RE_ _External_ Request for Additional Information_ SAW-2022-01383 (NCDOT Division 7 _ replace Pipe 40 2104 _ SR 3097 _ Ingold Road _ Guilford County

Baker, Caroline D
From:Parker, Jerry A
Sent:Tuesday, August 16, 2022 3:55 PM
To:[e-mail]
Cc:Conchilla, Ryan; [e-mail]
Subject:RE: \[External\] Request for Additional Information: SAW-2022-01383 (NCDOT Division
7 / replace Pipe 40 2104 / SR 3097 / Ingold Road / Guilford County
Attachments:Ingold Rd Small Whorled Pogonia Survey.pdf; Ingold Rd Mitigation Acceptance
Letter.pdf; Ingold Road Upland Form.pdf; Ingold Rd Wetland Determination.pdf
Dave,

I have provided the answers to your request in red. Please let me know if any other additional info is required.

Jerry

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, July 13, 2022 2:05 PM
To: Parker, Jerry A <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>
Subject: \[External\] Request for Additional Information: SAW-2022-01383 (NCDOT Division 7 / replace Pipe 40 2104 / SR
3097 / Ingold Road / Guilford County

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All,

Thank you for your PCN, dated 6/22/2022, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permit (NWP) 14 (https://saw-
reg.usace.army.mil/NWP2021/NWP-14.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consider your application withdrawn and close the file: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) The PCN references both a wetland delineation (Section C.5) and Endangered Species information pertaining to
Section 7 of the Endangered Species Act (Section G.5.), however this information was not included in the PCN
submittal package;
a. Please provide the delineation of potential waters of the US and supporting information, including
mapping, Wetland Determination Data Forms, and any other information (including pictures, stream
forms, etc.) that would be relevant for the Corps to confirm the boundaries of potential waters of the
US. Per NWP 29 General Condition 32(b)(5), this information is necessary to begin processing your
request to verify the use of this NWP; See attached. Also, by copy of this email NCDOT is requesting that
the wetland depicted on the submitted drawing be disregarded. This request is based on the more
recent wetland delineation that determined that the prior wetland no longer exists.
b. Small whorled pogonia (Isotria medeoloides) is the only listed Threatened or Endangered species in the
project Action Area, and it appears that suitable habitat for this species may be present in this case.
Please describe any potentially suitable habitat for this species in the Action Area, including any surveys
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that may have been conducted for this species as part of project planning. This information is necessary
to determine if consultation is required and/or initiate consultation with the USFWS. Per NWP General
Condition 18 the Corps cannot verify the use of a NWP until Section 7 consultation is complete; See
attached
2) Per NWP General Condition, the activity must be designed and constructed to avoid and minimize adverse
effects, both temporary and permanent, to waters of the United States to the maximum extent practicable at
the project site. Please more fully explain the necessity to realign the culvert, when it appears possible to
replace the pipe more-or less in place (thereby reducing permanent stream impacts), even if an on-site detour is
necessary. If the existing alignment is, for example, causing bank erosion at the downstream curve of the stream
channel, please further document with photographs.

In order to facilitate replacing this pipe on a road with no outlet, an onsite detour must be used. The
current stream on the inlet side of the pipe flows parallel to the roadway and has a severe skew at
the inlet of the pipe. The stream also has skew on the outlet end of the pipe. In order to maintain
traffic during construction impacts to the stream upstream or downstream is unavoidable. Because
the stream on the upstream side runs parallel to the roadway any attempt to place the onsite detour
on this side would generate a much larger impact on the stream. Therefore, the downstream side
was selected for the onsite detour which minimize the impacts to the stream.

The pipe was realigned to best fit the existing stream to prevent the outlet from discharging into the
stream bank which would cause erosion. The inlet skew is also improved to allow for better flow
capacity. Greater stream impacts would be generated if the detour pipe was
placed in the existing stream bed on the outlet side. Because of the bend in the stream a junction box
would need to be constructed in order to change the alignment of the 78 inch pipe. This would cause
the onsite detour to be pushed further downstream which would
generate greater stream impacts. These impacts were avoided by realigning so the inlet and outlet of
the new pipe to match the stream bed.

3) Per the “Final Plans”, there will be a narrow section of stream bank to remain unstabilized between two
proposed stabilized section of stream bank. The Corps is concerned that this area would be vulnerable to
erosion given the two hardened section of stream bank directly up- and down-stream. Please address these
concerns, and augment the plans as necessary;

The view below is just part of the phasing, the actual final pipe length will include the extent of the dashed
portion of the 78” pipe. The view below shows the second phase of pipe installation, with the downstream
portion of 78” (circled in red) already installed and proposed upstream (under the
road) portion of the pipe to be installed. But overall permanent length is both the
solid and dashed (circled) portion below.

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4) To support your compensatory mitigation plan, please provide a statement of availability from the NCDMS; See
attached.
5) It appears that an Individual 401 Water Quality Certification (WQC) is required from the North Carolina Division
of Water Resources (NCDWR) for this project; please note that the Corps cannot verify the use of any NWP
without a valid 401 WQC. NCDOT is requesting that the Corps evaluates this project under the RGP50.

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.

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From: NCDOT_REG <[e-mail]>
Sent: Wednesday, June 22, 2022 1:47 PM
To: [e-mail]
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Matthews, Monte K CIV USARMY
CESAW (USA) <[e-mail]>
Subject: SAW-2022-01383 (NCDOT / 17BP.7.C.15 / Replace pipe #40 2104 / SR 3097 Ingold Road / UT of Big Alamance
Creek / Guilford County / Div 7)

Good Afternoon,

Your Pre-Construction Notification (PCN) NWP request has been received, assigned action ID SAW-2022-01383 and
forwarded to Dave Bailey for further processing,

Please refer to the action ID in all correspondence.

Thank you,
Josephine Schaffer

From: [e-mail] <[e-mail]>
Sent: Wednesday, June 22, 2022 12:16 PM
To: NCDOT_REG <[e-mail]>
Cc: SAW-PCN-RG <[e-mail]>
Subject: \[Non-DoD Source\] PCN - Guilford - DOT

A new project has been received on 6/22/2022 12:13 PM for Ingold Road Pipe Replacement. The link below will take you
to the project folder.

https://edocs.deq.nc.gov/Laserfiche/index.aspx?db=WaterResources#id=2382089;view=browse

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