20180029 Ver 1_USACE Correspondence_20180215

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
PUBLIC NOTICE COMMENTS
Issue Date: 02/15/2018
Response Deadline: 03/19/2018
Corps Action ID Number: SAW -2018-00040
Mr. Bernhard Vorreiter
Egger Wood Products, LLC
P.O. Box 907
Lexington NC 27293
Dear Mr. Vorreiter:
Please reference your Individual Permit application for Department of the Army (DA)
authorization to discharge fill material into 0.238 acre of wetlands, 49 linear feet of stream, and
1.0 acres of open water, associated with the construction of a large-scale composite wood
products manufacturing facility in the I-85 Corporate Center Industrial Park located on the south
side of Belmont Road in the Linwood community of Davidson County, North Carolina.
Your proposal was advertised by public notice on January 12, 2018. Comments in response
to the notice were received from the North Carolina Department of Environmental Quality,
Division of Water Resources (NCDEQ-DWR), the North Carolina Wildlife Resources
Commission (NCWRC), the North Carolina Department of Natural and Cultural Resources,
State Historic Preservation Office (NC-SHPO), the U.S. Fish and Wildlife Service (USFWS),
and the National Oceanic and Atmospheric Administration, National Marine Fisheries Service
(NMFS). The comments received are enclosed for your information and to provide you with the
opportunity to address any of the stated concerns (Table 1). Please provide written responses to
the comments from the NCWRC, NC-SHPO, and the USFWS. The NMFS, in a letter dated
January 16, 2018, stated the proposed project would not occur within the vicinity of essential fish
habitat. The NCDEQ-DWR, in an email dated January 17, 2018, requested additional
information and you responded via email on February 5, 2018. The NCDEQ-DWR was satisfied
with your responses had no additional comments. Therefore, the U.S. Army Corps of Engineers
(Corps) believes you adequately addressed the NCDEQ-DWR comments and further action is
not needed related to the NCDEQ-DWR comments. Additionally, this letter serves as the Corps
comment letter, which needs written response, and the comments are as follows:
1. With respect to the project purpose, its analysis is a critical first step in the Corps
permitting process. The Corps is responsible in all cases for independently defining the
project purposes from both the applicant's and the public's perspective. Initially, the
Corps evaluates a project's "basic purpose" to assess whether the project is water

dependent. Once the Corps has determined the water dependency of the project, it no
longer considers the basic project purpose, but analyzes practicable alternatives in the
light of the "overall project purpose". The overall project purpose must be specific
enough to define the applicant's need, but not so restrictive as to preclude an analysis of
all reasonable alternatives. The project purpose stated in your application is "to develop a
large-scale composite wood products manufacturing facility within the North American
market that is capable of incorporating future technological advances and production
lines to allow the facility to remain viable in the future". In considering the overall
project purpose, we have determined that this project purpose is too broadly defined
which sets too large of a geographic region to analyze. Therefore, we have determined
the overall project purpose of this project is to develop a large-scale wood composite
manufacturing facility within the Southeast United States to meet current and future
market demands.
2. In the Individual Permit Submittal Package you stated "the proposed project is located in
an area that has been determined to have high market place demand for manufactured
goods, an adequate supply of raw materials, and adequate work for of highly skilled
laborers, and desirable logistics due to geographic location for export of produced goods
and import of raw materials". Please provide additional information to support this claim.
3. In the Individual Submittal Permit Package you stated "the geographic location of the
proposed project is centrally located in the eastern United States, thus providing optimal
logistics for shipping manufactured products and receipt of raw materials". Please
provide additional information to support this claim.
4. With regards to the Beallmont house, during the applicant preparation phase you received
a response letter from NC-SHPO stating the Beallmont house is not eligible for listing on
the National Register of Historic Places. However, during the public notice period the
NC-SHPO submitted a copy letter which stated the "proposed project will adversely
affect the National Register -listed Beallmont House (DV0007)." Therefore, further
consultation with Egger and the NC-SHPO will be needed to understand the Beallmont
House and its listing on the National Register of Historic Places.
5. With regards to the Off -Site Alternative Analysis, you expressed the importance of
proximity to a rail service; however, the two finalist sites, which were not chosen, did not
mention their proximity to a rail line. Therefore, please provide additional information for
the two finalist sites and their proximity to existing rail lines.
6. With regards to the Off -Site Alternatives Analysis, avoidance and minimization of the
waters of the United States was analyzed for the preferred site; however, the two other
finalists, were not analyzed or this information was not provided in the Individual Permit
Submittal Package. Therefore, please provide the analysis for the two other finalist sites
in relation to the potential impacts to waters of the United States based on proposed site
configuration. Also, include all impacts for each potential site configuration for each of
the three finalist sites. This information for all three sites (i.e., the preferred site and two
other non -preferred sites) will be beneficial to the Corps in analyzing the proposed
project. In addition, if impacts are less at another a non -preferred site or alternate site
configuration, then provide explanation as why the lesser impact alternative is not
practicable and/or feasible.
7. In the Individual Permit Submittal Package you state "the proposed project was
determined to be the preferred alternative and the least damaging to the environment

