20191660 Ver 1_More Info Received_20200116

Strickland, Bev
From: [e-mail]
Sent: Thursday, January 16, 2020 9:36 PM
To: Homewood, Sue; [e-mail]; [e-mail]
Cc: [e-mail]; [e-mail];
[e-mail]; [e-mail]
Subject: RE: [External] Request for Additional Information: Penry Crossing, Greensboro,
Guilford Co., NC; SAW-2010-01793
Attachments: PCN1-4StreamPermitCompleteRevised(1-16-20).pdf, 19-036-274 NCDEQ
RESPONSE- 1 - 1 6-20.pdf, 19-036-274 US ARMY CORPS RESPONSE(1-16-20).pdf;
19-036-274 Penry Road Sheets (1-16-20).pdf
Follow Up Flag: Follow up
Flag Status: Flagged
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Sue and David,
Please find attached the revised PNC, Drawings, comment response letter for the Army Corps comments, and
a comment response letter for NC DEQ's comments. If you have any questions please feel free to give us a
call.
Sincerely,
Juhann Waller, PE
Principal
191
A Minority Owned Engineering and Surveying Firm
7-L Dundas Circle
Greensboro, NC 27407
Tele# [phone]
jwaller(a-jcwaller.com
On Mon, 16 Dec 2019 17:03:21 +0000, "Homewood, Sue" <[e-mail]> wrote:
Please see attached
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
1

450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, December 3, 2019 4:20 PM
To: Jerome Myers <[e-mail]>; Juhann <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [External] Request for Additional Information: Penry Crossing, Greensboro, Guilford Co., NC; SAW-2010-01793
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Messrs. Myers and Waller,
Thank you for your PCN and attached information, dated 11/7/2019 (received 11/8/2019), for the above referenced
project. I have reviewed the information and need clarification before proceeding with verifying the use of Nationwide
Permit 29 http://saw-reg.usace.army.mil/NWP2017/2017NWP29.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Nationwide Permit or consider your application withdrawn and close the file: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. As discussed in the field on 8/13/2019, the purpose of the project is to provide access for a multi -family
residential development. However, the proposed wetland and stream impacts exceed those needed for access,
and include impacts proposed for parking facilities. Based on the Master Plan, it appears that additional
avoidance and minimization could be demonstrated (per Nationwide Permit General Conditions 23a and b)
whereby portions of the proposed development could be shifted east to avoid parking lot impacts within
streams and wetlands;
2. On the PCN, itemize stream impacts into three separate parts: permanent impacts due to the culvert,
permanent impacts due to rip rap (if proposed), and temporary impacts due to dewatering;
3. Is rip rap proposed to be placed within the stream channel? If so, show the rip rap on the plan and profile views,
and add this impact to the PCN (see item 2)above. Note that any rip rap placed within the stream channel must
be depressed/imbedded such that the top of the rip rap is no higher than the existing stream bed elevation (see
Regional Permit Condition 4.1.6);
4. Your proposed wetland impacts exceed 0.1 acre. Please revise your project to minimize your proposed wetland
impacts below the 0.1 acre threshold (see item 1 above). Otherwise, compensatory mitigation for wetland
impacts is required per Nationwide Permit General Condition 23c. Please provide a mitigation acceptance letter
from either a mitigation bank with the correct service area (HUC 03030002) or the NC Division of Mitigation
Services for riparian non-riverine wetland credits. Note that he Corps would require compensatory mitigation at
a 2:1 mitigation to impact ratio based on the relative quality of the wetlands proposed for impact.
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
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.

Office use Only:
Corps action ID no.
DWQ project no.
Form Version 1.4 January 2009
Pre -Construction Notification (PCN)
Form
A.
Applicant Information
1.
Processing
1 a.
Type(s) of approval sought from the Corps:
❑X Section 404 Permit
❑ Section 10 Permit
1 b.
Specify Nationwide Permit (NWP) number: 29 or General Permit (GP) number:
1c.
Has the NWP or GP number been verified by the Corps?
❑X Yes ❑ No
1 d.
Type(s) of approval sought from the DWQ (check all that apply):
❑ 401 Water Quality Certification — Regular ❑X Non-404
❑ 401 Water Quality Certification — Express X❑ Riparian
Jurisdictional General Permit
Buffer Authorization
1 e.
Is this notification solely for the record
because written approval is not required?
For the record only for DWQ
401 Certification:
❑ Yes ❑X No
For the record only for Corps Permit:
❑ Yes ❑X No
1f.
Is payment into a mitigation bank or in -lieu fee program proposed for
mitigation of impacts? If so, attach the acceptance letter from mitigation bank
or indieu fee program.
❑ Yes ❑X No
1 g.
Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below.
❑ Yes X❑ No
1 h.
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
❑ Yes ❑X No
2.
Project Information
2a.
Name of project:
402404 Penry Road Stream Crossing
2b.
County:
Guilford
2c.
Nearest municipality / town:
Greensboro
2d.
Subdivision name:
N/A
2e.
NCDOT only, T.I.P. or state project no:
N/A
3.
Owner Information
3a.
Name(s) on Recorded Deed:
Penry Crossing, LLC
3b.
Deed Book and Page No.
6956-1267
3c.
Responsible Party (for LLC if
applicable):
David Levy
3d.
Street address:
300 S. Greene Street, Suite 13-11
3e.
City, state, zip:
Greensboro, NC 27401
3f.
Telephone no.:
336-273-0568
3g.
Fax no.:
N/A
3h.
Email address:
[e-mail]
Page 1 of 10
PCN Form —Version 1.4 January 2009

