20180133 Ver 1_Cover Letter_20180209

(Ebyrombe Couutp
County Administration Building Eric Evans
201 St. Andrew St., PO Box 10 Tarboro, NC 27886 County Manager
252-641-7834 • Fax [phone] [e-mail]
www.edgecombecountync.gov
February 9, 2018
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
ATTN: Ms. Samantha Dailey
Raleigh Regulatory Field Office
SUBJECT: Application for Section 404 Individual Permit, Section 401 Individual Water
Quality Certification, and Isolated Waters General Permit 10000
Project Diamond and R-5868 (Kingsboro CSX Select Site Access Road)
Edgecombe County, NC
Debit $570 from WBS Element No. 47802. 1.1
Dear Ms. Dailey:
Edgecombe County (County) and the North Carolina Department of Transportation (NCDOT) are
jointly proposing to construct an access road and site pad for preparation of Project Diamond — the
preparation of Pad B of the Kingsboro CSX Select Site for the Triangle Tyre Company. Triangle
Tyre plans to subsequently construct four tire factory facilities in two phases, both of which are
included in this permit application. This is a joint application as the County and NCDOT are
working together to prepare the site under an accelerated schedule for this landmark project for
Edgecombe County and the State of North Carolina.
Project Diamond will entail construction of an approximate 400 -acre site pad for the planned
Triangle Tyre facility, and a 2 -lane roadway accessing the site from Kingsboro Road to the west and
US 64 Alternate to the north. The Triangle Tyre facility will consist of four separate factories, built
in two phases, and associated supporting infrastructure including rail spurs, internal roadways and
parking areas, raw material and finished product receiving and shipping areas, offices, and
stormwater best management practices (BMPs).
Please see the enclosed ENG 4345 forms signed by the County and NCDOT, Pre -construction
Notification form, Division of Mitigation Services (DMS) mitigation acceptance letter, US Fish and
Wildlife Service (USFWS) and NC State Historic Preservation Office (SHPO) concurrence letters,
list of property owners, figures, engineering drawings and impact maps, and the existing Approved
Jurisdictional Determination for the above referenced project.

PROJECT SCHEDULE
Triangle Tyre Site Pad:
Construction of Phase 1 of the project will begin in early March to meet the schedule required by
Triangle Tyre. Phase 1 construction activities will be limited to upland areas until all appropriate
permits are received. Construction duration on the Phase 1 site and pad preparation is limited to 5
months. Triangle Tyre and their contractors will then construct the factories. The construction
schedule of Phase 2 of the Triangle Tyre site has yet to be determined.
Road & Rail
Construction of the access roads will begin in Spring 2018 with priority placed upon sections
needed for construction access to the site. Construction access is needed immediately to meet
Triangle Tyre's required schedule but will not involve impacts to jurisdictional features until a
permit has been issued. Initial access will be through Harts Chapel Road from Alternate US 64. The
rail construction will begin later in 2018 and be completed prior to the completion of the
manufacturing facility. Final access road and rail construction is not on the critical path so a firm
completion date has not yet been determined. The duration will depend upon the timeline of the
facility construction.
Utilities
Water and sewer improvements are currently in the design and permitting phase contracted
independently by the County to serve the Kingsboro CSX Select Site. Construction is anticipated to
be complete no later than December 31, 2018. Other utility construction related to the site
(including power, fiber optic, and natural gas) will be constructed prior to the completion of the
manufacturing facility, but is not anticipated to involve any jurisdictional impacts.
PURPOSE AND NEED
The purpose of this project is for the County and NCDOT to provide site and transportation
infrastructure capable of supporting the Triangle Tyre plant, and on a larger scale to bring economic
benefit to Edgecombe County through a major industrial development.
Edgecombe County is considered the most economically depressed county in North Carolina in
2017 and 2018, according to NC Department of Commerce. Factors leading to this ranking include:
- Population (declined 3.3% from 2013 to 2016)
- Median income ($32,500)
- Unemployment (8%)
- Poverty rate (26%)
Compared with the other 9 of the 10 lowest ranked counties for 2018, Edgecombe County is the
only one to rank in the lowest 5 in all major categories (rankings in Table 1 are in reverse order —
i.e. 1 is the lowest rank in the category):
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Table 1: Comparison of Top 10 Economically Disadvantaged Counties in NC
2018
Overall
Rank
Property
Tax Base
Pop.
Growth
Median
Income
Unemployment
Poverty Rate
Bertie
4
16
2
2
18
22.3
Columbus
10
11
12
13
24
23.5
Edgecombe
1
4
3
4
3
26.3
Halifax
2
15
6
1
5
26.3
Hertford
9
7
19
12
20
25.6
Richmond
6
23
9
6
13
25.7
Robeson
3
1
20
3
7
31.6
Scotland
5
6
13
18
2
31.2
Vance
7
2
33
5
12
25.1
Washington
8
27
4
15
9
21.8
To address this issue, the County has been making significant efforts to attract major industrial
companies to locate infrastructure and bring jobs to their jurisdiction. The tire manufacturing
industry is one of the largest growth sectors in manufacturing that is currently locating facilities in
the U.S. Since a downturn in production between 2008 and 2013 which included four plants
closing, U.S. tire manufacturing is recovering. Since 2013, domestic tire production in the U.S. has
increased from approximately 300 million tires per year to 325 million. This growth is expected to
continue with a projection of another approximate 25 million tires per year increase by 2023.
