20201647 Ver 1_USACE More Info Requested_20210222

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, February 22, 2021 2:14 PM
To: Michael Brame
Cc: Homewood, Sue
Subject: [External] RE: Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements -Response
to Request for Additional Information_2.8.2021
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Hi Michael. I reviewed the additional information you provided for this project and found a few items that require
clarification:
1) Sheet 6:
a. It appears that a stream channel is shown within the proposed forested wetland impact. Please confirm
whether or not this is a stream channel, and if so, ensure that these stream impacts are accounted for in
the proposal and that you do not "double count" this area in the wetland impact estimates;
b. Stream buffers are shown near Station 45+00 to-46+50. If a stream exists in this location, ensure that
these stream impacts are accounted for in the proposal;
2) Sheet 8: Although the plan sheet states that this impact is to emergent wetlands, both the plan sheet and aerial
photos indicate that a portion of the wetland proposed for impact is forested. In scaling the forested portion of
the proposed impact, it appears that cumulative forested to herbaceous wetland conversion would exceed 0.1
acre for the project. Please clarify, and proposed compensatory mitigation for any such permanent wetland
conversion as required.
3) Please note that, as currently shown on Sheets 12 and 13, the proposed sewer line would conflict with the
planned stream restoration on the Turner and Ingle properties (see item 6 from our 1/5/2021 request for
additional information). It is our understanding that this portion of the sewer line would occur in a later phase
and that it will be re -designed to avoid any conflicts with the stream restoration. As such, at such time as we
verify the use of NWP 12 for this project, we would include a Special condition documenting the commitment to
avoid impacts to the future restored stream channel.
Please submit the requested information (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we
may deny verification of the use of the Nationwide Permit or consider your application withdrawn and close the file.
Please let me know if you have any questions.
-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.

Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
From: Michael Brame <[e-mail]>
Sent: Monday, February 8, 2021 3:50 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: [Non-DoD Source] Pilot Project 5168.1_Hwy 61/70 Water & Sewer Improvements_Response to Request for
Additional Information 2.8.2021
Dear David and Sue,
Attached is a complete set of updated Buffer Impact Drawings that includes the wetlands impacts along NC61 as
well as an updated Erosion Control Sheet (Sheet 20). The updated erosion control sheet now includes a stream
restoration detail and updated Temporary Stream Crossing Notes in addition to addressing the items below.
1) The review area for the Jurisdictional Determination for the project, dated 5/26/2020, did not cover the
proposed project area in the following locations: 1) the proposed corridor on Sheet 15 from approximately STA
9+00 to 13+81 and 2) the proposed waterline along NC Highway 61. Have these areas been
evaluated/delineated by a qualified environmental consultant? If so, please provide the appropriate
documentation. Note that the Corps may require a site visit to verify the delineation, and additional revisions
may be required on the PCN and plans based on the final Corps -verified boundaries of potential waters of the
US; Pilot personnel delineated the proposed waterline corridor. The attached exhibits depict the delineated
features and include updated impacts to the delineated features and associated buffers.
2) Please confirm that no permanent rip rap is proposed in stream channels below the Ordinary High Water Mark.
If otherwise, please correct the PCN and show on the plans. Any rip rap placed in the streambed must be keyed
in/depressed into the stream bed such that the top of the rip rap is no higher than the stream bed, and the
profile views should clearly show that;
No permanent rip rap is proposed in stream channels below the Ordinary High Water Mark. Temporary rip rap
placed in stream bed shall be removed by contractor following the temporary stream crossing, with permanent
rip rap for maintenance access to remain on banks and above the Ordinary High Water Mark.
3) Sheet 17 near STA 49+00 shows rip rap in the stream channel. Please confirm whether this is existing or
proposed rip rap;
The above referenced rip -rap is existing. Located in a ditch conveying stormwater runoff from a 15" RCP
leading to a 24" RCP culvert traveling under highway US 70.
4) Sheet 20, under "Temporary Stream Crossing Notes", item 7 references "restore stream banks in accordance
with details shown on Sheet 13." However, Sheet 13 does not appear to provide such detail. Please provide a
restoration plan for proposed temporary impacts to streams, ensuring that this plan complies with NWP 12
Regional Conditions 3.10 and 3.11;
Stream Restoration Detail has been added to Sheet 20 and Temporary Stream Crossing Notes have been
updated to reference correct detail.
5) Per NWP General Condition 18, and given recent USFWS concerns regarding suitable small whorled pogonia
habitat and the fact that the nearest known population of this species is less than 3 miles to the north, please
complete a pedestrian survey for this species within the Corps ESA action area during the appropriate field

survey season. In this case, the Corps ESA action area would be contained within a 100 foot radius of the extent
of each footprint of proposed impacts to waters of the US, including the currently proposed footprint and any
revised footprint if project plans are changed per the above items. Following the survey, please provide the
survey report to the Corps (copy also the USFWS) for review. Of course, if you do not believe that any suitable
habitat exists in the Action area for these species, please provide a more specific justification than what was
provided in the PCN so that the Corps could evaluate the potential for a No Effect determination. For reference,
habitat requirements for this species can be found on pages 23-29 of the species' Recovery Plan
(https://ecos.fws.gov/docs/recovery plan/921113b.pdf); Pilot returned to the site and completed a detailed
habitat assessment at the required locations. A copy of the report is attached.
6) Note that the owners of properties on Sheet 13 (specifically Ingle and Turner) have been working to resolve a
stream and buffer violation with NCDWR, and stream restoration has been proposed in this area that may
conflict with the proposed sewer installation project. It may be beneficial for the applicant and these property
owners to coordinate to avoid potential conflicts that may be detrimental to the success of both projects.
The town has communicated with the stream restoration agency regarding the location and timeline of all work
and it was determined that the area of concern is located within a section of Phase 2 of the proposed
project. Since this is a future Phase, there are no immediate concerns for conflict, but correspondence will
continue ensure future impacts are avoided.
Please let me know if you need additional information in order to process the JD.
Sincerely,
Michael Brame