20180029 Ver 1_More Info Received_20180205

Homewood, Sue
From:Brad Luckey <[e-mail]>
Sent:Monday, February 05, 2018 9:26 AM
To:Homewood, Sue
Cc:Roden Reynolds, Bryan K CIV (US)
Subject:\[External\] RE: Egger
Attachments:Egger OFFSITE ALT1_lot lines.pdf; Egger OFFSITE ALT2_rotated.pdf
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Sue,

Please find DWR questions and applicant responses below. Please let me know if you have any further questions or concerns
about the below responses, the attached, or other concerns with the overall application.

DWR Comments #1: The application documentation references lots within the I-85 Corporate Center Industrial Park. Would you
please provide a map that shows the existing lots. It would also be helpful to see an overlay of Off-Site Alternative 1 and the lot
layout to support the statement that there would be a loss of marketability of the other 3 lots under this Alternative.

Applicant Response: Please view the attached Off-Site Alternative #1 drawing, which includes the addition of the overall I-85
Corporate Center Industrial Park lot lines. As shown, Lot 2 would be nearly completely used for development activities and
would be assumed to be a complete loss of potential local tax authority revenue for any other future development. It would be
possible for a potential developer, not requiring a significant size building pad/developable area, to be able to use the remainder of
Lots 4 and 5 (the proposed alternative development area) or the remaining area of Lot 3. However, development of these lots is
fairly unlikely when considering other development constraints (topography, access to railroad infrastructure, construction costs,
etc.) compared to the potential size/return of the building. Therefore, based upon this layout, the local zoning authority could
potentially lose considerable tax revenue, employment opportunities, capital investments and previously obtained funding as
referenced within the initial 404/401 application. Furthermore, development of the remainder of Lots 3, 4 and 5 would likely
result in additional impact to streams/wetlands to provide access for potential future development.

DWR Comment #2: The application also states that “other layouts and design options within the I-85 Corporate Center Industrial
Park result in necessary development improvements occurring outside of the I-85 Corporate Center Industrial Park, within areas
not available for Applicant/Owner purchase or development”. Can you provide some more explanation of the “necessary
development improvements” would be.

Applicant Response: Necessary development improvements mean that the Egger proposed development improvements to
construct and maintain the proposed facility could not occur within the overall larger I-85 Corporate Center Industrial
Park. Essentially, the buildings just do not fit within land owned or controlled by the I-85 Corporate Center Industrial Park (See
attached drawing: Egger Off-Site Alt2_Rotated). As referenced throughout the 404/401 initial application, the size and layout of
the proposed facility are a necessity based upon the proposed manufacturing use of the applicant. Therefore, the applicant and
their civil engineer evaluated rotating the proposed facility construction/operation foot print within the larger I-85 Corporate
Center Industrial Park. It was quickly determined that with the exception of Off-Site Alternative 1, other off-site alternatives that
reduce impact to Waters result in the proposed facility extending outside of the boundaries of the I-85 Corporate Center Industrial
Park. Other alternatives that limit construction within the larger I-85 Corporate Center Industrial Park result in significantly
greater impact to waters than proposed within the preferred and proposed alternative.

Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
1

From: Homewood, Sue \[mailto:[e-mail]\]
Sent: Wednesday, January 17, 2018 3:16 PM
To: Brad Luckey <[e-mail]>
Cc: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Subject: Egger

Brad,

The application documentation references lots within the I-85 Corporate Center Industrial Park. Would you please provide a map
that shows the existing lots. It would also be helpful to see an overlay of Off-Site Alternative 1 and the lot layout to support the
statement that there would be a loss of marketability of the other 3 lots under this Alternative.

The application also states that “other layouts and design options within the I-85 Corporate Center Industrial Park result in
necessary development improvements occurring outside of the I-85 Corporate Center Industrial Park, within areas not available
for Applicant/Owner purchase or development”. Can you provide some more explanation of the “necessary development
improvements” would be.

Thanks,

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality

336 776 9693 office
336 813 1863 mobile
[e-mail]

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

2

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