20211449 Ver 1_USACE Comments_20211105

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, November 5, 2021 3:02 PM
To: Beasley, Troy; Lawrence Lane
Cc: Cohn, Colleen M
Subject: [External] Request for Additional Information: Atwater Station Subdivision / Fuquay-
Varina / Wake County / SAW-2019-02194 / NWP 29 Submittal
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All,
Thank you for your PCN, dated 10/1/2021 (complete application received 10/22/2021), for the above referenced
project. I have reviewed the information and need clarification before proceeding with verifying the use of Nationwide
Permit (NWP) 29 (https://saw-reg.usace.army.mil/NWP2021/NWP29.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the Nationwide Permit or consider your application withdrawn and close the file: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) Based on proposed grading and wetland fill and re-routing of drainage, the project would eliminate the drainage
area/hydrology source for much of Wetland A downstream of proposed impact W1. As currently proposed, the
Corps would consider much of the remainder of Wetland WB as indirect impacts (see NWP General Conditions
"District Engineers Decision") to wetlands resulting from a loss of hydrology. How will the project maintain
sufficient hydrology to this wetland area to maintain jurisdictional status and its current level of wetland
function? Note that the combination of direct and indirect impacts to wetlands would push the impacts above
the compensatory mitigation threshold, and thus compensatory mitigation would be required for direct and
indirect impacts resulting in a loss of hydrology and therefore wetland function; compensatory mitigation is
typically required at a 2:1 ratio unless otherwise justified based on resource quality (NCWAM);
2) Similar to the above, given the proposed alignment of Flagship and Fireship Roads, how will the project maintain
sufficient hydrology to Wetland B to maintain jurisdictional status and its current level of wetland function?
3) The proposed greenway boardwalks/bridges traverse forested wetlands. Although the temporary impact areas
outside of the footprint of the 10-foot wide boardwalks presumably would be allowed to regenerate woody
vegetation, the areas immediately under the 10-foot wide boardwalks would not. It appears that approximately
0.072 acre of wetlands would be permanently converted from forested to herbaceous wetlands directly under
the boardwalks, thereby resulting in a reduction in wetland function. Since the combination of direct and
indirect impacts to wetlands would push the impacts above the compensatory mitigation threshold,
compensatory mitigation would be required; compensatory mitigation is typically required at a 2:1 ratio for
direct impacts resulting in a loss of water (unless otherwise justified based on resource quality) and a 1:1 ratio
for permanent conversion of wetlands from forested to herbaceous. Please provide a mitigation acceptance
letter from your proposed compensatory mitigation provider.
4) The Overall Subdivision Plan shows an extension of Fender Road crossing a wetland/stream complex near the
west property line, however no impacts are proposed for this crossing. Noting that the Overall Wetland Impact
Map shows Fender Road stubbing short of this wetland/stream complex, please explain if this crossing is to be
proposed later. If so, would the development to the west be considered a phase of the Atwater Station
development, share any infrastructure, amenities, etc. that may cause the Corps to view this crossing as part of
the same single and complete project.
5) To enable coordination with US Fish and Wildlife Service pertaining to Section 7 of the Endangered Species Act,
please provide the date(s) of your survey(s) for Michaux's sumac (Rhus michauxii).
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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]
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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.
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