20201906 Ver 1_More Info Requested_20210228

Strickland, Bev
From: Homewood, Sue
Sent: Sunday, February 28, 2021 4:52 PM
To: Brad Luckey; [e-mail]
Cc: Bailey, David E CIV USARMY CESAW (USA)
Subject: RE: [External] Request for Additional Information - Summit Creek Charter Academy,
Scott Road, Greensboro, Guilford County; SAW-2020-00128
0
Please copy me on your response to David's questions listed below. In addition, I have one question/clarification
regarding the Jordan Lake Buffer Rules. Are all portions of the sewer line shown on the plans to be considered a private
sewer by the City and therefore covered under the City's implementation of the Jordan Lake Buffer Rules?
I will place the application on hold until all items have been addressed. Please respond by March 31, 2021.
Thank you.
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: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, February 9, 2021 10:24 AM
To: Brad Luckey <[e-mail]>; [e-mail]
Cc: Homewood, Sue <[e-mail]>
Subject: [External] Request for Additional Information - Summit Creek Charter Academy, Scott Road, Greensboro,
Guilford County; SAW-2020-00128
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Thank you for your PCN and attached information, dated 1/15/2021, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 12
(http://saw-reg.usace.army.mil/NWP2017/2017NWP12.pdf). Please submit the requested information below (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Permit or consider your application withdrawn and close the file:
1) The project plans show the proposed sewer corridor extending approximately 320 If on the east side of Stream
MSA, however neither the PCN package nor the delineation map (see PJD issued 6/11/2020) indicate that any
areas on the east side of Stream MSA have been evaluated/delineated for potential waters of the US. Given the
high likelihood of wetlands within the proposed sewer corridor, and per NWP General Condition 32(b)(5), please
provide an evaluation/delineation of this area per the current Corps, Wilmington District guidance on obtaining
a jurisdictional determination. Note that, upon receipt of the preceding information, a site visit may be required
to verify your delineation of potential waters of the US; wetland data forms and pictures may help in this regard;
2) Based on the PJD issued 6/11/2020, it appears that the proposed sewer line corridor and bore -and -jack
entry/exit pit is designed within a braided section of Stream MSA. However, the project plans do not show the
braided section of this stream. Please update the plans accordingly, as this information is necessary to fully
evaluate avoidance and minimization as required by NWP General Condition 23(a) and (b);
3) The PCN and plans do not appear to demonstrate avoidance and minimization to the maximum extent
practicable as required by NWP General Conditions 23(a) and (b). For example, the sewer corridor crosses
Wetland WB at its widest point (and also see item 2 above). Further, the bore -and -jack entry/exit pits are
designed within wetlands. Please re -design the sewer corridor to cross a narrower section of wetlands, and/or
design the bore -and -jack entry/exit pits outside of the wetland boundaries. If such avoidance and minimization
measures are not practicable (i.e. available and capable of being done after taking into consideration cost,
existing technology, and logistics in light of overall project purposes), provide clear reasoning/documentation;
4) Please provide a zoomed -in view of the other sewer crossing where stream impacts are proposed to be avoided
via bore -and -jack;
5) The PCN states that the permanent fill of 0.011 acres of wetlands would be required to satisfy City of
Greensboro sewer line maintenance slope requirements. However, these impacts are not shown/labeled on the
project plans. Further, please provide additional information as to why this impact cannot be avoided or made
temporary, as such a proposal for permanent wetland fill for a sewer crossing is unusual in Guilford County;
6) Per NWP General Condition 18, and given recent USFWS concerns regarding suitable small whorled pogonia
habitat, 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 the 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);
Please let me know if you have any questions.
Sincerely,
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.