20190289 Ver 1_WRC Comments_20190610

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Brian Breissinger
Timmons Group
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 10 June 2019
SUBJECT: Individual Permit for the Publix Distribution Center in Guilford County; USACE Action
ID: SAW -2018-00240; DEQ Project No. 20190289.
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 (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
The Timmons Group, on behalf of Publix Super Markets, Inc., has submitted an Individual Permit
application for the proposed development of an approximately 342.5 -acre Publix Distribution Center and
11.7 acres of roadway improvements along U.S. 70. The entire project area totals 354.2 acres. The
project would permanently impact 4,502 linear feet (lf) of streams; permanently impact 0.8 acre (ac) of
wetland; and permanent impacts to 1.8 ac of open water.
The project would impact unnamed tributaries to Little Alamance Creek in the Cape Fear River basin.
Little Alamance Creek is classified as a Water Supply IV and Nutrient Sensitive Water by the NC
Division of Water Resources (NCDWR). The project lies within the Jordan Lake Watershed Supply
Nutrient Strategy area and is subject to the riparian buffer rules; however, the applicant is seeking a major
variance.
We have records for the state special concern Greensboro burrowing crayfish (Cambarus catagius) near
the site. The Greensboro burrowing crayfish has been found in all types of soils from sandy loams to
hard clay and burrows are not usually directly associated with any drainage or stream flow (McGrath
1994). The species has never been found in any flowing water. The full extent of its distribution in this
watershed is unknown due to lack of targeted surveys. The lack of records from the site does not imply or
confirm the absence of federal or state -listed species. An on-site survey is the only definitive means to
determine if the proposed project would impact rare, threatened, or endangered species.
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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We have concerns on the impacts of this project on aquatic and terrestrial wildlife resources. We would
like to see impacts to waters of the U.S. further minimized or avoided. The large amount of impervious
surface proposed, along with the removal of those currently mostly -buffered tributaries, would contribute
to significant degradation of downstream habitat for these species, including increased flooding intensity
and erosion from stormwater.
We offer the following recommendations minimize impacts to aquatic and terrestrial wildlife resources.
1. We recommend avoiding the streams in the eastern portion of the site because they are of higher
quality. If any of the higher quality streams (streams 6-10) are impacted, then we recommend
surveys for state -listed mussel and crayfish species to determine if relocations are needed. For
more information, please contact Brena Jones, the Central Aquatic Wildlife Diversity Research
Coordinator, at 919-707-0369 or [e-mail].
2. The applicant should consider alternatives to the building layout to reduce impacts to streams and
riparian buffers. If the streams and riparian areas are impacted by construction of these parking
spaces, we question whether some of these impacts could be avoided or minimized by
constructing stand -along parking structures or a parking lot under the warehouse. The applicant
should also consider reducing the warehouse footprint by building the center support core for the
employees on a second floor and reduce the size of the stormwater ponds by implementing Low
Impact Development (LID) technology.
3. LID techniques include bioretention areas that can collect stormwater from driveways and
parking areas. On sheet EX 1, the dark shaded areas that appear to be concrete structures could
potentially be constructed as bioretention wetlands/swales that receive stormwater from the
parking areas. Similarly, we suggest the undeveloped space between the development and U.S. 70
could be used for bioretention areas or buildings. Additional recommended LID techniques
include narrower roads, swales versus curbs/gutters, and permeable surfaces such as permeable
pavement, 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
(hltp://www.ncwildlife.org/Conserving/Programs/GreenGrowthToglbox.aspx).
4. We recommend a minimum 100 -foot undisturbed buffer for perennial streams and a 50 -foot
undisturbed buffer for intermittent streams and wetlands.
5. Due to the decline in bat populations, trees should not be removed during the maternity roosting
season for bats (May 15 — August 15).
6. Incorporate the following elements into erosion and sediment control plans: minimize clearing
and grading, protect waterways, phase construction for larger construction sites (>25 acres),
stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish appropriate
perimeter controls, employ advanced settling devices, implement a certified contractors program,
and regularly inspect erosion control measures.
7. Disturbed areas should be reseeded with native seed mixtures that are beneficial to wildlife. The
applicant should consider planting native, wildflower seed mixes and plants that will create
pollinator habitat. Avoid using invasive, non-native plants in seed mixtures or landscaping
plants. Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-native
species, should not be used and these species provide little benefit to wildlife. A list of non-
native plants can be found at (http://www.ncwildflower.org//plant_galleries/invasives_list). In
lieu of lawn or grassy areas, we recommend planting native pollinator species or other native
vegetation.
8. Sediment and erosion control measures should be installed prior to any land clearing or
construction. 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

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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.
The NCWRC encourages the applicant to consider additional measures to protect 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 details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
http://www.ncwildlife.org/portals/O/Conserving/documents/2002 GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002).
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or olivia.munzerkncwildlife.org.
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.
Available at: https:Howl.cwp.org/mdocs-posts/roseen-et-al-2011-forging-the-link/.
ec: Sue Homewood, NCDWR
John Ellis, U.S. Fish and Wildlife Service
Brena Jones, NCWRC
David Bailey, USACE