20171527 Ver 1_Pre-App meeting notes on 2nd Draft IP_20180309

Homewood, Sue
From: Sullivan, Roscoe L III CIV (US) <[e-mail]>
Sent: Friday, March 09, 2018 3:41 PM
To: Anna Reusche
Cc: Bailey, David E CIV USARMY CESAW (US); Homewood, Sue
Subject: [External] SAW -2016-02542 Project Trace: Notes on the Draft IP Submittal and Pre -Application
Meeting
Attachments: 2_RLS and DEB Comments PERSON COUNTY APPENDICES COMPILED 03 -01 -18 -DRAFT ....pdf
realms o not click links or open -r ,,h,,,P ,,,,less verified. Send all ].
Hey Anna,
Attached is a truncated version of the revised Draft IP with comments from both me and Dave Bailey. Below is a list of issues and
comments for the latest Draft IP Application (submitted on 3/1/2018) that were discussed during the meeting:
1. The applicant needs to revise stream and wetland impacts to be consistent with the delineation as verified by Eric
Alsmeyer. Please coordinate with ECS to get the most up to date version of the data for the potentially jurisdictional
waters found within the Project Trace study area.
2. Off -Site Alternatives Analysis: We are fine with the approach of comparing the preferred alternative to existing megasites
in North Carolina. However, it was suggested that the applicant tailor this analysis to detail the specific utility
requirements (i.e. power redundancy and quality) and important needs (such as lack of vibration) for the proposed
development in a way that compares and contrasts the preferred alternative against the other off-site alternatives.
3. On -Site Alternatives Analysis: The applicant will need to provide a detailed on-site alternatives analysis for the entire
proposed project and not just the central processing facility. In addition to a written narrative, please provide sketch plans
showing the layout for each onsite alternative evaluated for this permit application. Typically, 3 to 4 reasonable on-site
alternatives are sufficient for this evaluation. Further, the written narrative and sketch plans should clearly detail the
layout and purpose for each of the buildings and associated infrastructure that are being proposed as a part of this project.
4. Avoidance and Minimization: The applicant will need to provide more information on avoidance and minimization. In
particular, the preferred alternative that was submitted with the most recently submitted Draft IP Application seems to be
designed in a manner that avoids placing many of the ancillary buildings on streams and wetlands. However, large stream
and wetland impacts are proposed in what appears to be open space in between buildings and roads. It will be hard to
justify that this project avoids and minimizes to the maximum extent practicable using the current preferred alternative.
Please provide information on fill slope requirements for buildings proposed and the use of retaining walls.
5. The USACE doesn't need the PJD request as a part of the application, as we already have a copy of the PJD request from
previous submittals.
6. Even though there is no "end" user for the proposed development, the applicant indicated that the goal is to get the project
permitted and then move forward with grading/prepping the portion of the project where the central operations facility
would be built. However, both NCDWR and USACE indicated that, if a permit is issued with no "end" user, then the
permit would likely be conditioned such that construction could not begin until an "end" user was identified/committed to
the proposed project.
7. Thin Film Solar Cell Manufacturing Facility: Is the thin film solar cell manufacturing facility, which is proposed north of
Edwin Robertson Road, a separate project from the semiconductor fabrication facility? Or, is the solar cell manufacturing
facility a necessary part of the semiconductor fabrication facility? Would one facility still be constructed without the
other? If this facility is a separate project from the semiconductor fabrication facility, it may need to be reviewed under a
separate permit application.
The NC DWR also provided several comments and concerns during the meeting. Below is my summary of what was requested by
DWR:
Secondary and Cumulative Impacts Analysis: Please incorporate this into the IP Application either as an appendix or as a
part of the document.

2. More discussion may be needed to iron out the details of mitigation and mitigation ratios.
3. If the applicant plans to phase the project, then the applicant will need to describe the order in which the proposed project
will be phased in the application.
4. Stormwater Treatment: NCDWR noted that some of the proposed stormwater control measures (SCMs) appear to be
designed in potentially jurisdictional waters. However, SCMs are not typically allowed to be constructed in jurisdictional
waters. Further, NCDWR noted that the project does not appear to provide sufficient stormwater treatment for such an
extensive development.
5. Stream and/or wetland segments that become isolated or extensively impaired as a result of the proposed project may need
to be included in the impact estimates.
6. DWR needs to verify some Intermittent/Perennial channels/breaks for DWR permitting/mitigation purposes. This doesn't
have to be completed for application submittal but will be necessary before DWR can issue the 401.
Should you have any questions, please feel free to give me a call or send me an email.
Sincerely,
Ross
Ross Sullivan, PWS, ISA Certified Arborist
Regulatory Specialist
Raleigh Regulatory Field Office
U.S. Army Corps of Engineers - Wilmington District
Wake Forest, North Carolina 27587
Office #: 919-554-4884. Ext. 25
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is located at:
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.

.Soso*
TIMMONS GROUP
YOUR VISION ACHIEVED THROUGH OURS.
5410 Trinity Road P 919.859.5663
Suite 102 www.timmons.com
Raleiqh, NC 27607
PERSON COUNTY MEGA -PARK
INDIVIDUAL PERMIT REQUEST
DRAFT INDI VID UAL PERMIT REQUEST FOR AGENCY REVIEW ONLY
F9910MMOT9101191TIS
PERSON COUNTY BUSINESS AND INDUSTRIAL CENTER, INC.
