20091070 Ver 1_Information Letter_20100301

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF February 25, 2010
Regulatory Division
Action ID No. SAW-2009-01927
North Carolina Department of Transportation
Attn: Ms. Elizabeth Lusk
Project Development and Environmental Analysis
Natural Environment Unit
1598 Mail Service Center
Raleigh, North Carolina 27699-1598
1. They believe impacts have been reduced and minimized to the maximum extent
practical.
2. The project will have no effect on federally threatened or endangered species.
3. They have no objection to the issuance of this permit.
Written comments were also received from an individual on January 20, 2010. A copy of
this correspondence is enclosed for your consideration and response. This individual expressed,
in general, concerns regarding cumulative effects of this project and recent past construction
effecting Big Alamance Creek and its floodplain and any effects of planned future projects.
Specific impacts mentioned include flooding, sedimentation and erosion of Big Alamance Creek.
Dear Ms. Lusk:
Reference is made to the application of December 2, 2009, for individual Department of
the Army (DA) permit. authorization to permanently impact approximately 1,487 linear feet (if)
of stream channels, and permanently impact 0.47 acre of adjacent wetlands within jurisdictional
waters of the United States. This project is referred to as Transportation Improvement Project
(TIP) R-2612A. Specifically, the project would impact portions of five (5) unnamed tributaries
to Big Alamance Creek and five (5) wetland areas adjacent to the unnamed tributaries of Big
Alamance Creek. These impacts are associated with the proposed construction of an interchange
at SR 3389 (Woody Mill Road, Section A or R-2612A), to replace an at-grade intersection along
US 421 in and near Pleasant Garden, Guilford County, North Carolina.
following:
After review of your proposal, the United States Department of Interior, Fish and Wildlife
Services (USFWS) submitted comments by letter dated January 5, 2009. A copy of this letter is
enclosed for your records No response is necessary. Specifically the USFWS stated the
Furthermore, as we discussed via telephone communications with Mr. James Pflaum, of
NCDOT on October 20, 2009 and Ms. Karen Reynolds, of NCDOT on October 26, 2009, please
provide updated details regarding the total impacts associated with each alternative (A-I and A-
2). Ms. Reynolds did provide additional information via electronic mail on January 28, 2010
regarding impacts associated with each alternative; however, it is still unclear if impacts shown
under both Alternatives A-1 and A-2 include all the updated aquatic resources (streams and
wetlands) that were confirmed during our May 8, 2007 field inspection. For example, the
Findings of No Significant Impacts (FONSI) indicates that Alternative A-2 (recommended) has
0.26 acre of wetland impacts and 1,875 linear feet of stream impacts. However, the application
indicates that there will be 0.47 acre of wetland impacts and 1,487 linear feet of stream impacts.
You must briefly discuss the discrepancy in impacts of Alternative A-2 in the FONSI and the
application. Also, please provide documentation that the differences in potential impacts to both
the wetlands and streams are also accounted for in Alternative A-1 (this may be provided in
tabular form). Please be aware that, except as provided under Section 404(b)(2), of the Clean
Water Act, no discharge of dredged or fill material shall be permitted if there is a practicable
alternative to the proposed discharge which would have less adverse impact on the aquatic
ecosystem, so long as the alternative does not have other significant adverse environmental
consequences. All the information requested in this letter must be received by March 12, 2010
otherwise your application will be withdrawn.
Finally, please provide updated Accident Data and Analysis (Page 6 and 7 of the October
30, 1998, Environmental Assessment).
Your response to these comments must be given full consideration before we can make a
final decision on your application. We need your information to address the concerns/issues
raised over the proposed project. You may submit additional information, revise your plans to
help resolve the issues, rebut the issues made or request a decision based on the existing record.
We must hear from you by March 12, 2010, otherwise your application will be withdrawn. If
you have questions or comments, please contact me at my Raleigh Regulatory Field Office
address, telephone [phone] ext. 26.
Sincerely,

Andrew Williams
Regulatory Project Manager
Raleigh Field Office
Enclosure
Copies Furnished (without enclosure):
Cyndi Karoly
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Wetlands/401 Unit
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Amy Euliss
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
January 16. 2010
Andrew E. Williams
US Army Corps of Engineers,
Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
RE: Transportation Improvement Project (TIP) R-2612A
Dear Mr. Williams;
I have received the Public Notice issued on December 22. 2009, regarding Corps Action
ID#: SAW - 2009-01927. The proposed project will impact several streams and
surrounding wetland areas feeding directly into Big Alamancc Creek. While the scope of
this proposed project may seem to be relatively small, I am requesting that additional
evaluation of the cumulative effect of not only this project, but also effects of recently
past construction and effects of a planned future project will have on Big Alamancc
Creek and its floodplain, as it flows across southeastern Guilford County.
