20231594 Ver 1_NWP 18 Attachments_20231121

Angela Petros
From: Angela Petros
Sent: Wednesday, May 31, 2023 8:51 AM
To: 401 PreFile
Subject: Strickland NWP 39 Pre -Application
To Whom It May Concern,
Atlas will be submitting an NWP 39 application for the Strickland project. This project is in Huntersville
(Mecklenburg County) and is an Industrial project. SunCap Properties is the applicant.
Angela Petros
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411
Charlotte, NC 28211
[phone] mobile
www.atiasenvi.com
Offices in Asheville and Charlotte
ONMENTAL

Preliminary ORM Data Entry Fields for New Actions
SAW — 201 - 202301217 BEGIN DATE [Received Date]:
Prepare file folder ❑ Assign Action ID Number in ORM ❑
1. Project Name [PCN Form A2a]: Strickland
2. Work Type: Private ❑ Institutional ❑ Government ❑ Commercial ❑✓
3. Project Description / Purpose [PCN Form 133d and 133e]:
The purpose of this project is for the construction of an industrial building with approximately
292,500 square feet under roof and associated infrastructure.
4. Property Owner / Applicant [PCN Form A3 or A41: Owner 1: Randy Strickland / Applicant: SunCap Properties
Owner 2: Ann H. Greene Attn: Kevin Dagenhart
5. Agent / Consultant [PCN Form AS — or ORM Consultant ID Number]: Atlas Environmental, Jennifer Robertson
6. Related Action ID Number(s) [PCN Form BSb]: SAW-2023-01217
7. Project Location - Coordinates, Street Address, and/or Location Description [PCN Form 131b]:
11006 Mt Holly-Huntersville Rd Huntersville, NC 28078
35.3727970 /-80.8544230
8. Project Location - Tax Parcel ID [PCN Form 131a]: 01704221 and 01704217 (partial)
9. Project Location — County [PCN Form A2b]: Mecklenburg
10. Project Location — Nearest Municipality or Town [PCN Form A2c]: Huntersville
11. Project Information — Nearest Waterbody [PCN Form 132a]: Dixon Branch, Class: C, Stream Index: 11-120-1
12. Watershed / 8-Digit Hydrologic Unit Code [PCN Form 132c]: Upper Catawba 03050101
Authorization: Section 10 ❑ Section 404
Regulatory Action Type:
❑Standard Permit
✓ Nationwide Permit # 18
❑ Regional General Permit #
❑ Jurisdictional Determination Request
❑✓ Section 10 & 404 ❑
❑Pre -Application Request
Unauthorized Activity
0 Compliance
❑ No Permit Required
Revised 20150602

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■•NVIENTAL
November 9, 2023
US Army Corps of Engineers NC Division of Water Resources
Charlotte Regulatory Field Office 401 and Buffer Permitting Unit
Attn: Doug Perez Attn: Stephanie Goss
8430 University Executive Park Drive, Suite 615 1617 Mail Service Center
Charlotte, North Carolina 28262 Raleigh, North Carolina 27699-1617
Re: Strickland- - 26.721 Acres
11006 Mt Holly-Huntersville Rd Huntersville, NC 28078
Nationwide Permit 18 Verification Request
Corps Action I D: SAW-2023-0920 / DWR Project #: unknown
Doug and Stephanie:
Atlas Environmental, Inc. (Atlas) is submitting the enclosed Nationwide Permit 18 verification
request package on behalf of the applicant, Kevin Dagenhart of SunCap Properties, for
unavoidable impacts to potential Waters of the United States at the Mt. Holly - Huntersville
Road Warehouse (Strickland) project review area. Atlas staff was onsite May 11, 2023 and
assessed the presence of one intermittent stream and two wetlands. Chanel CH 100 flows on
and off property at the Eastern boundary for approximately 612 linear feet (0.041 acres).
Wetland WL 1000 abuts CH 100 and is approximately 0.129 acre. Wetland 2000 is located
near the Southwestern boundary and is approximately 0.084 acre. Atlas conducted site
meetings with both agencies in July 2023.
The project's purpose is for the construction of an industrial building with 299,700 square feet
under roof with associated driveways, employee/vendor parking areas, trailer parking areas,
truck court, utilities, and additional infrastructure. No stream impacts are proposed for the
development. No impacts are proposed to WL 1000 which abuts CH 100. One avoidable
wetland impact is proposed as Impact W1 to WL 2000 as 0.084 acre of permanent fill. This
impact is required to provide road circulation around the building and grading in the Southern
end of the employee/vendor parking lot. The total area of wetland impact requested under
Nationwide Permit 18 is 0.084 acre. The amount of fill within WL 2000 is approximately 3.55
cubic yards.
The project has been designed and engineered to avoid and minimize impacts to the greatest
extent possible. Additional property was purchased to accommodate the circumference road
around the building to provide two access points to the back of the building and to both ends of
the employee parking lot - an access road at the North end of the building and an access road
at the South end of the building. Over 60% of wetlands and 100% of stream have been avoided
and remain undisturbed.
Wetland impacts necessary for development total less than 0.099 acre. No wetland mitigation is
proposed since impacts are minimal and below North Carolina Division of Water Resources and
United States Army Corps of Engineers mitigation thresholds. Two stormwater ponds will be
constructed to ensure that post development stormwater runoff does not exceed
predevelopment stormwater runoff. Forebays are included in both ponds to treat the first flush
ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

i
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of stormwater entering the control measure. Additionally, a ten -foot -wide vegetative shelf will be
planted around both ponds. The vegetation will help filter stormwater runoff absorb any
contaminants. The outlet structures for both ponds will be set at less than 0.7% slope which will
help ensure long term bank stabilization of the receiving waters (CH 100).
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,
�• ,
Jennifer L Robertson
[e-mail]
ATLAS Environmental, Inc.
338 S Sharon Amity #411, Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
www.atlasenvi.com / Offices in Asheville and Charlotte

