20210915 Ver 1_WRC Comments_20210920

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
20 September 2021
Ms. Jennifer Robertson
Atlas Environmental, Inc.
338 S. Sharon Amity Road #411
Charlotte, North Carolina 28211
SUBJECT: Pre -Construction Notification Application for Reedy Fork Industrial at 5955 Summit
Avenue in Browns Summit, Guilford County; USACE Action ID: SAW-2019-02059; DEQ
Project No. 20210915v1.
Dear Ms. Robertson,
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), and
North Carolina General Statutes (G.S. 113-131 et seq.).
Atlas Environmental, on behalf of SL Reedy Fork LLC, has submitted Pre -Construction Notification
(PCN) application and an Individual Water Quality Certification application for the proposed Reedy Fork
Industrial project, an approximate 158.5-acre development located at 5955 Summit Avenue in Browns
Summit, Guilford County, North Carolina.
The proposed project would permanently impact a total of 0.193 acres of jurisdictional wetlands, 46 linear
feet of intermittent streams, and 322 linear feet of perennial streams. Streams impacted by the project are
unnamed tributaries of Reedy Creek in the Cape Fear River basin. Reedy Creek is classified as a Water
Supply-V and Nutrient Sensitive Water by the NC Division of Water Resources.
We have records for the state threatened triangle floater (Alasmidonta undulata), state special concern
notched rainbow (Villosa. constricta), and state significantly rare eastern creekshell (V. delumbis) within
Reedy Fork. Additionally, the state special concern Greensboro burrowing crayfish (Cambarus catagius)
has been documented in Guilford County; however, the full extent of its distribution in this watershed is
unknown due to lack of targeted surveys. The Greensboro burrowing crayfish has been found in all types
of soils from sandy loams to hard clay and burrows are not usually directly associated with any drainage
or stream flow (McGrath 1994). A portion of the site is designated as the Brown's Summit Forest/Hardy's
Millpond Natural Heritage Natural Area (NHNA); natural areas are sites with special biodiversity
significance. Overall, the lack of records from the site does not imply or confirm the absence of federal or
state -listed species. An on -site survey for listed species is the only definitive means to determine if the
proposed project would impact rare, threatened, or endangered species.
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

20 September 2021
Reedy Fork Industrial
USACE Action ID: SAW-2019-02059
Page 2 WRC Comments
We have concerns on the impacts of this project on aquatic and terrestrial wildlife resources, especially
since this project is a relocation of the tenant. We offer the following recommendations minimize impacts
to aquatic and terrestrial wildlife resources.
1. Further minimize impacts to streams and wetlands.
2. We request site inspections for the Greensboro burrowing crayfish. We have included an
information sheet on preliminary site inspections for this species. Please notify Brena Jones,
Central Aquatic Wildlife Diversity Coordinator (brena [e-mail], 919-707-0369), if
any potential Greensboro burrowing crayfish or burrows are located.
3. Due to the presence of state -listed species and a NHNA, we strongly recommend a minimum
100-foot undisturbed buffer for perennial streams or the NHNA, whichever is greatest, and a 50-
foot undisturbed buffer for intermittent streams and wetlands.
4. 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.org/npsdeal/NC_LID_Guidebook.pdf.
5. 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).
6. 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.
7. All stormwater outlets should drain through a vegetated upland area prior to reaching any stream
or wetland area. Sufficient retention designs should be implemented to allow for the slow
discharge of storm water, attenuating the potential adverse effects of storm -water surges; thermal
spikes; and sediment, nutrient, and chemical discharges.
8. 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.
9. 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/invasivesiist).
10. Due to the presence of state -listed species downstream of the project and a NHNA, use strict
sediment and erosion control measures, which 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

20 September 2021
Reedy Fork Industrial
USACE Action ID: SAW-2019-02059
Page 3 WRC Comments
loose -weave netting that is made of natural fiber materials with movable joints 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.
11. We recommend using a bridge or using stream simulation design to install a bottomless culvert
where footers are positioned outside the bankfull and storm surge. If a box culvert must be used,
it 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.
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or [e-mail].
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Sue Homewood, NCDWR
John Ellis, U.S. Fish and Wildlife Service
Brena Jones, NCWRC
David Bailey, USACE