20230060 Ver 1_ePCN Application_20230110

DWR
Division of Water Resources
Initial Review
Pre -Construction Notification (PCN) Form
For Nationwide Permits and Regional General Permits
(along with corresponding Water Quality Certifications)
April 13, 2022 Ver 4.3
Has this project met the requirements for acceptance in to the review process?*
Yes
No
Is this project a public transportation project?*
Yes No
Change only if needed.
Pre -Filing Meeting Date Request was submitted on:
9/15/2022
BIMS # Assigned* Version#*
20230060 1
Is a payment required for this project?*
No payment required
Fee received
Fee needed - send electronic notification
What amout is owed?*
$240.00
$570.00
Reviewing Office* Select Project Reviewer*
Raleigh Regional Office - [phone] Zachary Thomas:eadstztthomas:[e-mail]
Information for Initial Review
la. Name of project:
TC&I Timber Tract
la. Who is the Primary Contact?*
Rick Trone
lb. Primary Contact Email:* lc. Primary Contact Phone:*
[e-mail] [phone]
Date Submitted
1/10/2023
Nearest Body of Water
Wombles Creek
Basin
Cape Fear
Water Classification
WS;IV
Site Coordinates
Latitude: Longitude:
35.592316 -79.107564
A. Processing Information
County (or Counties) where the project is located:
Lee
Is this a NCDMS Project
Yes No
Is this project a public transportation project? *
Yes No

la. Type(s) of approval sought from the Corps:
Section 404 Permit (wetlands, streams and waters, Clean Water Act)
Section 10 Permit (navigable waters, tidal waters, Rivers and Harbors Act)
Has this PCN previously been submitted?*
Yes
No
1 b. What type(s) of permit(s) do you wish to seek authorization?
Nationwide Permit (NWP)
Regional General Permit (RGP)
Standard (IP)
lc. Has the NWP or GP number been verified by the Corps?
Yes No
Nationwide Permit (NWP) Number: 39 - Commercial/Institutional Developments
NWP Numbers (for multiple NWPS):
ld. Type(s) of approval sought from the DWR:
401 Water Quality Certification - Regular
Non-404 Jurisdictional General Permit
Individual 401 Water Quality Certification
le. Is this notification solely for the record because written approval is not required?
For the record only for DWR 401 Certification:
For the record only for Corps Permit:
1f. Is this an after -the -fact permit application?*
Yes No
lg. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
Yes No
lg. Is payment into a mitigation bank or in -lieu fee program proposed for mitigation of impacts?
Yes No
1 h. Is the project located in any of NC's twenty coastal counties?
Yes No
1j. Is the project located in a designated trout watershed?
Yes No
B. Applicant Information
ld. Who is applying for the permit?
Owner Applicant (other than owner)
le. Is there an Agent/Consultant for this project?*
Yes No
2. Owner Information
2a. Name(s) on recorded deed:
Stephens Enterprises, LLC
2b. Deed book and page no.:
See attached Property Owner Exhibit
2c. Contact Person:
Matthew Stephens
2d. Address
Street Address
319 Chapanoke Road
Address Line 2
Suite 102
City
Raleigh
Postal /Zip Code
27603
401 Water Quality Certification - Express
Riparian Buffer Authorization
State / Province / Region
NC
Country
USA
Yes No
Yes No

2e. Telephone Number:
[phone]
2f. Fax Number:
2g. Email Address: *
[e-mail]
3. Applicant Information (if different from owner)
3a. Name:
Travis Caldwell
3b. Business Name:
Trinity Capital Advisors
3c. Address
Street Address
440 S. Church Street
Address Line 2
Suite 800
City
Charlotte
Postal / Zip Code
28202
3d. Telephone Number:
[phone]
3f. Email Address: *
[e-mail]
4. Agent/Consultant (if applicable)
4a. Name:
Rick Trone
4b. Business Name:
WithersRavenel
4c. Address
Street Address
115 MacKenan Drive
Address Line 2
City
Cary
Postal / Zip Code
27511
4d. Telephone Number:
[phone]
4f. Email Address: *
[e-mail]
C. Project Information and Prior Project History
State / Province / Region
NC
Country
USA
3e. Fax Number:
State / Province / Region
NC
Country
USA
4e. Fax Number:
1. Project Information
1 b. Subdivision name:
(if appropriate)
lc. Nearest municipality / town:
Sanford, NC
2. Project Identification
2a. Property Identification Number:
9666-78-7977-00, 9666-69-3230-00, 9666-58-
4589-00, 9667-50-6965-00,9667-50-3289-00
2b. Property size:
±346

2c. Project Address
Street Address
603 Rod Sullivan Road
Address Line 2
City State / Province / Region
Sanford NC
Postal / Zip Code Country
27330 USA
3. Surface Waters
3a. Name of the nearest body of water to proposed project: *
Wombles Creek
3b. Water Resources Classification of nearest receiving water: *
WS;IV
3c. What river basin(s) is your project located in?*
Cape Fear
3d. Please provide the 12-digit HUC in which the project is located.
030300040104
4. Project Description and History
4a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application:*
The site consists largely of undeveloped woodlands and a small area of livestock grazing area. The general land use in the vicinity consists of residential, agricultural, and industrial. The
site is flanked by US HWY 1 and the Raleigh Executive Jetport.
4b. Have Corps permits or DWR certifications been obtained for this project (including all prior phases) in the past? *
Yes No Unknown
4f. List the total estimated acreage of all existing wetlands on the property:
53.7
4g. List the total estimated linear feet of all existing streams on the property:
19,450
4h. Explain the purpose of the proposed project: *
The purpose of the proposed project is to construct a light industrial facility in multiple phases to meet the existing and growing demand for light industrial space in Lee County. Existing
industrial parks have nearly run out of available lots and this project is intended to create new industrial space for which there is currently a deficit in Lee County and is in high demand.
With entities such as Toyota and VinFast coming soon to nearby locations, this project will provide much needed supply chain industries in addition to the expanding life sciences
companies in the Sanford/Lee County area. The proposed project is strategically located adjacent to the Raleigh Executive Jetport and the CSX rail line and is near US Highway 1.
4i. Describe the overall project in detail, including indirect impacts and the type of equipment to be used: *
The portion of the project located south of Stream 1 has been fully designed and engineered. The lot/building sizes have been designed to meet the logistical needs of known and
anticipated users.
The northern portion of the project (north of Stream 1) is conceptual only at this time, as the final design and grading has not been completed at this point. However, the lot/building sizes
are based on the logistical needs of the anticipated users which must remain confidential at this time. Please note that while the northern portion of the project is currently conceptual, there
has been sufficient engineering design completed to determine that this portion of the project can been constructed without impacts to wetlands and streams. The only impacts necessary
to construct the northern portion of the project are the road crossings over Stream 1 and Wetland H to provide access to this area.
The proposed wetland and stream impacts are necessary for construction of the access road from Rod Sullivan Road and construction of one industrial building (Building 1).
An access road from Rob Sullivan Road to the northern portion of the site will require one stream crossing of Stream 1 (perennial) and one impact to Wetland H and will be constructed
with a traditional culvert and riprap dissipator at the stream crossing. The access road will largely be constructed where a farm road currently exists. The stream crossing for the access
road will be constructed in the location of an existing 18" culvert within the farm road. This road crossing is necessary to provide access to the developable uplands located north of Stream
1.
One additional permanent wetland impact (W2) is proposed for site grading and construction of Building 1.
The sewer line between Buildings 1 & 3 will be an aerial crossing over Stream 5 and Wetland D and will not result in impacts to these features.
There are no proposed impacts for construction of utilities or stormwater treatment (SCMs) and no impacts are proposed for Phase 2 to the north.
Standard commercial construction equipment and techniques will be used to construct the proposed project.
5. Jurisdictional Determinations
5a. Have the wetlands or streams been delineated on the property or proposed impact areas?*
Yes
Comments:
No Unknown
WithersRavenel conducted a delineation of the wetlands and streams in March 2022.
5b. If the Corps made a jurisdictional determination, what type of determination was made?*
Preliminary Approved Not Verified Unknown N/A
Corps AID Number:
SAW-2022-01249

5c. If 5a is yes, who delineated the jurisdictional areas?
Name (if known):
Agency/Consultant Company:
Other:
Alyssa Ricci, Patrick Welsh, Rick Trone, Gary Kreiser
WithersRavenel
5d. List the dates of the Corp jurisdiction determination or State determination if a determination was made by the Corps or DWR
Delineation was verified by the USACE on August 10, 2022. The USAGE issued a Preliminary Jurisdictional Determination (SAW-2022-01249) also on August 10, 2022. The USAGE PJD
and Approved Delineation Exhibit have been provided as attachments.
6. Future Project Plans
6a. Is this a phased project?*
Yes No
6b. If yes, explain.
The project is proposed to be constructed in phases, however, all impacts are included in this submittal.
Are any other NWP(s), regional general permit(s), or individual permits(s) used, or intended to be used, to authorize any part of the proposed project or related activity?
N/A
D. Proposed Impacts Inventory
1. Impacts Summary
la. Where are the impacts associated with your project? (check all that apply):
Wetlands
Open Waters
2. Wetland Impacts
Streams -tributaries
Pond Construction
Buffers
r2a. Site #* (?)
2a1 Reason (?)
2b. Impact type* (7)
2c. Type of W.*
2d. W. name
2e. Forested*
2f. Type of Jurisdicition*
(?)
2g. Impact
area*
W1
Road Crossing and
Grading
P
Unknown
Wetland H
Yes
Both
0.041
(acres)
W2
Site Grading
P
Unknown
Wetland F
Yes
Both
0.142
(acres)
2g. Total Temporary Wetland Impact
0.000
2g. Total Wetland Impact
0.183
2i. Comments:
3. Stream Impacts
2g. Total Permanent Wetland Impact
0.183
3a. Reason for impact (?)
3b.Impact type*
3c. Type of impact*
3d. S. name*
3e. Stream Type*
(?)
3f. Type of
Jurisdiction*
3g. S. width
3h. Impact
length*
St
Road Crossing and Grading
Permanent
Culvert
Stream 1
Perennial
Both
6
Average (feet)
135
(linear feet)
S2
Rip Rap Dissipator
Permanent
Rip Rap Fill
Stream 1
Perennial
Both
6
Average (feet)
33
(linear feet)
S3
Construction, dewatering,
access
Temporary
Dewatering
Stream 1
Perennial
Both
6
Average (feet)
36
(linear feet)
3i. Total jurisdictional ditch impact in square feet:
0
3i. Total permanent stream impacts:
168
3i. Total stream and ditch impacts:
204
3j. Comments:
3i. Total temporary stream impacts:
36

