20060447 Ver 3_USACE Correspondence_20200415

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
April 15, 2020
Regulatory Division/1200A
/_[4i[ a IbMaT_ATIT0 111WIIZ018 7
Old Towne WEH, LP
Attn: Eric Rifkin
56 Hunter Street
Apex, North Carolina 27502
Dear Mr. Rifkin:
Please reference your Individual Permit application for Department of the Army (DA)
authorization received on February 3, 2020. Impacts associated with this development
include 679 linear feet of permanent stream channel impacts from fill (570 linear feet
from fill and 109 linear feet from rip rap dissipator pad installation), 65 linear feet of
temporary stream channel impacts for construction access, 1.154 acre of permanent
wetland impacts from fill, and 0.012 acre of temporary wetland impacts from
construction access for the installation of four road crossings and lot fill. The applicant
also proposes to relocate 404 linear feet of stream channel utilizing natural stream
channel design, in association with the widening of Rock Quarry Road. (Impact site "I").
Previously authorized impacts from the project include 145 linear feet of
temporary stream channel impacts and 0.283 acre of permanent wetland
impacts.
The proposed Olde Towne residential developments is approximately 574 acres
in size and is located in southeast Raleigh, Wake County, and is bordered by
Walnut Creek to the north, South New Hope Road to the west, Rock Quarry
Road to the southwest, and residential properties along Holiday Drive and
Barwell Road to the east and southeast.
Your proposal was advertised by public notice dated February 25, 2020. Comments
in response to the notice were received from the North Carolina Department of Natural
and Cultural Resources State Historic Preservation Office (NCSHPO), National Marine
Fisheries Service (NMFS), U.S. Environmental Protection Agency (EPA), NC
Department of Environmental Quality (NCDEQ), and one adjacent property owner, Mr.
Eugene McCullers. The comments received are enclosed for your information and to
provide you with the opportunity to address any of the stated concerns. Please provide
written responses to the comments from EPA and DEQ.

-2-
Further, on February 6, 1990, the Department of the Army (DA) and the U.S.
Environmental Protection Agency (EPA) signed a memorandum of agreement (MOA)
establishing procedures to determine the type and level of mitigation necessary to
comply with Clean Water Act (CWA) Section 404(b)(1) Guidelines. This MOA provides
for first, avoiding impacts to waters and wetlands through the selection of the least
damaging, practical alternative; second, taking appropriate and practical steps to reduce
impacts on waters and wetlands; and finally, compensation for remaining unavoidable
impacts to the extent appropriate and practical. To enable us to process your
application, in compliance with the MOA, we request that you provide the following
additional information:
a. Permits for work within wetlands or other special aquatic sites are available only
if the proposed work is the least environmentally damaging, practicable
alternative. Please furnish information regarding any other alternatives, including
upland alternatives, to the work for which you have applied and provide
justification that your selected plan is the least damaging to water or wetland
areas.
1) Specifically, please add to the alternatives analysis provided in your
Individual Permit application, received February 3, 2020, to further explore
a No Permit alternative, including avoiding all Waters of the U.S. subject to
Clean Water Act Section 404 jurisdiction. Note that this alternative is
different from the No Build alternative, which was also presented. If a No
Permit alternative is not practicable, please explain why.
2) Your off -site alternatives analysis is insufficient. The Corps is concerned
that the proposed elimination of offsite alternatives based on the
assumption of increased cumulative effects from new development from
offsite sewer line upgrades is not justified, as development in the area is
presumed to continue regardless of those proposed utility improvements
required for the development of your specified offsite alternatives.
Elimination of potential offsite alternatives based only on potential
secondary and cumulative impacts to surrounding properties from sewer
line upgrades is not supported by the information provided. We
recommend reevaluating your selection criteria for comparison of the sites.
b. It is necessary for you to have taken all appropriate and practicable steps to minimize
losses of Waters of the U.S., including wetlands. Please indicate all that you have done,
especially regarding development and modification of plans and proposed construction
techniques, to minimize adverse impacts.

