20220522 Ver 1_USACE SAW-20221-02629 PN Comments_20220809

Kimley>»Horn
July 29, 2022
Krysta Stygar
Regulatory Specialist
US Army Corps of Engineers
Wilmington District
8430 University Executive Park Drive
Charlotte, NC 28262
RE: USACE and Agency Response to Public Notice Comments
USACE SAW-2021-02629 (DWR #2022-0522)
NorthPoint Development, LLC — NC Park 40/77
Iredell County, North Carolina
Dear Ms. Stygar,
On behalf of our client, NorthPoint Development, LLC, Kimley-Horn (KH) is submitting the following
responses to the Public Notice comments for the above -referenced project per the US Army Corps of
Engineers (USACE) Public Notice comments issued on June 29, 2022.
Below is an outline of the USACE comments with a brief narrative addressing each item. The USACE
comments with the applicant's response and explanation are as follows:
1. The project proposes to be constructed in two phases. The anticipated build -out of all phases of
construction is approximately five years. Please provide a more specific timeline for each phase of
development along with an approximate start and end date of each phase of construction. As
described in the application materials, Phase 1 and Phase 11 are independent of one another and are
capable of standing as single and complete projects in the event the other phase is not constructed,
please provide written updates on the status of both projects. Or approximate times lines when the
Phases are to be complete.
Response: See the project schedule matrix below:
Phase 1 Critical Milestones
Entitlements Complete
March 2022
Target Closing Date
April 2022
Construction Start
May 2022
Building 4 Delivery
February 2023
Park "cal Milestones
Individual Permit Issuance December 2022
Building 1 Anticipated Delivery
Building 2 Anticipated Delivery
May 2024
December 2023
Building 3 Anticipated Delivery
October 2023
Building 5 Anticipated Delivery July 2024
kimley-horn.com
200 South Tryon Street, Suite 200, Charlotte, NC 28202
704-333-5131

Kimley>»Horn
Page 2
2. The applicant determined that lredell County and more specifically Statesville was the most
appropriate project location based on the following criteria: 1) Capable of being constructed
considering cost 2) Capable of being constructed considering logistics 3) Property can be
reasonably obtained 4) Proximity to workforce 5) Meets basic project purpose 6) Meets overall
project purpose. The applicant did not state which other areas, counties, and/or cities were
considered for the proposed development in the Southeastern United States. Therefore, please
provide the other locations that were considered along with the reasons/justifications as to why those
sites were not chosen.
Response: Northpoint Developments Southeast presence covers a five -state region including North
Carolina, South Carolina, Georgia, Florida, and Alabama. The entire Southeast region benefits from
a combination of exponential growth, coastal connectivity, a robust interstate network, and a
business -friendly environment. When selecting where the next development should be built the team
considers these metrics as well as where buildings are currently owned and what competitors are
doing. Statesville was chosen above other markets on the following criteria:
a) Capable of being constructed considering cost
b) Capable of being constructed considering logistics
c) Property can be reasonably obtained
d) Proximity to workforce
e) Meets basic Project purpose
f) Meets Overall project purpose
Other markets that were considered for this development include Charlotte and Greensboro
Charlotte — The Charlotte market was considered but not selected given that it did not meet criteria
A and C of the above. Northpoint obtained an early foothold in the Charlotte market and has a
pipeline of 4.5M square feet that can be developed. With an already lengthy pipeline, additional
buildings in this market did not make sense. Additionally, the Charlotte MSA is set to deliver over
12M square feet of product this year and historically only absorbs about 10M square feet so the
additional product in this market is not currently necessary. Finally, the increased activity in this
market has driven land costs and construction costs to record highs which make construction
infeasible
Greensboro — The Greensboro Market was considered but not selected because Northpoint already
has a 2.8M square foot pipeline in this market. Additionally, given the recent economic
announcements of large manufacturers entering the market, land prices have seen a 54% increase
in the last 12 months. Increased land costs combined with increased material prices have made
deals in this market infeasible.
Compared with other major MSAs in North Carolina, Statesville is the only one that checks the box
for the six presented criteria.
kimley-horn.com
200 South Tryon Street, Suite 200, Charlotte, NC 28202
704-333-5131

