20220856 Ver 1_More Info Received_20220727

Strickland, Bev
From: Velasquez, Johanna <[e-mail]>
Sent: Wednesday, July 27, 2022 3:39 PM
To: Homewood, Sue; Dailey, Samantha J CIV USARMY CESAW (USA)
Cc: Mularski, Eric; Ahrens, Brooke T.
Subject: RE: [External] RE: SAW-2022-01358 Silas 100 kv Line - Request for Additional
Information (view html)
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Good afternoon Sue,
Thank you for your review and comments. Please see below my answers in blue. Let me know if there is anything
additional you would need.
Best regards,
Johanna Velasquez
D 980.337.5012 M 305.496.2462
hdrinc.com/follow-us
From: Homewood, Sue <[e-mail]>
Sent: Tuesday, July 26, 2022 8:15 AM
To: Velasquez, Johanna <[e-mail]>; Dailey, Samantha J CIV USARMY CESAW (USA)
<[e-mail]>
Cc: Mularski, Eric <[e-mail]>; Ahrens, Brooke T. <[e-mail]>
Subject: RE: [External] RE: SAW-2022-01358 Silas 100 kv Line - Request for Additional Information (view html)
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Hello Johanna,
Now that I have the complete set of plans I have the following questions:
1. I see where the permanent crossings have been justified as needed due to limitations on access points, however
in order to document avoidance and minimization, please provide a justification as to why all of the crossings,
regardless of location specific topography, are set at 60 feet lengths. This is longer than typically seen for
permanent utility access corridors.
The original proposed length of the culvert was based on a preliminary project design that overestimated the
length that is needed for the crossings. After discussing the project with our engineers the culvert lengths will be
shorten to 16 to 24 feet in length, and the size of the culverts will be between 18 and 24 inches in diameter.
Based on these changes the new proposed impacts will be as shown below in yellow:
i

Impact
ID
Stream
Name
Impact
Type
Stream
Width (LF)
Previous
Impact
Length
(LF)
Previous
Impact
Amount
(Sq ft)
Previous
Impact
Amount
(Ac)
Revised
Impact
Length (LF)
Revised
Impact
Amount
(Sq ft)
Revi
Imp
Amo
(A
S1
Stream 2
Permanent
3
60
180
0.004
24
72
0.0
S3
Stream 3
Permanent
9
60
540
0.012
24
216
0.0
S5
Stream 11
Permanent
4
60
240
0.006
24
96
0.0
S7
Stream 12
Permanent
3
60
180
0.004
24
72
0.0
S9
Stream 22
Permanent
2
60
120
0.003
24
48
0.0
S11
Stream 23
Permanent
2
60
120
0.003
24
48
0.0
S13
Stream 25
Permanent
2
60
120
0.003
24
48
0.0
Totals
1500
0.034
168
600
0.0
2. For each permanent crossing please provide a site specific plan and profile. I see there's a detail for temporary
crossings in the plans but for permanent crossings we need site specific design drawings so that we can carefully
review them. Please see below detail for permanent culvert installations.
STREAM �_-
CHANNEL
STONE APPROACH
STONE APPROACH
WATTLES TO ABUT CROSSING
PERSPECTIVE VIEW
SURFACE FLOW STONE APPROACH
DIVERSION TO TRAP
FILTRATION GEOTEXTILE
ROCK OVER EARTH FILL
STREAM BED
WATTLES TO ABUT CROSSING
USE 1 FOOT OVERLAP ON
ADJOINING WATTLES
EXTEND STONE UPWARD AND
REVECETATE AS NEEDED TO
PROTECT CUT SLOPES
SURFACE FLOW
F DIVERSION
INSTALL TRAP ON EITHER SIDE OF
CREEK. TRAP SIZE WILL VARY
ACCORDING TO LENGTH CC ACCESS
ROAD DRAINING TO THIS POINT EQUAL
TO 50 CU. FT. PER 10OFT OF ROAD
STONE APPROACH
FILTRATION OEOTEXTAE
ORIGINAL STREAMBANK
SURFACE FLOW
DIVERSION TO TRAP
LONGITUDINAL SECTION 18"-24' FIDPE PIPE. SIZE TO BE FIELD
DETERMINED 13? CONTRACTOR
MAINTENANCE
- REMOVE ANC
ACCU MULATI(
REACHES ON
OF THE PERII
ONE-HALF C
- REPLACE OR
AS NEEDED
SLOWLY DEW,
DEVICE BETW
- MONITOR THI
STAPLES TO
WATTLES REP;
ANCHORED A
HIGH WATER
- MONITOR DA1
STONE APPRI
PROPER FUN
- CLEAN ANY
TRACKED ON
IMMEDIATELY.
