20171559 Ver 3_Correspondence_20211005

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Scott McLendon, Chief
Regulatory Division, Wilmington District
US Army Corps of Engineers
69 Darlington Avenue
Wilmington NC 28403-1343
NORTH CAROLINA
Environmental Quality
October 5, 2021
Subject: REQUEST FOR ADDITIONAL REVIEW TIME
Certification Request for the proposed Greensboro -Randolph Megasite
USACE Action ID Number SAW-2015-01268
DWR# 20171559 v3
Dear Chief McLendon,
On July 7, 2021, the Division of Water Resources ("DWR") received a request for a 401 Water
Quality Certification for the referenced project. DWR public noticed the project on August 17,
2021 and the public comment period closed on September 17, 2021.
The "Clean Water Act Section 401 Certification Rule" ("Federal Rule") at 40 C.F.R. Section 121
became effective September 11, 2020. In May 2021, the Environmental Protection Agency
("EPA") announced its intention to reconsider and revise the Federal Rule'. On August 19, 2021,
EPA issued a guidance memorandum2 on the implementation of the Federal Rule until a revised
rule is promulgated. The Federal Rule at 40 C.F.R. § 121.6(c) requires federal agencies to set
the reasonable period of time for review of a certification request. In rule and guidance,
agencies are directed to consider the following factors when determining an appropriate
reasonable period of time: the complexity of the proposed project, the nature of any potential
discharge, and the potential need for additional study or evaluation of water quality effects
from the discharge.
The Wilmington District's default reasonable period of time for DWR action is 120 days. For the
subject project, DWR received the certification request on July 7, 2021 therefore the deadline
for DWR action is November 7, 2021. Pursuant to the Federal Rule and the August 2021
1 86 FR 29541 (June 2, 2021).
2 Memorandum from Environmental Protection Agency to EPA Regional Administrators, Region 1-10 and LTG Scott A. Spellmon, Chief of
Engineers, U.S. Army Corps of Engineers. Clean Water Act Section 401 Certification Implementation. Radhika Fox and Jaime Pinkham, August
19,2021(https://www.epa.gov/system/files/documents/2021-08/8-19-21-joint-epa-army-memo-on-cwa-401-implementation 508.pdf]
£ D_E
NORTH CAROLINA
Department of Environmental Dwllry
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11650 Mail Service Center I Raleigh, North Carolina 27699-1650
919.707.9000

Request for Additional Review Time
Greensboro -Randolph Megasite
Corps Action ID# SAW-2015-01268
DWR # 20171559 v3
Page 2 of 4
guidance memorandum, DWR understands that "the reasonable period of time may be
extended at the certifying authority or project proponent's request, as long as the extension
does not go beyond one year from the start of the reasonable period of time."3 Therefore DWR
hereby requests your written concurrence that a reasonable period of time for DWR to act on
the certification request for the proposed Greensboro -Randolph Megasite project is one year
from July 7, 2021.
In support of this request we direct your attention to the following considerations:
1. The complexity of the proposed project. [40 C.F.R. § 121.6(c)1]
The project proposes the construction of a 1,000-acre building pad which would be the
largest non -linear, non -transportation project in the state of North Carolina that DWR
has reviewed for certification. The project includes multiple components DWR is
required to carefully evaluate, including, but not limited to: site design and construction
plans, road improvement plans, rail improvement plans, utility infrastructure, a water
resource identification and testing plan, and a stormwater management plan. In
particular, stormwater management of a 1,000-acre impervious surface requires
thorough review to ensure it does not remove uses of downstream waters.
2. The potential need for additional study or evaluation of water quality effects from the
discharge. [40 C.F.R. § 121.6(c)3]
As designed, permanent resource impacts consist of 8.8 acres of wetlands, 21.8 acres of
open water and 41,409 liner feet of stream impacts. DWR does not have the
information necessary to complete a thorough evaluation of the project under state rule
15A NCAC 02H .0506. DWR requested additional information from the applicant on
September 6, 2021 and met with the applicants on September 13 and September 23,
2021 to clarify the needed information. On September 24, 2021 DWR sent another
information request asking the applicants to address comments received by the North
Carolina Wildlife Resources Commission. On September 27, 2021 DWR received an
incomplete response to both information requests. DWR met with the applicants on
September 30, 2021 and further/again explained the information needed to move
forward in our evaluation. We have enclosed our information requests and the
applicant's responses in order to specify to you the information DWR needs to evaluate
the water quality effects from the project's discharges in accordance with state rules.
3 Memorandum from Environmental Protection Agency to EPA Regional Administrators, Region 1-10 and LTG Scott A. Spellmon, Chief of
Engineers, U.S. Army Corps of Engineers. Clean Water Act Section 401 Certification Implementation. Radhika Fox and Jaime Pinkham, August
19,2021(https://www.epa.gov/system/files/documents/2021-08/8-19-21-joint-epa-army-memo-on-cwa-401-implementation 508.pdf]