E. Impact Justification and Mitigation
1. Avoidance and Minimization
la. Specifically describe measures taken to avoid or minimize the proposed impacts in designing the project:
Prior to site plan design, the applicant requested that a detailed delineation be conducted so that impacts to wetlands and "waters" could be minimized.
Proposed permanent wetland and stream impacts for construction of the facilities have been minimized to only those necessary for construction of one
road crossing and one wetland impact to access developable uplands within the site and those required for grading to accommodate Building 1. The
proposed road crossing has been designed to cross Stream 1 perpendicularly to minimize impacts. The proposed access road will be largely in the
location of an existing farm road. At the site of the stream crossing, an existing 18" RCP will be removed and upgraded along with the rest of the road.
Additionally, headwalls have been designed at the stream crossing to stabilize road fill and further minimize impacts.
The riprap dissipator below the Stream 1 road crossing will be constructed such that the riprap will be installed by burying the riprap such that the top of
the riprap matches the pre -construction contours of the natural stream bed, allowing for the passage of aquatic life and preventing a loss of function of
stream channel.
A permanent wetland impact for the access road is unavoidable due to the locations of Pond 3 and Wetland H. The proposed road is planned to utilize
the footprint of the existing farm road to the greatest extent possible and will impact the upper reach of Wetland H while avoiding impacts to Pond 3. It is
not feasible to shift the road west due to the existing pond dam.
Due to the location of onsite wetlands and large footprint of the manufacturing buildings wetland and stream impacts are unavoidable. Stream 1 bisects
the site in a west -east fashion and therefore impacts were necessary to provide access to the developable uplands located north of Stream 1.
Additionally, Wetlands H, G, and Stream 5 run south -north. These features along with property lines and Pond 3 constrain the site. Wetland impacts
were minimized to the greatest extent possible by locating the proposed buildings in such a way to avoid all the aquatic resources except for a narrow
finger of Wetland F that extends to the south. An alternative site design would have resulted in additional impacts.
There are no impacts proposed for stormwater SCMs or utilities. A proposed aerial sanitary sewer line was designed to completely avoid stream and
wetland impacts.
Upon completion of construction, all temporarily impacted stream channels will be restored to pre -construction conditions and grades, and temporarily
stabilized with biodegradable matting and seeded with a riparian seed mix. No matting will be placed on the stream bed.
lb. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques:
Access during construction will occur within uplands. Additionally, sediment and erosion control measures will be installed prior to construction.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for impacts to Waters of the U.S. or Waters of the State?
Yes No
2c. If yes, mitigation is required by (check all that apply):
DWR Corps
2d. If yes, which mitigation option(s) will be used for this project?
Mitigation bank Payment to in -lieu fee program Permittee Responsible Mitigation
4. Complete if Making a Payment to In -lieu Fee Program
4a. Approval letter from in -lieu fee program is attached.
Yes No
4b. Stream mitigation requested:
(Wear feet)
270
4d. Buffer mitigation requested (DWR only):
(square feet)
4c. If using stream mitigation, what is the stream temperature:
warm
4e. Riparian wetland mitigation requested:
(acres)
0 0
4f. Non -riparian wetland mitigation requested: 4g. Coastal (tidal) wetland mitigation requested:
(acres) (acres)
0.366 0
4h. Comments
Please see attached NC DMS letter of acceptance for stream and wetland mitigation.
6. Buffer mitigation (State Regulated Riparian Buffer Rules) - required by DWR
6a. Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? If yes, you must fill out this entire form - please contact DWR for more information.
Yes No
F. Stormwater Management and Diffuse Flow Plan (required by DWR)
1. Diffuse Flow Plan

la. Does the project include or is it adjacent to protected riparian buffers identified within one of the NC Riparian Buffer Protection Rules?
Yes No
If no, explain why:
Project is not located within a buffered river basin.
2. Stormwater Management Plan
2a. Is this a NCDOT project subject to compliance with NCDOT's Individual NPDES permit NCS000250? *
Yes No
2b. Does this project meet the requirements for low density projects as defined in 15A NCAC 02H .1003(2)?
Yes No
Local Government Stormwater Programs
Phase II NSW USMP Water Supply
Please identify which local government stormwater program you are using.
Lee County
Comments:
G. Supplementary Information
1. Environmental Documentation
la. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land?*
Yes No
2. Violations (DWR Requirement)
2a. Is the site in violation of DWR Water Quality Certification Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), or DWR Surface Water or Wetland Standards or
Riparian Buffer Rules (15A NCAC 2B .0200)?*
Yes No
3. Cumulative Impacts (DWR Requirement)
3a. Will this project result in additional development, which could impact nearby downstream water quality?*
Yes No
3b. If you answered "no," provide a short narrative description.
Project will not result in additional development that could impact nearby downstream water quality.
4. Sewage Disposal (DWR Requirement)
4a. Is sewage disposal required by DWR for this project?*
Yes No N/A
4b. Describe, in detail, the treatment methods and dispositions (non -discharge or discharge) of wastewater generated from the proposed project. If the wastewater will be treated at a
treatment plant, list the capacity available at that plant.
Sewage will be conveyed to an offsite wastewater treatment plant via collection system.
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or habitat?*
Yes No
5b. Have you checked with the USFWS concerning Endangered Species Act impacts?*
Yes No
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d. Is another Federal agency involved?*
Yes
5e. Is this a DOT project located within Division's 1-8?
Yes No
No Unknown
5f. Will you cut any trees in order to conduct the work in waters of the U.S.?
Yes No
5g. Does this project involve bridge maintenance or removal?
Yes No

5h. Does this project involve the construction/installation of a wind turbine(s)?*
Yes No
5i. Does this project involve (1) blasting, and/or (2) other percussive activities that will be conducted by machines, such as jackhammers, mechanized pile drivers, etc.?
Yes No
5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat?
On March 2, 2022, WithersRavenel conducted a review of the project site for the purpose of evaluating for the presence of federally listed threatened
and endangered species and/or their potential habitat. The review area does not contain occurrences of, or potential habitat for federally listed species
and the proposed activity will have no effect on these species or their critical habitat. The results of the survey were submitted to the USFWS for review.
In a letter dated September 8, 2022 the USFWS stated that the Service agreed with our determination. A copy of the USFWS concurrence letter is
attached.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as an Essential Fish Habitat?*
Yes No
6b. What data sources did you use to determine whether your site would impact an Essential Fish Habitat? *
There are no waters in Lee County classified as EFH.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation status?*
Yes No
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?*
SHPO issued a review letter on April 21, 2022 for the southern portion of the project (south of Stream 1), which has been provided as an attachment.
SHPO determined that the project as proposed within the southern portion of the project will not have any effect on historic structures. SHPO did
however recommend a comprehensive archeological survey be conducted due to numerous archeological sites having been identified in the immediate
vicinity. Terracon conducted a Phase 1 archeological survey on 119 acres which identified 7 new archeological sites. Terracon recommended that the
newly identified sites should not be considered eligible for listing in the NRHP and SHPO agreed with Terracon's findings and recommendations in their
comment letter dated 9/9/2022 (see attached).
Terracon conducted an additional archeological survey on the 255-acre northern portion of the project (north of Stream 1) which identified 12 new
archeological sites. Terracon recommended that the newly identified sites should not be considered eligible for listing in the NRHP and SHPO agreed
with Terracon's findings and recommendations in a December 13, 2022 letter (see attached). One site, 31LE241, a cemetery, was recommended to
preserved through avoidance. The cemetery has two grave sites and is within the footprint of the "truck loading area" of the eastern building in the
northern portion of the project and therefore must be relocated prior to construction. Terracon has completed the required procedures for relocation of
the gravesites within the cemetery and they will be properly relocated prior to ground disturbance in this area.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain?*
Yes No
8c. What source(s) did you use to make the floodplain determination?*
FEMA flood maps
Miscellaneous
Please use the space below to attach all required documentation or any additional information you feel is helpful for application review. Documents should be combined into one file when
possible, with a Cover Letter, Table of Contents, and a Cover Sheet for each Section preferred.
Click the upload button or drag and drop files here to attach document
Cover Letter and Attachments Final.pdf 9.36MB
File must be PDF or KMZ
Comments
Please see included Cover Letter and Attachments
Signature
By checking the box and signing below, I certify that:
• The project proponent hereby certifies that all information contained herein is true, accurate, and complete to the best of my knowledge and belief'; and
• The project proponent hereby requests that the certifying authority review and take action on this CWA 401 certification request within the applicable reasonable period of time.
• I have given true, accurate, and complete information on this form;
I agree that submission of this PCN form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND
I intend to electronically sign and submit the PCN form.
Full Name:
Rick Trone

Signature
Ric.¢ %atic
Date
1/10/2023

-0- WithersRavenel
.. Our People. Your Success.
January 10, 2023
US Army Corps of Engineers
Raleigh Regulatory Field Office
Ms. Jean Gibby
3331 Heritage Trade Drive
Suite 105
Wake Forest, NC 27587
NC -Division of Water Resources
401 & Buffer Permitting Unit
Ms. Kelsey Rowland
1617 Mail Service Center
Raleigh, NC 27699
Re: TC&I Timber Tract - NWP 39 & 401 PCN Submittal
Sanford, Lee County
USACE AID #SAW-2022-01249
WR Project #02211428.01
Dear Ms. Gibby and Ms. Rowland,
On behalf of Trinity Capital Investors, we are requesting authorization from the USACE to use
NWP 39 for 0.036 ac (168 If) of permanent stream impacts, 0.008 ac (36 If) of temporary stream
impacts, and 0.183 acres of permanent wetland impacts for construction of five buildings, an
access road, and associated infrastructure (roads, parking, utilities, stormwater management, etc.)
for construction of an industrial park to help meet the existing demand for new light industrial
space in Lee County and further fueling the economic growth of the region. We are also
requesting an NCDWR 401 WQC for the above referenced impacts.
The following tables represent the proposed impacts:
Proposed Impact Table
Feature
Type of Impact
Impact Area
LF
SF
AC
Stream
Permanent (Functional Loss)
135
1,263
0.029
Stream
Permanent (No Functional Loss)
33
305
0.007
Stream
Temporary
36
348
0.008
Stream Totals
204
1,916
0.044
Wetland
Permanent
-
7,954
0.183
Wetland Totals
-
7,954
0.183
The proposed total permanent impacts to jurisdictional waters are 0.077 acres (see table below)
Type of Impact
Impact Area
Wetland - Permanent
0.183 ac
Stream - Permanent
0.036 ac (168 If)
Total
0.219 ac
The proposed TC&I Timber Phase I project site is ±346-acres located within five parcels (see
Project Area Parcel/Owner Exhibit and located at 603 Rod Sullivan Road, Sanford, Lee County
(Lat: 35.592316°N;-79.107564°W).
115 MacKenan Drive I Cary, NC 27511
t: 919.469.3340 1 www.withersravenel.com I License No. F-1479
Asheville I Cary I Charlotte I Greensboro I Lumberton I Pittsboro I Raleigh I Southern Pines I Wilmington

TC&I Timber Tract :: WVithersRavenel
Sanford, Lee Co.
NWP 39 PCN Submittal Our People. Your Success -
The project is in the Cape Fear River basin (HUC: 03030004) and onsite waters drain to the
Wombles Creek. The Water Quality Classification for Wombles Creek is: WS;IV and the Stream
Index Number is: 18-2.
Proposed Project
The purpose of the proposed project is to construct a light industrial facility in multiple phases to
meet the existing and growing demand for light industrial space in Lee County. Existing industrial
parks have nearly run out of available lots and this project is intended to create new industrial
space for which there is currently a deficit in Lee County and is in high demand. With entities such
as Toyota and VinFast coming soon to nearby locations, this project will provide much needed
supply chain industries in addition to the expanding life sciences companies in the Sanford/Lee
County area. The proposed project is strategically located adjacent to the Raleigh Executive
Jetport and the CSX rail line and is near US Highway 1.
The portion of the project located south of Stream 1 has been fully designed and engineered. The
lot/building sizes have been designed to meet the logistical needs of known and anticipated users.
The northern portion of the project (north of Stream 1) is conceptual only at this time, as the final
design and grading has not been completed at this point. However, the lot/building sizes are based
on the logistical needs of the anticipated users which must remain confidential at this time. Please
note that while the northern portion of the project is currently conceptual, there has been
sufficient engineering design completed to determine that this portion of the project can been
constructed without impacts to wetlands and streams. The only impacts necessary to construct
the northern portion of the project are the road crossings over Stream 1 and Wetland H to provide
access to this area.
The proposed wetland and stream impacts are necessary for construction of the access road from
Rod Sullivan Road and construction of one industrial building (Building 1).
An access road from Rob Sullivan Road to the northern portion of the site will require one stream
crossing of Stream 1 (perennial) and one impact to Wetland H and will be constructed with a
traditional culvert and riprap dissipator at the stream crossing. The access road will largely be
constructed where a farm road currently exists. The stream crossing for the access road will be
constructed in the location of an existing 18" culvert within the farm road. This road crossing is
necessary to provide access to the developable uplands located north of Stream 1.
One additional permanent wetland impact (W2) is proposed for site grading and construction of
Building 1.
The sewer line between Buildings 1 & 3 will be an aerial crossing over Stream 5 and Wetland D
and will not result in impacts to these features.
There are no proposed impacts for construction of utilities or stormwater treatment (SCMs) and
no impacts are proposed for Phase 2 to the north.
Standard commercial construction equipment and techniques will be used to construct the
proposed project.
Protect History
WithersRavenel conducted a delineation of the wetlands and streams in March 2022.The USACE
issued a Preliminary Jurisdictional Determination (SAW-2022-01249) also on August 10, 2022
Page 2 of 6

