20211296 Ver 1_Response to Comments_FINAL_REDUCED_20211008

ENGINEERING | DESIGN | TECHNOLOGY
5410 Trinity Road
Suite 102
Raleigh, NC 27607

P 919.866.4951
F 919.859.5663
www.timmons.com

October 8, 2021

Lyle Phillips
U.S. Army Corps of Engineers – Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587

Rick Trone
NCDEQ – Division of Water Resources
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem NC 27105

Re: Response to Requests for Additional Information
Project Galaxy
USACE AID: SAW-2015-02137
(Approx. 147.5 acres)
Wake County, North Carolina

Dear Mr. Phillips and Mr. Trone,
On behalf of Fujifilm Diosynth Biotechnologies U.S.A., Inc. (FDBU; Applicant), Timmons Group (Agent) is
providing a response to the Request for Additional Information (RAI) emails received on September 14 and
20, 2021 for Project Galaxy, an approximately 147.5-acre site located south of Holly Springs New Hill Road,
approximately 0.5-mile from the intersection of Holly Springs New Hill Road and Green Oaks Parkway in
Holly Springs, Wake County, North Carolina (the Site).
Due to the comments received by the US Army Corps of Engineers (USACE), the NC Division of Water
Resources (DWR), and other public and agency comments, the site layout has been revised. The revised
Impacts Map and culvert details are included as Attachment 1. The new site layout reduces permanent
wetland impacts from 1.33 acres to 0.301 acres and reduces permanent stream impacts from 3,313 linear
feet (0.178 acres) to 1,738 linear feet (0.102 acres).
Upon further evaluation, it has been determined that temporary stream impacts are necessary for site
development. In addition to the permanent stream impacts associated with Impact 4, an additional 20 lf (41
sq. ft) of temporary impacts are necessary for construction access to install the culvert and associated
riprap protection in that location. In addition to the permanent stream impacts associated with Impact 6, an
additional 10 lf (47 sq. ft.) of temporary impacts are necessary for construction access to install the culvert
and associated riprap protection in that location. Lastly, a temporary construction crossing of Stream J is
necessary for trucks to construct and maintain a temporary power line which will provide power to the site
during the construction phase (Impact 10). This crossing will result in temporary impacts to 91 lf (145 sq.
ft.) of stream. All temporarily impacted streams and stream banks shall be restored to their original
elevations and contours within 30 calendar days of construction completion or crossing removal.
Upon further evaluation, it has been determined that 4,072 sq. ft. (0.093 acres) of permanent conversion
impacts (PFO to PEM) at Impact 9 are necessary for the construction, installation, and associated
easements for water and telecom utilities in that location. The temporary overhead powerline will share the
same alignment as the water and telecom utilities in that location. The temporary power lines (and
temporary stream crossing) will be removed once the power lines and electrical infrastructure area at the
southern portion of the property are installed. The easement for water and telecom will remain.

Based on the revised impact maps, the total impacts for the proposed Project are summarized in the table
below:

The comments are outlined below in italics and are grouped by impact, with USACE comments in blue and
DWR comments in green. Our response is below each comment.
A. Permits for work within wetlands or other special aquatic sites are available only if the proposed work
is the least environmentally damaging, practicable alternative. Please furnish information regarding any
other alternatives, including upland alternatives, to the work for which you have applied and provide
justification that your selected plan is the least damaging to water or wetland areas.
i. As requested in EPA’s email of August 12, 2021, please provide alternatives for the proposed
project and justification for the selected plan as the least environmentally damaging, practicable
alternative. This alternative analysis needs to be based upon siting criteria for your project,
which needs to include a comparison of impacts to jurisdictional features of the various off-site
and on-site alternatives, along with any other siting criteria utilized.
ii. Your alternatives analysis also needs to address the “No Action” alternative, which would
involve a discussion of the “No Build” alternative along with the “No Permit Required”
alternative.
Timmons Group has prepared an Alternatives Analysis (see Attachment 2). This alternatives
analysis provides alternatives for the proposed project and justification for the selected plan as
the least environmentally damaging, practicable alternative as requested in comment A.i. The
Length Area Length Area
1 Culvert Permanent 1,702 -- -- -- --
2 Road Fill Permanent 605 -- -- -- --
3 Fill/Grading Permanent 6,891 -- -- -- --
4 Culvert Permanent -- -- -- 105 211
4 Culvert Temporary -- -- -- 20 41
5 Fill/Grading Permanent -- -- -- 994 2,295
6 Culvert Permanent -- 181 1,125 -- --
6 Culvert Temporary -- 10 47 -- --
7 Fill/Grading Permanent -- -- -- 458 822
8 Fill/Grading Permanent 3,913 -- -- -- --
9 Utility Easement
Permanent Conversion
to PEM 4,072 -- -- -- --
10 Temporary Construction
Crossing/Utility Easement Temporary -- -- -- 91 145
Acres
0.301
0.093
0.026
0.001
0.076
0.004
Stream Length (LF) and Area (sq. ft.)
Perennial IntermittentImpact ID Impact Description Impact Type
PFO Wetland
Area (sq. ft.)
TOTALS
Permanent Impacts to Intermittent Streams
Temporary Impacts to Intermittent Streams
Impact Type
Permanent Impacts to Wetlands
Permanent Conversion to PEM
Permanent Impacts to Perennial Streams
Temporary Impacts to Perennial Streams 10
1,557
111
Square Feet
13,111
4,720
1,125
47
3,328
186
Linear Feet
--
--
181

alternatives analysis also addresses the “No Action” alternative by discussing a “No Build” and
a “No Permit Required” alternative requested in comment A.ii.
iii. With regards to the staging area for equipment and contractor parking, it doesn’t appear that
avoidance of jurisdictional features was maximized as this area shows no future development.
As was presented in EPA’s email and comments from the general public, you need to address
why another adjacent property, an area without waters (i.e., footprint of future phases west of
the initial phase) or another area designated as a future phase could not be utilized for
contractor storage/parking to avoid the majority of wetland and stream impacts in the northern
portion of the property. In addition, please advise as to whether there is additional development
that would occur at the location of the proposed staging area as this needs to be considered in
this evaluation.
These comments have been acknowledged and the location of equipment staging and
contractor parking has changed (see Attachment 1 for the current site layout). Some of the
staging and parking will be located on the future phases of the property (western side) and
some construction material laydown will be located at the very southern end of the property.
The applicant has expressed an interest in preserving the northern area as much as possible
and has limited the impacts to a road crossing originating from Holly Springs-New Hill Road
(necessary as a secondary access) and another road access originating from the neighboring
Oakview Innovation Park to the east. There are also temporary impacts from a proposed power
and water line.
B. It is necessary for you to have taken all appropriate and practicable steps to minimize losses of Waters
of the U.S., including wetlands. Please indicate all that you have done, especially regarding
development and modification of plans and proposed construction techniques, to minimize adverse
impacts.
i. Specifically describe in detail measures taken to further minimize the proposed impacts used
in designing the project, with various on-site alternative layouts.
The Alternatives Analysis (see Attachment 2) contains information on how impacts were
minimized compared to other on-site alternative layouts.
Detailed measures to minimize impacts that were incorporated in the final site design include:
· The use of headwalls and steep slopes on culverts
· The use of retaining walls around the site to limit wetland impacts
· Placement of ancillary buildings and structures (i.e., those buildings that are not
required to be connected to the Spine structure) in upland areas
· The use of a road access from the neighboring Oakview Innovation Park in order to
minimize the number of road accesses that need to be built for the project

ii. Please address the minimization comments submitted by the USEPA and both non-agency
comments. Specifically, address minimization efforts suggested by one of the commenters for
impact sites 7 and 8. In addition, please address the potential to restore the stream and
wetlands in the northern portion associated with the construction staging/parking area following
construction that was mentioned by both EPA and one of the commenters.
USEPA’s Comments:
The USEPA stated that “the site development configuration for the main facility is situated as
to avoid or minimize impacts to waters of the US, even with the future phases on the west side

of the property considered.” However, the EPA did not agree with the use of the northern
section of the property as equipment staging and contractor parking. The new site layout
(Attachment 1) shows reduced impacts to the northern area and the movement of equipment
staging and contractor parking in an effort to avoid surface water impacts.
Old Impact Site 7 (now labeled as Impact Site 8):
Ms. Keven Arrance suggested that the Lab & Administration Building for the Future Phase and
the access road could be reconfigured to avoid Impact 7 (which is now labeled as Impact 8 in
the new Impacts Map). The old site layout did not include the proposed parking decks that
would be needed for the future phase of the facility. The new site layout includes these decks
(see Attachment 1) and shows that it would be infeasible to shift the Lab & Administration
Building and access road to avoid impacts to this linear wetland.
Old Impact Site 8 (now labeled as Impact Site 5):
Ms. Keven Arrance suggested that the stream impacted in Impact 8 (which is now labeled as
Impact 5 in the new Impacts Map) could be relocated to the east of the toe of the proposed fill
slope. This relocation is infeasible because the toe of the proposed fill slope extends close to
the edge of the property boundary, leaving little to no room for a stream relocation. In addition,
the stream would have to relocated to an area where there currently exists a gravel, unpaved
road. Lastly, just to the east of the property boundary of Project Galaxy, there is a jurisdictional
PFO wetland (labeled as I2 in the delineation map for the Oakview Innovation Park project,
SAW-2015-02137), and relocating the stream in this area would involve impacts to a
jurisdictional wetland.
Northern streams and wetlands:
The site layout shows that the originally proposed grading of the northern area for equipment
staging and contractor parking has been eliminated. In this area, the current site layout now
proposes 9,198 square feet (0.211 acres) of permanent impacts and 4,720 (0.108 acres) of
permanent conversion to PEM impacts to PFO wetlands, and 105 linear feet (211 square feet
/ 0.005 acres) of permanent impacts and 125 linear feet (208 square feet / 0.005 acres) of
temporary impacts to the intermittent Stream J. The Applicant has also expressed a desire for
this northern portion of the property to be used as an environmental education resource for the
community.
C. The MOA requires that appropriate and practicable mitigation will be required for all unavoidable
adverse impacts remaining after the applicant has employed all appropriate and practicable
minimization. Please indicate your plan to mitigate for the projected, unavoidable loss of waters or
wetlands or provide information as to the absence of any such appropriate and practicable measures.
i. If a mitigation ratio less than 2:1 is proposed, please complete the NC Stream Assessment
Method (NCSAM) and NC Wetland Assessment Method (NCWAM) at the location of impact
and submit a revised compensatory mitigation plan.
NCSAM and NCWAM forms have been included for impacted stream and wetland features for
which a mitigation ratio less than 2:1 is proposed. All assessment forms, including associated
photopages illustrating general feature characteristics and conditions, can be found in
Attachment 3, while approximate locations where feature assessments were conducted can be
found on Figure 6 – Wetlands and Waters Delineation Map in Attachment 3.
A mitigation ratio of 1.5:1 is proposed for impacts to Stream M, which received an overall score
of medium. Despite receiving a score of high for hydrology, water quality was rated as medium
while habitat was rated as low. In addition, a mitigation ratio of 1.75:1 is proposed for Stream
L. Despite receiving an overall rating of high, no water was observed within the stream and
habitat functionality was rated as low.

A mitigation ratio of 1:1 is proposed for impacts to Wetland C, which received a rating of low.
Following completion of the functional assessments, the hydrology function of Wetland C was
rated as low. Further, Wetland C received a rating of low for water quality and high for habitat.
Impacts to all other features are proposed to be mitigated at a 2:1 ratio. Based on the new
impact amounts and the proposed mitigation ratios, the proposed project will require 0.537
wetland mitigation credits and 2,865 stream mitigation credits as detailed in the updated
Table below:

Compensatory mitigation for these unavoidable impacts will be achieved through the purchase
of off-site mitigation credits from Wetland Mitigation Banks. If credits are unavailable at the time
of permitting, compensatory mitigation will be achieved through payment into the North
Carolina Division of Mitigation Services (DMS) in-lieu fund.
D. Additionally, the following items must be resolved prior to continuing to process your permit request:
i. Sketches and profiles should be provided when necessary to show that the proposed activities
would maintain flows and circulation patterns of waters. Sketches and profiles should contain
sufficient detail to provide an illustrative description of the proposed activity. For example,
based upon the current drawings, we are unable to assess whether there are additional indirect
impacts to streams due to stormwater diversion. In the event that stormwater outlets are
constructed in such a manner that additional reaches are indirectly impacted, those reaches
will be considered impacts that would require permitting along with additional mitigation to
compensate for functional losses.
Outfalls for the two proposed stormwater ponds have been added to the site layout. These
outfalls will discharge to Perennial Stream Feature N (for Pond 2) and Perennial Stream
Feature O (for Pond 1) in order to avoid indirect impacts.
Culvert profiles and plan sheets are available in Attachment 1, which show how the proposed
activities will maintain flows and circulation patterns of waters.
PFO
Wetlands
PFO ->
PEM
Wetlands
R3
Streams
R4
Streams Ratio
Required
Credits
(Wetlands
Required
Credits
(Streams)
1 Permanent 0.039 -- -- --2:1 0.078 --
2 Permanent 0.014 -- -- --2:1 0.028
--
3 Permanent 0.158 -- -- --1:1 0.158
--
4 Permanent -- -- -- 105 2:1 -- 210
4 Temporary -- -- -- 20 NONE --
--
5 Permanent -- -- -- 994 1.5:1 --1,491
6 Permanent -- -- 181 --2:1 --362
6 Temporary -- -- 10 --NONE --
--
7 Permanent -- -- -- 458 1.75:1 -- 802
8 Permanent 0.090 -- -- --2:1 0.180 --
9 Perm. Conv. -- 0.093 -- --1:1 0.093 --
10 Temporary -- -- -- 105 NONE -- --
TOTALS: 0.537 2,865
Mitigation Information
Impact ID
Wetland (acres) and Stream (Lf) impacts
Impact
Type

ii. Based on the attached “NCDOT 2020-2029 STIP Map” it appears that the HE- 0002 project
proposes the construction of a roadway from Green Oaks Parkway between Thomas Mill Road
and NC 55 to the approximate location of the proposed Project Galaxy. Based on the attached
“HE-0002 NCDOT Letter to Economic Development Partnership of NC”, the North Carolina
Department of Transportation is partnering with the Economic Development Partnership of
North Carolina to support Project Galaxy. As discussed in the August 16, 2021, virtual meeting,
a project is considered to have independent utility if it would be constructed absent the
construction of other projects in the project area. At this time, we have not received sufficient
information to support that this proposed road is a separate and complete project and any
impacts associated with it should be included as a part of Project Galaxy.
The applicant has stated that Project Galaxy can be built absent the construction of the HE-
0002 project (the proposed roadway from Green Oaks parkway to the approximate location of
the southern portion of Project Galaxy). The current site layout (Attachment 1) shows no
proposed connection to the future HE-0002 project. The proposed north-south access road
shown in the current site layout is to service an electrical infrastructure pad and access an area
used for construction material laydown. The road is not currently proposed to extend off Project
Galaxy’s parcel. The Applicant has stated that the construction of the first phase of Project
Galaxy is feasible without access from HE-0002. This statement is supported by the fact that
construction of Project Galaxy is currently scheduled to begin in March 2022, which would be
before construction begins on HE-0002. Lastly, the Applicant also states that the access to HE-
0002 is not required for the operations of Project Galaxy nor emergency access. As shown in
the proposed site layout, there are currently two proposed accesses to Project Galaxy: 1)
coming from the east from the neighboring Oakview Innovation Park and 2) a proposed access
road originating from Holly Springs-New Hill Road and entering the facility/campus from the
North. In addition, an existing gravel road south of Project Galaxy near an existing Town of
Holly Springs pump station can be used as a third emergency access, with access coming from
the neighboring Trinity Creek Subdivision. To support the idea that Project Galaxy can be built
without the HE-0002 project, a letter of support from the Town of Holly Springs has been
included as Attachment 4.
Similarly, the HE-0002 project can likely be built absent the construction of Project Galaxy. In
the February 2, 2021 letter from the NCDOT to the Economic Development Partnership of
North Carolina, it is stated that funds from NCDOT could be directed to a new road with the
explicit stipulation that the road should “provide public benefit through direct access to other
parcels within Holly Springs Business Park.” In addition, the letter states that the “proposed
road would be critical to serving the long-term needs of Project Galaxy and other potential
industries in the area.” These statements support the idea that the proposed road would have
a greater service area than Project Galaxy, would serve other businesses in the area, and have
the potential to provide a connection to the Trinity Creek subdivision, located west of Project
Galaxy.
Therefore, the additional information the applicant provides to support Project Galaxy as a
separate and complete project from the proposed HE-0002 road are:
· An updated site layout (Attachment 1) showing no connection between any road on
the Project Galaxy and the proposed HE-0002.
· A letter from the Town of Holly Springs stating that Project Galaxy can be constructed
without access to HE-0002 and that they are not requiring that HE-0002 be built for
Project Galaxy (Attachment 4).
· Reference to the letter from the NCDOT to the Economic Development Partnership of
North Carolina stating that NCDOT funds can be directed towards a new road with the

stipulation that the new road also provide direct access to other parcels within the Holly
Springs Business Park.