-3-
1) Please provide further information regarding the need for proposed lot fill at
impact areas C, F, and G, including but not limited to financial viability data should
these lots not be constructed.
2) Please provide further information regarding minimization efforts at each of the
culverted stream crossings, primarily through the use of retaining walls or
spanning of jurisdictional waters. Please be aware that each alternative cost
analysis should take into account the cost of proposed compensatory mitigation
(stream, wetland, and buffer) when evaluating total cost of each alternative.
3) It appears that the construction of a road, lots, and stormwater devices in the area
of impacts E, F, ang G will remove hydrology from the remainder of wetland O.
Please provide further information regarding the potential for loss of function due
to secondary and cumulative effects to this wetland area. Should it be determined
that a loss of function will occur from your analysis, mitigation will be required, and
should be included in your final compensatory mitigation plan.
4) Please provide further information regarding the placement of impact D. It
appears that the location of this road could be moved further to the southeast to
avoid stream impacts in this location.
c. The MOA requires that appropriate and practicable mitigation will be required for all
unavoidable adverse impacts remaining after the applicant has employed all appropriate
and practicable minimization. Please indicate your plan to mitigate for the projected,
unavoidable loss of waters or wetlands or provide information as to the absence of any
such appropriate and practicable measures.
1) After review of functional quality using stream reach and/or wetland
functional assessments in the form of NC Stream Assessment Method
(NCSAM) and NC Wetland Assessment Method (NCWAM) evaluations,
justification for proposed credit ratios at the following impact locations are
insufficient.

-4-
Please review the table below and adjust your mitigation proposal
accordingly. Based on adjusted mitigation ratios and previously purchased
credits a total of 892 SMUs and 1.805 acre of wetland credits is required to
satisfy compensatory mitigation requirements for the proposed project.
Please adjust your compensatory mitigation proposal to reflect these
changes.
Impact Area
Resource Name
Assessment
area/reach
Impact amount
ac/1
Proposed
mitigation ratio
Corps required
mitigation ratio
C
Wetland X
C-2
0.031 acre
1.5:1
2:1
A
Stream B
A-1
l 201f
1.5:1
2:1
D
Stream F
D-2
57 if
0:1
.5:1
H
Stream C
H-1
351f
1:1
2:1
H
Wetland Z
H-1/H-2
.064 acre
.5:1/2:1
1:1
H
Wetland KK
H-3
0.137 acre
0.5:1
1:1
I
Wetland BB
I-1/I-2
0.108
1:1/1.5:1
1:1
I*
Stream C
I-1/I-2
404 If
.5:1/0:1
1:1
*impacts from stream relocation for the purposes of road widening is still considered an
impact with loss of aquatic function from the stream relocation and is considered a
minimization effort that typically still requires compensatory mitigation.
2) Please provide a more detailed stream restoration plan including but not
limited to locations of all proposed structures, profile of the proposed
channel, as well as a planting plan, and more robust monitoring plan in
accordance with the U.S. Army Corps of Engineers Stream Mitigation
guidelines (2016).
Additionally, the following items must be resolved prior to continuing to process your
permit request:
1) Please adjust impact table (M 1) as follows: itemize all proposed impacts
into stream and wetland impacts due to culvert/road fill/lot fill (permanent
loss of waters), rip rap dissipater pads (permanent impact, not a loss of
waters), wetland conversion within sewer easements (permanent
conversion) and temporary impacts for construction access, sewer line
installation, etc. Impact area C also appears to be missing from the table.
2) Also, provide a concise restoration plan for all temporary impacts.
The aforementioned requested information is essential to the expeditious
processing of your application; please forward this information to us within 30 days of

-5-
your receipt of this letter. If you have any questions regarding these matters, please
contact me at [phone] extension 32 or James. C.Lastinger usace.army.miI
Sincerely,
James C. Lastinger
Regulatory Project Manager
Raleigh Regulatory Field Office
Copies Furnished w/ attachments:
Ms. Jennifer Burdette
McAdams Company
2905 Meridian Parkway
Durham, North Carolina 27713
Copies furnished:
Ms. Sue Homewood
Division of Water Resources
Department of Environmental Quality
450 W. Hanes Mill Road, suite 300
Winston Salem, North Carolina 27105
Mr. Paul Wojoski
401 and Buffer Permitting Unit
Department of Environmental Quality
1617 Mail Service Room
Raleigh, North Carolina 27699

