20221617 Ver 2_USACE More Info Requested_20230926

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
STAT S O+'
Regulatory Division
Action ID: SAW-2017-00326
Mr. Kevin Dougherty
Eastfield Associates, LLC
101 South Raeford Street, Suite 200
Selma, North Carolina 27576
Dear Mr. Kevin Dougherty,
September 26, 2023
Please reference your Individual Permit application for Department of the Army
(DA) authorization to permanently discharge fill material into 0.258 acre (1,410 linear
feet) of stream channel and 3.563 acres of wetlands associated with the construction of
Eastfield Development. The proposed project is north of US-70A, east of Interstate 95
and south of Ballard Lane, located at in Selma, in Johnston County, North Carolina.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your
proposal by public notice dated January 17, 2023. Comments in response to the notice
were received from the North Carolina Department of Natural and Cultural Resources
(NCDNCR), North Carolina Department of Environmental Quality (NCDEQ), North
Carolina Wildlife Resources Commission (NCWRC), United States Environmental
Protection Agency (USEPA), and a member of the public. The comments received are
enclosed for your information and to provide you with the opportunity to address any of
the stated concerns.
Further, on February 6, 1990, the Department of the Army (DA) and the U.S.
Environmental Protection Agency (EPA) signed a memorandum of agreement (MOA)
establishing procedures to determine the type and level of mitigation necessary to
comply with Clean Water Act (CWA) Section 404(b)(1) Guidelines. This MOA provides
for first, avoiding impacts to waters and wetlands through the selection of the least
damaging, practical alternative; second, taking appropriate and practical steps to reduce
impacts on waters and wetlands; and finally, compensation for remaining unavoidable
impacts to the extent appropriate and practical. To enable us to process your
application, in compliance with the MOA, we request that you provide the following
additional information:

A. Permits for work within wetlands or other special aquatic sites are available
only if the proposed work is the least environmentally damaging, practicable alternative
(LEDPA). Please furnish information regarding any other alternatives, including upland
alternatives, to the work for which you have applied and provide justification that your
selected plan is the least damaging to water or wetland areas.
See item 1 below;
B. It is necessary for you to have taken all appropriate and practicable steps to
minimize losses of Waters of the U.S., including wetlands. Please indicate all that you
have done, especially regarding development and modification of plans and proposed
construction techniques, to minimize adverse impacts.
i. See items 3-8 below.
C. The MOA requires that appropriate and practicable mitigation will be required
for all unavoidable adverse impacts remaining after the applicant has employed all
appropriate and practicable minimization. Please indicate your plan to mitigate for the
projected, unavoidable loss of waters or wetlands or provide information as to the
absence of any such appropriate and practicable measures.
i. See item 2 below.
Additionally, the following items must be resolved prior to continuing to process your
permit request:
1.) It is unclear, based on the information provided, that the Preferred Alternative is
the LEDPA when compared to the other alternatives.
a.) Siting Criteria- Please provide more defined siting criteria for the project.
Currently the siting criteria does not indicate a required lot size or location. For
example, were locations adjacent to major transportation corridors the siting criteria
for the preferred alternative or was siting focused on the general Selma area.
b.) Onsite Alternative — Please provide an onsite alternative for the project.
Currently, the applicant has chosen not to provide an onsite alternative, stating it
would not meet the stated purpose and need. Onsite alternatives are required
under 404(b)(1); 40 CFR 230.94(c)(3). If cost is the basis for this alternative not
being practicable, please provide the cost -benefit analysis to support the Corps
decision.
-2-

-3-
c.) Offsite Alternative "Selma Site" -- Please provide additional information to
support the decision that this alternative is not practicable or more environmentally
damaging. It is stated in your application that this alternative does not meet the
basic purpose and need of the proposed project, therefore it is not a practicable
alternative. In order to be practicable, an alternative must be available, achieve the
overall project purpose (as defined by the Corps) and be feasible when considering
cost, logistics and existing technology. Additionally, for proposed alternatives a
description of the proposed actions impacts on wetlands and waters in a manner
that is comparable to the preferred alternative.
d.) Offsite Alternative "RRT Investment Site" — Please provide additional
information to support the decision that this alternative is not practicable or more
environmentally damaging. It is stated in your application that this alternative does
not meet the basic purpose and need of the proposed project, therefore it is not a
practicable alternative. In order to be practicable, an alternative must be available,
achieve the overall project purpose (as defined by the Corps) and be feasible when
considering cost, logistics and existing technology. Additionally, for proposed
alternatives a description of the proposed actions impacts on wetlands and waters
in a manner that is comparable to the preferred alternative.
2.) It is unclear, based on the information provided, what mitigation is provided.
Please include a mitigation statement, and compensatory mitigation plan that identifies
intended mitigation mechanism and proposed mitigation ratios.
3.) During a site visit on September 12, 2023, changes occurred to the extent of
aquatic resources present at the preferred alternative site. Specifically, a feature in
Block O was removed and a potential stream feature in Block E was added. Please
revise plans and impact quantities to reflect the changes during the site visit.
4). It appears proposed impact 4 could result in an additional 2.32 acres of indirect
impacts to a wetland at parcel K by a loss of hydrologic connection to downgradient
waters. Please further detail if/how a hydrologic connection will remain to aquatic
resources upgradient of impact 4.
5.) It appears proposed impact 8A appears to have less impactful alternatives to the
east and west. Please elaborate on why the road must enter at the proposed location
resulting in impact 8A or if plans could be modified to further avoid and minimize
impacts.
6.) It is unclear, based on the information provided, the purpose of proposed impact
15. Please elaborate on the intended use and necessity of impact 15.
-3-

