20151256 Ver 3_More Info Received_20190221

Homewood, Sue
From:Dalton Cook <[e-mail]>
Sent:Thursday, February 21, 2019 10:43 AM
To:Homewood, Sue
Subject:RE: \[External\] RE: Hodge Rd Business Park
Attachments:Hodge Road - IP Narrative (revised 2-21-19).pdf
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Ms. Homewood,

My apologies. Please see the revised IP Application Narrative which indicates no buffer impacts for the preferred,
proposed site plan. Please let me know if you have any additional questions or comments.

Thank you,

Dalton Cook
Environmental Project Scientist
Spangler Environmental, Inc.
www.SpanglerEnvironmental.com
Raleigh Office 919-875-4288
4338 Bland Road
Raleigh, NC 27609

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From: Homewood, Sue \[mailto:[e-mail]\]
Sent: Tuesday, February 19, 2019 1:25 PM
To: Dalton Cook <[e-mail]>
Subject: RE: \[External\] RE: Hodge Rd Business Park

1

Hello Dalton,

Your information satisfies my comments #2 and #3 below but I don’t see where/how you addressed comment #1.

Thanks,

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

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

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

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

From: Dalton Cook <[e-mail]>
Sent: Thursday, January 31, 2019 4:28 PM
To: Homewood, Sue <[e-mail]>
Subject: \[External\] RE: Hodge Rd Business Park

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Ms. Homewood,

Please see the attached drawings and a letter of wetland mitigation credit availability. Would you like me to print out an
entire new application package and mail it to you or are these digital copies sufficient?

Thank you,

Dalton Cook
Environmental Project Scientist
Spangler Environmental, Inc.
www.SpanglerEnvironmental.com
2

Raleigh Office 919-875-4288
4338 Bland Road
Raleigh, NC 27609

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entity to which it is addressed. This document and attachments may contain information subject to attorney work-product
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contents of this message for any purpose is prohibited. If you have received this message in error, please notify the
sender by return e-mail.

From: Homewood, Sue \[mailto:[e-mail]\]
Sent: Tuesday, January 15, 2019 12:39 PM
To: Dalton Cook <[e-mail]>
Cc: Gibby, Jean B CIV USARMY CESAW (US) <[e-mail]>
Subject: Hodge Rd Business Park

Dalton,

I have reviewed the application and have a few items that need to be addressed before I can draft up the Certification:

1. The application document contradicts itself with regards to impacts to the buffers. The Alternative Site Plans
(page 11) and Figure 1 state and show that the preferred alternative includes impacts to both Zone 1 and Zone
2. But in other locations within the document it is indicated that the project has been redesigned to avoid all
impacts to buffers. Please go back through the document and provide consistency throughout.
2. With regards to the stormwater ponds, I understand that those are reviewed and approved by the local
government, however most ponds are designed with discharge pipes/channels and these often require impacts
to the buffers. Please show enough detail on the ponds to show the outlet means/locations and if necessary
modify the application to include a Buffer Authorization application for any impacts from stormwater discharges
through the adjacent buffers.
3. The email from Restoration Systems confirming available wetland credits does not indicate any date it was
sent. Please provide some indication that credits are currently available. Also please note that DWR will require
all wetland mitigation to be secured prior to any impacts unless a phased mitigation plan is clearly proposed by
the applicant.

Thanks,

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

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

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

3

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

4

Exhibit B
Supporting Documentation
Section 401 Individual Permit Application
Hodge Road Warehouse Park aka "Eastgate 540"
Wake County, North Carolina
Applicant:
Mr. Joel Scannell
Scannell Development Company
1800 Diagonal Road, Suite 600
Alexandria, VA 22314
Agent:
Mr. James A. Spangler, CEI, A.M. ASCE
Spangler Environmental, Inc.
4338 Bland Rd.
Raleigh, NC 27609
December 2018

TABLE OF CONTENTS
1.0
PROJECT DESCRIPTION
2
1.1
Prior Agency Coordination ------------------------------------------------------------------------------------
3.
2.0
PURPOSE AND NEED FOR THE PROJECT
6
3.0
ALTERNATIVES ANALYSIS
6
3.1
Alternatives Considered
7
3.1.1 Off -Site Alternatives ----------------------------------------------------------------------------------
7.
3.1.2 No -build Alternative
10
3.1.3 On-site Alternatives within the Preferred Alternative Site
------------- 1-0.
3.1.4 Alternative Site Plans
12
3.1.5 No Permit Alternative
12
3.2
Alternatives Dismissed ------------------------------------------------------------------------------------------
13
3.3
Construction Sequence and Timeline --------------------------------------------------------------
13
4.0
ENVIRONMENTAL SETTING OF PREFERRED ALTERNATIVE --------------------------------
14
4.1
Physiographic, Topographic, Geology, and Land Use --------------------------------------------
14
4.2
Soils
1-5.
4.3
Water Resources
15
4.4
Wetlands ---------------------------------------------------------------------------------------------------------------
15
4.5
Threatened and Endangered Species ----------------------------------------------------------------------
15
4.6
Cultural Resources
18
5.0
SECTION 404 IMPACTS AND PERMITTING
18
5.1
Proposed Stream Impacts ---------------------------------------------------------------------------------------
18
5.1.1 Avoidance and Minimization of Stream Impacts ----------------------------------------
1-8-
5.2
Proposed Wetland Impacts -------------------------------------------------------------------------------------
18
5.2.1 Avoidance and Minimization of Wetland Impacts --------------------------------------
18
5.3
Proposed Riparian Buffer Impacts -------------------------------------------------------------------------
19
5.3.1 Avoidance and Minimization ofRiparian Buffer Impacts ---------------------------
1-9.
5.4
Compensatory Mitigation --------------------------------------------------------------------------------------
19
5.5
Potential Impacts on Human Use Characteristics ---------------------------------------------------
1-9-
5.6
Cumulative and Secondary Impacts -----------------------------------------------------------------------
20
6.0
REFERENCES ------------------------------------------------------------------------------------------------------------------
21.
APPENDIX A: Figures 1 - 11
APPENDIX B: Natural Heritage Program Letter
APPENDIX C: SHPO and Office of State Archeology Clearance Letter
APPENDIX D: Compensatory Mitigation Letters
APPENDIX E: NC DWR Buffer Applicability Letter
APPENDIX F: NC WAM Data Form
APPENDIX G: Corps Confirmation of LEDPA
Hodge Road Property 1

