20211406 Ver 1_More Info Received_20211209

Kimley>»Horn
December 9, 2021
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: REQUEST FOR ADDITIONAL INFORMATION
DWR #2021-1406 (USACE SAW-2021-00535)
NC Development Acquisition, LLC — Troutman Logistics Center
Iredell County, North Carolina
Dear Mr. Wojoski,
On behalf of our client, North Carolina Development Acquisition, LLC, Kimley-Horn (KH) is submitting
the response to the Request for Additional Information for the above -referenced Project per the NC
Division of Water Resources (NCDWR) request received on November 9, 2021.
Below is an outline of NCDWR's requested additional information with a brief narrative addressing each
item. The NCDWR requested additional information with Kimley-Horn response and explanation are
as follows:
Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon
determining that the proposed activity will comply with state water quality standards which includes
designated uses, numeric criteria, narrative criteria and the state's antidegradation policy, as defined
in rules of 15A NCAC 02B .0200... In assessing whether the proposed activity will comply with water
quality standards, the Division shall evaluate if the proposed activity: (1) has avoided and minimized
impacts to surface waters and wetlands..." As this project is speculative with a stated purpose as
"to provide warehousing and supply -chain distribution space to service the Charlotte MSA", please
provide a detailed justification for the sizes of the proposed buildings and the specific need for the
amount of parking proposed. It appears that the site could be re -designed to further avoid and
minimize stream and/or wetland impacts and still meet the stated purpose.
Due to recent changes in consumer spending habits, population growth and supply chain
constraints, the Charlotte regional industrial real estate market is experiencing tremendous growth.
To accommodate forthese changes, several factors are taking place within the region. The average
size of industrial buildings has tripled since 2019, which has pushed development outside of the
core industrial market and into the outlying surrounding counties due to additional land being needed
for the larger facilities. However, these facilities still need to be located within proximity to the
growing population areas and within 1-2 miles from a major interstate.
Furthermore, there are over 22.5M square feet of tenant demand within the Charlotte market
representing over 50 companies. 18% of this demand represents tenants seeking facilities of 1 M
SF and greater. As of Q4 2021, there are only five buildings, within the region, planned for 1 M SF
or greater. As of the date of this submittal, there are 11 current requests in the Charlotte area market
for buildings of 1 M SF or greater.

Kimley>»Horn
Please see the attached modified site plan for reference. While it is possible to build a warehouse
on this property with fewer stream impacts, the smaller buildings do not fulfill the highest and best
use of the property. Due to its proximity to 1-77, this site needs to be utilized for Build to Suit
distribution or 1 M+ SF users. The number of available sites for buildings of this size is rare in this
market and demand currently exceeds supply. Due to the absence of wetlands on this property,
this site lends itself even more to larger products while minimizing environmental impacts.
From a financial standpoint, the larger buildings are necessary to make the site financially viable
due to a large amount of wall required to minimize stream impact, the volume of earthwork, and the
cost of offsite improvements.
2. Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon
determining that the proposed activity will comply with state water quality standards which includes
designated uses, numeric criteria, narrative criteria and the state's antidegradation policy, as defined
in rules of 15A NCA C 02B .0200... In assessing whether the proposed activity will comply with water
quality standards, the Division shall evaluate if the proposed activity: (2) would cause or contribute
to a violation of water quality standards; (3) would result in secondary or cumulative impacts that
cause or contribute to, or will cause or contribute to, a violation of water quality standards;" Based
on the information provided in the application the Division has the following concerns:
a. Along the eastern boundary of the project site a small segment of Stream 2 and Stream
6 will be indirectly affected by becoming disconnected, and essentially isolated, from
all other natural features. This small, disconnected portion of Stream 2 and Stream 6
are unlikely to continue to provide the same hydrologic and biological function and
therefore should be counted as indirect "loss of water". Please revise the application,
plan sheets, and impact tables accordingly.
Please find the attached revised application, plan sheets, and impact tables indicating
an indirect "loss of water' for Streams 2 & 6.
b. All surface flow from the project is proposed to be rerouted through multiple stormwater
wet detention basins. In order to review possible secondary impacts to downstream
hydrology, please provide plans that clearly show the outlet location from each
stormwater control measure. Please note that the rerouting of any drainage area and
surface flow has the potential to remove existing hydrology from features adjacent to
this project and therefore remove existing uses of the stream channels or wetlands.
Based on the location of the proposed stormwater basins, it appears that the lower
portion of stream 3 and stream 1 will have a significantly reduced hydrology.
To continue contributing hydrology to the lower portion of Stream 3, the applicant will
direct 2-acres of greenspace runoff from the northwestern portion of the site to the
beginning of Stream 3.
The southern portion of Stream 1 will continue to receive flow from 4-acres west of the
stream and 30-acres from the parcel directly south of the proposed development.
The Stormwater Management Plan will be prepared after completion of annexation into
the Town of Troutman and the associated rezoning to Industrial. This hearing date is
scheduled for December 9, 2021. The plan which will include detailed plans
demonstrating the outlet locations at each stormwater control measure will be

Kimley>»Horn
Page 3
submitted upon completion. We are currently targeting a March 31, 2022 submittal
date.
3. Please submit a complete Stormwater Management Plan for the project which shall include all
appropriate supplemental forms, O&M agreements, calculations, engineering drawings, etc., that
complies with the requirements of the State Stormwater Program. The Stormwater Design Manual
and applicable forms may be found on the DEMLR's website at
https://deq. nc. gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permit-
guidance/stormwater-bmp-manual. In addition, please also submit the application form SWU-101
(attached). However, the $505 application fee and last two signature pages of this form may be
omitted. (15A NCAC 02H .0506(b) (2) and (3)]
The Stormwater Management Plan will be prepared after completion of annexation into the Town of
Troutman and the associated rezoning to Industrial. This hearing date is scheduled for December
9, 2021. This plan will be submitted upon completion. We are currently targeting a March 31, 2022
submittal date.
Please feel free to contact me at [phone] if you have any questions or if additional information
is necessary.
Sincerely,
KIMLEY-HORN AND ASSOCIATES, INC.
Chris Tinklenberg, PWS
Environmental Scientist
Attachments
Cc: Dominic Reinicker, NC Development Acquisition, LLC
Matt Prince, NC Development Acquisition, LLC
Austin Watts, Kimley-Horn