4.
Applicant Information (if different from owner)
4a.
Applicant is:
❑ Agent ❑X Other, specify: Buyer
4b.
Name:
4c.
Business name
(if applicable):
Technology Row
4d.
Street address:
6151 Burlington Road #169
4e.
City, state, zip:
Sedalia, NC 27342
4f.
Telephone no.:
757-207-0529
4g.
Fax no.:
N/A
4h.
Email address:
[e-mail]
5.
Agent/Consultant
Information (if applicable)
5a.
Name:
Juhann Waller, PE
5b.
Business name
(if applicable):
JC Waller & Associates, PC
5c.
Street address:
7-L Dundas Circle
5d.
City, state, zip:
Greensboro, NC 27407
5e.
Telephone no.:
33M97-2637
5f.
Fax no.:
N/A
5g.
Email address:
[e-mail]
Page 2 of 10

B.
Project Information and Prior Project History
1.
Property Identification
1a.
Property identification no. (tax PIN or parcel ID):
PIN:7885631518
1b.
Site coordinates (in decimal degrees):
Latitude: 36,09309
Longitude:-79.725184
1c.
Property size:
6.33 acres
2.
Surface Waters
2a.
Name of nearest body of water to proposed project:
South Buffalo Creek
2b,
Water Quality Classification of nearest receiving water:
WS-V
2c.
River basin:
Cape Fear
3.
Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The site is undeveloped with trees and vegetation.
3b.
List the total estimated acreage of all existing wetlands on the property: 0.534
3c.
List the total estimated linear feet of all existing streams (intermittent
and perennial) on the property: 296.29
3d.
The
Explain the purpose of the proposed project:
propose of this project is for the installation of stream crossing for access to
the western portion of the property.
3e.
The
Describe the overall project in detail, including the type of equipment to be used:
current project is for installing a culvert in a portion of the existing stream that bi-sects the property for access and the future development.
4.
Jurisdictional Determinations
4a.
Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
project (includingall prior phases)in the past?
❑X Yes ❑ No ❑ Unknown
Comments:
4b.
If the Corps made the jurisdictional determination, what type
of determination was made?
El Preliminary Final ❑X
4c.
If yes, who delineated the jurisdictional areas?
Name (if known): Jim Cutler
Agency/Consultant Company: Pyramid Environmental
Other:
4d.
If yes, list the dates of the Corps jurisdictional determinations or
State determinations and attach documentation.
5.
Project History
5a.
Have permits or certifications been requested or obtained for
this project (including all prior phases) in the past?
El Yes ❑ No ❑X Unknown
5b.
If yes, explain in detail according to "help file" instructions.
6.
Future Project Plans
6a.
Is this a phased project?
❑X Yes ❑ No
6b. If yes, explain.
The intent is to install the culvert/stream crossing which will allow for the clearing
property with Multi -family units.
of the rear of the property. The second phase will be to develop the
Page 3 of 10
PCN Form —Version 1.4 January 2009