while still meeting the Applicant's purpose and need". Currently the submittal package
does not support the claim of "least damaging to the environment". If Corps' question 7
is adequately addressed then this claim may be supported. Please provide any additional
information (i.e., that has not already been requested) to support the claim of the
preferred location and configuration is the least damaging to the environment.
8. No compensatory mitigation was proposed for the 1.0 acres of open water impacted by
the proposed project (PX 1-43 and PXA 1-12). This open water feature is immediately
downstream of wetland WXA 1-22. PX 1-43 and PXA 1-12 have been routinely
manipulated - shallow water levels maintained and lowered for use as a duck hunting
impoundment. Based on our review, PX 1-43 and PXA 1-12 display characteristics more
similar to shallow water wetlands rather than an open water impoundment. Based on its
landscape position and the surrounding land use, these features provide environmental
benefits including storm flow retention and storage, sediment deposition, and nutrient
deposition and/or uptake. Therefore, our initial determination is to require additional
compensatory mitigation for impacts to PX 1-43 and PXA 1-12 at a proposed mitigation
ratio of 0.5:1.
The aforementioned requested information is essential to the expeditious processing of your
application; please forwarded this information to us by March 19, 2018. If you do not submit this
information within the timeline provided above, your application will be administratively withdrawn.
Withdrawal of your application does not preclude you from reopening the application at a later time,
provided you submit the items listed above.
If you have any questions regarding these matters, please contact me at [phone] or
bryan.roden-re. n�(d),usace.army.mil.

Table 1. Comments in Response to the Public Notice
Date of
Comment
Commenter
Comment/Recommendation
Letter
January 16,
National Oceanic
NOAA stated the proposed project would not occur in the
2018
and Atmospheric
vicinity of essential fish habitat and present staffing levels
Administration
preclude further analysis; therefore no further action is
(NOAA)
planned.
January 18,
North Carolina
1). It would be helpful to see an overlay of Off -Site
2018
Department of
Alternative 1 and the lot layout to support the statement
Environmental
that there would be a loss marketability of the other three
Quality, Division
lots under this Alternative.
of Water
Resources
2). Can you provide some more explanation of the
(NCDEQ-DWR)
"necessary development improvements" would be?
February 6,
North Carolina
1). Recommends to maintain a minimum 100 -foot
2018
Wildlife Resources
undisturbed, native, forested buffer along perennial
Commission
streams, and a minimum 50 -foot buffer along intermittent
(NCWRC)
streams and wetlands.
2). Recommends to use non-invasive native species and
Low -Impact Development (LID) technology in landscaping.
3). Recommends to limit impervious surface to less than 10
percent or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less
than 10 percent. Where feasible, trees and shrubs should
be planted around stormwater ponds, or use LID
techniques.
4). Recommends to avoid tree clearing activities during the
maternity roosting season for bats (May 15 — August 1S).
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.
5). Recommends to re -seed disturbed areas with native
seed mixtures and plants that are beneficial to wildlife.
6). Recommends sediment and erosion control measures
should use advanced methods (i.e., biodegradable and
wildlife -friendly sediment and erosion control devices) and