-4-
7.) It is unclear based on the provided "Eastfield Masterplan" the intent of the stub
road south of proposed impact 15. Please elaborate if this proposed stub road would
result in future impacts.
8.) In a previous application, submitted on November 4, 2022, impacts related to
several residential developments were presented in Blocks I and J. Is it correct that
these developments have been removed from the proposed project?
9.) In order to verify compliance with Endangered Species Act of 1973 and 40 CFR
230.10(b)(3), the Corps has initiated informal consultation with The US Fish and Wildlife
Service and will not be able to render a decision until ESA Section 7 consultation is
complete.
10.) It appears that an Individual 401 Water Quality Certification (WQC) is required
from the North Carolina Division of Water Resources (NCDWR) for this project. Per the
2020 CWA Section 401 Rule, the application must contain the 9 elements listed in
Section 121.5(b) of the Rule. According to the 9/16/2022, Programmatic Agreement
(PA) between the USACE, Wilmington District, and the NCDWR, the Reasonable
Period of Time (RPOT) for NCDWR to act on a Section 401 certification request is 120
days after receipt of a certification request containing the 9 required elements. However,
it appears that element 4 is not met; as such, NCDWR's RPOT has not started yet. See
item 3 above.
11.) Please note that additional comments and questions may be required after
review of the responses to the comments above.
The above requested information is essential to the expeditious processing of your
application; please forward this information to us within 60 days of your receipt of this
letter. If you have any questions regarding these matters, please contact me at (984)
800-3741 or matthew.k.martin(a)usace.army.mil.
Sincerely,
Matthew K. Martin, Regulatory Specialist
Raleigh Regulatory Field Office
-4-

-5-
Enclosures
Copies Furnished:
Mr. Jeff Harbour
Terracon Consultants, Inc.
2401 Brentwood Road, Suite 107
Raleigh, North Carolina 27604
Mr. Todd Bowers
Permit Review Specialist
Wetlands Regulatory Section
U.S. Environmental Protection Agency - Region IV
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
Ms. Sue Homewood
NCDEQ— Division of Water Resources
450 W. Hanes Mill Road, Suite 300
Winston Salem, North Carolina 27105
-5-

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
February 14, 2023
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Christopher Hopper chri stopher. d.hoppergus ace. army.mil
USACE
Raleigh Regulatory Field Office,
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Re: Construct Eastfield Crossing multi -use development, I-95 and Ballard Lane, Selma, Johnston
County, ER 21-2395
Dear Mr. Hopper:
Thank you for your letter received January 17, 2023. We have reviewed the materials submitted and offer
the following comments.
We received a Public Notice seeking comment and concurrence on proposed actions associated with the
proposed construction of the Eastfield Crossing multi -use development.
We concur that all identified archaeological sites located within the Area of Potential Effects (APE) have
been considered and all compliance for archaeological resources with Section 106 of the National Historic
Preservation Act and GS 121-12(a) has been completed for this project.
We concur that the project as proposed will not have an effect on any historic structures.
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(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

