20210050 Ver 1_6_Agency Comments_20201223

Agency Comments
SEPI

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
August 15, 2019
Anna Reusche
SEPI
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Northern High School Replacement, 4804 North Roxboro Street, Durham, Durham County,
ER 15-0387
Dear Ms. Reusche:
Thank you for your letter of July 8, 2019, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.reviewgncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
6namona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Ashley Gallaugher
From: Young, Patrick <[e-mail]>
Sent: Thursday, May 28, 2020 2:14 PM
To: Anna Reusche
Cc: Egan, Sean; Michelle Suverkrubbe; Bernard Hall; Dobrzenski, Bo; Williams, Marvin; Armstrong, Maie;
Judge, Bill; Manns, Peri
Subject: RE: Northern High School Replacement Project Review Request
Ms. Reusche:
Thank you for your recent (May 27, 2020) letter. The information you've requested will be addressed through the City
and County review process of your (currently pending) site plan for this site and subsequent construction drawing
review. These reviews will coordinate City and County comments as they pertain to the local (City and County)
requirements pertaining to environmental impacts of the proposed high school.
There are supplemental issues regarding the transportation system and nearby roadway access that have been raised by
the City and that are not entirely within the purview of the site plan and/or construction drawing review. Development
Services Center Senior Manager Bo Dobrzenski will be convening a group to discuss these issues and will provide a
separate response after internal (City and County) coordination by June 27, 2020 as requested.
Thanks much and advise with any questions or concerns — regards, Pat
M:0
I R IHAM
r� MUUTV
Planning
Patrick O. Young, AICP
Director
Durham City -County Planning Department
101 City Hall Plaza, Ground Floor, Suite G500
Durham, NC 27701
919-560-4137 ext. 28273
Durham City -County Planning Department
Please note that e-mail correspondence to and from this sender may be subject to
the provisions of North Carolina Public Records Law and disclosed to third parties.
From: Anna Reusche <[e-mail]>
Sent: Wednesday, May 27, 2020 9:17 AM
To: Young, Patrick <[e-mail]>
Cc: Michelle Suverkrubbe <[e-mail]>; Bernard Hall <[e-mail]>
Subject: Northern High School Replacement Project Review Request
Dear Mr. Young,
On behalf of Durham Public Schools, the attached information has been provided to solicit comments for any potential
concerns regarding the proposed Northern High School Replacement project located at 4622 and 4804 North Roxboro
Street in Durham, Durham County, North Carolina. The proposed project will consist of a new high school, athletic fields,
track and stadium, parking areas and stormwater management.
Written comments should be submitted no later than June 27, 2020. Please direct your comments and/or questions to:

Anna Reusche, PWS
SEPI, Inc
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Thank you,
ANNA RI:USCHE i-w
-SenmProjilecf Manp9ef
"YGU Atruc-, Sulro'W, RaWgr. ',K: - MO
cftnct "IPJ47S5865 E u9:49P-816.77s5 € sWGnc.€om
We Are Here
Same Service,
Uninfemlohecf
[phone]
[e-mail]
Confidentiality Notice: This message is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be
subject to the attorney -client privilege or other confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this
message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.

Ashley Gallaugher
From: Egan, Sean <[e-mail]>
Sent: Thursday, May 28, 2020 3:54 PM
To: Anna Reusche
Cc: Michelle Suverkrubbe; Young, Patrick; Judge, Bill; Dobrzenski, Bo; Thomas, Earlene; Bernard Hall
Subject: Re: Northern High School Replacement Project Review Request
Attachments: RE: Northern High School Replacement Project Review Request
Dear Ms. Reusche,
Please find attached a related response on this inquiry from City -County Planning Director Patrick Young. As
described in the response, Planning will take the lead in coordinating the response, with support from the
Transportation Department.
Thanks,
Sean
Sean C. Egan
Director of Transportation
City of Durham Department of Transportation
101 City Hall Plaza, Ste. 4200
Durham, NC 27701
P: [phone]
From: Anna Reusche <[e-mail]>
Sent: Wednesday, May 27, 2020 9:28 AM
To: Egan, Sean <Sean.Egan @durhamnc.gov>
Cc: Michelle Suverkrubbe <[e-mail]>; Bernard Hall <[e-mail]>
Subject: Northern High School Replacement Project Review Request
Dear Mr. Egan,
On behalf of Durham Public Schools, the attached information has been provided to solicit comments for any potential
concerns regarding the proposed Northern High School Replacement project located at 4622 and 4804 North Roxboro
Street in Durham, Durham County, North Carolina. The proposed project will consist of a new high school, athletic fields,
track and stadium, parking areas and stormwater management.
Written comments should be submitted no later than June 27, 2020. Please direct your comments and/or questions to:
Anna Reusche, PWS [phone]
SEPI, Inc [e-mail]
One Glenwood Avenue, Suite 600
Raleigh, NC 27603

