20070245 Ver 1_Other Agency Comments_20070504

DEPARTMENT OF THE ARMY
WILIVIINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMT1vGTON. NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF:
CESAW-RG(1145-b)
o7-oa~.S
~.do.~sLd.. 5J~ y 1 ~
20 April 2007
MEMORANDUM FQR Commanding General, Marine Corps Base, Camp Lejeune, Attn: Mr.
Martin Korenek, PSC 20004, Building 12 Camp Lejeune, North Carolina 28542
SUBJECT: Action ID No. 2007 286 067, Department of the Army Permit Request
1. Please reference your request for a Department of the Army authorization and a State Water
Quality Certification to impact 12.5 acres of jurisdictional wetlands and 12,8001inear feet of
stream associated with the construction of a Special Forces detachment to be known as the
Marine Corps Special Operations Command (MARSOC) within Camp Lejeune, Onslow County,
North Carolina.
2. At the conclusion of the thirty-day public notice period, we received two comment letters,
one from the North Carolina Wildlife Resources Commission and one from the United States
Fish and Wildlife Service in reference to the proposed project. The Corps has not received any
other agency or public comments to date. The NC Wildlife Resources Commission did not
object to the issuance of the permit provided that strict adherence to the proposed minimization
and avoidance requirements are completed. The Commission's comments are attached for your
review. The Service comments echo the Wildlife Resources Commission comments in regards
to avoidance and minimization but also strongly recommends bridges and where not practicable
box culverts over jurisdictional areas. The Service comments are also attached for your review
and consideration. The Corps will forward any late comments from other resource agencies or
the public as they are received.
3. Upon a closer review of the submitted plans, the Corps notes a couple of opportunities for
additional minimization of proposed impacts. Specifically, the proposed development labeled as
"future" sever the wetland drains below the headwater systems. With this disruption of the
natural system it in essence affects the headwater systems likely causing additional cumulative
impacts. To further minimize impacts, the Marine Corps should explore removing these "future"
impacts from the proposed development or relocate them to more headwater positions thus
reducing cumulative impacts. Also, there are a number of small impacts in the natural drainage
features that are either associated with corners of proposed structures or crossings associated with
the road system. The majority of these drains are deeply incised and could be crossed easily with
small bridges or bottomless culverts. Please explore these no impact approaches as possible
options to further minimize proposed impacts.
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. '<"°'?Y~R~Qq BRA .A1dCH

CESAW-RG (1145-b)
SUBJECT: Action ID No. 2007 286 067, Department of the Army Permit Request
4. Finally, once the unavoidable wetland impact is established, more discussion needs to be
given to the mitigation. Regulatory policy requires that on-site or near site mitigation should be
explored before off-site alternatives are considered. There needs to be a better attempt to provide
mitigation in the area where the wetland loss will occur. The Marine Corps needs to further
explore on-site mitigation options first. During early visits to the Stone Bay Rifle Range by my
staff, there was at least one on-site mitigation option noted near a maintenance building down
from Brown Trail. This culvert removal should be incorporated as part of the mitigation plan
and attention given to finding other on-site mitigation options. If other on-site options are not
discovered, the Corps is in favor of the Marine Corps exploring its mitigation bank as a possible
near site mitigation option. More information will be known about its availability for use after
planned site visits by my staff. Utilizing the NC EEP program should be viewed as a last option.
The NC EEP program guarantees that the mitigation will occur in the same Hydrologic Unit
Code (HiJC) but there is no assurance that the restoration will occur near the site or even east of
Highway 17. If no other alternatives are shown to be available, you maybe required to mitigate
at a higher ratio to compensate for the expected distance of the mitigation project from the
wetlands impacted by your project.
5. Our administrative process provides you the opportunity to propose a resolution and/or rebut
any and all objections and comments before a final decision is made. In this regard, I would
appreciate being made aware of your intentions, in writing, on or before June 1, 2007. My staff
looks forward participating on the design build team. Any resolution of these issues before June
1, 2007, will expedite our review.
6. Mr. Brad Shaver of my Regulatory Division is responsible for processing your application. If
you have any questions or comments concerning this correspondence, please call Mr. Shaver at
[phone].
Encl
CF:
Ms. Becky Fox
Wetlands Regulatory Section -Region IV
U.S. Environmental Protection Agency
1349 Firefly Road
Whittier, North Carolina 28789
~~~
Colonel, EN
Commanding
2

CESAW-RG (1145-b)
SUBJECT: Action ID No. 2007 286 067, Department of the Army Permit Request
Ms. Cyndi Karoly
Division of Water Quality
N.C Department of Environment
and Natural Resources
2321 Mail Service Center
Raleigh, North Carolina 20601-2260
Mr. John Hammond
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636-3726
Mr. Steven H. Everhart
N.C. Wildlife Resources Commission
1721 Mail Service Center
Raleigh, North Carolina 27699-1721
3

0`l-02,.}5
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Cazolina 27636-3726
April 11, 2007 qPR 1 ~ 2007
Mr. Brad Shaver ~~ ~~~
U. S. Army Corps of Engineers 1 '
Wilmington Regulatory Field Office MAY ~ 2007
P. O. Box 1890
Wilmin ton North Carolina 28402-1890 ..~t;,~r+-WATERQUA~iTY
g ~ Y~`ETt ans~~.~; ~,ND TC~aM!nrpTEP, BRArdCH
Subject: Action Il?#200'-00286-067, Marine Corps Base Camp Lejeune, MARSOC facility, Onslow
County, NC
Dear Mr. Shaver:
This letter provides the comments of the U. S. Fish and Wildlife Service (Service) on the subject
Public Notice, dated ~%Iarc~.7, 200,7., The applicant, Marine Corps Base Camp Lejeiine; has'applied"
for a pepartment :of the. Army (D~) .ermit to impact,12.5 acres of ~uris'dictiorial w`etland's-and 12,800
.....
