20210773 Ver 1_More Info Received_20220527

Strickland, Bev
From: Michael Brame <[e-mail]>
Sent: Friday, May 27, 2022 2:17 PM
To: [e-mail]
Cc: Hugh Creed Associates Inc, P.A.; Homewood, Sue; David Michaels
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield
Road tract / McLeansville / Guilford County / residential)
Attachments: Flemingfield Reserve PCN 2022-05-27.pdf; 6663.3_Flemingfield_PCN_5.27.2022.pdf
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Good Afternoon David,
The revised PCN Application and exhibits are attached. The sections of the PCN application that have been revised are
the wetland impacts and mitigation sections. The impacts are now below the Nationwide Permit thresholds. The
attached exhibits address/clarify the other comments/items. Please let me know if you need additional information in
order to issue the PCN. Have a good Memorial Day weekend!
Sincerely,
Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, May 27, 2022 6:51 AM
To: David Michaels <[e-mail]>
Cc: Michael Brame <[e-mail]>; Hugh Creed Associates Inc, P.A. <[e-mail]>;
Homewood, Sue <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
Hi Mr. Michaels, and thank you for your email. Based on your responses below it appears that Corps concerns would be
resolved upon receipt of the revisions/items you noted, at which time I should be able to verify the use of the NWP. I
1

look forward to receiving the revised PCN and exhibits, and please let me know if you have any questions in the
meantime. Have a good Memorial Day weekend.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Office: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: David Michaels <[e-mail]>
Sent: Wednesday, May 25, 2022 2:52 PM
To: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Cc: Michael Brame <[e-mail]>; Hugh Creed Associates Inc, P.A. <[e-mail]>;
Homewood, Sue <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Request for Additional Information: SAW-2021-00814
(Flemingfield Road tract / McLeansville / Guilford County / residential)
David,
We are working on modifying the PCN and exhibits as per your comments. Please see my specific responses below in
green and thanks for your consideration of our responses. We look forward to wrapping this permit up very soon.
Yours truly,
David B. Michaels
Manager, Land Acquisition and Development
Windsor Homes
5603 New Garden Village Dr.
Greensboro, NC 27410
M: 336-207-8003
0: 336.282.3535 Ext. 239
From: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Sent: Friday, May 13, 2022 12:25 PM
To: David Michaels <[e-mail]>
Cc: Michael Brame <[e-mail]>; Hugh Creed Associates Inc, P.A. <[e-mail]>;
2

Homewood, Sue <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
CAUTION: EXTERNAL EMAIL
Good morning, Mr. Michaels, and thank you for your 3/30/2022 response to our request for additional information. I
have reviewed the information and included responses below to each item while we hold for additional information,
noted in your 4/5/2022 response to our request for additional information, necessary to confirm compliance with NWP
29 General Condition 18 pursuant to Section 7 of the Endangered Species Act (ESA). Note that the original items in our
request are in italics below. Corps comments/responses in response to the information you submitted on 3/30/2022 are
included below each item in red. Per the below clarification is needed before proceeding with verifying the use of
Nationwide Permit (NWP) 29 (https://saw-reg.usace.army.mil/NWP2021/NWP29.pdf). Please submit the requested
information below (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we may deny verification of
the use of the Nationwide Permit or consider your application withdrawn and close the file:
NWP 29 states that "The discharge must not cause the loss of greater than 1/2-acre of non -tidal waters of the United
States." Although the current proposed wetland loss is below the 0.5 acre threshold in NWP 29, the proposed wetland
loss (21,127 ft2) in combination with the proposed stream loss (770 ft2) equates to 21,897 ft2 (0.503 acre), which
exceeds the impact threshold of NWP 29. You may apply to authorize the proposed impacts via the Individual Permit
process. Or, you may further avoid or minimize proposed impacts to demonstrate that this development would fit
within the NWP 29 impact thresholds. Please notify this office immediately if you propose to pursue an Individual
Permit for this project. We are eliminating the impacts on lots 16 and 17 which should put us under the threshold for
an Individual Permit.
1) NWP 29 General Condition 23(a) requires that the activity be designed and constructed to avoid and minimize
adverse effects, both temporary and permanent, to waters of the US to the maximum extent practicable
(available and capable of being done after taking into consideration cost, existing technology, and logistics in
light of overall project purposes). It is not clear that the design of the proposed development meets this
requirement. Namely:
a. Slate Ridge Trail, including proposed Impacts 1 and 2, is routed to cross Stream SA at a tangent at the
widest portion of Wetland WD, and directly through a disjunct section of Wetland WC 12-58. Additional
avoidance and minimization would be shown by adjusting the route to follow closer to the existing
driveway of the site across Stream SA, and or re -aligning this road to the north of Wetland WC 21-58;
Corps concerns with Slate Ridge Trail through Wetland WD and Stream SA are resolved.
Corps concerns with Slate Ridge Trail through disjunct section of Wetland WC 12-58 are also resolved.
However, note that professional experience with wetlands as well as local experience in this portion of
Guilford County contradict the assertions that this portion of Wetland WC 12-58 are man-made. In fact,
as shown by much of the remainder of the verified wetland delineation which was field -verified with
particular attention to evaluate wetland areas extending well up -gradient, wetlands extending upslope
within topographic drainages are common in this portion of Guilford County. Further, the 1955 aerial
photo, taken prior to the installation of the existing driveway, shows that the farmed area at the time
surrounded but did not encroach into the existing disjunct section of Wetland WC 12-58, a typical
indication that this area would have been too wet to farm. Although it is likely that the existing
driveway has had the effect of ponding water in this area thereby making this portion of the wetland
"wetter", the primary hydrology source for this portion of the wetland is more likely to be shallow
subsurface groundwater flow similar to up -gradient portions of Wetland WE 1-58 on -site. I am an
experienced developer but certainly defer to your expertise and training in identifying wetlands. I was
assuming since the pipe was clogged up it was causing the area to be saturated.
b. Longfield Drive is routed through the upper -most portion of Wetland WE (Impact 5). Retaining walls and
other slope -steepening techniques are often used to eliminate or limit fill slope footprints in wetlands;
Corps concerns with Longfield Drive through Wetland WE are resolved. Thank you.
3