iii. The present layout of roadway infrastructure for the proposed project does not depict logical
termini leading to the potential for further/future jurisdictional impacts associate with roadway
impacts on adjacent parcels, therefore the Corps is unable to determine whether the proposed
activity will result in more than minimal individual or cumulative adverse environmental effects.
Please provide further information on the potential for adverse cumulative effects due to the
connection of the north/south roadway resulting in impact 8 and impact 9.
The new site layout (Attachment 1) now shows a logical terminus for the north/south roadway
that had resulted in Impacts 8 and 9 (now labeled as Impacts 5 and 6 in the revised Impacts
Map). The terminus for this roadway is for an electrical infrastructure pad that will be located
south of the perennial stream (Feature N on the Delineation Map).
The purpose of this electrical infrastructure pad is to support the primary electric service into
the facility, serve as a transition point from overhead power lines to underground duct bank,
and contain the electrical switching and paralleling gear where backup generation is connected
to the system. Meetings with a Duke Energy subcontractor indicated that the amount of
electrical equipment needed for Project Galaxy is greater than the footprint that was originally
shown in the initial Impact Map submitted with the Individual Permit application. The
subcontractor was also very concerned about the placement of this electrical infrastructure on
the side of a hill.
Fujifilm and Duke Energy coordinated to locate a better spot for this electrical infrastructure
and decided that the only placement that could work while still fulfilling the needs of the project
was at the southern portion of the site, south of Feature N. The new proposed location is shown
on the revised site layout plan (Attachment 1). This location provides the necessary footprint
for the equipment pad. Thus, Fujifilm is proposing to construct this electrical infrastructure area
south of Feature N and is proposing a 2-lane road constructed of Heavy Duty asphalt to cross
the stream so that trucks and other maintenance vehicles can access the electrical
infrastructure as needed. The road is designed to terminate approximately 200’ before the edge
of the Project Galaxy parcel and to include a turn-around area for trucks. Please note that the
electrical infrastructure cannot be relocated any further north within Project Galaxy because
the overhead power lines will be coming from the South (see below) and the project requires a
quick transition from overhead to underground for overall system reliability.
Additional coordination between Fujifilm and Duke Energy and with the Town of Holly Springs
has provided additional benefits to moving this electrical infrastructure to a location south of
Feature N:
1. The initial plans proposed that utility lines would cross underneath Feature N. Initial
conversations with the Town of Holly Springs public works department revealed that the
contractors are likely to encounter bedrock under the stream which would make crossing below
the stream infeasible. A geotechnical report completed in September 15, 2021 by S&ME
concluded that borings near Feature N encountered partially weathered rock (PWR) between
3 feet and 5 feet below land surface (BLS). The existence of PWR so close to the land surface
would make the installation of all utility lines under the stream infeasible from a cost
perspective.
The installation of the new road which will cross Feature N will allow for medium and low volt
electrical and other future utility lines to be installed via an underground concrete duct bank or
conduit that could be installed underneath the road but above the culvert. This would avoid any
temporary impacts to the stream from installing these electrical lines underneath the stream
and avoid any issues with encountering bedrock. The new service road would also cross the

stream in the same area as the proposed sanitary sewer from the adjacent Oak View
Innovations Park; thus this sanitary sewer could also be placed within this road fill and further
minimize impact to the stream.
If the electrical infrastructure was placed north of Feature N, then the utility lines (electrical,
fiber optic, sanitary sewer) could not be placed underneath the road shoulder and will need to
cross below the stream where bedrock is likely to be encountered.
2. The design intent for all utilities serving the project is to route them underground whenever
possible to improve system reliability and the overall aesthetics of the project. Locating the
electrical infrastructure south of Feature N moves this infrastructure closer to a new substation
that will be sited approximately 1,500’ to the south of the property and the proposed Duke
Transmission circuit located approximately 2.5 to 3 miles to the west of the Project Galaxy Site.
If the infrastructure is located south of Feature N, overhead power lines can be switched to the
underground concrete duct bank at this location, instead of having the overhead power lines
continue past Feature N before transitioning to underground at the previously proposed
location for the electrical infrastructure.
Locating the electrical infrastructure south of Feature N will allow overhead power lines to be
placed underground sooner and increase overall system reliability and project aesthetics. The
proposed 2-lane road with a truck turn-around section will be necessary to construct this
infrastructure and provide regular maintenance.
In addition to re-locating the electrical infrastructure to an area south of Feature N, Fujifilm also
wishes to use a portion of this area to store construction materials, landscape equipment, and
other materials. The existing gravel road is too small to serve this purpose, but the proposed
2-lane paved road will allow trucks to access this portion of the property.
In summary, these design changes will:
· Allow for betting siting of electrical infrastructure
· Avoid the construction of the electrical infrastructure on a steep slope, which will
improve safety
· Eliminate issues of utilities crossing shallow bedrock that is present near Feature N
· Allow for a quicker transition of overhead powerlines to an underground concrete duct
for better system reliability and overall aesthetics
· Allow for Fujifilm to use the southern portion of the site for construction material
laydown and storage of other materials
An alternative routing of the north/south roadway to be located west of the stormwater pond
was considered (see Onsite Alternatives in Attachment 2). However, this option is not feasible
for several reasons:
· The roadway would likely enter setback buffers that were established to provide an
adequate spacing distance between Project Galaxy and the neighboring Trinity Creek
subdivision.
· The roadway will still need extensive grading and would result in increased impacts to
the intermittent stream feature west of the stormwater pond (referred to as Impact 10
in the initial Impacts Map, but changed to Impact 7 in the revised Impacts Map).
· The gravity sewer from Oakview Innovation Park would not be able to be installed in
the road shoulder if the road were moved west of the stormwater pond
· The alignment for placing all utilities in a concrete duct bank would be straighter and
shorter if the road crossed the stormwater pond to the east, rather than the west.

· It is the understanding of the Applicant and the Agent that the area west of the
stormwater pond will be used in the future for the routing of several water mains leading
to the existing pump station south of Project Galaxy and eventually to the Utley Creek
Wastewater Treatment Plant.

iv. Please note that a request for additional information may be necessary after the Corps
evaluation of the responses to the Public Notice comments or the items listed above.
Acknowledged and understood.
DWR Comments:
1. The project proposes a contractor parking and equipment staging area on the northern end of the site.
This staging and parking area indicates temporary activities with permanent impacts to streams and
wetlands. It does not appear this area is slated for further development. This Office believes that the
contractor parking and equipment staging area can be moved or reconfigured to avoid the impacts.
Please revise the plans to avoid the impacts or provide a detailed explanation of why this plan of the
activity cannot be practically accomplished, reduced or reconfigured to avoid permanent impacts in the
area. [15A NCAC 02H .0506(b)(1)]
The site layout plans have been revised to remove the contractor parking and equipment staging for
this area (see Attachment 1).
2. Please enumerate all wetland and stream impacts on the site plans and clearly label impacts (Impact
ID 1, 2, 3, etc.). The Division recommends highlighting by hatching or shading all impact areas for
temporary impact areas and permanent impact areas. Impact maps should clearly depict the nature of
the impact, impact type, and impact amount. [15A NCAC 02H .0502(a)(9)]
Please see the revised Impact maps (Attachment 1). Impacts are clearly labeled, zoomed-in sheets
have been added, and hatching/coloring has been added to distinguish between temporary and
permanent impacts.
3. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of the
Public Notice or other requests, please provide the Division with a copy of your response to the USACE.
[15A NCAC 02H .0502(c)]
Acknowledged and understood.
4. Please provide a detailed engineering plan, profile view, and cross-section of all proposed culverts.
These drawing must include details regarding stream alignment in relation to pipe alignment, pipe slope,
pipe burial, and dissipator pad. [15A NCAC 02H .0502(a) and .0502(a)(9)]
Detailed engineering plans for the culverts (which include stream alignment vs. pipe alignment, pipe
slope, pipe burial, and dissipator pads, among other details) are included in Attachment 1.
5. Please provide the Division with a copy of any information submitted to the USACE regarding the
proposed roadway from Green Oaks Parkway between Thomas Mill Road and NC 55 to the proposed
location of Project Galaxy. On September 14, 2021, the USACE indicated sufficient information on this
roadway had not been received to support the proposal. The Division has similar concerns regarding
the roadway. [15A NCAC 02H .0502(c)]
Please see the response to Comment D.ii from the USACE above.
6. This Office believes that the northern entrance road can be moved or reconfigured to avoid the impacts
to streams and/or wetlands. Please revise the plans to avoid the impacts or provide a detailed

explanation of why this plan for the activity cannot be practically accomplished, reduced or reconfigured
to avoid permanent impacts in this area. [15A NCAC 02H .0506(b)(1)]
The northern entrance road is necessary to provide a secondary access to the facility/campus. It is
infeasible to avoid any stream impact since the intermittent stream (Feature J) flows from the eastern
property boundary all the way to the western property boundary. The northern entrance road is currently
proposed to be approximately 1,250 feet from the existing Ancient Oaks Drive. The North Carolina
Department of Transportation (NCDOT) requires at least 1,200-foot spacing between road intersections
and median breaks. Thus, the northern entrance road cannot be moved any more to the east to avoid
impacting Wetland E. In addition, the northern entrance road is proposed to be directly across from
Addison Pond Drive to the north and will complete a four-way intersection.
7. This Office believes that the access road on the western end of the site near the Lab and admin building
(Impact ID 7) can be moved or reconfigured to avoid or minimize the multiple impacts to the wetland.
Please revise the plans to avoid the impacts or provide a detailed explanation of why this plan for the
activity cannot be practically accomplished, reduced or reconfigured to avoid permanent impacts in this
area. [15A NCAC 02H .0506(b)(1)]
Please see the response to Comment B.ii from the USACE above.
8. This Office believes that the southern north-south road can be moved or reconfigured to avoid the
impacts and loss of stream at Impact ID 8. Please revise the plans to avoid the impacts or provide a
detailed explanation of why this plan for the activity cannot be practically accomplished, reduced or
reconfigured to avoid permanent impacts in this area. [15A NCAC 02H .0506(b)(1)]
Please see the response to Comment D.iii from the USACE above, specifically the last paragraph and
bullet points explaining why moving the north-south road is infeasible.
9. You have indicated that the southern electrical pad may need to be relocated from its currently
proposed location. Please provide detailed impact maps (see #2 above) and a revised impact table for
the new pad location if the any additional or changed impacts are proposed. [15A NCAC 02H .0502(c)]
The impact maps have been updated and a revised impact table is available on the map and in this
response letter (see above table).
Please review the updated Impact Maps and contact Matt Michel at [phone] or
[e-mail] if additional information is required.

Sincerely,
Timmons Group

Sydni Law, WPIT
Environmental Scientist

Matt Michel, PWS, PhD
Senior Environmental Scientist

Enclosures:

Attachment 1 Impact Maps
Culvert Details (profile view, plan view, cross-section view)

Attachment 2 Alternatives Analysis
Appendix A: Offsite Alternatives Analysis Documents
Appendix B: Onsite Alternatives