The selection of the Kingsboro CSX Select Site by Triangle Tyre addresses the County's economic
need with a projected economic impact of $2.4 billion. This includes a commitment of 800 jobs
averaging $56,000 per year, 75% above the County median income. The 800 jobs alone could
result in a 1.5% decrease in unemployment within the County.
R-5868 is proposed to provide access to the Kingsboro CSX Select Site, and specifically to Project
Diamond as its initial user. The new roadway will enable the incoming raw material truck traffic to
exit US 64 and immediately get to the facility. The access road will mitigate truck traffic impacts on
US 64 Alt by allowing the Triangle Tyre (and future Kingsboro Industrial Park companies)
incoming truck traffic to stay internal to the site and reduce costs for existing adjacent transportation
facility upgrades. The access is the most direct access for incoming materials traffic, and eliminates
a turning movement and conflict point at Kingsboro Road and US 64 Alt.
There are residential developments and farming communities to the east and west of the Industrial
Park; many of which use US 64 Alt as access to both Tarboro and Rocky Mount. Keeping truck
traffic internal as much as possible results in fewer conflict points between residential and slow
moving agricultural equipment/farming community vehicles and industrial traffic. This design, as
well as other proposed access/egress roads (all others are existing roads or in non jurisdictional
areas), optimizes material flow for Triangle Tyre - raw material comes in from the west by road and
rail and final products exit the facility by road to the east.
3

ALTERNATIVES
Off -Site Alternatives
Alternatives evaluation has been an ongoing and integral part of the site selection and site design
process. Off-site alternatives evaluation has been performed at multiple levels by multiple entities
in the development of this project including:
CSX's review and approval of the Kingsboro Select Site
Triangle Tyre's national site selection process
The County's analysis of multiple parcels meeting Triangle Tyre's criteria
The County chose to pursue approval of the Kingsboro site under the well-established CSX Select
Site process. This selection process identifies rail -accessible sites that meet stringent criteria
including:
- Buildable soils
- No zoning and entitlement restrictions
- Adequate utilities
- Proximity to highways
- Rail accessibility
- Environmental due diligence
The County chose to pursue the CSX Select Site designation to allow it to compete in a global
marketplace with other states in the nation and specifically the southeast, as well as other counties
in North Carolina. Tire plants have been located in several other southeast states in the last several
years including Georgia, Mississippi, South Carolina, and Tennessee. Many of these facilities have
been of equal or greater size than the proposed Triangle Tyre site. For example, tire plants in
Mississippi (500 acres), South Carolina (1100 acres) and Tennessee (470 ac) are all of greater size
than the proposed Triangle Tyre site. This intense competition between states for large scale
projects was a driver for the County to pursue a nationally recognized site certification. In addition.
the site is also a Certified Industrial Site by the NC Department of Commerce.
Grant funding for economically disadvantaged areas is being provided by the State and could be
considered available to other similarly economically distressed counties. None of the other lowest
ranked 10 counties in NC have a CSX Select Site. In addition, only Vance County (ranked 9t' in
2018) has a rail accessible site identified by CSX. However, this 300 acre site has not undergone
the rigorous CSX Select Site screening process.
Other appropriately sized industrial sites may be available in the state, but do not address the
economic situation in Edgecombe County and therefore would not meet the purpose and need for
this project. While similar sized sites in other regions of the state (mountain and piedmont) may
have fewer jurisdictional wetland impacts, they would likely have much greater jurisdictional
stream impacts. However, the majority (9 out of 10) of the most economically distressed counties
are in the coastal plain region. Therefore, it is reasonably likely that sites of equal size found in
these counties, or in Edgecombe County, would have similar levels of impacts due to the
predominance of wetlands in this region.
91

Triangle Tyre has used the CSX Select Site process as general criteria for identifying adequate sites,
then overlaid their own site-specific criteria for the final site selection. Their specific requirements
include:
Primary Site Selection Criteria:
- Minimum 300 acres
- Site controlled by a single entity
- Regular/rectangular shape
- Core area of 120 acres with relatively flat topography
- Core area without immediate obstacles (utilities, buildings, jurisdictional areas)
- No more than 10 miles to an Interstate
- Served or easily accessed by rail
- Within 400 miles of a deep-sea port
- Within a county in attainment of air emission standards
Secondary Site Selection Criteria:
- Soil bearing capacity minimum of 150 KPa
- Site located outside the 100 and 500 -year floodplain
- No negative sub -surface conditions
- Zoned for heavy manufacturing
- Proximity to electric utility with minimum available capacity of 21 MW
- Proximity to water line with an available capacity of 185,000 GPD
- Proximity to natural gas line with an available capacity of 0.71 MMSCF/day
- Proximity to wastewater line with an available capacity of 320,000 GPD
- Located in an economic empowerment, enterprise or other incentive zone
- Availability of property for sale
In pursuit of this facility's infrastructure and economic development, the County performed their
own County -specific search for sites that met the criteria specified above. The following sites were
evaluated:
Table 2: Alternative Sites within Edgecombe County
Site Location
Size
Distance to
Highway
Served by
Rail
Owned/ Controlled
by County
Industry Requirement:
300 acres
10 miles
Yes
Yes
Tarboro Commerce Center
96
0
No
Yes
Kingsboro CSX Select Site- Pad B
400
0
Yes
Yes
Kingsboro CSX Select Site- Pad C
300
0
Yes
Yes
June B Long Site (NW quadrant)
155
0
No
No
Carson Barnes Land
460
2
No
Yes
Long Site (SE quadrant)
154
0
Yes
Yes
Bulluck Property
577
4
No
No
Harell Site
500
8
Yes
No
Note: Shading indicates parameter met industry requirement.