Request for Additional Review Time
Greensboro -Randolph Megasite
Corps Action ID# SAW-2015-01268
DWR # 20171559 v3
Page 3 of 4
The history of this project has been considered carefully before making this request for
an extension of the reasonable period of time. The applicants previously requested
certification from the DWR for the same project on June 26, 2018. On August 27, 2018,
DWR requested additional information on that submittal. Almost one year later, the
applicants had not provided a complete response to the August 27, 2018 information
request and DWR denied the certification request on June 24, 2019 due to the lack of
information needed to evaluate water quality effects of the proposed discharge.
From this experience, DWR understands this project's unprecedented size, complexity,
and impacts to resources results in DWR needing a significant amount of time to obtain
the necessary information and review the certification request to render a final agency
decision. Therefore, in order to provide the greatest opportunity to obtain and review
the needed information, we are requesting written concurrence that a reasonable
period of time for DWR to act on the certification request for the project is one year
from July 7, 2021.
By making this request, DWR does not waive its right to determine upon further review of the
certification request that additional information and/or additional time is necessary to process
the application. DWR further does not waive its right to object to or contest the legality of any
of the provisions set forth in Federal Rule and any actions taken by the Corps pursuant to it,
whether related to this certification request or any other projects over which the State has
jurisdiction pursuant to Section 401 of the Clean Water Act.
Thank you for your consideration of this time -sensitive matter. Please contact Paul Wojoski at
919-707-9015 or [e-mail] with any questions.
Sincerely,
c—DocuSigned by:
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 and Buffer Permitting Branch
Division of Water Resources

Request for Additional Review Time
Greensboro -Randolph Megasite
Corps Action ID# SAW-2015-01268
DWR # 20171559 v3
Page 4 of 4
Enclosures:
1. DWR Letter to Greensboro -Randolph Megasite Foundation dated September 3, 2021
2. DWR Letter to Greensboro -Randolph Megasite Foundation dated September 24,
2021
3. HDR Letter to NC DEQ, response to comments (received September 6, 2021), dated
September 27, 2021
4. HDR Letter to NC DEQ, response to comments (received September 24, 2021), dated
September 27, 2021
cc via email:
Ronnie Smith, USACE Wilmington District
Henry Wicker, USACE Wilmington District
Todd Bowers, EPA
Wendee Smith, S2 Consulting
Vickie Miller, HDR
Jean Gibby, USACE Raleigh Regulatory Field Office
DWR 401 & Buffer Permitting Branch file
Filename: 20171559v3_GRMS_RPOT_Extension_Request

DocuSign Envelope ID: 21 E4F027-F09C-4368-8FA8-B41 DAA0333A0
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:
1. 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."
NORTH 1:tE
nepertment of Environmental jek"
CAROLINA
North Carolina Department of Environmental Quality Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

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-9]
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.deq.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.
cc via email:
Sincerely,
DocuSigned by:
Pma le 'o
�949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
Vickie Miller, HDR
Jean Gibby, USACE Raleigh Regulatory Field Office
Olivia Munzer, NCWRC
DWR 401 & Buffer Permitting Branch file
Filename: 20171559v3GreensboroRandolpMegasite(Randolph)_Addinfo.docx

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 24, 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.
In accordance with 15A NCAC 02H .0503 your application was placed on public notice on August
17, 2021. The comment period closed at 5 pm on September 17, 2021. The Division has
reviewed the comments received and has determined that additional information is necessary
to complete our review with regards to the comments that were received. The application is
on -hold until all of the following information is received:
1. Please provide a written response to the comments provided by the NCWRC on
September 14, 2021.
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 by submitting all of the above requested information through this
link: hh4 s:/% §Ag51:I gilPYFEC @I li I41if fgEti@l rc rm (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
£ D_E
NORTH CAROLINA
Department of Environmental Quality
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Greensboro Randolph Megasite Foundation
DWR# 20171559 v3
Request for Additional Information
Page 2 of 2
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.
Please contact Sue Homewood at 336-776-9693 orrS41.19AAvUORANVIINEA69 if you have
any questions or concerns.
Enclosure:
cc via email:
Sincerely,
DocuSigned by:
Pe e leoio;
949D91BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
WRC Memorandum to DWR, 14 September 2021
Vickie Miller, HDR
Jean Gibby, USACE Raleigh Regulatory Field Office
Olivia Munzer, NCWRC
DWR 401 & Buffer Permitting Branch file
Filename: 20171559v3GreensboroRandolpMegasite(Randolph)_Addinfo2.docx

