20120270 Ver 1_More Info Received_20120507

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UNITED STATES MARINE CORPS
MARINE CORPS INSTALLATIONS EAST — MARINE CORPS BASE
PSC BOX 20005
CAMP LEJEUNE NC 28542 -0005
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IN REPLY REFER TO
5090 11 2
BEMD
MAY 0 3 2012
From Commanding General, Marine Corps Installations East -
Marine Corps Base, Camp Le3eune
To Commanding Officer, United States Army Corps of
Engineers, Wilmington District 69 Darlington Avenue,
Wilmington, NC 28403 Attn, Brad Shaver
Subs APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT (ACTION ID
NO SAW - 2010 - 01797)
Encl (1) Supplemental Information Package for Maintenance
Hangar P683/P687, Parking Structure, and Airfield
Service Roads on Marine Corps Air Station New River,
Marine Corps Base Camp Lejeune North Carolina
1 The enclosed information is provided in response to your
letters dated 20 March 2012, requesting additional information
and 18 April 2012, regarding compliance with Clean Water Act
guidelines on avoidance and mitigation
2 This information has been prepared by our contractor Dial
Cordy and Associates, Inc , on behalf of Marine Corps
Installations East - Marine Corps Base Camp Le3eune
3 The point of contact for this project is Mr Martin Korenek,
Environmental Conservation Branch, Installations, Facilities,
and Environment Department, at telephone [phone] or email
martin korenek@usmc mil
JOHN R TOWNSON
By direction
Copy to _ _ _ _ _ _
NCDENR, DWQ, 401 Section, attn__ I _McMillan 1
NCDENR, DWQ, WRO, attn J Steenhuis
MAY
72012

DIAIL CORDY
AND ASSOCIATES INC
26 April 2012 Enuironmental Consultants
Mr Brad Shaver
Project Manager
USACE Wilmington District
CESAW RG(1145 -b)
69 Darlington Ave
Wilmington NC 28403
RE Action ID No SAW 2010 - 01797! Department of the Army Permit Request
New River Marine Corps Air Station Camp Lejeune NC 28542 0004
Dear Mr Shaver
Dial Cordy and Associates is pleased to respond to your comments dated 19 March 2012 regarding
the above referenced project as well as to the notification from CESAW RG dated 18 April 2012
regarding the 6 February 1990 memorandum of agreement (MOA) between the Department of Army
(DA) and U S Environmental Protection Agency (EPA) establishing procedures for avoidance and
reduction of impacts to wetlands and waters and subsequent compensatory mitigation for
unavoidable impacts We discuss the latter at the end of this letter Regarding the former your
comments from the 19 March letter are transcribed below in italics and below each is our response
in boldface type
1 The US Army Corps of Engineers Wilmington District has received the Manne Corps Base Camp
Lejeune s application for Department of the Army (DA) authorization to construct a Maintenance Hangar
P683IP687 Parking Structure and airfield Service Roads on Marine Corps Air Station New River which is
projected in total to impact 2 81 acres ofjunsdfctional wetlands and 207 linear feet of stream channel
[No response necessary ]
2 The file number assigned to your application is SAW 2010 -01797 Pursuant to the requirements of 33
CFR 325 2 the Corps has reviewed the application and has found it to be incomplete for Issuing a Public
Notice According to the same citation the application must include a complete description of the
proposed activity including necessary drawings sketches or plans sufficient for public notice (detailed
engrneenng plans and specifications are not required) The current package has a large amount of
information (aerials soils and topo mapping) covered which limits the information to give a clear
understanding of the nature and magnitude of the activity to generate meaningful comment The Corps
considered generating alternative maps (readily available from public mapping sources) of the same
scale to supplement the public notice but felt these would not provide a clear understanding of the activity
since they would lack the project overlay Please eliminate the covered sections of the application
On 19 March 2012 we provided revised drawingsisketches via email to clearly
demonstrate the nature and magnitude of the proposed activity Hardcoples were
subsequently sent via USPS
490 OSCCOLA AVENUE JACKSOM'ILLE BEACH FLORIDA 32250
904 241 8821 FAX [phone] E M a infoMalconll com
OFFICE ALSO IN WILMIN('TON NORTH CiROUNA

3 The application states that the proposed impact would require mitigation and that the current mitigation
option would be to use the North Carolina Ecosystem Enhancement Program (NCEEP) In order to have
a complete application please show that the NCEEP is able to provide mitigation for the unavoidable
impacts through their acceptance letter
On 27 March 2012 we provided USACE the NCEEP acceptance latter
4 The public notice needs to be clear to generate public comments Currently figure 4 shows potential
impact to several streams beyond what Is cross hatched on figure 5 It appears that a stream impact may
be expected north of W2 as part of the roadway another stream impact to the surface water emptying
into W3 and finally a surface water impact emptying into W5 The current mapping shows potential
impacts based on the blue line symbol What is not clear is which of these features are or are not
junsdictional9 If the features are not truly jurisdictional as depicted please correct the aforementioned
figures
On 27 March 2012, we provided USACE a revised drawing /sketch via email that labels
the streams noted as potential impact areas They are ephemeral non jurisdictional streams,
and Impacts thereto are not proposed to be compensated through mitigation
5 The following comments are not necessary for the issuance of the public notice but will need to be
addressed during processing of the permit
a The application states that Section 10 impacts are expected where are these section 10
►mpacts9
It was not previously known if any portion of the stream proposed for
filling was considered navigable waters As it appears that they are not, we
are no longer requesting a permit under Section 10
b Where would the source of fill for the project originate from?
The source of fill will be excavated lands elsewhere within the property
boundaries Hydric soils will not be used
c Cross section drawings will be necessary of the impact areas
Please see that attached drawing which shows both the impact area at
Wetland 4 as well as the distance between construction and Wetland 3, and all
adjacent Infrastructurelutilities
d Utilities are discussed ►n the body of the application please show where the utilities run
within the project area
The utilities will run parallel to the road, they are shown in the attached
drawing
Page 2 of 4
RAI Response/ SAW 2010 01797/ 26 April 2012

