20210927 Ver 1_P134 Slocum Rd - Public Notice Comment Responses 20211029_20211029

•• NAVY
TRANSPORTATION
PARTNERS JV
October 29, 2021
Ms. Emily Thompson
U.S. Army Corps of Engineers
Washington Regulatory Field Office
2407 West Fifth Street
Washington, NC 27889
Mr. Garcy Ward
NC Division of Water Resources
Transportation Permitting Unit
512 N. Salisbury Street
Raleigh, NC 27604
RE: SAW-2021-00067—Responses to Agency and Public Comments
Project P134 Perimeter Security Compliance, Slocum Road Entry Control Facility
MCAS Cherry Point, Craven County, North Carolina
Dear Ms. Thompson and Mr. Ward,
On behalf of our client, the United States Marine Corps Air Station (MCAS) Cherry Point, Navy
Transportation Partners, JV (NTPJV) is providing responses to the agency and public comments
provided by the US Army Corps of Engineers (USACE) as a result of the Public Notice which was
received via email on September 21, 2021.
On October 6, 2021, the USACE and NTPJV discussed the Project via conference call to review
potential responses, and to review other outstanding comments from USACE. Below is an outline of
the received agency comments, public comments, and additional USACE comments with a brief
narrative addressing each item.
The comments from the NCWRC with NTPJV response and explanation are as follows:
The NCWRC has reviewed the project proposal and has the following comments and
recommendations based on information provide in the public notice:
1. Riparian wetlands perform invaluable functions to aquatic resources and their habitats.
Stormwater treatment, runoff filtration, bank stabilization, nutrient removal, and terrestrial
wildlife corridors are all benefits of riparian wetlands. Avoidance and minimization of impacts
to these areas should be exhibited to the greatest extent practicable with appropriate
mitigation as necessary. Any permitted activity in these areas should address direct impacts
to the wetlands as well as impairment of adjacent wetland functions.
NTPJV response:
The Individual Section 404/401 Application Package for the Project has extensively
documented avoidance and minimization efforts conducted through the design phase of the

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project and proposed for the construction phase of the project. Proposed impacts to wetlands
include an evaluation of direct and indirect impairment of the adjacent wetlands and their
function.
2. Information regarding wetland surveys and assessment should be provided. It is
recommended the applicant use the NC Stream Assessment Method(NCSAM) and the NC
Wetlands Assessment Method(NCWAM) to determine the quality of wetlands impacted by
the proposal. Mitigation ratios should be based on the quality of wetlands impacted.
NTPJV response:
Mitigation ratios are proposed based on the NCWAM and NCSAM functional assessments
conducted by Kimley-Horn scientists, discussed in Sections 1.3.4 and 1.3.5 of the permit
support document. Stream S1 within the Project was found to have a NCSAM rating of
"High". Headwater forest wetlands within the Project were found to have a NCSAM rating of
"Medium", and the riverine swamp forest wetlands within the Project were found to have a
NCWAM rating of"High". The basin/pocosin wetlands within the Project were found to have
an NCWAM rating of"Low". MCAS Cherry Point has proposed variable mitigation ratios for
the impacted wetlands based on their respective NCWAM scores:
• 2:1 mitigation ratio for NCWAM score of"High"—W4 and W8
o Total Permanent Impact: W4 (<0.01 ac.), W8 (0.05 ac.)
• 1.5: mitigation ratio for NCWAM score of"Medium"—W3
o Total Permanent Impact: W3 (0.11 ac.)
• 1:1 mitigation ratio for NCWAM score of"Low"—W1, W2, W6, and W10
o Total Permanent Impact: W1 (1.13 ac.), W2 (1.91 ac.), W6 (2.51 ac.), W10
(0.42 ac.)
3. Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife-friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have
loose-weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing or similar materials that have been reinforced with
plastic or metal mesh should be avoided as they impede the movement of terrestrial wildlife
species. All sediment and erosion control measures should be routinely inspected and
properly maintained. Excessive silt and sediment loads can have numerous detrimental
effects on aquatic resources including destruction of spawning habitat, suffocation of eggs,
and clogging of gills of aquatic species.
NTPJV response:
The sediment and erosion control measures are detailed in the approved Stormwater
Management Plan. The project-specific sedimentation and erosion control measures that will
be utilized during construction will minimize downstream sedimentation. The majority of
turbidity increases would likely result from the clearing and construction of the realigned
Slocum Road and ECF, but minor turbidity impacts may result from the construction of the

