20171559 Ver 3_More Info Received_20220110

F�2
hdrinc.com
January 10, 2022
Andrew Williams
Regulatory Project Manager
US Army Corps of Engineers
Wilmington District, Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Re: Greensboro Randolph Megasite — USACE Action ID No. SAW-2015-01268
Dear Mr. Williams,
This letter encloses trade secrets and confidential information that no one may release or make
available to any person other than a USACE employee responsible for processing the GRMS
404 permit or a DEQ employee responsible for processing the GRMS water quality certification.
Any page of any enclosure that includes one or more of the following three stamps must not
be released to any third party pursuant to the North Carolina public records law, FOIA, or
otherwise:
• Contains information exempt from disclosure pursuant to Exemption 4 of the FOIA; trade secrets and
commercial or financial information that are customarily considered to be confidential; submitted to the
government for the sole purpose of informing the permit evaluation process; this information shall not
be disclosed without the express authorization of the applicant, Greensboro -Randolph Megasite
Foundation, Inc.
• CONFIDENTIAL BUSINESS INFORMATION/TRADE SECRET/SUBJECT TO G.S. 132-1.2(1)
• CONFIDENTIAL/NOT FOR PUBLIC DISCLOSURE/SUBJECT TO G.S. 132-6(d)
Thank you for emailing, on December 8, 2021, your letter regarding the Greensboro -Randolph
Megasite Foundation's ("GRMF") permit application. Your letter presents: three information requests
from the U.S. Army Corps of Engineers ("USACE"); and copies of public comments the USACE
received in response to the second USACE public notice (review period November 19, 2021 to
December 6, 2021) for the Greensboro Randolph Megasite ("GRMS") Section 404 Individual Permit
Application. Responses to the public comments were provided on January 8, 2021. The responses to
the three information requests from the USACE are provided below.
Responses to USACE information requests:
Capacity
The USACE made the following comment:
Capacity for the proposed battery facility; Toyota recently announced that the GRMS
site was selected as the location for their new automotive battery manufacturing plant.
The reported capacity of the plant (i.e. batteries for specific number of vehicles per
year or specific number of battery packs per year) is pertinent to the proposed size of
the facility and consequently the avoidance/minimization to the on -site aquatic
resources. Current publicly available information reports differing capacities. Please
555 Fayetteville Street, Suite 900 Raleigh, NC 27601-3034
[phone]

confirm the intended capacity of the proposed plant and a brief discussion regarding
the capacity as it relates to avoidance and minimization to aquatic resources impacts.
Toyota, the end user of the GRMS, forecasts that its facility will begin production after construction of
part of the facility and while additional construction of the remainder of the facility is ongoing.
Reducing the capacity of the facility could potentially result in a smaller footprint, but such a
modification is not practicable for a number of reasons, including: (1) the project's failure to achieve
the applicant's purpose and need (Attachment 1 — revisions that updated Environmental Report
Section 3.1 (Applicant's purpose and need)); (2) the factors related to practicability presented in the
attached letter from HDR (on behalf of the applicant) to the North Carolina Department of
Environmental Quality ("DEQ") (Attachment 2); and (3) a capacity reduction would also prevent the
project from satisfying the North Carolina General Assembly's goals and requirements for the project,
including goals related to employment and economic benefits.
Phasing
The USACE made the following comment:
Phasing- the recent announcement of Toyota's selection of the GRMS site indicated
that the project would have several phases. As requested in the November 8, 2021
meeting at the District Office, please provide additional specific information regarding
the construction phases of the proposed facility and specific construction timelines for
the components of the proposed facility.
The plan is for construction of the facility to be continuous. The "phases" identified by the State of
North Carolina and Toyota are points or dates during facility construction at which success criteria
will be achieved, for example, the point at which a minimum number of workers will be employed.
Dodson's Lake dam
The USACE made the following comment:
Additional information regarding avoidance/minimization related to Dodson's Lake.
During recent conversation with GRMS consultants, the potential re -construction of
the Dodson's Lake dam was mentioned as one reason for the selection of the
applicant's preferred alternative. Please provide a written response regarding dam
integrity in relation to the selected on site alternative and any correspondences from
the State of North Carolina resource agencies regarding this issue.
Public comments have identified Dodson's Lake as an important local aquatic resource. The
applicant's proposal avoids and minimizes impacts to waters and wetlands, including avoidance of
impacts to Dodson's Lake. In contrast, on -site alternatives are considered that would require (among
other things) the placement of fill in Dodson's Lake (Alternatives 2 and 3) which would be expected to
trigger subsequent effects and actions that would cause the loss of wetlands adjacent to the lake.
Based on our experience: placing fill in the lake would reduce the storage volume of Dodson's Lake;
storage reduction would cause water surface elevation increases produced by storm events to be
higher; the higher water surface elevations would trigger requirements to modify the dam to ensure its
structural and operational integrity; the cost of dam modifications or reconstruction would be cost

prohibitive and the dam would be breached instead; and the resulting absence of the lake would allow
the return of upland conditions where wetlands are currently located adjacent to the lake.
The Applicant looks forward to working with the USACE on completing the permitting process and
issuance of the 404 Individual Permit 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
Vi40 4�ldlav-
Vickie Miller, AICP, PWS
Senior Environmental Planner
cc: Jim Melvin, Greensboro Randolph Megasite Foundation
Sue Homewood, DWR
Wendee Smith, S2 Consulting

ATTACHMENT 1
The first paragraph of Section 3.1 (The Applicant's Purpose and Need) of the Greensboro -Randolph
Megasite Section 404 Individual Permit Application Supporting Documentation and Environmental
Report ("Environmental Report") was revised based on USACE comments to read as follows:
Establish an automotive storage battery manufacturing, production, and assembly facility with utilities
(electricity, water, sewer, roads, and rail) that is expected to generate employment and economic
benefits for the Project Region, including roughly 2,000-4,000 mostly skilled and semi -skilled
manufacturing jobs, an increase in the local tax base, and new payroll to circulate within Randolph
County and the City of Greensboro. This was transmitted by email on 11/13/2021 from Wendee Smith
to Jean Gibby and Andy Williams (USACE).
The remainder of Section 3.1 of the Environmental Report was not revised.

ATTACHMENT 2
(HDR Letter of December 29, 2021 to NC DEQ on behalf of the applicant, GRMF)

FN
December 29, 2021
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
North Carolina Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
ATTN: Ms. Sue Homewood and Mr. Andy Williams
SUBJECT: Individual Permit Application Additional Information Request
Greensboro Randolph Megasite and Associated Infrastructure
Randolph County, North Carolina
Ms. Homewood and Mr. Williams:
This letter encloses trade secrets and confidential information that no one may
release or make available to any person other than a USACE employee responsible
for processing the GRMS 404 permit or a DEQ employee responsible for processing
the GRMS water quality certification.
Any page of any enclosure that includes one or more of the following three stamps
must not be released to any third party pursuant to the North Carolina public records
law, FOIA, or otherwise:
• Contains information exempt from disclosure pursuant to Exemption 4 of the FOIA; trade secrets and
commercial or financial information that are customarily considered to be confidential; submitted to the
government for the sole purpose of informing the permit evaluation process; this information shall not
be disclosed without the express authorization of the applicant, Greensboro -Randolph Megasite
Foundation, Inc.
• CONFIDENTIAL BUSINESS INFORMATION/TRADE SECRET/SUBJECT TO G.S. 132-1.2(1)
• CONFIDENTIAL/NOT FOR PUBLIC DISCLOSURE/SUBJECT TO G.S. 132-6(d)
The Greensboro -Randolph Megasite Foundation, Inc. (GRMF) is providing the following
additional information requested by the DWR regarding the individual permit application for
development of the proposed Greensboro -Randolph Megasite, located in northern
Randolph County, North Carolina. Attached you will find responses to comments provided
hdrinc.com 555 Fayetteville Street, Suites 900 & 210, Raleigh, NC 27601-3034
[phone]

in the DWR letter received on November 5, 2021 and DWR email received on December
16, 2021(Attachments A and B). The Jurisdictional Determination, Stormwater Plan, and
Residential Well Sampling Plan files are being provided on OneDrive.
As a follow up to the applicants Oct. 27, 2021 response specifically regarding WRC's
comment to DWR on the state listed mussel and crayfish species, the applicant is providing
the results of the recently completed surveys for the species noted. The report shares
details about the survey and notes that no federal or state threatened or endangered species
were identified on the site. The report is included as Attachment C. With this submission
WRC comments have been addressed.
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
V�rkul aAillat�
Vickie Miller, AICP, PWS
Senior Environmental Planner
cc: Jim Melvin, Greensboro Randolph Megasite Foundation
Wendee Smith, S2 Consulting
Attachments:
A. Response to DWR Letter Received 11/5/2021
B. Response to DWR Email Received 12/16/2021
C. Freshwater Mussel and Burrowing Crayfish Survey Report