5

As can be seen in the table above, only three sites met all the criteria established by the industry:
the two Kingsboro CSX Select Site pads (B and C), and the Harell Site. However, the Harell Site is
not owned or controlled by the County and therefore is not a practical option. The County owns or
is under contract for the entire Project Diamond site.
The proposed Project Diamond site (Kingsboro CSX Select Site — Pad B) meets all of these criteria
and was selected by Triangle Tyre after an intensive national site search that narrowed down to this
and a site in Georgia. At this time, if the project delivery schedule can be met, Triangle Tyre has
committed to locating their new facility on the proposed site and bringing significant economic
development to the County. The Kingsboro CSX Select Site is therefore the most suitable site for
the Triangle Tyre facility in Edgecombe County.
On -Site Alternatives
In order to accept the site in Edgecombe County over other alternatives, including a site in Georgia,
Triangle Tyre had specific demands related to schedule of implementation and site layout. Tire
manufacturing has very specific needs for the layout of their sites, and Triangle Tyre is no
exception. Traffic must have a two-way flow with raw materials coming in from rail and road, and
finished tires exiting the plant in a separate direction.
Specifically, Triangle Tyre requires traffic flow from the west to the east to enable their industrial
process to function efficiently. Employee transportation and parking is located at multiple sites to
avoid pedestrian conflict with industrial facility processes for safety reasons. Triangle Tyre has
stipulated that a 400 -acre area will achieve this layout of safe and efficient flow of personnel,
materials, and product. One of the reasons this site was selected over the competition, was the
ability for it to house both the initial two plants as well as the future plants (included in this permit)
and avoid the need for additional sites or future impacts. Due to these specific constraints, Pad B
was chosen as the most appropriate of the two sites available in Edgecombe County and named
Project Diamond.
Within the Project Diamond site, several layouts were evaluated. This included shifting the
factories further to the north and east. Siting the plants further north would impact the stream,
wetland, and pond system along an unnamed tributary of Walnut Creek approximately 1 mile
upstream of the Tar River, which was recently designated as critical habitat for the Atlantic
Sturgeon. Due to the proximity to the River and the amount of impact associated with that location,
Project Diamond was shifted south.
The area to the east adjacent to SR 1337 is not currently owned by the County, and therefore not
available within the implementation schedule required by Triangle Tyre. In addition, a residential
development is directly east of the site and creates a constraint to providing a regular, rectangular
development area.
Adjusting the factory layout to a north -south orientation was considered, but the flow of raw
materials and product would not be efficient, and additional room (and resource impacts) would
likely be required to site four factories.
2

Alternative R-5868 access road alignments were also considered. The western entrance off
Kingsboro Road is constrained by the presence of the US 64 interchange to the south and the US 64
Alt.-Kingsboro Road intersection to the north. Shifting the western entrance to the north would
impact additional stream and wetland resources, while shifting it south would create traffic and
safety conflicts with US 64 as a full movement intersection would not be possible.
Alternative crossing locations were also evaluated internal to the site. Shifting the western crossing
(Site 3) south would make the western portion of Pad C, consisting primarily of uplands,
impractical for future development and therefore increase likelihood of impacts on the eastern
portion of the pad where multiple streams and wetlands are present. The proposed roadway
alignment also allows access to the other Kingsboro CSX Select Site tracts without the need for
future crossings. NCDOT has reviewed the alignment and determined that all other parcels can be
accessed without additional stream crossings.
Rail access alternatives are limited by the presence of the CSX rail line on the southern boundary of
the site. Since raw materials will be transported by both road and rail, the spurs are necessary on
the western portion of the Project Diamond site. Rail access from the eastern side would be
contrary to the flow of finished product and not be a practicable option.
INDEPENDENT UTILITY
While the Kingsboro CSX Select Site has been developed by the County as a compilation of
multiple pads or tracts, the Triangle Tyre site (Project Diamond) can be developed and function
independently of any other future uses of the other pads. In fact, there is no practical way to predict
the timing, nature and extent of development of the other pads until actual industrial users approach
the County regarding the site. The Project Diamond site development plans (attached) include both
phases of development, and no additional infrastructure is proposed or required for the facility.