1.0 PROJECT DESCRIPTION
Scannell Development Company proposes the construction of an approximately 1,000,000 s.f.
warehouse distribution hub comprised of six (6) buildings. The buildings will include 30 -ft clear ceiling
heights, supporting office space, dock -high and drive in loading areas, vehicular parking, tilt -up concrete
construction, ESFR sprinkler systems, 190 -ft wide truck courts with rear and cross -dock loading
configurations. The use requires a semi -truck roadway, circulation, parking and loading infrastructure,
and required stonnwater and utility services. The proposed warehouse distribution hub is located in
Knightdale on Hodge Road, approximately 2,000 feet north of the intersection of Poole Road and Hodge
Road in Wake County, North Carolina (Figure 1 in Appendix A). The project is being developed to
serve multiple possible end users.
The 78.8 - acre project area has previously been used for agricultural purposes. It has been partially
cleared of vegetation. Field confirmed waters of the US include one jurisdictional stream and multiple
wetlands (see Figure 2 in Appendix A). The project area consists of two parcels that now or formerly
were owned by Mary Lou Murphy and Susan Elain Murphy. These parcels are currently zoned as
Manufacturing and Industrial by the Town of Knightdale. The proposed warehouse distribution center
development construction activities involve unavoidable impacts to jurisdictional wetlands that are
subject to Section 404 regulations under the Clean Water Act ("CWA").
The first phase of this project was initially authorized to impact 0.465 acres of wetland by the USACE
under Nationwide Permit ("NAT") 39 and 12 on February 19, 2016 (Action ID: SAW -2014-02127).
This document is being submitted in efforts to receive an Individual Permit for this project in order to
resume construction activities. The previously authorized NWP project originally proposed additional
wetland impacts at an off-site location for the purposes of installing a sanitary sewer line. These wetland
impacts are no longer necessary because the Town of Knightdale extended its sewer line to the project
site.
Scannell Development Company is submitting an Individual Permit application to the U.S. Army Corps
of Engineers ("USACE") requesting authorization to permanently impact 1.658 acres of wetlands
pursuant to Section 404 of the CWA of 1972 (33 USC 1344). This quantity includes the adjusted
quantity of permanent impacts previously authorized by the 2016 Nationwide Permit. An Individual
Water Quality Certification will also be requested from the North Carolina Division of Water Resources
(DWR) for these impacts pursuant to Section 401 of the Clean Water Act.
This document is intended for use by USACE and DWR as the basis for determining the applicant's
compliance with the Section 404 (b) (1) guidelines and other Section 404 permitting requirements, and
Section 401 water quality certification.
1.1 Prior Agency Coordination
A Nationwide Permit (NWP) was initially pursued for this project verses submitting for an Individual
Pen -nit for all of the impacts at one time, because at the time the NWP PCN was submitted, the project
owner did not own the entire property (the owner had/has a continuing option for the remainder parcels
in the parent project tract.) The site plan showing full build -out was required to be submitted to the
Town of Knightdale for the purposes of rezoning the property for warehouse/industrial use and for the
allocation of utility capacity. At the time the owner was ready to begin construction of the first phase,
Hodge Road Property 2

the owner did not know if the site plan submitted to the Town would be completed under its direction
or if the remainder of the development would be sold by the prior owner to another developer prior to
the commencement of construction activities in the remainder.
Prior coordination with USACE and other Public Agencies regarding this project includes:
• November 10, 2014 - PJD is submitted to Corps. PJD includes the entirety of the parcel.
• November 20, 2014 — Representatives of Corps and Spangler Environmental, Inc. ("SEI") visit
the entirety of the parcel for the purpose of regulatory confirmation of SEI's delineation efforts.
• July 27, 2015 - Representatives of Corps and SEI have an informal meeting regarding permitting
of the project.
• August 28, 2015 - Sketch Plan (version 1) submitted to the Town of Knightdale for the entire
parent parcel.
• August 31, 2015 — NCDOT approves offsite sewer 3 -party utility encroachment agreement for
Phase 1.
• September 10, 2015 - Protected Species Report submitted to the Town of Knightdale
• September 28, 2015 — Sketch Plan (version 2) submitted to the Town of Knightdale for the
entire parent parcel.
• September 28, 2015 — Master Plan submitted to the Town of Knightdale for the entire parent
parcel.
• September 28, 2015 — Traffic Impact Analysis (version 1) submitted to the Town of Knightdale
for the entire parent parcel.
• November 2, 2015 — Offsite sewer construction plan (version 1) submitted to the Town of
Knightdale for Phase 1.
• December 4, 2015 — PCN (NWP 3 9 and NWP 12) is submitted to the USACE and NCDEQ for
Phase I of the project.
• December 7, 2015 — Offsite sewer flood study (version 1) submitted to the Town of Knightdale
for Phase 1.
• December 17, 2015 — NCDEQ issues the 401 water quality certification (DWR # 15-1256) in
response to the PCN.
• December 18, 2015 — Corps' representative sends an email to SEI requesting revisions to the
PJD map within the PCN submittal. The representative also indicates to direct all further
correspondence to a new Corps' representative to be assigned to the project.
• January 7, 2016 — Offsite sewer construction plan (version 2) submitted to the Town of
Knightdale for Phase 1.
• January 11, 2016 — Public infrastructure construction plan (version 1) submitted to the Town of
Knightdale for Phase 1.
• January 20, 2016 - SEI speaks with the new Corps' representative on the phone.
• January 21, 2016 - SEI emails the new Corps representative to provide supporting information
that addresses the original Corps representative's feedback. SEI also provides clarification
regarding the sewer easement impacts. SEI provides new Corps representative with a
compressed PDF of the PCN submittal.
• February 3, 2016 — Offsite sewer flood study approved by the Town of Knightdale for Phase 1.
• February 19, 2016 - Corps issues the NWP 39 and 12 verifications (Action ID: 2014-02127) in
response to the PCN for Phase 1.
Hodge Road Property 3

• March 21, 2016 — Offsite sewer construction plan (version 3) submitted to the Town of
Knightdale for Phase 1.
• March 21, 2016 — Public Infrastructure Construction Plan (version 2) submitted to the Town of
Knightdale.
• March 21, 2016 — Stormwater Management Report approved by the Town of Knightdale for
Phase 1.
• March 22, 2016 — Exempt Plat (version 1) submitted to the Town of Knightdale for Phase 1.
• March 24, 2016 — Offsite sewer erosion and sediment control plan (version 2) submitted to
Wake County for Phase 1.
• March 24, 2016 — Public Infrastructure sediment and erosion control plan (version 2) submitted
to Wake County for Phase 1.
• March 24, 2016 — Hodge Road sediment and erosion control plan (version 2) submitted to Wake
County for Phase 1.
• April 19, 2016 — Traffic Impact Analysis (version 3) submitted to the Town of Knightdale for
the entire parent parcel, as required by zoning (not design -specific).
• April 20, 2016 — NCDOT approves the Hodge Road Planting Permit for Phase 1.
• April 25, 2016 — Exempt Plat (version 2) submitted to the Town of Knightdale for Phase 1.
• May 5, 2016 — Myrick Plat (version 1) submitted to the Town of Knightdale for Phase 1.
• May 6, 2016 — Traffic Impact Analysis (version 4) submitted to the Town of Knightdale for the
entire parent parcel.
• May 10, 2016 — Utility Allocation and Development Agreement (I't Draft) submitted to the
Town of Knightdale for the entire parent parcel.
• May 23, 2016 — Utility Allocation comments received from the Town of Knightdale for the
entire parent parcel.
• May 25, 2016 — Myrick Plat (version 2) submitted to the Town of Knightdale for Phase 1.
• May 27, 2016 — Utility Allocation Agreement (2' Draft) submitted to the Town of Knightdale
for the entire parent parcel.
• June 20, 2016 — Utility Allocation Agreement (3' Draft) submitted to the Town of Knightdale
for the entire parent parcel.
• June 24, 2016 — Exempt Plat (version 2) submitted to the Town of Knightdale for Phase 1.
• June 24, 2016 — Myrick Plat (version 2) submitted to the Town of Knightdale for Phase 1.
• June 28, 2016 — Public Infrastructure Construction Plan (version 3) submitted to the Town of
Knightdale for Phase 1.
• July 25, 2016 — SEI and Corps representative have an informal meeting regarding additional
permitting of the project. The focus of the meeting was explicitly geared towards the preparation
of an IP submittal.
• August 11, 2016 — Public Infrastructure Construction Plan (version 4) submitted to the Town of
Knightdale for Phase 1.
• August 30, 2016 — Public Infrastructure sediment and erosion control plan (version 3) submitted
to Wake County for Phase 1.
• September 14, 2016 — Utility Allocation and Development Agreement recorded with the Town
of Knightdale for the entire parent parcel.
• September 28, 2016 — Deed recorded by Wake Co. clerk documenting the purchase of the land
for Phase 1 (24.447 ac) by SP -Raleigh -Hodge Road, LLC, a business entity of Scannell
Properties/Joel Scannell (applicant). (DB 016548, Page 01463-01473).
Hodge Road Property 4

