20210816 Ver 1_More Info Requested_20220411

Strickland, Bev
From: Homewood, Sue
Sent: Monday, April 11, 2022 9:18 AM
To: Brad Luckey
Cc: [e-mail]; [e-mail]; [e-mail];
Bailey, David E CIV USARMY CESAW (USA); [e-mail]; [e-mail];
Samuel Hinnant; Munzer, Olivia
Subject: Request for Additional Information for Gallimore Dairy Road Extension-DWR#
20220379 and Project Elixir (350 South)-DWR#20210816- Guilford Co
All,
I have completed the DWR review of the subject projects. I have many of the same questions as the USACE, therefore
please copy me on your response to the items listed below. In addition, please address the following additional
items. Please response within 30 days of this request and note that both applications will be considered "on hold" until
receipt of a complete response to all listed items.
1. Please provide a drawing/plan sheet that shows both Gallimore Dairy Road Extension (in it's entirety) and
Project Elixir and all jurisdictional features to assist the Division with evaluating Avoidance and Minimization for
both projects.
2. Notwithstanding the responses to item 1 below regarding Gallimore Dairy Road extension:
a. If this roadway is determined to be a public thoroughfare maintained by the City of High Point then we
strongly recommend that the City be a co -applicant for the 401.
b. Depending on the further evaluation of the roadway, the proposed Randleman Buffer impacts may
require Division review and approval.
c. Please clarify who/what entity is providing assurances that future crossings will be constructed as
spanning structures.
d. If the City of High Point is to assume responsibility of the proposed roadway, please provide
documentation that they will allow the proposed spanning structure as it does not appear to comply
with local NCDOT recommendations/requirements.
e. Please clearly show the proposed limits of Phase 1 of Gallimore Dairy Rd extension on the plan sheets.
f. Please provide a detailed stormwater management plan and/or diffuse flow plan for the entirety of
Gallimore Dairy Rd Extension and ensure that the proposed plan is in compliance with the Randleman
Buffer Rules.
3. Notwithstanding the responses to item 1 below regarding Project Elixir:
a. Please provide information regarding the location of utilities being provided to the site. Will any utility
corridors require additional jurisdictional impacts?
b. While the Division recognizes the parking requirements of the applicant, and safe ingress/egress for
large vehicles, it is unclear that the current roadway alignment and parking areas provide for the
maximum Avoidance and Minimization within the site. For example, could employee parking be
reconfigured in a more North/South alignment allowing for the western access road to be moved west
and south and impact less of the stream and buffer at this location?
c. It is unclear from the application documentation that the project is in compliance with the City of High
Point's Ordinance requirements regarding the Randleman Buffer Rules. As the Division is unable to
issue a 401 Certification that may not be in compliance with the local ordinances related to the
Randleman Buffer Rules, please provide a Buffer Authorization (or other form of approval) from the City
of High Point or provide further information/documentation of the City's review process.
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Please be aware that the upon review of the responses to the items requested, it may be necessary to request
additional information.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, April 7, 2022 3:36 PM
To: Brad Luckey <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]
Subject: [External] Request for Additional Information: SAW-2014-02098/SAW-2021-01390, Gallimore Dairy Road
Extension and Project Elixir (350 South), Colfax, Guilford Co, NWP 14 and 39 Verifications
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
All,
Thank you for your PCNs for the above referenced Gallimore Dairy Road Extension and Project Elixir (350 South)
projects, dated 3/8/2022 and 3/16/2022, respectively. I have reviewed the information and need clarification before
proceeding with verifying the use of Nationwide Permits (NWPs) 14 (https://saw-reg.usace.army.mil/NWP2021/NWP-
14.pdf) and 39 (https://saw-reg.usace.army.mil/NWP2021/NWP39.pdf). Please submit the requested information below
(via e-mail is fine) within 30 days of receipt of this Notification, otherwise we may deny verification of the use of the
NWPs or consider your applications withdrawn and close the files:
The following items are specific to the proposed Gallimore Diary Road Extension:
1) The information provided does not fully justify that the proposed Gallimore Diary Road Extension is a project
with independent utility from Project Elixir (350 South). Please provide the following to enable our continued
evaluation:
a. What municipality/entity will assume responsibility and maintenance of this transportation facility into
perpetuity? Please provide any supporting documentation;
b. Provide documentation to justify that this road extension is part of a thoroughfare or other
transportation plan to show purpose and need other than to facilitate access to Project Elixir (350 South)
and future portions of the High Point North Industrial Center;
c. Provide traffic data/analysis to justify the Gallimore Dairy Road Extension as a transportation project
with independent utility, absent of future traffic needs for Project Elixir (350 South) and future portions
of the High Point North Industrial Center;
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d. Design of the first crossing only, which does not allow evaluation of all potential direct and indirect
impacts required to complete the proposed road extension to Adkins Road (i.e. not logical termini), is
insufficient for the evaluation of the proposed road extension. Please provide plan and cross section
drawings of the remaining crossings;
e. In order to justify width of the proposed roadway and show avoidance and minimization to the
maximum extent practicable per NWP General Condition 23a, please provide the roadway cross section
showing the number and width of travel lanes and shoulder widths, and a description of how that
compares to the existing portion of Gallimore Dairy Road just east of the existing intersection of Sandy
Ridge Road and Gallimore Dairy Road;
f. Absent Project Elixir (350 South), would an alignment of Gallimore Dairy Road be available/viable to
avoid at least one stream crossing, such as aligning the route south of the origins of Streams MSB/BSA
and thereby crossing Stream MSA downstream of its confluence with Stream MSC?
