20151256 Ver 2_USACE Correspondence_20180917

Strickland, Bev
From: Gibby, Jean B CIV USARMY CESAW (US) <[e-mail]>
Sent: Monday, September 17, 2018 2:34 PM
To: Jim Spangler; Dalton Cook
Cc: Alexander, Tasha L CIV USARMY CESAW (US); Homewood, Sue
Subject: [External] Scannell Development/Hodge Road
Attachments: Section 7.ppt
Jim/Dalton,
I have been trying to write the document, which has resulted in me having to review the previously provided documents
to Tasha, so that I can bring myself up to speed in order to write an environmental assessment for the project. As a
result of our discussion with Scott/Sam Collinson, it is apparent that the modified purpose and need that we had
coordinated with you back in March is inaccurate:
The primary purpose is to improve intermodal trucking distribution by constructing a regional package transfer
station. This purpose is based on the applicant's needs, as follows:
Construction of warehouse space for a distribution hub that meets industry standards.
* Close proximity to a network of interstates. (Access to (Future) 1-587 (current US -264), (Future) 1-87 (current US -
64/1 -495) and 1-40/440.)
* Central location to take advantage of the intermodal trucking demand created by the international air -freight
hubs in Raleigh and the Triad, the ports of Virginia Beach, VA, Morehead City, NC, and Wilmington, NC, and rail
infrastructure in eastern and central North Carolina.
Based upon our discussion, it appears that the basic purpose and need as a result of our discussion when Scott was here
is "to develop an industrial business park". I will let you craft your overall project purpose based upon the fact that your
client will be catering to multiple end users. Please review the attached slides that can assist you with the development
of that part of the purpose and need.
Your initial documentation provided to support the project lies entirely around the utilization of the facility by one end
user, which we discussed was not the reality of the site. While they may desire to utilize a major portion of the facility,
the fact that the space is being advertised as being available for a little as 30,000 square feet to 1,000,000 square feet,
supports multiple end users. Perhaps, some of the statements that you have made regarding the alternatives analysis
are accurate, but I expect some of them need to be better justified.
When looking at alternatives siting criteria, I suggest that you consider utilizing suitable acreage, zoning restrictions,
utilities, topography, proximity to highways, wetlands/streams, construction costs... -here is an example of how you
should address this in the document for whatever issues assisted with the decision to develop the project. This was
taken from a road project to give you an idea of what we are looking to have.
Issue Measurement and/or constraint
Stream impacts Linear feet of direct impact/number of crossings

Wetland impacts
Acres of direct impacts
Housing/Business Relocations
Number of residences and businesses relocated
by each alternative
Historic structures/Archeological sites
Adverse Impacts
Required Right -of -Way
Acres
Construction Cost
Dollars
In addition, while you provided the two tables about the cut and fill, you need to provide a narrative that specifically
addresses the issue that you are trying to justify.
I know that there has been some discrepancies in the numbers and I spoke with Dalton about that the other day and
that what has been submitted doesn't correlate with the JD information. We really need the accurate JD amounts and
impact amounts.
Please realize that when I write an EA, all the information needs to be there, nobody following up behind me should
have to look back and forth in the administrative record to find answers to their questions. I am in the office the rest of
the day until 530 and in through Thursday should you wish to discuss. The sooner, we can this information, the sooner I
will be able to complete my review and writeup.
Thanks so much in advance,
Jean B. Gibby
Chief, Raleigh Field Office
[phone], Ext. 24

PROJECT PURPOSE
• Objective:
- Distinguish between basic project
purpose and overall project purpose.
100-7-1 DTP-CEHND

PROJECT PURPOSE
• Basic Project Purpose:
- Defines the project purpose in the most
simplistic terms;
- Necessary to evaluate the "water
dependency" of a project.
- A project is "water dependent" if it must be
located in, or in close proximity to a water of the
U.S. in order to fulfill it's basic purpose.
100-7-2 DTP-CEHND

PROJECT PURPOSE
• Water Dependency:
- If you determine a project is not water
dependent, then alternatives, which do not
involve impacts to waters of the U.S. are
presumed to be available to the applicant,
unless clearly demonstrated otherwise.
- Regardless of water dependency, if a project
would result in substantial adverse impacts to
the aquatic environment, an evaluation of
alternatives is required.
100-7-3 DTP-CEHND

PROJECT PURPOSE
• Overall Project Purpose:
- Specific definition of the purpose and need for
an applicant's project.
- Definition should not be so restrictive as to
preclude discussion of alternatives.
- Used in the evaluation of practicable
alternatives under Section 404(b)(1)
Guidelines.
- Corps defines with applicant's input.
100-7-4 DTP-CEHND