Attachment 3 SAM/WAM forms and photopages

Attachment 4 Letter of Support from the Town of Holly Springs

ATTACHMENT 1

REVISED IMPACT MAPS
CULVERT PLAN SHEETS

DRAWING DESCRIPTION
PROJECT NAME & LOCATION
SHEET NUMBERSCALE
DATE 10/05/2021
DESIGNED BY / DRAWN BY
PROJECT NAME
M. COOLEY
PR OJECT GALAXY FDBU
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Cedar
WrenLnDuckBranchDrSageThrushBnd
C hickasaw P lum D rPondLilyCt
ScarletTanagerCirAddisonPondD rTrinityCreekDrTupeloGroveLn
SweetbriarRoseCtCedarWrenLnA m berw ing C tScar
l
et
TanagerCirT h r e a d l eaf Dr
HazelAlderCt
Fern Glade Dr
ChickasawPlum
DrGreyHeronLnCrestedCoralDrTrinity Creek Dr1 " = 220 'H:
FIGURE 6:PRELIMINARYJURISDICTIONALWATERS OF THEU.S. IMPACTS MAP
REVISIONS
MM/DD/YY#DESCRIPTION
These plans and associated documents are theexclusive property of TIMMONS GROUP andmay not be reproduced in whole or in part andshall not be used for any purpose whatsoever,inclusive, but not limited to construction, bidding,and/or construction staking without the expresswritten consent of TIMMONS GROUP.
PROJECT NUMBER48455PROJECT GALAXY FDBUWAKE COUNTY,NORTH CAROLINA 1001 Boulders Parkway, Suite 300Richmond, VA 23225TEL [phone]www.timmons.com[
PLANS PRINTED AS 11X17 ARE HALF SCALE0220440
SCALE (FEET)
Y:\805\48455 - Project Galaxy FDBU\GIS\WTIM\48455-WTIM.mxd
1. Waters of the U.S. within theproject study limits have beensurvey located by TimmonsGroup.2.Waters of the U.S. have notbeen confirmed by the U.S. ArmyCorps of Engineers.3. Project limits are surveylocated.4. Topography based on USGSLiDAR.5. Cowardin StreamClassifications are based solelyon field observations. No formalStream assessment methodologywas completed to determine theseCowardin Classifications.
Legend
Project Study Limits- 1 47.5 Acr es
Previously Permitted By Others
DOLDOL
DOLLimits of Disturbance- 94 .0 Acres
")X Stream Impact
!(X Wetland Impact
Proposed Storm Pip e
E Proposed Electr ic
F Proposed Fire Pipe
G Proposed Gas
NAS Proposed Sanitary Se wer
W Proposed Water
TGU Proposed Telecommunication
ËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËË Proposed RipRap
Proposed Grading
Permanent Stream Im pact
Temporary Stream Im pa ct
Permanent Wetland Imp act
Permanent Conversion Im pact
Perennial Stream (R3)
Intermittent Stream (R4 )
Culvert
Palustrine Forest ed (PFO ) We tlan ds
Palustrine Open Wate r (POW )1 of 3
Permanent (PFO)Permane ntConversion (PFO)lf.sq. ft.lf.sq. ft.lf.sq. ft.lf.sq. ft.1 1,702260536,8914 20 41 105 21159942,295610471811,1257 458 82283,9139 4,07210 91 14513,111 sq ft 4,072 sq ft0.30 a c 0.09 a c
Strea m (R3)Te mporary Impa ctWetland Impact (sq. ft)
Impa cts Table
Total 181 lf 1,125 sq ft
Stream (R4)Permane nt Impact
Impa ct ID
Permane nt Impact
1,557 lf 3,328 sq ft47 sq ft10 lf
Stream (R4)Tempora ry Impact
111 lf 186 sq ft
Stream (R3)
DRAWING DESCRIPTION
PROJECT NAME & LOCATION
SHEET NUMBERSCALE
DATE 10/05/2021
DESIGNED BY / DRAWN BY
PROJECT NAME
M. COOLEY
PR OJECT GALAXY FDBU
!(3
!(2
!(1
!(8
!(9
")10
")4
AddisonPondDr
H ollyS p rin g sN e w H illR d
GreyHeronLnA m berw ing C t1 " = 75 'H:
FIGURE 6:PRELIMINARYJURISDICTIONALWATERS OF THEU.S. IMPACTS MAP
REVISIONS
MM/DD/YY#DESCRIPTION
These plans and associated documents are theexclusive property of TIMMONS GROUP andmay not be reproduced in whole or in part andshall not be used for any purpose whatsoever,inclusive, but not limited to construction, bidding,and/or construction staking without the expresswritten consent of TIMMONS GROUP.
PROJECT NUMBER48455PROJECT GALAXY FDBUWAKE COUNTY,NORTH CAROLINA 1001 Boulders Parkway, Suite 300Richmond, VA 23225TEL [phone]www.timmons.com[
PLANS PRINTED AS 11X17 ARE HALF SCALE070140
SCALE (FEET)
Y:\805\48455 - Project Galaxy FDBU\GIS\WTIM\48455-WTIM.mxd
1. Waters of the U.S. within theproject study limits have beensurvey located by TimmonsGroup.2.Waters of the U.S. have notbeen confirmed by the U.S. ArmyCorps of Engineers.3. Project limits are surveylocated.4. Topography based on USGSLiDAR.5. Cowardin StreamClassifications are based solelyon field observations. No formalStream assessment methodologywas completed to determine theseCowardin Classifications.
Legend
Project Study Limits- 1 47.5 Acr es
Previously Permitted By Others
DOLDOL
DOLLimits of Disturbance- 94 .0 Acres
")X Stream Impact
!(X Wetland Impact
Proposed Storm Pip e
E Proposed Electr ic
F Proposed Fire Pipe
G Proposed Gas
NAS Proposed Sanitary Se wer
W Proposed Water
TGU Proposed Telecommunication
ËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËË Proposed RipRap
Proposed Grading
Permanent Stream Im pact
Temporary Stream Im pa ct
Permanent Wetland Imp act
Permanent Conversion Im pact
Perennial Stream (R3)
Intermittent Stream (R4 )
Culvert
Palustrine Forest ed (PFO ) We tlan ds
Palustrine Open Wate r (POW )2 of 3
Permanent (PFO)Permane ntConversion (PFO)lf.sq. ft.lf.sq. ft.lf.sq. ft.lf.sq. ft.1 1,702260536,8914 20 41 105 21159942,295610471811,1257 458 82283,9139 4,07210 91 14513,111 sq ft 4,072 sq ft0.30 a c 0.09 a c
Strea m (R3)Te mporary Impa ctWetland Impact (sq. ft)
Impa cts Table
Total 181 lf 1,125 sq ft
Stream (R4)Permane nt Impact
Impa ct ID
Permane nt Impact
1,557 lf 3,328 sq ft47 sq ft10 lf
Stream (R4)Tempora ry Impact
111 lf 186 sq ft
Stream (R3)
DRAWING DESCRIPTION
PROJECT NAME & LOCATION
SHEET NUMBERSCALE
DATE 10/05/2021
DESIGNED BY / DRAWN BY
PROJECT NAME
M. COOLEY
PR OJECT GALAXY FDBU
")7
")5
")6
ChickasawPlumDr
1 " = 75 'H:
FIGURE 6:PRELIMINARYJURISDICTIONALWATERS OF THEU.S. IMPACTS MAP
REVISIONS
MM/DD/YY#DESCRIPTION
These plans and associated documents are theexclusive property of TIMMONS GROUP andmay not be reproduced in whole or in part andshall not be used for any purpose whatsoever,inclusive, but not limited to construction, bidding,and/or construction staking without the expresswritten consent of TIMMONS GROUP.
PROJECT NUMBER48455PROJECT GALAXY FDBUWAKE COUNTY,NORTH CAROLINA 1001 Boulders Parkway, Suite 300Richmond, VA 23225TEL [phone]www.timmons.com[
PLANS PRINTED AS 11X17 ARE HALF SCALE070140
SCALE (FEET)
Y:\805\48455 - Project Galaxy FDBU\GIS\WTIM\48455-WTIM.mxd
1. Waters of the U.S. within theproject study limits have beensurvey located by TimmonsGroup.2.Waters of the U.S. have notbeen confirmed by the U.S. ArmyCorps of Engineers.3. Project limits are surveylocated.4. Topography based on USGSLiDAR.5. Cowardin StreamClassifications are based solelyon field observations. No formalStream assessment methodologywas completed to determine theseCowardin Classifications.
Legend
Project Study Limits- 1 47.5 Acr es
Previously Permitted By Others
DOLDOL
DOLLimits of Disturbance- 94 .0 Acres
")X Stream Impact
!(X Wetland Impact
Proposed Storm Pip e
E Proposed Electr ic
F Proposed Fire Pipe
G Proposed Gas
NAS Proposed Sanitary Se wer
W Proposed Water
TGU Proposed Telecommunication
ËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËËË Proposed RipRap
Proposed Grading
Permanent Stream Im pact
Temporary Stream Im pa ct
Permanent Wetland Imp act
Permanent Conversion Im pact
Perennial Stream (R3)
Intermittent Stream (R4 )
Culvert
Palustrine Forest ed (PFO ) We tlan ds
Palustrine Open Wate r (POW )3 of 3
Permanent (PFO)Permane ntConversion (PFO)lf.sq. ft.lf.sq. ft.lf.sq. ft.lf.sq. ft.1 1,702260536,8914 20 41 105 21159942,295610471811,1257 458 82283,9139 4,07210 91 14513,111 sq ft 4,072 sq ft0.30 a c 0.09 a c
Strea m (R3)Te mporary Impa ctWetland Impact (sq. ft)
Impa cts Table
Total 181 lf 1,125 sq ft
Stream (R4)Permane nt Impact
Impa ct ID
Permane nt Impact
1,557 lf 3,328 sq ft47 sq ft10 lf
Stream (R4)Tempora ry Impact
111 lf 186 sq ft
Stream (R3)
PONDEXISTING 40' PERMANENTACCESS EASEMENTDB 12957 PG 1315DIRT TRAIL
DIRT TRAILDIRT ROADAREA = 551,830.27 SF / 12.668 ACRESN/FDUKE ENERGY PROGRESS, INC.PIN: 0639721436ACREAGE: 139.98 AC.DB 1961 PG 491 &DB 15289 PG 243731531532032032532533
0
33
0
3
3
5335335
34034034034534534535035035035
0
350355355355290295300305310315320325330335340345
DIRIM = 362.21'INV OUT = 357.51'DIRIM = 361.10'INV IN = 356.35'INV OUT =356.25'DIRIM = 359.04'INV IN = 354.09'INV OUT = 348.99'DIRIM = 359.47'INVERTS OBSCUREDDIRIM = 338.64'INV OUT = 328.94'RIM = 363.96'INV IN = 358.08'INV OUT = 358.01'DIRIM = 353.10'INVERTS OBSCUREDDIRIM = 348.56'INVERTS OBSCUREDDIRIM = 345.17'INVERTS OBSCUREDDIRIM = 342.43'INVERTS OBSCUREDDIRIM = 340.28'INVERTS OBSCUREDDIRIM = 339.83'INVERTS OBSCUREDDIRIM = 337.93'INVERTS OBSCUREDDIRIM = 334.82'INVERTS OBSCURED15"RCP15"RCP15"RCP15"RCPN/FHELIX VENTURES, LLCPIN: 0639633688ACREAGE: 12.64 AC.DB 17498 PG 2164ZONING: R-30OHUOHUOHU12'' W16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW16''RW6''RWFMWETLANDHOLLY SPRINGS BUFFERS12''W12''WTEMPORARY24" CULVERTTEMPORARY24" CULVERTRR-3RR-4WESTBOUND LEFT TURN LANE150' OF STORAGE AND 100' TAPERPER NCDOT STANDARDSR40'26'15'15'WESTBOUND LEFT TURN LANE100' OF STORAGE AND 100' TAPERSITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')30'22'150' STORAGE100'100'SITE DISTANCETRIANGLE (15'x305')59' ROW15'15'5' SIDEWALK15'2'35' B-B15'5' UTILITY STRIP5' UTILITY STRIP5' SIDEWALK2'2.5'2.5'40' ACCESS EASEMENT26'R30'R40'R40'R30'SITE DISTANCETRIANGLE (15'x425')35' B-B5' SIDEWALK5' SIDEWALK5' UTILITY STRIP5' UTILITY STRIP2.5'2'2'2.5'59' ROWR30'R30'R40'R2000'R30'R30'OHN M. & NORMA C. WILLISN/FRUDY M. & FRANCINE A. BURTPIN: 0639526998DB 2219 PG 74N/FCAREY & FREDA P. CAINESPIN: 0639538140DB 2955 PG 10N/FCLIFTON & MATTIE BARBEEPIN: 0639539380DB 2621 PG 90N/FHELIX VENTURES, LLCPIN: 0639633688DB 17498 PG 2164BM 2019 PG 11251.17'2'3.42'1.92'1.42'1.92'2'4'1.5'5.25'1.92'WETLANDS #1AREA = 3,034 SF/0.070 ACWETLANDS #2AREA = 1,171 SF/0.027 ACWETLANDS #4AREA = 9,597 SF/ 0.220 AC3.42'1.58'2.17'2.42'WETLANDS #5AREA = 2,634 SF/ 0.060 ACWETLANDS #6AREA = 44,922 SF/ 1.031 ACWETLANDS #7AREA = 4,593 SF/0.105 AC2.92'2.92'2.58'3.67'INTERM
ITTENT
STREAMINTERMITTENT STREAMINTERMITTENT
STREAMINTERMITTENT STREAMAREA = 766 SF/ 0.018 ACINTERMITTENT STREAM1.75'N/FMARIO L. DONNELLPIN: 0639837443DB 13-E PG 3781N/FHELIX VENTURES, LLCPIN: 0639721436DB 18040 PG 1512BM 2016 PG 595WETLANDS #8AREA = 1,161SF/ 0.027 ACINTERMITTENT STREAM894.19'1605.55
'31531532032032532533
0
33
0
3
3
5335335
34034034034534534535035035035
0
350355355355290295300305310315320325330335340345285285290290290290295295 295295295300300300
305305305305 305305
3
0
5305305310310310310310
3
1
0 310310315315315 315315315315
3153153153203203203203203203203203203203203
2
0
3203
2
0 3253253
2
5
325325325325325325325325 330330330330330330330330330330330 335335335335335335335335335335335335335335
3403403403403403403
4
03403403403403403453453453453
5
0
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1
0 3103103103
1
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315 3153
1
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31
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0
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5325325 3253
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330
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4
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34
5
350330335340345 EXIT DOWN LOOP 6' X 8' ARMING LOOP 6' X 8' ENTRANCE DOWN LOOP 6' X 8' ARMING LOOP 6' X 8' ENTRANCE DOWN LOOP 6' X 8' ARMING LOOP 6' X 8' DOWN
LOOP
6
' X
8'
DOWN LOOP 6
' X
8'
LOD LOD LOD LOD LOD LOD LOD LODLOD LOD LODLODLODLODLODLOD LODLODLODLODLODLODLODLOD
LOD LOD LODLOD
LOD LOD
LODLODLODLODLODLODLODLODLODLODLODLODLODL
O
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L
O
D
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LODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLOD36"
S
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42"SD42"SD42"SD42"SD
48"SD48"SD
24"SD24"
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S
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36"SD36"SD42"SD42"SD
42"SD42"SD36"SD
36"SD 24"SD24"SD36"SD42"SD 24"SD24"SD24"SD24"SD24
"SD24"SD24
"
S
D
24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD42"
S
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24"SD24"SD24"SD
24"SD24"SD24"SD2
4
"
SD24"SD24"SD24"SD 24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24
"
S
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24"SD
W W W W W W W W W W W W W W W W W W W W W
FPFPFPFPSSSSSS SS
SS SS SS SS SS SS SS SSFPFPFPFPFPFPFPFP FP FP
GGGGGGGGGGGGGGGGGSSSSSSSSFPFPFPFPFPFP FP FP FP FPFPFPFPFPFPFPFPFPFPFPSS SS SS SSSSSSFPFPFPFPFPFPFPSSFPFPFPW
W W W W W W W W W
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SSSS SSDSM - PHASE 1DSM - PHASE 1LAB ADMIN - PHASE 1CUB - PHASE 1TANK FARM - PHASE 1DSM - PHASE 2DSM - PHASE 2DSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASELAB ADMIN - FUTURE PHASEPARKINGSTRUCTURE -FUTUREPHASEUGTUGT UGTPARKING STRUCTURE- FUTURE PHASEPOND 1MONTESALE WAYBA
R
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W
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ROAD BY OTHERSROAD BY OTHERSMODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)PONDDIRT TRAILD
I
R
T