Date of
Comment
Commenter
Comment/Recommendation
Letter
installed prior to any land -disturbing activity.
7). Recommends using green construction techniques to
improve water, waste, and energy efficiency.
February 8,
North Carolina
1). Recommends installing a substantial, evergreen
2018
Department of
vegetation buffer along the length of the applicant's
Natural and
property line on Belmont Road prior to the commencement
Cultural
of construction. In addition, the plant material shall be
Resources, State
guaranteed for two full growing seasons.
Historic
Preservation
Office (NCDNCR-
SHPO)
February 9,
U.S. Fish and
1). Recommends avoiding any associated tree clearing
2018
Wildlife Service
activities during the maternity roosting season from May 15
(USFWS)
— August 15 to reduce the probability for take of the
northern long-eared bat (Myotis septentrionalis).
2). Recommends measures to control sediment and erosion
should be installed before any ground -disturbing activities
occur.
3). Recommends forested riparian buffers (i.e., a minimum
of 50 feet wide along intermittent streams and 100 feet
wide along perennial streams) should be created and/or
maintained along all aquatic areas.
4). Recommends the consideration of LID techniques for
retaining and treating storm -water runoff rather than the
more traditional measures such as large retention ponds.
5). Recommends when a water detention pond is used,
storm -water outlets should drain through a vegetated area
prior to reaching any natural stream or wetland area.
6). Recommends the use of pervious materials (i.e.,
pervious concrete, interlocking/open paving blocks, etc.) for
the construction of roads, driveways, sidewalks, etc.

Sincerely,
Bryan Roden -Reynolds
Regulatory Program Manager
Charlotte Field Office
Enclosures:
1. NMFS Comment Letter Dated January 16, 2018
2. NCDEQ-DWR Comment Email Dated January 17, 2018
3. NCWRC Comment Letter Dated February 6, 2018
4. NC-SHPO Comment Letter Dated February 8, 2018
5. USFWS Comment Letter Dated February 9, 2018
Copies Furnished:
Mr. Bradley Luckey
Pilot Environmental, Inc.
P.O. Box 128
Kernersville NC 27285
6

(Sent via Electronic Mail)
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Ad ministration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
26313th Avenue South
St. Petersburg, Florida 33701-5505
http:ltsera. n mfs. noaa.gov
January 16, 2018
NOAA's National Marine Fisheries Service (NMFS) reviewed the project described in the public
notice listed below. Based on the information in the public notice, the proposed project would
NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date Comment Due Date
SAW -2018-00040 Egger Wood Products January 12, 2018 February 10, 2018
SAW -2006-20748 NCDOT, US 321 January 9, 2018 February 7, 2018
(Catawba and Caldwell
Counties) STIP U-4700
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical
habitat under the purview of the NMFS, please initiate consultation with the Protected Resources
Division at the letterhead address.
Sincerely,
Pace Wilber for
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

Roden Reynolds, Bryan K CIV (US)
From: Homewood, Sue <[e-mail]>
Sent: Wednesday, January 17, 2018 3:16 PM
To: Brad Luckey
Cc: Roden Reynolds, Bryan K CIV (US)
Subject: [EXTERNAL] Egger
Follow Up Flag: Follow up
Flag Status: Completed
Brad,
The application documentation references lots within the 1-85 Corporate Center Industrial Park. Would you please
provide a map that shows the existing lots. It would also be helpful to see an overlay of Off -Site Alternative 1 and the lot
layout to support the statement that there would be a loss of marketability of the other 3 lots under this Alternative.
The application also states that "other layouts and design options within the 1-85 Corporate Center Industrial Park result
in necessary development improvements occurring outside of the 1-85 Corporate Center Industrial Park, within areas not
available for Applicant/Owner purchase or development". Can you provide some more explanation of the "necessary
development improvements" would be.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
I

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

0 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 1-85 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]

Page 2
06 February 2018
Egger Wood Products
SAW -2018-00040
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 galleries/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
(httl2s: //www. forconstructionpros. com/busine ss/article/ 1206879 8/five-techniques-for-sustainable-
building-construction).

