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HomeMy WebLinkAbout20120270 Ver 2_More Info Received_20121120DIAIL CORDY ANI) ::1 °! "1r INS( I,IIt 1 i I t ) ! ) N I u I I k I I r)II�aPPId4dPld- 41)1►0 T4 Ili07ZTI W01 VA 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