20001116 Ver 1_Other Agency Comments_20000921

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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REGION 4
Sam Nunn Atlanta Federal Center
61 Forsyth Street, SAS'.
Atlanta, Georgia 30303 - 8960
SEP 1 ,4 2000
Colonel James W. DeLony
District Engineer
ATTN: Mr. Todd Tugwell
Raleigh Re`*ulatorv Field Office
Wilmington District, Corps of Engineers
6508 Falls of the NeuSe Road, Suite 120
Raleigh, North Carolina 27615
SUBJ: North Carolina Golf Enterprises
Action 1D No. 199920576
Dear Colonel DeLony:

SEP 2 1 20M
V,-161.ArjDSz C,
This is in response to the above referenced public notice, dated August 22, 2000,
concerning the proposed modification of the permit for Sandler at Old Stage, to relocate 130
linear feet of an intermittent tributary to Swift Creek, place culvert and fill within 315 linear feet
of an intermittent tributary to Swift Creek, authorize the completed placement of fill into 0.04
acre of wetlands, and modify the existing mitigation plan associated with the construction of the
golf course for Eagle Ridge Community. According to the public notice, the project site is in
Garner, Wake County, North Carolina. Mitigation is proposed, in the form of preservation of
535 linear feet of intermittent streams, preservation of 0.61 acres of riparian area, and creation of
0.08 acre of wet detention basin, and creation of an additional 0.04 acre of wetland.
EPA does not believe that the proposed mitigation will adequately compensate for the
proposed losses. From the information provided, it appears that the wet detention basin is a
treatment system constructed primarily for the purpose of treatment to meet the requirements of
the Clean Water Act. Therefore, EPA does not consider it to be waters of the U.S. Areas which
are not considered to be waters of the U.S. should not be utilized for mitigation. Use of such
areas for mitigation purposes, in EPA's opinion, represents a net loss.
Until an appropriate mitigation plan is submitted and approved, the modification should
not be authorized. Appropriate mitigation would include:
• wetlands restoration at a 2:1 ratio;
• wetlands enhancement at a 4:1 ratio;
• wetlands creation at a 6:1 ratio; and/or
• wetlands preservation at a 10:1 ratio.

All mitigation must be conducted in waters of the U.S., or result in the creation of waters of the
U.S. Thank you for the opportunity to comment on this project. If you have any questions or
comments, please contact Kathy Matthews, of my staff, at [phone]).
Sincerel ,
r
William L. Cox, Chief
Wetlands Section
cc: USFWS, Raleigh
NCDOT, Raleigh
NCDWQ, Raleigh
NCWRC, Raleigh