20200758 Ver 1_Mitigation Information_20200723

Wanucha, Dave
From:Jim Mason <[e-mail]>
Sent:Monday, July 20, 2020 2:03 PM
To:Nancy Oberle; [e-mail]
Cc:Wanucha, Dave; Parker, Jerry A; Wilver, David; Craig Young; Ketner, Brian K
Subject:\[External\] RE: Request for Additional Information - NCDOT Division 7 - U-6010,
Alamance County; SAW-2018-01083
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Dave-

You should have received a DMS letter from Beth Harmon for this project. The amounts listed in the letter cover all of
the permanent wetland impacts and all permanent stream impacts that result in a loss of waters. As you had stated
previously we assumed 2:1 mitigation on all of these impacts. Please let me know if you have any questions or require
any additional information regarding the DMS letter.

Thanks and have a great day,

Jim

From: Nancy Oberle <[e-mail]>
Sent: Monday, July 13, 2020 9:58 AM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Jim Mason
<[e-mail]>
Cc: Wanucha, Dave <[e-mail]>; Parker, Jerry A <[e-mail]>; Wilver, David
<[e-mail]>; Craig Young <[e-mail]>; Ketner, Brian K
<[e-mail]>
Subject: RE: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-2018-01083

Hi Dave,
Thank you for your review of the subject permit application. Here are the responses to your questions below:
1) Project U-6010 is an intersection improvement (University at S. Church Street) project and not tied to U-
2581B/R-2910. The 2020-2029 STIP shows U-2581 BC (section from Knox Road to Rock Creek Dairy Road) as
unfunded (hanging out past 2029 in the STIP). R-2901 is not listed in the 2020-2029 STIP at all.
2) The seven lanes (dual thru, dual left, and separate right turn) is proposed to improve the intersection capacity
and level of service. It has nothing to do with matching another project widening to the west. Also, S. Church
Street was already five lanes at Westbrook Drive. Once the intersection was widened to accommodate dual left
turn lanes, dual through lanes, and a separate right turn lane along with the required storage lengths it did not
make sense to leave a short section of unwidened roadway along S. Church Street between University Drive and
Westbrook Drive.
3) Site 1 – No floodplain benches are proposed at this culvert extension. This culvert is located in a FEMA study
area and the entire opening is needed for compliance. Also, the existing stream width closely matches the
existing culvert width at both the upstream and downstream sections. Site 2 – The existing culvert is only being
extended on the downstream end. A 2’ tall sill is proposed in the northern barrel at the outlet as there is an
existing 2’ sill already on the inlet side. There is an existing floodplain bench on the outlet end that will be
maintained.
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4) A DMS request will be submitted.

Please let us know if you have any further questions.

Thanks,
Nancy
Nancy Scott Oberle
Three Oaks Engineering
324 Blackwell Street , Suite 1200
Durham, NC 27701
919 732 1300 office
919 900 6535 direct – please note my new number
[e-mail] – please note my new email
www.threeoaksengineering.com

From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, June 26, 2020 3:41 PM
To: Jim Mason <[e-mail]>; Nancy Oberle <[e-mail]>
Cc: Wanucha, Dave <[e-mail]>; Parker, Jerry A <[e-mail]>
Subject: Request for Additional Information - NCDOT Division 7 - U-6010, Alamance County; SAW-2018-01083

All,

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
(http://saw-reg.usace.army.mil/NWP2017/2017NWP14.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) 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,
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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]

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