_External_ FW_ Request for Additional Information_ SAW-2019-00578 (NCDOT _ I-5898 _ improve US 220 at NC 135 Interchange _ Bridge 74 _ Rockingham County _ transportation)

Carpenter,Kristi
From:Bode, Ray <[e-mail]>
Sent:Sunday, August 7, 2022 10:51 AM
To:Conchilla, Ryan; [e-mail]
Cc:Parker, Jerry A; Barbour, Charles; Sekula, Tina; Hart, Teresa
Subject:\[External\] FW: Request for Additional Information: SAW-2019-00578 (NCDOT / I-5898
/ improve US 220 at NC 135 Interchange / Bridge 74 / Rockingham County /
transportation)
Attachments:18-12-0002_Historic Arch_SurveyReq.pdf; 18-12-0002_NoHistoricProperties.pdf;
Bridge #780074 I-5898 Rockingham County tribal coordination.pdf; PA
18-12-0002 No Archaeological Survey Required I-5898 redesign US 311 NC 135 at US
220 Mayodan Rockingham.pdf; NCSAM SC, SD.pdf; I-5898
_Wetland_and_Surface_Water_Impacts_Permit_Drawings REV 8-7-2022.pdf
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Hi Dave and Ryan
Please see the requested information below in red. Please let us know if any further details are needed.
Thanks

JMT
Ray Bode, PWS
Direct: 984.269.4923
Mobile: [phone]

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Thank You.
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, June 24, 2022 11:07 AM
To: [e-mail]; Bode, Ray <[e-mail]>
Cc: Conchilla, Ryan <[e-mail]>; Della Moore <[e-mail]>
Subject: \[EXTERNAL\] Request for Additional Information: SAW-2019-00578 (NCDOT / I-5898 / improve US 220 at NC 135
Interchange / Bridge 74 / Rockingham County / transportation)

All,

Thank you for your PCN, dated 1/11/2022 (received 6/9/2022), for the above referenced project. I have reviewed the
information and need clarification before proceeding with verifying the use of Regional General Permit (RGP) 50
(https://saw-reg.usace.army.mil/RGP/RGP50.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consider your application withdrawn and close the file:

