20210947 Ver 1_Agency_Concurrence_Memo_20210513

ATKINS
Member of the SNC-Levalirr Group
Memo
To: David Bailey; Sue Homewood
From: Ben Cogdell
Email: [e-mail]
Date: 09 December 2020
Phone: [phone]
Ref: SAW-2020-01942
cc: Matt Cusack, Amit Sachan, Johnnie
Hill
Subject: Summary of Woodcroft Circle Streambank Stabilization Jurisdictional Determination
Agency Concurrence Meeting
The purpose of this memo is to provide a record of the Woodcroft Circle streambank stabilization
agency concurrence meeting that occurred on December 3, 2020. Atkins' lead technical
professional for this assignment, Ben Cogdell, met on site with Mr. David Bailey (USACE) at the
west end of the "Preferred Access Corridor." Below is a list of locations visited and a summary of
pertinent discussion of jurisdictional features and permitting issues that took place during the
agency concurrence meeting. JD Package Figure 2 is incorporated in this memo for reference.
Wetland WC located at the south end of the study area within the maintained utility easement was
reviewed and confirmed by Mr. Bailey, he agreed that no changes would be required to the limits of
the jurisdictional feature. Mr. Cogdell informed Mr. Bailey that the southern end of the study area
(along Grandover Parkway) was initially proposed as the preferred construction access location,
however upon visiting the site it was determined that Wetland WC could potentially be avoided by
accessing the site from the north via, what is now labelled as the "Preferred Access Corridor" in
Figure 2. Mr. Bailey agreed that this approached seemed like the best alternative.
Wetland WA located within the utility easement and was reviewed and confirmed by Mr. Bailey and
agreed that no changes would be required to the limits of the jurisdictional boundary. Mr. Bailey
confirmed that Wetland WA was directly connected along its western boundary to Reddicks Creek.
Mr. Bailey and Mr. Cogdell then reviewed the swale along the upslope (eastern) end of WA
(designated as "X1" in Figure 2) and confirmed that this drainage was ephemeral and contained
upland soils. This confirmation prompted a discussion regarding connectivity and jurisdictional
reach as it relates to the June 2020 Navigable Waters Protection Rule and the definition of "waters
of the United States". During this conversation Mr. Bailey informed Mr. Cogdell that Wetlands WB
and WD would not be considered jurisdictional should the City of Greensboro (City) wish to apply
for an Approved Jurisdictional Determination rather than a Preliminary Jurisdictional Determination
(as is currently submitted). Atkins will advise the City on this and will submit an Approved JD
package if potential impacts are needed to support access to the construction area when a Pre -
Construction Notification is submitted.
While reviewing Wetland WA Mr. Cogdell and Mr. Bailey discussed the optimal construction access
for equipment to perform the stabilization measures along Reddicks Creek. Mr. Cogdell suggested
that there may be a need for a temporary crossing at Wetland WA within the existing utility
Woodcroft_Memo_COGD3624_STEP03_12092020 1

ATKINS
Member of the SNC-Lavalin Group
easement. Mr. Bailey confirmed that this approach seemed reasonable and would be acceptable
under the guidelines of a Nationwide Permit (NWP) 33 if the fill was indeed temporary. However,
Mr. Bailey went on to say that it would need to be demonstrated that avoidance and minimization
measures were considered if impacts to WA are deemed necessary. If the crossing needs to be
permanent, then Mr. Bailey said that action would need to be justified and avoidance and
minimization measures would need to be demonstrated.
Mr. Bailey and Mr. Cogdell then reviewed Reddicks Creek and the limits of the proposed
stabilization. Concepts of stabilization actions were discussed, and Mr. Bailey provided his opinion
on potential permitting strategies. Mr. Bailey agreed that this project was a reasonable fit for NWP
13-Bank Stabilization as it was less than 500 linear feet in length, however a Pre -Construction
Notification (PCN) would be required in writing. Mr. Cogdell informed Mr. Bailey of the proposed
stabilization techniques for further clarity. Below is a summary of the techniques proposed:
• Installation of boulders armoring along the right bank of the upstream end of the
stabilization reach.
• Installation of J-hook opposite boulder armoring to maintain centralized flow.
• Provide floodplain bench on the inside bend (opposite boulder armouring) to
provide stream with better access to floodplain during larger flow events.
• Repair washout on downstream end of proposed stabilization reach to prevent
further erosion.
Mr. Bailey informed Mr. Cogdell that these measures seemed reasonable and were within the spirit
of NWP 13 authorization. He went on to say that should the volume of fill below the Ordinary High
Water Mark (OHWM) exceed the limits (>1 cubic yard of fill per running foot of stream) then he
would be willing to consider a NWP 18-Minor Discharges (limit of 25 cubic yards of fill per running
foot of stream) acceptable.
The final item discussed was the consideration of Riparian Buffer Rules since Reddicks Creek falls
with the jurisdiction of the Randleman Lake Buffer Rules. Mr. Bailey informed Mr. Cogdell that Ms.
Sue Homewood (North Carolina Division of Water Resources) would need to be consulted
regarding impact justification and any potential buffer mitigation.
Woodcroft_Memo_COGD3624_STEP03_12092020 2

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Prepared By:
Prepared For:
0Data Form Locations
Preliminary Jurisdictional Determination
DWnBy. RLG
FIGURE
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Potential Non -Wetland Waters of the US Streams
(Aerial Map)
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Woodcroft Circle Streambank Stabilization
Feet
Date:
...',`a
9/15/2020
2
GREENSBORO
Project Study Area
GUILFORD COUNTY, NORTH CAROLINA
Project No.:
100068937
D:\Woodcroft\Fig02_Aerial. mxd

Right bank of Reddicks Creek (looking downstream) at the proposed start of bank
armoring and J-Hook installation
(Lat/Long): 35.988934 ,-79.894334000000001
Right bank of Reddicks Creek (looking upstream) at the proposed start of bank
armoring and J-Hook installation
(Lat/Long): 35.988872999999998 ,-79.894278
1 of 2

Right bank of Reddicks Creek (looking downstream) at failing bulkhead. Proposed
armoring/boulder-toe installation
(Lat/Long): 35.988880000000002 ,-79.894281000000007
Right bank of Reddicks Creek (looking upstream) at end of the proposed
stabilization reach. Proposed repair of bank failure (foreground).
(Lat/Long): 35.988818999999999 ,-79.893906000000001
2 of 2