20220041 Ver 1_More Info Received_20220121

From:Michelle Savage-Measday, PWS
To:Yankura, Kaylie; Leslie, Andrea J
Cc:Brown, David W CIV USARMY CESAW (US) ([e-mail])
Subject:[External] B&F Ceramics, Henderson County (DWR#20220041)
Date:Friday, January 21, 2022 3:45:05 PM
Attachments:B&F Ceramis DWR#20220041 1-20-22.pdf
2021-Dec-21 Letter to Mills River RE Rezoning.pdf
BF Ceramics Concept Plan 1-18-22.pdf
111 Bagwell Mill Road Buncombe County GIS Creeks and Streams_9.28.2021.pdf
LOI Offer Dated 3.19.2021 Signed by MEF 7 pp.pdf
220 Continuum Dr Full Data_4.7.2021.pdf
Buncombe Co Tax Map with Flood Zone Layers Shown.pdf
FEMA MAP 508 Swannanoa River Rd Asheville.pdf
NC WAM Rating Calculator v5.0.xlsm
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Kaylie and Andrea:

Please see below in red and also attachments as referenced in this response.

1. The site plan provided with the PCN does not demonstrate the need for impacts to Wetland 1
(W1) and the upper reach of Stream 1 (S1). Please provide a site plan with proposed impacts
(road, building, parking, stormwater control features, utility layout, etc.) overlain on
jurisdictional features. [15A NCAC .0502(a)(9)]
The attached December 21, 2021 letter to Mills River request that the town consider an accessory
residential dwelling unit at the rear of the property, as shown in the Preliminary Site Plan dated
January 18, 2022. As described in the letter to Mills River, the purpose of the residential dwelling
unit is to provide temporary on-site lodging for visiting owners of the company (headquartered in
Fredericksburg, VA), visiting guests of the company, and other visitors such as manufacturers
traveling from abroad. The nature of the business involves wholesale import of ceramic, porcelain
and finished floor products from western European manufacturers. The Preliminary Site Plan
requires extensive grading for the driveway leading to this accessory residential dwelling unit
resulting in impacts to both Wetland W1 and Stream S1.

2. The site plan provided with the PCN shows impacts to Wetland 2 (W2) associated with a
proposed parking lot. These impacts were not included on the PCN impact table. Please
confirm if impacts to W2 are proposed. If so, please submit an updated PCN impact table and
NCDMS acceptance letter that reflects this information. [15A NCAC 02H .0506(b)(1) and (c)]
[15A NCAC 02H .0502(c)]
As stated in David Brown’s email on January 14, 2022, “Wetland 2 was a stormwater feature from
the former airplane hangar building & concrete pad. It caught runoff from the building & pad &
diverted the surface flow to the west & south”. It is a non-jurisdictional feature.

Follow up comment from NC DWR:
Per 15A NCAC 02H .1405 (3), impacts to federally non-jurisdictional features for the
entire project that total less than or equal to 1/3 acre in the mountain region are
deemed to be permitted, provided that they comply with Subparagraph 4 of 15A NCAC
02H .1405:

(A) Erosion and sediment control practices shall equal at a minimum those required
by the N.C. Division of Energy, Mineral, and Land Resources (DEMLR) or its local
delegated program for the Sedimentation Pollution Control Act and shall be in
compliance with all DEMLR or appropriate local delegated program
specifications governing the design, installation, operation, and maintenance of
such practices in order to help assure compliance with the appropriate turbidity
and other water quality standards;
(B) All erosion and sediment control practices placed in federally non-jurisdictional
wetlands or federally non-jurisdictional classified surface waters shall be
removed and the original grade restored within two months after the DEMLR or
appropriate local delegated program has released the specific drainage area
within the project;
(C) Uncured or curing concrete shall not come into direct contact with waters of the
State;
(D) All work in or adjacent to federally non-jurisdictional intermittent or perennial
streams shall be conducted so that the flowing stream does not come in contact
with the disturbed area; and
(E) Measures shall be taken to ensure that the hydrologic functions of any
remaining federally non-jurisdictional wetland and federally non-jurisdictional
classified surface waters are not adversely affected by the discharge.
The project will comply with the above conditions. Refer to Figures 5.2 and 5.3 of the
attachment entitled B&F Ceramics DWR#20220041 1-20-2022, which details BMP measures
to be utilized during construction.