c. Elk Horn Drive, is routed through one of the wider sections of Wetland WE 1-58 (Impact 7). Additional
avoidance and minimization would be shown by adjusting the route to cross this wetland closer to the
existing dirt path crossing to the north, or re -aligning this road to cross this wetland slightly to the south;
Corps concerns with Elk Horn Drive through Wetland WE are resolved. Thank you.
d. Wetland impacts are proposed for Lot fill at Lots 16, 17, 48, 62, and 63 (Impacts 3, 4, 6, and 8). It is not
clear that project viability is dependent on the inclusion of these 5 Lots, when the overall development
proposes 99. Further, retaining walls and other slope -steepening techniques are often used to eliminate
or limit fill slope footprints in wetlands;
Corps concerns with Lot fill at Lots 48, 62, and 63 (Impacts 3, 4, and 6) are resolved due to lower quality
wetlands in the cleared portion of Wetland WE and the very small size of these proposed impacts at the
fringes of a larger wetland system. Thank you.
However, wetland impacts at proposed Lots 16 and 17 (Impact 8) are neither low quality wetlands nor
particularly small when compared to other authorized residential Lot fill impacts in the North Carolina
Piedmont. The portion of Wetland WC proposed for impact for these two lots is a mature forest at the
edge of a geomorphic floodplain within 75 feet of a perennial stream channel, indicating relatively high
function. Although proposed impacts include a relatively small percentage of wetlands on -site, the
requirement in NWP 29 General Condition 23(a) is to avoid and minimize adverse effects to waters of
the US (including wetlands) to the maximum extent practicable. It appears that the relatively small
proportion of proposed wetland impacts to total wetlands on -site is more of a function of the relatively
large amount of wetlands existing on this site than the demonstrated efforts to avoid and minimize.
Give the preceding, please avoid Impact 8 accordingly (e.g. combining lots 16 and 17, steepen fill slopes,
etc.), or provide more specific documentation that such measures are not practicable (i.e. available and
capable of being done after taking into consideration cost, existing technology, and logistics in light of
overall project purposes). We are modifying the grading plan to eliminate the impacts to these wetlands
on lots 16 and 17.
2) Item la above notwithstanding, revisions are required on Sheets 2 and 3 of the plans provided with the PCN:
a. The culvert pipe footprint is not visible on Sheet 2. This information is needed to show the pipe alignment
vs. the location of the stream, the culvert width vs. the width of the stream, etc., to ensure that the
project meets NWP 29 Regional Condition 8.9c;
Corps concerns with this item are resolved. Thank you.
b. Sheet 2 does not clearly indicate the footprint of stream impacts for each of the 110 If of stream impact,
50 If of embedded rip rap, and 10 additional If of temporary impacts;
Corps concerns with this item are resolved. Thank you.
c. Sheet 3 indicates that two 60" culvert pipes are proposed at Impact 1. In order to comply with NWP 29
Regional Condition B.9b, one pipe should act as the low flow pipe (inverts buried 1' below the stream
bed), and the other pipe should act as the high flow culvert (only to receiving bank full flows). High flow
culverts are typically designed by placing its invert at bankfull level, or at least a foot or two above the
existing stream bed. Another way to comply with this condition it to design sills at the inlet and outlet of
the high flow culvert to only allow flow in the high flow culvert at the above referenced flow level;
Corps concerns with this item are resolved. Thank you.
d. The top and bottom of the culvert is not visible on the profile view; this information is needed to ensure
that the culvert meets NWP 29 Regional Condition 8.9 pertaining to culvert burial. Ensure that this
drawing clearly labels the top and bottom of the high and low flow culverts;
Corps concerns with this item are resolved. Thank you.
e. Items la and 2a above notwithstanding, Sheet 2 indicates that the culverts would be oriented such that
the stream exits the culverts aimed directly at the stream bank. Furthermore, the stream alignment
would then run parallel to the proposed fill slope only a few feet to the south for approximately 37 linear
feet. This information indicates that maintaining a functioning stream channel in its current location
under these conditions is extremely unlikely. How would the design minimize the risk of indirect impacts
to this portion of the stream channel? Based on the current proposal the Corps would consider this
portion of stream as an indirect reduction of stream function, potentially calculated cumulatively with
the proposed direct permanent stream impacts when considering compensatory mitigation thresholds,
4

per NWP General Conditions "District Engineers Decision;"
Corps concerns with this item are resolved, with the caveat that a cross-section view of the rip rapped
reach of channel must be provided that clearly shows that the existing channel dimensions will be
maintained, rather than over -widened (i.e. "blown out") to create a wide dissapator pad. Engineer is
working on this revision and will submit.
f. Items la above notwithstanding, the portion of unimpacted Wetland WD between the south side of the
proposed fill slope and Stream SA includes a remanent fringe of wetland too small (-0.016 acre) and
narrow to be expected to retain its previous function. As such, and the fact that grading for the adjacent
direct impact would eliminate any upslope drainage to this area, the Corps would consider the remainder
of the south side of this wetland as a reasonably foreseeable indirect impact. This area would be added
to the required compensatory mitigation amount.
Corps concerns with this item are resolved. Thank you.
3) Please provide zoomed -in details, including a plan and profile view, for Impact 7. Ensure that these details clearly
show the size and number of culvert pipes (placed at -grade rather than buried), head walls, rip rap, etc.
Corps concerns with this item are resolved. Thank you.
4) Items 1 a-c above notwithstanding, how would the project maintain appropriate hydrology to the remainders of
Wetlands WC 21-58 and WE 1-58. The Corps is concerned that upland grading in these areas would re-route
overland flow away from these areas and into downslope stormwater basins. If onsite hydrology is expected to
be maintained via culverts under roadways, swales, or other methods, please include plan detail sheets to
demonstrate. Note that, in addition to compensatory mitigation requirements for direct, the Corps would
consider requiring compensatory mitigation reasonably foreseeable indirect impacts resulting in a loss of
hydrology and therefore aquatic function, per NWP General Conditions "District Engineers Decision;"
Corps concerns with this item are resolved. Thank you.
5) For proposed Impact 9, sanitary sewer crossing of Stream SD and Wetland WC 21-58:
a. Per NWP 29 General Condition 10.c., please provide a plan to restore and re -vegetate wetland areas
within the utility corridor;
Please confirm the following, and add to Sheet 5:
In wetlands, the top 6-12 inches of the trench will be backfilled with topsoil from the trench;
Wetland areas within the sewer corridor shall be seeded with a regionally appropriate wetland seed
mix. No fescue grass or any other species identified as invasive or exotic species by the NC Native Plant
Society (NCNPS, https://ncwildflower.org/invasive-exotic- species -list/) shall be used to re -seed the
sewer corridor through wetlands. We will add these notes to the PCN.
b. Given that the project exceeds the compensatory mitigation ratio for wetland impacts, the Corps will also
require compensatory mitigation for the permanently maintained sewer corridor through forested
wetlands. Compensatory mitigation for permanent conversion of forested to herbaceous wetlands is
typically required at a 1:1 ratio unless otherwise justified based on resource quality (NCWAM/NCSAM).
Corps concerns with this item are resolved. Thank you.
6) We acknowledge the statement in the PCN pertaining to endangered species (Section 7 of the Endangered
Species Act), that "Potential habitat for these species is not located within the proposed project areas." However,
given the general nature of potentially suitable habitat for Schweinitz's sunflower and small whorled pogonia,
the existence of both open and forested areas within the project area, and given recent USFWS concerns
regarding these species, the Corps cannot currently reach a No Effect determination for these species within the
Section 7Action Area based on the information provided. Note that, given the distribution of proposed impacts
throughout the property, the entire proposed Flemingfield Reserve development would be considered the Action
Area for Section 7 purposes. As such:
a. If you do not believe that any suitable habitat exists in the Action area for these species, please provide a
more thorough justification so that the Corps could evaluate the potential for a No Effect determination;
b. If suitable habitat for either of these species does exist in the Action Area, please complete a pedestrian
survey for these species within the appropriate survey window. Following the survey, please provide the
survey report to the Corps (copy also the USFWS) for review;
Please note that, per NWP 29 General Condition 18, the Corps cannot verify the use of a NWP until Section 7
consultation is complete.
5

Per your 4/5/2022 response to our request for additional information, resolution of NWP 29 General Condition
18 pursuant to Section 7 of the ESA is pending, specifically, an "on -site survey will need to be conducted within
these areas during the appropriate survey window as determined by U.S. Fish and Wildlife Service." Pilot
Environmental will assess during the survey window.
7) Items la and c notwithstanding, to demonstrate further avoidance and minimization, would it be possible to
remove the existing driveway crossing of Stream SA or dirt road crossing of Wetland WE 1-58 and stabilize with
appropriate sloping and matting?
Your response is appreciated. At such time as a permit can be issued/verified for this project, a Special Condition
would be added requiring the removal of the existing driveway crossing of Stream SA and dirt road crossing of
Wetland WE 1-58, matching the grades above and below the crossings, and stabilization with appropriate
sloping and matting. We will add this requirement to the plan.
8) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Office: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: David Michaels <[e-mail]>
Sent: Wednesday, March 30, 2022 6:10 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Cc: Michael Brame <[e-mail]>; Hugh Creed Associates Inc, P.A. <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Request for Additional Information: SAW-2021-00814
(Flemingfield Road tract / McLeansville / Guilford County / residential)
David and Sue,
Please find attached our response to your comments as set forth in prior emails dated March 2 and March 4, 2022. Our
response includes:
• Written answers to questions posed by each of you,
• Attached drawings as set forth in the written response.
6

