20190459 Ver 1_IP WAIVED?_20201013

Strickland, Bev
From: Roden Reynolds, Bryan K CIV (USA) < [e-mail] >
Sent: Tuesday, October 13, 2020 4:33 PM
To: Aliisa Harjuniemi
Cc: Johnson, Alan; Homewood, Sue; Perez, Douglas J; Shaeffer, David Leigh (Dave) CIV
USARMY CESAW (USA)
Subject: RE: [Non-DoD Source] Re: [External] Patterson Road - ID # 20190459
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ort.s am nc. ov
Ms. Harjumiemi,
Please provide documentation as to support your assumption of "Client was under impression that if impacts will be
reduced below 500 If the project would qualify for an IP waiver. According to them this was discussed in one of the
meetings."
As I stated previously, based on the administrative record, the last correspondence the Corps had with CWS about this
project is summarized as: The applicant has still yet to demonstrate avoidance and minimization to the extent
practicable based on previously issued permits in the region. The Corps made additional recommendations to reduce
the size and/or eliminate Building 600 (a.k.a. Building 200) from the proposed project site layout which would further
reduce impacts to waters of the United States. The Corps has not changed it stance or recommendations. Therefore,
additional information and further justification is needed as to why now the Corps should consider a waiver, especially if
the site plan has not changed from the past iteration.
Thanks,
Bryan Roden -Reynolds, PWS
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
From: Aliisa Harjuniemi <[e-mail]>
Sent: Tuesday, October 13, 2020 4:28 PM
To: Roden Reynolds, Bryan K CIV (USA) <Bryan.K.Roden [e-mail]>
Cc: Johnson, Alan <[e-mail]>; Homewood, Sue <[e-mail]>; Perez, Douglas J
<[e-mail]>; Shaeffer, David Leigh (Dave) CIV USARMY CESAW (USA) <[e-mail]>
Subject: Re: [Non-DoD Source] Re: [External] Patterson Road - ID # 20190459
Bryan,
Client was under impression that if impacts will be reduced below 500 If the project would qualify for an IP
waiver. According to them this was discussed in one of the meetings. The rationale for the IP waiver was that the
stream was intermittent and low quality.

Alan, can we plan on meeting on site on November 4th to assess the stream quality and whether we need to schedule a
full IP pre-app meeting?
Thanks,
Aliisa
On Tue, Oct 13, 2020 at 3:16 PM Roden Reynolds, Bryan K CIV (USA) <Bryan.K.Roden [e-mail]> wrote:
Ms. Harjuniemi,
Before we start scheduling a site visit, you need to response to the Corps question below.
Therefore, additional information and further justification is needed as to why now the Corps should consider a waiver,
especially if the site plan has not changed from the past iteration.
Sent from my Verizon, Samsung Galaxy smartphone
-------- Original message --------
From: Aliisa Harjuniemi <[e-mail]>
Date: 10/13/20 2.22 PM (GMT-05:00)
To: "Roden Reynolds, Bryan K CIV (USA)" <Bryan.K.Roden [e-mail]>
Cc: "Johnson, Alan" <[e-mail]>, "Homewood, Sue" <[e-mail]>, "Perez, Douglas J"
<[e-mail]>, "Shaeffer, David Leigh (Dave) CIV USARMY CESAW (USA)"
<[e-mail]>
Subject: Re: [Non-DoD Source] Re: [External] Patterson Road - ID # 20190459
Alan and Bryan,
Sounds like a pre -application meeting on -site would be beneficial. Let me know some dates that would work for you.
Aliisa
On Fri, Oct 9, 2020 at 1:36 PM Roden Reynolds, Bryan K CIV (USA) <Bryan.K.Roden [e-mail]> wrote:
Ms. Harjuniemi,
When the proposed project was initially presented to the Corps, The Corps had concerns about the proposed impacts
in relation to the size of the development and was not convinced the applicant appropriately demonstrated avoidance
and minimization to the extent practicable. The Corps stated "We looked at the square footage proposed per acre
because property size is often a primary siting criteria used for such developments. The applicant is proposing building
square footages per acre that are 23% higher than the highest reviewed and 42% high than the aver per acre across all
sites reviewed. This would seem to suggest that reducing the size of or completely eliminating building 200 would be
practicable since it has been achieved by many other developers in the market. We believe this may eliminate the
need for a waiver altogether."

Based on the administrative record, the last correspondence the Corps had with CWS about this project is summarized
as: The applicant has still yet to demonstrate avoidance and minimization to the extent practicable based on
previously issued permits in the region. The Corps made additional recommendations to reduce the size and/or
eliminate Building 600 (a.k.a. Building 200) from the proposed project site layout which would further reduce impacts
to waters of the United States. The Corps has not changed it stance or recommendations. Therefore, additional
information and further justification is needed as to why now the Corps should consider a waiver, especially if the site
plan has not changed from the past iteration.
Thanks,
Bryan Roden -Reynolds, PWS
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
From: Aliisa Harjuniemi <[e-mail]>
Sent: Friday, October 9, 2020 8:55 AM
To: Roden Reynolds, Bryan K CIV (USA) <Bryan.K.Roden [e-mail]>
Cc: Johnson, Alan <[e-mail]>; Homewood, Sue <[e-mail]>; Perez, Douglas J
<[e-mail]>
Subject: [Non-DoD Source] Re: [External] Patterson Road - ID # 20190459
Brian,
PCN was originally submitted on April 8, 2019 and IP waiver was requested (SAW-2018-02209). IP waiver was
discussed in the IP pre -application meeting and based on Sean Martin's notes, Todd Bowers from EPA would have
been favorable towards this as the stream was intermittent. However, the permit was never issued and I assume it
has been withdrawn.