ATTN: MR. DAVID NEWELL & STUART GILBERT
PREPARED BY:
TIMMONS GROUP
5410 TRINITY ROAD, SUITE 102
RALEIGH, NC 27607
MARCH 2018
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EXECUTIVE SUMMARY
On behalf of Person County Business and Industrial Center, Inc. (Applicant), Timmons Group is submitting this
Individual Permit Request for the development of the Person County Mega -Park (Project). The proposed
project is situated on approximately 1,350 acres and is located approximately 5 miles north of Roxboro in
Person County, North Carolina (see Figure 1. Vicinity Map). The proposed mega -park is comprised of both
wooded and agricultural fields. Land use surrounding the property is predominately comprised of
undeveloped forested lands interspersed with agricultural fields and single family residential homes. Access to
the property is via Country Club Road or Edwin Robertson Road.
The purpose of the proposed project is to develop the Person County Business and Industrial Park to
accommodate a semiconductor fabrication chip plant as well as critically necessary support facilities for the
main industry. Support facilities required for the operations are described in detail below, however, generally
include manufacturing, research and development, chemical and gas suppliers, engineering and maintenance,
and public safety facilities. An integrated circuit or monolithic integrated circuit (also referred to as an IC, a
chip, or microchip) is a set of electronic circuits on one small flat piece (or "chip") of semiconductor material,
normally silicon. ICs are now used in virtually all electronic equipment and have revolutionized the world of
electronics. Computers, mobile phones, and other digital home appliances are now inextricable parts of the
structure of modern societies, made possible by the small size and low cost of ICs.
The proposed Person County Business and Industrial Center park layout is comprised of 27 buildings in
addition to the approximate 3.5 million square feet central operations facility. The property is suitable for the
proposed development based on specific industry requirements including, but not limited to, a minimum of
200 acres with compatible zoning, access to available and high-quality electricity, experienced workforce, and
direct routes to interstates.
It is rare that a single site meets all the criteria necessary for the successful development of a semiconductor
fabrication chip plant. Power requirements for a semiconductor fabrication chip plant are significant. The
existing availability of power sets the Person County Mega -Park apart from alternative locations, not only in
North Carolina, but also globally. Currently the proposed mega -park is served by a 2,422 Megawatt Steam
Plant, a 729 Megawatt Steam Plant, a 49 Megawatt Combined Cycle Plant and 230 KV lines and 115 KV lines
that cross the property. The amount and quality of available power in addition to the amount of available
water, wastewater, natural gas and telecom further sets this property apart. The Person County Mega -Park
was determined to be the most suitable option based on the size and currently available infrastructure (i.e.
electrical, natural gas, water and sewer).
Person County has identified the proposed mega -park as an economic development priority and has invested
significant resources into the planning and due -diligence required to develop the mega -park. Based on an
Economic Impact Study completed by N.C. Department of Commerce for the project, the ongoing, annual
employment impact of the new facility will result in approximately 7,870 jobs in the Person County area
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including 4,000 direct company jobs and an additional 3,870 jobs it the region through indirect and induced
effects.
Based on the 2017 report from the North Carolina Department of Commerce, the median household income for
families living in the County was $54,474 and the per capita income for the county was $22,189. In Person
County, about 9.4% of families and 19.9% of the population are below the poverty line. The N.C. Department
of Commerce annually ranks the state's 100 counties based on economic well-being and assigns each a tier
designation. These designations are based on the average unemployment rate, median household income,
percentage growth in population, and adjusted property tax base per capita. The 40 most distressed counties
are designated as Tier 1, the next 40 as Tier 2, and the least 20 least distressed as Tier 3. Person County is
currently ranked as a Tier 1 county.
The County has incorporated concerns of relevant stakeholders into their master plan and studied the
development needs and patterns of the industrial clients it wishes to attract. The County has completed the
environmental and utility infrastructure studies necessary to attract industrial users, in order to facilitate an
expedient approval process. The property is currently zoned RC -Rural Conservation and the proposed use is
consistent with the current zoning and is considered a permitted use.
In order to accomplish the goals of the Project, a total of 9.1 acres of unavoidable permanent impacts to
jurisdictional wetlands and 46,959 linear feet of stream are required. These unavoidable impacts will be
mitigated through the purchase of compensatory wetland and stream credits through the N.0 Division of
Mitigation Services (DMS). The purchase of this compensatory mitigation will ensure the unavoidable impacts
proposed by the Project, will result in a "no net loss" of aquatic resource function and value to Waters of the
U.S.
Impacts to jurisdictional features were avoided and minimized to the maximum extent practicable throughout
the planning and design process. The current proposed layout provides sufficient area to construct the
approximately 3.5 million square feet central operations facility as well as position the facility along the
existing ridgeline which will serve to minimize impacts to 2nd order streams on the property. The proposed
support facilities have been designed and strategically located to avoid impacts to the main stem of Story's
Creek and its floodplain. Furthermore, all environmentally sensitive areas have been avoided in the
northwestern portion of the property, also associated with Story's Creek.