TC&I Timber Tract :: WithersRavenel
Sanford, Lee Co.
NWP 39 PCN Submittal Our People. Your Success.
approving the delineation. The USACE PJD and Approved Delineation Exhibit have been provided
as attachments.
SHPO issued a review letter on April 21, 2022 for the southern portion of the project (south of
Stream 1), which has been provided as an attachment. SHPO determined that the project as
proposed within the southern portion of the project will not have any effect on historic structures.
SHPO did however recommend a comprehensive archeological survey be conducted due to
numerous archeological sites having been identified in the immediate vicinity. Terracon conducted
a Phase 1 archeological survey on 119 acres which identified 7 new archeological sites. Terracon
recommended that the newly identified sites should not be considered eligible for listing in the
NRHP and SHPO agreed with Terracon's findings and recommendations in their comment letter
dated 9/9/2022 (see attached).
Terracon conducted an additional archeological survey on the 255-acre northern portion of the
project (north of Stream 1) which identified 12 new archeological sites. Terracon recommended
that the newly identified sites should not be considered eligible for listing in the NRHP and SHPO
agreed with Terracon's findings and recommendations in a December 13, 2022 letter (see
attached). One site, 31LE241, a cemetery, was recommended to preserved through avoidance.
The cemetery has two grave sites and is within the footprint of the "truck loading area" of the
eastern building in the northern portion of the project and therefore must be relocated prior to
construction. Terracon has completed the required procedures for relocation of the gravesites
within the cemetery and they will be properly relocated prior to ground disturbance in this area.
WithersRavenel completed a survey for federally listed species in March 2022 and determined
that the proposed project would have No Effect on federally listed species or their critical habitat.
The results of the survey were submitted to the USFWS for review. In a letter dated September
8, 2022, the USFWS stated that the proposed project is not likely to adversely affect any federally
listed endangered or threatened species, their formally designated critical habitat, or species
currently proposed for listed and that requirements of section 7(a)(2) of the ESA have been
satisfied for this project. The USFWS concurrence letter has been provided as an attachment.
WithersRavenel submitted the Pre -Filing Meeting Request via email on September 15, 2022. A
copy of the request email has been provided as an attachment.
Proposed Impacts
The proposed impacts consist of:
• 0.029 acres (135 If) of permanent functional loss stream impacts
• 0.007 acres (33 If of permanent no functional loss stream impacts
• 0.008 acres (36 If) of temporary stream impacts
• 0.183 acres of permanent wetland impacts
The proposed permanent impacts are necessary for construction of one of the proposed
manufacturing buildings and the access road. The large footprint of the manufacturing buildings
is necessary for the efficient function of a manufacturing facility.
Proposed permanent stream impacts with functional loss total 0.029 ac (135 If) and are necessary
for the installation of the access road crossing over Stream 1 (perennial) at the location of an
existing 18" RCP culvert. The proposed crossing is necessary to access the developable uplands in
the northern portion of the site. The access road has been designed to cross Stream 1
perpendicularly using an 8' x 8' box culvert. The culvert will be buried 12" below the stream bed
Page 3 of 6

TC&I Timber Tract :: WVithersRavenel
Sanford, Lee Co.
NWP 39 PCN Submittal Our People. Your Success-
to allow for aquatic life passage. A riprap dissipator will be installed below the culvert to prevent
erosion and sedimentation of downstream waters which will result in 0.007 ac (33 If) of permanent
stream impacts with no functional loss. The riprap will be installed by burying the riprap such that
the top of the riprap matches the pre -construction contours of the natural stream bed, allowing
for the passage of aquatic life and preventing a loss of function of stream channel.
During construction of the culverted road crossing, work will be completed "in the dry" by
constructing temporary coffer dams upstream and downstream of the culverts within the impact
areas and pumping flow around the construction area. 0.008 ac (36 If) of temporary stream impacts
are proposed for construction of the crossing and dewatering activities.
Permanent wetland impacts to Wetland H are proposed for an impact of the wetland to construct
the access road to access developable uplands in the northern portion of the site. Wetland H is
proposed to be permanently impacted by 0.041 acres of road fill.
Avoidance and Minimization
Prior to site plan design, the applicant requested that a detailed delineation be conducted so that
impacts to wetlands and "waters" could be minimized.
Proposed permanent wetland and stream impacts for construction of the facilities have been
minimized to only those necessary for construction of one road crossing and one wetland impact
to access developable uplands within the site and those required for grading to accommodate
Building 1. The proposed road crossing has been designed to cross Stream 1 perpendicularly to
minimize impacts. The proposed access road will be largely in the location of an existing farm road.
At the site of the stream crossing, an existing 18" RCP will be removed and upgraded along with
the rest of the road. Additionally, headwalls have been designed at the stream crossing to stabilize
road fill and further minimize impacts.
The riprap dissipator below the Stream 1 road crossing will be constructed such that the riprap will
be installed by burying the riprap such that the top of the riprap matches the pre -construction
contours of the natural stream bed, allowing for the passage of aquatic life and preventing a loss
of function of stream channel.
A permanent wetland impact for the access road is unavoidable due to the locations of Pond 3 and
Wetland H. The proposed road is planned to utilize the footprint of the existing farm road to the
greatest extent possible and will impact the upper reach of Wetland H while avoiding impacts to
Pond 3. It is not feasible to shift the road west due to the existing pond dam.
Due to the location of onsite wetlands and large footprint of the manufacturing buildings wetland
and stream impacts are unavoidable. Stream 1 bisects the site in a west -east fashion and therefore
impacts were necessary to provide access to the developable uplands located north of Stream 1.
Additionally, Wetlands H, G, and Stream 5 run south -north. These features along with property
lines and Pond 3 constrain the site. Wetland impacts were minimized to the greatest extent
possible by locating the proposed buildings in such a way to avoid all the aquatic resources except
for a narrow finger of Wetland F that extends to the south. An alternative site design would have
resulted in additional impacts.
There are no impacts proposed for stormwater SCMs or utilities. A proposed aerial sanitary sewer
line was designed to completely avoid stream and wetland impacts.
Page 4 of 6

TC&I Timber Tract :: WithersRavenel
Sanford, Lee Co.
NWP 39 PCN Submittal ❑urPeople.YourSuccess.
Upon completion of construction, all temporarily impacted stream channels will be restored to pre -
construction conditions and grades, and temporarily stabilized with biodegradable matting and
seeded with a riparian seed mix. No matting will be placed on the stream bed.
Access during construction will occur within uplands. Additionally, sediment and erosion control
measures will be installed prior to construction.
Mitigation
Stream Mitigation
The proposed project will result in 0.029 acres (135 If) of permanent stream impacts with
functional loss. Because the proposed total permanent stream impacts with functional loss exceed
0.02 acres, the applicant proposes stream mitigation at a 2:1 ratio. Because stream mitigation
credits were not available in this HUC from mitigation banks, WR has provided the Letter of
Acceptance from NCDMS for 270 If of stream credits.
Wetland Mitigation
The proposed project will result in 0.183 acres of permanent wetland impacts. Because the
proposed total permanent wetland impacts exceed 0.1 acres, the applicant proposes to provide
compensatory mitigation for permanent wetland impacts at a 2:1 ratio. Because wetland mitigation
credits in this HUC were not available from mitigation banks, WR has provided the Letter of
Acceptance from NCDMS for 0.366 ac of riparian wetland credits. Please see attached DMS letter
for stream and wetland mitigation.
Please feel free to call if you have questions or require additional information to complete your
review.
Sincerely,
WithersRavenel
Rick Trone
Environmental Scientist
Attachments:
• PCN Form
• Agent & Access Authorization Forms
• Pre -Filing Meeting Request Email
• Aerial Exhibit
• USGS Quads
• Lee County Soil Survey
• Project Area Parcel/Property Owner Exhibit
• Approved Delineation Exhibit
• USACE Preliminary Jurisdictional Determination
• NCDMS Letter of Acceptance
• USFWS Concurrence Letter
• NCNHP Project Review Letter
Page 5 of 6

TC&I Timber Tract
Sanford, Lee Co.
NWP 39 PCN Submittal
::WikhefsRavenel
Our People. Your Success.
• SHPO Response Letter (4/21/2022)
• SHPO Comment Letter for Southern Portion (9/9/2022)
• SHPO Comment Letter for Northern Portion (12/13/2022)
• Impact Exhibits
Page 6 of 6

■■ WithersRavenel
lipOur People. Your Success.
AGENT& ACCESS
AUTHORIZATION
FORMS

■■ WithersRavenel
'. Our People. Your Success.
AUTHORITY FOR APPOINTMENT OF AGENT
The undersigned contract purchaser, Trinity Capital Advisors (Client) does hereby appoint
WithersRavenel. Inc. as his, her, or it's agent for the purpose of petitioning the appropriate local, state
and federal environmental regulatory agencies (US Army Corps of Engineers, NC Division of Water
Quality, NC Division of Coastal Management, local municipalities, etc.) for: a) review and approval of
the jurisdictional boundaries of onsite jurisdictional areas (wetlands, streams, riparian buffers, etc.)
and/or; b) preparation and submittal of appropriate environmental permit applications/requests for the
following parcels, located in Sanford, NC:
• Lee Co. PIN: 9667-72-1752-00, ±53.0 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9667-50-6965-00, t1.43 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9666-58-4589-00, ±36.63 acres, located at 113 Rod Sullivan Road
• Lee Co. PIN: 9666-69-3230-00, ±46.61 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9666-78-7977-00, ±401.92 acres, located at 603 Rod Sullivan Road
• Lee Co. PIN: 9666-57-0619-00, f1.24 acres, located at 120 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9499-00, t1.30 acres, located at 116 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9279-00, t0.93 acres, located at 108 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9077-00, t0.84 acres, located at 104 Rod Sullivan Road
• Lee Co. PIN: 9666-57-5048-00, t2.64 acres, located near 104 Rod Sullivan Road
The Client does hereby authorize that said agent has the authority to do the following acts on behalf
of the owner:
(1) To submit appropriate requests/applications and the required supplemental
materials;
(2) To attend meetings to give representation on behalf of the Client.
(3) To authorize access to subject property for the purpose of environmental
review by appropriate regulatory agencies.
This authorization shall continue in effect until completion of the contracted task or termination by
the Client.
Agent's Name, Address & Telephone:
Date: 513 f
Signature of Client:
WithersRavenel. Inc. K JonLr,Q LQ
(Name - Prin (Title)
115 MacKenan Drive
Cary. NC 27511 _ ignature)
Tel. [phone] L wO '50 C r1�1 rrh ��
Mailing Address
6\0" ' Io,A, . i� L , a
City State Zip
Phone: 0" t-lL)y-
Email: k}cr, rAoJ r4—_ k-1'r-,i k/Co? )i kIOG' VL cbrs, c.p�
115 MacKenan Drive k Cary. NC 27511
t: 919.469.3340 1 f: 919.467.6008 ( www.withersravenel.com License No. F-1479
Asheville ( Cary E Greensboro I Pittsboro I Raleigh I Wilmington

■10 WithersRavenel
RioOur People. Your Success.
AUTHORIZATION FOR PROPERTY ACCESS
The undersigned owner(s), Stephens Enterprises LLC, do(es) hereby authorize WithersRavenel, Inc. to access
the following parcels below, located in Sanford, NC for the purpose of environmental regulatory agency
review (US Army Corps of Engineers, NC Division of Water Quality, NC Division of Coastal Management,
US Fish and Wildlife Service, local Municipalities, etc.) and approvals (i.e. wetland delineation, stream/buffer
determination, environmental permitting, etc.) at the request of the contract purchaser.
• Lee Co. PIN: 9667-72-1752-00, ±53.0 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9667-50-6965-00, ±1.43 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9666-58-4589-00, ±36.63 acres, located at 113 Rod Sullivan Road
• Lee Co. PIN: 9666-69-3230-00, ±46.61 acres, located near 113 Rod Sullivan Road
• Lee Co. PIN: 9666-78-7977-00, ±401.92 acres, located at 603 Rod Sullivan Road
• Lee Co. PIN: 9666-57-0619-00, ±1.24 acres, located at 120 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9499-00, ±1.30 acres, located at 116 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9279-00, ±0.93 acres, located at 108 Rod Sullivan Road
• Lee Co. PIN: 9666-47-9077-00, ±0.84 acres, located at 104 Rod Sullivan Road
• Lee Co. PIN: 9666-57-5048-00, ±2.64 acres, located near 104 Rod Sullivan Road
This authorization does not bind the current property owner(s) to financial responsibility for services
rendered on the subject property by WithersRavenel, Inc.
This agreement shall continue in effect until completion/termination of the purchase contract for the subject
property.
Date: 3 41 -5- I? azZ
Contract Purchaser's Agent Info:
WithersRavenel, Inc.
115 MacKenan Drive
Cary, NC 27511
Tel. [phone]
Signature of Owner(s):
1 ► 04 a 1 e✓ty-MCrn�IP.�
Name - Print Title
Signature
3 I`) Chap pev4 r 14 5 d �►'.L
Mailing Address
City State Zip
Phone:((
Email: �-C � 5 �re_
115 MacKenan Drive I Cary. NC 27511
t: 919.469.3340) f: 919.467.6008 1 www,withersrovenot.com I License No. F-1479
Asheville I Cary I Greensboro I Pittsboro I Raleigh I Wilmington