•• PROTECTED r411 t5'f• :6
ATTACHMENT A
1. We have requested a supporting narrative that expands upon the broad outline and
process flow description recently provided in order to further document Avoidance and
Minimization forproposed manufacturing facility. The response received on October 20
uses broad speculative language such as "has the capability to manufacture" and
"potential use". Please provide an updated process narrative that is more specific as to
what is occurring on the site.
The Overall Site Plan and Site Flow Narrative provide an overview of the proposed site
layout and use of the site as an automotive vehicle battery manufacturing, production,
and assembly facility with utilities (electricity, water, sewer, roads, rail, and more). The
applicant has minimized and avoided impacts to streams and wetlands by, among other
things, configuring and reducing the facility footprint as much as practicable (i.e., available
and capable of being done after taking into consideration cost, existing technology and
logistics in light of overall project purposes). Some of the practicability factors for the
proposed project include (for example) the size of the facility needed for production
purposes, existing technology, and logistics.
1- A contiguous, flat area with size and layout as shown on the site plan for the facility
and described in the Site Flow Narrative is necessary to accommodate: production
operations; transportation and storage of heavy equipment, materials and product
(including ingress and egress to/from the site and areas/buildings within the site);
employees (including their ingress and egress to/from the site and areas/buildings
Attachment A 1

•• PROTECTED r411 t5'f• :6
within the site); and the orderly, safe, and efficient flow and interaction of production
operations trucks, trains, and employees.
2- The concrete surface areas are necessary to allow for transportation of the heavy
materials needed for the facility. This includes transportation of materials onto the
site for incorporation into manufacturing processes and transportation of product
offsite. It is anticipated that transportation and shipping will occur by both trucking
and rail.
3- The planned location and configuration of buildings was based on, among other
considerations, building requirements for the manufacturing processes (e.g.,
footprint required to accommodate manufacturing machinery and operators; relative
locations of buildings based on the sequence of manufacturing, transportation, and
storage/staging operations, as well as existing railroad and road locations at the site,
which will be used for employee ingress and egress and for transportation of
materials and products. For example:
a. The buildings are located and positioned in accord with the need for a large,
level, contiguous area. The need for a large, level, contiguous area is
reflected in the Site Flow Narrative and Master Site Plan figure, which provide
an abridged description and depiction of the processes and logistics
(including the flow of people and materials) necessary for electric vehicle
battery cell production at the GRMS site.
b. The plan for the facility includes shipment of manufactured product and raw
materials via truck and rail,
c.
This trucking/transportation
requirement, existing roads, and the need for separate employee ingress and
egress due to safety considerations largely dictate the truck (green arrows)
and employee flows (orange arrows) depicted in the site plan and narrative.
d. The production operation flows and sequences (depicted in the site plan and
described in the narrative) are required for an efficient and productive facility
and determine the building and site layout.
Attachment A 2

•• PROTECTED r411 t5'f• :6
2. Based on the response received October 27, please explain this statement: "shared
resources exist in each product line which provide avoidance and minimization as
requested". What shared resources are providing avoidance? What shared resources
result in minimization?
As described in a letter to the agencies on October 15, 2021 the Parts Storage (or BLDG BPTS)
buildings will receive chemicals and rolls of metals for the manufacturing process. The parts
buildings are shared with in order to reduce the number of parts receiving
facilities on the site and minimize the overall site footprint.
3. The parking area is based on 'planned employee capacity." What is the planned
employee capacity? How many parking spaces/area is needed to meet this capacity?
Attachment A 3

•• PROTECTED r411 t5'f• :6
4. It's stated that the rail yard/warehouse area is based on the raw material storage and
product storage. What are the storage area needs as related to the specific materials and
products being stored?
The manufacturing and transportation design parameters and logistics dictate warehouse storage
area and rail yard capacities, location and configuration as illustrated.
5. Please explain this statement that was included in the October 27 information submittal:
"It is not possible to have different pads on the site due to the manufacturing process and
logistics through the site." What specifically about the manufacturing process and
logistics requires a contagious [sic] pad?
A contiguous, level pad is needed to convey parts, materials, and product(s) between and among
the buildings and warehouses and truck and rail shipping yards depicted on the Site Plan in order
to safely and efficiently carry out the planned manufacturing operations. Without a contiguous
pad, logistics and parts, materials, and products delivery and shipping patterns would be limited
and impacted, such that the applicant would not be able to carry out the manufacturing and
shipping operations in a safe and efficient manner.
Each set of buildings must be level. For instance, on the Site Plan, Building A, Parts Storage,
Building B and Building C must all be at the same elevation for the process to flow from building
to building and to take advantage of the single parts storage to be shared with each manufacturing
building. Significant grade changes would create safety and logistical concerns for movement of
employees, materials, and products. Elevation changes must also be at grades that are
considered safe and accessible.
This ensures that through
parking lots or other areas that employees can maneuver safely including those covered by the
Americans with Disabilities Act. It also ensures adequate sight distances (lengths of
passageways ahead that are visible to a driver), etc.
6. In the October 27 information submittal you stated: "there may be potential to take these
elements off the pad and potentially reduce the impact to the channel at this location" in
regards to a proposed solar farm and wastewater pre-treatment facility. Your response
indicates that the removal of these items may be feasible and result in impact avoidance.
Please clarify if thesecomponents are being removed from the pad and update exhibits
and impact maps accordingly. If the components are not being removed from the pad
please explain why.
These items are being removed from the pad. Updated exhibits and revised impact information
will be provided under separate cover.
Attachment A
4

•• PROTECTED r411 t5'f• :6
7. Please explain the statement in your October 27t response: "Parking decks would inhibit
movement through the site as required by the end user'. What specifically about a parking
deck will inhibit movement and contradict the end users requirements?
The end user's requirements include safe and efficient ingress and egress of hundreds of workers
and visitors to the site each day. A parking deck inhibits movement through the site by creating
bottlenecks during ingress and egress. These bottlenecks create safety concerns with visibility
and stop/go conditions. Parking decks also produce safety problems by introducing conflict points
between pedestrians and vehicles due to numerous blind spots and tight corners.
8. Based on your statement, "Parking decks are cost prohibitive," please provide justification
or cost analysis that eliminates a parking deck option due to cost. The component cost
as a percentage of overall project cost is a common metric used to determine cost
prohibition.
The average cost to build a parking deck is $25,700 .er space in 2021 see the included reference
material and .ustification of construction cost).
This indicates that the average construction cost of parking decks onsite
would be approximately dollars. Note that one deck on site would not be sufficient
and it would require multiple decks across the site which could drive the cost up from the estimate,
and increase other site development costs. The referenced document also had prices that are
more regional. The nearest location to the GRMS is Charlotte with a cost er space of $22,359.
The more regional estimate indicates a cost of approximately However, aside from
the financial infeasibility of this option, it does not meet the safety and efficiency of ingress and
egress of workers.
24. As communicated previously, the Division will need confirmation from USACE for all
isolated features in order to confirm they are subject to 15A NCAC 02H .1300. Please
provide total impacts to all non jurisdictional features evaluated under 15A NCAC 02H
.1300 to determine any permitting requirements in accordance with 02H .1301. In the
information provided, you have shown one wetland "WD" at 0.018 acre as a non -
jurisdictional feature and an isolated surface water pond "PB". Please update your
October 27th response to include this feature.
The USACE has provided the Jurisdictional Determination for the project and it is provided in
OneDrive for review. Pond B is a non jurisdictional pond that totals 1.06 acres of surface water.
This pond was created by the previous property owner. The pond was shown as an impact due
to the potential for a stormwater basin at this location; however, the stormwater basin has been
relocated to avoid impacts to Pond B and HDR WD.
25. In the October 27th information submittal you stated "The original avoidance and
minimization underestimated the impacts of the two options that impacted Dodson's
Lake". You also stated "Similar to other projects which impact a lake, the entire lake is
taken." Please explain why the entire lake must be lost if partially impacted. DWR is not
aware of any "similar projects" that result in a total loss of a lake or pond aside from
projects that intentionally impact dams. Please update the avoidance and minimization
analysis as needed.
Attachment A 5