Please advise if you have other questions at this time. There are additional reports forthcoming that will be forwarded
to you as received. Also, please confirm receipt of this response.
Yours truly,
� r N SOR
1ES
David B. Michaels
Manager, Land Acquisition and Development
Windsor Homes
5603 New Garden Village Dr.
Greensboro, NC 27410
M: 336-207-8003
0: 336.282.3535 Ext. 239
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, March 21, 2022 7:49 AM
To: David Michaels <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
CAUTION: EXTERNAL EMAIL
That sounds good, Mr. Michaels. Thanks.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Office: [phone], Ext. 30.
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: David Michaels <[e-mail]>
Sent: Friday, March 18, 2022 3:19 PM
To: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Cc: Michael Brame <[e-mail]>; Hugh Creed Associates Inc, P.A. <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Request for Additional Information: SAW-2021-00814
(Flemingfield Road tract / McLeansville / Guilford County / residential)

Thanks Dave — we will proceed with the assessment. I have prepared a partial response to some of your concerns and
am waiting on my consultants to provide the additional data. We anticipate resubmittal by the end of next week — I will
keep you informed if it looks like it will extend beyond that time frame.
David B. Michaels
Manager, Land Acquisition and Development
Windsor Homes
5603 New Garden Village Dr.
Greensboro, NC 27410
M: 336-207-8003
0: 336.282.3535 Ext. 239
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, March 18, 2022 3:07 PM
To: David Michaels <[e-mail]>
Cc: Michael Brame <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
CAUTION: EXTERNAL EMAIL
Hi Mr. Michaels, and thanks for your email. Yes, a site assessment to determine if suitable habitat exists onsite is an
appropriate course of action; such an assessment can be your response to item #6. Once that information is received I
can begin informal consultation with the USFWS. Hopefully that helps.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Office: [phone], Ext. 30.
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: David Michaels <[e-mail]>
Sent: Tuesday, March 15, 2022 9:40 AM
To: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Cc: Michael Brame <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Request for Additional Information: SAW-2021-00814
(Flemingfield Road tract / McLeansville / Guilford County / residential)
8

David,
Regarding item 6, it is my understanding that the window for observation of these species will not open until late
summer or early fall of this year. Consequently, the only timely response I can provide is a site assessment to determine
if suitable habitat exists onsite or not. I just want to confirm that this method of assessment will be acceptable at this
time. Pilot has referred us to a botanist that can cruise the site within the week or so if I give them the authorization.
Please reply at your earliest opportunity.
David B. Michaels
Manager, Land Acquisition and Development
Windsor Homes
5603 New Garden Village Dr.
Greensboro, NC 27410
M: 336-207-8003
0: 336.282.3535 Ext. 239
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, March 7, 2022 7:15 AM
To: David Michaels <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
CAUTION: EXTERNAL EMAIL
Sounds good. Thanks David.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Office: [phone], Ext. 30.
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: David Michaels <[e-mail]>
Sent: Friday, March 4, 2022 4:15 PM
To: Homewood, Sue <[e-mail]>; Michael Brame <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Teresa Andrews
9

<[e-mail]>; Munzer, Olivia <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: [External] Request for Additional Information: SAW-2021-00814
(Flemingfield Road tract / McLeansville / Guilford County / residential)
Sue and David,
I will have formal answers back to each of you hopefully by the end of next week. I need to discuss a couple of these
concerns with Mike Brame and I've already spoken with the design engineer to provide answers as well. Have a nice
weekend and look forward to corresponding with you soon.
David Michaels
From: Homewood, Sue <[e-mail]>
Sent: Friday, March 4, 2022 10:54 AM
To: Michael Brame <[e-mail]>; David Michaels <[e-mail]>
Cc: [e-mail]; Teresa Andrews <[e-mail]>; Munzer, Olivia
<[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
All,
CAUTION: EXTERNAL EMAIL
The Division has the same questions and comments as the USACE, therefore please copy me on your response to David's
email. In addition, I have the following comments and questions:
1. In order to determine the applicability of the state isolated permitting rules 15A NCAC 02H .1300, please provide
the wetland classification using the NCWAM dichotomous key.
2. Please clarify the stormwater requirements for this project. The PCN indicates that the site is Low Density but
also that a Stormwater Management Plan will be reviewed by the County.
3. As the stormwater control measures are located within confined areas adjacent to jurisdictional features, please
provide information regarding the status of the review of the stormwater management plan. Modifications to
the stormwater management plan could require additional impacts to jurisdictional features.
4. The plans propose 110 linear feet of culvert installation for the stream impact and 50 foot riprap apron. While
the agencies acknowledge that properly installed riprap aprons are not considered a loss of stream, it is the
Division's opinion that there is a loss of stream function and aquatic passage with longer riprap aprons,
especially when they are combined with the culvert length. Please confirm that the riprap apron is designed for
the minimum length allowed by regulations.
5. The Jordan Lake Buffer Rules are implemented by Guilford County, however the PCN notes that buffer
mitigation is not proposed. Please note that the Jordan Buffer Rules state that road crossings that impact
greater than 150 linear feet or 1/3 acre of buffer require mitigation. The total stream impacts at this location
are listed as 160 linear feet.
The Division will consider this application on hold until receipt of complete responses to all items. Please be aware that
additional questions or comments may be necessary upon review of your response.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
10

[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, March 2, 2022 2:33 PM
To: Michael Brame <[e-mail]>; David Michaels <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [External] Request for Additional Information: SAW-2021-00814 (Flemingfield Road tract / McLeansville /
Guilford County/ residential)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
All,
Thank you for your PCN, dated 2/1/2022, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permit (NWP) 29 (https://saw-
reg.usace.army.mil/NWP2021/NWP29.pdf). Please submit the requested information below (via e-mail is fine) within 30
days of receipt of this Notification, otherwise we may deny verification of the use of the Nationwide Permit or consider
your application withdrawn and close the file:
1) NWP 29 General Condition 23(a) requires that the activity be designed and constructed to avoid and minimize
adverse effects, both temporary and permanent, to waters of the US to the maximum extent practicable
(available and capable of being done after taking into consideration cost, existing technology, and logistics in
light of overall project purposes). It is not clear that the design of the proposed development meets this
requirement. Namely:
a. Slate Ridge Trail, including proposed Impacts 1 and 2, is routed to cross Stream SA at a tangent at the
widest portion of Wetland WD, and directly through a disjunct section of Wetland WC 12-58. Additional
avoidance and minimization would be shown by adjusting the route to follow closer to the existing
driveway of the site across Stream SA, and or re -aligning this road to the north of Wetland WC 21-58;
b. Longfield Drive is routed through the upper -most portion of Wetland WE (Impact 5). Retaining walls and
other slope -steepening techniques are often used to eliminate or limit fill slope footprints in wetlands;
c. Elk Horn Drive, is routed through one of the wider sections of Wetland WE 1-58 (Impact 7). Additional
avoidance and minimization would be shown by adjusting the route to cross this wetland closer to the
existing dirt path crossing to the north, or re -aligning this road to cross this wetland slightly to the south;
d. Wetland impacts are proposed for Lot fill at Lots 16, 17, 48, 62, and 63 (Impacts 3, 4, 6, and 8). It is not
clear that project viability is dependent on the inclusion of these 5 Lots, when the overall development
proposes 99. Further, retaining walls and other slope -steepening techniques are often used to eliminate
or limit fill slope footprints in wetlands;
Please re -design the project accordingly, or provide documentation that such avoidance and minimization
measures are not practicable.
2) Item la above notwithstanding, revisions are required on Sheets 2 and 3 of the plans provided with the PCN:
a. The culvert pipe footprint is not visible on Sheet 2. This information is needed to show the pipe
alignment vs. the location of the stream, the culvert width vs. the width of the stream, etc., to ensure
that the project meets NWP 29 Regional Condition B.9c;
11

