HomeMy WebLinkAbout20221617 Ver 2_Eastfield_USACE Siting Letter and Responses_Nov2023_20231116
2401 Brentwood Rd, Suite 107
Raleigh, NC 27604
P (919) 873-2211
Terracon.com
November 16, 2023
Department of The Army
Wilmington District, Corps of Engineers
69 Darlington Avenue
Wilmington, North Carolina 28403-1343
Attn: Matthew K. Martin, Regulatory Specialist
Re: Action ID SAW-2017-00326
Dear Matthew:
The Eastfield team is submitting this letter in response to the meeting held at your office on October
31, 2023. Attendees included yourself, Lyle Phillips (USACE), Jeff Harbour (Terracon) and Mark
McDonnell (Adventure). The main purpose of this meeting was to discuss the alternative site
selection process that is required to satisfy 404(b)(1) criteria as part of your review of the
Individual Section 404 permit application for the Eastfield project. The team has subsequently
identified two offsite alternatives that we are presenting here for your review and consideration
starting with the revised purpose and need statement.
The following items are addressed in this letter or in the attachments and each item is based on
discussions held during our October 31st meeting.
1. Offsite Alternatives Analysis
2. Onsite Alternatives
3. Master Wetland Exhibit and Impact Table
4. Block E Stream & Buffer Impact Exhibit
5. Other Public Comments
6. Letter from NCDOT
7. NCDWR Submittal Information
Purpose and Need
The basic purpose of this project is to construct necessary infrastructure for a mixed-use
development within a strategic location along the I-95 corridor in North Carolina. The overall
purpose and need of the proposed project is to meet the market needs of the region for commercial
and industrial facilities of the type proposed here.
Siting Criteria
The applicant states that their site selection criteria for a development of this type is contingent
upon several factors that are necessary to achieve the purpose and need. These include but are
not limited to the following in no order of importance.
• Close to the I-95 Corridor
• Reasonable distance to I-40
• Rail service
Eastfield Development
Action ID SAW-2017-00326
November 16, 2023
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• Contiguous land totaling up to 350 acres.
• Land configured such that lots with buildable areas as rectangular as possible for efficient
construction of building and supporting parking and loading areas.
• Lot Sizing / Site Layout Requirements for maximum tenant usability.
• Potential separate routes for truck and office vehicle access
• No steep topography to avoid extensive cut, fill and retaining walls
• Sewer, water, electrical, technology connections
• Nearby interstate quality roads
• Rail access
• Near similar developments
• Skilled labor force
• Appropriate zoning
Off Site Alternatives
Two offsite alternative locations have been identified and subjected to a screening process, along
with the preferred site, to determine the least environmentally damaging practicable alternative
(LEDPA). Each site is briefly summarized below followed by a table that depicts the screening
criteria that were evaluated for the offsite and preferred alternatives.
Halifax County Site
The Halifax Site consists of 204 acres of land located in Enfield, NC. This site was evaluated
for its potential to serve as a mixed-use development, like what is proposed for the
preferred Eastfield Site. The Halifax Site is being marketed by the Halifax County Economic
Development Commission. The site is relatively small compared to the Eastfield Site and
contains an extensive wetland along the western boundary. Terracon staff have worked
on this site and are familiar with the site’s characteristics. The wetland is a riverine swamp
forest system and a development of a similar nature to what is proposed on the Eastfield
Site would impact up to 30 acres of high-quality wetlands. A rail spur is abutting the
western boundary; however significant improvements would be required to access the rail
and to modernize the existing roads that service the Halifax Site. The Screening Matrix
provided below details many more criteria that were considered. Although the Halifax Site
does possess some of the necessary attributes that the proposed project requires; when
viewed as a whole, the Halifax Site does not meet the stated purpose and need of the
applicant and would incur significant environmental impacts were it to be used for this
project.
Legacy Farms
The Legacy Farms site consists of 290 acres of land located in Wayne County, NC. The site
consists of a combination of undeveloped woods along with components of an active hog
farm. The site contains extensive hydric soil flats, and we estimate approximately 90 acres
of wetlands may occur on the site. The Legacy Farms site does provide enough developable
land; however, a site design such as that proposed for Eastfield would incur up to 15 acres
of wetland impact. The closest rail line is 5 miles away and the cost to construct a rail spur
to the Legacy Farms site would be cost prohibitive for the project and the applicant. The
rural nature of the site also does not promote adequate utilization of the intended mixed -
use development and I-95 is approximately 14 miles away. The Screening Matrix provided
Eastfield Development
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below details many more criteria that were considered. Although the Legacy Farms Site
does possess some of the necessary attributes that the proposed project requires; w hen
viewed as a whole, the Legacy Farms Site does not meet the stated purpose and need of
the applicant and would incur significant environmental impacts were it to be used for this
project.