•• PROTECTED r411 t5'f• :6
Public comments have identified Dodson's Lake as an important local aquatic resource. The
applicant's proposal avoids and minimizes impacts, including avoidance of impacts to Dodson's
Lake. In contrast, on -site alternatives are considered that would require (among other things) the
placement of fill in Dodson's Lake (Alternatives 2 and 3) which would be expected to trigger
subsequent effects and actions that would cause the loss of wetlands adjacent to the lake. Based
on our experience: placing fill in the lake would reduce the storage volume of Dodson's Lake;
storage reduction would cause water surface elevation increases produced by storm events to be
higher; the higher water surface elevations would trigger requirements to modify the dam to ensure
its structural and operational integrity; the cost of dam modifications or reconstruction would be
cost prohibitive and the dam would be breached instead; and the resulting absence of the lake
would allow the return of upland conditions where wetlands are currently located adjacent to the
lake.
32. Please indicate whether the potential manufacturer intends to operate the entire facility
as shown on the proposed site plans at one time or plans to phase in operations.
Facility operations (manufacturing/production operations; transportation and storage of heavy
equipment, materials and product (including ingress and egress to/from the site and
areas/buildings within the site); ingress and egress of employees to/from the site and
areas/buildings within the site); and the orderly, safe, and efficient flow and interaction of production
operations trucks, trains, and employees) will begin while the construction of the facility is
underway. The facility will reach full capacity at buildout (see Site Plan). There will be no phases
of construction of the contiguous pad - site grading and construction of the pad will be continuous.
Full grading of the pad area is necessary prior to constructing buildings and initiating manufacturing
operations in order for manufacturing operations to continue and remain ongoing during
construction of additional buildings to full build out.
33. If the US Army Corps of Engineers determines that the current project warrants an
updated public notice, the Division will not able to finalize it's review until the public
comment period has concluded and all comments have been evaluated. Additional
information may be required upon review of any public comments received.
We understand DWR's position and the USACE reissued the Public Notice on November 19, 2021.
The public notice comment deadline was December 6, 2021. The DWRs comment deadline was
December 10, 2021.
34. Note that the project includes NCDOT transportation infrastructure improvements. The
application includes conceptual plans for the proposed improvements. Please provide a
very detailed description of the overall project dependency on the transportation
infrastructure improvements and the proposed schedules for construction activities of the
various portions ofthe proposed project.
The interchanges need to be in place before manufacturing operations begin. The interchanges
are necessary to safely move trucks carrying materials and product as well as employees into
and out of the manufacturing facility. The timing for these proposed improvements is noted in the
table below:
Attachment A 6

•• PROTECTED r411 t5'46
TRANSPORTATION
IMPROVEMENTS
APPROXIMATE TIME
FRAME OF
DEVELOPMENT
Northern interchange
June 2022 - Dec 2023
Southern interchange
Dec 2022 - Dec 2024
Attachment A 7

Howl%\
rl
University of Iowa Hospitals and Clinics Underground Parking Ramp I Iowa City, IA
PARKING STRUCTURE COST OUTLOOK FOR 2021
Rob McConnell, PE, Vice President, WGI
Raymond Smith, PE, Vice President, WGI
WGI specializes in parking structure planning and design, and for
more than 40 years, we maintained a database of construction
costs from hundreds of parking facilities of varying sizes and scopes
throughout the country. Since 2003, publishing our annual parking
structure construction cost report provides an important planning
tool for owners, contractors, and design teams.
The disruptions from COVID-19 during 2020-21 created industry-
wide uncertainty and challenges for predicting construction costs.
Using the best industry sources as a guide, we analyzed the data and
prepared our parking structure outlook for the year. For this forecast,
we only omit the cost of parking structures that are completely or
significantly below grade since their cost is much higher. The cost
data is assigned factors based on the time of bidding and location
of the parking structure. The time factor is based on the Building
Cost Index (BCI), published by Engineering News -Record (ENR).
The location factor is taken from the yearly edition of the RS Means
Building Construction Cost Data. Applying these two factors to
actual construction cost data adjusts the cost to a current national
basis, and from that we determine the national median. The national
median can then be re -adjusted to reflect a median construction
cost in almost every city in the United States.
As of August 2021, our statistical data indicates that the median
construction cost for a new parking structure is $25,700 per space, or
$76.70 per square foot; a 15.8% increase from 2020 when the median
cost was $22,200 per space. The table on the following page lists
the 2021 median parking structure construction costs in various U.S.
cities with the lowest cost in Jacksonville, the highest in New York,
and Detroit at the national median index of 100.0.
Please note that the construction cost data does not include costs
for items such as land acquisition, architectural and engineering fees,
environmental evaluations, materials testing, special inspections,
geotechnical borings and recommendations, financing, insurance,
owner administrative and legal, or other project soft costs. Soft costs
are typically about 20% of construction costs but can be higher for
owners who allocate their internal costs directly to the project.
Four -level, 326-space, CIP PT parking structure. This garage was designed for future
expansion and included glass -enclosed stair towers for optimal passive security. The
parking facility provides crucial additional parking for the VA Siera Nevada, Reno, NV
campus.
Ideas for parking. SOLUTIONS FOR OEOPLE
Offices Nationwide 1800.394.7275 I WGInc.com

FOR COMPARISON, A MEDIAN -COST PARKING STRUCTURE TODAY TYPICALLY INCLUDES:
• 8'-6" to 8'-9" wide parking spaces
• Precast concrete superstructure
• Precast concrete facade with a single integral color and basic
reveal pattern or basic thinset brick
• One or two elevators and stairs open to the interior, and clad
with exterior glass curtain wall
• Standard wayfinding and signage
• Shallow -spread footing foundations
• All above -grade construction
• Open parking structure with natural ventilation; without
mechanical ventilation or fire sprinklers
• Minimal or no grade -level commercial space
• Standard parking access and revenue -control system
• Standard energy efficient LED lighting
OVERALL PARKING STRUCTURE CONSTRUCTION COST WOULD BE HIGHER THAN THE MEDIAN IF IT
INCLUDES THESE ENHANCED FEATURES
• 9'-0" wide parking spaces or larger
for improved user comfort
• Cast -in -place post -tensioned
concrete superstructure for
lower maintenance costs
• Architectural facade with
adorned precast, brick,
metal panels, and other
materials
• Stormwater management
including on -site retention/
detention
• Deep foundations such as caissons
or piles
• Below -grade construction
• Enclosed stair towers due to local code requirements
• Enclosed parking structure without natural ventilation where
mechanical ventilation, fire sprinklers, and fire -rated stair shafts
are required
• Flexibility for future parking/building expansion, or incorporation
of roof -level photovoltaic ("solar") panels
• Service life in northern/
coastal regions beyond a
standard 50 to 60 years
• Grade -level commercial
space
• Mixed -use development
where the parking is
integrated with office, retail,
residential, or other uses
• Custom wayfinding and signage system
• ParkSmart® Certification following the Green Business
Certification, Inc. (GBCI) program
• Energy efficient LED lighting with occupancy and photocell
computer -control system
• Electric vehicle charging stations
• Enhanced parking technology
• License -plate recognition
• Parking -guidance system
• Car -count system with variable -message LED signs
• WiFi and cellular services
• Solar -energy collection
• Building Management System
PARKING
GARAGE
ACCFSS
Building Management Systems are
often used to help manage technology.
2021
CONSTRUCTION
COST
15.8%
FROM 2020
Urn( II
Cost/Space Cost/SF
Albuquerque
87.1
$22,385
$66.81
Atlanta
89.2
$22,924
$68.42
Birmingham
86.4
$22,205
$66.27
Boston
114.3
$29,375
$87.67
Charlotte
87.0
$22,359
$66.73
Chicago
119.5
$30,712
$91.66
Cincinnati
89.9
$23,104
$68.96
Cleveland
96.0
$24,672
$73.64
Denver
91.5
$23,516
$70.18
Dallas
86.0
$22,102
$65.97
Detroit -Median
$25,700
$76.70
Houston
86.6
$22,256
$66.43
Indianapolis
92.3
$23,721
$70.80
Jacksonville - Lowest
84.0
$21,588
$64.43
Kansas City, MO
99.3
$25,520
$76.17
Las Vegas
105.4
$27088
$80.85
Los Angeles
118.8
$30,532
$91.12
Miami
85.1
$21,871
$65.28
Minneapolis
107.0
$27499
$82.07
Nashville
89.0
$22,873
$68.27
New Orleans
85.0
$21,845
$65.20
New York - Highest
132.2
$33,975
$101.40
Oklahoma City
84.8
$21,794
$65.05
Philadelphia
115.8
$29,761
$88.82
Phoenix
87.0
$22,359
$66.73
Pittsburgh
100.7
$25,880
$77.24
Portland, OR
103.2
$26,522
$79.16
Richmond
88.8
$22,822
$68.11
St. Louis
100.6
$25,854
$77.16
Salt Lake City
90.5
$23,259
$69.42
San Diego
109.4
$28,116
$83.91
San Francisco
129.8
$33,359
$99.56
Seattle
106.7
$27,422
$81.84
Tampa
84.8
$21,794
$65.05
Washington, D.C.
95.5
$24,544
$73.25
National Median
100
$25,700
576.70
Ideas for parking. SOLUTIONS FOR OEOPLE®
Offices Nationwide 1800.394.7275 I WGInc.com

