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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 2 • 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 Action ID SAW-2017-00326 November 16, 2023 3 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 Action ID SAW-2017-00326 November 16, 2023 4 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 Action ID SAW-2017-00326 November 16, 2023 5 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 Action ID SAW-2017-00326 November 16, 2023 6 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