• September 28, 2016 — Amendment to approved 3 -party utility encroachment submitted to the
NCDOT for Phase 1.
• September 28, 2016 — Exempt subdivision plat recorded with the Town of Knightdale for Phase
1 .
• September 28, 2016 — Myrick easement and right-of-way dedication plat recorded with the
Town of Knightdale for Phase 1.
• September 28, 2016 — Annexation submitted to the Town of Knightdale for Phase 1.
• September 30, 2016 — Myrick easement agreement for Phase 1 recorded with the Town of
Knightdale.
• October 3, 2016 — Public Infrastructure Construction Plan (version 5) submitted to the Town of
Knightdale for Phase 1.
• October 5, 2016 — Public Infrastructure sediment and erosion control plan (version 4) submitted
to Wake County for Phase 1.
• October 14, 2016 — Public Infrastructure sediment and erosion control plan approved by Wake
County for Phase 1. Clearing and grading of fully -permitted Phase I underway.
• October 31, 2016 — NCDOT approves amendment to 3 -party utility encroachment agreement
for Phase 1.
• October 31, 2016 — SEI receives letter from the DE stating NWP 39 and NWP 12 verifications
were being suspended.
• November 1, 2016 - SEI issues a letter responding to the letter from the District Engineer.
• November 9, 2016 — Applicant, SEI and Corps' meet at Corps' Wake Forest office to resolve
suspended NWP verifications.
• November 28, 2016 — SEI receives a letter from the DE reinstating the two previously obtained
NWPs verifications.
• December 15, 2016 — Town of Knightdale approves and issues construction permit for Hodge
Road widening.
• December 15, 2016 — Town of Knightdale approves and issues construction permit for building
#1 in Phase 1.
• December 15, 2016 — Town of Knightdale approves and issues construction permit for public
infrastructure.
• December 22, 2016 — Wake County approves and issues building #1 building permit.
• January 15, 2017 — City of Raleigh approves and issues sewer main extension permit.
• January 15, 2017 — City of Raleigh approves and issues water main extension permit.
• March 2, 2017 — SEI, the Corps representative and a DWR representative hold an Individual
Pertnit Pre -application meeting at the Corps' Wake Forest Field Office.
• June 30, 2017 — Public force main passes City of Raleigh inspections and testing.
• July 11, 2017 — Final plat to subdivide parcel, dedicate easements and dedicate right-of-way
recorded with the Town of Knightdale.
• July 20, 2017 — Public water main extension passes City of Raleigh inspections and testing.
• July 27, 2017 — Completion of building #1 (Wake County)
• August 3, 2017 — Public sewer main extension passes City of Raleigh inspections and testing.
• July — September, 2017 — Various draft Individual Permit narratives submitted to Corps' for
preliminary review; responses from Corps' received and incorporated into current document.
Hodge Road Property 5

2.0 PURPOSE AND NEED FOR THE PROJECT
The purpose of this project is to construct an approximately 1,000,000 s.f. industrial business
park/regional package transfer station, known as "Eastgate 540", which has the potential to serve
multiple end users in geographic proximity to major interstate highway corridors.
The Triangle region provides a competitive advantage for businesses. It is an area that includes high
labor productivity, a modest cost -of -living, affordable higher education, and an excellent primary
education system. Scannell Properties market research indicates that the economy in the Raleigh MSA
region has been resilient and outperformed most of the country throughout the recent recession. Since
late 2009 there have been more than 7,000 jobs announced in the region and more than $700 million in
capital investments in the area over the past 12 to 24 months. Regional economic developers are
currently working with 58 companies who seek a Triangle location for either an expansion or a new
operation. These companies represent more than $2.7 billion in investment and 13,000 jobs. The project
site has been chosen, relative to other MSA's due to this recent influx of new Raleigh-Durham area jobs.
This site is in close proximity to (Future) 1-587 (current US -264), (Future) 1-87 (current US -64/1-495)
and 1-40/440. This network of interstates has been identified as a high priority future Interstate corridor,
as indicated by the December 4, 2015 "Fixing America's Surface Transportation (FAST) Act," enacted
by Congress. The general location was selected also because of the recent improvements to the Port of
Wilmington and Port of Morehead City. These two North Carolina ports ship and receive a variety of
goods and combined they have shipped and received over 6,130,000 tons of goods over the past year.
Proprietary to this project is the ability to provide build -to -suit ownership of up to 1 MM SF east of
Raleigh is a key aspect of its need. Scannell Properties has only two competitors on the east side of
RDU airport for modem light industrial buildings (Hinton Oaks and Greenfield), neither of which has
the land at its option to construct a building larger than 240,000 square feet, and/or sells the built
infrastructure to a user.
3.0 ALTERNATIVES ANALYSIS
Headquarters of the U.S. Army Corps of Engineers ("HQUSACE") guidance from April 22, 1986 and
November 1992 requires that alternatives be practicable to the applicant and that the purpose and need
for the project must be the applicant's purpose and need. This guidance also states that project purpose
is to be viewed from the applicant's perspective rather than only from the broad, public perspective.
The essential point of the HQUSACE policy guidance is that under the Section 404(b)(1) Guidelines,
an alternative must be available to the applicant to be a practicable alternative. Section 40 CFR 230.10
(a) of the Guidelines state that "no discharge of dredged or fill material shall be permitted if there is a
practicable alternative to the proposed discharge which would have less adverse impact on the aquatic
ecosystem, so long as the alternative does not have other significant environmental consequences".
Pursuant to 40 CFR 230. 1 0(a)(2) practicable alternatives are those alternatives that are "available and
capable of being done after taking into consideration cost, existing technology, and logistics in light of
overall project purpose". The 404(b)(1) Guidelines Preamble, "Economic Factors", 45 Federal Register
85343 (December 24, 1980) states, "if an alleged alternative is unreasonably expensive to the applicant,
the alternative is not practicable".
Hodge Road Property

The USACOE has concluded that this proposed activity is in fact the least environmentally damaging
practicable alternative (LEDPA) (Appendix G).
3.1 Alternatives Considered
3.1.1 Off-site Alternatives
Alternatives meeting the purpose and need for the project within an approximately 3 -mile radius
of the mid -pint between the 1-540/1-87 (US -264) interchange and the 1-40/1-540 Interchange
were evaluated by SEL The following criteria were used for identification of alternative proj ect
locations:
• Minimum 75 contiguous acres (individual parcels less than 5 acres were excluded) are
required to accommodate 1,000,000 s.f. of warehouse space on the same elevation plane
for highway truck circulation
• Industrial or Manufacturing zoning by the local municipal planning authority, or
undeveloped sites meeting acreage requirement that could be up -zoned
• Sites not currently developed or under development by evidence of a development plan
filed with the local planning authority as of June 6, 2017.
Seven alternatives, including the "No -Build" scenario were evaluated. A total of six sites,
including the preferred alternative location, met the first criterion of a minimum of 75
contiguous un -built -upon acres within the search radius. These alternative locations are shown
on Figure 3 in Appendix A.
An evaluation of comparative suitability, considering the following criteria, was undertaken on
each site:
• Potential impact to jurisdictional resources (indicated by stream feet/acre taken from
Wake Co. GIS -June 6-27, 2017, and ground-truth/window-survey for verification
when possible by Spangler Environmental, Inc., June, 2017),
• Potential secondary/cumulative impact (indicated by need for significant off-site
utility construction as indicated by utility mapping or available plans found on
municipal Interactive Development Maps, if available, or via local planning authority
contacts -June, 2017), and/or unsuitable topography requiring major grading/hauling
(as indicated by window -survey, and/or major off-site road improvements), and
• Practical availability for acquisition (as determined by whether the site has received
site plan approval or is in plan approval process as a precursor to development, as an
indicator of unavailability.
Based on those investigations the following data was used to evaluate certain relative
subjective and objective criteria, with additional information summarized in the table below.
0 Current Site:
Topo: Elevations range from 294' to 224' = 70' of topo relief on site
Hodge Road Property 7