PARKING INDUSTRY 2021 CONSTRUCTION ECONOMIC FORECAST
Four -level, 399-space, precast parking structure. This garage is located off the historic
courthouse square in the City of Oxford, MS. This garage offers convenient parking
for visitors and employees of local businesses, especially during Ole Miss fall football
season and Double Decker Festival in the Spring.
Construction in the United States saw unprecedented challenges
in 2021 as we emerge from the COVID-19 pandemic. Material and
labor shortages are the new normal, resulting in cost increases for
both design and construction. Challenges in the construction market
prior to the pandemic were headlined by skilled and unskilled labor
shortages in the construction trades, tariffs, and international trade
relationships. Today, those challenges still exist, are more pronounced,
and are now joined by material production, manufacturing, and
shipping bottlenecks and the ongoing and often intermittent
government restrictions intended to curb the spread of COVID-19.
Turner Construction reported price spikes in material costs for lumber,
steel, copper, aluminum, PVC, and gypsum although — heading into
Q3 — raw material costs appear to be returning to earth.
The global pandemic certainly impacted every asset class in some
manner. Urban core office buildings, hotels, education, and the retail
sector were all negatively impacted by a decrease in new project
starts. Richard Branch, chief economist for Dodge Data & Analytics
("Dodge") told ENR that, "the dollar value of hotel construction starts
fell 46% in 2020, to $9.7 billion... in 2021 Dodge forecasts an additional
7% decline:'' Meanwhile, healthcare, industrial/warehouse, and
residential construction all saw increases in activity. After falling 26%
in 2020, overall forecasts for commercial construction are mixed, with
a consensus that office and hotel construction will remain depressed
while other types of commercial buildings will show modest increases
over last year. Dodge posits that parking structure starts will increase
by 4% during the year, possibly linked to the forecast growth of retail,
healthcare, and transportation buildings.
This past March 2021, President Biden signed into law the
American Rescue Plan Act (ARPA). Passage of ARPA
promoted communities around the country
to start developing strategies for how
to win and spend American
Rescue Plan Act (ARPA) funding. ARPA provided $350 billion for state,
local, territorial, and tribal governments to address COVID-19-related
economic impacts. Building infrastructure is notably eligible for ARPA
funding, specifically including construction or enhancement to medical
and educational facilities. The Congressional Budget Office projects
real GDP growth of 6.7%, but coupled with that, many economic
models show inflation of more than 2.5% persisting through 2023.
On the horizon, in the Fall of 2021, are two potential infrastructure
bills currently making their way through Congress; potentially
totaling over $4.5 trillion in broadly classified infrastructure spending.
Should one or both infrastructure bills become law, we would
anticipate an increase in construction costs and labor challenges for
construction markets.
Finally, construction starts and spending will be uneven across the
country. Speaking to ENR, Jay Bowman of FMI Corp. suggested, we
believe correctly, that, "geography will be a defining characteristic
of the post -pandemic recovery. Although this always has influence
on how recessions and expansions are experienced, it will be much
more pronounced [this time]:'' Geographic differences due to different
political policies, that were and continue to be adopted at state and
local levels to curb COVID-19 infections, are a significant factor in the
recovery of local construction markets.
COST DRIVERS:
Features That Impact
the Cost of a
Parking Structure
0
/xi
• Cast -in -Place Concrete Construction
• Increased Building Area/Car
• Below -Grade Construction
• Architectural Enhancements
• Deep Foundation System
• Northern Climate Durability Features
• Enhanced Technology
• Sophisticated Parking Management System
• Integration of Solar Panels
• Enhanced Snow and Ice Management System
• EV Charging Stations
• LED Lighting System Premiums - Motion Sensors/Dimming
• Unique Site Conditions
• Stormwater Management
• Forestry Management
• Enclosed Floors/Mechanical Ventilation and Fire Sprinklers
• Bicycle Housing
• Custom Wayfinding
• Flexibility for Future Parking or Building Expansion
• Pedestrian Bridge
• Integration of Mixed Uses
• Enhanced Landscaping / Hardscape
COST
INCREASE
MEDIAN FEATURES
• Pretopped Precast Concrete
• Single Supported Level
• Decreased Building Area/Car
• Eliminate Parking Access Control
• Plain Precast Facade
• Eliminate Glass -Backed Elevators
• Eliminate Exterior Glass Stair Enclosure
• Reduced Durability Features (Regional)
• Eliminate Enclosed Stairs (Regional)
• Asphalt Paving at Grade
• Eliminate Grade -Level Barrier Wall
. •f
COST
DECREASE
REASE
FEATURES
iiir
Ideas for parking. SOLUTIONS FOR OEOPLE®
Offices Nationwide 1800.394.7275 I WGInc.com

SUMMARY REFERENCES
What does this mean for the new parking structure construction
and the median construction cost for these facilities in 2021 and
near term? The short answer is costs are going up. We believe that
nearly all local markets will see an increase in the construction cost of
parking facilities over 2020, primarily due to the increase in the cost of
manufactured goods and the increasingly acute skilled and unskilled
labor shortages, more so than due to an increase in overall demand.
Meanwhile, above -average demand will play a significant factor in
markets that experienced greater post -pandemic population growth
than the already -expected net population growth, and construction will
be necessary to accommodate that growth. As previously mentioned,
WGI's cost model shows a construction cost increase of 15.8% over
last year, but most economic indicators suggest that this trend will not
continue at this pace but is expected to increase at a more normal 3%
to 5% through 2022 and 2023.
The parking professionals at WGI are happy to assist with the
planning and budgeting of your next parking structure. If you have
any questions or would like specific cost information for your
area, contact Raymond Smith at [e-mail]
and Rob McConnell at [e-mail]. Or call us
at 800.FYI.PARK (800.394.7275).
As a multidisciplinary solutions -providing consulting firm, WGI has
20 offices in seven states, serving an active client base in 30 states,
specializing in the following disciplines: parking facility design and
engineering, building restoration and structural engineering, mobility
planning, transportation engineering, land development/municipal
engineering, traffic and transportation engineering, geospatial and
land surveying, subsurface utility engineering, landscape architecture,
environmental sciences and water resources, architecture, land
planning, and MEP engineering. In 2021, ENR ranked WGI #175 — up
12 places — on its list of the Top 500 Design Firms, while at the same
time naming WGI its 2021 Design Firm of the Year in the southeast
United States.
!,31
1.
After a Rocky Year, PCA Forecasts Slight Growth in Cement
Demand in 2021;' Engineering News -Record, February 3, 2021.
https://www.enrcom/articles/51142-after-a-rocky year-pca-
forecasts-sligh t-gro wth-in-cemen t-demand-in-2021
2. AIA Consensus Construction Forecast, July 2021, American Institute
of Architects. http://info.aiaorg/aiarchitect/2021/charts/Jul%20
2021/ccf 071621.html
3. "Reading Between the Trendlines'; William Richards, American
Institute of Architects, June 2021. https://www.aiaorg/
articles/6345080-read ing-between-the-trend-lines
4. Architecture Billing Index (ABI), American Institute of Architects , July
2021. https://www.aia.org/pages/6425639-abijuly-2021-business-
conditions-remain-s
5. Dodge Construction Outlook 2021, Dodge Data & Analytics,
November 2020. https://www.construction.com/news/dodge-data-
analytics-expects-construction-starts-recover-2021
6. Turner Construction Company. "Turner Cost Index - Turner's Second
Quarter Building Cost Index'; Turner Construction Company, July
2021. http://www.turnerconstruction.com/cost-index
7 "2021 Construction Forecast: A Slow Road to Recovery;' Engineering
News -Record, November 18, 2020. https://www.enrcom/
articles/50766-construction-forecast-a-slow-road-to-recovery
8. "2021 Expected to be Another Down Year for Nonresidential
Building;' Kermit Baker, American Institute of Architects, January
2021. https://www.aia.org/articles/6364941-2021-expected-to-be-
another-down-year-for-
9. The American Rescue Plan Act of 2021 (ARPA), Congressional
Research Service, March 16, 2021. https://crsreports.congress.gov/
prod uc t/pd f/R/R46680
10. "Higher Inflation is Here to Stay for Years, Economists Forecast'
Gwynn Guilford and Anthony DeBarros, Wall Street Journal, July 11,
2021. https://www.wsj.com/articles/higher-inflation-is-here-to-stay-
for-years-economists-forecast-11626008400
11. An Update to the Budget and Economic Outlook: 2021 to 2031','
Congressional Budget Office, July 2021, https://www.cbo.gov/
publication/57339# idTextAnchor006
For more information about this study or to have a
conversation with one of our experts, please contact us:
Rob McConnell, PE
VP Market Leader
Structures + Parking
[e-mail]
Raymond Smith, PE
VP Market Leader
Structures + Parking
[e-mail]
WGIm
TOMORROW'S INFRASTRUCTURE SOLUTIONS, TODAY
Offices Nationwide 1800.394.7275 I WGInc.com