TR
A
I
L
DIRT TRAILDIRT
R
OADDIRT ROADDIRT ROADN/FDUKE ENERGY PROGRESS, INC.PIN: 0639721436ACREAGE: 139.98 AC.DB 1961 PG 491 &DB 15289 PG 243715"RCP15"RCP15"RCP15"RCPN/FHELIX VENTURES, LLCPIN: 0639633688ACREAGE: 12.64 AC.DB 17498 PG 2164ZONING: R-30FMWETLANDHOLLY SPRINGS BUFFERS16"X8"JACK &BORETEE W/GATEVALVESBLOW OFF VALVEASSEMBLY (TYP.)12"X12"TAPPINGSLEEVEANDGATEVALVE12"X12"CROSSW/ GATEVALVES8"X8"X8"4"CROSSW/ GATEVALVES8"X8" TEE W/ GATEVALVESFIRE HYDRANTASSEMBLY (TYP)8"PURPLEPVCRECLAIMEDWATERMAIN12" DI WATERLINE8"RECLAIMEDWATER LINESTUB FORTHEDONNELLPROPERTYW/ BLOWOFFVALVEASSEMBLY8" WATERLINE STUBFOR THEDONNELLPROPERTYW/BLOWOFFVALVEASSEMBLYFIRE HYDRANTASSEMBLY (TYP)FIRE HYDRANTASSEMBLY (TYP)FIRE HYDRANTASSEMBLY (TYP)4"RECLAIMEDWATER LINESTUB W/BLOWOFFVALVEASSEMBLY8" WATERLINE STUBW/BLOWOFFVALVEASSEMBLYBLOWOFFVALVEASSEMBLY(TYP)8"PURPLEPVCRECLAIMEDWATERMAIN8"PURPLEPVCRECLAIMEDWATERMAIN12" DI WATERLINE12" X12"TEE W/GATEVALVES12" DIWATERMAINEX. 16"RECLAIMEDWATERLINEEX. 12"WATERMAINRELOCATEDEXISTINGFIREHYDRANTASSEMBLY(TYP)WESTBOUND LEFT TURN LANE150' OF STORAGE AND 100' TAPERPER NCDOT STANDARDSR40'26'15'15'WESTBOUND LEFT TURN LANE100' OF STORAGE AND 100' TAPERSITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')30'22'150' STORAGELENGTH150' DECELERATION100'100'SITE DISTANCETRIANGLE (15'x305')59' ROW15'15'5' SIDEWALK15'2'35' B-B15'5' UTILITY STRIP5' UTILITY STRIP5' SIDEWALK2'2.5'2.5'40' ACCESS EASEMENT26'R30'R40'R40'R30'SITE DISTANCETRIANGLE (15'x425')35' B-B5' SIDEWALK5' SIDEWALK5' UTILITY STRIP5' UTILITY STRIP2.5'2'2'2.5'59' ROWR30'R30'R40'R2000'R30'R30'R300'N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424N/FDUKE ENERGY PROGRESS, INC.PIN: 0638454415DB 15289 PG 2437N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424N/FJOHN M. & NORMA C. WILLISPIN: 0639525817DB 12137 PG 2217N/FFIELDING HOMES TRINITYCREEK, LLCPIN: 0639523135DB 17430 PG 1026BM 2019 PG 809N/FCOS-4TRINITY CREEK PROPERTYOWNERS ASSOCIATIONPIN: 0639515604DB 17008 PG 1344BM 2017 PG 2515N/FRUDY M. & FRANCINE A. BURTPIN: 0639526998DB 2219 PG 74N/FCAREY & FREDA P. CAINESPIN: 0639538140DB 2955 PG 10N/FCLIFTON & MATTIE BARBEEPIN: 0639539380DB 2621 PG 90N/FHELIX VENTURES, LLCPIN: 0639633688DB 17498 PG 2164BM 2019 PG 1125WETLANDS #1AREA = 3,034 SF/0.070 ACWETLANDS #2AREA = 1,171 SF/0.027 ACWETLANDS #4AREA = 9,597 SF/ 0.220 ACWETLANDS #5AREA = 2,634 SF/ 0.060 ACWETLANDS #6AREA = 44,922 SF/ 1.031 ACWETLANDS #7AREA = 4,593 SF/0.105 ACIN
TERM
I
TT
ENT

STRE
AMINTERMITTENT STREAMIN
TERM
I
TT
ENT

STR
EAM
INTERM
ITTENT STREAMWETLANDS #8AREA = 766 SF/ 0.018 ACINTERMITTENT STREAMWETLANDS #9AREA = 11,095 SF/0.25 ACPERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAM
PE
R
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I
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S
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295295
300300
305305
310315320325330335335335340340
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3452852902902
9
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EXIT
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
ENTRANCE
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
ENTRANCE
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
DOWN LOOP 6' X 8'
DOWN LOOP 6' X 8'LODLODLO
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LOD
LODLOD
LODLODLODLODLOD36"
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48
"
S
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36"SD36"SD24"SD24"SD36"SD24"SD36"SD
36"SD
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60"SD60
"
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"
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4
"
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"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24
"
S
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4
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S
D
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"
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D24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD24
"
S
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4
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2
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4
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24"SD24"SD24"SD
10+35
11+47
10+2
410+8
2 10+2810+81W WSSFP
FPW DSM - PHASE 1DSM - PHASE 1LAB ADMIN - PHASE 1CUB - PHASE 1TANK FARM - PHASE 1DPFG - PHASE 1WAREHOUSE -PHASE 1DSM - PHASE 2DSM - PHASE 2DSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASECUB - FUTURE PHASEWAREHOUSE - FUTUREPHASELAB ADM
IN

-
FUTURE
PHASEPARKINGSTRUCTURE -FUTUREPHASESOUTH PARKINGFUTURE EXPANSIONTANK FARM - FUTUREPHASE10+3210+50PARK
ING

S
TRUC
TURE
-
FUTURE

PH
A
SE
POND 1MONTESALE WAYBAR
A
B
E
L
L
A

W
A
Y
ROAD BY OTHERSROAD BY OTHERSMODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)TANK FARMGENERATOR YARD-GRADE TO 2% MAXSLOPEFIRE TANK/PUMP HOUSEPOND 2®PRELIMINARY - NOTFOR CONSTRUCTION30° 0' 00"PLANTNORTHTRUENORTHKEY MAPSCALE: 1" = 1000'0100'200'1"=100'CULVERT 1CULVERT 2CULVERT 3
G 40' PERMANENTCESS EASEMENTDB 12957 PG 1315EXISTING 40' PERMANENTACCESS EASEMENTDB 12957 PG 1315DIRT TRAILDIRT ROAD265265265265270270 270275275 275280 280280285285285285285290 295 300 305310 315 32032527528028529029530
0
305 310
315320325330N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424DUKE ENERGY PROGRESS, INC.N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424WETLANDS #8AREA = 766 SF/ 0.018 ACFLAG LOCATIONFLAG LOCATION42" CMPSURVEYED LOCATION2.58'3.42'5.08'2.59'4.08'3.26'5.17'5.17'6.33'5.5'4.25'2'4.78'8'6.26'5'8'5.08'5.07'4.42'6.33'7.18'4.45'6.08'7'WETLANDS #9AREA = 11,095 SF/0.25 ACTHIS PORTIONNOT DRAWN TO SCALE8.25'7.7'5'7'6.25'7.75'8.75'6.42'4.67'6.17'4.67'10.67'4.42'5.42'12.58'8'8'PERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAMP
E
R
E
N
N
I
A
L

S
T
R
E
A
MPERENNIAL
STREAMPERENNIAL STREAM1.33'1.58'1.58'2'1.67'2.17'3.67'1.42'1.42'1.42'2.17'1.42'1.42'1.67'1.58'1.75'1.42'1.42'2'INTERMITTENT STREAMINTERMITTENT STREAM5.07'WETLANDS #10AREA = 1,239 SF/0.028 ACSSS
SSSSSSS
SSANSANSANSANSANS
A
NSANSANSAN265265265265270270270275275 275280 280280285285285285285290 295 300 305310 315 32032527528028529029530
0
305 310
315320325330265265265270270270270275275275 275280280280 280280285285285285285285290290290290290290290290290290
29529529529529529529529530030
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8
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320
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310
315
320
325270270275275280280280285285285290295280285290295300305310
290
295
295300
300305305
LODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLODLOD LOD LODLODLOD LODLODLO
D
L
O
D
LO
D
LOD
LOD LODLODLODLOD LOD LOD LOD LOD LOD LODLOD LODLODLODLODLOD LOD LOD
LODLODLODLODLODLODLODLODLODLODLODLODLODLODLOD48"SD48"SD
48"SD60"SD60"SD
36"SD
36"SD24"SD24"SD24"SD36"SD
36"SD
36"SD36"SD
60"SD 60"SD
2
4
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SD
24"SD24"SD24"SD24"SD24"SD24"SD24"SD24"SD
24
"
S
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"
S
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24"S
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24"SD24"SD24
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I
R
T

TR
A
I
L
DIRT TRAILDIRT
R
OADDIRT ROADDIRT ROADN/FDUKE ENERGY PROGRESS, INC.PIN: 0639721436ACREAGE: 139.98 AC.DB 1961 PG 491 &DB 15289 PG 243715"RCP15"RCP15"RCP15"RCPN/FHELIX VENTURES, LLCPIN: 0639633688ACREAGE: 12.64 AC.DB 17498 PG 2164ZONING: R-30FMWETLANDHOLLY SPRINGS BUFFERS16"X8"JACK &BORETEE W/GATEVALVESBLOW OFF VALVEASSEMBLY (TYP.)12"X12"TAPPINGSLEEVEANDGATEVALVE12"X12"CROSSW/ GATEVALVES8"X8"X8"4"CROSSW/ GATEVALVES8"X8" TEE W/ GATEVALVESFIRE HYDRANTASSEMBLY (TYP)8"PURPLEPVCRECLAIMEDWATERMAIN12" DI WATERLINE8"RECLAIMEDWATER LINESTUB FORTHEDONNELLPROPERTYW/ BLOWOFFVALVEASSEMBLY8" WATERLINE STUBFOR THEDONNELLPROPERTYW/BLOWOFFVALVEASSEMBLYFIRE HYDRANTASSEMBLY (TYP)FIRE HYDRANTASSEMBLY (TYP)FIRE HYDRANTASSEMBLY (TYP)4"RECLAIMEDWATER LINESTUB W/BLOWOFFVALVEASSEMBLY8" WATERLINE STUBW/BLOWOFFVALVEASSEMBLYBLOWOFFVALVEASSEMBLY(TYP)8"PURPLEPVCRECLAIMEDWATERMAIN8"PURPLEPVCRECLAIMEDWATERMAIN12" DI WATERLINE12" X12"TEE W/GATEVALVES12" DIWATERMAINEX. 16"RECLAIMEDWATERLINEEX. 12"WATERMAINRELOCATEDEXISTINGFIREHYDRANTASSEMBLY(TYP)WESTBOUND LEFT TURN LANE150' OF STORAGE AND 100' TAPERPER NCDOT STANDARDSR40'26'15'15'WESTBOUND LEFT TURN LANE100' OF STORAGE AND 100' TAPERSITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')SITE DISTANCETRIANGLE (15'x305')30'22'150' STORAGELENGTH150' DECELERATION100'100'SITE DISTANCETRIANGLE (15'x305')59' ROW15'15'5' SIDEWALK15'2'35' B-B15'5' UTILITY STRIP5' UTILITY STRIP5' SIDEWALK2'2.5'2.5'40' ACCESS EASEMENT26'R30'R40'R40'R30'SITE DISTANCETRIANGLE (15'x425')35' B-B5' SIDEWALK5' SIDEWALK5' UTILITY STRIP5' UTILITY STRIP2.5'2'2'2.5'59' ROWR30'R30'R40'R2000'R30'R30'R300'N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424N/FDUKE ENERGY PROGRESS, INC.PIN: 0638454415DB 15289 PG 2437N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FSEQUIRUS INC.PIN: 0639914852DB 16104 PG 1384BM 2007 PG 87N/FFIELDING HOMES TRINITY CREEK, LLCPIN: 0639614491DB 17430 PG 1026BM 2019 PG 1424N/FJOHN M. & NORMA C. WILLISPIN: 0639525817DB 12137 PG 2217N/FFIELDING HOMES TRINITYCREEK, LLCPIN: 0639523135DB 17430 PG 1026BM 2019 PG 809N/FCOS-4TRINITY CREEK PROPERTYOWNERS ASSOCIATIONPIN: 0639515604DB 17008 PG 1344BM 2017 PG 2515N/FRUDY M. & FRANCINE A. BURTPIN: 0639526998DB 2219 PG 74N/FCAREY & FREDA P. CAINESPIN: 0639538140DB 2955 PG 10N/FCLIFTON & MATTIE BARBEEPIN: 0639539380DB 2621 PG 90N/FHELIX VENTURES, LLCPIN: 0639633688DB 17498 PG 2164BM 2019 PG 1125WETLANDS #1AREA = 3,034 SF/0.070 ACWETLANDS #2AREA = 1,171 SF/0.027 ACWETLANDS #4AREA = 9,597 SF/ 0.220 ACWETLANDS #5AREA = 2,634 SF/ 0.060 ACWETLANDS #6AREA = 44,922 SF/ 1.031 ACWETLANDS #7AREA = 4,593 SF/0.105 ACIN
TERM
I
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ENT

STRE
AMINTERMITTENT STREAMIN
TERM
I
TT
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STR
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ITTENT STREAMWETLANDS #8AREA = 766 SF/ 0.018 ACINTERMITTENT STREAMWETLANDS #9AREA = 11,095 SF/0.25 ACPERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAMPERENNIAL STREAM
PE
R
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N
N
I
A
L

S
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A
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PER
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N
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N/FMARIO L. DONNELLPIN: 0639837443DB 13-E PG 3781N/FHELIX VENTURES, LLCPIN: 0639721436DB 18040 PG 1512BM 2016 PG 595INTERMITTENT STREAMINTERMITTENT STREAMWETLANDS #8AREA = 1,161SF/ 0.027 ACINTERMITTENT STREAM5.07'WETLANDS #10AREA = 1,239 SF/0.028 ACEX MH 1B290290
295295
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9
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290
295
295300
300305305
EXIT
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
ENTRANCE
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
ENTRANCE
DOWN LOOP 6' X 8'
ARMING LOOP 6' X 8'
DOWN LOOP 6' X 8'
DOWN LOOP 6' X 8'LODLODLO
D LODLOD
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48
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S
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24"SD24"SD24"SD
10+35
11+47
10+2
410+8
2 10+2810+81W WSSFP
FPW DSM - PHASE 1DSM - PHASE 1LAB ADMIN - PHASE 1CUB - PHASE 1TANK FARM - PHASE 1DPFG - PHASE 1WAREHOUSE -PHASE 1DSM - PHASE 2DSM - PHASE 2DSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASEDSM - FUTURE PHASECUB - FUTURE PHASEWAREHOUSE - FUTUREPHASELAB ADM
IN