Please let me know if you would like me to submit the above changes and information on a separate submittal
uploaded to DWR here: https://edocs.deq.nc.gov/Forms/Supplemental-Information-Form
Thanks!
2

Johanna
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: Velasquez, Johanna <[e-mail]>
Sent: Thursday, July 21, 2022 4:51 PM
To: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Mularski, Eric <[e-mail]>; Ahrens, Brooke T.
<[e-mail]>
Subject: [External] RE: SAW-2022-01358 Silas 100 kv Line - Request for Additional Information (view html)
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Good afternoon Ms. Dailey,
Thank you for your response and the all the information provided. As per your comments we have reviewed the current
Endangered Species list associated with the Silas 100kV project area (see attached updated IPaC and NCNHP reports)
and understand there is potential suitable habitat within the project area for Michaux's Sumac, Schweinitz's sunflower,
and a candidate species (Monarch butterfly).
During our field survey evaluation conducted in May 2020 (during the recommended optimal survey window, May —
October), HDR biologist identified potential habitat for Michaux's Sumac, although no individual plants were found. At
the time of the investigation, Schweinitz's sunflower was not listed as a federally protected species in either Davie or
Forsyth counties, therefore we do not have survey data available for that species. Nonetheless, if one is required we will
inform our client.
In reference to the proposed permanent impacts for the project (420 linear feet, approx. 0.034 acres), they are
associated with culvert installations for crossings at 7 different streams (Streams 2, 3, 11, 12, 22, 23, and 25), which are
all single and complete. Given that none of the individual crossings exceed 0.02 acres, could you clarify why the impacts
would be cumulative? My understanding was that the threshold would be cumulative if the permanent impacts were
occurring on the same stream/ feature.
Looking forward to understanding the difference and correcting any misconception.
Best regards,
Johanna Velasquez,
Senior Environmental Scientist
HDR
3

440 S. Church Street, Suite 1000
Charlotte, NC 28202-2075
T 704.338.6700 M 305.496.2462
Johanna.Velasquezhdrinc.com
hdrinc.com/follow-us
From: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, July 8, 2022 1:24 PM
To: Velasquez, Johanna <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: SAW-2022-01358 Silas 100 kv Line - Request for Additional Information (view html)
CAUTION: [EXTERNAL] This email originated from outside of the organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Good afternoon Johanna,
I've taken a look at your submitted Pre -Construction Notification (PCN) and have a couple of comments. To briefly
summarize, written approval will be required from our office PRIOR to impacting waters of the United States. This is due
to the potentially suitable habitat for threatened/endangered species within your proposed impact areas. The IPAC list
provided in your PCN (dated April 7, 2020) does not incorporate all of the current, listed species. Further, it appears you
have suitable habitat within your project area and will need to survey for Michaux's sumac and Schweinitz's sunflower.
Considering a PCN is required in conjunction with your proposed project, and taking into account the cumulative,
permanent stream impacts for the access road crossings, compensatory mitigation will be required for the 420 linear
feet of stream impact. It must also be noted that an individual 401 WQC is required for your proposed activity. As such,
we are required to obtain written 401 approval from the DWR and EPA prior to issuance of our NWP.
