20221064 Ver 2_More Info Received_20221026

Baker, Caroline D
From:
Michelle Savage-Measday, PWS <[e-mail]>
Sent:
Wednesday, October 26, 2022 3:15 PM
To:
[e-mail]
Cc:
Homewood, Sue
Subject:
RE: [External] RE: Request for Additional Information: SAW-2021-02168 (McConnell
Road Industrial at 3655 McConnell Road / Greensboro / Guilford County)
Attachments:
McConnellRdlnd_GSO_10262022.pdf; McConnell Road Industrial - Wetland SOA
08-22-2022 (002).pdf
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Dave,
Attached are two SOA letters for compensatory mitigation for the McConnell Road Industrial Site Project to cover the
0.475 ac credit requirements. The letter dated 10/26/2022 added the 0.027 acre needed to cover the additional impacts
(Total: 0.055 acre). The letter dated 8/22/2022 is unchanged (0.42 acre).
Thanks,
Michelle
MICHELLE SAVAGE-MEASDAY, PWS I Environmental Senior Project Manager
T 919.861.9910 1 D 919.861.9821 C 919.441.2437
5260 Greens Dairy Road I Raleigh NC 1 27616
ECS SOUTHEAST, LLP
www.ecslimited.com
THE NEW ASTM PHASE I STANDARD IS HERE - Contact us to find out more.
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From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, October 26, 2022 10:48 AM
To: Michelle Savage-Measday, PWS <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: RE: [External] RE: Request for Additional Information: SAW-2021-02168 (McConnell Road Industrial at 3655
McConnell Road / Greensboro / Guilford County)
Thanks for the updated plan and information, Michelle. I have itemized the remaining items to resolve prior to
verification of the use of NWP 39 for this project:
1) Updated compensatory mitigation statement of availability from your chosen mitigation provider (see updated
compensatory mitigation requirement in part c. below):
a. total wetland impacts = 10,348 sq. ft.;
b. compensatory mitigation requirement is the total wetland impacts at 2:1 = 20,696 sq. ft. (0.475 acre)
c. Compensatory mitigation requirement = 0.475 riparian non-riverine wetland credits in HUC 03030002.
1

2) NCDWR 401 Individual WQC modification per Sue's requirements below.
Please let me know if you have any questions.
-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]
Email: David. [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: Homewood, Sue <[e-mail]>
Sent: Monday, October 17, 2022 9:00 AM
To: Michelle Savage-Measday, PWS <[e-mail]>; Bailey, David E CIV USARMY CESAW (USA)
<[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] RE: Request for Additional Information: SAW-2021-
02168 (McConnell Road Industrial at 3655 McConnell Road / Greensboro / Guilford County)
Michelle,
Since this wasn't identified until after I issued the 401, you will need to officially request a 401 modification to account
for the impacts that weren't shown accurately in the application. Please submit an epcn and pay the application
application fee.
Sue Homewood (she/her/hers)
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
r
From: Michelle Savage-Measday, PWS <[e-mail]>
Sent: Monday, October 10, 2022 3:13 PM
To: [e-mail]
Cc: Homewood, Sue <[e-mail]>