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
MEMORANDUM
TO:
Sue Homewood
Division of Water Resources
NC Department of Environmental Quality
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 14 September 2021
Subject: Public Notice for Greensboro Randolph Megasite in Randolph County; USACE Action ID:
SAW-2017-01268; DEQ Project No. 20171559v3.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
HDR, on behalf of Greensboro -Randolph Megasite (GRMS) Foundation, Inc., has submitted an
Individual Permit application and associated documents for the proposed development of the GRMS, an
approximate 1,825-acre advanced automotive manufacturing facility, and associated utility and
transportation improvement sites. The GRMS is bounded by Old US 421 to the north, Julian Airport to
the west, Troy Smith Road to the east and US 421 to the south in the Town of Liberty, Randolph County,
North Carolina.
The proposed project would impact a total of 8.4 acres of jurisdictional wetlands, 21.3 acres of open
water, 6,806 linear feet of intermittent streams, and 29,656 linear feet of perennial streams. Streams
impacted by the project are Dobson Creek and its unnamed tributaries (UTs), Sandy Creek and its UTs,
UTs of Little Polecat Creek, Polecat Creek and its UTs, Climax Creek and its UTs, North Prong Stinking
Quarter Creek, and Big Alamance Creek and its UTs in the Cape Fear River basin.
We have records for the Carolina creekshell (Villosa vaughaniana; Federal Species of Concern, State
Endangered), notched rainbow (V. constricta; State Special Concern), eastern creekshell (V. delumbis),
and Carolina ladle crayfish (Cambarus davidi; State Significantly Rare) in waterways that are directly or
indirectly impacted by the project. The Greensboro burrowing crayfish (C. catagius; State Significantly
Rare) could also potentially occur within the project area. Although some records occur within the area,
we have many data gaps, including throughout the site. The lack of records from the site does not imply
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

14 September 2021
Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
Page 2 WRC Comments
or confirm the absence of state -listed species. An on -site survey for state -listed species is the only
definitive means to determine if the proposed project would impact rare, threatened, or endangered
species.
We have concerns on the impacts of this project on aquatic and terrestrial wildlife resources. Although
the applicant will mitigate for the impacts to streams and wetlands, there is a temporal lag in aquatic and
terrestrial function at a mitigation site. Additionally, the impacts to aquatic and terrestrial flora and fauna
from such a large project cannot be replaced with mitigation. Therefore, we would like to see impacts to
waters of the U.S. further minimized or avoided. Furthermore, the large amount of impervious surface
proposed, along with the removal of those currently mostly buffered tributaries, would contribute to
significant degradation of downstream habitat for aquatic species, including increased flooding intensity
and erosion from stormwater.
We offer the following recommendations minimize impacts to aquatic and terrestrial wildlife resources.
Overall Project:
1. We recommend surveys for state -listed mussel and crayfish species to determine if relocations are
needed. Please contact Brena Jones, the Central Aquatic Wildlife Diversity Research
Coordinator, at 919-707-0369 or [e-mail].
2. We highly recommend avoiding impacts to the tributary complex (S21 and its UTs) in the eastern
portion of the project. It is the only stream complex in the project area not flowing into Dobson
Lake, which is a man-made lake that already impedes aquatic movements.
3. A large portion of the project is used for surface parking. We recommend building a parking deck
or underground parking rather than impacting the streams for surface parking. For any surface
parking or roads, we recommend using bioretention cell in parking lot medians, for example, that
can collect stormwater from the building and parking area. Additional information can be found
at the NC State University's guide:
http://www.onsiteconsortium.org/npsdeal/NC_LID_Guidebook.pdf.
4. The applicant should avoid the removal of large trees. Due to the decline in many tree -roosting
bat populations, trees should not be removed during the maternity roosting season for bats (May
15 — August 15).
5. We recommend a minimum 100-foot undisturbed buffer for perennial streams and a 50-foot
undisturbed buffer for intermittent streams and wetlands.
6. Incorporate the following elements into erosion and sediment control plans: minimize clearing
and grading, protect waterways, phase construction for larger construction sites (>25 acres),
stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish appropriate
perimeter controls, employ advanced settling devices, implement a certified contractors program,
and regularly inspect erosion control measures. Ensure all silt fencing is removed once vegetation
has reestablished and soils have stabilized.
7. Disturbed areas should be reseeded with native seed mixtures that are beneficial to wildlife. The
applicant should consider planting native, wildflower seed mixes and plants that will create
pollinator habitat, which would also improve the aesthetics of the project and within rights -of -
way. Bermudagrass, redtop, tall fescue, and lespedeza, which are invasive and/or non-native
species, should not be used and these species provide little benefit to wildlife. In lieu of lawn or
grassy areas, we recommend planting native pollinator species or other native vegetation. Avoid
using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.org/plant_galleries/invasivesiist).

