20171527 Ver 1_USACE Correspondence_20190521

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
May 21, 2019
Regulatory Division
Action ID No. SAW -2016-02542
Mr. David Newell
Person County
Post Office Box
Roxboro, North Carolina 27573
Dear Mr. Newell:
Please reference your application of January 8, 2019, for individual Department of
the Army (DA) permit authorization to construct a semiconductor chip manufacturing
plant and associated infrastructure within the area identified as the Person County
Mega Park. The application was for the discharge of fill material into 10,529 linear feet
of stream and 1.94 acres of wetlands subject to our regulatory authority pursuant to
Section 404 of the Clean Water Act. The requested impacts are associated with the
proposed development of a semiconductor chip manufacturing plant, including a fill pad
and transportation and utility infrastructure. The proposed project site is located south
of Edwin Robertson Road and is bisected by Country Club Road, north of the City of
Roxboro, in northern Person County, North Carolina. The associated infrastructure
projects for the semiconductor chip manufacturing plant include water and gas utility
lines that extend south from the project along Country Club Road and transportation
improvements that extend east from the project along Edwin Robertson Road and
Shiloh Church Road to US Highway 501.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your
proposal by public notice dated January 23, 2019, with a comment deadline date of
February 22, 2019. A total of six (6) written comments were received in response to the
notice from the North Carolina Division of Water Resources (NCDWR), North Carolina
Wildlife Resources Commission (NCWRC), North Carolina Department of Natural and
Cultural Resources State Historic Preservation Office (NCSHPO), U.S. Fish and Wildlife
Service (USFWS), the Cherokee Nation, and one local resident. The comments
received are enclosed for your information and to provide you with the opportunity to
address any of the stated concerns. In particular, please provide a written response to
comments from the NCSHPO. Note that the Cherokee Nation and the USFWS both
indicated that they had no comments or objections in their respective letters. Reference
also the Request for Additional Information sent by the NCDWR dated February 19,
2019 (copy enclosed).

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
Action ID No. SAW -2016-02542
Mr. David Newell
Person County
Post Office Box
Roxboro, North Carolina 27573
Dear Mr. Newell:
May 21, 2019
Please reference your application of January 8, 2019, for individual Department of
the Army (DA) permit authorization to construct a semiconductor chip manufacturing
plant and associated infrastructure within the area identified as the Person County
Mega Park. The application was for the discharge of fill material into 10,529 linear feet
of stream and 1.94 acres of wetlands subject to our regulatory authority pursuant to
Section 404 of the Clean Water Act. The requested impacts are associated with the
proposed development of a semiconductor chip manufacturing plant, including a fill pad
and transportation and utility infrastructure. The proposed project site is located south
of Edwin Robertson Road and is bisected by Country Club Road, north of the City of
Roxboro, in northern Person County, North Carolina. The associated infrastructure
projects for the semiconductor chip manufacturing plant include water and gas utility
lines that extend south from the project along Country Club Road and transportation
improvements that extend east from the project along Edwin Robertson Road and
Shiloh Church Road to US Highway 501.
The U.S. Army Corps of Engineers, Wilmington District (Corps) advertised your
proposal by public notice dated January 23, 2019, with a comment deadline date of
February 22, 2019. A total of six (6) written comments were received in response to the
notice from the North Carolina Division of Water Resources (NCDWR), North Carolina
Wildlife Resources Commission (NCWRC), North Carolina Department of Natural and
Cultural Resources State Historic Preservation Office (NCSHPO), U.S. Fish and Wildlife
Service (USFWS), the Cherokee Nation, and one local resident. The comments
received are enclosed for your information and to provide you with the opportunity to
address any of the stated concerns. In particular, please provide a written response to
comments from the NCSHPO. Note that the Cherokee Nation and the USFWS both
indicated that they had no comments or objections in their respective letters. Reference
also the Request for Additional Information sent by the NCDWR dated February 19,
2019 (copy enclosed).