::WithersRavenel
Our People. Your Success.
PRE -FILING
MEETING REQUEST
EMAIL

From: Trone, Rick
To: 401PreFile( ncdenr.aov
Subject: Pre -Filing Meeting Request - TC&I Timber (WR#02211428.00)
Date: Thursday, September 15, 2022 10:45:00 AM
On behalf of Trinity Capital Investors, we are requesting a Pre -filing meeting for the following
project:
Project Name: TC&I Timber - Sanford
County: Lee
Applicant Name: Trinity Capital Investors
Applicant Email: [e-mail]
Thank you,
Rick Trone
I Full
115 MacKenan Drive I Cary, NC ''7511
Office:919.469.3340 1 Direct: 919.538.8184
rtroneCEDwithersravenetcom
ININININIo
CONFIDENTIALITY AND NONDISCLOSURE

::WithersRavenel
Our People. Your Success.
AERIAL EXHIBIT

GRAPHIC SCALE
0 300 600
1 inch = 600 R. . -
Ot
c
ro
L a
`` ,,
PROPERTY BOUNDARY
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PROJECT LIMITS
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::WithersRavenel
Our People. Your Success.
USGS QUADS

Ell
it
GRAPHIC SCALE
0 1500 3000
1 inch = 3000 ft.
Arf,A
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Ralei xecutire •1
Jet at Sant°rd•
PROJECT BOUNDARY
'Ji`� )e,,
rw
V r
TC&I TIMBER TRACT USGS QUAD (2019) - MONCURE11 40 WithersRavenel
Planners Surveyors
SANFORD LEE COUNTY NORTH CAROLINA 1/ Engineers

rj
GRAPHIC SCALE
0 500 1000
1 inch = 1000 ft.
j
PROPERTY BOUNDARY
IN
rz ?- --, ) I � \ 1, —, , -
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PROJECT LIMITS
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at, .1S8',nford-
upty'.. Airport
T--
"All
TC&I TIMBER TRACT
D LEE COUNTY NORTH CAROLINA
USGS QUAD (2019) - MONCURE
1!WithersRavenel
Engineers I Planners I Surveyors

::WithersRavenel
Our People. Your Success.
LEE COUNTY SOIL SURVEY

00 0 0O NaD �0° MfB oo GRAPHIC SCALE
NaD00 0 500 1000
MfB It,00 00
' N a B _ - _ 00 d 1 inch = 1000 ft.
1 �
` 00
MfD CrB
00 MfD
' 0 0 0 `, MfB PROPERTY BOUNDARY
,MfB °°
0
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00 00
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TC&I TIMBER TRACT LEE COUNTY SOIL SURVEY (1989) \/ WithersRavenel
1,-N LEE COUNTY NORTI CIROJHNASHEET 3 1/ Engineers I Planners I Surveyors
RD LEE COUNTY NORTH CAROLINA

::WithersRavenel
Our People. Your Success.
PROJECT AREA
PARCEL/PROPERTY OWNER
EXHIBIT

A
Proj a ct Are a - Pa rce l/Owne r lnfonnation
Source: Lee Count GFS- 1/9/2023
Stephens Enterprises, i1C /
Parcels Owned 6y: 319 [hapanoke Rd
Suite 102
Raleigh, NC 27603
y
Parcel Number
Map 10 Oeed9aak/Page Site INN)
1 9666-79-7977-00 1667/1003 603 Rod Sullivan Rd
2 9696 69-3230-00 1667/651 0 Farrel Rd
3 9666-58-4589-00 166W287 113 Rod Sullivan Rd
4 9697-S0-6965-00 1657/651 0 Farrel Rd
5 9667-5O-3289-00 1707/0060 N/A —
. I /
rGRAPHIC SCALE
0 500 1000
III
I /
PROPERTY BOUNDARY
TC&I TIMBER TRACT PROJECT AREA PARCEL/OWNER EXHIBIT No mcnersRavenel
Engineers I Planners I Surveyors
D LEE COUNTY NORTH CAROLINA

■■ WithersRavenel
lipOur People. Your Success.
APPROVED DELINEATION EXHIBIT

NOTES:
GRAPHIC SCALE 1) WETLAND DELINEATION PERFORMED BY WR ON 03/01/2022, 03/02/2022 & 3/29/2022. _
0 300 600 2) WETLAND/STREAM/POND/DITCH LOCATIONS ARE APPROXIMATE, BASED ON GPS LOCATION, LEE COUNTY GIS DATA, AND
TOPOGRAPHIC INTERPRETATION.
3) THE REVIEW AREA IS LOCATED WITHIN THE CAPE FEAR RIVER BASIN. THEREFORE, THE REVIEW AREA IS NOT SUBJECT TO STATE
1 inch = 600 ft. RIPARIAN BUFFERS.
4) THIS PROPERTY MAY BE SUBJECT TO ADDITIONAL MUNICIPALZONING BUFFERS WHICH SHOULD BE VERIFIED PRIOR TO DESIGN.
5) DELINEATION AND JURISDICTIONAL STATUS WAS VERIFIED BY USACE ON 8/10/2022 (SAW-2022-01249).
0J �
WETLANDO �
0J
STREAM 10 - - rro s
PERENNIAL Q
r4 STREAM 6
PERENNIAL
L
WETLAND P � WETLAND R �, 3 W
WETLANDO ooDR,AD �,
STREAM 11 STREAM 10-
- - - REVIEW AREA
INTERMITTENT
PERENNIAL
STREAM 12
PERENNIAL
WETLAND N
STREAM 9
INTERMITTENT
W ETLA N D T p�
.. T
STREAM 8
INTERMITTENT
STREAM 1 ISliTTEMMEN
PERENNIAL
STREAM 2 WETLAND B POND 1INTERMITTENT NON -JURISDICTIONAL TO USSTREAM 3
PERENNIAL
WETLAND C
WETLAND D WETLAND F
POND 2
POTENTIALLY
WETLAND E NON-JURISICTIONALTO
USDACE
STREAM 4 — W
INTERMITTENT
WETLAND G
WETLAND I A �Wl
POND 3
JURISDICTIONAL TO USACE
MAW r-
STREAM 5
INTERMITTENT
STREAM 6
PERENNIAL
WETLAND JF�,
STREAM 1
PERENNIAL
FIRI
-d
Egg

::WithersRavenel
Our People. Your Success.
USACE PRELIMINARY JURISDICTIONAL
DETERMINATION

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id. SAW-2022-01249 County: Lee U.S.G.S. Quad: NC-Moncure
NOTIFICATION OF JURISDICTIONAL DETERMINATION
Requestor: WithersRavenel
Alvssa Ricci
Address: 115 Mackenan Drive
Carv, NC 27511
Telephone Number: 919-215-8619
E-mail: aricci(dwithersravenel.com
Size (acres) 551 Nearest Town Sanford
Nearest Waterway Copper Mine Creek River Basin Cape Fear
USGS HUC 03030004 Coordinates Latitude: 35.5923
Longitude:-79.1075
Location description: The proiect site is approximately 551 acres adiacent to US 1 and bordered to the east by Raleigh
Executive Airport, near the town of Sanford, Lee Countv, North Carolina. The approved portion of this determination onlv
aoolies to Ponds 1 and 2 as shown on the attached delineation sketch map. The approved portion of this determination
includes all other waters on site, as shown on the attached delineation sketch mat).
Indicate Which of the Following Apply:
A. Preliminary Determination
® There appear to be waters, including wetlands on the above described project area/property, that may be subject to Section 404
of the Clean Water Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403). The
waters, including wetlands have been delineated, and the delineation has been verified by the Corps to be sufficiently accurate
and reliable. The approximate boundaries of these waters are shown on the enclosed delineation map dated 6/3/2022. Therefore
this preliminary jurisdiction determination may be used in the permit evaluation process, including determining compensatory
mitigation. For purposes of computation of impacts, compensatory mitigation requirements, and other resource protection
measures, a permit decision made on the basis of a preliminary JD will treat all waters and wetlands that would be affected in any
way by the permitted activity on the site as if they are jurisdictional waters of the U. S. This preliminary determination is not an
appealable action under the Regulatory Program Administrative Appeal Process (Reference 33 CFR Part 331). However, you may
request an approved JD, which is an appealable action, by contacting the Corps district for further instruction.
❑ There appear to be waters, including wetlands on the above described project area/property, that may be subject to Section 404
of the Clean Water Act (CWA)(33 USC § 1344) and/or Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403).
However, since the waters, including wetlands have not been properly delineated, this preliminary jurisdiction determination
may not be used in the permit evaluation process. Without a verified wetland delineation, this preliminary determination is
merely an effective presumption of CWA/RHA jurisdiction over all of the waters, including wetlands at the project area, which
is not sufficiently accurate and reliable to support an enforceable permit decision. We recommend that you have the waters,
including wetlands on your project area/property delineated. As the Corps may not be able to accomplish this wetland
delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that can be verified by the Corps.
B. Approved Determination
❑ There are Navigable Waters of the United States within the above described project area/property subject to the permit
requirements of Section 10 of the Rivers and Harbors Act (RHA) (33 USC § 403) and Section 404 of the Clean Water Act
(CWA)(33 USC § 1344). Unless there is a change in law or our published regulations, this determination may be relied upon for
a period not to exceed five years from the date of this notification.
❑ There are waters, including wetlandson the above described project area/property subject to the permit requirements of Section
404 of the Clean Water Act (CWA) (33 USC § 1344). Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
❑ We recommend you have the waters, including wetlands on your project area/property delineated. As the Corps may not be
able to accomplish this wetland delineation in a timely manner, you may wish to obtain a consultant to conduct a delineation that
can be verified by the Corps.