•• PROTECTED r411 t5'f• :6
ATTACHMENT B
• The US Fish and Wildlife Service has requested that the GRMF utilize innovative
stormwater designs and other BMP's to reduce impacts to downstream waters and
habitat during all phases of the project and to maintain buffers on all remaining
streams. Please address this request.
BMPs will be used during and post construction to avoid impacts to downstream waters
and habitat. The applicant has been working with DEQ staff reviewing erosion control
plans and will continue that process for construction as well as finalizing the stormwater
management plan with the state for the site during and post construction.
There are 50-foot riparian buffers on streams within Water Supply Watershed Class III
(WS-III) that are applicable to the site. However, to offset mitigation requirements, the
applicant would be willing to discuss adding 100-foot buffers to streams within the
property boundary which are not impacted by the development footprint or utilities. This
has been discussed with the Corps and DWR in the past and the applicant would be
willing to engage in these conversations again.
• The reconfiguration of Wet Pond B2 appears to partially resolve the Division's concerns
regarding potential indirect impacts to Stream Si. Please provide a plan sheet that
shows the location of the edge of fill impact and the location of the proposed outlet of
Wet Pond B2 at a sufficient scale to clearly determine the length of stream channel S1
between the two points so that we may further evaluation the potential impacts on this
channel.
Attachment B 1

•• PROTECTED r411 t5'f• :6
An additional plan view of Wet Pond B2 was added to Appendix E. Due to file size, the
revised Stormwater Plan is being provided on OneDrive.
• Studies and modeling conducted by the Division indicate that watershed size cannot be
used as a predictor of the presence or absence of a stream, therefore the assumption
that a certain watershed size will continue to provide hydrology to these streams does
not satisfy the Division's concerns. You have indicated that underdrain systems will be
installed "in the existing stream channel and will remain in place and provide additional
hydrology to streams S17 and S18", however streams 17 and 18 begin below the footprint
of the construction pad, therefore the Division is not confident that providing underdrains
in these locations will be sufficient to support existing uses in downstream waters. The
Division continues to have concerns that since many piedmont headwater streams are
fed by interflow and shallow groundwater as a result of infiltration from surface flow and
since a significant portion of these watersheds will be redirected away from these
features there is likely to be indirect impacts from reduced hydrology in these
channels. Please provide a detailed hydrology analysis and/or model to document the
downstream waters will be maintained or provide a monitoring plan that establishes
baseline conditions and a specific monitoring protocol to document hydrology in these
channels and adjacent wetlands for a minimum of 3 years post construction.
The statement above appears to be concerned with continuing to support existing uses
in downstream waters. These channels, although determined perennial by the agencies,
have times when they are dry and lack flow as illustrated in the attached photos taken
December 21, 2021 of both S17 and S18 reaches. The Stream Assessment Method
(SAM) form for S17 had an overall medium score due to low hydrology, medium water
quality, and medium habitat. The medium habitat score was due to a high score for
stream -side habitat. S18 had an overall low score with a medium hydrology score, low
water quality score, and a low habitat score.
S17 was noted as having weak macrobenthos, crayfish, and fish (near the lake), and
absent for amphibians, algae, and mollusks. S18 was noted as having weak crayfish,
amphibians, and algae and absent for macrobenthos, fish, and mollusks. The streams
should continue to support the aquatic fauna they currently support following construction
with a similar flow regime as they currently have. In addition, both of these channels have
existing riparian buffers which will remain and continue to provide stream side habitat
which led to higher scores for those items on the SAM forms.
The invert elevations of Stream 17 and Stream 18 (S17 and S18) are much deeper than
our deepest cut elevations so the temporary and permanent dewatering will have no
effect on S17 and S18 since we are only dewatering to a few feet below the proposed
pad elevation. The headwaters of any existing streams on -site in a fill area will be filled
with open graded stone to allow any groundwater to continue to flow until it daylights at
the edge of the fill slope from the pad.
In addition, we have reduced impacts to S17 as we continue to look for avoidance and
minimization opportunities. S17 is no longer impacted by the pad footprint although it will
still have a road crossing into the site. Please see the attached graphic illustrating the
minimization of impacts to S17. The pad has also been edited slightly near S18 and the
pad is now approximately 275 feet north of the stream invert of S18.
Attachment B 2

•• PROTECTED r411 t5'f• :6
• It appears that Wet Pond C2 has been reconfigured so that it impacts a pond that as
shown as Isolated on the jurisdictional map previously provided to the Division. As
indicated in Item 24 of the November 5th Request for Additional Information, please
provide confirmation of all Isolated features from the USACE and provide total impacts
to all isolated features evaluated pursuant to 15A NCAC 2H .1300
An Approved Jurisdictional Determination (AJD) was complete and provided to the
applicant on December 20, 2021. Wet Pond C2 has been reconfigured to avoid impacts
to Pond B and HDR WD. The Corps has noted these as non -jurisdictional features in the
provided AJD on OneDrive.
Wet Pond C2 was relocated and is upstream of the existing pond and wetlands. During
final design the outlet structure will divert some flow to the pond to supplement the natural
hydrology through the pond. The revised Stormwater Plan is being provided on
OneDrive.
• Pond IDs are confusingly referenced throughout the document due to the change in the
design, however, the document should be revised for its accuracy and consistency. Some
examples of these discrepancies are:
Wet pond A is referred to as pond A 1 but sometimes as pond A3 in the narratives,
calculations, and forms.
- Drainage area of wet pond A is 278.5 acres under the narrative but 224.6 acres
in the calculations.
- Supplemental EZ form's cover page still lists 4 dry ponds for the project.
- Supplemental EZ form still has the now -removed dry ponds A 1 and A2.
- Supplemental EZ form, drainage areas 6 and 7 are incorrectly identified for ponds
Al and A2 where they should be for dry pond C1 and wet pond C2.
- Dry pond sheet, under item #4, it was indicated that the ponds are not located
away from contaminated soils.
- Dry ponds exhibit on page 70 of the document shows dry ponds being identified
as B2 and C2 where they should be ponds B1 and C1.
Page 6 was modified to reflect the Pond A3 in the narrative to match the calculations,
figures and exhibits and the drainage area was modified to reflect the calculations. The
Stormwater Management Permit Application Form and the Supplemental EZ form has
been updated to reflect the most recent submittal. The dry pond exhibit in Appendix E
has been modified to reflect Pond B1 and Pond C1. The revised Stormwater Plan is
being provided on OneDrive.
• Scour hole calculations for wet pond C2 still used Q 10 (364 cfs) from the previous
version, the new Q 10 is 388 cfs according to the updated HydroCAD.
The scour hole calculation for wet pond C2 was updated to reflect 388 cfs. The revised
Stormwater Plan is being provided on OneDrive.
• Wet pond C2 is moved slightly south and is now located over an existing pond. Please
provide reason for the relocation and whether the existing water feature(s) will be
accounted for as new impact.
Attachment B 3

•• PROTECTED r411 t5'f• :6
The pond was relocated due to a potential solar farm in the previous location. The pond
was located just upstream of the existing pond water surface and wetland. During final
design the outlet structure will divert some flow to the pond to supplement the natural
hydrology through the pond and therefore no additional impacts are warranted. The
revised Stormwater Plan is being provided on OneDrive.
• In a previous response to the Division submitted on October 27, 2021 it was stated that
"If the need to connect to the public water supply is a result of contamination due to
processes on the GRMS, then the manufacturer will be responsible for financing the
connection." The Division has expressed concerns for both surface water contaminants
and yield reduction impacts to adjacent wells Please update the Well Testing and
Resolution Plan to include a statement that the need to connect to a public water supply
may also be a result of well yield reduction due to the GRMS facility, and that in either
case the manufacturer will be responsible for financing the connection. Provide a copy
of the updated plan to the Division.
The Residential Well Testing and Resolution Plan has been updated to include well yield
reduction and is provided on OneDrive.
• The Residential Well Testing Resolution Plan dated 11/02/2021 indicates that wells
proposed for testing are those within 150 feet of the GRMS property line. You indicate
that in most cases this will be well beyond the 500 feet requested based on the location
of the 1000-acre construction pad. However, the application indicates additional
construction activities outside of the "construction pad" limits which include utilities,
roadways and stormwater control measures. The Division reiterates that the Well
Testing Plan should address a 500-foot distance from the site limits/property lines.
The Residential Well Testing and Resolution Plan has been updated to 500 feet beyond
the property line.
• The Division specifically requested documentation of assurance from Randolph County
of the commitments identified in the Residential Well Testing Resolution Plan.
A copy of the relevant letter from the County Manager is on OneDrive with the Residential
Well Testing and Resolution Plan.
Attachment B 4

•• PROTECTED r411 t5'46
Photos of S17 on December 21, 2021
iY: 5 fib/
wr
-101.1
S17 - No flow at pipe outlet.
Attachment B
5

•• PROTECTED r411 t5'46
S17 - No water or flow in channel.
Attachment B 6

•• PROTECTED r411 t5'46
S17 - Headcut with standing water — deeply incised.
Attachment B 7