/��� i
�,
WMba71-_t�oil
AGENT AUTHORIZATION FORM
U.S. Army Corps of Engineers, Wilmington District
Attn: Tommy Fennel, Chief, Regulatory Division
PO Box 1890
Wilmington, North Carolina 28402-1890
-and-
NC Division of Water Resources, Water Quality Program
Wetlands, Buffers, Streams — Compliance and Permitting Unit
Attn: Stephanie Goss, Supervisor
1617 Mail Service Center
Raleigh, North Carolina 27699-1650
I, the current landowner, lessee, contract holder to purchase, right to purchase holder, or easement
holder of the property/properties identified below, hereby authorize Atlas Environmental Inc to act on my
behalf as my agent during the processing of permits to impact Wetlands and Waters of the US that are
regulated by the Clean Water Act and the Rivers and Harbors Act. Federal and State agents are
authorized to be on said property when accompanied by Atlas Environmental Inc staff for the purpose of
conducting on -site investigations and issuing a determination associated with Waters of the US subject to
Federal jurisdiction under Section 404 of the Clean Water Act and/or Section 10 of the Rivers and Harbors
Act of 1899 and Waters of the State including 404 Wetlands, Isolated Wetlands, and other non-404
Wetlands subject to a permitting program administered by the State of North Carolina. Atlas
Environmental Inc is authorized to provide supplemental information needed for delineation approval
and/or permit processing at the request of the Corps or NC DWR Water Quality Program.
Project Name: Strickland
Property Owner of Record: Randy C. Strickland
Contact Name:
Adam Essink
Address:
6101 Carnegie Blvd
Address:
Charlotte, NC 28209
Phone/Fax Number:
Email Address:
[e-mail]
Project Address:
11006 Mt. Holly Huntersville
Project Address:
Huntersville, NC
017-042-21
Tax PIN:
A 6�wc_
Signature:
Date:
5/25/2023
ATLAS Environmental Inc.
338 S. Sharon Amity Road, #411
Charlotte, North Carolina 28211
704-512-1206 (o) / 828-712-9205 (m)
[e-mail]
www.atlasenvi.com

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513180
35° 22' 30" N
35° 22' 10" N
513180 513250 513320 513390 513460
Map Scale: 1:3,050 if printed on A portrait (8.5" x 11") sheet.
Meters
N
0 45 90 180 270
Feet
0 100 200 400 600
k Map projection: Web Mercator Comer coordinates: WGS84 Edge tics: UiM Zone 17N WGS84
L!si):, Natural Resources Web Soil Survey
Conservation Service National Cooperative Soil Survey
Soil Map —Mecklenburg County, North Carolina
(Strickland)
513250 51332D 513390 513460
mawA"
"-�ENVIHUN MENTAL
MIGNI?I1
656LI?I]
o
513600
35° 22'30"N
35° 22'10"N
513600
5/10/2023
Page 1 of 3

Soil Map —Mecklenburg County, North Carolina
(Strickland)
MAPLEGEND
MAP INFORMATION
Area of Interest (A°I)
Spoil Area
The soil surveys that comprise your AOI were mapped at
0
Area of Interest (AOI)
Stony Spot
1 :24,000.
Soils
Very Stony Spot
Warning: Soil Map may not be valid at this scale.
0
Soil Map Unit Polygons
Wet spot
Enlargement of maps beyond the scale of mapping can cause
,y
Soil Map Unit Lines
misunderstanding of the detail of mapping and accuracy of soil
Other
line placement. The maps do not show the small areas of
Soil Map Unit Points
�
Special Line Features
contrasting soils that could have been shown at a more detailed
Special
Point Features
scale.
U
Blowout
Water Features
Streams and Canals
Please rely on the bar scale on each map sheet for map
Borrow Pit
measurements.
Transportation
Clay Spot
444
Rails
Source of Map: Natural Resources Conservation Service
0
Closed Depression
Web Soil Survey URL:
�y
Interstate Highways
Coordinate System: Web Mercator (EPSG:3857)
Gravel Pit
rr/
US Routes
Maps from the Web Soil Survey are based on the Web Mercator
Gravelly Spot
^y
r }
Major Roads
projection, which preserves direction and shape but distorts
distance and area. A projection that preserves area, such as the
Landfill
Yv
Local Roads
Albers equal-area conic projection, should be used if more
pp
Lava Flow
accurate calculations of distance or area are required.
Il
Background
Marsh or swamp
.
Aerial Photography
This product is generated from the USDA-NRCS certified data as
of the version date(s) listed below.
s
Mine or Quarry
Soil Survey Area: Mecklenburg County, North Carolina
Miscellaneous water
Survey Area Data: Version 22, Sep 12, 2022
0
Perennial water
Soil map units are labeled (as space allows) for map scales
1W
Rock Outcrop
1:50,000 or larger.
Saline Spot
Date(s) aerial images were photographed: Mar 13, 2022—May
9, 2022
Sandy Spot
The orthophoto or other base map on which the soil lines were
.g;,
Severely Eroded Spot
compiled and digitized probably differs from the background
imagery displayed on these maps. As a result, some minor
Sinkhole
shifting of map unit boundaries may be evident.
Slide or Slip
oa
Sodic Spot
usDA Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
Project Name: Strickland
5/10/2023
Page 2 of 3
Location:11006 Mt Hollv-Huntersville Rd Huntersville, NC 28078
RONMENTAL
re: 13b
For: SunCap Properties Attn: Kevin Dagenhart
Coordinates: 35.3727970/-80.8544230 Date: May 10, 2023