SAW-2022-01249
❑ The waters, including wetlands on your project area/property have been delineated and the delineation has been verified by
the Corps. The approximate boundaries of these waters are shown on the enclosed delineation map dated DATE. We strongly
suggest you have this delineation surveyed. Upon completion, this survey should be reviewed and verified by the Corps. Once
verified, this survey will provide an accurate depiction of all areas subject to CWA jurisdiction on your property which, provided
there is no change in the law or our published regulations, may be relied upon for a period not to exceed five years.
❑ The waters, including wetlands have been delineated and surveyed and are accurately depicted on the plat signed by the
Corps Regulatory Official identified below onDATE. Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
X❑ There are no waters of the U.S., to include wetlands, present on the above described project area/property (Ponds 1 and 2) which
are subject to the permit requirements of Section 404 of the Clean Water Act (33 USC 1344). Unless there is a change in the law
or our published regulations, this determination may be relied upon for a period not to exceed five years from the date of this
notification.
❑ The property is located in one of the 20 Coastal Counties subject to regulation under the Coastal Area Management Act (CAMA).
You should contact the Division of Coastal Management in Morehead City, NC, at [phone] to determine their
requirements.
Placement of dredged or fill material within waters of the US, including wetlands, without a Department of the Army permit may
constitute a violation of Section 301 of the Clean Water Act (33 USC § 1311). Placement of dredged or fill material, construction or
placement of structures, or work within navigable waters of the United States without a Department of the Army permit may
constitute a violation of Sections 9 and/or 10 of the Rivers and Harbors Act (33 USC § 401 and/or 403). If you have any questions
regarding this determination and/or the Corps regulatory program, please contact James Lastinger at 919-554-4884 ext 32 or
James.C.Lastinger(dusace. armv.mil.
C. Basis For Determination: Basis For Determination: See the preliminary iurisdictional determination
form dated 08/10/2022.
D. Remarks: The approved portion of this determination only applies to Ponds I and 2 as shown on the
attached delineation sketch map. The approved portion of this determination includes all other waters on site,
as shown on the attached delineation sketch map.
E. Attention USDA Program Participants
This delineation/determination has been conducted to identify the limits of Corps' Clean Water Act jurisdiction for the particular site
identified in this request. The delineation/determination may not be valid for the wetland conservation provisions of the Food Security
Act of 1985. If you or your tenant are USDA Program participants, or anticipate participation in USDA programs, you should request
a certified wetland determination from the local office of the Natural Resources Conservation Service, prior to starting work.
F. Appeals Information (This information applies only to approved jurisdictional determinations as indicated in B.
above)
If you object to this determination, you may request an administrative appeal under Corps regulations at 33 CFR Part 331. Enclosed
you will find a Notification of Appeal Process (NAP) fact sheet and Request for Appeal (RFA) form. If you request to appeal this
determination you must submit a completed RFA form to the following address:
US Army Corps of Engineers
South Atlantic Division
Attn: Mr. Philip A. Shannin
Administrative Appeal Review Officer
60 Forsyth Street SW, Floor M9
Atlanta, Georgia 30303-8803
AND
PHIL,IP.A. SHANNIN(&USACE.ARMY.MIL,
In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for appeal
under 33 CFR part 331.5, and that it has been received by the Division Office within 60 days of the date of the NAP. Should you
decide to submit an RFA form, it must be received at the above address by Not applicable.
**It is not necessary to submit an RFA form to the Division Office if you do not object to the determination in this correspondence.

SAW-2022-01249
Corps Regulatory Official:
Date of JD: 08/10/2022 Expiration Date of PJD: Not applicable
Expiration Date of AJD: 08/10/2027
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete our Customer Satisfaction Survey, located online at
https:Hre2ulatoKy.ops.usace.anny.mil/customer-service-survey/.
Copy Furnished:

NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND
REQUEST FOR APPEAL
Applicant: WithersRavenel, Al ssa Ricci File Number: SAW-2022-01249 Date: 08/10/2022
Attached is:
See Section below
INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission)
A
PROFFERED PERMIT (Standard Permit or Letter of permission)
B
PERMIT DENIAL
C
X❑
APPROVED JURISDICTIONAL DETERMINATION
D
X❑
PRELIMINARY JURISDICTIONAL DETERMINATION
E
SECTION I - The following identifies your rights and options regarding an administrative appeal of the above decision.
Additional information may be found at or http://www.usace.annv.mil/Missions/CivilWorks/Res ulatorvPros4ramandPennits.asbx
or the Corps regulations at 33 CFR Part 331.
A: INITIAL PROFFERED PERMIT: You may accept or object to the permit.
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your
signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all
rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the
permit.
• OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request
that the permit be modified accordingly. You must complete Section II of this form and return the form to the district
engineer. Your objections must be received by the district engineer within 60 days of the date of this notice, or you will
forfeit your right to appeal the permit in the future. Upon receipt of your letter, the district engineer will evaluate your
objections and may: (a) modify the permit to address all of your concerns, (b) modify the permit to address some of your
objections, or (c) not modify the permit having determined that the permit should be issued as previously written. After
evaluating your objections, the district engineer will send you a proffered permit for your reconsideration, as indicated in
Section B below.
B: PROFFERED PERMIT: You may accept or appeal the permit
• ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final
authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your
signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all
rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the
permit.
• APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein,
you may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section II of
this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days
of the date of this notice.
C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by
completing Section 11 of this form and sending the form to the division engineer. This form must be received by the division
engineer within 60 days of the date of this notice.
D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide new
information.
• ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the
date of this notice, means that you accept the approved JD in its entirety, and waive all rights to appeal the approved JD.
• APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers
Administrative Appeal Process by completing Section 11 of this form and sending the form to the district engineer. This form
must be received by the division engineer within 60 days of the date of this notice.

E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps regarding the
preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved JD (which may be appealed),
by contacting the Corps district for further instruction. Also you may provide new information for further consideration by the
Corps to reevaluate the JD.
SECTION II - RE T FOR APP L or OBJECTIONS TO AN INITIAL PROFFERED PERMIT
REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial
proffered permit in clear concise statements. You may attach additional information to this form to clarify where your reasons or
objections are addressed in the administrative record.)
ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the
record of the appeal conference or meeting, and any supplemental information that the review officer has determined is needed to
clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record.
However, you may provide additional information to clarify the location of information that is already in the administrative
record.
POINT OF CONTACT FOR QUESTIONS OR INFORMATION:
If you have questions regarding this decision and/or the
If you only have questions regarding the appeal process you may
appeal process you may contact:
also contact:
District Engineer, Wilmington Regulatory Division
MR. PHILIP A. SHANNIN
Attn: James Lastinger
ADMINISTRATIVE APPEAL REVIEW OFFICER
Raleigh Regulatory Office
CESAD-PDS-O
U.S Army Corps of Engineers
60 FORSYTH STREET SOUTHWEST, FLOOR M9
3331 Heritage Trade Drive, Suite 105
ATLANTA, GEORGIA 30303-8803
Wake Forest, North Carolina 27587
PHONE: [phone]; FAX [phone]
EMAIL: PHILIP.A.SHANNIN(&USACE.ARMY.MIL,
RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government
consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15-day
notice of any site investigation, and will have the opportuni to participate in all site investi ations.
Date:
Telephone number:
Signature of appellant or agent.
For appeals on Initial Proffered Permits send this form to:
District Engineer, Wilmington Regulatory Division, Attn: James Lastinger, , 69 Darlington Avenue, Wilmington, North
Carolina 28403
For Permit denials, Proff' 'ered Permits and Approved Jurisdictional Determinations send this form to:
Division Engineer, Commander, U.S. Army Engineer Division, South Atlantic, Attn: Mr. Philip Shannin, Administrative
Appeal Officer, CESAD-PDO, 60 Forsyth Street, Room 1OM15, Atlanta, Georgia 30303-8801
Phone: [phone]

APPROVED JURISDICTIONAL DETERMINATION FORM
U.S. Army Corps of Engineers
This form should be completed by following the instructions provided in Section IV of the JD Form Instructional Guidebook.
SECTION I: BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR APPROVED JURISDICTIONAL DETERMINATION (JD): 08/10/2022
B. DISTRICT OFFICE, FILE NAME, AND NUMBER: Wilmington District, 603 Rod Sullivan Road property, SAW-2022-01249
C. PROJECT LOCATION AND BACKGROUND INFORMATION: The project site is approximately 551 acres adjacent to US 1 and
bordered to the east by Raleigh Executive Airport, near the town of Sanford, Lee County, North Carolina.
State: NC County/parish/borough: Lee City: Sanford
Center coordinates of site (lat/long in degree decimal format): Lat. 35.5923 , Long.-79.1075
Universal Transverse Mercator:
Name of nearest waterbody: Copper Mine Creek
Name of nearest Traditional Navigable Water (TNW) into which the aquatic resource flows:
Name of watershed or Hydrologic Unit Code (HUC): 03030004
® Check if map/diagram of review area and/or potential jurisdictional areas is/are available upon request.
❑ Check if other sites (e.g., offsite mitigation sites, disposal sites, etc...) are associated with this action and are recorded on a different JD form:
D. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY):
® Office (Desk) Determination. Date: August 10, 2022
❑Field Determination. Date(s):
SECTION II: SUMMARY OF FINDINGS
A. RHA SECTION 10 DETERMINATION OF JURISDICTION.
There are no "navigable waters of the U.S." within Rivers and Harbors Act (RHA) jurisdiction (as defined by 33 CFR part 329) in the review area.
[Required]
❑ Waters subject to the ebb and flow of the tide.
❑ Waters are presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce. Explain:
B. CWA SECTION 404 DETERMINATION OF JURISDICTION.
There are "waters of the U.S." within Clean Water Act (CWA) jurisdiction (as defined by 33 CFR part 328) in the review area. [Required]
1. Waters of the U.S.
a. Indicate presence of waters of U.S. in review area (check all that apply):t
❑ TNWs, including territorial seas
❑ Wetlands adjacent to TNWs
❑ Relatively permanent waters' (RPWs) that flow directly or indirectly into TNWs
❑Non-RPWs that flow directly or indirectly into TNWs
❑ Wetlands directly abutting RPWs that flow directly or indirectly into TNWs
❑ Wetlands adjacent to but not directly abutting RPWs that flow directly or indirectly into TNWs
❑ Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs
❑Impoundments of jurisdictional waters
❑ Isolated (interstate or intrastate) waters, including isolated wetlands
b. Identify (estimate) size of waters of the U.S. in the review area:
Non -wetland waters: linear feet, wide, and/or acres.
Wetlands: acres.
c. Limits (boundaries) of jurisdiction based on: Established OHWM
Elevation of established OHWM (if known):
Boxes checked below shall be supported by completing the appropriate sections in Section III below.
For purposes of this form, an RPW is defined as a tributary that is not a TNW and that typically flows year-round or has continuous flow at least "seasonally" (e.g.,
typically 3 months).
Page 1 of 8 Form Version 10 June 2020

2. Non -regulated waters/wetlands (check if applicable):3
©Potentially jurisdictional waters and/or wetlands were assessed within the review area and determined to be not jurisdictional. Explain:
Ponds 1 and 2 are considered non -jurisdictional and are not a Water of the U.S. pursuant to the preamble to the Corps 1986
regulations (33 CFR Parts 320-330). The areas immediately adjacent to Ponds 1 and 2 consists of uplands and ponds 1 and 2
were dug entirely within uplands.
SECTION III: CWA ANALYSIS
A. TNWs AND WETLANDS ADJACENT TO TNWs
The agencies will assert jurisdiction over TNWs and wetlands adjacent to TNWs. If the aquatic resource is a TNW, complete Section
IILA.1 and Section IILD.1. only; if the aquatic resource is a wetland adjacent to a TNW, complete Sections IILA.1 and 2 and Section
IILD.1.; otherwise, see Section IILB below.
1. TNW
Identify TNW:
Summarize rationale supporting determination:
2. Wetlandadjacent to TNW
Summarize rationale supporting conclusion that wetland is "adjacent":
B. CHARACTERISTICS OF TRIBUTARY (THAT IS NOT A TNW) AND ITS ADJACENT WETLANDS (IF ANY):
This section summarizes information regarding characteristics of the tributary and its adjacent wetlands, if any, and it helps determine
whether or not the standards for jurisdiction established under Rapanos have been met.
The agencies will assert jurisdiction over non -navigable tributaries of TNWs where the tributaries are "relatively permanent waters"
(RPWs), i.e. tributaries that typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months). A wetland
that directly abuts an RPW is also jurisdictional. If the aquatic resource is not a TNW, but has year-round (perennial) flow, skip to
Section IILD.2. If the aquatic resource is a wetland directly abutting a tributary with perennial flow, skip to Section IILD.4.
A wetland that is adjacent to but that does not directly abut an RPW requires a significant nexus evaluation. Corps districts and EPA
regions will include in the record any available information that documents the existence of a significant nexus between a relatively
permanent tributary that is not perennial (and its adjacent wetlands if any) and a traditional navigable water, even though a significant
nexus finding is not required as a matter of law.
If the waterbody4 is not an RPW, or a wetland directly abutting an RPW, a JD will require additional data to determine if the
waterbody has a significant nexus with a TNW. If the tributary has adjacent wetlands, the significant nexus evaluation must consider
the tributary in combination with all of its adjacent wetlands. This significant nexus evaluation that combines, for analytical purposes,
the tributary and all of its adjacent wetlands is used whether the review area identified in the JD request is the tributary, or its adjacent
wetlands, or both. If the JD covers a tributary with adjacent wetlands, complete Section IILB.1 for the tributary, Section IILB.2 for any
onsite wetlands, and Section III. B.3 for all wetlands adjacent to that tributary, both onsite and offsite. The determination whether a
significant nexus exists is determined in Section III.0 below.
1. Characteristics of non-TNWs that flow directly or indirectly into TNW
(i) General Area Conditions:
Watershed size: Choose an item.
Drainage area: Choose an item.
Average annual rainfall: inches
Average annual snowfall: inches
(ii) Physical Characteristics:
(a) Relationship with TNW:
❑ Tributary flows directly into TNW.
❑ Tributary flows through Choose an item. tributaries before entering TNW.
Project waters are Choose an item. river miles from TNW.
Project waters are Choose an item. river miles from RPW.
Project waters are Choose an item. aerial (straight) miles from TNW.
s Supporting documentation is presented in Section IILF.
4Note that the Instructional Guidebook contains additional information regarding swales, ditches, washes, and erosional features generally and in the and West.
Page 2 of 8 Form Version 10 June 2020