Page 3
06 February 2018
Egger Wood Products
SAW -2018-00040
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.munzerkncwildlife.org.
Sincerely,
0—�
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

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
February 8, 2018
Bryan Roden -Reynolds
USACE Regulatory Field Office
151 Patton Avenue
Asheville, NC
bryan.roden-reynolds e,usace.army.mil
RE: Egger Wood Products, Located off Belmont Road, Linwood, SAW -2018-00040,
Davidson County, ER 18-0115
Dear Mr. Roden -Reynolds:
Office of Archives and History
Deputy Secretary Kevin Cherry
Thank you for your January 12, 2018, Public Notice for the above -reference undertaking. We have reviewed
the materials provided and believe that the proposed project will adversely affect the National Register -listed
Beallmont House (DV0007). The house was moved from the subject site in 2017 under a Memorandum of
Agreement with Davidson County, which used Community Development funds to develop the house's original
site as an industrial park for an undetermined manufacturing facility.
While the house is no longer on the subject site, it is located to the east and across Belmont Road from the
proposed wood products center. Given the nature of the proposed industry, it will create traffic, industrial
noises, and light pollution that will increase as its several phases are developed. These conditions will adversely
affect the setting and atmosphere of the historic house and diminish its desirability for reuse, without some
form of buffering.
As the wood products manufacturing facility would not be able to be constructed, but for the issuance of the
USACE's permit, we believe that the undertaking is subject to Section 106 of the National Register and
requires additional consideration by the Corps. To avoid the adverse effects that are likely to result from the
construction of the wood products manufacturing facility, we recommend that the USACE condition any
permit issued for the undertaking to include the following.
The permittee shall install a substantial, evergreen vegetative buffer along the length of its property line
on Belmont Road for Phases I and II. Plans for the buffer shall be reviewed and approved by the State
Historic Preservation Officer. The buffer shall be installed prior to any construction taking place on the
subject property. The plant materials shall be guaranteed for two full growing seasons. Any plants lost
during that time shall be replaced in-kind.
The project area has been investigated with an archaeological reconnaissance survey and one previously
recorded archaeological site is present within the project area. That site, 31DV756, was determined not eligible
for listing in the National Register of Historic Places (NRHP). No additional archaeological investigations are
recommended within the current project area.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.review(kncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
�C� )�4duL-tajfj�
�=KRamona M. Bartos
cc: Ted Alexander, PNC, talexanderkpresnc.org

ua
FTM &AVTLIHIFE
United States Department of the InteriorSERVIUE
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa StreetFl
Asheville, North Carolina 28801
February 9, 2018
Mr. Bryan Roden -Reynolds
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Dear Mr. Roden -Reynolds:
Subject: Egger Wood Products Development Project; Davidson County, North Carolina
Log No. 4-2-15-555
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public
notice issued January 12, 2018 (and associated documents) for the proposed project referenced
above. We submit the following comments in accordance with the provisions of the Fish and
Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National Environmental
Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531-1543) (Act).
Project Description
According to the information provided, the Applicant is seeking an individual permit for impacts
to jurisdictional waters of the U.S. associated with the phased construction of a wood products
manufacturing facility on approximately 238 acres adjacent to the in Linwood, North Carolina.
Specifically, the proposed project would result in permanent impacts to 1.00 acre of open water,
0.238 acre wetland, and 49 linear feet of an unnamed tributary to the Yadkin River. Current
project area land cover is composed of a mixture of agricultural, forested, and residential areas.
Federally Listed Endangered and Threatened Species
According to Service records, suitable summer roosting habitat may be present in the project
area for the federally threatened northern long-eared bat (Myotis septentrionalis; i.e. crevices,
cavities, and gaps in the bark of live and dead trees). However, the final 4(d) rule (effective as of
February 16, 2016), exempts incidental take of northern long-eared bat associated with activities
that occur greater than 0.25 miles from a known hibernation site, and greater than 150 feet from
a known, occupied maternity roost during the pup season (June 1 — July 31). Based on the
information provided, the project (which may or may not require tree clearing) would occur at a
location where any incidental take that may result from associated activities is exempt under the
4(d) rule. Although not required, we encourage the Applicant to avoid any associated tree
clearing activities during the maternity roosting season from May 15 — August 15 to reduce
the probability for take of this species.

