19910022 Ver 2_Complete Plan Package w App_20170601

Burdette, Jennifer a
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To:
[e-mail]; [e-mail]; Burdette, Jennifer a;
Turlington, Chad
Cc:
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Subject:
Smithfield Foods Pre -App Meeting IP support documents and figures
In preparation for our call on Monday, June 5t" @10am, attached for your review is a working/preliminary draft of our IP
support document and accompanying figures and appendices. This document is still a work in progress and has not been
formatted or edited by Smithfield Foods. I suggest we review the document together during our call to facilitate our
discussion anticipating we will focus more on the purpose and need, off-site alternatives, on-site alternatives, and the
impacts associated with the Preferred Alternative.
If anyone has problems downloading the documents, please let me know. Thanks for your assistance with this permit
submittal. We look forward to further discussing the project with you on Monday.
Thanks,
Beth
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Beth A. Reed, PWS
iley- orn 1 421 Fayetteville Street, Suite 600, Raleigh NC 27601
Direct: 919-677-2073 Mobile: [phone]
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INDIVIDUAL PERMI T APPL 1 CA TION AND
SUPPORTING DOCUMENTATION
Smithfield Foods Expansion Project
Tar Heel, Bladen•unty, North Carolinl
Prepared for:
Smithfield Foods, Inc.
200 Commerce Street
Smithfield, VA 23430
= 6% 11 Z;Imlo
Prepared By:
Kimley-Horn
421 Fayetteville Street, Suite 600
Raleigh, NC 27601
June 2017
©Kimley-Horn and Associates, Inc. 2017

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Executive Summary
This document is intended to provide supplementary information in support of the U.S. Army Corps
of Engineers' (USACE) preparation of the Public Notice, Environmental Assessment, Finding of No
Significant Impact, Statement of Findings, and Review and Compliance Determination according to
the 404(b)(1) guidelines for the proposed cold storage distribution center expansion in Tar Heel,
Bladen County, North Carolina.
Applicant: Smithfield Foods, Inc.
Attn: Corey Ragole
11500 N. Ambassador Drive
Kansas City, Missouri 64153
Agent: Kimley-Horn
Beth Reed, Permit Project Manager
421 Fayetteville Street, Suite 600
Raleigh, NC 27601
Date of Application: June XX,2017
Location: Smithfield Foods, Inc. is proposing to construct a cold storage distribution center
expansion connected to their current food processing facility located on NC Highway 87 in Tar Heel,
Bladen County, North Carolina. The facility is situated on an approximately 526 -acre parcel owned
by Smithfield Packing Realty Partnership, a subsidiary of Smithfield Foods, Inc. The property is
bounded by NC -87 to the east, Goodman Swamp to the west, farmland to the north, and forestland
to the south. The proposed expansion will adjoin the western side of the existing facility.
Applicant's Stated Purpose: Smithfield Foods' purpose is to construct a finished goods cold storage
distribution center at their existing food processing facility to consolidate product distribution for
the region. The project is necessary to increase product distribution efficiency, reduce truck
trips/traffic, improve employee safety, improve food safety, and further separate raw product from
finished goods during the material processing operations as dictated by the Food Safety
Modernization Act.
Project Description: The project will consist of the construction of an approximately 495,175
square foot cold storage distribution center (providing approximately 48,000 pallet positions) and
associated truck staging areas connected to the existing Smithfield Foods processing facility. The
new cold storage distribution center will employ approximately 200 additional people when it
begins operations, scheduled for 2018. Currently, pork product processed at the Smithfield facility
is loaded onto trucks and taken to multiple off-site distribution centers for storage prior to its
eventual shipment to clients. The proposed on-site cold storage distribution center would

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
eliminate trucking the processed product off-site (an approximate 60 truck trip per day reduction)
and eliminate the need for the multiple storage/distribution centers. In addition, the proposed
project would improve employee safety by separating truck traffic from employee traffic, improve
Smithfield Foods' compliance with Food Safety Modernization Act (FSMA) guidelines, and improve
the safety of Smithfield Foods' customers by further separating raw materials from finished goods.
As part of the cold storage distribution center construction, the following components would be
constructed:
• Separate entrance routes for truck/trailer access and automotive access;
• Rack storage and pallet areas for staging finished goods associated with each zone,
• Refrigerated product loading docks and loaded trailer staging areas for product
distributuion,
• Stormwater management basins.
Existing Site Conditions: The approximately 77 -acre project area (proposed Limits of Disturbance)
is contained within the larger 154 -acre delineation study area, both of which are contained within
the 532 -acre property parcels owned by Smithfield Packing Realty Partnership, a subsidiary of
Smithfield Foods, Inc. The proposed project area is located 0.75 mile north of the Town of Tar Heel
on NC Highway 87 and is currently zoned as Industrial (1) by Bladen County. The proposed project
area is bounded to the east by NC Highway 87, farmland to the north and south, and by an electric
transmission line easement to the west. A large portion of the project area is an existing industrial
food processing facility with associated parking and infrastructure. The remainder of the project
area consists of undeveloped forestland.
The project area is located in the Lumber River Basin (USGS 8 -digit HUC: 03040203) and is situated
in the coastal plain physiographic region of North Carolina. Topography within the project study
area is mostly flat with several large depressional Carolina Bays situated in and around the Site.
Elevations in the proposed project area range from 125 to 135 feet above sea level.
North Carolina Wetlands Assessment Method (NCWAM): Five wetlands were identified in the
delineation study area, covering three distinct wetland types using the NCWAM classification
system. Two wetlands (W2 and W3) are headwater forest wetlands, wetlands W1 and W6 are basin
wetlands, and wetland W4 is a pocosin wetland. The project area only impacts two (W1 and W3) of
the five wetlands that were identified within the delineation study area.
W1 was classified as a basin wetland and was found to have a "Medium" qualitative rating due to
the overall size, connectivity, and relatively minor disturbance to the wetland's interior. W3 was
classified as a headwater forest wetland and was found to have a "Low" overall wetland rating due
to the small size, lack of connectivity, and the influence of adjacent development on the wetland
system. The wetlands delineated within the delineation study area, but located outside of the
project area were not evaluated using NCWAM.
11

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
North Carolina Stream Assessment Method (NCSAM): No streams are located within the project
study area.
CAMA Regulated Areas: The project is not located within a NCDCM regulated county.
Protected Species: As of July 21, 2016, the U.S. Fish and Wildlife Service lists seven federally
threatened or endangered species protected under the Endangered Species Act (ESA) known to
occur in Bladen County, including American alligator (Alligator mississippiensis), northern long-
eared bat (Myotis septentrionalis), red -cockaded woodpecker (Picoides borealis), wood stork
(Mycteria Americana), American chaffseed (Schwalbea americana), pondberry (Lindera
melissifolia), and rough -leaf loosestrife (Lysimachia asperulaefolia). Bald eagle is also known to
occur in Bladen County and is protected by the Bald and Golden Eagle Protection Act (BGPA). A
review of the North Carolina Natural Heritage Program (NCNHP) database records (updated April
2017), indicates no known occurrences of any federally -listed species within a one -mile radius of
the project area. The formal NCNHP database record search letter with findings is included in
Appendix H. It has been determined that the proposed project will have no effect on any of the
federally listed threatened or endangered species known to occur in Bladen County.
Cultural Resources: The State Historic Preservation Office (SH PO) HPOWeb GIS Service was
reviewed on May 1, 2017 to determine if any historic resources occurred in the vicinity of the
Property. As a result of the SHPO HPOWeb GIS Service review, four historical resources were listed
as occurring within 1.0 -mile of the Property. Three of the historical resources identified within 1.0 -
mile of the property are listed as Surveyed Only (SO), and the fourth is listed as Determined
Eligible, Gone (DOE, Gone). No National Register (NR) or Study List (SL) historical sites are listed as
occurring in or within 1.0 -mile of the Property. Due to the size and function of the pre-existing
facility, it is anticipated that there will be no impacts to any historical or archaeological sites.
Proposed Impacts: Impacts to jurisdictional wetlands will be avoided and minimized to the extent
practical. However, the preferred Site alternative will result in 2.81 acres of permanent impact to
basin wetlands and 0.015 acres of permanent impacts to headwater forest wetlands.
Development of the Site requires the placement of fill material into wetlands for the construction
of a proposed parking lot and staging area, the interior transportation network, and the associated
grading footprint.
Mitigation: Smithfield Foods will be responsible for mitigation associated with the construction of
the proposed project. Smithfield Foods proposes to mitigate for permanent impacts to wetlands by
purchasing both riparian and non -riparian wetland mitigation credits from the NC Division of
Mitigation Services (DMS) In -Lieu Fee (ILF) program. Documentation of acceptance by the ILF
program from DMS is also included in Appendix G.
Due to the relative wetland size and position within the watershed, a 2:1 mitigation ratio will be
applied to offset unavoidable impacts to all wetlands within the project area. With a 2:1 mitigation
ratio, the proposed project requires a total of 0.03 acre of riparian wetland mitigation credits and
iii

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
5.62 acres of non -riparian wetland mitigation credits. However, the DMS calculates fees for
wetland mitigation credits in quarter -acre increments and there is a flat fee for each increment of
0.25 acres. Therefore, the total wetland mitigation credits that are proposed to be purchased for
the project through the ILF program is 0.25 acre of riparian wetland mitigation credits, and 5.75
acres of non -riparian wetland mitigation credits.
Smithfield Foods has requested an in -lieu fee payment from DMS due to the lack of private
mitigation banks located in the primary, secondary, or tertiary service areas, the anticipated credit
need for this project, and the expected timeline for permit review. DMS has accepted Smithfield's
request for in -lieu fee payment for up to 6.5 acres of non -riparian wetland mitigation credits and
0.25 acre of riparian wetland mitigation credits.
Other Required Authorizations: Other required authorizations will be obtained prior to
construction of the proposed work. These authorizations include:
Individual 401 Water Quality Certification (WQC) from the North Carolina Division of Water
Resources (NCDWR),
• A Stormwater Permit application and accompanying Stormwater Management Plan is not
required by Bladen County. A General Stormwater Permit with NC Department of
Environmental Quality (NCDEQ) is currently on file for the existing property, however this
project will be required to obtain a new General Stormwater Permit with NCDEQ.
• As part of the 401 General Certification requirements, a Sediment and Erosion Control
Plan/Land Disturbance Permit will be required by NCDEQ.
iv

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Contents
1.0 The Applicant/Project Overview, Location, Existing Site Conditions, Project Description ...... 1
1.1 The Applicant/ Project Overview.................................................................................. 1
1.2 Project Location...........................................................................................................
2
1.3 Existing Site Conditions................................................................................................
2
1.3.1 Land Use...........................................................................................................3
1.3.2 Topography......................................................................................................
3
1.3.3 Jurisdictional Features......................................................................................3
1.3.4 North Carolina Wetland Assessment Method (NCWAM)..................................
5
1.3.5 North Carolina Stream Assessment Method (NCSAM) ....... Error! Bookmark not
defined.
1.3.6 Soils..................................................................................................................7
1.3.7 Vegetation........................................................................................................7
1.3.8 CAMA Regulated Areas................................................................................................
9
1.3.9 Protected Species and Habitat..........................................................................
9
1.3.10 Historical and/or Archaeological Sites..............................................................
11
1.3.11 Regulated Floodplain.......................................................................................
11
1.3.12 Zoning.............................................................................................................
11
2.0 Project Description...................................................................................................................
12
2.1 Land Ownership.........................................................................................................12
2.2 Construction Sequence.................................................................................................
12
2.3 Proposed Impacts.........................................................................................................
13
2.4 Stormwater Quality Controls.........................................................................................
14
3.0 The Public Need........................................................................................................................
15
4.0 Project Purpose and Need..................................................................................................
16
5.0 Scope of Analysis: ...............................................................................................................
16
6.0 Other Federal, State, and Local Authorizations Obtained or Required and Pending ............
16
6.1 State Water Quality (401) Certification......................................................................
16
6.2 Stormwater Permit....................................................................................................
16
6.3 Sedimentation and Erosion Control Permit................................................................
17
6.4 Site Plan Approval........................................................... Error! Bookmark not defined.
7.0 Project Alternatives/Alternatives Considered.....................................................................
17
7.1 Avoidance (No action, uplands, and availability of other sites) ...................................
17
7.1.1 No -Action Alternative.....................................................................................
17
7.1.2 Off -Site Alternatives.......................................................................................
18
7.1.3 Preferred (Practical) Alternative.....................................................................
18
7.2 Minimization (modified project designs, etc.).............................................................
19
7.2.1 On -Site Alternatives...........................................................................................
19
7.2.2 On -Site Minimization of Unavoidable Impacts ...................................................
23
7.3 Conclusion of Alternatives Analysis............................................................................
23
8.0 Mitigation.................................................................................................................................
23
9.1 Factual determinations..............................................................................................
24
9.1.2 Water circulation, fluctuation, and salinity .....................................................
24
V