DocuSign Envelope ID: B02lA343-65F7-47CO-9035-ACC9C2C9A3F9
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 10, 2020
DWR # 20060447 v3
Wake County
Olde Towne WEH, LP
Attn: Mr. Eric Rifkin
56 Hunter Street
Apex, NC 27502
Subject: REQUEST FOR ADDITIONAL INFORMATION
Olde Towne Master Plan Community
Dear Mr. Rifkin:
On February 5, 2020, the Division of Water Resources — Water Quality Programs (Division) received your
application requesting a 401 Individual Water Quality Certification and Neuse River Buffer Authorization
from the Division for your project. The Division has determined that your application is incomplete and
cannot be processed. The application is on -hold until all of the following information is received:
If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. [15A
NCAC 02H .0502(c)]
2. You have proposed a stream restoration/relocation for a portion of Stream C (Impact Area 1).
You have provided a conceptual stream relocation design on Figure 40, as well as some typical
stream restoration details on Figure 44. Please provide a detailed stream restoration plan which
includes exact locations of all proposed structures, as well as a profile of the proposed channel.
Please also provide a planting plan that indicates the proposed new buffer location and the
types of vegetation proposed to be planted within each Zone. The current planting plan does
not clearly include the Neuse buffer area planting details.
Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. Based on the information provided in the application and associated documents, the
current drainage area and upper portion of Wetland 0 (Impact Area E/F/G) is proposed to be
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NOFiTN CR%3(JI.iNA
919.707.9000

DocuSign Envelope ID: B02lA343-65F7-47CO-9035-ACC9C2C9A3F9
Olde Towne WEH, LP
DWR Project #20060447 v3
Request for Additional Information
Page 2of3
filled and routed through a stormwater control measured that will be discharged along a stream
channel. Please note that the rerouting of any drainage area and surface flow has the potential
to remove existing hydrology from Wetland O and therefore remove existing uses of the
wetland. Please provide a detailed hydrologic analysis of indirect impacts to the remaining
portion of Wetland O immediately below this impact area. Alternatively, you may propose
updated impact amounts that include this area as a loss of wetland due to indirect impacts.
4. Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. Based on the information provided in the application and associated documents, the
current drainage area and upper portion of Stream F is proposed to be routed through a
stormwater control measured that will be discharged a substantial distance further downstream
along the stream channel. Please note that the rerouting of any drainage area and surface flow
has the potential to remove existing hydrology from the upper portion of Stream F and
therefore remove existing uses of the stream. Please provide a detailed hydrologic analysis of
indirect impacts to the portion of Stream F above all stormwater control measure discharge
points. Alternatively, you may propose updated impact amounts that include this area as a loss
of stream due to indirect impacts.
5. The outlet channels from some of the proposed Stormwater Control Measures are aligned at
approximately 90 degrees from the stream channel. The Division is concerned that these
proposed alignments have the potential to cause impacts do downstream water quality from
erosion of the streambanks. Please re -align the outlets, or provide detailed evaluation of the
area to document that streambank erosion will not occur as a result of the current alignments.
Pursuant to Title 15A NCAC 02H .0502(e) and 15A NCAC 02B [Neuse] .0233, the applicant shall furnish all
of the above requested information for the proper consideration of the application. Please respond in
writing within 30 calendar days of receipt of this letter by sending one (1) copy of all of the above
requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC
27699-1617 OR by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.

