20210816 Ver 1_More Info Received_20220627

Strickland, Bev
From: Brad Luckey <[e-mail]>
Sent: Monday, June 27, 2022 5:39 PM
To: [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]
Cc: Homewood, Sue; Munzer, Olivia
Subject: [External] RE: Request for Additional Information for Gallimore Dairy Road Extension-
DWR#20220379 and Project Elixir (350 South)-DWR#20210816- Guilford Co
Attachments: RES Cape Fear 03 SOA - Feed & Seed - 350 South-PNK High Point.pdf; 350 South
Project Elixir DMS Acceptance.pdf; HP Industrial Park North DEM Overlay.png
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Good Afternoon David and Sue,
Please find the below applicant response and attachments. Please let me know if you require additional
information. Thanks.
USACE RFI 1) Based on the information submitted the Corps will evaluate impacts to potential waters of the US
proposed under both PCNs as cumulative for one single and complete project, pertaining to NWP and compensatory
mitigation thresholds (per NWP General Condition 28).
USACE RFI 2) Thank you for the information submitted in response to item 2) from our 4/7/2022 request for additional
information. The data resolved our concerns with this item.
Applicants Response: The applicants acknowledge.
USACE RFI 3) Additional information was not provided to justify the Gallimore Dairy Road Extension as a transportation
project with independent utility, as requested in items 1)b. or c. of our 4/7/2022 request for additional information. As
such, if the primary purpose of Phase A of the Gallimore Dairy Road Extension is to provide access to Project PNK-High
Point, could additional avoidance and minimization of impacts to potential waters of the US (per NWP General
Conditions 23.(a)) be achieved by accessing the proposed PNK-High Point development site via Joe Drive instead of the
proposed Phase A of the Gallimore Dairy Road Extension? If so, please re -design the project accordingly. If such design is
not practicable (available and capable of being done after taking into consideration cost, existing technology, and
logistics in light of overall project purposes), please provide specific justification.
Applicant Response: The use of Joe Drive for accessibility to the Project PNK-High Point project is not feasible for
multiple reasons. The Project PNK-High Point's access has been designed to utilize access from Gallimore Dairy Road
extension to meet or exceed general safety requirements for separation of tractor and vehicular traffic in addition to
satisfying the users internal requirements for operational efficiency. The Project PNK-High Point has been designed for
approximately 180 tractor trailer trips and 550 vehicular trips daily for employees and visitors. The proposed facility is
anticipated to operate three shifts that allow 24-hour per day operations. As part of the user's site development
requirements, access to Sandy Ridge Road near the intersection of Interstate 40 from a signaled intersection is a
necessity for tractor and vehicular travel.
i