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
9.1.3
Suspended particulate/turbidity.....................................................................
25
9.1.4
Contaminant availability.................................................................................
25
9.1.5
Aquatic ecosystem effects..............................................................................
26
9.1.6
Proposed disposal site....................................................................................
26
9.1.7
Cumulative effects..........................................................................................
26
9.1.8
Secondary effects...........................................................................................
27
10.0 Public Interest Review........................................................................................................
29
10.1 Public Interest
Factors................................................................................................29
10.1.1
Conservation..................................................................................................
29
10.1.2
Economics......................................................................................................
29
10.1.3
Aesthetics............................................................ Error! Bookmark not defined.
10.1.4
General environmental concerns(33CFR320.4(p))..........................................
29
10.1.5
Wetlands (33CFR320.4(b))..............................................................................
29
10.1.6
Historic and cultural resources (33CFR320.4(e)).............................................
30
10.1.7
Fish and wildlife values (33CFR320.4(c)).........................................................
30
10.1.8
Flood hazards.................................................................................................
32
10.1.9
Floodplain values(33CFR320.4(I))...................................................................
32
10.1.10
Land use......................................................................................................33
10.1.11
Navigation(33CFR320.4(o)).........................................................................
33
10.1.12
Shore erosion and accretion........................................................................
33
10.1.13
Recreation...................................................................................................33
10.1.14
Water supply (33CFR320.4(m))...................................................................
33
10.1.15
Water quality (also 33CFR320.4(d)).............................................................
33
10.1.16
Energy needs (33CFR320.4(n))....................................................................
34
10.1.17
Safety..........................................................................................................34
10.1.18
Food and fiber production...........................................................................
34
10.1.19
Mineral needs.............................................................................................34
10.1.20
Considerations of property ownership........................................................
34
11.0 Indirect and Cumulative Impacts........................................................................................
35
V1

Figure 1: Vicinity Map
Figure 2: Aerial Photograph (2014)
Figure 3: USGS Topographic Map
Figure 4: NRCS Soils Map
Figure 5: Jurisdictional Features Map
Figure 6: Overall Site Plan
WITIMS
Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Appendix A: On -Site Project Alternatives
Appendix B: Site Photographs
Appendix C: Agency Coordination
Appendix D: Permit Drawings
Appendix E: Adjacent Property Owners and Addresses
Appendix F: NCWAM Data Forms
Appendix G: Mitigation
Appendix H: NCNHP Letter
Vii

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
1.0 The Applicant/Project Overview, Location, Existing Site
Conditions, Project Description
1.1 The Applicant/ Project Overview
This document is intended to provide supplementary information in support of the U.S.
Army Corps of Engineers' (USACE) preparation of the Public Notice, Environmental
Assessment, Finding of No Significant Impact, Statement of Findings, and Review and
Compliance Determination according to the 404(b)(1) guidelines for the proposed cold
storage distribution center expansion in Tar Heel, Bladen County, North Carolina.
Smithfield Foods, Inc. (Smithfield) is a global packaged meats company headquartered
in Smithfield, Virginia. The company operates farms, facilities, and offices in the United
States, Mexico, England, Poland, and Romania, where they employ approximately
52,000 people.
As an environmentally conscious company, Smithfield employs a Chief Sustainability
Officer who oversees the company's sustainability practice. The company's
sustainability practice operates under the following six pillars: animal care, people,
environment, food safety and quality, helping communities, and value creation. Under
this operation, Smithfield received 49 Environmental Recognition Awards from the
North American Meat Institute (NAMI) in 2015. These awards are bestowed upon
organizations that go beyond environmental compliance by designing and successfully
implementing plant upgrades or environmental programs. In addition, in 2013 the
Virginia Department of Environmental Quality presented Smithfield with its
Environmental Excellence Silver Award. This award reflects Smithfield's environmental
effort to successfully reduce solid waste by 60%, water use by 17%, energy use by 13%,
and greenhouse gas emissions by 20% from 2008 to 2012.
The company opened its existing food processing facility in Tar Heel, North Carolina in
1991. This existing facility is located immediately adjacent to the east side of the
proposed expansion area, west of INC 87. The facility specializes in fresh pork and case
ready fresh pork products and currently employees approximately 4,833 workers.
Smithfield's Tar Heel North Carolina plant is the largest hog harvesting facility in the
world.

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
1.2 Project Location
Smithfield is proposing the development of a cold storage distribution center located
adjacent to their existing food processing facility situated 1.8 miles north of the
intersection of NC Highway 87 and NC Highway 131 in Tar Heel, Bladen County, North
Carolina. Figure 1 (Vicinity Map) shows the project area location. The approximately 77 -
acre project area is contained within the larger 154 -acre delineation study area, both of
which are contained within the 532 -acre property parcels owned by Smithfield Packing
Realty Partnership, a subsidiary of Smithfield Foods, Inc. The property is bounded by NC
Highway 87 to the east, Goodman Swamp to the west, farmland to the north, and
forestland to the south.
A detailed delineation was conducted within the 154 -acre study area to identify stream
and wetland areas that would need to be avoided or where impact footprints would
need to be minimized as part of the final project layout. Detailed avoidance and
minimization discussion is included in Section 7.
1.3 Existing Site Conditions
The 77 -acre project area is composed of roughly 23.7 acres of forested land crossed by
old farm roads and sanitary sewer and overhead powerline utility easements. The
existing processing facility occupies the remaining 53.3 acres of the project area. Figure
2 shows a 2016 aerial photograph of the project area. Within the project area, there are
2.83 acres of forested wetlands present that drain to Goodman Swamp located west of
the Smithfield property. The project is located in the Lumber River Basin (USGS 8 -digit
H UC: 03040203).
Based upon the North Carolina Wetland Assessment Methodology (NCWAM)
classification system, the centrally located wetland W1 is classified as a basin wetland
(22.6 acres in size, 2.81 acres within the project area). A small wetland (W3) is located in
the western portion of the project area and is classified as a headwater forest using
NCWAM. W3 totals 0.015 acre in size, entirely within the project area.
Additionally, one jurisdictional ditch was identified within the project area. Feature JD1
originates at a culvert under an existing driveway and drains the parking lot and upland
areas of the existing facility. JD1 becomes jurisdictional at a pointjust southeast of
wetland W1, where a distinctive change in vegetation occurs and soils become hydric.
There are multiple permanent structures located within the project area, grouped into
three main areas: the existing processing facility is located in the southeastern corner of
the project area, a guard house with a covered carport is centrally located along the
entranceway near the eastern boundary of the project area, and a tractor trailer scale
2

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
house and weigh station located between the existing processing facility and the
existing guardhouse. Photographs of the project area are included in Appendix B.
1.3.1 Land Use
Land uses within the project area include an existing food processing facility with
associated loading bays and parking, trailer staging areas, and undeveloped
mixed -hardwood forested tracts. Land use in the vicinity of the project area
consists primarily of agricultural development and undeveloped forested land.
1.3.2 Topography
The project is located in the coastal plain physiographic region of North Carolina.
Topography in the project vicinity is primarily flat with moderate slopes down to
large river systems. The project area abuts the Lumber River and Cape Fear River
watershed divide, which runs along NC Highway 87 within the project vicinity.
Elevations in the project area range from 125 to 140 feet above mean sea level
(MSL) (Figure 3 — USGS Topographic Map).
1.3.3 Jurisdictional Features
Figure 5 shows the delineated jurisdictional areas evaluated by Kimley-Horn staff
on January 26, 2017, April 6, 2017, and April 14, 2017, and reviewed by US Army
Corps of Engineers (USACE) representative Tom Charles and North Carolina
Division of Water Resources (NCDWR) representatives Jennifer Burdette and
Chad Turlington on March 21, 2017. The jurisdictional delineation was conducted
utilizing the USACE Regional Supplement to the Corps of Engineers Wetlands
Delineation Manual: Atlantic and Gulf Coastal Plain Region (Version 2.0). The
project area is located in the Lumber River Basin, U.S. Geological Survey (USGS)
Hydrologic Unit Code (HUC) 03040203.
Kimley-Horn staff evaluated the larger 154 -acre study area in the initial stages of
the project, and identified 6 wetland features. Wetlands W2, W4, W5, and W6
were all avoided by the proposed project, and a large pocosin wetland system
located west of the project area was also avoided by the project layout.
A Preliminary Jurisdictional Determination (Pre JD) request for the delineation is
included as part of this permit application. Based upon the NCWAM classification
system, the centrally located wetland W1 is classified as a basin wetland (22.6
acres in total size). Additionally, a small headwater forest wetland totaling 0.015
acre in size (W3) is located in the southern portion of the project area. USACE
wetland determination data forms were completed for each of the features

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
identified within the project area as appropriate and are included as part of the
Pre JD request.
No stream features are mapped as occurring in the project area on the most
recent Natural Resources Conservation Service (N RCS) Soil Survey for Bladen
County (Figure 4), or the most recent USGS Topographic Quadrangle Map.
The project area is located just east of the Lumber River and Cape Fear
watershed divide and all waters in the project area drain west toward Goodman
Swamp. Goodman Swamp is a tributary to a larger swamp system called Big
Swamp, which eventually flows into the Lumber River. Goodman Swamp is
classified by NCDWR as a "C, SW" water. Class C waters are protected for
secondary recreational uses, and SW is a supplemental classification for Swamp
Waters. There are no Outstanding Resource Waters or High Quality Waters
located within ten miles of the project area.
The following paragraphs describe the wetlands that were delineated within the
project area and are displayed on the attached Figure 5: Jurisdictional Features
Map.
Wetland W1 is a 22.6 -acre forested basin wetland located in the northwest
portion of the project area. Approximately 10.3 acres of Wetland W1 are located
within the project area, and W1 drains offsite to the west through a manmade
jurisdictional ditch into an offsite wetland, eventually discharging into Goodman
Swamp. Wetland W1 is an elliptical depression that is angled from the northwest
to the southeast, typical of wetland features known as Carolina Bays. Wetland
W1 is generally bowl -shaped, which concentrates surface hydrology to the
central region of the wetland. No standing water was observed in the wetland
fringe, however, water was ponded to depths of 12" in the center of W1.
Hummocks, buttressed trees, and drainage patterns indicate water ponds
throughout the interior of the wetland following storm events. The dominant
trees/shrubs observed at the wetland data form location included loblolly pine
(Pinus taeda), red maple (Acerrubrum), water oak (Quercus nigra), ti -ti (Cyrilla
racemiflora), and sweet bay (Magnolia virginiana). Little to no herbaceous
vegetation was present at the wetland data form location at the time of
delineation, however woody vine species such as laurel greenbrier (Smilax
laurifolia) and common greenbrier (Smilaxrotundifolia) were present throughout
W1.
Wetland W3 is a small 0.015 -acre headwater wetland located in the western
portion of the project area. Hydrology within W3 is supported by groundwater
levels and surface runoff from the adjacent uplands and industrial development.
The wetland was dry at the time of observation, but hydric soil indicators, water
11

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
stained leaves, and a sparsely vegetated concave surface indicate the wetland
pools water frequently. Trees, including red maple and sweetgum (Liquidambar
styraciflua), and various sedges (Carexspp.) were present around the fringe of
wetland W3.
1.3.4 North Carolina Wetland Assessment Method (NCWAM)
In order to evaluate the level of function for the wetland systems within the Site,
the North Carolina Wetland Assessment Method (NCWAM) (Version 5.0) was
utilized. This assessment methodology evaluates the following three major
wetland functions and associated sub -functions: 1) hydrology (surface storage
and retention and sub -surface storage and retention), 2) water quality (pathogen
change, particulate change, soluble change, physical change, and pollution
change), and 3) habitat (physical structure, landscape patch structure, and
vegetation composition).
Functional ratings are applied to each wetland assessment area in comparison to
reference conditions of one of the sixteen North Carolina general wetland types.
Field evaluations of representative wetland assessment areas within each of the
two delineated wetlands were conducted on January 26, 2017, April 6, 2017, and
April 14, 2017. Data collected during this site evaluation, as well as the extensive
data collected during the wetland delineation efforts was utilized as part of the
NCWAM evaluation.
The following table summarizes the results of the NCWAM analysis for the two
wetlands evaluated in the project area. NCWAM data forms are included in
Appendix F.

