20120270 Ver 4_Mod request 2014 for SAW-2010-01797wNotes_20140313

DIAL CORDY
10 February 2014
Mr. Brad Shaver
Project Manager
USACE Wilmington District
CESAW- RG(1145 -b)
69 Darlington Ave
Wilmington, NC 28403
RE: Modification Request for Action ID SAW -2010- 01797/ Department of the Army Permit
North Carolina DWQ Project # 2012 0270/ Onslow County
New River Marine Corps Air Station, Camp Lejeune, NC 28542 -0004
Dear Mr. Shaver,
Your last official correspondence regarding the above - referenced project (dated 29 November 2012) provided
the applicant with a modification to proposed work. During the permit process we segregated the project
elements into phases, based on construction and planning schedules (Phases I, II, and III), and were ultimately
permitted to impact up to 1.84 acres of wetlands regulated by DA under CWA Section 404 (and an additional
0.014 ac regulated by NCDENR under Section 401). For the Phase III portion only, the applicant was
permitted to permanently fill 0.45 acre (both under Section 404 and 401 regulatory authorities). Those impacts
were to be mitigated via purchase of credits equal to 0.45 acre. These impacts were listed in table format in our
letter to USACE dated 20 November 2012, the relevant portion of which is shown below:
Permitted permanent and emporary impacts November 2012)
Phase
Wetland
impact
Impact
type
Area (ac)
III
Wi -1P
Permanent
0.4300 ac
1a'
t, 1 -11
1 >r � °trfJ`cft`i'
0, 0 i o ac
III
Wi -2P
Permanent
0.0200 ac
r
t 1 %1'
1'clnp frart
0,011 8 ac*
:v1v .ti'
To assist in your review the applicant's plans for Phase III, we stated in our correspondence dated 4 October
2012 the following:
"Perimeter Road near Wetland I (i.e., "i ") is proposed for realignment in accordance with UFC 3 -260-
01 (i.e., 500 feet clear distance +7:1 -foot allowance for a perimeter fence), which results in impacts to
Wetland L Because a future project phase (to be completed between approximately 2014 and 2016) will
extend the western runway /over -run to the southwest (to address the airfield operational design
considerations in the NATOPS Flight Manual for MV -22s and also to fulfill UFC 3- 260 -01 requirement
for 1,000 -ft over -runs on all Navy and Marine Corps runways), the proposed Perimeter Road will need
to be realigned again in a few years to run parallel to the future runway /over -run, heading farther to the
southwest before turning to the northwest around the end of the over - run.... In the interim, the roadway
will be temporarily configured to balance aviation safety and wetland protection; the UFC clear distance
is observed for as much of the roadway as possible, but the corner of Perimeter Road near impacts Wi -1

and Wi -2 (see Figure 8) will not involve a 90- degree turn, but instead a graded turn. The sharper- angle-
turn alternative would have had approximately 100% more impacts to wetlands due to installing the
necessary grading along two road segments that together are longer (and closer to the wetland) than the
proposed single reach. To achieve this reduction of impacts, a temporary exemption from the UFC was
allowed, but just for the turn /corner area. This will allow for at least a temporary preservation of
approximately 0.75 acre of wetland functions for the habitat area that would have been impacted by a
90- degree comer positioned 570 feet from the existing over -run. The combined wetland impacts for
Phase III have been minimized from the original plan by 0.69 acres and further reductions are not
practicable or possible given engineering and aviation /transportation safety concerns."
As a follow -up to the above, we indicated in subsequent correspondence the following from our letter dated 20
November 2012:
"At this point in time, only the conceptual framework for such future work is available, as discussed in
our 4 October 2012 letter. Detailed design and engineering work for that future work is not currently
under contract by the applicant, and that would have to be completed (along with any future permit
modification) to allow for the runway extension to be constructed. In the interim, we continue to support
acquiring permits to construct the re- aligned roadway as specified in our 4 October letter, as that will
provide additional safety as well as minimize wetland impacts."
In November 2013, the applicant was able to complete detailed engineering for the Phase III impact areas
referenced above (the portion indicated as being ready for construction between 2014 and 2016). In
preparation for extension of the over -run for Runway 05/23 (the western runway on the airfield) to the
southwest (necessary pursuant to the NATOPS Flight Manual for MV -22s and also to fulfill UFC 3- 260 -01),
the applicant is now requesting a permit modification to accommodate the re- location of the perimeter road to
the south.
As indicated above, the applicant was able to be granted a temporary exemption from compliance with UFC 3-
260-01 specifically regarding (1) the requirement of 500 feet clear distance (laterally from the centerline of the
runway) in addition to the 7:1 -foot allowance for a perimeter fence and (2) 1,000 feet clear distance (from the
end of the runway to the southwest) for all Navy and Marine Corps runways, and was therefore able to plan for
only a slight impact to Wetland "I" until it was absolutely necessary to be in complete compliance with the
UFC. At this time, it is now necessary to affect full compliance with federal aviation safety regulations.
Avoidance and Minimization. Given the above requirements, the applicant's engineer has repositioned the
comer /vertex of Perimeter Road approximately 200 feet to the south, while continuing to minimize impact to
wetlands the maximum extent practicable. To that effect, the road is proposed for placement as close to the
runway as possible, and sheet pile walls are proposed along the road surface boundary (at /near the comer)
where typical grading would have impacted an additional approximate 6,000 square feet (40 feet wide slope
extending approximately 150 feet along the road) to the south and 9,600 square feet (40 feet wide slope
extending approximately 240 along the road) to the north. The use of the walls will result in minimizing
impacts by 0.46 acre (see related cross - sections on revised Figures 9 and 10). Furthermore, the applicant
proposes to maintain the hydrological connection to wetland habitats in the central portion of the impact area,
just north of the comer. This will prevent impacts to an additional 0.2 -acre wetland area. Therefore, in
summary, the applicant has minimized impacts by approximately 0.66 acre. Where possible, adjacent to
permanent wetland impact areas, the applicant will re -grade and restore certain wetland areas following
construction. These temporary wetland impact areas will recover, to once again perform most wetland
functions.
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Request for Modification of SAW- 2010 - 01797/ 10 February 2014