Soil Map —Mecklenburg County, North Carolina
Strickland
Map Unit Legend
Map Unit Symbol
Map Unit Name
Acres in AOI
Percent of AOI
HeB
Helena sandy loam, 2 to 8
percent slopes
19.3
73.3%
MO
Monacan loam, 0 to 2 percent
slopes, frequently flooded
0.3
1.1 %
VaB
Vance sandy loam, 2 to 8
percent slopes
0.1
0.2%
VaD
Vance sandy loam, 8 to 15
percent slopes
6.7
25.3%
Totals for Area of Interest
26.3
100.0%
USDA Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
Project Name: Strickland
5/10/2023
Page 3 of 3
Location:11006 Mt Hollv-Huntersville Rd Huntersville, NC 28078
ONMENTAL
Figure: 13c
For: SunCap Properties Attn: Kevin Dagenhart
Coordinates: 35.3727970/-80.8544230 I Date: May 10, 2023

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DEPARTMENT OF THE ARMY
U.S. ARMY CORPS OF ENGINEERS, WILMINGTON DISTRICT
CHARLOTTE REGULATORY OFFICE
8430 UNIVERSITY EXECUTIVE PARK DRIVE, SUITE 615
CHARLOTTE NORTH CAROLINA 28262
August 28, 2023
Regulatory Program/Division
Kevin Dagenhart
SunCap Properties
6101 Carnegie Blvd.
Suite 180
Charlotte, NC 28209
Via Email: [e-mail]
Dear Mr. Dagenhart:
This letter is in response to your request to the Wilmington District, Charlotte
Regulatory Office for a preliminary jurisdictional determination (PJD). The project/review
area is located on the E side of Mt. Holly-Huntersville Road, 11006 Mt. Holly-
Huntersville Road, at Latitude 35.372797 and Longitude-80.854423-1 in Huntersville,
Mecklenburg County, North Carolina. The review area for this determination is limited to
an approximately 26.721-acres area comprised of 2 parcels (parcel numbers: 01704221
and 01704217 (partial)), which is illustrated on the enclosed site maps. This project has
been assigned the file number SAW-2023-01217 (Strickland). This file number should
be referenced in all correspondence concerning this project.
Based on our review of the information you furnished, a site inspection conducted on
July 12, 2023, and other information available to our office, we have preliminarily
determined the above -referenced area may contain approximately 612 linear feet of
non -wetland waters and 0.213-acre of waters of the United States under the U.S. Army
Corps of Engineers (Corps) regulatory jurisdiction. These waters are identified in the
enclosed site maps, "Aquatic Resources Sketch Map" dated May 12, 2023. This
determination was made in accordance with the Corps regulatory authority pursuant to
Section 404 of the Clean Water Act, and based upon criteria/ contained in the 1987
Corps of Engineers Wetland Delineation Manual and the Eastern Mountains and
Piedmont regional supplement.
Section 404 of the Clean Water Act requires a Department of the Army (DA) permit
be obtained prior to the discharge of dredged or fill material into waters of the United
States, including wetlands. Section 10 of the Rivers and Harbors Act of 1899 requires a
DA permit be obtained for any work in, on, over or under navigable waters of the United
States.

For purposes of computation of impacts, compensatory mitigation requirements, and
other resource protection measures, a permit decision made based on a preliminary
jurisdictional determination will treat all waters including wetlands that would be affected
in any way by the permitted activity on the site as if they are jurisdictional waters of the
U.S. This preliminary determination is not an appealable action under the Regulatory
Program Administrative Appeal Process (Reference 33 CFR Part 331). However, you
may request an approved jurisdictional determination, which is an appealable action, by
contacting the Corps district for further instructions. Please sign and return the
attached PJD form within 30 days of receipt. If a signed PJD form is not received within
30 days of the date of this letter, the Corps will presume concurrence.
This determination has been conducted to identify the limits of Corps' Clean Water
Act jurisdiction for the review area identified in this request. The determination may not
be valid for the wetland conservation provisions of the Food Security Act of 1985. If you
or your tenant are USDA Program participants, or anticipate participation in USDA
programs, you should request a certified wetland determination from the local office of
the Natural Resources Conservation Service, prior to starting work.
You are cautioned that work performed in areas which may be waters of the United
States, as indicated in the preliminary JD, without a Department of the Army permit
could subject you to enforcement action.
If you have any questions concerning this correspondence, please contact Doug
Perez, Biologist -Regulatory Specialist of the Charlotte Regulatory Office at (704) 510-
1439, by mail at the above address, or by email at [e-mail].
Please take a moment to complete our customer satisfaction survey located at
http-//corpsmapu.usace.army.mit/cm_apex/f?p=136.4.0.
Sincerely,
�B �eAz
Doug Perez
Biologist -Regulatory Specialist
Enclosures
cc: Jennifer Robertson Atlas Environmental (via [e-mail])

PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM
BACKGROUND INFORMATION
A. REPORT COMPLETION DATE FOR PJD: 8/28/2023
B. NAME AND ADDRESS OF PERSON REQUESTING PJD: Kevin Dagenhart, 6101 Carnegie Blvd. Suite 180,
Charlotte, NC 28209
C. DISTRICT OFFICE, FILE NAME, AND NUMBER: Wilmington, Strickland, SAW-2023-01217
D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION The project/review area is located on the E side
of Mt. Holly-Huntersville Road, 11006 Mt. Holly-Huntersville Road.
(USE THE TABLE BELOW TO DOCUMENT MULTIPLE AQUATIC RESOURCES AND/OR AQUATIC
RESOURCES AT DIFFERENT SITES)
State: North Carolina County: Mecklenburg City: Huntersville
Center coordinates of site (lat/long in degree decimal format): Latitude: 35.372797 Longitude:-80.854423
Universal Transverse Mercator:
Name of nearest waterbody: Dixon Branch
E. REVIEW PERFORMED FOR SITE EVALUATION (CHECKALL THAT APPLY):
❑ Office (Desk) Determination. Date:
® Field Determination. Date(s): 7/12/2023
TABLE OF AQUATIC RESOURCES INREVIEW AREA WHICH "MAY BE" SUBJECT TO REGULATORY
JURISDICTION
Site Number
Latitude
Longitude
Estimated
Type of aquatic
Geographic authority to
(decimal
(decimal degrees)
amount of
resources (i.e.,
which the aquatic
degrees)
aquatic
wetland vs. non-
resource "may be"
resources in
wetland waters)
subject (i.e., Section 404
review area
or Section 10/404)
(acreage and
linear feet, if
applicable
Non -wetland
CH 100
35.3716
-80.8509
612 FEET
Waters
Section 404
WL 1000
35.37205
-80.8512
.129 ACRES
Wetland
Section 404
WL 2000
35.37068
-80.8529
.084 ACRES
Wetland
Section 404

I . The Corps of Engineers believes that there may be jurisdictional aquatic resources in the review area, and
the requestor of this PJD is hereby advised of his or her option to request and obtain an approved JD
(AJD) for that review area based on an informed decision after having discussed the various types of JDs
and their characteristics and circumstances when they may be appropriate.
2. In any circumstance where a permit applicant obtains an individual permit, or a Nationwide General
Permit (NWP) or other general permit verification requiring "pre- construction notification" (PCN), or
requests verification for a non -reporting NWP or other general permit, and the permit applicant has not
requested an AJD for the activity, the permit applicant is hereby made aware that: (1) the permit applicant
has elected to seek a permit authorization based on a PJD, which does not make an official determination
of jurisdictional aquatic resources; (2) the applicant has the option to request an AJD before accepting the
terms and conditions of the permit authorization, and that basing a permit authorization on an AJD could
possibly result in less compensatory mitigation being required or different special conditions; (3) the
applicant has the right to request an individual permit rather than accepting the terms and conditions of the
NWP or other general permit authorization; (4) the applicant can accept a permit authorization and
thereby agree to comply with all the terms and conditions of that permit, including whatever mitigation
requirements the Corps has determined to be necessary; (5) undertaking any activity in reliance upon the
subject permit authorization without requesting an AJD constitutes the applicant's acceptance of the use of
the PJD; (6) accepting a permit authorization (e.g., signing a proffered individual permit) or undertaking
any activity in reliance on any form of Corps permit authorization based on a PJD constitutes agreement
that all aquatic resources in the review area affected in any way by that activity will be treated as
jurisdictional, and waives any challenge to such jurisdiction in any administrative or judicial compliance
or enforcement action, or in any administrative appeal or in any Federal court; and (7) whether the
applicant elects to use either an AJD or a PJD, the JD will be processed as soon as practicable. Further,
an AJD, a proffered individual permit (and all terms and conditions contained therein), or individual
permit denial can be administratively appealed pursuant to 33 C.F.R. Part 331. If, during an
administrative appeal, it becomes appropriate to make an official determination whether geographic
jurisdiction exists over aquatic resources in the review area, or to provide an official delineation of
jurisdictional aquatic resources in the review area, the Corps will provide an AJD to accomplish that
result, as soon as is practicable. This PJD finds that there "may be" waters of the U.S. and/or that there
"may be" navigable waters of the U.S. on the subject review area, and identifies all aquatic features in the
review area that could be affected by the proposed activity, based on the following information:

SUPPORTING DATA. Data reviewed for PJD (check all that apply) Checked items are included in the administrative record
and are appropriately cited:
®Maps, plans, plots, or plat submitted by or on behalf of the PJD requestor:
Map: "Aquatic Resources Sketch Map" dated 5/12/2023, Topo, USGS Topo, LiDAR, WSS, NWI, NHD, HUC 12 & 8, Aerials,
and Parcel Map
®Data sheets prepared/submitted by or on behalf of the PJD requestor. Datasheets: NCDWR Stream Data Forms & USACE
Wetland Determination Data Sheets dated 5/24/2023
❑ Office concurs with data sheets/delineation report.
❑ Office does not concur with data sheets/delineation report. Rationale:
❑ Data sheets prepared by the Corps:
❑ Corps navigable waters' study: CORPS STUDY LABEL dated CORPS STUDY DATE
NU.S. Geological Survey Hydrologic Atlas:
®USGS NHD data: National Hydrogrraphic Dataset dated 5/10/2023
®USGS 8 and 12 digit HUC maps: HUC 12 & 8 Watersheds dated 5/10/2023
® U. S. Geological Survey map(s). Cite scale & quad name: 1:24,000 Derita dated 5/10/2023
®Natural Resources Conservation Service Soil Survey. Citation: GIS Database dated 5/10/2023
® National wetlands inventory map(s). Cite name: GI S Database dated 5/10/2023
❑ State/local wetland inventory map(s): GIS Database dated LOCAL NWI DATE
® FENIA&IRM maps: Google Earth FEMA Tool dated 5/10/2023
❑ 100-year Floodplain Elevation is: ELEVATION (National Geodetic Vertical Datum of 1929)
FLOOD ELEVATION LABEL dated FLOOD ELEVATION DATE
® Photographs: ® Aerial (Name & Date): NC OneMap Aerial Imagery dated 2019
or ® Other (Name & Date): Site Photographs dated 5/11/2023
❑Previous determination(s). File no. and date of response letter: PREVIOUS DETERMINATION LABEL dated
PREVIOUS DETERMINATION DATE
❑ Other information (please specify):
OTHER INFORMATION LABEL dated OTHER INFORMATION DATE
IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corps and
should not be relied upon for later iurisdictional determinations.
9
Signature and date KRegulatoyy
staff member completing PJD
Doug Perez
8/28/2023
Signature and date of person requesting
PJD (REQUIRED, unless obtaining
the signature is impracticable)'
1 Districts may establish timeframes for requester to return signed PJD forms. If the requester does not respond within the established time frame, the
district may presume concurrence and no additional follow up is necessary prior to finalizing an action.

NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND
REQUEST FOR APPEAL
Applicant:
Kevin Da enhart, SunCap Pro erties
File Number: SAW-2023-01217
Date: 8/28/2023
Attached is:
See Section below
❑
INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission)
A
❑
PROFFERED PERMIT (Standard Permit or Letter of permission)
B
❑
PERMIT DENIAL WITHOUT PREJUDICE
C
❑
PERMIT DENIAL WITH PREJUDICE
D
❑
APPROVED JURISDICTIONAL DETERMINATION
E
❑x
PRELIMINARY JURISDICTIONAL DETERMINATION
F
SECTION I
The following identifies your rights and options regarding an administrative appeal of the above decision.
Additional information may be found at https://www.usace.army.miI/Missions/Civil-Works/Regulatory-
Program-and-Permits/appeals/
or Corps regulations at 33 CFR Part 331.
A:
INITIAL PROFFERED PERMIT: You may accept or object to the permit
•
ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the
district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the
LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP
means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its
terms and conditions, and approved jurisdictional determinations associated with the permit.
•
OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein,
you may request that the permit be modified accordingly. You must complete Section II of this form and
return the form to the district engineer. Upon receipt of your letter, the district engineer will evaluate your
objections and may: (a) modify the permit to address all of your concerns, (b) modify the permit to
address some of your objections, or (c) not modify the permit having determined that the permit should
be issued as previously written. After evaluating your objections, the district engineer will send you a
proffered permit for your reconsideration, as indicated in Section B below.
B:
PROFFERED PERMIT: You may accept or appeal the permit
•
ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the
district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the
LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP
means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its
terms and conditions, and approved jurisdictional determinations associated with the permit.
•
APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and
conditions therein, you may appeal the declined permit under the Corps of Engineers Administrative
Appeal Process by completing Section II of this form and sending the form to the division engineer. This
form must be received by the division engineer within 60 days of the date of this notice.
in

C. PERMIT DENIAL WITHOUT PREJUDICE: Not appealable
You received a permit denial without prejudice because a required Federal, state, and/or local authorization
and/or certification has been denied for activities which also require a Department of the Army permit before
final action has been taken on the Army permit application. The permit denial without prejudice is not
appealable. There is no prejudice to the right of the applicant to reinstate processing of the Army permit
application if subsequent approval is received from the appropriate Federal, state, and/or local agency on a
previously denied authorization and/or certification.
D: PERMIT DENIAL WITH PREJUDICE: You may appeal the permit denial
You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by
completing Section II of this form and sending the form to the division engineer. This form must be received
by the division engineer within 60 days of the date of this notice.
E: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or
provide new information for reconsideration
• ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps
within 60 days of the date of this notice means that you accept the approved JD in its entirety and waive
all rights to appeal the approved JD.
• APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of
Engineers Administrative Appeal Process by completing Section II of this form and sending the form to
the division engineer. This form must be received by the division engineer within 60 days of the date of
this notice.
• RECONSIDERATION: You may request that the district engineer reconsider the approved JD by
submitting new information or data to the district engineer within 60 days of the date of this notice. The
district will determine whether the information submitted qualifies as new information or data that justifies
reconsideration of the approved JD. A reconsideration request does not initiate the appeal process. You
may submit a request for appeal to the division engineer to preserve your appeal rights while the district
is determining whether the submitted information qualifies for a reconsideration.
F: PRELIMINARY JURISDICTIONAL DETERMINATION: Not appealable
You do not need to respond to the Corps regarding the preliminary JD. The Preliminary JD is not
appealable. If you wish, you may request an approved JD (which may be appealed), by contacting the
Corps district for further instruction. Also, you may provide new information for further consideration by the
Corps to reevaluate the JD.
POINT OF CONTACT FOR QUESTIONS OR INFORMATION:
If you have questions regarding this decision you
If you have questions regarding the appeal process, or
may contact:
to submit your request for appeal, you may contact:
District Engineer, Wilmington Regulatory Division
Philip Shannin
Attn: Doug Perez
Regulatory Administrative Appeal Review Officer
Wilmington District U.S. Army Corps of Engineers
U.S. Army Corps of Engineers
8430 University Executive Park Drive, Suite 615
South Atlantic Division
Charlotte, North Carolina 28262
60 Forsyth Street, Room M9
Atlanta, Georgia 30303-8801
Phone: [phone]
Email: [e-mail]
-7-