-
FUTURE
PHASEPARKINGSTRUCTURE -FUTUREPHASESOUTH PARKINGFUTURE EXPANSIONTANK FARM - FUTUREPHASE10+3210+50PARK
ING

S
TRUC
TURE
-
FUTURE

PH
A
SE
POND 1MONTESALE WAYBAR
A
B
E
L
L
A

W
A
Y
ROAD BY OTHERSROAD BY OTHERSMODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)MODULARRETAINING WALL(TYP.)TANK FARMGENERATOR YARD-GRADE TO 2% MAXSLOPEFIRE TANK/PUMP HOUSEPOND 2®PRELIMINARY - NOTFOR CONSTRUCTION30° 0' 00"PLANTNORTHTRUENORTHKEY MAPSCALE: 1" = 1000'0100'200'1"=100'CULVERT 4
CULVERT 1 PROFILEScale: 1"=50' H, 1"=5' V3153203253303353403153203253303353409+9010+0011+0011+15CULVERT 1 CROSS SECTION10+27.67Scale: 1" = 50' H, 1" = 50' V29030031032033034035036029030031032033034035036001020300-10-20-30CULVERT 1 CROSS SECTION10+81.49Scale: 1" = 50' H, 1" = 50' V30031032033034035036030031032033034035036001020300-10-20-30PROPOSED GRADEEXISTING GRADEPROPOSEDGRADEEXISTINGGRADEPROPOSEDGRADEEXISTINGGRADE72 LF
60
"
RCP
@
5
.39%60" RCP60" RCPENDWALLHEADWALLCULVERT 2 PROFILEScale: 1"=50' H, 1"=5' V3053103153203253303353403053103153203253303353409+9010+0011+0011+10CULVERT 2 CROSS SECTION10+24.13Scale: 1" = 50' H, 1" = 50' V29030031032033034035036029030031032033034035036001020300-10-20-30CULVERT 2 CROSS SECTION10+82.21Scale: 1" = 50' H, 1" = 50' V29030031032033034035036029030031032033034035036001020300-10-20-3061 LF 60" RCP @ 1.88%PROPOSEDGRADEEXISTINGGRADEPROPOSEDGRADEEXISTINGGRADEPROPOSED GRADEEXISTING GRADE60" RCP60" RCPENDWALLHEADWALLCULVERT 4 PROFILEScale: 1"=50' H, 1"=5' V2652702752802852902952652702752802852902959+5010+0011+0012+0012+50CULVERT 4 CROSS SECTION10+35.14Scale: 1" = 50' H, 1" = 50' V240250260270280290300310320240250260270280290300310320010203040500-10-20-30-40-50CULVERT 4 CROSS SECTION11+46.60Scale: 1" = 50' H, 1" = 50' V25026027028029030031025026027028029030031001020300-10-20-30113 LF 72" RCP @ 0.24%PROPOSEDGRADEEXISTINGGRADEPROPOSEDGRADEEXISTINGGRADEPROPOSED GRADEEXISTING GRADEEXISTING 72" CMPCONNECT TO EXIST.CMP WITH 24"CONCRETE COLLAR72" RCP72" RCPENDWALL325330 N/FHELIX VENTURES, LLCPIN: 0639633688ACREAGE: 12.64 AC.DB 17498 PG 2164ZONING: R-30325330LODLODLODLOD LOD LOD LOD LOD LODLODLODLODLODLODLODLODLODLOD10+2810+813153153203203253252'4'AREA = 2,634 SF/ 0.060 AC1605.55
'315315320320325325LODLODLOD
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LOD
LODLODLODLODLODLODLODLODLODLOD24"SD24"SD10+2
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2DIRT ROAD6.42'4.67'PERENNIAL
STREAM20012498.57CP 2001272973269.37IE E 72" CMPSSANSANS
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285
LODLODLODLODLODLODLODLOD
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11+47
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UGPUGP3.42'1.58'2.17'INTERMITTENT STREAM305 305310 310315 315LODLODLODLODLODW W W W W W WUGTUGT10+3210+50CULVERT 3 CROSS SECTION10+32.13Scale: 1" = 50' H, 1" = 50' V28029030031032033028029030031032033001020300-10-20-30CULVERT 3 CROSS SECTION10+49.86Scale: 1" = 50' H, 1" = 50' V28029030031032033028029030031032033001020300-10-20-30CULVERT 3 PROFILEScale: 1"=50' H, 1"=5' V29530030531031529530030531031510+0010+81PROPOSEDGRADEEXISTINGGRADE18 LF 60" RCP @ 0.79%EXISTINGGRADEPROPOSEDGRADEEXISTINGGRADEPROPOSEDGRADE®PRELIMINARY - NOTFOR CONSTRUCTION30° 0' 00"PLANTNORTHTRUENORTH24" CONCRETECOLLARCONNECTION050'100'1"=50'150'CULVERT 1 PLANScale: 1" = 50'CULVERT 2 PLANScale: 1" = 50'CULVERT 4 PLANScale: 1" = 50'CULVERT 4EXIST. 72" CMPCULVERT 1CULVERT 2CULVERT 3 PLANScale: 1" = 50'CULVERT 3TEMPORARYSTREAMCROSSING

ATTACHMENT 2

ALTERNATIVES ANALYSIS AND SUPPORTING DOCUMENTS

ALTERNATIVE ANALYSIS

Introduction

Fujifilm Diosynth Biotechnologies U.S.A., Inc (FDBU; the Applicant) completed an extensive site
selection process for Project Galaxy, aided by the consultant firm Jacobs Engineering (Jacobs).
The initial site selection process focused on three important criteria: proximity to an existing FDBU
facility, overall business climate, and Life Sciences business climate. FDBU currently has facilities
in three states: Massachusetts, North Carolina, and Texas. In Site Selection’s 2020 State
Business Climate Rankings, North Carolina placed first, Texas placed fourth, and Massachusetts
was unranked (ranked greater than 25). The Raleigh-Durham Metro area ranked fifth in JLL’s
2020 U.S. Life Sciences Outlook and Houston ranked 11th (see Appendix A: Offsite Alternative
Analysis Documents). Thus, North Carolina and Texas were shortlisted due to good general and
sector specific rankings and proximity to an existing FDBU facility.

In choosing between North Carolina and Texas, FDBU and Jacobs applied six different criteria
(with weighting percentages given in parentheses): skilled workforce (30% weighted), business
environment (20%), real estate & infrastructure (20%), supply chain (12.5%), risk management
(12.5%), and transportation (5%). North Carolina scored much higher in skilled workforce and real
estate & transportation and received a final score of 73.94, compared to Texas at 63.21 (see
Appendix A: Offsite Alternative Analysis Documents).

The existing FDBU facility in North Carolina is in Morrisville, Wake County, which is within the
Raleigh-Durham-Cary Combined Statistical Area (CSA). This CSA offers convenient access to
three Interstates (I-40, I-85, I-87), seven U.S. Routes (1, 15, 64, 70, 264, 401, 501), numerous
rail stations, and Raleigh-Durham Airport. This CSA also contains the Research Triangle Park
(RTP), which would provide the talented and skilled workforce that is critical for Project Galaxy.
Based on these factors (proximity to the existing FDBU facility, access to transportation, and
availability of skilled workforce), the Applicant identified the Raleigh-Durham-Cary CSA as the
ideal geographic location for the development of a biopharmaceutical manufacturing facility and
campus.

Facility components, at final build-out, are anticipated to consist of a total of 3,459,000 square
feet (approximately 79 acres) of buildings and two multi-story spine structures that will serve as
connector hubs for personnel, materials, and utilities. The Spine structures are a critical design
element of Project Galaxy. They will provide support for all buildings on the campus as a
connective circulation device and will allow for efficient delivery of personnel and materials. The
use of the Spine-design necessitates the need for a contiguous area for site development.
Because the buildings must be connected to this Spine, avoiding impacts to streams and wetlands
by placing the buildings in scattered locations was infeasible.

The full site design also includes appropriate stormwater controls, parking, ancillary buildings
(such as tank farms and electrical cabins), access roadways and drives, and trailer storage.
Access is proposed from Holly Springs-New Hill Road at two locations.

Based on the identified geographic location and required site design, multiple alternatives were
evaluated to determine the Least Environmentally Damaging Practicable Alternative (LEDPA).
These alternatives included: (a) no action alternative, (b) no permit required alternative, (c) off-
site alternatives, and (d) on-site alternatives. After consideration of available alternatives to meet

the needs of the project, the Preferred Alternative, as proposed, is considered the Least
Environmentally Damaging Practicable Alternative (LEDPA).

FDBU consulted with the Economic Development Partnership of North Carolina to determine
available sites within the Raleigh-Durham-Cary CSA that may meet the project’s needs. FDBU
then applied several criteria to identify the preferred alternative. These criteria included the
following:
· Proximity to existing facility in Morrisville, NC
· Proximity to workforce for the construction of the project
· Proximity to skilled life sciences workforce
· Regularity/Contiguity of developable area
· Ability to accommodate the full build-out of the program
· Access to existing infrastructure
· Favorable zoning
· Low costs for site construction and development
· Magnitude of environmental impacts, including WOTUS impacts

No Action Alternative

The No Action Alternative, which would avoid all impacts to aquatic resources, is not a viable
option given the purpose and need of the Project. Under the No Action Alternative, the proposed
development of the biopharmaceutical manufacturing facility and campus would not result in
impacts to Jurisdictional Waters of the U.S. and would not require the issuance of a 404/401
Individual Permit. The Applicant evaluated the possibility of delaying investment in a new facility.
However, it was determined that the increased need for a domestic supply of drug products and
prospective job opportunities necessitates development.

No Permit Required Alternative

The No Permit Required Alternative, which would avoid all impacts to aquatic resources, is not a
viable option given the purpose and need of the Project. Under the No Permit Required
Alternative, the proposed facility and campus would be built without any impacts to Jurisdictional
Waters of the U.S. and would not require the issuance of a 404/401 permit. The Applicant
investigated available sites within the Raleigh-Durham-Cary CSA that: 1) were large enough to
accommodate the full build out of the facility and campus and 2) would result in no impacts to
Jurisdictional Waters of the U.S. However, it was concluded that no such sites were available.

Offsite Alternatives

Several parcels were evaluated as potential project locations for the proposed biopharmaceutical
manufacturing facility and campus. Five sites were closely evaluated based on the criteria
described in Table 1 below. Exhibits depicting the alternative locations are included as Appendix
A: Offsite Alternative Analysis Documents.

Alternative 1, referred to as the Cornwallis Road site, is located at approximately 3029 E.
Cornwallis Road in Durham County. The site is currently zoned as Science Research Park (SRP).
The site has generally flat topography, has readily available access to utilities, and is also the
closest of the evaluated sites to the existing FDBU facility in Morrisville, NC. However, while the
site contains enough acreage (approximately 110 acres) to accommodate the initial phases of

Project Galaxy, the estimated final build-out of the site is only estimated at 1,500,000 square feet,
which would be well short of the 3,459,000 square feet that would be required by Project Galaxy.
In addition, the site was the previous location of a textiles research and development and
manufacturing facility operated by the Monsanto Company and is now recorded as a Brownfield
as of July 2020. The site is currently undergoing active site remediation to reduce site
contaminants. The time constraints that are associated with the site remediation and Brownfield
development would severely reduce the speed at which FDBU wishes to develop the property for
a biopharmaceutical facility and would not meet the needs of the project. Lastly, there are existing
buildings, roadways, parking lots, and other amenities present on the site that would increase the
costs of site preparation.

Alternative 2, referred to as the Junction East site, is located at approximately 1200 Junction Road
in Durham County. The site is currently zoned as Industrial Light (IL). This site was one of the
largest properties considered, at approximately 191 acres with the possibility to expand to 250
acres. The site is also approximately 15 miles from the existing FDBU Morrisville location and has
readily available access to utilities. However, this site has topographical challenges such as
extreme grade changes and contains a significant amount of rock which would require extensive
blasting in order to regrade the property. The site also contains over 6,000 feet of potentially
jurisdictional stream and associated riparian buffers, including approximately 2,000 linear feet of
stream and associated 100-year floodplain that bisects the site. Thus, the significant costs of site
development associated with rock removal, the topographical challenges, and the location and
amount of potentially jurisdictional streams and wetlands have made this parcel not as viable as
the preferred alternative.

Alternative 3, referred to as the Hamlin Road site, is located at approximately 1507 Hamlin Road
in Durham County. The site is currently zoned as Industrial Light (IL). This site is large enough to
accommodate the full Project Galaxy build-out and is within 19 miles of the existing FDBU
Morrisville facility. The site also has readily available access to utilities. However, similar to the
Junction East site, Hamlin Road presented significant topographical challenges and contains a
high degree of rock which increased site development costs. The site is also bisected by a
railroad, which would reduce the regularity of the developable area. Lastly, the developed site
would lie next to an elementary school, which could potentially create safety issues, significant
public controversy, and delay the development of the project.

Alternative 4, referred to as Industrial Park West, is located at approximately 0 Hawkins Avenue
in Lee County. The site is currently zoned as Heavy Industrial (HI). This site is the largest of all
the sites considered at approximately 300 acres. The county and the local municipality also
offered significant amounts of incentives for Project Galaxy compared to most of the other
considered sites. However, the distance of this site from the existing facility in Morrisville
(approximately 35 miles away) and the lack of readily available infrastructure and utility access
would increase the site development costs and potentially reduce the availability of the skilled
workforce required to operate the facility. In addition, the site contains a significant acreage of
100-year floodplains and potentially jurisdictional streams and wetlands.

The Holly Springs Business Park site was determined to provide the Applicant with the most value
based on the evaluation criteria examined. This site provides enough regular buildable area for
the full Project Galaxy development and is within 20 miles of the existing FDBU facility in
Morrisville. The site will have readily available access to utilities, including access to a renewable
energy source that will fit the sustainability goals of FDBU. The parcel is appropriately zoned as
Research Technology and is also designated as a foreign trade zone. Lastly, the Town of Holly

Springs has offered several incentives that have reduced the cost of site development. Though
jurisdictional impacts will be required, this site represents the Lease Environmentally Damaging
Practicable Alternative (LEDPA) based on availability, cost, logistics, and technology.

Table 1: Evaluation Criteria

Preferred
Alternative
Cornwallis
Road
Junction
East
Hamlin
Road
Industrial
Park
West
Regular buildable area X X X X X
Can fit initial program X X X X X
Can fit full program and support
facilities X X X X
Proximity to existing facility in
Morrisville X X X X
Proximity to available workforce
and market
X X X X
Presence of existing
infrastructure X X X X

Favorable zoning and lack of
other site restrictions X X X X
Minimal topographic challenges X X
X
Cost to develop X X
X
Local incentives X
X
Environmental Impacts X

Onsite Alternatives

Due to the needs of the project, in conjunction with the location of aquatic resources present
throughout the Site, impacts to surface waters are unavoidable, and therefore, development could
not occur without an Individual Permit. The project area was examined to develop the proposed
facility and campus in a manner that avoids and minimizes impacts to environmentally sensitive
areas to the maximum extent practicable, while meeting configuration requirements necessary to
provide efficient long-term operation of the facility. In order to fit all future phases of the project
and access existing roads, adjusting the layout to completely avoid surface waters onsite would
not be suitable for the proposed project.

An initial Site Master Plan was developed in February 2021 (see Appendix B: Onsite Alternatives).
This plan examined the feasibility of a U-shaped Spine and an access road encircling the entire
site. Grading and site utilities were not developed for this design, but it was anticipated that this
February alternative would have impacted the entire northern stream and wetland complex and a

complete impact of Stream Feature L to the south. In addition, portions of Stream Feature K on
the western portion of the property would likely be impacted due to grading. The February site
layout was later deemed infeasible because the north-south access road exiting the property to
the South would be too close to the neighboring Trinity Creek residential subdivision. The current
revised site layout that is submitted with the response to the Request for Additional Information
(RFAI) eliminates most of the northern stream and wetland impacts and does not impact Stream
Feature K.

An updated layout alternative was included with the Initial Individual Permit application (see
Appendix B: Onsite Alternatives). This layout would have resulted in approximately 1.33 acres of
permanent wetland impacts and 3,313 linear feet and 0.18 acres of stream impacts. This layout
was also deemed infeasible because of the proposed placement of the electrical infrastructure
equipment (labelled as “electrical” in the impact map). It was later determined by Duke Energy
and its subcontractors that the proposed placement of this electrical infrastructure pad was unsafe
due to being placed on the side of a hill and too small to fit the power generation needs of the
project. It was determined that this electrical infrastructure pad should be placed at the southern
end of the property to best fit the project’s needs.

The revised layout submitted with this response to the RFAI has greatly reduced impacts from
the initial site plans. The revised layout now only permanently impacts 0.301 acres of PFO
wetlands and 1,738 linear feet and 0.102 acres of streams.

Preferred Alternative

The current layout presented was determined to be the LEDPA as it meets the necessary site
requirements while minimizing impacts to environmental resources compared to other
alternatives (Figure 6: Wetlands and Waters Impacts Map). This layout will provide long-term
capacity to fill the project’s needs and allow for the future expansion of the project.

Conclusion

The proposed facility at the Holly Springs Business Park was determined to be the most
practicable long-term solution by providing the largest benefit to the Applicant. The proposed
property and site design meets the requirements of: 1) a large enough area that can fit the full
Project Galaxy program, 2) close proximity to the existing FDBU facility in Morrisville, 3) few
obstacles to site development, and 4) minimal environmental impacts as is practicable.