U.S. Army Corps of Engineers (USACE)
Form Approved -
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT
OMB No. 0710-0003
33 CFR 325. The proponent agency is CECW-CO-R.
Expires: 02-28-2022
The public reporting burden for this collection of information, OMB Control Number 0710-0003, is estimated to average 11 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding the burden estimate or burden reduction suggestions to the Department of Defense, Washington Headquarters Services,
at whs.mc-alex.esd.mbx.dd-dod-information-collections(a)mail.mil. Respondents should be aware that notwithstanding any other provision of law, no person shall
be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number. PLEASE DO NOT
RETURN YOUR APPLICATION TO THE ABOVE EMAIL.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection, Research, and Sanctuaries Act,
Section 103, 33 USC 1413; Regulatory Programs of the Corps of Engineers; Final Rule 33 CFR 320-332. Principal Purpose: Information provided on this form
will be used in evaluating the application for a permit. Routine Uses: This information may be shared with the Department of Justice and other federal, state, and
local government agencies, and the public and may be made available as part of a public notice as required by Federal law. Submission of requested information
is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit be issued. One set of original drawings or good
reproducible copies which show the location and character of the proposed activity must be attached to this application (see sample drawings and/or instructions)
and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application that is not completed in full will be returned.
System of Record Notice (SORN). The information received is entered into our permit tracking database and a SORN has been completed (SORN #A1145b)
and may be accessed at the following website: http://dpcld.defense.gov/Privacy/SORNslndex/DOD-wide-SORN-Article-View/Article/570115/a1145b-ce.aspxx
(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)
1. APPLICATION NO.
2. FIELD OFFICE CODE
3. DATE RECEIVED
4. DATE APPLICATION COMPLETE
(ITEMS BELOW TO BE FILLED BY APPLICANT)
5. APPLICANT'S NAME
8. AUTHORIZED AGENT'S NAME AND TITLE (agent is not required)
First - Matt Middle - Last - Prince
First - Chris Middle - Last - Tinklenberg
Company - NC Development Acquisition, LLC
Company - Kimley-Horn & Associates, Inc.
E-mail Address-inprince((ttpa-grp.com
E-mail Address -Chris.Tinklenberg(a,kimley-horn.com
6. APPLICANT'S ADDRESS:
9. AGENT'S ADDRESS:
Address- 1776 Peachtree Street, NW, Suite 100
Address- 200 South Tryon Street, Suite 200
City - Atlanta State - GA Zip - 30309 Country -USA
City - Charlotte State - NC Zip - 28202 Country -USA
7. APPLICANT'S PHONE NOs. w/AREA CODE
10. AGENTS PHONE NOs. w/AREA CODE
a. Residence b. Business c. Fax
a. Residence b. Business c. Fax
770-4361791
704-409-1802
STATEMENT OF AUTHORIZATION
11. 1 hereby authorize, Kimley-Horn & Associates, Inc. to act in my behalf as my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this permit application.
2021-12-09
SIGNATURE OF APPLICANT DATE
NAME, LOCATION, AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE (see instructions)
Troutman Logistics Center
13. NAME OF WATERBODY, IF KNOWN (if applicable)
14. PROJECT STREET ADDRESS (if applicable)
I-L Creek
Address NW corner of I-77 and Ostwalt Amity Road
15. LOCATION OF PROJECT
City - Troutman State- NC Zip- 28166
Latitude: -N 35.689908 Longitude: -W-80.861081
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions)
State Tax Parcel ID Multiple Municipality
Section - Township - Range -
ENG FORM 4345, FEB 2019 PREVIOUS EDITIONS ARE OBSOLETE. Page 1 of 3

17. DIRECTIONS TO THE SITE
From Statesville, head south on I-77 for approximately 6.5-miles then take Exit 42 for US-21/State Hwy 115, towards Troutman. Turn left
onto US-21 N/ State Hwy 115 N. Continue for 0.6-miles and turn right onto Ostwalt Amity Road, continue for another 0.6-miles and turn left
onto Perry Road. Continue for 0.3-miles and the Site is on the left.
18. Nature of Activity (Description of project, include all features)
See attached.
19. Project Purpose (Describe the reason or purpose of the project, see instructions)
See attached.
USE BLOCKS 20-23 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
The proposed project includes the construction of two (2) distribution center warehouses, as well as associated access roads, parking, utilities,
and stormwater management facilities. Due to the size of the warehouse buildings, the location and layout of these facilities were limited to
areas within the property where larger development clusters could be created. Areas were chosen that maximize the use of uplands
and minimize impacts to streams to the greatest extent practicable.
21. Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards:
Type Type Type
Amount in Cubic Yards Amount in Cubic Yards Amount in Cubic Yards
Structural Fill/Earthen Material - 300,000 cy
22. Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
Acres
or
Linear Feet 2,236 (Streams - includes 241 indirect loss of waters)
23. Description of Avoidance, Minimization, and Compensation (see instructions)
See attached.
ENG FORM 4345, FEB 2019 Page 2 of 3

24. Is Any Portion of the Work Already Complete? Yes ®No IF YES, DESCRIBE THE COMPLETED WORK
25. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (if more than can be entered here, please attach a supplemental list).
a. Address- 121 Ostwalt Amity Road
City - Troutman State - NC Zip - 28166
b. Address- 103 Ostwalt Amity Road
City - Troutman State - NC Zip - 28166
c. Address- 168 Levo Drive
City - Troutman State - NC Zip - 28166
d. Address -
City - State - Zip -
e. Address -
City - State - Zip -
26. List of Other Certificates or Approvals/Denials received from other Federal, State, or Local Agencies for Work Described in This Application.
AGENCY TYPE APPROVAL' IDENTIFICATION DATE APPLIED DATE APPROVED DATE DENIED
NUMBER
Would include but is not restricted to zoning, building, and flood plain permits
27. Application is hereby made for permit or permItsto authorize the work described in this application. I certify that this information in this application is
complete and accurate. I further certifythat I possess the authority to undertake the work described herein or am acting as the duly authorized agent of the
applicant.
2021-12-09 mac.-- — 7 2021-12-09
SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE
The Application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or fraudulent
statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or fraudulent
statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
ENG FORM 4345, FEB 2019 Page 3 of 3

Troutman Logistics Center
SECTION 404 INDIVIDUAL PERMIT APPLICATION
SEPTEMBER 2021
(Revised December2021)
Applicant: NC Development Acquisition, LLC,
a North Carolina limited liability company
Agent: Kimley-Horn and Associates, Inc.
Engineer: Kimley-Horn and Associates, Inc.
Kimley»>Horn

