20220210 Ver 1_More Info Requested_20220411

Strickland, Bev
From: Homewood, Sue
Sent: Monday, April 11, 2022 9:55 AM
To: Michelle Savage-Measday, PWS; [e-mail]
Cc: Brian E. Hecke; Blake Jones; Anthony Lester - Evans Engineering, Inc. (adl@evans-
eng.com)
Subject: RE: [External] SAW-2021-00395 (415 Gallimore Dairy Road / Greensboro / Guilford
County / industrial)
All,
Thank you for providing a copy of your responses to the USACE's questions. I have completed the DWR review and have
a few follow up questions/comments. Please respond to this email within 30 days. The application will be considered
"on hold" until receipt of a complete response.
1. With regard to item #2 below, please provide the report and updated plans to DWR. Please note that upon
review of the information provided the Division may have follow up questions, or may condition any 401
approval to address changes to downstream hydrology (both in the wetland and in the stream)
2. Please provide an acceptance letter from the mitigation provider.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Michelle Savage-Measday, PWS <[e-mail]>
Sent: Monday, April 4, 2022 11:07 AM
To: [e-mail]
Cc: Brian E. Hecke <[e-mail]>; Blake Jones <[e-mail]>; Anthony Lester - Evans
Engineering, Inc. ([e-mail]) <[e-mail]>; Homewood, Sue <[e-mail]>
Subject: [External] SAW-2021-00395 (415 Gallimore Dairy Road / Greensboro / Guilford County / industrial)
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David,
Below responds to comments from your email dated March 2, 2022. The applicant is proceeding with geotechnical
investigation on the site to better characterize groundwater conditions. That information will be forwarded to your
office to further address comment #2.
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Michelle
1) NWP 29 General Condition 23(a) requires that the activity be designed and constructed to avoid and minimize
adverse effects, both temporary and permanent, to waters of the US to the maximum extent practicable
(available and capable of being done after taking into consideration cost, existing technology, and logistics in
light of overall project purposes). For the purposes of documenting that the project complies with this
requirement, please provide any additional information as to the end -user of the proposed facility or other
justification of building sizes and attendant features at this location;
The purpose and need of the project is for development of an industrial/commercial site that provides key
components for bulk warehousing, distribution with commercial space. Other aspects of the site include central
location, sufficient size for the proposed buildings, can be supported with current infrastructure, and is
complimentary to the existing commercial and industrial properties that are located in the general area. The
site is also located in the vicinity of major interstate thoroughfares and access to the Piedmont Triad (GSO)
International Airport.
The selected site offers the following which was important to the intended use:
1. Preferred site location in the vicinity of 1-85 and 1-40 along major thoroughfares. Access to Piedmont Triad
International Airport.
The site is located within approximately 0.5 mile of 1-40 via Gallimore Dairy Road and approximately 1.5
miles via Route 68.
2. Utilities in place and or close to the site. The site requires electrical, gas, fiber, water, and sanitary sewer.
Utilities are located within Chimney Rock Road.
3. The site is generally flat and was free of poor soils which is important to the feasibility of bulk
warehousing/distribution projects.
The site is slopes in an east to west direction. The larger of the two warehouse buildings is located along the
eastern boundary in a more level area of the site.
4. A site was large enough to accommodate the site program and was controlled by a single landowner.
Current industry standard is 200,000-SF for a warehouse/distribution building. The site split warehouse
space between two buildings to achieve close to 180,000-SF
5. The site must provide good secondary road access to support the expected truck and employee traffic.
A traffic signal at the intersection of Gallimore Dairy Road and Chimney Rock Road controls traffic adjacent
both site entrances.
6. A site that was relatively free of environmental features, streams, and floodplain, and/or features that would
be to large building footprints.
7. The site is entitled/zoned to appropriately allow for the intended bulk warehousing/distribution and
commercial use.
Due to the site's unique configuration with a wetland and stream in the center of the site, in order to achieve close to the
minimum industry standard of 200,000-SF warehouse space, while avoiding further impacts to the wetland and stream
onsite, the warehouse space was split between two buildings. The larger warehouse space was configured as far back
from the wetland to minimize further impacts to the resource. The depth of the building is at the minimum while still
providing separation of vehicular and tractor trailer parking and movement with separate driveways. Separation of
vehicular and tractor trailer movements provides safety for both operators. Fire safety requires full access to a minimum
of three sides of the building, which has been provided. Impacts to the wetland were minimized to the maximum extent
practicable with grading at a 2:1 slope. A retaining wall was considered, however costs, maintenance and safety concerns
with regard to the height of the wall and additional fencing on top of the wall were considered impracticable.
2) Based on proposed grading, wetland fill, and re-routing of drainage into stormwater ponds, the project appears
to eliminate the drainage area/hydrology source for the remainder of the on -site Wetland downstream of the
proposed impact site. Unless otherwise justified, the Corps would consider the remainder of the Wetland as a
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reasonably foreseeable indirect impact (see NWP General Conditions "District Engineers Decision") resulting
from a loss of hydrology. Unless otherwise justified, compensatory mitigation would be required for both direct
impacts and indirect impacts resulting in a loss of hydrology and therefore aquatic function; compensatory
mitigation is typically required at a 2:1 ratio, depending largely on resource quality (reference the NCWAM score
of "High" for this wetland);
Based upon site characteristics and aerial photos, there is evidence that the wetland was an excavated farm
pond, which intercepts groundwater. USGS StreamStats (attached to this email) depicts an overall drainage area
at the bottom of the stream at Gallimore Diary Road as 20 acres. Aerial photos from 1955 depict a farm pond
(attached to this email). It is unlikely that the wetland is completely sustained by surface water runoff and based
upon the aerials and drainage area, it is more likely groundwater driven and will be hydrologically sustainable
with the impact shown on the plans. In addition, the applicant is undertaking geotechnical investigations at the
site. Additional borings will be performed to confirm the location of groundwater. Based upon that information,
the applicant will make a decision with regard to adding footing drains that would discharge to the remaining
wetland area in order to avoid indirect impacts to sustaining hydrology to this area. The geotechnical
investigation is anticipated to occur within the next month. Upon receipt of those results and modifications to
the project design, specifically with regard to the addition of footing drains, the information will be submitted to
your office for review as part of this application.
3) We acknowledge the information you provided in the PCN pertaining to endangered species (Section 7 of the
Endangered Species Act). However, given the general nature of potentially suitable habitat for Schweinitz's
sunflower and small whorled pogonia, the existence of both open and forested areas within the project area,
and given recent USFWS concerns regarding these species, the Corps cannot currently reach a No Effect
determination for these species within the Section 7 Action Area based on the information provided. Note that
the Corps is willing to request concurrence from the USFWS on a May Affect Not Likely to Adversely Affect
determination for both species using the information you provided. However, please be aware that, if the
USFWS cannot concur with this determination based on this information, they may request a plant -by -plant
survey for these species within the appropriate survey season(s). Per NWP 29 General Condition 18, the Corps
cannot verify the use of a NWP until Section 7 consultation is complete.
See USFWS letter dated March 9, 2022 (attached) which states that based upon information provided, it appears
that the proposed action is not likely to adversely affect any federally -listed endangered or threatened species,
their formally designated critical habitat, or species currently proposed for list under the Act at this site.
MICHELLE SAVAGE-MEASDAY, PWS I Environmental Senior Project Manager
T 919.861.9910 I D 919.861.9821 I C 919.441.2437
5260 Greens Dairy Road I Raleigh I NC 127616
ECS SOUTHEAST, LLP
www.ecslimited.com
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