20200376 Ver 1_USACE Request for More Info_20200324

Strickland, Bev
From: Roden Reynolds, Bryan K CIV (US) < [e-mail] >
Sent: Tuesday, March 24, 2020 8:17 AM
To: [e-mail]
Cc: [e-mail]; Homewood, Sue
Subject: [External] SAW-2020-00523_Broken Saddle (Notice of Incomplete Pre -Construction
Notification)
Attachments: 2017NWP03.pdf
Importance: High
Follow Up Flag: Follow up
Flag Status: Completed
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[e-mail]
Mr. Hortsman,
On March 16, 2020, we received the Pre -Construction Notification you submitted on behalf of the Town of Kernersville
on a property located in Forsyth County, North Carolina. I have completed my initial review of the report and I have
determined that it is incomplete. The following information is necessary before I will issue a determination:
a. The PCN did not contain a signed Agent Authorization Form between the applicant (i.e., Wendi Hartup of the
Town of Kernersville) and the consultant (i.e., March Horstman of WK Dickson). Therefore, please provide a
signed Agent Authorization form between applicant and consultant;
b. In the PCN, Section D(3) Stream Impacts and the Figure labeled "Impact Map" depicts the proposed impacts
for the project. However, there are discrepancies between these two sources. Please clarify and accurately
represent the proposed impacts. Below is the impacts as described in the PCN;
Proposed Impact
Reason for Impact
Impact Type
(Permanent or
Temporary)
Table in PCN
(Section D)
Impact Map
S1
Bank stabilization
Permanent/Temporary
10 linear feet
(Permanent)
10 linear feet
(Temporary)
S2
Bank stabilization
Permanent
70 linear feet
65 linear feet
S3
Riffle grade control
Temporary
10 linear feet
10 linear feet
S4
Bank Stabilization
Permanent/Temporary
9 linear feet
(Permanent)
9 linear feet
(Temporary)
S5
Culvert extension
Permanent
40 linear feet
35 linear feet
S6
Riffle grade control
Temporary
10 linear feet
65 linear feet
PROPOSED PERMANET IMPACTS
129 LINEAR FEET
100 LINEAR FEET
PROPOSED TEMPORARY IMPACTS
20 LINEAR
FEET
94 LINEAR FEET
TOTAL STREAM IMPACTS
1 149 LINEAR FEET
194 LINEAR FEET
c. The riffle grade control proposed at Broken Saddle Lane is proposed as 10 linear feet of temporary impacts.
Please describe the type of riffle grade control that will be placed as proposed and to why it is considered a
temporary impact and not a permanent impact. Please note all temporary stream impacts will need to be

restored to pre-existing conditions after the completion of construction. Therefore, these temporary grade
controls will need to be removed to comply with any issued permit. Riffle grade controls proposed as
temporary installments will likely cause more adverse effects to the stream channel because of installation
and removal;
d. The riffle grade control proposed on Marylebone Drive is proposed as a buried riffle complex. However, as
stated in Additional Information Request "b", there are discrepancies in length of impact and duration of
impact (i.e., temporary or permanent). If the activity is a buried riffle, then the Corps would consider this
impact as permanent, as it would not be removed after the completion of construction;
e. The Broken Saddle portion of the project, proposes to replace an existing culvert with an appropriately sized
culvert in the same footprint of the existing culvert. This culvert replacement (i.e., 60 linear feet of
permanent stream impacts) needs to be depicted in the table in Section D(3) and the figure labeled "Impact
Map" Therefore, please revise these sections accordingly;
f. The PCN states the culvert at Marylebone Drive is adequately sized for the Town's design storm. The PCN
lacked enough detail to determine the size of the existing culvert under Marylebone Drive. Therefore, please
provide the current size of this existing culvert. In addition, if this culvert is a different size than the culvert
to be replaced and installed under Broken Saddle Lane, please provide explanation as to why culverts in
series on the same stream channel and in the same watershed would be required and designed to have two
different sizes.
g. The Corps is unsure/confused as to why a PCN was submitted and requested for a Nationwide Permit 3.
Nationwide Permit 3 notification requirements, on page 2 of Nationwide Permit 3, state "for activities
authorized by paragraph (b) of the NWP, the permittee must submit a PCN. Activities under paragraph (b)
refer to the removal of accumulated sediments and debris outside the immediate vicinity of existing
structures. However, the activities as proposed in the PCN are more related to activities described in
paragraph (a) of NWP 3 (i.e., repair, rehabilitation, or replacement of any previously authorized structure or
fill and includes minor deviations in authorized structures and any minimum stream channel work necessary
for the repair). Once all the additional information requested in "a-f" is received, the Corps will be able to
make a determination if the proposed project qualifies for a non -reporting Nationwide Permit 3. If a non -
reporting Nationwide Permit 3 would cover these proposed activities, then the Corps will issue an non -
reporting email to the applicant rather than reviewing the PCN, which was not needed, and issuing a formal
verification letter. If the additional information provided does not meet the conditions in paragraph (a) of
NWP 3, then the Corps will likely issue a formal verification letter for the proposed project.
Please provide the information requested above in ONE consolidated response within 30-days of the date of this
correspondence. If you do not respond within 30-days, the request will be administratively canceled. Please contact me
via telephone or e-mail if you have any questions.
Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]