The use of Joe Drive for access to the Project PNK-High Point project was evaluated and considered to not be feasible,
absent of Phase A of the Gallimore Diary Road extension, for multiple reasons. Joe Drive is a state maintained road with
an existing approximate 60-foot right of way. Generally, a proposed industrial right of way for a thoroughfare will be as
much as twice this for general safety concerns. Five private landowners, four single family residences and one church,
are located adjacent to Joe Drive. The church's primary building is currently located approximately 25' to 30' from the
exiting right of way and approximately 65' or less from existing edge of pavement. For Joe Drive to be utilized as sole
access for Project PNK-High Point, then additional right of ways would need to be obtained to support the necessary
width of the road such that the road can safely accommodate the proposed tractor trailer and vehicular requirements of
the site. Doing so has significant potential to result in demolition of the existing church structure and/or potential
rebuilding of the church on the existing parcel or relocation of the church to another off -site location. Notwithstanding
significant concerns associated with the church, the remaining single family residences only access to or from their
residences is from Joe Drive, which would result in significant adverse effects to aesthetics, property value and safety of
those residences due to substantial increases in vehicular and tractor trailer traffic. Therefore the use of Joe Drive was
determined to not be feasible because it does not meet the users' internal requirements, general safety requirements
and would be a significant adverse effect to nearby populace along Joe Drive. While the use of Gallimore Diary Road
extension for access to the Project PNK-High Point facility does result in impact to streams, this impact is necessary
The applicants have utilized several methods of avoidance and minimization including a smaller building footprint,
redesign of cross-dock/trailer storage to reduce stream impact from the road drive around the building, utilization of a
bottomless arch/span crossing for Gallimore Diary Road extension and several other methods to avoid and minimize
impacts to the waters of the US. There are no other practical or reasonable design considerations that can be
incorporated that meets the projects' purpose and need and general safety requirements that would avoids or
minimizes more impacts to the waters of the US than proposed.
USACE RFI 4) Thank you for the additional information provided pertaining to the proposed bottomless culvert structure.
The information provided satisfies item 3)a. from our 4/7/2022 request for additional information. The information also
indicates that the structure would be tied to bedrock within 5 vertical feet of the soil surface, although it remains
uncertain that the City of High Point would accept the proposed design. Based on our review of the information
provided, proposed permanent loss of stream for the single and complete project is 0.0198 acre (158 linear feet),
whereas the amount of stream proposed under the bottomless culvert is approximately 0.01 acre (135 linear feet). As
stated in our request for additional information, based on our District's considerable experience with these structures,
the shading that will occur under the proposed bottomless culvert (^'4-7 foot height within the ^'145-foot long structure)
will lead to the die -off of woody vegetation which provides the structure that keeps the stream banks intact. Erosion of
stream banks then occurs leading to sediment loading in the stream, over -widening of the channel, and reductions in
habitat heterogeneity. Such reductions in stream function are predictable, and therefore the District reviews these
activities as indirect impacts per the NWP General Conditions District Engineer's Decision part 2. Given that such
reduction in function to 0.01 acre (135 linear feet) of stream channel is anticipated as indirect impacts, and considering
that the proposed permanent loss impacts to streams associated with the project (0.0198 acre [158 linear feet]) are only
slightly below the compensatory mitigation threshold typified in NWP 39/14 Regional Condition C.7, compensatory
mitigation for these cumulative impacts is warranted to ensure that the cumulative adverse environmental effects
associated with this project are no more than minimal.
You correctly note that the proposed bottomless culvert would not result in a complete loss of aquatic habitat/function,
and does not eliminate all habitat/function or aquatic passage compared to a traditional culvert with bottom. However,
as stated above, reductions in these functions are predictable and therefore justify a compensatory mitigation
requirement, understandably at a reduced mitigation -to -impact ratio at least for the indirect impacts. Whereas a
compensatory mitigation ratio of 2:1 is typically required for permanent loss impacts, a reduced ratio of 1:1 is typically
required for reductions (though not a loss) of aquatic function. As an example, NCDOT, the entity primarily installing
bottomless culverts in North Carolina does so rarely, and when they do typically provide compensatory mitigation at a
1:1 ratio.
As stated in our request for additional information, an evaluation of stream function (i.e. NCSAM) could be provided in
2