-2 -
Please be aware that Section 404(b)(1), of the Clean Water Act, states 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 adverse
environmental consequences. As such, please elaborate on or provide additional
information regarding alternatives as follows:
Please clarify if there will be any co -applicants for this project.
2. Additional site specific information regarding the alternatives analysis is
required to ensure compliance with the National Environmental Policy Act
(NEPA) and the Section 404(b)(1) guidelines. This includes the following
items:
a. Provide additional discussion/analysis for the Overall Layout Plan
(Sheet 1). Specifically, please clearly label each feature (building,
parking lot, component of the facility, etc.) and provide details
regarding the purpose of each feature (i.e., what the use of that
feature would be, reason for the size, etc.).
i. Note that the second sentence of the second paragraph of
the Executive Summary for the Person County Mega Park
Individual Permit Request states that "The proposed Project
layout is comprised of an approximate 3.5 million square feet
central operations facility to house the clean room,
manufacturing spaces, office spaces, mechanical yard,
vehicular load deck areas and associated parking." Please
clearly identify the above -referenced project components on
the site plans and provide a written explanation describing
the need for and arrangement of the specific buildings and
components within the framework of the overall project.
ii. Clearly describe the capacity of the proposed parking lot
layout for each of the alternatives. Is the proposed parking
layout sufficient to meet the needs of the estimated labor
force (4,000 employees) at the proposed facility?
iii. The on-site alternatives do not include an analysis for
impacts associated with the proposed utility lines and
transportation improvements. Please explain how the
preferred alternatives for the utility lines and transportation
improvements would affect the total impacts for the on-site
alternatives.

iv. Please provide additional information and a detailed
discussion regarding the methods used to determine the
layout of the Overall Layout Plan (Sheet 1). Please indicate
if other current or former semiconductor chip manufacturing
plants were used to determine the number, size, use of each
building and surface lot (and if so, which facilities?) and
methods used to arrive at the current proposed
configuration. Please explain how this was determined to be
a requirement of all semiconductor chip manufacturing
plants.
V. Please provide additional discussion regarding the Overall
Layout Plan (Sheet 1). As this plan appears to be a typical
semiconductor chip manufacturing plant site plan, please
provide additional details/discussion regarding the
mechanism and methods the applicant would take to ensure
that any potential end user would not request to re -design
the proposed campus to their own specifications and would
ultimately build the proposed design as indicated. We
believe it is important to reiterate that in the event a permit is
issued for this project, it must be built exactly as depicted in
the plans you have submitted and for the purpose and need
expressed in your application, unless a modification to the
proposed project is authorized by the District Engineer.
b. Provide an alternatives analysis for each of the utility line and
transportation improvement projects associated with the proposed
project. Specifically explain how and why the preferred alternative
was chosen for the following:
i. The proposed water utility line that extends south from the
proposed semiconductor chip manufacturing facility;
ii. The proposed gas utility line that extends south from the
proposed semiconductor chip manufacturing facility; and
iii. The proposed transportation improvements along Edwin
Robertson Road and Shiloh Church Road.
c. The Person County Megasite Traffic Impact Analysis, dated
September 20, 2017, was written with the assumption that the
proposed project was a "six (6) million square foot (SF) plus semi-

-4 -
conductor facility along with ancillary, supporting land uses."
However, the current application only considers an approximately 3.5
million square feet semiconductor ship manufacturing plant. Please
explain how the Traffic Impact Analysis mentioned above still applies
to the proposed project in light of the reduction in size and scope of
the proposed project? If the Traffic Impact Analysis no longer applies
due to changes in the scope of the proposed project, please revise
the analysis accordingly to match the currently proposed scope of the
project.
d. The project is proposed to be constructed in two phases. It appears
that Phase 1 would effectively disconnect Country Club Road from
Edwin Robertson Road. Is there a plan to route traffic through or
around the site during and following the implementation of Phase 1 of
the proposed project?
e. There is no accounting for any temporary impacts associated with
the transportation component of this project. Typically, temporary
impacts are necessary for dewatering activities associated with
culvert installation. Please provide and/or distinguish between
temporary and permanent impacts associated with the transportation
portion of this project. Additionally, please itemize permanent
impacts by type of fill (e.g. culvert fill versus outlet stabilization via rip
rap dissipater pad).
f. The Preliminary Jurisdictional Waters of the U.S. Impacts Maps
(Sheets 5 and 6) do not accurately show the limits of waters within
the project corridor. Therefore, the impact totals to streams and
wetlands are not accurate on the above referenced impacts maps
and in the permit application. Please reference the revised
delineation maps entitled "Figure 6: Waters of the U.S. Delineation
Map" (Sheets 2 and 3 of 3) that were submitted to the Corps on
September 24, 2018, as part of the Preliminary Jurisdictional
Determination Request; these features were field verified by Mr.
Ross Sullivan with the Corps on May 3, 2018. Please revise the
permit application to correctly account for all impacts to Waters of the
U.S.