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PERSON COUNTY BUSINESS AND INDUSTRIAL CENTER, INC. - PERSON COUNTY
MEGA -PARK INDIVIDUAL PERMIT REQUEST
TABLE OF CONTENTS
EXECUTIVESUMMARY..........................................................................................................................................................................2
1.0 PRJOECT INFORMATION SHEET...........................................................................................................................................6
2.0 INTRODUCTION...........................................................................................................................................................................8
3.0 SITE DESCRIPTION..........................................................................................................................................................................9
3.1 Site Location...................................................................................................................................................................................9
3.2 Site Conditions..............................................................................................................................................................................9
4.0 PURPOSE AND NEED..............................................................................................................................................................10
5.0 ALTERNATIVES ANALYSIS...................................................................................................................................................12
5.1 No -Build Alternative................................................................................................................................................................12
5.2 Off-site Alternatives.................................................................................................................................................................12
5.3 On -Site Alternatives.................................................................................................................................................................13
5.4 Preferred Alternative..............................................................................................................................................................15
6.0 JURISDICTIONAL IMPACTS..................................................................................................................................................16
7.0 AVOIDANCE AND MINIMIZATION.....................................................................................................................................16
8.0 COMPENSATORY MITIGATION..........................................................................................................................................17
9.0 SUPPORTING SITE INFORMATION...................................................................................................................................17
9.1 Threatened and Endangered Species Information......................................................................................................17
9.2 Cultural Resources...................................................................................................................................................................18
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FIGURES
Figure 1 Vicinity Map
Figure 2 Parcel Map
Figure 3 Environmental Inventory Map
Figure 4 FEMA Floodplain
Figure 5 Jurisdictional Waters of the U.S Overall
Figure 6 Typical Cross Sections
APPENDICES
Appendix A
Joint Permit Application
Appendix B
Wetland Delineation Information
Appendix C
Scoping Letters and Agency Response
Appendix D
Zoning Information
Appendix E
NCDOC Economic Impact Study
Appendix F
Selection Criteria Matrix & On -Site Alternatives Evaluated
Appendix G
Waters of the U.S. Impact Maps
Appendix I
N.C. Division of Mitigation Services Coorespondance
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1.0 PRJOECT INFORMATION SHEET
General
Project Name:
State:
Location:
Latitude:
Longitude:
Subject Property Size:
5410 Trinity Road P 919.859.5663
Suite 102 www.timmons.com
Raleiqh, NC 27607
Person County Mega -Park
North Carolina
Person County
36.4779
-78.9941
1350 Acres
HUC Code: 03010104
Waterbodies on Property: Story's Creek & Marlowe Creek
Corresponding
Information
USGS Quad: Olive Hill & Roxboro
County: Person County
Applicant Person County Business and Industrial Center, Inc.
Mr. David Newell, Chairman EDC, President of PCBIC and
Mr. Stuart Gilbert, Director, PCBIC, Person County
Name: Economic Development Director
Address: PO Box 1824
Roxboro, North Carolina 27573
Contact:
Telephone: C: 336-504-3079
Email: [e-mail]
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TIMMONS GROUP
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Agent Timmons Group
Name: Mrs. Anna Reusche
Address
Contact:
Telephone:
Email:
5410 Trinity Road P 919.859.5663
Suite 102 www.timmons.com
Raleiqh, NC 27607
5410 Trinity Road, Suite 102
Raleigh, North Carolina 27607
0: 919-866-4500 C: 919-816-7745
[e-mail]
Anticipated Permit Authorizations
• U.S. Army Corps of Engineers: Individual Permit
• North Carolina Division of Water Resources: 401 General Water Quality Certification
• Erosion and Sediment Control Plan & Grading Permit
• Site Plan Permit
• NCDOT Encroachment Agreement
• Duke Site Certification
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2.0 INTRODUCTION
On behalf of the Person County Business and Industrial Center, Inc. (Applicant), Timmons Group is submitting
this permit request for the Person County Business and Industrial Mega -Park (Project). The proposed project
is situated on approximately 1,350 acres and is located approximately 5 miles north of Roxboro in Person
County, North Carolina (see Figure 1. Vicinity Map). The proposed mega -park is comprised of both wooded
and agricultural fields. Land use surrounding the proposed mega -park is predominately comprised of
undeveloped forested lands interspersed with agricultural fields and single family residential homes. Access to
the mega -park is via Country Club Road or Edwin Robertson Road.
The purpose of the proposed project is to develop the Person County Business and Industrial Park to
accommodate a semiconductor fabrication chip plant as well as critically necessary support facilities for the
main industry, which will serve to bring significant economic relief to the citizens of Person County.
Semiconductor fabrication chip plants (commonly called a fab or foundry) produce devices such as integrated
circuits. An integrated circuit or monolithic integrated circuit (also referred to as an IC, a chip, or microchip) is
a set of electronic circuits on one small flat piece (or "chip") of semiconductor material, which is normally
constructed of silicon. ICs are now used in virtually all electronic devices and have revolutionized the world of
electronics. Computers, mobile phones, and other digital home appliances are now inextricable parts of the
structure of modern societies, made possible by the small size and low cost of ICs.
The proposed Person County Business and Industrial Mega -Park layout is comprised of 27 buildings including
the 3.5 million square foot central operations facility. The proposed mega -park is suitable for the proposed
development based on specific industry requirements including, but not limited to, a minimum of 200 acres
with compatible zoning, access to available and high-quality electricity (3 Megawatts during initial phases),
experienced workforce, and direct routes to interstates.
Person County has identified the proposed mega -park as an economic development priority and has invested
significant resources into the planning and due -diligence required to develop the mega -park. The N.C.
Department of Commerce has identified Person County as a Tier 1 county, based on the average
unemployment rate, median household income, percentage growth in population, and adjusted property tax
base per capita. Based on an Economic Impact Study completed by N.C. Department of Commerce for the
project, the ongoing, annual employment impact of the new facility will result in approximately 7,870 jobs in
the Person County area including 4,000 direct company jobs and an additional 3,870 jobs it the region through
indirect and induced effects.
Due -diligence completed to date includes a Phase I Environmental Site Assessment, geotechnical study,
wetland and stream investigations, historic and cultural resource surveys, threatened and endangered species
surveys, a traffic impact analysis, and economic impact assessment. In addition, on-site concurrence meetings
and pre -application meetings have been held with the U.S. Army Corps of Engineers and N.C. Division of Water
Resources.
