20171559 Ver 3_More Info Requested_20210903

DocuSign Envelope ID: 21 E4F027-F09C-4368-8FA8-B41 DAA0333AO
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 3, 2021
DWR # 20171559 v3
Randolph/Guilford County
Greensboro Randolph Megasite Foundation
Attn: Mr. Jim Melvin
324 W. Wendover Ave, Suite 207
Greensboro NC 27408
Subject: REQUEST FOR ADDITIONAL INFORMATION
Greensboro Randolph Megasite
Dear Mr. Melvin:
On July 28, 2021 the Division of Water Resources (Division) received your application
requesting a 401 Individual Water Quality Certification from the Division for the subject project.
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:
In accordance with 15A NCAC 02H .0503 your application was placed on public notice
on August 17, 2021. The comment period will remain open until 5 pm on September
17, 2021. It may be necessary for the Division to request additional information at a
later date in order to address any comments received during the public comment
period.
2. The Division is required to conduct an evaluation of avoidance and minimization as
required under 15A NCAC 02H .0506(b). The summary of similarly sized auto
manufacturing facilities throughout the southeast does not adequately address the
specific proposal for an exact 1,000-acre or rectangular building pad that you have
requested. In a response to a previous request from the US Army Corps of Engineers
you noted that "Automotive manufacturing sites will have different acreage needs
based on what they are producing and their storage capacity needs." and "Additional
avoidance and minimization efforts will be addressed during final design of the
project."
EQ � North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center Raleigh, North Carolina 27699-1617
NORTH CAROL1Nl
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DocuSign Envelope ID: 21 E4F027-F09C-4368-8FA8-B41 DAA0333A0
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 2 of 4
Accordingly, please provide all additional information that supports the specific
design and layout of the project necessary for an evaluation and assessment of
avoidance and minimization pursuant to 15A NCAC 02H .0506(b)(1).
3. Is any portion of the project (inclusive of utilities and other supporting infrastructure)
on "public lands" or is any funding of the project a "significant expenditure of public
moneys" as those terms are defined in the State Environmental Policy Act (SEPA)?
[G.S. § 113A-91
4. The application indicates that there will be no co -applicants. You have submitted an
Agent Authorization Form for the Greensboro Randolph Megasite Foundation
("GRMF"), the NC Railroad Company and Randolph County, however the impacts
proposed include transportation improvements to NCDOT roadways, electric power
upgrades by Duke Power and water and sewer lines provided by the City of
Greensboro. Please clarify whether all impacts requested in the 401 Individual
Certification are to be authorized to the GRMF and if so, please provide Agent
Authorization Forms for all entities and please confirm that these entities. Please
note that if the 401 is to be issued only to the GRMF then it will be responsible for
compliance with all conditions of that 401 including conditions related to
construction compliance, mitigation requirements, post construction stormwater
requirements, and any other potential long term requirements that may be
applicable beyond the construction period of the project.
5. The onsite avoidance and minimization analysis (on -site alternatives analysis)
indicates that there is a preference to avoid impacts to Dodsons Lake. Please provide
a more detailed explanation of why it is preferable to select an alternative with less
impacts to Dodsons Lake and greater impacts to streams.
6. Pursuant to 15A NCAC 02H.0506(b) a 401 Water Quality Certification may only be issued
upon determining that existing uses are not removed or degraded by a discharge to classified
surface waters. Based on the information provided in the application the Division has the
following concerns:
a. Along the northern boundary of the project site (plan sheets 01X-05 —01X- 07) small
segments of streams will be indirectly affected by becoming disconnected, and
essentially isolated, from all other natural features. These small disconnected
features are unlikely to continue to provide the same hydrologic and biological
function and therefore should be counted as indirect "loss of water". Please revise
the application, plan sheets, and impact tables accordingly.
b. All surface flow from the project is proposed to be rerouted through multiple
stormwater wet detention basins. In order to review possible secondary impacts to
downstream hydrology, please provide plans that clearly show the outlet location
from each stormwater control measure. Please note that the rerouting of any
drainage area and surface flow has the potential to remove existing hydrology from
features adjacent to this project and therefore remove existing uses of the stream

DocuSign Envelope ID: 21 E4F027-F09C-4368-8FA8-B41 DAA0333A0
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 3 of 4
channels or wetlands. Upon further review of the information provided in response
to this Item, the Division may require a more thorough analysis and/or more
information for particular portions of this project.
7. Given the significant potential for downstream water quality impacts from the
significant size and impacts of this proposed project, a conceptual stormwater
management plan will not be sufficient for the Division to certify that there will be no
violations of downstream water quality standards. Please provide a full
design/complete Stormwater Management Plan for the 1000-acre building site and
any interior transportation infrastructure that will not be part of the NCDOT
transportation plans.
8. For the NCDOT transportation infrastructure improvement plans, please provide a
conceptual stormwater management plan.
9. Please provide an updated acceptance letter from the Division of Mitigation Services.
10. In order to sufficiently address public concerns regarding impacts to adjacent drinking
water wells please provide a residential well sampling and complaint resolution plan.
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 denied as
incomplete. The denial of this project will necessitate reapplication to the Division for approval,
including a complete application package and the appropriate fee.
Please be aware that you have no authorization under the Section 401 of the Clean Water for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.

DocuSign Envelope ID: 21 E4F027-F09C-4368-8FA8-B41 DAA0333A0
Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 4 of 4
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have
any questions or concerns.
Sincerely,
DOCUSSiigned by:
�GwtG �O L�
949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc via email: Vickie Miller, HDR
Jean Gibby, USACE Raleigh Regulatory Field Office
Olivia Munzer, NCWRC
DWR 401 & Buffer Permitting Branch file
Filename: 20171559v3GreensboroRandolpMegasite(Randolph)_Addinfo.docx