g. The permit application and supporting documentation highlights the
proposed project's needs for redundant power supplies and
highlights the availability of multiple 230 kV lines and 115 kV lines
that currently cross the property. However, the plans do not clearly
identify the location of these utility lines or show how they would tie
into each of the proposed project alternatives. Please clearly display
and explain how the proposed project alternatives would connect to
the existing utility lines and indicate whether or not any impacts to
waters of the U.S. would occur as a result of these utility connections.
3. Provide additional discussion/analysis for the Overall Layout Plan (Sheet 1).
Specifically, please clearly label each feature (building, parking lot, component of the
facility, etc.) and provide details regarding the purpose of each feature (i.e., what the
use of that feature would be, reason for the size, etc.).
4. Your offsite alternatives analysis should also include the transportation and utility
components when assessing the environmental impacts in order to compare it to the
preferred alternative.
5. Provide the Corps with a copy of your responses to Items 2-7 listed in the
Request for Additional Information from the NCDWR, dated February 19, 2019.
6. A more detailed compensatory mitigation proposal is needed once you have a
final site plan. Note that any impacts where the proposed mitigation is not located within
the same 8 -digit HUC may be subject to higher compensatory mitigation ratios.
7. Please provide a more detailed indirect impacts analysis with regards to streams
and wetlands that exist just outside of the fill footprint for the proposed project. In
particular, Will any streams lose their watershed through rerouting of stormwater? Will
any wetlands lose their recharge area due to fill/rerouting of stormwater? If so, please
quantify these indirect impacts and include them in the compensatory mitigation
proposal?
Your response to the comments must be given full consideration before we can
make a final decision on your application. You may submit additional information,
revise your plans to help resolve the issues, rebut the issues made or request a
decision based on the existing record. Please be aware that, depending upon the level
of detailed information you provide, we may still have concerns and/or questions that
will need to be addressed. Finally, if a permit is issued for your proposed project, it is
our intention to condition the permit such that no fill could be placed in waters of the
U.S. until a specific end user has been identified and all additional steps have been
taken to avoid and minimize impacts to waters of the U.S. for that particular end user. If

you need additional assistance regarding any issues mentioned in or information
requested in this letter, please call Mr. Ross Sullivan at telephone [phone] ext.
25 or contact him at email address [e-mail].
Sincerely, ll ,, II
W l�L
Henry Wicker
Deputy Chief, Regulatory Division
Wilmington District
Copy Furnished:
Mr. Todd Bowers
Permit Review Specialist
Wetlands Regulatory Section
U.S. Environmental Protection Agency - Region IV
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303
Ms. Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
450 West Hanes Mill Road, Suite 300
Winston Salem, North Carolina 27105
Mr. Brian Breissinger
Timmons Group
1001 Boulders Parkway, Suite 300
Richmond, Virginia 23225

Attachments — Copy of Comments Received by the USACE for
the Person County Mega Park Semiconductor Chip
Manufacturing Plant (SAW -2016-02542)

