20220229 Ver 1_USACE More Info Request_20220309

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, March 9, 2022 8:35 AM
To: Brad Luckey; Scott Wallace
Cc: Homewood, Sue
Subject: [External] Request for Additional Information: SAW-2021-02294 (Hudson Way / 6341
Burlington Road / Whitsett NC / Guilford County)
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All,
Thank you for your PCN, dated 2/8/2022, 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your application withdrawn and close the file: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) Sheet 1 does not include the southern portion of the proposed development and its potential connections to
adjacent parcels. Please provide this plan view of the lot layout and infrastructure (roads, utilities, stormwater,
etc.) for the entire proposed development. This plan is necessary to evaluate avoidance and minimization
measures and potential secondary and cumulative impacts of the project;
2) Proposed bottomless arch culvert:
a. Please provide a cross section view of the proposed bottomless culvert structure clearly showing the
outer walls of the culvert structure and footers, disturbance limits needed to construct the structure,
and the stream profile. This information is needed to ensure that this structure would not result in direct
impacts to the stream;
b. The Corps Wilmington District Raleigh Regulatory Field Office has had long experience with bottomless
arch culverts. We generally agree with NCDOT that the long-term success of such structures is
significantly enhanced when they are tied into shallow bedrock. NCDOT Division 7 does not typically
pursue bottomless arch culverts unless there is non-scourable bedrock within 5 vertical feet of the soil
surface. In cases where the structures are not tied into bedrock we have seen numerous instances of
foundation undercutting, often leading to replacement with traditional culverts. Further, shading under
the arch culvert inevitably leads to die off of any remaining woody vegetation, even more so in this case
in the location of the proposed temporary stream crossing where woody vegetation would be removed
entirely prior to culvert construction. These factors predictably lead to loss of aquatic function through
stream bank erosion and winnowing out from foundation to foundation.
c. Given that the project proposes impacts requiring 404 approval, we are evaluating both direct and
reasonably foreseeable indirect impacts to 404 resources associated with the project to ensure that the
individual and cumulative adverse environmental effects are no more than minimal (NWP General
Condition 23 and District Engineer's Decision part 2). Based on the above, it is reasonable to conclude
that the proposed bottomless culvert would result in indirect impacts to the stream in the footprint of
the structure. The proposed direct and indirect impacts to streams do not appear to exceed 0.02 acre,
the typified stream mitigation threshold per Regional Condition B.7, in this case. However, please note
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that these direct and indirect stream impacts would be considered cumulative with any future proposed
impacts to potential waters of the US related to this development when considering compensatory
mitigation requirements.
3) It is your responsibility to contact the North Carolina Division of Water Resources (NCDWR) Winston Salem
Regional Office to determine the 401 requirements for this project. Please note that, if an Individual 401 WQC is
required from NCDWR, the Corps cannot verify the use of any NWP without without a valid 401 Water Quality
Certification.
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 <[e-mail]>
Sent: Tuesday, February 8, 2022 10:55 AM
To: Brad Luckey <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: SAW-2021-02294 (6341 Burlington Road / Whitsett NC / Guilford County)
Good Morning
We have received your Pre -Construction Notification (PCN) NWP request for the above project.
Dave- docs forwarded in your folder.
Thank you,
Josephine Schaffer
From: Brad Luckey <[e-mail]>
Sent: Tuesday, February 8, 2022 10:11 AM
To: RaleighNCREG <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
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<[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] SAW-2021-02294, Burlington Road PCN, Guilford County
Happy Tuesday Morning Corps -Please find attached PCN for above referenced site. Please let me know if you require
additional information.
Sue —we will upload to DWR today.
Thanks.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
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