APPENDIX A

OFFSITE ALTERNATIVE ANALYSIS DOCUMENTS
www.fujifilmdiosynth.comConfidential and Proprietary4The initial scan shortlisted NC and TX as the top candidate states based on proximity to existing FF sites and overall and sector-specific business climate rankingsOverall Business ClimateSector-specific Business ClimateExisting FUJIFILM Mfg LocationsExisting FF facilities in 25 states of which FDB facilities in 3 states (MA, TX, NC)FF facilities located in 8 of top-10 states in the overall business climate rankings. FDB facilities in 2 of top-4 ranked states.FF facilities in 12 of top-14 cluster states. FDB facilities in MA and NC located inside cluster regions FDB facility in TX located 100 miles from HoustonTexas and North Carolina shortlisted due to good general and sector specific rankings and proximity to existing FDB facilities.FDBFDBFFFFFFFFFFFFFFFFFFFFFFFFFDBFDBFFFDBFFFFFFFFFFFFFFFF
New Drug Substance Manufacturing Campus
Regional Comparison - OverviewRev B: 19 Oct 2020
SITE SELECTION
REGIONAL COMPARISON:
In order to recommend a preferred location for the proposed facility, the two candidate regions of Research
Triangle Park (RTP) in North Carolina and in the Brazos Valley of Texas were compared to one another using six
sets of criteria.
Each of the six major categories contains a set of discrete subcategories relevant to that domain, which were
then weighted within the category. This establishes a weighted score (raw score x weight factor) for each
region in each category. For example, the weighted score for RTP in the category of Skilled Workforce is
64.10, compared to a weighted score for the Brazos Valley of 53.85.
In collaboration with the client, the six categories were given a prioritized weight to reflect the relative
importance of each category in making a selection. Each category's weighted score is then multiplied it by this
prioritized weight to get its overall prioritized score. The categories and prioritized weightings are as follows:
- Skilled Workforce: reflecting the cost of and access to labor (30%)
- Business Environment: reflecting the availability of Economic Development incentives, ease of permitting,
and overall “business friendly” setting (20%)
- Real Estate & Infrastructure: the cost and availability of suitable sites for development (20%)
- Supply Chain: access to key suppliers and customers (12.5%)
- Risk Management: the relative exposure of each region to disruptions due to natural disasters (12.5%)
- Transportation: including safety and capacity of major roadways, as well as airport service (5%)
Using this approach, the highest scoring region on both a weighted and prioritized basis is RTP, with a score of
73.94, compared to Brazos Valley’s score of 63.21.
RTP scored higher than Brazos Valley in three of the six categories: Skilled Workforce, Real Estate &
Infrastructure, and Supply Chain. Brazos Valley scored higher in Business Environment, Risk Management, and
Transportation. RTP pulled away through strong scores in the highly-weighted Skilled Workforce and Real
Estate categories. There was also significant differentiation in Supply Chain, where RTP showed clear
advantages, and Transportation, where Texas outperformed.
Fujifilm Diosynth Biotechnologies
Site Selection Comments and Description of Purpose
Greenfield DS Manufacturing facility
21 Oct 2020
RTP Candidate Sites
A
B
C
D
E
F
G
H JI
13
2
K
L
M
10 miles20 miles30 miles
A
1 Initial Cost Comparison Sites
All sites from Economic Development Authority
A Short Listed Sites
Existing Facility
Candidate Sites & Short List Considerations
©Jacobs 2020 2
•Proximity
•To existing facility
•To workers & market
•Is it within RTP?
•Initial Test Fit
•Regularity of developable area
•Can it fit the full program?
(8 cells & support facilities)
•Development constraints
•Existing infrastructure
•Speed & timeline
•Site prep costs
Manufacturing Jobs in
Region
©Jacobs 2020 3
Manufacturing Workforce in Region
10 miles20 miles30 miles10 miles20 miles30 miles
E) 3029 E. Cornwallis Rd, Durham County, NC
©Jacobs 2020 4
•7.8 miles away (closest site)
•110 acres (enough usable acres)
•Brownfield development
•Build to suit opportunity in RTP
•Existing Genesis development plans did
not leave enough space to fit the full
program of the Galaxy project
SHORT LIST (1 of 5)
K) Holly Springs Business Park, Wake County,
NC
©Jacobs 2020 5
•17.5 miles away
•125-150 acres
•Zoned for planned unit development
& designated as foreign trade zone
•Owner occupied & build-to-suit
options available
•This site chosen for the project
Seqirus
SHORT LIST (2 of 5)
F) Junction East, Durham County, NC
©Jacobs 2020 6
•15 miles away
•191 acres
•Potential expansion to 250+ acres
•Disqualified due to topography,
wetlands, and cost to develop site
due notable rock removal
SHORTLIST (3 of 5)
D) 1507 Hamlin Rd. Durham County, NC
©Jacobs 2020 7
•19 miles away
•160.73 acres
•Zoned for Light Industrial
•ENO Venture Park
•Disqualified due to topography, wetlands, and cost to
develop site due notable rock removal
SHORTLIST (4 of 5)
I) Industrial Park West, Lee County, NC
©Jacobs 2020 8
•34.6 miles away
•300 acres (in two
tracks, subdivide-
able)
•Disqualified due to
travel distances and
utility services
SHORTLIST (5 of 5)
APPENDIX B

ONSITE ALTERNATIVES
2
12 February 2021
Feasibility study
•4 dbl. DSM Modules
•1 expandable DPFG Bldg.
•2 expandable WH
•1 expandable Lab/Admin/
Amenity Building
•U shaped Spine and Ring
Road
•DSM support lockering
and office space in
Adjacent WH

ATTACHMENT 3

NCWAM AND NCSAM DOCUMENTATION

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Sheet 7
Sheet 8
Sheet 3
Sheet 5
SAM-33B1-1
SAM-40A1-2
SAM-33C1-1
SAM-40A1-1
SAM-33A1-1
WAM-40B1-1
WAM-40F 1-1
WAM-40C1-1
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Path: Y:\805\48455 - Project Galaxy FDBU\GIS\WTDM\48455-WTDM.mxdLegend
Project Study Limits- 147.5 AcresPreviously Permitted By Others
")X Stream Identifier
!(X Wetland Identifier
gM/Wetland Flag
A Field Data Station
k WAM PointSAM ReachPerennial Stream (R3)Intermittent Stream (R4)CulvertPalustrine Forested (PFO) WetlandsPalustrine Open Water (POW)Topographic ContoursMajor - 10 FeetMinor - 1 Foot
³
0 500 1,000250
Feet
1. Waters of the U.S. within the project study limits have beensurvey located by Timmons Group.2.Waters of the U.S. have not been confirmed by the U.S. ArmyCorps of Engineers until stamped.3. Project limits are survey located.4. Topography based on USGS LiDAR.5. Cowardin Stream Classifications are based solely on fieldobservations. No formal Stream assessment methodology wascompleted to determine these Cowardin Classifications.These plans and associated documents are the exclusive property of TIMMONS GROUP and may not be reproduced in whole or in part and shall not be used for any purpose whatsoever, inclusive, but not limited to construction, bidding, and/or construction staking without the express written consent of TIMMONS GROUP.EnvironmentalJOB NUMBER
CHECKED BY
SCALE
SHEET NO.
DATE
DESIGNED BY
DRAWN BYYOUR VISION ACHIEVED THROUGH OURSSite DevelopmentResidentialInfrastructureDATEREVISION DESCRIPTIONTHIS DRAWING PREPARED AT THE1001 Boulders Parkway, Suite 300 | Richmond, VA 23225TEL [phone] FAX [phone] www.timmons.comCORPORATE OFFICETechnologyPROJECT GALAXY FDBUFIGURE 6: WETLANDS AND WATERS DELINEATION MAP48455WAKE COUNTY, NORTH CAROLINA06/11/2021
M. COOLEY

M. COOLEY
L.NORRIS-HEFLIN
1 " = 500 '
1 of 8
PFO(sq ft)PSS(sq ft)PEM(sq ft)POW(sq ft)R3(lf)R4(lf)R6(lf)Ditch(lf)Stream(sq ft)A 0 0 0 3,034 0 0 0 0 0
NT/NVB1,171 0 0 0 0 0 0 0 0
NT/VC9,597 0 0 0 0 0 0 0 0
NT/VD2,634 0 0 0 0 0 0 0 0
NT/VE43,333 0 0 0 0 0 0 0 0
NT/VF4,593 0 0 0 0 0 0 0 0
NT/VG10,156 0 0 0 0 0 0 0 0
NT/VH2780 0 0 0 0 0 0 0
NT/VI1,054 0 0 0 0 0 0 0 0
NT/VJ0 0 0 0 0 1,905 0 0 4,008 NT/NVK0 0 0 0 0 1,146 0 0 3,478 NT/NVL0 0 0 0 0 1,114 0 0 2,243 NT/NVM0 0 0 0 0 993 0 0 2,292 NT/NVN0 0 0 0 2,142 0 0 0 13,088 NT/NVO0 0 0 0 931 0 0 0 2,637 NT/NVP0 0 0 0 0 204 0 0 204 NT/NVTotal72,816 0 0 3,034 3,073 5,362 0 0 27,950
Resource Identification
Confirmation ResourceDescriptionNotes*
Total Wetland Area =75,850 sq ft 1.74 ac
* T=Tidal; NT=Non-tidal; V=Vegetated; NV=Non-Vegetated; PFO=Palustrine Forested Wetland; PSS=Palustrine Scrub-Shrub Wetland; PEM=Palustrine Emergent Wetland; POW= Palustrine Open Water; EIW= Estuarine Intertidal Wetlands; R3= Upper Perennial Streams; R4=Intermittent Streams;R6 = Ephemeral Streams
Total Stream Area =27,950 sq ft 0.64 acTotal Stream Length =8,435 lf
NC SAM FIELD ASSESSMENT FORM
Accompanies User Manual Version 2.1
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5-minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the “Notes/Sketch” section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Project Galaxy FDBU 2. Date of evaluation: 07/28/2021
3. Applicant/owner name:
FUJIFILM Diosynth Biotechnologies
USA, Inc. 4. Assessor name/organization:
Morgan Gilbert - Timmons
Group
5. County: Wake 6. Nearest named water body
on USGS 7.5-minute quad: Utley Creek (18-7-5.5) 7. River basin: Cape Fear
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.6499, -78.8736
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): SAM-33A1-1 10. Length of assessment reach evaluated (feet): 994
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 0.4 Unable to assess channel depth.
12. Channel width at top of bank (feet): 2 13. Is assessment reach a swamp steam? Yes No
14. Feature type: Perennial flow Intermittent flow Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: Mountains (M) Piedmont (P)Inner Coastal Plain (I) Outer Coastal Plain (O)
16. Estimated geomorphic
19 valley shape (skip for
Tidal Marsh Stream):
A B
(more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip Size 1 (< 0.1 mi2) Size 2 (0.1 to < 0.5 mi2)Size 3 (0.5 to < 5 mi2) Size 4 (≥ 5 mi
2)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? Yes No If Yes, check all that apply to the assessment area.
Section 10 water Classified Trout Waters Water Supply Watershed (I II III IV V)
Essential Fish Habitat Primary Nursery Area High Quality Waters/Outstanding Resource Waters
Publicly owned property NCDWR Riparian buffer rule in effect Nutrient Sensitive Waters
Anadromous fish 303(d) List CAMA Area of Environmental Concern (AEC)
Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in “Notes/Sketch” section or attached? Yes No

1. Channel Water – assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
A Water throughout assessment reach.
B No flow, water in pools only.
C No water in assessment reach.
2. Evidence of Flow Restriction – assessment reach metric
A At least 10% of assessment reach in-stream habitat or riffle-pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
B Not A
3. Feature Pattern – assessment reach metric
A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
B Not A
4. Feature Longitudinal Profile – assessment reach metric
A Majority of assessment reach has a substantially altered stream profile (examples: channel down-cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
B Not A
5. Signs of Active Instability – assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down-cutting (head-cut), active widening, and artificial hardening (such as concrete, gabion, rip-rap).
A < 10% of channel unstable
B 10 to 25% of channel unstable
C > 25% of channel unstable

6. Streamside Area Interaction – streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
A A Little or no evidence of conditions that adversely affect reference interaction
B B Moderate evidence of conditions (examples: berms, levees, down-cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
C C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
7. Water Quality Stressors – assessment reach/intertidal zone metric
Check all that apply.
A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
B Excessive sedimentation (burying of stream features or intertidal zone)
C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
D Odor (not including natural sulfide odors)
E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in “Notes/Sketch”
section.
F Livestock with access to stream or intertidal zone
G Excessive algae in stream or intertidal zone
H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
I Other: (explain in “Notes/Sketch” section)
J Little to no stressors
8. Recent Weather – watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
C No drought conditions
9. Large or Dangerous Stream – assessment reach metric
Yes No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In-stream Habitat Types – assessment reach metric
10a. Yes No Degraded in-stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in-stream hardening [for example, rip-rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
A Multiple aquatic macrophytes and aquatic mosses
(include liverworts, lichens, and algal mats)
B Multiple sticks and/or leaf packs and/or emergent
vegetation
C Multiple snags and logs (including lap trees)
D 5% undercut banks and/or root mats and/or roots
in banks extend to the normal wetted perimeter
E Little or no habitat
F 5% oysters or other natural hard bottoms
G Submerged aquatic vegetation
H Low-tide refugia (pools)
I Sand bottom
J 5% vertical bank along the marsh
K Little or no habitat

*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate – assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. Yes No Is assessment reach in a natural sand-bed stream? (skip for Coastal Plain streams)
11b. Bedform evaluated. Check the appropriate box(es).
A Riffle-run section (evaluate 11c)
B Pool-glide section (evaluate 11d)
C Natural bedform absent (skip to Metric 12, Aquatic Life)
11c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach – whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) = > 10-40%, Abundant (A) = > 40-70%, Predominant (P) = > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
Bedrock/saprolite
Boulder (256 – 4096 mm)
Cobble (64 – 256 mm)
Gravel (2 – 64 mm)
Sand (.062 – 2 mm)
Silt/clay (< 0.062 mm)
Detritus
Artificial (rip-rap, concrete, etc.)
11d. Yes No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Check for Tidal Marsh Streams Only
12. Aquatic Life – assessment reach metric (skip for Tidal Marsh Streams)
12a. Yes No Was an in-stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. No Water Other:
12b. Yes No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to “individuals” for Size 1 and 2 streams and “taxa” for Size 3 and 4 streams.
Adult frogs
Aquatic reptiles
Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
Beetles
Caddisfly larvae (T)
Asian clam (Corbicula)
Crustacean (isopod/amphipod/crayfish/shrimp)
Damselfly and dragonfly larvae
Dipterans
Mayfly larvae (E)
Megaloptera (alderfly, fishfly, dobsonfly larvae)
Midges/mosquito larvae
Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
Mussels/Clams (not Corbicula)
Other fish
Salamanders/tadpoles
Snails
Stonefly larvae (P)
Tipulid larvae
Worms/leeches
13. Streamside Area Ground Surface Condition – streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
A A Little or no alteration to water storage capacity over a majority of the streamside area
B B Moderate alteration to water storage capacity over a majority of the streamside area
C C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage – streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
A A Majority of streamside area with depressions able to pond water ≥ 6 inches deep
B B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
C C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence – streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
Y Y Are wetlands present in the streamside area?
N N
16. Baseflow Contributors – assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
A Streams and/or springs (jurisdictional discharges)
B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
C Obstruction passing flow during low-flow periods within the assessment area (beaver dam, leaky dam, bottom-release dam, weir)
D Evidence of bank seepage or sweating (iron in water indicates seepage)
E Stream bed or bank soil reduced (dig through deposited sediment if present)
F None of the above
17. Baseflow Detractors – assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
B Obstruction not passing flow during low-flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
C Urban stream (≥ 24% impervious surface for watershed)
D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
E Assessment reach relocated to valley edge
F None of the above
18. Shading – assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider “leaf-on” condition.
A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
B Degraded (example: scattered trees)
C Stream shading is gone or largely absent
19. Buffer Width – streamside area metric (skip for Tidal Marsh Streams)
Consider “vegetated buffer” and “wooded buffer” separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
A A A A ≥ 100 feet wide or extends to the edge of the watershed
B B B B From 50 to < 100 feet wide
C C C C From 30 to < 50 feet wide
D D D D From 10 to < 30 feet wide
E E E E < 10 feet wide or no trees
20. Buffer Structure – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 (“Vegetated” Buffer Width).
LB RB
A A Mature forest
B B Non-mature woody vegetation or modified vegetation structure
C C Herbaceous vegetation with or without a strip of trees < 10 feet wide
D D Maintained shrubs
E E Little or no vegetation
21. Buffer Stressors – streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
A A A A A A Row crops
B B B B B B Maintained turf
C C C C C C Pasture (no livestock)/commercial horticulture
D D D D D D Pasture (active livestock use)
22. Stem Density – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 (“Wooded” Buffer Width).
LB RB
A A Medium to high stem density
B B Low stem density
C C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer – streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
A A The total length of buffer breaks is < 25 percent.
B B The total length of buffer breaks is between 25 and 50 percent.
C C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition – streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
A A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
B B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear-cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
C C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non-characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity – assessment reach metric (skip for all Coastal Plain streams)
25a. Yes No Was conductivity measurement recorded?
If No, select one of the following reasons. No Water Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
A < 46 B 46 to < 67 C 67 to < 79 D 79 to < 230 E ≥ 230

Notes/Sketch:
According to the US Drought Index, Wake County was experiencing D0 level drought conditions at the time of sampling. Further, according to
the APT, conditions onsite were wetter than normal and the assessment occurred during the dry season. The Raleigh-Durham International
Airport
Station reported 0.02 inches of rain received between 07/26 and 07/28/2021. The stream feature has a gravel road running adjacent to the left
bank for a portion of the reach. Areas of the stream adjacent to this road appear to have been straightened. Areas around the assessment reach
has been clearcut, modifying the vegetation structure. Vegetation structure is made up of young vegetation and a considerable amount of non-
native invasive species.