Sullivan, Roscoe L III CIV (US)
From: Elizabeth Toombs <[e-mail]>
Sent: Monday, January 28, 2019 8:43 PM
To: Thames, Joyce A CIV USARMY CESAW (US); Sullivan, Roscoe L III CIV (US); Gibby, Jean B
CIV USARMY CESAW (US)
Cc: Smith, Ronnie D CIV USARMY CESAW (US)
Subject: [Non-DoD Source] RE: US Army Corps of Engineers Public Notice
Many thanks for the review request for SAW -2016-02542 in Person County, North Carolina. Person County is outside
the Cherokee Nation's Area of Interest. Thus, this Office respectfully defers to federally recognized Tribes that have an
interest in this landbase.
Thank you for the opportunity to comment upon this proposed undertaking. Please contact me if there are any
questions or concerns.
Wado,
Elizabeth Toombs, Tribal Historic Preservation Officer
Cherokee Nation
Tribal Historic Preservation Office
PO Box 948
Tahlequah, OK 74465-0948
918.453.5389
From: Thames, Joyce A CIV USARMY CESAW (US) [mailto:[e-mail]]
Sent: Wednesday, January 23, 2019 6:20 AM
To: Sullivan, Roscoe L III CIV (US) <[e-mail]>; Gibby, Jean B CIV USARMY CESAW (US)
<[e-mail]>
Cc: Smith, Ronnie D CIV USARMY CESAW (US) <[e-mail]>
Subject: <EXTERNAL> US Army Corps of Engineers Public Notice
Importance: High
As you requested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued a
Public Notice. The text of this document can be found on the Public Notices portion of the Regulatory Division Home
Page. Each Public Notice is available in ADOBE ACROBAT (.pdf) format for viewing, printing or download at
Blockedhttp://www.saw.usace.army.miI/Missions/RegulatoryPermitProgram.aspx.
The current notice involves:
Corps Action ID#: SAW -2016-02542
Issue Date: 23 January 2019
Applicant: Person County
Mr. David Newell
Project Name: Person County Mega Park
Expiration Date: 22 February 2019

Point of Contact: Ross Sullivan
Project Description:
US Army Corps of Engineers (Corps) received an application from Person County seeking Department of the Army
authorization to discharge dredged or fill material into waters of the United States, associated with the construction of a
semiconductor chip manufacturing plant on a 318 acre parcel of land that is situated within a larger tract of land
(approximately 1,456 acres) designated by Person County as the Person County Mega Park. The proposed project
includes off-site transportation and utility improvements. The proposed project site is located south of Edwin Robertson
Road, on both sides of Country Club Road, north of the City of Roxboro, Person County, North Carolina.
Subscribe/Unsubscribe: This email was sent out as a result of subscribing to the Wilmington District regulatory program
public notices. Please email Cindy. [e-mail] with the subject or message "unsubscribe" to remove
your address from future mailings.

Ross Sullivan
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
February 21, 2019
U.S. Army Corps of Engineers, Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Person County Mega Park/ SAW -2016-02542/ Person County
Dear Mr. Sullivan:
The U.S. Fish and Wildlife Service (Service) has reviewed the project advertised in the above
referenced Public Notice. The project, as advertised in the Public Notice, is expected to have
minimal adverse impacts to fish and wildlife resources. Therefore, we have no objection to the
activity as described in the permit application.
In accordance with the Endangered Species Act of 1973, as amended, (ESA) and based on the
information provided, and other available information, it appears the action is not likely to adversely
affect federally listed species or their critical habitat as defined by the ESA. We believe that the
requirements of section 7 (a)(2) of the ESA have been satisfied for this project. Please remember
that obligations under the ESA must be reconsidered if: (1) new information identifies impacts of this
action that may affect listed species or critical habitat in a manner not previously considered; (2) this
action is modified in a manner that was not considered in this review; or, (3) a new species is listed
or critical habitat determined that may be affected by the identified action.
For your convenience a list of all federally protected endangered and threatened species in North
Carolina is now available on our website at <http://www.fws.gov/raleigh>. Our web page contains a
complete and updated list of federally protected species, and a list of federal species of concern
known to occur in each county in North Carolina.
The Service appreciates the opportunity to review and provide comments on the proposed action.
Should you have any questions regarding the project, please contact John Ellis at [phone],
extension 26.
Sincer
Pet jamin,
Fiel Supervisor
cc: NMFS, Beaufort, NC
EPA, Atlanta, GA
WRC, Raleigh