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The County has incorporated concerns of relevant stakeholders into their master plan and studied the
development needs and patterns of the industrial clients it wishes to attract. The County has completed the
rezoning, environmental and utility infrastructure studies necessary to attached industrial users, in order to
facilitate an expedient approval process. The property is currently zoned RC -Rural Conservation and the
proposed use is consistent with the current zoning and is considered a permitted use. See Zoning information
included in Appendix D.
To accomplish the goals of the Project, the Applicant has proposed the Preferred Alternative as the Least
Environmentally Damaging Practicable Alternative (LEDPA). Based on the proposed mega -park layout
approximately 46, 959 linear feet of stream and 9.1 acres of wetland will be impacted by the proposed project.
3.0 SITE DESCRIPTION
3.1 Site Location
The proposed project is situated on approximately 1,350 acres and is located approximately 5 miles north of
Roxboro in Person County, North Carolina (see Figure 1. Vicinity Map). The proposed mega -park is comprised
of both wooded and agricultural fields. Land use surrounding the proposed mega -park is predominately
comprised of undeveloped forested lands interspersed with agricultural fields and single family residential
homes. Access to the mega -park is via Country Club Road or Edwin Robertson Road. The proposed mega -park
is located in the Roanoke watershed (HUC 03010104) and all surface waters drain to Story's Creek and
Marlowe Creek, located along the western and eastern property boundaries respectively. The property is
located in the Piedmont Physiographic Province.
A FEMA Flood Rate Insurance Map (FIRM) is included for review (Figure 3: FEMA FIRM MAP). The map shows
the project area as located in both Zone AE and Zone X. Areas of the property in the immediate vicinity of
Story's and Marlowe Creek, generally located along the western and eastern project boundaries, are
designated as Zone AE of the 100 -year flood plain. All other areas of the property are located Zone X
categorized as occurring outside of the 100 -year floodplain and having minimal flood hazard. Furthermore,
these areas are above the 500 -year flood level. The project has been designated to comply with the applicable
FEMA -approved state and local floodplain management requirements and no increase in the 100 -year flood
elevation is anticipated.
3.2 Site Conditions
The proposed mega -park is comprised of both wooded and agricultural fields. Land use surrounding the
proposed mega -park is predominately undeveloped forested lands interspersed with agricultural fields and
single family residential homes. Access to the property is via Country Club Road or Edwin Robertson Road.
The majority of the proposed mega -park has moderate slopes along a ridgeline that bisects the center of the
property. Elevations range from 400 feet above mean sea level (MSL) along the western and eastern
boundaries to 492 feet MSL in the center of the property. Surface waters on the property drain to Story's Creek
and Marlowe Creek, located along the western and eastern property boundaries respectively.
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The property was delineated by ECS, Inc to identify the presence and location of jurisdictional wetlands and
streams within the project area. The wetland delineation was performed in accordance with the U.S. Army
Corps of Engineers (COE) 1987 Delineation Manual and subsequently issued Regional Supplement to the 1987
Delineation Manual. The initial field work for the proposed mega -park was conducted in June and August of
2016. The delineation was verified by Eric Alsmeyer on July 28th, August 4th and August 5th. Additional areas
associated with roadway improvements were delineated in June 2017 and have not been confirmed as of the
date of this report. Documents pertaining to the wetland delineation and subsequent confirmation are
provided in Appendix B: Wetland Delineation Information. There are no wetlands, open water, stream and
associated upland buffers within the Project Area that are under a deed restriction, conservation easement
restrictive covenant, or other land use protective instrument.
4.0 PURPOSE AND NEED
The purpose of the proposed project is to develop the Person County Business and Industrial Mega -Park to
accommodate a semiconductor fabrication chip plant as well as critically necessary support facilities for the
main industry, which will serve to bring significant economic relief to the citizens of Person County. An
integrated circuit or monolithic integrated circuit (also referred to as an IC, a chip, or microchip) is a set of
electronic circuits on one small flat piece (or "chip") of semiconductor material, normally silicon. ICs are now
used in virtually all electronic equipment and have revolutionized the world of electronics. Computers, mobile
phones, and other digital home appliances are now inextricable parts of the structure of modern societies,
made possible by the small size and low cost of ICs.
The County has incorporated concerns of relevant stakeholders into their master plan and studied the
development needs and patterns of the industrial clients it wishes to attract. Based on these findings, the
optimal layout for a semiconductor fabrication chip plant incorporates all elements of production contiguous
to one another and arranged in the most efficient manner for maximum efficiency and cost benefits.
Furthermore, the operations of this industry will require significant resources to support the main facility
including manufacturing, research and development, chemical and gas suppliers, engineering and
maintenance, and public safety facilities. Having these support facilities in close proximity to the main facility
is critical for the operations.
The proposed Person County Industrial Mega -Park layout is comprised of 27 buildings, in addition to the
central operations facility. The central operations facility is comprised of 3.5 million square feet. The central
part of a semiconductor fabrication chip plant is the clean room, an area where the environment is controlled
to eliminate all dust, since even a single speck can ruin a microcircuit, which has features much smaller than
dust. The clean room must also be damped against vibration and kept within narrow bands of temperature and
humidity. Controlling temperature and humidity is critical for minimizing static electricity. In addition, the
manufacturing facility will consist of cooling towers, waste water treatment facilities, waste facilities, office
space, associated parking, and vehicular load deck areas. Manufacturing facilities of this size require high-
quality and easily accessible electrical power which is uniquely available at the proposed mega -park.
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To effectively maintain and operate the central operations facility, support buildings and infrastructure (i.e.
stormwater, utilities, parking) will be required. The proposed industrial park will house one (1) 1.2 million
square feet thin-film solar cell manufacturing facility to supplement the exorbitant energy requirements of the
overall proposed industrial park. Thin film solar cell devices are designed to convert light energy to electrical
energy and are widely used because of their relatively low cost and their efficiency in producing electricity.
