20210915 Ver 1_USACE More Info Requested_20210827

Homewood, Sue
From:
Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent:
Friday, August 27, 2021 4:32 PM
To:
Jennifer Robertson; Dan Lacz
Cc:
Homewood, Sue
Subject:
[External] Request for Additional Information: SAW-2019-02059 (Reedy Fork Ranch
Site / 5955 Summit Avenue / Greensboro / Guilford County / commercial)
Attachments:
RE: Reedy Fork Follow Up / Action ID 2019-02059
Follow Up Flag:
Follow up
Flag Status:
Flagged
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Thank you for your PCN, dated 7/14/2021 (received 7/31/2021), for the above referenced project. I have reviewed the
information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 39
(https://saw-reg.usace.army.mil/NWP2021/NWP39.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Permit or consider your application withdrawn and close the file: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) The wetland/stream delineation shown as an overlay on the proposed project plans and used to calculate
proposed impacts to potential waters of the US appears to be based on Atlas Environmental's own delineation.
Please reference my email, dated 6/23/2021(attached), where I agreed to accept Atlas' "delineation of the
stream that parallels Summit Avenue... Please do share your CAD file of this feature with the engineer for
permitting purposes." I further consented that for "stream channel locations of verified streams in areas of
proposed impacts, you may use either a current detailed survey (if available), or a rendering based on the QL2
LiDAR if the channels show up obviously enough." However, the delineation shown on the project plans is quite
different in many wetland areas than that shown in the PJD dated 6/2/2021), and the flow regime of various
sections of stream channels are also shown to have changed to ephemeral; this does not represent the
delineation as approved by the Corps following field evaluation. It is our understanding that there are various
mapping errors shown on the figure included in the existing PJD; however, the wetland delineation flags verified
for the PJD should be located in the field and shown on the overlay on the project plans and used to calculate
proposed project impacts. Further, I see no cause to alter the stream flow regimes. Please recalculate proposed
impacts to streams and wetlands accordingly, proposing compensatory mitigation as required;
2) The overall project plan shows the proposed footprint that seems to include two buildings, road infrastructure,
and parking areas. To better justify the components of this speculative development, please provide labels for
the major aspects of the conceptual design. This information will be necessary to fully evaluate whether or not
the proposed project demonstrates avoidance and minimization of adverse effects, both temporary and
permanent, to waters of the United States to the maximum extent practicable at the project site, per NWP
General Condition 23a;
3) The project plans appear to show fill/grading over the portion of Stream 6 (PJD)/CH100 (Atlas) between
proposed Impact S1 and the culvert under US 29, however this impact (>200 If) is not reported on the PCN or
shown as a Stream impact on the plans. If impacts to this stream are proposed, please add them to the PCN and
plans;