Sullivan, Roscoe L III CIV (US)
From:
Sent: Monday, February 4, 2019 9:54 AM
To: Sullivan, Roscoe L III CIV (US)
Subject: [Non-DoD Source] Request for Public Hearing on SAW -2016-02542
Dear Mr. Ross Sullivan,
Per the Public Notice issued on January 22, 2019 with comment deadline February 22, 2019 and Corps Action ID
Number SAW -2016-02542; I am writing to request that a public hearing be held to consider the application. The
reasons for holding such are as follows:
1. To my knowledge this is the first opportunity the persons living in the affected area, as well as the entirety of the
county, have been given access to the details of the application and resultant environmental and community
impacts. All previous discussions on the matter held by the County Board of Commissioners have been closed to
the public.
2. The project area is located in the Roanoke River watershed. The public would be interested to hear the opinion
of the Roanoke River Basin Association, which holds a permanent seat on the Army Corps of Engineers
Stakeholders Water Management Committee. The stated mission of the RRBA is to establish and carry out a
strategy for the development, use, preservation and enhancement of the resources of the Roanoke River basin
in the best interest of present and future generations of Basin residents. A public hearing would afford the
residents of the county the opportunity to ask questions, in an open forum, about the details of the Avoidance
and Minimization and Compensatory Mitigation plans for the proposed project.
3. The timing of the comment period for this application is overlapped by the current discussion in the community
about the proposed methods of closure for the coal ash basins at both the Hyco and Mayo coal fired power
plants. The community is rightfully occupied with this discussion at this time. Attendance and participation at
two public hearing events on the matter of coal ash basin closure in January of 2019 were high. The proposed
project area is located between these TWO coal fired power plants which are also located in the northern
section of the county. A public hearing would provide an opportunity to differentiate this matter from the
additional environmental pressures the community is currently facing. Under this consideration, an extension of
the comment period might also be made so that the community is afforded the opportunity to consider all
issues in their entirety and potentially avoid a scenario where comment on one is distracted by preoccupation
with another.
Thank you in advance for your time and consideration. Please also let me know if you agree to hold the public hearing or
if you require further information. Also, I respectfully ask that my contact information remain confidential to the extent
possible.
Sent from Mail for Windows 10

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
February 4, 2019
Ross Sullivan
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Office of Archives and History
Deputy Secretary Kevin Cherry
roscoe.l. sullivangusace.army.mil
Re: Trace Commercial Development, Country Club Road & Edwin Robertson Road, Roxboro,
SAW 2016-02542, Person County, ER 14-1122
Dear Mr. Sullivan:
We have received a public notice concerning the above -referenced undertaking. We have reviewed the
materials submitted and offer the following comments.
The area of disturbance for the semiconductor chip manufacturing plant site has already been surveyed for
archaeological resources and cleared for use. Most of the area covered by the proposed utility and
transportation improvement sites are low probability for intact, significant archaeological resources. However,
we note the presence of three cemeteries on the topographic quad maps: one along the proposed
transportation corridor (Shiloh Primitive Baptist Church Cemetery, Shiloh Church Road, Roxboro, NC 27574),
one along the proposed waste water line (3919 Chub Lake Road, Roxboro, NC 27573), and one along the
PSNC gas pipeline (705 McGhees Mill Road, Roxboro, NC 27574). These cemeteries have not been previously
recorded with our office, and online information gives conflicting accounts of how well they are marked. Prior
to any earth -moving activities, these cemeteries should be delineated, recorded with our office, and the
boundaries marked to ensure that human skeletal remains are not inadvertently impacted. We recommend
pedestrian reconnaissance (visual inspection) and probing for any evidence of additional burials in the
immediate vicinity of the cemeteries by an experienced archaeologist, and at least a 25 -ft buffer to be
established around the cemetery and a fence placed to ensure its protection. Please note that our office now
requests consultation with the Office of State Archaeology Environmental Review Archaeologist to discuss
appropriate field methodology prior to the archaeological field investigation.
If an archaeological field investigation is conducted, one paper copy and one digital file (PDF on disc) of each
report, and one digital copy (PDF on disc) of each site form should be submitted to the OSA for review and
comment as soon as they are available and well in advance of any earth moving activities. PDF -A (Archival
format) is preferred but a high-quality standard PDF file is also acceptable.
The above comments are made pursuant to Section 106 and 110 of the National Historic Preservation Act and
the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewgncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
6"KRamona M. Bartos