an attempt to propose compensatory mitigation ratios different than those listed above for both permanent loss and
indirect impacts.
Applicant Response: The applicant proposes 1:1 compensatory mitigation for the cumulative and indirect impacts to 135
linear feet of stream channel affected by the bottomless arch culvert. The applicant will satisfy the mitigation proposal
from the Feed & Seed private mitigation bank, which according to attached SOA dated 6.27.22, currently has credits
available to satisfy the mitigation proposal. If mitigation credits are not available from the Feed & Seed private
mitigation bank at the time of NWP verification, then the applicant will utilize available credits from NCDMS to satisfy
the mitigation proposal. Please find also attached NCDMS letter dated 3.8.22.
USACE RFI 5) Information provided in your response do not adequately address item 5 from our 4/7/2022 request for
additional information. Information we previously provided pertaining to the High Point North Industrial Center clearly
shows that there are future plans for development within this area. These concerns are more relevant given the absence
of justification of the Gallimore Dairy Road Extension as a single and complete project. Unless the currently proposed
project can be justified as having independent utility from the High Point North Industrial Center, information is needed
to justify that the reasonably foreseeable impacts associated with full buildout of the High Point North Industrial Center
would not exceed NWP thresholds.
Applicant Response: The extension of Gallimore Diary Road from Sandy Ridge to Adkins Road is planned, per zoning
requirements of the site, but only Phase A has been designed. Phase A of the Gallimore Dairy Road extension will
provide access to the PNK-High Point project. Phase B of the Gallimore Diary Road extension would require 2 additional
stream crossings. It is the applicant's intention to avoid exceedance of NWP impact thresholds associated with the
construction of the remaining two stream crossings by utilizing remaining NWP impact amounts and/or the use of
bottomless arch culverts or spans. Neither applicants nor the owner have proposed plans for future development or
impacts to waters within the larger High Point Industrial Park at this time, with the exception of the disclosed two future
crossings associated with the extension of Gallimore Diary Road.
The informational brochure provided in USACE RFI dated 4.7.22 for the larger High Point Industrial Park is conceptual
and was contracted, designed, and created by the City of High Point without consent, recommendations, or
communications from the owner or either of the applicants. Significant portions of the areas shown in the larger High
Point Industrial Park have not been delineated or contracted to be delineated by the owner or applicants, specifically
those north or across Adkins Road as there are no proposed development plans for these areas at this time. The
informational brochure was completed utilizing a previously expired delineation/USACE JD that has since been updated
in 2021 for the Proposed PNK-High Point project and publicly available GIS stream/wetland information for marketing
purposes by the City of High Point or local chamber of commerce. However, the informational brochure combined with
the most recently completed stream/wetland delineation and overlaid on DEM (attached) does reasonably validate that
large scale industrial buildings and development, specifically up to a 600,000SF and 175,000SF building could occur north
of the Gallimore Diary Road extension/south of Adkins Road without future impact to waters. Therefore, additional
impact to waters associated with future build out of the High Point Industrial Park located south and east of Adkins Road
is not proposed or anticipated at this time. As documented within the informational brochure, the northern portion of
the larger High Point Industrial Park, designated as Phase II, is located north and west of Adkins Road and south of West
Market Street, both of which are existing NCDOT throughfares. Generally speaking, the depicted conceptual industrial
buildings have been designed to avoid impacts to waters based on GIS locations of streams and anticipated jurisdictional
features. Based on the conceptual layout, it is reasonable to foresee that independent utility and access from Adkins
Road and/or West Market Street could be utilized to eliminate or avoid impact to waters from the shown internal access
and interconnectivity for development located north and west of Adkins Road.
Based on information at this time, the anticipated use of future bottomless arch culverts/bridge span for the future two
crossing for Gallimore Diary Road extension and the conceptual layout of future speculative build out of the larger High
Point Industrial Park North, it is reasonable to conclude that future development or build out of the larger High Point
Industrial Park North will be done in a manner that would avoid impacts to waters.
3

Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
bluckey@ " .com
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, June 22, 2022 11:38 AM
To: Brad Luckey <[e-mail]>; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]
Cc: Homewood, Sue <[e-mail]>; Munzer, Olivia <[e-mail]>
Subject: RE: Request for Additional Information for Gallimore Dairy Road Extension-DWR#20220379 and Project Elixir
(350 South)-DWR#20210816- Guilford Co
All,
Thank you for your response to our request for additional email. Upon review of the submitted information the
following items are unresolved and/or require 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:
1) Based on the information submitted the Corps will evaluate impacts to potential waters of the US proposed
under both PCNs as cumulative for one single and complete project, pertaining to NWP and compensatory
mitigation thresholds (per NWP General Condition 28).
2) Thank you for the information submitted in response to item 2) from our 4/7/2022 request for additional
information. The data resolved our concerns with this item.
3) Additional information was not provided to justify the Gallimore Dairy Road Extension as a transportation
project with independent utility, as requested in items 1)b. or c. of our 4/7/2022 request for additional
information. As such, if the primary purpose of Phase A of the Gallimore Dairy Road Extension is to provide
access to Project PNK-High Point, could additional avoidance and minimization of impacts to potential waters of
the US (per NWP General Conditions 23.(a)) be achieved by accessing the proposed PNK-High Point
development site via Joe Drive instead of the proposed Phase A of the Gallimore Dairy Road Extension? If so,
please re -design the project accordingly. If such design is not practicable (available and capable of being done
after taking into consideration cost, existing technology, and logistics in light of overall project purposes), please
provide specific justification.
4) Thank you for the additional information provided pertaining to the proposed bottomless culvert structure. The
information provided satisfies item 3)a. from our 4/7/2022 request for additional information. The information
also indicates that the structure would be tied to bedrock within 5 vertical feet of the soil surface, although it
remains uncertain that the City of High Point would accept the proposed design. Based on our review of the
information provided, proposed permanent loss of stream for the single and complete project is 0.0198 acre
(158 linear feet), whereas the amount of stream proposed under the bottomless culvert is approximately 0.01
acre (135 linear feet). As stated in our request for additional information, based on our District's considerable
experience with these structures, the shading that will occur under the proposed bottomless culvert (^'4-7 foot
height within the ^'145-foot long structure) will lead to the die -off of woody vegetation which provides the
structure that keeps the stream banks intact. Erosion of stream banks then occurs leading to sediment loading in
the stream, over -widening of the channel, and reductions in habitat heterogeneity. Such reductions in stream
function are predictable, and therefore the District reviews these activities as indirect impacts per the NWP
4

General Conditions District Engineer's Decision part 2. Given that such reduction in function to 0.01 acre (135
linear feet) of stream channel is anticipated as indirect impacts, and considering that the proposed permanent
loss impacts to streams associated with the project (0.0198 acre [158 linear feet]) are only slightly below the
compensatory mitigation threshold typified in NWP 39/14 Regional Condition C.7, compensatory mitigation for
these cumulative impacts is warranted to ensure that the cumulative adverse environmental effects associated
with this project are no more than minimal.
You correctly note that the proposed bottomless culvert would not result in a complete loss of aquatic
habitat/function, and does not eliminate all habitat/function or aquatic passage compared to a traditional
culvert with bottom. However, as stated above, reductions in these functions are predictable and therefore
justify a compensatory mitigation requirement, understandably at a reduced mitigation -to -impact ratio at least
for the indirect impacts. Whereas a compensatory mitigation ratio of 2:1 is typically required for permanent loss
impacts, a reduced ratio of 1:1 is typically required for reductions (though not a loss) of aquatic function. As an
example, NCDOT, the entity primarily installing bottomless culverts in North Carolina does so rarely, and when
they do typically provide compensatory mitigation at a 1:1 ratio.
As stated in our request for additional information, an evaluation of stream function (i.e. NCSAM) could be
provided in an attempt to propose compensatory mitigation ratios different than those listed above for both
permanent loss and indirect impacts.
5) Information provided in your response do not adequately address item 5 from our 4/7/2022 request for
additional information. Information we previously provided pertaining to the High Point North Industrial Center
clearly shows that there are future plans for development within this area. These concerns are more relevant
given the absence of justification of the Gallimore Dairy Road Extension as a single and complete project. Unless
the currently proposed project can be justified as having independent utility from the High Point North Industrial
Center, information is needed to justify that the reasonably foreseeable impacts associated with full buildout of
the High Point North Industrial Center would not exceed NWP thresholds.
Please note that responses to the questions above may prompt additional information requests to allow full evaluation
of the proposed project(s), and 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: Brad Luckey <[e-mail]>
Sent: Tuesday, May 24, 2022 4:21 PM
To: Homewood, Sue <[e-mail]>; Bailey, David E CIV USARMY CESAW (USA)
<[e-mail]>; Munzer, Olivia <[e-mail]>
5

Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail];
[e-mail]
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Request for Additional Information for Gallimore Dairy Road
Extension-DWR#20220379 and Project Elixir (350 South)-DWR#20210816- Guilford Co
Good Tuesday Afternoon David/Sue,
I hope you both are well. Please find the attached updated PCNs for the Gallimore Diary Road extension and Project
PNK-High Point and below applicant's response to request for information and comments. Additionally, please note that
Project Elixir name has been changed to Project PNK-High Point. If you require additional information to process the
requests, then please let me know. Thanks and have a great day.
NCDWR RFI 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.
Applicant Response: See Attached Overall Impacts Map, Exhibit 1.0, Gallimore Dairy Road PCN
NCDWR RFI 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.
Applicant Response: As noted within attached PCNs, the purpose of Phase A of the extension of Gallimore Dairy Road is
to provide access and water/sewer services to the PNK-High Point project. As proposed, the applicant of the Gallimore
Diary Road extension would relinquish maintenance of Gallimore Diary Road extension to the City of High Point
following construction of the Gallimore Dairy Road extension. The proposed Phase A of the extension of Gallimore Diary
Road has been designed to be in compliance with the City of High Point, NCDOT and the Randleman Lake stormwater
and riparian buffer regulations. Requests for review and approval of site plan engineering and stormwater management
requirements has been submitted to the City of High Point for their review and approval.
NCDWR RFI 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
6

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.
Applicant Response: See Attached Overall Impacts Map, Exhibit 1.0, Gallimore Dairy Road PCN and updated PCNs. The
proposed project PNK-High Point is being accessed from Phase A of the Gallimore Diary Road extension (SAW-2014-
02098). The proposed PNK High Point project will connect to exiting sanitary sewer from the southwestern portion of
the site and existing water services from Sandy Ridge Road. An aerial sewer crossing that does not impact waters is
proposed on the western portion of the site. Other or future impacts to waters as a result of the proposed project are
not anticipated. Please see attached page 16, Impact Exhibits, Project PNK-High Point PCN. The proposed riparian
buffer impact and associated stream impact has been designed as a road crossing, whereas up and down -gradient
grading impacts from the proposed access road at 2:1 slope result in the temporary and permanent impact to the
proposed stream buffer as proposed within this application, regardless of overlap of grading or final conditions within
the riparian buffer from parking and proposed building impervious surfaces. Therefore, the proposed crossing is an
allowable use within the Randleman Buffer table of uses. The applicant is in the process of submitting a Randleman Lake
Riparian Buffer No Practical Alternative Letter to the City of High Point for review and approval.
NCWRC Comment 1) We recommend further minimizing impacts to streams. As Sue mentioned, it seems that the
parking layout could be tweaked to reduce impacts.
NCWRC Comment 2) The applicant should consider integrating some Low Impact Development techniques, such as
swales instead of curb and gutter and bioretention cells in parking lot medians
(https://www.uni-groupusa.org/PDF/NC LID Guidebook.pdf) could reduce the size of the
stormwater BMP.
NCWRC Comment 3) Sediment and erosion control measures should be installed prior to any land -disturbing
activity. Incorporate the following elements into erosion and sediment control plans: minimize
clearing and grading, protect waterways, phase construction for larger construction sites (>25
acres), stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish
appropriate perimeter controls, employ advanced settling devices, implement a certified
contractors program, and regularly inspect erosion control measures. Excessive silt and
sediment loads can have detrimental effects on aquatic resources including destruction of
spawning habitat, suffocation of eggs, and clogging of gills.
NCWRC Comment 4) Erosion control matting made of plastic mesh or twine should not be used within the project
area, including upland areas, because it can entrap and kill wildlife. The use of biodegradable
and wildlife -friendly sediment and erosion control devices is strongly recommended. Silt
fencing, fiber rolls and/or other products should have loose -weave netting that is made of
natural fiber materials with movable joints between the vertical and horizontal twines. Silt
fencing that has been reinforced with plastic or metal mesh should be avoided as it impedes the
movement of terrestrial wildlife species.
NCWRC Comment 5) Also, non-native plants should not be used for seeding disturbed areas. Specifically, avoid using
Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-native. A list of
alternatives to non-native species has been attached. Alternatively, use a grain, such as oats,
wheat, or rye for temporary cover and native seed mixes for permeant seeding. We recommend
planting native, wildflower seed mixes that will create pollinator habitat and/or and plant native
trees and shrubs for landscaping rather than using turf grass. Using native plants will also
reduce costs and time for maintenance of landscaping.
NCWRC Comment 6) Avoid tree clearing activities during the maternity roosting season for bats (May 15 — August 15)
because of the decline in populations of several tree -roosting bat species.
NCWRC Comment 7) We recommend not clearing the entire site, but rather maintaining the maximum amount of
native vegetation as possible. We suggest having the site logged instead of burning the cleared trees.
Applicants Response: The applicants acknowledge recommendations and comments from NCWRC and will incorporate
these recommendations and comments into construction and maintenance of the proposed projects whereas practical
and possible.

