20200123 Ver 1_USACE Correspondence_20200203

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, February 3, 2020 8:42 AM
To: Tinklenberg, Chris
Cc: Homewood, Sue
Subject: [External] RE: High Point University - Panther Drive Relocation
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Hi Chris, and thanks for your email. I apologize for my delayed response. Assuming you can justify low aquatic function
(NCSAM), I would not require compensatory mitigation for impacts to feature S4 as you described.
You're right about cumulative impacts though, and I'm glad the previous HPU permit notes/conditions were reviewed. In
most circumstances we would not retroactively require compensatory mitigation for impacts previously authorized
under NWPs. As such, the remaining compensatory mitigation question would pertain to the other —20 If culvert
extension. If the functional quality of this feature warrants compensatory mitigation, then we would require
compensatory mitigation (for that 20 If impact only) at 2:1, unless a reduced ratio is justified based on reduced aquatic
function (NCSAM).
Hopefully this helps. 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: Tinklenberg, Chris [mailto:[e-mail]]
Sent: Thursday, January 16, 2020 11:37 AM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Subject: [Non-DoD Source] RE: High Point University - Panther Drive Relocation
David - my apologies.... there are 2 culvert extension locations. The other is —20 If. Please consider this as well in your
response.

Thanks,
Chris
Chris Tinklenberg, PWS
Kimley-Horn 1 200 South Tryon Street, Suite 200, Charlotte, NC 28202
Direct: 704 409 1802 1 Mobile: [phone]
-----Original Message -----
From: Tinklenberg, Chris
Sent: Thursday, January 16, 2020 11:03 AM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Subject: RE: High Point University - Panther Drive Relocation
Good morning David,
I hope you're doing well. I just have a couple of quick mitigation question for you. We discussed this over the phone, but
just to refresh your memory, we will be proposing to remove an existing 56 If culvert under Panther Drive (along
Boulding Branch), perform approximately 225 If of stream restoration on Boulding Branch including through the section
of removed culvert, and then dropping a 50 If bottomless arch culvert (Conspan) over a section of the restored portion
of stream. All of that work will request authorization under NWP 27. As of this email, it looks like we may need to
extend an existing culvert on a small trib that would result in approximately 15 If of permanent impact. The civil
engineer mentioned that a previous project resulted in approximately 148 If of impacts, so they did not pay any
mitigation, but you communicated that for any future impacts, mitigation would be required .... so here are my questions:
-Since we are removing the existing 561f of piped stream and restoring —225 in its place, can we offset the minor
stream impacts associated with the culvert extension to avoid mitigation? If not,
-Will we need to pay for the cumulative impacts to this point? So, 148 If for the previous project and —15 If for this
project, 163 If total?
Just FYI, the culvert extension is only necessary to match the grading for the stream restoration. It's S4 on the attached
PJD map, which is essentially a stormwater outfall but has at least seasonal baseflow, is heavily degraded and rip -rap
lined. I've attached a couple of photos for reference as well.
Please let me know if you have any questions. We plan to submit PCN towards the beginning of next week. This is really
the last unknown piece.
Thanks,
Chris
Chris Tinklenberg, PWS
Kimley-Horn 1 200 South Tryon Street, Suite 200, Charlotte, NC 28202
Direct: 704 409 1802 1 Mobile: [phone]
-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, December 12, 2019 2:10 PM
To: Tinklenberg, Chris <[e-mail]>; [e-mail]
Cc: Maschoff, Jake<[e-mail]>; Lasitter, Addie <[e-mail]>
Subject: RE: High Point University - Panther Drive Relocation
Sounds good, Chris. Thanks.
-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: David. [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
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-----Original Message -----
From: Tinklenberg, Chris [mailto:[e-mail]]
Sent: Thursday, December 12, 2019 12:04 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; [e-mail]
Cc: Maschoff, Jake <Jake.Maschoff @kimley-horn.com>; Lasitter, Addie <[e-mail]>
Subject: [Non-DoD Source] RE: High Point University - Panther Drive Relocation
Thanks David! We have submitted a concurrence request to SHPO for their review. I'll be sure to forward their response
as soon as it is received.
Chris
Chris Tinklenberg, PWS
Kimley-Horn 1 200 South Tryon Street, Suite 200, Charlotte, NC 28202
Direct: 704 409 1802 1 Mobile: [phone]
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, December 10, 2019 7:44 AM
To: Tinklenberg, Chris <[e-mail]>; [e-mail]
Cc: Maschoff, Jake <Jake.Maschoff @kimley-horn.com>; Lasitter, Addie <[e-mail]>
Subject: RE: High Point University - Panther Drive Relocation
Hi Chris, and thanks for the email and attachments. Generally speaking, I am ok in this case with the utility work
proceeding ahead of the proposed road relocations, given that the complete project (including utility and roadway
components) should fit the constraints of the Nationwide Permit (NWP) program. Just as a note, however, I am