Acquisition Available: Does not have a Raleigh Development Plan, is not in
an area of Raleigh Economic Development, does not have a designated
Raleigh Future Land Use, and does not include any Raleigh Special Use
Areas.
Proximity to Highway Infrastructure: 1,989 feet to US 64 Hwy using
Hodge Road as access.
0 Site 3:
Topo: Elevations range from 272' to 160' = 112' of topo relief on site
Acquisition Available: Does not have a Raleigh Development Plan, is not in
an area of Raleigh Economic Development, does not have a designated
Raleigh Future Land Use, and does not include any Raleigh Special Use
Areas.
Proximity to Highway Infrastructure: 213 feet to US 64 Hwy, however,
there is currently no road to facilitate access to the highway.
0 Site 4:
Topo: Elevations range from 284' to 184' = 100' of topo relief on site
Acquisition Available: Includes area inside of a Raleigh Supportive Housing
Buffer, does include a parcel with a Raleigh Development Plan, and does
include area designated as a Raleigh Future Land Use including Community
Mixed Use, Moderate Density Residential and Private Open Space.
Proximity to Highway Infrastructure: 7,788 feet to 1-40 using S. New
Hope Road/Jones Sausage Road to facilitate access to the highway.
0 Site 5:
Topo: Elevations range from 216' to 168' = 48' of topo relief on site
Acquisition Available: Does include area inside of a Raleigh Supportive
Housing Buffer, much of the area is included in a Raleigh Development Plan,
and does include areas designated as a Raleigh Future Land Use including
Community Mixed Use, Public Parks and Open Space, Private Open Space,
and Office & Residential Mixed Use.
Proximity to Highway Infrastructure: 7,788 feet to 1-40 using S. New
Hope Road/Jones Sausage Road to facilitate access to the highway.
0 Site 6:
Hodge Road Property 8

0 Site 7:
Topo: Elevations range from 248' to 180' = 68' of topo relief on site
Acquisition Available: Does not include any Raleigh Special Use Areas,
does include areas with Raleigh Development Plans, does not include any
Raleigh Economic Development target areas, and does include areas of
Raleigh Future Land Use including Private Open Space, Low Density
Residential and Moderate Density Residential.
Proximity to Highway Infrastructure: 14,175 feet to 1-40 via a currently
nonexistent access road to Rock Quarry Road to Jones Sausage Road to
facilitate access to the highway.
Topo: Elevations range from 236' to 160' = 76' of topo relief on site
Acquisition Available: Does include area inside of a Raleigh Supportive
Housing Buffer, does include areas with Raleigh Development Plans, and
does include areas of Raleigh Future Land Use including Moderate Density
Residential, Public Parks and Open Space, and Low Density Residential.
Proximity to Highway Infrastructure: 11,078 feet to Hwy 440 using Poole
Road to facilitate access to the highway.
Table 1. Summary of Relative Criteria
Green = Overall relatively more acceptable
Black = Overall relatively acceptable
Red = Overall relatively less acceptable
Hodge Road Property
Approx.
Stream
Off-site Utility
Unsuitable
Floodplain
Access to Highway
Acquisition
Alternative
Acres
Parcels
ft./ac
Needs
Topo
Impacts
Infrastructure
Suitable Zoning
Feasible
No -build
N/A
Property owned
by applicant or
under option; no
Hodge Road
Manufacturing and
resident
(preferred)
. 78.8
2
17.4
Minimal
70' of relief
None
Very Good
Industrial
relocations
Moderately
Feasible -
requires some
Open Space Preserve,
relocation of
3
144.9
1 1
1 9. 8
Minimal
112' of relief
Significant
Poor
General Residential
residents
4
90.1
5
8.1
High
100'of reliefl
None
Moderate
Planned Development
Not Feasible
Conservation
Management, Planned
5
89
4
55
Minimal
48' of relief
Significant
Moderate
Development
Not Feasible
6
98.9
3
0
High
68' of relief
None
Poor
Planned Development
Not Feasible
Residential Mixed Use,
Manufactured
7
93.3
3
13.2
Minimal
76' of relief
Significant
Poor
Housing, Residential -4
Not Feasi��
Green = Overall relatively more acceptable
Black = Overall relatively acceptable
Red = Overall relatively less acceptable
Hodge Road Property

3.1.2 No Build Alternative
In the No -Build scenario, no undertaking of the warehouse project would be made to serve the
increased multi -modal logistics demand create by the geographic warehouse void and the CCX
Transfer complex. Relative to the property owned and optioned by the applicant, the applicant
would not make use of the property it already owns and would not capitalize on their asset. A
no build decision would not meet the applicant's purpose and need.
3.1.3 On -Site Alternatives within the Preferred Alternative Site
The "Eastgate 540" Hodge Road property has local government -approved site planning to
accommodate the construction of an approximately 1,000,000 s.f. warehouse distribution hub,
including office space, required semi -truck roadway, circulation, parking and loading
infrastructure, and required stonnwater and utility services. This layout allows the applicant to
make the commercial development financially viable and stay within the zoning guidelines as
defined in the Town of Knightdale UDO. The design team believes that the warehouse design
presented in this permit application represents the most practicable and least environmentally
damaging alternative while still maintaining the applicant's purpose and need.
There are several factors that require the relatively flat finished elevation across the site, which
requires area -wide fill to facilitate the final grade. These factors include:
0 Public streets require design with minimum and maximum grades.
• The ability to sewer the individual buildings by gravity that discharges into a wet well
located at the pump station. Pump station wet wells have limits on depth.
• Relief must be provided from individual buildings to their respected BMPs to carry
stormwater and provide volume capacity in the BMP.
• Semi -truck maneuverability and safe operation requires less than 4% grade change.
• Warehouses must be flat, cannot be stepped, for interior forklift and other equipment
safe maneuverability.
• The maximum slope due to ADA requirements is 5% from buildings to public right-of-
way.
These conditions that facilitate a flat, finished grade then dictate the final vertical grade
elevations across the site, which requires significant volumes of fill to get to final grade.
Additional engineering considerations that create alternative layout limitations include:
• The elevation of Hodge Road is fixed.
• Pre -development condition has 70 feet of elevation change from the northwest comer
of the site to the east side of the site.
The site will require 425,000 cubic yards of cut to fill to achieve the grades necessary
to accommodate ADA compliance, semi -truck maneuverability, and flat -finished floors
of warehouses.
The site plan utilizes retaining walls to assist with grade transitions and reduce footprint
of the project.
Over 20% of the site is undevelopable due to stream buffers, Town of Knightdale
required perimeter buffers, and Town of Knightdale required right-of-way dedication
for public streets.
Hodge Road Property 10