USACE RFI 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;
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?
Applicant Response: See attached updated PCNs. The proposed project PNK-High Point is being accessed from Phase A
of the Gallimore Diary Road extension (SAW-2014-02098). The proposed PNK High Point will connect to exiting sanitary
sewer service from the southwestern portion of the site and existing water services along Sandy Ridge Road.
USACE RFI 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.
Applicant Response: Pilot personnel conducted a stream/wetland delineation for an approximate 5.10-acre tract,
located along Adkins Road, which contains the above described drainage swale. Based on the
stream/wetland delineation, jurisdictional waters are not present on the approximate 5.10-are tract or
within the proposed disturbance limits of the Gallimore Diary Road extension.
USACE RFI 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
8

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).
Applicant Response: See Impact Exhibit 2.0, Gallimore Diary Road Extension PCN. The proposed bottomless arch culvert
does not result in a net loss fill impact to the stream and is being tied to shallow bedrock. It is our opinion that all
factors as outlined in the District Engineers Decision Part 2 of NWP 39 should be evaluated to determine what is or is not
minimal indirect loss or cumulative effect to the environment as a whole, and thus appropriate compensatory
mitigation, if any, for effects that would be considered more than individual or minimal. As noted within District
Engineers Decision Part 2 of NWP 39, "The district engineer will also consider site specific factors, such as the
environmental setting in the vicinity of the NWP activity, the type of resource that will be affected by the NWP activity,
the functions provided by the aquatic resources that will be affected by the NWP activity, the degree or magnitude to
which the aquatic resources perform those functions, the extent that aquatic resource functions will be lost as a result
of the NWP activity (e.g., partial or complete loss), the duration of the adverse effects (temporary or permanent), the
importance of the aquatic resource functions to the region (e.g., watershed or ecoregion), and mitigation required by
the district engineer". While there will be some decreases in aquatic function comparatively to conditions now, it is not
a complete or net loss (i.e. a minimal loss) of aquatic habitat/function and does not prohibit habitat/function or aquatic
passage comparatively to a traditional culvert with bottom. Furthermore, the size of the culvert (width and length) will
minimize the effect of shading impacts and die -back of woody species. Additionally, existing channel stability and local
geology (i.e. low channel slope, no presence of highly erosive soils, etc.) contribute to minimalizing the potential indirect
effect of the bottomless arch culvert to overall watershed or ecoregion. Based on these factors, we have determined
that the loss of aquatic function from the bottomless arch culvert to the stream would not be more than minimal
indirect impact or require compensatory mitigation and would have negligible effect to the overall function of the
watershed or ecoregion.
USACE RFI 4)
USACE RFI 5)
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.
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). 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
9