14 September 2021
Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
Page 3 WRC Comments
8. Sediment and erosion control measures should be installed prior to any land clearing or
construction. 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 that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment loads can
have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
Utility Lines:
9. To reduce impacts to streams, we recommend the sewer/water line run from Liberty Road portion
as seen in Alternative 1 and then use Alternative 2 route along Steeple Chase Road.
10. The directional bore stream crossing method should be used for utility crossings rather than open -
cut stream crossing method to prevent the likelihood of future lateral movement of the stream,
causing undercutting or erosion around the utility line. The open -cut stream crossing method
should only be used when water level is low and stream flow is minimal.
11. Sewer lines, water lines, and other utility infrastructure should be kept out of riparian buffer
areas. Manholes or similar access structures should not be allowed within buffer areas. Stream
crossings should be near perpendicular (75° to 105°) to stream flow.
12. Clearing of the rights -of -way should be avoided during the migratory bird nesting season, roughly
March to August.
Transportation:
13. The culvert must be designed to allow for aquatic life and fish passage. Generally, the culvert or
pipe invert should be buried at least 1 foot below the natural streambed (measured from the
natural thalweg depth). If multiple barrels are required, barrels other than the base flow barrel(s)
should be placed on or near stream bankfull or floodplain bench elevation (similar to Lyonsfield
design). These should be reconnected to floodplain benches as appropriate. This may be
accomplished by utilizing sills on the upstream and downstream ends to restrict or divert flow to
the base flow barrel(s). Silled barrels should be filled with sediment so as not to entrap wildlife
or support mosquito breeding conditions. Sufficient water depth should be provided in the base
flow barrel(s) during low flows to accommodate fish movement. If culverts are longer than 40-50
linear feet, alternating or notched baffles should be installed in a manner that mimics existing
stream pattern. This should enhance aquatic life passage: 1) by depositing sediments in the
barrel, 2) by maintaining channel depth and flow regimes, and 3) by providing resting places for
fish and other aquatic organisms. In essence, base flow barrel(s) should provide a continuum of
water depth and channel width without substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment whenever possible to
avoid channel realignment. Widening the stream channel must be avoided. Stream channel
widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be
professionally designed, sized, and installed.

14 September 2021
Greensboro -Randolph Megasite IP
USACE Action ID: SAW-2015-01268
Page 4 WRC Comments
The NCWRC encourages the applicant to consider additional measures to protect 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 details measures to
minimize secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
http://www.ncwildlife.org/portals/O/Conserving/documents/2002 GuidanceMemorandumforSecondaryan
dCumulativelmpacts.pdf (August 2002).
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or [e-mail].
ec: Vickie Miller, HDR
John Ellis, U.S. Fish and Wildlife Service
Brena Jones, NCWRC
Jean Gibby, USACE

hdrinc.com
September 27, 2021
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
ATTN: Ms. Sue Homewood
SUBJECT: Individual Permit Application Comments Received on September 6, 2021
Greensboro Randolph Megasite and Associated Infrastructure
Randolph County, North Carolina
Ms. Homewood:
The Greensboro -Randolph Megasite Foundation, Inc. (GRMF) is providing responses to
comments received from the Division of Water Resources on September 6, 2021 for the
individual permit application and supporting documentation for development of the proposed
Greensboro -Randolph Megasite (the "Proposed Project" or "Project GRMS"), located in
northern Randolph County, North Carolina. Below you will find the comment from DWR in
bold followed by the GRMF's response in italics.
1. 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.
Noted
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."
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).
555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
[phone]

DWR referred to a site plan that reflects a "final design. "As DWR knows, since the inception
of the project the permitting of the GRMS is being done in advance of identifying the end
user. This aspect of the project is essential for this North Carolina project to be competitive
nationally. Similar projects have been permitted. GRMS marketing continues. If the DWR
concept of "final design" requires details that will be identified by the end user, it cannot be
provided at this time. However, more information than has already been provided is
unnecessary.
A multilayer analysis was conducted on the GRMS site to evaluate several configurations
of the pad and find the one that provides avoidance and minimization of impacts. This starts
on Page 12, Section 4.3.3 Level 3 Analysis of the Supporting Documentation and
Environmental Report. In addition, the GRMS Supporting Documentation and
Environmental Report dated May 10, 2021 included Appendix H which was titled "Agency
Coordination Following Public Notice." This Appendix discusses the requirement of a 1,000-
acre pad as well as the site criteria that have been requested previously. This information
states the size requirements including the rectangular shaped pad. On November 12, 2020
a letter to the USACE described the types of facilities that would be required for the OEM
requirements which is also in Appendix H. In addition, on January 8, 2021 a site plan was
provided that detailed where manufacturing facilities, parking, roadways, testing facilities,
rail/rail yards, etc. would be located (page 283 of the supporting documentation pdt).
More detailed information than already provided is not required to complete an impact
avoidance and minimization analysis under 15A NCAC 2H .0506. We understand the issue
of avoidance and minimization has already been correctly resolved by use of a condition to
be included in the permit and/or certification.
We also understand an impact avoidance and minimization analysis has been conducted
by and will be finalized by the USACE under its regulations. There is no need for DWR to
conduct an analysis under EMC regulations. In fact, by law, EMC regulations cannot
produce a more restrictive analysis. NCGS § 150B-19.3(a). There is no point to DWR
conducting a duplicative analysis.
It is not unusual to issue certifications for projects for which there is uncertainty regarding
impacts that is resolved by certification/permit conditions. For example, the North Carolina
Court of Appeals upheld a certification despite uncertainty about whether the project would
cause an outright water quality standard violation:
"no one will know precisely whether or to what extent exceedances [sic] of
the Standard will occur until construction of the dam and impoundment of
the lake have been completed" ....
Deep River Citizens' Coalition v. NCDENR, 165 N.C. App. 206, 213, 598 S.E.2d 565, 569
(2004). Unlike a reservoir project, the GRMS application does not require construction and