•• PROTECTED r411 t5'46
S17 - Downstream of headcut — deeply incised.
Attachment B 8

•• PROTECTED r411 t5'46
Photos of S18 on December 21, 2021
S18 - Standing water at pipe outlet but no flow beyond the small scour at the end of the pipe.
Attachment B 9

•• PROTECTED r411 t5'46
S18 - Downstream of the pipe outlet.
Attachment B
10

•• PROTECTED r411 t5'46
S18 - Ponded water downstream.
Attachment B 11

•• PROTECTED r411 t5'46
S 18 - Ponding of water at pipe crossing downstream.
Attachment B 12

•• PROTECTED r411 t5'46
Legend
I Megasite Boundary
nApprox. Pad Area
Perennial Screams
Intermittent Screams
Wetlands
LOpen Water
o Feet 150
godsons Lake
Attachment B
RC�t�Ain-_(CPC�.7=p-1�JIiA.O:iRLurs7Bo C`,Gti:glOE:.
S17 & S18 MAP
13

ATTACHMENT C
Freshwater Mussel and Burrowing Crayfish Survey Report
For
Greensboro Randolph Megasite
Randolph County, North Carolina
Prepared For:
F�2
555 Fayetteville St., Suite 900
Raleigh, North Carolina
Contact Person:
Vickie Miller
Senior Environmental Planner
HDR
[e-mail]
November 19, 2021

Prepared by:
RK5K
8601 Six Forks Road, Forum 1 Suite 700
Raleigh, NC 27615
Contact Person:
Neil Medlin
Manager, Natural Resources
[e-mail]
919-878-9560

Table of Contents
1.0 Introduction 1
2.0 Waters Affected 2
2.1 NPDES Dischargers 2
2.2 303(d) Classification 3
3.0 Target Species 3
3.1 State or Federally Listed Mussels 3
3.2 Greensboro Burrowing Crayfish (Cambarus catagius) 3
3.2.1 Characteristics 3
3.2.2 Distribution and Habitat Requirements 4
4.0 Survey Efforts 4
4.1 Mussel Survey Locations: 4
4.1.1 Stream S21 (Location 1) 4
4.1.2 Stream SQ (Location 2) 5
4.1.3 Stream SE (Location 3) 5
4.1.4 Stream S 1 (Location 4) 5
4.2 Burrowing Crayfish Survey Locations: 5
4.3 Methodology 6
4.3.1 Mussel Survey 6
4.3.2 Burrowing Crayfish Survey 6
5.0 Results 6
5.1 Mussel Survey 6
5.2 Burrowing Crayfish Survey 7
6.0 Discussion/Conclusions 7
7.0 References 9
Appendix A. Figures:
Figure 1: Project Vicinity & Survey Location
Figure 2: NCNHP Element Occurrences
Figure 3: NPDES Dischargers and 303(d) Listed Streams

1.0 Introduction
This evaluation was conducted as part of the environmental studies conducted for the potential
development of a tract of land located in northeast Randolph County typically referred to as the
Greensboro Randolph Megasite (Appendix A, Figure 1). As of November 15, 2021, the U.S.
Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) webpage
listed the Cape Fear Shiner (Notropis mekistocholas) as an Endangered species under the
Endangered Species Act (ESA) that could potentially be affected by activities at the Greensboro
Randolph Megasite (Megasite) location (Table 1). Habitat evaluations and an electrofishing
survey for the Cape Fear Shiner at the Megasite were conducted by RK&K personnel on
September 26, 2017, and summarized in a previous report. The Atlantic Pigtoe (Fusconaia
masoni) was listed as a Threatened species under the ESA on November 16, 2021, and IPaC
listed it as a species that also could be potentially affected by activities at the Megasite location.
The IPaC webpage indicated that there are no critical habitats that overlap with the Megasite
location.
Table 1. Federally protected species that potentially occur within the upper Sandy Creek
watershed.
Scientific Name
Common Name
Federal
Status
Notropis mekistocholas
Cape Fear Shiner
Endangered
Fusconaia masoni
Atlantic Pigtoe
Threatened
This portion of Randolph County potentially harbors three rare freshwater mussel species (i.e.,
Carolina Creekshell (Villosa vaughaniana, NC Endangered), Notched Rainbow (Villosa
constricta, NC Threatened), Eastern Creekshell (Villosa delumbis, NCNHP Significantly Rare)
and the Greensboro Burrowing Crayfish (Cambarus catagius, NC Special Concern) (Table 2).
Therefore, targeted mussel and burrowing crayfish surveys were recommended by the North
Carolina Wildlife Resources Commission (NCWRC). Currently, there are no statutory
requirements to conduct these surveys; however, the potential endpoint owner has
voluntarily elected to proactively address NCWRC comments by having mussel and
burrowing crayfish surveys conducted within the boundaries of the Megasite.
Table 2. North Carolina rare species that occur or potentially occur within the upper Sandy
Creek watershed.
Scientific Name
Common Name
State Status
NCNHP
Designation
Freshwater Mussels
Villosa constricta
Notched Rainbow
Threatened
Threatened
Villosa delumbis
Eastern Creekshell
--
Significantly Rare
Villosa vaughniana
Carolina Creekshell
Endangered
Endangered
Crayfishes
Cambarus catagius
Greensboro Burrowing Crayfish
Special Concern
Special Concern
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 1

A review of the NC Natural Heritage Program (NCNHP) records, last accessed on November 19,
2021, indicated that no element occurrences (EOs) exist for federally or state listed species
within a 5-mile buffer from a point on Stream SQ at the Megasite's southern boundary (Table 3;
Figure 2).
Table 3. NC Natural Heritage Program Element Occurrence records and approximate distance
from Stream SQ at the Megasite's southern boundary (i.e., stream miles (SM)).
Species
EO ID
EO
Status
Waterway
First
Observation
Last
Observation
SM
Eastern Creekshell
29595
Current
Sandy
Creek
May 2002
May 2002
1.9
Notched Rainbow
29482
Current
Sandy
Creek
July 2002
May 2019
7
Carolina Creekshell
25532
Current
Sandy
Creek
July 2002
May 2019
7
Eastern Creekshell
25594
Current
Sandy
Creek
July 2002
May 2019
7
Greensboro
Burrowing Crayfish
1826
Historical
Muddy
Creek
April 1993
April 1993
>30
The Eastern Creekshell EO 29595 is located within the 5-mile buffer. However, the species is
not state listed by the NCWRC but is designated as Significantly Rare (SR) by the NCNHP.
NCNHP is a non -regulatory agency responsible for inventorying and tracking native flora and
fauna in North Carolina. Significantly Rare is a lower level NCNHP designation and is generally
defined as any species that "has been determined by the NCNHP to need monitoring". The
Carolina Creekshell and Notched Rainbow are listed the NCWRC as state Endangered and
Threatened, respectively. The EOs for these two species are both approximately seven stream
miles from the Megasite boundary. The Greensboro Burrowing Crayfish EO is not located
within the 5-mile buffer and there are no known occurrences of the species within the Sandy
Creek watershed.
2.0 Waters Affected
The small streams located within the Megasite boundaries are all in the Cape Fear River Basin
(HUC # 03030003). All of the streams converge to exit the property via one of two streams,
Stream SQ (Dodsons Creek) which flows out of Dodsons Lake, or Stream S21 (Figure 1). From
the Megasite's southern boundary, Stream SQ (Dodsons Creek) flows approximately 0.4 stream
miles downstream to its confluence with Sandy Creek. From the southern site boundary, Stream
S21 flows approximately 1.1 stream miles to its confluence with Sandy Creek.
2.1 NPDES Dischargers
There are no NPDES permitted dischargers in a location that could directly affect streams on the
Megasite (Figure 3).
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 2