b. Sheet 2 does not clearly indicate the footprint of stream impacts for each of the 110 If of stream impact,
50 If of embedded rip rap, and 10 additional If of temporary impacts;
c. Sheet 3 indicates that two 60" culvert pipes are proposed at Impact 1. In order to comply with NWP 29
Regional Condition B.9b, one pipe should act as the low flow pipe (inverts buried 1' below the stream
bed), and the other pipe should act as the high flow culvert (only to receiving bank -full flows). High flow
culverts are typically designed by placing its invert at bankfull level, or at least a foot or two above the
existing stream bed. Another way to comply with this condition it to design sills at the inlet and outlet of
the high flow culvert to only allow flow in the high flow culvert at the above referenced flow level;
d. The top and bottom of the culvert is not visible on the profile view; this information is needed to ensure
that the culvert meets NWP 29 Regional Condition B.9 pertaining to culvert burial. Ensure that this
drawing clearly labels the top and bottom of the high and low flow culverts;
e. Items la and 2a above notwithstanding, Sheet 2 indicates that the culverts would be oriented such that
the stream exits the culverts aimed directly at the stream bank. Furthermore, the stream alignment
would then run parallel to the proposed fill slope only a few feet to the south for approximately 37
linear feet. This information indicates that maintaining a functioning stream channel in its current
location under these conditions is extremely unlikely. How would the design minimize the risk of indirect
impacts to this portion of the stream channel? Based on the current proposal the Corps would consider
this portion of stream as an indirect reduction of stream function, potentially calculated cumulatively
with the proposed direct permanent stream impacts when considering compensatory mitigation
thresholds, per NWP General Conditions "District Engineers Decision;"
f. Items la above notwithstanding, the portion of unimpacted Wetland WD between the south side of the
proposed fill slope and Stream SA includes a remanent fringe of wetland too small (^'0.016 acre) and
narrow to be expected to retain its previous function. As such, and the fact that grading for the adjacent
direct impact would eliminate any upslope drainage to this area, the Corps would consider the
remainder of the south side of this wetland as a reasonably foreseeable indirect impact. This area would
be added to the required compensatory mitigation amount.
3) Please provide zoomed -in details, including a plan and profile view, for Impact 7. Ensure that these details
clearly show the size and number of culvert pipes (placed at -grade rather than buried), head walls, rip rap, etc.
4) Items 1 a-c above notwithstanding, how would the project maintain appropriate hydrology to the remainders of
Wetlands WC 21-58 and WE 1-58. The Corps is concerned that upland grading in these areas would re-route
overland flow away from these areas and into downslope stormwater basins. If onsite hydrology is expected to
be maintained via culverts under roadways, swales, or other methods, please include plan detail sheets to
demonstrate. Note that, in addition to compensatory mitigation requirements for direct, the Corps would
consider requiring compensatory mitigation reasonably foreseeable indirect impacts resulting in a loss of
hydrology and therefore aquatic function, per NWP General Conditions "District Engineers Decision;"
5) For proposed Impact 9, sanitary sewer crossing of Stream SD and Wetland WC 21-58:
a. Per NWP 29 General Condition 10.c., please provide a plan to restore and re -vegetate wetland areas
within the utility corridor;
b. Given that the project exceeds the compensatory mitigation ratio for wetland impacts, the Corps will
also require compensatory mitigation for the permanently maintained sewer corridor through forested
wetlands. Compensatory mitigation for permanent conversion of forested to herbaceous wetlands is
typically required at a 1:1 ratio unless otherwise justified based on resource quality (NCWAM/NCSAM).
6) We acknowledge the statement in the PCN pertaining to endangered species (Section 7 of the Endangered
Species Act), that "Potential habitat for these species is not located within the proposed project areas."
However, given the general nature of potentially suitable habitat for Schweinitz's sunflower and small whorled
pogonia, the existence of both open and forested areas within the project area, and given recent USFWS
concerns regarding these species, the Corps cannot currently reach a No Effect determination for these species
within the Section 7 Action Area based on the information provided. Note that, given the distribution of
proposed impacts throughout the property, the entire proposed Flemingfield Reserve development would be
considered the Action Area for Section 7 purposes. As such:
12

a. If you do not believe that any suitable habitat exists in the Action area for these species, please provide
a more thorough justification so that the Corps could evaluate the potential for a No Effect
determination;
b. If suitable habitat for either of these species does exist in the Action Area, please complete a pedestrian
survey for these species within the appropriate survey window. Following the survey, please provide the
survey report to the Corps (copy also the USFWS) for review;
Please note that, per NWP 29 General Condition 18, the Corps cannot verify the use of a NWP until Section 7
consultation is complete.
7) Items 1a and c notwithstanding, to demonstrate further avoidance and minimization, would it be possible to
remove the existing driveway crossing of Stream SA or dirt road crossing of Wetland WE 1-58 and stabilize with
appropriate sloping and matting?
8) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Office: [phone], Ext. 30.
Mobile: [phone]
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG <[e-mail]>
Sent: Wednesday, February 2, 2022 10:41 AM
To: Michael Brame <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Subject: SAW-2021-00814 (Flemingfield Road tract / McLeansville / Guilford County / residential)
Good Morning
We have received your Pre -Construction Notification (PCN) NWP request for the above project.
Dave- docs forwarded in your folder
Thank you,
Josephine Schaffer
13

From: Michael Brame <[e-mail]>
Sent: Tuesday, February 1, 2022 1:23 PM
To: RaleighNCREG <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: [URL Verdict: Unknown][Non-DoD Source] SAW 2021-00814 - Pilot Project 6663.1 - Flemingfield Road - PCN
Application
Find attached a PCN Application for a site in Greensboro. Please let me know if you need additional information in order
to process the PCN. Thank -you.
Sincerely,
PILOT
PLOT l H v I l O M N l M 1 A 4, I M C
Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenvirc.com
[e-mail]
14

nA�
NORTH CAROLINA
Environmental Quality
Water Resources
Office Use Only
Corps Action ID no. 2021-00814 Date received: 2/1/2022
DWR project no. 20210773 Date received: 2/1/2022
Site Coordinates:
Latitude (DD.DDDDDD): 36.096371'
Longitude (DD.DDDDDD): 79.707263'
Form Version 1.5, September 2020
Pre -Construction Notification (PCN) Form
(Ver. 1.5, September 2020)
For Nationwide Permits and Regional General Permits and corresponding Water Quality Certifications
Please note: fields marked with a red asterisk are required. The form is not considered complete until all mandatory
questions are answered.
The online help file may be found at this link:
https:Hedocs.deg.nc.gov/WaterResources/0/edocl6247041PCN%2OHelp%2OFile%202018-1-30.pdf
The help document may be found at this link:
http://www.saw. usace.army. mil/Missions/Regulatory-Permit-Program/Permits/2017-Nationwide-Permits/Pre-
construction-Notification/
Before submitting this form, please ensure you have submitted the Pre -Filing Meeting Request Form as DWR will not be
able to accept your application without this important first step. The Pre -Filing Meeting Request Form is used to satisfy 40
C.F.R. Section 121.4(a) which states "At least 30 days prior to submitting a certification request, the project proponent shall
request a pre -filing meeting with the certifying agency." In accordance with 40 C.F.R. Section 121.5(b)(7), and (c)(5), all
certification requests must include documentation that a pre -filing meeting request was submitted to the certifying authority
at least 30 days prior to submitting the certification request.
Attach documentation of Pre -Filing Meeting Request to this Application.
Date of Pre -filing Meeting Request (MM/DD/YYYY) : 10/4/2020
DWR ID # 20210773 Version 1 (If applicable)
A. Processing Information
County (counties) where project is located:
Guilford Additional (if needed).
Is this a public transportation project?
(Publicly funded municipal, state, or federal road, rail,
❑ Yes ❑x No
or airport project)
Is this a NCDOT project?
❑ Yes ❑x No
If yes, NCDOT TIP or state project number:
Click to enter.
If yes, NCDOT WBS number:
Click to enter.
❑x Section 404 Permit (wetlands, streams, waters,
Clean Water Act)
la. Type(s) of approval sought from the Corps:
❑ Section 10 Permit (navigable waters, tidal
waters, Rivers and Harbors Act)
Pagel of 22 PCN Form - Version 1.5, September 2020