According to our records and a review of the information presented, no other federally protected
species or their respective habitats occur within the project boundary, and we require no further
action or information at this time. However, obligations under section 7 of the Endangered
Species Act must be reconsidered if. (1) new information reveals impacts of this identified
action that may affect listed species or critical habitat in a manner not 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.
We offer the following comments in the interest of protecting fish and wildlife resources:
Erosion and Sediment Control
The size of the proposed ground disturbance and its proximity to jurisdictional features
necessitates stringent erosion control measures to prevent degradation of aquatic habitats.
Measures to control sediment and erosion should be installed before any ground -disturbing
activities occur. To the extent that it is reasonably feasible, instream work should occur under
dry conditions utilizing a temporary diversion/pump-around system. Grading and backfilling
should be minimized, and existing native vegetation should be retained (if possible) to maintain
riparian cover for fish and wildlife. Disturbed areas should be revegetated with native grass and
tree species as soon as possible. A reasonable effort should be made to limit the extent of
disturbance to what will be stabilized by the end of the workday. Natural fiber matting (coir)
should be used for erosion control as synthetic netting can trap animals and persist in the
environment beyond its intended purpose.
Riparian Buffers
Natural, forested riparian buffers are critical to the health of aquatic ecosystems. They
accomplish the following:
1. catch and filter runoff, thereby helping to prevent nonpoint-source pollutants
from reaching streams;
2. enhance the in -stream processing of both point- and nonpoint-source
pollutants;
3. act as "sponges" by absorbing runoff (which reduces the severity of floods)
and by allowing runoff to infiltrate and recharge groundwater levels (which
maintains stream flows during dry periods);
4. catch and help prevent excess woody debris from entering the stream and
creating logjams;
5. stabilize stream banks and maintain natural channel morphology;
6. provide coarse woody debris for habitat structure and most of the dissolved
organic carbon and other nutrients necessary for the aquatic food web; and
7. maintain air and water temperatures around the stream.
Forested riparian buffers (a minimum 50 feet wide along intermittent streams and 100 feet wide
along perennial streams [or the full extent of the 100 -year floodplain, whichever is greater])
should be created and/or maintained along all aquatic areas. Impervious surfaces, ditches, pipes,
2

roads, utility lines (sewer, water, gas, transmission, etc.), and other infrastructures that require
maintained, cleared rights-of-way and/or compromise the functions and values of the forested
buffers should not occur within these riparian areas.
Impervious Surfaces and Low -Impact Development
The Service is concerned about the proposed increase in impervious surface and stormwater-
mediated impacts to streams and wetlands onsite. At 35- to 50 -percent impervious surface,
runoff triples, and deep infiltration is decreased by 40 percent. Adequate treatment of storm
water in development areas is essential for the protection of water quality and aquatic habitat in
developing landscapes.
We recommend consideration for low -impact -development techniques, such as reduced road
widths, grassed swales in place of curb and gutter, rain gardens, and wetland retention areas, for
retaining and treating storm -water runoff rather than the more traditional measures, such as large
retention ponds, etc.
Where detention ponds are used, storm -water outlets should drain through a vegetated area prior
to reaching any natural stream or wetland area. Detention structures should be designed 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. Since the purpose of
storm -water -control is to protect streams and wetlands, no storm -water -control measures or best
management practices should be installed within any stream (perennial or intermittent) or
wetland. Moreover, we recommend that retention ponds be located at least 750 feet from
small wetlands to minimize hydrologic disturbance and ecological function.
We also recommend that consideration be given to the use of pervious materials (i.e., pervious
concrete, interlocking/open paving blocks, etc.) for the construction of roads, driveways,
sidewalks, etc. Pervious surfaces minimize changes to the hydrology of the watershed and can
be used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and
store heat and allow the cooler soil below to cool the pavement. Additionally, pervious concrete
requires less maintenance and is less susceptible to freeze/thaw cracking due to large voids
within the concrete.
The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-15-555.
E.c. Bradley Luckey; USACE
Oliva Munzer; NCWRC
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
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