completion of the project to resolve uncertainty. Any uncertainty about the site plan will be
resolved before construction occurs.
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-9]
A SEPA document is being prepared for the transportation component of the project and is
currently underway. Please note that the Supporting Documentation and Environmental
Report was developed to meet the 404(b)(1) guidelines.
A SEPA document is not required for DWR issuance of the certification. The SEPA statute
expressly specifies that no document is required for DWR to issue a certification.
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.
Noted. Agent authorizations forms for Duke, City of Greensboro, and NCDOT were
inadvertently left out of the submittal. The NCDOT and City of Greensboro agent
authorization forms are attached. The Duke form will be provided soon.
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.
Please review Section 4.3.3 of the Supporting Documentation and Environmental Report.
In that section you will note the preferred alternative impacts 36,774 If of stream which is the
second lowest amount of stream impact of the options. The lowest stream impact option,
Option 3, has less stream impact; however, it impacts over 1.5 acres more of wetlands and
nearly 15 acres more of open watch which includes Dodsons Lake. Also, note that Option
3 does not include the rail siding impacts and the stream/wetland/open water impacts would

be increased due to those impacts. Option 1 (preferred) was selected due to having similar
or less impacts to jurisdictional resources.
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.
The resources on those plan sheets are headwater reaches that have minimal biological or
hydrologic function according to the stream classifications as intermittent channels and the
SAM form scores which show their quality as low (see attached). These resources will
provide the same benefit to downstream water quality as they currently serve.
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 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.
The conceptual stormwater plan considers the drainage areas on the site and the
stormwater ponds/outlets are situated to maintain hydrology to the streams down gradient
of the pad. In addition, the groundwater for the main streams is intended to have an
underdrain system which should ensure the stream maintain hydrology very similar to
existing conditions. See the attached stormwater concept mapping for additional detail.
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.

See note the previous answer and the Conceptual Overall Site Plan, sheet 01X-01, for the
current concept design.
The development will increase the storm water runoff to the downstream systems. It is
anticipated that 400-450 acre/ft of detention volume storage will be required for this
development to meet current local and State of North Carolina DEQ requirements. A storm
drainage system will be developed onsite to discharge into detention ponds A, B and C,
depicted on sheet SW-01. Outlets from the ponds will be designed to mimic the pre -
developed flows into each downstream drainage system. Upstream of the site, any existing
channel flow will be captured and conveyed through the site to discharge back into the
downstream channels that water would naturally flow to before development. See Sheet
SW-01 for these conceptual storm sewers.
This development will require filling in several streams on the property. Stream beds that
are impacted by the fill will be replaced with an underdrain system to allow ground water to
flow in its natural channel under the site until it discharges into the existing downstream
systems. This is depicted on sheet SW-02.
8. For the NCDOT transportation infrastructure improvement plans, please provide a
conceptual stormwater management plan.
Once the NCDOT roadway plans have been finalized the stormwater plan will also be
finalized. The plan will follow NCDOT's typical process for development of the Stormwater
Plan. The NCDOT Stormwater Management Plan Version 3.00 will summarize general
project information and stormwater pollution source control and treatment measures
proposed for the transportation portion of the project.
9. Please provide an updated acceptance letter from the Division of Mitigation
Services.
This was provided in the files transmitted on July 7, 2021. It has also been attached.
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.
Please refer to Appendix H of the Supporting Documentation where this comment was
addressed for the USACE. The City of Greensboro will provide water and sewer service to
the GRMS site and has stated the City will allow private landowners to obtain water service
should issues occur to their drinking water wells as a result of the activities at the GRMS.
The private landowners will need to contact the City of Greensboro Engineering Manager if
there are concerns.

