20230446 Ver 1_02 NWPs Cover Letter (Apex Coke)_20230323

LAS
NVIRONVIENTAL
22 March 2023
US Army Corps of Engineers
Raleigh Regulatory Field Office
Attn: Chris Hopper
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
NC Division of Water Resources
401 and Buffer Permitting Unit
Attn: Paul Wojoski
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Mills Chatham Development Group LLC +/- 55.122 Acres
Apex Coke
102 NC Highway 751
Apex, North Carolina 27523
Nationwide Permits 18 and 39
Action ID: SAW-2022-01050 (may be appropriate to issue a new number)
NC DWR #: 2022-1496 (may be appropriate to issue a new number)
Dear Chris and Paul:
Atlas Environmental, Inc., on behalf of Mills Chatham Development Group LLC (Applicant;
Attn: Hagar Rand), is submitting the following information and request for approval of
Nationwide Permits 18 and 39 for unavoidable impacts to wetlands and waters of the
United States from the proposed Apex Coke industrial development.
Project Location
The proposed project site is located at 102 NC Highway 751, Apex, North Carolina, 27523.
The review area includes one parcel (Parcel ID Numbers 17900), totaling approximately
55.122 acres in Chatham County, North Carolina. The general project location is in the
Northeastern quadrant of the intersection of US Highway 64 and NC Highway 751,
approximately 7 driving miles East of the city center of the City of Apex, North Carolina
(Appendix A — Resource Maps).
Project Applicant/Developer
Mills Chatham Development Group LLC, doing business as Durham Coca-Cola Bottling
Company, opened in 1905 in a small building on Corcoran Street, in Durham, North
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
Carolina. The facility employed four people, and included bottling equipment that
consisted of a foot powered filling machine, a wooden tub and brush arrangement for the
washing of bottles, a liquid carbonator, a couple of barrels of syrup and a few cases of
bottles. Delivery equipment consisted of one lame horse and a broken wagon, which were
kept at a stable behind the building. Over the years, the company grew and expanded its
operations, moving to new facilities on Parrish Street in 1911, then to Church Street in
1920, and then to W. Main Street at Buchanan Boulevard in 1930.
In the late 1950s, Durham Coca-Cola Bottling Company expanded its product line, and
then its territory through the purchase of the Roxboro Coca-Cola Bottling Company. By
1961, they had once again outgrown their facilities, so a new, modern facility located on
Hillsborough Road went into operation. From 1961 through 1981 the company conducted
four major expansions growing the plant from 44,000 square feet to 100,000 square feet.
In 2017, Durham Coca-Cola expanded once again with the acquisition of Sanford Coca-
Cola. Durham Coca-Cola Bottling Company is combining their facilities from Durham and
Sanford and expanding them into this new proposed facility, and is partnering with Beacon
Partners as a development consultant for the construction of their facilities.
Beacon Partners is a full -service commercial real estate firm focused on the development,
acquisition, lease, and management of quality industrial, office, and mixed -use properties,
and have invested more than $2.4 billion dollars in real estate projects throughout North
and South Carolina. Their portfolio currently includes more than 30.4 million square feet of
developed or acquired real estate, with approximately 14.5 million square feet currently
leased, owned, or managed.
Project Purpose
The purpose of the proposed project is to construct an executive offices and state-of-the-
art bottling facility that will feature enhanced sustainable building specifications. The
facility, developed in partnership with Beacon Partners, will serve the greater Raleigh,
Durham, Roxboro, Henderson, and Sanford markets, and combine bottling facilities from
Durham and Sanford. Ideally, the project site would be near major transportation corridors
with easy ingress and egress of the corridors and the project site. Proximity to major
transportation corridors help ensure greater capability of the road system handling
increased volume of traffic without major roadway improvements or changes. The
principal challenge for Durham Coca-Cola Bottling Company is the availability of utility
infrastructure given their stringent service requirements.