Subject: [External] RE: Request for Additional Information: SAW-2021-02168 (McConnell Road Industrial at 3655
McConnell Road / Greensboro / Guilford County)
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David,
I apologize for the delayed response. The client, design engineer and Greensboro have been ironing out details with
regard to the basin and the outfall structures. Greensboro is requiring the outlets from the basin and also the shallow
swale. Attached is the revised plan that includes additional wetland impacts associated with these outlets. The changes
are outlined in the red cloud on the plan. The green area includes a pipe, outfall and scour hole and the purple/red
areas are a shallow swale less than 12 inches deep, also required by Greensboro. I will request a revised SOA from the
mitigation bank for the permit application and forward to you shortly.
Please let me know if you have any further comments or questions.
Thanks,
Michelle
MICHELLE SAVAGE-MEASDAY, PWS I Environmental Senior Project Manager
T 919.861.9910 1 D 919.861.9821 C 919.441.2437
5260 Greens Dairy Road I Raleigh NC 1 27616
ECS SOUTHEAST, LLP
www.ecslimited.com
THE NEW ASTM PHASE I STANDARD IS HERE - Contact us to find out more.
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From: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Sent: Thursday, September 8, 2022 1:22 PM
To: Michelle Savage-Measday, PWS <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [EXTERNAL] RE: Request for Additional Information: SAW-2021-02168 (McConnell Road Industrial at 3655
McConnell Road / Greensboro / Guilford County)
Hi again, Michelle. A quick follow-up: I scaled Wetland Impact Areas 2 and 3 on the revised project plan (dark green,
magenta, and red shaded areas combined for each), and came up with —1,065 s.f. and 621 s.f., respectively. If that's the
case, then the impacts reported on the revised plan are underreported there. Obviously this could affect compensatory
mitigation requirements and SOA's, so please have the engineer confirm this as well. Thanks.
-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]
Email: David. [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: Bailey, David E CIV USARMY CESAW (USA)
Sent: Thursday, September 8, 2022 1:08 PM
To: Michelle Savage-Measday, PWS <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: RE: Request for Additional Information: SAW-2021-02168 (McConnell Road Industrial at 3655 McConnell Road /
Greensboro / Guilford County)
Hi Michelle, and thanks for your time on the phone this afternoon. As we discussed, I have a few additional questions to
be resolved prior to proceeding with verifying the use of Nationwide Permit (NWP) 39.
A) Regarding Wetland Impact Areas 2 and 3 on the revised project plan, please confirm whether or not the
impact totals (0.016 acre and 0.008 acre, respectively) include the dark green, magenta, and red shaded
areas, and the labels on the plans appear to indicate that these totals only include the dark green and
magenta shaded areas. Also, aside from culvert pipe placement, please specify the activities that would take
place in these areas (e.g. ditching, rip rap, etc.), including the depth of any ditching to be cut through
wetlands; provide cross -sections if necessary. Note that additional information requests may be necessary
depending on your response.
B) The following statement in your 8/19/2022 response appears to be contradictory: "Sufficient space to
complete grading and construction of the retaining wall exists to avoid further impacts to wetland areas. All
temporary wetland impacts resulting from construction activities have been accounted for and as outline in
the soil erosion control plans will be restored with a riparian seed mix upon construction completion."
Please confirm whether or not temporary wetland impacts are required for this project; if so, please provide
an updated plan sheet and impact calculations.
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 Nationwide Permit or consider your application withdrawn and
close the file. As always, let me know if you have any questions.
-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]
Email: David. [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: Michelle Savage-Measday, PWS <[e-mail]>
Sent: Friday, August 19, 2022 8:52 AM
To: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Cc: Homewood, Sue <[e-mail]>

Subject: [URL Verdict: Neutral][Non-DoD Source] Request for Additional Information: SAW-2021-02168 (McConnell Road
Industrial at 3655 McConnell Road / Greensboro / Guilford County)
David,
See below for response to your comments. In addition, in response to the City of Greensboro comments, some
additional temporary impacts (10 LF (44 SF)) adjacent to McConnell Road is accounted for in the attached impact plan.
Revisions are shown in the red cloud on the plan and are accounted for in the Wetland and Stream Impacts Table on the
plan.
1) Based on proposed grading and re-routing of drainage directly to the north of Wetland 1 and the origin of
Stream 1 into a stormwater pond, the project appears to eliminate/reduce the drainage area/hydrology source
for the upper part of Wetland 1 and Stream 1. Unless otherwise justified, the Corps would consider the upper
part (see attached marked -up "Environmental Impact Map") of Wetland 1 (0.46 acre) and Stream 1 (-0.011 acre
[154 linear feet]) as reasonably foreseeable indirect impacts (see NWP General Conditions "District Engineers
Decision") resulting from a reduction of hydrology. Unless otherwise justified, compensatory mitigation would
be required for the reasonably foreseeable indirect impacts resulting in a loss of hydrology and therefore
aquatic function; compensatory mitigation is typically required at a 1:1 ratio, depending largely on resource
quality (reference the NCWAM score of "High" for this wetland). You may also redesign aspects of the project to
ensure surface or subsurface drainage reaches this portion of the wetland/stream complex for our review,
offering specific information to justify that these areas will retain their current aquatic function;
At the request of Greensboro, the City requested the applicant to pipe and ditch pond outfalls to the two legs of
the stream. These additional discharge points will also provide hydrology to the stream and wetland to
avoid/minimize indirect impacts. This will result in additional impacts to the wetland area as shown in the table.
The revisions increases wetland impact by 1,081 SF (0.026 Ac). The wetland impact areas include the green,
purple and red areas.
2) A small area of wetland fill shown on the plans and related to proposed parking for "Area A" (included on
marked -up "Environmental Impact Map") does not appear to be included or accounted for in the PCN as an
impact or in consideration of compensatory mitigation. Please revise the plan to remove this fill, or update the
PCN, plans and compensatory mitigation proposal accordingly;
The small area of wetland fill due to grading was pulled back to avoid impacting the wetland. See the attached
plan.
3) Please ensure that appropriate construction access space is accounted for on the project plans to allow for
installation of fill slopes, retaining walls, and associated sediment and erosion control features, especially in the
several areas where these items would be placed directly along wetland boundaries. Any temporary wetland
impacts should be accounted for on the plans and PCN, including specific restoration plans to restore these
areas to functional wetlands following construction;
The comment above has been noted. Sufficient space to complete grading and construction of the retaining wall
exists to avoid further impacts to wetland areas. All temporary wetland impacts resulting from construction
activities have been accounted for and as outline in the soil erosion control plans will be restored with a riparian
seed mix upon construction completion.
4) Please provide a profile view of the proposed culvert extension stream impact, overlaid on the elevation of the
existing stream channel bottom.
A profile of the culvert extension is included on the attached plan.
5) Please provide a filled out Preliminary Jurisdictional Determination (PJD) form (see attached) for this project to
support your PJD request from 10/5/2021, with a signature above the section that states "Signature and date of
person requesting PJD (REQUIRED, unless obtaining the signature is impracticable)."
See attached PJD form.
Please let me know if you have any further questions or comments.
Thank you,
Michelle

