20201077 Ver 1_More Info Requested_20200916

Strickland, Bev
From: Homewood, Sue
Sent: Wednesday, September 16, 2020 10:07 AM
To: [e-mail]; Jason Steele
Cc: Bailey, David E CIV USARMY CESAW (USA)
Subject: RE: [External] Request for Additional Information - Registers Creek Pump Station and
Force Main, City of High Point, Guilford County; SAW-2020-00682
Please copy me when you respond to David's request.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
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From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, September 15, 2020 2:31 PM
To: [e-mail]; Jason Steele <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [External] Request for Additional Information - Registers Creek Pump Station and Force Main, City of High Point,
Guilford County; SAW-2020-00682
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
No
Thank you for your PCN and attached information, dated 8/24/2020, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 12
(http://saw-reg.usace.army.mil/NWP2017/2017NWP12.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Permit or consider your application withdrawn and close the file: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) The proposed project encroaches into a 200-foot buffer around Randleman Lake as required by an Individual
Permit issued by the Corps to Piedmont Triad Regional Water Authority (SAW-1991-02669, see attached) on
4/6/2001. Specifically, Special Condition c of this permit requires:
"As part of the project described in the EIS, the Permittee will acquire in fee simple or through conservation
easements a 200-foot wide horizontal buffer adjacent to and around the perimeter of the Randleman Lake. This

buffer will be maintained or developed as a forested preservation area. Existing fields and early successional
plant communities will be allowed to proceed through natural ecological succession ultimately to hardwood
forest. The buffer area will not be developed for silviculture, and no timber harvesting will be allowed except
where the forestry activities are necessary for the health and viability of the forest and are consistent with the
primary goal of watershed protection for the reservoir. No development of any type will be allowed in the buffer
area except for construction of and access to boat launching ramps. All other development such as boat access
parking areas, day visitor picnic facilities, restrooms, and walking and/or bicycle trails will be located outside the
buffer area. Any activities, including maintenance or modification of existing utilities, which result in land
disturbance or cutting of trees or vegetation within the buffer will require advance written approval from
U SAC E. "
Encroachments into PTRWA property as proposed by this project (see attached) do not appear to be in
compliance with this special condition, and aspects of this project that encroach into this buffer should be
redesigned to avoid encroachment or employ construction methodology that allows all existing forested
preservation areas to remain forested. Any encroachments into this buffer must be justified as unavoidable; in
this case, any such justifications must be accompanied by an acceptable buffer mitigation plan.
2) Per NWP 12 Regional Condition 4.1.1, utility line construction through jurisdictional waters must be
accomplished utilizing trenchless methods to the maximum extent practicable. Both Reddicks Creek and the
Deep River (see also item 1 above) are within water supply watersheds and warrant additional avoidance and
minimization of impacts to these resources. Please update the PCN and Plans to abide by this condition,
including stating the specific method of trenchless installation to be employed, entry/exit pits, etc. If such
techniques are not practicable for one or both crossings, please provide specific documentation that such
avoidance and minimization measures are not practicable (i.e. available and capable of being done after taking
into consideration cost, existing technology, and logistics in light of overall project purposes).
3) References to stream and wetland crossing details do not seem to be accurate. Please compare references on
Sheets PP-1 through PP-13 and ER-2 through ER-8 with detail sheets and ensure that references/details are
correct.
4) All stream impacts are listed on the PCN as temporary, however the plans show that rip rap is proposed to be
placed along the banks and in the channel of most if not all crossings. Since the rip rap material would not be
removed these impacts are considered permanent, although we would not consider them a permanent loss of
waters and these amounts would not contribute to the Nationwide Permit impact limit thresholds.
5) Please submit additional details about the wetland restoration plan for the temporary wetland impact areas,
including confirmation that the top 6-12 inches of the trench will be backfilled with topsoil from the trench, and
including a re -vegetation plan using native wetland species per NWP 12 Regional Condition 4.1.9.
Please let me know if you have any questions.
Sincerely,
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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