concerned that Note 8 on Pg. 3 of NWP 12 (Blocked Blockedhttp://saw-reg.usace.army.mil/NWP2017/2017NWP12.pdf
<BlockedBlockedhttps://nam03.safelinks.protection.outlook.com/?url=http%3A%2F%2Fsaw-
reg.usace.army.mil%2FNWP2017%2F2017NWP12.pdf&data=02%7C01%7CChris.Tinklenberg%40kimley-
horn.com%7COad18c30461444c8937308d77d6eb325%7C7e220d300b5947e58a81a4a9d9afbdc4%7CO%7C1%7C637115
786743478188&sdata=UgLP7Z2csjUYMhfi%2Beav8rRq%2FIDuMGIxSnRz8LfyAfo%3D&reserved=0> ) suggests that
constructing the utility line portion first as a non -reporting NWP 12 may not conform to the intent of the Regulations.
One issue to get cleared up right away, is that the proposed work (utilities, road alignment, etc) would take place
directly adjacent to the High Point College Historic District (GF0627; National Register Study List), and there are several
houses along the proposed limits of disturbance that may be potentially eligible (due to age) for the National Register of
Historic Places; unfortunately we didn't discuss this aspect during our phone call. Given the requirements of NWP
General Condition 32(b)(8), a PCN is required if "the NWP activity might have the potential to cause effects to a historic
property listed on, determined to be eligible for listing on, or potentially eligible for listing on, the National Register of
Historic Places."
I strongly recommend that you start the coordination process with SHPO now to get these questions answered; SHPO
usually takes 30 days to respond to such requests. Certainly the Corps can coordinate with SHPO per the usual process,
but we'll need a PCN to go that route. If you would like to discuss further I'm back in the office tomorrow through Friday.
-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]<maiIto: David. [e-mail]>

We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: BlockedBlockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
From: Tinklenberg, Chris [mailto:[e-mail]]
Sent: Friday, December 6, 2019 11:43 AM
To: [e-mail] <mailto:[e-mail]> ; Bailey, David E CIV USARMY CESAW (USA)
<[e-mail] <mailto: David. [e-mail]> >
Cc: Maschoff, Jake <[e-mail] <mailto:[e-mail]> >; Lasitter, Addie
<[e-mail] <mailto:[e-mail]> >
Subject: [Non-DoD Source] High Point University - Panther Drive Relocation
David and Sue,
Good morning, I hope you both have had a good week.
Sue, David and I spoke about this project over the phone a couple of weeks ago. My apologies for not having you looped
in until now, but you are familiar with the site for sure. You provided a buffer determination letter on February 5 of this
year (see attached).
The purpose of this project is to remove the at -grade greenway crossing and construct a greenway tunnel under Panther
Drive for pedestrian safety. This requires relocation of Panther Drive and modifications to two (2) existing culverts
under Panther Drive as well as minor modifications to the storm -drainage network and utility relocations. The
contractor is concerned about schedule (the project has to be completed before the start of the new school year) and is
requesting that they go ahead and get the utilities relocated prior to any road relocation work. David is seeing the
attachments for the first time as well, but based on our conversation, he thought that it would be ok to move forward
with the temporary stream impacts to opencut, backfill and stabilize banks without notification. The attached
preliminary plans illustrate the proposed work. The profiles indicate that rip -rap will be keyed into the channel bed as
part of the stabilization activities; however, we will remove this note from the plan and include stream stabilization work
in the forthcoming PCN in order to eliminate the permanent impact. All buffer impacts associated with the utility
relocates will be perpendicular. I included a GIS figure to provide a bit more clarity.
Can you both please review the attached information at your earliest convenience and confirm that the utility
relocations can be completed without notification? Once confirmed, I would like to send over the preliminary plans for
the culvert and storm drainage modifications and schedule a call to discuss a detailed permitting approach.
If you have any questions, please let me know. Please 'reply -all' to this and future correspondence.

Thanks,
Chris
Chris Tinklenberg, PWS
Kimley-Horn 1 200 South Tryon Street, Suite 200, Charlotte, NC 28202
Direct: 704 409 1802 1 Mobile: [phone] Blocked Blocked Blockedwww.kimley-horn.com
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