20211505 Ver 1_Public Notice Comment Response_20220407

Strickland, Bev
From: Homewood, Sue
Sent: Monday, April 18, 2022 2:32 PM
To: Strickland, Bev
Subject: FW: [External] RE: SAW-2020-00436 Hedrick Industries - Lake Norman Quarry Public
Notice Comment Response
Attachments: 183802_SHEET EC-002_Conservation Easement Layout.pdf; 183802
StreamlmpactSummary_100%.pdf; CEC Response to Public Notice Comments -
Comment Response Matrix.docx; FW: [Non-DoD Source] RE: Pre -Application Meeting
Request, Hedrick Industries, Lake Norman Quarry, Lincoln County (SAW-2020-00436);
183802_FigX_PotentialAvailableAcreage_Map.pdf
For some reason I'm getting an error message when uploading this email and attachments to LF
20211505
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
[e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Thomas, Kevin <[e-mail]>
Sent: Thursday, April 7, 2022 3:15 PM
To: Steve Kichefski <[e-mail]>; Jason Conner <[e-mail]>; Homewood, Sue
<[e-mail]>
Cc: Turner, Jena <[e-mail]>; Stygar, KRYSTYNKA B CIV USARMY CESAW (USA)
<[e-mail]>; Rauch, Sarah <[e-mail]>; Chewning, Clark <[e-mail]>
Subject: [External] RE: SAW-2020-00436 Hedrick Industries - Lake Norman Quarry Public Notice Comment Response
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Mr. Kichefski.
Thank you for your comment responses to our application for expansion of the Hedrick Industries, Inc. — Lake Norman
Quarry. CEC has given full consideration to the questions and concerns raised and has addressed each individually in the
attached Comment Response Matrix (CRM). We have also attached the following supporting information as requested in
part of your comments.
i

CRM Supporting Documents:
GIS Figure: Available Acreage in Additional Properties
Stream Impact Summary Table and Plan Sheet with Conservation Easement (EC-002)
PreApp Meeting 7/15/2020 Email
We ask that you please review the above mentioned materials and provide any final comments so we may resolve any
outstanding issues. If you have no further questions or concerns, CEC will proceed with the following action items.
ACTION ITEM LIST (upon USACE and NCDEQ permit approvals)
- CEC to provide red -line track changed copies of the DRAFT FINAL Alternative Analysis and Appendix G Permittee
Responsible Mitigation, and FINAL CLEAN CHECK COPY versions of all materials for the administrative record.
Please note that for all questions regarding the Catawba Land Conservancy (CLC), CEC has asked Sean Bloom, GIS
Director and Biologist, to provide these responses as he will be the project Conservation Easements POC. Many of the
answers to your inquiries may also be found at the CLC site: Home I Catawba Lands Conservancy
We expect CLC to provide feedback to your questions in the next few days and will submit to you once received.
We would like to thank you for your continued coordination regarding this project.
Thank you,
Kevin Thomas, PWS & LSS (NC, SC & FL) / Principal
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive • Suite 400 • Charlotte, NC 28273
Toll -Free: 855-859-9932 • Direct: 980-260-2035 • Fax: [phone]
Mobile: [phone] • http://www.cecinc.com
Senior Leadership • Integrated Services • Personal Business Relationships
CEC CHARLOTTE CELEBRATING 10 YEARS
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notify the sender by reply electronic communication and immediately delete this message from your system.
From: Kichefski, Steven L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, March 21, 2022 4:08 PM
To: Jason Conner <[e-mail]>; Thomas, Kevin <[e-mail]>
Cc: Sue Homewood <[e-mail]>; Hamstead, Byron <byron [e-mail]>; Bowers, Todd
<[e-mail]>; Munzer, Olivia <[e-mail]>; Jones, M Scott (Scott) CIV USARMY CESAW
(USA) <[e-mail]>; Stygar, KRYSTYNKA B CIV USARMY CESAW (USA)
<[e-mail]>
Subject: SAW-2020-00436 Hedrick Industries - Lake Norman Quarry Public Notice Comment Response
Mr. Conner,
Please find the attached letter providing comment responses to the public notice regarding your application for
expansion of the Hedrick Industries, Inc. — Lake Norman Quarry. Your response to the comments identified must be
given full consideration before we can make a final decision on your application. We need your information to address
the concerns/issues raised over the proposed project.
2

This electronic copy is your official Department of the Army Notification. I paper copy will be provided upon request.
Feel free to contact me with any questions.
Regards,
Steve Kichefski
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District, Asheville Field Office
151 Patton Avenue, Suite 208
Asheville, NC 28801
(828)-271-7980 Ext. 4234
(828)-933-8032 cell
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at our website at
https://regulatory.ops.usace.army.mil/customer-service-survey/ to complete the survey online.
3

Strickland, Bev
From: Thomas, Kevin <[e-mail]>
Sent: Wednesday, March 23, 2022 10:04 AM
To: Chewning, Clark; Turner, Jena; Rauch, Sarah
Subject: FW: [Non-DoD Source] RE: Pre -Application Meeting Request, Hedrick Industries, Lake
Norman Quarry, Lincoln County (SAW-2020-00436)
See below.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Principal
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive Suite 400 Charlotte, NC 28273
Toll -Free: 855-859-9932 • Direct: 980-260-2035 • Fax: [phone]
Mobile: [phone] http://www.cecinc.com
Senior Leadership Integrated Services Personal Business Relationships
CEC CHARLOTTE CELEBRATING TO YEARS
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notes the sender by reply electronic communication and immediately delete this message from your system.
From: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Sent: Thursday, July 16, 2020 8:56 AM
To: Thomas, Kevin <[e-mail]>
Subject: RE: [Non-DoD Source] RE: Pre -Application Meeting Request, Hedrick Industries, Lake Norman Quarry, Lincoln
County (SAW-2020-00436)
Kevin,
The only additions I would have to your emails is as follows:
1 - In order to demonstrate aquatic uplift, the entire reach, not just a few monitoring stations, of the relocated
stream would need to be rated at least at medium, which is an increase from the current low rating.
2- In addition to post construction monitoring of the relocated stream channel, the headwaters wetland should
also have a monitoring station to ensure no loss of wetland acreage and/quality.
Thanks,
Bryan
Sent from my Verizon, Samsung Galaxy smartphone
Original message
i

From: "Thomas, Kevin" <[e-mail]>
Date: 7/16/20 8:44 AM (GMT-05:00)
To: "Roden Reynolds, Bryan K CIV (US)" <[e-mail]>
Cc: Jason Conner <[e-mail]>, "Campbell, David" <[e-mail]>
Subject: [Non-DoD Source] RE: Pre -Application Meeting Request, Hedrick Industries, Lake Norman Quarry,
Lincoln County (SAW-2020-00436)
Mr. Roden Reynolds.
Thank you for taking the time to meet yesterday, especially with the current
weather pattern. Please let me know if you still have access to the Pre -Application
packet I submitted in February to the Asheville Corp office. Originally we had
proposed two designs. Please ignore the "Engineered Option" as we will be
proposing the Natural Stream Channel Design or some modification of.
Based on our site meeting on 7.15.2020 the United States Army Corp of Engineers
(USACE) would require an individual permit to relocate Forney Creek. It was
agreed that Forney Creek is a highly degraded stream, with a low NCSAM score
and is on the federal and state list of 303d /303e, respectively, streams.
As a result of the current state of Forney Creek, there was concurrence that if
ecological uplift was provided by the Client through Natural Stream Channel
design, a 50' to 100' wooded buffer, the removal of the low head dam and no net
loss of the aquatic resource (linear feet), compensatory mitigation would not be
required.
The ecological uplift would be on a 7 year monitoring period, two times a year and
during 10+ year storm events. The NCSAM method would be used to evaluate,
quantify, the ecological uplift provided, with a goal of meeting a Medium score
within several of the monitoring stations. This would also help maintain the new
channel while vegetation and in -channel structures become stable.
There was concern of potential inadvertent impacts to wetland waters of the US
that have formed, anthropogenically, above the existing low head dam. CEC will
provide you a baseline assessment of the Wetland by utilizing the NCWAM
method. Additionally our design will seek to maintain the current water level,
through modeling and design, with a goal to limit long term impacts.
2