Alternatives. In addition to the no action alternative, three others could be considered. They include (1)
positioning Perimeter Road to the north, outside of the wetland area, (2) positioning Perimeter Road farther to
the south of the currently proposed alignment, and (3) positioning Perimeter Road as shown in revised Figure 8
(the preferred alternative). Because the no action alternative and alternative "1" above would not result in
compliance with air safety regulation, they should be excluded from further consideration. Alternative "2"
above is not preferred as it would involve additional impacts to wetlands and would prove more costly than the
preferred alternative. Therefore, the currently proposed alignment (alternative "3 ") is the only alternative that
supports the project objectives (safe transit around the air field) and comprises wetland impacts that have been
minimized as much as practicable.
Unavoidable Impacts. Unavoidable impacts due to the relocation of Perimeter Road summarized below, in
comparison to the impacts as previously predicted. Formerly anticipated permanent impacts were 0.45 acre;
currently, the applicant anticipates approximately 1.34 acres of jurisdictional wetland impacts. In addition, the
applicant anticipates that approximately 361 linear feet of intermittent stream /ditch ( "R05" on the federal J.D.)
contained within the limits of the jurisdictional wetland will be temporarily impacted (due to fence
construction on its northeastern bank/top- of- slope); its downstream -most, approximately 70 -foot section will
be relocated into a 48 -inch, round, reinforced, concrete pipe under the proposed road and then daylight to the
historical streambed in the native wetland "WI."
Permitted permanent and temporary jurisdictional impacts for Phase III (November 2012)
Wetland impact
Impact type
Area ac
WI -1P
Permanent
0.4300 ac
WI-IT
Temporary
0.0500 ac
WI -2P
Permanent
0.0200 ac
WI -2T
Temporary
0.0118 ac
Totals: 0.45 permanent and 0.06 acres temporary
Proposed, modified permanent and temporary jurisdictional impacts for Phase III (December 2013)
Wetland impact
Impact type
Area (ac)
WH -1P
Permanent
0.07
WI -1P
Permanent
0.93
WI -1T
Temporary
0.05
WI -2P
Permanent
0.01
WI -3P
Permanent
0.27
WI -3T
Temporary
0.05
WI4P
Permanent
0.06
WI4T
Temporary
0.15
Totals: 1.34 permanent and 0.25 acres temporary
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Request for Modification of SAW- 2010 - 01797/ 10 February 2014

Mitigation. The applicant will provide compensatory mitigation for the above - reference minimal and
necessary wetland impacts. The type and nature of mitigation will comprise that which was previously
provided for other project phases.
We appreciate your efforts on behalf of regulatory compliance for this important project. Should you have any
questions regarding the above, please contact me at (904) 476 -9571 or [e-mail] at your earliest
convenience.
Best Regards,
Jason Evert
Senior Ecologist
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Request for Modification of SAW- 2010 - 01797/ 10 February 2014