❑x Nationwide Permit (NWP)
1 b. Permit type(s)?
❑ Regional General Permit (RGP)
❑ Standard (IP)
This form may be used to initiate the standard/ individual permit process with the USACE. Please contact your Corps
representative concerning submittals for standard permits. All required items can be included as separate attachments
and submitted with this form.
1 c. Has the NWP or GP number been verified by the Corps?
❑ Yes ❑x No
NWP number(s):
NWP 29
RGP number(s):
Click to enter.
1 d. Type(s) of approval sought from the DWR (check all that apply):
❑x 401 Water Quality Certification — Regular ❑ 401 Water Quality Certification— Express
❑ Non-404 Jurisdictional General Permit ❑ Riparian Buffer Authorization
❑ Individual 401 Water Quality Certification
1e. Is this notification solely for the record because written approval is not required?
For the record only for DWR 401 Certification: *
❑ Yes ❑x No
For the record only for Corps Permit: *
❑ Yes ❑x No
1f. Is this an after -the -fact permit/certification application?
❑ Yes ❑x No
1 g. Is payment into a mitigation bank or in -lieu fee program proposed for
mitigation of impacts?
® Yes ❑ No
If yes, attach the acceptance letter from mitigation bank or in -lieu fee program.
1 h. Is the project located in any of NC's twenty coastal counties?
❑ Yes ❑x No
1 i. Is the project located within an NC DCM Area of Environmental
Concern (AEC)?
❑ Yes ❑x No ❑ Unknown
1j. Is the project located in a designated trout watershed?
❑ Yes ❑x No
If yes, you must attach a copy of the approval letter from the appropriate Wildlife Resource Commission Office.
Trout information may be found at this link: http://www.saw.usace.army.mil/Missions/Regulatory-Permit-
Program/Agency-Coordination/Trout.aspx
Page 2 of 22 PCN Form - Version 1.5, September 2020

B. Applicant Information
1 a.
Who is the primary contact?
David Michaels
1 b.
Primary Contact Email:
[e-mail]
1 c.
Primary Contact Phone: (###)###-####
[phone]
1 d.
Who is applying for the permit/certification? (check
all that apply)
❑ Owner ❑x Applicant (other than owner)
1 e.
Is there an agent/consultant for this project?
® Yes ❑ No
2.
Landowner Information
2a.
Name(s) on Recorded Deed:
Allen Jim Inc., Hathcock Properties, LLC, Alan R. Albert
2b.
Deed Book and Page No.:
000327/00127, 008103/02294 & 004174/0217
2c.
Responsible Party (for corporations):
Nadine Allen, Justin Hathcock & Sam Albert
2d.
Address
Street Address:
Multiple (Attached)
Address line 2:
Clicktu IVI RIM.
City:
Click to enter.
State/ Province/ Region:
Click to enter.
Postal/ Zip Code:
Click to enter.
Country:
Click to enter.
2e.
Telephone Number: * (###)###-####
Click to enter.
2f.
Fax Number: (###)###-####
Click to enter.
2g.
Email Address: *
Click to enter.
3.
Applicant Information (if different from owner)
3a.
Name:
David Michaels
3b.
Business Name (if applicable):
Windsor Investments
3c.
Address:
Street Address:
PO Box 9147
Address line 2:
Clicktu U1Rer.
City:
Greensboro
State/ Province/ Region:
NC
Postal/ Zip Code:
27429
Country
us
3d.
Telephone Number: (###)###-####
[phone]
3e
Fax Number: (###)###-####
UICK io enter.
Page 3 of 22 PCN Form - Version 1.5, September 2020

3f. Email Address: [e-mail]
4. Agent/ Consultant (if applicable)
4a. Name: *
Michael T. Brame
4b. Business Name:
Pilot Environmental, Inc.
4c. Address: *
Street Address:
743 Park Lawn Court
Address line 2:
Click to enter.
City:
Kernersville
State/ Province/ Region:
NC
Postal/ Zip Code:
27284
Country:
U.S.
4d. Telephone Number: (###)###-####
[phone]
4e Fax Number: (###)###-####
Click to enter.
4f. Email Address: *
[e-mail]
Agent Authorization Letter:
Attach a completed/signed agent authorization form or letter. A sample form may be found at this link:
https://www.saw. usace.army. mil/Missions/Regulatory-Permit-Program/Permits/2017-Nationwide-Permits/Pre-
construction-Notification/
Page 4 of 22 PCN Form - Version 1.5, September 2020

C. Project Information and Prior Project History
1. Project Information
1 a. Name of project:
Flemingfield Reserve
1 b. Subdivision name (if appropriate):
Flemingfield Reserve
1 c. Nearest municipality/town: *
McLeansville, NC
2.
Project Identification
2a.
Property identification number (tax PIN or parcel ID):
7895047974, 7895043546, 7895043649 and a portion of
PIN 7895037134
2b.
Property size (in acres):
30
2c.
Project Address:
Street Address:
138 (portion), 168, 170 & 172 Flemingfield
Road
Address line 2:
Click to enter.
City:
McLeansville
State/ Province/ Region:
NC
Postal/ Zip Code:
27301
Country:
U.S.
2d.
Site coordinates in decimal degrees (using 4-6 digits
after the decimal point):
Latitude (DD.DDDDDD): 36.096371'
Longitude (-DD.DDDDDD):-79.707263'
3. Surface Waters
3a. Name of nearest body of water to proposed project:
South Buffalo Creek
3b. Water Resources Classification of nearest receiving
WS V; NSW
water:
The Surface Water Classification map may be found at this link:
https://ncdenr.maps.arcqis.com/apps/webappviewer/index.html?id=6e125ad7628f494694e259c80dd64265
Cape Fear
3c. In what river basin(s) is your project located? *
Choose additional (if needed)
3d. Please provide the 12-digit HUC in which the project is
030300020104
located:
The Find Your HUC map may be found at this link:
https://ncdenr.maps.arcgis.com/apps/Publiclnformation/index.html?appid=ad3a85aOc6d644aOb97cdO69db238ac3
Page 5 of 22 PCN Form - Version 1.5, September 2020

4.
Project Description and History
4a.
Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of
this application:
Single family residences and out-buldings are located on the eastern and western portions of the site.
The remainder of the site contains wooded land and fields. The site is located in a residential area of
McLeansville.
4b.
Have Corps permits or DWR certifications been obtained for this
❑ Yes ❑x No ❑ Unknown
project (including all prior phases) in the past?
4c.
If yes, please give the DWR Certification number and/or Corps
2021-00814
Action ID (ex. SAW-0000-00000):
[Click to enter 1
Attach any pertinent project history documentation
4d.
Attach an 8'h x 11" excerpt from the most recent version of the USGS topographic map indicating the location of
the project site.
4e.
Attach an 8'h x 11" excerpt from the most recent version of the published County NRCS Soil Survey map
depicting the project site.
4f.
List the total estimated acreage of all existing wetlands on the
4.761 acres
property:
4g.
List the total estimated linear feet of all existing streams (intermittent
1,263 linear feet
and perennial) on the property:
4g1.
List the total estimated acreage of all existing open waters on the
0.174 acres
property:
4h.
Explain the purpose of the proposed project:
The purpose of the proposed project is to construct a 99 lot single family residential subdivision.
4i.
Describe the overall project in detail, including the type of equipment to be used:
The overall project includes the construction of a 99 lot single family residential subdivision. In order to facilitate the
proposed development and access the majority of the subdivision, it is necessary to cross a stream and wetland. The
proposed road will also impact wetlands in three additional locations. In order to connect to an existing sewer line it is
necessary to impact an additional wetland and stream. In order to grade out the site and develop 6 of the lots, it is
necessary to impact four additional wetlands. To facilitate the development of the site, clearing and grading the site is
necessary. Graders, haulers, excavators and other heavy equipment will be used during grading and construction of
the site.
4j.
Attach project drawings/site diagrams/depictions of impact areas for the proposed project.
5. Jurisdictional Determinations
5a. Have the wetlands or streams been delineated on the property or in
® Yes ❑ No ❑ Unknown
proposed impact areas?
Comments:
The site was delineated by Pilot Environmental in March, 2021 (Pilot Project 6663.1, report dated 4.1.2021). The site
was verified by Mr. David Bailey with the USACE on May 18, 2021 (Corps Action ID SAW- 2021-00814). A PJD has
not been received for the site. Mr. Bailey concurred with the delineation as depicted on Drawing 5 (attached).
Name (if known): David Brame/Michael Brame
5b. If 5a is yes, who delineated the jurisdictional
Agency/Consultant Company: Pilot Environmental
areas?
Other: Click to enter
Page 6 of 22 PCN Form - Version 1.5, September 2020