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Table 1. Summary of NCWAM Results
Wetland
Community
NCWAM
Man-made
Function Rating
Overall
ID
Type
Reference
Alteration/
Summary
Wetland
Wetland
Disturbance
Rating
Type
Mixed
Hydrology — Med.
Basin
W1
Hardwood
Yes
Water Qual. — High
Medium
Wetland
Forest
Habitat — High
Mixed
Hydrology — Med.
Headwater
W3
Hardwood
Yes
Water Qual. — Low
Low
Forest
Forest
Habitat — Low
In summary, the two wetland types observed within the project area were basin
wetland (W1) and headwater forest (W3). The basin wetland was found to have
a "Medium" qualitative rating due to the overall size, connectivity, and relatively
minor disturbance to the wetland interior. The headwater forest wetland within
the project area has a "Low" overall wetland rating due to the small size, lack of
connectivity, and the influence of adjacent development on the wetland system.
The wetlands delineated within the study area, but located outside of the project
area were pocosin wetlands and headwater forest wetlands, however offsite
wetlands were not evaluated using NCWAM.
101

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
1.3.6 Soils
Based on information obtained in the United States Department of Agriculture
(USDA) Natural Resources Conservation Service (N RCS) Soil Survey for Bladen
County, the soils within the project area are composed of nine soil series. Table 2
summarizes the characteristics of each soil series in the project area.
Soils within the project area are well drained (Norfolk, Udorthents, and Wagram
soil series), moderately well drained (Goldsboro soil series), somewhat poorly
drained (Lynchburg and Ocilla soil series), poorly drained (Rains and Woodington
soil series), or very poorly drained mineral (Pantego soil series) soils.
Table 2. Soils within the project Site
Soil Series Name
Map
Symbol
Drainage
Class
Percentage
of Site
Hydric
Status
Goldsboro sandy loam (0-3% slopes)
GbA
Moderately well drained
1.8%
Hydric*
Lynchburg fine sandy loam (0-2% slopes)
LnA
Somewhat poorly drained
2.4%
Non -Hydric
Norfolk loamy fine sand (0-2% slopes)
NoA
Well drained
46.5%
Hydric*
Ocilla loamy sand
Oc
Somewhat poorly drained
2.0%
Hydric*
Pantego loam
Pe
Very poorly drained
2.0%
Hydric
Rains fine sandy loam (0-2% slopes)
RaA
Poorly drained
9.8%
Hydric
Udorthents, loamy
Ud
Well drained
<1%
Non -hydric
Wagram fine sand
WaB
Well drained
28.4%
Hydric*
Woodington loamy sand
Wo
Poorly drained
7.0%
Hydric
*- soils which are primarily non -hydric, but which may contain hydric inclusions
The soils underlying the forested wetland systems in the project area are Rains
fine sandy loam and Wagram fine sand. The existing processing facility is
underlain primarily by Norfolk loamy fine sand with smaller pockets of Goldsboro
sandy loam, Rains fine sandy loam, and Ocilla loamy sand soil series.
1.3.7 Vegetation
The 77 -acre project area is dominated by existing industrial development, but
large areas of undeveloped forest lands are present in the northern and western
ends of the project area. The forested areas in the project area are a mix of basin
wetland areas, headwater forests, and expansive upland pine -dominated forests.
The wetland systems in the project area comprise approximately 3.7% of the
project area.
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Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Brief descriptions of the forested communities, as well as common species
observed in each community type, are provided below.
Basin Wetland
Wetland W1 in the project area is a basin wetland system. The dominant
trees/shrubs observed in the basin wetland on the project area include Loblolly
pine, red maple, water oak, sweetgum, bald cypress (Taxodium distichum), ti -ti,
and loblolly bay (Gordonia lasianthus). The dominant herbaceous plants and
vines include netted chain fern (Woodwardia areolata), laurel greenbrier, and
common greenbrier.
The shape, topography, and general orientation of W1 appear to be consistent
with a Carolina bay, and is surrounded by upland forests of varying widths. A
frequently maintained overhead electric utility corridor runs along the western
boundary of W1. A constructed ditch feature, located north of the study area
and project area but located within the Smithfield property, connects the
interior portion of W1 to the large pocosin wetland system located west of the
project area. The basin wetland on the Site is appears to be seasonally saturated
and intermittently to seasonally inundated with surface water following periods
of high rainfall or in conjunction with a seasonal high water table condition. The
interior depressional portions of the wetland was observed multiple times
inundated to depths of approximately 12 inches, and a high water table (within
12 inches of the surface) was typically observed throughout W1
Headwater Forest
Vegetation was sparse within the headwater forest community. The canopy and
understory species observed within this community consist of loblolly pine, red
maple, and sweetgum. The herbaceous and vine species include sedges (Carex
spp.), laurel greenbrier, and common greenbrier.
The headwater forest system receives hydrology primarily from groundwater,
precipitation events, and overland flows from adjacent uplands. The headwater
forest areas in the project area is subject to ponding following significant
precipitation events.
Pine -Dominated Forest
The dominant trees/shrubs observed in the pine -dominated forest community
on the Site included loblolly pine, red maple, sweet gum, and tulip poplar. The
understory was dominated by various huckleberry species ( Vaccinium spp.).
Areas of pine -dominated forest are present throughout the study area. These
areas are likely remnant pockets that were once managed for silviculture
production but were allowed to revegetate naturally after a clear-cut harvest.
Canopy species observed included loblolly pine, red maple, sweetgum, and tulip

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
poplar. The understory consists of loblolly pine, sweetgum, red maple, tulip
poplar, eastern redcedar, and American holly. Herbaceous and vine species
observed were blackberry, grape vine, common greenbrier, and Japanese
honeysuckle.
1.3.8 CAMA Regulated Areas
The project is located in Bladen County and is therefore not subject to regulation
by the NC Division of Coastal Management (NCDCM) under the Coastal Area
Management Act (CAMA).
1.3.9 Protected Species and Habitat
As of July 21, 2016, the U.S. Fish and Wildlife Service lists seven federally
threatened or endangered species protected under the Endangered Species Act
(ESA) known to occur in Bladen County, including American alligator (Alligator
mississippiensis), northern long-eared bat (Myotis septentrionalis), red -cockaded
woodpecker (Picoides borealis), wood stork (Mycteria Americana), American
chaffseed (Schwalbea americana), pondberry (Lindera melissifolia), and rough -
leaf loosestrife (Lysimachia asperulaefolia). Bald eagle is also known to occur in
Bladen County and is protected by the Bald and Golden Eagle Protection Act
(BGPA). A review of the North Carolina Natural Heritage Program (NCNHP)
database records (updated April 2017), indicates no known occurrences of any
federally -listed species within a one -mile radius of the project area. The formal
NCNHP database record search letter with findings is included in Appendix H.
The American alligator is listed as threatened due to similarity of appearance,
and, therefore, does not require Section 7 consultation with USFWS. Suitable
habitat for American alligator is not present within the study area due to the lack
of perennial features present. In addition, a review of the NCNHP database
records (updated April 2017), indicates no known American alligator occurrences
within a 1.0 -mile radius of the proposed project.
During the agency scoping meeting held on April 11, 2017, Kathy Matthews of
the USFWS explained that surveys for northern long-eared bat (NLEB) have been
conducted on the opposite side of Bladen County. In addition, Kathy advised that
any tree clearing activities associated with the proposed project should take
place outside of the NLEB summer pupping season. Since no known roost trees
or occurrences of NLEB have been recorded in or within 1.0 mile of the project
area and all tree clearing activities will take place outside of summer pupping
season, it has been determined that the proposed will have no effect on this
species.
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Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Habitat evaluations were conducted within the forested portions of the property
for red -cockaded woodpecker (RCW) nesting and foraging habitat in January and
April 2017. The dense understory found within the project area and the large
number of hardwoods precludes these areas from providing suitable nesting
habitat for the RCW. Potentially suitable foraging habitat is located in the
southwestern corner of the project area, however, based on historic aerials, this
area was cleared less than 30 years ago, and the area was found to contain a
dense understory. In addition, the NCNHP database (updated April 2017) has no
records, historical or current, of RCW individuals or cavity trees within one mile
of the proposed project. Based upon this information, it has been determined
that the proposed project will have no effect on the RCW.
Suitable habitat for wood stork is not present within the project area. For
nesting, feeding, and roosting, wood stork requires open freshwater or estuarine
wetlands that are seasonally flooded. The wetlands within the project area are
dense with vegetation and do not pool water long enough to provide an
adequate feeding habitat for wood stork. In addition, the NCNHP database
records (updated April 2017), indicate no known occurrences of wood stork in or
within a 1.0 -mile radius of the proposed project. Based on the lack of suitable
habitat and the lack of known occurrences, it is anticipated that the proposed
project will have no effect on the wood stork.
Suitable habitat for American chaffseed is present along the power line rights-of-
way and the maintained drives located within project area. Kimley-Horn
biologists conducted field surveys of the suitable habitat on May 16, 2017. No
individuals of American chaffseed were observed within the project area. In
addition, the NCNHP database (updated April 2017) has no records, historical or
current, of American chaffseed within 1.0 mile of the proposed project. Due to
the lack of individuals observed and the lack of known occurrences, it has been
determined that the proposed project will have no effect on American chaffseed.
Suitable habitat for pondberry is present within wetland W1 in the project area.
Kimley-Horn biologists conducted field surveys within the area of suitable
habitat on May 16, 2017 and no Lindera species were observed. Additionally, a
review of the NCNHP database records (updated April 2017), indicates no known
occurrences of pondberrry in or within a 1.0 -mile radius to the project area. Due
to the lack of individuals observed and the lack of known occurrences, it has
been determined that the proposed project will have no effect on pondberry.
Suitable habitat for rough -leaf loosestrife is present in the power line rights-of-
way, in the center of wetland W1, and within the ditches along the maintained
drives located within the project area. Kimley-Horn biologists conducted field
surveys within these areas of suitable habitat on May 16, 2017, and no
individuals were observed. In addition, the NCNHP database (updated April
10