Table of Contents
Table of Contents
1.0 INTRODUCTION...................................................................................................................1
2.0 BACKGROUND....................................................................................................................1
3.0 PROJECT PURPOSE & NEED............................................................................................2
4.0 EXISTING CONDITIONS......................................................................................................2
5.0 PROPOSED PROJECT & DEVELOPMENT PLAN..............................................................2
6.0 ALTERNATIVES ANALYSIS................................................................................................3
6.1 No Action Alternative......................................................................................................3
6.2 Off -Site Alternatives........................................................................................................4
6.2.1 Applicant's Preferred Site........................................................................................4
6.2.2 Off -Site Alternative 1.................................................................................................5
6.2.3 Off -Site Alternative 2.................................................................................................5
6.2.4 Off -Site Alternative 3.................................................................................................6
6.2.5 Off -Site Alternative 4.................................................................................................6
6.2.6 Off -Site Alternative 5.................................................................................................7
6.3 On -Site Configurations...................................................................................................7
6.3.1 On -Site Configuration 1............................................................................................7
6.3.2 On -Site Configuration 2............................................................................................7
6.3.3 On -Site Configuration 3 (Applicant's Preferred).....................................................8
6.4 Alternatives Not Practicable or Reasonable..................................................................8
6.5 Review of Practicable Alternatives...............................................................................10
6.5.1 Proposed Action or Applicant's Preferred Alternative/On-Site Configuration 3
10
6.5.2 Alternative Site#2...................................................................................................11
6.5.3 On -Site Configuration #1........................................................................................12
6.5.4 On -Site Configuration#2........................................................................................12
6.6 Summary of Alternatives Analysis...............................................................................13
7.0 THREATENED & ENDANGERED SPECIES......................................................................15
8.0 CULTURAL RESOURCES.................................................................................................15
9.0 STORMWATER MANAGEMENT.......................................................................................16
10.0 COMPENSATORY MITIGATION......................................................................................16
11.0 CONCLUSION..................................................................................................................16
Kimley»>Horn

EVISTSaffilln,
A: Figures/Site Maps
B: USACE Jurisdictional Determination
C: Permit Drawings (Applicant's Preferred Alternative)
D: Off -Site Alternatives Information
E: On -Site Configurations
F: Compensatory Mitigation
G: USFWS Survey Report
H: NCSHPO HPOWeb Public Database Information
Kimley»>Horn

NCDA — Troutman Logistics Park
September 2021
1.0 INTRODUCTION
NC Development Acquisition, LLC, a North Carolina limited liability company, is proposing the
construction of a multi -building logistics park in Iredell County, North Carolina. The project area
totals approximately 157 acres located at the NW corner of I-77 and Ostwalt Amity Road in the
town of Troutman, Iredell County, NC (35.689908°,-80.8610810). The project is located
approximately 1.5 miles from I-77, 12 miles from I-40, and 11 miles from the Charlotte Douglas
International Airport (CLT). The proposed project will include two distribution center warehouses,
totaling 1,700,000 square feet (SF). Associated access roads, parking, utilities, and stormwater
management facilities are also proposed as a part of this development. The project proposes
impacts to 1,995 linear feet (LF) of jurisdictional streams.
2.0 BACKGROUND
The south/southeast United States demands around 32% of the national need for new industrial,
warehouse, and distribution center space, which translates into approximately 80 million SF of
traditional demand and approximately 160 million SF of projected demand (Meyer, Craig S.,
Jones Lang, and Lasalle, 2020 Industrial Demand Study, September 2020). This growth may
accelerate even more in the south and southeast, which leads the nation in population growth
(Census.gov; ncdemography.org). Charlotte, for example, has seen its total industrial,
warehouse, and distribution space demands more than double in the past 5 years (Jones Lang
and LaSalle, Charlotte Industrial Market Report, Q2 2020). Where demand was approximately
8-9 million SF in 2019, it is anticipated to grow to 16-18 million SF annually over the next decade
(CBRE, Industrial & Logistics Insights Panel, "Impact of Covid-19 on Future Industrial
Demand", May 28, 2020, Breeze, James; Meyer, Craig S., Jones Lang, and Lasalle, 2020
Industrial Demand Study, September 2020). The problem is that the supply of products is not
keeping up with the projected demand, particularly within the Charlotte region.
Currently, the Charlotte warehouse market is sitting just above a 6% vacancy rate (Cushman &
Wakefield, US Industrial Report, Q2 2021). For functional space that can accommodate current
material handling equipment, the vacancy rate is lower, closer to 2% (Cushman & Wakefield,
Industrial Insights - Charlotte, NC, Q1 2020). For new projects that are either under
construction or are planned, the total anticipated new inventory is less than 10 million SF in the
Charlotte market (Jones Lang and Lasalle, Charlotte Industrial Market Report, Q3 2020). This
means that there will not be enough supply to accommodate demand over the next 12 months.
There is increasing concern that supply cannot meet demand over the next 2 years, much less
the next decade. Additionally, there is a shortage of industrial sites in Mecklenburg County which
is pushing development into surrounding counties. The proximity to Interstate 77 has made
developers more and more interested in Iredell County, Troutman specifically (Distribution
Dynamo, Charlotte Business Journal, August 20, 2021).
Kimley>»Horn