Project waters are Choose an item. aerial (straight) miles from RPW.
Project waters cross or serve as state boundaries. Explain:
Identify flow route to TNW':
Tributary stream order, if known:
(b) General Tributary Characteristics (check all that apply):
Tributary is: ❑Natural
❑Artificial (man-made). Explain:
❑Manipulated (man -altered). Explain:
Tributary properties with respect to top of bank (estimate):
Average width: feet
Average depth: feet
Average side slopes: Choose an item..
Primary tributary substrate composition (check all that apply):
❑ Silts ❑ Sands ❑ Concrete
❑Cobbles ❑Gravel ❑XMuck
❑Bedrock ❑ Vegetation. Type/% cover:
El Other. Explain:
Tributarycondition/stability [e.g., highly eroding, sloughing banks]. Explain:
Presence of run/riffle/pool complexes. Explain:
Tributary geometry: Choose an item.
Tributary gradient (approximate average slope): %
(c) Flow:
Tributary provides for: Choose an item.
Estimate average number of flow events in review area/year: Choose an item.
Describe flow regime:
Other information on duration and volume:
Surface flow is: Choose an item.. Characteristics:
Subsurface flow: Choose an item.. Explain findings:
❑Dye (or other) test performed:
Tributary has (check all that apply):
❑Bed and banks
❑OHWM'(check all indicators that apply):
El clear, natural line impressed on the bank
❑ changes in the character of soil
❑ shelving
❑ vegetation matted down, bent, or absent
❑ leaf litter disturbed or washed away
❑ sediment deposition
El water staining
El other (list):
❑Discontinuous OHWM.' Explain:
❑the presence of litter and debris
❑ destruction of terrestrial vegetation
❑the presence of wrack line
❑ sediment sorting
❑ scour
❑ multiple observed or predicted flow events
® abrupt change in plant community
If factors other than the OHWM were used to determine lateral extent of CWA jurisdiction (check all that apply):
El High Tide Line indicated by: El Mean High Water Mark indicated by:
'Flow route can be described by identifying, e.g., tributary a, which flows through the review area, to flow into tributary b, which then flows into TNW.
'A natural or man-made discontinuity in the OHWM does not necessarily sever jurisdiction (e.g., where the stream temporarily flows underground, or where the
OHWM has been removed by development or agricultural practices). Where there is a break in the OHWM that is unrelated to the waterbody's flow regime (e.g., flow
over a rock outcrop or through a culvert), the agencies will look for indicators of flow above and below the break.
'Ibid.
Page 3 of 8 Form Version 10 June 2020

❑oil or scum line along shore objects ❑survey to available datum,
❑fine shell or debris deposits (foreshore) ❑physical markings;
❑physical markings/characteristics ❑vegetation lines/changes in vegetation types.
❑tidal gauges
❑other (list):
(iii) Chemical Characteristics:
Characterize tributary (e.g., water color is clear, discolored, oily film; water quality; general watershed characteristics, etc.). Explain:
Identify specific pollutants, if known:
(iv) Biological Characteristics. Channel supports (check all that apply):
❑Riparian corridor. Characteristics (type, average width):
❑ Wetland fringe. Characteristics:
❑Habitat for:
❑Federally Listed species. Explain findings:
❑Fish/spawn areas. Explain findings:
❑Other environmentally -sensitive species. Explain findings:
❑Aquatic/wildlife diversity. Explain findings:
2. Characteristics of wetlands adjacent to non-TNW that flow directly or indirectly into TNW
(i) Physical Characteristics:
(a) General Wetland Characteristics:
Properties:
Wetland size: acres
Wetland type. Explain:
Wetland quality. Explain:
Project wetlands cross or serve as state boundaries. Explain:
(b) General Flow Relationship with Non-TNW:
Flow is: Choose an item. Explain:
Surface flow is: Choose an item.
Characteristics:
Subsurface flow: Choose an item.. Explain findings:
❑Dye (or other) test performed:
(c) Wetland Adjacency Determination with Non-TNW:
El Directly abutting
❑Not directly abutting
❑Discrete wetland hydrologic connection. Explain:
❑Ecological connection. Explain:
❑ Separated by berm/barrier. Explain:
(d) Proximity (Relationship) to TNW
Project wetlands are Choose an item. river miles from TNW.
Project waters are Choose an item. aerial (straight) miles from TNW.
Flow is from: Choose an item..
Estimate approximate location of wetland as within the Choose an item. floodplain.
(ii) Chemical Characteristics:
Characterize wetland system (e.g., water color is clear, brown, oil film on surface, water quality; general watershed characteristics,
etc.). Explain:
Identify specific pollutants, if known:
(iii) Biological Characteristics. Wetland supports (check all that apply):
❑Riparian buffer. Characteristics (type, average width):
Page 4 of 8 Form Version 10 June 2020

❑ Vegetation type/percent cover. Explain:
❑Habitat for:
❑Federally Listed species. Explain findings:
❑Fish/spawn areas. Explain findings:
❑Other environmentally -sensitive species. Explain findings:
❑Aquatic/wildlife diversity. Explain findings:
3. Characteristics of all wetlands adjacent to the tributary (if any)
All wetland(s) being considered in the cumulative analysis: Choose an item.
Approximately acres in total are being considered in the cumulative analysis.
For each wetland, specify the following:
Directly abuts? (Y/N) Size (in acres) Directly abuts? (Y/N) Size (in acres)
Summarize overall biological, chemical and physical functions being performed:
C. SIGNIFICANT NEXUS DETERMINATION
A significant nexus analysis will assess the flow characteristics and functions of the tributary itself and the functions performed by any
wetlands adjacent to the tributary to determine if they significantly affect the chemical, physical, and biological integrity of a TNW.
For each of the following situations, a significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has more
than a speculative or insubstantial effect on the chemical, physical and/or biological integrity of a TNW. Considerations when
evaluating significant nexus include, but are not limited to the volume, duration, and frequency of the flow of water in the tributary and
its proximity to a TNW, and the functions performed by the tributary and all its adjacent wetlands. It is not appropriate to determine
significant nexus based solely on any specific threshold of distance (e.g. between a tributary and its adjacent wetland or between a
tributary and the TNW). Similarly, the fact an adjacent wetland lies within or outside of a floodplain is not solely determinative of
significant nexus.
Draw connections between the features documented and the effects on the TNW, as identified in the Rapanos Guidance and discussed in
the Instructional Guidebook. Factors to consider include, for example:
• Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to carry pollutants or flood waters to TNWs, or to
reduce the amount of pollutants or flood waters reaching a TNW?
• Does the tributary, in combination with its adjacent wetlands (if any), provide habitat and lifecycle support functions for fish and other
species, such as feeding, nesting, spawning, or rearing young for species that are present in the TNW?
• Does the tributary, in combination with its adjacent wetlands (if any), have the capacity to transfer nutrients and organic carbon that
support downstream food webs?
• Does the tributary, in combination with its adjacent wetlands (if any), have other relationships to the physical, chemical, or biological
integrity of the TNW?
Note: the above list of considerations is not inclusive and other functions observed or known to occur should be documented below:
1. Significant nexus findings for non-RPW that has no adjacent wetlands and flows directly or indirectly into TNWs. Explain findings
of presence or absence of significant nexus below, based on the tributary itself, then go to Section ITI.D:
2. Significant nexus findings for non-RPW and its adjacent wetlands, where the non-RPW flows directly or indirectly into TNWs.
Explain findings of presence or absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands,
then go to Section ITI.D:
3. Significant nexus findings for wetlands adjacent to an RPW but that do not directly abut the RPW. Explain findings of presence or
absence of significant nexus below, based on the tributary in combination with all of its adjacent wetlands, then go to Section TILD:
D. DETERMINATIONS OF JURISDICTIONAL FINDINGS. THE SUBJECT WATERS/WETLANDS ARE (CHECK ALL THAT
APPLY):
1. TNWs and Adjacent Wetlands. Check all that apply and provide size estimates in review area:
❑ TNWs: linear feet, wide, Or acres.
❑Wetlands adjacent to TNWs: acres.
Page 5 of 8 Form Version 10 June 2020

2. RPWs that flow directly or indirectly into TNWs.
❑ Tributaries of TNWs where tributaries typically flow year-round are jurisdictional. Provide data and rationale indicating that tributary is
perennial:
❑Tributaries of TNW where tributaries have continuous flow "seasonally" (e.g., typically three months each year)are jurisdictional. Data
supporting this conclusion is provided at Section IILB. Provide rationale indicating that tributary flows seasonally:
Provide estimates for jurisdictional waters in the review area (check all that apply):
❑ Tributary waters: linear feet wide.
El Other non -wetland waters: acres.
Identify type(s) of waters:
3. Non-RPWss that flow directly or indirectly into TNWs.
❑ Waterbody that is not a TNW or an RPW, but flows directly or indirectly into a TNW, and it has a significant nexus with a TNW is
jurisdictional. Data supporting this conclusion is provided at Section III.C.
Provide estimates for jurisdictional waters within the review area (check all that apply):
❑ Tributary waters: linear feet, wide.
❑Other non -wetland waters: acres.
Identify type(s) of waters:
4. Wetlands directly abutting an RPW that flow directly or indirectly into TNWs.
❑Wetlands directly abut RPW and thus are jurisdictional as adjacent wetlands.
❑ Wetlands directly abutting an RPW where tributaries typically flow year-round. Provide data and rationale indicating that tributary
is perennial in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW:
❑ Wetlands directly abutting an RPW where tributaries typically flow "seasonally." Provide data indicating that tributary is seasonal
in Section IILB and rationale in Section III.D.2, above. Provide rationale indicating that wetland is directly abutting an RPW:
Provide acreage estimates for jurisdictional wetlands in the review area: acres.
5. Wetlands adjacent to but not directly abutting an RPW that flow directly or indirectly into TNWs.
❑ Wetlands that do not directly abut an RPW, but when considered in combination with the tributary to which they are adjacent and with
similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisidictional. Data supporting this conclusion is
provided at Section III.C.
Provide acreage estimates for jurisdictional wetlands in the review area: acres.
6. Wetlands adjacent to non-RPWs that flow directly or indirectly into TNWs.
❑ Wetlands adjacent to such waters, and have when considered in combination with the tributary to which they are adjacent and with
similarly situated adjacent wetlands, have a significant nexus with a TNW are jurisdictional. Data supporting this conclusion is
provided at Section IILC.
Provide estimates for jurisdictional wetlands in the review area: acres.
Impoundments of jurisdictional waters.9
As a general rule, the impoundment of a jurisdictional tributary remains jurisdictional.
El Demonstrate that impoundment was created from "waters of the U.S.," or
❑Demonstrate that water meets the criteria for one of the categories presented above (1-6), or
❑Demonstrate that water is isolated with a nexus to commerce (see E below).
E. ISOLATED [INTERSTATE OR INTRA-STATE] WATERS, INCLUDING ISOLATED WETLANDS, THE USE, DEGRADATION
OR DESTRUCTION OF WHICH COULD AFFECT INTERSTATE COMMERCE, INCLUDING ANY SUCH WATERS (CHECK
ALL THAT APPLY):10
'See Footnote # 3.
'To complete the analysis refer to the key in Section IILD.6 of the Instructional Guidebook.
10Prior to asserting or declining CWA jurisdiction based solely on this category, Corps Districts will elevate the action to Corps and EPA HQ for review
consistent with the process described in the Corps/EPA Memorandum Regarding CWA Act Jurisdiction Following Rapanos.
Page 6 of 8 Form Version 10 June 2020