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parallel bridge over Slocum Creek. Sediment loss from the Project would be minimized by the
implementation of sediment and erosion control measures. Once construction of the Project
is complete, the soils would be stabilized, revegetated, and stormwater runoff would be
directed to detention and treatment basins and swales. Accordingly, the effects of turbidity
resulting from the proposed undertaking are expected to be temporary and minor.
4. Measures to mitigate secondary and cumulative impacts can be found in NCWRC's
Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to
Aquatic and Terrestrial Wildlife Resources and Water Quality(August 2002;
http://www.ncwildlife.org/Portals/0/Conserving/documents/2002 GuidanceMemorandumforSe
condarvandCumulativelmpacts.pdf). Conservation easements on adjacent wetlands would
minimize future impacts to Slocum Creek's riparian habitats in the immediate area.
NTPJV response:
The Project has considered secondary and cumulative effects that may result from the
proposed project, and they have been mitigated to the extent practicable. The cumulative
effect of the proposed undertaking does not pose a significant threat to the integrity of the
aquatic environment. Additionally, the secondary impacts resulting from the proposed plans
are primarily limited to increased development pressure within MCAS Cherry Point that could
result by the Project allowing additional vehicles per day through the Slocum Road ECF.
However, the overall secondary effects on aquatic resources associated with this Project are
not more than minimal. Mitigation provided by the Project would restore aquatic ecosystem
function in the watershed and offset any losses resulting from the Project. The mitigation
payment to the NCDMS would also be used to restore and preserve stream corridors and
wetland areas elsewhere in the Neuse River Basin. The secondary short-term effects
expected downstream would primarily be limited to temporary discharges of sediment during
construction. Even with proper construction and maintenance, sediment control measures do
not eliminate all turbidity in receiving waters, though these effects should be limited to the
duration of Project construction and maintenance of required sediment and erosion control
measures.
In addition to the comments above regarding wetland fill, the following are site specific and standard
recommendations for bridge replacement and construction projects:
5. Slocum Creek is designated a Primary Nursery Area (PNA) by the NCWRC. PNAs are
defined as those areas inhabited by the embryonic, larval or juvenile life stages of marine or
estuarine fish or crustacean species due to favorable physical, chemical or biological factors.
As a designated PNA, this waterbody provides an important rearing area for this variety of
estuarine fishes and invertebrates that need relatively undisturbed habitats. Therefore,
stream crossing guidelines for anadromous fish passage should be followed to maintain or
improve aquatic passage. To minimize impacts to this resource during construction, no in-
water work should occur within Slocum Creek or the connected floodplain from February 15—
September 30.

