20221576 Ver 1_USACE More Info Requested_20230726 (2)

From:
Bailey, David E CIV USARMY CESAW (USA)
To:
Hartshorn. Jason; anh.nouvenCalvinfastauto.com; Teague. Jeff L
Cc:
Mellor, Colin; Homewood, Sue; Bowers, Todd; Jason Steele
Subject:
[External] Request for Additional Information: Vinfast electric vehicle (EV) manufacturing complex and associated
infrastructure (Project Blue, NCDOT HE-0006, City of Sanford Utilities); SAW-2014-00610
Date:
Wednesday, July 26, 2023 10:39:56 AM
Attachments:
Corns Comments - Sanford TIP Water and Sewer Impacts 23 0710.xlsx
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Please reference your Individual Permit application for Department of the Army (DA) authorization
to permanently discharge dredged or fill material into a total of 3,688 linear feet of stream channel,
22.789 acres of wetlands, and 1.0 acre of open water impoundments, and to temporarily discharge
dredged or fill material into a total of 4,095 linear feet of stream channel and 14.292 acres of
wetlands, associated with developing an electric vehicle (EV) manufacturing complex and associated
infrastructure in Chatham County, North Carolina. Please also reference the U.S. Army Corps of
Engineers, Wilmington District (Corps) public notice for this project dated November 21, 2022, and
letter containing agency and public comments and requesting additional information dated January
27, 2023, your response letter dated March 10, 2023, and the Corps' subsequent request for
additional information dated April 21, 2023. Following receipt of your response letters dated May 19
and June 1, 2023, as well as subsequent plan revisions received July 15, 18, and 20, 2023, additional
items are required to be resolved prior to continuing to process your permit request:
Project Blue
1. Add the Corps approved delineation to Alternative 4 overall plan to enable full evaluation of
potential indirect impacts related to grading/drainage on the site. Please also show grading
limits, stormwater controls and other proposed infrastructure that would ensure that existing
aquatic resources maintain their hydroperiod;
2. The conceptual Phase 3 plan building layout does not appear to match the detail plan for
Crossings 4 and 5. Direct impacts appear likely to Wetland W113, and indirect impacts appear
likely to the remainder of Wetland W112 and Stream 123 based on conceptual Phase 3 plan
where a building appears to cut off or re-route hydrology away from this drainage.
3. Impact Site 4: given the small remnant of wetland proposed to remain downstream of the rip
rap pad, the Corps would consider this wetland remnant as additional permanent wetland
loss for this crossing.
4. Thank you for the Archeological Survey Report you provided for Phases 1B, 2, and 3 f Project
Blue. Given that the proposed project activities occur in areas that contain archeological
resources, consultation may need to be initiated with the State Historic Preservation Office.
The Corps is currently reviewing this project in this context to determine any responsibilities
pertaining to Section 106 of the National Historic Preservation Act (NHPA). If required, please
note that NCSHPO may require up to 30 days to respond to our coordination request. Please
note that Corps authorizations cannot preclude completion of Section 106 of the NHPA.
H E-0006

1. In the response to the Corps request for additional information, received by our office via
email on 3/10/2023, a map was provided entitled "STIP HE-0006" "Figure 513: Prior Concepts
Map" and Tables 1 and 2 were provided showing the alternative routes evaluated for HE-
0006. Please update and provide those items to include the expanded study area referenced
and shown in the NCDOT supplemental PJD request package submitted to our office on
4/27/2023.
2. Phase 1B Plans:
a. Site 1: the "triangle" of temporary wetland impacts bound by the permanent
mechanized clearing and fill wetland impacts should also be considered permanent, as
this small remnant wetland area would not retain existing wetland function following
construction;
b. Site 2:
i. Please provide a cross-section view of the inlet and outlet of the
proposed double box culvert that clearly shows if both boxes would be the
low flow structure, or whether one would be set or silled higher than the
other to create a low- and high -flow box. Please also provide a detail of the
proposed floodplain bench, including how these areas would be stabilized
and revegetated following construction.
ii. Wetland WM appears to be wide enough such that at -grade flood plain
culverts are warranted to maintain hydrologic flow across the larger wetland
area.
c. Site 4: project plans reference "Existing Channel w/6' Bench See Detail AF." Please
provide this detail for review.
d. Site 5: Wetland WJ would be segmented into smaller sections as currently proposed,
including what would become a disjunct area within a gore area surrounded by an
access ramp. How would this wetland area maintain its current function as proposed?
Unless otherwise justified, this wetland portion appears to be an indirect impact of the
proposed project, suitable for compensatory mitigation at a 1:1 ratio.
e. Sites 7 and 9: the plans appear to show rip rap on either side of the banks of Streams
SBD and SBB. Please ensure that, if rip rap is proposed to be placed below the Ordinary
High Water Mark (OHWM) of the channel, that the impacts are listed as Permanent
with no net loss of stream function.
2. Phase 1D Plans: The project plans at Site 1 appear to cut off the western extent of proposed
wetland impacts (Wetland WAT).
3. Phase 2A and 2B Plans: note that the conceptual plans submitted appear to indicate future
opportunities to avoid and minimize impacts to aquatic resources. The stage of design
presented does not show drainage structures or other details necessary to fully evaluate such
measures and therefore comments herein are withheld. Several wetland areas may be
considered complete functional losses due to small remaining remnants, rerouting hydrologic
input, etc., including Wetlands WBE (Site 2) and WBF (Site 3) in Phase 2A, and Wetlands WBJ
and WCE (Site 1), WAK (Site 2), WZ (Site 8), WAB (Site 9), and WAC (Site 15) in Phase 2B.
City of Sanford Utilities
1. On the "Phase I Water and Sewer Line Potential WOTUS Impacts" drawings submitted on
6/1/2023, the legend lists the light blue line as the "Phase 2 Water' line and the dark blue line

as the "Phase 1 Water'; this appears to be reversed on the sheets themselves.
2. Phase 2 Sewer
a. Impacts 5-38, 5-36, 5-34, 5-33, and 5-87 are all very large temporary impacts, which do
not appear to be justified by the size of the sewer line installation. Please justify that
these temporary impacts have been minimized to the maximum extent practicable for
the utilities necessary to support the Vinfast project alone, rather than any future
unrelated project.
b. Sheets FM-5, FM-6, and FM-7 show proposed grades several feet above the elevation
of the Streams P2S_529, P2S_28, P2S_27, RD_P2S_SD, and P2S_526. Furthermore, the
grades and culverts that are shown on these plan sheets appear to be proposed for a
future unrelated road project and are not consistent with minimization practicable for
the proposed project. Please revise the plan sheets accordingly.
3. Itemized comments regarding avoidance and minimization and apparent inconsistencies
between various impact drawings and plan sheets are provided in columns V and W on the
attached spreadsheet; please revise and update the affected drawings, plans, and impact
spreadsheets accordingly.
The above requested information is essential to the expeditious processing of your application;
please forward this information to us within 30 days of your receipt of this letter.
Further, the Corps is currently drafting the environmental document for this project. Given the
scope, complexity, and interrelation of the activities proposed, note that the Corps is likely to
request additional information during this process regarding specific aspects of the proposed project
as needed to entirely and adequately address all components of the document.
If you have any questions regarding these matters, please contact me at [phone] or
[e-mail].
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Email: David. E.Bailey2Pusace.army.mil
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