The industrial park will also contain four (4) 75,000 square feet buildings to supply gas to the manufacturing
process. To efficiently and safely provide chemicals necessary for the manufacturing process, ten (10)
chemical supplier buildings need to be in close proximity to provide immediate delivery and suitable storage
space of the chemicals. As mentioned, the clean room is a central component of the semiconductor fabrication
chip plant that requires specific support materials in order to maintain operational efficiency of the plant.
Three (3) 75,000 square feet buildings are required to house the necessary tubing, plastics, and valves needed
for the clean room. In addition, two (2) (buildings) both 75,000 square feet in size are required by clean room
contractors tasked with maintenance and upkeep of the clean room. An additional eight (8) buildings and
associated infrastructure improvements is required for engineering support services such as electrical, steel,
structural, mechanical, mechanical processing buildings.
Based on the 2017 North Carolina Department of Commerce report, the median household income for families
living in the County was $54,474 and the per capita income for the county was $22,189. About 9.4% of families
and 19% of the population were below the poverty line in Person County. The N.C. Department of Commerce
annually ranks the state's 100 counties based on economic well-being and assigns each a tier designation.
These designations are based on the average unemployment rate, median household income, percentage
growth in population, and adjusted property tax base per capita. The 40 most distressed counties are
designated as Tier 1, the next 40 as Tier 2, and the least 20 least distressed as Tier 3. Person County is
currently ranked as a Tier 1 county.
Person County has identified the proposed mega -park as an economic development priority and has invested
significant resources into the planning and due -diligence required to develop the property. Due -diligence
completed includes a Phase I Environmental Site Assessment, geotechnical study, wetland and stream
investigations, historic and cultural resource surveys, threatened and endangered species surveys, a traffic
impact analysis, and economic impact assessment. A copy of all reports have been included in Appendices B
and C respectively.
The County has completed the rezoning, environmental and utility infrastructure studies necessary to attract
industrial users, to facilitate an expedient approval process. The property is currently zoned RC -Rural
Conservation and the proposed use is consistent with the current zoning and is considered a permitted use.
See Zoning information included in Appendix D.
Based on an Economic Impact Study completed by N.C. Department of Commerce for the project, the ongoing,
annual employment impact of the new facility will result in approximately 7,870 jobs in the Person County
area including 4,000 of direct company jobs and an additional 3,870 jobs in the region through indirect and
induced effects. A copy of the Economic Impacts Study has been included as Appendix E.
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5.0 ALTERNATIVES ANALYSIS
The alternatives that were evaluated to determine the Least Environmentally Damaging Practicable
Alternative (LEDPA) include: (1) The no -build alternative, (2) off-site alternatives, and (3) on-site alternatives.
Each alternative will be discussed in detail below. The criteria evaluated during site selection for this type of
facility is extensive. However, the quality and quantity of electricity, water and waste -water are the primary
considerations for this specific type of industry. After consideration of available alternatives to meet the needs
of the project, the Preferred Alternative as proposed, is considered the Least Environmentally Damaging
Practicable Alternative (LEDPA). The Preferred Alternative has been designed to accommodate the substantial
energy, water, waste -water and land needs of a semi -conductor chip manufacturing plant and associated
support facilities, which will serve to bring significant economic relief to the distressed Person County.
5.1 No -Build Alternative
The No -Build Alternative, which would avoid all impacts to aquatic resources, is not a viable option given the
Purpose and Need of the Project is to develop the Person County Business and Industrial Mega -Park to house a
specific industry and deliver significant economic relief to the residents of Person County, currently
categorized as a severely distressed, Tier 1 County. The no -build alternative would result in a continued lack
of economic growth resulting in lost job opportunities, loss in tax revenue for the County, loss of local
expenditure of dollars, and residents would continue to be forced to commute farther distances for work.
5.2 Off-site Alternatives
It is rare that a single site meets all the criteria necessary for the successful development of a semiconductor
fabrication chip plant. Power requirements for a semiconductor fabrication chip plant are significant. The
existing availability of power sets the Person County Mega -Park apart from alternative locations. Currently the
proposed mega -park is served by a 2,422 Megawatt Steam Plant, a 729 Megawatt Steam Plant, a 49 Megawatt
Combined Cycle Plant and 230 KV lines and 115 KV lines that cross the property. The amount and quality of
available power in addition to the amount of available water, wastewater, natural gas and telecom further sets
the proposed Person County Mega -Park apart. Based on information from CH2M Hill there are currently only 5
sites globally that compare to the suitability of the Person County Mega -Park. Based on information from the
N.C. Economic Development Partnerships of N.C., detailed information concerning global site exploration
activities are proprietary.
Within the State of North Carolina, however, there are currently three other mega -sites in addition to the
Person County Mega -Park. These include the Chatham -Siler City Megasite, Greensboro -Randolph Megasite and
the Moncure Megasite. All three were evaluated as potential off-site alternatives for the proposed project. As
stated above the primary considerations for this type of industry are quality and quantity of electricity, water
and waste -water. Based on a comparison of all four sites, including the preferred alternative, there are no
other sites that can readily meet or address the requirements for this type of customer. A comparison of all
four sites is provided in Table 1 below.
