20180029 Ver 1_WRC Comments_20180206

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
06 February 2018
Mr. Bradley Luckey
Pilot Environmental, Inc.
P.O. Box 128
Kernersville, North Carolina 27285
Subject: Individual Permit Application for the Egger Wood Products Project, Davidson County;
USACE Action ID SAW -2018-00040, DEQ Project No. 20180029.
Dear Mr. Luckey,
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 Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
On behalf of Egger Wood Products, LLC., Pilot Environmental, Inc. has submitted an Individual Permit
(IP) application for the construction of a wood -based products manufacturing facility. The approximately
238 -acre project area is located south of Belmont Road within the 432 -acre I-85 Corporate Center
Industrial Park in Linwood, Davidson County, North Carolina. The proposed project would permanently
impact 49 linear feet (If) of streams, 0.24 acres of wetlands, and 1.00 acre of open water pond. Unnamed
tributaries to South Potts Creek in the Yadkin River basin occur in the project area. South Potts Creek is
classified as a Class C stream by N.C. Division of Water Resources (NCDWR).
We have records for state threatened eastern lampmussel (Lampsilis radiata) in the Yadkin River. As
indicated in the IP application, Environmental Resources Management conducted habitat assessment for
federally -listed species and suitable habitat and/or individuals were not observed in the project area.
Should the permit be issued, we offer the following recommendations to further minimize impacts to
aquatic and terrestrial wildlife resources.
1. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a
minimum 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.
Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment
of pollutants associated with urban stormwater.
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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2. Use non-invasive native species and Low Impact Development (LID) technology in landscaping.
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. LID techniques include
permeable pavement and bioretention areas that can collect stormwater from driveways and
parking areas. Additional alternatives include narrower roads, swales versus curbs/gutters and
permeable surfaces such as turf stone, brick, and cobblestone. Compared to conventional
developments, implementing appropriate LID techniques can be more cost-effective, provide
space -saving advantages, reduce runoff, and protect water quality (Roseen et al. 2011).
Also, NCWRC's Green Growth Toolbox provides information on nature -friendly planning.
(http://www.ncwildlife.orWConservin /g Programs/GreenGrowthToglbox.aspx).
Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. Where feasible, trees and
shrubs should be planted around stormwater ponds, or use LID techniques. 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.
4. Avoid tree clearing activities during the maternity roosting season for bats (May 15 — August 15).
Also, avoid clearing the proposed project during the migratory bird nesting season, roughly
March to August, or conduct surveys for active nests prior to construction to avoid "taking"
migratory birds, which includes wounding or killing. Migratory birds and their eggs are protected
from "take" by the Migratory Bird Treaty Act of 1918.
5. Re -seed disturbed areas with native seed mixtures and plants that are beneficial to wildlife.
Using native species instead of ornamentals should reduce the need for water, fertilizers, and
pesticides. We also urge the Egger Wood Products to incorporate pollinator species into their
plantings. Avoid using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.org/plant izalleries/invasives_list). Further information and free
technical guidance from NCWRC is available upon request.
6. Sediment and erosion control measures should use advanced methods and installed prior to any
land -disturbing activity. 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 that has been reinforced with plastic or metal mesh
should be avoided as it impedes 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.
7. We recommend using green construction techniques to improve water, waste, and energy
efficiency. The following five techniques have the greatest impact on sustainable building:
prefabricating materials in controlled environments, construction waste management, lean
manufacturing to reduce energy, and environmentally -friendly material selection
(https://www.forconstructionpros. com/business/article/ 12068798/five-techniques-for-sustainable-
building-construction).

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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,
C�
Olivia Munzer
Western Piedmont Habitat Conservation Coordinator
Habitat Conservation Program
Literature Cited
Roseen, R. M., T. V. Janeski, J. J. Houle, M. H. Simpson, and J. Gunderson. 2011. Forging the Link:
Linking the Economic Benefits of Low Impact Development and Community Decisions.
University of New Hampshire Stormwater Center, Virginia Commonwealth University, and
Antioch University New England.
ec: Sue Homewood, NCDWR
Bryan Roden -Reynolds, U.S. Army Corps of Engineers
Byron Hamstead, U.S. Fish and Wildlife Service
W. Thomas Russ, NCWRC