The proposed project will include multiple buildings of sufficient size (totaling more than
300,000 square feet) to meet the project purpose, including the addition of more than
20,000 square feet of executive offices. Typically, a larger building takes advantage of
economies of scale which drastically saves on marginal cost; the per square foot cost of a
larger building in many instances is much less than smaller buildings of the same total
size. Consultants and engineers also can focus on the larger building as a single project
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
rather than multiple projects, saving time and decreasing labor cost. Larger constructed
buildings typically have less overall impact on -site, reduces impervious cover, and requires
less landscape and hardscape when compared to the same square footage under multiple
buildings. Lastly, larger buildings often attract tenants with more established businesses
and credit, thereby reducing the chance of default on a tenant lease. However, multiple
building facilities may be necessary when the site or location has constraints to
construction or when the demands of businesses are better suited for multiple buildings
and associated infrastructure. Regardless of site configuration or constraints, the size of
the building is often maximized to plan for current and future growth opportunities. The
parcel also must be of ample size to properly support the accompanying parking,
stormwater control measures, utilities, and other associated infrastructure components.
Project Marketing and Need
The proposed project location in Chatham County, at the Wake -Chatham County line, near
the City of Apex, the Raleigh -Durham International Airport, NC Highway 540/1-540, US
Highway 64, and NC Highway 751 providing convenient access to 1-40, was carefully
selected based on the project purpose, development opportunities, and available utilities.
The proposed project site was driven by Durham Coca-Cola Bottling Company's
distribution requirements across the Triangle region and combining existing distribution
facilities in Durham and Sanford at a central location. Durham Coca-Cola Bottling
Company originally evaluated more than eight potential project sites across Durham,
Wake, Chatham, and Orange Counties for a new facility, however their distribution
consultants eventually identified Chatham County, and specifically West Apex, as their
targeted submarket. A principal challenge in identifying a suitable site was the availability
of utility infrastructure given the Coca-Cola Company's stringent service requirements.
After more than nine months of coordination with the Chatham County and Apex Economic
Development Teams, the proposed project location emerged as the only viable site.
Beacon Partners has worked closely as a development consultant with Durham Coca-Cola
Bottling Company to develop the proposed project site.
Property History
Aerial photographs can provide excellent documentation of property history and land uses
over time. A reliable timeline of activity and development of the property can be
established when certain imagery/photographs are available. A review of available
historical aerial imagery indicates that the proposed project site has been predominantly
forested with some agricultural fields and a few residences since the early 1980s.
Project History
The US Army Corps of the Engineers (USACE) conducted a site visit to the proposed
project location on February 21, 2023. As a result of the site visit, Atlas Environmental has
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
identified six streams and five wetland areas that are considered jurisdictional waters by
the USACE.
Proposed Project
Mills Chatham Development Group LLC, doing business as Durham Coca-Cola Bottling
Company, proposes development of approximately 55.122 acres off Highway 751 for a
new headquarters, bottling, and distribution facility. The area of development for this NWP
18 and 39 request will include the construction of two buildings, 259,130 square feet and
79,500 square feet, respectively, ingress and egress roadways, parking, stormwater
control measures, and other associated infrastructure.
The Town of Apex recently annexed the proposed project location and secured water,
sewer, and electric service at the site. This required extensive coordination and approval
from Chatham County, Town of Cary, and Town of Apex, as several regional pump
stations and public water main distribution lines were designed, permitted, and installed to
service development in this area. The total public infrastructure requirements for the
proposed site are more than $15 million, and include three regional pumpstations, public
road(s) construction, and an additional 25-acres of NCDOT right-of-way dedication for
future NC-751 and US-64 overpass intersection improvements. A new roadway, Gateway
Drive, will be constructed off NC Highway 751 to allow access to the Durham Coca-Cola
Bottling Company's facilities, and will be dedicated as public right-of-way to the Town of
Apex. Lastly, a substantial area (approximately 11.5 acres) including streams and
wetlands along the Eastern property boundary, have been set aside as stream buffer, a
tree save area, and greenspace.
Project Site Evaluation
As stated above, the distribution consultants for Durham Coca-Cola Bottling Company had
already identified Chatham County and the general West Apex area as their targeted
submarket and the perfect location to combine and expand Durham Coca-Cola Bottling
Company's facilities.
The proposed project site is adjacent to US Highway 64 and NC Highway 751, which
provide easy access to 1-540 and 1-40, and has existing utility infrastructure and service
that satisfies the stringent needs of the Durham Coca-Cola Bottling Company. The
proposed project site also is in a Federal Opportunity Zone (37037020600).