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
February 19, 2019
DWR# 20171527
Person County
Ross Sullivan
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Subject Project: Person County Mega Park
Corps Action ID# SAW -2016-02542
Dear Mr. Sullivan:
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 Division requests that the USACE consider the mitigation requirements and needs of this
project as significant and unique. The Division requests that the USACE review the ability of the
Division of Mitigation Services to satisfy this need in a complete and timely manner. While the
Division recognizes the prior decisions made by the Interagency Review Team (IRT) regarding
mitigation within the Roanoke River Basin, the Division requests that the USACE consider this
project separate from the IRT decision due to the significant quantity of impacts.
2. The Division is unable to complete a review of the project for compliance with 15A NCAC 02H .0506
at this time. Please see the attached request for more information that has been sent to the
applicant.
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 sue. homewoodPncdenr.eov.
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Brian Bressinger, Timmons Group (via email)
Maria Dunn, NCWRC (via email)
DWR RRO
DWR —Wetlands and Buffer Permitting Branch
Filename: 20171527PersonCou ntyMega Park(Perso n)_404_Com ments
E
North Carolina Department of Environmental Quality I Division of Water Resources
D
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699 1617
, /��
919.707.9000

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
February 19, 2019
DWR # 20171527
Person County
Person County
Attn: Mr. David Newell
PO Box 1824
Roxboro NC 27573
Subject: REQUEST FOR ADDITIONAL INFORMATION
Person County Mega Park
Dear Mr. Newell:
On January 8, 2019, the Division of Water Resources — Water Quality Programs (Division)
received your application dated January 7, 2019, requesting an Individual Water Quality
Certification from the Division for your project. The Division had previously received an
application from the Person County Business and Industrial Center for this project on December
5, 2018. The Division has determined that your application is incomplete and cannot be
processed. The application is on -hold until all of the following information is received:
1. If the U.S. Army Corps of Engineers requests a response to any comments received as a
result of the Public Notice, please provide the Division with a copy of your response to
the USACE. [15A NCAC 02H .0502(c)]
2. Please provide more details regarding avoidance and minimization of impacts for this
project. It appears that the circulatory roadway is for the purpose of serving future
ancillary features and future traffic needs which are not part of the purpose and need of
this current application. Provide detailed justification for the need, location, and
roadway width/lanes for the circulatory roadway. [15A NCAC 02H .0506(f) and (g)]
3. Provide a detailed site plan on full plan sheets at a scale of no smaller than 1"=50' with
topographic contours shown for the proposed project, all transportation improvements
(including stormwater management from roadway improvements) and utility
improvements associated with this project. Please re -submit your site plans on full plan
sheets at a scale of no smaller than 1" = 50' with final topographic contours shown. [15A
NCAC 02H.05021
00 North Carolina Department of Environmental Quality I Division of Water Resources
D_EWft7�_
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
�� 919.707.9000

