20170239 Ver 1_Permit Application for U-3109B and U-3109A Modification Alamance County_20180517

Carpenter,Kristi
From: Bailey, David E CIV USARMY CESAW (US)
<[e-mail]>
Sent: Thursday, May 17, 2018 12:18 PM
To: Dagnino, Carla S
Cc: Norton, Apri) R
Subject: [External] RE: Permit Application for U-3109B and
U-3109A Modification Alamance County
CAUTION: External email. Do not click links or open attachments unless verified. Send all
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Hi Carla, and thank you for your Application for Modification to Phased Permit
Application for Section 404 Individual Permit and Section 401 Water Quality
Certification and attached information, dated and received 5/4/2018, for the above
referenced project. I have reviewed the information and need clarification before
proceeding with modifying the Department of the Army (DA) permit for U-3109 (Action
ID: SAW-2002-20667), dated June 27, 2017. Please submit the requested information
below (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we may
deny the permit modification request or consider your application withdrawn and close
the file:
1) U-3109B Site 3 proposes 22 I.f. of in-channel rip rap, however no compensatory
mitigation is proposed. As was discussed at the Concurrence Point (CP) 4B and 4C
meetings, in-channel rip rap in Stream SB will require compensatory mitigation due to
loss of aquatic function. Based on my site visits and inclusion of the downstream reach
in NCDOTs future proposed Cates Farm permittee responsible mitigation site, Stream SB
is a high quality resource. Furthermore, based on CP 4B and 4C discussions, the rocky
nature of the stream bed made it unlikely that the rip rap could be keyed into the
stream bed successfully. Lastly, during CP 4B and 4C NCDOT indicated that above grade
rip rap would likely be necessary in this location to dissipate velocity of water flowing
into the mitigation reach of Stream SB given the high slope of the valley. For these
reasons, a 2:1 mitigation to impact ratio is reasonable. Please update the permit mod
request accordingly;
2) Site 4 plans appear to show the outlet of the proposed culvert and downstream rip
rap pad to align at a skew with the existing stream bed. Please update plans and impacts
to allow the proposed structures to outlet in alignment with the existing downstream
section of the tributary. If the alignment is correct, please explain the alignment as
shown on the plans;
3) For Site 6, as discussed during CP 4C, please provide a detail showing the elevation of
the bottom of the lateral V ditch and invert of the 30" pipe at its upstream intersection
with Wetland WB, relative to existing ground surface. The purpose of this information is
to justify weather or not this ditch will have a drainage effect on Wetland WB beyond
the lateral extent of the proposed mechanized clearing impacts.

4) You propose to provide compensatory mitigation for U-3109B entirely through
purchasing stream and wetland credits from NCDMS. This is an acceptable method of
proving compensatory mitigation, per the second tier of the compensatory mitigation
hierarchy (33 CFR Part 332(b)). However, you also note that you plan to request another
modification to the DA permit consisting of replacement of the plan to use NCDMS
credits, and instead propose to use the third tier of the compensatory mitigation
hierarchy, permittee-responsible mitigation. Note that it would be your responsibility to
clearly and specifically explain why use of permittee-responsible mitigation is
environmentally preferable to using NCDMS credits.
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
Phone: [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:
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
-----Original Message-----
From: Dagnino, Carla S [mailto:[e-mail]]
Sent: Friday, May 4, 2018 2:34 PM
To: Bailey, David E CIV USARMY CESAW (US) <[e-mail]>;
Chapman, Amy <[e-mail]>
Cc: AI-Dhalimy, Nadia A<[e-mail]>; AI-Ghandour, Majed N
<[e-mail]>; Barclay, Carl A <[e-mail]>;
[e-mail]; Hanks, Brian <[e-mail]>; Carpenter,Kristi
<[e-mail]>; Lauffer, Matthew S <[e-mail]>;
Mellor, Colin <[e-mail]>; Mills, James M<[e-mail]>; NCDOT
Service Account - Roadway Design <[e-mail]>; Norton, April R
<[e-mail]>; Parker, Jerry A<[e-mail]>; Staley, Mark K
<[e-mail]>; Wilson, Travis W. <[e-mail]>; Harmon, Beth
<[e-mail]>; Zerman, William S <[e-mail]>
Subject: [Non-DoD Source] Permit Application for U-3109B and U-3109A Modification
Alamance County
The Phased Permit Application for U-3109B / Modification for U-3109A has been posted
to the NCDOT website. The electronic copy can be viewed / downloaded at

Blockedhttps://connect.ncdot.gov/resources/Environmental/
<Blockedhttps://connect.ncdot.gov/resources/Environmental/>
Named: U-3109B Phased IP and U-3109A Mod Alamance May 4 2018
This email serves as NCDOT's permit application submittal to the NC Division of Water
Resources.
A hard copy will be provided to the US Army Corp of Engineers.
Thankyou!
Carla Dagnino
Western Region Environmental Program Supervisor II
Environmental Analysis Unit
NC Department of Transportation
919 707 6110 office
[e-mail] <mailto:[e-mail]>
1598 Mail Service Center
Raleigh, NC 27699 -1598
1020 Birch Ridge Drive
Raleigh, NC 27610

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Email correspondence to and from this sender is subject to the N.C. Public Records Law
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