20171559 Ver 3_More Info Received_Response to RAI_20210927

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 pdf).
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
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
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HDR Engineering Inc.
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440 S. Church Street, Suite 1000
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704.338.6700
N.C.B.E.L.S. License Number: F-0116
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PROJECT MANAGER VICKIE M. MILLER, AICP, PWS
PROJECT PRINCIPAL PAUL MEEHAN, PE
PROJECT ENGINEER DAVID BAKER, PE
DESIGN ENGINEER
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ISSUE DATE
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PROJECT NUMBER 10068163
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Attachment C

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
TIM BAUMGARTNER
Director
Jim Melvin
Greensboro Randolph Megasite Foundation
324 W. Wendover Ave., Suite 207
Greensboro, NC 27408
NORTH CAROLINA
Environmental quality
June 18, 2021
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 Oualtt-Ns Joe.°
Sincerely,
•
4.7yk_,,o
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