2.2 303(d) Classification
None of the streams located on the Megasite are on the North Carolina Department of
Environmental Quality (NCDEQ) - Division of Water Resources 2020 303(d) list of impaired
streams. The streams from the Megasite flow into Sandy Creek. Sandy Creek is on the 2020
303(d) list for exceeding Chlorophyll criteria.
3.0 Target Species
3.1 State or Federally Listed Mussels
Based on current distribution records, two state listed mussel species are known to occur within
the mid to upper Sandy Creek watershed, the Notched Rainbow and Carolina Creekshell. While
the federally listed Atlantic Pigtoe is reported by IPaC as a species that could potentially be
affected by activities in this area, it has not been observed from the Sandy Creek watershed or
the Deep River watershed upstream of Richland Creek confluence (i.e., southern eastern
Randolph County).
The Notched Rainbow and Carolina Creekshell are sexually dimorphic (i.e., males and females
have distinct shell shape) mussels that rarely exceed 50mm in length. Females have a more
broadly rounded posterior slope, which creates the marsupial chamber. In comparison, males
have a slightly pointed posterior slope and exhibit an overall elongate elliptical shell shape.
Characteristics to separate these two species include subtle differences in shell morphology, foot
color, location of green rays, and marsupial band color. Specifically, the Notched Rainbow
usually has a slightly smaller and more robust shell, black to yellowish periostracum with thin
unbroken green rays dispersed throughout most of the shell, white foot, and females have a dark
marsupial band on top of the gills. In comparison, the Carolina Creekshell usually has a slightly
larger and thinner shell, thin unbroken green rays generally restricted to the posterior ridge,
bright orange foot, and females have a white marsupial band on top of the gills.
The maximum age for the Notched Rainbow is approximately 3-14 years and it is presumed that
the Carolina Creekshell has a similar life span. Both are known to be long-term brooding
(bradytictic) species. Notched Rainbow host fish species include the Fantail Darter (Etheostoma
flabellare), and Green Sunfish (Lepomis cyanellus), Pumpkinseed (Lepomis gibbosus), and
Redbreast Sunfish (Lepomis auritus) for the Carolina Creekshell. Both species are typically
collected in areas with moderate current and substrate consisting of clay, silt, sand, and gravel.
3.2 Greensboro Burrowing Crayfish (Cambarus catagius) — NC Special Concern
3.2.1 Characteristics
The Greensboro Burrowing Crayfish is a small, dark brown burrowing crayfish with light tan
flecks that transition to a pinkish -tan ventral coloration. The rostrum and postorbital ridges are
orange and the dorsal surface of chelipeds are greenish to tan with two rows of pale pinkish -
orange to cream tubercles on the mesial margin of the palm. In addition, a green color phase is
occasionally observed, which results the brown base coloration being replaced with dark green
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 3

and orange markings appear to be more conspicuous. The gonopod of first form males (i.e.,
reproductively active form) has a central projection that is slightly curved and set at an angle
greater than 90°, and the mesial projection is bulbous with a tapered point.
Life history information on the Greensboro Burrowing Crayfish is extremely limited due to the
lack of a species -specific life history study. First form males have been collected in February,
April, and June. Males and females typically occupy separate burrows and females share their
burrow with newly hatched crayfish in late spring to early summer. This species is classified as a
primary burrower, which indicates that the species can construct a complex burrow system that
does not typically connect to surface waters. It is not known to construct a burrow chimney and
instead piles burrow spoils near the burrow entrance. The burrow pathway is highly variable and
ranges from a simple, straight down burrow to lateral tunnels with multiple chambers.
3.2.2 Distribution and Habitat Requirements
The Greensboro Burrowing Crayfish is endemic to the piedmont of North Carolina and is known
to occur in Davidson, Guilford, Montgomery, and Randolph counties. Prior collection localities
include portions of the Yadkin -Pee Dee and Cape Fear River basins. Within this range, the
species often occupies urban and rural backyards; however, they are known to occupy areas that
transition into bottomland forests. Burrows are excavated in sand, clay, and sand -clay soil
mixtures. Burrowing sites are typically located within areas that are classified as "usually wet";
however, a drainage feature may or may not be present. Ground water level varies considerably
from site to site and is known to range from 15 cm to >1.2 m at occupied sites.
4.0 Survey Efforts
Mussel and Burrowing Crayfish surveys were conducted by RK&K personnel Neil Medlin
(Permit # 21-ES00030), Tyler Black (Permit # 19-ES00554) and Gordon Marsh on November 3,
2021. Burrowing Crayfish surveys were conducted by RK&K personnel Tyler Black, Gordon
Marsh, and Matt Martin on November 4-5, 2021.
4.1 Mussel Survey Locations:
4.1.1 Stream S21 (Location 1)
The survey location began at the southern boundary of the Megasite and continued upstream for
approximately 300 meters. Stream S21 had a width that varied from 1- 4 meters and depth
ranging from 1 meter in a pool to 0.010 meters in constricted shallow riffles. Average stream
depth was 0.10 meters. The substrate was composed of clay, sand, gravel, cobble, and
occasional boulders. Sand was the dominant substrate type with cobble subdominant. Although
there was very little water flow, the stream had run, riffle, and pool flow regimes and generally
stable banks with some areas of erosion/undercutting. No evidence of beaver activity was noted
in the survey reach. A wide forested buffer was present along the survey location.
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 4

4.1.2 Stream SQ (Location 2)
This survey location extended from the southern boundary of the Megasite along SR 2407
(Starmount Road) upstream to near the Dodsons Lake dam for a total of approximately 200
meters. Stream SQ had a wetted width varying from 2 — 3 meters and a depth ranging from
0.010 — 1 meter. The average depth was 0.10 meters. The substrate consisted of silt, clay, sand,
gravel, and cobble with sand dominant and clay subdominant. The stream banks averaged 1
meter high with some areas of erosion/undercutting. Riffle, run, and pool flow regimes were
noted during the mussel survey. No evidence of beaver activity was observed within the survey
reach. A moderate to wide forested buffer was present along the survey reach.
4.1.3 Stream SE (Location 3)
The Stream SE survey location ran from approximately 25 meters below SR 2408 (Browns
Meadow Road) to approximately 200 meters above the road crossing. Wetted width varied from
1 — 3 meters and depth ranged from 0.10 — 1.5 meters with an average depth of 0.5 meters. The
substrate was composed of silt, clay, sand, gravel, and an area of bedrock. Sand was the
dominant substrate type with silt subdominant. The survey reach had primarily a run flow
regime with few shallow riffles and occasion pools. Beaver dams were present within the survey
reach and created impounded areas upstream of the dams. Slow flowing water was visible at a
shallow riffle at the upper end of the survey reach and some flow was observed going through
the beaver dams. A moderate width forested buffer was present along the survey reach with the
exception of the road crossing.
4.1.4 Stream S1 (Location 4)
Mussel survey Location 4 in Stream S1 was the most narrow (1 — 2 meters wetted width) and the
most shallow (0 01 — 0.1 meters deep) of the mussel survey locations. No visibly flowing water
was observed during the survey. The stable stream banks were approximately 0.25 meters high.
The substrate consisted of silt, clay, sand, and gravel. Sand was the dominant substrate type with
silt subdominant. No evidence of beaver activity was observed at this location.
4.2 Burrowing Crayfish Survey Locations:
Biologists established survey locations within the upper, middle, and lower portions of the
drainages within the study area. A total of eleven burrowing crayfish sites were visited during
the survey. The majority of the survey sites were located within forested upland areas associated
with waterway floodplains, dry to nearly dry drainage features, ponds, or toe of slope seeps. In
contrast, two sites were located within the powerline right of way, which contained mowed grass
and shrub vegetation. Soils within these areas were primarily composed of clay, sand, clay loam,
and sandy loam.
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 5

4.3 Methodology
4.3.1 Mussel Survey
Within the survey reaches for each stream assessed, the areas of appropriate habitat were
searched, concentrating on the stable habitats preferred by mussel species. Visual surveys were
conducted with and without view buckets (bathyscopes) along with tactile methods that were
employed where appropriate. All freshwater bivalves were identified, recorded, and returned to
the substrate. Timed survey efforts (recorded in person -hours) typically provide Catch Per Unit
Effort (CPUE) data for each mussel species.
4.3.2 Burrowing Crayfish Survey
A burrowing crayfish survey was conducted within waterway floodplains, drainage features, and
areas previously identified as wetlands. Biologists visually searched targeted habitats for the
presence of active crayfish burrows. Once identified, burrows were excavated using shovels and
yabby pumps to extract crayfish. Timed survey efforts were recorded in person -hours and all
collected crayfish were temporarily placed in a divided tackle box containing freshwater. All
crayfish were identified, recorded, and released onsite.
5.0 Results
5.1 Mussel Survey
No mussels or mollusk of any species were observed at three of the four survey locations (Table
4). Three mussel species and one clam (the invasive Asian Clam) were observed in Stream SQ
(Location 2). None of the mussel species documented during the survey are currently federally
listed under the ESA or state listed by the NCWRC.
Table 4. Bivalves for Randolph Greensboro Megasite, November 03, 2021, by Mussel Survey
Location (MSLI.
Scientific Name
Common Name
No. of Live (Shell)/Search Time/CPUE
MSL 1
(1 p-h)
MSL 2p
(3.0 p-h)
MSL 3
(1 p-h)
MSL 4
(0.5 p-h)
Freshwater Mussels
Elliptio complanata
Eastern Elliptio
--
268(45)
CPUE=89.33
--
--
Uniomerus carolinianus
Florida Pondhorn
--
3(0)
CPUE=1.0
--
--
Pyganodon cataracta
Eastern Floater
--
1(0)
CPUE=0.33
--
--
Freshwater Clams
Corbicula fluminea
Asian Clam
--
2 (60)
--
--
Total Number of Mussels
--
272
--
--
Total Number of Mussel Species
--
3
--
--
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 6

