HomeMy WebLinkAbout20120270 Ver 2_More Info Received_20121120DIAIL CORDY
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Mr. Brad Shaver
Project Manager
USACE Wilmington District
CESAW- RG(1145 -b)
69 Darlington Ave
Wilmington, NC 28403
RE: Response to Request for Information
Modification Request for Action ID SAW- 2010 - 01797/ Department of the Army Permit
DWQ Project # 2012 0270/ Onslow County
New River Marine Corps Air Station, Camp Lejeune, NC 28542 -0004
Dear Mr. Shaver,
Pursuant to our recent e-mail and telephone correspondence, Dial Cordy a nd Associates is
providing the following update to information presented in our modification request dated 4 October
2012. This is regarding document 2012- 08 -08- 130225 dated 15 August 2012. Specifically, we have
segregated impacts by jurisdiction (i.e., USACE vs. NCDENR) for Clean Water Act (CWA) Section
404 and Section 401 regulatory purposes, respectively, and re- assigned one impact (which ha s
been removed from further consideration for construction) from Phase II to Phase III.
All impacts (for both CWA Sections 404 and 4 01 regulatory purposes) that were initially proposed
and that are now proposed for modification are shown in Table 1 below.
Table 1: Previously proposed (i.e., initial) and
currently proposed (i.e., modified) impacts
Phase
Wetland
Impact
Modified
Modified
Initial
Delta
impact
type
Area (ac or sf)
area (ac)
area (ac)
(ac)
I
W4P
Permanent
0.630 ac
0.6300
0.6200
0.0100
I
W4T
Temporary
0.190 ac
0.1900
0.1800
0.0100
I
W5P
Permanent
487 sf
0.0112
0.0000
0.0112
1
W5T
Temporary
351 sf
0.0081
0.0000
0.0081
11
W7P
Permanent
0.110 ac
0.1100
0.3200
- 0.2100
11
W7T
Temporary
237 sf
0.0054
0.0000
0.0054
11
W7 -2
Permanent
0.000 ac
0.0000
0.2400
- 0.2400
11
W9*
Permanent
625 sf
0.0143
0.5600
- 0.5457
11
W9*
Temporary
500 sf
0.0115
0.0000
0.0115
III
Wi -1P
Permanent
0.4300 ac
0.4300
0.7400
- 0.3100
III
Wi -1T
Temporary
0.0500 ac
0.0500
0.0000
0.0500
III
Wi -2P
Permanent
0.0200 ac
0.0200
0.2200
- 0.2000
III
Wi -2T
Temporary
515 sf
0.0118
0.0000
0.0118
The previously proposed impacts totaled ap proximately 2.88 acres; t he currently pro posed plan
involves only approximately 1.49 acres of unavoidable impacts. Therefore the new pla ns reflect a
48% reduction in direct impacts.
The summary of changes, per project phase, for CWA Section 401 regulatory purposes are shown
below in Table 2, while the changes (from initially proposed to currently proposed) for each project
phase regulated under CWA Section 404 are shown in Table 3 below.
Table 2: Summary of previously proposed (i.e., initial) impacts and currently proposed (i.e.,
modified ) impacts for each project phase, under CWA Section 401 Jurisdiction
Phase
401 Initial (ac)
401 Modified (ac)
401 Delta (ac)
1
0.80
0.84
+0.04
11
1.12
0.14
-0.98
111
0.96
0.51
-0.45
Project Total
2.64
1.49
-1.15
Table 3: Summary of previously proposed (i.e., initial) impacts and currently proposed (i.e.,
modified )im acts for each phase, under CWA Section 404 Jurisdiction
Phase
404 Initial (ac)
404 Modified (ac)
404 Difference (ac)
1
0.80
0.84
+0.04
11
0.56
0.12
-0.44
111
0.96
0.51
-0.45
Project Total
2.32
1.47
-0.85
Phase /. The applicant is providing the attached revised Figure 5 (regarding the modified Phase I
zone), as the 4 October 2012 version was found to have outdated impact acreages for the Wetland 4
area.
Phase //. You recently inquired whether any non - permitted clearing (not filling) woul d occur in the
Phase II wetlands south of the proposed road and runway extension as a consequence of UFC
regulations and airfield operations. According to the 19 No vember 2012 email you r eceived from
John Strong, the manager of airfield operations at MCAS New River, you have assurance that, "The
future runway extension project will not require any clearing south of the perimeter road."
Phase / //. As you are aware, the applicant has been directed to pursue Section 404 and Section
401 permits for Phase III as specified in our last written correspondence, even though there may be
future work in the area. At this point in time, only the conceptual framewo rk for such future work is
available, as discussed in our 4 October 2012 letter. Detailed design and engineering work for that
future work is not currently under contract by the applicant, and that would have to be completed
(along with any future permit modification) to allow for the runway extension to be constructed. In the
interim, we continue to support acquiring permits to construct the re- aligned roadway as specified in
our 4 October letter, as that will provide additional safety as well as minimize wetland impacts.
Page 2 of 4
Request for Modification of SAW- 2010 - 01797/ 20 November 2012
Mitigation. The applicant is seeking to mitigate ce rtain unavoidable impacts to jurisdictional
wetlands at a ratio lower than the standard 2:1 (i.e., two acres of comp ensation for each acre
impacted). Due to the altered ve getative coverage (lack of an overstory due to continued
maintenance pressure, which results in decreased wetland habitat function) in areas proposed for
impacts W7P and W9P, we are proposing a mitigation ratio of 1.5:1. Impacts at these sites are 0.1 1
acre and 625 square feet, respectively. The impact for W9P is mentioned here for CWA Section 401
compliance purposes only; that impact is not under USACE jurisdiction. These areas are depicted on
the photos below. Please respond if this change in mitigation ratio is agreeable to USACE.
View west to W7P &W7T impact area (shrub -line) from road
Page 3 of 4
Request for Modification of SAW- 2010 - 01797/ 20 November 2012
View east to W9P &W9T impact area (currently mowed /maintained for airfield use) from road
We appreciate your efforts on be half of fede ral regulatory compliance for this important pr oject.
Should you have a ny questions regarding the a bove, please contact me at (904) 476- 9571 or
jevert @dialcordy.com at your earliest convenience.
Best Regards,
Jason Evert
Senior Ecologist
Page 4 of 4
Request for Modification of SAW- 2010 - 01797/ 20 November 2012