20200103 Ver 1_More Info Received_20200228

Strickland, Bev
From: Brad Luckey <[e-mail]>
Sent: Friday, February 28, 2020 10:15 AM
To: [e-mail]; Patrick Donnelly
Cc: Homewood, Sue; Spencer Burnett
Subject: [External] RE: Request for Additional Information; Carraway s/d, Summerfield, Guilford
Co.; SAW-2020-00026
• r External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Good Morning David,
Please find the applicant response below. Let me know if you need anything additional. Thanks.
USACE Comment 1) 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 changes to the road alignment. 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 Michaelis Street to the east to accomplish additional avoidance and
minimization of stream and wetland impacts? The Corps is comfortable with the number of overall lots proposed to be a
minimum constraint in this case. So, could such a road realignment be accomplished such that the number of lots would
be maintained? If not, please explain why this is not practicable (i.e. specific engineering constraints, setback
requirements, etc.).
Applicant Response: The applicant has evaluated further avoidance and minimization measures by altering the
alignments of Michaelis Street and Wolfsheim Place. If the alignments of the aforementioned roads and their
intersection was designed to avoid or further minimize impacts to WoUS, then Lots 5, 6 & 29 would be eliminated from
the development because they would not meet the local zoning requirement of 30,000 square foot lots. The applicant
has already reduced the number of lots to the maximum amount possible to avoid impacts to WoUS. Further reduction
of lots and/or re -alignment of the aforementioned roads is not possible.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]

From: Bailey, David E CIV USARMY CESAW (USA)[maiIto: David. [e-mail]]
Sent: Friday, February 21, 2020 4:11 PM
To: Patrick Donnelly <[e-mail]>; Brad Luckey <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Spencer Burnett <[e-mail]>
Subject: RE: Request for Additional Information; Carraway s/d, Summerfield, Guilford Co.; SAW-2020-00026
Hi Brad, and thanks for your response to our request for additional information for the above referenced project that
you submitted on 2/12/2020. 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 changes to the road alignment. 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 Michaelis Street to the east to accomplish additional avoidance and
minimization of stream and wetland impacts? The Corps is comfortable with the number of overall lots proposed to be a
minimum constraint in this case. So, could such a road realignment be accomplished such that the number of lots would
be maintained? If not, please explain why this is not practicable (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
Thank you for taking the time to visit this site and complete the survey.
From: Bailey, David E CIV USARMY CESAW (USA)
Sent: Wednesday, February 12, 2020 1:28 PM
To: Spencer Burnett <[e-mail]>; Patrick Donnelly <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: Request for Additional Information; Carraway s/d, Summerfield, Guilford Co.; SAW-2020-00026

Messrs. Burnett 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). 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 for a road crossing (Impact 1). 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 road were shifted to the east and redesigning the affected lot
shapes/lines (e.g. Lots 2-5, 26-30, etc.). It is not clear that the overall lot number would be reduced or that
project viability would suffer through such changes. Please provide additional information to this effect,
including updates to the PCN/plans as necessary;
2) Based on the project plans, much of the drainage area for Stream SAA could be rerouted away from
downstream portions of Stream SAA due to grading. How will this stream retain hydrology to remain
jurisdictional/functional? Perhaps a grading plan would be beneficial in answering this question.
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.