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Home My WebLink About20150525 Ver 1_USACE Correspondence_20061106_~~~~~ IN REPLY REFER TO Action ID No. 200211070 DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS Washington Regulatory Field Office P.O. BOX 1000 Washington, North Carolina 27889-1000 November 2, 2006 ~a N~V ~ ~~~i~~i Mr. David James (Code EV41DJ) 9N~p8aa~~:r~~~N~'l~! Commander, NAVFAC Atlantic Division 6506 Hampton Boulevard Norfolk, Virginia 23508-1278 SUBJECT: Wetlands Assessment and Mapping for OLF Sites Alternative Analysis Mr. James: This correspondence confirms our receipt of the Outlying Landing Field (OLF) Wetland Mapping Project associated-with the U.S. Department of the Navy's preparation of a Supplemental Environmental Impact Statement (SEIS) including the proposed construction of an outlying landing field (OLF) facility in eastern North Carolina. A complete version of this document was received by the Wilmington District Regulatory Division on October 17, 2006. Jurisdictional wetlands at the alternative sites (Sites A-E) were initially identified through various means ofremote-sensing that included NWI map review, soil survey analysis, aerial photo and satellite imagery review, windshield surveys, and helicopter reconnaissance. These remote-sensing methodologies were determined to be inadequate because they did not provide a sufficient level of detail for the USAGE to consider alternatives that would avoid and minimize impacts to jurisdictional waters under the Clean Water Act. Specifically, the USAGE requested that the Department of the Navy further the findings of the Environmental Impact Statement published in July 2003 with a combination ofremote-sensing supported by focused, on-site verification of wetlands at each site Beginning in November 2005, Land Management Group, Incorporated (LMG) was subcontracted by Geo-Marine Incorporated (GMI) to perform preliminary wetland mapping exercises on the five alternative OLF site locations. These sites are located throughout the outer coastal plain of North Carolina. LMG completed basic field reconnaissance on four of the five sites. The project was encumbered by site access limitations as several local property owners were uncooperative. LMG honored all of the access agreements secured by the Navy for this work. A majority of the land reviewed by LMG is owned and/or managed by Weyerhaeuser Corporation or the United States Government, who allowed entry. LMG determined that several different land-use management practices have been applied to each site over the past several decades. All incorporated prescribed drainage improvements for increasing yields in both agriculture and timber production. While a significant amount of jurisdictional wetland acreage has been impacted by these historic land-use practices, jurisdictional waters and wetlands are still present at each site. USACE wetland data sheets with site specific plant, soils, and hydrologic information were compiled in representative soil types on all accessible tracts (Sites B-E). This information was compared with available well data and infrared aerial photography to support a preliminary wetland boundary determination. These boundaries were then compared with existing data developed by state and federal agencies (NC- Crews, NWI, etc.). Staff from the Washington Regulatory Field Office accompanied Mr. Brent Manning, LMG, you, and Mr. Paul Block, NAVFAC Atlantic, to sites B, C, and E on October 23 through October 25, 2006. The purpose of these site visits was to evaluate the preliminary boundary mapping techniques and review the findings discussed in the Outlying Landing Field (OLF) Wetland Mapping Project. In general, staff agrees with the findings outlined in the study. It was noted and discussed that this mapping effort is a "broad-brush" approach and should be used for preliminary planning and alternatives analyses only. Boundary lines reviewed and depicted in the study are approximate and do not represent a distinct boundary between jurisdictional and non jurisdictional areas. For example, additional jurisdictional areas beyond those reported were observed at each of three sites visited. This discovery however does not significantly alter LMG's findings. A synopsis of the findings at each site is listed below: A - Perquimans 2,000 37.3 acres 19,613 linear feet 493 acres 1,517 acres Coun ~ acres B - Berfie County 2,000 S 15 acres 2,3001inear feet 2,000 acres n/a acres C -Washington 2,000 <10 acres 52,881 linear feet n/a 1,980 acres Coun acres D -Hyde County 2,000 240 acres 29,599 linear feet 240 acres 1,760 acres acres E -Craven County 2,000 902 acres 24,453 linear feet 2,000 acres n/a acres 1- All data provided based on interpretation of aerial photography and USDA soil survey information. No field conducted due to the lack ofRight-of--Entry Agreements. Based on our review of the preliminary wetlands mapping conducted at the five alternative sites, the USACE believes that the Navy has obtained the requisite information and data to more 2 accurately consider environmental impacts for each alternative. These findings, once incorporated into the SEIS, will satisfy the USAGE site alternative analysis review under the National Environmental Policy Act. This submission satisfies relevant comments previously provided to the Navy on September 24, 2002; Apri17, 2004; and June 7, 2005. Please note that Section 404 of the Clean Water Act requires an accurate depiction of impacts to all jurisdictional areas. A USACE reviewed and approved wetland delineation will be required for permit processing. The Corps will make the final decision regarding Department of the Army wetland jurisdiction pursuant to the 1987 Manual. In some instances hydrologic monitoring maybe required to support wetland hydrology determinations. Should the Navy choose to utilize shallow groundwater monitoring wells, the wells must be installed pursuant to the document entitled, Technical Standard for Water-Table Monitoring of Potential Wetland Sites, ERDC TN-WRAP-OS-2 June 2005. This document can be found at lam://el.erdc.usace.arm .miUelpubs/pdf/tnwrap05-2.pdf. For the data to be useful, the wells must be periodically inspected and maintained, and precipitation must be within the range of normal. The number of wells required for a statistically valid analysis depends on the site's varying soil types, topographic differences and drainage features. If the recording period is less than three years, additional analysis must be made to support the conclusions [NRCS Engineering Handbook, Observation Wells, 650.1907). In order to satisfy the memorandum of agreement (MOA) signed by the USAGE and the U.S. Environmental Protection Agency that established procedures to determine the type and level of mitigation necessary to comply with the Clean Water Act Section 404(b)(1) Guidelines, all permits for work within wetlands or other special aquatic sites are available only if the proposed work is the least environmentally damaging, practicable alternative. In accordance with this MOA, applicants must demonstrate: first, avoidance of impacts to waters and wetlands through the selection of the least damaging, practicable alternative; second, appropriate and practicable steps are taken to reduce impacts on waters and wetlands; and finally, compensation is made for any remaining unavoidable impacts to the maximum practicable extent. This information is essential to our Regulatory Division's expeditious processing of your application. 3 Thank you for your time and cooperation regarding this project. If you have any questions, please contact Mr. Scott Jones of my staff at the Washington Regulatory Field Office, telephone (252) 975-1616, extension 27. Sincerely, IVY . David M. Lekson, P.W.S. Chief, Washington Regulatory Field Office Copies Furnished: 1VIr. Ronald J. Mikulak, Chief Wetlands Regulatory Section Water Management Division United States Environmental Protection Agency 61 Forsyth Street, SW Atlanta, GA 30303 Mr. Pete Benjamin United States Fish and Wildlife Service Fish and Wildlife Enhancement Post Office Box 33726 Raleigh, North Carolina 27636-3726 Mr. Ron Sechler National Marine Fisheries Service Habitat Conservation Division Pivers Island Beaufort, North Carolina 28516 Mrs. Cyndi Karoly North Carolina Department of Environment and Natural Resources Division of Water Quality 1650 Mail Service Center Raleigh, North Carolina 27699-1650 4 Mr. Doug Huggett Division of Coastal Management North Carolina Department of Environment and Natural Resources 400 Commerce Ave. Morehead City, NC 28557 Mr. Brent Manning Land Management Group, Incorporated Post Office Box 2522 Wilmington, North Carolina 28402 5