20200758 Ver 1_More Info Requested_20200625

Wanucha, Dave
ON
Thank you for your PCN and attached information, dated 6/10/2020, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 14
.mil NWP20i7 20�7NWPl4. df saw -re etas c e rrnyernil]). 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the use of the Nationwide Permit or consider your application withdrawn and close the file: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) It appears that this project is a segment of the proposed U-2581B/R-2910 project, which completed
Concurrence Points 1 and 2/2A of the Section 404/NEPA Merger Process in October 2011 and November 2013,
respectively. The western -most segment of the U-2581B/R-2910 project was split off to become part of the
Publix Distribution Center project (SAW-2018-00240). However, to our knowledge this overall project had not
been dissolved or permanently shelved, and further piecemealing of this overall project presents additional
questions regarding avoidance and minimization; further, it does not appear that the Merger team was advised
of this segmentation. The Corps highly recommends notifying the remainder of the Merger Team of this action.
2) Per the above, does the project purpose and need justify increasing lanes from 2 to 7 on US Highway 70, west of
University Drive, which then condense back down to two lanes within —0.15 mile of the intersection? Or, does
that aspect of the project design have more to do with tie-in to a future widened US Highway 70 to the west?
3) Are floodplain benches proposed at the inlet/outlets of Sites 1 and 2? If so, please provide cross-section views
that clearly show the proposal;
4) Currently the proposal does not include compensatory mitigation. However, given that this project is a widening
of a previous NCDOT project (U-2905), and the fact that the Corps views NCDOT projects cumulatively as a state-
wide transportation network, compensatory mitigation would be required in this case for all stream and wetland
impacts resulting in a loss of waters. Compensatory mitigation requirements typically start at a 2:1 mitigation to
impact ratio with decisions to lower those ratios based on aquatic function of the resources proposed for
impact. Note, however, that NCSAM and NCWAM forms provided with the PCN indicate medium or higher rated
resources; as such, 2:1 mitigation is justified.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers

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