Kimley»>Horn
Page 3
3. The applicant analyzed six specific siting criteria to determine if the off -site alternatives would be a
practicable alternative. Per the geographic location criteria, sites considered and presented for this
project were limited to the 1-77 corridor with connectivity to 1-40. Other potential sites within Lake
Norman Water Supply Watershed (WSW) area were excluded to avoid high -density development
within the environmentally sensitive watershed. It appears that all of the analyzed alternatives were
located in the Statesville area or Iredell County. Is there additional supporting information to exclude
development within the Lake Norman Water Supply Watershed? Please explain.
Response: The 1-77 corridor from Huntersville to Troutman is virtually completely within the Lake
Norman WSW. Per the NCDEQ Water Supply Watershed Rules, development activities,
particularly industrial uses, are more restraining including built upon area restrictions and wider
stream buffers, further limiting developable area. These factors result in sites that are cost -
prohibitive. To avoid these restrictions, site alternatives considered were situated from the Town of
Troutman, north into Iredell County. Please see the table below:
Surface
Freshwater
Classifications
AREA
AFFECTED
WASTEWATER
DISCHARGES
ALLOWED
DEVELOPMENT ACTIVITIES
ALLOWABLE DENSITY
LOW DENSITY
OPTION
(Du = DWELLING
LINIT)
(AC =ACRE)
HIGH
DENSETY
OPTION1z
STREAM 14
BUFFERS
WATER SUPPLY - IV
(WS-IV)1
1 /2 mile
critical area
domestic and
industrial'
1 du / 112 ac or
24% build pon
area
24-50%
built upon
area
low density - 30'
high density - 100'
protected
area'
domestic and
industrial
1 du 11/2 ac or
built
24% u
areal 'oon
24-70%
on
built areal u ' 11
low density - 30'
high density - 100'
4. In discussing the Land Use/Zoning siting criteria for alternative 1, 389-acre tract located along
Shelton Avenue, south of 1-40 and West of 1-77 the application package states, "this alternative
meets the basic and overall project purpose; however, the property cannot be reasonably obtained
due to zoning. This alternative is not capable of being constructed when considering costs and
logistics." Please provide additional details about the added costs and logistical support which
would potentially make this off -site alternative not viable.
Response: Rezoning this particular site would entail a timeline of approximately 6 months to
potentially obtain the required documents, file applications, and hold the required public hearings
at a cost of up to $250,000+ based on recent experience. Since the site is currently zoned
residential as well as the surrounding areas, it's reasonable to presume that the probability of a
successful rezoning is low.
5. In the discussion of off -site alternative 2, the application states, "The property can be reasonably
obtained, and the project meets the basic and overall project purpose; however, based on the size
of the property this alternative is not capable of being constructed when considering cost and
logistics." Please provide additional details about the added costs and logistical support which
would potentially make this off -site alternative not viable.
kimley-horn.com
200 South Tryon Street, Suite 200, Charlotte, NC 28202
704-333-5131

Kimley»>Horn
Page 4
Response: Alternative Site 2 does not meet the size element of the Specific Siting Criteria, that
the site needs to be at least 350 acres to meet the project need. This is demonstrated in the
Concept Plan which results in only 4 buildings and a deficit of approximately 1 million square feet
when compared to the preferred site and other off -site alternatives.
6. The discussion for off -site alternatives 2 and 5 reads "The site is currently under contract and
cannot be purchased". Please provide additional details as to why an alternative that could not be
reasonably feasible or purchased was considered a viable alternative option to the applicant's
preferred alternative.
Response: Per Mr. Grant Miller, a broker with Colliers International, Alternative Sites 2 and 5 are
both currently under contract to purchase by other industrial developers. Alternative Site 2 is under
contract with The Silverman Group. Alternative Site 5 is under contract with TPA Group. These
sites cannot be purchased at the current time.
7. While In section 8.0 the application indicated that a review of potential cultural resources was
submitted to the NCSHPO on December 6, 2021. NCSHPO responded on January 25, 2022, and
requested the further evaluation of structures and/or complexes with more than 50 years of age
within the approved permit area. New South Associates (NSA) was contracted by the applicant to
prepare a Historic Structures Survey Report (HSSR) for the project area. In addition, in a comment
letter from NCSHPO on June 1, 2022, NCSHPO indicated that this information request is required.
Please provide the USACE with a copy of the historical report (HSSR) and any correspondence
between the applicant and NCSHPO. Your response to this item needs to include 1) date(s) of field
survey; and 2) the approximate timeframe when the survey and report will be available to the Corps
and NCSHPO.
Response: The Historic Structures Survey Report (HSSR) and The Phase II Archaeological
Evaluation of Site 31 ID292 and Archaeological Assessment of Possible Gravesites is attached for
reference. On July 18, 2022, we received a determination from NCSHPO that no property or
structures on the project site are eligible for listing. The correspondence is attached. We will provide
the correspondence from NCSHPO regarding their concurrence for the results of the archeological
investigation upon receipt.
8. In section 9.0 the application indicated that a "preliminary stormwater management plan is being
designed by Kimley-Horn and although the 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. Please provide USACE
stormwater management approvals from the state. On June 15, 2022, USACE received the
additional information requested by NCDWR as well as the City of Statesville annexation
approval memo. The proposed new drainage map was included in this material. Please provide
any additional information for the Stormwater approvals for both Phase I and Phase 11.
kimley-horn.com
200 South Tryon Street, Suite 200, Charlotte, NC 28202
704-333-5131

Kimley>»Horn
Page 5
Response: At this time, the Stormwater Management Plan (SWMP) approval from the City of
Statesville has not been obtained; however, Kimley-Horn has prepared a draft SWMP Report to
provide to NCDWR to support the issuance of a conditional 401 Individual Water Quality
Certification (IWQC). The 401 IWQC will include a special condition that the SWMP approval from
the City of Statesville is to be provided to NCDWR prior to the commencement of any permitted
activities. Once obtained, Kimley-Horn will provide a copy of the approved SMWP to NCDWR.
The draft SWMP Report is attached for your reference.
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: Michael Johnston, NorthPoint Development, LLC
Ryan Phipps, Kimley-Horn
kimley-horn.com
200 South Tryon Street, Suite 200, Charlotte, NC 28202
704-333-5131