Avoiding the stream buffer of the northern -most stream necessitates building setbacks
from slope which then necessitates fill of wetland/old pond on the south side of the
project.
3.1.4 Alternative Site Plans
The applicant evaluated several alternative site plans in an effort to avoid wetland impacts to
the greatest extent practicable. These alternate site plans are labeled as Figure 4-8 in Appendix
A. With exception of Option 5 shown on Figure 8, the remaining site plans contain the same
configuration north and west of the spine road. The spine road bisects the site and terminates at
a Town of Knightdale-required point along the northern site boundary, which provides future
connectivity to the adjacent undeveloped parcel to the north, as required by the Town of
Knightdale. This point of termination allows the future roadway extension to be located outside
a stream buffer, avoiding stream, wetland and buffer impacts. After fixing road location and
grades, the alternative of avoiding old farm -pond wetlands along the southern boundary was
evaluated. To avoid these wetlands would require over 300,000 sf of building infrastructure to
be eliminated from the project, which does not satisfy the project's purpose and need.
During the design process, several alternative layouts of 1,000,000 s.f. of warehouse space (at
the required elevation dictated by the spine road) were considered that would produce varying
amounts of jurisdictional impacts. Site Plan options 1-4 all require the same amount of impact
to achieve the purpose of the project. Site Plan option 5 increased wetland impact, and was
therefore eliminated from further consideration.
• Site Plan Option I (Preferred); Figure 4 General Description: Would include 72,211
s.f. (1.658 acres) of permanent wetland impacts, 0 s.f. of permanent impact to Zone I
of stream buffer, and 0 s.f. of permanent impact to Zone 2 of stream buffer. This option
includes 6 large warehouse buildings, parking lots, access roads and three stormwater
ponds. This preferred site plan option avoids 44.2% (1.315 acres) of wetlands and
100% (1,390 linear feet) of streams present on the property. The wetlands avoided are
of higher quality using the NC WAM assessment than those that would be impacted.
• Site Plan Option 2; Figure 5 Would include 72,211 s.f. (1.658 acres) of permanent
wetland impacts, 128 s.f. of permanent impact to Zone 1 of stream buffer, and 1,215
s.f. of permanent impact to Zone 2 of stream buffer. This option includes 4 large and 3
smaller warehouse buildings, parking lots, access roads and four stormwater ponds.
• Site Plan Option 3; Figure 6 Would include 72,211 s.f. (1.658 acres) of permanent
wetland impacts, 128 s.f. of permanent impact to Zone 1 of stream buffer, and 1,215
s.f. of permanent impact to Zone 2 of stream buffer. This option includes 4 large and 3
smaller warehouse buildings, parking lots, access roads and four stormwater ponds.
• Site Plan Option 4; Figure 7 Would include 72,211 s.f. (1.658 acres) of permanent
wetland impacts, 128 s.f. of permanent impact to Zone I of stream buffer, and 1,215
s.f. of permanent impact to Zone 2 of stream buffer. This option includes 4 large and 3
smaller warehouse buildings, parking lots, access roads and four stormwater ponds.
• Site Plan Option 5; Figure 8 Would include 75,571 s.f. (1.735 acres) of permanent
wetland impacts, 128 s.f. of permanent impact to Zone I of stream buffer, and 1,215
s.f. of permanent impact to Zone 2 of stream buffer. This option includes 4 very large
warehouse buildings, parking lots, access roads and three stormwater ponds.
Hodge Road Property 11

3.1.5 No Permit Alternative
The no permit alternative is considered to be a construction plan that avoids all wetland and
surface water impacts (Figure 9 in Appendix A). This project cannot be downsized or
redesigned to avoid all jurisdictional areas and still satisfy the project purpose and need. Due
to the size of the project, lack of appropriately zoned sites in the area and development
regulations a no permit decision on this property would not meet the applicant's purpose and
need.
Additionally, as previously discussed in the siting criteria the only wetland to avoid is located
in the southeastern portion of the site and developing around the wetland would not satisfy the
project's purpose and need. Saving the wetland would not be feasible. Due to the wetland's
location, size, irregular shape, and elevation, a 75 -ft to 100 —ft wide slope would need to be
constructed around the feature to tie into planned grades. This impact creates an unusable area
of 14.9 acres, which is 19% of the 78.8 acre site before required right-of-way dedication,
perimeter landscape buffers, and dedication of public easements. If the project eliminated
impacts to this wetland by constructing around its perimeter and knowing the project is required
to capture surface runoff from impervious surfaces the wetland rainfall source would be
eliminated and cease to be a wetland. The proposed storrawater control measure discharges
downstream of the wetland and could not be used to replenish moisture in the soil.
3.2 Alternatives Dismissed
The No Build Alternative and No Permit Alternative are dismissed from further evaluation
because they cannot practicably meet the applicant's stated purpose and need.
The Off -Site Alternative project locations were dismissed due to unfeasible acquisitions,
relatively greater wetland, stream or floodplain impacts, relatively greater fill and grading
costs, unsuitable zoning, and/or residential displacements.
9 On-site Alternative site plan Option 5 was dismissed due to greater wetland impacts.
3.3 Construction Sequence and Timeline
The property is currently planned to be developed in multiple phases. Phase 1 consists of Buildings I
and 2, Phase 2 will consist of Building 3 and 4, and Phase 3 will consist of Buildings 5 and 6.
Nationwide Permit 39 and 12 verifications allowing Phase I construction were obtained in February,
2016. The applicant purchased the land for Phase I in September, 2016. The applicant submitted a
Petition for Annexation to the Town of Knightdale for Phase I in September 2016. Phase I on-site
improvements are currently being constructed, and consist of a public street named Spectrum Drive and
contains public sidewalk, waterline, sanitary sewer and storm drainage. Pond #1, a storrawater control
measure has been constructed. Mass grading has been limited to those areas necessary to install the
public improvements, Building # I and a pad for Building # 2. Phase I off-site improvements consisted
of Hodge Road widening and a sanitary sewer outfall.
Hodge Road Property 12

The construction of the improvements associated with Phase 1 are currently on schedule to be complete
on or before December 31, 2018.
Phase 2 will require further extension of Spectrum Drive and utilities. The development of Phase 2 will
begin by January 1, 2019 and shall be complete by June 30, 2020. The applicant plans to submit a
Petition for Annexation of Phase 2 by October 1, 2018. Phase 2 improvements will consist of the
remainder of the Spectrum Drive, 2 and will contain public sidewalk, waterline, sanitary sewer and
storm drainage. Pond # 3, a stormwater control measure, will be constructed as part of Phase 2. Mass
grading for Phase 2 will be limited to those areas necessary to install the public improvements, Building
# 3 and Building # 4.
The applicant plans to submit a Petition for Annexation of Phase 3 by October 1, 2020. Phase 3 on-site
improvements will consist of the remainder of the site and will contain sidewalk, waterline, sanitary
sewer and storm drainage. Pond # 4, a stormwater control measure, will be constructed as part of Phase
3. Mass grading for Phase 3 will be limited to those areas necessary to install the public improvements,
Building # 5 and Building #6. Phase 3 off-site improvements will include the remaining widening of
Hodge Road to facilitate dual left -turns into the site with appropriate storage and tapers along with the
installation of the traffic signal at the intersection of Hodge Road and Spectrum Drive. The construction
of these improvements will allow development of either Building 5 or Building 6, or both
simultaneously. The construction of Phase 3 will begin by January 1, 2021 and be completed by
December 31, 2023.
4.0 ENVIRONMENTAL SETTING OF PREFERRED ALTERNATIVE
This section presents existing environmental conditions of the project study area and discusses
environmental impacts anticipated as a result of the proposed project. The project study area has been
visited several times by ESI and agency personnel to evaluate existing conditions and to document
physical and biological resources. The site is located on Hodge Road in Wake County, approximately
2000 feet north of the intersection of Hodge Road and Poole Road. Refer to Figure 1 for a Project Site
Location Map. Total size of the project study area is 78.8 acres.
4.1 Physiographic, Topography, Geology, and Land Use
The project study area is located on the U.S. Geologic Survey (USGS) 7.5 -minute topographic
quadrangles of Raleigh -East, NC (USGS 2013). More specifically the site is located in the Town of
Knightdale between US Highway 64 and Poole Road. Wake County is in the central part of the piedmont
physiographic providence of North Carolina.
4.1.1 Physical Conditions ofPreferred Site
Elevations on the site range from a low of approximately 224 feet above mean sea level (MSL)
within the unnamed tributary stream to the Neuse River floodplain to a high of approximately
294 feet above MSL near Hodge Road, according to County GIS data.
The Hodge Road property is located in the Foliated to Massive Granitic Rock in Intrusive Rocks
of the Raleigh Belt Group, undivided, within the piedmont physiographic region (NCDENR
1985). The project study area is located in the Neuse River Basin.
Hodge Road Property 13