The proposed roadway has been located and designed to serve the transportation flow of materials,
personnel, and products for the Triangle Tyre site, as well as address access to the remaining tracts
and therefore avoid relocations or additional transportation impacts in the future. All other tracts
are accessible either by the proposed roadway or off US 64 Alt. from the north, and no additional
road crossings are proposed or required. A minor widening of Kingsboro Road is required for turn
lanes, and is included in this application.
The County, under separate contract, is upgrading water and sewer infrastructure in the area to serve
the Kingsboro CSX Select Site. This infrastructure will be used to support Project Diamond, as
well as the other tracts on site. Due to contracting constraints, this work is being done as a separate
project from the enclosed application, but is being coordinated with this work.
The segments of the Kingsboro CSX Select Site south of US 64 and the CSX rail line are
logistically cut off from the main portion of the site and will not be served by the proposed
infrastructure. Therefore, these areas are also independent of Project Diamond and R-5868.
7

RESOURCESTATUS
The project area lies within the coastal plain physiographic region of North Carolina. Jurisdictional
features within the project footprint are located in the Tar -Pamlico River Basin (United States
Geological Survey [USGS] Hydrologic Unit 03020101) in Edgecombe County. Jurisdictional
streams that will be impacted by this project include Walnut Creek, three UTs to Walnut Creek
(NCDWR Classification WS-IV;NSW; NCDWR Index No. 28-76), and a UT to Penders Mill Run
(NCDWR Classification WS-IV;NSW Index No. 28-77) as shown in Table 4.
There are no designated High Quality Waters (HQW), Outstanding Resource Waters (ORW), Water
Supply I (WS -I), or Water Supply II (WS -II) waters occurring within 1.0 mile of the project area.
Anadromous Fish Spawning Areas or potential habitat areas are located near the project study area,
in the Tar River, according to "A Reference Guide to the Distribution of Anadromous Fishes in
North Carolina Rivers" prepared by National Marine Fisheries Service in September 2010. Within
1.0 mile of the construction footprint no streams are listed as a 303(d) water in the 2014 Final North
Carolina 303(d) List of Impaired Waters of North Carolina.
The jurisdictional wetlands, streams, and ponds for the Kingsboro CSX Select Site were delineated
in August 2008 and issued an Approved Jurisdictional Determination (AJD) (Action ID: SAW -
2008 -02741) by the USACE. The delineation was verified and the AJD renewed by Mr. Thomas
Brown of the USACE on December 20, 2013. This AJD expires on December 20, 2018. The AJD
does not include the portions of the overall site that are located south of US 64 and the main CSX
rail line which are separated by these constraints and therefore not served by the proposed site
improvements.
IMPACTS TO WATERS OF THE UNITED STATES
Impacts are summarized below according to resource type (surface waters and wetlands) and then
described in detail by individual impact site. Roadway impacts are based on the preliminary 160
foot wide corridor design that encompasses both roadway construction and temporary impacts
associated with construction access and erosion control. Project Diamond site impacts also
encompass both proposed fill slopes and other construction, including a 50 foot offset from the edge
of grading to encompass temporary impacts for erosion control and construction access.
Surface Waters
Total jurisdictional stream impacts of 2,769 linear feet are proposed for Project Diamond and R-
5868. The jurisdictional stream impacts are summarized in Table 3 below.

Table 3. Stream Impacts
Site
Stream Name
Stream ID'
T/I/P'
Impact Type
p
Impacts
5
N/A
2.99
Riparian
Drain
(linear feet)
5
UT to Walnut
2.15
Riparian
Drain
2.15
I
Area 38
Area 1
P
Culvert/Fill
87
Total Impacts
Creek
13.87
Riparian
Fill
7.71
3
Walnut Creek
Area 1
P
Culvert/Fill
365
Total Impacts
UT to Walnut
4
Area 1
P
Culvert/Fill
163
Creek
8
UT to Penders
Area 64
T
Fill
635
Mill Run
UT to Walnut
10
Area 1
P
Fill
1,519
Creek
Total Impacts
2,769
'Stream ID and T/I/P (Tributary/Intermittent/Perennial calls) are from the December 20, 2013 AJD.
There will be a total of 5.23 acres of open water (pond) impacts associated with this project at
impact sites 5 and 6 as shown on the permit drawings. The ponds at Site 5 were omitted from the
AJD but are being treated as jurisdictional ponds due to their direct connections with an unnamed
tributary of Walnut Creek. The jurisdictional pond impacts are summarized in Table 4 below.
Table 4. Surface Water (Pond) Impacts
Site
Pond
Name
Pond Size
(ac)
Pond Type
Impact Type
Impacts (ac)
5
N/A
2.99
Riparian
Drain
2.99
5
N/A
2.15
Riparian
Drain
2.15
6
Area 38
0.09
Riparian
Fill
0.09
Total Impacts
5.232
'Wetland names are from the AJD document approved December 20, 2013.
2Rounded total is based on the sum of the actual impacts.
Wetlands
There will be a total of 11.11 acres of wetland impacts associated with this project due to fill. These
impacts are summarized in Table 5 below.
