20211413 Ver 1_More Information Received_20211223

Staff Review
Does this application have all the attachments needed to accept it into the review process?*
Yes No
ID#* Version* 1
20211413
Is this project a public transportation project?* Yes
• No
Reviewer List: * Rick Trone:eads\rvtrone
Select Reviewing Office: * Central Office - [phone]
Does this project require a request for payment to be sent?*
Yes
No

Project Submittal Form
Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: * For the Record Only (Courtesy Copy)
New Project
Modification/New Project with Existing ID
More Information Response
Other Agency Comments
Pre -Application Submittal
Re-Issuance\Renewal Request
Stream or Buffer Appeal
Is this supplemental information that needs to be sent to the Corps?*
Yes No
Project Contact Information
Name: Philip May
Who is submitting the information?
Email Address: [e-mail]
Project Information
Existing ID #: Existing Version:
20211413 1
20170001(no dashes) 1
Project Name: Project Eagle
Is this a public transportation project?
Yes
No
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
Yes No Unknown
County (ies)
Edgecombe
Please upload all files that need to be submited.
Click the upload button or drag and drop files here to attach document
ProjectEagle_DWRCommentResponse_12232021... 1.86MB
Only pdf or kmz files are accepted.
Describe the attachments or
comments:
Responses to requested items are attached. Please let me know if you need anything else.
Sign and Submit
By checking the box and signing box below, I certify that:

• I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to the
best of my knowledge and belief.
• I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time.
• I agree that submission of this online form is a "transaction" subject to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act');
• I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act');
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a
written signature; AND
• I intend to electronically sign and submit the online form.
Signature:
Submittal Date: Is filled in automatically.

CAROLITIA
ECOSYSTEMS
December 23, 2021
Mr. Rick Trone
401 & Buffer Permitting Unit
NC Department of Environmental Quality
512 N. Salisbury St.
Raleigh, NC 27604
3040 NC 42 West, Clayton NC 27520
P:919-359-1102 — F:919-585-5570
RE: DWR #20211413 - Request for Additional Information - Project Eagle
Edgecombe County, North Carolina
Dear Mr. Trone,
In response to your 12/22/21 email requesting additional information related to the above -
referenced permit application, Carolina Ecosystems, Inc. (CEI), on behalf of Appian Engineers
and Edgecombe County is providing the responses to each requested item below. Your request
items are in italics, followed by our responses.
1. Please provide documentation of the NCWAM classification to determine if the wetlands
proposed to be impacted are exempt from permitting in accordance with 02H .1301. If
the wetlands in questions are not classified as basins or bogs, permitting would be more
appropriate under 02H. 1400.
The wetlands in question were determined to be Basin Wetlands based on the NCWAM
methodology and training. In regard to documentation, since the NCWAM form is for
functional assessment and only requires the wetland classification to be entered on the
form, we are providing the attached Dichotomous Key to General Wetland Types with
mark-ups showing the decision -making process used in our classification. The primary
consideration resulting in the classification of Basin Wetlands is the location not being an
interstream divide. While the subject wetlands are located between stream channels, the
surrounding upland areas are not typical of an interstream divide, and the wetlands are
not evidently in a natural topographic crenulation (see Figure 5 in the permit application
for current LiDAR elevation mapping). Therefore, Basin Wetland was deemed the most
appropriate classification. If, based on your review of this information, it is deemed more
appropriate to issue approval under 02H .1400, we would not contest that decision.
2. Please provide more details regarding avoidance and minimization of non federally
jurisdictional wetland impacts for this project [15A NCAC 02H. 0506(b)(1)]
Avoidance and minimization of the proposed wetland impacts was thoroughly evaluated,
but not deemed practicable for this project. As stated in our application, this is a key
economic development project for the State and the interested occupant, currently
deciding between this site and one in another state, has provided their process and
building configuration requirements. The industry's manufacturing process flow requires
the manufacturing and warehouse buildings to be adjacent to each other with loading
dock access to the warehouse. These required areas cannot be manipulated to avoid the
Isolated Wetlands, which are generally located in the middle of the site. Shifting the
impacts in any direction would involve impacting Section 404 jurisdictional features that