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
2017) has no records, historical or current, of rough -leaf loosestrife within 1.0
mile of the proposed project. Due to the lack of individuals observed and the lack
of known occurrences, it has been determined that the proposed project will
have no effect on rough -leaf loosestrife.
1.3.10 Historical and/or Archaeological Sites
The State Historic Preservation Office (SH PO) HPOWeb GIS Service was reviewed
on May 1, 2017 to determine if any historic resources occurred in the vicinity of
the Property. As a result of the SHPO HPOWeb GIS Service review, four historical
resources were listed as occurring within 1.0 -mile of the Property. The Walter
Robeson House (located approximately 5,000 feet north of the Property), the
Robeson -Moore House & Kitchen (located approximately 1,300 feet northeast of
the Property), and the A. Hobson Singletary house (located approximately 1,000
feet south of the property) are all listed as Surveyed Only (SO). The Cape Fear
River Bridge (Gone) 2005 which is located approximately 4,700 feet east of the
property is listed as Determined Eligible, Gone (DOE, Gone). No National Register
(NR) or Study List (SL) historical sites are listed as occurring in or within 1.0 -mile
of the Property. Due to the size and function of the pre-existing facility, it is
anticipated that there will be no impacts to any historical or archaeological sites.
1.3.11 Regulated Floodplain
A search of the North Carolina Floodplain Mapping Program's Flood Risk
Information System (accessed May 1, 2017) indicated that the project site is not
located within a 100 -year floodplain as designated by FEMA Flood Insurance
Rate Map (FIRM) Panel 3720034600K effective January 5, 2007.
1.3.12 Zoning
The project area is situated on property parcels that are currently zoned as an
Industrial District by Bladen County. The proposed project is consistent with the
allowable uses for an Industrial District in accordance with the Bladen County's
Code of Ordinances.
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Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
2.0 Project Description
The project will consist of the construction of an approximately 495,175 square foot cold
storage distribution center (providing approximately 48,000 pallet positions) and associated
truck staging areas connected to the existing Smithfield Foods processing facility. The new cold
storage distribution center will employ approximately 200 additional people when it begins
operations, scheduled for 2018. Currently, pork product processed at the Smithfield facility is
loaded onto trucks and taken to multiple off-site distribution centers for storage prior to its
eventual shipment to clients. The proposed on-site cold storage distribution center would
eliminate trucking the processed product off-site (an approximate 60 truck trip per day
reduction) and eliminate the need for the multiple storage/distribution centers. In addition,
the proposed project would improve employee safety by separating truck traffic from
employee traffic, improve Smithfield Foods' compliance with Food Safety Modernization Act
(FSMA) guidelines, and improve the safety of Smithfield Foods' customers by further separating
raw materials from finished goods. As part of the cold storage distribution center construction,
the following components would be constructed:
• Separate entrance routes for truck/trailer access and automobile access;
• Rack storage and pallet areas for staging finished goods associated with each
zone,
• Refrigerated product loading docks and loaded trailer staging areas;
• Stormwater management basins.
The project is scheduled to be constructed in three parts as shown on Figure 6, with
construction of the initial two sequences (located entirely in uplands) currently underway and
scheduled for completion in 2017. The third and final sequence would construct the cold
storage distribution center and is anticipated to begin within the next year.
2.1 Land Ownership
The current project property parcel is owned by Smithfield Packing Realty Partnership, a
subsidiary of Smithfield Foods, Inc. The property is bounded by NC Highway 87 to the
east, Goodman Swamp to the west, farmland to the north, and forestland to the south.
The project property parcel has been operating as a processing plant since 1991.
The names and addresses of each adjacent property owner are included in Appendix E.
2.2 Construction Sequence
Smithfield Foods plans to construct new blast freezing rooms, palletizing areas, office
space, new cold storage distribution center and associated infrastructure connected to
their existing food processing plant.
12

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
The first addition will be for new blast freezing rooms, palletizing areas and office space.
This construction area does not impact any jurisdictional waters of the U.S. The grading
contractor already has approved erosion control permits for this portion of the work.
Entry roads into the property will be re -paved and utilities will either be relocated
and/or installed as needed.
Following approval/issuance of the Section 404/401 permit, the work will expand to the
entire site layout. Clearing and grubbing will be followed by mass excavation and
preparations for full construction logistics setup.
2018 will see an increase in site personnel as structural construction activities
commence on the remaining buildings, and progress to the distribution center for
architectural, mechanical, electrical, and piping (MEP) activities on the buildings started
in the previous year. Earthwork activities will begin to slow, but logistics support, and
erosion control maintenance will continue throughout the year. Power consumption will
increase during this year as well.
2.3 Proposed Impacts
Impacts to jurisdictional wetlands will be avoided and minimized to the extent practical.
However, permanent impacts to jurisdictional areas will be unavoidable. These
unavoidable permanent impacts within the project area will be necessary for
construction of the project. Impacts necessary for the proposed project total 2.83 acres
of permanent impacts to wetlands. Each permanent impact area is depicted in the
attached Permit Drawings (Appendix XX) and summarized in Table 3.
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Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Table 3. Wetland and Stream Impact Summary
Impact
Feature
Feature Type
Type of
Permanent
Mitigation
Site
ID
Impact
Impact
Ratio
1
W1
Basin
Fill
2.81
2:1
Wetland
2
JD1
Jurisdictional
Fill
0.03
N/A
Ditch
3
W3
Headwater
Fill
0.015
2:1
Forest
Development of the project requires the placement of fill material into wetlands for the
construction of a cold storage distribution center and the corresponding parking lot and loading
bay. Fill would also be required for construction of internal access roads around the new
development connecting the distribution center to NC Highway 87. On-site utility corridors
(water, sewer, electricity) will be located within the limits of disturbance as shown on Figure 6.
No additional wetland impacts will occur as a result of utility encroachments.
2.4 Stormwater Quality Controls
The Smithfield Foods facility is located on a 532 -acre parcel with approximately 128
acres of existing impervious which is 24.1% of the total site area. The proposed project
will add approximately 30 acres of impervious area resulting in a total impervious site
area of 29.7%.
Itemized stormwater management design considerations for the project include:
• The existing site is divided into 2 existing drainage areas discharging from
the site. The basin contributes to a wetland feature located on and off
the site. The site primarily consists of tree covered area and an existing
industrial facility.
• The proposed project will consist of 1 building, new access roads, paved
trailer parking, and trailer weighing stations. All stormwater will be
collected within a stormwater system. Stormwater post -construction
discharge will be reduced to non-erosive velocities utilizing rip -rap aprons
or other best management practices deemed appropriate by the
engineer. The stormwater basin will be designed to hold the 25 -year, 24-
hour storm. Post -construction water quality will be achieved in
accordance within NCDEQ guidelines.
14

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
• During construction, the entire limits of disturbance will be enclosed with
silt fence with temporary diversion ditches to divert stormwater to a soil
erosion and sedimentation BMP. Land disturbance adjacent to existing
wetlands will utilize a minimum double silt fence.
3.0 The Public Need
Foodborne illness is a substantial burden on American citizens. The Food and Drug
Administration (FDA) estimates about 48 million people (or 1 in 6 Americans) get sick from
foodborne illnesses in a given year. Of those 48 million, roughly 128,000 people are
hospitalized, and about 3,000 people die from the illness. In response to this burden, the FDA
proposed the Food Safety Modernization Act of 2011 (FSMA). FSMA works to reduce foodborne
illness through improvements in the food supply chain, including the implementation of new
transportation requirements. The Sanitary Transportation of Human and Animal Food; Final
Rule (81 FR 20091), part of the FSMA, went into effect June 6, 2016. The ruling tasks food
production companies with necessary improvements to both their transportation vessels and
facilities.
The construction of a new cold storage distribution center connected to the existing food
processing facility will allow Smithfield to control the transportation, storage, and distribution
of their produce. Currently, Smithfield transports fresh and case ready pork products to various
storage and distribution centers throughout the region. Involved in this is the loading,
transportation, and unloading of food products —three areas that FSMA has targeted for
improved standards. The new cold storage and distribution center attached to the existing
plant will cut out unnecessary product handling and transporting. By reducing the amount of
handling, Smithfield will be able to better store and distribute food that is safe for consumers
and above and beyond the FDA standards.
15

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
4.0 Project Purpose and Need
Smithfield Foods' purpose is to construct a finished goods cold storage distribution center at
their existing food processing facility to consolidate product distribution for the region. The
project is necessary to increase product distribution efficiency, reduce truck trips/traffic,
improve employee safety, improve food safety, and further separate raw product from finished
goods during the material processing operations as dictated by the Food Safety Modernization
Act.
5.0 Scope of Analysis:
The proposed work will benefit pork consumers across the United States, as well as in the State
of North Carolina, Bladen County, and the Town of Tar Heel by providing jobs and expanding
the local tax base. The primary financial beneficiary of the proposed project would be the
Applicant, Smithfield, a privately -owned corporation. The entirety of the project is anticipated
to be privately funded. In addition to the requirement to obtain a Section 404 permit, the only
other federal involvement in the proposed project is USFWS coordination. There are no
practicable alternatives to the proposed plan that would further avoid or minimize impacts to
waters of the U.S., and meet the Applicant's purpose and need, save the proposed impacts.
6.0 Other Federal, State, and Local Authorizations Obtained or
Required and Pending
Smithfield will obtain all permits and approvals required by federal, state, and local laws and
regulations prior to the construction and operation of the Facility.
6.1 State Water Quality (401) Certification
The NCDWR 401 certification application is submitted concurrent to this 404 permit
application.
6.2 Stormwater Permit
A Stormwater Permit application and accompanying Stormwater Management Plan is
not required by Bladen County. A General Stormwater Permit with NC Department of
Environmental Quality (NCDEQ) is currently on file for the existing property, however
this project will be required to obtain a new General Stormwater Permit with NCDEQ.
16

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
6.3 Sedimentation and Erosion Control Permit
As part of the 401 General Certification requirements, a Sediment and Erosion Control
Plan/Land Disturbance Permit will be required by NCDEQ.
7.0 Project Alternatives/Alternatives Considered
The purpose of the proposed development is to consolidate Smithfield Foods' finished goods
distribution through the construction of a new cold storage distribution center connected to
their largest existing food processing facility in Tar Heel, North Carolina. In addition to
consolidating regional distribution, the project will also create a safer workplace for the
employees by separating truck and automobile traffic, and address items related to the Food
Safety Modernization Act (FSMA). As part of the development process, numerous on-site and
off-site alternatives were analyzed. Based on the factors considered below, Smithfield Foods
has demonstrated there are no practical off-site alternatives that achieve the projects above
stated purposes. Smithfield Foods has also demonstrated that they have reviewed alternative
on-site alignments as well as the environmental consequences of each plan, and that the
proposed alignment (Preferred Alternative) minimizes and avoids the most impacts to aquatic
resources while still meeting the projects purpose and goals.
7.1 Avoidance (No action, uplands, and availability of other sites)
As the largest pork production facility in the world, the processing facility accounts for a
significant amount of packaged pork products in the region. Currently, the products
generated from the facility are being transported away to various third -party
distribution centers, and then transported again to Smithfield Foods' customers. The
addition of a cold storage distribution center tied to the existing processing facility will
have a significant impact on the regional truck traffic generated from this single facility.
In addition to consolidating transportation activities, the expansion will improve
Smithfield Foods' ability to comply with The Sanitary Transportation of Human and
Animal Food, Final Rule (81 FR 20091), a part of the Food Safety Modernization Act
(FSMA). The ruling tasks food production companies with necessary improvements to
both their transportation vessels and facilities. These guidelines will be more easily met
by having the distribution center tied to the existing facility to ensure minimal handling
and transportation of finished goods. Other considerations taken into account in the
development of the project include improving worker and visitor safety by dividing truck
and automobile traffic, and ensuring raw and finished good separation.
7.1.1 No -Action Alternative
The No -Action Alternative means that Smithfield Foods' proposed project would
not be implemented, and the resulting environmental effects from taking no
action would serve as a baseline from which to compare the effects of permitting
the proposed project or an alternative to proceed.
17

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
Smithfield Foods has considered the no action (i.e. no permit required)
alternative which would not result in temporary or permanent impacts to
jurisdictional waters and wetlands. While this would be the least damaging
alternative, it is not practicable, and does not support the project purpose and
need. Therefore, a no -action alternative is not a viable option for the Smithfield
Foods.
With regard to upland -only alternatives on other sites, off-site alternatives
would not meet the Smithfield Food's objective of consolidation of regional
product distribution by having a finished goods Distribution Center located at
their existing food processing facility. Loading and trucking the finished product
to another off-site distribution center for storage and eventual shipment to
clients would be the same process that is currently implemented and would not
support the projects purpose and need.
7.1.2 Off -Site Alternatives
Smithfield currently utilizes off-site alternatives for their distribution. The
product produced by the Tar Heel plant is shipped to multiple storage vendors
who then ship the product to the customer. The main objective of this project is
to consolidate finish goods distribution into one distribution center connected
directly to the processing plant. This will increase food safety, reduce the
inventory footprint, and reduce the number of truck trips from the plant by 60-80
trips per day.
7.1.3 Preferred (Practical) Alternative
The Preferred Alternative is the proposed Smithfield Food alternative. This
alternative incorporates additional wetland minimization measures by relocating
the new truck access drive from north of the existing C.R. England facility to
south of the facility avoiding impacts to Wetland 2 (a 0.72 -acre reduction of
impact). The building expansion remains at 495,175 square feet and the trailer
staging remains at 329 positions. The alternative incorporates approximately 103
of these positions to the to the south of the new DC which helps minimize impacts
to Wetland 1.
The Preferred Alternative layout initially resulted in 4.10 acres of wetland impact.
In order to further minimize impacts to Wetland 1, the width of the driveway isles
within the trailer staging areas to the north of the DC were reduced from 420 feet
to 410 feet, further reducing impacts to Wetland 1 to 3.17 acres. In addition,
when finalizing the Preferred Alternative design, the limits of disturbance for the
trailer staging area with reduced as much as feasible to further minimize impacts
to Wetland 1 and bring the total wetland impact for this alternative to 2.83.
The Preferred Alternative is the proposed Smithfield Foods Expansion
alternative.
IV

