20200102 Ver 1_Request to Withdraw_20200317

Strickland, Bev
From: Brad Luckey <[e-mail]>
Sent: Tuesday, March 17, 2020 7:23 AM
To: [e-mail]; Homewood, Sue
Cc: Patrick Donnelly
Subject: [External] RE: Request for Additional Information; Air Harbor Road site, Greensboro,
Guilford Co.; SAW-2020-00125
• r External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ort.s am nc. ov
David and Sue,
On behalf of the applicant, please withdraw the PCN request for NWP Verification and 401 WQC for the above
project. Impacts to waters are not proposed at this time. Thank you for your assistance.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.oilotenviro.com loilotenviro.com
[e-mail]
From: Bailey, David E CIV USARMY CESAW (USA) [mailto:[e-mail]]
Sent: Friday, February 21, 2020 4:24 PM
To: Brad Luckey <[e-mail]>; Patrick Donnelly <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: RE: Request for Additional Information; Air Harbor Road site, Greensboro, Guilford Co.; SAW-2020-00125
Hi Brad, and thanks for your response to our request for additional information for the above referenced project that
you submitted on 2/13/2020. Pertaining to my concerns regarding item #1, 1 appreciate your description and illustration
of the applicant's previous designs and reductions in proposed impacts by the time you submitted the PCN. My
remaining concerns are based on the design that was submitted, and what appear to be additional ways that stream and
wetland impacts could be minimized or avoided altogether by small reductions in the number of units proposed and/or
other commonly used methods to shorten fill slopes. My comments are based on NWP 29 General Condition 23(a),
which requires that "The activity must be designed and constructed to avoid and minimize adverse effects, both
temporary and permanent, to waters of the United States to the maximum extent practicable at the project site."
Practicable, for our purposes refers to measures that are "Available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of overall project purposes."
As such, would it be practicable to shift the hammerhead turnaround north by eliminating between 2 and 4 residential
units? It is not clear that project viability is dependent on the inclusion of these 2-4 units, when the overall development
proposes 104. Include in your response the practicability of using retaining walls, possibly in combination with
eliminating 2 units, to accomplish additional avoidance and minimization of stream and wetland impacts. If the above or
similar avoidance and minimization actions are not practicable, please clearly explain the reasons (i.e. specific
engineering constraints, setback requirements, etc.).

Hopefully this correspondence clarifies my concerns.
Please submit the requested information above (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.
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 [corpsmapu.usace.army.mill
Thank you for taking the time to visit this site and complete the survey.
From: Bailey, David E CIV USARMY CESAW (USA)
Sent: Tuesday, February 11, 2020 8:34 AM
To: Brad Luckey <[e-mail]>; Patrick Donnelly <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: Request for Additional Information; Air Harbor Road site, Greensboro, Guilford Co.; SAW-2020-00125
Messrs. Luckey and Donnelly,
Thank you for your PCN and attached information, dated and received 1/14/2020, 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 [saw-reg.usace.army.mill)• 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 proposed project includes fill in stream and wetland areas at the southern margins of the tract due to a
hammerhead turnaround for emergency vehicle use. The need for such access is not disputed, however you
have not demonstrated avoidance and minimization to the maximum extent practicable as required by NWP
General Conditions 23(a) and (b). For example, it appears that all impacts to wetlands and streams could be
avoided if the hammerhead turnaround were shifted to the north by eliminating between 2 and 4 residential
units. It is not clear that project viability is dependent on the inclusion of these 2-4 units, when the overall
development proposes 104. Further, retaining walls could also be used, possibly in combination with eliminating
2 units, to avoid and minimize impacts. Please provide additional information to this effect, including updates to
the PCN/plans as necessary;
2) Based on the project plans, approximately 30% of the drainage area for downstream portions of Stream SB
would be rerouted to a stormwater pond due to grading. How will this stream retain hydrology to remain
jurisdictional/functional?

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: David. [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 fcorpsmapu.usace.army.mill
Thank you for taking the time to visit this site and complete the survey.