20190814 Ver 2_More Info Requested_20210525

Strickland, Bev
From: Homewood, Sue
Sent: Tuesday, May 25, 2021 10:02 PM
To: [e-mail]
Subject: FW: [External] Request for Additional Information: SAW-2018-01810 (The Point at
Elon / Fixed Point Homes / Shallowford Church Road / Elon / Alamance County /
residential)
From: Homewood, Sue
Sent: Tuesday, May 25, 2021 10:01 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; [e-mail];
[e-mail]
Cc: Hopper, Christopher D CIV (USA) <[e-mail]>
Subject: RE: [External] Request for Additional Information: SAW-2018-01810 (The Point at Elon / Fixed Point Homes /
Shallowford Church Road / Elon / Alamance County / residential)
All,
Please provide me with a copy of your response to David's email below. In addition please provide:
1. A more zoomed-in/detailed plan view of the plunge pool.
2. A more detailed/extended profile view of the crossing looking along the line of flow, including the upstream
"boulders at pipe for scour prevention", rock toe, and apparent floodplain bench (stabilize toe with coir log and
plant"), and the downstream plunge pool and all of the associated features.
I will place the application on hold until receipt of the requested information.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, May 19, 2021 10:45 AM
To: [e-mail]; [e-mail]; Homewood, Sue
<[e-mail]>
Cc: Hopper, Christopher D CIV (USA) <[e-mail]>
Subject: [External] Request for Additional Information: SAW-2018-01810 (The Point at Elon / Fixed Point Homes /
Shallowford Church Road / Elon / Alamance County / residential)
1

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
All,
Thank you for your PCN, dated 4/19/2021, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permit (NWP) 29 and 18 (https://saw-
reg.usace.army.mil/NWP2021/NWP29.pdf and https://saw-reg.usace.army.mil/NWP2017/2017NWP18.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may deny verification of the use of the Nationwide Permit or consider your application withdrawn and close the file: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) Please confirm the point of contact (POC) for the applicant (The Point at Elon, LLC). The PCN lists Mr. Paul Holst
as the POC, although I have an email from the previous consultant stating that Mr. Matt Quint is the POC;
2) Per the previous NWP 29/18 verification dated 3/18/2020, this project would result in the indirect reduction in
wetland function via partial loss of hydrology to an additional 0.2 acre of riparian non-riverine wetlands (see
Sheet No. EX-2 included in NWP 29/18 verification). However, these impacts were not included on the most
recently submitted PCN or plans. Please include these indirect impacts for the record;
3) Please note that a total of 0.968 riparian non-riverine wetland credits were debited from NCDMS for this project
per the attached Compensatory Mitigation Responsibility Transfer Form dated 8/17/2020. Unless a refund has
been subsequently secured from NCDMS, these 0.968 riparian non-riverine wetland credits will count towards
any new compensatory mitigation requirement;
4) Sheets C-404 and C-407 appear to show that the invert of the culvert carrying the main flow (Channel Culvert)
will be buried between 2 and 3' below the existing stream bed rather than 1' below the stream bed as stated on
text in the PCN and on Sheet C-404. Please correct this discrepancy.
5) Wetland Impact C appears to divert any flow from Wetland A2000 (as labeled on the PJD) via a "clean water
diversion" ditch into the main stream channel just upstream of the proposed culvert Stream Impact F. We are
concerned about this plan change for the following reasons:
a. The previous NWP 29/18 verification (see Sheet No. 407 included in NWP 29/18 verification) included a
42" culvert under the road to connect the future disconnected segments of Wetland A2000 and provide
more natural wetland connectivity. Can the current plan be revised accordingly? Note that, as currently
proposed, the portion of Wetland A2000 upstream of the Wetland Impact C could potentially lose
jurisdictional status under the Navigable Waters Protection Rule, and may therefore be considered a
loss of waters;
b. The placement of a "clean water diversion" ditch perpendicularly through the graded floodplain bench
to be constructed at the head of the floodplain culvert could result in erosion of the floodplain bench,
given the drainage area of the portion of Wetland A2000. If item 4a can be addressed, how would the
floodplain bench remain stable while receiving this perpendicular flow, particularly during period of high
rainfall?
6) Portions of the proposed retaining wall just southeast of Wetland Impact C are within only a few feet of the
edge of Wetland A2000. It is unclear how wetland impacts (even temporary ones) would be avoided curing
construction of this retaining wall. If temporary wetland impacts are required, please updated the PCN and plans
accordingly. Please also include a wetland restoration plan for all proposed temporary wetland impacts.
North Carolina Division of Water Resources (NCDWR): After review of the submitted PCN for the above referenced
project, and the Nationwide Permit 29 Water Quality General Certification (GC) No. 4256, dated December 18, 2020
(https://saw-reg.usace.army.mil/NWP2021/NWP29 StateWQC.pdf), it appears that an individual 401 water quality
certification (WQC) is required from the NCDWR for the proposed activities. The PCN provided the 9 required elements
for an individual WQC, and constitutes the Corps initial receipt of the 401 WQC application. The reasonable period of
time (RPOT) for you to act on this WQC request is 120 calendar days from the date of the complete 401 request. Unless
NCDWR is granted a time review extension, a waiver will be deemed to occur if you do not act on this request for
certification within the RPOT. The date upon which the waiver will occur if you do not act on the certification is
8/17/2021.
2

Applicant/Consultant: Please note, should we finalize our review prior to receiving the 401 WQC, you will receive a
provisional general permit verification from the Corps. Once a 401 WQC is issued or waived by the NCDWR, the Corps
will provide you with a final general permit verification. Your proposed work shall not commence until after the 401
WQC has been issued or waived AND until a final general permit verification has been provided to you. 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
Office: [phone], Ext. 30.
Mobile: [phone]
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: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG
Sent: Monday, April 19, 2021 12:28 PM
To: [e-mail]
Cc: Hopper, Christopher D CIV (USA) <[e-mail]>; Thames, Joyce A CIV USARMY CESAW
(USA) <[e-mail]>
Subject: SAW-2018-01810 (The Point at Elon / Fixed Point Homes / Shallowford Church Road / Elon / Alamance County /
residential)
Good Afternoon
We have received your Pre -Construction Notification (PCN) NWP request for the above project and forwarded it to Mr.
Christopher Hopper for further processing.
Thank you,
Josephine Schaffer
3