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
7.2 Minimization (modified project designs, etc.)
The Applicant has made an effort to avoid and minimize impacts to wetlands on the
project site while still allowing the development to remain operationally functional and
efficient as well as financially feasible. In order to further minimize impacts, the width of
the driveway isles within the trailer staging areas to the north of the DC were reduced
from 420 feet to 410 feet and the limits of disturbance for the trailer staging area with
reduced as much as feasible to further minimize impacts. From the initial site layout,
minimization measures were employed into the project design to reduce the initial
impacts for the Preferred Alternative from 4.10 acres to 2.83 acres.
7.2.1 On -Site Alternatives
The development of the site plan layout was an iterative process based upon
numerous variables, but also including purposeful avoidance and minimization of
impacts to jurisdictional areas to the maximum extent possible.
Site planning evolved quickly with consideration to preliminary discussions with the
regulatory and resource agencies to identify critical areas and design constraints.
Therefore, the site layout incorporated design criteria intended to avoid and
minimize environmental impacts early in the design process. The design criteria
included the following:
• An approximately 495,175 square foot finished goods Distribution Center
(providing approximately 48,000 pallet positions)
• Truck parking/storage at Distribution Center for delivery of finished product
(approximately 226 spaces north of Distribution Center and approximately
103 spaces south of Distribution Center)
• Parking to allow for additional employees and visitors (approximately 260
spaces)
• Restriping and reconfiguration of existing trailer storage areas at the
Processing Facility
• A new truck entrance at the north end of the Site to provide a safe
separation of trucks entering/exiting the Distribution Center from
employee's entrance
• Construction of blast freezers to allow on-site storage of finished product at
Distribution Center
• A new truck entrance at the south end of the Site to provide a safe
separation of live product delivery for processing from finished product
leaving the distribution center
• Stormwater management basins located in an upland areas
19