Table 5. Wetland Impacts
Site
Wetland
Name
Wetland
Size (ac)
Wetland Type
Impact
Type
Impacts (ac)
4
Area 16
0.36
Riparian
Fill
0.07
6
Area 37
6.45
Riparian
Fill
0.71
7
N/A
0.56
Non -Riparian
Fill
0.56
8
N/A
13.87
Riparian
Fill
7.71
9
Area 32
0.28
Riparian
Fill
0.07
Total Impacts
9.122
'Wetland names are from the AJD document approved December 20, 2013.
2Rounded total is based on the sum of the actual impacts.
0

Riparian Buffers
Project Diamond is located within the Tar -Pamlico River Basin (United States Geological Survey
[USGS] Hydrologic Unit 03020101). This river basin is subject to riparian buffers pursuant to NC
statute 15A NCAC 02B .0259. These protected stream buffers are depicted in the attached
Kingsboro CSX Select Site Overall Concept Plan and will be addressed in a subsequent submittal of
a request for a major variance to NCDWR.
Permit Impact Sites
Project Diamond involves ten impact sites as described below and presented in the attached plans.
R-5868 (Sites 1-5)
The following impacts are calculated based on corridor/preliminary design. Final impact totals are
expected to be less than described. Once final design is complete and final impacts numbers are
calculated, that information will be submitted during permit review or addressed in a permit
modification request, depending on when final designs are complete.
Site 1
Site 1 is just north of the proposed access road entrance on Kingsboro Road. An extension of the
existing culvert under Kingsboro Road is required for road widening to accommodate traffic
associated with the access road. Perennial stream impacts will total 87 linear feet to a UT of Walnut
Creek (AJD Area 1).
Site 3
Site 3 is a proposed crossing of the access road over Walnut Creek. This crossing will result in 365
linear feet of perennial stream impacts (AJD Area 1) from culvert installation and roadway fill
slopes. The site avoids wetland impacts and crosses at a location with a shallow valley that reduces
the amount of fill required. Shifting this crossing upstream would not only increase wetland
impacts but would significantly encroach into the western upland areas on Pad C, potentially
forcing future development impacts to the eastern stream and wetland features within this pad.
Site 4
Site 4 is a stream and wetland crossing for culvert installation and fill slopes of the proposed access
road. Estimated impacts to a UT to Walnut Creek (AJD Area 1) in this location are 163 linear feet
of perennial stream and 0.07 acre of wetland (AJD Area 16) in total. This location avoids the need
to cross multiple tributaries above the stream confluence.
Site 5
The access road will intersect US 64 Alt. at the existing intersection of Dunbar Road (SR 1252).
Impacts associated with Site 5 include 5.14 acres of surface water impacts in two ponds. This total
includes dewatering these ponds for the purposes of road and culvert construction.
10

Ponds will be pumped down or drained in stages according to NCDWR guidance to limit
downstream releases and sedimentation. Reconstructing the ponds is not anticipated, and stream and
wetland resources will be allowed to naturally recover in the old pond bed. A pond drainage plan
will be provided once design is complete and prior to construction in this area. The area will be
monitored to ensure stream banks are stable.
Project Diamond (Sites 6-10)
Site 6
Site 6 is located in the northeastern portion of Project Diamond and involves impacts to a small
headwater wetland. An outbound warehouse and associated grading will result in impacts to a
wetland (AJD Area 37) and pond (AJD Area 38). These impacts will total 0.71 acre of wetland and
0.09 acre of surface water (pond). Reducing this impact would not be possible without shifting the
entire site south or west, resulting in additional impacts to other jurisdictional features.
Site 7
Site 7 is an impact to an isolated wetland on the eastern portion of the site. This 0.56 acre of
wetland impact will be a result of pad and roadway grading for the outbound warehouse. This site
is included to document impacts authorized through IWGP 10000 under jurisdiction of the NCDEQ.
Site 8
Site 8 is a result of planned grading of the Phase 2 southern factory areas and associated roadway
that would result in 7.7 acres of wetland impact and 635 linear feet of tributary (AJD Area 64)
impact. The turn radius of the road at the southeast corner of the site has been evaluated to balance
safety versus environmental impact. The impact to the wetland has been reduced by approximately
two acres through this minimization effort. Further reducing impact at this site would require
shifting all the factory buildings and other infrastructure closer together. This is not practical as the
room is needed for maneuvering trucks and materials safely within the confines of the Project
Diamond as described in the avoidance and minimization section below.
Site 9
The rail spur that enters the site along the western boundary provides raw materials to the inbound
warehouses and crosses a portion of a wetland feature (AJD Area 32), resulting in 0.07 acre of
impact. Locating the rail line further east would impede the factory layout and delivery system and
potentially increase impacts to other resources as other infrastructure would be shifted as well.
Site 10
Site 10 will have impacts to a UT to Walnut Creek (AJD Area 1) occurring due to warehouse
construction, a road crossing, two rail spur crossings, and site grading. These impacts will total
1,519 linear feet of perennial stream. This impact is unavoidable as the stream encroaches further
into the center of the 400 -acre tract than any of the other jurisdictional features. Avoiding the
11

stream would make the incoming flow of materials on the west of the site impracticable for both of
the first phase factories. Minimization of this impact area was evaluated, but resulted in only small
segments of stream channel being retained with degraded function, with a loss of room for truck
maneuvering and staging.