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Considering the projected needs for the Charlotte Metropolitan Statistical Area (MSA) industrial
market, the applicant determined that Iredell County —and more specifically Troutman —was the
most appropriate project location for the following reasons:
• Location within the 1-77 corridor;
• Proximity to a major interchange for access to a major highway/interstate in the Charlotte
MSA;
• Iredell County provides a large supply of qualified labor pool;
• Availability of large tracts of land.
For Iredell County, the proposed logistics park project will create approximately 2,000-3,100
direct jobs with an estimated annual payroll of around $97M—$162M. Annual real property taxes
are projected to be roughly $1.8M at build -out of the park, and an anticipated additional +/-$1.OM
of personal property taxes associated with furniture, fixture, and equipment in the building. The
project will provide greater economic mobility for citizens in Iredell County and will stimulate
economic growth, which is desperately needed given the catastrophic economic impacts from the
COVID-19 pandemic. The project not only will result in significant long-term benefits to the
adjacent communities of Troutman but will also benefit the rural areas of Iredell County and the
metropolitan areas of Charlotte.
3.0 PROJECT PURPOSE & NEED
Generally, the project's purpose is to provide warehousing and supply -chain distribution space to
service the Charlotte MSA. Specifically, the purpose of the proposed project is to construct a
multi -building industrial logistics park within the 1-77 corridor of the Charlotte MSA for connection
to 1-85, 1-40, and CLT airport, providing eCommerce and traditional brick and mortar support
warehousing and supply -chain distribution space to optimize the efficiency of their distribution
network in the region, meeting current and future demands. While this project —with
approximately 1.7 million SF represents approximately 5 percent of the projected 2-year market
need —the proposed logistics centerwill assistwith maintaining a healthy regional market required
to support the continued growth of the Charlotte MSA.
4.0 EXISTING CONDITIONS
The project site totals 157 acres and consists of undeveloped forested land and an open field. An
aquatic resources delineation was completed within the project site and was verified by the U.S.
Army Corps of Engineers (USACE) on March 22, 2021. The project area contains 6,863 LF of
streams, no wetlands, and no open waters. A vegetation community consisting of predominately
American beech (Fagus grandifolia), willow oak (Quercus phellos), sweetgum (Liquidambar
styraciflua), red maple (Acer rubrum), loblolly pine (Pinus taeda), and (Quercus albs) covers the
majority of the site.
5.0 PROPOSED PROJECT & DEVELOPMENT PLAN
The proposed project includes the construction of access roads, parking, utilities, and stormwater
management facilities. The proposed project seeks to construct two (2) distribution warehouse
buildings, totaling 1,700,000 SF. Trailer and employee parking are required. While the stormwater
plan has not been finalized, it is anticipated that three or four ponds will be required to satisfy the
stormwater management needs of the site and are strategically positioned within the western
portion of the site where the construction of warehouse facilities is not feasible without additional
stream impacts. Permit drawings depicting the proposed project are included in Appendix C.
Due to the size of the warehouse buildings and the north/south orientation of the project site, the
location and layout of the facilities were limited to the eastern portion of the property where a
larger, contiguous development cluster could be created. The applicant chose the eastern portion
Kimley»>Horn

3
of the property to maximize the use of uplands and minimize impacts to streams to the greatest
extent practicable. As shown in the attached permit drawings, the proposed site plan requires
impacts to aquatic resources totaling 1,995 LF of stream. An additional 241 LF of stream is
assumed to be indirectly affected by the downstream development, resulting in an indirect loss of
waters. In total, the project will result in 2,236 LF of stream impacts. The applicant has been in
coordination with the owner of an approximately 10-acre parcel, located between the project site
and Perry Road, to establish a purchase agreement for this property; however, the sale of the
property is not feasible at this time due to continuing legal issues.
6.0 ALTERNATIVES ANALYSIS
As part of the overall project, the applicant completed a thorough alternatives analysis. A review
of the 404(b)(1) guidelines indicates that "(a) Except as provided under section 404(b)(2), no
discharge of dredged or fill material shall be permitted if there is a practicable alternative to the
proposed discharge which would have less adverse impact on the aquatic ecosystem, so long as
the alternative does not have other significant adverse environmental consequences." The
guidelines define practicable alternatives as "(q) The term practicable means available and
capable of being constructed after taking into consideration cost, existing technology, and logistics
in light of overall project purposes."
The guidelines outline further consideration of practicable alternatives: "(1) For the purpose of this
requirement, practicable alternatives include, but are not limited to: (i) Activities which do not
involve a discharge of dredged or fill material into the waters of the United States or ocean waters;
(ii) Discharges of dredged or fill material at other locations in waters of the United States or ocean
waters; (2) An alternative is practicable if it is available and capable of being constructed after
taking into consideration cost, existing technology, and logistics in light of overall project
purposes. If it is otherwise a practicable alternative, an area not presently owned by the applicant
which could reasonably be obtained, utilized, expanded, or managed to fulfill the basic purpose
of the proposed activity may be considered."
Considering the guidelines above and having identified Iredell County as the most advantageous
location for the proposed industrial park, the applicant evaluated a No Action Alternative and six
alternative sites including the applicant's preferred site. In addition, three on -site configurations
were evaluated including the applicant's preferred on -site configuration. As noted above, the
permit drawings depicting the proposed site plan are provided in Appendix C. Mapping information
for off -site alternatives is provided in Appendix D and on -site configuration alternatives are
provided in Appendix E. As part of this alternative evaluation, the following
"Practicability/Reasonability Screening Selection Criteria" were applied to each alternative to
confirm whether the particular alternative and/or on -site configuration was practicable:
• Capable of being constructed considering cost (Is the cost reasonable considering scope
and type of project considering total cost, funding source, profit margin, etc.)
• Capable of being constructed considering logistics (Must consider existing infrastructure,
traffic patterns, etc.)
• Property can be reasonably obtained (Must consider availability, liens, etc.)
• Proximity to workforce
• Meets basic project purpose
• Meets overall project purpose
6.1 No Action Alternative
A "no action" alternative must be considered, and complete avoidance of aquatic resources was
the first alternative considered for this project. Due to the location of aquatic resources and
Kimley»>Horn

rd
proposed land use (industrial warehousing), it was determined that complete avoidance of stream
impacts was not feasible. Unlike many development activities (i.e., residential, recreational, or
light commercial), little flexibility in warehouse design is afforded. Industry standards dictate
building widths and lengths; and access, parking, and docking requirements associated with semi-
trailer truck traffic greatly limit design flexibility. For these reasons, major modifications to the
facility footprint beyond a reduction in square footage to the minimum square feet are not feasible.
While this option would result in no impacts to jurisdictional features, it would not fulfill the need
for warehousing distribution space in the Charlotte MSA. Because the "no action" alternative and
complete avoidance of impacts prohibits the construction of the proposed logistics park, this
alternative was determined to be unreasonable and not practicable.
6.2 Off -Site Alternatives
In addition to the six general Practicability/ Reasonability Screening Selection Criteria evaluated,
specific criteria including geographic location, size, zoning, utilities, access, and availability were
considered. The following provides a summary of each criterion.
• Size — The potential site must be 150 acres or more to accommodate the required
minimum size of the development.
• Geographic Location — The proposed project will provide warehousing and logistics
services to the Charlotte MSA. Sites considered for this project were limited to the 1-77
corridor with connectivity to 1-40 and 1-85. Additionally, potential sites within the Lake
Norman Water Supply Watershed (WSW) area were excluded to avoid high -density
development within the environmentally sensitive watershed.
• Land Use/Zoning — Land use restrictions associated with current zoning are a major
consideration in all industrial projects. Truck traffic, equipment operation, adjoining land
use, buffers, etc. make the location of the project and the current zoning a critical
component. Forthis site screening criterion, tracts that are currently zoned forthe intended
use or that could be reasonably re -zoned to accommodate the proposed project were
considered.
• Utilities — Utility services or access to utility services (water, sewer, electrical, gas,
phone, cable, etc.) are required. For this reason, the location of existing utilities and the
cost associated with servicing the project site if those utilities were not already available
was a consideration in the site screening criteria.
• Availability — Sites listed for sale and/or known to be available for purchase were
considered.
Access — Access to a warehousing and distribution facility requires the continual
operation of large semi -trailer trucks. For this project, three access criteria were
established. First, the site must provide suitable access to a major interstate. Suitable
access to a major interstate would be defined as direct access to the site from a paved
road suitable to support truck traffic associated with the proposed facility. Second, the site
must be located adjacent to or within two miles of an interstate interchange. For this
project, alternative sites, except for one, were limited to major interchanges within the
Interstate 77 corridor. Third, the site must allow for truck access that avoids at -grade rail
crossings and/or minimizes at -grade rail crossing relocations.
6.2.1 Applicant's Preferred Site
The applicant's preferred alternative totals 157 acres located at the NW corner of 1-77 and Ostwalt
Amity Road in Iredell County. The following provides a summary of each criterion reviewed for
the applicant's preferred site:
Kimley»>Horn