DocuSign Envelope ID: B02lA343-65F7-47CO-9035-ACC9C2C9A3F9
Olde Towne WEH, LP
DWR Project #20060447 v3
Request for Additional Information
Page 3 of 3
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
DocuSigned by:
Rye W,
949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc: Jennifer Burdette, McAdams Company (via email)
James Lastinger, USACE Raleigh Regulatory Field Office (via email)
DWR RRO 401 files
DWR 401 & Buffer Permitting Unit

DocuSign Envelope ID: B02lA343-65F7-47CO-9035-ACC9C2C9A3F9
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 10, 2020
Corps Action ID# SAW-2006-20287
DWR# 20060447 v3
Wake County
James Lastinger
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
331 Heritage Trade Dr, Suite 105
Wake Forest NC 27587
Subject Project: Olde Towne Master Plan Community
Dear Mr. Lastinger:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the following
comments within your review of the 404 Individual Permit request for the above referenced property:
The applicant proposes some reduced mitigation ratios based on NCSAM and NCWAM analyses,
however these analyses have likely been influenced by previous clearing and grading activities
within the project boundary. The Division recommends reconsideration of whether the NCSAM
or NCWAM evaluations are appropriate in these situations.
2. The Division has requested additional technical information from the applicant and requests that the
USACE also consider the attached letter during the review of the application.
Thank you for your considering the Division's comments during your review of this Individual Permit. If you have
any questions, please contact Sue Homewood at 336-776-9693 or [e-mail].
Sincerely,
EP
DDocuSignn�e/d by:
Lw� N ,
949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Unit
cc: Jennifer Burdette, McAdams Company (via email)
DWR RRO
DWR — Wetlands and Buffer Permitting Branch
DE Q North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NOFiTN CR%3(JI.iNA
a�:Iily 919.707.9000

Lastinger, James C CIV USARMY CESAW (USA)
From: Mac <[e-mail]>
Sent: Saturday, March 21, 2020 10:14 AM
To: Lastinger, James C CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Olde Towne Residential Subdivision Development (Project SAW-2006-20287)
I am Eugene McCullers, 5012 Rock Quarry Road, Raleigh, North Carolina 27610. 1 received a notification indicating that
this group is seeking permission to discharge fill materials into wetlands and waters in the Neuse River Basin. area. I am
totally against ANY use of our wetlands for this purpose whatsoever. Enough damage is bei9ng done to the
environment by this developers without disturbing our wetlands. The city has changed the zoning allowing the golf
course to be deleted from the original plans. Now they seeing to disturb and destroy our wetlands for their monetary
gains. We, the present residents should not have our picturesque wetlands destroyed for the benefit of a few. Again, I
am totally and completely against any dumping, disturbing or use of the wetlands associated with the Old Towne
residential project in Wake County.

Lastinger, James C CIV USARMY CESAW (USA)
From: Bowers, Todd <[e-mail]>
Sent: Tuesday, March 10, 2020 11:38 AM
To: Lastinger, James C CIV USARMY CESAW (USA)
Subject: [Non-DoD Source] Public Notice SAW-2006-20287 Agency Comments
James,
The EPA Region 4 Ocean, Wetlands and Streams Protection Branch has reviewed the subject Public Notice under DA
Action ID SAW-2006-20287 dated February 25, 2020. It is our understanding that the applicant, Olde Towne WEH, LP
(McAdams Company), proposes to discharge fill material into wetlands and waters within the Neuse River Basin (HUC
03020201), associated with the construction of the Old Towne residential subdivision in Wake County, North Carolina.
According to the public notice project description, the project consists of the construction of a large-scale, master plan
community comprised of five residential sub -communities, a commercial district, and a central amenity center,
combined with greenways, multi -use paths, roadways, and utilities. Impacts associated with this development include
679 linear feet of permanent stream channel impacts from fill (570 linear feet from fill and 109 linear feet from rip rap
dissipater pad installation), 65 linear feet of temporary stream channel impacts for construction access, 1.154 acre of
permanent wetland impacts from fill, and 0.012 acre of temporary wetland impacts from construction access for the
installation of four road crossings and lot fill. The applicant also proposes to relocate 404 linear feet of stream channel
utilizing natural stream channel design, in association with the widening of Rock Quarry Road. (Impact site ITT
Previously authorized impacts from the project include 145 linear feet of temporary stream channel impacts and 0.283
acre of permanent wetland impacts.
Additionally from the public notice, the original site development plan from September 2018 shows 3.9 AC of wetland
impact and 1,315 LF of stream impact. Impacts to these features were reduced by shifting and reconfiguring the
entrance road from S. New Hope Road and reconfiguring the site plan to further avoid wetlands. Approximately 700 LF
of stream and 2.5 AC of wetland impacts were avoided by the revisions to the final plan. Compensatory mitigation
offered by the applicant is as follows: A total of 580 LF of stream credits and 1.9835 AC of riparian wetland credits are
proposed to mitigate the project's impact to these jurisdictional resources. Before the original project was abandoned,
payment was made for 300 stream credits and 0.4752 AC riparian wetland credits. Of the permitted impacts, only 0.283
AC of wetland impacts were completed.
The approved mitigation ratio for these permitted impacts was 1:1. Therefore, 0.1922 AC of wetland and 300 LF of
stream mitigation credits paid for this project remains. An additional 280 LF of stream and 1.7913 AC of wetland credits
must be acquired to mitigate impacts for the proposed project.
At this time the EPA would like to submit the following comments for consideration by the Wilmington District. I wish to
commend the applicant for reconfiguring their site plan to reduce impacts (and subsequent need for compensatory
mitigation) by 50 percent of those originally proposed. However, in order to determine the proper amount and type of
compensatory mitigation for losses to waters of the United States, a functional assessment of the streams and wetlands