5c. If the Corps made a jurisdictional determination,
0 Preliminary ❑ Approved ❑ Emailed Concurrence
what type of determination was made?
❑ Not Verified ❑ Unknown
Corps AID number (ex. SAW-0000-00000):
SAW — 2021-00814
5d. List the dates of the Corps jurisdictional determination or State determination if a determination was made by
either agency.
USACE — May 18, 2021 Site Visit — PJD not issued.
5d1. Attach jurisdictional determinations.
Page 7 of 22 PCN Form - Version 1.5, September 2020

6. Future Project Plans
6a. Is this a phased project?
❑ Yes ❑x No
6b. If yes, explain.
The site is a proposed single phase residential development. Roads are stubbed onto properties to the west and
north as required for site plan approval. The applicant does not own the properties where the roads are stubbed
and does not have intentions to develop them. There are no mapped jurisdictional features in the immediate
vicinity of the termination points of the roads.
Are any other NWP(s), regional general permit(s), or individual permit(s) used, or intended to be used, to authorize
any part of the proposed project or related activity? This includes other separate and distant crossings for linear
projects that require Department of the Army authorization but don't require pre -construction notification.
No other permits are intended to be used.
Page 8 of 22 PCN Form - Version 1.5, September 2020

D. Proposed Impacts Inventory
Impacts Summary
1 a. Where are the impacts associated with your project
(check all that apply):
❑x Wetlands
❑x Buffers
❑ Pond Construction
❑x Streams - tributaries
❑ Open Waters
2. Wetland Impacts
If there are wetland impacts proposed on the site, complete this table for each wetland area impacted.
2a.
2a1.
2b.
2c.
2d.
2e.
2f.
2g.
Site #
Impact
Impact
Wetland Name
Wetland Type
Forested
Jurisdiction
Impact Area
Reason/Type
Duration
?
Type
(ac)
W1
Fill (Incl.
Permanent
WD 1-13
Bottomland
Yes
Both
0.1919
Riprap)
Hardwood
Forest
W2
Fill (Incl.
Permanent
WC 21-58
Bottomland
Yes
Both
0.0896
Riprap)
Hardwood
Forest
W3
Fill (Incl.
Permanent
WE 1-58
Bottomland
Yes
Both
0.0070
Riprap)
Hardwood
Forest
W4
Fill (Incl.
Permanent
WE 1-58
Bottomland
Yes
Both
0.0003
Riprap)
Hardwood
Forest
W5
Fill (Incl.
Permanent
WE 1-58
Bottomland
Yes
Both
0.0205
Riprap)
Hardwood
Forest
Fill (Incl.
Permanent
WE 1-58
Bottomland
Yes
Both
0.0040
W6
Riprap)
Hardwood
Forest
2g1. Total temporary wetland impacts
0.05 ac
2g2. Total permanent wetland impacts
0.68 ac
2g3. Total wetland impacts
0.73 ac
Page 9 of 22 PCN Form - Version 1.5, September 2020

2h. Comments:
Additional Impacts:
W7 Fill Permanent WE 1-58 Bottomland Yes Both 0.1054
Hardwood
Forest
W9 Other Temporary WC 21-58 Bottomland Yes Both 0.0531
Hardwood
Forest
W10 Fill Permanent WF 1-11 Isolated Yes Both 0.260
Wetland impacts 1, 2, 5 and 7 are associated with proposed roads that provide access to the site. Permanent impacts
from the roads account for 0.4073 acres of the proposed impacts. Wetland impacts 3, 4 and 6 are associated with lot
fill in order to create developable lots. Permanent impacts associated with lot fill accounts for 0.0113 acres of the
proposed impacts. Wetland impact 9 is associated with providing sewer connectivity to the site. A temporary impact of
0.0531 is proposed. Wetland impact 10 is associated with lot fill in an isolated wetland (Determined to be Non -JD by
the USACE).
Mitigation is required for the proposed permanent impacts. Mitigation is proposed at a 2:1 for the bottomland hardwood
wetlands (0.42 acres). Mitigation is proposed at a 1:1 for the isolated wetland (0.26 acres).
Page 10 of 22 PCN Form - Version 1.5, September 2020

3.
Stream Impacts
If there are perennial or intermittent stream/ tributary impacts (including temporary impacts) proposed on the site,
complete this table for all stream/ tributary sites impacted.
** All Perennial or Intermittent streams must be verified by DWR or delegated local government
Site #
3a.
Impact Reason/
Type
3b.
Impact
Duration
3d.
Stream Name
3e.
Stream
Type
3f.
Jurisdiction
Type
3g.
Stream Width
(avg ft)
3h.
Impact length
(linear ft)
S1
Crossing/ Culvert
Temp/ Perm
SA
Perennial
Both
7
110/50/10
S2
Other
Temporary
SD2
Perennial
Both
7.15
20
S3
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S4
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S5
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S6
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S7
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S8
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S9
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S10
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S11
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S12
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S13
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S14
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
S15
Choose one
Temp/ Perm
Click to enter
Per/Int
Choose one
Click to enter
Click to enter
3i1.
Total jurisdictional ditch impact:
0 linear ft
3i2.
Total permanent stream impacts:
160 linear ft
36.
Total temporary stream impacts:
30 linear ft
3i4.
Total stream and ditch impacts:
190 linear ft
3j.
Comments:
The road crossing culvert and fill will impact 110 linear feet (770 square feet/0.018 acres) of stream channel. The
proposed rip rap (to be keyed in) will impact 50 linear feet (350 square feet/0.008 acres) of stream channel. The
coffer dam/pump around will temporarily impact 10 linear feet (70 square feet/0.002 acres) of stream channel.
The sewer line will temporarily impact 20 linear feet (143 square feet/0.003 acres) of stream channel. Stream
mitigation is not proposed.
Page 11 of 22 PCN Form - Version 1.5, September 2020

4.
Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries,
sounds, the Atlantic Ocean, or any other
open water of the U.S., individually list all open water impacts in the table below.
4a.
4b.
4c.
4d.
4e.
4e1.
4f.
Site #
Impact Reason/
Impact
Waterbody Name
Waterbody
Jurisdiction
Impact area (ac)'
Type
Duration
Type*
Type
01
Choose one
Temp/
Click to enter.
Choose one
Choose one
Click to enter.
Perm
02
Choose one
Temp/
Click to enter.
Choose one
Choose one
Click to enter.
Perm
03
Choose one
Temp/
Click to enter.
Choose one
Choose one
Click to enter.
Perm
04
Choose one
Temp/
Click to enter.
Choose one
Choose one
Click to enter.
Perm
4g.
Total temporary open water impacts
Click to enter. ac
4g.
Total permanent open water impacts
Click to enter. ac
4g.
Total open water impacts
Click to enter. ac
4h.
Comments:
Open water impacts are not proposed.
5.
Pond or Lake Construction
If pond or lake construction is proposed, complete
the table
below. (*This
does NOT include ofFline stormwater
management ponds.)
5a.
5b.
5c.
5d.
5e.
Pond ID
Proposed use or
Wetland Impacts
(ac)
Stream
Impacts (ft)
Upland
#
purpose of pond
Impacts (ac)
Flooded
Filled
Excavated
Flooded
Filled
Excavated
P1
Choose one
Click to
Click tL
Click to
Click to
Click to
Click to
Click to
enter.
enter.
enter.
enter.
enter.
enter.
enter.
P2
Choose one
Click to
Click to
Click to
Click to
Click to
Click to
Click to
enter.
enter.
enter.
enter.
enter.
enter.
enter.
5f.
Total
Click to
Click to
Click to
Click to
Click to
Click to
Click to
enter.
enter.
enter.
enter.
enter.
enter.
enter.
5g.
Comments:
Pond or lake construction is not proposed.
5h.
Is a dam high hazard permit required?
❑ Yes ❑ No
If yes, permit ID no.:
Click to enter.
5i.
Expected pond surface area (acres):
Click to enter.
5j.
Size of pond watershed (acres):
Click to enter.
5k.
Method of construction:
Click to enter.
Page 12 of 22 PCN Form - Version 1.5, September 2020