The Applicant looks forward to working with the DWR on completing the permitting process
and issuance of a 401 Water Quality Certification for the GRMS project. Please call me at
919-232-6637 or email at [e-mail] if you need additional information or
clarification on any of the information provided.
Sincerely,
HDR Engineering Inc. of the Carolinas
/*aLclfcr
Vickie Miller, AICP, PWS
Senior Environmental Planner
Attachments:
Attachment A — Agent Authorization Forms
Attachment B — Conceptual Stormwater Plans
Attachment C — DMS Acceptance Letter
cc: Jim Melvin, Greensboro Randolph Megasite Foundation
William G. Ross, Brooks Pierce
V. Randall Tinsley, Brooks Pierce
Wendee Smith, S2 Consulting

Attachment A

AGENT AUTHORIZATION FORM
I, Michael Borchers, representing the City of Greensboro, hereby certify
that I have authorized Vickie Miller, representing HDR Engineering, Inc. of
the Carolinas, to act on my behalf in the processing, issuance, and
acceptance of the verification of jurisdictional waters of the U.S. and
Section 404/401 permitting associated with infrastructure for the
Greensboro Randolph Megasite, located in Randolph County, North
Carolina.
Owner's Contact Information:
Michael Borchers, Water Resources Director
City of Greensboro
Owner's Address: PO Box 3136
Greensboro, NC 27402-3136
Telephone Number. 336-373-2494
Email address: [e-mail]
Owner's signature
September 27, 2021
Date
Agent's Contact Information:
Vickie Miller, AICP, PWS
HDR Engineering Inc. of the Carolinas
Agent's Address: 555 Fayetteville Street, Suite 900
Raleigh, NC 27601
Telephone Number. 919-232-6600
Email address: [e-mail]

AGENT AUTHORIZATION FORM
I, Patrick Norman, representing the North Carolina Department of
Transportation, hereby certify that I have authorized Vickie Miller,
representing HDR Engineering, Inc. of the Carolinas, to act on my behalf
in the processing, issuance, and acceptance of the verification of
jurisdictional waters of the U.S. and Section 404/401 permitting associated
with infrastructure for the Greensboro Randolph Megasite, located in
Randolph County, North Carolina.
Owner's Contact Information:
Patrick Norman, Division Engineer
North Carolina Department of Transportation, Division 8
Owner's Address: 121 DOT Drive
Carthage, NC 28327
Telephone Number.
Email address:
910-773-8003
[e-mail]
Owner's signature
Date
Agent's Contact Information:
Vickie Miller, AICP, PWS
HDR Engineering Inc. of the Carolinas
Agent's Address: 555 Fayetteville Street, Suite 900
Raleigh, NC 27601
Telephone Number. 919-232-6600
Email address: [e-mail]

Attachment B

1
US HWY 421
INTERCHANGE
\pwworking\east0l\d0394127\01X-01.dwg, Overall Site Plan, 9/22/2021 9:54:31 PM, MMESSING
FACILITIES
SAN SEWER
FORCE MAI
HDR Engineering Inc.
of the Carolinas
440 S. Church Street, Suite 1000
Charlotte, NC 28202
704.338.6700
N.C.B.E.L.S. License Number: F-0116
2
3
AIL SPUR INTO SITE
1,000 ACRE
PAD BOUNDARY
GRADING LIMITS
US HWY 421
INTERCHANGE
■
■ AIL YARD
SITE ENTRANCE
7 DODSONS
LAKE
MATCHLINE - SEE INSET THIS SHEET
4
PARKING
PROJECT MANAGER VICKIE M. MILLER, AICP, PWS
PROJECT PRINCIPAL
PAUL MEEHAN, PE
PROJECT ENGINEER
DAVID BAKER, PE
DESIGN ENGINEER
DRAWN BY
CHECKED BY
5
00 KV TRANSMIS
MAIN REROUTE
PERIMETER ROAD
4
MANUFACTURING FACILITY
■
PARKING
PARKING
PARKING
PARKING
GREENSBORO RANDOLPH
MEGASITE PROPERTY BOUNDARY
6
0�042
SION
-70
co
TESTING
TRACK
AIL YARD
RAIL
LOGISTICS
RADING
LIMITS
GREENSBORO RANDOLPH MEGASITE
FOUNDATION
GREENSBORO RANDOLPH MEGASITE
RANDOLPH COUNTY, NORTH CAROLINA
N
0
7
600
0
8
GRAPHIC SCALE
300 600 1200
2400
(IN FEET)
1 INCH = 600 FT.
MATCHLINE - OVERALL SITE PLAN THIS SHEET
SAN SEWER
FORCE MAI
INSET
SAN SEWER
PUMP
STATION
GREENSBORO-RANDOLPH MEGA SITE
CONCEPTUAL
OVERALL SITE PLAN
WITH DRAINAGE AREAS SHOWN
600' 1200' FILENAME
01 X-01.dwg
SHEET
01 X-01
D
c
B
A
ISSUE DATE
DESCRIPTION
PROJECT NUMBER
10068163
SCALE
1" = 600'

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of the Carolinas
555 Fayetteville Street, Suite 900
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DATE
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11/21/2017
SW-01

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DATE
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11 /21 /2017
SW-02