in question should be conducted. Simply offering a replacement of 1:1 for stream and wetland impacts fails to consider
the functional condition or ecological value of the aquatic resources being lost. For instance, a high quality perennial
stream or wetland may require a replacement ratio closer to or at 2:1 to replace the functions lost and allow for no net
loss of aquatic resources. Similarly, a low quality intermittent stream or wetland with little ecological function or value
may require less for compensation.
The amount of proposed stream credit needed to replace the streams on -site at a minimum should be 1:1 assuming
medium quality or function. This scenario would equate to a minimum of 679 stream mitigation units (SMU) or credits
needed to adequately replace the streams on -site. The applicant has paid for 300 credits or SMU and in the absence of a
functional assessment the remainder of credits needed should be 379.
Lastly, I would like to commend the applicant for considering some compensatory mitigation on -site with the 404 linear
feet of stream relocation in Impact Area I. However, I recommend that the applicant provide a mitigation plan for the
on -site permittee responsible mitigation in order to demonstrate how the relocation will be designed, built, planted,
protected, monitored for 7 years and how the site will demonstrate that it has met minimum performance standards for
stream restoration projects. In order for the applicant to receive proper credit for their stream relocation, they must
demonstrate that the site is a successful mitigation project per Wilmington District Guidance for Compensatory
Mitigation. If the applicant is unable or unwilling to conform to compensatory mitigation guidelines for the stream
relocation, the EPA recommends that the applicant consider purchasing additional stream mitigation credits.
Thank you for the opportunity to provide feedback on the public notice for DA Action ID SAW-2006-20287 associated
with the construction of the Old Towne residential subdivision in Wake County, North Carolina.
Best Regards,
Todd Bowers
Todd Allen Bowers
US EPA Region 4 Oceans, Wetlands and Streams Protection Branch
61 Forsyth St. SW
Atlanta, GA 30303
404.562.9225
[e-mail] <maiIto: [e-mail]>