C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
❑X Wetlands ❑X Streams —tributaries ❑X Buffers ❑ Open Waters ❑ Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a.
Wetland impact
number
Permanent (P) or
Temporary
2b,
Type of impact
2c,
Type of wetland
2d,
Forested
2e.
Type of jurisdiction
Corps (404,10) or
DWQ (401, other)
2f.
Area of
impact
(acres)
W1 P
Culvert
Unknown
Yes
Corps
0.069
W2
Choose one
Yes/No
W3
Choose one
Choose one
Yes/No
W4
Choose one
Choose one
Yes/No
W5
Choose one
Choose one
Yes/No
W6
Choose one
Choose one
Yes/No
2g, Total Wetland Impacts:
0.069
2h, Comments:
Wetlands disturbances is required for the installation of the culvert/stream crossing.
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a.
Stream impact
number
Permanent (P) or
Temporary (T)
3b,
Type of impact
3c.
Stream name
3d,
Perennial (PER) or
intermittent (INT)?
3e.
Type of
jurisdiction
3f,
Average
stream
width
(feet)
3g.
Impact
length
(linear
feet)
S1 P
Culvert
unnamed tributary
PER
Corps
4
60
S2 T
Dewatering
unnamed tributary
PER
Corps
4
21
S3
Choose one
S4
Choose one
S5
Choose one
S6
Choose one
3h. Total stream and tributary impacts
81
3i, Comments:
A portion of the stream is being piped for access to the rear of the property.
Page 4 of 10
PCN Form —Version 1.4 January 2009

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. then individually list all open water impacts below.
4a.
Open water
impact number
Permanent (P) or
Temporary
4b,
Name of waterbody
(if applicable)
4c.
Type of impact
4d,
Waterbody
type
4e.
Area of impact (acres)
01
Choose one
Choose
02
Choose one
Choose
03
Choose one
Choose
04
Choose one
Choose
4f. Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If pond or lake construction proposed, then complete the chart below.
5a.
Pond ID number
5b,
Proposed use or
purpose of pond
5c.
Wetland Impacts (acres)
5d,
Stream Impacts (feet)
5e.
Upland
(acres)
Flooded
Filled
Excavated
Flooded
Filled
Excavated
P1
Choose one
P2
Choose one
5f. Total:
5g, Comments:
5h. Is a dam high hazard permit required?
❑ Yes ❑ No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If any impacts require mitigation, then you MUST fill out Section D of this form.
6a. Project is in which protected basin?
❑ Neuse ❑ Tar -Pamlico []Catawba ❑ Randleman ❑X Other: Cape Fear
6b,
Buffer Impact
number —
Permanent (P) or
—Temporary
6c.
Reason for impact
6d,
Stream name
6e,
Buffer
mitigation
required?
6f,
Zone 1
impact
(square
feet)
6g,
Zone 2
impact
(square
feet
B1 P
Culvert Crossing
unnamed Tributary
No
33215.34
11389,76
B2 T
Culvert Crossing
unnamed Tributary
No
3,403.7
2,987.8
B3
Yes/No
B4
Yes/No
B5
Yes/No
B6
Yes/No
6h. Total Buffer Impacts:
61619,04
41377,56
6i. Comments: Impacts are due to the culvert crossing for accessing the rear of the property.
Page 5 of 10

D.
Impact Justification and Mitigation
1.
Avoidance and Minimization
1 a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
The measures taken to avoid and/or minimize the proposed impact is to design and construction the roadway near the southern property line and
make the roadway perpendicular to the stream. In addition to the location 3:1 side slopes are utilized within the buffer area to minimize disturbance.
1b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
The construction techniques that will be utilized to avoid and/or minimize the impacts would be installing erosion control measures and installing the
culvert in the dry.
2.
Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a.
Does the project require Compensatory Mitigation for
impacts to Waters of the U.S. or Waters of the State?
❑ Yes ❑X No
2b.
If yes, mitigation is required by (check all that apply):
❑ DWQ ❑ Corps
2c.
If yes, which mitigation option will be used for this
project?
❑ Mitigation bank
El Payment to in -lieu fee program
❑ Permittee Responsible Mitigation
3.
Complete if Using a Mitigation Bank
3a.
Name of Mitigation Bank:
3b,
Credits Purchased (attach receipt and letter)
Type: Choose one
Type: Choose one
Type: Choose one
Quantity:
Quantity:
Quantity:
3c,
Comments:
4.
Complete if Making a Payment to In -lieu Fee Program
4a.
Approval letter from in -lieu fee program is attached.
❑ Yes
4b.
Stream mitigation requested:
linear feet
4c.
If using stream mitigation, stream temperature:
Choose one
4d.
Buffer mitigation requested (DWQ only):
square feet
4e.
Riparian wetland mitigation requested:
acres
4f.
Non -riparian wetland mitigation requested:
acres
4g.
Coastal (tidal) wetland mitigation requested:
acres
4h.
Comments:
5.
Complete if Using a Permittee Responsible Mitigation Plan
5a.
If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
Page 6 of 10
PCN Form —Version 1.4 January 2009

