20220142 Ver 1_USACE Comments_20220224

Moore, Andrew W
From: Amschler, Crystal C CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, February 24, 2022 4:30 PM
To: Jeff Golladay; Moore, Andrew W
Cc: Leslie, Andrea J; Clement Riddle
Subject: [External] RE: Request for Additional Information, Busbee Phase 1 & la, Buncombe
County (DWR Project #20220142)
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Hi Jeff,
I've reviewed the subject PCN and I have some comments/questions.
1) First, just want to piggy back on Andrews comments from his email below dated 2/7/2022. I agree that the road
design in this location should be reconsidered to see if the meander can be avoided and impacts reduced.
2) I also need some additional information on the phasing of this project. As you know we issue permits for single
and complete projects. The plans and PCN indicate that this permit request is only for Phase 1 and Phase la of
an unknown amount of phases and future development. A plan showing all phases is required on multi -phase
projects if all phases are considered to be a single and complete project.
3) Additionally, based on the information provided, it does not appear to me as though this project adequately
minimizes and avoids impacts to waters of the US. There seems to be substantial amount of high ground on site
that has not been used, and rather and in particular, Phase 1A seems to be in the one area that would
potentially result in the most impacts for the entire site. This issue ties back into the single and complete
project mentioned above. Without see future development plans that justify the impacts to the area of Phase
1A, I see no reason why Phase 1A couldn't be placed in an area that isn't almost completely enclosed by streams
resulting in the stream crossings. Further, without plans for the entire development, its hard to see why the
roadway couldn't be re -designed to circle around the streams and access the high ground in the Phase 1A area
in the high ground area just above the termination of S5 (as shown on the delineation map). If there are to be
future phases with more extensive road networks it seems that this area could be accessed without a stream
crossing.
4) Lastly, the Blue Ridge Parkway is just north of the property. I just want to mention this as I still need to run it
down, but I believe it has some sort of protection under the Historic Preservation Act but not really sure. If so,
there could possibly be a view shed issue that we need to work out with SHPO. I will find out more about this
and get back to you but wanted to put it on your radar in case this does become an issue.
If you have any questions regarding this email and information request, feel free to reach out to me.
Sincerely,
Crystal C. Amschler
Project Manager
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
(828)-271-7980 Ext 4231
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From: Jeff Golladay <[e-mail]>
Sent: Friday, February 11, 2022 3:30 PM
To: Moore, Andrew W <[e-mail]>
Cc: Amschler, Crystal C CIV USARMY CESAW (USA) <[e-mail]>; Leslie, Andrea J
<[e-mail]>; Clement Riddle <[e-mail]>
Subject: [URL Verdict: Unknown][Non-DoD Source] RE: Request for Additional Information, Busbee Phase 1 & la,
Buncombe County (DWR Project #20220142)
Andrew,
Thank you for the comments. The project engineer is considering options and we will have response for DWR as soon as
possible.
Thank you,
Jeff Golladay
Biologist
ClearWater, an EnviroScience Company
O. 828.698.9800 I C. 815.451.8139
From: Moore, Andrew W <[e-mail]>
Sent: Monday, February 7, 2022 3:48 PM
To: Jeff Golladay <[e-mail]>
Cc: Crystal C. Amschler ([e-mail]) <[e-mail]>; Leslie, Andrea J
<[e-mail]>
Subject: Request for Additional Information, Busbee Phase 1 & la, Buncombe County (DWR Project #20220142)
Jeff,
On January 25, 2022, the Division of Water Resources (Division) received your application requesting a 401 Water
Quality Certification from the Division for the subject project. The Division has determined that your application is
incomplete and cannot be processed. The application is on -hold until all of the following information is received:
1. Stream impact S1 is proposed in an area of stream that contains a significant meander. It appears that the
impact associated with this crossing could be minimized by moving the crossing slightly downstream, or farther
upstream above the meander. Please revise the plans to minimize the impact by avoiding the meander or
provide a detailed explanation of why this plan for the activity cannot be reconfigured to better minimize
impacts to the stream. [15A NCAC 02H .0506(b)(1)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the
proper consideration of the application. Please provide your response by March 7, 2022. If all of the requested
information is not received, the Division will be unable to approve the application and it will be denied as incomplete.
The denial of this project will necessitate reapplication to the Division for approval, including a complete application
package and appropriate fee.
Feel free to contact me if you have any questions.
Andrew W. Moore, PG
Environmental Specialist II — Asheville Regional Office
Water Quality Regional Operations Section
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NCDEQ — Division of Water Resources
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