20190289 Ver 1_Staff Comments to USACE_20190328

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
March 28, 2019
Corps Action ID# SAW -2018-00240
DWR# 20190289
Guilford County
David Bailey
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Dr, Suite 105
Raleigh, North Carolina 27587
Subject Project: Publix Distribution Center
Dear Mr. Bailey:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above
referenced property:
1. The applicant's siting criteria includes requirements that are unclear, too vague, and/or
not appropriate or applicable to the 404 process.
The applicant's Off -Site Alternatives Analysis states "The Guilford County area was
determined to be the most practicable long-term solution to the distribution issues". It
is unclear how this location limitation was determined based on the proposed site
criteria.
3. The applicant's Off -Site Alternatives Analysis disqualifies other alternatives under
consideration for reasons that do not match the siting criteria or are not equally viewed
between sites. For example, it is stated that Reedy Fork Corporate Park Site is limited by
a secondary road that would require upgrades, however transportation upgrades are
proposed for the preferred alternative. It is indicated that the Young's Mill Site would
require a property assemblage of multiple property owners, however the proposed
alternative is also an assemblage of multiple owners. More examples of conflicting
information or unequal comparisons exist within the applicant's Alternatives Analysis
which weaken the applicant's justification for their proposed alternative.
North Carolina Department of Erw1ronmental Quality I Division of Water Resources
D EJ� 512 North Salisbury Street 1 1617 Mall Service Center I Raleigh, North Carolina 27699-1617
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Publix Super Markets Inc. / NC DOT
DWR# 20190289
404 Comments SAW -2018-00240
Page 2 of 2
4. It is unclear from the scale of the drawings and lack of comparable information on the
exhibits as to whether the applicant's On -Site Alternatives Analysis provides similarly
sized alternatives and therefore demonstrates adequate Avoidance and Minimization.
5. The Division has concerns that some secondary impacts have not been adequately
accounted for in the applicant's preferred alternative. Specifically, whether
downstream hydrology will be maintained in adjacent features upon completion of the
project. If downstream hydrologic impacts are likely to occur, then the On -Site
Alternatives Analysis may need to be reconsidered.
6. The Division has requested additional technical information from the applicant and
requests that the USACE also consider the attached letter during the review of the
application.
Thank you for your considering the Division's comments during your review of this Individual
Permit. If you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
�cg I"
Karen Higgins, Supervisor
401 & Buffer Permitting Unit
cc: Brian Breissinger, Timmons Group (via email)
Philip Harris III, NCDOT (via email)
Olivia Munzer, NCWRC (via email)
DWR WSRO
DWR — Wetlands and Buffer Permitting Branch
Filename: 20190289PublixDistributionCenter(Guilford)_404_Comments