20171527 Ver 1_WRC Comments_20190222

IQ North Carolina Wildlife Resources Commission IQ
Gordon Myers, Executive Director
MEMORANDUM
TO: Lyn Hardison, Environmental Assistance Coordinator
NCDEQ Division of Environmental Assistance and Customer Services
FROM: Ross Sullivan r
Raleigh Regulatory Field Office
US Army Corps of Engineers
DATE: February 22, 2019
SUBJECT: Public Notice for Person County Mega Park, Corps Action ID Number: SAW -2016-
02542.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25) and North Carolina General Statutes (G.S. 113-131 et seq.).
Person County proposes to construct a semiconductor chip manufacturing plant and associated
infrastructure, including transportation improvements and water and natural gas utility lines. Proposed
work will be completed in two phases. Phase I will include the 318 -acre chip manufacturing plant. Phase
2 will include transportation improvements, such road widening, interchange improvements and
additional lanes, as well as gas and water infrastructure projects, specifically a 30 -inch waterline serviced
by the City of Roxboro. The project area contains 10,529 linear feet of streams, 1.94 acres of wetlands
and is located in the Roanoke River watershed. Surface waters on the property drain to Storys Creek,
Marlowe Creek and Castle Creek. The proposed project will directly impact 10,529 linear feet of streams
and 1.94 acres of wetlands.
The proposed chip manufacturing plant is in northern Person County, approximately 1.8 miles north of
the City of Roxboro. It is situated on both sides of Country Club Road, south of its intersection with
Edwin Robertson Road. The proposed water utility line will follow Country Club Road to Cavel-Club
Lake and terminate at Kelly Carver Road. The gas utility line will follow Country Club Road to
Community House Road to McGhees Mill Road and terminate at its intersection with Concord Ceffo
Road.
There is a record for the federal species of concern and state -special concern, notched rainbow (Villosa
constricta) in Storys Creek in the project vicinity. The lack of any further records from the site does not
imply or confirm the absence of federal or state -listed species or state Species of Greatest Conservation
Need listed in the 2015 State Wildlife Action Plan (http://www.ncwildlife.org/plan). An on-site survey is
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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the only definitive means to determine if the proposed project would impact rare, threatened or
endangered species.
The NCWRC hesitates to concur with stream impacts and the filling of wetlands due to wildlife habitat
value and the beneficial functions they provide for flood control and water quality protection. Changes in
land use and increases in impervious surfaces may exacerbate channel degradation and sediment impacts
to stream ecosystems due to increased stormwater runoff and elevated flooding. In addition, pollutants
(e.g., sediment, heavy metals, pesticides and fertilizers) washed from roads and developed landscapes can
adversely affect and extirpate species downstream. If the permit is approved, the NCWRC offers the
following recommendations to minimize impacts to aquatic and terrestrial wildlife resources:
Maintain or establish 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. Wide riparian buffers are helpful in maintaining stream
bank stability. In addition, these buffers provide a travel corridor for wildlife species. Lay
down and staging areas should be located outside wetland areas and at least 100 feet from
streak banks.
2. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert, where practicable. If culverts must be used, the culvert
should be designed to allow aquatic life passage. Fords may be appropriate and preferred for
intermittent stream crossings or where crossings will be used only once or twice a year. For
fords, crossings in riffles are preferred with the banks lowered upstream and downstream of
the crossing. Stabilize the stream bottom with geo-textile fabric and rock; concrete should
not be used for bed stabilization.
Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and
water quality protection. Temporarily disturbed wetland areas should be returned to original
soils and contours, reseeded with annual small grains appropriate for the season (e.g. oats,
millet, rye, wheat or rye grass) and allowed to revert to natural wetland vegetation. In all
forested wetlands, clearing should be done by hand.
4. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re -seeded with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures as fescue is invasive and provides little benefit to wildlife. Native, annual small
grains appropriate for the season are preferred and recommended. Pollinator mixes are
commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths and birds. Where feasible, use woody debris and logs from cleared areas to
establish brush piles adjacent to cleared right-of-ways to improve habitat. Allowing the
corridor areas to re -vegetate into a brush/scrub habitat would maximize benefits to wildlife.
For areas adjacent to residential areas, a native shrub/grass option may also be beneficial.
Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of ROWS within 100 feet of perennial streams and 50 feet of intermittent
streams, or within floodplains and wetlands associated with these streams.

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Sediment and erosion control measures should be 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 and 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.
The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondaryandCumulativelmpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources; in addition, the Green Growth
Toolbox (http://216.27.39.101/ r� een r� owth/) provides information on nature -friendly planning that
discusses how to address growth while concurrently conserving priority terrestrial and aquatic habitat.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or gabriela. arrison a,ncwildlife.org.
ec: Karen Higgins, NCDWR