Attachment C

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
TIM BAUMGARTNER NORTH CAROLINA
Director Environmental Quality
June 18, 2021
Jim Melvin
Greensboro Randolph Megasite Foundation
324 W. Wendover Ave., Suite 207
Greensboro, NC 27408
Expiration of Acceptance: 12/18/2021
Project: Greensboro Randolph Megasite County: Randolph
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing
to accept payment for compensatory mitigation for impacts associated with the above referenced project
as indicated in the table below. Please note that this decision does not assure that participation in the
DMS in -lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for
project impacts. It is the responsibility of the applicant to contact permitting agencies to determine if
payment to the DMS will be approved. You must also comply with all other state, federal or local
government permits, regulations or authorizations associated with the proposed activity including G.S. §
143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification within this time frame, this acceptance
will expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives
a copy of the permit(s) an invoice will be issued based on the required mitigation in that permit and
payment must be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid
by an applicant is calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of
mitigation required and assigned to DMS for this impact is determined by permitting agencies and may
exceed the impact amounts shown below.
River Basin
Impact Location
(8-digit HUC)
Impact Type
Impact Quantity
Cape Fear
03030003*
Warm Stream
42,398
Cape Fear
03030003*
Riparian Wetland
9.25
Cape Fear
03030002*
Warm Stream
38
*DMS proposes to provide the required mitigation credits for the above -referenced impacts in the Cape
Fear 03030002 and 03030003 HUCs. Upon receipt of payment, DMS will take responsibility for providing
the compensatory mitigation. The mitigation will be performed in accordance with the In -Lieu Fee
Program instrument dated July 28, 2010. Thank you for your interest in the DMS in -lieu fee mitigation
program. If you have any questions or need additional information, please contact
[e-mail].
cc: Vickie Miller, agent
£ D_E
NORTH CAROLINA
Department of Environmental Oual\
Sincerely,
AtUviTAit:ata
FOR James. B Stanfill
Asset Management Supervisor
North Carolina Department of Environmental Quality I Division of Mitigation Services
217 West Jones Street 11652 Mail Service Center I Raleigh, North Carolina 27699-1652
919.707.8976

hdrinc.com
September 27, 2021
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
ATTN: Ms. Sue Homewood
SUBJECT: Individual Permit Application Public Notice Comments Received on
September 24, 2021
Greensboro Randolph Megasite and Associated Infrastructure
Randolph County, North Carolina
Ms. Homewood:
The Greensboro -Randolph Megasite Foundation, Inc. (GRMF) is providing responses to
comments received from the Division of Water Resources on September 24, 2021
following the public notice for individual permit application and supporting documentation
for development of the proposed Greensboro -Randolph Megasite (the "Proposed Project"
or "Project GRMS"), located in northern Randolph County, North Carolina. Below you will
find the comments from Wildlife Resources Commission followed by the GRMF's response
in italics.
Overall Project:
1. We recommend surveys for state -listed mussel and crayfish species to determine if
relocations are needed. Please contact Brena Jones, the Central Aquatic Wildlife
Diversity Research Coordinator, at 919-707-0369 or brena.jones(a�ncwildlife.orq.
Contact with Brena Jones will be made prior to construction of the components of
the project. Please note most of the stream reaches within the site experience
intermittent flow for portions of the year.
2. We highly recommend avoiding impacts to the tributary complex (S21 and its UTs)
in the eastern portion of the project. It is the only stream complex in the project
area not flowing into Dobson Lake, which is a man-made lake that already impedes
aquatic movements.
Noted. S21 and its tributaries exhibit periods of low or no flow regularly throughout
the season. Please note during the Cape Fear shiner survey, completed by RK&K,
S21 (Pages 216-217 of the Supporting Documentation) state this stream was
completely dry at the AL-4 location and had minimal water at AL-2. Please also
see page 218 of the supporting information which states the following "While these
stream conditions may not be common throughout the year, streams experiencing
555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
[phone]

these conditions tend to support a more limited aquatic fauna than streams not
subjected to such low flow conditions."
3. A large portion of the project is used for surface parking. We recommend building a
parking deck or underground parking rather than impacting the streams for surface
parking. For any surface parking or roads, we recommend using bioretention cell in
parking lot medians, for example, that can collect stormwater from the building and
parking area. Additional information can be found at the NC State University's
guide:
http://www.onsiteconsortium.orq/npsdeal/NC LID Guidebook.pdf.
Noted. The conceptual stormwater plan has been developed. Final stormwater
plans will consider these options as well as others in the NC LID Guidebook.
4. The applicant should avoid the removal of large trees. Due to the decline in many
tree -roosting bat populations, trees should not be removed during the maternity
roosting season for bats (May 15 — August 15).
Noted. A large portion of the site has been previously timbered. This will be taken
into consideration for the remaining areas.
5. We recommend a minimum 100-foot undisturbed buffer for perennial streams and
a 50-foot undisturbed buffer for intermittent streams and wetlands.
Noted.
6. Incorporate the following elements into erosion and sediment control plans:
minimize clearing and grading, protect waterways, phase construction for larger
construction sites (>25 acres), stabilize soils as rapidly as possible (<2 weeks),
protect steep slopes, establish appropriate perimeter controls, employ advanced
settling devices, implement a certified contractors program, and regularly inspect
erosion control measures. Ensure all silt fencing is removed once vegetation has
reestablished and soils have stabilized.
Noted. The project will adhere to the NCDEQ NPDES Construction Stormwater
requirements and the NCG01 General Construction Permit.
7. Disturbed areas should be reseeded with native seed mixtures that are beneficial
to wildlife. The applicant should consider planting native, wildflower seed mixes
and plants that will create pollinator habitat, which would also improve the
aesthetics of the project and within rights -of -way. Bermudagrass, redtop, tall
fescue, and lespedeza, which are invasive and/or non-native species, should not
be used and these species provide little benefit to wildlife. In lieu of lawn or grassy
areas, we recommend planting native pollinator species or other native vegetation.