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NTPJV response:
The Project will comply with the NCWRC-requested construction moratoria to minimize
impacts to the designated PNA during construction. In addition, the new bridge over Slocum
Creek will mirror the existing bridge, and no impacts to anadromous fish passage will occur
following completion of the Project.
6. Bridge deck drains should not discharge directly into the stream.
NTPJV response:
As shown on the design plans for the bridge, stormwater will be collected into a closed
drainage system along the bridge deck. The closed drainage system for the bridge outlets
outside of protected riparian buffer zones and includes riprap dissipator pads to ensure non-
erosive velocities as stormwater is directed to treatment swales prior to discharging to
Slocum Creek. No direct discharge of stormwater from the bridge deck will occur to Slocum
Creek.
7. Live concrete should not be allowed to contact the water in or entering into the stream.
NTPJV response:
Live concrete will not be allowed to contact the water in or entering the stream in compliance
with NCWRC requests and NCDWR requirements in the pending 401 Water Quality
Certification.
8. If temporary access roads or detours are constructed, they should be removed back to
original ground elevations immediately upon the completion of the project. Disturbed areas
should be seeded or mulched to stabilize the soil and native tree species should be planted
with a spacing of not more than 10 x10'. If possible, when using temporary structures, the
area should be cleared but not grubbed. Clearing the area with chain saws, mowers, bush-
hogs, or other mechanized equipment and leaving the stumps and root mat intact, allows the
area to revegetate naturally and minimizes disturbed soil.
NTPJV response:
The majority of the disturbed areas are associated with permanent components of the
Project, but any temporary disturbance areas will be regraded to pre-construction contours
and revegetated with native vegetation in compliance with NCDEQ requirements.
9. A clear bank(riprap free) area of at least 10 feet should remain on each side of the stream
underneath the bridge.
NTPJV response:
Protection of the bridge abutments is critical to the long-term stability of the bridge structure
over Slocum Creek, and riprap armoring helps ensure the integrity of the banks. The
proposed armoring will mirror the existing bridge over Slocum Creek.

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10. Temporary or permanent herbaceous vegetation should be planted on all bare soil within 15
days of ground disturbing activities to provide long-term erosion control. Noninvasive species
with wildlife benefits are recommended.
NTPJV response:
Disturbed areas will be re-vegetated within 15 days of ground disturbing activity in
compliance with NCDEQ requirements.
11. Heavy equipment should be operated from the bank or on top of structure rather than in
stream channels in order to minimize sedimentation and reduce the likelihood of introducing
pollutants into streams.
NTPJV response:
Heavy equipment will not be operated in stream channels. The proposed stream crossing will
be built from the banks, and the proposed bridge over Slocum Creek will be built from a work
trestle and/or barges.
12. Only clean, sediment-free rock should be used as temporary fill(causeways) and should be
removed without excessive disturbance of the natural stream bottom when construction is
completed.
NTPJV response:
While no temporary fills for causeways are currently proposed, should any temporary fill be
necessary they will utilize clean, sediment-free rock as requested by NCWRC and will be
removed following construction completion.
13. During subsurface investigations, equipment should be inspected daily and maintained to
prevent contamination of surface waters from leaking fuels, lubricants, hydraulic fluids, or
other toxic materials.
NTPJV response:
Contractors will create and maintain a Spill Prevention, Control, and Countermeasures
(SPCC) plan that will ensure equipment is inspected daily and maintained such that
contamination of surface waters in the Project is prevented to the extent practical during
construction.
The public comments received from the adjacent property owners Mrs. Tammy S. Dixon, Mrs. Crystal
Coleman, and Mrs. Patrina Wilson located within parcel number 6-036-007 with NTPJV response and
explanation are as follows:
We received the Public Notice dated 08/26/21 as noted above and write to express our concern about
what this proposal means for our specific property located at 201 Slocum Road, Havelock, NC.
Please accept this as our written comments/response submitted by the September 15, 20215:00 pm

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dead fine. All of the descendants have very fond memories of our home, and this property has been
in our family since 1876,just 11 years after the enslaved were freed. We are very hopeful that this
land can remain *fully accessible to us and in our ownership!As part of our written comments of
concern, we also have the following questions:
1. On page 3 of this Public Notice, under`Existing Site Conditions"section (p.2), it states "The
proposed project is locate entirely within the MCAS Cherry Point installation and zoned as
Military Reserve (MR). Does this mean our property will not be impacted at all, and this notice
is just to notify us?
NTPJV response:
The commenter is correct, the Project described in the Public Notice does not impact the
property noted in the comment. The commenter may experience minor disruptions in normal
traffic flow during construction, however, those impacts are temporary in nature and duration
and will not impede access to their property.
2. If Slocum Road is relocated, will this impact our access to our property?If so, how?
NTPJV response:
The relocated Slocum Road will begin east of the existing gate facility, and much further east
of the commenter's property. Access to the commenter's property will not be impacted by the
Project.
3. With the proposed "relocation"of Slocum Road and widening of Slocum Road from 2 lanes to
4 lanes, does this mean some of our property will have to be relinquished?
NTPJV response:
The 4-lane section of Slocum Road will begin east of the commenter's property. No property
will be relinquished as part of this Project.
4. When will this proposal be implemented started/completed?
NTPJV response:
The Project is slated to start in 2022 and will be completed in 2024.
5. Is this proposal part of an Eminent Domain execution?
NTPJV response:
The Project does not involve any execution of Eminent Domain.
6. When will we know if this proposal will be finalized/approved?
NTPJV response:

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The Project will be considered finalized or approved upon receipt of pending permit
authorizations from the USACE and NCDWR.
7. How does Slocum Creek affect our property?It is our understanding that it is not near our
property.
NTPJV response:
Slocum Creek is not located near the commenter's property. The proposed Project crosses
Slocum Creek farther to the east along Slocum Road (approximately 1.40 miles east)from
the commenter's property.
8. If you are not the appropriate person to answer these questions, can you please let us know
the name%ontact information for the appropriate person and/or forward this letter/these
questions to that person?
NTPJV response:
Based on the content of the commenter's comments, it appears that the concerns are largely
not applicable to the Project as the commenter's property is not impacted by the Project.
9. *If such is avaiiable, can you please provide a chronological flowchart describing the
timeline/process of this proposed project?
NTPJV response:
No flowchart describing the timeline/process of the proposed Project is available; however,
construction start date (contingent on permit review completion and issuance) is currently
slated for 2022. The commenter is likely to see construction activity in Q2 2022.
10. *What is the estimated time range we will receive a response to these questions?
NTPJV response:
NTPJV will defer to the USACE on if responses will be provided to this commenter during
their review and what that time range will be.
11. Will our access to our property be affected by any proposed/implemented construction; If so,
how long, and are there any other barrier or constraints that we may not be aware of that
would affect us and our property?
NTPJV response:
No direct impact to property access by the commenter will occur. The Project start point is
further east along Slocum Road than the commenter's driveway. However, indirect impacts
such as alterations in traffic flow along Slocum Road may occur as a result of construction
signage and barriers in the vicinity of Slocum Road within MCAS Cherry Point property. Any
indirect impacts are anticipated to be temporary in nature.

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The public comments from the adjacent property owner Deacon Perry Owens in reference to Green
Chapel Missionary Baptist Church with NTPJV response and explanation are as follows:
1. My name is Perry Owens and 1 am emailing you on behalf of Green Chapel Missionary
Baptist Church, we own the land from the middle of Slocum Road down to Highway 70 which
right in the middle of the expansion. Doing the previous expansion of Slocum we were paid
for half of our land. The question now is will we be paid for the rest of our land. 1 can be
reached at+15738550541 or by email deaconowens20130)hotmail.com
NTPJV response:
The Green Chapel Missionary Baptist Church property will not be impacted by the proposed
Project. The Project begins east of the commenter's property. No land will change hands as a
result of this Project as it is located entirely within existing MCAS Cherry Point land.
The additional USACE comments that were discussed on the October 6, 2021 conference call but not
otherwise addressed in the above with NTPJV response and explanation are included here:
1. The USACE requested that the screening criteria used in the alternatives analysis and the
identification of the Least Environmentally Damaging Practicable Alternative (LEDPA) be
confirmed. The USACE noted the following criteria and requested NTPJV confirm the criteria
were used for the alternatives analysis:
a) Impacts to Waters of the US
b) Impacts to residential areas
c) Security requirements (such as line-of-sight requirements, commercial/personal
vehicle inspection areas, and protection of nearby housing)
d) Proximity to ESQD facilities and arcs (setbacks)
NTPJV response:
The USACE-identified screening criteria are indeed the same screening criteria used by
NTPJV for the alternatives analysis and ultimate LEDPA selection. Development of the
proposed Slocum Road alignment and overall site layout for the Project was an iterative
process based upon numerous variables, but primarily focused on avoiding impacts to
jurisdictional areas to the maximum extent practicable (screening criteria (a)), and then
alternatives were further evaluated screening criteria (b), (c), and (d)to determine if the
alternative was practicable and met the purpose and need for the Project.
2. The USACE requested that we clarify that the"No Action Alternative" needs to address notjust
a "No Build" condition, but an alternative that does not require a Section 404/401 permit.
NTPJV response:
While the No Action Alternative described in Section 6.1.1 of the Individual Permit Application
Support Document is described as a no build alternative, due to the presence of extensive
jurisdictional wetlands along both sides of Slocum Road and the need to cross Slocum Creek
and its adjacent wetlands to meet the purpose and need of the Project, the only No Action