DocuSign Envelope ID: C566A98C-4282-4875-AF48-5DEAF56029CC
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
February 6, 2023
Corps Action ID# SAW-2017-00326
DWR# 20221617
Johnston County
Mr. Chris Hopper
U.S. Army Corps of Engineers
Wilmington Regulatory Field Office
Delivered via email to: [e-mail]
Subject Project: Eastfield Development
Dear Mr. Hopper:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
project:
1. The applicant has not provided an off -site alternatives analysis. The Division recommends that
to ensure consistency with other similar projects and to ensure that this project is the Least
Environmentally Damaging Practical Alternative, an appropriate Alternatives Analysis be
required for this project.
The applicant states that alternative site designs within the project parcels have been
considered but no additional documentation has been provided. The Division recommends that
to ensure consistency with other similar projects and to ensure that this project is the Least
Environmentally Damaging Practical Alternative, an appropriate Alternatives Analysis be
required for this project.
The applicant states that the purpose of the significant amount of impacts identified as Impact E
are for future development of an industrial park of 500,000 to 1,000,000 square feet facility.
The applicant has not provided any detailed information regarding the sizing of this facility and
associated infrastructure. The Division recommends that to ensure consistency with other
similar projects and to ensure that this project is the Least Environmentally Damaging Practical
Alternative that the USACE review the Purpose and Need and detailed site sizing information.
There appears to be sufficient uplands within the overall project to support warehouse facilities
elsewhere within the project boundaries.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA
Uapwhnanl of Fmimnnnental 0a 1 919.7o7.9oDo

DocuSign Envelope ID: C566A98C-4282-4875-AF48-5DEAF56029CC
Corps Action ID# SAW-2017-00326
DWR# 20221617
Wake County
Page 2of2
4. A significant portion of the impacts occur for a residential development. It appears that a slight
reduction in residential lots would provide substantial avoidance and minimization of
jurisdictional impacts.
5. The applicant has not provided documentation that the NC Division of Mitigation Services, or an
approved Mitigation Bank will accept responsibility for the required stream and wetland
mitigation for the site.
6. The Division is unable to complete a review of the project for compliance with 15A NCAC 02H
.0506 at this time. The Division has requested additional technical information from the
applicant. The Division requests that the USACE also consider the items requested in the
attached letter during the review of the application.
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-813-1863 or
[e-mail].
Sincerely,
DocuSignedNAby- - -
-MSAA_�l
A43C72700BD543E...
Katie Merritt, Acting Supervisor
401 & Buffer Permitting Unit
Enclosures: Request for Additional Information, DWR#20221617, dated 1/2/2023
Electronic cc: Robert Turnbull, Terracon
DWR RRO
DWR 401 & Buffer Permitting Branch file
Filename: 20221617 Eastfield Development-Jonhston-PN Comments to USACE.docx
D North Carolina Department of Environmental Quality I Division of Water Resources
r/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
, E QNORTH CAROLINA 919.707.9000
operhnM of EmironmanW 9uallly

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
January 4, 2023
DWR # 20221617
Johnston County
Eastfield Associates LLC
Attn: Mr. Kevin Dougherty
101 S. Raiford St, Suite 200
Selma NC 27576
Delivered via email to: [e-mail]
Subject: REQUEST FOR ADDITIONAL INFORMATION
Eastfield Development
Dear Mr. Dougherty:
On November 17, 2022, the Division of Water Resources (Division) received your application requesting
an Individual Water Quality Certification from the Division for the subject project. The Division has
determined that your application is incomplete and cannot be processed. The application is on -hold
until all the following information is received:
The application is considered incomplete until the conclusion of a public notice comment period
pursuant to a Public Notice issued by the U.S. Army Corps of Engineers (USACE). If the USACE
requests a response to any comments received during the Public Notice, please provide the Division
with a copy of your response to the USACE.
2. Your application notes that stream buffer impact D is to be permitted under a separate application.
The Division considers that area to be part of the overall projects, as shown in this application. The
application submitted for Impact D, submitted as Eastfield Retail Block A (DWR# 20221707) will be
incorporated into this project review.
3. Please provide another copy of the wetland map. The map that was provided with the application is
not legible.
4. Please provide a jurisdictional features map that has been verified by the USACE. Please ensure the
documentation includes confirmation that the pond that is adjacent to 195 has been determined to
be isolated by the USACE and that the tributaries on the eastern portion of the project have been
determined to be jurisdictional ditches rather than jurisdictional streams. The plan sheet provided
with this application does not appear to match the wetland determination map previously
submitted as part of the Nationwide Permit application for Providence Road Construction
(DWR#20201750).
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA
Uapwhnanl of Fmimnnnental 0a 1 919.7o7.9oDo