Thank you,
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Mlntem,ohed
Confidentiality Notice: This message is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be
subject to the attorney -client privilege or other confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this
message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.

Ashley Gallaugher
From: Young, Patrick <[e-mail]>
Sent: Thursday, May 28, 2020 2:14 PM
To: Anna Reusche
Cc: Egan, Sean; Michelle Suverkrubbe; Bernard Hall; Dobrzenski, Bo; Williams, Marvin; Armstrong, Maie;
Judge, Bill; Manns, Peri
Subject: RE: Northern High School Replacement Project Review Request
Ms. Reusche:
Thank you for your recent (May 27, 2020) letter. The information you've requested will be addressed through the City
and County review process of your (currently pending) site plan for this site and subsequent construction drawing
review. These reviews will coordinate City and County comments as they pertain to the local (City and County)
requirements pertaining to environmental impacts of the proposed high school.
There are supplemental issues regarding the transportation system and nearby roadway access that have been raised by
the City and that are not entirely within the purview of the site plan and/or construction drawing review. Development
Services Center Senior Manager Bo Dobrzenski will be convening a group to discuss these issues and will provide a
separate response after internal (City and County) coordination by June 27, 2020 as requested.
Thanks much and advise with any questions or concerns — regards, Pat
M:0
I R IHAM
r� MUUTV
Planning
Patrick O. Young, AICP
Director
Durham City -County Planning Department
101 City Hall Plaza, Ground Floor, Suite G500
Durham, NC 27701
919-560-4137 ext. 28273
Durham City -County Planning Department
Please note that e-mail correspondence to and from this sender may be subject to
the provisions of North Carolina Public Records Law and disclosed to third parties.
From: Anna Reusche <[e-mail]>
Sent: Wednesday, May 27, 2020 9:17 AM
To: Young, Patrick <[e-mail]>
Cc: Michelle Suverkrubbe <[e-mail]>; Bernard Hall <[e-mail]>
Subject: Northern High School Replacement Project Review Request
Dear Mr. Young,
On behalf of Durham Public Schools, the attached information has been provided to solicit comments for any potential
concerns regarding the proposed Northern High School Replacement project located at 4622 and 4804 North Roxboro
Street in Durham, Durham County, North Carolina. The proposed project will consist of a new high school, athletic fields,
track and stadium, parking areas and stormwater management.
Written comments should be submitted no later than June 27, 2020. Please direct your comments and/or questions to:

Anna Reusche, PWS
SEPI, Inc
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Thank you,
ANNA RI:USCHE i-w
-SenmProjilecf Manp9ef
"YGU Atruc-, Sulro'W, RaWgr. ',K: - MO
cftnct "IPJ47S5865 E u9:49P-816.77s5 € sWGnc.€om
We Are Here
Same Service,
Uninfemlohecf
[phone]
[e-mail]
Confidentiality Notice: This message is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be
subject to the attorney -client privilege or other confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this
message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.