6. Buffer Impacts (DWR requirement)
If project will impact a protected riparian buffer, then complete the chart below. Individually list all buffer impacts.
❑ Neuse ❑ Tar -Pamlico ❑ Catawba
6a. Project is in which protected basin(s)?
❑x Jordan ❑ Goose Creek ❑ Randleman
(Check all that apply.)
❑ Other: Click to enter.
6b.
6c.
6d.
6e.
6f.
6g.
Site #*
Impact Type*
Impact Duration*
Stream Name*
Buffer
Zone 1 Impact*
Zone 2 Impact*
Mitigation
(sq ft)
(sq ft)
Required?*
131
Road/ Temp. Road
Temp/ Perm
Unnamed
No
9,191
2,214/5,431
132
Utility Lines
Temporary
Unnamed
No
1,423
583
133
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter.
Click to enter.
134
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter.
Click to enter.
135
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter.
Click to enter.
136
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter
Click to enter.
137
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter
Click to enter.
138
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter
Click to enter.
139
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter
Click to enter.
B10
Choose one
Temp/ Perm
Click to enter.
Y/N
Click to enter
Click to enter.
6h. Total temporary impacts:
Zone 1: 1,423 sq ft
Zone 2: 583 sq ft
6h. Total permanent impacts:
Zone 1: 9,191 sq ft
Zone 2: 2,214 sq ft
6h. Total combined buffer impacts:
Zone 1: 10,614 sq ft
Zone 2: 2,797 sq ft
6i. Comments:
In order to construct the road that provides access to the majority of the subdivision, it is necessary to permanently impact
9,191 square feet of Zone 1 buffer and 2,214 square feet of Zone 2 buffer. The temporary impact area (1,423 square feet
Zone 1 and 583 square feet Zone 2) will consist of graded slopes associated with the roadway and sanitary sewer
line/easement that will be reseeded. Mitigation is not proposed.
Please attach supporting documentation (impact maps, plan sheets, etc.) for the proposed project.
Page 13 of 22 PCN Form - Version 1.5, September 2020

E. Impact Justification and Mitigation
1. Avoidance and Minimization
1 a. Specifically describe measures taken to avoid or minimize the proposed impacts through project design:
The applicant has designed the proposed development to avoid impacts to the remainder of the streams and wetlands
on the site. The driveway has been designed as narrow as practicable to minimize impacts to the stream and
wetlands. The sewer line crossing has been put in the narrowest area of wetlands to minimize the impacts. The
subdivision has been designed to avoid impacts to large wetlands on the central and southern portions of the site.
Additionally, a substantial number of lots have been sacrificed under the proposed design to avoid wetland impacts.
The remaining roads, lots and utilities have been designed to avoid additional impacts to jurisdictional areas.
1 b. Specifically describe measures taken to avoid or minimize proposed impacts through construction techniques:
The clearing limits will be surveyed, staked and silt fencing and clearing limit fencing will be used. Disturbed areas will
be seeded and mulched to limit sediment from entering downgradient waters. Slope matting will be used on steep
slopes.
2. Compensatory Mitigation for Impacts to Waters of the U.S., Waters of the State, or Riparian Buffers
2a. If compensatory mitigation is required, by whom is it required? ❑x DWR ❑x Corps
(check all that apply)
2b. If yes, which mitigation option(s) will be used for this ® Mitigation Bank
project? (check all that apply) ❑ In Lieu Fee Program
❑ Permittee Responsible Mitigation
3. Complete if using a Mitigation Bank
(Must satisfy NC General Statute143-214.11 (d1).)
3a. Name of mitigation bank:
Click to ente-
3b. Credits purchased/requested:
Type: Riparian Wetland
Quantity 0.84 (0.42 @ 2:1)
Type: Non -riparian
Wetland
Quantity 0.26
Type: Choose one
Quantity Click to enter.
Attach receipt and/or approval letter.
3c. Comments:
Click to enter.
4.
Complete if Using an In Lieu Fee Program
4a.
Attach approval letter from in lieu fee program.
4b.
Stream mitigation requested:
Click to enter. linear feet
4c.
If using stream mitigation, what is the stream temperature:
Choose one
NC Stream Temperature Classification Maps can be found under the Mitigation Concepts tab on the Wilmington
District's RIBITS website: (Please use the filter and select Wilmington district)
https://ribits.usace.army.mil/ribits apex/f?p=107:27:2734709611497::NO: RP: P27 BUTTON KEY:O
4d.
Buffer mitigation requested (DWR only):
Click to enter. square feet
4e.
Riparian wetland mitigation requested:
1.1 acres
Page 14 of 22 PCN Form - Version 1.5, September 2020

4f. Non -riparian wetland mitigation requested:
Click to enter. acres
4g. Coastal (tidal) wetland mitigation requested:
Click to enter. acres
4h. Comments:
Click to enter.
5. Complete if Providing a Permittee Responsible Mitigation Plan
5a. If proposing a permittee responsible mitigation plan, provide a description of the proposed mitigation plan,
including the amount of mitigation proposed.
Click to enter.
5b. Attach mitigation plan/documentation.
6.
Buffer Mitigation (State Regulated Riparian Buffer Rules) — DWR requirement
6a.
Will the project result in an impact within a protected riparian buffer
❑ Yes ❑x No
that requires buffer mitigation?
If yes, please complete this entire section — please contact DWR for more information.
6b.
If yes, identify the square feet of impact to each zone of the riparian buffer that requires
mitigation. Calculate the
amount of mitigation required in the table below.
6c.
6d.
6e.
Zone
Reason for impact
Total impact (square
Multiplier
Required mitigation
feet)
(square feet)
Zone 1
Slick to enter.
:,lick to enter.
:,hoose one
:,lick to enter.
Zone 2
;lick to enter.
Click to enter.
:,hoose one
Click to enter.
6f. Total buffer mitigation required
lick to enter.
6g.
If buffer mitigation is required, is payment to a mitigation bank or
❑ Yes ❑ No
NC Division of Mitigation Services proposed?
6h.
If yes, attach the acceptance letter from the mitigation bank or NC Division of Mitigation Services.
6i.
Comments:
Buffer mitigation is not proposed.
Page 15 of 22 PCN Form - Version 1.5, September 2020

F. Stormwater Management and Diffuse Flow Plan (DWR requirement)
1. Diffuse Flow Plan
1 a. Does the project include or is it adjacent to protected riparian buffers
® Yes ❑ No
identified within one of the NC Riparian Buffer Protection Rules?
1 b. All buffer impacts and high ground impacts require diffuse flow or other forms of stormwater treatment. If the
project is subject to a state implemented riparian buffer protection program, include a plan that fully documents
how diffuse flow will be maintained.
All Stormwater Control Measures (SCM) must be designed in accordance with the NC Stormwater Design
Manual (https://deg.nc.gov/about/divisions/energv-mineral-land-resources/energv-mineral-land-permit-
guidance/stormwater-bmp-manual).
Associated supplement forms and other documentation must be provided.
❑ Level Spreader
What Type of SCM are you
❑ Vegetated Conveyance (lower seasonal high water table- SHWT)
providing?
❑ Wetland Swale (higher SHWT)
(Check all that apply)
❑ Other SCM that removes minimum 30% nitrogen
❑x Proposed project will not create concentrated stormwater flow through the
buffer
For a list of options to meet the diffuse flow requirements, click here:
Attach diffuse flow documentation.
2. Stormwater Management Plan
2a. Is this an NCDOT project subject to compliance with NCDOT's
Individual NPDES permit NCS000250?
El Yes ❑x No
2b. Does this project meet the requirements for low density projects as
defined in 15A NCAC 02H .1003(2)?
❑x Yes ❑ No
To look up low density requirements, click here:
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20guality/chapter%2002%20-
%20environmental%20management/subchapter%20h/15a%20ncac%2002h%20.1003.pdf
2c. IS the project over an acre?
❑x Yes ❑ No
2d. Does this project have a stormwater management plan (SMP)
reviewed and approved under a state stormwater program or state-
❑x Yes ❑ No
approved local government stormwater program?
Note: Projects that have vested rights, exemptions, or grandfathering from state or locally implemented
stormwater programs or projects that satisfy state or locally -implemented stormwater programs through use of
community in -lieu programs should answer "no" to this question.
2e. Which of the following stormwater management program(s) apply?
❑x Local Government
(Check all that apply)
❑ State
If you have local government approval, please include the SMP on their overall impact map.
Page 16 of 22 PCN Form - Version 1.5, September 2020