Wetlands and Waters of the United States and Impacts
On November 16-17, 2021 Atlas Environmental conducted an initial pedestrian survey of
the project site to identify streams and wetlands which may be subject to Federal and
State regulations. An additional site visit was conducted on February 21, 2023. The site
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
visit identified approximately 2862 linear feet of stream channel in six streams and 0.988
acres of wetlands in five wetland areas (Appendix B — Aquatic Resources Sketch Maps).
Table 1. List of aquatic resources within the proposed project area.
Name
Type
Linear Feet
Acres
CH 100
Stream
1696
0.109
CH 200
Stream
210
0.009
CH 300
Stream
192
0.010
CH 400
Stream
248
0.010
CH 500
Stream
120
0.005
CH 600
Stream
396
0.017
WL 1000
Wetland
0.737
WL 1100
Wetland
0.013
WL 1200
Wetland
0.002
WL 1300
Wetland
0.093
WL 4000
Wetland
0.143
TOTAL
2862
0.988 (WL only)
A proposed site development plan for the project site is attached, including potential
impacts to wetlands (Appendix C — Proposed Site Plan and Associated Wetland Impacts).
The following information about associated impacts is based on the development plan for
the proposed project site.
Permanent impacts to waters from the proposed project plan include impacts to a portion
of one stream and two of the identified wetland areas. A list of unavoidable impacts to
aquatic resources from the proposed project is provided in Table 2.
Table 2. List of proposed impacts under Nationwide permit 18 and 39.
Aquatic
Resource
Type
Perm / Temp
Impacts
AC
Impacts
LF
NWP
Reason for Impact
CH 400
Stream
Permanent
0.005
134
18
Discharge of fill material
WL 1300
Wetland
Permanent
0.040
39
NCDOT improvements
WL 4000
Wetland
Permanent
0.143
39
Discharge of fill material
TOTAL
0.188
134
Potential Effects on Physical/Chemical Characteristics of the Aquatic Ecosystem
Substrate: No effects are expected beyond the proposed impact areas. Substrate will be
permanently affected at the impact areas. Downstream sediment will remain in -place.
Erosion control and stormwater practices will prevent upland material from impacting the
substrate.
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
Suspended particulates/turbidity: No effects are expected beyond the proposed impact
areas. Suspended particulates and turbidity are not expected to affect any streams on or
off property. Short-term, minor effects to total suspended solids (TSS) and turbidity are
expected during construction. Proposed "off-line" stormwater detention facilities will
protect the remaining wetlands and streams on property and downstream of the project
site through detention and water quality treatment of storm flows before being discharged
into jurisdictional waters. The proposed stormwater management system has been
designed to provide water quality treatment of a 1-inch rainfall event and achieve greater
than 85% reduction in post -development TSS loadings to receiving waters. These controls
will prevent the discharge of sediment and other attached pollutants (excess nutrients, oil
and grease, etc.) to downstream waters.
Water: Minor permanent effects are expected. The flow path of surficial water will
continue to move from the property toward White Oak Creek.
Current patterns and water circulation: Minor permanent effects are expected. The flow
path of stormwater will be slightly different due to the development. Interception and
infiltration will differ due to the impervious surfaces. Infiltration will still occur in the areas
of the stormwater treatment basins and along the diffuse flow outflow of the basins to the
non -impacted reaches.
Normal water fluctuations: Seasonal water fluctuations of precipitation will not be affected.
Ground water fluctuations may have minor/inconsequential permanent impacts due to the
surficial ground conditions resulting in altered hydrogeology from impervious surfaces and
grading of the building pads. Any actual effects would be quantitatively unmeasurable.
Salinity gradients: No effects to salinity are expected. The project is not located in a
coastal area where a salinity gradient and/or a saltwater intrusion wedge could be present.
Impacts relating to the application of salt for snow/ice control would be negligible as the
average annual snowfall for the project area is less than four inches per year.
Potential Effects on Biological Characteristics of the Aquatic Ecosystem
Threatened or endangered species: No adverse effect is expected. Additional information
on the presence of Federally listed species or potential suitable habitat for species is
provided below in the Endangered and Threatened Species section.
Fish, crustaceans, mollusks, and other aquatic organisms in food web: No adverse effect
is expected. The aquatic systems impacted by the proposed project are small first order
streams or adjacent wetlands that are small and have been degraded. The largest natural
aquatic systems within the project site will not be impacted.