MITIGATION OPTIONS
The USACE has adopted, through the Council on Environmental Quality (CEQ), a wetland
mitigation policy that embraces the concept of "no net loss of wetlands" and sequencing. The
purpose of this policy is to restore and maintain the chemical, biological, and physical integrity of
the waters of the United States. CEQ has defined mitigation of wetland and surface water impacts
to include: avoiding impacts, minimizing impacts, rectifying impacts, reducing impacts over time,
and compensating for impacts (40 CFR 1508.20).
The applicants are committed to incorporating all reasonable and practicable design features to
avoid and minimize jurisdictional impacts, and to provide full compensatory mitigation of all
remaining, unavoidable jurisdictional impacts. Avoidance measures were taken during the planning
phase and minimization measures were incorporated as part of the project design. Minimization
includes the examination of appropriate and practicable steps to reduce adverse impacts.
Avoidance and Minimization
Avoidance and minimization of the Project Diamond site impacts was discussed in detail in the On -
Site Alternatives section and the individual impact sites above. In summary, the site design
balances provision of a 400 -acre site for Triangle Tyre with retention of the tributary systems on
site that flow directly to the Tar River. Overall, for a facility of this size located in a coastal plain
county, impacts are unavoidable and the level of impact has been minimized to the greatest practical
extent.
The spacing of factory buildings was established by Triangle Tyre based on their existing facilities.
It allows for adequate room between the buildings for fire suppression — typically wider space than
the height of the building. The layout also provides sufficient construction access for the large
buildings and utility corridors that meet standard requirements (i.e. typically a 40 -foot offset from
structures to fire hydrants). The site configuration allows for adequate ramp lengths and
maneuvering room for trucks to back up to the buildings. The Project Diamond roads meet Institute
of Transportation Engineers guidelines for interstate model truck -tractor turning. Road curves were
minimized as much as practical without impeding truck traffic flow.
The access road alignment has been designed to minimize impacts to jurisdictional resources on the
Kingsboro CSX Select Site, and avoid future impacts to access other pads. The entrance off
Kingsboro Road has been located to allow for adequate traffic flow and safety between the US 64
interchange and the US 64 Alt.-Kingsboro Road intersection. The entrance off US 64 Alt. uses an
existing road between two ponds (Site 5). The eastern crossing internal to the site (Site 3) is located
in an area of minimal wetlands and shallower slope, and the second crossing (Site 4) is below a
confluence to avoid crossing two stream channels.
12

Rail access from the south was evaluated and shifted as far east as possible to avoid impacts to the
main drainage between Pads B and C. Further shifting to avoid impacts entirely was not practical
as it would interfere with the operations and flow of materials on the site.
Avoidance and minimization has been employed in the project area to the maximum extent
practicable. Detailed descriptions of each site are included above. Listed below are some of the
measures implemented on the project:
Site Infrastructure:
• The entire site has been located to avoid and minimize impacts to the two major tributaries
to Walnut Creek (north and west of the project area)
• Non -factory buildings including office, conference area, and research & development
facility on the north end of the site have been located to avoid streams and headwater
wetlands
• Stormwater BMPs have been shifted west or divided into smaller features to avoid locating
them in jurisdictional areas
• Sediment and erosion control measures in accordance with NC Division of Energy, Mineral,
and Land Resources will be strictly implemented and monitored throughout construction
Roadway:
• NCDOT's Best Management Practices (BMPs) for the Protection of Surface Waters will be
enforced;
• NCDOT's BMPs for Construction and Maintenance Activities will be utilized;
• NCDOT will implement installation, inspection, and maintenance of erosion and sediment
control measures;
• Rip rap stabilization will be sized appropriately based on flow velocity to ensure long term
stability of banks;
• New roadway drainage will be directed, where practical, to uplands and ditches/swales
rather than direct discharge to surface waters;
• At the inlets and outlets of culverts carrying jurisdictional streams, stream realignment is
proposed to avoid sharp bends in the streams and prevent future instability;
• Unstable eroded stream banks will be stabilized with rip rap armoring where necessary;
• Low flow conditions at culverts will be accommodated with the appropriate sizing, grade
controls, and burial;
• Existing drainage patterns will be maintained to the maximum extent practicable.
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In addition to the above practices, specific measures have been utilized to maintain water quality:
Stormwater Management
While final designs and stormwater management plans are not available at this time, Edgecombe
County and NCDOT will ensure that the project complies with watershed regulations including:
Site Infrastructure:
• Proposed outfalls will comply with the Tar -Pamlico Buffer Rules, including retaining sheet
flow throughout the buffer. This will be achieved through level spreaders or, in areas of
steeper slopes, full treatment of stormwater by wet detention ponds.
• Three stormwater retention basins are to be located on Phase 1 of Project Diamond. The
basins will be of sufficient size to adequately treat stormwater from the site. The County
will ensure that final design of the stormwater BMPs meets the required watershed
protections.