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Table 1: Primary Matrix Criteria Evaluated for Off -Site Alternatives
Preferred Alternative
Acreage
1,350 acres
Water
1 MGD, up to 4 MGD
Wastewater
0.75 MGD, double to 1.5 MGD
Natural Gas
Available
Electricity
5MW, Expand to 50 MW
Chatham -Siler City Advanced Manufacturing Site
Acreage
2,879 areas
Water
16 -inch water line, 4+ MGD capacity
Wastewater
18 -inch sewer line, 4+ MGD treatment capacity
Natural Gas
6 -inch pipeline, 350 psi
Electricity
230 kV Capacity
Greensboro Randolph Megasite
Acreage
2,000 acres
Water
16 -inch dual fed water line, 5.47 MGD line capacity, 25 MGD excess system capacity (Planned)
Wastewater
16 -inch sewer line, 2.16 MGD line capacity, 24 MGD excess system capacity (Planned)
Natural Gas
12 -inch pipeline provided by Piedmont Natural Gas, 400 psi (Planned)
Electricity
115 kV lines (Planned)
Moncure Megasite
Acreage
2,568 acres
Water
6 -inch water line, 3 MGD+ capacity
Wastewater
16 -inch sewer line 12 MGD+ treatment capacity
Natural Gas
6 -inch pipeline, 500 psi
Electricity
115kV lines
*Provided by Austin Rouse, Research Analyst and Certified Sites Program Coordinator, Economic
Development Partnerships of N.C.
5.3 On -Site Alternatives
To provide an optimal facility layout that is arranged in the most efficient manner, on-site layouts were
examined to locate the facility in a manner that avoids and minimizes impacts to environmentally sensitive
areas to the maximum extent practicable. The current proposed layout provides sufficient area to construct
the approximately 3.5 million square feet central operations facility along the existing ridgeline which will
serve to minimize impacts to streams and wetlands, avoid all impacts to the 100 -year floodplain, will not
encroach on the existing utility easement, and will require the least amount of cut and fill based on the existing
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Raleiqh, NC 27607
percent slope. Five central operations facility layouts were examined to determine which one impacted the
least amount of streams and wetlands as a whole. All five central operations facility layout options avoid
impacts to Story's Creek, floodplains, and associated wetland features located within the western portion of
the project site. Additional support buildings and infrastructure located in the northwestern portion of the
project site have avoided impacts to Story's Creek, floodplain, and associated wetland features
Option 6.2 reduced the amount of streams impacted to 9,275 linear feet and wetlands impacted to 0.60 acres.
However, impacts to the 100 -year floodplain are unavoidable with this option. Option 6.3 impacts a greater
amount of streams (11,659 linear feet) and wetlands (2.21 acres), impacts the 100 -year floodplain and
encroaches on the electrical power line to the north. Option 6.4 is situated on an existing ridgeline reducing
the amount of stream impacted to 9,113 linear feet and wetlands impacted to 0.48 acres, however impacts to
the 100 -year floodplain are unavoidable with this option. Option 6.5, impacts the greatest amount of streams
(12,820 linear feet) and wetlands (2.4 acres), results in impacts to the 100 -year floodplain and encroaches on
the existing utility easement. Therefore, the selected alternative, the LEDPA was determined to meet the size
requirements of the proposed facility, resulted in the least amount of impacts to Waters of the U.S. and
provided for access to the property as well as connectivity of the main operations facility to other the support
facilities required for the property. Table 2 below lays out the primary site considerations evaluated for all on-
site alternatives during design.
Table 2: Primary Matrix Criteria Evaluated During Design for Preferential On -Site Layout
Preferred Alternative
Average Percent Slope
7%
Impacts to Waters of the U.S.
3. 279 LF stream/0.9 acres wetland
Impacts to Flood Plain (100 Year)
Yes
Existing Power Easement Encroachment
No
Option 6.2
Average Percent Slope
18%
Impacts to Waters of the U.S.
9,275 LF stream/0.60 acres wetland
Impacts to Flood Plain (100 Year)
Yes
Existing Power Easement Encroachment
No
Option 6.3
Average Percent Slope
18%
Impacts to Waters of the U.S.
11,659 LF stream/2.21 acres
wetland
Impacts to Flood Plain (100 Year)
Yes
Existing Power Easement Encroachment
Yes
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Option 6.4
Average Percent Slope
18%
Impacts to Waters of the U.S.
9,113 LF stream/ 0.48 acres
wetland
Impacts to Flood Plain (100 Year)
Yes
Existing Power Easement Encroachment
No
Option 6.5
Average Percent Slope
18%
Impacts to Waters of the U.S.
12,820 LF stream/ 2.4 acres
wetland
Impacts to Flood Plain (100 Year)
Yes
Existing Power Easement Encroachment
Yes
5.4 Preferred Alternative
The criteria evaluated during site selection for this type of facility is extensive. CH2M Hill, a nationally
recognized site consultant firm, evaluated criteria specific to the industry for the Person County Mega -Park
and a copy of the Selection Criteria Matrix has been included in Appendix F. The Selection Criteria Matrix
considered 60 criteria factors and project specific requirements related to the industry so that a score could be
assigned. The score was weighted based on how important the criteria and/or requirement is to the industry.
A score of 10 was considered extremely significant and important; while, a score of 2 was considered not
significant and not important. The weighted optimal sum will change by project based on the criteria assessed.
Generally, the scores are based on the circumstances that existed 2 years ago and now the scores for the
Person County Mega -Park would be considered higher, based on information from CH2M representative,
Richard Sheehy.
The site selection matrix requirements used in the Selection Criteria Matrix (Appendix F) can be grouped into
5 general categories, and they are: Location, Site Characteristics, Infrastructure, Financials, and Incentives.