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
The following table and discussion compares the jurisdictional impacts of the site
alternatives considered in the site design process. The site plan for each alternative,
including the Preferred Alternative, is shown in Appendix A.
Table 4. On -Site Alternatives Considered
Alternative 1 (C1.0 Original Master Plan): This alternative layout was the original
master plan for the Distribution Center (DC) expansion. The building expansion
consisted of 495,175 square feet. The location of the DC building expansion was
established by the existing plant operations and processing flow. The plant's process
begins with raw material at the south end of the plant and the process flows to the
north. Finished goods are palletized at the north end of the plant making this the ideal
location for the new finished goods distribution center. The truck docks for the new
DC were oriented to the north which is the best approach for food safety and
truck/trailer logistics as this clearly separates raw goods from finished goods. The
entire new trailer staging area was positioned north of the DC expansion and
contained 390 trailer spaces. This minimized impact to the existing plant and existing
trailer staging area which was ideal from a manufacturing standpoint as the plant will
need to remain operational during construction.
As part of this project, a new truck access drive will be constructed off of Highway87
in order to separate truck traffic from employee vehicular traffic creating a safer site
for both employees and truck drivers. In this option, the new (north) truck access
drive was located north of the existing C.R. England facility. This location is
preferred as it is located on property that Smithfield currently owns and does not
impact the existing adjacent businesses. This alternative was the best solution from a
20
USACE Jurisdictional
Jurisdictional Water/Ditch
Alternative
Wetlands Impact (acres)
Impact (acres)
Preferred Alternative
4.10/2.83
0.03
Alternative 1
9.26
0.03
(C1.0 Original)
Alternative 2
5.36
0.03
(C2.0)
Alternative 3
6.28
0.03
(C3.0)
Alternative 4
4.58
0.03
(C4.0)
Alternative 1 (C1.0 Original Master Plan): This alternative layout was the original
master plan for the Distribution Center (DC) expansion. The building expansion
consisted of 495,175 square feet. The location of the DC building expansion was
established by the existing plant operations and processing flow. The plant's process
begins with raw material at the south end of the plant and the process flows to the
north. Finished goods are palletized at the north end of the plant making this the ideal
location for the new finished goods distribution center. The truck docks for the new
DC were oriented to the north which is the best approach for food safety and
truck/trailer logistics as this clearly separates raw goods from finished goods. The
entire new trailer staging area was positioned north of the DC expansion and
contained 390 trailer spaces. This minimized impact to the existing plant and existing
trailer staging area which was ideal from a manufacturing standpoint as the plant will
need to remain operational during construction.
As part of this project, a new truck access drive will be constructed off of Highway87
in order to separate truck traffic from employee vehicular traffic creating a safer site
for both employees and truck drivers. In this option, the new (north) truck access
drive was located north of the existing C.R. England facility. This location is
preferred as it is located on property that Smithfield currently owns and does not
impact the existing adjacent businesses. This alternative was the best solution from a
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Smithfield Foods Expansion Project
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manufacturing and logistic standpoint. Food safety is addressed by clearly separating
raw and finished goods, truck traffic is rerouted to create a safer traffic flow and does
not impact adjacent businesses, and impacts to the existing facility are minimized.
However, this alternative created the greatest impacts to the wetland areas.
Jurisdictional impacts associated with the new trailer staging lot resulted in 8.54 acres
and an additional .72 acres of Jurisdictional wetlands were impacted by the new truck
access drive. The total impact to Jurisdictional wetlands by this alternative was 9.26
acres. Further wetland avoidance measures were employed for the Preferred
Alternative reducing the jurisdictional wetland impacts by more than 4.0 acres.
Alternative 2: This alternative looked at a reorientation of the facility so that the dock
and dock doors for the new distribution warehouse would face to the south. The
building remained at 495,175 square feet. The new truck access drive remains
located north of the existing C.R. England facility and impacts wetland 42. As a
result of locating the docks to the south, additional trailer staging spots were added to
the south side of the facility. This allowed for a reduction of trailer staging spots to
the northside of the building which helped minimize impacts to wetland 41. In
addition, Smithfield reevaluated the required number of trailer staging positions and
reduced the need to 329 positions. This further reduced the wetland impacts.
Jurisdictional impacts associated with the new trailer staging lot resulted in 4.64 acres
and an additional .72 acres of Jurisdictional wetlands were impacted by the new truck
access drive for a total of 5.36 acres of jurisdictional wetland impacts. While this
alternative succeeds in reducing wetland impacts, there are major logistic and food
safety issues that are created as a result of the layout. With the docks facing south,
there is not a clear separation of raw and finished goods. Raw goods will be staged
and received via the existing truck docks. The new DC will ship finished goods from
the new docks.
In this alternative, the raw and finished goods are now received/shipped in the same
location. In addition, raw and finish good trailers would be intermingled creating an
additional food safety hazard. One of the major goals of this project was to increase
food safety by clearly separating raw and finished goods within the building and on
site. Laying out the new DC with the docks to the south does not accomplish this
goal. There are also logistic issues with this layout. With the new docks facing
south, all loading & unloading will be done in the same area. This would create
major traffic issues on the site as the facility will be handling approximately 400
trucks per day. Because of these logistic and food safety issues, it was determined
that this alternative would not be a viable option. The Preferred Alternative
incorporates some of the impact minimization efforts integrated within this alternative
while also meeting the project goals of a safer, more logistically efficient site.
Alternative 3: This alternative was another look at orienting the facility differently
on the site. In this alternative, the building was rotated 90 degrees with the new
docks facing west. The building remained at 495,175 square feet. The new truck
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Smithfield Foods Expansion Project
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access drive remains located north of the existing C.R. England facility and impacts
wetland 42. As a result of locating the docks to the west, the additional trailer staging
area was added to the west side of the new DC instead of the north. Smithfield
reevaluated the required number of trailer staging positions and reduced the need to
329 positions. The location of the new DC remains to the north for the reasons
discussed in the Alternate 41 summary and the connection to the existing plant is
minimal to limit disruption during construction. This option resulted in a reduction of
jurisdictional impacts when compared to Alternate 41 but more than Alternate 42.
Furthermore, in this option, both the DC addition and the trailer staging area create
jurisdictional impacts. Jurisdictional impacts associated with the new trailer staging
area and the DC expansion resulted in 5.56 acres and an additional .72 acres of
Jurisdictional wetlands were impacted by the new truck access drive for a total of
6.28 acres of jurisdictional wetland impacts. While this alternative is practical, if fails
to further reduce the wetland impacts over Alternative 42, does not separate raw and
finish goods as well as Alternative 41, and traffic flow is not as functional. Because
of these factors, this Alternative was not a reasonable solution compared to the
Preferred Alternative which further reduces impacts and better achieves the projects
goals.
Alternative 4: This alternative layout is a similar layout to Alternative 41 but
incorporates some of the wetland impact reduction measures designed into
Alternative 42. In this alternative the docks are oriented north with the trailer staging
lot located north of the docks. The building remained at 495,175 square feet. The
new truck access drive remains located north of the existing C.R. England facility and
impacts wetland 42. Smithfield reevaluated the required number of trailer staging
positions and reduced the need to 329 positions. In addition, approximately 103
positions have been incorporated to the south of the new DC which helped minimize
the wetland impacts. Staging spaces to the north were reduced to 171 spaces. The
rest of the staging positions, 55 in total, were located south of the new DC in an open
area adjacent to the water treatment plant. This was an attempt to further reduce
wetland impacts, however thru the wetland delineation process, it was discovered that
this area is also a wetland (noted on the plans as wetlands 43 & 44). Therefore,
impacts were not reduced. Jurisdictional impacts associated with the new trailer
staging lot to the north resulted in 2.6 acres. Impacts associated with the relocation of
trailer positions to the south resulted in 1.26 acres and an additional .72 acres of
Jurisdictional wetlands were impacted by the new truck access drive for a total of
4.58 acres of jurisdictional wetland impacts. Locating the additional trailer staging
positions to the south near the water treatment facility is problematic and still resulted
in wetland impacts, therefore this alternative is not a practical alternative compared to
the preferred alternative with further reduces wetland impacts and achieves the
project goals.
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7.2.2 On -Site Minimization of Unavoidable Impacts
In addition to modifying the general layout of the site, the Applicant has also
implemented the following measures to minimize unavoidable impacts.
Relocation of the new truck access drive from north of the existing C.R.
England facility to south of the facility avoiding impacts to Wetland 2 (a 0.72 -
acre reduction of impact)
• Reducing the width of the driveway isles within the trailer staging areas to the
north of the DC from 420 feet to 410 (a 0.83 -acre reduction of impact).
• Reducing the limits of disturbance associated with the trailer staging areas to
the maximum extent feasible (a 0.27 -acre reduction of impact).
7.3 Conclusion of Alternatives Analysis
The Applicants have provided information regarding the site selection process. This
analysis demonstrates that there are no off-site alternatives that would meet the
project purpose and need and result in reduced impacts to waters of the U.S. The
Applicants have also addressed on-site alternatives for the facility, including a discussion
of the limitations to the site design process, such as product distribution efficiency,
employee safety, food safety, and site separation of raw product from finished good as
dictated by the Food Safety Modernization Act. The evaluation has also addressed
alternative site configurations and efforts make by the Applicants to minimize impacts
to wetlands, and to attempt to locate unavoidable impacts in areas that support the
least aquatic functions. After reviewing the alternatives and the efforts made to avoid
and minimize impacts to the aquatic environment, the proposed plan represents the
least damaging practicable alternative.
8.0 Mitigation
Jurisdictional Wetlands
The proposed project will result in 2.81 acres of permanent impact to jurisdictional
basin wetlands and 0.015 acres of permanent impacts to forested headwater wetlands.
Permanent impacts will be associated with the parking lot and staging area, the interior
transportation network of the project, and the associated grading footprint.
Kimley-Horn staff conducted a field evaluation of the wetlands identified within the
project area using NCWAM to evaluate wetland functions and recommend appropriate
mitigation for unavoidable impacts to wetlands. The method utilizes a qualitative
assessment of departure from reference condition for the evaluated wetland complex.
In summary, the two wetland types observed within the project area were headwater
forest wetlands (W3) and a basin wetland (W1). The headwater forest wetland within
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Smithfield Foods Expansion Project
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the project area has a "Low" overall wetland rating due to its small size, man-made
disturbance, and lack of hydrologic function. The basin wetland W1 has "Medium"
ratings due to its overall size and minimal disturbance to the wetland interior.
Due to the relative wetland size and position within the watershed, a 2:1 mitigation
ratio will be applied to offset unavoidable impacts to all wetlands within the project
area. With a 2:1 mitigation ratio, the proposed project requires a total of 0.03 acre of
riparian wetland mitigation credits and 5.62 acres of non -riparian wetland mitigation
credits. However, the DMS calculates fees for wetland mitigation credits in quarter -acre
increments and there is a flat fee for each increment of 0.25 acres. Therefore, the total
wetland mitigation credits that are proposed to be purchased for the project through
the ILF program is 0.25 acre of riparian wetland mitigation credits, and 5.75 acres of
non -riparian wetland mitigation credits.
Smithfield Foods has requested an in -lieu fee payment from DMS due to the lack of
private mitigation banks located in the primary, secondary, or tertiary service areas, the
anticipated credit need for this project, and the expected timeline for permit review.
DMS has accepted Smithfield Food's request for in -lieu fee payment for up to 6.5 acres
of non -riparian wetland mitigation credits and 0.25 acre of riparian wetland mitigation
credits.
9.0 Evaluation of the 404(b)(1) Guidelines:
9.1 Factual determinations
9.1.1 Physical substrate
The project area is composed primarily of mixed pine and hardwood forests
interspersed with utility easements and development. The majority of the
forested areas within the project boundaries are upland forests that have
historically been altered by activities on the property. Approximately 5.32 acres
of wetland would be filled to construct the proposed project. Impacts would be
primarily associated with the parking lot and building footprints and aprons. In
these areas, unsuitable substrates would be excavated prior to the placement of
clean fill capable of providing suitable compaction for the building and parking
lot foundations. In all areas where fill would be placed, the existing elevation
would be increased. Sedimentation and erosion control measures would be
utilized to limit the displacement of sediment downstream.
9.1.2 Water circulation, fluctuation, and salinity
The proposed project should have no appreciable effect on current, circulation,
or drainage patterns. Fill within wetland W3 will have a minor effect on the
water circulation and fluctuation of the small headwater system. Wetland W3
has historically been altered and mostly hydrologically disconnected from
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Smithfield Foods Expansion Project
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downstream waters, and the proposed impacts would not greatly change the
function of the headwater system as a whole.
The project is situated along the Cape Fear and Lumber River watershed divide.
The wetland systems within the project area are upper headwater systems to
the Goodman Swamp. There are no upstream features present, so potential off-
site flooding upstream of the filled areas should not be a concern. The wetland
impact is not substantial given the size of the wetland systems present within
the project area. The loss of floodwater retention capacity of the wetlands would
be offset by the installation of stormwater detention basins, such that the
project would not result in a measurable decrease in overall floodwater
retention. In general, the discharge of stormwater from the project would be
regulated to prevent large spikes in volume following most rainfall events. Large
storms in excess of the 100 -year storm event may exceed the storage capacity of
the basins and result in increased flows downstream of the site. Water chemistry
may also be changed somewhat from existing levels. Additionally, the increase in
impermeable surfaces may result in increased temperatures in stormwater
runoff.
9.1.3 Suspended particulate/turbidity
The project -specific sedimentation and erosion control measures that will be
utilized during construction will minimize downstream sedimentation. The
majority of turbidity increases would likely result from the clearing and
construction of upland areas. Sediment loss would be minimized by the
implementation of sediment and erosion control measures. Once construction of
the project is complete, the soils would be stabilized, revegetated, and
stormwater runoff would be directed to detention and treatment basins.
Accordingly, the effects of turbidity resulting from the proposed undertaking are
expected to be temporary and minor.
9.1.4 Contaminant availability
Historically, the project area has supported agricultural uses, which likely
included the application of numerous herbicides and pesticides. Additionally, a
historic railroad ran along the existing power line easement on the western
boundary of the project area. In 1991, Smithfield converted the agricultural
fields to a food processing facility. The forests located to the west of the food
processing facility have been historically logged, but have remained mostly intact
over the last 50 years. Proposed uses for the project area would result in the
potential discharge of some pollutants typical of construction and maintenance
associated with paved lots. In general, the level of potential contaminant
introduction to the aquatic systems is low. Contaminants would leave the project
area in the initial runoff for up to a 100 -year storm event, where they would
wash to the stormwater detention basin. Additionally, only suitable earthen
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Smithfield Foods Expansion Project
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material originating on-site, which should be free of toxic pollutants or
contaminants, would be used for construction of the permitted fills.
9.1.5 Aquatic ecosystem effects
The direct effects due to the placement of fill associated with the project would
be a total loss to the impacted aquatic ecosystem and its functions in the
footprint of the fill placement. Wetland W3 would be filled and would no longer
be able to provide nutrient filtration, sediment removal, or stormwater storage.
Any aquatic habitat present within the wetland area would be lost. Portions of
wetland W1 within the project area would be filled and the wetland may lose
some storage capacity. The secondary short-term effects expected downstream
would primarily be limited to temporary discharges of sediment during
construction. Even with proper construction and maintenance, sediment control
measures do not eliminate all turbidity in receiving waters, though these effects
should be limited to the duration of site construction and maintenance of
required sediment and erosion control measures.
9.1.6 Proposed disposal site
No disposal sites are required by the proposed plans.
9.1.7 Cumulative effects
For the purposes of assessing cumulative effects that the proposed action may
have to the aquatic environment, it is reasonable to evaluate the effects within
the project boundaries and downstream of the project as it could affect the
watershed. The direct impact of the proposed construction includes the loss of
0.015 acres of jurisdictional riparian wetland and 2.81 acres of jurisdictional non -
riparian wetlands. The impacts to these resources would result in a complete
loss of function, including water quality functions (nutrient sequestration,
sediment filtration, etc.), habitat for aquatic and terrestrial species, and
hydrology (flood water attenuation, groundwater recharge, etc.).
The proposed project is located in an area that is relatively rural, with a mix of
industrial development, low-density residential areas, and agricultural land uses.
The project area contains a portion of the headwater systems flowing to
Goodman Swamp at the top of the Lumber River watershed. Current stresses on
Goodman Swamp come from high sediment loads and nutrient inputs that come
from agricultural land use (resulting from the constant tilling of soils, and the
addition of pesticides and fertilizers), as well as development for commercial
industrial and residential uses. The potential cumulative effects on the aquatic
environment generated by the project would be both temporary and
permanent. The temporary effects would primarily be limited to the increased
sediment load that result from ground disturbance. High sediment loads can
cause changes to the channels capacity, potential destabilization of the stream
banks, and loss of aquatic habitat. The potential for sediment discharges would
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Smithfield Foods Expansion Project
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last for the duration of project construction, though the effects of the sediment
may be long lasting. This effect can be moderated by the proper installation and
maintenance of erosion control measures.
Stormwater discharge from the proposed project would not affect downstream
properties or the natural environment. All stormwater falling on the construction
site will be collected within the stormwater system and conveyed to the
proposed stormwater basin within the project area, which is designed to hold
the 100 -year storm event post -construction. The final project conditions will
result in post -construction runoff rates below that of pre -construction
conditions. All velocities (ditch, swale and outlet) during construction and post -
construction will be non-erosive. Rip rap dissipater pads will be utilized at outlets
to promote diffuse flow and ensure non-erosive velocities.
The long-term cumulative effects could include the incremental loss of aquatic
function provided by the wetlands within the project area, including sediment
and nutrient filtration, stormwater retention, baseflow maintenance,
groundwater recharge, sediment transport, etc. The long-term effects would also
include increases in stormwater flowing off the site. Increased stormwater can
have a substantial effect on a stream system's stability and functional integrity
for miles downstream of a discharge. This effect can also manifest itself over
many years, and is often caused by numerous small changes within a watershed.
The proposed development plan includes the construction of a stormwater
detention basin, designed to capture up to the 100 -year storm event within the
contributing basin. These measures can substantially reduce the effect of
stormwater on downstream tributaries. As the watershed is still largely rural, the
cumulative effect of the proposed project and other similar projects is still
minimal. Proper implementation of sediment and erosion control measures and
stormwater management practices, as proposed by the current plans, is the best
way to minimize the cumulative impact of this type of development.
Overall, the anticipated effects of the proposed project would be minimal
relative to similar types of projects in the region, and taken alone, do not present
a significant or imminent threat to the stability and integrity of the aquatic
ecosystem within the watershed. The type of wetland system that would be
impacted is not a particularly unique or high quality resource. By implementing
proposed best management practices, such as the retention of stormwater and
the implementation of sediment and erosion control measures, the effects of the
project could be somewhat reduced. The loss of wetland function would also be
replaced by the proposed mitigation.
9.1.8 Secondary effects
The proposed project is designed to serve as a sustainable, practical means of
storing and staging Smithfield food products. The proposed project will reduce
the carbon footprint generated from running trucks back and forth between cold
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Smithfield Foods Expansion Project
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storage facilities and the existing processing plant. The project is expected to
provide an economic boost to the local community, primarily in the form of tax
revenues and job creation. Based on the type and number of jobs created, the
economic benefit is expected to go toward meeting current job demand as well
as contributing to a moderate regional population growth.
Based on the factors discussed above, the cumulative effect of the proposed
undertaking does not pose a significant threat the integrity of the aquatic
environment. Additionally, the secondary impacts resulting from the proposed
plans are primarily limited to increased development pressure on neighboring,
undeveloped tracts of land. Based on this estimate, the overall secondary effects
on aquatic resources associated with this project are not more than minimal.