Attached is an updated Potential Aquatic Resources Figure.
At this time CEC and the Client request the PJD application withdrawn, as
discussed during the on -site meeting for pre -application.
Please let me know if you have any questions, additions or further concerns on
what was stated within the email or it's attachments.
Kevin Thomas, PWS & LSS (NC, SC & FL) / Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive Suite 400 Charlotte, NC 28273
Toll -Free: 855-859-9932 • Direct: 980-260-2035 • Fax: [phone]
Mobile: [phone] • Blockedhttp://www.cecinc.com
Senior Leadership Integrated Services • Personal Business Relationships
This electronic communication and any attachments are intended solely for the use of the person or entity to which it is addressed, and may contain
information that is confidential, privileged and exempt from disclosure under applicable law, including copyright law. If you are not the intended
recipient of this message, you are prohibited from disclosing, reproducing, distributing, disseminating or otherwise using this transmission. Please
promptly notes the sender by reply electronic communication and immediately delete this message from your system.
From: Thomas, Kevin
Sent: Friday, February 28, 2020 9:08 AM
To: [e-mail]
Cc: Jason Conner <[e-mail]>
Subject: Pre -Application Meeting Request, Hedrick Industries, Lake Norman Quarry, Lincoln County
Please find below a link to our companies FTP site to a Pre -Application Meeting Request Packet for Hedrick Industries
Lake Norman Quarry, Forney Creek Project located in Lincoln County, NC. We look forward to hearing from you soon
with an assigned action ID number.
Blockedhttp://downloads.cecinc.com/183-802
Please contact me with any questions or concerns.
Thanks,
Kevin Thomas, PWS & LSS (NC, SC & FL)/ Senior Project Manager
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive Suite 400 Charlotte, NC 28273
Toll -Free: 855-859-9932 • Direct: 980-260-2035 • Fax: [phone]
Mobile: [phone] • Blockedhttp://www.cecinc.com
Senior Leadership Integrated Services • Personal Business Relationships
3

NORTH
I ))
,_822_335311
PROPOSED MAINSTEM STA 32+62 ice.
EXISTING MAINSTEM STA 29+58
END OF FIRST PART OF r
CONSERVATION EASEMENT BUFFER'
I i) °
PROPOSED MAINSTEM STA 34+12
EXISTING MAINSTEM STA 31+09
END OF PRIORITY 2 RESTORATION
j 1I)11 \ \-
1 PROPOSED MAINSTEM STA 33+67
RI EXISTING MAINSTEM STA 30+04 START OF SECOND PART OF I
]) 1 ,DONSERVATI,ON EASEHEN7 BUFFER
REs,13 00FEA,r2
O/START OF PRIORITY 2
RESTORATION
EXISTING MAINSTEM STA 29+48
END OF TEMPORARY IMPACTS FOR
P ION/START OF
rJ
Line 4
L1
L2
L3
L4
Line To Isle
Distance
1T5.923
133.491
194.996
159 846
1F,
Buffer Offset width lMmmation
Maximum Offset
mr
dM
Minim Offset
Width
AveOffset
Width
offset width measured from banMull toeasement
boundary
Bea ing
N72` 39' 10.61,
N85' 42' 2622,
S84° 40' 3852'W
S74° 53' II24,
LE
L8
125.TTT
S29" 53' 30.83,
L9
286.647
S38° 19' 59.32"W
L10
35.921
S43° 20' 04.52,
51. 729
S49° 41' 2346'W
L12
139318
S60° 40' 5353'W
LIS
81219
S29° 11' 37,47,
L16
1T1,455
S43° 09' 55.81"W
L16
59158
SI, 12' 36.86,
L1T
131.945
S2. 4745,47'W
L18
46.540
SI° 35' 29.64'W
L19
146.892
S6° 19' 39.65'W
18-13343.
Line Toble
Line d
Distance
Ben Ing
L21
134,T3T
S27' 46' 5158,
L22
99.196
S64. 25' 31,76,
L23
140. 797
N20° 17' 51.03"W
L24
79 906
N26. 28' 0458'E
L28
308.952
N47" 40' 03.92"E
L29
302,425
N34" 05' 22.61'E
L30
108.809
N43. 55' 22.97'E
L31
334 383
N64° 21' 4152"E
L32
29059T
N86° 05' 1665"E
L35
86.30T
S81" 19' 1839,
L36
10T.823
S3° 45' 44.87'E
L38
134.95T
SIT' 40' 34.18,
L39
6942T
S88° 33' 49.65,
L40
131.732
NT° 38' 15.89'W
L41
171108
N74° 25' 2157°E
,34
iJ
�)I
SUBMITTAL RECORD
NO DATE DESCRIPTION
'PROPOSED MAINSTEM STA 3,3
_TART OF PROPOSED PRIORITY 'I FT \ 1,
RESTORATION
1\
Impact, Mitigat
on and Connotation
Easement Table
nfact Component
bnna eot(aln
Nobs
Existing Forney Malnstem (Aquatic Bed) to be Relocated:
3,798
Excludes 50 LF of existing culvert
Pdodty 1 Aquatic Bed Restoration on Proposed Mamstem:
Z819
Within Conservation Easement
Length of Priority 2 Restoration:
115
WRNn Conservation Easement
Tgml Rez[orrtlon (Priority le Priority 2)
2999
Within Conservation Easement (excludes 951E of proposed
badge and maintenance condors(
Additional ma. bed established during Restoration:
III
matches existing mainstem 1:1 with additionaltl
linearfeet of aquatic bed established
4361inear feet of tribu.ry will also be established but will not Daunt towards rediting
STREAM AND IMPACTS NOTES:
r. En TING MAINSTEM TO BE MOVED FOR RESTORATION. 2.790 LINEAR FEET (LF) (STA. 1+00 To STA 294481 NOTE. EXCLUDES 50 LF OF EXISTING CU Eat.
2. PR ORI, 1 RESTORATION ON PROPOSED MAINSTEM: 2,879 LF (STA 3+73 TO STA 32452).
33 PR oPROPOSED MNSTOM• STA 3,52 TO STA 3,62 (To v) IN FIRST Pour of P BUFFER, STA MOT To STA 3,1+12 (105 LF) IN SECOND PolrT of P BUFFER
MAINSTEM: STA. 29+48 TO STA.
(10 LF) IN FIRST
OF
BUFFER; STA. 30+04 TO STA. 31409
4. PRIORI, 1 AND PRIORI, 2 RESTORATION MATCHES OEXISTING MAINSTEM 1 WITHANADDITION, S LF) IN SECOND PART of C[ BUFFER.
I0N, 81 LF OF PROPOSED STREAM.
5. MAJORITY OF EXISTING MAINSTEM IS LOCATED OUTSIDE OF THE CONSEFNATION EASEMENT BUFFER BOUNDARY.
SCALE
EXISTING CONTOURS
PROPOSED CONTOURS
PROPOSED BANKFULL
NOT FOR MCTIONI
"Fr
M /
Civil & Environmental Consultants, Inc. 3701 Arco Corporate Drive • Suite 900 • Char.% NC ,
HEDRICK INDUSTRIES
FORNEY CREEK
STREAM RELOCATION PLAN
LAKE NORMAN QUARRY, STANLEY N.C.
DATE APRIL 2022 DWG SCALE
CHECKED ay
DRAWN BY
AS NOTED PPPIECT NO
183-802
DRAFT
CONSERVATION EASEMENT
LAYOUT
D EC-200

Impact, Mitigation, and Conservation Easement Table
Project Component
Linear Feet (LF)*
Notes
Existing Forney Mainstem (Aquatic Bed) to be Relocated:
2,798
Excludes 50 LF of existing culvert
Priority 1 Aquatic Bed Restoration on Proposed Mainstem:
2,879
Within Conservation Easement
Length of Priority 2 Restoration:
115
Within Conservation Easement
Total Restoration (Priority 1 + Priority 2):
2,994
Within Conservation Easement (excludes 45 LF of proposed bridge
and maintenance corridors)
Additional aquatic bed established during Restoration:
81
Restoration matches existing mainstem 1:1 with additional 81 linear
feet of aquatic bed established
*Linear feet measured via centerline of stream
436 linear feet of tributary will also be established but will not count towards crediting