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1) The project plans do not show enough detail to fully evaluate the proposed impacts or facilitate compliance
inspections upon permit issuance. Please provide zoomed-in views of all impact areas at a scale sufficient to
show both permanent and temporary impacts;
a. Please see attached revised permit plan sheets.
2) The nature/necessity of proposed impacts S5 and S6 (925 lf and 41 lf of impact, respectively) is not clear from
the PCN materials or plans. Will these areas be piped during portions of construction? If not, how will the work
be done in the dry? Also, given the scale of proposed impact for S5 especially, please provide additional detail
on how the area will be returned to pre-existing grade/contour and stabilized post-construction. Existing vs.
proposed cross-sections or other detail views/descriptions would be helpful;
a. Project plans have been revised so that the full length of Stream SD at impact Site S5 is not within the
work area. There will be 66 of temporary impact where the slope of the road prism is such that workers
will be within the jurisdictional limits of the channel to install/un-install the silt fence. This work will all
be done by hand and we do not anticipate a high degree of impact. Plan sheets and impact quantities
have been revised accordingly. See Sheets 4 and 5. A note is on the plan sheets stating that temporary
impacts shown to the JS are due to hand installation of silt fence. Proposed activities will involve foot
traffic only and no machinery shall be allowed to enter the jurisdictional stream limits. Changes to
existing channel geometry and/or vegetation shall be restored by hand to the original geometry. Riprap
shall be installed on the slope by machine from the roadway side of the silt fence. There should be no
permanent impacts from this activity.
b. Project plans have been revised so that Stream SC at impact Site S6 is not within the work zone and no
impacts are proposed at this location. Plan sheets and impact quantities have been revised accordingly.
3) Given the small size of Wetland WA, and the proximity of impacts W1 (permanent) and W2 (temporary) to each
other, and the reasonably foreseeable likelihood that this wetland area would not retain significant wetland
function following the activities proposed, please note that the Corps will consider the full acreage of Wetland
WA (0.009 acre per the PJD, <0.02 acre per the PCN) as a permanent loss;
a. Plan sheets and impact quantities have been revised accordingly.
4) Proposed mitigation ratios for permanent stream impacts are not clear based on the PCN. Unless otherwise
justified, the corps would typically require compensatory mitigation at a 2:1 mitigation to impact ratio (i.e. 468
warm water stream credits required. However, the Corps acknowledges that the 16 lf of impacts proposed at
impact Site S2 (Stream SC Reach 3) and 211 lf of impacts proposed at impact Site S3 (Stream SD Reach 2), occur
within what appear to be somewhat degraded streams. Further, the 7 lf of impacts proposed at impact Site S4
(Stream SD Reach 1) appears to involve rip rap only on the banks (per Permit Drawing Sheets 4 and 5); such
impacts would typically not require compensatory mitigation. Please clarify your compensatory mitigation plan:
if mitigation ratios less than 2:1 are proposed for impact Sites S2 and/or S3, please provide justification for each
stream reach based on aquatic function (i.e. NCSAM forms).
a. The 16 lf of impacts proposed at impact Site S2 (Stream SC Reach 3) and 211 lf of impacts proposed at
impact Site S3 (Stream SD Reach 2), occur within degraded streams (see NCSAM forms attached). Per
the phone conversation with USACE on 7/5/2022, those impacts will be mitigated at a 1:1. Further, the 7
lf of impacts proposed at impact Site S4 (Stream SD Reach 1) involve rip rap only on the banks (per
Permit Drawing Sheets 4 and 5); and will not require compensatory mitigation. This brings the total
stream mitigation need to 227 linear feet. NCDMS has previously accepted the project request for 234
linear feet of stream mitigation credits.
5) Section G.5 of the PCN references “field habitat assessments and species surveys” pertaining to endangered
species concerns per Section 7 of the Endangered Species Act; however, this documentation is not provided in
the PCN. Please provide this information to enable the Corps to either make a No Effect determination or
facilitate coordination with the USFWS for listed species in the Action Area (Roanoke logperch \[Percina rex\]).
a. An NRTR was prepared and finalized for this project. A determination of "No Effect" was given for the
Roanoke logperch. The NRTR is available on the NCDOT Project Sharepoint access at:
https://connect.ncdot.gov/site/Preconstruction/division/div07/I-
5898/ATLAS%20Deliverables/Forms/By%20Topic.aspx
6) Section G.7 of the PCN references “Coordination with SHPO” pertaining to Historic or Prehistoric Cultural
Resources concerns per Section 106 of the National Historic Preservation Act; however, this documentation is
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not provided in the PCN. Please provide this information to enable the Corps to either make a No Potential to
Effect determination or facilitate coordination with the SHPO.
a. See attached correspondence from NCDOT.
7) Please provide any information documenting tribal coordination completed for this project.
a. See attached correspondence from NCDOT.

Please let me know if you have any questions.

Sincerely,

Dave Bailey

---
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Office: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]

We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.

From: Schaffer, Josephine L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, June 9, 2022 1:33 PM
To: [e-mail]
Cc: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Matthews, Monte K CIV USARMY
CESAW (USA) <[e-mail]>
Subject: SAW-2019-00578 (NCDOT / I-5898 / improve US 220 at NC 135 Interchange / Bridge 74 / Rockingham County /
transportation)

Good afternoon,

We have received your Pre-Construction Notification (PCN) NWP request for the above project and forwarded it to Dave
Bailey for further processing.

Thank you,
Josephine Schaffer

From: Smith, Ronnie D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, June 9, 2022 8:59 AM
To: Jones, Kasey L CIV USARMY CESAW (USA) <[e-mail]>; Schaffer, Josephine L CIV USARMY
CESAW (USA) <[e-mail]>
Subject: FW: I-5898

Looks like this one was never received. Below is a link to the PCN materials.
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Ronnie Smith
Project Manager
Wilmington District, U.S. Army Corps of Engineers
Phone: [phone]

We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at:
https://regulatory.ops.usace.army.mil/customer-service-survey/

From: Strickland, Bev <[e-mail]>
Sent: Thursday, June 9, 2022 8:35 AM
To: Smith, Ronnie D CIV USARMY CESAW (USA) <[e-mail]>
Cc: SAW-PCN-RG <[e-mail]>
Subject: \[Non-DoD Source\] I-5898

Mr. Ronnie,

I just got a notice that said your group did not receive a application that was submitted and I am not sure who
it should go to. I put the link to the documents below.

https://edocs.deq.nc.gov/Laserfiche/index.aspx?db=WaterResources#id=2363147;view=browse

It appears to be correct. I am not sure what happened but we have been having issues with the server forms
is on.

Beverly Strickland (she/her)
Laserfiche Administrator
Division of Water Resources
Department of Environmental Quality
919-707-3876 Office

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