Eastfield Development
DWR# 20221617
Request for Additional Information
Page 2 of 5
5. Clarify whether a buffer determination has been conducted, and has not expired, for the entire
project site.
6. The application notes that some roadway impacts were previously approved by authorization under
Nationwide Permits. All impacts that have been previously approved need to clearly called out in
the application. The areas identified on the current plans do not appear to correspond with the
plans in DWR Project #20201750. In addition, clearly indicate which previously approved impacts
have been constructed and which have not been constructed to date. Please note that these
impacts were approved under General Certification 4135 which has expired, therefore any impacts
that have not been constructed will require reauthorization.
7. Provide mitigation acceptance letters and/or statement of availability letters from your proposed
mitigation providers.
8. The application states that the total impacts are approximate. The Division is unable to issue a 401
for approximate impacts. Provide detailed construction plans showing exact impact amounts. If the
project is proposed to be constructed in phases, you may submit detailed construction plans for
Phase 1 and conceptual plans and impact amounts for future phases. Please ensure that the
detailed construction plans show the proposed fill slopes, any potential impacts for construction
activities/access, appropriate dewatering as necessary, and any required sediment and erosion
control measures.
9. Pursuant to 15A NCAC 02H .01305(b) "In assessing whether the proposed activity will comply with
water quality standards, the Division shall evaluate if the proposed activity: (1) has avoided and
minimized impacts to surface water and wetlands....". You have provided a statement that
alternative site designs did not meet the applicants purpose and need. However, you have neither
provided on -site alternative layouts, nor sufficient information to support that the current layout is
the least impactful to the maximum extent practicable. Please provide more detailed information
regarding why further modifications to any project components, such as reduction in the number of
residential units or the size or layout of commercial buildings, or the reduction in widths or
realignments of roads, or the reduction or redesign of industrial and/or commercial buildings within
the project are not feasible to further reduce impacts.
If the locations or widths of roads are dictated by local government requirements or transportation
plans, then the avoidance and minimization analysis must be based on traffic analysis. DWR
understands that many local governments require developers to design and construct roadways
identified on the transportation plans, however DWR will evaluate the justifications for location and
widths of these roads as if they were being proposed/designed by the local government. A
statement that the location or design is required by the local government will not be considered a
sufficient avoidance and minimization justification.
Please note that if any of the justifications are based on financial reasons, then the justification
should include specific detailed information regarding the loss of the area/facilities (number of lots,
etc) when considered as part of the entire project. In addition, construction and mitigation costs
should be included in any financial justification.
��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH cnaouNn ��` 919.707.9000
n.p. mm Bmmnm qum�

Eastfield Development
DWR# 20221617
Request for Additional Information
Page 3 of 5
The following are specific areas where it appears further avoidance and/or minimization may be
feasible.
a. Provide traffic information that supports the proposed roadway design of two lanes with a
center turn lane.
b. It appears that Impact areas 6A could be avoided by removing 2 lots from the development.
c. It appears that Impact area 6B could be avoided or reduced by removing up to 5 lots from the
development.
d. It appears that Impact area 6C could be avoided by removing up to 5 lots from the development.
10. The plan sheets provided show impacts to buffers from a greenway in the vicinity of Impact 6A.
However, these impacts do not appear to be included in this application. It also appears that there
may be fill slope impacts to the riparian buffer in the vicinity of impact 6A. Clearly show fill slopes
adjacent to/within all impact areas and buffers throughout the project.
11. Provide a detailed description of the proposed development and associated infrastructure (parking,
road network, etc) in the Eastfield Industrial Park section of the project. Please ensure the
description includes details regarding how the size of the project and necessary infrastructure has
been determined. Please also provide a plan sheet that shows the future use/development for
proposed Impact E.
12. Provide final construction drawings (plans, cross-section, and profiles,) for the relocated
jurisdictional tributary at proposed Impact E.
13. It appears that the development has been designed such that future access to parcels located on the
eastern edge of the property, just to the south of the future industrial development, would require
additional impacts to wetlands, streams, ponds and buffers. Please provide an application and
documents that show all future development areas are accessible and buildable without additional
impacts, or incorporate future impacts into the current application.
14. It appears that the project impacts have the potential to disconnect large wetlands. For example,
the plans do not indicate that culverts will be installed within roadways to connect wetlands on
either side of the proposed fill.
15. In order to carefully evaluate that all culvert installations will not cause water quality violations,
please provide detailed culvert information, including culvert sizing as well as plan and profile
drawings. You must provide detailed information for Phase 1 impacts; however, you may provide
conceptual/typical plans for future phases.
16. Please clarify if there will be any additional utility impacts within the project site.
17. Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon
determining that the proposed activity will comply with state water quality standards which includes
designated uses, numeric criteria, narrative criteria and the state's antidegradation policy, as defined
North Carolina Department of Environmental Quality I Division of Water Resources
���
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA ��`
neoe Mm Bmmnm quay
919.707.9000