Other wildlife: Minor permanent habitat loss due to the construction of the buildings is
expected. Effects are considered minor due to the degrading or impounding of the aquatic
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
systems on the property that are proposed for impact, which has created marginal quality
habitat for most aquatic species.
Potential Effects on Special Aquatic Sites
Sanctuaries and refuges: No effects are expected. The project site does not include
sanctuaries or refuges and is not upstream of these types of locations.
Wetland: Permanent impacts to streams and wetlands are described above in Table 2.
Mud flats: No effect is expected because no mud flats exist on the project site.
Vegetated shallows: No effect is expected because no vegetated shallows exist on the
project site.
Coral reefs: No effect is expected because no coral reefs exist on the project site.
Riffle and pool complexes: No effect is expected because no riffle and pool complexes
exist within any of the aquatic resources proposed for impact.
Endangered and Threatened Species
Atlas Environmental referenced the US Fish and Wildlife Service (USFWS) Information for
Planning and Consultation (IPaC) tool for the project review area on April 14, 2022. Atlas
Environmental also referenced the North Carolina Natural Heritage Program website (on
April 11, 2022) for additional information on Endangered and Threatened Species that may
occur in the project area. The corresponding reports indicated the potential presence of
four Federally listed Endangered or Threatened species within the project review area.
Designated Critical Habitat was not listed within the project review area. Atlas
Environmental also conducted on -site assessments on November 16-17 and 23, 2021,
and February 21, 2023, but Federally listed Endangered or Threatened species or their
habitats were not observed. Adverse impacts to Federally listed Endangered and
Threatened species are not expected. An Endangered, Threatened, and Candidate
Species Report of Findings is included in Appendix D. The report was submitted to the
USFWS on June 8, 2022, and their concurrence was provided on July 14, 2022.
Table 3. Summary of effects determinations for Federally listed species.
Species
Listed
Status
Habitat
Present
Species
Observed
Effects Determination
Red -cockaded Woodpecker
E
No
No
No Effect
Monarch Butterfly
C
--
--
N/A
Atlantic Pi toe
T
No
No
No Effect
Har erella
E
No
No
No Effect
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
Historic and Cultural Resources
A search of the National Register of Historic Places did not identify any cultural resources
located within the proposed project review area. However, Atlas Environmental conducted
a pedestrian survey for the presence of important cultural and historical resources on the
proposed project site. The transects that were visibly inspected during the pedestrian site
evaluation would not allow for identification of any potential subterranean artifacts. No
shovel tests were conducted to identify potential cultural or archaeological resources that
may be located within the proposed project area. Atlas Environmental received a written
response from the North Carolina Department of Natural and Cultural Resources, dated
July 12, 2022. Based on their review of the project, they are "aware of no historic
resources which would be affected by the project." (Appendix E — NC Department of
Natural and Cultural Resources Letter).
Avoidance and Minimization: On -Site Alternatives
Due to the nature of this business, storage, parking, and docking facilities are extremely
valuable and having more of both is beneficial. The building placement and overall size
and the amount of parking spaces have been designed for the preferred site plan to avoid
higher quality resources and to minimize impacts to streams and wetlands. Furthermore,
the building placement and project layout has been designed to comply with public
infrastructure requirements, including the construction and dedication of public roads to the
Town of Apex, an additional 25-acres of NCDOT right-of-way dedication for future NC-751
and US-64 overpass intersection improvements, and an additional 11.5 acres of tree save
and greenspace buffer. When taking development requirements and restrictions into
account, such as building design needs, local zoning (e.g., setbacks, buffers, stormwater,
and landscaping), parking, internal site access, ingress and egress corridors, and docking,
we concluded that impacts to aquatic resources could not be avoided. However,
avoidance and minimization of impacts could be achieved by the sizing and placement of
the buildings, parking, and corridors within the project review area.
The proposed project has been designed to avoid impacts to the greatest extent possible.
The building size, placement, and floor elevation were designed to avoid all perennial
streams and most wetlands. The buildings and associated infrastructure are being sized
to the minimum spatial extents to accomplish the project purpose and need (reference
Appendix C). The design of the stormwater control measure will prevent potential impacts
associated with sediment and erosion control and is positioned to avoid higher quality
perennial streams. The current proposed location for the stormwater control measure is
the only remaining sufficient space to satisfy the stormwater control without impacting
more or higher quality aquatic resources. Furthermore, the placement of the stormwater
control measure is the only location of sufficient size to avoid impacting the dedicated
stream buffer and tree save area.
