20200244 Ver 1_ATC COE 03092020_20200316

2725 East Millbrook Road
Suite 121
Raleigh, NC 27604
Tel: [phone]
Fax: [phone]
www.atcassociates.com

March 9, 2020

G. Lyle Phillips Email: [e-mail]
Regulatory Specialist
US Army Corps of Engineers
CE-SAW -RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 25.
Fax: [phone]

CC: Stephanie Z. Goss Email: [e-mail]
Environmental Specialist II
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
919-791-4256

RE: Revised PCN Application
Belmont Subdivision
Wake County, NC
Belmont Phase 5 / SAW-2008-01986

ATC Job Number- HJGA1901

Dear Mr. Phillips:

At your request, ATC Atlas has revised the PCN to address the comments in your email of 03-05-20. The
comments are addressed below in red and have been incorporated into the revised PCN.

1) Under conditions of nationwide permit 29 an application/pre-construction notification is considered complete
only if the activity is deemed a single and complete project. For non-linear projects “single and complete” is
defined as the total proposed or accomplished by one owner/developer or part nership, and must have
independent utility. Single and complete non-linear projects may not be “piecemealed”. Based on the information
provided in your PCN the proposed project is dependent on the existing Belmont Subdivision, therefore the
impacts from past phases must be considered together before we are able to authorize a Department of the Army
permit for the proposed project. The total impacts were mentioned in the previous submittal but are now included
in this revision.

2) For any NWP that results in a loss of more than 150 linear feet of stream, the permittee shall provide a
mitigation proposal to compensate for more than minimal individual and cumulative adverse impacts to the
aquatic environment. Mitigation will be accomplished by payment into the In-Lieu Fee Program.

3) In order to verify use of a NWP a PCN must include a delineation of wetlands, other special aquatic sites, and
other waters, such as streams. Wetland delineations must be prepared in accordance with the current method
required b y the Corps. The permittee may ask the Corps to delineate the special aquatic sites and other waters
on the project site, but there may be a delay if the Corps does the delineation. The 45 day period will not start until
the delineation has been submitted to or completed by the Corps. A new delineation has been completed and is
attached for Phase 5. The delineation by ATC for the entire project of 99.82 acres which was completed in August
2007 and approved for the NWP issued in 2008 is attached to the new delineation.

Revised PCN Application
Belmont Subdivision
Wake County, NC
Belmont Phase 5 / SAW -2008-01986
Page 2 of 2

4) Based on the delineation provided in association with the application for Belmont Subdivision Phases 1 - 4 it
appears wetlands were delineated September 2008 in the general location of the proposed road crossing. If the
proposed project will result in wetland impacts please update the PCN and exhibits accordingly. Please note that
compensatory mitigation will be required for all wetland losses that exceed 1/10 -acre. The wetlands delineated in
2007 for the 2008 NWP are below the Buffaloe Partners Property. A new delineation and stream determination
from 9/26/19 and 10/3/19 is attached. There are no wetlands (except the stream bank to bank) which will be
impacted in the new construction.

5) 0.02 acres of wetland impacts are proposed in Section C.2 on the PCN submitted. There are no wetlands or
wetland impacts depicted on the submitted Impact exhibits. Please revise and update the PCN and exhibits
accordingly. There will be no wetlands impacts except the stream bank to bank. The PCN has been revised
accordingly.

6) Based on the information in the PCN and other experiences with similar crossings, it appears that 65 linear feet
of rip rap dissipater pad is more than minimal. Please submit additional information regarding the need for such a
long pad (i.e. calculations for velocities at the outlet demonstrating the need for a pad that is almost as long as the
culvert itself), the need for its placement within the stream bed and not just along the banks, and how the crossing
complies with NWP General Condition 23 (a) and (b), requiring the avoidance and minimization of adverse effects
to the maximum extent practicable. Note that the Corps is considering requiring compensatory mitigation for this
impact given the likely reduction in aquatic function in the proposed rip rap footprint. This has been revised and is
attached.

7) Please provide profile views (i.e. along the culvert) and cross section views of the proposed stream crossing.
The crossings must comply with NWP Regional Condition 4.1.6, ensuring that any rip rap placed in the stream
channel will be imbedded or “keyed” into the stream bed such that low flow water flows on top of the rip rap rather
than under it. Revised and attached.

If you have questions or require further information concerning the recommendations in this report please call us
at our business office at [phone].

Respectfully,
ATC associates of North Carolina, PC
Mike Harwood, PE Benjamin V. Wilson, PE
Project Manager Principal Engineer

Attachments: Revised PCN

Separate Enclosure: Wetlands and Stream Delineation