20180133 Ver 1_WRC Comments_20180326

K"'j' North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Samantha Dailey
US Army Corps of Engineers, Wilmington District
FROM: Maria T. Dunn, Coastal Coordinator / y
Habitat Conservation
DATE: March 26, 2018
SUBJECT: Public Notice for Edgecombe County and North Carolina Department of
Transportation, Triangle Tyre, Edgecombe County, North Carolina,
SAW -2008-02741
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
public notice with regard to impacts on fish and wildlife resources. The project site is within a
1400 -acre tract of agriculture and forested lands bordered to the north by US Highway 64
Alternate, to the west by Kingsboro Road, to the south by US Highway 64 and the CSX
Railroad, and to the east by Harts Mill Run Road, approximately 5 miles east of Rocky Mount, in
Kingsboro, NC. Our comments are provided in accordance with provisions of Sections 401 and
404 of the Clean Water Act, as amended, and the Fish and Wildlife Coordination Act (48 Stat.
401, as amended; 16 U.S.C. 661 et seq.)-
The applicants' stated purpose is to provide site infrastructure capable of supporting a tire
manufacturing facility and to relieve economic distress in Edgecombe County through major
industrial development. The proposal includes the discharge of fill material into 5.23 acres of
open water, 9.12 acres of wetlands, and 2,769' of stream channel associated with the
construction of a 400 -acre pad site for the Triangle Tyre facility, and a 2 -lane roadway assessing
the site from Kingsboro Road to the west and US 64 Alternate to the north. The Triangle Tyre
facility would consist of four separate factories built in two phases, and associated supporting
infrastructure including rail spurs, internal roadways, and parking areas, raw material and
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fag: [phone]

finished product receiving and shipping areas, offices and stormwater best management
practices. Jurisdictional boundaries were reviewed by the USACE in August 2008 and an
approved jurisdictional determination (AJD) was received and renewed on December 20, 2013.
The on-site streams are three UTs to Walnut Creek, Walnut Creek, and one UT to Penders Mill
Run. These features are classified WS -N, NSW and are subject to the Tar / Pamlico Basin
Buffer Rules.
The NCWRC has reviewed the information associated with the public notice and does not
believe adequate information has been provided to assess the impacts the project will have on
wildlife resources. The project essentially removes the entire watershed for Walnut Creek and
likely will have an adverse effect on aquatic resources, such as freshwater mussels and
freshwater non -game fish, that utilize Walnut Creek, the UTs of Walnut Creek, and the Tar
River. Therefore, we request additional data be obtained and alternatives considered that reduce
project impacts.
Information associated with the project included a mussel survey that was conducted in 2008.
We request a new mussel survey be conducted throughout the project area and downstream the
project area to determine species present and habitat opportunities. The Tar River and tributaries,
including Walnut Creek, are known to have numerous fresh water mussel species. Included in
the USFWS Edgecombe County records are Dwarf wedgemussel (Alasmidonta heterodon), Tar
River spinymussel (Parvaspina steinstansana), Yellow lance (Elliptio lanceolata), Atlantic
pigtoe (Fusconaia masoni), and Green floater (Lasmigona suhviridis)_ Several other species
important to the NCWRC and listed in the Wildlife Action Plan are Eastern Elliptio (Elliptio
complanata) and Creeper (Strophitus undulates). Since the Walnut Creek system has been under
sampled, a survey conducted by experienced ES permitted biologists should be done. The survey
should be conducted to demonstrate appropriate amount of effort for the system. In addition to
the freshwater mussels, observations should be made for Carolina madtom (Noturus furiosus)
during aquatic surveys. NCWRC recommends a 200 -foot native, forested buffer on perennial
streams and a 100 -foot forested buffer on intermittent streams, or the full extent of the 100 -year
floodplain, adjacent to features that contain threatened or endangered species. This is greater
than the buffer requirements for the NCDWR's Tar / Pamlico Basin Buffer Rules, but
maintaining undisturbed, forested buffers along these areas would reduce impacts to aquatic and
terrestrial wildlife resources and improve water quality_ Grassed buffers do not provide the
necessary and highly valuable functions that forested buffers provide. Sediment and erosion
control structures should also be located outside of these buffers.
The NCWRC would like to see additional avoidance and minimization of wetland and stream
impacts. The public notice is focused on the 400 -acre Triangle Tyre pad, but several other
impacts are also presented that could be avoided or minimized. Use of the existing road system
and elimination of the proposed access road would eliminate several stream impacts, especially if
these reaches contain important aquatic resources. It appears the access road is to provide future
access to developments not disclosed at this time. This will likely increase total wetland and
stream impacts for the 1400 -acre site. All impacts should be presented, avoided, minimized, and
then mitigated at appropriate mitigation ratios. The public notice mentions the NCWAK but
does not provide data sheets or an indication of wetland function. We request this information be

provided. Depending on the results of the NCWA 4, mitigation ratios greater than 1:1 may be
requested.
Upon completion of the proposed 1400 -acre development, the majority of the Walnut Creek
watershed will become impervious. Details regarding stormwater treatment, treatment locations
from wetlands and streams, and discharge rates should be provided. Our agency has concern that
the hydrology of the system will experience significantly altered flow rates, water temperatures,
nutrients, and other water quality parameters that would affect important downstream aquatic
habitats_ Therefore, it is important stormwater systems are carefully designed to treat stormwater
while maintaining appropriate flows, water quality parameters, and buffers to these systems. It is
also important to survey reaches downstream the project area to determine if population changes
are noted post -project construction and if so potential remediation measures may need to be
considered.
The NCWRC appreciates the opportunity to review and comment on this public notice and looks
forward to additional information. Please do not hesitate to contact me at [phone] or at
maria. dunn�,ncwildlife.org if can provide additional assistance.