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONVIENTAL
Permanent impacts by the proposed project include a portion of an intermittent stream (CH
400) and two wetland areas (WL 1300 and WL 4000). No impacts are proposed to any
perennial stream, and cumulative stream impacts will affect less than 5% of all streams on
property. All of stream channels CH 100, CH 2O0, CH 300, CH 500, and CH 600, and
wetland areas WL 1000, WL 1100, and WL 1200 are being avoided. Cumulative wetland
impacts amount to slightly more than 17% of the total wetlands on property. The largest
wetland impact (WL 1300; 0.143 acres) is located approximately 142 feet from the next
nearest aquatic resource. Permanent impacts associated with the preferred project
proposal total approximately 134 linear feet of stream and 0.183 acres of wetlands.
Mitigation
Compensatory mitigation is required for the above listed permanent impacts in the form of
in -lieu fee mitigation at a 2.1 ratio. Total permanent impacts to aquatic resources for the
project are 0.183 acres of wetlands. Stream impacts do not require mitigation because
impacts (i.e., 0.005 acres) are less than the 0.02 acres threshold of the Nationwide Permit.
Based on the 2.1 ratio, permanent impacts require 0.366 acres of wetland mitigation.
The applicant proposes purchasing the 0.366 wetland credits through a private mitigation
bank. A Statement of Availability letter is included in Appendix F. The mitigation required
for impacts to aquatic resources is listed in Table 4.
Table 4. Summary of impacts and mitigation based on credit calculation.
Name
Type Measure Amount AC
Required Wetland Credits
WL 1300
Wetland Acre 0.040
0.056
WL 4000
Wetland Acre 0.143
0.286
TOTAL
0.183
0.366
In addition to mitigation, the applicant will include buffers around all remaining aquatic
resources within the tree save area as additional avoidance and minimization measures.
Buffer enhancement includes natural or planted buffers. Buffer width varies depending on
distance from limit of disturbance or property boundary to the aquatic resources.
Nevertheless, the buffer area will include the entirety of the tree save area and totals
approximately 11.5 acres in size. Buffer areas will be plainly marked before, during, and
after any construction activities to ensure that no encroachment occurs.
Stormwater Treatment
All stormwater treatment will meet or exceed the stormwater management requirements
for Chatham County and the North Carolina Department of Environmental Quality
(NCDEQ). Stormwater management plans will be prepared in accordance with a
stormwater drainage masterplan to be prepared by a professional engineering firm
licensed by the State of North Carolina prior to the development. The stormwater drainage
masterplan will address the hydrological characteristics of the entire site, as well as
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

LAS
NVIRONMENTAL
adjacent drainage patterns of relative importance. The plan will address predevelopment
conditions and post -development stormwater management for flood control and sediment
reduction. This plan will also address stormwater quality to enhance water quality and
protect the surrounding freshwater wetlands.
Stormwater control measures with the proposed project are designed to avoid or minimize
impacts to higher quality aquatic resources and avoid the buffer and tree save area. The
proposed stormwater control measure also is at a natural low point for the project site and
in the best location to collect the most impervious area runoff as well as other disturbed
areas in the development so that it can detain and treat stormwater as required.
Alternative designs for stormwater control measures are not feasible on this site. Low
Impact Development practices are not always practical for industrial developments
because the amount of impervious surface area is typically more concentrated than
comparably sized impervious surfaces for residential or commercial developments.
Similarly, underground stormwater control measures may not be suitable on sites with
shallow bedrock. The proposed site has exposed bedrock in a stream channel suggesting
a shallow bedrock. Nevertheless, the stormwater control measure design within an
industrial development can include components to mimic the natural processes of retaining
rainwater. The proposed project will include grass and treed islands within the parking lots
that will retain rainwater and allow a natural soak into the ground.