5
• General Screening Criteria: This alternative is capable of being constructed when
considering cost and logistics, the property can be reasonably obtained and the project
site meets the basic and overall project purpose.
• Size: The site totals approximately 157 acres which meets the size criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated immediately
adjacent to I-77, and is located outside of the Lake Norman WSW, which meets the
minimum criteria for the project.
• Land Use/Zoning: The site is not currently zoned for the proposed use, however,
rezoning of the property has been petitioned and, according to the Town of Troutman, the
rezoning petition is anticipated to be accepted.
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is currently listed for sale and can be purchased.
• Access: The site is surrounded by paved roads, is less than 2 miles to an I-77
interchange, and affords truck access that avoids at -grade rail crossings.
In summary, the applicant's preferred site meets all the site screening criteria and is therefore a
practicable alternative.
6.2.2 Off -Site Alternative 1
This tract totals approximately 271.2 acres and is located east of 1-77. The following provides a
summary of each criterion reviewed for the applicant's preferred site:
• General Screening Criteria: The property can be reasonably obtained, and the project
site meets the basic and overall project purpose; however, due to the presence of
overhead power lines, the 700,000 SF building cannot be constructed. This alternative is
not capable of being constructed when considering cost and logistics.
• Size: The site totals 271.2 acres which does meet the minimum criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated immediately
adjacent to 1-77, and is located outside of the Lake Norman WSW, which does meet the
minimum criteria for the project.
• Land Use/Zoning: The site is not currently zoned for the proposed use, however,
rezoning of the property is assumed to be feasible.
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is not for sale and cannot be purchased.
• Access: The site is surrounded by paved roads, is less than 2 miles to an 1-77
interchange, and affords truck access that avoids at -grade rail crossings.
In summary, Off -Site Alternative 1 does not meet all the site screening criteria and is therefore
not a practicable alternative.
6.2.3 Off -Site Alternative 2
This tract totals approximately 389 acres and is located west of 1-77. The following provides a
summary of each criterion reviewed for the applicant's preferred site:
• General Screening Criteria: This alternative is capable of being constructed when
considering cost and logistics; the property can be reasonably obtained and the project
site meets the basic and overall project purpose.
• Size: The site totals 389 acres which does meet the minimum criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated west of 1-77, and
is located outside of the Lake Norman WSW, which does meet the minimum criteria for
the project.
Kimley»>Horn

M
• Land Use/Zoning: The site is not currently zoned for the proposed use. Rezoning of the
site is assumed unfeasible due to the current residential zoning designation, proximity to
the Barium Springs Home for Children, and the proximity to residential developments to
the north and south.
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is currently listed for sale and can be purchased.
• Access: The site is surrounded by paved roads and is more than 2 miles to an 1-77
interchange. Truck access avoids at -grade rail crossings.
In summary, Off -Site Alternative 2 does not meet all the site screening criteria and is, therefore,
is not a practicable alternative.
6.2.4 Off -Site Alternative 3
This tract totals approximately 192 acres and is located along Gilbert Road immediately south of
I-40. The following provides a summary of each criterion reviewed for the applicant's preferred
site:
• General Screening Criteria: The property can be reasonably obtained, and the project
site meets the basic and overall project purpose; however, based on the geographic
configuration of the property, the 700,000 SF building does not fit within the property
boundary. This alternative is not capable of being constructed when considering cost and
logistics.
• Size: The site totals 192 acres which does meet the minimum criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated south of I-40, in
proximity to the I-77 corridor, and is located outside of the Lake Norman WSW, which
does meet the minimum criteria for the project.
• Land Use/Zoning: The site is not currently zoned for the proposed use. Rezoning of the
site is assumed unfeasible due to the current residential zoning designation and the
proximity to residential developments to the south and east.
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is not for sale and cannot be purchased
• Access: Construction of access roads would be required. The site is less than 2 miles to
an I-40 interchange but is greater than 2 miles to an I-77 interchange. Truck access avoids
at -grade rail crossings.
In summary, Off -Site Alternative 3 does not meet all the site screening criteria and is therefore
not a practicable alternative.
6.2.5 Off -Site Alternative 4
This tract totals approximately 336 acres and is situated at the northeastern corner of I-77 and I-
40. The following provides a summary of each criterion reviewed for the applicant's preferred site:
• General Screening Criteria: This alternative is capable of being constructed when
considering cost and logistics; the property can be reasonably obtained and the project
site meets the basic and overall project purpose.
• Size: The site totals 336 acres which does meet the minimum criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated at the NE corner
of 1-77 and 1-40, and is located outside of the Lake Norman WSW, which does meet the
minimum criteria for the project.
• Land Use/Zoning: The site is not currently zoned for the proposed use, however,
rezoning of the property is assumed to be feasible.
Kimley»>Horn