linear feet. of streams to cox~~truct a facility for the iVlarine Corps Special f~peratltyris Cdiarrd '"`'
(1VIARSOC) These comments, are siibinitted in accordance ~ri'th the~F"~sh anclW~ld~i~e Co`orciinati'o~
Act (FWeA) (48 Stat. 401,nas amended; 1~6 U.S:C. 661-667d). Comrrierits rel'at:ed fo~the'~'~WCtk~are
ta:be;used ire Your determination of compliance with 404(b)(1) guidelines (40 CFR 230) and in your
public interest review (33 CFR 320.0 iri relation to the protection of fish and wildlife resources.
Additional corriments are provided regarding the District Engineer's determination of project impacts
pursuant to section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 153 l-
15A~3)~ -.
Project Area,. Proposed Activities, and Environmental Impacts
The project area is a 1,857-acre tract east of Stone Bay along'New River. Except for some existing
training facilities, the' area is primarily forested with approximately 345 acres of wetlands. The area
has streams which range from ephemeral to intermittent/perennial. The streams and associated
wetlands are considered as headwater systems which flow into Stone Bay. The PN notes that some
are~as;show head cuts and incised channels. Water in the channels of the upstream area closest to the
project site was-absent to weak with moderate to strong leaf litter. The benthic macroinvertebrate
community appears to be week due to the input of sediment: The PN states that the unnamed
..
tribiitary,that dissects the project area has been designated as a Primary Nursery~Area (PNA) by the
North Carolina. Divisioii'of 1Vlanrie Fisheries: _ ~ ~~ - ` '
. - .. ..
. t~ i t 'i s. ,t.: ~ tit 'r cr ~._
T~ie.apl?licant rQ~iose t:o~const ~ct~a new cbmplEx`to sn cirt liousiri i;.tratnrn , and s~e~ri ~or,'.~r
~ .. ~~ r ~ ~ ~ j?P ~ g ~
1v,~'SCE~~nc ud~a~'an~illaryrfacil~ties and u ilifie5{,The"site~cor~ip"le~i~n~ffi~ie~ap~roximalely~~~#4=
,acres Cons~ruc~ton woulc~~invol~ve gr~dmg, drainatg~; feri~ing~ and road deii'ib~itttin'~s~e~)''a~s~oad
im rovements and new road cbnst~ruc`t'ion' to.access'and support,the ner~` ~'acil.~t`~ The ~aariC'7~ r ~ j~
expected to pexmaneaxtly,impacti 12.S,acres of wetlands (9.3 acre`s of riparian'wetlarrtfs'and "3 2 ~aci'es
ofnon-riparian wetlands) as well as 1,800 inear feet (2:42'~iles)'of`streams: " ~ ~ '

Compensatory mitigation would be provided by at the Greater Sandy Run Area (GSRA) Wetland
Mitigation Bank which is within Camp Lejeune and west of the project site. The PN states that over
50.0 credits are available within the bank. Some credits are non-riparian wetlands such as pine
flatwoods and pocosins, but bottomland hardwoods credits are available. The number of credits to be
debited for the proposed work is not given. The PN also states that the applicant would provide
compensatory- mitigation for riparian wetlands and stream impacts by payment to the North Carolina
Ecosystem Enhancement Program if no on-site mitigation alternatives are available.
Federally Protected Species
The applicant initiated informal consultation pursuant of section 7 of the ESA by correspondence
datedbecember 4, 2006. The applicant provided the Service with information on listed species that
could occur in the project area and the nature of the proposed work. The two species of greatest
concern are the red-cockaded woodpecker (Picoides borealis) (RCW) and rough-leaved loosestrife
(RLL) (Lysimachia asperulifolia). Both are listed as endangered. The applicant stated that there
were no RCW clusters within ahalf--mile of the proposed compound. Surveys for the RLL were
conducted along the route of new sewer pipe. No RLL or other listed plants were found along the
route.
By letter dated January 18, 2007, the Service informed the applicant that, based on the information
provided, the Service believed that the construction of the MARSOC compound and supporting
facilities was not likely to adversely affect the RCW, RLL, or any other federally listed species or
species currently proposed for federal listing under the ESA. Therefore, the Service would concur
with a determination by the District Engineer that the action is not likely to adversely affect species
designated as threatened, endangered, or their designated critical habitat. However, the requirements
of section 7 would need to 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 maybe affected by the identified action.