Each of these categories were further divided into specific criteria. The specific criteria were assigned an
Optimal Score based on importance to the industry and the Person County Mega -Park was assessed as a
comparison to the Optimal Score. The Person County Site ranked 356 out of a possible 423 available points
evaluated in the site selection matrix completed by CH2M Hill. Most notable scores for the Person County
Mega -Park are within the Site Characteristics and Infrastructure categories. The main section of the property
is relatively square and has additional properties that are adjacent and/or nearby. Therefore, a relatively high
score was assigned to the "shape" criteria and a maximum score was assigned to the "compatible adjacent
uses" criteria since the proposed mega -park will enhance the ability to attract manufacturers. Extraordinarily
rare for project sites of this magnitude, the Person County Mega -Park achieved the maximum score for the
"electricity minimum", "natural gas", and "fiber" criteria, which are extremely important for this industry. The
availability of electrical power, water, fiber optic for the Person County Mega -Park is one of the best in the
United States. Also, of significant importance for this industry are the "water" and "waste water" criteria,
which the Peron County Mega -Park scored relatively high. Other notable criteria that the Person County Mega -
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Park scored relatively high or obtained the maximum number are "regional airport", "access from interstate",
"technology universities", "silicon experienced workforce", "regional electronic managers", "region
recruitability", "training ability", "site zoning", and "adjacent zoning".
6.0 JURISDICTIONAL IMPACTS
To accomplish the goals of the Project, the Applicant has proposed the Preferred Alternative as the Least
Environmentally Damaging Practicable Alternative (LEDPA), as the least impactful action to jurisdictional
areas when compared to other alternatives. To accomplish the goals of the Project, impacts to jurisdictional
Waters of the U.S. are unavoidable. The location of impacts to jurisdictional Waters of the U.S. identified within
the Project limits are shown on the attached Impact Maps (Appendix G: Person County Mega -Park -
jurisdictional Waters of the U.S. Impacts Maps - Sheets 1-6). Based on the proposed park layout approximately
46,959 linear feet of stream and 9.1 acres of wetland will be impacted by the proposed project. Storm runoff
from the proposed park will be managed and treated and ultimately directed into off-site waters. Therefore,
the drainage area of the receiving waters located off-site will not be reduced. Rip -rap dissipater pads that will
be installed flush with the existing grade of the stream bed to allow for aquatic life passage (see Figure 6 for
Typical Plan, Profile, and Cross Sectional Views).
7.0 AVOIDANCE AND MINIMIZATION
Impacts to jurisdictional features were avoided and minimized to the maximum extent practicable by
incorporating resourceful site planning, including the utilization of the wetland delineation to adjust the layout
to avoid and minimize impacts. After the wetlands were delineated, an engineering plan was developed to
meet all needs at the proposed mega -park, while minimizing impacts to Waters of the U.S.
Alternative siting locations for the central operations facility are limited based on the size and layout
requirements. The current proposed layout provides sufficient area to construct the approximately 3.5 million
square feet facility as well as position the facility along the existing ridgeline which will serve to minimize
impacts to 2nd order streams. Building were strategically placed to maximize buildable area on the proposed
mega -park in regard to building shape and size, location, access, functionality and circulation. The proposed
support facilities have been designed and strategically located to avoid impacts to the main stem of Story's
Creek and its floodplain. Furthermore, all environmentally sensitive areas have been avoided in the
northwestern portion of the property, also associated with Story's Creek.
An Erosion and Sediment Control (E&S) Plan that meets the latest State and local regulations and adheres to
the methodology prescribed in the North Carolina Sedimentation and Pollution Control Act of 1973 will be
utilized. All erosion and sediment control measures will be checked for stability and operation following every
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runoff producing rainfall, but in no case less than once every week. Any needed repairs will be made
immediately to maintain all measures designed. The project will meet all relative requirements of Best
Management Practices and Engineered Stormwater Control Structures as outlined through State and Local
Stormwater Rules. Stormwater management on-site will managed and treated before discharging into down
gradient waters in order to protect waters from degradation. Therefore, the project should have no effect on
downstream waters, shellfish or other aquatic species. (see Figure 6 for Typical Plan, Profile, and Cross
Sectional Views).
8.0 COMPENSATORY MITIGATION
Compensatory mitigation for these unavoidable impacts will be achieved through payment into the North
Carolina Division of Mitigation Services (DMS) in -lieu fund. There are sufficient opportunities to meet the
need if we're permitted to use the larger service area. The mitigation will take place in one following HUC's
Roanoke 03010103, 03010104 or 03010102. An email confirming mitigation credit availability from DMS is
attached in Appendix H.
9.0 SUPPORTING SITE INFORMATION
9.1 Threatened and Endangered Species Information
An Endangered Species Project Review was conducted to gain insight regarding the potential presence of
Endangered Species Act (ESA) listed species within or in the vicinity of the Project. The following agencies and
associated databases were reviewed:
• U.S. Fish and Wildlife Services (USFWS) - Information, Planning and Consultations Systems (IPaC)
• North Carolina Natural Heritage Department (NHP) database
Based upon a review of available information, one (1) federally protected species is currently listed by USFWS
for Person County. The dwarf -wedge mussel (Alasmidonta heterodon) is currently listed as endangered on the
Endangered Species, Threatened Species, Federal Species of Concern, and Candidate Species list for Person
County (dated 12-27-2012). There is no critical habitat identified for this species within the project area based
on results from the IPaC database search. Therefore, the project will not affect the dwarf -wedge mussel or its
critical habitat.
Furthermore, USFWS issued a scoping response letter on July 11, 2014 that stated that the proposed action is
not likely to adversely affect any federally -listed endangered or threatened species, their formally designated
critical habitat, or species currently proposed for listing under the Act at the property and all requirements of
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section 7(a)(2) of the Act have been satisfied. A copy of the scoping response letters has been included in
Appendix B.
