20171559 Ver 3_More Info Received_response to WRC comments_20210927

hdrinc.com
September 27, 2021
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
ATTN: Ms. Sue Homewood
SUBJECT: Individual Permit Application Public Notice Comments Received on
September 24, 2021
Greensboro Randolph Megasite and Associated Infrastructure
Randolph County, North Carolina
Ms. Homewood:
The Greensboro -Randolph Megasite Foundation, Inc. (GRMF) is providing responses to
comments received from the Division of Water Resources on September 24, 2021
following the public notice for individual permit application and supporting documentation
for development of the proposed Greensboro -Randolph Megasite (the "Proposed Project"
or "Project GRMS"), located in northern Randolph County, North Carolina. Below you will
find the comments from Wildlife Resources Commission followed by the GRMF's response
in italics.
Overall Project:
1. We recommend surveys for state -listed mussel and crayfish species to determine if
relocations are needed. Please contact Brena Jones, the Central Aquatic Wildlife
Diversity Research Coordinator, at 919-707-0369 or brena.jonest ncwildlife.orq.
Contact with Brena Jones will be made prior to construction of the components of
the project. Please note most of the stream reaches within the site experience
intermittent flow for portions of the year.
2. We highly recommend avoiding impacts to the tributary complex (S21 and its UTs)
in the eastern portion of the project. It is the only stream complex in the project
area not flowing into Dobson Lake, which is a man-made lake that already impedes
aquatic movements.
Noted. S21 and its tributaries exhibit periods of low or no flow regularly throughout
the season. Please note during the Cape Fear shiner survey, completed by RK&K,
S21 (Pages 216-217 of the Supporting Documentation) state this stream was
completely dry at the AL-4 location and had minimal water at AL-2. Please also
see page 218 of the supporting information which states the following "While these
stream conditions may not be common throughout the year, streams experiencing
555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
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these conditions tend to support a more limited aquatic fauna than streams not
subjected to such low flow conditions."
3. A large portion of the project is used for surface parking. We recommend building a
parking deck or underground parking rather than impacting the streams for surface
parking. For any surface parking or roads, we recommend using bioretention cell in
parking lot medians, for example, that can collect stormwater from the building and
parking area. Additional information can be found at the NC State University's
guide:
http://www.onsiteconsortium.orq/npsdeal/NC LID Guidebook.pdf.
Noted. The conceptual stormwater plan has been developed. Final stormwater
plans will consider these options as well as others in the NC LID Guidebook.
4. The applicant should avoid the removal of large trees. Due to the decline in many
tree -roosting bat populations, trees should not be removed during the maternity
roosting season for bats (May 15 — August 15).
Noted. A large portion of the site has been previously timbered. This will be taken
into consideration for the remaining areas.
5. We recommend a minimum 100-foot undisturbed buffer for perennial streams and
a 50-foot undisturbed buffer for intermittent streams and wetlands.
Noted.
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. Ensure all silt fencing is removed once vegetation has
reestablished and soils have stabilized.
Noted. The project will adhere to the NCDEQ NPDES Construction Stormwater
requirements and the NCGO1 General Construction Permit.
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, which would also improve the
aesthetics of the project and within rights -of -way. 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. In lieu of lawn or grassy
areas, we recommend planting native pollinator species or other native vegetation.

Avoid using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.orq/plant galleries/invasives list).
Noted.
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 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.
Noted. Sediment and erosion control devices will be monitored/maintained
regularly throughout the project construction and removed following
construction/stabilization.
Utility Lines:
9. To reduce impacts to streams, we recommend the sewer/water line run from
Liberty Road portion as seen in Alternative 1 and then use Alternative 2 route
along Steeple Chase Road.
The City of Greensboro has a Capital Improvements Program (CIP) project that
takes water and sewer service approximately 2 miles from the project. This
alternative has fewer impacts than the Alternative 2 route noted above and is the
preferred alignment as it can tie to the CIP Southeast Feeder Main and Liberty
Road Sewer Force Main project.
10. The directional bore stream crossing method should be used for utility crossings
rather than opencut stream crossing method to prevent the likelihood of future
lateral movement of the stream, causing undercutting or erosion around the utility
line. The open -cut stream crossing method should only be used when water level
is low and stream flow is minimal.
Noted. The City of Greensboro evaluates utilizing directional bores during their
design and incorporate it when feasible.
11. Sewer lines, water lines, and other utility infrastructure should be kept out of
riparian buffer areas. Manholes or similar access structures should not be allowed

within buffer areas. Stream crossings should be near perpendicular (75o to 1050)
to stream flow.
Noted.
12. Clearing of the rights -of -way should be avoided during the migratory bird nesting
season, roughly March to August.
Noted.
Transportation:
13. The culvert must be designed to allow for aquatic life and fish passage. Generally,
the culvert or pipe invert should be buried at least 1 foot below the natural
streambed (measured from the natural thalweg depth). If multiple barrels are
required, barrels other than the base flow barrel(s) should be placed on or near
stream bankfull or floodplain bench elevation (similar to Lyonsfield design). These
should be reconnected to floodplain benches as appropriate. This may be
accomplished by utilizing sills on the upstream and downstream ends to restrict or
divert flow to the base flow barrel(s). Silled barrels should be filled with sediment so
as not to entrap wildlife or support mosquito breeding conditions. Sufficient water
depth should be provided in the base flow barrel(s) during low flows to
accommodate fish movement. If culverts are longer than 40-50 linear feet,
alternating or notched baffles should be installed in a manner that mimics existing
stream pattern. This should enhance aquatic life passage: 1) by depositing
sediments in the barrel, 2) by maintaining channel depth and flow regimes, and 3)
by providing resting places for fish and other aquatic organisms. In essence, base
flow barrel(s) should provide a continuum of water depth and channel width without
substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to
remain dry during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment
whenever possible to avoid channel realignment. Widening the stream channel
must be avoided. Stream channel widening at the inlet or outlet end of structures
typically decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the
streambed in a manner that precludes aquatic life passage. Bioengineering
boulders or structures should be professionally designed, sized, and installed.
These items will be incorporated into the NCDOT design unless there is an existing
pipe, culvert, or bridge which would dictate a different design.

14. 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/0/Conserving/documents/2002 GuidanceMemora
ndumforSecondaryandCumulativelmpacts.pdf (August 2002).
Noted.
The Applicant looks forward to working with the DWR on completing the permitting
process and issuance of a 401 Water Quality Certification for the GRMS project. Please
call me at 919-232-6637 or email at [e-mail] if you need additional
information or clarification on any of the information provided.
Sincerely,
HDR Engineering Inc. of the Carolinas
Vick0,JA(l(cv
Vickie Miller, AICP, PWS
Senior Environmental Planner
cc: Jim Melvin, Greensboro Randolph Megasite Foundation
Wendee Smith, S2 Consulting