7
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is listed for sale; however, it is currently under contract and cannot
be purchased.
• Access: The site has very poor access from a logistics perspective given the proximity to
1-40 and 1-77. The site is surrounded by paved roads and is less than 2 miles to an 1-40
interchange but is greater than 2 miles from an 1-77 interchange. Truck access avoids at -
grade rail crossings.
In summary, Off -Site Alternative 4 does not meet all the site screening criteria and is therefore
not a practicable alternative.
6.2.6 Off -Site Alternative 5
This tract totals approximately 260 acres and is located west of 1-77. The following provides a
summary of each criterion reviewed for the applicant's preferred site:
• General Screening Criteria: This alternative is capable of being constructed when
considering cost and logistics; the property can be reasonably obtained and the project
site meets the basic and overall project purpose.
• Size: The site totals 260 acres which does meet the minimum criteria for the project.
• Geographic Location: The site is located in Iredell County, is situated just west of 1-77,
and is located outside of the Lake Norman WSW, which does meet the minimum criteria
for the project.
• Land Use/Zoning: The site is not currently zoned for the proposed use, however,
rezoning of the property is assumed to be feasible.
• Utilities: All required utilities can be feasibly extended to the site.
• Availability: The site is not currently listed for sale but is known to be available.
• Access: The site has poor access as trucks must use a narrow residential road to access
the interstate; however, the site is less than 2 miles to an 1-77 interchange and affords
truck access that avoids at -grade rail crossings.
In summary, Off -Site Alternative 5 does meet all the site screening criteria and is, therefore, a
practicable alternative.
6.3 On -Site Configurations
In addition to considering off -site alternatives, the applicant considered on -site alternatives. The
following provides a summary of each alternative during the design review process.
6.3.1 On -Site Configuration 1
This configuration was a preliminary 2-building design that provided the greatest logistical
functionality for the applicant but resulted in greater impacts to aquatic resources and a lower
than desirable square footage yield. The design includes 2 buildings of 523,260 SF and 1,046,529
SF, 3-4 stormwater detention basins, truck access and parking, and employee parking. The
configuration totals 1,523,260 SF of warehouse space. This concept would impact 3,100 LF of
streams.
6.3.2 On -Site Configuration 2
This configuration was the initial site plan reviewed by the applicant designed for a single -building
build -to -suit warehouse tenant. During design, the agreement with the build -to -suit tenant was
terminated, resulting in a speculative redesign of the site. This configuration includes one
1,501,200 SF building, 6 stormwater detention basins, truck access and parking, and employee
parking. This concept would impact 2,400 LF of streams.
Kimley»>Horn

E-3
6.3.3 On -Site Configuration 3 (Applicant's Preferred)
This configuration is the applicant's preferred alternative. The site plan was specifically designed
to minimize impacts to aquatic resources to the greatest extent practicable by maximizing the use
of retaining walls and proposes Con/Span bridge structures to minimize additional stream
impacts. The design includes 2 buildings of 700,000 SF and 1,000,000 SF, 3-4 stormwater
detention basins, truck access and parking, and employee parking. The configuration totals
1,700,00 SF of warehouse space. This concept would impact 2,236 LF of streams.
6.4 Alternatives Not Practicable or Reasonable
Following reviews of both off -site alternatives and on -site configurations, the applicant completed
a comparison of alternatives to the practicability/reasonability screening criteria. Table 1 on the
following page summarizes a comparison of each alternative discussed above to the screening
criteria for practicability and reasonableness.
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6.5 Review of Practicable Alternatives
Following a determination of practicable alternatives using the "Practicability/Reasonability
Screening Selection Criteria", the applicant completed an analysis of practicable alternatives to
identify the least environmentally damaging practicable alternative pursuant to 40 CFR 230.7(b)(1).
The purpose of the below analysis is to ensure that "no discharge of dredged or fill material shall be
permitted if there is a practicable alternative to the proposed discharge which would have a less
adverse impact on the aquatic ecosystem". The applicant evaluated potential environmental impacts
that would result from the construction of the proposed facility. This evaluation was completed by
considering environmental factors that could impact the development of the site. The environmental
factors included:
• Stream Impacts (quantitative) — The estimated linear footage of potential stream impact
was evaluated for each practicable alternative.
• Stream Function (qualitative) — The functional value of potential stream impact areas was
evaluated for each practicable alternative utilizing the most recent version of the North
Carolina Stream Assessment Method (NCSAM). Results of the NCSAM assessment include
a qualitative rating of low, medium, or high value based on an overall function class rating
which considers hydrology, water quality, and habitat functions.
• Wetland Impacts (quantitative) — The estimated acreage of potential wetland impact was
evaluated for each practicable alternative.
• Wetland Function (qualitative) — The functional value of potential wetland impact areas
was evaluated for each practicable alternative utilizing the most recent version of the North
Carolina Wetland Assessment Method (NCWAM). Results of the NCWAM assessment
include a qualitative rating of low, medium, or high value based on an overall function class
rating which considers hydrology, water quality, and habitat functions.
• Federally -Listed Threatened or Endangered Species — A preliminary assessment of
each practicable alternative was conducted to determine the potential occurrence of animal
and plants species (or their preferred habitats) currently listed as threatened or endangered
by state and federal regulations [Federal Endangered Species Act of 1973 (16 USC 1531-
1543)]. The U.S. Fish and Wildlife Service (USFWS) Information, Planning, and Conservation
System (IPaC) database at http://ecos.fws.gov/ipac/ database was reviewed to determine
plant and animal species as endangered or threatened for each alternative.
• Cultural Resources — A preliminary assessment of cultural resources was conducted for
each site by reviewing available State Historic Preservation Office information. Potential
impacts to sites listed or eligible for listing on the National Register of Historic Places were
noted for each alternative.
• Floodplain Impacts — The estimated acreage of flood plain impact was evaluated for each
practicable alternative.
Considering the assessment criteria above, the applicant evaluated 4 alternatives consisting of 2
alternative sites (including the applicant's preferred site) and 3 alternative on -site configurations
(including the applicant's preferred on -site configuration). The following provides a summary of each
practicable alternative and associated environmental impacts.
6.5.1 Proposed Action or Applicant's Preferred Alternative/On-Site Configuration 3
The applicant's preferred site and the preferred on -site configuration include two (2) distribution
warehouse buildings, totaling 1,700,000 SF, 3-4 stormwater detention basins, truck access and
parking, and employee parking. The formal aquatic resources delineation documents no wetlands
Kimley»>Horn