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1

Stream Site Name Project Galaxy FDBU
SAM-33A1-1 Date of Assessment 07/28/2021
Stream Category Pa3 Assessor Name/Organization Morgan Gilbert - Timmons
Group

Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent

Function Class Rating Summary
USACE/
All Streams
NCDWR
Intermittent
(1) Hydrology HIGH
(2) Baseflow MEDIUM
(2) Flood Flow HIGH
(3) Streamside Area Attenuation HIGH
(4) Floodplain Access HIGH
(4) Wooded Riparian Buffer MEDIUM
(4) Microtopography LOW
(3) Stream Stability MEDIUM
(4) Channel Stability HIGH
(4) Sediment Transport LOW
(4) Stream Geomorphology MEDIUM
(2) Stream/Intertidal Zone Interaction NA NA
(2) Longitudinal Tidal Flow NA NA
(2) Tidal Marsh Stream Stability NA NA
(3) Tidal Marsh Channel Stability NA NA
(3) Tidal Marsh Stream Geomorphology NA NA
(1) Water Quality MEDIUM
(2) Baseflow MEDIUM
(2) Streamside Area Vegetation MEDIUM
(3) Upland Pollutant Filtration MEDIUM
(3) Thermoregulation HIGH
(2) Indicators of Stressors NO
(2) Aquatic Life Tolerance OMITTED
(2) Intertidal Zone Filtration NA NA
(1) Habitat LOW
(2) In-stream Habitat LOW
(3) Baseflow MEDIUM
(3) Substrate LOW
(3) Stream Stability HIGH
(3) In-stream Habitat LOW
(2) Stream-side Habitat HIGH
(3) Stream-side Habitat MEDIUM
(3) Thermoregulation HIGH
(2) Tidal Marsh In-stream Habitat NA NA
(3) Flow Restriction NA NA
(3) Tidal Marsh Stream Stability NA NA
(4) Tidal Marsh Channel Stability NA NA
(4) Tidal Marsh Stream Geomorphology NA NA
(3) Tidal Marsh In-stream Habitat NA NA
(2) Intertidal Zone NA NA
Overall MEDIUM

SAM-33A1-1 (Stream M) – Project Galaxy
Representative of gravel access road through the
Site adjacent to stream assessment reach.
Representative view of lower reach of intermittent
stream assessment reach.
Representative view of downcut banks in upper
portions of stream assessment reach with logging
road in the background.
Representative view of water observed in pools
within upper reaches of the stream assessment
area.
Representative view of middle section of stream
assessment reach with young planted pine forest in
left and right bank streamside area.
Representative view of left bank streamside area of
stream assessment reach with planted pine and
adjoining clearcut area.
NC SAM FIELD ASSESSMENT FORM
Accompanies User Manual Version 2.1
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5-minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the “Notes/Sketch” section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Project Galaxy FDBU 2. Date of evaluation: 07/28/2021
3. Applicant/owner name:
FUJIFILM Diosynth Biotechnologies
USA, Inc. 4. Assessor name/organization: M. Gilbert - Timmons Group
5. County: Wake 6. Nearest named water body
on USGS 7.5-minute quad: Utley Creek (18-7-5.5) 7. River basin: Cape Fear
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.6502, -78.8757
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): SAM-33C1-1 10. Length of assessment reach evaluated (feet): 426
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 0.9 Unable to assess channel depth.
12. Channel width at top of bank (feet): 2.5 13. Is assessment reach a swamp steam? Yes No
14. Feature type: Perennial flow Intermittent flow Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: Mountains (M) Piedmont (P)Inner Coastal Plain (I) Outer Coastal Plain (O)
16. Estimated geomorphic
19 valley shape (skip for
Tidal Marsh Stream):
A B
(more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip Size 1 (< 0.1 mi2) Size 2 (0.1 to < 0.5 mi2)Size 3 (0.5 to < 5 mi2) Size 4 (≥ 5 mi
2)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? Yes No If Yes, check all that apply to the assessment area.
Section 10 water Classified Trout Waters Water Supply Watershed (I II III IV V)
Essential Fish Habitat Primary Nursery Area High Quality Waters/Outstanding Resource Waters
Publicly owned property NCDWR Riparian buffer rule in effect Nutrient Sensitive Waters
Anadromous fish 303(d) List CAMA Area of Environmental Concern (AEC)
Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in “Notes/Sketch” section or attached? Yes No

1. Channel Water – assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
A Water throughout assessment reach.
B No flow, water in pools only.
C No water in assessment reach.
2. Evidence of Flow Restriction – assessment reach metric
A At least 10% of assessment reach in-stream habitat or riffle-pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
B Not A
3. Feature Pattern – assessment reach metric
A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
B Not A
4. Feature Longitudinal Profile – assessment reach metric
A Majority of assessment reach has a substantially altered stream profile (examples: channel down-cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
B Not A
5. Signs of Active Instability – assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down-cutting (head-cut), active widening, and artificial hardening (such as concrete, gabion, rip-rap).
A < 10% of channel unstable
B 10 to 25% of channel unstable
C > 25% of channel unstable

6. Streamside Area Interaction – streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
A A Little or no evidence of conditions that adversely affect reference interaction
B B Moderate evidence of conditions (examples: berms, levees, down-cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
C C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
7. Water Quality Stressors – assessment reach/intertidal zone metric
Check all that apply.
A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
B Excessive sedimentation (burying of stream features or intertidal zone)
C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
D Odor (not including natural sulfide odors)
E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in “Notes/Sketch”
section.
F Livestock with access to stream or intertidal zone
G Excessive algae in stream or intertidal zone
H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
I Other: (explain in “Notes/Sketch” section)
J Little to no stressors
8. Recent Weather – watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
C No drought conditions
9. Large or Dangerous Stream – assessment reach metric
Yes No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In-stream Habitat Types – assessment reach metric
10a. Yes No Degraded in-stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in-stream hardening [for example, rip-rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
A Multiple aquatic macrophytes and aquatic mosses
(include liverworts, lichens, and algal mats)
B Multiple sticks and/or leaf packs and/or emergent
vegetation
C Multiple snags and logs (including lap trees)
D 5% undercut banks and/or root mats and/or roots
in banks extend to the normal wetted perimeter
E Little or no habitat
F 5% oysters or other natural hard bottoms
G Submerged aquatic vegetation
H Low-tide refugia (pools)
I Sand bottom
J 5% vertical bank along the marsh
K Little or no habitat

*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate – assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. Yes No Is assessment reach in a natural sand-bed stream? (skip for Coastal Plain streams)
11b. Bedform evaluated. Check the appropriate box(es).
A Riffle-run section (evaluate 11c)
B Pool-glide section (evaluate 11d)
C Natural bedform absent (skip to Metric 12, Aquatic Life)
11c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach – whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) = > 10-40%, Abundant (A) = > 40-70%, Predominant (P) = > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
Bedrock/saprolite
Boulder (256 – 4096 mm)
Cobble (64 – 256 mm)
Gravel (2 – 64 mm)
Sand (.062 – 2 mm)
Silt/clay (< 0.062 mm)
Detritus
Artificial (rip-rap, concrete, etc.)
11d. Yes No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Check for Tidal Marsh Streams Only
12. Aquatic Life – assessment reach metric (skip for Tidal Marsh Streams)
12a. Yes No Was an in-stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. No Water Other:
12b. Yes No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to “individuals” for Size 1 and 2 streams and “taxa” for Size 3 and 4 streams.
Adult frogs
Aquatic reptiles
Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
Beetles
Caddisfly larvae (T)
Asian clam (Corbicula)
Crustacean (isopod/amphipod/crayfish/shrimp)
Damselfly and dragonfly larvae
Dipterans
Mayfly larvae (E)
Megaloptera (alderfly, fishfly, dobsonfly larvae)
Midges/mosquito larvae
Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
Mussels/Clams (not Corbicula)
Other fish
Salamanders/tadpoles
Snails
Stonefly larvae (P)
Tipulid larvae
Worms/leeches
13. Streamside Area Ground Surface Condition – streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
A A Little or no alteration to water storage capacity over a majority of the streamside area
B B Moderate alteration to water storage capacity over a majority of the streamside area
C C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage – streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
A A Majority of streamside area with depressions able to pond water ≥ 6 inches deep
B B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
C C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence – streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
Y Y Are wetlands present in the streamside area?
N N
16. Baseflow Contributors – assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
A Streams and/or springs (jurisdictional discharges)
B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
C Obstruction passing flow during low-flow periods within the assessment area (beaver dam, leaky dam, bottom-release dam, weir)
D Evidence of bank seepage or sweating (iron in water indicates seepage)
E Stream bed or bank soil reduced (dig through deposited sediment if present)
F None of the above
17. Baseflow Detractors – assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
B Obstruction not passing flow during low-flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
C Urban stream (≥ 24% impervious surface for watershed)
D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
E Assessment reach relocated to valley edge
F None of the above
18. Shading – assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider “leaf-on” condition.
A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
B Degraded (example: scattered trees)
C Stream shading is gone or largely absent
19. Buffer Width – streamside area metric (skip for Tidal Marsh Streams)
Consider “vegetated buffer” and “wooded buffer” separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
A A A A ≥ 100 feet wide or extends to the edge of the watershed
B B B B From 50 to < 100 feet wide
C C C C From 30 to < 50 feet wide
D D D D From 10 to < 30 feet wide
E E E E < 10 feet wide or no trees
20. Buffer Structure – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 (“Vegetated” Buffer Width).
LB RB
A A Mature forest
B B Non-mature woody vegetation or modified vegetation structure
C C Herbaceous vegetation with or without a strip of trees < 10 feet wide
D D Maintained shrubs
E E Little or no vegetation
21. Buffer Stressors – streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
A A A A A A Row crops
B B B B B B Maintained turf
C C C C C C Pasture (no livestock)/commercial horticulture
D D D D D D Pasture (active livestock use)
22. Stem Density – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 (“Wooded” Buffer Width).
LB RB
A A Medium to high stem density
B B Low stem density
C C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer – streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
A A The total length of buffer breaks is < 25 percent.
B B The total length of buffer breaks is between 25 and 50 percent.
C C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition – streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
A A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
B B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear-cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
C C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non-characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity – assessment reach metric (skip for all Coastal Plain streams)
25a. Yes No Was conductivity measurement recorded?
If No, select one of the following reasons. No Water Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
A < 46 B 46 to < 67 C 67 to < 79 D 79 to < 230 E ≥ 230

Notes/Sketch:
According to the US Drought Index, Wake County was experiencing D0 level drought conditions at the time of sampling. Further, according to
the APT, conditions onsite were wetter than normal and the assessment occurred during the dry season. The Raleigh-Durham International
Airport Station reported 0.02 inches of rain received between 07/26 and 07/28/2021. Vegetation structure is made up of young and old vegetation
and a considerable amount of non-native invasive species.

Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1

Stream Site Name Project Galaxy FDBU
SAM-33C1-1 Date of Assessment 07/28/2021
Stream Category Pa3 Assessor Name/Organization M. Gilbert - Timmons Group

Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent

Function Class Rating Summary
USACE/
All Streams
NCDWR
Intermittent
(1) Hydrology HIGH
(2) Baseflow MEDIUM
(2) Flood Flow HIGH
(3) Streamside Area Attenuation HIGH
(4) Floodplain Access HIGH
(4) Wooded Riparian Buffer MEDIUM
(4) Microtopography LOW
(3) Stream Stability HIGH
(4) Channel Stability HIGH
(4) Sediment Transport LOW
(4) Stream Geomorphology HIGH
(2) Stream/Intertidal Zone Interaction NA NA
(2) Longitudinal Tidal Flow NA NA
(2) Tidal Marsh Stream Stability NA NA
(3) Tidal Marsh Channel Stability NA NA
(3) Tidal Marsh Stream Geomorphology NA NA
(1) Water Quality HIGH
(2) Baseflow MEDIUM
(2) Streamside Area Vegetation HIGH
(3) Upland Pollutant Filtration HIGH
(3) Thermoregulation HIGH
(2) Indicators of Stressors NO
(2) Aquatic Life Tolerance OMITTED
(2) Intertidal Zone Filtration NA NA
(1) Habitat LOW
(2) In-stream Habitat LOW
(3) Baseflow MEDIUM
(3) Substrate LOW
(3) Stream Stability HIGH
(3) In-stream Habitat LOW
(2) Stream-side Habitat HIGH
(3) Stream-side Habitat HIGH
(3) Thermoregulation HIGH
(2) Tidal Marsh In-stream Habitat NA NA
(3) Flow Restriction NA NA
(3) Tidal Marsh Stream Stability NA NA
(4) Tidal Marsh Channel Stability NA NA
(4) Tidal Marsh Stream Geomorphology NA NA
(3) Tidal Marsh In-stream Habitat NA NA
(2) Intertidal Zone NA NA
Overall HIGH

SAM-33C1-1 (Stream L) – Project Galaxy
Representative view of lower portion of stream
assessment reach.
Representative view of planted pine forest with
adjoining clearcut areas along the left streamside
area of the stream assessment reach.
Representative view of downed trees across the
stream observed throughout the stream
assessment reach.
Representative view of headcuts and debris lines
observed within the stream assessment reach.
Representative view of middle of stream
assessment reach.
Representative view of young mixed hardwood-
pine forest along the right bank streamside area of
the stream assessment reach.
NC WAM FIELD ASSESSMENT FORM
Accompanies User Manual Version 5.0
USACE AID # NCDWR#
Project Name Project Galaxy FDBU Date of Evaluation 07/28/2021
Applicant/Owner Name FUJIFILM Diosynth Biotechnologies
USA, Inc. Wetland Site Name WAM-40E1-1
Wetland Type Seep Assessor Name/Organization S. Law, E. Sharp - Timmons
Group
Level III Ecoregion Piedmont Nearest Named Water Body Utley Creek (18-7-5.5)
River Basin Cape Fear USGS 8-Digit Catalogue Unit 03030004
County Wake NCDWR Region Raleigh
Yes No Precipitation within 48 hrs? Latitude/Longitude (deci-degrees) 35.656263, -78.875111
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on the last page if evidence of stressors is apparent. Consider departure from reference, if appropriate, in
recent past (for instance, within 10 years). Noteworthy stressors include, but are not limited to the following.
• Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
• Surface and sub-surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby septic
tanks, underground storage tanks (USTs), ho g lagoons, etc.)
• Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
• Habitat/plant community alteration (examples: mowing, clear-cutting, exotics, etc.)
Is the assessment area intensively managed? Yes No