Center would not exceed the NWP threshold; any information you can provide to this effect would be
useful.
UACCE RFI 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;
Applicant Response: See updated PCNs. There are no future plans for development within the High Point Industrial
Center. The extension of Gallimore Diary Road from Sandy Ridge to Adkins Road is planned but only Phase A has been
designed. Phase A of the Gallimore Dairy Road extension will provide access to the PNK-High Point project. Phase B of
the Gallimore Diary Road extension would require 2 additional stream crossings. It is the applicant's intention to avoid
exceedance of NWP impact thresholds associated with the construction of the remaining two stream crossings by
utilizing remaining NWP impact amounts and/or the use of bottomless arch culverts or spans. Therefore, at this time
and based on the limited information from conceptual designs, it is not possible for the Applicant to speculate any
future roadway impact or development within the larger High Point Industrial Centers project's purpose and need or if
there would be an impact to waters as a result thereof. The Applicants acknowledges that should the future Phase B of
Gallimore Diary Road extension or other development within the larger High Point North Industrial Center were to
impact jurisdictional waters, then the USACE would need review the project's purpose and need to determine if the road
improvement project or other development within the larger High Point Industrial Center was considered cumulative to
impacts to jurisdictional waters as a result of the proposed project.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
From: Homewood, Sue <[e-mail]>
Sent: Monday, April 11, 2022 9:18 AM
To: Brad Luckey <[e-mail]>
Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; Samuel Hinnant<[e-mail]>; Munzer, Olivia
<[e-mail]>
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.
10

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.
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
11

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;
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
12

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).
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
13

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.
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
14

Kernersville, NC 27285
www.pilotenviro.com
bl uckey@ pilotenviro.com
15

Environmental Banc & Exchange, LLC Stream and Stream Banks
Statement of Availability June 27, 2022
U.S. Army Corps of Engineers
David Bailey
Raleigh Regulatory Field Office
3331 Heritage Trade Center, Suite 105
Wake Forest, NC 27587
Re Project: 350 South/Project PNK High Point
This document confirms that the PNK Holdings, LLC (Applicant) for the 350 South/Project PNK High
Point (Project) has expressed an interest to utilize 243.38 Stream Mitigation Credits from the EBX
sponsored RES Cape Fear 03 Umbrella Mitigation Bank, specifically 243.38 Stream credits from the
Feed and Seed Site, in the Cape Fear HUC 03030003. As the official Bank Sponsor, Environmental Banc
& Exchange, LLC, attests to the fact that mitigation is available for reservation at this time.
These mitigation credits are not considered secured, and consequently are eligible to be used for alternate
purposes by the Bank Sponsor, until payment in full is received from the Applicant resulting in the
issuance of a Mitigation Credit Transfer Certificate by the bank acknowledging that the Applicant has
fully secured credits from the bank and the Banker has accepted full responsibility for the mitigation
obligation requiring the credits/units.
The Banker will issue the Mitigation Credit Transfer Certificate within three (3) days of receipt of the
purchase price. Banker shall provide to Applicant a copy of the Mitigation Credit Transfer Certificate and
a documented copy of the debit of credits from the Bank Official Credit Ledger(s), indicating the permit
number and the resource type secured by the applicant. A copy of the Mitigation Credit Transfer
Certificate, with an updated Official Credit Ledger will also be sent to regulatory agencies showing the
proper documentation.
Please contact me at 919-209-1055 or [e-mail] if you have any questions.
Best Regards,
Amy Staley
Resource Environmental Solutions, LLC
3600 Glenwood Avenue, Suite 100
Raleigh, NC 27612

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretory
MARC RECKTENWALD
Director
Bradley Luckey
Pilot Environmental Inc.
PO Box 128
Kernersville, NC 27285
NORTH CAROLINA
Environmental Quality
March 8, 2022
Expiration of Acceptance: 9/8/2022
Project: 350 South Project Elixir County: Guilford
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-digit HUC)
Impact Type
Impact Quantity
Cape Fear
03030003
Randleman
Riparian Buffer Z1
Up to 11,672
Riparian Buffer Z2
Up to 19,500
Cape Fear
03030003
Warm Stream
Up to 385
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].
cc: Bradley Luckey, agent
Sincerely,
7Jh
FOR James. B Stanfill
Asset Management Supervisor
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
919.70711976

Table Of Contents
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