SECTION II — REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT
REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your
objections to an initial proffered permit in clear concise statements. Use additional pages as necessary. You
may attach additional information to this form to clarify where your reasons or objections are addressed in
the administrative record.)
ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps
memorandum for the record of the appeal conference or meeting, and any supplemental information that the
review officer has determined is needed to clarify the administrative record. Neither the appellant nor the
Corps may add new information or analyses to the record. However, you may provide additional information
to clarify the location of information that is already in the administrative record.
RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any
government consultants, to conduct investigations of the project site during the course of the appeal
process. You will be provided a 15-day notice of any site investigation and will have the opportunity to
participate in all site investigations.
in

Signature of appellant or agent.
Date:
Email address of appellant and/or agent:
Telephone number:
in

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QPP�MENT OF FISH&WILDLIFE
SERVICE
United States Department of the Interior
o
FISH AND WILDLIFE SERVICE
�9RCH 3,�$a9 Asheville Field Office
160 Zillicoa Street Suite B
Asheville, North Carolina 28801
July 26, 2023
Mr. David Rabon
Atlas Environmental, Inc.
338 S. Sharon Amity Road, 9411
Charlotte, North Carolina 28211
Subject: Strickland Industrial Development in Huntersville, Mecklenburg County, North Carolina.
Dear Mr. Rabon:
On June 1, 2023, we received (via email) your information requesting our review of the subject project.
We originally provided comments for this project on July 17, 2023. This current request includes
modification to conservation measures associated with the project. We have reviewed the information that
you presented for this request and the following comments are provided in accordance with the provisions
of the National Environmental Policy Act (42 U.S.C.§ 4321 et seq.) and section 7 of the Endangered
Species Act of 1973, as amended (16 U.S.C. 1531 - 1543) (Act). This letter supersedes the letter dated
July 17, 2023
Proiect Description
According to the information provided, SunCap Properties proposes to construct an industrial
development and associated infrastructure on approximately 26.7 acres at 11006 Mt. Holly-Huntersville
Road in Huntersville, Mecklenburg County, North Carolina.
Federally Listed Species
An assessment of suitable habitat and potential impacts to five species was conducted by environmental
specialist with Atlas Environmental, Inc. on May 11 and 26, 2023. The findings were compiled and
included in the review request submitted to our office on June 1, 2023. The following species and their
associated habitats were evaluated.
Species
Status'
Michaux's sumac
Rhus michauxii
E
Monarch
Danaus plexippus
CAN
Schweinitz's sunflower
Helianthus schweinitzii
E
Smooth coneflower
Echinacea laevigata
T
Tricolored bat
Perimyotis subflavus
PE
'E = endangered, PE = proposed endangered, T = threatened, and
CAN = candidate species.
The review request states that no suitable habitats are present for Michaux's sumac, Schweinitz's
sunflower, or smooth coneflower. Based on the information and photographs provided, we agree with the

assessment that no suitable habitats are present for these species. Should the lead federal action agency
make "no effect" determinations for these species, consultation is not required
Monarch butterfly is a candidate species, and we appreciate the project proponent Is consideration of
monarch butterfly when evaluating the action area for impacts to federally listed species and their
habitats. The species is not subject to section 7 consultation, and an effects determination is not necessary.
General recommendations for pollinators can be provided and would be protective of monarch butterfly
should the project proponent like to implement them in the future.
Suitable habitat for tricolored bat may be present at the site. On September 14, 2022, the Service
published a proposal in the Federal Register to list the tricolored bat as endangered under the Act. The
Service has up to 12 months from the date the proposal published to make a final determination, either to
list the tricolored bat under the Act or to withdraw the proposal. Species proposed for listing are not
afforded protection under the Act; however, as soon as a listing becomes effective (typically 30 days after
publication of the final rule in the Federal Register), the prohibitions against jeopardizing its continued
existence and "take" will apply. Therefore, if you suspect your future or existing project may affect
tricolored bats after the potential new listing goes into effect, we recommend analyzing possible effects of
the project on tricolored bats and their habitat to determine whether consultation under section 7 of the
Act is necessary. Conferencing procedures can be followed prior to listing to ensure the project does not
jeopardize the existence of a species. Projects with an existing section 7 biological opinion may require
re -initiation of consultation to provide uninterrupted authorization for covered activities. Please contact
our office for additional guidance or assistance.
We believe the requirements under section 7 of the Act are fulfilled for the federally listed species
discussed above. However, obligations under section 7 of the Act must be reconsidered if (1) new
information reveals impacts of the identified action may affect listed species or critical habitat in a
manner not previously considered, (2) the identified action is subsequently modified in a manner that was
not considered in this review, or (3) a new species is listed, or critical habitat is determined that may be
affected by the identified action.
Fish and Wildlife Resource Recommendations
We offer the following general recommendations for the benefit of fish and wildlife resources:
Equipment Use in Riparian Areas and In -Stream. Equipment should be operated from the
streambank. If in -stream work is necessary, stone causeways, work bridges, or mats (designed for
the specific location and type of equipment) should be used. Work pads on streambanks or
approaches to in -stream work areas should minimize disturbance to woody vegetation. Equipment
operated in riparian areas and in/near aquatic resources should be inspected daily and maintained
regularly to prevent contamination of surface waters from leaking fuels, lubricants, hydraulic
fluids, or other toxic materials. Construction staging, toxic material storage, and equipment
maintenance, including refueling, should occur outside of the riparian area. The project proponent
should report any toxic material spills in riparian areas and/or aquatic resources to the Service
within 24 hours.
Erosion and Sedimentation Control. Construction activities near aquatic resources, streams,
and wetlands have the potential to cause bank destabilization, water pollution, and water quality
degradation if measures to control site runoff are not properly installed and maintained. In order
to effectively reduce erosion and sedimentation impacts, best management practices specific to
the extent and type of construction should be designed and installed prior to land -disturbing
activities and should be maintained throughout construction. Natural fiber matting (coir) should
be used for erosion control as synthetic netting can trap animals and persists in the environment