The original site conditions contained two abandoned single family residences with several
small out buildings associated with past farming activities. The site is currently partially -
developed with warehouses, and the remainder a mixture of undeveloped, sparse wooded areas
and formerly cultivated fields. Most of the cultivated fields are within the western and northern
portions of the site, while the mostly wooded areas are in the eastern portion of the site. The
sparse mixture of vegetation was a result of the original land owner timbering the site many
years ago. A stream subject to the Neuse River Riparian Buffer rules runs west to east was
delineated north of the site. Jurisdictional wetlands have been delineated and filed confirmed
by the Corps' in the interior of the site and adjacent to the buffered stream. The site is located
in the Lower Neuse River Watershed and Upper Neuse River Basin. The site does not contain
floodplain per the most recent FIRM map dated 2006. The current conditions contain a 150,000
sf warehouse building, associated parking and truck court, public infrastructure (spine road,
water, sewer, and storm drainage), a poured concrete pad and steel superstructure for Building
# 2, interior and perimeter landscaping, and a stormwater control measure.
4.2 Soils
The Soil Survey of Wake County, North Carolina (USDA 1970) (Figure 10 in Appendix A) depicts the
following soil mapping units within the study area: Vance sandy loam (2 to 6 percent slopes, eroded),
Durham sandy loam (2 to 6 percent slopes), Colfax sandy loam, Creedmoor sandy loam (10 to 20 percent
slopes), Appling sandy loam (6 to 10 percent slopes, eroded), Appling fine sandy loam (2 to 6 percent
slopes) and Mantachie soils. These are combined into the Appling-Durham soil association, which is
comprised of gently sloping to sloping, deep, well drained soils that have a subsoil of friable sandy clay
loam to firm clay; derived mostly of granite, gneiss, and schist.
4.3 Water Resources
The project study area is in subbasin 05 of the Neuse River Basin and is located in USGS hydrologic
unit 03020201 (USDA 2012, NCDWR 2010). The project site is subject to the Neuse River buffer
regulations. The Neuse River buffer rules do not allow vegetation removal within 30 feet of perennial
or intermittent streams and do not allow most permanent building structures within 50 feet of perennial
or intermittent streams that are depicted on the most recent version of the USGS quadrangle map (Figure
9 in Appendix A) or on the Natural Resource Conservation Service (NRCS) county soils map for Wake
County (Figure 10 in Appendix A). One stream channel is mapped within the study area on either
USGS or NRCS mapping. The stream channel is subject to the Neuse River buffer rules.
A Best Usage Classification ("BUC") is assigned to waters of North Carolina based on the existing or
contemplated best usage of various bodies of water. There is one jurisdictional stream channel within
the project study area. The jurisdictional stream in the study area is an unnamed tributary to the Neuse
River. The unnamed stream on the subject property has a BUC of C;NSW. The supplemental
classification C designates aquatic life, secondary recreation and fresh water. The supplemental
classification NSW designates Nutrient Sensitive Waters which require limitations on nutrient inputs.
NC DWR confirmation of buffer applicability is included in Appendix E.
4.4 Wetlands
Hodge Road Property 14

Eleven wetland units were identified onsite prior to development that are subject to Section 404
jurisdiction, pursuant to the USACE Jurisdictional Determination from October 2014. The wetlands
within the project study area are characterized as a complex of Piedmont Bottomland Forests and
Headwater Forests per the North Carolina Wetland Assessment Method (NCWAM). NC WAM data is
included in Appendix F.
4.5 Threatened and Endangered Species
Species with the federal classifications of Endangered (E), or Threatened (T), are protected under the
Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.). Five (5) species are listed
by the U.S. Fish and Wildlife Service (USFWS) as having a range that is considered to extend into Wake
County (list date 4/2/2015) (USFWS 2013): bald eagle (Haliaeetus leucocephalus), northern long-eared
bat (Myotis septentrionalis), red -cockaded woodpecker (Picoides borealis), dwarf wedgemussel
(Alasmidonta heterodon), and Michaux's sumac (Rhus michauxii).
Bald eagle — Bald eagles typically nest in tall, living trees in a conspicuous location near water and
forage over large bodies of water with adjacent trees available for perching. Bald eagles typically feed
on fish but may also consume birds and small mammals. In the Carolinas, nesting season extends from
December through May.
The bald eagle was officially delisted and removed from the federal Endangered Species List on August
9, 2007, but they are still protected under the federal BGPA and the MBTA. The National Bald Eagle
Management Guidelines (Guidelines) prohibit disturbance to a bald eagle. The Guidelines define
disturb as "to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based
on the best scientific information available: 1) injury to an eagle; 2) a decrease in its productivity, by
substantially interfering with normal breeding, feeding, or sheltering behavior; or 3) nest abandonment,
by substantially interfering with normal breeding, feeding, or sheltering behavior." The definition also
covers impacts that result from human -caused alterations initiated around a previously used nest site
during a time when eagles are not present, if, upon the eagles return, such alterations agitate or bother
an eagle to a degree that injures an eagle or interferes with normal breeding, feeding, or sheltering
behavior.
Under the current Guidelines, USFWS recommends the following measures for roads, trails, canals,
power lines, and other linear utilities. If the eagle nest can be seen from the project site and there is no
similar activity within 660 feet, then USFWS recommends that the project: 1) maintain a buffer of at
least 660 feet between your activities and the nest; 2) maintain any established landscape buffers; and
3) if possible, create additional landscape buffers to screen the new activity from the nest. If these
recommendations cannot be adopted for the project, then coordination is recommended with the local
USFWS office (USFWS 2007).
Habitat Present: No
The study area does not include any large open water habitat that would provide nesting or foraging
opportunities. The proposed project will have no effect on this species. A review of NCNHP records,
updated October 2015, indicates no known occurrence of bald eagle within 1.0 mile of the study area.
Hodge Road Property 15