4) It appears that the proposed stream impacts do not include reaches confirmed as perennial or intermittent
during the Corps field delineation, but now shown as ephemeral. Given that these sections have already been
field -approved by the Corps, please include them as part of the proposed stream impacts (e.g. between Impacts
S1 and S2);
5) Please provide additional information regarding the apparent utility line shown to the north of the proposed
development;
a. Clearly explain the purpose of this utility;
b. Show the full extent of this utility necessary to justify the single and complete project, including a
delineation of all potential waters of the US within that corridor, even if off -site;
c. Provide profile views of proposed Impacts S5-S8;
d. Clearly describe any and all additional on- and off -site infrastructure necessary to operate the proposed
facility;
6) Based on proposed grading, wetland and stream fill, and re-routing of drainage into proposed stormwater
ponds, the project would eliminate the drainage area/hydrology source for several resources, including:
a. Wetland 8 (PJD)/WL 5000 (Atlas) and Stream 8 (PJD)/CH 500 (Atlas) below Wetland Impact W4;
b. Stream 9 (PJD)/CH 700 (Atlas) below Stream Impact S4;
c. New Wetland 3 (PJD)/various wetlands (Atlas) and Stream 7 (PJD)/CH 400 (Atlas);
d. New Wetland 5 (PJD)/WL 6000 (Atlas) and Stream 5 (PJD)/CH 600 (Atlas);
As currently described, the Corps would consider the remainder of these features (down to the nearest viable
groundwater input), as reasonably foreseeable indirect impacts (see NWP General Conditions "District Engineers
Decision") to wetlands and streams resulting from a loss of hydrology. Note that the combination of direct and
indirect impacts to these resources would push the proposed impacts above the compensatory mitigation
threshold for streams as well as wetlands, and thus compensatory mitigation would be required for indirect
impacts resulting in a loss of hydrology and therefore aquatic function in addition to all direct impacts.
Compensatory mitigation is typically required at a 2:1 ratio unless otherwise justified based on resource quality
(NCWAM/NCSAM);
7) We are also concerned that the proposed project would have indirect impacts on the following resources:
a. New Wetland 4 (PJD)/WL 3100 (Atlas) due to stormwater outfall into this narrow wetland feature,
leading to erosion in this feature and resulting reduction of aquatic function;
b. Stream 6 (PJD) /CH 100 (Atlas) and Wetland 4 (PJD)/WL 1000 and 1100 (Atlas) due to isolation to a
narrow valley between fill slopes and proposed Stream Impacts S2 and S3;
How will these features retain their aquatic function when surrounded by impervious surfaces as proposed?
8) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
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: David. [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 <[e-mail]>
Sent: Monday, August 2, 2021 7:54 AM
To: Jennifer Robertson <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Thames, Joyce A CIV USARMY CESAW
(USA) <[e-mail]>
Subject: SAW-2019-02059 (Reedy Fork Ranch Site / 5955 Summit Avenue / Greensboro / Guilford County / commercial)
Jennifer,
Received the Pre -Construction Notification (PCN) NWP for the above project and forwarded it to Dave Bailey for further
processing.
Thank you,
Josephine Schaffer
From: Jennifer Robertson <[e-mail]>
Sent: Saturday, July 31, 2021 11:54 PM
To: RaleighNCREG <[e-mail]>
Subject: [Non-DoD Source] Reedy Fork NWP 39 / Action ID 2019-02059
Josephine,
Attached is a NWP 39 application for David Bailey. Thanks!
Thank you,
Jennifer L Robertson, President
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411
Charlotte, NC 28211
[phone] office
[phone] mobile
www.atiasenvi.com
Offices in Asheville and Charlotte

Homewood, Sue
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, June 23, 2021 3:56 PM
To: Jennifer Robertson
Cc: Homewood, Sue
Subject: RE: Reedy Fork Follow Up / Action ID 2019-02059
Hi Jennifer. Thanks for your email and patience. After review of the information you sent as well as information in my
file (including Avenza Maps points of the start [headcut] and end [culvert] of the stream in question I had collected in
the field during the verification), I agree with your delineation of the stream that parallels Summit Avenue. The ECS
representation of this feature on the PJD map is a mapping error. Please do share your CAD file of this feature with the
engineer for permitting purposes.
Also, for stream channel locations of verified streams in areas of proposed impacts, you may use either a current
detailed survey (if available), or a rendering based on the QL2 LiDAR if the channels show up obviously enough.
Hopefully this helps. Please let me know if you have any questions moving forward.
-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: David. [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: Jennifer Robertson <[e-mail]>
Sent: Tuesday, June 15, 2021 4:40 PM
To: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: [Non-DoD Source] Reedy Fork Follow Up / Action ID 2019-02059
David,
Following up from our phone conversation yesterday the maps took Jacob a little longer to get together than I
anticipated. The first map includes the ECS delineation and our delineation. The ECS delineation is
purple. The Atlas delineation is dark blue (perennial streams), light blue (intermittent streams), green
(wetlands), and orange (open water). The ECS stream layer for the stream that parallels Summit Avenue
extends beyond the end points in the field both on the upstream and downstream ends. As we discussed

yesterday their stream on the downstream end would need to flow uphill. Their stream on the upstream end
extends up to the gravel entrance road into the farm. This is not accurate either.
The second attachment includes maps of our delineation inserted onto LiDAR. As we discussed please let me
know if I can share our CAD file with the engineer for permitting purposes.
Thank you,
Jennifer L Robertson, President
ATLAS Environmental, Inc.
338 S. Sharon Amity Road #411
Charlotte, NC 28211
[phone] office
[phone] mobile
www.atiasenvi.com
Offices in Asheville and Charlotte
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