20171559 Ver 3_USACE More Info Requested_20220121

Homewood, Sue
From: Williams, Andrew E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, January 21, 2022 3:51 PM
To: Miller, Vickie M. (Raleigh); Wendee Smith
Cc: Crumbley, Tyler A CIV USARMY CESAW (USA); McLendon, C S CIV USARMY CESAW
(USA); Gibby, Jean B CIV USARMY CESAW (USA); Pruitt, Carl E Jr CIV USARMY CESAW
(USA); Williams, Andrew E CIV USARMY CESAW (USA); Homewood, Sue
Subject: [External] USACE evaluation/response of GRMS additional information submittal (29
December 2021, 10 and 14 January 2022)
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Vickie/Wendee:
Reference is made to your revised permit application for individual Department of the Army (DA) permit authorization
to construct the project identified as the Greensboro Randolph Megasite. The site is located in northern Randolph
County, northwest of the town of Liberty and east of the Town of Julian. The site is generally bounded by Old US
Highway 421 to the north, Julian Airport Road to the west, Troy Smith Road to the east, and US Highway 421 to the
south.
On December 8, 2021 we provided you with comments received in response to our November 19, 2021 Public Notice for
this project as well as a requests for additional information.
On December 29, 2021 we received a copy of your response to the North Carolina Division of Water Resources questions
concerning this project. Additionally, on January 10 and 14, 2022, we received your response to the public notice
comments and your response to our request for additional information. Thank you for providing this information.
After review of the information/items received on December 29, 2021, and January 10 and 14, 2022, we are still
requesting additional information in order to finalize a permit decision. As stated in our December 8, 2021 email, please
be aware that Section 404(b)(1), of the Clean Water Act, requires that no discharge of dredged or fill material shall be
permitted if there is a practicable alternative to the proposed discharge which would have a less adverse impact on the
aquatic ecosystem, so long as the alternative does not have other significant adverse environmental consequences. As
such, please elaborate on and provide additional information as follows:
1) In your January 10 and 14, 2022 responses, you listed several instances of additional avoidance and
minimization, including the removal of a proposed waste treatment and solar facility. Information provided also
includes additional impacts associated with a new access road. While you provided new impact maps, you did
not provide a new site layout map. Please provide a new site layout map for the project as it is currently
proposed. Also, please quantify the resources (length of streams and acreage of wetlands/open waters) that
have been avoided with your newly proposed site plan(s).
2) Information provided on December 29, 2021, indicated that there would be
In an effort to avoid and minimize impacts please
consider the elimination of some of these excess (161) spaces or provide justification for those spaces.
3) We requested a construction timeline in our December 8, 2021 correspondence with you. Please provide a
construction timeline for all components of this project (site, transportation, water/wastewater utilities/electric
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utilities). Also, please indicate the construction timeframe for each of the proposed on -site components (each
building, park lot, facility, etc.).
4) The current on -site alternatives analysis was provided prior to the announcement of Toyota as the end user for
this project. Since the submittal of your original application, the purpose and need for the project and the site
plans have been revised. Additionally, the Approved/Preliminary Jurisdictional Determinations for on -site
waters has been completed. As such, we are requesting that you provide a revised/updated on -site analysis
showing the four different pad locations/layouts. You should also re -quantify the proposed aquatic impacts
associated with each location/layout. As there is a reduction in pad size/configuration please consider any
alternative or additional alternative that could potentially avoid either the easternmost tributaries or the
westernmost tributaries or larger portions of those tributaries.
5) In your January 10, 2022 response, you indicated that alternatives 2 and 3 would impact Dodson's Lake with fill,
reduce the storage capacity, cause the loss of wetlands and would require modification of the dam to ensure its
structural and operational integrity. You also indicated that dam modification/reconstruction would be cost
prohibitive. In regard to this issue, please provide:
a. Quantity of wetlands/waters that would be impacted or lost if the lake was drained/altered.
b. An engineering report stating that the structural and operational integrity of the dam would potentially be
impacted such that it would require modification.
c. An estimate of cost to reconstruct the Dodson Lake dam based on fill amounts associated with alternatives
2/3.
We are aware that alternatives 2/3 may change, based on #4 above; however, you should still look at
alternatives that include lake impacts (in an effort to avoid streams and wetlands), and provide a discussion
regarding the applicant's preferred alternative and compliance with the 404(b)(1) guidelines.
6) Please be aware that the current plans for the transportation portion of the proposed project are preliminary. If
a permit is issued with these plans as proposed, the permit will be conditioned to require the submittal of
finalized transportation plans prior to initiation of construction on the transportation component of the project.
7) Your December 9, 2021 correspondence mentions the potential for on -site, permittee responsible mitigation
proposal associated with this project. Please be aware that the current Corps of Engineers regulations for
mitigation states that when considering options for successfully providing the required compensatory
mitigation, the district engineer shall consider the type and location options in order presented in paragraphs 33
CFR 323.3(b)(2) through (b)(6). The mitigation order outlined in these regulations is: (1) Mitigation bank credits,
(2) In -lieu fee program credits, (3) Permittee-responsible mitigation under a watershed approach, (4) Permittee-
responsible mitigation through on -site and in -kind mitigation and lastly (5) Permittee-responsible mitigation
through off -site and/or out -of -kind mitigation. Also, please be aware that any permittee-responsible mitigation
proposal will have to be approved prior to permit issuance for this project and would require additional
coordination and review.
Please provide the requested information within 30 days of receipt of this email. If you have any questions, concerns,
etc., please contact me via telephone or email.
Andrew Williams
Regulatory Project Manager
Regulatory Division Office
US Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Office Tel: [phone], x26
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