6.
Buffer Mitigation (State Regulated
Riparian Buffer Rules) — required by DWQ
6a.
Will the project result in an impact within a protected riparian buffer that requires
❑ Yes No
buffer mitigation?
6b.
If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
6c.
6d,
6e.
Zone
Reason for impact
Total impact
Multiplier
Required mitigation
(square feet)
(square feet)
Zone 1
3 (2 for Catawba)
Zone
2
1.5
6f. Total buffer mitigation required:
6g.
If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer
restoration, payment into an approved in -lieu fee fund).
6h.
Comments:
Page 7 of 10

E.
Stormwater Management and Diffuse Flow Plan (required by DWQ)
1.
Diffuse Flow Plan
1a.
Does the project include or is it adjacent to protected riparian buffers identified
❑ Yes
❑ No
within one of the NC Riparian Buffer Protection Rules?
1 b.
If yes, then is a diffuse flow plan included? If no, explain why.
❑ Yes
❑ No
2.
Stormwater Management Plan
2a.
What is the overall percent imperviousness of this project?
2b.
Does this project require a Stormwater Management Plan?
❑ Yes
No
2c.
If this project DOES NOT require a Stormwater Management Plan, explain why:
The project does not require a stormwater management plan due to the impacts are for access only and
less than 1 acre will be
disturbed.
2d.
If this project DOES require a Stormwater Management Plan, then provide a brief, narrative
description
of the plan:
2e.
Who will be responsible for the review of the Stormwater Management Plan?
City of Greensboro
3.
Certified Local Government Stormwater Review
3a.
In which localgovernment's jurisdiction is thisproject?
City of Greensboro
❑X Phase II
❑ NSW
3b.
Which of the following locally -implemented stormwater management programs
❑ USMP
apply (check all that apply):
❑ Water Supply
Watershed
❑ Other:
3c.
Has the approved Stormwater Management Plan with proof of approval been
El Yes
❑X No
attached?
4.
DWQ Stormwater Program Review
❑Coastal counties
❑HQW
4a.
Which of the following state -implemented stormwater management programs apply
❑ORW
(check all that apply):
❑Session Law
2006-246
[:]Other:
4b.
Has the approved Stormwater Management Plan with proof of approval been
❑ Yes
❑X No
attached?
5.
DWQ 401 Unit Stormwater Review
5a.
Does the Stormwater Management Plan meet the appropriate requirements?
❑ Yes
❑ No
5b.
Have all of the 401 Unit submittal requirements been met?
❑X Yes
❑ No
Page 8 of 10
PCN Form —Version 1.4 January 2009

F.
Supplementary Information
1.
Environmental Documentation (DWQ Requirement)
1a.
Does the project involve an expenditure of public (federal/state/local) funds or the
❑ Yes ❑X No
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
❑ Yes ❑ No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c.
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 NEPA or SEPA final approval
letter.)
❑ Yes ❑ No
Comments:
2.
Violations (DWQ Requirement)
2a.
Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards,
❑ Yes ® No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b.
Is this an after -the -fact permit application?
El Yes ❑X No
2c.
If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3.
Cumulative Impacts (DWQ Requirement)
3a.
Will this project (based on past and reasonably anticipated future impacts) result in
El Yes ❑X No
additional development, which could impact nearby downstream water quality?
3b.
If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact
analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
4.
Sewage Disposal (DWQ Requirement)
4a.
Clearly detail the ultimate treatment methods and disposition (non -discharge or discharge)
of wastewater generated from
the proposed project, or available capacity of the subject facility.
Page 9 of 10
PCN Form —Version 1.4 January 2009

5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or
❑ Yes ❑X No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act
0 Yes ❑ No
impacts?
5c. If yes, indicate the USFWS Field Office you have contacted.
Raleigh
5d, What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
NHP-data layer from ArcGis.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat?
❑ Yes F No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
No EFH resources In Guilford County
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
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
❑ Yes 0 No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
NC DCR GIS Viewer- accessed 11-1-19
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain?
❑ Yes ❑X No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination?
Guilford County GIS Viewer floodplain layer -accessed 11-1-19
, plicant/Agent's Signature
Applicant/Agent's Printed Name
Date
( rfl's signature is valid only if an authorization
letter from the applicant isprovided.)
J
Page 10 of 10