11
and 6,863 LF of stream. A summary of the environmental impacts associated with this on -site
configuration is provided below.
• Stream Impacts (quantitative) — The aquatic resources delineation that has been
completed within the project area indicates 2,236 LF of stream impact, including 241 LF of
indirect loss of waters, is required for the preferred site and on -site configuration.
• Stream Function (qualitative) — Results of the NCSAM assessment include an overall
function class rating of medium for on -site streams.
• Wetland Impacts (quantitative) — Based on the jurisdictional determination, 0-acres of
wetland would be impacted by this alternative.
• Wetland Function (qualitative) — N/A
• Federally -Listed Threatened or Endangered Species — Based on a review of the U.S.
Fish & Wildlife Service Information for Planning and Consultation (IPaC) System and the
North Carolina Natural Heritage Program (NCNHP) database, no federally listed species are
known to occur within this site or proximity of the site. Pedestrian surveys were conducted
on March 30, 2021, and August 31, 2021. No individuals of listed species or critical habitat
associated with a listed species were observed during the pedestrian surveys. Since the
project seeks impacts to suitable habitat of listed plant species, but no occurrences were
detected during the appropriate survey window, a biological conclusion of "may affect, not
likely to adversely affect" (MANLAA) was recommended to USFWS.
• Cultural Resources — A request for a review of potential cultural resources was submitted
to the North Carolina Department of Natural and Cultural Resources State Historic
Preservation Office (NCSHPO) on March 12, 2021. On July 9, 2021, NCSHPO provided a
response letter concurring with the absence of potentially eligible cultural resources within
the project boundary. No documented archaeological sites of significance within the project
boundary were identified.
• Floodplain Impacts — Based on a review of available FEMA maps, impacts to FEMA-
regulated floodplains are not anticipated by the proposed project.
6.5.2 Alternative Site #5
Alternative Site 5 includes 2 buildings, 1,000,000 SF and 700,000 SF, two stormwater detention
basins, truck access and parking, and employee parking. This configuration totals 1,700,000 SF of
warehouse space. The NWI/aerial/Lidar desktop assessment indicates that the 260.5-acre project
site contains 41.2 acres of wetlands. The NHD/Lidar desktop assessment indicates that the project
site contains 13,694 LF of stream. A summary of the environmental impacts associated with this on -
site configuration is provided below.
• Stream Impacts (quantitative) — Based on the National Hydrography Dataset (NHD)
flowlines and desktop lidar stream assessment, approximately 2,438 LF of stream would be
impacted by this alternative.
• Stream Function (qualitative) — A review of current and historical aerial photography
indicates that the property has been utilized for agricultural purposes in the northeastern area
of the site. The streams on -site, however, are present in the forested portions of the site. It
appears that the forested areas have been undeveloped, and it is likely that the functional
value of the streams that would be impacted by this alternative are assigned a medium value
based on the assumed results of an NCSAM assessment.
• Wetland Impacts (quantitative) — Based on the NW, 0-acres of wetland would be
impacted by this alternative.
• Wetland Function (qualitative) — N/A
Kimley»>Horn

12
Federally -Listed Threatened or Endangered Species — Based on a review of the U.S.
Fish and Wildlife IPaC and the North Carolina Natural Heritage Program (NCNHP) database,
no federally listed species are known to occur within this site or proximity of the site. Based
on the location of the tract and site conditions, no adverse impacts to federally listed
threatened and endangered species would be expected.
Cultural Resources — Upon review of the NCSHPO's HPOWeb online database, the
property does not contain any National Register -eligible historic sites.
Floodplain Impacts — Based on a review of available FEMA maps, impacts to FEMA-
regulated floodplains are not anticipated by the proposed project.
6.5.3 On -Site Configuration #1
On -Site Configuration #1 includes two (2) distribution warehouse buildings, totaling 1,523,260 SF,
3-4 stormwater detention basins, truck access and parking, and employee parking. The formal
aquatic resources delineation documents no wetlands and 6,863 LF of stream. A summary of the
environmental impacts associated with this on -site configuration is provided below.
• Stream Impacts (quantitative) — The aquatic resources delineation that has been
completed within the project area indicates 3,100 LF of stream would be impacted by this
configuration.
• Stream Function (qualitative) — Results of the NCSAM assessment include an overall
function class rating of medium for on -site streams.
• Wetland Impacts (quantitative) — Based on the jurisdictional determination, 0-acres of
wetland would be impacted by this alternative.
• Wetland Function (qualitative) — N/A
• Federally -Listed Threatened or Endangered Species — Based on a review of the U.S.
Fish & Wildlife Service Information for Planning and Consultation (IPaC) System and the
North Carolina Natural Heritage Program (NCNHP) database, no federally listed species are
known to occur within this site or proximity of the site. Pedestrian surveys were conducted
on March 30, 2021, and August 31, 2021. No individuals of listed species or critical habitat
associated with a listed species were observed during the pedestrian surveys. Since the
project seeks impacts to suitable habitat of listed plant species, but no occurrences were
detected during the appropriate survey window, a biological conclusion of "may affect, not
likely to adversely affect" (MANLAA) was recommended to USFWS.
• Cultural Resources — A request for a review of potential cultural resources was submitted
to the North Carolina Department of Natural and Cultural Resources State Historic
Preservation Office (NCSHPO) on March 12, 2021. On July 9, 2021, NCSHPO provided a
response letter concurring with the absence of potentially eligible cultural resources within
the project boundary. No documented archaeological sites of significance within the project
boundary were identified.
• Floodplain Impacts — Based on a review of available FEMA maps, impacts to FEMA-
regulated floodplains are not anticipated by the proposed project.
6.5.4 On -Site Configuration #2
On -Site Configuration #2 includes one (1) distribution warehouse building, totaling 1,501,200 SF, 6
stormwater detention basins, truck access and parking, and employee parking. The formal aquatic
resources delineation documents no wetlands and 6,863 LF of stream. A summary of the
environmental impacts associated with this on -site configuration is provided below.
Kimley»>Horn