P:120181183-8021-GISIMaps1183802_FigX PotentialAvailableAcreage_Map.mxd 4/1/2022 3:47 PM (jtumer)
0
NORTH
LEGEND
Permitted Boundary (— 499.5
Acres)
Hedrick Parcels Outside of
Permitted Boundary (-59.2
Acres)
Delineated Features
Gas Line ROW
Duke Energy ROW
100 Year Floodplain
Acreage Within Southern Area of
Permitted Boundary (-44.3
Acres)
Acreage Within Additional
Hedrick Properties (-33.0 Acres)
/ffm/m/7
Nm iw
Civil & Environmental Consultants, Inc.
3701 Arco Corporate Drive • Suite 400 • Charlotte, NC 28273
[phone] • [phone]
www.cecinc.com
DRAWN BY:
JST
DATE:
4/1/2022
CHECKED BY:
DRAFT
SCALE:
1 "=800'
REFERENCES AND NOTES
1. ESRI World Imagery /ArcGIS Map Service:
http://goto.arcgisonline.com/maps/world_imagery
Accessed: 4/1/2022
2. Parcels derived from NC One Map website
www.nconemap.gov
3. FEMA National Flood Hazard Layer (NFHL) for
North Carolina - Dated 8/16/2007.
NOTE:
Jurisdictional features have been field verified by
the USAGE SAW-2020-01835, PM Mr. Roden -
Reynolds, PWS 7/15/2020 and Jurisdictional
Determination issued by USACE PM Krystynka
Stygar 3/8/2021.
Available acreage was calculated using 50'
buffers off FEMA floodplain, delineated streams,
neighboring Non -Hedrick properties, and
utility ROWs.
0
400
SCALE IN FEET
800
1,600
B. V. HEDRICK INDUSTRIES
LAKE NORMAN QUARRY
ALTERNATIVE ANALYSIS
LINCOLN COUNTY, NORTH CAROLINA
POTENTIAL AVAILABLE ACRES
APPROVED BY:
DRAFT*
PROJECT NO:
183-802
FIGURE NO:
X
*Hand Signature on file

Public Notice Comment Response Matrix
Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
#
Location
Type of
Comment
Agency Comment
Reviewer
CEC Response
Document
Date
Section, Page
S, C, A
GLOBAL DOCUMENT CHANGE
Please note that Alternative 2 has been renamed as the No Action Alternative. Subsequently, Alternative 7 has been deleted
from the analysis.
CEC
Please note that under further analysis, Alternative 2 presents what would occur under the No Action Alternative. As such,
the updated Alternatives Analysis has been revised to combine Alternatives 2 (No Mine Wall Expansion, Deepen Current
Pit) and Alternative 7 (No Action Alternative).
1.
a.
Alternatives
Analysis
3/21
Section 3.0, pg.
12
If a lower Life of Mine (LOM) were targeted, would there be a
reduction in impacts proposed or would a similar impact/pit
expansion footprint be required?
p p q
SK
The only option for reducing the LOM is the No Action Alternative, as the current mine plan gives Hedrick approximately
15 to 20 years of a projected LOM. Implementation of Alternative 2 (No Wall Expansion, Deepen Current Pit — renamed as
the No Action Alternative) would result in a narrower pit than the Preferred Alternative. This would reduce the impact/pit
expansion footprint, as no lateral expansion would occur. However, this option was deemed infeasible due to safety
requirements. The projected LOM generated from this proposed expansion (Preferred Alternative) is a secondary
attribute due to safety. Moving the mine wall will allow for deeper mining, improving the longevity of the LNQ Mine.
Other on -site alternatives with a similar LOM were thoroughly considered, however results of the Alternatives Analysis
concluded most of these alternatives would result in significant impacts. Additionally, under the other on -site alternatives,
ForneyCreek would not be restored to the degree currentlyproposed under thepreferred alternative. The proposed
gp p p p
restoration of Forney Creek (currently listed as a 303d stream and a low scoring [in all categories] per NCSAM) is beneficial
to the area cumulatively, specifically in regards to efforts currently underway in the upper Forney Creek watershed.
*Please see the response to comment 10 for additional details regarding cumulative impacts.
While a reduction in the LOM was also considered, it was ultimately determined that a reduction in LNQ's projected
longevity would affect aggregate distributions to the local industry, which is growing under an accelerated demand.
1.
b.
Alternatives
Analysis
3/21
Section 3.0, pg.
12
Does the LNQ Mine have any tentative plans for future phases of
mine expansion beyond the future LOM projection?
SK
Implementation of the proposed action would ensure that future mining would occur within the permitted mine
boundary (of which includes the expansion footprint). Additional impacts to aquatic resources would not be anticipated.
2.
a.
Alternatives
Analysis
3/21
Section 4.0, pg.
14
Item 5 seems to restrict potential off -site alternatives. Why is a 1-
mile limit necessary if there were a potential off -site alternative?
SK
A 1-mile limit was set for potential off -site alternatives to meet current mine trucking/transportation needs. This limit was
set specifically to minimize the quantity, frequency, and travel distance of customer vehicles (i.e. dump trucks, CDL
licensed vehicles, mine vehicles, etc.). Please note that mine vehicles cannot travel on public roads. As such, a 1-mile limit
and 100-acre site alternative screening criterion were selected.
2.
b.
Alternatives
Analysis
3/21
Section 4.0, pg.
14
Please clarify how 100-acre site alternative screening criteria was
determined so the Corps can verify it does not unnecessarily
restrict alternatives.
SK
Please see above comment response. Additionally, the 100-acre footprint was chosen as the bare minimum; 100-acres
would limit Hedrick's current ability to mine and distribute to the local market under demands. Hedrick can currently
produce 1 million tons of aggregate material. A 100-acre area footprint would reduce production to approximately
250,000 tons of material per year. Under the proposed action, Hedrick would be able to produce up to 2 million tons of
material per year.
Additionally, please refer Figure 1-2 Permitted Area Use Map (page 9). The current existing infrastructure (including the
quarry pit, processing plant, and overburden/pond fine storage) requires approximately 169 acres. This is a conservative
measurement, as it does not account for an additional 110 acres of existing overburden storage on site. In order to
replicate a similar system at an off -site location, it was determined that at least 100 acres would be a bare minimum
acreage required based on industry standards for a quarry in NC.
2.
c.
Alternatives
Analysis
3/21
Section 4.0, pg.
14
Throughout the alternative analysis options presented, several
alternatives are deemed not practical as LEDPA due to prohibitive
costs without providing an approximate cost of the preferred
alternative for comparison or what threshold might constitute a
prohibitive cost and why. This information and how it was
determined is needed in order to appropriately evaluate the
alternatives provided.
SK
All of the Alternatives considered were deemed environmentally impactful. However, under the Preferred Alternative
impacts to Forney Creek would be temporary. Permanent impacts to the area would be beneficial through stream
improvements (via ecological uplift to a degraded stream) to the natural channel design. The repaired stream will be
protected in -perpetuity by the established Conservation Easement (CE). Note that the CE option was chosen as it is a
more environmentally and cost-conscious alternative than moving the stream and buying in -lieu fee credits.
For purposes of this project, Hedrick has defined prohibitive cost as 5 million. Cost was analyzed in the context of the
overall scope/cost of the project and whether it is unreasonably expensive. This determination was made in relation to
1