3. Please provide more details regarding avoidance and minimization of wetland and stream
impacts in the design/layout of this project. This should include alternative designs and layout
evaluations considered. The Division cannot issue a certification until it is determined that
impacts to surface waters have been minimized and there are no practical alternatives to the
proposed discharge. [15A NCAC .0506(b)(1) and (2)]
Prior to the selection of the 12.4 acres of land on Boylston Highway, the applicant and their agent
spent approximately 13 months seeking sites within the Asheville area and focused their effort on
existing sites and buildings in Henderson County and in Buncombe County. The sites needed
highway access, existing utilities or access to utilities, potential modification/expansion to smaller
warehouse space to meet their need for a larger facility and avoid properties with environmental
constraints (i.e., floodplain, wetlands, streams). The list of candidate properties and the reason(s) for
their elimination or consideration are as follows:

1. 111 Bagwell Mill Road, Buncombe County NC, 5.41 Acres: This site was heavily considered
based upon its zoning characteristics, however it proved to lack feasibility for two principal
reasons, namely that it is bisected by streams likely to be considered WOUS, and it lacked
adequate public sewer capacity for the intended development. Our LOI was withdrawn based
upon these findings. (See attached 111 Bagwell Mill Road Buncombe County GIS Creeks and
Streams_9.28.2021.pdf and LOI Offer Dated 3.19.2021 Signed by MEP 7 pp.pdf))
2. 220 Continuum Drive, Fletcher NC, 8.35 Acres: This 31,500 SF existing building was vacant at
the time of our interest. It would have required a significant addition of almost equal size to
that existing, in order to be large enough for the Applicant. Although the site had no known
WOUS impacts, the asking price proved to be largely non-negotiable, which left the project
without merit on a cost basis. The building is now fully leased to others. (See attached 220
Continuum Dr Full Data_4.7.2021.pdf)
3. 508 Swannanoa River Road, Asheville NC: This site offered a potential opportunity to
purchase a vacant land site and adjacent existing building, together with a compatible
business opportunity. All of the available land needed for future growth and under the same
ownership as the principal facility had WOUS impacts. The site was eliminated from
consideration due to the WOUS issues and the fact that there had been previous flooding at
the property. (See attached Buncombe Co Tax Map with Flood Zone Layers Shown.pdf and
FEMA Map 508 Swannanoa River Rd Asheville.pdf)
4. Boylston Highway, 12.43 acres, Town of Mills River NC: The Chosen Site. This site
possessed all of the zoning criteria needed for development of a 67,000 SF showroom and
warehouse facility with heavy truck loading and future expansion capability. At the time of our
first contact with the owner’s exclusive agents, there was no apparent knowledge of any
WOUS impacts and no awareness of any other property constraints that would prevent
feasible warehouse development. Public sewer availability was 1500 LF to the northeast,
however all other wet and dry utilities were readily available. Of these four parcels
considered, the Boylston Highway land was the only viable choice that could be considered in
an extremely tight land market south and west of Asheville. This site requires heavy truck
loading on the southwest side of the site because there is over 20 feet of elevation difference
from the rear of the site to Boylston Highway, and grades in excess of 5-7% are prohibitive
with tractor trailers loaded with pallets of ceramic tile.

The location of a +/- 67,000-SF warehouse and showroom facility on the Boylston Highway site with
loading dock space, tractor trailer parking and vehicular parking were limited with regard to
alternative configurations and site placement of the building. In addition, topographic constraints
and leveling of the property to house a 67,000-SF facility presented its own constraints and
challenges. The current location of the building towards the rear of the property accommodates
heavy truck loading with good separation from vehicular traffic to avoid conflicts/safety issues.
Buildings located at the front of the warehouse/showroom facility are anticipated to contain
complementary businesses.

4. Please provide a detailed engineering plan, profile view, and cross-section of all proposed
culverts. These drawings must include details regarding stream alignment in relation to pipe
alignment, pipe slope, pipe burial, and dissipater pad if applicable [15A NCAC 02H .0506(b)(2)
and (3)]
Refer to Figures 5.2 and 5.3 of the attachment entitled B&F Ceramics DWR#20220041 1-20-2022,
which details BMP measures to be utilized during construction and the BF Ceramics Concept Plan
dated 1-18-2022.

NC Wildlife Resources Commission Comments:

Why are impacts to Wetland 1 needed? It’s unclear from the plan that was provided
in the PCN. See response to 1 above with regard to the need to impact Wetland W1.

Did you rate Wetland 1 with NCWAM? If yes, can you send the form along? The
NCWAM spreadsheet is attached to this email. The wetland ranked as Medium. David Brown
informed me that a 2:1 ratio for mitigation would be required.

Please reach out with any further questions or comments.

Thank you,

Michelle

MICHELLE SAVAGE‑MEASDAY, PWS​ | Environmental Senior Project Manager
T 919.861.9910 | D 919.861.9821 | C 919.441.2437
5260 Greens Dairy Road | Raleigh | NC | 27616
ECS SOUTHEAST, LLP
www.ecslimited.com
THE NEW ASTM PHASE I STANDARD IS HERE ‑ Contact us to find out more.

Instagram | LinkedIn | Facebook | Twitter
Confidential/proprietary message/attachments. Delete message/attachments if not intended recipient.53195319