❑which are or could be used by interstate or foreign travelers for recreational or other purposes.
❑from which fish or shellfish are or could be taken and sold in interstate or foreign commerce.
❑which are or could be used for industrial purposes by industries in interstate commerce.
❑Interstate isolated waters. Explain:
❑Other factors. Explain:
Identify water body and summarize rationale supporting determination:
Provide estimates for jurisdictional waters in the review area (check all that apply):
❑ Tributary waters: linear feet, wide.
El Other non -wetland waters: acres.
Identify type(s) of waters:
❑ Wetlands: acres.
NON -JURISDICTIONAL WATERS, INCLUDING WETLANDS (CHECK ALL THAT APPLY):
El If potential wetlands were assessed within the review area, these areas did not meet the criteria in the 1987 Corps of Engineers Wetland
Delineation Manual and/or appropriate Regional Supplements.
❑Review area included isolated waters with no substantial nexus to interstate (or foreign) commerce.
❑Prior to the Jan 2001 Supreme Court decision in "SWANCC," the review area would have been regulated based solely on the "Migratory
Bird Rule" (MBR).
❑ Waters do not meet the "Significant Nexus" standard, where such a finding is required for jurisdiction. Explain:
®Other: (explain, if not covered above): Ponds 1 and 2 are considered non -jurisdictional and are not a Water of the U.S. pursuant to the
preamble to the Corps 1986 regulations (33 CFR Parts 320-330). The areas immediately adjacent to Ponds 1 and 2 consists of
uplands and ponds 1 and 2 were dug entirely within uplands.
Provide acreage estimates for non -jurisdictional waters in the review area, where the sole potential basis of jurisdiction is the MBR factors (i.e.,
presence of migratory birds, presence of endangered species, use of water for irrigated agriculture), using best professional judgment (check all
that apply):
❑Non -wetland waters (i.e., rivers, streams):linear feet, wide.
®Lakes/ponds: 0.5 acres.
El Other non -wetland waters: acres. List type of aquatic resource:
❑ Wetlands: acres.
Provide acreage estimates for non -jurisdictional waters in the review area that do not meet the '`Significant Nexus" standard, where such a
finding is required for jurisdiction (check all that apply):
❑Non -wetland waters (i.e., rivers, streams):linear feet, wide.
❑Lakes/ponds: acres.
❑ Other non -wetland waters: acres. List type of aquatic resource:
❑ Wetlands: acres.
SECTION IV: DATA SOURCES.
A. SUPPORTING DATA. Data reviewed for JD (check all that apply - checked items shall be included in case file and, where checked and
requested, appropriately reference sources below):
® Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant: attached dated June 6, 2022
® Data sheets prepared/submitted by or on behalf of the applicant/consultant.
©Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report.
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study:
® U.S. Geological Survey Hydrologic Atlas:
®USGS NHD data.
❑USGS 8 and 12 digit HUC maps.
® U.S. Geological Survey map(s). Cite scale & quad name: Moncure Quad
Page 7 of 8 Form Version 10 June 2020

USDA Natural Resources Conservation Service Soil Survey. Citation: Lee County, 1989, sheet 3
National wetlands inventory map(s). Cite name: USFWS NWI mapper
State/Local wetland inventory map(s):
FEMA/FIRM maps: NC FIRM
100-year Floodplain Elevation is: (National Geodectic Vertical Datum of 1929)
Photographs: ©Aerial (Name & Date): NC One Map 2017 aerial
Or ❑ Other (Name & Date):
Previous determination(s). File no. and date of response letter:
Applicable/supporting case law:
Applicable/supporting scientific literature:
Other information (please specify):
B. ADDITIONAL COMMENTS TO SUPPORT JD:
Page 8 of 8 Form Version 10 June 2020

PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PJD: 08/ 10/2022
B. NAME AND ADDRESS OF PERSON REQUESTING PJD: WithersRavenel, Alyssa Ricci, 115
Mackenan Drive, Cary, NC 27511
C. DISTRICT OFFICE, FILE NAME, AND NUMBER: Wilmington District, 603 Rod Sullivan Road
property, SAW-2022-01249
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION: The project site is approximately
551 acres adjacent to US 1 and bordered to the east by Raleigh Executive Airport, near the town of Sanford,
Lee County, North Carolina.
(USE THE TABLE BELOW TO DOCUMENT MULTIPLE AQUATIC RESOURCES
AND/OR AQUATIC RESOURCES AT DIFFERENT SITES)
State: NC County: Lee City: Sanford
Center coordinates of site (lat/long in degree decimal format): Latitude: 35.5923 Longitude:-79.1075
Universal Transverse Mercator:
Name of nearest waterbody: Copper Mine Creek
E. REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY):
© Office (Desk) Determination. Date: August 10, 2022
❑Field Determination. Date(s):
TABLE OF AQUATIC RESOURCES INREVIEW AREA WHICH "MAY BE" SUBJECT TO
REGULATORY JURISDICTION
Site Number
Latitude
(decimal
degrees)
Longitude
(decimal degrees)
Estimated
amount of
aquatic
resources in
review area
(acreage and
linear feet, if
applicable
Type of aquatic
resources (i.e.,
wetland vs.
non -wetland
waters)
Geographic authority to
which the aquatic resource
"may be" subject (i.e.,
Section 404 or Section
10/404)
Wetland A
35.57924467
-79.11033321
0.5 acre
wetland
Section 404
Wetland B
35.58909568
-79.11593114
0.077 acre
wetland
Section 404
Wetland C
35.58891872
-79.11563052
0.05 acre
wetland
Section 404
Wetland D
35.58859652
-79.11589237
0.047 acre
wetland
Section 404
Wetland E
35.58797210
-79.11590041
0.21 acre
wetland
Section 404
Wetland F
35.58480577
-79.11127928
13.34 acre
wetland
Section 404
Wetland G
35.58566342
-79.11521572
0.57 acre
wetland
Section 404
Wetland H
35.58447636
-79.11612761
0.26 acre
wetland
Section 404
Wetland 1
35.58435732
-79.11789513
0.03 acre
wetland
Section 404
Wetland J
35.59013659
-79.10460990
35.41 acre
wetland
Section 404
Wetland K
35.59152226
-79.11133468
0.75 acre
wetland
Section 404
Wetland L
35.59408126
-79.11145424
0.57 acre
wetland
Section 404
Wetland M
35.59336360
-79.11469875
0.22 acre
wetland
Section 404
Wetland N
35.59649734
-79.11277773
0.082 acre
wetland
Section 404
Wetland O
35.59799562
-79.11455184
0.05 acre
wetland
Section 404
Wetland P
35.59879441
-79.11421771
0.15 acre
wetland
Section 404

Wetland Q
35.59991629
-79.11328077
0.18 acre
wetland
Section 404
Wetland R
35.59901507
-79.10848057
0.68 acre
wetland
Section 404
Wetland T
35.59566776
-79.10203102
0.54 acre
wetland
Section 404
Stream 1
35.58480577
-79.11127928
7,557 LF
Non -wetland
Section 404
Stream 2
35.58842825
-79.11816493
129 LF
Non -wetland
Section 404
Stream 3
35.58862377
-79.11721518
835 LF
Non -wetland
Section 404
Stream 4
35.58566342
-79.11521572
688 LF
Non -wetland
Section 404
Stream 5
35.58356982
-79.11317524
1,136 LF
Non -wetland
Section 404
Stream 6
35.59013659
-79.10460990
5,580 LF
Non -wetland
Section 404
Stream 7
35.59194891
-79.11027996
1,115 LF
Non -wetland
Section 404
Stream 8
35.59408126
-79.11145424
964 LF
Non -wetland
Section 404
Stream 9
35.59649734
-79.11277773
335 LF
Non -wetland
Section 404
Stream 10
35.59879441
-79.11421771
375 LF
Non -wetland
Section 404
Stream 11
35.59799562
-79.11455184
132 LF
Non -wetland
Section 404
Stream 12
35.59566776
-79.10203102
604 LF
Non -wetland
Section 404
Pond 3
35.58441160
-79.11777748
0.45 acre
Non -wetland
Section 404
1. The Corps of Engineers believes that there may be jurisdictional aquatic resources in the
review area, and the requestor of this PJD is hereby advised of his or her option to request
and obtain an approved 7D (AID) for that review area based on an informed decision after
having discussed the various types of 7Ds and their characteristics and circumstances when
they may be appropriate.
2. In any circumstance where a permit applicant obtains an individual permit, or a Nationwide
General Permit (NWP) or other general permit verification requiring "pre- construction
notification" (PCN), or requests verification for a non -reporting NWP or other general
permit, and the permit applicant has not requested an AID for the activity, the permit
applicant is hereby made aware that: (1) the permit applicant has elected to seek a permit
authorization based on a PJD, which does not make an official determination of
jurisdictional aquatic resources; (2) the applicant has the option to request an AID before
accepting the terms and conditions of the permit authorization, and that basing a permit
authorization on an AID could possibly result in less compensatory mitigation being
required or different special conditions; (3) the applicant has the right to request an
individual permit rather than accepting the terms and conditions of the NWP or other

general permit authorization; (4) the applicant can accept a permit authorization and
thereby agree to comply with all the terms and conditions of that permit, including
whatever mitigation requirements the Corps has determined to be necessary; (5)
undertaking any activity in reliance upon the subject permit authorization without
requesting an AID constitutes the applicant's acceptance of the use of the PJD; (6)
accepting a permit authorization (e.g., signing a proffered individual permit) or undertaking
any activity in reliance on any form of Corps permit authorization based on a PJD
constitutes agreement that all aquatic resources in the review area affected in any way by
that activity will be treated as jurisdictional, and waives any challenge to such jurisdiction
in any administrative or judicial compliance or enforcement action, or in any administrative
appeal or in any Federal court; and (7) whether the applicant elects to use either an AID or
a PJD, the JD will be processed as soon as practicable. Further, an AID, a proffered
individual permit (and all terms and conditions contained therein), or individual permit
denial can be administratively appealed pursuant to 33 C.F.R. Part 331. If, during an
administrative appeal, it becomes appropriate to make an official determination whether
geographic jurisdiction exists over aquatic resources in the review area, or to provide an
official delineation of jurisdictional aquatic resources in the review area, the Corps will
provide an AID to accomplish that result, as soon as is practicable. This PJD finds that
there "may be"waters of the U.S. and/or that there "may be" navigable waters of the U.S.
on the subj ect review area, and identifies all aquatic features in the review area that could
be affected by the proposed activity, based on the following information:
SUPPORTING DATA. Data reviewed for PJD (check all that apply) Checked items are included in the administrative
record and are appropriately cited:
❑X Maps, plans, plots or plat submitted by or on behalf of the PJD requestor:
Map: attached dated June 6, 2022
❑X Data sheets prepared/submitted by or on behalf of the PJD requestor. Datasheets:
® Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report. Rationale:
❑ Data sheets prepared by the Corps:
❑Corps navigable waters' study:
❑XU.S. Geological Survey Hydrologic Atlas:
®USGS NHD data:
❑USGS 8 and 12 digit HUC maps:
© U.S. Geological Survey map(s). Cite scale & quad name: Moncure Quad
®Natural Resources Conservation Service Soil Survey. Citation: Lee County, 1989, sheet 3
® National wetlands inventory map(s). Cite name: USFWS NWI mapper
❑ State/local wetland inventory map(s):
® FENLVFIRM maps: NC FIRM

❑ 100-year Floodplain Elevation is: (National Geodetic Vertical Datum of 1929)
® Photographs: ® Aerial (Name & Date): NC One Map 2017 aerial
or ❑ Other (Name & Date):
❑ Previous determination(s). File no. and date of response letter:
❑ Other information (please specify) :
IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corns
and should not be relied upon for later imisdictional determinations.
cvrn.co �✓
Signature and date of Regulatory
staff member completing PJD
08/10/2022
Signature and date of person requesting PJD
(REQUIRED, unless obtaining the signature is
impracticable)'
1 Districts may establish timeframes for requester to return signed PJD forms. If the requester does not respond within the established
time frame, the district may presume concurrence and no additional follow up is necessary prior to finalizing an action.

