20181194 Ver 1_NCWRC Comments_20181119

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
19 November 2018
Mr. David Shaeffer
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive,
Suite 611
Charlotte, North Carolina 28262
Subject: Individual Permit Application for the Charlotte Intermodal Logistics Center,
Mecklenburg County; USACE Action ID SAW -2018-00162, DEQ No. 20181194.
Dear Mr. Schaeffer,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
Individual Permit (IP) application. 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 Mr. Dan Lacz of SL Horton LLC, Atlas Environmental, Inc. (Atlas) has submitted an
Individual Permit (IP) application for the approximately 42.6 -acre property located at 10137 Horton Road
in Charlotte, Mecklenburg County, North Carolina. The applicant is proposing to construct an
approximately 421,900 -square foot commercial warehouse building, two trailer parking areas, two
employee parking areas, two truck courts, and two stormwater best management practice ponds.
Unnamed tributaries to Beaverdam Creek in the Catawba River basin occur in the project area. The IP
application is requesting to permanently impact 115 linear feet of an intermittent stream, 0.0. 17 acre of
wetlands, and 1.009 acres of open water. NCWRC is pleased to see the applicant is avoiding 88.5% of
streams and 70.7% of floodplain wetlands.
We have no current records of state or federally -listed rare, threatened, or endangered species within or
adjacent to the project; however, the lack of records from the site does not imply or confirm the absence
of rare, threatened, or endangered species. A Mecklenburg County Open Space occurs adjacent to the site
to the south-southwest. NC Division of Mitigation Services has an easement along unnamed tributaries to
Beaverdam Creek, including the tributary abutting the wetland (WL 2000) in the southeast corner of the
site.
Although we have no objections to the project, we are concerned for the amount of imperviousness at the
site. Additional impervious surface results in an increase in stormwater runoff that can exert significant
impacts on stream morphology. This will cause further degradation of aquatic habitat through accelerated
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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stream bank erosion, channel and bedload changes, altered substrates, and scouring of the stream channel.
In addition, pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed
landscapes can adversely affect and extirpate species downstream. However, we offer the following
recommendations to further minimize impacts to aquatic and terrestrial wildlife resources.
1. We are pleased to see larger riparian buffers. We prefer the outlet structure for the Stormwater
BMPs to remain outside the riparian buffer to the greatest extent possible. The manage -use zone
should also occur outside the 100 -foot buffer (difficult to discern in drawing). In general, we
recommend a minimum 100 -foot, undisturbed native forested buffer along each side of a
perennial streams and 50 -foot undisturbed, native forested buffer along each side of an
intermittent stream and wetland.
2. We would prefer the applicant use stormwater wetlands instead of dry ponds. Stormwater
wetlands are one of the more effective stormwater practices in removal of pollutants. On page 9
of the application, the applicant proposed to compensate for the open water impact with a
stormwater BMP. Dry ponds do not compensate for the loss of ecological function the pond has
provided wildlife for over 53 years. Atlas indicates the use of dry ponds is due to the proximity
of Charlotte International Airport. It is unlikely the stormwater wetlands on site, depending upon
their design, would attract birds, of size or number, that would cause a significant hazard to air
traffic compared to the existing pond or nearby lakes.
3. We recommend that stormwater BMPs be located at least 750 feet from small wetlands to
minimize hydrologic disturbance and ecological function.
4. 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
stormwater planters and bioretention 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).
5. Due to population declines in bats, we recommend avoiding tree clearing activities during the
maternity roosting season for bats (May 15 — August 15).
6. We recommend draining the pond slowly and during late fall or winter.
7. Consider using native seed mixtures and plants that are beneficial to wildlife for revegetating
disturbed areas and landscaping. Avoid using Bermudagrass, redtop, tall fescue, and lespedeza,
which are invasive and/or non-native and provide little benefit to wildlife. Consider an
alternative mix of red clover, creeping red fescue, and a grain, such as oats, wheat, or rye. Also
avoid using invasive, non-native landscaping plants, such as privet and nandina
(http://www.ncwildflower.org/plant_galleries/invasives—list).
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. 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.

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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
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: Alan Johnson, NCDWR
Sue Homewood, NCDWR
Byron Hamstead, USFWS
Todd Bowers, U.S. Environmental Protection Agency
Jennifer Robertson, Atlas Environmental, Inc.
Dan Lacz, SL Horton Road, LLC