Mr. Rick Trone
Project Eagle
Page 2 of 2
December 23, 2021
are directly connected to unnamed tributaries to Walnut Creek and the Tar River. Staff
parking and access is restricted to the north side of the site in order to keep truck and
private vehicle traffic separated for the safety of the workers going to and from the
buildings. In addition, the rail spur access requires the main buildings to be directly
adjacent to the southern portion of the property. These factors result in the facility being
located where proposed impacts to the Isolated Wetlands is unavoidable.
Pad C of the Business Park, which contains this project, is the only parcel of sufficient
size to house the industry, without significant additional impacts to Section 404 waters.
The other business park sites are smaller and located between Walnut Creek and Alt US
64, or across US 64. None of the other pads, shown in the attached Kingsboro Site Map,
could house an industry of this size. Overall, the Kingsboro Business Park was
determined to be the most appropriate location for industrial development in the area
based on rigorous selection criteria and intensive study of multiple sites. This was
documented in detail in the 2018 permit application for the NCDOT R-5868 and Project
Diamond (Triangle Tire) facility (DWR # 20180133).
3. Mitigation is required for losses of impacts that exceed the thresholds set out in
Subparagraph (b)(3) of 02H .1300. Please provide a Statement of Availability from an
appropriate mitigation bank to meet this requirement or a credit reservation letter from
NC DMS if no wetland credits are available from an appropriate mitigation bank.
Mitigation is proposed to be provided through the NC Division of Mitigation Services
(see attached Conditional Acceptance letter) valid through March 2022.
We appreciate your review of this material and issuance of the requested permit as soon as
possible, as the industry is in the process of making a final decision between this site and an out-
of-state location. If you have any questions or need additional information, please contact me at
your earliest convenience at [phone] or [e-mail].
Sincerely,
Carolina Ecosystems, Inc.
P
Philip May
Vice President/Senior Environmental Scientist
Cc: Billy Standridge, USACE — Wilmington District
Eric Evans, County Manager - Edgecombe County
David Revoir, Appian Engineers
Attachments:
- NCWAM Dichotomous Key (Markup)
- Kingsboro Site Map
- DMS Conditional Acceptance

Dichotomous Key to General North Carolina Wetland Types
Accompanies NC WAM User Manual Version 5
Before using this key, the assessor should read and become familiar with descriptions of the general
wetland types. The assessor should use best professional judgment to verify that the wetland type
determined with the use of this key matches the written description (see User Manual page number
following wetland type name).
The following rule should be used to assist in the selection of the most appropriate general wetland type.
Narrative descriptions are also available to assist in this choice (see User Manual Section 3.1).
Wetlands with alterations (man-made or natural) should generally be classified as the
original, naturally occurring type if this determination can be made. However, if the full
range of stable, existing, wetland parameters (vegetation, hydrology, and soils) better
resembles another wetland type because of long-established, permanent alterations, the
wetland should be classified as this current, more appropriate type.
If there is evidence suggesting the wetland is a type other than the keyed type, the wetland may be
classified as the evidenced type. Also, if the wetland does not appear to conform to any of the following
general types, the site should be evaluated based on what the assessor believes is the closest wetland
type. If the wetland is "intensively managed" or "intensively disturbed," the assessor should note this fact
on the field assessment form and then select the most appropriate general wetland type based on the
guidance provided above.
I. Wetland affected by lunar or wind tide, may include woody areas contiguous with tidal marsh
A. Wetland affected, at least occasionally, by brackish or salt water
i. Dominated by herbaceous vegetation — Salt/Brackish Marsh (p. 12)
ii. Dominated by woody vegetation — Estuarine Woody Wetland (p. 15)
B. Wetland primarily affected by freshwater
i. Dominated by herbaceous vegetation — Tidal Freshwater Marsh (p. 17)
ii. Dominated by woody vegetation — Riverine Swamp Forest (p. 19)
(D(
etLcl not affected by tides
A.1 Not in a geomorphic floodplain or a natural topographic crenulation and not contiguous with an
J open water 20 acres or larger
i. On a side slope — Seep (p. 24)
ii. On interstream divides or on a coastal island
1. Flats on interstream divides in Coastal Plain ecoregions
a. Dominated by deciduous trees
i. Seasonally saturated to seasonally inundated (typically dominated by sweetgum
and oaks) — Hardwood Flat (p. 26)
ii. Seasonally to semi -permanently inundated (typically dominated by cypress and
black gum) — Non-Riverine Swamp Forest (p. 28)
b. Dominated by evergreens
i. Dominated by dense, waxy shrub species (typically include gallberries,
fetterbushes, honeycup, greenbriar); canopy may include pond pine, Atlantic
white cedar, and bays — Pocosin (p. 30)
ii. Not dominated by dense, waxy shrub species
1. Dominated by long -leaf or pond pine and wire grass — Pine Savanna (p. 32)
2. Dominated by loblolly or slash pines — Pine Flat (p. 33)
2. In depressions surrounded by uplands anywhere in the state (mafic depressions, lime
sinks, Carolina bays) or contiguous with an open water
NC Wetland Assessment Method (NC WAM) v5 vi Dichotomous Key to General Wetland Types