Public Notice Comment Response Matrix
Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
#
Location
Type of
Comment
Agency Comment
Reviewer
CEC Response
Document
Date
Section, Page
S, C, A
comparable costs for similar actions in the region or analogous markets. (Note: For practicability purposes, if costs of an
alternative are clearly exorbitant compared to those of similar actions, and possibly, of the proposed action, they can be
eliminated without the need to establish a cost threshold for practicability determinations — per the USACE's 'Preparing An
Alternatives Analysis Under Section 404 of the Clean Water Act, Fort Worth District— Regulatory Division November 2014).
Please see below for projected cost estimates by alternate: *Please note that these costs were estimated based on similar
projects completed across the nation, as calculated by Hedrick.
Comparison of Projected Costs for each Alternative:
• Alternative 1: Projected cost of Preferred Alternative is estimated to be approximately $2 million
• Alternative 2: new No Action Alternative
• Alternative 3: No cost was determined because the location of the berm negates this as a viable choice due to
the low acreage available.
• Alternative 4: Projected cost is approximately $5 million to move the Duke ROW (see Appendix C) and $40 million
to construct a new plant (see page 25) per Hedrick's estimate.
• Alternative 5: Projected cost is either $3.2-4 million to relocate the pond fines, or $10-15 million to construct a
new pond system (see page 27) per Hedrick's estimate.
• Alternative 6: No cost was determined as the Greenfield sites were deemed unsuitable by not meeting the
required screening criteria.
• Alternative 7: Per page 32, this alternative would result in the LOM expiring in 15-25 years, a loss of $82,000 in
annual taxes, a loss of 25 direct jobs with a gross payroll of $2 million, and affiliated job loss of 128.
In comparing projected costs and/or other impacts, the Preferred Alternative was chosen as the most LEDPA, cost
efficient, ecologically beneficial, and safe alternative.
2.
d.
Alternatives
Analysis
3/21
Section 4.0, pg.
14
What are the total projected costs of the compensatory
mitigation (design CLOMR/LOMR, construction, monitoring, and
long-term stewardship, etc.)? These costs need to be factored
into the alternative analysis comparisons.
SK
These actions and subsequent costs were considered as part of the Preferred Alternative (estimated to be up to 2 million
dollars). Note that the standard endowment costs and finical assurances are included separately.
3.
a.
Alternatives
Analysis
3/21
Section 4.2.2, pg.
20
Please clarify whether this alternative is considering the same
depth and pit size as the preferred alternative or the same depth
but a narrower pit size at that depth so the slopes would meet
safety requirements but still avoid all impacts?
SK
Implementation of Alternative 2 (No Wall Expansion, Deepen Current Pit — renamed as the No Action Alternative) would
result in a narrower pit than the Preferred Alternative as no lateral expansion would or could occur due to safety
requirements. The current mine plan gives Hedrick approximately 15 to 20 years of LOM.
3.
b.
Alternatives
Analysis
3/21
Section 4.2.2, pg.
20
Is an option available that would allow extension of LOM by
deepening mine pit and meet safety requirements even if not
fully meeting 75-100-year LOM? If yes, what would it's LOM be
and what would preclude it from being feasible/practicable
alternative?
SK
Please see comment response to 1.a.
3.
c.
Alternatives
Analysis
3/21
Section 4.2.2, pg.
20
Please clarify why dewatering and additional haul trucks would
not be an issue with the applicants preferred alternative if both
miningto the same depth (100 additional feet)?
propose p)•
SK
Hedrick currently estimates 1 truck > 1 million dollars, with a life span of a truck at around 15 years. While this alternative
is not cost prohibitive, it was still deemed infeasible as the alternative's constraints were based on safety and projected
LOM. Under the No Action Alternative the current mine plangives Hedrick approximately 15 to 20 years of LOM.
pp Y
2

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4.
a.
Alternatives
Analysis
3/21
Section 4.2.4, pg.
25
Paragraph 1 of this alternative and the associated figure on page
26 seem to imply this alternative would expand to the edge of the
Duke Right -of -Way (ROW), but not beyond it, except for the pond
replacement and overburden storage areas to the south of it.
Those areas appear to already have access across the ROW. The
remaining paragraphs of this alternative seem to suggest that the
Duke ROW would need to be moved for this alternative. Please
clarify whether the Duke ROW would have to be moved for this
alternative to be considered. If it does not have to be moved,
update what factors would make it not practicable.
SK
Correct, while there are a few existing crossing locations within the Duke Energy (Duke) ROW, these crossings are not
impaired from existing infrastructure.
Under Alternative 4, the Duke ROW and existing infrastructure (i.e. transmission lines, ponds, etc.) would have to be
moved in order to expand the mine and construct a new plant safely. Duke Energy has dictated that Hedrick cannot
construct structures within or near the ROW. This option was deemed infeasible due to the feasibility, practicability, and
cost of breaking down and moving the existing infrastructure, and the associated subsequent permitting/scheduling that
would be required under this alternative.
4.
b.
Alternatives
Analysis
3/21
Section 4.2.4, pg.
25
There seems to be feasible configurations of utilizing the LNQ
Mine area south of the existing —16.1 acres overburden storage
area, possibly in some combination with the additional parcels
(59.2 acres) owned by Hedrick outside of the permitted boundary
that would avoid much of the 3,544 linear feet of stream impacts.
Even if crossings were needed the impacts, mitigation costs, and
FEMA impacts seem like they could be significantly reduced.
Further explain this possibility and how it might change the
alternative consideration.
SK
This area is outside of the currently permitted LNQ Mine Boundary and would require Hedrick to obtain a new/revised
permit. While this is not a fatal flaw, there is existing infrastructure (massive overburden) that would need to be moved
and a new (separate) pit would need to be constructed. The cost of breaking down, stripping, storing overburden, and
rebuilding this infrastructure would be cost prohibitive (estimated at a cost of 25+ million). Additionally, striping the land
and moving the overburden (— 35 million cubic yards) would impact the streams onsite and would create significant
impacts across multiple resource areas (such as biological, water, safety, and infrastructure) and subsequent permitting
would be required. In addition to not being feasible, this suggested alternative would not provide Hedrick with enough
acreage to justify pursuing this alternative. The preferred alternative would not require additional land to store
overburden.
The massive overburden required to be removed in this area would cause permeant impacts to aquatic resources (green
hatched area) or the 3000+ linear feet.
(*Note that this alternative currently considers a new mine pit. Please see the details of this alternative in the Alternatives
Analysis for constraints associated with this option).
4.
c.
Alternatives
Analysis
3/21
Section 4.2.4, pg.
25
The preferred alternative seems to have a much smaller
expansion footprint to provide the LOM extension desired. Why
would this alternative require so much expansion space to be a
feasible alternative?
SK
The Preferred Alternative does not require the removal and rebuilding of existing infrastructure. Under Alternative 4,
existing overburden areas (of which are massive) would need to be moved. Moving these areas would require additional
planning (and potential permitting under the SWPPP) to keep the sediment out of the waterway. Note that moving the
infrastructure would create a permanent impact to aquatic resources, while the Preferred Alternative would include a
temporary impact to aquatic resources. The Preferred Alternative also accounts for improving the overall habitat and
conditions of the currently degraded 303d stream.
4.
d.
Alternatives
Analysis
3/21
Section 4.2.4, pg.
25
See comment 2c related to practicable costs to better evaluate
this alternative also in consideration with the comments a, b & c
of this alternative.
SK
Please refer to paragraph 3 on page 25 where it states that it would not be feasible to disassemble, move, and reassemble
the current plant. The cost of constructing a new plant is—$40 million according to Hedrick's estimate. Even if the ROW,
stream, and FEMA impacts were not considered, the cost alone of constructing a new plant negates this option.
5.
a.
Alternatives
Analysis
3/21
Section 4.2.5, pg.
28
There seem to be feasible configurations of utilizing the LNQ Mine
area south of the existing —16.1 acres overburden storage area,
possibly in some combination with the additional parcels (59.2
acres) owned by Hedrick outside of the permitted boundary that
would avoid much of the 3,310 linear feet of stream impacts.
Even if crossings were needed the impacts, mitigation costs, and
FEMA impacts seem like they could be significantly reduced.
Whether for overburden storage, fine storage, or pond
SK
Please see comment response to 4.b.
3