Eastfield Development
DWR# 20221617
Request for Additional Information
Page 4 of 5
in rules of 15A NCAC 028.0200...... In assessing whether the proposed activity will comply with water
quality standards, the Division shall evaluate if the proposed activity: (2) would cause or contribute
to a violation of water quality standards; (3) would result in secondary or cumulative impacts that
cause or contribute to, or will cause or contribute to, a violation of water quality standards;" The
application states that the project is subject to a local government post construction water quality
stormwater review, however according to the Division of Energy, Mineral and Land Resources
website, this project is located outside of any local government jurisdiction for water quality
stormwater review. Therefore, in order to ensure protection of downstream water quality, please
provide a complete stormwater management plan for review. Please ensure that it includes all
appropriate supplemental forms, O&M agreements, calculations, engineering drawings, etc., that
complies with the requirements of the State Stormwater Program. The Stormwater Design Manual
and applicable forms may be found on the DEMLR's website at
https://deg.nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permit-
guidance/stormwater-bmp-manual. In addition, please also submit the application form SWU-101
(attached). However, the $505 application fee and last two signature pages of this form may be
omitted.
18. Please provide a detailed qualitative indirect and cumulative impact analysis that clearly follows the
steps outlined in the Division's policy for guidance on our website at:
http://portal.ncdenr.org/web/wq/swp/ws/401/policies. [15A NCAC 02H .0506(b)(4)]
19. Please provide responses to the attached recommendations from the NCWRC.
It is important to note that a complete review of the project could not be conducted at this time based
on the information and lack of information that was submitted. Upon receipt of the requested
information, additional requests may be necessary to determine compliance with all appropriate state
regulations.
Pursuant to Title 15A NCAC 02H .0502(e) / 15A NCAC 02B .0611, the applicant shall furnish all the above
requested information for the proper consideration of the application. Please respond in writing within
30 calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617
OR by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note that the DWR# requested
on the link is referenced above).
If all the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Section 401 of the Clean Water Act or the
Tar -Pamlico Buffer Rules for this activity and any work done within waters of the state may be a
violation of North Carolina General Statutes and Administrative Codes.
��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NCRTH CnaouNA ��` 919.707.9000
neoe Mm Bmmnm quay

Eastfield Development
DWR# 20221617
Request for Additional Information
Page 5 of 5
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
DocuSigned by:
V
A43C72700,BrD 543 Ems...
Katie Merritt, Acting Supervisor
401 & Buffer Permitting Branch
Electronic cc: Robert Turnbull, Terracon
Chris Hopper, USACE Raleigh Regulatory Field Office
Gabriela Garrison, NCWRC
DWR RRO
DWR 401 & Buffer Permitting Branch file
Filename: 20221617_Eastfield Development_Johnston_IP_addinfo.docx
D North Carolina Department of Environmental Quality I Division of Water Resources
r/ 512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
neaaNnM of EmironmanW 9uallly