Preferred Alternative
The preferred alternative for this project is the Eastfield site that is presented in the permit
application. As reported by the Johnston County Economic Development Board, Johnston County
is the fastest growing county in NC, with over 205,000 current residents and is growing at a pace
of 10,000 residents per year. This growth has created a need for this type of facility in Johnston
County.
Unlike many small towns in North Carolina, Selma is in a growing and relatively prosperous county
and is connected to the economic opportunity of the Research Triangle Region. However, the same
transportation infrastructure that benefits the town also means that residents have choices and
can travel outside Selma for shopping and services. Selma has often seen itself as the outlier of
Johnston County. Therefore, the Selma area was chosen for the siting for Eastfield to meet the
needs of the local community and economic development goals of Johnston County.
Considering the planned mixed-use development of Eastfield, the ideal siting required nearby
connections to both major transportation corridors and rail access. Based on these acreage and
transportation requirements, the current location became the Preferred Alternative. The screening
process that has been completed also leads the pr oject team to believe that the current Eastfield
location in Selma, NC should be viewed as the LEDPA.
Screening Matrix
Criteria Preferred Site Halifax County
Site
Legacy Farms
Near I-95 Yes (abutting) 14 miles 17 miles
Road Network 2 and 4-lane
highways
2-lane unimproved;
Highway 301 0.5 mi
away
2-lane rural
Near Rail Access Yes (abutting; rail
spur easily
constructable)
Yes (abutting site
but also abuts large
swamp system)
No (closest is 5
miles away)
Proper Zoning Yes Yes Partially
Contiguous Tracts Yes Yes Yes
Size (ac) 307 204 ac 290 ac
Meets Developable Area Yes No Yes
Stream Impacts (lf) 267 0 0
Onsite Wetlands (ac) 50 74 90
Wetland Impacts (ac) 3 5.5 to 30 15
Floodplain Impacts No Yes Yes
Eastfield Development
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Criteria Preferred Site Halifax County
Site
Legacy Farms
NCNHP Element
Occurrences
No No No
NCSHPO Clearance Yes No No
Technology
Connections Available
(i.e. fiber optic)
Yes No No
Water/Sewer Yes, installation
ongoing
Water available 0.5
mile away; sewer-no
Water-yes; Sewer-
no
Alternatives Dismissed
The project team has evaluated two offsite alternatives in comparison to the preferred Eastfield
Site. The team found it unexpectedly difficult to locate a property of sufficient size, with adequate
access to I-95, rail access, and with limited environmental constraints. Sites possessing these
attributes near I-95 are extremely rare and the project team utilized www.loopnet.com to help
with the property search. The Halifax County Site and the Legacy Farms Site represent the two
sites along the I-95 corridor that possessed at least two of the required siting criteria and were
identified as being available properties.
After our screening process, that is summarized above, the project team feels that the Halifax
County Site and the Legacy Farms Site can be eliminated from further consideration due to multiple
factors; however, the amount of potential wetland impact far exceeds the proposed wetland impact
that would result from utilizing the Eastfield Site. Therefore, the Halifax and Legacy sites cannot
be claimed as the LEDPA based on this screening. The team proposes that the Eastfield Site be
viewed as the LEDPA pursuant to this analysis.
Onsite Alternatives
The entirety of the Eastfield Development has been designed to avoid impacts to the greatest
extent possible, while also balancing the connectivity of the developable space of the project. The
impacts proposed are not designed to create more developable space but are dictated by
transportation and utility connectivity of the site as required by NCDOT and local jurisdictions. The
attached exhibits include onsite alternative designs that would have incurred significantly more
impact in both Block O and Block E. Additionally, a facility was planned for Block N; however, that
facility would have impacted up to 9 acres of wetlands and was, therefore, dropped from
consideration.