Ll
Dichotomous Key to General NC Wetland Types, Continued
0. In depressions surrounded by uplands anywhere in the state (mafic depressions, lime
sinks, Carolina bays) or contiguous with an open water (repeated from the
previous page)
a. Dominated by dense, waxy shrub species (typically include gallberries, fetterbushes,
honeycup, greenbriar); canopy may include pond pine, Atlantic white cedar, and bays
and not characterized by clay -based soils— Pocosin (p. 30)
b. ] Not dominated by dense, waxy shrub species and not characterized by a peat -filled
bay — Basin Wetland (p. 35)
In a geomorphic floodplain or a natural topographic crenulation or contiguous with an open water
20 acres or larger
i. Northern Inner Piedmont or Blue Ridge Mountains ecoregions and dense herbaceous or
mixed shrub/herbaceous vegetation with characteristic bog species (see wetland type
description), with or without tree canopy; at least semi -permanent saturation; typically on
organic or mucky soils; sphagnum moss commonly present — Bog (p. 37)
ii. Anywhere in the state and not Bog
1. Dominated by herbaceous vegetation. At least semi -permanently inundated or saturated.
Includes lacustrine and riparian fringe and beaver ponds with dense herbaceous
vegetation; sphagnum moss scarce or absent — Non -Tidal Freshwater Marsh (p. 40)
2. Dominated by woody vegetation. Trees may be present on edges or hummocks.
a. Localized depression and semi -permanently inundated — Floodplain Pool (p. 43)
b. Not "a"
i. Less than second -order stream or in a topographic crenulation without a stream.
Diffuse surface flow and groundwater more important than overbank flooding.
1. Seasonally to semi -permanently saturated and/or only intermittently
inundated — Headwater Forest (p. 45)
2. Seasonally to semi -permanently inundated — Riverine Swamp Forest
(p. 19)
ii. Second -order or greater stream or contiguous with an open water 20 acres or
larger
1. Intermittently to seasonally inundated (may be dominated by sweetgum,
ash, sycamore, and oaks) — Bottomland Hardwood Forest (p. 49)
2. Seasonally to semi -permanently inundated (may be dominated by
cypress and blackgums in Coastal Plain and ash, overcup oak, and elms
in Piedmont and Mountains) — Riverine Swamp Forest (p. 19)
'See stream order schematic diagrams in User Manual Appendix F.
NC Wetland Assessment Method (NC WAM) v5 vii Dichotomous Key to General Wetland Types

zi
�ON 'AlNnoo 38W003J43.5.°_,
311S 13313S XSO OdOSSONIN 0�
sNolslnaa ,
Gm NVId 1d3ONO3 11VE13AO
m3 At "per g
Z a3
p 'Lu
I
/
NHS j R
w
b,v o �l
jQ
CL
a Q 0 w 0
v, i I WN
/ i3dvN.� U � a
o'er, j /i ,/,;'�'� siaea � � _ •—
z Hp zi
CL
if
Iz
LLI
p yam. 'I \\ �waQa Q •� r �� / � 0��.
I
1
r-
Jai Q� i u�oa j
O
�4
r �-
-
0
i � x� ! oroa o mi! imp ii 2�
uY Y
=Ga

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
TIM BAUMGARTNER
Director
Eric Evans
Edgecombe County
PO Box 10
Tarboro, NC 27886
NORTH CAROLINA
Environmental Quality
September 24, 2021
Expiration of Acceptance: 3/24/2022
Project: Project Eagle County: Edgecombe
This is a conditional acceptance letter.
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin
Impact Location
8-di it HUC
Impact Type
Impact Quantity
Tar -Pamlico
03020101*
Non -Riparian Wetland
1.62
*DMS is proposing to use existing credits from an adjacent HUC (03020103 or 03020102) if sufficient credits
in 03020101 are not available at the time of payment. Upon receipt of payment, DMS will take responsibility
for providing the compensatory mitigation. The mitigation will be performed in accordance with the In -Lieu
Fee Program instrument dated July 28, 2010 and 15A NCAC 02B .0295 as applicable. Thank you for your
interest in the DMS in -lieu fee mitigation program. If you have any questions or need additional information,
please contact [e-mail].
Sincerely,
FOR James. B Stanfill
Asset Management Supervisor
cc: Phil May, agent
D Q� North Carolina Department of Environmental Quality I Division of Mitigation Services
217 west Jones Street 11652 Mail Service Center I Raleigh, North Carolina 27699-1652
oonaam��eoiewbmeui on 9I9.707.8976