Ashley Gallaugher
From: Somerville, Amanetta <[e-mail]>
Sent: Friday, June 26, 2020 12:20 PM
To: Anna Reusche
Cc: Kajumba, Ntale
Subject: EPA Start of Study Comments on the Northern High School Replacement on Roxboro Street in
Durham County, North Carolina
Dear Ms. Reusche:
The U.S. Environmental Protection Agency (EPA) Region 4 appreciates the opportunity to provide comments
on the proposed Northern High School Replacement project on N. Roxboro Street in Durham County, North
Carolina. In response to your May 27, 2020, environmental assessment scoping notice, the EPA has reviewed
the provided information and used geospatial and environmental quality data analysis tools (please see links
to online databases and tools provided at the end of this email for reference) to provide the following
technical comments and recommendations:
Waters of the United States:
A review of the proposed project area shows the presence of two unnamed jurisdictional streams. The GIS
analysis of the National Wetlands Inventory identified several acres of riverine wetlands located in the
proposed project area as well. The EPA recommends that any contractor working on -site should use best
management practices and should address any potential impacts to off -site streams and waterways. The EPA
also recommends that site grading, excavation, and construction plans should include implementable
measures to prevent erosion and sediment runoff from the project site during and after construction.
Consistent with Section 404 of the Clean Water Act, the project should avoid and minimize, to the maximum
extent practicable, placement of fill into jurisdictional waters of the United States, which include wetlands and
streams. Any fill material in waters of the United States will potentially require permit authorization from the
U.S. Army Corps of Engineers (COE). Any wetland or stream losses allowed under a COE Section 404 permit,
should be mitigated by the applicant. This mitigation can be designed and implemented by the applicant or
procured by the purchase of wetland and stream mitigation credits from a commercial wetland mitigation
bank.
Stormwater:
The proposed construction of Northern High School replacement will increase impervious surface area,
thereby increasing stormwater runoff during times of precipitation. The EPA supports the development of a
stormwater management system proposed in the scoping notice. Additionally, the site grading, excavation,
and construction plans should include implementable measures to prevent erosion and sediment runoff from
the various project sites during and after construction.
The EPA appreciates the opportunity to submit scoping comments. If there are any questions regarding these
comments, please feel free to contact me by phone at 404-562-9025 or via email at
[e-mail].
Links to online resources used in this analysis:

• FWS Wetlands Mapper: https://www.fws.gov/wetlands/Data/Mapper.html
Amanetta Somerville
U.S. Environmental Protection Agency Region 4
61 Forsyth Street SW. Atlanta, Ga 30303
National Environmental Policy Act Section
Strategic Programs Office
Phone: [phone]
E-mail: [e-mail]

Ashley Gallaugher
From: Mann, Leigh <[e-mail]>
Sent: Wednesday, June 17, 2020 4:54 PM
To: Anna Reusche
Subject: UPDATED LETTER Fw: [EXTERNAL] Northern High School Replacement Project Review Request
Attachments: 20200617_LTRSNT_FWS_SEPllnc_NorthernHighSchoolReplacement. pdf
Mrs. Reusche,
My apologies but I just realized the first letter didn't have the signature so here is the correct one.
Respectfully,
Leigh Mann
Office Automation
USFWS Raleigh ES FO
551-F Pylon Drive
Raleigh, NC 27606
Office: 1-919-856-4520 ext. 10
Fax: [phone]
leigh mann(aD-fws.gov
NOTE. This email correspondence and any attachments to and from this sender is subject to the Freedom of
Information Act (FOIA) and may be disclosed to third parties.
From: Mann, Leigh <[e-mail]>
Sent: Wednesday, June 17, 2020 4:32 PM
To: Anna Reusche <[e-mail]>
Subject: Re: [EXTERNAL] Northern High School Replacement Project Review Request
Mrs. Reusche,
Please find the attached pdf letter for the above listed project. If you need anything additional please let me
know.
Respectfully,
Leigh Mann
Office Automation
USFWS Raleigh ES FO
551-F Pylon Drive
Raleigh, NC 27606
Office: 1-919-856-4520 ext. 10
Fax: [phone]