13
• Stream Impacts (quantitative) — The aquatic resources delineation that has been
completed within the project area indicates 2,400 LF of stream would be impacted by this
configuration.
• Stream Function (qualitative) — Results of the NCSAM assessment include an overall
function class rating of medium for on -site streams.
• Wetland Impacts (quantitative) — Based on the jurisdictional determination, 0-acres of
wetland would be impacted by this alternative.
• Wetland Function (qualitative) — N/A
• Federally -Listed Threatened or Endangered Species — Based on a review of the U.S.
Fish & Wildlife Service Information for Planning and Consultation (IPaC) System and the
North Carolina Natural Heritage Program (NCNHP) database, no federally listed species are
known to occur within this site or proximity of the site. Pedestrian surveys were conducted
on March 30, 2021, and August 31, 2021. No individuals of listed species or critical habitat
associated with a listed species were observed during the pedestrian surveys. Since the
project seeks impacts to suitable habitat of listed plant species, but no occurrences were
detected during the appropriate survey window, a biological conclusion of "may affect, not
likely to adversely affect" (MANLAA) was recommended to USFWS.
• Cultural Resources — A request for a review of potential cultural resources was submitted
to the North Carolina Department of Natural and Cultural Resources State Historic
Preservation Office (NCSHPO) on March 12, 2021. On July 9, 2021, NCSHPO provided a
response letter concurring with the absence of potentially eligible cultural resources within
the project boundary. No documented archaeological sites of significance within the project
boundary were identified.
• Floodplain Impacts — Based on a review of available FEMA maps, impacts to FEMA-
regulated floodplains are not anticipated by the proposed project.
6.6 Summary of Alternatives Analysis
When comparing the practicable alternatives, the Applicant's Preferred Alternative requires fewer
stream impacts. When considering environmental impacts, the Applicant's Preferred Alternative
represents the least environmentally damaging alternative. Table 2 provides a summary of the
practicable alternatives and the values for each factor.
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In summary, the applicant and design team considered a variety of alternatives that would avoid and
minimize impacts to streams to the greatest extent practicable while satisfying the overall project
purpose. Through a comprehensive analysis of both off -site alternatives and on -site configurations,
the applicant has been able to reduce the overall environmental impacts and demonstrate that the
proposed site and design is the least environmentally damaging practicable alternative. Specific to
the on -site configurations, the applicant reduced the overall aquatic resource impacts by 1,105 LF
of stream through the proposed design and facility layout.
7.0 THREATENED & ENDANGERED SPECIES
Kimley-Horn (KH) completed a threatened and endangered species assessment for the project site.
KH reviewed state and federal records to determine if any listed species were known to occur within
and/or in the general vicinity of the project area. A review of the U.S. Fish & Wildlife Service
Information for Planning and Consultation (IPaC) System and the North Carolina Natural Heritage
Program (NCNHP) was conducted on February 1, 2021, to identify species that are known to occur
within Iredell County. Based on the review, the range of the plant species dwarf -flowered heartleaf
(Hexastylis naniflora) includes Iredell County. No known occurrences of dwarf -flowered heartleaf
were identified within 1.0 miles of the project site. Following the review of available information, KH
conducted a pedestrian survey of the project site throughout areas of potentially suitable habitat on
March 30, 2021, to document occurrences of listed species. No individuals of dwarf -flowered
heartleaf were observed during the survey.
A Project Review Certification Letter was submitted to USFWS on April 20, 2021, summarizing the
results of the species survey. Since the project seeks impacts to suitable habitat of listed plant
species, but no occurrences were detected during the appropriate survey window, a biological
conclusion of "may affect, not likely to adversely affect" (MANLAA) was recommended to USFWS.
A concurrence response letter from USFWS was received on May 18, 2021, indicating that the
USFWS was in agreeance with the MANLAA biological conclusion.
Following receipt of the concurrence response letter, the USFWS Asheville Office modified the
current range and area of influence (AOI) for Schweinitz's sunflower (Helianthus schweinitzh). As a
result of the modification, the project site is now within the range of Schweinitz's sunflower. On
August 31, 2021, KH performed a pedestrian survey for Schweinitz's sunflower throughout areas of
potentially suitable habitat. No individuals of Schweinitz's sunflower were observed during the
pedestrian surveys. A revised Project Review Certification Letter recommending a MANLAA
biological conclusion for Schweinitz's sunflower has been prepared and submitted to USFWS for
their concurrence. Upon receipt, the revised concurrence response letter will be provided to the
applicable review agencies.
Copies of all USFW correspondence are including in Appendix G
8.0 CULTURAL RESOURCES
A request for a review of potential cultural resources was submitted to the North Carolina Department
of Natural and Cultural Resources State Historic Preservation Office (NCSHPO) on March 12, 2021.
NCSHPO responded on April 29, 2021, and requested further information regarding all structures 50
years or older within the project site. Kimley-Horn visited the site on May 13, 2021, to photograph
and document the existing 50-year-old structures. Following the site visit, Kimley-Horn prepared a
photographic documentation package and submitted the information to NCSHPO. On July 9, 2021,
NCSHPO provided a response letter concurring with the absence of potentially eligible cultural
resources within the project boundary. A copy of the correspondence is provided in Appendix H.
No documented archaeological sites of significance within the project boundary were identified.
Kimley»>Horn

16
9.0 STORMWATER MANAGEMENT
The Town of Troutman and Iredell County are Phase II stormwater delegated local authorities that
jointly implement NCDEQ's Post -Construction Stormwater Program. A preliminary stormwater
management plan is being designed by KH and although this plan has not yet been finalized, the
preliminary plan includes the construction of stormwater ponds designed to accommodate the
stormwater volume associated with the development of the site. The final stormwater management
plan will meet all stormwater management requirements and will be submitted to the delegated local
authorities for review. Approvals will be provided to NCDWR once they are received
10.0 COMPENSATORY MITIGATION
Compensatory mitigation will be met by the purchase of credits through the NC Division of Mitigation
Services (NCDMS) in -lieu fee program. 2,236 LF of stream impacts, including 241 LF of indirect
loss of waters, will be mitigated through the purchase of stream mitigation credits. Based on an
NCSAM assessment of Medium for intermittent Streams 313, 4, and 5, mitigation is proposed at a
1.5:1 ratio for impacts to these features, or 882 stream mitigation credits. A quality assessment
result of Medium for perennial Stream 2 proposes mitigation at a 2:1 ratio for impacts to this feature,
or 2,814 stream mitigation credits. It is assumed that indirect loss of waters impacts may result to
the upstream portion of Stream 2 and the entirety of Stream 6. Based on these assumed impacts,
mitigation is proposed at a 1:1 ratio, or 241 stream mitigation credits. In total, 3,937 stream mitigation
credits will be purchased from NCDMS to offset impacts associated with this project. Quality
assessment results and NCDMS mitigation acceptance are included in Appendix F.
11.0 CONCLUSION
NC Development Acquisition, LLC, a North Carolina limited liability company, is proposing the
construction of a multi -building industrial logistics park in Iredell County, North Carolina. The project
area totals approximately 157-acres located at the NW corner of 1-77 and Ostwalt Amity Road in the
town of Troutman, Iredell County, NC (35.689908°,-80.8610810). The industrial warehousing
complex will include two distribution center warehouses, totaling 1,700,000 SF of warehouse space,
and will provide warehousing and logistics services to Charlotte MSA-related clients and the 1-77
corridor. As compensatory mitigation for impacts to aquatic resources, the applicant is proposing to
purchase 3,696 stream mitigation credits from NCDMS. The proposed project is the result of
numerous development plan reviews during which the applicant was able to further avoid and
minimize impacts to aquatic resources. All development activities will be conducted using best
management practices to prevent incidental impacts to the remaining on -site aquatic resources.
Kimley»>Horn

APPENDIX C
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