Waffer 6t Associates, PC
LEE
�
January 2, 2020
Sue Homewood
North Carolina Department of Environmental Quality
450 W. Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
RE: NC DEQ lst Round Comment Response for 402-404 Penry Road Stream Crossing
JC Waller &Associates Project Number: 19-036-274
Ms. Sue Homewood
Please find below our response to your comments issued on December 19, 2019.
1) Comment: Please provide the Division a copy of your response to the December 3, 2019
email from the U.S. Army Corps of Engineers (USAGE) requesting additional
information. [15A NCAC 02H.0502(c)].
Response: A copy of our response to the email on December 3, 2019 from the U.S Army
Corps of Engineers has been provided to the Division.
2) Comment: Please note that the City of Greensboro is the regulatory authority for the
Jordan Lake riparian Buffer Rule. Since the Project includes development activities
within the protected buffer that are not designated items within the Table of Uses 15A
NCAC 02B .0267, please provide a copy of the Buffer Approval from the City.
Response: The development activities of the project are now activities within the
protected buffer that are designated items within the Table of Uses 15A
NCAC 02B. 0267.
7-L D u�1 cCas Ciac Ce
Gree�ls6oro, NC 27407
P�n�ie9 i33rW9 "';7

Ms. Sue Homewood
North Carolina Department of Environmental Quality
RE: NC DEQ I" Round Comment Response for 402-404 Penry Road Stream Crossing
3) Comment: The PCN indicates that this project "does not require a stormwater
management plan". However, the justification for the requested impacts are for final
development. You may either request approval for access to the property for another
purpose (please note that avoidance and minimization is determined based on the project
purpose), or update Section E. of the PCN form to indicate the project is for development.
A stormwater management plan reviewed and approved by the local government us a
requirement of Condition I.5 of 401 Water Quality Certification #4139,
Response: Approval for access to the property for another purpose has been requested.
If you have any questions, please feel free to give me a call at [phone].
Sincerely,
uhann Waller, PE
Project Manager
CC: David Bailey, PWS
Jerome Myers, PE
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1 Va[fer & Associates, PC
January 29 2020
Mr. David E Bailey, PWS
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 150
Wake Forest, North Carolina 27601
RE: US Army Corps of Engineers lst Round Comments Response for Penry Crossing,
Greensboro, Guilford Co., NC
SAW-2010-01793
JC Waller &Associates Project Number: 19-036-274
Mr. David Bailey
Please find below our response to your comments issued on December 3, 2019.
1) Comment: As discussed in the field on 8/13/2019, the purpose of the project is to provide
access for a multi -family residential development. However, the proposed wetland and
stream impacts exceed those needed for access, and include impacts proposed for parking
facilities. Based on the Master Plan, it appears that additional avoidance and
minimization could be demonstrated (per Nationwide Permit General Conditions 23a and
b) whereby portions of the proposed development could be shift east to avoid parking lot
impacts within streams and wetlands;
Response: The proposed development has been shifted east to avoid parking lot impacts
within streams and wetlands.
2) Comment: On the PCN, itemize stream impacts into three separate parts: permanent
impacts due to the culvert, permanent impacts due to rip rap (if proposed), and temporary
impacts due to dewatering;
Response: The stream impacts have been itemized into two separate parts: permanent
impacts due to culvert and temporary impacts due to dewatering. There is no
rip rap proposed.
7-L Duw.das Ci.tcle
Greens6oro, :NC 2,•4Q7
P(ujue* (3 6) 6N1 2G;7

Mr. David E. Bailey, PWS
US Army Corps of Engineers
RE: Penry Crossing, Greensboro, Guilford Co., NC
3AW-2010-01793
3) Comment: Is rip rap proposed to be placed wn the stream channel? If so, show the rip
rap on the plan and profile views, and add the impact to the PCN (see item 2) above. Note
that any rip rap placed within the stream channel must be depressed/imbedded such that
the top of the rip rap is no higher than the existing stream bed elevation (see Regional
Permit Condition 4.1.6);
Response: There is no rip rap proposed to be placed in the stream channel.
4) Comment: Your proposed wetland impacts exceed 0.1 acre. Please revise your project to
minimize your proposed wetland impacts below the 0.1-acre threshold (see item 1
above). Otherwise, compensatory mitigation for wetland impacts is required per
Nationwide Permit General Condition 23c. Please provide a mitigation acceptance letter
from either a mitigation bank with the correct service area (HUC 03 03 0002) or the NC
Division of Mitigation Services for riparian non-riverine wetland credits. Note that he
Corps would require compensatory mitigation at a 2:1 mitigation to impact ratio based on
the relative quality of the wetlands proposed for impact.
Response: With the eastward shift of the proposed development, the proposed wetland
impact is less than 0.1 acre.
If you have any questions, please feel free to give me a call at [phone].
Waller, PE
Project Manager
Attachment
Co
Sue Homewood
Jerome Myers, PE

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