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relocation, further explain this possibility and how it might change
the alternative consideration
5.
b.
Alternatives
Analysis
3/21
Section 4.2.5, pg.
28
The preferred alternative seems to have a much smaller
expansion footprint to provide the LOM extension desired. Why
would this alternative require so much expansion space to be a
feasible alternative?
SK
The Preferred Alternative does not require the removal and rebuilding of existing infrastructure. Under Alternative 5,
existing overburden areas (of which are massive) and large pond would need to be moved. Moving these areas would
require additional planning (and potential permitting under the SWPPP) to keep the sediment out of the waterway. Note
that moving the overburden storage areas and pond would create a permanent impact to aquatic resources, while the
Preferred Alternative would include a temporary impact to aquatic resources. The Preferred Alternative also accounts for
improving the overall habitat and conditions of the currently degraded 303d stream.
5.
c.
Alternatives
Analysis
3/21
Section 4.2.5, pg.
28
See comment 2c related to practicable costs to better evaluate
this alternative, also in considering with the comments a & b of
this alternative
SK
Please refer to paragraphs 3-4 on page 27; a primary constraint to this alternative is the requirement for moving the
gravity -fed pond system and the pond fines stockpiles. Hedrick has provided a cost estimate of—$3.2-4 million for
relocating the pond fines and an additional $10-15 million to replicate or move the current pond system.
6.
a.
Alternatives
Analysis
3/21
Section 4.2.6, pg.
29
Comments 2a, b & c need sufficient explanation before
Greenfield site alternatives can be appropriately evaluated
SK
Please see 2a, b, and c comment responses.
6.
b.
Alternatives
Analysis
3/21
Section 4.2.6, pg.
29
Would Greenfield Alternative AA2 be feasible when considered
with the large unused area to the east of the current pond
system, especially with the potential for retaining use of much of
the current infrastructure?
SK
This area is currently used as overburden storage, as well as landfill owned by Republic Services. In order for this
Alternative to be feasible, Hedrick would have to purchase this land from Republic Services under the assumption that this
land is not slated for future use or development.
The Preferred Alternative does not require the removal and rebuilding of existing infrastructure. Under Alternative 5,
existing overburden areas (of which are massive) would need to be moved. Moving these areas would require additional
planning (and potential permitting under the SWPPP) to keep the sediment out of the waterway. Note that moving the
overburden storage areas would create a permanent impact to aquatic resources, while the Preferred Alternative would
include a temporary impact to aquatic resources. The Preferred Alternative also accounts for improving the overall habitat
and conditions of the currently degraded 303d stream.
7.
a.Section
4.3.2
Update or confirm Alternative 1 impacts as discussed during our
onsite visit which regarding mitigable stream footage only
considered by stream center line and within the proposed
conservation easement (not within crossing locations, etc.)
SK
Please refer to the Stream Impact Spreadsheet and Sheet EC-002 — Conservation Easement Layout.
Alternative 1 impacts have been confirmed as discussed during our onsite visit. All measurements have been conducted
via stream centerline and within the proposed conservation easement.
As shown on Sheet EC-002 and the Stream Impact Summary Table, the existing Forney Creek aquatic bed to be relocated
is 2,798 linear feet. The Proposed Priority 1 Aquatic Bed restoration within the Conservation Easement is 2,879 linear feet.
The Proposed Priority 2 restoration within the Conservation Easement is 115 linear feet. The total restoration (Priority 1
and Priority 2) within the Conservation Easement is 2,994 linear feet. This measurement excludes 45 linear feet of
proposed bridge and maintenance corridors that would be outside of the Conservation Easement.
Comparing the measurements of the existing Forney Creek and the Proposed Priority 1 restoration within the
Conservation Easement, linear feet of the proposed restoration matches linear feet of the existing mainstem 1:1 with an
additional 81 linear feet of proposed aquatic bed established.
7.
b.
Section 4.3.2
USACE appreciate the proposed replacement of the current
culvert with a bridge under the preferred alternative
SK
Noted, thank you.
7.
C.
Section 4.3.2
Please see previous alternative analysis comments 4b and 5a
regarding the potential for reducing stream impacts with more
SK
Please see applicable comment responses.
4

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careful consideration of the overburden area utilization and
additional parcels.
8
Section 5, pg.
46-47
See comments above seeking additional information to clarify
alternative comparisons.
SK
Please see applicable comment responses.
9.
Table 5-1
Please clarify what is meant by "Impacts to NWI Resources" for
this project. Does this just mean WoUS or include other protected
resources?
SK
"NWI Resources" indicates anything that appears on the National Wetland Inventory database — wetlands and WoUS.
10.
Provide further information on any anticipated cumulative and
secondary impacts that will occur in the project area or local
region.
SK
The proposed restoration
NCSAM) is directly
Forney Creek watershed.
over 8,000 linear ft
the Preferred Alternative,
10 miles of unnamed
to remove Forney
enhancement restoration
for additional information).
Under the No Action
pollutants from the
and residential development.
low head dam would
of Forney Creek (currently listed as a 303d stream and a low scoring [in all categories] per
beneficial to the area cumulatively, specifically in regards to efforts currently underway in the upper
The Catawba Lands Conservancy (CLC) has applied for state grant funds to design and permit
of the mainstem and tributaries in an effort to control the headwaters for restoration. Combined with
CLC would be able to cumulatively restore approximately Smiles of the main channel and over
tributaries to Forney Creek in a conservation easement (CE). CLC and CEC's ultimate goal would be
off the 303d list. CLC has preemptively purchased easements for conservation and potential
actions (please see https://storymaps.arcgis.com/stories/c118c1c83ce14ed88b664b4ce9f000c2
Alternative, it is anticipated that the watershed would stay the same or be subjected to further
urbanization of the surrounding areas. The landscape has been disturbed by continuous commercial
The low head dam currently inhibits aquatic passage. Under the Preferred Alternative, the
be removed, directly and indirectly improving the aquatic ecosystem/WOTUS.
11.
How long is LNQ Mine proposing for this permit to be valid? If
approved, when does LNQ mine propose to begin and complete
work?
SK
Upon receipt of 401/404 and FEMA LOMR/CLOMR permits, implementation of the processes associated with the
proposed action (i.e. hiring of construction crews and contractors) would begin within 6 to 12 months. This is a single and
complete project, all impacts are to be performed in one phase. Once the proposed action is complete Hedrick intends to
expand the mine wall within 1 to 2 years of proposed action completion. Assuming the proposed action is released within
by the USACE after its 7 year monitoring period Hedrick anticipates needing the permit for no more than 10 to 12 years.
12.
a.Appendix
B
Who is the project designer? Who will construct the project?
Who will monitor the project? What is experience level of those
involved?
SK
CEC serves as the project designer. Hedrick will put out bids for construction. CEC will serve as the 7-year monitor, as
detailed in Appendix G PRMP. CLC has been assigned the monitoring designee past the 7-year monitoring.
12.
b
Appendix B
How much and what is the plan for managing the sediment from
the upstream impoundment?
SK
The elevation that the current low head dam sits at will be maintained and the proposed stream invert with be brought up
to reduce flow velocity and minimize erosion potential. This coupled with an improvement in pool -riffle sequences,
improved sinuosity, and floodplain reconnection should help reduce the amount of sediment transported down from the
upstream impoundment.
12.
c.
Appendix B
What % of the relocated stream buffer will be under 50 feet in CE
width? May need to provide non-standard buffer width data
(maps/excel sheet) if over 5%.
SK
Zero percent of the relocated stream buffer will be under 50 feet in CE width. The shortest width is 50.6 feet, the average
width is 69.8 feet, and the maximum width is 129.4 feet. Please see Sheet EC-002 — Conservation Easement Layout for
reference.
5