leigh mann(@-fws.gov
NOTE. This email correspondence and any attachments to and from this sender is subject to the Freedom of
Information Act (FOIA) and may be disclosed to third parties.
From: Jordan, Gary <[e-mail]>
Sent: Wednesday, May 27, 2020 9:53 AM
To: Mann, Leigh <[e-mail]>
Cc: Anna Reusche <[e-mail]>; Michelle Suverkrubbe <[e-mail]>; Bernard Hall
<[e-mail]>
Subject: Fw: [EXTERNAL] Northern High School Replacement Project Review Request
Leigh,
Please assign this to the appropriate staff. It is not an NCDOT project, so I won't be working on it. Thanks.
Gary Jordan
Fish and Wildlife Biologist, Liaison to NCDOT
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, NC 27636-3726
Phone:[phone] x.32
Email: [e-mail]
From: Anna Reusche <[e-mail]>
Sent: Wednesday, May 27, 2020 9:38 AM
To: Jordan, Gary <[e-mail]>
Cc: Michelle Suverkrubbe <[e-mail]>; Bernard Hall <[e-mail]>
Subject: [EXTERNAL] Northern High School Replacement Project Review Request
Dear Mr. Jordan,
On behalf of Durham Public Schools, the attached information has been provided to solicit comments for any potential
concerns regarding the proposed Northern High School Replacement project located at 4622 and 4804 North Roxboro
Street in Durham, Durham County, North Carolina. The proposed project will consist of a new high school, athletic fields,
track and stadium, parking areas and stormwater management.
Written comments should be submitted no later than June 27, 2020. Please direct your comments and/or questions to:
Anna Reusche, PWS
SEPI, Inc
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Thank you,
[phone]
[e-mail]

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Confidentiality Notice: This message is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be
subject to the attorney -client privilege or other confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this
message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh ES Field Office
551-F Pylon Drive
Raleigh, North Carolina 27606
June 17, 2020
Anna Reusche
SEPI, Inc.
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Re: Northern High School Replacement — Durham County
Dear Mrs. Reusche:
This letter is to inform you that the Service has established an on-line project planning and
consultation process which assists developers and consultants in determining whether a
federally -listed species or designated critical habitat may be affected by a proposed project. For
future projects, please visit the Raleigh Field Office's project planning website at
https://www.fws. ovg /raleigh/pp.html. If you are only searching for a list of species that may be
present in the project's Action Area, then you may use the Service's Information, Planning, and
Consultation System (IPaC) website to determine if any listed, proposed, or candidate species
may be present in the Action Area and generate a species list. The IPaC website may be viewed
at https://ecos.fws.goy/ipac/. The IPaC web site contains a complete and frequently updated list
of all endangered and threatened species protected by the provisions of the Endangered Species
Act of 1973, as amended (16 U.S.C. 1531 et seq.)(Act), a list of federal species of concern' that
are known to occur in each county in North Carolina, and other resources.
Section 7 of the Act requires that all federal agencies (or their designated non-federal
representative), in consultation with the Service, insure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
federally -listed endangered or threatened species. A biological assessment or evaluation may be
prepared to fulfill that requirement and in determining whether additional consultation with the
Service is necessary. In addition to the federally -protected species list, information on the
species' life histories and habitats and information on completing a biological assessment or
'The term "federal species of concern" refers to those species which the Service believes might be in need of
concentrated conservation actions. Federal species of concern receive no legal protection and their designation
does not necessarily imply that the species will eventually be proposed for listing as a federally endangered or
threatened species. However, we recommend that all practicable measures be taken to avoid or minimize adverse
impacts to federal species of concern.

