20171559 Ver 3_NCWRC Comments -SAW-2015-01268_20210914

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sue Homewood
Division of Water Resources
NC Department of Environmental Quality
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation C-21
DATE: 14 September 2021
Subject: Public Notice for Greensboro Randolph Megasite in Randolph County; USACE Action ID:
SAW-2017-01268; DEQ Project No. 201715590.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
HDR, on behalf of Greensboro -Randolph Megasite (GRMS) Foundation, Inc., has submitted an
Individual Permit application and associated documents for the proposed development of the GRMS, an
approximate 1,825-acre advanced automotive manufacturing facility, and associated utility and
transportation improvement sites. The GRMS is bounded by Old US 421 to the north, Julian Airport to
the west, Troy Smith Road to the east and US 421 to the south in the Town of Liberty, Randolph County,
North Carolina.
The proposed project would impact a total of 8.4 acres of jurisdictional wetlands, 21.3 acres of open
water, 6,806 linear feet of intermittent streams, and 29,656 linear feet of perennial streams. Streams
impacted by the project are Dobson Creek and its unnamed tributaries (UTs), Sandy Creek and its UTs,
UTs of Little Polecat Creek, Polecat Creek and its UTs, Climax Creek and its UTs, North Prong Stinking
Quarter Creek, and Big Alamance Creek and its UTs in the Cape Fear River basin.
We have records for the Carolina creekshell (Villosa vaughaniana; Federal Species of Concern, State
Endangered), notched rainbow (V. constricta, State Special Concern), eastern creekshell (V. delumbis),
and Carolina ladle crayfish (Cambarus davidi; State Significantly Rare) in waterways that are directly or
indirectly impacted by the project. The Greensboro burrowing crayfish (C. catagius; State Significantly
Rare) could also potentially occur within the project area. Although some records occur within the area,
we have many data gaps, including throughout the site. The lack of records from the site does not imply
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
or confirm the absence of state -listed species. An on -site survey for state -listed species is the only
definitive means to determine if the proposed project would impact rare, threatened, or endangered
species.
We have concerns on the impacts of this project on aquatic and terrestrial wildlife resources. Although
the applicant will mitigate for the impacts to streams and wetlands, there is a temporal lag in aquatic and
terrestrial function at a mitigation site. Additionally, the impacts to aquatic and terrestrial flora and fauna
from such a large project cannot be replaced with mitigation. Therefore, we would like to see impacts to
waters of the U.S. further minimized or avoided. Furthermore, the large amount of impervious surface
proposed, along with the removal of those currently mostly buffered tributaries, would contribute to
significant degradation of downstream habitat for aquatic species, including increased flooding intensity
and erosion from stormwater.
We offer the following recommendations minimize impacts to aquatic and terrestrial wildlife resources.
Overall Project:
1. We recommend surveys for state -listed mussel and crayfish species to determine if relocations are
needed. Please contact Brena Jones, the Central Aquatic Wildlife Diversity Research
Coordinator, at 919-707-0369 or brena.jone s(a ncwildlife.org.
2. We highly recommend avoiding impacts to the tributary complex (S21 and its UTs) in the eastern
portion of the project. It is the only stream complex in the project area not flowing into Dobson
Lake, which is a man-made lake that already impedes aquatic movements.
3. A large portion of the project is used for surface parking. We recommend building a parking deck
or underground parking rather than impacting the streams for surface parking. For any surface
parking or roads, we recommend using bioretention cell in parking lot medians, for example, that
can collect stormwater from the building and parking area. Additional information can be found
at the NC State University's guide:
http://www.onsiteconsortium.or/g_npsdeal/NC_LID_Guidebook.pdf.
4. The applicant should avoid the removal of large trees. Due to the decline in many tree -roosting
bat populations, trees should not be removed during the maternity roosting season for bats (May
15 — August 15).
5. We recommend a minimum 100-foot undisturbed buffer for perennial streams and a 50-foot
undisturbed buffer for intermittent streams and wetlands.
Incorporate the following elements into erosion and sediment control plans: minimize clearing
and grading, protect waterways, phase construction for larger construction sites (>25 acres),
stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish appropriate
perimeter controls, employ advanced settling devices, implement a certified contractors program,
and regularly inspect erosion control measures. Ensure all silt fencing is removed once vegetation
has reestablished and soils have stabilized.
7. Disturbed areas should be reseeded with native seed mixtures that are beneficial to wildlife. The
applicant should consider planting native, wildflower seed mixes and plants that will create
pollinator habitat, which would also improve the aesthetics of the project and within rights -of -
way. Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-native
species, should not be used and these species provide little benefit to wildlife. In lieu of lawn or
grassy areas, we recommend planting native pollinator species or other native vegetation. Avoid
using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.org_/plant galleries/invasives_list).

14 September 2021 Page 3
Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
WRC Comments
Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife -friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have
loose -weave netting that is made of natural fiber materials with movable j oints between the
vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. 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.
Utility Lines:
9. To reduce impacts to streams, we recommend the sewer/water line run from Liberty Road portion
as seen in Alternative 1 and then use Alternative 2 route along Steeple Chase Road.
10. The directional bore stream crossing method should be used for utility crossings rather than open -
cut stream crossing method to prevent the likelihood of future lateral movement of the stream,
causing undercutting or erosion around the utility line. The open -cut stream crossing method
should only be used when water level is low and stream flow is minimal.
11. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer
areas. Manholes or similar access structures should not be allowed within buffer areas. Stream
crossings should be near perpendicular (750 to 1050) to stream flow.
12. Clearing of the rights -of -way should be avoided during the migratory bird nesting season, roughly
March to August.
Transportation:
13. The culvert must be designed to allow for aquatic life and fish passage. Generally, the culvert or
pipe invert should be buried at least 1 foot below the natural streambed (measured from the
natural thalweg depth). If multiple barrels are required, barrels other than the base flow barrel(s)
should be placed on or near stream bankfull or floodplain bench elevation (similar to Lyonsfield
design). These should be reconnected to floodplain benches as appropriate. This may be
accomplished by utilizing sills on the upstream and downstream ends to restrict or divert flow to
the base flow barrel(s). Silled barrels should be filled with sediment so as not to entrap wildlife
or support mosquito breeding conditions. Sufficient water depth should be provided in the base
flow barrel(s) during low flows to accommodate fish movement. If culverts are longer than 40-50
linear feet, alternating or notched baffles should be installed in a manner that mimics existing
stream pattern. This should enhance aquatic life passage: 1) by depositing sediments in the
barrel, 2) by maintaining channel depth and flow regimes, and 3) by providing resting places for
fish and other aquatic organisms. In essence, base flow barrel(s) should provide a continuum of
water depth and channel width without substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment whenever possible to
avoid channel realignment. Widening the stream channel must be avoided. Stream channel
widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be
professionally designed, sized, and installed.

14 September 2021 Page 4 WRC Comments
Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
The NCWRC encourages the applicant to consider additional measures to protect wildlife species in
developing landscapes. The NCWRC's Guidance Memorandum to Address and Mitigate Secondary and
Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water Quality details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
http: //www.ncwildlife . org/portal s/O/Conserving/documents/2002_GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002).
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or olivia.munzerkncwildlife.org.
ec: Vickie Miller, HDR
John Ellis, U.S. Fish and Wildlife Service
Brena Jones, NCWRC
Jean Gibby, USACE