Additional Public Interest Factors
Construction operations of the proposed project are planned for five days a week, weather
permitting, and will largely be conducted during normal business hours (e.g., 7.00 am to
5.00 pm). Operations of the proposed project site are not expected to be routinely outside
of normal business hours. A vegetated buffer will be established along the Eastern
property boundary and a natural buffer will be established between the future Town of
Apex public road and the project site. Traffic from the proposed project will be routed
along the future Gateway Drive (a future Town of Apex public road) to NC Highway 751.
Turn lanes to access the facility along NC Highway 751 may be required by NCDOT, but
additional road improvements are not anticipated. Additional public interest factors are
summarized in Table 5 with commentary below.
Table 5. Public Interest Factors.
Q
Factor
c
°'
E
a�
Q
a'
a
Z c�
o u
Z
Z
L
0
a
0
Z
m
a
Conservation
X
Economics
X
Aesthetics
X
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte 10

LAS
NVIRONMENTAL
General Environmental Concerns
X
Wetlands
X
Historic Properties
X
Fish and Wildlife Values
X
Flood Hazards
X
Flood lain Values
X
Land Use
X
Navigation
X
Shoreline Erosion and Accretion
X
Recreation
X
Water Supply and Conservation
X
Water Quality
X
Energy Needs
X
Safety
X
Food and Fiber Production
X
Mineral Needs
X
Consideration of Property Ownership
X
Needs and Welfare of the People
X
Conservation: Negligible — Implementation of the proposed activity would impact upon the
ecological integrity of a wetland, floodplain, and aquatic and wildlife resources, as
described above. The proposed project would change the area that supports some variety
of species to one that would support less or a different diversity. The aquatic and upland
environments proposed for impact are largely surrounded by forested areas and residential
homesites with increasing industrial and commercial development. The nearby White Oak
Creek and its associated wetland function will continue to provide connected and buffered
habitats for aquatic and terrestrial wildlife and help maintain the ecological integrity of
White Oak Creek and Jordan Lake. Impacts to aquatic habitats also will be mitigated to
offset any negative impacts. Endangered, Threatened, or rare species or Designated
Critical Habitats are not expected to be adversely affected by the proposed project. In
summary, the proposed project will have negligible impacts on conservation and the
overall ecology of the project area.
Economics: Beneficial — The applicant, contractor, equipment supplier, and other
commercial enterprises would benefit from the proposed project by increasing earnings
from activities associated with construction of the proposed project and operation of the
facilities when completed. The consumer also will benefit from the proposed project by
receiving goods more quickly because the Durham Coca-Cola Bottling Company is
combining facilities and service areas with the proposed project facilities. The neighbors'
property values would be unaffected by the proposed project but could increase if the
property becomes more valuable by changing zoning status. Increased use of the area
could benefit local businesses. Local workers could benefit from the creation of new job
opportunities associated with both construction and operations of the proposed project.
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte 11

LAS
NVIRONVIENTAL
Lastly, the proximity to transportation corridors means a cost savings to deliver goods. In
summary, the proposed project would have a major, long-term, positive effect on local
econom ics.
Aesthetics: Neutral — The public's view of the proposed project will be no different to views
of similar structures in the vicinity of the proposed project and along US Highway 64. The
neighboring landowners will have a vegetative buffer screen established between their
properties and the proposed project property. The proposed project will likely be visible
from NC Highway 751, and may be visible from US Highway 64. Vegetated buffers and
the possible use of planted berms will screen the development to help maintain the
compositional harmony or unity or diversity of the area as viewed by the public. The net
impact of the transformation associated with the construction and/or operation of the
proposed project will depend solely on individual taste. In summary, the effects of the
proposed project on aesthetics will be neutral and dependent on personal preference.
General Environmental Concerns: Negligible — General environmental concerns from the
proposed project are expected to be negligible. Impacts to air quality, ambient noise, and
light are expected from construction and operation of the proposed project. But these
impacts are expected to be like construction or warehouse operations impacts already
occurring in the area. By concentrating similar businesses additional general
environmental impacts area minimized overall. Introducing these impacts into more rural
areas or areas nearer to alternative land uses (e.g., residential, agricultural, or
recreational) may have a greater impact simply because those types of impacts are
different than impacts associated with the alternative land uses.