❑x Phase II ❑ USMP
Local Government Stormwater Programs
❑ NSW ❑ Water Supply
Please identify which local government stormwater program you are using.
Guilford
❑ Phase II ❑ HQW or ORW
State Stormwater Programs
❑ Coastal Counties ❑x Other
Comments:
A SWMP is required and has been submitted to Guilford County for review and approval.
Page 17 of 22 PCN Form - Version 1.5, September 2020

G. Supplementary Information
1. Environmental Documentation
1 a. Does the project involve an expenditure of public (federal/state/local)
❑ Yes ❑x No
funds or the use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require
preparation of an environmental document pursuant to the
requirements of the National or State (North Carolina) Environmental
❑ Yes ❑ No
Policy Act (NEPA/SEPA)?
1 c. If you answered "yes" to the above, has the document review been
finalized by the State Clearing House? (If so, attach a copy of the
❑ Yes ❑ No
NEPA or SEPA final approval letter.)
Comments:
A NEPA or SEPA is not required.
2. Violations (DWR Requirement)
2a. Is the site in violation of DWR Water Quality Certification Rules (15A
NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300),
DR Surface Water or Wetland Standards or Riparian Buffer Rules El Yes ❑x No
W
(15A NCAC 2B .0200)?
2b. If you answered "yes" to the above question, provide an explanation of the violation(s):
Click to enter.
3. Cumulative Impacts (DWR Requirement)
3a. Will this project (based on past and reasonably anticipated future
impacts) result in additional development, which could impact nearby
❑ Yes ❑x No
downstream water quality?
3b. If you answered "no", provide a short narrative description:
Additional development as a result of the proposed development is not anticipated.
3c. If yes, attach a qualitative or quantitative cumulative impact analysis (.pdo in accordance with the most recent
DWR policy.
4. Sewage Disposal (DWR Requirement)
4a. Is sewage disposal required by DWR for this project? I ® Yes ❑ No ❑ N/A
4b. If yes, describe in detail the treatment methods and dispositions (non -discharge or discharge) of wastewater
generated from the proposed project. If the wastewater will be treated at a treatment plant, list the capacity
available at that plant.
Sewage will be discharged into existing sewer lines that are located on the site. The sewer line must cross a stream
and wetland in order to connect to the existing lines. Impacts are described in Section D (Proposed Impacts
Inventory).
Page 18 of 22 PCN Form - Version 1.5, September 2020

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected
® Yes ❑ No
species or habitat? (IPAC weblink: https://www.fws.gov/ipac/ Ifws.govl)
5b. Have you checked with the USFWS concerning Endangered Species
❑ Yes ❑x No
Act impacts?
5c. If yes, indicate the USFWS Field Office you have contacted.
:,hoose one
5d. Is another federal agency involved?
❑ Yes ❑x No ❑ Unknown
If yes, which federal agency?
Click to enter.
5e. Is this a DOT project located within Divisions 1-8?
❑ Yes ❑x No
5f. Will you cut any trees in order to conduct the work in waters of the
U.S.?
❑ Yes ❑x No
5g. Does this project involve bridge maintenance or removal? *
❑ Yes ❑x No
Link to NLEB SLOPES document: http://saw-reg.usace. army. mil/NLEB/1-30-17-signed NLEB-
SLOPES&apps.pdf
5h. Does this project involve the construction/ installation of a wind
turbine(s)?
❑ Yes ❑x No
If yes, please show the location of the wind turbine(s) on the permit drawings/ project plans (attach .pdo
5i. Does this project involve blasting and /or other percussive activities
that will be conducted by machines, such as jackhammers,
❑ Yes ❑x No
mechanized pile drivers, etc.?
If yes, please provide details to include type of percussive activity, purpose, duration, and specific location of this
activity on the property (attach .pdo
5j. What data sources did you use to determine whether your site would impact Endangered Species or Designated
Critical Habitat?
US Department of the Interior — Fish and Wildlife Service Official Species List from IPaC
6 listed species are identified on the IPaC report (attached). Small whorled pogonia, monarch butterfly, Cape Fear
shiner, Schweinitz's sunflower, Roanoke Iogperch and Atlantic pigtoe are federally listed species. Potential habitat for
these species is not located within the proposed project areas.
Attach consultation documentation.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as
an Essential Fish Habitat?
❑ Yes
❑x No
Are there submerged aquatic vegetation (SAV) around
the project vicinity?
El Yes
❑x No El Unknown
Will this project affect submerged aquatic vegetation?
❑ Yes
❑x No ❑ Unknown
Explain:
Click to enter.
Page 19 of 22 PCN Form - Version 1.5, September 2020

6b. What data source(s) did you use to determine whether your site would impact Essential Fish Habitat?
Essential Fish Habitat Mapper— NOAA Fisheries
Page 20 of 22 PCN Form - Version 1.5, September 2020

7. Historic or Prehistoric Cultural Resources (Corps Requirement)
Link to the State Historic Preservation Office Historic Properties Map (does not include archaeological data):
hftp://qis.ncdcr.gov/hpoweb/
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural
preservation status (e.g., National Historic Trust designation or
❑ Yes ❑x No
properties significant in North Carolina history and archaeology)?
7b. What data source(s) did you use to determine whether your site would impact historic or archeological
resources?
NC Historic Preservation Office's HPOWEB 2.0. Historic properties were not identified on the site or within one mile of
the site. A surveyed "gone" residence is identified on adjacent property northwest of the site. A copy of the SHPO
Map is included as an attachment.
7c. Attach historic or prehistoric documentation.
8. Flood Zone Designation (Corps Requirement)
Link to the FEMA Floodplain Maps: https://msc.fema.gov/portal/search
8a. Will this project occur in a FEMA-designated 100-year floodplain? *
i] Yes ❑x No
8b. If yes, explain how the project meets FEMA requirements.
Click to enter.
8c. What source(s) did you use to make the floodplain determination?
National Flood Hazard Layer froom FEMA Web Map Service — Drawing 4 (Attached)
Page 21 of 22 PCN Form - Version 1.5, September 2020

H. Miscellaneous
Comments:
Please let me know if you need additional information in order to process this application.
Attach pertinent documentation or attachments not previously requested
I. Signature *
❑x By checking the box and signing below, I, as the project proponent, certify to the following:
• The project proponent hereby certifies that all information contained herein is true, accurate, and complete, to
the best of my knowledge and belief;
• The project proponent hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time;
• The project proponent hereby agrees that submission of this PCN form is a "transaction" subject to Chapter
66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• The project proponent hereby agrees to conduct this transaction by electronic means pursuant to Chapter 66,
Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act");
• The project proponent hereby understands that an electronic signature has the same legal effect and can be
enforced in the same way as a written signature; AND
• As the project proponent, I intend to electronically sign and submit the PCN/online form.
Full Name: Michael T. Brame
Michael o,.9,y� dbyMknae�B—
°— - n 1e,nme,°=v.wn
Signature:
Brame p ,M22-27141216„°°m,-=
5/27/2022
Page 22 of 22 PCN Form - Version 1.5, September 2020

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