Service Concerns and Recommendations
The Service supports creating adequate training facilities for the applicant. However, we wish to
ensure that all feasible measures are taken to avoid and minimize the adverse environmental impacts
associated with constructing these facilities.
The Service is concerned about any loss of PNA. However, the upper reaches of the streams in the
project area, which appear to be impacted the most by this work, seem to be somewhat degraded by
sedimentation and incised channels. In order to benefit fisheries resources, the Service encourages
the Corps to work with the applicant to seek stream reaches outside the construction area that could
be enhanced for~fisheries resources. Incised channels outside the construction footprint could be
restored. Degraded channels which do not now have riffle-and-pool sequences could be evaluated to
see if such features could be developed. Any DA permits should require adequate stormwater control
measures.

3
The DA should be conditioned to prohibit poorly designed crossings which can impede water flow
and block animal passage. The applicant should consider low bridges to cross streams and wetlands
as an alternative to culverts. If streams and wetlands are crossed without bridging, culverts should
adequately convey flowing water.. If areas with flowing water are not bridged, culverts should be of
adequate size and buried in the substrate. Culverts should maintain natural water flows and hydraulic
regimes without scouring, or impeding fish and wildlife passage. Culverts or pipes should be of
sufficient size to allow normal surface water exchange between the wetlands above and below the
culvert. The Service recommends that streams and wetlands be crossed by one or more buried, box
culverts which extends across the entire wetland area and include a portion of each adjacent upland
margin. Such a design would not only convey low flows, but also allow for the. conveyance of major
storm events. The natural substrate bottoms would facilitate the movement of aquatic species.
With regard to compensatory mitigation, the Service does not oppose the use of the GSRA mitigation
bank for in-kind mitigation. If adequate in-kind compensation is not possible, primarily-for riparian
wetland and stream losses, the Service would prefer on-site enhancement of areas which are presently
degraded. Work in riparian areas along stream could involve planting native trees and shrubs in
areas tivith impoverished vegetation as well as the removal of any undesirable invasive/foreign
species. As noted, restoration or enhancement may be possible in streams outside the construction
area.
Overall, we do not believe, based on information in the PN, that the proposed activity will have
significant adverse and/or irreversible effects on general fish and wildlife resources under our
jurisdiction. Therefore, with adequate measures of avoidance and minimization along with adequate
in-kind compensatory mitigation, the Service has no objection, from the standpoint offish and
wildlife, to the issuance of a DA permit for the proposed work.
The Service appreciates the opportunity to comrrient on this permit application. If you have
questions regarding these comments, please contact Howard Hall at 919-856-4520, ext. 27 or by e-
mail at < [e-mail] >.
nce 1 ,
Pete Hamm
Field pervisor
cc: Steve Everhart, NCWRC, Wilmington, NC
Noelle Lutheran, NC Division of Water Quality, Wilmington, NC
Stephen Rynas, NC Division of Coastal Management, Morehead City, NC

® North Carolina Wildlife Resources Commission
Richard B. Hamilton, Executive Director
MEMORANDUM
To: Cyndi Karoly
NC DENR/DWQ ~
From: Steven H. Everhart, PhD, CWB a~""~"
Southeastern Permit Coordinator
Date: March 6, 2007
RE: MCB Camp Lejeune, MARSOC Complex, Onslow County, DWQ No. 20070245, USAGE AID# 2007-00286-
067
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
application for impacts to wildlife and fishery resources. Our comments are provided in accordance with provisions
of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et. seq.), and Sections 401 and
404 of the Clean Water Act (as amended).
The project is located northeast of NC 210 in areas near the Stone Bay Ranges Complex, aboard MCB Camp
Lejeune, Onslow CounTy. The nearest body of water is New River and its tributaries.
The applicant proposes to mechanically clear, cut and fill an estimated 12.5 acres of wetlands (9.0 riparian/3.5 non-
riparian) and 12,800 linear ft of stream to construct a Marine Special Operations Command complex including a
headquarters building, operations and supply storage buildings, ammunition storage building, security fencing and
underground utilities (sewer) across the New River. The complex will also include a telephone distn~bution system,
secondary power distribution system, data distribution system, roads, and parking. Directional boring will be
required under waters of the U. S. for utility lines. Minimization and avoidance of wetland impacts will be required
and mitigation is proposed through use of GSRA mitigation bank credits and payment to the NC EEP.
We have no objection to the issuance of the permits applied for in this application, provided strict adherence to the
proposed minimization and avoidance requirements are enforced and unavoidable impacts are fully mitigated. We
look forward to further review as the final design plans are developed.
Thank you for the opportunity to review and comment on this application. If you have any questions or require
additional information, please call me at [phone].
CC: Noelle Lutheran, NCDWQ
Fritz Rohde, NCDMF
Howard Hall, USFWS
Stephen Rynas, NCDCM
Brad E. Shaver, USAGE
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] Fag: [phone]