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Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
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12.
d.
Appendix B
Stream relocation ends downstream just before a large bend
according to submitted plans. Is that bend unstable and/or is
there concern for it becoming unstable post project? Document
stability of this bend (at least photos) and include in post-
construction monitoring.
SK
The bend is stable as it is naturally armored with bedrock, as such there are no concerns with stability post project.
Stability and conditions of this bend will be documented via photos and included in the post -construction monitoring as
detailed in Appendix G of the PRMP.
12.
e.
Appendix B
Explain Drawing Sheet 4 — Existing Plan and Profile: this area
appears to be the impoundment behind the dam, yet with
channel riffle/pool parameters? Is the impoundment
drained/dam breached? Is the bottom consolidated enough to
have accurate dimensions or is mobile silt present in this area?
SK
This sheet does not display channels or riffle/pool parameters in the impoundment behind the dam. On the plan view
portion, the dam is labeled to the left with the existing channel and alignment continuing off to the right. The north arrow
on the plan view portion and the corresponding key map on the right of Sheet 4 should help readers orientate
themselves. The existing channel does have some riffle/pool parameters and those areas have been called out on the
profile view as well as areas where features were not well defined.
12.
f'
Appendix B
Channel is within floodplain/floodway — what challenges are
expected with the proposed project and where does the project
stand regarding FEMA approval? Existing FEMA floodway line
appears to cross the channel on Fig 4 & 6. Is this correct? Please
explain.
SK
The FEMA floodway lines shown on Sheets 4 & 6 are data downloaded from FEMA's National Flood Hazard Layer database
for Lincoln County, North Carolina. While it is the most recent floodplain data available, it was last updated 09/2015
according to the FEMA GIS website. It is understood that some erosion may have occurred since then especially in such a
degraded watershed. CEC is currently evaluating impacts to the base flood elevation within the community in the vicinity
of the project area. Because a change to the stream centerline is proposed, CEC is preparing a Conditional Letter of Map
Revisions (CLOMR) application to be submitted to FEMA.
12.
g.
Appendix B
Plan Sheet 8: Confirm that the dam is to remain as stated in
executive summary (Appendix G, pg. 2) or to be removed as
stated in project goals (Appendix G, pg. 5) and shown in plans
(Sheet 8). How much sediment is upstream of the dam? In
otherwards, is the sediment a risk for burying downstream
habitat/structures post construction?
SK
Effectively, the dam will not be removed. Under the proposed action, the elevation of the spillway will not be changed and
the floodplain will be reinforced. The current spillway consists of anthropogenic materials that are functioning poorly. The
proposed design consists of removing the anthropogenic materials and elevating the stream channel invert to the current
spillway elevation of the impoundment, per USAGE requirements, allowing aquatic passage. As such, CEC has identified
Alternative 1 as the preferred alternative as sediment release would be limited.
12.
h.
Appendix B
Plans indicate that excess soil material will be generated by
excavation (cut) for this project. In floodplain cut areas, how will
topsoil be kept from washing away during storm events (prior to
vegetation establishment)?
SK
The newly constructed stream channel will have coir fiber matting installed from bottom of bank to top of bank (bankfull
elevation) along the entire alignment. It is common practice to install matting up to bankfull elevation, and install seed
and straw along with stem/bare root species in the floodplain for permanent vegetation and erosion prevention.
12.
i.
A endix B
pp
What is the maximum boulder step and vane/j-hook height from
normal pool water surface elevation to top of step?
SK
The proposed design limits the drop height across structures to 0.5 ft. This ensures long-term stability of the structure
while also providing appropriate scour in pool sections.
12.
j•
Appendix B
Please add a clearly visible CE boundary to the plans.
SK
Change made - A clearly visible CE boundary has been added to the plans.
12.
k
Appendix B
Is any of the unnamed tributary to Forney Creek being sought for
compensatory mitigation credit offset? If so, explain the
functional uplift and whether it is expected to remain a single
thread channel even with the dam elevation being maintained to
hold the upstream wetland intact. In order to receive any credit, it
would also need to meet performance standards through
monitoring.
SK
No, the unnamed tributary to Forney Creek is not being sought for compensatory mitigation credit offset. It is meant to
serve as a preferential flow path for floodwaters that overtop the spillway to prevent excessive erosion in this area.
13.
a.
Appendix G,
Section 6, pg. 8
More information is needed regarding the site protection
instrument such as who will hold the CE, an approval letter from
SK
Please see answers to long-term steward questions below.
6

Public Notice Comment Response Matrix
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Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
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them, a redlined version of our District CE template (any changes
of which must be reviewed by our District Office of Counsel), and
several long-term steward questions provided below must be
answered.
13.
b
Appendix G,
Section 6, pg. 8
Clarification of buffer widths is needed, including minimum,
maximum, and average. If 5% or greater of the buffer width from
top of bank is less than the 50 linear food minimum on either
side, then the nonstandard buffer width application may apply
and additional GIS figures and an excel table may be required. If
applicable, instructions can be found on the District RIBITS
website.
SK
A Conservation Easement Buffer display has been added to the plan set. The minimum offset width is 50.6', the maximum
offset width is 129.4', and the average offset width is 69.8'. Zero percent of the buffer is less than 50-feet from top of
bank. Please see Sheet EC-002 — Conservation Easement Layout for reference.
13.
c.
Appendix G,
Section 6.1.2, pg.
9
It is stated that, "There are no federally designated critical
habitats located within or near the proposed project area." What
was the radius of the plant survey to define "near"?
SK
USFWS designated Critical Habitats were evaluated at the county level. There are no Critical Habitats in Lincoln County NC
per the USFWS Information and Planning Consultation online system
(https://ipac.ecosphere.fws.gov/location/AGSONFXDCFFPBCP542QYKZ7NG4/resources).
13.
d.
Appendix G,
Section 7, pg. 10
This section states, "In lieu of credit purchases, it was determined
during onsite pre -application meetings (and subsequent email
correspondence) between the USACE, NCDEQ/NCDWR, Hedrick,
and CEC that the relocation and proposed restoration of Forney
Creek will serve to offset credit purchases as compensatory
mitigation for the proposed Permittee Responsible Mitigation
(PRM) project." Please provide any documentation supporting
this statement.
SK
Please see the email from Kevin Thomas dated 7/16/2020 sent to Brian Roden -Reynolds PWS and PM USACE.
Onsite pre -application meeting held on 07/15/2020. Concurrence was given that a PRM would be allowed as
compensatory mitigation with no other forms of compensatory mitigation required.
Please see response to comment 15.
13.
e.Section
Appendix G,
8.1.1, pg.
11
Based on the amount of cut associated with the proposed
mitigation, verify that soil fertility will be considered so vegetation
can meet appropriate vigor performance standards
SK
(1) Soil fertility & the physical component —
In an effort to minimize erosion potential and stabilize the site, Hedrick will implement terracing of
slopes in the areas designated as A & B (please see plan attachment). In those areas of terracing, the
terrace material will be sampled for soil fertility. If fertility samples are low or amendments are
needed, amendments will be added per the NC State University Soil Fertility Lab's recommendations or
the terraces will be over excavated and backfilled with onsite fertile topsoil. These terraces will be
stabilized at the end of every working day during the construction period. Fertility amendments will
only occur during years 1 and 2 of monitoring.
(2) Vegetation success —
Soils (including legacy soils) will be monitored long-term to ensure success and that no washout to
vegetation has occurred. Due to the fact that the project area is within an active mine site that is
constantly being stripped of topsoil, Hedrick will begin stockpiling topsoil outside of the flood zone for
use during the project's construction phase. This topsoil will also be tested for fertility through the NC
State University Soil Fertility Lab to monitor and promote vegetation success for restoration purposes.
Attached Sue Homewood's email accepting this response
7