Regulatory Considerations - Were regulatory considerations evaluated? Yes No If Yes, check all that apply to the assessment area.
Anadromous fish
Federally protected species or State endangered or threatened species
NCDWR riparian buffer rule in effect
Abuts a Primary Nursery Area (PNA)
Publicly owned property
N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
Abuts a stream with a NCDWQ classification of SA or supplemental classifications of HQW, ORW, or Trout
Designated NCNHP reference community
Abuts a 303(d)-listed stream or a tributary to a 303(d)-listed stream
What type of natural stream is associated with the wetla nd, if any? (check all that apply)
Blackwater
Brownwater
Tidal (if tidal, check one of the following boxes) Lunar Wind Both
Is the assessment area on a coastal island? Yes No
Is the assessment area’s surface water storage capacity or duration substantially altered by beaver? Yes No
Does the assessment area experience overbank flooding during normal rainfall conditions? Yes No
1. Ground Surface Condition/Vegetation Condition – assessment area condition metric
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure (VS) in the
assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable, then rate the assessment
area based on evidence an effect.
GS VS
A A Not severely altered
B B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire-plow lanes, skidder tracks, bedding, fill, soil compact ion, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing, less
diversity [if appropriate], hydrologic alteration)
2. Surface and Sub-Surface Storage Capacity and Duration – assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub -surface storage capacity and duration (Sub).
Consider both increase and decrease in hydrology. A ditch ≤ 1 foot deep is considered to affect surface water only, while a ditch > 1 foot
deep is expected to affect both surface and sub-surface water. Consider tidal flooding regime, if applicable.
Surf Sub
A A Water storage capacity and duration are not altered.
B B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
C C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation change )
(examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3. Water Storage/Surface Relief – assessment area/wetland type condition metric (skip for all marshes)
Check a box in each column. Select the appropriate storage for the assessment area (AA) and the wetland type (WT).
AA WT
3a. A A Majority of wetland with depressions able to pond water > 1 deep
B B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
C C Majority of wetland with depressions able to pond water 3 to 6 inches deep
D D Depressions able to pond water < 3 inches deep
3b. A Evidence that maximum depth of inundation is greater than 2 feet
B Evidence that maximum depth of inundation is between 1 and 2 feet
C Evidence that maximum depth of inundation is less than 1 foot
4. Soil Texture/Structure – assessment area condition metric (skip for all marshes)
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape feature.
Make soil observations within the top 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for regional
indicators.
4a. A Sandy soil
B Loamy or clayey soils exhibiting redox imorphic features (concentrations, depletions, or rhizospheres)
C Loamy or clayey soils not exhibiting redox imorphic features
D Loamy or clayey gleyed soil
E Histosol or histic epipedon
4b. A Soil ribbon < 1 inch
B Soil ribbon ≥ 1 inch
4c. A No peat or muck presence
B A peat or muck presence
5. Discharge into Wetland – opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf) and sub-surface pollutants or discharges (Sub). Examples
of sub-surface discharges include presence of nearby septic tank , underground storage tank (UST), etc.
Surf Sub
A A Little or no evidence of pollutants or discharges entering the assessment area
B B Noticeable evidence of pollutants or discharges entering the wetla nd and stressing, but not overwhelming the
treatment capacity of the assessment area
C C Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area a nd
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use – opportunity metric (skip for non-riparian wetlands)
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources draining
to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the assessment area (5M),
and within 2 miles and within the watershed draining to the assessment area (2M).
WS 5M 2M
A A A > 10% impervious surfaces
B B B Confined animal operations (or other local, concentrated source of pollutants
C C C ≥ 20% coverage of pasture
D D D ≥ 20% coverage of agricultural land (regularly plowed land)
E E E ≥ 20% coverage of maintained grass/herb
F F F ≥ 20% coverage of clear-cut land
G G G Little or no opportunity to improve water quality. Lack of opportunity may result from little or no disturbance in
the watershed or hydrologic alterations that prevent drainage and/or overbank flow from affecting the
assessment area.
7. Wetland Acting as Vegetated Buffer – assessment area/wetland complex condition metric (skip for non-riparian wetlands)
7a. Is assessment area within 50 feet of a tributary or other open water?
Yes No If Yes, continue to 7b. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is wetland? (Wetland buffer need only be present on one side of the .water body. Make
buffer judgment based on the average width of wetland. Record a note if a portion of the buffer has been removed or disturbe d.)
A ≥ 50 feet
B From 30 to < 50 feet
C From 15 to < 30 feet
D From 5 to < 15 feet
E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
≤ 15-feet wide > 15-feet wide Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend in to the bank of the tributary/open water?
Yes No
7e. Is stream or other open water sheltered or exposed?
Sheltered – adjacent open water with width < 2500 feet and no regular boat traffic.
Exposed – adjacent open water with width ≥ 2500 feet or regular boat traffic.
8. Wetland Width at the Assessment Area – wetland type/wetland complex condition metric (evaluate WT for all marshes and
Estuarine Woody Wetland only; evaluate WC for Bottomland Hardwood Forest, Headwater Forest, and Riverine Swamp Forest
only)
Check a box in each column for riverine wetlands only. Select the average width for the wetland type at the assessment area (WT) and
the wetland complex at the assessment area (WC). See User Manual for WT and WC boundaries.
WT WC
A A ≥ 100 feet
B B From 80 to < 100 feet
C C From 50 to < 80 feet
D D From 40 to < 50 feet
E E From 30 to < 40 feet
F F From 15 to < 30 feet
G G From 5 to < 15 feet
H H < 5 feet

9. Inundation Duration – assessment area condition metric (skip for non-riparian wetlands)
Answer for assessment area dominant landform.
A Evidence of short-duration inundation (< 7 consecutive days)
B Evidence of saturation, without evidence of inundation
C Evidence of long-duration inundation or very long-duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition – assessment area condition metric (skip for non-riparian wetlands and all marshes)
Consider recent deposition only (no plant growth since deposition).
A Sediment deposition is not excessive, but at approximately natural levels.
B Sediment deposition is excessive, but not overwhelming the wetland.
C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size – wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FW) (if applicable , see User
Manual). See the User Manual for boundaries of these evaluation areas. If assessment area is clear-cut, select “K” for the FW column.
WT WC FW (if applicable)
A A A ≥ 500 acres
B B B From 100 to < 500 acres
C C C From 50 to < 100 acres
D D D From 25 to < 50 acres
E E E From 10 to < 25 acres
F F F From 5 to < 10 acres
G G G From 1 to < 5 acres
H H H From 0.5 to < 1 acre
I I I From 0.1 to < 0.5 acre
J J J From 0.01 to < 0.1 acre
K K K < 0.01 acre or assessment area is clear-cut
12. Wetland Intactness – wetland type condition metric (evaluate for Pocosins only)
A Pocosin is the full extent (≥ 90%) of its natural landscape size.
B Pocosin type is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas – landscape condition metric
13a. Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This metric
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contigu ous
naturally vegetated area and open water (if appropriate). Boundaries are formed by four -lane roads, regularly maintained utility line
corridors the width of a four-lane road or wider, urban landscapes, maintained fields (pasture and agriculture), or open water > 300
feet wide.

Well Loosely
A A ≥ 500 acres
B B From 100 to < 500 acres
C C From 50 to < 100 acres
D D From 10 to < 50 acres
E E < 10 acres
F F Wetland type has a poor or no connection to other natural habitats

13b. Evaluate for marshes only.
Yes No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect – wetland type condition metric (skip for all marshes and Estuarine Woody Wetland)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificia l edges include
non-forested areas ≥ 40 feet wide such as fields, development, roads, regularly maintained utility line corridors, and clear -cuts. Consider
the eight main points of the compass. Artificial edge occurs within 150 feet in how many directions? If the assessme nt area is clear cut,
select option ”C.”
A 0
B 1 to 4
C 5 to 8
15. Vegetative Composition – assessment area condition metric (skip for all marshes and Pine Flat)
A Vegetation is close to reference condition in species present and their proportions. Lower strata compo sed of appropriate
species, with exotic plants absent or sparse within the assessment area.
B Vegetation is different from reference condition in species diversity or proportions , but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or clearing.
It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
C Vegetation severely altered from reference in composition, or expected species are unnaturally absent (planted stands of non -
characteristic species or at least one stratum inappropriately composed of a single species), or exotic species are dominant in at
least one stratum.
16. Vegetative Diversity – assessment area condition metric (evaluate for Non-tidal Freshwater Marsh only)
A Vegetation diversity is high and is composed primarily of native species (< 10% cover of exotics).
B Vegetation diversity is low or has > 10% to 50% cover of exotics.
C Vegetation is dominated by exotic species (> 50 % cover of exotics).
17. Vegetative Structure – assessment area/wetland type condition metric
17a. Is vegetation present?
Yes No If Yes, continue to 17b. If No, skip to Metric 18.

17b. Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non-marsh wetlands.
A ≥ 25% coverage of vegetation
B < 25% coverage of vegetation

17c. Check a box in each column for each stratum. Evaluate this portion of the metric for non-marsh wetlands. Consider
structure in airspace above the assessment area (AA) and the wetland type (WT) separately.
AA WT
A A Canopy closed, or nearly closed, with natural gaps associated with natural processes
B B Canopy present, but opened more than natural gaps
C C Canopy sparse or absent

A A Dense mid-story/sapling layer
B B Moderate density mid-story/sapling layer
C C Mid-story/sapling layer sparse or absent

A A Dense shrub layer
B B Moderate density shrub layer
C C Shrub layer sparse or absent

A A Dense herb layer
B B Moderate density herb layer
C C Herb layer sparse or absent
18. Snags – wetland type condition metric (skip for all marshes)
A Large snags (more than one) are visible (> 12 inches DBH, or large relative to species present and landscape stability).
B Not A
19. Diameter Class Distribution – wetland type condition metric (skip for all marshes)
A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 inch DBH.
C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris – wetland type condition metric (skip for all marshes)
Include both natural debris and man-placed natural debris.
A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
B Not A
21. Vegetation/Open Water Dispersion – wetland type/open water condition metric (evaluate for Non-Tidal Freshwater Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. P atterned
areas indicate vegetated areas, while solid white areas indicate open water.
A B C D

22. Hydrologic Connectivity – assessment area condition metric (evaluate for riparian wetlands and Salt/Brackish Marsh only)
Examples of activities that may severely alter hydrologic connectivity include intensive ditching, fill, sedimentation, channelization, diversion,
man-made berms, beaver dams, and stream incision. Documentation required if evaluated as B, C, or D.
A Overbank and overland flow are not severely altered in the assessment area.
B Overbank flow is severely altered in the assessment area.
C Overland flow is severely altered in the assessment area.
D Both overbank and overland flow are severely altered in the assessment area.

Notes
According to the US Drought Index, Wake County was experiencing D0 level drought conditions during the time of sampling. The Raleigh-Durham
International Airport Station reported 0.02 inches of rain received between 07/26 and 07/28/2021. According to t he APT, conditions onsite were
wetter than normal and the assessment occurred during the dry season.
Wetland area the product of man-made pond outfall and leaking berm (evidenced by large amounts of iron deposits and presence of Fe -oxidizing
bacteria near the base of the berm), draining downslope to an intermittent stream. Pond was drained within 6 months prior to the assessment .
Area historically mapped as upland (aerial imagery, NRCS, USGS) and pond likely affected water stroage capacity and duration to the wetland
area. Evidence of surface pollution observed as foam in water near pond outfall in the wetland area. Due to increased water i nputs to the area
from the pond, herbaceous layer greatly different than that of surrounding area and what would be exp ected; also contains mostly exotic and
opportunistic species.
Canopy, sapling, and shrub species: Pinus taeda (45%), Liriodendron tulipifera (15%), and Liquidambar styraciflua (5%).
Herbaceous and woody vine species: Microstegium vimineum (30%), Woodward ia areolata (5%), Vitis rotundifolia (3%), and Osmundastrum
cinnamomeum (1%).

Canopy Mid-Story Shrub Herb
NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0

Wetland Site Name WAM-40E1-1 Date of Assessment 07/28/2021
Wetland Type Seep Assessor Name/Organization
S. Law, E. Sharp -
Timmons Group

Notes on Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
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

Sub-surface Storage and
Retention Condition NA
Water Quality Pathogen Change Condition NA
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 NA
Condition/Opportunity NA
Opportunity Presence (Y/N) NA
Habitat Physical Structure Condition MEDIUM
Landscape Patch Structure Condition HIGH
Vegetation Composition Condition MEDIUM

Function Rating Summary
Function Metrics Rating
Hydrology Condition LOW
Water Quality Condition LOW
Condition/Opportunity NA
Opportunity Presence (Y/N) NA
Habitat Condition HIGH

Overall Wetland Rating LOW

WAM-40E1-1 (Wetland C) – Project Galaxy
Representative view of mature planted pine
adjoining the wetland assessment area.
Representative view through the wetland
assessment area.
Representative view through wetland assessment
area with planted pine forest adjoining in the
background.
Representative view of saturated and inundated
areas of wetland assessment area.
Representative view of pond outfall located at the
upper reach of the wetland assessment area.
Representative view of drainage patterns observed
within the wetland assessment area with foam
(lower left) in the water.

ATTACHMENT 4

LETTER OF SUPPORT FROM THE TOWN OF HOLLY SPRINGS

September 27, 2021
Lyle Phillips
U.S. Army Corps of Engineers — Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Rick Trone
401 & Buffer Permitting Branch
NCDEQ— Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Phillips and Mr. Trone,
This letter is to certify that the Town of Holly Springs has worked with Fujifilm Diosynth Biotechnologies (FDB) to
locate their new biopharmaceutical manufacturing facility known as Project Galaxy on approximately 147.5 acres
within the town limits. The site development will serve as a facility to manufacture, package, and distribute
pharmaceutical products over a large geographical area. Ultimately this project represents an investment of $1.5
billion and the creation of over 700 full-time jobs.
Throughout the 404/401 permitting of the of the project, it has come to our attention that a future roadway,
referred to as the NCDOT HE-0002 project and further described as a roadway originating from the Green Oaks
Parkway between Thomas Mill Road and NC 55 and continuing westward towards the approximate location of
Project Galaxy, has caused some confusion regarding "independent utility". To be clear, the construction of this
road is not a required stipulation associated with the Town's plan approval for the site. It is our understanding
that Fujifilm plans to proceed with the construction of their facility even if the NCDOT HE-0002 project is never
constructed. If and when that future roadway is designed and constructed, it will be for the purposes of multiple
end users within the business park, including Fujifilm Diosynth Biotechnologies. As such, the permitting of the
road should be considered separately from the specific site development of Project Galaxy.
Should you have any additional questions or concerns, please feel free to contact me at your earliest convenience.
ns Hills, AICP, CZO
Development Services Director
Town of Holly Springs Development Services
P.O. Box 8 • 128 S. Main St.. Holly Springs, NC 27540 . [phone]
[e-mail] • www.hollyspringsnc.gov