WETLAND H-ENTH/� �—
WETLAND I / - CULVERT \--
TERILVYETETHE U, �/� STREAM 1
r / STREAM 5 a,FNnIL �a�-wETLANI
POND 3 ITE-AL—ETLAW IT
.ATERI IF THE Ul IAERI E IFTHUl `llL/
�o
O WETLAND A c
POTENTIAL WETL AND �V
WATERS OF THE Its

■■ WithersRavenel
lipOur People. Your Success.
NCDMS LETTER OF
ACCEPTANCE

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
MARC RECKTENWALD
Director
Travis Caldwell
Trinity Capital Investors
440 S. Church Street, Suite 800
Charlotte, NC 28202
Project: TC&I Timber - PH 1
NORTH CAROLINA
Environmental Quality
November 10, 2022
Expiration of Acceptance: 5/10/2023
County: Lee
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-di it HUC
Impact Type
Credits
Cape Fear
03030004
Non -Riparian Wetland
0.366
Cape Fear
03030004
Warm Stream
270
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.
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].
Sincerely, / ,J ,
t �tl �t�
FOR James. B Stanfill
Deputy Director
cc: Rick Trone, agent
North Carolina Department of Environmental Quality I Division of Mitigation Services
217 West Jones Street 1 1652 Mail Service Center I Raleigh, North Carolina 27699-1652
h(h�TH :.AROI iRA IV
o �nmmmenni w�a 919,707,8976

NO WithersRavenel
lip
Our People. Your Success.
USFWS CONCURRENCE
LETTER

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
September 8, 2022
Alyssa Ricci
WithersRavenel
115 MacKenan Drive
Cary, NC 27511
Re: TC&I Tracts — Lee County
Dear Mrs. Ricci:
This letter is to inform you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in determining whether a
federally -listed species or designated critical habitat may be affected by a proposed project. For
future projects, please visit the Raleigh Field Office's project planning website at
https://www.fws.Rov/office/eastern-north-carolina/proiect-planning-and-consultation. If you are
only searching for a list of species that may be present in the project's Action Area, then you
may use the Service's Information, Planning, and Consultation System (IPaC) website to
determine if any listed, proposed, or candidate species may be present in the Action Area and
generate a species list. The IPaC website may be viewed at https://ipac.ecosphere.fws.gov/.
The IPaC web site contains a complete and frequently updated list of all endangered and
threatened species protected by the provisions of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531 et seq.)(Act), a list of federal species of concern' that are known to
occur in each county in North Carolina, and other resources.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, ensure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
federally -listed endangered or threatened species. A biological assessment or evaluation may be
prepared to fulfill that requirement and in determining whether additional consultation with the
Service is necessary. In addition to the federally -protected species list, information on the
species' life histories and habitats and information on completing a biological assessment or
'The term "federal speciesof concern" refers to those specieswhich the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

evaluation and can be found on our web page at https://fws.gov/office/eastern-north-carolina.
Please check the web site often for updated information or changes.
If your project contains suitable habitat for any of the federally -listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally -protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
With regard to the above -referenced project, we offer the following remarks. Ourcomments are
submitted pursuant to, and in accordance with, provisions of the Endangered Species Act.
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely affect any federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)(2) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation must be
reconsidered if: (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered; (2) this action is
subsequently modified in a manner that was not considered in this review; or, (3) a new species
is listed or critical habitat determined that may be affected by the identified action.
However, the Service is concerned about the potential impacts the proposed action might have
on aquatic species. Aquatic resources are highly susceptible to sedimentation. Therefore, we
recommend that all practicable measures be taken to avoid adverse impacts to aquatic species,
including implementing directional boring methods and stringent sediment and erosion control
measures. An erosion and sedimentation control plan should be submitted to and approved by
the North Carolina Division of Land Resources, Land Quality Section prior to construction.
Erosion and sedimentation controls should be installed and maintained between the construction
site and any nearby down -gradient surface waters. In addition, we recommend maintaining
natural, vegetated buffers on all streams and creeks adjacent to the project site.
The North Carolina Wildlife Resources Commission (NCWRC) has developed a Guidance
Memorandum (found at https://www.ncwildlife.org/Conserving/Learn-Resources/Ways-to-
Conserve) to address and mitigate secondary and cumulative impacts to aquatic and terrestrial

wildlife resources and water quality. We recommend that you consider this document and the
NCWRC's other conservation recommendations in the development of your projects and in
completing an initiation package for consultation (if necessary).
We hope you find our web page useful and informative and that following the process described
above will reduce the time required, and eliminate the need, for general correspondence for
species' lists. If you have any questions or comments, please contact John Ellis of this office at
[phone] ext. 26.
Sincerely,
Pete Benjamin
Field Supervisor

::WithersRavenel
Our People. Your Success.
NCNHP PROJECT REVIEW LETTER

Roy Cooper, Governor
9" 0 INC DEPARTMENT OF
""i ■
WMk.M 1 NATURAL AND CULTURAL RESOURCES
■-000
January 10, 2023
Troy Beasley
Withers & Ravenel
115 MacKenan Drive
Cary, NC 27511
RE: TC&I Timber Tract; 02211428.01
Dear Troy Beasley:
13. Reid Wilson, Secretary
Misty Buchanan
Deputy Director, Natural Heritage Program
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database indicates that
there are no records for rare species, important natural communities, natural areas, and/or
conservation/managed areas within the proposed project boundary. Please note that although there
may be no documentation of natural heritage elements within the project boundary, it does not
imply or confirm their absence; the area may not have been surveyed. The results of this query
should not be substituted for field surveys where suitable habitat exists. In the event that rare
species are found within the project area, please contact the NCNHP so that we may update our
records.
The attached `Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one -mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one -mile
radius of the project area, if any, are also included in this report.
If a Federally -listed species is found within the project area or is indicated within a one -mile radius of
the project area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS) for
guidance. Contact information for USFWS offices in North Carolina is found here:
httr)s://www.fws.gov/offices/Directory/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a
Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund easement, or Federally -
listed species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rod ney.butler�ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPARTMENT OF NATURAL AND CULTURAL RESOURCES
121 1N. JON S STREET, RALEIGI I_ NC 27603 - 16Sl MAOL SERVICE CENTER. PAL EIGH. rkc 276�0
OFC 919.707.9120 • FAK 919.707.9421

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::WithersRavenel
Our People. Your Success.
SH PO RESPONSE LETTER
4/21/2022

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
April 21, 2022
Alyssa Ricci
WithersRavenel
115 MacKenan Drive
Cary, NC 27511
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
aricci(a,withersravenel.com
Re: Construct industrial development, 603 Rod Sullivan Road, Sanford, Lee County, ER 22-0924
Dear Ms. Ricci:
Thank you for your letter dated March 14, 2022, concerning the above -referenced project. We have
reviewed the information provided and offer the following comments.
We have determined that the project as proposed will not have an effect on historic structures.
While no archaeological resources have been previously recorded within the project area, the project area
includes landforms and soils adjacent to tributaries associated with Wombles Creek that have a high
probability for archaeological sites. Numerous archaeological sites have been identified in the immediate
vicinity including sites determined eligible for inclusion on the National Register of Historic Places
(NRHP). Based on the topographic and hydrological setting, we expect the project area may contain intact,
significant archaeological sites.
Prior to the initiation of any ground disturbing activities within the project area, we recommend that a
comprehensive archaeological survey be conducted by an experienced archaeologist. The purpose of this
survey will be to identify any archaeological sites that may be damaged or destroyed by the proposed
project and make recommendations regarding their eligibility status in terms of the National Register of
Historic Places. Potential effects on unknown resources must be assessed prior to the initiation of
construction activities. This work should be conducted by an experienced archaeologist that meets the
Secretary of the Interior professional qualifications standards. A list of archaeological consultants who have
conducted or expressed an interest in contract work in North Carolina is available at
https://archaeology.ncdcr.gov/programs/environmental-review/archaeological-consultant-list.
Please note that our office requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate field methodologies prior to the archaeological field investigation.
One paper copy and one digital copy (PDF) of all resulting archaeological reports, as well as a digital copy
(PDF) of the North Carolina site form for each site recorded, should be forwarded to the Office of State
Archaeology (OSA) through this office for review and comment as soon as they are available and in
advance of any construction or ground disturbance activities. OSA's Archaeological Standards and
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 22-0924, April 21, Page 2 of 2
Guidelines for Background Research, Field Methodologies, Technical Reports, and Curation can be found
online at: https://archaeology.ncdcr.gov/osa-guidelines.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579
or environmental.reviewkncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
(1� aouLtwlt�
Ramona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

■■ WithersRavenel
lipOur People. Your Success.
SHPO COMMENT LETTER
FOR SOUTHERN PORTION
9/9/2022

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
September 9, 2022
Melissa McKay
Terracon Consultants, Inc.
2401 Brentwood Rd 9107
Raleigh, NC 27604
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Melissa.mckav(c�r�,terracon.com
Re: Phase I Archaeological survey for industrial development, 603 Rod Sullivan Road, Sanford, Lee
County, ER 22-0924
Ms. McKay:
Thank you for your submittal of July 11, 2022, transmitting the draft of the above -referenced report. We
have reviewed the information provided and offer the following comments.
Terracon Consultants, Inc. (Terracon) conducted a Phase I archaeological survey on approximately 119
acres. As part of these investigations, Terracon identified seven (7) new archaeological sites (31LE225-
231).
Terracon recommends that all newly identified sites should be considered not eligible for listing in the
National Register of Historic Places (NRHP). We concur with Terracon's findings and recommendations.
We accept the report as final.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
please contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.review(a�ncdcr.gov. In all future communication concerning this project, please cite the
above -referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
(� State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

■■ WithersRavenel
lipOur People. Your Success.
SHPO COMMENT LETTER
FOR NORTHERN PORTION
12/13/2022

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
December 13, 2022
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Melissa McKay [e-mail]
Terracon Consultants, Inc.
2401 Brentwood Road, Suite 107
Raleigh, North Carolina 27604
Re: Phase I Archaeological survey for industrial development- TC&I Timber Phase II, 603 Rod Sullivan Road, Sanford,
Lee County, ER 22-0924
Dear Ms. McKay:
Thank you for your submittal of October 19, 2022, transmitting the draft of the above -referenced report. We have reviewed the
information provided and offer the following comments.
Terracon Consultants, Inc. (Terracon) conducted a Phase I archaeological survey on approximately 255 acres. As part of these
investigations, Terracon identified 12 new archaeological sites (3 1 LE233-244).
Terracon recommends that all newly identified sites should be considered not eligible for listing in the National Register of
Historic Places (NRHP). Terracon further recommends that the cemetery associated with 31LE241, although not eligible for the
NRHP, should be preserved in place and avoided.
We concur with Terracon's findings and recommendations. We accept the report as final. We recommend that site 31 LE241 be
preserved through avoidance and that an avoidance plan be submitted prior to construction. As part of the avoidance plan, we
recommend the cemetery boundary be mapped by a licensed surveyor, recorded on deeds or plats, and filed with Lee County. If
the cemetery cannot be avoided, we recommend that a mitigation plan be developed in consultation with our office.
Please note that cemeteries are protected under North Carolina General Statutes Chapter 14-148 and 14-149 and are afforded
consideration under NCGS Chapters 65 and 70.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on
Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment, contact Renee
Gledhill -Earley, environmental review coordinator, at 919-814-6579 or environmental.review(&,,ncdcr.gov. In all future
communication concerning this project, please cite the above referenced tracking number.
Sincerely,
CRa=onaBartos, De u
p tY
V State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

Legend
Q Project Area
Sources: Project Area based
Meters on information provided by the
0 125 250 500 Client; USA Topo Maps
Drwn: MM
Topographic Map
FIGURE
ChkProject
TR
rerraco ra
TC&I Timber Tracts: Phase II
1.2
roeNo.:
j
70227278
2401 Brentwood Road, Suite 107 Raleigh, NC 27604
Lee County, North Carolina
Date:
October 2022
Phone: [phone] Fax: [phone]

::WithersRavenel
Our People. Your Success.
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