Biological Conclusion: No Effect
Northern long-eared bat — In North Carolina, the Northern long-eared bat (NLEB) occurs in the
mountains, with scattered records in the Piedmont and coastal plain. In western North Carolina, NLEB
spend winter hibernating in caves and mines. Since this species is not known to be a long-distance
migrant and caves and subterranean mines are extremely rare in eastern North Carolina, it is uncertain
whether or where NLEB hibernate in eastern North Carolina. During the summer, NLEB roost singly
or in colonies underneath bark, in cavities, or in crevices of both live and dean trees (typically >3 inches
dbh). Males and non -reproductive females may also roost in structures like bams and sheds, under eaves
of buildings, behind window shutters, in bridges, and in bat houses. Foraging occurs on forested
hillsides and ridges, and occasionally over forest clearings, over water, and along tree -lined corridors.
Mature forests may be an important habitat type for foraging (USFWS 2014).
Habitat Present: No
Potential summer roosting habitat in the form of hardwood trees greater than 3 inches dbh does not exist
within the study area. A review of NCNHP records, updated October 2015, indicates no known
occurrence of northern long-eared bat within 1.0 mile of the study area. Based on the USFWS Key to
the NLEB 4(d) Rule for Non -Federal Activities, this project should be exempt from USFWS
Consultation.
Biological Conclusion: No Affect
Red -cockaded woodpecker — The red -cockaded woodpecker (RCW) typically occupies open, mature
stands of southern pines, particularly longleaf pine, for foraging and nesting/roosting habitat. The RCW
excavates cavities for nesting and roosting in living pine trees, aged 60 years or older, which are
contiguous with pine stands at least 30 years of age to provide foraging habitat. The foraging range of
the RCW is normally no more than 0.5 mile (USFWS 2003).
Habitat Present: No
Suitable foraging and/or nesting habitat for the RCW does not exist within the study area. The study
area lacks the open mature pine dominated community habitat associated with nesting for this species
and lacks pine stands greater than 30 years old required for foraging. A review of NCNHP records,
updated October 2015, indicates no known occurrence of RCW within 1.0 mile of the study area.
Biological Conclusion: No Effect
Dwarf wedgernussel — The dwarf wedgemussel is typically 1. 5 inches in length or smaller with a brown
or yellowish brown outer surface. This mussel species typically inhabits streams with moderate flow
velocities and substrates varying in texture from gravel to coarse sand to mud with little silt deposition
(USFWS 1993a).
Habitat Present: No
Suitable habitat for the dwarf wedgemussel is not present within the project study area. A review of
NCNHP records, updated October 2015, indicates no known occurrence of dwarf wedgemussel within
1.0 mile of the project study area.
Biological Conclusion: No Effect
Hodge Road Property 16

Michaux's sumac — Michaux's sumac, endemic to the inner Coastal Plain and lower Piedmont, grows
in sandy or rocky, open, upland woods on acidic or circumneutral, well -drained soils or sandy loam soils
with low cation exchange capacities. The species is also found on sandy or submesic loamy swales and
depressions in the fall line Sandhills region as well as in openings along the rim of Carolina bays;
maintained railroad, roadside, powerline, and utility rights-of-way; areas where forest canopies have
been opened up by blowdowns and/or storm damage; small wildlife food plots; abandoned building
sites; under sparse to moderately dense pine or pine/hardwood canopies; and in and along edges of other
artificially maintained clearings undergoing natural succession. In the central Piedmont, it occurs on
clayey soils derived from mafic rocks. The plant is shade intolerant and, therefore, grows best where
disturbance (e.g., mowing, clearing, grazing, periodic fire) maintains its open habitat (USFWS 1993b).
Habitat Present: No
Suitable habitat for Michaux's sumac is not present within the study area.
Biological Conclusion: No Effect
4.6 Cultural Resources
The term "cultural resources" refers to prehistoric or historic archaeological sites, structures, or artifact
deposits over 50 years old. "Significant" cultural resources are those sites that are eligible or potentially
eligible for inclusion in the National Register ofHistoric Places. Evaluations for cultural resources are
required whenever a Section 404 permit application is submitted to USACE. Evaluations of site
significance are made with reference to the eligibility criteria of the National Register (33 CFR 60) and
in consultation with the North Carolina State Historic Preservation Officer (SHPO).
In June 2017, ESI consulted with the North Carolina Office of State Archaeology (OSA) and the Survey
and Planning Branch (S&P) of the North Carolina State Historic Preservation Office (SHPO) regarding
this project study area. Research revealed that no previously recorded archaeological sites are located
within or adjacent to the proposed project study area, and no properties listed in or eligible for listing in
the National Register of Historic Places are located within the project site. The OSA and the SHPO
provided a written response in June 2017 indicating that there are no records of any significant cultural
resource issues with the project study area (copy included as Appendix Q.
5.0 SECTION 404 IMPACTS AND PERMITTING
Section 404 of the CWA requires regulation of discharges into "Waters of the United States". Although
the principal administrative agency of the CWA is the U.S. Environmental Protection Agency (EPA),
the ACOE has major responsibility for implementation, permitting, and enforcement of provisions of
the Act. The ACOE regulatory program is defined in 33 CFR 320-330. Water bodies such as rivers,
lakes, and streams are subject to jurisdictional consideration under the Section 404 program. However,
by regulation, wetlands are also considered "Waters of the United States".
5.1 Proposed Stream Impacts
No impacts to streams are proposed for this project.
5.1.1 Avoidance and Minimization of Stream Impacts
Hodge Road Property 17

The site plan layout was configured in a way to avoid impacting the stream and stream
buffer on the northeastern portion of the property.
5.2 Proposed Wetland Impacts
1.658 acres of impacts to Section 404 wetlands will result from this commercial development action.
These impacts will occur where building 5, building 2 and their associated roads and parking spaces are
located on the Sketch Plan (Figure 4). Material to fill the wetlands will contain an initial layer of onsite
material followed by aggregate and topped with asphalt or portland cement concrete.
5.2.1 Avoidance and Minimization of Wetland Impacts
The proposed wetland impacts are minimized to the greatest extent practicable. Specific
wetland avoidance and minimization considerations include:
* Choosing a project site location with minimal amount of wetlands.
• Completely avoiding the wetlands on the northeastern portion of the property
during the design of the site layout.
• Abandonment of the off-site sewer installation will avoid 0.23 acres of wetland
impacts and 40 linear feet of stream impact.
5.3 Proposed Riparian Buffer Impacts
The previous authorizations and proffered mitigation allowed 1,343 s.f. (0.031 acres) of impacts to
Neuse River Riparian Buffers as a result of the installation of the sanitary sewer line in the southeast
comer of the project. This impact is no longer necessary for this commercial development action.
5.3.1 Avoidance and Minimization ofRiparian Buffer Impacts
The riparian buffer will not be impacted due to this proposed project. Specific riparian
buffer avoidance and minimization considerations include:
The preferred site plan layout was configured in a way as to avoid impacting
both the stream and the stream buffer in the northeastern portion of the property
through the use of retaining walls. Please refer to the revised site plan that was
e-mailed to Sue Homewood (NCDWR) on February 13, 2018 and put into the
project file.
Table 2. Proposed Jurisdictional Impacts
*Site labels correspond with Exhibit labels on Figure 2
Site*
Reason for
Permanent/
Wetland
Stream
Proposed
impact
Temporary
Impacts
Impacts
Mitigation Ratio
Fill
Wetland
(Building
Permanent
0.002 ac
0 ft.
2:1
C2
footprint)
Wetland
Fill
(Building
Permanent
0.326 ac
0 ft.
2:1
C3
footprint)
Wetland
Fill (Building
DI
Footprint)
Permanent
0.008 ac
0 ft.
2:1
Hodge Road Property 18

Wetland
Fill (Building
Permanent
0.039 ac
0 ft.
2:1
D2
Footprint)
Human Use
No
Negligible
Wetland
Fill (Building
Permanent
0.002 ac
0 ft.
2:1
D3
Footprint)
Characteristics
Wetland
Fill (Building
Permanent
1. 104 ac
0 ft.
2:1
D4
Footprint)
Term)
Term)
Wetland
Fill (Building
Permanent
0 ft.
2:1
D5
Footprint)
0.007 ac
Wetland
Fill (Building
Permanent
0 ft.
2:1
E
Footprint)
0.008 ac
Wetland
Fill (Building
Permanent
0 ft.
2:1
F
Footprint)
0. 162 ac
commercial fisheries
1.658 ac
2:1
Total Impacts:
Water -related
(72,220 sq.
0 ft.
ft.)
Wetland C2 and C3 were authorized under the NWP (Action ID: 2014-02127) and have been filled.
The remaining wetlands would be impacted by the proposed project but have not been permitted at this
time.
5.4 Compensatory Mitigation
Scannell Development Company will purchase available mitigation credits from private mitigation
banks and will satisfy the remainder of the necessary mitigation through the North Carolina Division of
Mitigation Services (NCDMS). Proposed mitigation ratios are included in Table 2. The project has
already mitigated for 0.465 acres of impacted wetlands via the original NAT. The remaining 1. 193
acres of impacted wetlands will be offset by the purchase of wetland mitigation credits from Restoration
Systems, LLC.
5.5 Potential Impacts on Human Use Characteristics
Potential Impacts on Human Use Characteristics
Minor
Minor
Human Use
No
Negligible
Effect
Effect
Major
N/A
Characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Municipal and private
x
supplies
-water
Recreational and
x
commercial fisheries
Water -related
x
recreation
Aesthetics
x
Hodge Road Property 19