• An additional two basins will treat runoff from Phase 2. These basins will collect and retain
runoff and stormwater collected from the constructed site in order to reduce stream velocity
and turbidity downstream of their outlets, and meet similar standards as the Phase 1 BMPs.
Roadway:
• Roadway drainage will be designed to sheet flow through the shoulders and side slopes in
order to provide treatment and diffuse flow into downstream resources. No curb and gutter
is proposed.
• Roadway drainage design will be reviewed and approved by NCDOT.
A conceptual plan for stormwater management for the remainder of the Kingsboro CSX Select Site
is not practicable at this time. Until future industries decide to locate facilities at the site, it is not
possible to predict the nature or extent of impervious surface on each tract. Therefore, it is also not
practicable to identify stormwater BMP locations. The County is committed to ensuring that
adequate room for stormwater BMPs will be retained on each site to ensure compliance with water
quality and buffer regulations.
Compensatory Mitigation
Compensatory requirements for Project Diamond are summarized below. This project will impact
2,769 linear feet of warm water streams and 9.12 acres of wetlands. Mitigation is proposed for
2,134 linear feet of stream impacts, which encompasses all sites except the 635 feet of tributary at
Site 8. Mitigation is proposed for 8.56 acres of wetland impacts, which encompasses all sites
except the 0.56 acre of isolated wetland at Site 7.
The NC Division of Mitigation Services has agreed to supply compensatory mitigation for these
impacts. There are no private mitigation banks within the HUC that can meet the full mitigation
requirements, however if credits become available during the permit review period the applicants
will coordinate with the USACE and NCDWR to evaluate this option.
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FEDERALLY PROTECTED SPECIES
Plants and animals with federal classifications of Endangered (E) or Threatened (T) are afforded
protection under provisions of Section 7 and Section 9 of the Endangered Species Act (ESA) of
1973, as amended. As of November 13, 2017, the U.S. Fish and Wildlife Service (USFWS) lists
two (2) species as threatened and / or endangered in Edgecombe County, NC.
Table 6. Federally Protected Species for Edgecombe Count , NC
'E — Endangered
Summary of Protected Species
The biological conclusions of "No Effect" for the red -cockaded woodpecker and Tar River
spinymussel were determined by Soil Horizons, Inc. in their Protected Species Assessment report
dated May 5, 2008. Concurrence of these findings was obtained from USFWS in a letter dated
October 19, 2012 (attached).
The yellow lance (Elliptio lanceolata) is proposed for official listing as a threatened species in
Edgecombe County. As prior surveys did not reveal the presence of the Tar River spiny mussel, it
is not anticipated that the streams on-site would be adequate habitat for the yellow lance.
Although not listed as a threatened or endangered species for Edgecombe County by USFWS, the
Atlantic sturgeon has designated critical habitat located within the Tar River approximately one
mile downstream of the project area. Impacts to tributaries discharging directly to Walnut Creek
and then the Tar River have been minimized as discussed above in order to enhance protection of
this species. No streams on site are large enough to provide habitat for the sturgeon.
CULTURAL RESOURCES
In order to comply with Section 106 of the National Historic Preservation Act (1966, as amended),
the applicants must evaluate the project's impact upon any extant architectural and archaeological
resources, and determine if additional measures will be necessary to mitigate any adverse effects of
the project upon any significant properties and sites.
Field surveys and a review of the State Historic Preservation Office web site were conducted in
April 2012 to evaluate the property for the presence of historic building sites. Three houses were
listed on this site; the Richard Hart house, the Eason -Tenant house, and the Hart -Eason Tenant
house (no longer present). These structures are not candidates for the national register of historic
places. A site visit to the Department of Archeology at the State Historical Preservation Office was
also performed to review site records for the presence of archaeological sites.
The North Carolina Department of Cultural Resources State Historic Preservation Office provided a
letter on September 13, 2012 (attached) stating that after their review of the project they are aware
of no historic resources which would be affected by the project.
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Federal
Habitat
Biological
Scientific Name
Common Name
Status'
Present
Conclusion
Picoides borealis
Red -cockaded woodpecker
E
No
No Effect
Parvaspina steinstansana
Tar River spinymussel
E
No
No Effect
'E — Endangered
Summary of Protected Species
The biological conclusions of "No Effect" for the red -cockaded woodpecker and Tar River
spinymussel were determined by Soil Horizons, Inc. in their Protected Species Assessment report
dated May 5, 2008. Concurrence of these findings was obtained from USFWS in a letter dated
October 19, 2012 (attached).
The yellow lance (Elliptio lanceolata) is proposed for official listing as a threatened species in
Edgecombe County. As prior surveys did not reveal the presence of the Tar River spiny mussel, it
is not anticipated that the streams on-site would be adequate habitat for the yellow lance.
Although not listed as a threatened or endangered species for Edgecombe County by USFWS, the
Atlantic sturgeon has designated critical habitat located within the Tar River approximately one
mile downstream of the project area. Impacts to tributaries discharging directly to Walnut Creek
and then the Tar River have been minimized as discussed above in order to enhance protection of
this species. No streams on site are large enough to provide habitat for the sturgeon.
