitted by Mr Michael Moran of Ashley Furniture, Industries
seeking a Department of Army permit authorization for permanent impacts to 316 linear feet of
jurisdictional stream channels, and 4 089 acres of jurisdictional forested wetlands,adjacent to,
Buffalo, Creek, associated with the proposed expanse of their existing warehouse and

manufacturing facilities
As small business owners we recognize the much needed and important contribution that
Ashley-Furniture will make to our community However, after reviewing the proposal we have
many legitimate concerns regarding the proposed changes to our community as well as our
environment.
We believe that Mr Michael Moran and Ashley Furniture Industries is equally concerned about
our local community as well as our environment and would not mind proving it by granting ,those
impacted by their proposed changes an extension to the deadline previously requested
The need for revenue m_a time of economic turmoil should not be overshadowed by adequate
time for due diligence into this mattef.
We,have�several concerns regarding this application,, however, our concerns regarding
watershed.and water quality.are paramount to us
Buffalo Creek - Buffalo Creek has already proven difficult for,our community during heavy rains.
Shortly after our community was developed we had to "replace the culvert on Baltimore Trails
Rd. due to,damage.
Last year Buffalo Creek flowed over the giant culvert on Baltimore Trails Road and breached its
banks overflowing and damaging the section of road that encircles our riding arena at an
expense our HOA will have to absorb The damage has yet to be repaired so the evidence of
the-damage that I describe is still present
Our equestrian trails cross Buffalo Creek in two different areas Baltimore Trails HOA is
regularly repairing these crossings throughout the year as these heavy rains continue to
damage the'footing There is current evidence of the outstanding issue where the proposed
land adjoins our equestrian trails Ashley furniture's current boundary fence continues to be
washed away_ during these times of -heavy rain leaving a lot-of debris on our trails, often times
their entire fence This, boundary fence is a well maintained six foot tall chain linked fence set in
a concrete footing Unless very recently repaired this fence is again currently washed away.
I am definitely not an engineer but from our communities ongoing issues with Buffalo Creek
throughout the year, year after year, I have some reservations about the reduction of wetlands
and the paving of large parking lots and docking stations due to the watershed Since Buffalo
Creek currently cannot'adequately handle its water flow throughout'the =year, it would be -worth
tfie,additiorial effort to reevaluate the idea of increasing the amount additional water added to
Buffalo Creek Without any information of the studies already conducted we really have no idea
what has been planned Maybe the US Army Corp of Engineers has actually reduced the water
flow and has the water routed elsewhere We dust don't know
There is a tributary that adjoins Mr. And Mrs Kohl's property that also consistently floods over

the culvert during these downpours as well_ Again, is more or less water routed to that stream?
We dust don't know
Since Buffalo Creek and its tributaries give our community such difficulty throughout the year a
strong argument could be made that others downstream-are also, adversely effected by the
current water flow Again, we just don't know.
We are equally concerned about surface water contamination as well. Our community is
adjacent to and downstream of Ashley Furniture Industries on Buffalo Creek. Our.horses along
with livestock drink this water -on a regular basis Adjacent fields are also turned into hay
providing food to many animals
We are also concerned about the aquifers that provide the water that our families consume All
of the homes in out community are on a well system.
I ,am confident that after reviewing our concerns that you will also agree that the, application
should be delayed while more research is conducted
Thanks for your consideration,
Mr And Mrs Cook
197 Browder Lane
Advance, NC 27006
336- 391 -9160
Cc
Senator Richard Burr
United States Senator
200 W First Street, Suite 508
Winston Salem, NC 27104
Senator Kay Hagan
United States Senator
701 Green Valley Road, Suite 201
Greensboro, NC 27408

Represeritative,Julia C. Howard
NC House of Representatives
16 W. Jones Street, km 1106
Raleigh, NC 27601
State Senator Andrew C Brock
NC Senator
300 N. Salisbury St Rm 623
Raleigh, NC 27603
Honorable Robert Wisecarver
Chairman of Davie County Board of Commissioners
388 Fort Bixby Road
Advance, NC 27006
M"s Beth Dirks
Manager of Davie County
123 S Main Si.
Mocksvdle, NC 27028
Baltimore Trails Homeowners
Baltimore Downs Homeowners
Advance, NC 27006