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Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
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13.
f.
Appendix G,
Section 8.1.1, pg.
13
Will existing channel substrate be utilized within the new stream
channel and if so, will it be done in a way to facilitate survival of
any potential macroinvertebrates?
SK
Currently the stream is a 303d stream. Site surveys did not identify the presence of aquatic life due to the degraded
quality of the watershed. Habitat would be enhanced for macroinvertebrates under the proposed action. Any existing
channel substrate meeting particle size requirements for proposed design will be used.
13.
g.
Appendix G,
Section 10.1, pg.
15
Paragraph 1: include visual monitoring in the list of requirements
SK
Change made to text.
13.
h.
Appendix G,
Table 2, pg. 15
Include visual monitoring as detailed in the District 2016 guidance
for years 4 & 6
SK
Change made to text.
13.
i.
Appendix G,
Section 10.1, pg.
16
The District 2016 guidance stipulates a 90-day submittal of the as-
built report. Make sure the as -built report includes a redlined set
of plans showing any deviation from the approved design and
planting plan.
SK
A track change copy of the Alternatives Analysis Report (DRAFT FINAL) will be provided to the USACE. Upon USACE's
approval of the changes, a FINAL clean copy of the Alternatives Analysis will be provided for the administrative record.
13.
j'
Appendix G,
Section 10.1.1,
pg. 16
Are there any plans to address the presence or treatment of
invasive species throughout the monitoring? Include details on
what species are present and that they will be successfully
treated during monitoring in accordance with performance
standards. Who will perform vegetative planting, invasive
treatments, and monitoring?
SK
Invasive species encroachment will be monitored during the vegetative monitoring periods. The contractor will perform
vegetative planting as part of the restoration project, CEC will perform monitoring and any invasive species.
13.
k.
Appendix G,
Section 10.1.1,
pg. 16
What was determined to be the target community for this project
area? What onsite or nearby reference communities were utilized
to support this determination and assist with the selection of
appropriate species?
Please see Appendix G page 16: The detailed planting list has been developed based on the Schafale Classification of
Natural Communities of NC 4th approximation. CEC was directed to this community by Olivia Munzer, Western Piedmont
Habitat Conservation Coordinator, NC Wildlife Resource Commission.
13.
I.
Appendix G,
Section 10.1.1,
pg.16
Multiple, sometimes duplicate, planting lists were provided, and
none clarify what target community you are seeking to achieve.
Are species such as spicebush, sycamore, river birch, and tag
alder appropriate for use as live stakes?
Please see above comment that references page 16 in Appendix G: the detailed planting list has been developed based on
the Schafale Classification of Natural Communities 4 approximation. Spicebush, sycamore, river birch, and tag alder are
species commonly used as live stakes according to WQ0114.pdf (ncforestservice.gov) 4th edition Riparian and Wetland
Planting Guide for NC NC Forest Service & NC Dept of Agriculture & Consumer Services, and Kristen Kyler, Penn State Univ
Ag and Environment Center; What is Live Staking
13.Appendix
m
G,
Section 10.1.3,
pg. 18
Include the entrenchment ratio performance standard in
accordance with the District 2016 guidelines.
Wilmington 2016 Section IV.B.4 states "ER must be no less than 1.4 at any measured riffle cross-section". Change made to
text in Appendix G.
13.
n.
Appendix G,
Section 10.1.5,
pg. 19
Make sure you include the District 2016 guidance for visual
monitoring in each year of monitoring Years 4 & 6?
CEC will provide visual monitoring, per the 2016 Wilmington Monitoring guidelines and after every rainfall event equal to
or greater than a 10-year storm event, at previously surveyed longitudinal profiles, cross sections. Refer to Table 2 for the
proposed project -monitoring schedule.
13.
o'
Appendix G,
Section 10.1.6,
pg.19 20
Please clarify the statement regarding requirement of
NCSAM/NCWAM utilization twiceperyear. Is this meant for re
p
project data collection to guide project design/authorization or
post -construction? If post -construction, pending clarification, this
CEC will visually monitor the proposed project area twice a year and post 10 year storm events. CEC understands that this
site is extremely "flashy"/vulnerable to large storm events and flooding. As such, it will be critical to have boots/eyes on
the ground for the first 2-3 years to make sure issues are detected prior to becoming significant. Originally CEC was
requested by the USACE PM to perform NCSAM and NCWAM bi-annually post construction.
8

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criterion may not be needed if all District 2016
monitoring/performance standards are utilized
13.Appendix
p.
G,
Section 11, pg.
23
Please clarify between long term management, long term
stewardship and monitoring project components
Long-term management refers to any maintenance that may be required during the 7-year monitoring period.
Long-term stewardship refers to after the 7-year monitoring is complete and the Conservation Easement is held by CLC in
perpetuity
Monitoring project components will be carried out during the 7-year monitoring by CEC after restoration is complete.
13.Appendix
q'
G,
Section 11, pg.
23
It is stated "In the event that unforeseen problems occur during
long-term management, which may jeopardize the integrity of the
natural stream system, Hedrick Industries will notify USACE to
coordinate and appropriate management strategy to be
implemented. Hedrick has money set aside for long-term stream
maintenance related expenses." Is this statement meant for
financial assurances during monitoring or after project closeout
during the long-term stewardship by the CE holder? If during
stewardship, specific management actions must be clearly
defined, and money set aside to fund such actions. Depending on
what is proposed, this may not be necessary.
Please see Appendix G pg. 23: this statement is meant for financial assurances during monitoring. "Long-term stream
maintenance expenses" are meant to be used during the 7-year monitoring period. After the 7-year monitoring is
complete and all monitoring goals are reached, a non -wasting endowment shall be established for the purposes of the
long-term stewardship.
13.
r.
Appendix G,
Section 11, pg.
23
Financial assurance information is needed, even if proposing no
financial assurances. What form would it take, how much (provide
itemized mitigation project costs for construction, monitoring,
vegetation, invasives, contingencies, etc.)?
Hedrick Industries is proud to be a fourth -generation family -owned and operated North Carolina business since 1924.
Today, Hedrick Industries is the fifth -largest producer of crushed stone in the state of North Carolina and has worked its
way towards becoming one of the most respected and innovative aggregate producers in the industry. Hedrick Industries
is, therefore, financially secure and has a proven record of accomplishment with regards to its ability to complete all
required jurisdictional waters mitigation activities, including necessary post -mitigation maintenance and monitoring.
13.
s.
Appendix G,
Section 12, pg.
24
It is stated, "Upon written approval, Hedrick Industries will use
available funds that have been set aside for mitigation related
expenses to address corrective measures and provide
documentation to the agencies with corrective measures have
been addressed." Please clarify this sentence. Is this referring to
financial assurances or some other contingency funds?
Please see response to comment 13.r.
13.
t.
Appendix G,
Section 12, pg.
24
Although invasive treatments can be needed under adaptive
management as species outbreaks occur, they are also expected
as a normal part of the mitigation project management
throughout monitoring.
CEC concurs with this statement.
13.
u.
Appendix G.2,
Conservation
Easement
Drawing 1
As noted in other comments, the average, minimum, and
maximum CE width is needed, as well as total stream length
within CE compared to the impacts in order to determine
appropriate compensatory mitigation offset?
Please see responses to comments 12.c., 12.j., and 13.b. regarding Conservation Easement buffer extents and updates.
Total stream lengths and comparable impacts are included on Sheet EC-002 - Conservation Easement Layout, and the
Stream Impact Summary Table.
The minimum CE width is 50.6 feet, the average CE width is 69.8 feet, and the maximum CE width is 129.4 feet.
9

Public Notice Comment Response Matrix
Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
Location
Type of
Comment
Reviewer
#
Agency Comment
CEC Response
Document
Date
Section, Page
S, C, A
As shown on Sheet EC-002 and the Stream Impact Summary Table, the existing Forney Creek aquatic bed to be relocated
is 2,798 linear feet. The Proposed Priority 1 Aquatic Bed restoration within the Conservation Easement is 2,879 linear feet.
The Proposed Priority 2 restoration within the Conservation Easement is 115 linear feet. The total restoration (Priority 1
and Priority 2) within the Conservation Easement is 2,994 linear feet. This measurement excludes 45 linear feet of
proposed bridge and maintenance corridors that would be outside of the Conservation Easement.
Comparing the measurements of the existing Forney Creek and the Proposed Priority 1 restoration within the
Conservation Easement, linear feet of the proposed restoration matches linear feet of the existing mainstem 1:1 with an
additional 81 linear feet of proposed aquatic bed established.
Long Term
14.
Alternatives
Stewardship / CE
a.
Analysis
3/21
Holder
S
Are they willing and able to enforce the easement restrictions?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
Questions
Long Term
14.
Alternatives
Stewardship / CE
b.
Analysis
3/21
Holder
S
How is the organization formed (non-profit, govt. entity, etc?)
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
Questions
Long Term
14.
Alternatives
Stewardship / CE
c.
Analysis
3/21
Holder
S
Are they licensed to operate in North Carolina?
SK
Yes; Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
Questions
Long Term
14.
Alternatives
Stewardship / CE
d.
Analysis
3/21
Holder
S
Are they an accredited Land Trust?
SK
Yes; Sent to Sean Bloom (GIS Director and Biologist —Catawba Lands Conservancy), awaiting response
Questions
14.
Alternatives
Long Term
Stewardship / CE
The CLC was established in 1991. For detailed information, please see the CLC website available at
e.
Analysis
3/21
Holder
Questions
S
How long have they been around?
SK
https://catawbalands.org/. Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting
response
Long Term
14.
Alternatives
Stewardship / CE
For detailed information, please see the CLC website available at https://catawbalands.org/. Sent to Sean Bloom (GIS
f.
Analysis
3/21
Holder
S
How big is their staff?
SK
Director and Biologist — Catawba Lands Conservancy), awaiting response
Questions
Long Term
What are their connections to the proposed site? (e.g., are there
14.
Alternatives
Stewardship / CE
any board members or others that have an interest to the site?)
g.
Analysis
3/21
Holder
Questions
S
Are any employees of the company affiliated with mitigation
banks or their sponsors?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
Long Term
How do they monitor these sites (frequency, staffing, on -site or
14.
Alternatives
Stewardship / CE
remotely)? Do they monitor themselves or contract it out?
h.
Analysis
3/21
Holder
Questions
S
Provide a site inspection Standard Operating Procedure (SOP),
report template and/or example if available.
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Long Term
i.
Analysis
3/21
Stewardship / CE
S
Do they contact neighboring landowners?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
10