2) The Gallimore Dairy Road Extension alignment intersects with Adkins Road just west of a topographic drainage
that occurs outside of the PJD Review Area for Project Elixir (350 South) and does not appear to be covered by
the additional evaluation area you provided in the PCN. Within the proposed alignment, has this drainage been
evaluated for the presence of potential waters of the US, including wetlands? Please provide documentation
accordingly.
3) Proposed bottomless culverts:
a. Please provide a cross section view of the proposed bottomless culvert structures (see item 1)d. above)
clearly showing the outer walls of the culvert structures and footers, disturbance limits needed to
construct the structure, and the stream profile. This information is needed to ensure that this structure
would not result in direct impacts to the stream;
b. The Corps Wilmington District Raleigh Regulatory Field Office has had long experience with bottomless
culverts. We generally agree with NCDOT that the long-term success of such structures is significantly
enhanced when they are tied into shallow bedrock. NCDOT Division 7 does not typically pursue
bottomless culverts unless there is non-scourable bedrock within 5 vertical feet of the soil surface. In
cases where the structures are not tied into bedrock we have seen numerous instances of foundation
undercutting, often leading to replacement with traditional culverts. Further, shading under the arch
culvert inevitably leads to die -off of any remaining woody vegetation. These factors predictably lead to
loss of aquatic function through stream bank erosion and winnowing out from foundation to
foundation.
c. Given that the project proposes impacts requiring 404 approval, we are evaluating both direct and
reasonably foreseeable indirect impacts to 404 resources associated with the project to ensure that the
individual and cumulative adverse environmental effects are no more than minimal (NWP General
Condition 23 and District Engineer's Decision part 2). Based on the above, it is reasonable to conclude
that the proposed bottomless culverts would result in indirect impacts to streams in the footprint of the
structures. The proposed indirect impacts to streams appears to exceed 0.02 acre, the typified stream
mitigation threshold per Regional Condition B.7, in this case. Compensatory mitigation for this
predictable reduction in (though not a total loss of) stream function is typically required at 1:1, unless
otherwise justified based on an evaluation of stream function (i.e. NCSAM).
The following items are specific to Project Elixir (350 South):
4) The information provided does not fully justify that Project Elixir is a project with independent utility from the
Gallimore Dairy Road Extension. Specifically, a portion of impacts proposed to Stream MSB are for an access
road that does not connect to any infrastructure (i.e. has no purpose) absent the proposed Gallimore Dairy Road
Extension. Information in item 1 above will be required to evaluate the independent utility of the Gallimore
Dairy Road Extension. Otherwise, note that these projects currently appear to be part of the same single and
complete project to provide required infrastructure to develop Project Elixir (350 South) and future portions of
the High Point North Industrial Center.
5) It has come to our attention that the area proposed for development of the Gallimore Dairy Road Extension and
Project Elixir (350 South) appear to be phases of the High Point North Industrial Center (see attached).
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Generally, the Corps would consider the entire buildout of such an industrial park as a single and complete
project with impacts considered cumulative with respect to NWP and compensatory mitigation thresholds.
Please provide for our evaluation any information available to justify that Project Elixir (350 South) is a single
and complete project with independent utility apart from the High Point North Industrial Center. Furthermore,
even if Project Elixir (350 South) and the Gallimore Dairy Road Extension are considered part of an overall High
Point North Industrial Center single and complete project, it may still be possible to permit in phases by stacking
NWPs if it can be shown that the reasonably foreseeable impacts associated with full buildout of the High Point
North Industrial Center would not exceed the NWP threshold; any information you can provide to this effect
would be useful.
6) Thank you for addressing avoidance of indirect impacts to remaining portions of Stream MSB downstream of the
proposed fill slope. Please show the location of the proposed French drain on the zoomed -in plansheet;
Please note that responses to the questions above may prompt additional information requests to allow full evaluation
of the proposed project(s). Also note that it appears that an Individual 401 WQC would be required from NCDWR for the
proposed project(s); the Corps cannot verify the use of any NWP without a valid 401 Water Quality Certification.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Office: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG <[e-mail]>
Sent: Thursday, March 17, 2022 11:34 AM
To: Brad Luckey <[e-mail]>; RaleighNCREG <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: RE: SAW-2021-01390, Project Elixir (350 South), Colfax, Guilford Co, NWP 39 Verification
Good Morning,
We have received your Pre -Construction Notification (PCN) NWP request for the above project.
Dave-docs forwarded it to your folder.
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Sorry for the mistake, but the correct action ID for this project is SAW-2014-02098 (Project 350 South / Sandy Ridge
Road / Adkins Road / Joe Drive / Greensboro / Guilford County).
Thank you,
Josephine Schaffer
From: Brad Luckey <[e-mail]>
Sent: Wednesday, March 16, 2022 4:35 PM
To: RaleighNCREG <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: [URL Verdict: Unknown][Non-DoD Source] SAW-2021-01390, Project Elixir (350 South), Colfax, Guilford Co,
NWP 39 Verification
Happy Mid Week Corps —please find attached PCN for NWP 39 Verification of above referenced site. Please let me
know if you require additional information.
Sue —we will upload to DWR today.
Thanks.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
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