_External_ RE_ Request for Additional Information_ SAW-2019-01257 (NCDOT _ Bridge 183 _ SR2710 _ Running Creek Road _ Guilford County _ Greensboro NC) (2)

Carpenter,Kristi
From:Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent:Thursday, August 18, 2022 1:07 PM
To:Parker, Jerry A
Cc:Conchilla, Ryan; Powers, Tim
Subject:\[External\] RE: Request for Additional Information: SAW-2019-01257 (NCDOT / Bridge
183 / SR2710 / Running Creek Road / Guilford County / Greensboro NC)
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Hi Jerry. A few items have come up since we last spoke about the above-referenced project that must be resolved
before we can authorize it:
1) Please forward any tribal consultation that has been undertaken for this project; I was unable to locate any in
the PCN or my files. Tribal consultation is required for this project, including giving applicable tribes 30 days to
provide comments. If such letters have not been provided to applicable tribes please do so and include me on
the correspondence per the usual process;
2) Although I had previously stated that RGP 50 could authorize bridge to culvert projects, I had a conversation
with Monte Matthews (Corps NCDOT Team Lead) this morning and he clarified that our decision document does
not support the use of RGP 50 for bridge to culvert projects. Essentially, the two types of NCDOT activities
authorized by RGP 50 are:
a. a. (1) Road widening, and/or (2) construction, maintenance, and/or repair of bridges. For bridge projects,
work can include the approaches.
b. b. (1) Improvement of interchanges or intersections, or (2) construction of interchanges or intersections
over, or on, existing roads.
Our decision document does not contemplate using RGP 50 for bridge to culvert projects, or pipe replacement
projects for that matter, unless they are part of a road widening or Improvement/construction of interchanges.
Because bridge to culvert replacement projects activities are not discussed in our decision document I cannot
use RGP 50 to authorize then. This is contrary to what I had specifically told you previously, and for that I
sincerely apologize.
Instead of RGP 50 as I had previously suggested, NWP 14 would be the appropriate authorization for this
project. Please coordinate with NCDWR to determine if General WQC No. 4246 could be used, or if an Individual
WQC will be required; if an Individual WQC is required for this project (as appears likely), please note that the
Corps cannot verify the use of this NWP until the Individual WQC is received.

Please let me know if you have any questions.

-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]
Email: [e-mail]

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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: Parker, Jerry A <[e-mail]>
Sent: Thursday, August 11, 2022 1:56 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>; Powers, Tim <[e-mail]>
Subject: \[URL Verdict: Neutral\]\[Non-DoD Source\] RE: \[External\] Request for Additional Information: SAW-2019-01257
(NCDOT / Bridge 183 / SR2710 / Running Creek Road / Guilford County / Greensboro NC)

Dave,

In response to a) and b). Floodplain benches constructed using Class II riprap will be backfilled
to proposed grade with native bed material excavated from the stream bed at the project site
during culvert construction. Vegetative stabilization will be established by utilizing a
riparian/wetland seed mix overlayed with coir fiber matting. Let me know if you have any
questions. Thanks.

Jerry

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, August 4, 2022 2:34 PM
To: Parker, Jerry A <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>
Subject: RE: \[External\] Request for Additional Information: SAW-2019-01257 (NCDOT / Bridge 183 / SR2710 / Running
Creek Road / Guilford County / Greensboro NC)

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Hi Jerry. You responses for Items 1 and 3 address our concerns. Regarding Item 2:
a) Using the “natural ground” in the cut condition can be a concern given that cutting into subsoil can expose soils
that are nutrient poor, have very high bulk density, and are generally unsuitable for vegetative growth; perhaps
a statement regarding backfilling to proposed grade with native bed material if soils are unsuitable would allay
that concern;
b) The note you provided does not address vegetative stabilization: please describe the vegetative stabilization to
be used under/through the coir fiber mat (e.g. riparian/wetland seed mix, annual seed only, etc.), or clearly
describe why no vegetative stabilization is necessary/practicable.

Thanks, and please let me know if you have any questions.

-Dave Bailey

---
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
2

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: Parker, Jerry A <[e-mail]>
Sent: Tuesday, August 2, 2022 9:46 AM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>
Subject: \[URL Verdict: Neutral\]\[Non-DoD Source\] RE: \[External\] Request for Additional Information: SAW-2019-01257
(NCDOT / Bridge 183 / SR2710 / Running Creek Road / Guilford County / Greensboro NC)

David,

I have responded to your requests in red and with the attachment. Please let me know if you need anything else.

Jerry

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, July 13, 2022 3:29 PM
To: Parker, Jerry A <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>
Subject: \[External\] Request for Additional Information: SAW-2019-01257 (NCDOT / Bridge 183 / SR2710 / Running Creek
Road / Guilford County / Greensboro NC)

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Report Spam.

All,

Thank you for your PCN, dated 6/23/2022, 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) 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. Also note that this project may fit RGP 50 which may have a General WQC available
for use. Please let me know if you would like the Corps to evaluate this project for use of RPG50; NCDOT would
like to request that the Corps evaluate this project under the RGP50.
2) Please provide a detail to describe the proposed floodplain benches. Details of interest include that material the
benches will be constructed/backfilled with, the materials on the bench itself that will be used for stabilization
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(e.g. matting, etc.), and vegetative stabilization to be used (e.g. riparian/wetland seed mix, annual seed only,
etc.); Dave, the following is the description of the flood plain benches which was at the bottom of page 6. Will
this suffice?

3) Although the proposed permanent loss stream impacts are below the thresholds typified in NWP 14 Regional
Condition B.7, compensatory mitigation is required to ensure minimal adverse environmental effects in
accordance with the Corps letter dated 9/1/2004, and NCDOT's corresponding letter dated 10/19/2004,
addressing mitigation requirements for NCDOT projects. Accordingly, please submit a compensatory mitigation
plan. The mitigation rule generally prescribes purchasing stream credits first through a mitigation bank with
stream credits available in this 8-digit HUC (03030002), or second through the NC Division of Mitigation Services;
please provide a statement of availability letter from your proposed compensatory mitigation provider.
Typically, compensatory mitigation is required at a 2:1 credit to impact ratio for permanent loss stream impacts
unless otherwise justified based on evaluation of aquatic function. See attached.

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: NCDOT_REG <[e-mail]>
Sent: Friday, June 24, 2022 8:31 AM
To: [e-mail]
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Matthews, Monte K CIV USARMY
4

CESAW (USA) <[e-mail]>
Subject: SAW-2019-01257 (NCDOT / Bridge 183 / SR2710 / Running Creek Road / Guilford County / Greensboro NC)

Good Morning,

We have received your Pre-Construction Notification (PCN) NWP request for the above project and forwarded it to Dave
Bailey for further processing.

Thank you,
Josephine Schaffer

From: [e-mail] <[e-mail]>
Sent: Thursday, June 23, 2022 4:49 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 6/23/2022 4:46 PM for Running Creek Road Bridge Replacement. The link below will
take you to the project folder.

https://edocs.deq.nc.gov/Laserfiche/index.aspx?db=WaterResources#id=2384136;view=browse

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responses aren’t monitored.

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Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
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