Public Notice Comment Response Matrix
Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
Location
Type of
Comment
Reviewer
#
Agency Comment
CEC Response
Document
Date
Section, Page
S, C, A
Holder
Questions
Long Term
14.
Alternatives
Stewardship / CE
j
Analysis
3/21
Holder
S
How do they handle violations?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
Questions
Long Term
Are there separate funds set aside for legal defense if necessary?
14.
Alternatives
Stewardship / CE
Have they bought funds or additional coverage to aid in legal
k.
Analysis
3/21
Holder
Questions
S
defense for this site and if so, would it cover all legal fees in the
case of an encroachment?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Long Term
Stewardship / CE
Do they hold the easement themselves, or are they just the land
I.
Analysis
3/21
Holder
Questions
S
steward? If so, approximately how many easements do they hold
and the approximate total acreage in North Carolina?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Long Term
Stewardship / CE
Do they currently hold mitigation bank easements in other
m.
Analysis
3/21
Holder
Questions
S
districts? If so, please provide the name of the district and a
contact person.
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Long Term
Stewardship / CE
If applicable, are they able to provide for management practices
n.
Analysis
3/21
Holder
Questions
S
that are unique to the site that require special consideration (e.g.,
burning, invasive control, beaver management, etc.)?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
o.
Analysis
3/21
Endowments
S
How is their financing structured?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
p.
Analysis
3/21
Endowments
S
How big an endowment is required?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
How do they determine the endowment size? (Typically, the long-
q.
Analysis
3/21
Endowments
S
term steward/CE holder will itemize via an endowment calculator
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
— the TLC calculator is also on RIBITS as a reference.)
14.
Alternatives
Regarding
Do they manage the endowments, or are they funded through a
r.
Analysis
3/21
Endowments
S
financial mechanism for these sites?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
How will the endowment be funded (up front in a lump sum or
s.
Analysis
3/21
Endowments
S
though the monitoring period)?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
If they do manage the endowment (type of account, provide a
t.
Analysis
3/21
Endowments
S
cap rate, is the cap rate already adjusted for inflation, etc.)?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
Alternatives
Regarding
Is the endowment put into a combined fund or kept separate for
u.
Analysis
3/21
Endowments
S
each site?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
11

Public Notice Comment Response Matrix
Hedrick Gravel & Sand Co -Lake Norman Quarry Mine Expansion - Alternatives Analysis
Hedrick Industries, Forney Creek Relocation, Lincoln County, NC SAW-2020-00436
#
Location
Type of
Comment
Agency Comment
Reviewer
CEC Response
Document
Date
Section, Page
S, C, A
14.
v.
Alternatives
Analysis
3/21
Regarding
Endowments
S
Are the funds used for anything other than stewardship of the
site?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
w.
Alternatives
Analysis
3/21
Regarding
Endowments
S
Is the easement holder and/or land manager able to access the
entire endowment or is there a financial instrument that provides
annual funding? (This gets to the question of whether an
endowment can be used up, leaving no funding if long-term
steward must be replaced or whether it is non -wasting.)
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
14.
x.
Alternatives
Analysis
3/21
Regarding
Endowments
S
What is the name and location of the financial institution that
holds their accounts?
SK
Sent to Sean Bloom (GIS Director and Biologist — Catawba Lands Conservancy), awaiting response
15.
Alternatives
Analysis
3/21
The size and scope of the proposed on -site stream mitigation is
very similar to many mitigation banks and sites across North
Carolina. PRM needs to meet or exceed the standards that those
sites, which have been providing function for many years before
providing credits for impacts to aquatic resources. EPA
recommends that the applicant consult with the Corps PM and
provide a full mitigation plan to the North Carolina Interagency
Review Team for the realignment of Forney Creek and associated
riparian buffer to receive full credit for the proposed action.
TB
Please see answer to comment 13.d.
CEC understands that we are stepping outside of the 2008 Mitigation Sequence as we were given concurrence to do so
during the first on -site Pre -Application Meeting on July 15, 2020. Scott Jones and Bryan Roden -Reynolds of the USACE
were present (boots on ground or by phone) at this meeting.
In an email sent July 16, 2020, Kevin Thomas of CEC provided a summary of the talking points of that on -site meeting to
Mr. Roden -Reynolds. Please see reference text below:
"As a result of the current state of Forney Creek, there was concurrence that if ecological uplift was provided by the Client
through Natural Stream Channel Design...and no net loss of the aquatic resource (linear feet), compensatory mitigation
would not be required". Mr. Roden-Reynold's provided a response email that did not contend the above statement.
A second Pre -Application meeting was held on October 21, 2020. In attendance was Sue Homewood (NC DENR), Alan
Johnson (NC DENR), Erin Davis (NC DENR and an IRT member), Doug Perez (NC DENR), Olivia Munzer (NC Wildlife
Resource Commission), Scott Jones (USACE), Krystynka Stygar (USACE), Jason Connor (Hedrick), Robert Stewart (CEC), and
Kevin Thomas (CEC). Duringthis meetingno opposition wasgiven to a PRM as thepreferred compensatory mitigation
( ) pp p Y g
method. If requested, CEC can provide the meeting notes as reference.
During an additional onsite meeting with Steve Kichefski (USACE), Jason Connor (Hedrick), Kevin Thomas (CEC), and Jena
Turner (CEC) on January 27, 2022, it was stated that PRM was the preferred compensatory mitigation method due to the
following factors:
• The project is a single and complete, linear/non-fragmented project.
• The project is in-kind/like for like.
• There will be no net loss of aquatic resource.
• The project is within the proximity (i.e. same floodplain) as existing degraded aquatic resource. The aquatic
resource is an EPA listed 303d stream and scored low on the NCSAM throughout the entire action area.
• The feature will be placed inside a CE held by a third party, in -perpetuity, that is not surrounded or contingent to
other activities other than the mine.
• CEC will be providing natural stream channel design as opposed to the engineered design option that was also
initially proposed.
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12

Comment Types: C=Critical; S= Substantive; A=Administrative (See definitions below)
DEFINITIONS
Critical — Comments identifying deficiencies that, if not addressed, would cause the document to be insufficient.
Substantive — Comments identifying an item in the document that requires more information; and or/appears to be, or is potentially, incorrect, misleading, or confusing.
Administrative — Comments identifying minor inconsistencies between different sections or errors in typography and grammar.
Reviewers: Please provide your name, title, commercial phone number, email address, and date of comments
• SK — Steve Kichefski, Project Manager, Asheville Regulatory Field Office, United States Army Corps of Engineers, 828-271-7980 ext. 4234, [e-mail]
• TB —Todd Bowers, US EPA Region 4 Oceans Wetlands and Streams Protection Branch, Environmental Protection Agency, 404-562-9225, [e-mail]