NORTH CAROLINA WILDLIFE RESOURCES COMMISSION EJ
Cameron Ingram, Executive Director
MEMORANDUM
TO: Sue Homewood
Division of Water Resources
N.C. Department of Environmental Quality
FROM: Gabriela Garrison
Eastern Piedmont Coordinator. W
Habitat Conservation
DATE: December 15, 2022
SUBJECT: Individual Permit Application for Eastfield Development, Johnston County, North
Carolina (DEQ Project No. 2022-1617).
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; 1 NCAC 25), and North Carolina General Statutes (G.S. 113-131 et seq.).
Adventure Development proposes to construct the Eastfield Mixed -use Development. The proposed
project area is approximately 348 acres and located east of the intersection of NC Highway 70 and
Interstate 95, south of Selma. Currently, the project site consists of mixed hardwoods, agricultural fields,
utility easements, and buildings. Proposed project work includes road construction, utility installation,
and site grading for future residential, commercial, and industrial use.
Permanent project impacts from the Eastfield Development include the following: 151 linear feet of
stream channel loss, 4.092 acres of wetland loss, and 1.024 acre of ditch loss. Temporary impacts include
30 linear feet of stream channel. Permanent buffer impacts include 6,414 square feet in Zone 1 and 5,011
square feet in Zone 2.
Aerial images and maps indicate Bawdy Swamp and unnamed tributaries to Mocassin Creek bisect the
proposed project area. The NCWRC is concerned with potentially adverse ecological impacts resulting
from project construction. Placing fill in aquatic systems can alter hydrology, result in significant
negative impacts to downstream areas, and eliminate aquatic and terrestrial wildlife habitat. Additional
impervious surface in developing areas results in increased stormwater runoff that can impact stream
morphology. This will cause further degradation of aquatic habitat through accelerated stream bank
erosion, channel, and bedload changes, altered substrates and scouring of the stream channel. In addition,
pollutants (e.g., sediment, heavy metals, pesticides, and fertilizers) washed from developed landscapes
can adversely affect and extirpate species downstream.
Forest fragmentation is a serious concern as outlying areas of Smithfield and Selma remain predominantly
rural. Reduction of habitat due to fragmentation has severe impacts on wildlife populations, including
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
December 15, 2022
Eastfield Development
IP Application
deleterious effects on reproduction and migration. Small patches of forest often become degraded and
provide little or no value to remaining wildlife. In addition, as healthy ecosystems are disturbed and
minimized, invasive plant species become established and create monocultures in areas that previously
hosted diverse and intricate natural communities. As such, the NCWRC offers the following guidance
and recommendations to minimize impacts to aquatic and terrestrial wildlife resources:
1. The NCWRC recommends maintaining 100-foot, native, forested buffers on all perennial streams and
50-foot, forested buffers on all intermittent steams. If wooded buffers do not exist, these areas should
be revegetated or allowed to naturally revegetate to increase functionality. Periodic checks should be
established to ensure invasive species are not growing in areas that have been disturbed during
construction. Wooded buffers include a combination of native trees, shrubs, perennials, and warm
season grasses. There are local nurseries that specifically sell native vegetation suitable for riparian
areas. Non-native grassed buffers, particularly fescue, do not provide the necessary and highly
valuable functions that forested buffers provide, including refugia and travel corridors for terrestrial
wildlife species. In addition, forested buffers protect water quality by stabilizing stream banks and
filtering stormwater, including sediment, nutrients, pesticides, and other material found in runoff.
2. Small, isolated wetlands are not protected by state and federal regulations but provide critical
breeding habitat for declining populations of amphibians. These areas are important for the
protection of biodiversity, groundwater recharge, and reducing sedimentation and pollution into
streams and rivers. These wetlands are considered an imperiled habitat in the 2015 North Carolina
Wildlife Action Plan(hltp://www.ncwildlife.org/plan). As such, the NCWRC recommends
maintaining a 150-foot forested buffer around all small, isolated wetlands.
3. The NCWRC recommends the use of Low Impact Development (LID) technology and effective
stormwater management strategies. Possible suggestions include engineered stormwater wetlands,
bioswales, and permeable pavement. Information on other LID techniques can be found in `Low
Impact Development, A Guidebook for North Carolina':
hl!ps://digital.ncdcr.gov/digital/collection/T I6062co119/id/232781.
4. Recreational areas and trails in open spaces should be located outside forested, riparian buffers and
surfaced with pervious materials. Further information can be found here:
https://www.railstotrails.org/build-trails/trail-building-toolbox/trail-building-and-design/developing_-
trails-in-sensitive-areas/.
5. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas where
stabilization is needed should be re -seeded with seed mixtures that are beneficial to wildlife - see
attached Table. The NCWRC strongly recommends against the use of fescue -based mixtures and
Sericea lespedeza (Lespedeza cuneata) as stabilizing groundcover. Sericea lespedeza in particular is
an egregious and invasive, non-native species that spreads easily and is very hard to eradicate.
Native, annual small grains appropriate for the season are preferred and recommended. Pollinator
mixes are commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths, and birds. Using native species instead of ornamentals should reduce the need for
water, fertilizers, and pesticides, as well as preserve the natural integrity of the ecosystem.
6. The NCWRC strongly encourages the use of native vegetation in public areas and rights -of -way. In
efforts to restore diversity and ecosystem functionality in a highly fragmented landscape, please also
consider revegetating residential and commercial areas with native trees, shrubs, warm season grasses
and perennials that are attractive and valuable to pollinating insects and other wildlife. The following
website has a wide assortment of native vegetation specific to North Carolina:
hl ps://ncbg.unc.edg/wp-content/uploads/sites/963/2019/08/NativePlantsWoody_pd£ In addition,
there are numerous local nurseries that specialize in native plants for both upland and riparian areas.
Free technical guidance from NCWRC biologists is available upon request.