evaluation and can be found on our web page at http://www.fws.gov/raleigh. Please check the
web site often for updated information or changes.
If your project contains suitable habitat for any of the federally -listed species known to be
present within the county where your project occurs, the proposed action has the potential to
adversely affect those species. As such, we recommend that surveys be conducted to determine
the species' presence or absence within the project area. The use of North Carolina Natural
Heritage program data should not be substituted for actual field surveys.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a federally -protected species, you should notify this office with your
determination, the results of your surveys, survey methodologies, and an analysis of the effects
of the action on listed species, including consideration of direct, indirect, and cumulative effects,
before conducting any activities that might affect the species. If you determine that the proposed
action will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on federally
listed species, then you are not required to contact our office for concurrence (unless an
Environmental Impact Statement is prepared). However, you should maintain a complete record
of the assessment, including steps leading to your determination of effect, the qualified personnel
conducting the assessment, habitat conditions, site photographs, and any other related articles.
With regard to the above -referenced project, we offer the following remarks. Our comments are
submitted pursuant to, and in accordance with, provisions of the Endangered Species Act.
Based on the information provided and other information available, it appears that the proposed
action is not likely to adversely affect any federally -listed endangered or threatened species, their
formally designated critical habitat, or species currently proposed for listing under the Act at
these sites. We believe that the requirements of section 7(a)(2) of the Act have been satisfied for
your project. Please remember that obligations under section 7 consultation must be
reconsidered if: (1) new information reveals impacts of this identified action that may affect
listed species or critical habitat in a manner not previously considered; (2) this action is
subsequently modified in a manner that was not considered in this review; or, (3) a new species
is listed or critical habitat determined that may be affected by the identified action.
However, the Service is concerned about the potential impacts the proposed action might have
on aquatic species. Aquatic resources are highly susceptible to sedimentation. Therefore, we
recommend that all practicable measures be taken to avoid adverse impacts to aquatic species,
including implementing directional boring methods and stringent sediment and erosion control
measures. An erosion and sedimentation control plan should be submitted to and approved by
the North Carolina Division of Land Resources, Land Quality Section prior to construction.
Erosion and sedimentation controls should be installed and maintained between the construction
site and any nearby down -gradient surface waters. In addition, we recommend maintaining
natural, vegetated buffers on all streams and creeks adjacent to the project site.
The North Carolina Wildlife Resources Commission has developed a Guidance Memorandum (a
copy can be found on our website at (http://www.fws.gov/raleigh) to address and mitigate
secondary and cumulative impacts to aquatic and terrestrial wildlife resources and water quality.

We recommend that you consider this document in the development of your projects and in
completing an initiation package for consultation (if necessary).
We hope you find our web page useful and informative and that following the process described
above will reduce the time required, and eliminate the need, for general correspondence for
species' lists. If you have any questions or comments, please contact John Ellis of this office at
[phone] ext. 26.
Sincerely,
Pete Benjamin
Field Supervisor

"R " D U R H A M Construction and Capital Planning
�� boo 511 Cleveland Street / Durham, North Carolina, 27701
PUBLIC SCHOOLS 919-560-2000
Date: May 26, 2020
To: [NAME]
[ADDRESS]
Subject: NEPA Scoping for Proposed Northern High School Replacement
Dear [NAME],
Durham County Public Schools (DPS) is preparing an Environmental Assessment (EA) document under the
National Environmental Policy Act (NEPA) for the proposed Northern High School Replacement project in the
City of Durham, Durham County. The location of this project (see attached Vicinity Map) includes two adjacent
parcels located at 4804 and 4622 N. Roxboro Street. Proposed development will consist of a new high school,
athletic fields, track and stadium, parking areas and stormwater management. To date, a Phase 1 ESA,
Natural Resources Report and associated wetland delineation, buffer determination, aquatic assessment and
threatened and endangered species habitat assessments have been completed (see attached Environmental
Resources Map).
Due to projected impacts on Jurisdictional Waters of the U.S., an Individual Permit and associated Water
Quality Certification are required by the USACE under Sections 401 and 404 of the US Clean Water Act,
respectively. SEPI, Inc. is assisting DPS in preparing this Individual Permit application as well as a Statement
of Findings - Environmental Assessment (SOFEA) under USACE's NEPA Guidelines. By default, approved
NEPA documents, such as the proposed SOFEA, automatically satisfy the requirements of SEPA (State (NC)
Environmental Policy Act).
This notification letter will act as a Start of Study/Agency Scoping letter under NEPA for this project. We would
greatly appreciate any information that you can provide that would be helpful in the further evaluation of
potential environmental impacts associated with the project. Given prior scoping comments received on the
project from several agencies (including the State Historic Preservation Office), scoping through the State
Environmental Clearinghouse is not proposed. There is also no plan to hold a scoping meeting.
Written comments should be submitted no later than June 26, 2020. Please direct your comments and/or
questions to:
Anna Reusche, PWS [phone]
SEPI, Inc [e-mail]
One Glenwood Avenue, Suite 600
Raleigh, NC 27603
Sincerely,
Bervi arr� 4fxt t
Bernard Hall, Project Manager
Durham Public School
Construction & Capital Planning
Attachments: Vicinity & Environmental Resources Maps, Agency Notification Contact List