Person County
DWR# 20171527
Request for Additional Information
Page 2 of 3
4. Provide a site-specific detailed engineering plan, profile view, and cross-section of all
proposed impact areas. These drawings must include details regarding proposed final
contours for fill/cut areas, stream alignment in relation to pipe alignment, pipe slope,
pipe burial, dissipater pad requirements, and temporary dewatering design and impacts,
adjacent sediment and erosion control measures, and plans for restoration of any
temporarily impacted areas. [15A NCAC 02H .0502(b)]
5. Please provide an updated acceptance letter from the Division of Mitigation Services
(current letter to expire 2/24/2019) or an alternative mitigation plan that conforms to
the requirements of 15A NCAC 02H .0500 and G.S. 143-214.11. [15A NCAC 02H
.0502(h)]
6. In order for the Division to accurately determine the required amount of mitigation in
accordance with state statutes, provide documentation of intermittent and perennial
stream calls as verified by the Division of Water Resources staff. [15A NCAC 02H
.0502(h)]
7. Please provide a detailed qualitative indirect and cumulative impact analysis that clearly
follows the steps outlined in the Division's policy for guidance on our website at:
htp://portal.ncdenr.org/web/wq/swp/ws/401/policies. [15A NCAC 02H .0506(b)(4)]
8. Provide a complete Stormwater Management Plan. [15A NCAC 02H .0506(b)(5) and
(c)(5)]
Please note that a complete review of the project could not be conducted at this time based on
the information submitted. Upon receipt of the requested information, additional requests
may be necessary to determine compliance with all appropriate state regulations.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC
27699-1617 OR by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR#
requested on the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this
letter, the Division will be unable to approve the application and it will be returned. The return
of this project will necessitate reapplication to the Division for approval, including a complete
application package and the appropriate fee.

Person County
DWR# 20171527
Request for Additional Information
Page 3 of 3
Please be aware that you have no authorization under the Water Quality Certification Rules for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
I \"IM& ,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Brian Bressinger, Timmons Group (via email)
Ross Sullivan, USACE Raleigh Regulatory Field Office (via email)
Maria Dunn, NCWRC (via email)
DWR RRO 401 files
DWR 401 & Buffer Permitting Unit
Filename: 20171527PersonCou ntyMega Pa rk(Person)_401_I C_HO LD