Big Alamance Creek flows through 10.66 acres of my property, located directly south and
slightly east of the named project for about 900 feet. This tract was placed in a
Conservation Easement in February 1996 through Piedmont Land Conservancy, Register
1396,Guilford County. North Carolina (documentation is available upon request). This
area has been protected because of its value as a natural area that has been used for
educational study and instruction for more than 40 years. In fact, I have considered this
area to be my "classroom" during those years and I still use it for instruction, observation
and teacher training in many areas of the science, social studies and environmental
courses included in the Standard Course of Study for schools in North Carolina.
In addition to the normal development and growth that has occurred in this county during
the late 1900s and into 2000, work done by the City of Greensboro and County of
Guilford between 1994 and 1999 to extend a sewer outtull through the southeastern area
of Guilford County has caused great damage to the portion of the creek on my property. I
have observed the erosion, destruction of stream bank, sedimentation, unstable streambcd
and loss of large trees and plants along the creek that has occurred as the result of this
construction. In the summer of 1999 all of the black plastic erosion control fencing used
for the sewer project washed into the strcambed during a summer storm. Clean up was
required and much of the aquatic life and organisms in the stream were destroyed.
This fall, for the first time in ten years, this stream has riffle areas, stable bottom, good
water quality and a variety of organisms again living there. In November 2009, 1 worked
with four, 8'h grade science teachers and 320 of their students over a period of several
days during which time they did stream monitoring activities, studied plant and animal
life in the area, learned about watersheds, storm water management and the effects of the
construction/development carried out in a less than responsible manner.
My concern is that the proposed project scheduled to begin in the fall of 2010, can once
again bring flooding, sediment and erosion to this still recovering creek.
Please review the cumulative effect of projects in this area. In addition to the work
scheduled for fall of 2010, another interchange is being planned for the intersection of'
Neeley Road and Highway 421, to begin within the next 5 years. Having spent much of
my life observing first hand the environmental impact of many projects that were either
poorly planned, poorly executed or poorly supervised, I worry about the work being done
in more isolated areas where the effects are not readily and regularly observed.
I have visited the Department of Transportation oft-ice on Yanceyville Street in
Greensboro to view larger maps of this area. They did not have erosion control plans for
review, but assured me that DOT work is monitored carefully. My request is very simple:
Review carefully the impact data and erosion control plans. Inspect Big Alamance Creek
in this area for still existing sedimentation and other damage and make sure that the
project in question will not have additional negative impact on this stream. Big Alamance
Creek flows into Lake Macintosh, the Haw River and other critical water supply sources.
It is impossible to do too much to protect our natural resources.
This request does not ask for major changes in the plan or in the timeline established for
this project. My request simply asks that you carefully evaluate the environmental impact
that this and future road construction will have on Big Alamance Creek. 1 am more than
willing to provide additional information, including pictures, of previous damage to the
creek.
Thank you for considering this request. I look forward to hearing your requirements for
this project and how the project will be monitored or inspected to assure compliance with
environmental regulations.
I appreciate your consideration.
Best Regards.
Ile
Nancy R'Routh (Property owner)
5802 Hagan Stone Park Road
PO Box 564
Pleasant Garden, North Carolina 27313
Phone: [phone]
Email: [e-mail]
`SENT OF ?? United States Department of the Interior
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January 5, 2010
Andy Williams
U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Suite 105
Wake Forest, NC 27587
Dear Mr. Williams:
This letter is in response to your request for comments on Public Notice SAW-2009-01 927,
dated December 22, 2009. The North Carolina Department of Transportation has applied for a
Department of the Army permit to impact waters of the US in order to replace an existing at-
grade intersection with a new interchange at SR 3389 (Woody Mill Road) and US 421 (TIP No.
R-2612A) in Guilford County, North Carolina. These comments are provided in accordance
with provisions of the Fish and Wildlife Coordination Act (16 U.S.C. 661-6674) and Section 7 of
the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543).
The U.S. Fish and Wildlife Service (Service) has been involved in the development of this
project through the NEPA/Section 404 Merger Process. We believe that impacts to streams,
wetlands and wildlife resources have been reduced to the maximum extent practical. The
Service believes that the project will have no effect on federally threatened and endangered
species. Therefore, we have no objection to the issuance of this permit. The Service appreciates
the opportunity to review this project. If you have any questions regarding our response, please
contact Mr. Gary Jordan at [phone], ext. 32.
Sincerelv.
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rt,.vr. vr
Pete Benjamin
Field Supervisor
cc: Chris Militscher, USEPA, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
John Sullivan, FHWA, Raleigh, NC