Potential Impacts on Human Use Characteristics
Minor
Minor
Human Use
No
Negligible
Effect
Effect
Major
N/A
Characteristics
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Parks, national and
historical
monuments, national
seashores,
X
wilderness areas,
research sites, and
similar preserves
5.6 Cumulative and Secondary Impacts
The distribution center will increase traffic. The proposed development is projected to generate 300
trips (237 entering, 63 exiting) occurring in the AM peak hour and 320 trips (80 entering, 240 exiting)
in the PM peak hour. The project will not generate noise pollution outside the allowable limit. The
project will not generate air pollutants through the use of emission stacks or vents, though, there will be
some increase in the level of air pollution due to mobile sources such as cars and trucks.
The project will not generate any light pollution that encroaches onto surrounding properties. Chapter
11 titled Lighting located in the Town of Knightdale's UDO is very specific. This Chapter defines
practical and effective measures by which the obtrusive aspects of outdoor light usage may be reduced;
while preserving safety, security, and the nighttime use and enjoyment of property. This section of the
ordinance are intended to: curtail the degradation of the nighttime visual environment; reduce light
trespass and glare by encouraging lighting practices that direct appropriate amounts of light where and
when it is needed and prohibiting the use of poorly shielded or inappropriately directed lighting fixtures;
and reduce energy waste by increasing the use of energy-efficient sources.
Hodge Road Property 20

6.0 REFERENCES
[NCDWQ] N.C. Division of Water Quality. 2010. Basinwide Information Management System
(BIMS). Stream Classification. <h2o.enr.state.nc.us/bims> accessed February 2016.
[NCNHP] N.C. Natural Heritage Program. 2017. October 2017 NHP Element Occurrences, Raleigh,
NC. Accessed June 2017.
[NCDENR] N.C. Department of Environment and Natural Resources. 1985. Geologic Map of North
Carolina.
[USDA] U.S. Department of Agriculture. 1970. Soil Survey of Wake County, North Carolina. United
States Department of Agriculture -Soil Conservation Service. Sheet 61.
[USDA] U.S. Department of Agriculture. 2012. Watershed Boundary Dataset. Natural Resources
Conservation Service National Cartography and Geospatial Center.
[USFWS] U.S. Fish and Wildlife Service. 1993a. Dwarf Wedgemussel Recovery Plan. Hadley,
Massachusetts. 39 pp.
[USFWS] U.S. Fish and Wildlife Service. 1993b. Michaux's Sumac Recovery Plan. Atlanta, Georgia.
30 pp.
[USFWS] U.S. Fish and Wildlife Service. 2003. Recovery Plan for the Red -cockaded Woodpecker
(Picoides borealis): Second Revision. Atlanta, Georgia. 296 pp.
[USFWS] U.S. Fish and Wildlife Service. 2007. National Bald Eagle Management Guidelines
[USFWS] U.S. Fish and Wildlife Service. 2012. Endangered, Threatened, and Candidate Species and
Federal Species of Concern, by County, in North Carolina: Wake County.
http://www.fws.gov/nc-es/es/countyfr.html. Accessed January 2016.
[USFWS] U.S. Fish and Wildlife Service. 2014. Northern Long -Eared bat Interim Conference and
Planning Guidance. USFWS Regions 2,3,4,5,& 6. 10 pp. plus appendices.
[USGS] U.S. Geological Survey. 1993. Raleigh -East, North Carolina. Topographic 7.5 -minute
quadrangle map. United States Geologic Survey, Washington, D.C.
[WakeGOV] City of Raleigh and Wake County iMaps. 2017. https://www.maps.raleighnc.gov/iMaps/.
[FEMA] Flood Insurance Rate Map. FEMA Flood Map Service Center, FEMA, 2006,
msc.fema.gov/portal/search.
[ToK] Town of Knightdale, NC "Chapter 16. Development Plan Requirements.", 2017,
www.knightdalenc.gov/modules/showdocument.aspx?documentid=1982.
Hodge Road Property 21

Appendix A
Figures 1-11
Figure 1 - Hodge Road Site Location Map
Figure 2 — Hodge Road Wetland Map
Figure 3 — Hodge Road Alternative Site Map
Figure 4 — Preferred Site Layout Design Option I
Figure 4A — Revised Site/Grading Plan (no buffer impacts)
Figure 5 — Site Layout Design Option 2
Figure 6 — Site Layout Design Option 3
Figure 7 — Site Layout Design Option 4
Figure 8 — Site Layout Design Option 5
Figure 9 — Site Layout Design Option 6 (No Permit Alternative)
Figure 10 — USGS Site Location Map
Figure 11 — USDA Soil Survey Map
Hodge Road Property

Appendix B
Natural Heritage Program Letter
Hodge Road Property

Appendix C
SHPO and OSA Concurrence Consultation
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From: Beckman, Hannah S
Sent: Thursday, June 22, 2017 1:02 PIVI
To: Dalton Cook
Subject: Re: Hodge Road Project
Hello Dalton,
2309 Hodge Road in Knightdale does not appear to have been listed on the National Register
of Historic Places. At this time, the property has not been surveyed by our office or entered
into our database.
That said, depending on what you are using this information for, you may want to consult
with someone at the Office of State Archaeology to see if this site has been identified by
them for some reason.
https://archaeology.ncdcr.gov/about/whos-my-archaeologist
Hope this helps!
HANNAH S. BECKMAN
Survey & National Register Specialist
State Historic Preservation Office
109 E Jones St, IVISC 4617, Raleigh, NC 27699-4617
919 807 6577 office
V 8EIIIIII
09 0 NC DEPARTMENT OF
NEMEN NATURAL AND CULTURAL RESOURCES
0 JIME
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Hodge Road Property

Mon 6/26/2017 11:08 AM
Dalton,
Good morning. Thanks for this message and your voicemail. I have checked the address of
2039 Hodge Road, Knightdale and find that we have no previously recorded sites at that
location. Please let me know if you have questions; thanks.
Best,
Susan
Susan Myers
Assistant State Archaeologist and Site Registrar
NC Dept. of Natural and Cultural Resources
919 807 6556 office
919 715 2671 fax
susan.myers(a)ncdcr.gov
109 East Jones Street 1 4619 Mail Service Center I Raleigh, North Carolina 27699-4619
Hodge Road Property

Appendix D
Compensatory Mitigation Letters
Hodge Road Property

Hi Dalton —
Yes, we have the 1. 193 riparian riverine credits available. They are $7 1,000/acre — sold in tenth acre
increments (total cost: $85,200). 1 have attached our current credit policy.
Thanks,
Tiffani
Tiffani BylowlRestoration Systems, LLC
1101 Haynes St.jSuite2lljRaleigh,NC27604
p: 919.334.91231c: 919.754.72781f.- 919.755.9492
www.restorationsystems.com
Hodge Road Property

Appendix E
NC DWR Buffer Applicability Letter
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Appendix F
NC WAM Data Form
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Appendix G
US Army Corps of Engineers LEDPA Statement
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