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Alternative would require maintaining the limits of the existing roadway corridor and entrance
gate facility as-is with no expansion. While constructing a smaller entrance control facility
within the limits of the existing roadway corridor would not result in any impacts to Waters of
the US (meeting screening criteria (a)), this alternative does not meet screening criteria (b) -
(d) and is therefore not practicable and was not carried forward.
3. The COAs that were mentioned in the permit need to be defined or more clearly described to
appropriately explain the alternatives analysis and alternative selection process. Additionally,
the USACE requested to specifically reference how each of the COAs/alternatives were ruled
out based on whether or not it met the specific selection criteria.
NTPJV response:
As stated in Section 6.2.1 of the Individual Permit Application Support Document,
development of the proposed Slocum Road alignment and overall site layout for the Project
was an iterative process based upon numerous variables, but also included purposeful
avoidance and minimization of impacts to jurisdictional areas to the maximum extent
practicable. As is standard for large scale federal projects like this, early in the Project
development process, NAVFAC and MCAS Cherry Point held a collaborative Concept Design
Workshop (CDW)where all stakeholders reviewed the Purpose and Need, constraints,
screening factors, and any other applicable concerns that would need to guide or otherwise
alter that proposed alignment and site layout. At the CDW, multiple alternatives were
prepared and considered (also known as Courses of Action, or COAs). The Project team then
applied the screening criteria to the four alternatives which led to the selection of the
Preferred Alternative, which is also the LEDPA.
In an effort to provide additional clarification and detail for USACE review, below is an
expanded description of each alternative (also known as each COA), which are also reflected
in the On-Site Alternatives figures included in the Individual Permit Support Document in
Appendix A.
Alternative 1 (also known as COA1) is shown in Appendix A as Figure COA1, has the ECF
and infrastructure located north of Alexander Road, tying into Alexander Road just before the
bridge crossing of Slocum Creek. Alternative 1 (COA1)was considered but eliminated from
further analysis due to screening criteria (a), since Alternative 1 has substantially increased
wetland and stream impacts than the preferred alternative. Alternative 1 (COA1)would have
impacted approximately 10.6 acres of wetlands, 1.0 acres of stream buffer, and 330 LF of
stream.
Alternative 2 (also known as COA2) is shown in Appendix A as Figure COA2. Alternative 2
shifted the main ECF location further east in an effort to reduce overall wetland impacts and
mostly avoided impacts to W1, but increased impacts to W6 and W3, and substantially
increased stream impacts from Alternative 1. Alternative 2 was eliminated from further
analysis due to screening criteria (a), and its substantially increased stream and riparian