Page 3
December 15, 2022
Eastfield Development
IP Application
7. Please confirm that all contractors and landscapers have been educated on proper herbicide use and
protocol. In areas where native vegetation will be installed, please post signage to ensure that
contractors will not spray on or in the vicinity of the vegetation. Staff biologists from NCWRC
monitor numerous sites across the State where contractors and landscapers have unknowingly sprayed
native vegetation because it was not clearly marked. Insecticides and herbicides should not be used
within 100 feet of perennial streams and 50 feet of intermittent streams, or within floodplains and
wetlands associated with these streams.
8. In addition to standard erosion and sediment control measure, the use of biodegradable and wildlife -
friendly sediment and erosion control devices is strongly recommended. Silt fencing, fiber rolls
and/or other products should have loose -weave netting that is made of natural fiber materials with
movable joints between the vertical and horizontal twines. Silt fencing and similar materials that
have been reinforced with plastic or metal mesh should be avoided as they impede the movement of
terrestrial wildlife species. Existing DWR 401 certifications state that `erosion control matting that
incorporates plastic mesh and/or plastic twine shall not be used along streambanks or within
wetlands. Exceptions to this condition require application to and written approval from DWR'.
Plastic -free mesh or twine in all erosion control matting should be used in all areas within the project
boundary.
The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/Conserving/documents/2002_
GuidanceMemorandumforSecondgaandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources.
In addition, please consider following guidance found in the Green Growth Toolbox:
hops://www.ncwildlife.org/conserving/rograms/Green-Growth-Toolbox. This is a guide specifically
designed for local governments to conserve natural resources while sustaining economic growth. An
applicable strategy for the Eastfield Mixed -use Development would include creating higher density areas
of residential and commercial development in order to leave larger areas of green space and recreational
areas.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or gabriela.garrisonkncwildlife.org.

Page 4
December 15, 2022
Eastfield Development
IP Application
Table: Wildlife -friendly stabilizing groundcover.
lb./ac
cost/lb
Proso or Brown Top Millet
Austrian Winter Pea or Iron Clay*
Buckwheat
Durana Clover
Black-eyed Susan
P urp letop
Beaked Panicgrass
Wild Rye*
Carthage Switch Grass
Partridge Pea
Ragweed
30
10
40
5
0.88 $26.40
1.1 $11.00
0.88 $35.20
8.33 $41.65
22 $22.00
22 $110.00
19.8 $79.20
6.6 $33.00
6.6 $26.40
6.6 $19.80
13.33 $13.33
1
5
4
5
4
3
1
Sum $417.98
Prices from Adams Briscoe or Ernst -4
Ernst Mix NC Steep Slope Mix $993.60 plus cover crop
Other mixes run 700 to $800 without cover.
* During cool season use Austrian Winter Peas and increase Wild Rye to 20 lbs.

Hopper, Christopher D CIV USARMY CESAW (USA)
From: Hopper, Christopher D CIV USARMY CESAW (USA)
Sent: Wednesday, February 15, 2023 4:33 PM
To: Turnbull, Robert T; Mark McDonnell
Subject: FW: SAW-2017-00326 Public Notice epa comments 02.15.23
Christopher D. Hopper
Regulatory Specialist
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
[phone]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey can
be accessed by copying and pasting the following link into your web browser:
https://regulatory.ops.usace.army.mil/customer-service-survey/. Thank you for taking the time to visit this site and
complete the survey.
From: Bowers, Todd <[e-mail]>
Sent: Wednesday, February 15, 2023 3:59 PM
To: Hopper, Christopher D CIV USARMY CESAW (USA) <[e-mail]>
Subject: [Non-DoD Source] SAW-2017-00326 Public Notice epa comments 02.15.23
Chris,
The EPA Region 4 Ocean, Wetlands and Streams Protection Branch has reviewed the subject Individual
Permit Public Notice under DA Action ID SAW-2017-00326 dated January 17, 2023. It is our understanding
that the applicant, Eastfield Associates, LLC. Is seeking Department of the Army authorization to permanently
impact 1,541 linear feet (If) of stream channel [0.48 acre (ac)] and 4.686 acres of wetlands, associated
with development of the Eastfield Mixed -Use Development (Eastfield), southeast of Selma, in Johnston
County, North Carolina.
According to the Public Notice, Applicant's Stated Purpose, and Project Description, the basic purpose of the
proposed project is to construct infrastructure for a mixed -use development within a strategic location in the
Selma, North Carolina market. The strategy for the development is to meet the market needs of the Selma
community for commercial, industrial, and residential facilities. The applicant's goal was to assemble enough
land to address the voids in the community, increase the tax base of Selma and minimize any environmental
impact. The site requires good access to Interstate 95 and rail lines. The project consists of road construction,
utility installation, and site grading for future commercial, residential, and industrial uses. The proposed
development goals have been oriented based on input received from the Johnston County Economic
Development Commission.
The proposed project would permanently impact 4.686 ac of wetlands, and 1,541 If of streams (0.48 ac)
subject to our regulatory authority pursuant to Section 404 of the CWA of 1972 (33 USC 1344). These impacts
would be in addition to the 67 If (0.02 ac) of stream and 0.39 acre of wetland already permanently impacted as
part of the Providence Boulevard crossing of Bawdy Creek.