5.2 Burrowing Crayfish Survey
Three crayfish species were collected during the survey of the Megasite with a total of 29
individuals observed (Table 5). Burrows were observed at 11 sites and crayfish were collected at
10 of 11 sites (i.e., No crayfish were collected from Site 11). No Greensboro Burrowing
Crayfish individuals were observed during the survey. A total of 22.5 person -hours of
excavation time were utilized during the surveys.
Table 5. Burrowing crayfishes on the Megasite, November 3-5, 2021.
Scientific Name
Common Name
No. of Individuals
Survey Site
Cambarus davidi*
Carolina Ladle Crayfish
7
2,
5, 6,
7
Cambarus reduncus
Sickle Crayfish
19
1,
3, 4,
5, 8,
9,
10
Lacunicambarus diogenes
Devil Crawfish
3
10
Total Number of Individuals
29
Total Number of Species
3
Excavation Person -hours
22.5
* Denotes a Significantly Rare species (NC Natural Heritage Program (NCNHP) designation
only, not affording official state protection).
6.0 Discussion/Conclusions
Physical stream substrate components including silt, clay, sand, gravel, and cobble that are
typically associated with native freshwater mussel populations were present at all four of the
mussel survey locations. However, based on observations by RK&K personnel in 2017 and
2021, and repeated observations by HDR personnel over multiple years, many of the streams
within the Megasite boundaries not only cease to have flowing water, but are completely dry for
prolonged periods of time during most years. Dry stream conditions place aquatic species unable
to relocate, such as freshwater mussels, under extreme stress. Even occasional drought
conditions can result in inhospitable instream conditions for freshwater mussels (e.g., Golladay
et al., Haag and Warren) and lead to a reduction in number of species present and reduced
numbers of individuals. No mollusks were detected at the mussel survey locations on Stream
S21 (Location 1), Stream SE (Location 3), or Stream S 1 (Location 4). These three streams have
been observed to experience frequent nonflowing and/or dry periods during the late summer and
fall seasons. These periods of stressful conditions reduce the likelihood of these three streams
supporting any freshwater mussel species.
The exception to the streams having little to no water was Stream SQ (Location 2) below
Dodsons Lake. RK&K personnel observed that this stream segment had visibly flowing water in
2017 and contained visibly flowing water at the time of the November 3, 2021, mussel survey.
Three freshwater mussel species and 272 total individuals were collected during the mussel
survey. None of the species collected during this survey are currently state listed by the
NCWRC or have an NCNHP designation.
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 7

Burrowing crayfish habitat is present throughout the Megasite, including habitat and soils
consistent with that reported for the Greensboro Burrowing Crayfish. Three species of
burrowing crayfish were collected within the boundaries of the property; however, no
Greensboro Burrowing Crayfish individuals were collected during the survey. Burrows within
Site 11 (i.e., only site where crayfish were not collected) were excavated to a depth of
approximately 1.5 meters without observing the water table or crayfish; thus, burrows extended
well below the excavation depth or were abandoned by the crayfish prior to excavation. The
closest known record for Greensboro Burrowing Crayfish is approximately 11.6 air miles north
of the project location (i.e., Alamance Creek watershed). To date, there are no known
occurrences of Greensboro Burrowing Crayfish within the Sandy Creek watershed, which drains
south to the Deep River. Within the Deep River watershed, Greensboro Burrowing Crayfish are
known to occur within the upper portion of the watershed, >30 stream miles from the project
location. Furthermore, the Greensboro Burrowing Crayfish often inhabits lawns within urban
and suburban landscapes, as such, the species appears to be somewhat tolerant of some landuse
disturbance. Based on the survey results and distance to known localities, the likelihood of
Greensboro Burrowing Crayfish occurring on the Megasite is low.
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 8

7.0 References
Eads, C. B., A. E. Bogan, and J. F. Levine. 2006. Status and life -history aspects of Villosa
constricta (Conrad 1838) (Notched Rainbow), in the upper Neuse River basin, North
Carolina. Southeastern Naturalist 5(4):649-660.
Eads, C., and J. Levine. 2007. A Summary of Laboratory and Field Research Related to
Freshwater Mussels: July 2006-June 2007. North Carolina State University College of
Veterinary Medicine Aquatic Epidemiology and Conservation Laboratory, Final Report.
Golladay, S.W., P Gagmon, M. Kearns, J.M. Battle, and D.W. Hicks. 2004. Response of
freshwater mussel assemblages (Bivalvia: Unionidae) to a record drought in the Gulf
Coastal Plain of southwestern Georgia. Journal of the North American Benthological
Society, 23(3):494-506.
Haag, W.R. and M.L. Warren, Jr. 2008. Effects of Severe Drought on Freshwater Mussel
Assemblages. Transactions of the American Fisheries Society, 137:1165-1178.
Hobbs, H.H., Jr., and F.O. Perkins. A New Burrowing Crayfish from North Carolina (Decapoda,
Astacidae). Proceedings of the Biological Society of Washington. 80: 141-146.
Kendig, K. M. 2014. Freshwater Mussels of North Carolina (Atlantic Slope). North Carolina
Department of Transportation, Raleigh, North Carolina.
McGrath, C. 1994. Status Survey for the Greensboro Burrowing Crayfish. The Proceedings of
the Annual Conference of the Southeastern Association of Fish and Wildlife Agencies.
48: 343-349.
North Carolina Department of Environmental Quality - Division of Water Resources. 2020
North Carolina 303(d) List. Available:
https://files. nc. gov/ncdeq/W ater%20Quality/Planning/TMDL/3 03 d/2020/2020-NC-3 03 -
d--List-Final.pdf. (August 2021).
North Carolina Department of Environmental Quality. 2021. NPDES Wastewater Discharge
Permits. Available: https://data-ncdenr.opendata.arcgis.com/datasets/npdes-wastewater-
discharge-permits?geometry=-87.493%2C33.635%2C-72.200%2C36.776. (August
2021).
North Carolina Natural Heritage Program. 2020. List of Rare Animal Species of North Carolina.
Available: https://www.ncnhp.org/media/522/open. (November 2021).
North Carolina Natural Heritage Program. 2021. nheo-2021-10. Natural Heritage Element
Occurrence polygon shapefile. (October 2021).
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 9

North Carolina Wildlife Resources Commission. 2017. Protected Wildlife Species of North
Carolina. Available:
https://www. ncwildlife. org/Portals/0/Conserving/documents/Protected-Wildlife-Species-
of-NC.pdf. (November 2021).
North Carolina Wildlife Resources Commission. 2021. Atlantic Pigtoe Species Profile.
Available: http://www.ncwildlife.org/Learning/Species/Mollusks/Atlantic-Pigtoe. (March
2021).
North Carolina Wildlife Resources Commission. 2021. Greensboro Burrowing Crayfish Species
Profile. Available: https://www.ncwildlife.org/Learning/Species/Crustaceans/Cambarus-
D-catagius. (November 2021).
North Carolina Wildlife Resources Commission. 2021. Unpublished Aquatics Database.
(November 2021).
U.S. Fish and Wildlife Service. 2021. Information for Planning and Consultation (IPaC).
Available: https://ecos.fws.gov/ipac/. (November 2021).
Freshwater Mussel and Burrowing Crayfish Survey Report; HDR, Randolph County
November 2021
Page 10

Appendix A
Figures

4ialt;uv`
'Ahia9terV Dr
Legend
Study Area
Survey Locations
O Burrowing Crayfish
❑ Freshwater Mussel
Bandy Cie plc
4, ,nere v e„
Dods•. is
_ tiiteny
5•
Trn, sFrRt Rd
K,rna:y Ln
State of North Carolina DOTS, Esri, ERE, Garmin, I�R- ENT��PPASDA
Prepared By:
RKK
Prepared For:
EN)
Freshwater Aquatics Survey
Greensboro Randolph
Megasite
RANDOLPH COUNTY
Date:
November 2021
Scale
0 1,500 3,000 US Feet
Job No.
Drawn by:
GSM
Checked by:
KNM
Figure
1

I
Legend
Study Area
5-Mile Buffer
Freshwater Mussels
Element Occurrence
Villosa constricta
Villosa delumbis
�] Villosa vaughaniana
Prepared By:
RKIKK
Prepared Far:
F�2
NC NHP
Element Occurrence
Greensboro Randolph
Megasite
RANDOLPH COUNTY
Date:
November 2021
Vo
Scale
0 1 Miles
Job No.
Drawn
Y
GSM
Checked by'
KNM
Figure

Legend
/ NPDES Sites
Study Area
5-Mile Buffer
303(d) Streams
M�nt�Q�f
C0038164
Prepared By
R4101
Prepared Far:
FEZ
NPDES Dischargers and
303(d) Listed Streams
Greensboro Randolph
Megasite
Date:
November 2021
Scale
0 1 Miles
Joh No.
Figure
RANDOLPH COUNTY
Drawn
Y
GSM
Checked by
KN M