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buffer impacts. Alternative 2 (COA2) would have impacted approximately 7.0 acres of
wetlands, 1.8 acres of stream buffer, and 750 LF of stream.
Alternative 4 (also known as COA4) is shown in Appendix A as Figure COA4 and attempted
to reduce wetland and stream impacts as much as possible. The ECF was shifted to land on
W10 but avoided heavy impacts to W2 and W6. The realigned Slocum Road also crossed
info the residential housing area quicker than Alternatives 1 and 2 and utilized as much of
existing Alexander Road as possible south of the Project Area. While Alternative 4 (COA4)
had substantially reduced wetland and riparian buffer impacts, stream impacts were still
higher than the preferred alternative, and Alternative 4 was determined to be not practicable
because it placed the main gate very close to residential housing area. Alternative 4 also
increased noise and light pollution for residents, and the curvature of the realigned Slocum
Road presented substantial security challenges due to line-of-sight concerns approaching the
ECF and would not satisfy the purpose and need of the Project. Alternative 4 was removed
from consideration based on screening criteria (b)and (c).
The Preferred Alternative (shown in Appendix A as Figure PREFERRED ALTERNATIVE, or
sheet CS100 based on the title block)was based on a minor variation of COA3, which shifted
the ECF and realigned Slocum Road further south from Alternative 2 (COA2) and utilized
even more of the existing Alexander Road. The minor variation from COA3 to the Preferred
Alternative then further reduced impacts by shifting the ECF slightly more south and then
east to maximize the avoidance of wetland impacts to W6, W3, and stream S1. The change
in impacts from COA3 to the Preferred Alternative was minor enough that COA3 was not
included as a separate alternative for purposes of the Alternative Analysis. The Preferred
Alternative also represents a reduction in personal and commercial vehicle inspection lanes
from three to two in an effort to further reduce fill impacts in the area of the ECF and
realigned Slocum Road. The Preferred Alternative represents the least amount of stream and
wetland impacts and meets screening criteria (a), and by utilizing the existing Alexander
Road but then provides a realigned Alexander Road corridor for the residential housing and
has the least amount of impacts to adjacent housing, meeting screening criteria (b). The
Preferred Alternative meets screening criteria (c) and (d) by meeting all required security
factors and ESQD radius arcs. The total permanent impacts associated with the Preferred
Alternative are: 242 LF of stream impact, 6.13 acres of wetland impacts, and 0.91 acre of
stream buffer impacts.
4. The USACE asked about clarification as to why the project is seeking mitigation from NCDMS
instead of a third-party bank.
NTPJV response:
Mitigation approach was discussed with the USACE during the October 6 conference call, and
all parties agreed that the requirement imposed by NC G.S. 143-214.11 to utilize third-party
mitigation banks before NCDMS does not apply to government entities, and that government
entities (which includes federal applicants) are permitted to use NCDMS mitigation in-lieu fee
payment before third-party mitigation bank credits. NTPJV further clarified that while they

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acknowledge the potential benefit of third-party mitigation credits to the watershed as a whole,
the timeline associated with this Individual Permit review means that any third-party credits
secured at time of application would likely not be available for use later in the year when USACE
is likely to conclude their review. For that reason, NTPJV proposed NCDMS in-lieu fee payment
for mitigation of unavoidable impacts associated with the Project but intends to monitor credit
availability throughout the duration of USACE review. If third-party mitigation credits are
available prior to construction, NTPJV will evaluate the appropriateness of those credits
compared to NCDMS in-lie fee payment and coordinate with the USACE if needed.
5. The USACE stated that they were going to provide the Standard Conditions for the 404 permit
for the proposed project for applicant review.
NTPJV response:
NTPJV appreciates the opportunity to review the DRAFT Standard Conditions prior to permit
issuance. The USACE provide the DRAFT Standard Conditions via email on October 21,
2021. The DRAFT Standard Conditions document is currently being reviewed by NTPJV,
MCAS Cherry Point, and NAVFAC.
If you need any additional information to assist in your review of this additional information, feel free to
contact me at 919-678-4155 or [e-mail].
Sincerely,
Navy Transportation Partners, JV
Jason Hartshorn, PWS
Cc: George Radford, MCAS Cherry Point
William Wescott, MCAS Cherry Point
Navy
Transportation 421 Fayett - Street, Suite 611 Raleigh, 27601 • • • 111