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
10.0 Public Interest Review
10.1 Public Interest Factors
10.1.1 Conservation
The proposed development does not include the permanent conservation of any
wetlands on site. The mitigation payment to the DMS would be used to restore
and preserve wetland areas elsewhere in the Lumber River Basin.
10.1.2 Economics
The proposed project will expand Smithfield's ability to produce and deliver pork
products.
• Reduced truck trip costs
• Meeting demand of pork products
• Reduced need of offsite warehouse
• 200 new jobs
• Private investment
10.1.3 General environmental concerns (33CFR320.4(p))
The overall impact to the environment as a result of the construction would be
minimal. Temporary increases in sediment, construction noise, traffic levels, etc.,
would be expected during construction of the project. Long-term impacts to
wetlands, streams, and fish and wildlife would primarily result from the loss of
existing aquatic and terrestrial habitat and by changes to the watershed, though
these effects would be somewhat offset by functions provided by the
stormwater facility and by the mitigation offered by the Applicant. Stormwater
generated by the increases in impervious surfaces would be retained on-site,
preventing potential negative impacts to persons living or owning land within the
floodplain downstream of the project. The property is currently owned by
Smithfield and the surrounding region is not occupied by any particular minority
or ethnic group, so the proposed activity should not lead to environmental
justice concerns.
10.1.4 Wetlands (33CFR320.4(b))
There is a total of 15.32 acres of jurisdictional wetlands within the delineation
study area. The proposed project would result in the loss of 2.81 acres of basin
wetland and 0.015 acre of headwater forest wetland, which currently provide
nutrient filtration, sediment removal, and aquatic habitat. Smithfield Foods
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Smithfield Foods Expansion Project
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proposes to mitigate for permanent impacts to jurisdictional wetlands associated
with the cold storage distribution center by requesting an in -lieu fee payment of
0.25 acre of riparian wetland mitigation credits and 6.5 acres of non -riparian
wetland mitigation credits from the NC Department of Mitigation Services
(DMS). However, the proposed project is anticipated to only need 0.25 acres of
riparian wetland mitigation credits and 5.75 acres of non -riparian wetland
mitigation credits due to revisions to the proposed project area made after the
mitigation credits were requested from DMS.
Some of the lost wetlands functions, such as the nutrient and sediment filtering
capabilities, would also be replaced by construction of the on-site stormwater
treatment facility.
10.1.5 Historic and cultural resources (33CFR320.4(e))
Based on a review of the SHPO HPOWeb GIS Service, there are no known or
suspected historic or cultural resources located within the Property. In addition,
due to the size and function of the pre-existing facility, it is anticipated that there
will be no impacts to any surrounding historical or archaeological sites.
10.1.6 Fish and wildlife values (33CFR320.4(c))
The project would not be expected to result in more than minimal permanent
adverse effects to fish or wildlife values. During construction, it is likely that
some aquatic and terrestrial animals would be displaced, along with their
habitat. The types of habitats within the Project Area include headwater forest
wetlands, a basin wetland, forested upland areas, and maintained rights-of-way.
The proposed plans have relatively minimal impacts to a historically altered and
discontinuous wetland.
As of July 21, 2016, the USFWS lists seven federally threatened or endangered
species protected under the ESA known to occur in Bladen County, including
American alligator (Alligatormississippiensis), northern long-eared bat (Myotis
septentrionalis), red -cockaded woodpecker (Picoides borealis), wood stork
(Mycteria americana), American chaffseed (Schwalbea americana), pondberry
(Lindera melissifolia), and rough -leaf loosestrife (Lysimachia asperulaefolia). Bald
eagle is also known to occur in Bladen County and is protected by the Bald and
Golden Eagle Protection Act (BGPA). A review of the North Carolina Natural
Heritage Program (NCNHP) database records (updated April 2017) indicates
there are no known occurrences of any of the aforementioned species within a
one -mile radius of the Project Area.
The American alligator is listed as threatened due to similarity of appearance,
and, therefore, does not require Section 7 consultation with USFWS. Suitable
habitat for American alligator is not present within the study area due to the lack
of perennial features present. In addition, a review of the NCNHP database
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records (updated April 2017), indicates no known American alligator occurrences
within a 1.0 -mile radius of the proposed project.
During the agency scoping meeting held on April 11, 2017, Kathy Matthews of
the USFWS explained that surveys for northern long-eared bat (NLEB) have been
conducted on the opposite side of Bladen County. In addition, Kathy advised that
any tree clearing activities associated with the proposed project should take
place outside of the NLEB summer pupping season. Since no known roost trees
or occurrences of NLEB have been recorded in or within 1.0 mile of the project
area and all tree clearing activities will take place outside of summer pupping
season, it is unlikely that the proposed will have any effect on this species.
Habitat evaluations were conducted within the forested portions of the property
for red -cockaded woodpecker (RCW) nesting and foraging habitat in January and
April 2017. The dense understory found within the project area and the large
number of hardwoods precludes these areas from providing suitable nesting
habitat for the RCW. Potentially suitable foraging habitat is located in the
southwestern corner of the project area, however, based on historic aerials, this
area was cleared less than 30 years ago, and the area was found to contain a
dense understory. In addition, the NCNHP database (updated April 2017) has no
records, historical or current, of RCW individuals or cavity trees within one mile
of the proposed project. Based upon this information, it has been determined
that the proposed project will have no effect on the RCW.
Suitable habitat for wood stork is not present within the project area. For
nesting, feeding, and roosting, wood stork requires open freshwater or estuarine
wetlands that are seasonally flooded. The wetlands within the project area are
dense with vegetation and do not pool water long enough to provide an
adequate feeding habitat for wood stork. In addition, the NCNHP database
records (updated April 2017), indicate no known occurrences of wood stork in or
within a 1.0 -mile radius of the proposed project. Based on the lack of suitable
habitat and the lack of known occurrences, it is anticipated that the proposed
project will have no effect on the wood stork.
Suitable habitat for American chaffseed is present along the power line rights-of-
way and the maintained drives located within project area. Kimley-Horn
biologists conducted field surveys of the suitable habitat on May 16, 2017. No
individuals of American chaffseed were observed. In addition, the NCNHP
database (updated April 2017) has no records, historical or current, of American
chaffseed within 1.0 mile of the proposed project. Due to the lack of individuals
observed and the lack of known occurrences, it has been determined that the
proposed project will have no effect on American chaffseed.
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Suitable habitat for pondberry is present within wetland W1 in the project area.
Kimley-Horn biologists conducted field surveys within the area of suitable
habitat on May 16, 2017 and no individuals were observed. Additionally, a
review of the NCNHP database records (updated April 2017), indicates no known
occurrences of pondberrry in or within a 1.0 -mile radius to the project area. Due
to the lack of individuals observed and the lack of known occurrences, it has
been determined that the proposed project will have no effect on pondberry.
Suitable habitat for rough -leaf loosestrife is present in the power line rights-of-
way, in the center of wetland W1, and within the ditches along the maintained
drives located within the project area. Kimley-Horn biologists conducted field
surveys within these areas of suitable habitat on May 16, 2017, and no
individuals were observed. In addition, the NCNHP database (updated April
2017) has no records, historical or current, of rough -leaf loosestrife within 1.0
mile of the proposed project. Due to the lack of individuals observed and the lack
of known occurrences, it has been determined that the proposed project will
have no effect on rough -leaf loosestrife.
10.1.7 Flood hazards
The proposed Project Area is located in areas determined to be outside the 0.2%
annual chance flood hazard area (Zone X) according to the FEMA FIRM Panel
3720034600K effective January 5, 2007. The project would not be expected to
have an impact on the overall hazard of flooding downstream of the Property.
The proposed development would result in increases to impervious surface
within the watershed, but this increase would be offset by the retention of
stormwater originating on-site in the proposed stormwater detention basin.
Additionally, the project is located at the upper end of the watershed and
outside of any flood hazard zones mapped on the FIRM panels, so there is
minimal risk of causing flooding upstream of the proposed project site.
10.1.8 Floodplain values (33CFR320.4(I))
Pursuant to Executive Order 11988, consideration has been given to the effect of
the proposed project toward reducing the risk of flood loss, minimizing the
impact of floods on human safety, health and welfare, and restoring and
preserving the natural and beneficial values served by floodplains. The proposed
Project Area is located outside of the 0.2% annual chance flood hazard area
(Zone X) according to the FEMA FIRM Panel 3720034600K effective January 5,
2007
The project would result in the conversion of a portion of the Study Area to
impervious surface. Stormwater generated by the project would be directed to a
detention basin, to be constructed in compliance with state guidelines for
stormwater management. Stormwater discharge will approximately maintain
natural drainage to the local watershed, limiting potential impacts to
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downstream systems. Accordingly, the project should not result in measurable
impacts to the functions or value of these areas.
10.1.9 Land use
The proposed expansion would result in the conversion of some forested areas
to industrial development. While this would be a major shift in land use, the
project would remain consistent with the existing facility, local zoning
requirements. The project would be located immediately adjacent to the existing
Smithfield processing facility in a property parcel that is currently zoned as an
industrial district along the NC Highway 87 corridor.
10.1.10 Navigation (33CFR320.4(o))
The project is located on non -navigable waterways. Accordingly, consideration of
the project's effect on navigation is not applicable.
10.1.11 Shore erosion and accretion
No ponds, lakes, or other such features are located on the proposed project site.
Therefore, shore erosion and/or accretion would not occur as a result of the
project.
10.1.12 Recreation
The proposed site currently has limited use for recreation, and the proposed
facility would have limited access to the public due safety and security concerns
related to the nature of the facility. The proposed project would not be intended
to provide recreational activities to the surrounding community. Overall, the
proposed project is not anticipated to affect regional recreational opportunities.
10.1.13 Water supply (33CFR320.4(m))
The proposed expansion does not include any additional processing but rather
refrigeration storage/distribution. No new wells are proposed as a result of this
expansion and water withdrawl will be minimal. The storage/distribution center
will utilize approximately 90% recycled water with the only anticipated
additional new water usage associated with the eleven proposed employee
restrooms.
10.1.14 Water quality (also 33CFR320.4(d))
No major impacts to water quality are expected. Temporary increases in
turbidity during construction, loss of nutrient removal capacity of the filled
wetlands, and some discharge of pollutants and nutrients in the runoff could
result. It is anticipated that the proposed construction of stormwater treatment
facilities on site should offset long-term impacts by removing sediments,
nutrients, and other pollutants from treated stormwater, and by attenuating
33

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
peak flows downstream. The NCDWR will review the proposed plans as part of
the Individual Section 401 Water Quality Certification prior to construction of the
project. The stormwater plan for the facility will also be reviewed and approved
by Bladen County prior to Site Plan approval.
10.1.15 Energy needs (33CFR320.4(n))
The proposed project would result increase demand from the local electrical
grid. For this reason, an electrical mini -substation would be constructed as part
of the proposed project to help alleviate demand through the existing
infrastructure in the area. In addition, Smithfield intends to reduce their energy
consumption by investing in an energy saving refrigeration system for the
distribution center.
10.1.16 Safety
The project has been designed to improve safety for both Smithfield employees
and the public. By constructing separate truck and automobile entrance ways,
Smithfield will greatly increase the traffic safety on site. Through the reduction of
handling and consolidation of storage, Smithfield Foods can also ensure a more
controlled product will be distributed to consumers. In addition, during
construction of the project, all applicable safety standards would be observed.
10.1.17 Food and fiber production
The project area currently exists as a mix between forestland and developed
land. The project would not remove any land from food or fiber production.
10.1.18 Mineral needs
The project has not historically been used for the production of mineral
products, so consideration of mineral needs is not applicable.
10.1.20 Considerations of property ownership
Adjacent landowners may be affected as a result of project construction
activities. It is possible that adjacent landowners may experience increased noise
and temporary traffic patterns along NC Highway 87. However, the use of the
land would be consistent with the designated zoning, the existing industrial
facility, and the owner's right to reasonable, private use of their land.
34

Smithfield Foods Expansion Project
Tar Heel, Bladen County, North Carolina
11.0 Indirect and Cumulative Impacts
TO BE COMPLETED
35

FIGURES

'Gro
Legend
Project Area
Tar Heel
Bladen County
10 2,000 4,000
Feet
DI
Cree/r
Kentucky � CUMBERLAND
Virginia SAMPSON
��_ Project Location
Tennessee
Bladen County
North
arolin,
South
CarolinaAtlantic Ocear
Georgia
A
40 80
mw= Miles
Kimley>»Horn
BLADEN
COLUMBUS
0 6 12
Iles
Figure 1: Vicinity Map
Smithfield Foods Expansion
Bladen County, NC

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O
Figure 2: Aerial Map
(NC Orthoimagery Program, 2013)
Smithfield Foods Expansion
Bladen County, NC

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Figure 3: USGS Topographic Map
Kimley>>> Horn (Duart and Tar Heel Quads, 1986)
Smithfield Foods Expansion
Bladen County, NC

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Pe Pantego loam Hydric
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Wo 1woodingtonloamy sand Hydric
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Figure 4: NRCS Soil Survey Map
Kimley>>> Horn (Bladen County, 1990)
Smithfield Foods Expansion
Bladen County, NC

Legend
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C3 Wetlands
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vg%
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Figure 5: Jurisdictional Features Map
Smithfield Foods Expansion
Bladen County, NC