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
March 18, 2020
TO: James Lastinger
US Army Corps of Engineers
Raleigh Regulatory Field Office
FROM: Ramona M. Bartos, Deputy N+ �U*a.
State Historic Preservation Officer
Office of Archives and History
Deputy Secretary Kevin Cherry
James. C.Lastingergusace.armymil
SUBJECT: Olde Towne Residential Subdivision, Rock Quarry Road & South New Hope Road
(SAW-2006-20287), Raleigh, Wake County, ER 19-2514
Thank you for your February 25, 2020, submission concerning the above -referenced project. We have reviewed
the submitted materials and offer the following comments, which were also provided to the applicant in a letter
dated September 10, 2019.
There are no recorded archaeological sites located within the proposed project area. However, there is a high
probability for precolonial American Indian sites to be present given the property's proximity to Walnut Creek.
In addition, the 1914 Wake County Soil Survey map shows four structures in the proposed project area, where
associated archaeological remains are likely.
We recommend that prior to the initiation of any ground disturbing activities within the project area, a
comprehensive archaeological survey of the project area be conducted by an experienced archaeologist. The
purpose of this survey will be to identify and evaluate the significance of archaeological sites and cemeteries
that may be damaged or destroyed by the proposed project.
Please note that our office now requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate field methodologies prior to the archaeological field investigation. A list of
archaeological consultants who have conducted or expressed an interest in contract work in North Carolina is
available at www.archaeology.ncdcr.gov/ncarch/resource/consultants.htm. The archaeologists listed, or any
other experienced archaeologist, may be contacted to conduct the recommended survey.
One paper and one digital copy of all resulting archaeological reports, as well as one digital copy of the North
Carolina site form for each site recorded, should be forwarded to the Office of State Archaeology through this
office for review and comment as soon as they are available and in advance of any construction or ground
disturbance activities.
We have determined that the project as proposed will not have an effect on any historic structures.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewkncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.

(UNITED STATES DEPARTMENT OF COMMERCE
y National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
. �e 263 13th Avenue South
BTMres°*°� St. Petersburg, Florida 33701-5505
https:llwww.fisheries.noaa.govlreg ionlsoutheast
(Sent via Electronic Mail) February 27, 2020
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date
SAW-2019-00503 LGI Homes -NC, LLC February 24, 2020
SAW-2006-20287 Olde Towne WEH LP February 25, 2020
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or
critical habitat under the purview of the NMFS, please initiate consultation with the Protected
Resources Division at the letterhead address.
Sincerely,
Digitally signed by
WILBER•THOMASYA WILBER.THOMAS.PAYSON.13658
YSON.1365820186 20186
for Date: 2020.02.27 09:14:48-05'00'
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
April 15, 2020
Dawn Reid
Archaeological Consultants of the Carolinas, Inc.
121 East First Street
Clayton, NC 27520
Office of Archives and History
Deputy Secretary Kevin Cherry
dawnreid&archcon.org
Re: Olde Towne Residential Subdivision, Rock Quarry Road & South New Hope Road
(SAW-2006-20287), Raleigh, Wake County, ER 19-2514
Dear Ms. Reid:
Thank you for your March 23, 2020, submission concerning the above -referenced project. We have reviewed
the materials provided and offer the following comments.
Having conducted an on -site inspection of ground disturbances that have already taken place on the western
portion of the project area, you think it is unlikely that this portion of the property contains archaeological sites
with sufficient integrity to be considered eligible for listing in the National Register of Historic Places. Based on
the information provided, we concur with this recommendation. No archaeological survey is warranted in this
portion of the project area.
We continue to recommend that prior to any ground disturbing activities within the remaining 282.5-acre
project area east of the Walnut Creek tributary, and within the Walnut Creek floodplain north of the disturbed
portion of the project area, a comprehensive archaeological survey be conducted by an experienced
archaeologist. The purpose of this survey will be to identify and evaluate the significance of archaeological sites
and cemeteries that may be damaged or destroyed by the proposed project.
Please note that our office now requests consultation with the Office of State Archaeology Review
Archaeologist to discuss appropriate field methodologies prior to the archaeological field investigation. A list of
archaeological consultants who have conducted or expressed an interest in contract work in North Carolina is
available at https://archaeology.ncdcr.gov/archaeological-consultant-list. The archaeologists listed, or any
other experienced archaeologist, may be contacted to conduct the recommended survey.
One paper and one digital copy of all resulting archaeological reports, as well as one digital copy of the North
Carolina site form for each site recorded, should be forwarded to the Office of State Archaeology through this
office for review and comment as soon as they are available and in advance of any construction or ground
disturbance activities. Office of State Archaeology report guidelines are available at https://files.nc.gov/dncr-
arch/OSA Guidelines Dec2017.12df.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewkncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
✓Ramona Bartos, Deputy
v State Historic Preservation Officer
cc: Jennifer Burdette, McAdams burdette cgmcadamsco.com
James Lastinger, USACE James. C.Lastingergusace.army.mil