HomeMy WebLinkAbout20200024 Ver 1_USACE More Info Requested_20200122Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <David.E.Bailey2@usace.army.mil>
Sent: Wednesday, January 22, 2020 11:04 AM
To: Brad Luckey; eric@ldequity.com
Cc: Homewood, Sue
Subject: [External] Request for Additional Information; Quarry Hills s/d, Swepsonville,
Alamance Co.; SAW-2019-02210
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Brad,
Thank you for your PCN and attached information, dated and received 12/23/2019, 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Permit or consider your application withdrawn and close the file: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) The Corps will consider all proposed/foreseeable impacts for this development as cumulative when considering
Nationwide Permit (NWP) and compensatory mitigation thresholds. Based on your proposed impacts for Phase
1 as well as the conceptual plans for future phases, the project would not fit within acreage thresholds for NWP
29. Specifically, cumulative impacts would include proposed impacts to wetland WPA (0.243 ac.) and Stream ISF
(41 If or 0.004 ac.), and conceptual impacts to all of Pond PF (-0.37 ac.) and Wetland WF (-0.059 ac.), and
portions of (proposed impacts unknown) Stream SB, Stream SD3, and Wetland WD 1-13/WDA 1-12. You may
apply for the entirety of this phased development via the Individual Permit process. Or, as an alternative, you
may further avoid or minimize impacts proposed in Phase 1 and/or amend the conceptual design to show that
full build out of this development would fit within the NWP impact thresholds;
2) Please provide drawings that clearly show the drainage/stormwater plans for Phase 1 of this project. We will use
these plans to ensure that the remaining portions of Wetland WPA and Stream ISF would retain hydrologic input
following grading of the site. For example, culverts currently discharge into the heads of these features. Would
the remainder of these features still have the same/similar drainage flowing to them at the limits of the
proposed fill? If culverts currently carrying flow to these feature will still discharge into these features, please
clearly show on the plans, and also provide profile drawings showing culvert elevation vs. existing
wetland/stream bed along with any rip rap proposed. If existing drainage would be routed around any portion of
the remaining features, please note that we will likely consider indirect impacts to the portion of those features
affected;
3) It appears that Wetland WH may be impacted by Lots 244/245; please provide a zoomed in grading plan for this
area showing the limits of proposed fill along with the verified wetland delineation. Further, a sewer easement is
shown extending through this wetland. Is this an existing sewer line? If not, please provide justification that
wetland impacts would be avoided, or provide proposed impacts for this crossing in the revised PCN/plans;
4) The Overall Site Impact Map currently shows two proposed stream crossings in future phases of the
development: a road in Phase 1 East extending across Stream SIB, and a recreational road extending across
Stream SD3. In order to evaluate cumulative stream impacts for all phases of the Quarry Hills development, and
in particular consideration of the compensatory mitigation threshold for streams, please provide a reasonable
estimate of stream fill required for these future crossings. Please note, if it is reasonably foreseeable that
cumulative stream impacts would exceed the NWP compensatory mitigation thresholds (NWP 29 Regional
Condition 3.2), we would require compensatory mitigation for stream impacts proposed in Phase 1 unless
otherwise justified by a functional assessment of that resource (i.e. NCSAM evaluation);
5) Per Wilmington District Public Notice dated 4/21/2015, please provide a functional assessment (i.e. NCWAM) for
Wetland WPA to justify a reduced compensatory mitigation ratio;
6) Please note that the future phase recreational road extending across Stream SD3 and Wetland WD 1-13/WDA 1-
12 would occur within the 100 year floodplain. As such, any such impacts resulting in permanent above -grade
fills could not be authorized via NWP 29 (NWP 29 Regional Condition 4.1.4).
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: (919) 554-4884, Ext. 30.
Fax: (919) 562-0421
Email: David. E.Bailey2@usace.army.miI
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