beyond its intended purpose. Land disturbance should be limited to what can be stabilized
quickly, preferably by the end of the workday. Once construction is complete, disturbed areas
should be revegetated with native riparian grass and tree species as soon as possible. For
maximum benefits to water quality and bank stabilization, riparian areas should be forested;
however, if the areas are maintained in grass, they should not be mowed. The Service can provide
information on potential sources of plant material upon request.
A complete design manual that is consistent with the requirements of the North Carolina
Sedimentation and Pollution Control Act and Administrative Rules, can be found at the following
website: https:lldeq.nc.govlabout/divisions/energy-mineral-land-resources.
Impervious Surfaces/Stormwater/Low Impact Development (LID). Increased development
contributes to the increased quantity and decreased quality of stormwater entering project area
waterways. Additionally, increased development outside the floodplain increases stormwater
flows already caused by the lack of or loss of riparian buffers and floodplain development. Recent
studies' have shown that areas of 10 percent to 20 percent impervious surface (such as roofs,
roads, and parking lots) double the amount of stormwater runoff compared to natural cover and
decrease deep infiltration (groundwater recharge) by 16 percent. At 35 — 50 percent impervious
surface, runoff triples, and deep infiltration is decreased by 40 percent. Above 75 percent
impervious surface, runoff is 5.5 times higher than natural cover, and deep infiltration is
decreased by 80 percent. Additionally, the adequate treatment of stormwater at project sites is
essential for the protection of water quality and aquatic habitat. Impervious surfaces also collect
pathogens, metals, sediment, and chemical pollutants and quickly transmit them (via stormwater
runoff) to receiving waters. According to the Environmental Protection Agency, this
nonpoint-source pollution is one of the major threats to water quality in the United States, posing
one of the greatest threats to aquatic life, and is also linked to chronic and acute illnesses in
human populations from exposure through drinking water and contact recreational.
Increased stormwater runoff also directly damages aquatic and riparian habitat, causing
streambank and stream channel scouring. Additionally, impervious surfaces reduce groundwater
recharge, resulting in even lower than expected stream flows during drought periods, which can
induce potentially catastrophic effects for fish, mussels, and other aquatic life. To avoid any
additional impacts to habitat quality within the watershed, we recommend that all new
developments, regardless of the percentage of impervious surface area created, implement
stormwater retention and treatment measures designed to replicate and maintain the hydrograph at
the preconstruction condition.
We recommend the use of low impact development techniques,2 such as reduced road widths,
grassed swales in place of curb and gutter, rain gardens, and wetland retention areas, for retaining
and treating stormwater runoff rather than the more traditional measures, such as large retention
ponds, etc. These designs often cost less to install and significantly reduce environmental impacts
from development.
'Federal Interagency Stream Restoration Working Group (15 federal agencies of the United States Government).
Published October 1998, Revised August 2001. Stream Corridor Restoration: Principles, Processes, and Practices.
GPO Item No. 0120-A; SuDocs No. A 57.6/2: EN 3/PT.653. ISBN-0-934213-59-3.
2We recommend visiting the Environmental Protection Agency's Web site (ht62://www.fga.goL/polluted-runoff-
nonpoint-sourcepollution/urban-runo(f--low-impact-development) for additional information and fact sheets
regarding the implementation of low -impact -development techniques.

Where detention ponds are used, stormwater outlets should drain through a vegetated area prior to
reaching any natural stream or wetland area. Detention structures should be designed to allow for
the slow discharge of stormwater, attenuating the potential adverse effects of stormwater surges;
thermal spikes; and sediment, nutrient, and chemical discharges. Also, because the purpose of
stormwater control measures is to protect streams and wetlands, no stormwater control measures
or best management practices should be installed within any stream (perennial or intermittent) or
wetland.
We also recommend that consideration be given to the use of pervious materials (i.e., pervious
concrete, interlocking/open paving blocks, etc.) for the construction of roads, driveways,
sidewalks, etc. Pervious surfaces minimize changes to the hydrology of the watershed and can be
used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and store
heat and allow the cooler soil below to cool the pavement. Additionally, pervious concrete
requires less maintenance and is less susceptible to freeze/thaw cracking due to large voids within
the concrete.
Use of any of the proposed stormwater collection devices described above will dramatically
decrease the quantity and increase the quality of stormwater runoff.
Stream Buffers. Natural, forested riparian buffers are critical to the health of aquatic ecosystems.
They accomplish the following:
o Catch and filter runoff, thereby helping to prevent nonpoint-source pollutants from
reaching streams.
o Enhance the in -stream processing of both point- and nonpoint-source pollutants.
o Act as "sponges" by absorbing runoff (which reduces the severity of floods) and by
allowing runoff to infiltrate and recharge groundwater levels (which maintains stream
flows during dry periods).
o Catch and help prevent excess woody debris from entering the stream and creating
logjams.
o Stabilize stream banks and maintain natural channel morphology.
o Provide coarse woody debris for habitat structure and most of the dissolved organic
carbon and other nutrients necessary for the aquatic food web.
o Maintain air and water temperatures around the stream.
Forested riparian buffers (a minimum 50 feet wide along intermittent streams and 100 feet wide
along perennial streams [or the full extent of the 100-year floodplain, whichever is greater])
should be created and/or maintained adjacent to all aquatic areas. Within the watersheds
supporting federally listed aquatic species, we recommend undisturbed, forested buffers that are
naturally vegetated with trees, shrubs, and herbaceous vegetation. These buffers should extend a
minimum of 200 feet from the banks of all perennial streams and a minimum of 100 feet from
the banks of all intermittent streams (or the full extent of the 100-year floodplain, whichever is
greater.) Impervious surfaces, ditches, pipes, roads, utility lines (sewer, water, gas, transmission,
etc.), and other infrastructure that requires maintenance, cleared rights -of -way and/or compromise
the functions and values of the forested buffers should not occur within these riparian areas.
Stream Crossings. Bridges or spanning structures should be used for all permanent roadway
crossings of streams and associated wetlands. Structures should span the channel and the
floodplain in order to minimize impacts to aquatic resources, allow for the movement of aquatic
and terrestrial organisms, and eliminate the need to place fill in streams, wetlands, and
floodplains.
4