APPENDIX A
ON-SITE
PROJECT ALTERNATIVES

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APPENDIX B
SITE PHOTOGRAPHS

LIA
m`e-.r tK"•� s L �'
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AN
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Photo 5 — View of the western boundary of Wetland W2 bounded by a utility easement.
Photo 6 — View of the northern boundary of Wetland W3. Note the lack of water stained leaves present
in the upland pine forest.
Smithfield Foods Expansion Page 3 of 7 Kimley>» Horn
Bladen County, North Carolina

"'fii
d . r ) i 1` y T7
°F is Nlz 9�

vS _
I .a � •C
}
i

Photo 13 — View of Jurisdictional Ditch 1 (JD 1) looking out of Wetland W1 towards the existing
facility.
Photo 14 — View of Jurisdictional Ditch 2 (JD2) looking south from the origin within the Study Area.
Smithfield Foods Expansion Page 7 of 7 Kimley»Horn
Bladen County, North Carolina

APPENDIX E
ADJACENT PROPERTY
OWNERS AND ADDRESSES

APPENDIX E
ADJACENT PROPERTY PARCELTABLE
A. ID
1
PIN
35600779915
ZONING
1
NAME 1
DUNN TOMMY LEE
NAME 2
ADDRESS
335 OUR WAY
CITY
LINDEN
STATE
NC
ZIP
28356
2
35600727451
RA
FOUR COUNTY ELECTRIC CORP
PO BOX 667 SUB STATION
BURGAW
NC
28425
3
35600812169
1
FOUR COUNTY ELECTRIC MEMBERSHI
P COR
PO BOX 667
BURGAW
NC
28425
4
35600887143
1
SMITHFIELD PACKING REALTY
PARTNERSHIP
2800 POST OAK BLVD SUITE 4200
HOUSTON
TX
77056
5
35600957605
RA
WOODELL DIANE
16246 NC 87 HWY W
TAR HEEL
NC
28392
6
35600674219
1
CANADY PATRICK M
PO BOX 11408
WILMINGTON
NC
28404-1408
7
35600945742
RA
TERRY JOSETTE MARIE
4101 UPLAND WAY
GARLAND TEX
AS
75042
8
35600945398
RA
TERRY JOSETTE MARIE
4101 UPLAND WAY
GARLAND TEX
AS
75042
9
36600056883
RA
JACKSON MICHAEL &
JACKSON TERESA R
7350 NC 131 HWY
BLADENBORO
NC
28320
10
36600058881
RA
GARNER ROBERT L &
GARNER RITA S
15938 NC 87 HWY W
TAR HEEL
NC
28392
11
36600134104
RA
EDGE MARY BETH &
STOUT VAN MARTIN
16224 NC 53 HWY W
WHITE OAK
NC
28399
12
35600856419
1
CAROLINA COLD STORAGE LIMITED
PART
4808 RADFORD AVE
RICHMOND
VA
23230
13
35600446116
RA
MARY S EDGE -TRUSTEE FOR VAN ST
OUT
16224 NC 53 HWY W
WHITE OAK
NC
28399
14
35600950511
RA
WOODELL DIANE
16246 NC 87 HWY W
TAR HEEL
NC
28392
15
35600952334
RA
WOODELL MARK L
WOODELL SHANNON
16324 NC HWY 87
TAR HEEL
NC
28392
16
35600936607
RA
GARNER ROBERT L &
GARNER RITA S
15938 NC 87 HWY W
TAR HEEL
NC
28392
17
35600935155
RA
GARNER RITA S
15938 NC 87 HWY W
TAR HEEL
NC
28392
18
35600816293
1
SMITHFIELD PACKING REALTY
PARTNERSHIP
2800 POST OAK BLVD SUITE 4200
HOUSTON
TX
77056
19
36600134104
RA
EDGE MARY BETH &
STOUT VAN MARTIN
16224 NC 53 HWY W
WHITE OAK
NC
28399
20
NODATA
NODATA
NODATA
NODATA
NODATA
21
35500596274
RA
BENSON B EJR PROPERTIES
PO BOX 1250
LUMBERTON
NC
28359-1250
22
1355008689341
RA
I EDGE MARY S &
STOUT VAN (TRUSTEE) 1
16224 NC 53 HWY W
WHITE OAK
NC
28399
23
1355006802441
RA
I DAVIS MARGARET M
1
3521 CEDAR HILL DRIVE
FAYETTEVILLE
NC
28,312

APPENDIX F
NCWAM DATA FORMS

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0
Wetland Site Name Wetland W1
Wetland Type Basin Wetland
Date January 26, 2017
Assessor Name/Organization B. Reed/Kimley Horn
Notes on Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Wetland is intensively managed (Y/N) NO
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N)
Assessment area is substantially altered by beaver (Y/N) NO
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N) NO
Assessment area is on a coastal island (Y/N) NO
Sub -function Rating Summary
Function
Sub -function
Metrics
Rating
Hydrology
Surface Storage and Retention
Condition
NA
HIGH
Sub -Surface Storage and Retention
Condition
NA
Water Quality
Pathogen Change
Condition
NA
Condition
MEDIUM
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Particulate Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Soluble Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Physical Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Pollution Change
Condition
HIGH
Condition/Opportunity
HIGH
Opportunity Presence? (Y/N)
NO
Habitat
Physical Structure
Condition
MEDIUM
Landscape Patch Structure
Condition
MEDIUM
Vegetation Composition
Condition
MEDIUM
Function Rating Summary
Function
Metrics/Notes
Rating
Hydrology
Condition
MEDIUM
Water Quality
Condition
HIGH
Condition/Opportunity
HIGH
Opportunity Presence? (Y/N)
NO
Habitat
Condition
MEDIUM
Overall Wetland Rating MEDIUM

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0
Wetland Site Name Wetland W3
Wetland Type Headwater Forest
Date January 26, 2017
Assessor Name/Organization B. Reed/Kimley Horn
Notes on Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Wetland is intensively managed (Y/N) NO
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N) NO
Assessment area is substantially altered by beaver (Y/N) NO
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N) NO
Assessment area is on a coastal island (Y/N) NO
Sub -function Rating Summary
Function
Sub -function
Metrics
Rating
Hydrology
Surface Storage and Retention
Condition
LOW
LOW
Sub -Surface Storage and Retention
Condition
HIGH
Water Quality
Pathogen Change
Condition
LOW
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence? (Y/N)
NO
Particulate Change
Condition
LOW
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Soluble Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence? (Y/N)
NO
Physical Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence? (Y/N)
NO
Pollution Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence? (Y/N)
NA
Habitat
Physical Structure
Condition
MEDIUM
Landscape Patch Structure
Condition
LOW
Vegetation Composition
Condition
MEDIUM
Function Rating Summary
Function
Metrics/Notes
Rating
Hydrology
Condition
MEDIUM
Water Quality
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence? (Y/N)
NO
Habitat
Condition
LOW
Overall Wetland Rating LOW

APPENDIX G
MITIGATION

Mitigation Services
ENVIRONMENTAL QUALITY
May 26, 2017
Todd Gerken
Smithfield Foods, Inc.
11500 NW Ambassador Drive, Suite 500
Kansas City, MO 64153
Project: Smithfield Foods Expansion
ROY COOPER
Gove ftor
MICHAEL S. REGAN
Seerefary
Expiration of Acceptance: November 26, 2017
County: Bladen
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to accept
payment for compensatory mitigation for impacts associated with the above referenced project as indicated in the
table below. Please note that this decision does not assure that participation in the DMS in -lieu fee mitigation
program will be approved by the permit issuing agencies as mitigation for project impacts. It is the responsibility
of the applicant to contact permitting agencies to determine if payment to the DMS will be approved. You must
also comply with all other state, federal or local government permits, regulations or authorizations associated with
the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification/CAMA permit within this time frame, this
acceptance will expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS
receives a copy of the permit(s) an invoice will be issued based on the required mitigation in that permit and
payment must be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an
applicant is calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the impact
amounts shown below.
Impact
River
Basin
CU Location
[(8 -digit HUC)
Stream (feet) Wetlands (acres) Buffer I Buffer II
(Sq. Ft.) (Sq. Ft.)
Cold Cool Warm Riparian Non -Riparian Coastal Marsh
Lumber
03040203
0 0 0 0.25 6.5 0 0 0
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The mitigation
will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and 15A NCAC
02B .0295 as applicable. Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any
questions or need additional information, please contact Kelly Williams at [phone].
cc: William Sullivan, agent
Sincerely,
Jam s. Stanfill
Asset anagement Supervisor
State of North Carolina f Environmental Quality I Mitigation Services
1652 Mail Service Center I Raleigh, NC 27699-1652 1 217 W. Jones Street, Suite 3000
919 707 8976 T

APPENDIX H
NCNHP LETTER

North Carolina Department of Natural and Cultural Resources
Natural Heritage Program
Govemor Roy Cooper
May 26, 2017
Jason Hartshorn
Kimley-Horn
421 Fayetteville Street
Raleigh, NC 27601
RE: Smithfield Foods
Dear Jason Hartshorn:
Secretary Susi H. Hamilton
NCNHDE-3593
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
A query of the NCNHP database, based on the project area mapped with your request, indicates that there are
no records for rare species, important natural communities, natural areas, or conservation/managed areas
within the proposed project boundary. Please note that although there may be no documentation of natural
heritage elements within the project boundary, it does not imply or confirm their absence; the area may not have
been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists.
In the event that rare species are found within the project area, please contact the NCNHP so that we may
update our records.
The attached `Potential Occurrences' table summarizes rare species and natural communities that have been
documented within a one -mile radius of the property boundary. The proximity of these records suggests that
these natural heritage elements may potentially be present in the project area if suitable habitat exists and is
included for reference. Tables of natural areas and conservation/managed area within a one -mile radius of the
project area, if any, are also included in this report.
Please note that natural heritage element data are maintained for the purposes of conservation planning, project
review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions.
Information provided by the NCNHP database may not be published without prior written notification to the
NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP
data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature
Preserve (DNP), Registered Heritage Area (RHA), Clean Water Management Trust Fund (CWMTF) easement,
or Federally -listed species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at rodney.butler(a-)ncdcr.gov or 919.707.8603.
Sincerely,
NC Natural Heritage Program
MAILING ADDRESS: Tele hone: [919) 7D7-8107 LOCATICN
16`1 MaiI Service Center wyow.ncnhv.org 121 West Jones S-reet
Ralsigh, NC 27699-1651 Ralsigh, NC 27603

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mile Radius of the Project Area
Smithfield Foods
May 26, 2017
NCNHDE-3593
Element Occurrences Documented Within a One -mile Radius of the Project Area
Taxonomic EO ID Scientific NamjM
Common NameLast Element
Group Observation Occurrence
Date Rank
Dragonfly or 33737 Somatochlora georgiana Coppery Emerald 2004 -Pre H?
Damselfly
Dragonfly or
33779
Stylurus ivae
Shining Clubtail
2004 -Pre
Damselfly
Status
Status
Rank
Rank
Freshwater
4561
Elliptio roanokensis
Roanoke Slabshell
2009-07-22
Bivalve
Rare
Freshwater
10453
Villosa delumbis
Eastern Creekshell
2006-07-20
Bivalve
Rare
Vascular Plant
23815
Eriogonum tomentosum
Southern Wild -buckwheat
1890
No Natural Areas are Documented Within a One -mile Radius of the Project Area
No Managed Areas are Documented Within a One -mile Radius of the Project Area
X?
E
E
Accuracy
Federal
State
Global
State
Status
Status
Rank
Rank
5 -Very
---
Significantly
G3G4
S2?
Low
Rare
5 -Very
---
Significantly
G4
S2S3
Low
Rare
3 -Medium
Species of
Threatened
G3
S3
Concern
3 -Medium
---
Significantly
G4
S4
H 5 -Very ---
Low
Rare
Special G4G5 SH
Concern
Historical
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/content/help. Data query generated on May 26, 2017; source: NCNHP, Q2 April 2017. Please resubmit your
information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 3

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Page 3 of 3
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Sources' Fsri, HERE, DeLorms, Intermap, increment P Corp_, GFBCO,, USGS,
FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL Ordnance Survey, Fsri Japan,
METI, Es" China (Hong Kong), swisstopo, Mapmylndia, © OpenStreetMap
contributors, and the GIS User Community