20240238 Ver 1_Public Notice Comments_20240322

DocuSign Envelope ID: 5DB7D450-D1DE-455F-8C47-759F597CBED9
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
March 21, 2024
Corps Action ID# SAW-2023-02308
DWR# 20240238
Davidson/Guilford Counties
Ms. Emily Greer
U.S. Army Corps of Engineers
Charlotte Regulatory Field Office
Delivered via email to: [e-mail]
Subject Project: South Point Commerce Center
Dear Ms. Greer:
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 Division requests that the USACE consider whether the "Near Similar Development" should
be considered in the alternatives analysis. Multiple offsite alternatives would rate more
favorably without this criterion.
The applicant has identified additional zoning and access to utilities as criteria for the offsite
alternative however these criteria are often overcome for the purpose of similar projects. If
these criteria are based on financial factors, then financial information should be provided. The
Division requests that the USACE consider the weight these criteria have in eliminating multiple
alternatives.
3. It appears that the conceptual layout of the Clinard Farms Alternative could be revised to
provide further avoidance and minimization to more appropriately compare with the preferred
alternative.
4. The applicant proposes stream mitigation at a ratio of 1.5:1 based NCSAM ratings. Based on
historical imagery, the property has been recently cleared which is likely to have had a negative
effect on the ratings. The Division requests that you consider whether recent clearing to
promote development of the property should be considered when determining the appropriate
mitigation ratio for the proposed impacts.
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 CARCLINA
919.707.9000

DocuSign Envelope ID: 5DB7D450-D1DE-455F-8C47-759F597CBED9
Corps Action ID# SAW-2023-02308
DWR# 20240238
Davidson/Guilford Counties
Page 2of2
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 and requests that the USACE also consider 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,
Es
DocuSigned by:
ft p�G lass
980C5097D80E4E9...
Stephanie Goss, Supervisor
401 & Buffer Permitting Unit
Encl.: Request for Additional Information — South Point Commerce Center, dated March 21, 2024
Electronic cc: Jennifer Robertson, ATLAS Environmental
Olivia Munzer NCWRC
DWR 401 & Buffer Permitting Branch file
Filename: 20240238 South Point Commerce Center - Davidson - Guilford - Comments to the USACE.docx
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
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