DEQ now requires requesting a pre -filing meeting for all projects. We need to determine if the IP waiver still is a valid
option and how to proceed. The new Nationwide Permits are proposing eliminating the 300 linear feet threshold
altogether. CWS staff working on this project has changed and David Shaeffer no longer works as a regulator so we
were hoping to gain understanding how to proceed.
We are tentatively meeting on site November 4th to assess the stream the developer wants to impact. The
currently estimated impacts are approximately 500 If.
Thanks,
Aliisa
On Fri, Oct 9, 2020 at 8:22 AM Roden Reynolds, Bryan K CIV (USA) <[e-mail]> wrote:
Aliisa,
Has a PCN for this project been submitted to the Corps yet?
Thanks,
Bryan Roden -Reynolds, PWS
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]

From: Johnson, Alan <[e-mail]>
Sent: Friday, October 9, 2020 8:19 AM
To: Aliisa Harjuniemi <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Roden Reynolds, Bryan K CIV (USA)
<Bryan.K.Roden [e-mail]>; Perez, Douglas J <[e-mail]>
Subject: [Non-DoD Source] RE: [External] Patterson Road - ID # 20190459
That will work for me. Bring the proposed site plan and the NCSAM form
How 'bout you guys?
Thanks
DWR
1-61",
DNIslon of WAter Resources
Alan D Johnson — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.

From: Aliisa Harjuniemi [mailto:[e-mail]]
Sent: Thursday, October 8, 2020 4:56 PM
To: Johnson, Alan <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Roden Reynolds, Bryan K CIV (USA)
<Bryan.K.Roden [e-mail]>; Perez, Douglas J <[e-mail]>
Subject: Re: [External] Patterson Road - ID # 20190459
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
.c
Alan,
Would November 4th work?
Thanks,
Aliisa
On Wed, Oct 7, 2020 at 4:27 PM Johnson, Alan <[e-mail]> wrote:
Starting in November,
DWR
DMWon of Water Resources
Alan D Johnson — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations

610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax:[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Aliisa Harjuniemi [mailto:[e-mail]]
Sent: Wednesday, October 7, 2020 1:14 PM
To: Homewood, Sue <[e-mail]>
Cc: Johnson, Alan <[e-mail]>
Subject: Re: [External] Patterson Road - ID # 20190459
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
To [e-mail]
Alan,
Let me know when you would be available to meet on site. Since the project has been on hold for so long we are
essentially starting from scratch.
Thanks,
Aliisa
On Wed, Oct 7, 2020 at 10:16 AM Homewood, Sue <[e-mail]> wrote:
I wasn't able to find any notes that indicate I attended a pre-app meeting. Alan do you have notes from the
meeting that occurred last year?
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
From: Homewood, Sue
Sent: Tuesday, October 6, 2020 4:53 PM
To:'Aliisa Harjuniemi' <[e-mail]>; Johnson, Alan <[e-mail]>
Subject: RE: [External] Patterson Road - ID # 20190459
Hi,
I will be at the office tomorrow and see if I have any notes from a pre-app meeting. The project name sounds
familiar. I'll forward anything I can find and then we can re -assess "what next"..
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: Aliisa Harjuniemi <[e-mail]>
Sent: Tuesday, October 6, 2020 4:49 PM
To: Johnson, Alan <[e-mail]>
s

Cc: Homewood, Sue <[e-mail]>
Subject: Re: [External] Patterson Road - ID # 20190459
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
v
Alan,
To clarify, pre-app meeting with agencies initially occurred in 2019 before the original NWP submittal. I am not
100% sure what happened, but during that meeting an option for the IP waiver was discussed and the client
is under the impression that if he can reduce the impacts below 500 If USACE would grant IP waiver.
Obviously, USACE PM has changed since then and I was not involved with any of the meetings or correspondence,
so we are basically starting from the beginning, but we need agencies to make decisions whether IP waiver is even
an option anymore.
Thanks,
Aliisa
On Tue, Oct 6, 2020 at 4:31 PM Johnson, Alan <[e-mail]> wrote:
I have included Sue on this, if the IP isn't waived. Not sure we would be in favor.
It might be good to have all involved at the site together if they feel the need to revisit.
Thanks
Alan
9

DVVR
[division of Dater Resources
Alan D Johnson — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax:[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may
be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Aliisa Harjuniemi [mailto:[e-mail]]
Sent: Tuesday, October 6, 2020 2:04 PM
To: Johnson, Alan <[e-mail]>
Subject: [External] Patterson Road - ID # 20190459
• x ernal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment
am anc r..
Alan,
We just submitted a pre -filing request for the resubmittal of Patterson Road project through the
electronic form. Due to the nature of the project, it would be helpful if you could meet us on site.
10

Our client is requesting an IP waiver.
Thanks,
Aliisa
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Office: 704-527-1177
Blocked Blocked Blocked Blockedwww.cws-inc.net
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Officc- Inn-[;')7-1 1 7-
BlockedBlockedBlockedBlockedwww.cws-inc.net
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
_ ". --- 1-527-' " --
BlockedBlocked Blocked Blockedwww.cws-inc.net
11

Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Office: 704-527-1177
Blocked Blocked Blocked Blockedwww.cws-inc.net
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Office: 704-527-1177
Blocked Blocked Blockedwww.cws-inc.net
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Office: 704-527-1177
Blocked Blockedwww.cws-inc.net
Aliisa Harjuniemi, PWS
Project Manager
Carolina Wetland Services, Inc.
550 E. Westinghouse Boulevard
Charlotte, NC 28273
Direct: 980-259-1222
Office: 704-527-1177
Blockedwww.cws-inc. net
12