Bridges should be designed and constructed so that no piers or bents are placed in the stream,
approaches and abutments do not constrict the stream channel, and the crossing is perpendicular
to the stream. Spanning some or all of the floodplain allows stream access to the floodplain,
dissipates energy during high flows, and provides terrestrial wildlife passage. When bank
stabilization is necessary, we recommend that the use of riprap be minimized and that a
riprap-free buffer zone be maintained under the bridge to allow for wildlife movement. If fill in
the floodplain is necessary, floodplain culverts should be added through the fill to allow the
stream access to the floodplain during high flows.
If bridges are not possible and culverts are the only option, we suggest using bottomless culverts.
Bottomless culverts preserve the natural stream substrate, create less disturbance during
construction, and provide a more natural post -construction channel. Culverts should be of
sufficient size to leave natural stream functions and habitats at the crossing site unimpeded.
Culvert installation and presence should not change water depth, volume (flow), or velocity levels
that permit aquatic organism passage; and accommodate the movement of debris and bed material
during bankfull events. Widening the stream channel must be avoided.
• Utility Line Crossings. In the interest of reducing impacts to natural resources, utility crossings
(i.e., sewer, gas, and water lines) should be kept to a minimum, and all utility infrastructure
(including manholes) should be kept out of riparian buffer areas. If a utility crossing is necessary,
we recommend that you first consider the use of directional boring. Directional boring under
streams significantly minimizes impacts to aquatic resources and riparian buffers.
If directional boring cannot be used and trenching is determined to be the only viable method,
every effort should be made to ensure that impacts to in -stream features are minimized and
stabilized upon completion of the project. Our past experiences with open -trench crossings
indicate that this technique increases the likelihood for future lateral movement of the stream
(which could undercut or erode around the utility line), and the correction of such problems could
result in costly future maintenance and devastating impacts to natural resources. Therefore, as
much work as possible should be accomplished in the dry, and the amount of disturbance should
not exceed what can be successfully stabilized by the end of the workday. In -stream work should
avoid the spring fish spawning season and should consider forecasted high flow events.
Regardless of the crossing method, all utility lines should cross streams perpendicularly. We
strongly encourage that a qualified biologist monitor the work area until the work is complete in
order to identify any additional impact -minimization measures. The Service may be available to
assist you in this effort.
To determine if any maintenance is required, the work site should be monitored at least every 3
months during the first 24 months and annually thereafter. Moreover, we recommend the
development of a riparian monitoring and maintenance program that would outline procedures for
the prompt stabilization of streambanks near the utility crossing (should any streambank erosion
or destabilization occur) throughout the life of this project.

The Service appreciates the opportunity to provide these comments. Please contact Ms. Rebekah Reid of
our staff at rebekah reid(afws.gov, if you have any questions. In any future correspondence concerning
this project, please reference Log Number 4-2-23-388.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
October 19, 2023
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
Sarah Lowry slowrygnewsouthassoc.com
New South Associates, Inc.
1006 Yanceyville Street
Greensboro, NC 27405
Re: Construct Strickland industrial building, 11006 Mt Holly-Huntersville Road, Huntersville, Mecklenburg
County, ER 23-1300
Dear Ms. Lowry:
Thank you for your letter of August 28, 2023, submitting the hard copy of the cemetery delineation survey for
the above -referenced project. We have reviewed the submittal and offer the following comments.
New South Associates Inc. (NSA) conducted a cemetery delineation survey just outside the eastern edge of the
Chapel Hill Missionary Baptist Church Cemetery (31MK1169). The survey included surface reconnaissance
(visual) survey, ground -penetrating radar (GPR) survey, and soil compaction probing. NSA did not identify any
unmarked burials within the survey area and recommends a cemetery protection buffer 25 feet from the
previously identified site boundary for 31MK1169 on the eastern side of the cemetery. As the northern,
southern, and western sides have not been delineated, NSA recommends that the buffer on these sides remain at
50 feet. NSA also recommends temporary fencing along the buffer line, final project designs showing the
cemetery and buffer on maps, the boundary be marked with clear signs, and contractors and consultants working
in the vicinity be informed of the cemetery's sensitivity. We concur with NSA's recommendations and accept
the report as final. No further archaeological work is needed in conjunction with this project.
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&dncr.nc.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
tRamona Bartos, Deputy
f( 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]S70/814-6898