9.2 Cultural Resources
A query of the North Carolina State Historic Preservation Office (SHPO) database was performed for the
Project and the vicinity (0.25 miles from the project boundary) to determine the effect, if any, that the project.
No National Register sites or sites Eligible for listing in the National Register are present on the property or
within 0.25 miles of the property.
In addition, an archaeological survey was completed by Archaeological Consultants of the Carolinas (ACC) in
July 2017. Twelve (12) archaeological resources were identified during the course of this investigation. None
of the 12 resources identified were considered to retain research potential beyond the survey level of
investigation and have recommend not eligible for the National Register. A concurrence letter from the State
Historic Preservation Office was received on September 15, 2017. A copy of this report has been included in
Appendix C.
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FIGURES

APPENDIX G
WATERS OF THE US IMPACT MAPS

Legend
F L°o
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0
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-
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Intermittent Stream (R4)
Perennial Stream (R3)
- - •- - •
Other Stream
Permanent Wetland Impact - 9.1 Acres
Ponds
Wetlands
NOTES:
1. WATERS OF THE U.S. WITHIN THE PROJECT STUDY
LIMITS HAVE BEEN GPS LOCATED BY TIMMONS GROUP.
2. WATERS OF THE U.S. HAVE NOT BEEN CONFIRMED BY
THE U.S. ARMY CORPS OF ENGINEERS.
3. PROJECT STUDY LIMITS ARE APPROXIMATE.
4. TOPOGRAPHY BASED ON USGS LIDAR DATA.
5. COWARDIN STREAM CLASSIFICATIONS ARE BASED
SOLELY ON FIELD OBSERVATIONS. NO FORMAL STREAM
ASSESSMENT METHODOLOGY WAS COMPLETED TO
DETERMINE THESE COWARDIN CLASSIFICATIONS.
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LVITIMF1iT159
NOTES:
1. WATERS OF THE U.S. WITHIN THE PROJECT STUDY
LIMITS HAVE BEEN GPS LOCATED BY TIMMONS GROUP.
2. WATERS OF THE U.S. HAVE NOT BEEN CONFIRMED BY
THE U.S. ARMY CORPS OF ENGINEERS.
3. PROJECT STUDY LIMITS ARE APPROXIMATE.
4. TOPOGRAPHY BASED ON USGS LIDAR DATA.
5. COWARDIN STREAM CLASSIFICATIONS ARE BASED
SOLELY ON FIELD OBSERVATIONS. NO FORMAL STREAM
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Legend
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Ponds
Wetlands
/
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1. WATERS OF THE U.S. WITHIN THE PROJECT STUDY
LIMITS HAVE BEEN GPS LOCATED BY TIMMONS GROUP.
2. WATERS OF THE U.S. HAVE NOT BEEN CONFIRMED BY
THE U.S. ARMY CORPS OF ENGINEERS.
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4. TOPOGRAPHY BASED ON USGS LIDAR DATA.
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SOLELY ON FIELD OBSERVATIONS. NO FORMAL STREAM
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LVITIMFTiT159
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– – •– – • Other Stream
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Ponds
LVITIMF1iT159
NOTES:
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LIMITS HAVE BEEN GPS LOCATED BY TIMMONS GROUP.
2. WATERS OF THE U.S. HAVE NOT BEEN CONFIRMED BY
THE U.S. ARMY CORPS OF ENGINEERS.
3. PROJECT STUDY LIMITS ARE APPROXIMATE.
4. TOPOGRAPHY BASED ON USGS LIDAR DATA.
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APPENDIX I
N.C. DIVISION OF MITIGATION SERVICES COORESPONDANCE

Anna Reusche
From: Williams, Kelly <[e-mail]>
Sent: Tuesday, January 16, 2018 10:54 AM
To: Anna Reusche
Subject: Checking on Credit Availability
Anna -
I discussed this potential request with my supervisor and our procurement manager. We have done projects there and have some in place now, but have never
had much demand in the upper Roanoke. At this point with the limited information available, we think DMS would be able to accept payment for the credits
contingent on the permits allowing the mitigation in Roanoke 03010103, 03010104 or 03010102. It's likely we'd concentrate on getting it in 03010104, but
would need flexibility to provide at least a portion of the credits in the adjacent HUCs.
We do have credits available in these areas now, just not as many as you're potentially going to need. So, we'd need to go after new projects. We do think there
are sufficient opportunities to meet the need if we're permitted to use the larger service area.
Kelly Williams
In -Lieu Fee Program Coordinator
Division of Mitigation Services
Department of Environmental Quality
919 707 8915 office
[e-mail]
US Postal Service Address:
1652 Mail Service Center
Raleigh, NC 27699-1652
From: Anna Reusche [mailto:[e-mail]]
Sent: Monday, January 15, 2018 1:52 PM
To: Williams, Kelly <[e-mail]>
Subject: [External] Checking on Credit Availability

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to [e-mail].
Hi Kelly,
It has been a while since we crossed paths. Hope your New Year is going well so far! We are working on an economic development project in 03010104 and are
likely going to need the following in mitigation. David Bailey and Ross Sullivan asked that we go ahead and reach out to be sure that DMS would be able to fill the
need, in the event that no private banks are available. I checked with the private banks last summer and no one had any in that area at that time. We will be sure
and check again as we get closer.
9.1 in riparian wetlands credits
46,959 in stream credits
Please feel free to call me with any questions!
Anna Reusche, PWS
Environmental Project Manager
TIMMONS GROUP www.timmons.com
5410 Trinity Rd, Suite 102 1 Raleigh, NC 27607
Office: 919.866.4500 Fax: [phone] Mobile: [phone]
[e-mail]
Your Vision Achieved Through Ours
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