A detailed explanation is outlined below:
1) NWP 57, General Condition 18. Endangered Species (page 6 of enclosed NWP 57): The IPAC report included and
referenced in your PCN is dated April 7, 2020. This list is outdated and does not include Schweinitz's sunflower.
I've included an updated IPAC list for your reference. I would also like to point out that suitable habitat for
Michaux's sumac and Schweinitiz's sunflower is known to occur within maintained right-of-ways (ROW). As
outlined in your PCN submittal, the proposed aerial transmission line is located within an existing, maintained
ROW where there is potentially suitable habitat for both endangered species. Under General Condition 18, if the
proposed activity "may affect" a listed species or critical habitat, a PCN is required and that work shall not begin
until the ESA requirements have been satisfied. Taking into account the potentially suitable habitat within your
proposed project area, I cannot make a no effect determination for Michaux's sumac or Schweinitz's sunflower. I
have had several conversations with Mr. Byron Hamstead with the Asheville USFWS over the past several
months and he has stated the following:
"If suitable habitat is present within the action area (50CFR 402.02) for Schweintiz's sunflower or Michaux's
sumac, we always recommend that project proponents conduct targeted botanical surveys within the optimal
survey window to inform a prudent effect determination from the action agency. Negative survey results
collected during the appropriate timeframe typically warrant our concurrence with a MANLAA determination
from the action agency. Alternatively and in lieu of surveys, project proponents may choose to assume presence
of this species where its suitable habitats occur within the action area and identify impact avoidance and
minimization measures that would reduce the probability for incidental take or inadvertent loss to a level that is
insignificant or discountable - which would also support our concurrence with MANLAA."
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Based on the potential for suitable habitat for Michaux's sumac and Schweinitz's sunflower within the proposed
impact areas, the Corps does believe that targeted botanical survey's will need to be completed in order to
determine the presence/absence of these species. The survey windows for Michaux's sumac and Schweintiz's
sunflower are May — October and late Aug -October, respectively (https://www.fws.gov/story/2022-03/north-
carolinas-federally-threatened-endangered-and-risk-plant-species).
2) NWP 57, Regional Conditions, 7. Mitigation for Loss of Stream Bed (page 33 of NWP 57): Considering a PCN is
required in conjunction with General Condition 18, and in accordance with our regional conditions, for any NWP
that results in a loss of more than 0.02 acre of stream bed, the permittee shall provide a mitigation proposal to
compensate for more than minimal individual and cumulative adverse impacts to the aquatic environment.
Based on your submitted PCN, there are 7 proposed road crossings that would result in the cumulative
(permanent) loss of 420 linear feet or 0.034 acre of stream channel. These impacts are evaluated on a
cumulative basis for the purposes of mitigation and exceed the 0.02 acre of allowable stream impact. Therefore,
the applicant will be required to compensate for these stream impacts at a 2:1 mitigation to impact ratio, unless
the areas are of low quality, and then a lower ratio can be applied. The North Carolina Stream Assessment
Forms would need to be filled out in order to demonstrate the low quality rating (if applicable).
3) ORM Upload Sheet Consolidated — Please fill out the enclosed ORM Upload Sheet (aquatic resources tab) to
reflect the aquatic resources in Appendix C. of your JD submittal. I do appreciate that your PCN correlates the
impacts to the appropriate JD resources; that is very helpful.
Please know that I am happy to hop on a call to discuss matters further, but as it stands, written approval is required by
our office prior to impacting waters of the US, surveys will likely be required by the USFWS, and compensatory
mitigation will be required to offset the loss of aquatic resources. I look forward to your response.
Best Regards,
Sam
Samantha Dailey
U.S. Army Corps of Engineers
Wilmington District, Regulatory Division, Raleigh Field Office
Email: [e-mail]
Phone: [phone]
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