Wetlands: Beneficial — No additional impacts to wetlands or streams are expected beyond
those presented above. Areas of wetlands and streams that will be impacted from the
proposed project will be mitigated off -site. The overall impact to wetlands is expected to
be beneficial because wetlands will be mitigated off -site but within the same hydrologic
area at an amount greater than that impacted. The integrity of White Oak Creek and its
associated wetlands will be maintained and will continue to provide wetland function.
Historic Properties: None — No historic properties are located on the proposed project site
and none in the vicinity of the proposed project area expected to be affected.
Fish and Wildlife Values: Beneficial — The proposed project area is a forested upland with
a riparian system along the East side of the property. Wildlife species have been observed
using the proposed project area. Impacts to these species, as well as aquatic species on -
site (as addressed above), are expected to be negligible. A substantial vegetated area will
remain as a tree save area, especially along the riparian corridor system, following
construction of the proposed project. Maintaining the connection of this riparian corridor
will continue to provide habitat for wildlife species and have an overall beneficial effect.
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte 12

LAS
NVIRONVIENTAL
Flood Hazards: Neutral — The proposed project aquatic impact areas are first order
streams and adjacent wetlands. The proposed project intends to maintain water flow and
wetland habitats within the riparian corridor on -site and downstream of the property,
thereby reducing the potential for flood hazards. Potential flood hazards following
construction of the proposed project are not expected to be different from current
conditions.
Floodplain Values: Negligible — Impacts to the primary floodplain are avoided in the
preferred project plan. The impacts from the proposed project to the floodplain value is
expected to be negligible during construction and operation of the facility.
Land Use: Negligible — The proposed project effects on land use are negligible. The land
use will change from a forested residential tract to an industrial development. However, a
forested area and riparian system will remain, especially along the perimeter of the
property and riparian corridor leading toward White Oak Creek. While the project
proposes conversion from forested land to developed land, the property is within a planned
area for warehouse and industrial facilities. Furthermore, utilizing the property for
industrial facilities provides benefits to land use given its proximity to transportation
corridors, rather than other types of development (e.g., residential development).
Navigation: Not applicable. No impacts would be expected.
Shoreline Erosion and Accretion: Not applicable. No impacts would be expected.
Recreation: Not applicable. No impacts would be expected.
Water Supply and Conservation: Negligible — The proposed project is not expected to
have any effect on the water supply and conservation. Additional water use may be
required during project construction and operation, but the use would be negligible when
compared to existing use in the project area.
Water Quality: Neutral — The proposed project is not expected to have positive or negative
effects on water quality. The expected impacts from the proposed project on streams on
the property are of lower quality. Minimal wetlands impacts are associated with the
proposed project. The large riparian system will remain intact and will continue to provide
benefits for water quality. Stormwater management associated with the proposed project
will be constructed in a manner to avoid any water quality impacts. The proposed project
is not expected to have any other impact to water quality.
Energy Needs: Not applicable. No impacts would be expected.
Safety: Negligible — No unsafe conditions would be created or increased by the proposed
construction or operation of the proposed project. However, construction and operational
activities come with inherent conditions that create safety concerns. These concerns are
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte 13

LAS
NVIRONMENTAL
different, but not appreciably greater or fewer than the concerns of the proposed project.
No short-term or long-term, negative impacts are expected from the proposed project.
Food and Fiber Production
Not applicable. No impacts would be expected.
Mineral Needs: Not applicable. No impacts would be expected.
Consideration of Property Ownership: Beneficial — The applicant has a right to reasonable
private use of the property, subject to the rights and interests of the public in the waters of
the United States, including federal navigation servitude and federal regulation for
environmental protections. The proposed project will have benefits to the applicant's right
to property ownership. In summary, the proposed project would have a major, long-term,
positive impact for the property owner.
Needs and Welfare of the People: Beneficial — The proposed project would benefit
consumers and job seekers. Consumers would receive goods more quickly with expanded
and combined facilities in the target submarket. Jobs also would be created during
construction of the proposed project and operations of the finished facilities. People
looking for employment would benefit from the jobs created. In summary, the proposed
project would create major short-term and long-term, positive impact on the needs and
welfare of the people.
Enclosed are the necessary permit application documents and additional information.
Thank you for your attention to the enclosed request. Please contact me if you need any
additional information.
Best regards,
j& W 4e " d/& kz VV "
Jennifer L Robertson, President
[e-mail]
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411 Charlotte, North Carolina 28211; 704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte 14