North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Lyn Hardison, Environmental Assistance Coordinator
NCDEQ Division of Environmental Assistance and Customer Services
FROM: Ross Sullivan
Raleigh Regulatory Field Office`'~
US Army Corps of Engineers
DATE: February 22, 2019
SUBJECT: Public Notice for Person County Mega Park, Corps Action ID Number: SAW -2016-
02542.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), North Carolina Environmental Policy Act (G.S.
I I3A-1 through I I3A-10; 1 NCAC 25) and North Carolina General Statutes (G. S. 113-131 et seq.).
Person County proposes to construct a semiconductor chip manufacturing plant and associated
infrastructure, including transportation improvements and water and natural gas utility lines. Proposed
work will be completed in two phases. Phase I will include the 318 -acre chip manufacturing plant. Phase
2 will include transportation improvements, such road widening, interchange improvements and
additional lanes, as well as gas and water infrastructure projects, specifically a 30 -inch waterline serviced
by the City of Roxboro. The project area contains 10,529 linear feet of streams, 1.94 acres of wetlands
and is located in the Roanoke River watershed. Surface waters on the property drain to Storys Creek,
Marlowe Creek and Castle Creek. The proposed project will directly impact 10,529 linear feet of streams
and 1.94 acres of wetlands.
The proposed chip manufacturing plant is in northern Person County, approximately 1.8 miles north of
the City of Roxboro. It is situated on both sides of Country Club Road, south of its intersection with
Edwin Robertson Road. The proposed water utility line will follow Country Club Road to Cavel-Club
Lake and terminate at Kelly Carver Road. The gas utility line will follow Country Club Road to
Community House Road to McGhees Mill Road and terminate at its intersection with Concord Ceffo
Road.
There is a record for the federal species of concern and state -special concern, notched rainbow (Villosa
constricta) in Storys Creek in the project vicinity. The lack of any further records from the site does not
imply or confirm the absence of federal or state -listed species or state Species of Greatest Conservation
Need listed in the 2015 State Wildlife Action Plan (http://www.ncwildlife.org//lan). An on-site survey is
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Person County Mega Park
SAW -2016-02542
the only definitive means to determine if the proposed project would impact rare, threatened or
endangered species.
The NCWRC hesitates to concur with stream impacts and the filling of wetlands due to wildlife habitat
value and the beneficial functions they provide for flood control and water quality protection. Changes in
land use and increases in impervious surfaces may exacerbate channel degradation and sediment impacts
to stream ecosystems due to increased stormwater runoff and elevated flooding. In addition, pollutants
(e.g., sediment, heavy metals, pesticides and fertilizers) washed from roads and developed landscapes can
adversely affect and extirpate species downstream. If the permit is approved, the NCWRC offers the
following recommendations to minimize impacts to aquatic and terrestrial wildlife resources:
Maintain or establish a minimum 100 -foot undisturbed, native, forested buffer along
perennial streams, and a minimum 50 -foot buffer along intermittent streams and wetlands.
Maintaining undisturbed, forested buffers along these areas will minimize impacts to aquatic
and terrestrial wildlife resources. Wide riparian buffers are helpful in maintaining stream
bank stability. In addition, these buffers provide a travel corridor for wildlife species. Lay
down and staging areas should be located outside wetland areas and at least 100 feet from
streak banks.
2. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert, where practicable. If culverts must be used, the culvert
should be designed to allow aquatic life passage. Fords may be appropriate and preferred for
intermittent stream crossings or where crossings will be used only once or twice a year. For
fords, crossings in riffles are preferred with the banks lowered upstream and downstream of
the crossing. Stabilize the stream bottom with geo-textile fabric and rock; concrete should
not be used for bed stabilization.
3. Measures to avoid or minimize impacts to wetlands should be implemented. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and
water quality protection. Temporarily disturbed wetland areas should be returned to original
soils and contours, reseeded with annual small grains appropriate for the season (e.g. oats,
millet, rye, wheat or rye grass) and allowed to revert to natural wetland vegetation. In all
forested wetlands, clearing should be done by hand.
4. Avoid the removal of large trees at the edges of construction corridors. Disturbed areas
should be re -seeded with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures as fescue is invasive and provides little benefit to wildlife. Native, annual small
grains appropriate for the season are preferred and recommended. Pollinator mixes are
commercially available and provide forage and shelter for numerous species of bees,
butterflies, moths and birds. Where feasible, use woody debris and logs from cleared areas to
establish brush piles adjacent to cleared right-of-ways to improve habitat. Allowing the
corridor areas to re -vegetate into a brush/scrub habitat would maximize benefits to wildlife.
For areas adjacent to residential areas, a native shrub/grass option may also be beneficial.
Minimize corridor maintenance and prohibit mowing between April 1 and October 1 to
minimize impacts to nesting wildlife. Create a maintenance schedule that incorporates only a
portion of the area (one third of the area, for example) each year instead of the entire project
area every 3 to 4 years. Pesticides (including insecticides and herbicides) should not be used
for maintenance of ROWS within 100 feet of perennial streams and 50 feet of intermittent
streams, or within floodplains and wetlands associated with these streams.

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February 22, 2019
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Sediment and erosion control measures should be installed prior to any land -disturbing
activity. The use of biodegradable and wildlife -friendly sediment and erosion control devices
is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose -
weave netting that is made of natural fiber materials with movable joints between the vertical
and horizontal twines. Silt fencing and similar products that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. Excessive silt and sediment loads can have detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs and clogging of gills.
The NCWRC encourages the applicant to consider additional measures to protect aquatic and terrestrial
wildlife species in developing landscapes. The NCWRC's Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (August 2002; http://www.ncwildlife.org/Portals/0/ConservingJdocuments/2002_
GuidanceMemorandumforSecondaryandCumulativeImpacts.pdf) details measures to minimize secondary
and cumulative impacts to aquatic and terrestrial wildlife resources; in addition, the Green Growth
Toolbox (http://216.27.39.101/ rg een rg owth/) provides information on nature -friendly planning that
discusses how to address growth while concurrently conserving priority terrestrial and aquatic habitat.
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] orabr�iela.garrison(&ncwildlife.org.
ec: Karen Higgins, NCDWR