The applicant would compensate for unavoidable losses with compensatory mitigation. The applicant proposes
to compensate for 1,541 If of permanent streambed loss due to construction at a 2:1 mitigation ratio, and 4.686
ac of riparian wetland loss of forested wetlands at a 2:1 mitigation ratio.
At this time, EPA Region 4 has a few site -specific comments or concerns with the project as presented in
the Public Notice. The applicant has claimed that "The proposed Eastfield Development design has minimized
wetland impacts to the greatest extent practicable within the project study area" and that "Wetlands, streams,
and surface waters proposed for impact cannot be avoided while still meeting the applicant's stated purpose
and need." Without additional information, it appears that additional avoidance of impacts can be achieved if
the applicant is willing to truncate a few key small parcels that appear to be residential lots. Impact area 6A
could almost be eliminated if two residential lots were removed and the greenway rerouted out of the wetland.
Impact area 6B could be further minimized if Road A were shortened, the turnabout spur moved closer to Road
B and 3-4 residential lots were removed or realigned. Impact area 6C could similarly be reduced with a
reduction of a least one residential lot and the turn around spur on Road F moved closer to Road E. Based on
the size and breadth of the project, it does not appear that these further reductions in impact to waters of the
U.S. will significantly affect the project purpose and will still meet the needs of the applicant to produce a
mixed -use development project. In order to determine if the applicant has avoided as much impacts to waters
of the U.S. as technically and financially practicable, EPA recommends that the applicant provide specific
justification for the need of the project to incur the permanent wetland losses at Impact Areas 6A, 61B
and 6C.
Thank you for the opportunity to provide feedback on DA Action I D SAW-2017-00326 associated with
development of the Eastfield Mixed -Use Development (Eastfield), southeast of Selma, in Johnston County,
North Carolina.
Best Regards,
Todd Bowers
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
919.523.2637 cell/telework
404.562.9225 office
Bowers.todd&e�a.gov
"Do unto those downstream as you would have those upstream do unto you."
— Wendell Berry

Hopper, Christopher D CIV USARMY CESAW (USA)
From: Hopper, Christopher D CIV USARMY CESAW (USA)
Sent: Friday, February 17, 2023 12:23 PM
To: Turnbull, Robert T; Mark McDonnell
Subject: FW: Eastfield Crossing Business Park
Christopher D. Hopper
Regulatory Specialist
U.S. Army Corps of Engineers
Regulatory Division
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
[phone]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey can
be accessed by copying and pasting the following link into your web browser:
https://regulatory.ops.usace.army.mil/customer-service-survey/. Thank you for taking the time to visit this site and
complete the survey.
From: Frankie H Mozingo <[e-mail]>
Sent: Thursday, February 16, 2023 4:58 PM
To: Hopper, Christopher D CIV USARMY CESAW (USA) <[e-mail]>
Subject: [Non-DoD Source] Eastfield Crossing Business Park
I think the current proposal for the Eastfield Crossing Business Park is bad idea for this area. I do not think that a permit
should be issued for the proposed development. I think it is too large and too ambitious for this area and its existing
infrastructure.
There is not reasonable infrastructure to support this type of development. The roads and traffic are already
bad enough. It is dangerous to drive in this area now. There are wrecks often. The stoplights and
intersections are backed up continuously especially at peak times. The drive on Hwy 70 from JR Road through
the Hwy 301 intersection is congested. It is difficult to safely turn in and out of the service stations and
restaurants in that area. We do not need more traffic in this area. The I-95 overpass is a bottleneck as well as
the railroad overpass by Bojangles cannot be widen. The railroad crossing at the next exit on I-95 is another
bottleneck. There is a lot of 18 wheeler traffic on Firetower Road and back ups that railroad crossing.
If the project is allowed sight and sound barriers for existing homes and properties need to be prioritized. Also
proper drainage should be prioritized as well. This area already has problems with standing water after heavy
rains. I fear the build up on the new development would cause flooding to the existing homes and
surrounding areas.
Also it is not worth the loss and impact to environment and wildlife. There are enough shopping centers in
this area. Carolina Premium Outlets and Walmart. It is an easy commute to Raleigh, Garner and Wilson areas
for similar options. Many people are already commuting to these areas for work.
Surely we can find a better use for this area than more retail outlets. I do think this are is ready for this.

Regards,
Frankie Mozingo
Software Developer
Hyper Protect Hosting Appliance
[e-mail]