20170688 Ver 1_WRC Comments_20170630

� North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
30 June 2017
Mr. Stephen Brown
The EI Group, Inc.
201 McCullough Drive, Suite 150
Charlotte, North Carolina 28025
Subject: Individual Permit Application for Johnson Concrete - Piedmont Block Company, Storage
Area Expansion Project; Cabarrus County. USACE ID No. SAW -2016-0030; DEQ Project
No. 20170688.
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resource Commission (NCWRC) have reviewed the subject
information. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of Johnson Concrete - Piedmont Block Company, the EI Group, Inc. has submitted an
Individual Permit (IP) application for the Storage Area Expansion project located at 103 Old Davidson
Place, NW, Concord, Cabarrus County, North Carolina. An unnamed tributary to Irish Buffalo Creek
flows into the pond through an existing 36 -inch pipe and it becomes channelized after the dam. The
project proposes to fill the pond and continue piping the stream through the property in a 48 -inch pipe.
The channelized portion of the stream will be cleared of debris and restored; rip rap will be installed to
stabilize the bed and bank and to dissipate energy. As stated in the IP, the project would result in 33 if of
permanent impacts to an unnamed tributary of Irish Buffalo Creek, and the fill of an approximately 0.99 -
acre pond and a 0.003 -acre wetland.
Irish Buffalo Creek in the Yadkin River — Pee Dee River basin is classified as a Class C stream by N.C.
Division of Water Resources (NCDWR). We do not have records of federal or state -protected species
adjacent to or within the site.
We offer the following recommendations to minimize impacts to aquatic and terrestrial wildlife resources.
We are concerned with the filling of the pond and piping of the stream due to the potential for
long-term and cumulative impacts. Stream piping and placing fill in aquatic resources can alter
hydrology, result in significant negative impacts to downstream areas, and eliminate aquatic and
terrestrial wildlife habitat. Stream piping reduces the infiltration of stormwater and associated
pollutants, as well as the dissipation of stream energy. Instead, impacted streams should be
relocated using natural channel design or the stream should be incorporated into the design of the
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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30 June 2017
Johnson Concrete - Piedmont Block Company
Cabarrus County
development. Streams that are sunlit with forested buffers provide aquatic habitat and beneficial
water quality functions.
2. After construction, disturbed stream banks should be restored to original contours and re -
vegetated with native plant materials. Consider using state-of-the-art natural channel design and
restoration techniques. We prefer natural materials such as coir -fiber rolls, biodegradable
erosion -control blankets, and vegetation instead of rip -rap, where practical. If rip -rap is required,
it should be placed above normal bankfull. Aquatic life passage should be assured during low
flow or drought conditions. Any riprap used should not interfere with aquatic life movement
during low flow.
Manage non-native, invasive species during all phases of the project. Long-term bank
stabilization can be accomplished using native plants such as red maple, black willow, sycamore,
river birch, silky dogwood, and other native woody species. Re -seed disturbed areas with seed
mixtures or native plants that are beneficial to wildlife. Avoid fescue -based mixtures because
fescue is invasive and provides little benefit to wildlife. Using native species instead of
ornamentals should reduce the need for water, fertilizers and pesticides. In open areas, consider
planting native, wildflower seed mixes that will create pollinator habitat within the project
boundary. A list of wildlife -friendly plants is available upon request.
4. Water discharges from the site should be proportional to the size of the receiving stream so the
hydrology of the stream is not altered, and all discharges should comply with NPDES permit
requirements. In particular, turbidity of the discharge should be maintained at or below the
permit requirement. High water discharge rates and turbidity can negatively impact aquatic
resources within and downstream of the site. 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.
An increase in impervious surfaces from development alters the hydrology of a watershed and
affects water quality. With reduced infiltration, runoff rates increase and cause stream levels to
increase more quickly and result in more frequent flood events. Such increased flood frequency
can worsen streambank erosion, particularly if riparian conditions are poor. Efforts to reduce the
amount of imperviousness and control stormwater are important to reduce the hydrologic impacts
of increased development and the effects on aquatic and terrestrial wildlife habitat
6. Sediment and erosion control measures should be installed prior to any land clearing, construction
or disturbance. 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 joints between the
vertical and horizontal twines. Silt fencing or similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.

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30 June 2017
Johnson Concrete - Piedmont Block Company
Cabarrus County
Thank you for the opportunity to provide input for this project. For further information or free technical
guidance from the NCWRC, please call [phone] or email olivia.munzer@,ncwildlife.org.
Sincerely,
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
ec: Alan Johnson, NCDWR
Jason Randolph, U.S. Army Corps of Engineers
Byron Hamstead, U.S. Fish and Wildlife Service