e Regarding avoidance and minimization could the future squadron warehouse be
onented east west which would allow for the hanger to move further south thus
minimizing impacts further If impacts can be reduced to below 0 5 acre of wetlands and
300 linear feet of stream a natlonwide permit may be a variable for use
The projects consulting engineer the facility manager of the military
base and the environmental consultant have discussed the above alternative
Due to the existing structure (water tower), the squadron warehouse cannot
be oriented east/west Several other alternatives suggested by USACE have
also been considered in order to ensure that wetland impacts are avoided and
minimized to the maximum extent practicable The applicant revisited the idea
of splitting the hangar Into two facilities one of which would be situated
slightly to the north of the western margin of Wetland 4 and the other slightly
to the south During discussions, it was noted that in the early development of
the project that might have been feasible as only two squadrons were
planned for use of the facility, so the hanger(s) could have been smaller
However the hangars were later required to service four squadrons to meet
the project objectives As a result, if the hangar were again divided Into two
facilities, the resulting length of the building would not be simply half of its
proposed configuration, due to the need to replicate certain features in each
hangar to support each of its dual squadrons By having one hangar, there is
greater efficiency of space and less square footage necessary to
accommodate the four combined squadrons Splitting up the building would
therefore result in two buildings longer than half of the proposed single
facility and would then result in Impacts to Wetland 3 (similar to those
depicted in Exhibit 6 of the application package) as well as Wetland 4 due to
the perimeter road
In reference to your letter of 18 April 2012 regarding the DA/EPA MOA we respectfully offer the
following information according to items listed therein as paragraphs 2 a 2 b and 2c
a) Permits for work within wetlands or other special aquatic sites are available only if the
proposed work is the least environmentally damaging practicable altemative Please furnish
information regarding any other altematives including upland alternatives to the work for
which you have applied and provide justification that your selected plan is the least
damaging to water or wetland areas
Please see (1) Final Environmental Impact Statement, US Marine Corps Grow
the Force at MCB Camp Lejeune, MCAS New River, and MCAS Cherry Point, North
Carolina (NAVFAC Mid Atlantic 2009) which provides the rationale for siting the
proposed facilities at MCAS New River, in accordance with the National Environmental
Policy Act (NEPA), (2) our response to Question "D 1a in our initial permit
application dated 29 February 2012, which further details geographic and spatial
considerations necessary to implement project objectives, and also discusses seven
alternative plans that were attempted on order to avoid and/or reduce impacts to
waters /wetlands and (3) the response to RAI question "6e' above, which discusses
an additional pair of alternative plans The resulting proposed plan reduces Impacts
to wetlands and waters of the U S to the maximum extent practicable yet
accomplishes project objectives
Additional graphic materials displaying these alternatives are available at the
USACE's request, if written material is insufficient to effectively demonstrate the nine
other alternatives considered for construction
Page 3 of 4
RAI Response/ SAW 2010 - 01797/ 26 Apn12012

b) It is necessary for you to have taken all appropriate and practicable steps to minimize
wetland or water losses Please indicate all that you have done especially regarding
development and modification of plans and proposed construction techniques to minimize
adverse impacts
Please see the section entitled `On site Avoidance and Minimization Wetland
Avoidance & Impact Minimization Plan in our response to Question "D 1a in our
Initial permit application dated 29 February 2012, which details avoidance and
minimization, including construction techniques Adverse impacts to wetlands and
waters of the U S Include the following Stormwater treatment will make use of
systems of grassed swales, piped culverts, and dry infiltration basins LEED and LID
principles will be Incorporated to the maximum extent practicable, Including
underground infiltration chambers as well as a rainwater harvesting system that will
collect roof drain runoff to be used for vehicle washing Discharge from proposed
grassed swales or engineered BMP s will either connect to existing swales or outfall
Into surrounding wetlands All discharge created by this proposed project will abide
by the allowable permissible flow rates per NCDENR regulations, Including the usage
of level spreaders where necessary Additional information regarding Best
Management Practices (BMPs) that will be utilized during construction are available at
the request of USACE
c) The MOA requires that appropriate and practicable mitigation will be required for all
unavoidable adverse impacts remaining after all appropriate and practicable minimization
has been employed Please indicate your plan to mitigate for the projected unavoidable loss
of waters or wetlands or provide information as to the absence of any such appropriate and
practicable measures
Unavoidable adverse Impacts to wetlands and waters of the U S will be
mitigated via use of the North Carolina EEP, as Indicated in the initial permit
application package
We appreciate your efforts on behalf of federal regulatory compliance for this important project
Should you have any questions regarding the above please contact me at [phone] or
Levert@dialcordy corn at your earliest convenience
Best Rega
Jason Evert
Senior Ecologist
Page 4 of 4
RAI Response/ SAW 2010 01797/ 26 April 2012

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