Block O
The proposed development in Block O has been redesigned to minimize impacts. A
previous design for Block O would have resulted in impacts to the entire jurisdictional ditch,
which would total approximately 0.3 acre of wetland impact. This is depicted in an
attachment with his submittal. A less impactful design is now proposed that only incurs
0.027 acre of impact to the jurisdictional ditch from a single road crossing.
Eastfield Development
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Block E
The original site design for Block E would have resulted in potentially 454 linear feet of
stream impact. A redesign of Block E has greatly minimized the stream impact to 267
linear feet of actual stream bed loss resulting from two road crossings. Each of the two
road crossings will have 8-foot riprap aprons at the end of each culvert. These riprap
aprons will be embedded into the stream bed to prevent a loss of the aquatic resource.
Five, small stormwater outfalls located along the streambank in Block E each incur 10 linear
feet of stream bank disturbance; however, any rip rap will be directly embedded to avoid
stream bed loss. This redesign results in significantly less stream impact for the Eastfield
project. The currently proposed design for Block E is attached and depicts the two road
crossings and the outfalls. The impacts have been quantified and are included in this
drawing.
Other Public Comments
The team has also reviewed other public comments, including those from NCWRC and EPA, and
our responses to those comments follow.
Comment Response
EPA comments dated 2/15/2023
The residential portion of the project has been
dropped and is no longer part of the project.
The wetland impacts noted in the EPA
comment have been reduced from the original
4.68 acres to 3.03 acres. This results
primarily from the removal of the residential
portion of the project.
NCWRC comments dated12/15/2022
The team has reviewed the comments
received from NCWRC and will take into
consideration each of their recommendations
with regards to wildlife habitat and forest
fragmentation. Large areas of undisturbed
woodlands, including wetlands will remain on
the site Note that the original wetland impacts
noted in the NCWRC letter have decreased
from 4.07 acre to 3.03 acres. Native
vegetation will be used to revegetate and
stabilize areas where applicable.
Mr. Frankie Mozingo comment dated
2/16/2023
The main concerns identified in the comments
from Mr. Mozingo focus on the existing road
network, site drainage, and the perceived lack
of need for a development of this this type.
The project will include significant
improvements to the existing road network as
extensively documented in the IP application
and report. The site will comply with all State
and federal water quality regulations including
those that address site runoff and stormwater
management. Also, the project will include
more than simple retail shopping. The mixed-
used development will bring much needed
jobs and economic uplift to the Selma area.
Eastfield Development
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Mitigation
The applicant has secured Statements of Availability from a private mitigation bank as well as from
NCDMS. Currently these SOAs suggest that wetland mitigation credits to cover up to 3.56 acres
of wetland impact can be secured. This 3.56-acre amount of impact was presented in initial
application prior to the impact reductions detailed in this submittal. Additional avoidance and
minimization measures have been taken by the project team and total wetland impacts proposed
are now 3.03 acres. The applicant is assuming the standard 2:1 wetland mitigation ratio for the
remaining project impacts. Stream impacts in Block E have been added to the proposed action
and total 267 linear feet (0.123 acre) of stream bed loss resulting from the two road crossings
(Impacts F & G). The private bank in this HUC that reported stream credits was contacted and
they did not have sufficient credits available until possibly later this year. Therefore, Terracon has
secured stream mitigation credits from NCDMS to cover this amount of stream impact. The SOAs
for wetland and stream mitigation are attached.
Information for NCDWR
The project team is also addressing the comments in NCDWR’s letter dated September 22, 2023.
This information is intended to be submitted to NCDWR concurrent with his submittal to USACE.
The entire project team would like to express our appreciation for both USACE’s and NCDWR’s
assistance and guidance during this review process. We hope that the information we are now
providing will satisfy your request and the permit review process can continue and the approval
can be issued soon. Please do not hesitate to contact us if you have further questions.
Sincerely,
Terracon Consultants, Inc
for
Jeff Harbour, PWS Terri Russ, RPA
Senior Scientist Department Manager
Cc: Sue Homewood, NCDEQ Division of Water Resources
Kevin Dougherty, Eastfield Associates
Mark McDonnell, Adventure
Matt Phillips, Adventure
Aric Geda, Modulus
Daniel S. Deiseroth, P.E. The Gateway Engineers
Josh Scanlon, P.E., The Gateway Engineers
Ryan Enoch, P.E., The Gateway Engineers
Rhiannon Graham