MICHELLE SAVAGE-MEASDAY, PWS I Environmental Senior Project Manager
T 919.861.9910 1 D 919.861.9821 C 919.441.2437
5260 Greens Dairy Road I Raleigh NC 1 27616
ECS SOUTHEAST, LLP
www.ecslimited.com
THE NEW ASTM PHASE I STANDARD IS HERE - Contact us to find out more.
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KCI
10/26/2022
ENGINEERS • SCIENTISTS • SURVEYORS • CONSTRUCTION MANAGERS
4505 Falls of Neuse Road Suite 400 Raleigh, NC 27609 [phone] [phone] Fax
Wyatt Bone
McConnell Road Industrial, LLC
302 West Third Street, Suite 800
Cincinnati, OH 45202-3426
Subject: Statement of Availability — Riparian Wetland Credits
Project: McConnell Road Industrial, 3635 McConnell Road, Greensboro, NC 27405
Dear Mr. Bone,
This letter serves to confirm that KCI Technologies Inc. (KCI) has availability of 0.055 acres of riparian
wetland credits in the Black Bull Stream and Wetland Mitigation Bank, within HUC 03030002 of the Cape
Fear River Basin, to satisfy the obligation for your McConnell Road project. KCI is willing to sell these
credits for a total of $6,000.
Once you receive your permit and you agree to purchase these credits, we will issue an invoice. As soon as
KCI receives payment for this transaction, we will sign the Compensatory Mitigation Responsibility Transfer
Form (to be provided) and return it to you. We will also provide copies to the US Army Corps of Engineers
as well as your agents at ECS Southeast, LLP.
Sincerely,
Kirsten Ullman
KCI Technologies, Inc.
Natural Resources Project Manager
Cc: Michelle Savage-Measday, ECS Southeast, LLP (email)

HOLDIN*Gs
Wetland Mitigation Statement of Availability
August 22, 2022
McConnell Road Industrial, LLC
302 West Third Street, Suite 800
Cincinnati, OH 45202-3426
Attn: Mr. Wyatt Bone
RE: Availability of Riparian Wetland Credits for the "McConnell Road Industrial" project
Bank Name: Cane Creek Umbrella Mitigation Banking Instrument
Bank Site: Bethel Branch Mitigation Site
Bank Sponsor: Wildlands Holdings IV, LLC
USACE Action ID: SAW-2016-02365
Riparian Wetlands Credits Needed: 0.448 acres
Riparian Wetlands Credits Available: 0.42 acres
Cape Fear 03030002 River Basin
Dear Mr. Bone,
Wildlands Holdings IV, LLC has the above -mentioned riparian wetland credits from the Cane Creek
Umbrella Mitigation Banking Instrument: Bethel Branch Mitigation Site to partially satisfy the
mitigation requirements related to the above -mentioned project. The project is located within the
service area (HUC 03030002) of the Bank.
Credits may be reserved for a period of 6 months upon the receipt of a non-refundable deposit of 10%
of the purchase price. Should credits not be reserved, they will be sold on a first come, first serve basis.
Credit prices will be guaranteed for a period of 6 months from the date of this letter and are then
subject to change.
An invoice for this transaction will be sent upon your request and we will reserve the credits and price
for a period of 30 days from invoice. This letter is a Statement of Availability as of the date provided — it
is not a reservation of credits nor a guarantee of price.
Final transfer of credits will occur upon completion of the Mitigation Responsibility Transfer Form within
the 404 permit.
We appreciate the opportunity to assist you with your mitigation requirements. Please contact me at
[phone] x124 [e-mail] if you have any questions or need any additional
information.
Wildlands Holdings IV, LLC • Wildlands Engineering, Inc • 1430 South Mint Street, Suite 104, Charlotte, NC 28203

HWILDLANGSoiOO
Sincerely,
Ashley N. Yarsinske
Wildlands Engineering, Inc.
Marketing & Credit Sales
[e-mail]
0: [phone] ext. 124
M: [phone]
Cc: Ms. Michelle Savage-Measday, PWS, Environmental Senior Project Manager I ECS Southeast, LLP
Wildlands Holdings IV, LLC • Wildlands Engineering, Inc • 1430 South Mint Street, Suite 104, Charlotte, NC 28203