CULTURAL RESOURCES
In order to comply with Section 106 of the National Historic Preservation Act (1966, as amended),
the applicants must evaluate the project's impact upon any extant architectural and archaeological
resources, and determine if additional measures will be necessary to mitigate any adverse effects of
the project upon any significant properties and sites.
Field surveys and a review of the State Historic Preservation Office web site were conducted in
April 2012 to evaluate the property for the presence of historic building sites. Three houses were
listed on this site; the Richard Hart house, the Eason -Tenant house, and the Hart -Eason Tenant
house (no longer present). These structures are not candidates for the national register of historic
places. A site visit to the Department of Archeology at the State Historical Preservation Office was
also performed to review site records for the presence of archaeological sites.
The North Carolina Department of Cultural Resources State Historic Preservation Office provided a
letter on September 13, 2012 (attached) stating that after their review of the project they are aware
of no historic resources which would be affected by the project.
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FEMA COMPLIANCE
The proposed access road corridor is anticipated to impact the upper extent of the FEMA 100 year
floodplain at Impact Site 4. A FEMA no -rise certification will be required, and is being pursued by
the applicants. The County will be the reviewing and issuing entity for the no -rise certification.
INDIRECT CUMULATIVE IMPACT ANALYSIS
The proposed project would employ approximately 800 employees for Phase 1 (northern two
factories). While the majority of employees will be hired from in and around the County, it is
anticipated that a portion of the employees will travel to or relocate to the immediate vicinity of the
proposed project area. The influx of employees associated with this project could drive additional
residential, recreational, institutional, and/or commercial development in this area to support the
growing population base. However, this change is likely to only offset the 3% population decline
since 2013.
The County will facilitate relocation of the residence renting homes in the Midlakes Mobile Home
Park on the northern portion of the site. Several public hearings and community outreach efforts
have occurred in the development of the Kingsboro CSX Select Site and property acquisition by the
County. These include:
• 12/4/17 - Citizens input before approving financing of $17 million for land purchase for
Economic Development. This included the Midlakes Mobile Home Park purchase.
• 12/19/17 - Public Hearing for citizens input before entering into an agreement (inducement)
to purchase and convey land for to promote economic development.
• 1/2/2018 - Second Public Hearing regarding financing due to adjustment from $17 million to
$22 million in loans.
• 2/8/18 — Public Meeting to discuss the purchase of the Midlakes Mobile Home Park by the
County and potential incentives and relocation assistance.
The proposed project would result in a permanent increase to traffic loads on US 64, Kingsboro
Road, and other associated roads, as well as a temporary increase in construction traffic during the
construction phase of the project. Roadway improvements are proposed to offset increased traffic
in this area, including:
• Operational improvements along Kingsboro Road, including the addition of turn lanes and
increased traffic storage.
• Construction of the Kingsboro CSX Select Site Access Road (R-5868) to reduce truck traffic
on Kingsboro Road and US 64 Alt. and increase safety.
Overall, the project is not expected to have a long-term impact on water quality in the project area.
Development of other Kingsboro CSX Select Site tracts will have to comply with the same strict
watershed regulations as described for the Project Diamond site. This includes impervious surface
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limits and requirements for engineered stormwater controls to prevent increase in post -development
stormwater runoff, as well as sheet flow through existing riparian buffers. Quantification of future
impacts is not practical at this time, as the size and nature of individual industries is difficult to
ascertain. Each individual tenant of the Kingsboro CSX Select Site will be required to provide
appropriate BMPs to meet watershed standards. The individual facilities will also be required to
permit and justify their own impacts to jurisdictional waters, if any are required.
Future development in the area will be required to follow appropriate local, state, and federal
guidelines and permitting regulations. As mentioned above, due to the negative growth in the
County, future development is likely to only offset this loss rather than increase development.
WILD AND SCENIC RIVER SYSTEM
The project will not impact any designated Wild and Scenic Rivers or any rivers included in the list
of study rivers (Public Law 90-542, as amended) or North Carolina Natural and Scenic Rivers.
ESSENTIAL FISH HABITAT
The project will not impact any essential fish habitat afforded protection under the Magnuson -
Stevens Act of 1996 (16 U.S.0 1801 et seq.).
REGULATORY APPROVALS
Application is hereby made for a Department of the Army Section 404 Individual Permit as required
for the above-described activities. We are also hereby requesting a Section 401 Water Quality
Certification from the NCDWR along with issuance of IWGP 10000, if necessary. In compliance
with Section 143-215.3D(e) of the NCAC, NCDOT will provide $570.00 to act as payment for
processing the Section 401 Certification. A request for a Major Variance from the Tar -Pamlico
Buffer Rules is also being submitted to the NCDWR in conjunction with this permit submittal.
Thank you for your time and assistance with this project. Please contact me at your earliest
convenience if you have any questions or need additional information.
Sincerely,
ii
Signed by:
065014D8453...
Eric Evans
County Manager
Edgecombe County
Cc:
Karen Higgins, NCDWR 401 Unit (4 copies)
Tony Coggins, NCDOT Division 4
Bob May, P.E., Wetherill Engineering, Inc.
Bobby Joyner, P.E., Appian Consulting Engineers
Phil May, Carolina Ecosystems, Inc.
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