20220325 Ver 1_USACE Request for More Info_20220324

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, March 24, 2022 3:47 PM
To: Turnbull, Robert T; Will Stevens
Cc: Homewood, Sue
Subject: [External] Request for Additional Information: SAW-2021-00827 (3521 Battleground
Avenue / Will Stevens property / Greensboro / Guilford County / residential)
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All,
Thank you for your PCN, dated 2/28/2022, 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your application withdrawn and close the file: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) There are two versions of preliminary sketches of the overall development provided, each showing a different
alignment of Crossing A with no clear explanation of why both plans were included:
a. The version including revisions dated 1/31/2022 shows an alignment of Crossing A that appears to have
been designed with the future proposed NCDOT widening of Battleground Avenue (U-5892), relying on a
possible proposed realignment of Stream TA. However, NCDOT has not received authorization from the
Corps for any portion of U-5892, nor have they submitted a PCN/application for proposed impacts to
waters of the US (WOUS) associated with this project. Further, NCDOT's Let Date for U-5892 is currently
scheduled for 12/16/2025, leading to a reasonable assumption that NCDOT's PCN/application for
impacts to WOUS associated with that project would not be submitted until late 2024 at the earliest.
Given the preceding, the current proposed culvert alignment for Crossing A does not maintain flow in
the existing stream bed on the downstream side of the crossing, and as such does not comply with NWP
General Conditions 2, 8, 9, 23(a) and 23(b), and Regional Conditions B.7 and B.9.
b. Please confirm that the intended overall project plan for permitting purposes is version whose most
recent revision was dated 9/30/2021, and that the alignment of Crossing A in this version maintains flow
in the existing stream channel rather than a possible future stream re -alignment.
2) The overall project plan shows an added 0.38 acre area labeled "Possible Land Conveyance from COG" that was
not included in the Review Area for the delineation as verified in the field on 4/21/2021. Comparison between
the delineation shown on the overall plan vs. the Potential Wetlands and Waters map verified by the Corps
shows discrepancies between the boundaries of Wetland WA, which extends at least as far as the SE property
line on the Potential Wetlands and Waters map (and possibly onto the adjacent property) but has a different
shape and stops short of the SE property line on the overall plansheet. Please explain this discrepancy and
confirm whether or not potential wetlands and other waters of the US were delineated on the 0.38 acre
"Possible Land Conveyance from COG"; provide any documentation of this additional delineation effort as
required. Make any changes to the PCN and plans accordingly.
3) Although the overall and culvert section plansheets do show the footprint of the proposed culvert structures
and rip rap, they do not show the temporary impacts areas necessary to provide dewatering and construction
access to these stream reaches. Please add these temporary impact areas to the PCN and plans. Provide also the
dewatering plans to install the culverts "in the dry.". Further, please update the plans to clearly indicate the
impact limits in wetlands.
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4) Section D.3 of the PCN lists the stream impact lengths as 45 If (culvert) and 20 If (rip rap) for Crossing A, and 70 If
(culvert) and 30 If (rip rap) for Crossing B. However, the impact footprints from the plans overlayed with the QL2
LiDAR indicate stream impact lengths as —63 If (culvert) and —39 If (rip rap) for Crossing A, and —62 If (culvert)
and —63 If (rip rap) for Crossing B. Please explain these discrepancies and update the PCN and plans as
necessary, noting also the compensatory mitigation threshold for permanent loss stream impacts as typified in
NWP 39 Regional Condition B.7.
5) Section D.3 of the PCN lists the average stream widths as 5 feet. However, my site visit notes as well as QL2
LiDAR indicate that the stream channel is wider than that in most locations. Please clearly document the width
of the stream reaches proposed or impact as measured between the Ordinary High Water Marks of the stream.
Update the PCN and plans as necessary, noting also the compensatory mitigation threshold for permanent loss
stream impacts as typified in NWP 39 Regional Condition B.7.
6) The proposed box culvert structures for both Crossings A and B are 12 feet wide. Note that these structure
widths are both inconsistent with the reported stream channel widths per item 5 above. Further, these
structures do not appear to comply with NWP 39 Regional Conditions B.9.b and c. In particular, per Regional
Conditions B.9.c, If the width of the culvert is wider than the stream channel, the culvert shall include multiple
boxes/pipes, baffles, benches and/or sills to maintain the natural width of the stream channel. Please redesign
the culvert structures accordingly.
7) Per NWP 39 Regional Condition B.8.b, Riprap shall be placed only on the stream banks, or, if it is necessary to be
placed in the stream bed, the finished top elevation of the riprap should not exceed that of the original stream
bed. Please confirm that both of the proposed rip rap pads will comply with this condition, and show on the
profile drawings of each culvert.
8) Given the relatively steep slope (>4%) of Crossing B, we are concerned that this stream would be subject to
headcutting above the proposed culvert if the invert is buried 1 foot as proposed (see also NWP 39 Regional
Condition B.9.a). Please confirm with NCDWR regarding whether or not culvert burial is required/advisable in
this situation. If burial of the culvert pipe is not advised, please redesign accordingly and update the PCN and
applicable plansheets.
9) Project plans indicate that Crossing B is oriented such that the stream exits the culvert aimed at the stream
bank. It is reasonable to expect severe bank erosion in this area during high flows. Please re -design the culvert to
align with the up and downstream stream banks to avoid indirect impacts of erosion and sediment loading into
the stream. If slight re -alignment of the stream channel is necessary at either end of the culvert, please include
proposed cross sections of the stream re -alignment, include the stream impact footprint and the proposed
channel alignment on the plans, and itemize the length of stream impacted as a permanent impact on the PCN.
If such revisions are not practicable, clearly explain why and describe how stream bank erosion in these areas
will be prevented.
10) Please provide the compensatory mitigation acceptance letter from your proposed mitigation sponsor.
11) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
12) It appears that an Individual 401 Water Quality Certification (WQC) is required from the North Carolina Division
of Water Resources (NCDWR) for this project; please note that the Corps cannot verify the use of any NWP
without a valid 401 WQC.
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
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Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG <[e-mail]>
Sent: Monday, February 28, 2022 1:53 PM
To: Turnbull, Robert T <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Subject: SAW-2021-00827 (3521 Battleground Avenue / Will Stevens property / Greensboro / Guilford County /
residential)
Good Afternoon,
We have received your Pre -Construction Notification SAW-2021-00827 request for the above project and forwarded it
to Mr. Dave Bailey for further processing.
Thank you,
Josephine Schaffer
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