20180957 Ver 3_00_DTGW_Modification_CoverLetter_20220901

September 1, 2022

Mr. David Bailey
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Ms. Sue Homewood
NC Division of Water Resources
Winston Salem Regional Office
450 West Hanes Mill Road
Winston-Salem, NC 27105
RE: Greensboro Downtown Greenway Phase 4 and College Branch Stream Enhancement
(NCDWR #20180957; SAW-2017-01430)
Section 404/401 and Buffer Authorization Reauthorization Request
Greensboro, Guilford County, North Carolina

Dear Mr. Bailey and Ms. Homewood,

On behalf of our client, the City of Greensboro, Kimley-Horn is requesting a reauthorization for the
previously approved Section 404 Nationwide Permit (SAW-2017-01430), Section 401 Water Quality
Certification, and Jordan Lake Watershed Riparian Buffer Authorization (NCDWR #20180957) for the
above referenced project in Guilford County. The project was originally permitted in July 2018 under a
combination of the 2017-2022 Nationwide Permits #3, #14, and #27, and corresponding Water Quality
Certifications 4132, 4134, and 4135. A Section 404 Authorization was issued by Mr. David Bailey of the
USACE on August 6, 2018. A Section 401 Authorization and Jordan Lake Buffer Authorization was issued
by Ms. Sue Homewood of NCDWR on August 27, 2018. The project then when through a permit
modification in December 2021 under the same NWPs and WQCs. A Section 404 Modification was issued
by Mr. James Lastinger of the USACE on January 12, 2022. A Section 401 and Jordan Lake Buffer
Authorization Modification was issued by Ms. Sue Homewood of NCDWR on February 14, 2022.
This reauthorization request proposes no new impacts or design changes from the 2021 submittal, only
recalculations of impacts to comply with the condition of the new 2021/2022 Nationwide Permit Program.
For the purposes of the proposed Nationwide Permit #14 impacts, Site 1, Site 2-3, Site 4-5, and Sites 6-8
are considered separate and distant crossings.
Unavoidable permanent impacts to streams and the associated Jordan Lake Watershed Buffer Zones will
result from the proposed project. Permanent stream impacts will occur at Impact Sites 1, 2, 4, 5, 6, and 8
as a result of proposed culvert installations associated with the greenway construction. Permanent no-net
loss (P-NNL) stream impacts will occur at Impact Sites 1-8 as a result of the proposed stream repair,
restoration, and enhancement activities as well as the placement of keyed-in rip rap for outlet protection.
These activities will include the grading of damaged and unstable stream banks to match natural channel
contours and the placement of wood and boulder toe protection along the stream banks to provide
stabilization and improve aquatic species habitat. The installation of constructed riffles and boulder rock
and roll riffles within the stream is also proposed to establish grade control, facilitate sediment transport,
and enhance in stream structure and habitat. Temporary impacts to streams S2 and North Buffalo Creek
kimley-horn.com 421 Fayetteville Street, Suite 600, Raleigh, NC 27601 919 677 2000

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at impact sites 3,4,5, and 8 will result from the construction access necessary to facilitate the stream
enhancements and install the proposed pedestrian bridges in connection with the greenway. All temporarily
impacted streams will be returned to pre-existing conditions upon completion of construction. Native
vegetation will be planted within the project corridor and invasive species removal will take place.

Additionally, portions of the Jordan Lake Watershed buffer zones along streams S2, S3, and North Buffalo
Creek will be permanently impacted at Buffer Impact Sites 1-8 resulting from the construction of the
greenway path and shoulder, stream enhancement bank stabilization, and the construction of a parallel
sanitary sewer easement. Temporary buffer impacts will result from the construction access necessary to
facilitate the stream enhancements and greenway construction. All temporarily impacted riparian buffers
will be returned to pre-existing conditions upon completion of construction.

To offset the unavoidable permanent Buffer Zone 1 impacts resulting from the proposed parallel sanitary
sewer easement, compensatory mitigation has been paid through Resource Environmental Solutions
(RES), LLC (Cloud & Banner Nutrient Offset & Buffer Mitigation Bank). The mitigation transfer certificate
from the mitigation bank has been included as part of this application.

To assist in your review of this modification request, the following information has been included:
ePCN Application Form
Signed Agent Authorization Form
Figures
Previously Submitted Section 404/401 Approvals
Buffer Permit Drawings
Stream Permit Drawings
Plan Sheets
Mitigation Transfer Certificate

If there is any additional information you need to assist in the processing of this permit modification request,
please do not hesitate to contact me at [phone] or [e-mail].

Sincerely,

Kimley-Horn and Associates, Inc.

Emma Radford, WPIT
Environmental Scientist

kimley-horn.com 421 Fayetteville Street, Suite 600, Raleigh, NC 27601 919 677 2000