Avoid using invasive, non-native plants in seed mixtures or landscaping plants
(http://www.ncwildflower.orq/plant qalleries/invasives list).
Noted.
8. Sediment and erosion control measures should be installed prior to any land
clearing or construction. 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 that has been reinforced with plastic or metal mesh should be
avoided as it impedes the movement of terrestrial wildlife species. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including
destruction of spawning habitat, suffocation of eggs, and clogging of gills of aquatic
species.
Noted. Sediment and erosion control devices will be monitored/maintained
regularly throughout the project construction and removed following
construction/stabilization.
Utility Lines:
9. To reduce impacts to streams, we recommend the sewer/water line run from
Liberty Road portion as seen in Alternative 1 and then use Alternative 2 route
along Steeple Chase Road.
The City of Greensboro has a Capital Improvements Program (CIP) project that
takes water and sewer service approximately 2 miles from the project. This
alternative has fewer impacts than the Alternative 2 route noted above and is the
preferred alignment as it can tie to the CIP Southeast Feeder Main and Liberty
Road Sewer Force Main project.
10. The directional bore stream crossing method should be used for utility crossings
rather than opencut stream crossing method to prevent the likelihood of future
lateral movement of the stream, causing undercutting or erosion around the utility
line. The open -cut stream crossing method should only be used when water level
is low and stream flow is minimal.
Noted. The City of Greensboro evaluates utilizing directional bores during their
design and incorporate it when feasible.
11. Sewer lines, water lines, and other utility infrastructure should be kept out of
riparian buffer areas. Manholes or similar access structures should not be allowed

within buffer areas. Stream crossings should be near perpendicular (75o to 1050)
to stream flow.
Noted.
12. Clearing of the rights -of -way should be avoided during the migratory bird nesting
season, roughly March to August.
Noted.
Transportation:
13. The culvert must be designed to allow for aquatic life and fish passage. Generally,
the culvert or pipe invert should be buried at least 1 foot below the natural
streambed (measured from the natural thalweg depth). If multiple barrels are
required, barrels other than the base flow barrel(s) should be placed on or near
stream bankfull or floodplain bench elevation (similar to Lyonsfield design). These
should be reconnected to floodplain benches as appropriate. This may be
accomplished by utilizing sills on the upstream and downstream ends to restrict or
divert flow to the base flow barrel(s). Silled barrels should be filled with sediment so
as not to entrap wildlife or support mosquito breeding conditions. Sufficient water
depth should be provided in the base flow barrel(s) during low flows to
accommodate fish movement. If culverts are longer than 40-50 linear feet,
alternating or notched baffles should be installed in a manner that mimics existing
stream pattern. This should enhance aquatic life passage: 1) by depositing
sediments in the barrel, 2) by maintaining channel depth and flow regimes, and 3)
by providing resting places for fish and other aquatic organisms. In essence, base
flow barrel(s) should provide a continuum of water depth and channel width without
substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to
remain dry during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment
whenever possible to avoid channel realignment. Widening the stream channel
must be avoided. Stream channel widening at the inlet or outlet end of structures
typically decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the
streambed in a manner that precludes aquatic life passage. Bioengineering
boulders or structures should be professionally designed, sized, and installed.
These items will be incorporated into the NCDOT design unless there is an existing
pipe, culvert, or bridge which would dictate a different design.

14. The NCWRC encourages the applicant to consider additional measures to protect
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 details measures to minimize
secondary and cumulative impacts to aquatic and terrestrial wildlife resources:
http://www.ncwildlife.orq/portals/0/Conservinq/documents/2002 GuidanceMemora
ndumforSecondaryandCumulativelmpacts.pdf (August 2002).
Noted.
The Applicant looks forward to working with the DWR on completing the permitting
process and issuance of a 401 Water Quality Certification for the GRMS project. Please
call me at 919-232-6637 or email at [e-mail] if you need additional
information or clarification on any of the information provided.
Sincerely,
HDR Engineering Inc. of the Carolinas
\(60.dfdiav
Vickie Miller, AICP, PWS
Senior Environmental Planner
cc: Jim Melvin, Greensboro Randolph Megasite Foundation
Wendee Smith, S2 Consulting