20141142 Ver 1_Corps of Engineer Correspondence_20141126

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action Id. SAW- 2014 -01591 County: Guilford U.S.G.S. Quad: NC- CLIMAX
INCOMPLETE APPLICATION
Applicant: Redwolf Development Company, LLC Agent: ECS Carolinas
attn: David B. Michaels attn: Eric McClanahan
Address: 621 Eugene Court, Suite 103 Address: 502 Wando Park Blvd., Suite 109
Greensboro, NC 27406 Mt. Pleasant, SC 29484
Location/Description of Proposed Activity: The proiect is located on the north side of Liberty Road,
annroximately 0.2 mile from its intersection with Field Hornev Road in Greensboro. Guilford Countv. North
Carolina. 35.97793 N, 79.71394 W. The applicant has submitted a Preconstruction Notification (PCN)
application to construct access and infrastructure for a residential subdivision to be called The Farm at
Forest Oaks, including permanent impacts to 0.206 acre of riparian, non - riverine wetlands.
Type of Permit Applied For (check one): IP ❑ NWP ® GP ❑
Applicable law: Section 404 of the Clean Water Act®; Section 10, Rivers and Harbor Act ❑
YOUR APPLICATION IS INCOMPLETE AND CANNOT BE PROCESSED UNTIL THE FOLLOWING
INFORMATION IS RECEIVED (CHECK ALL THAT APPLY):
❑ Your application form has not been completed and/or signed (see remarks)
❑ Under the conditions of the Nationwide Permit, mitigation is required for your project. The mitigation
proposal submitted with your application is insufficient. (see remarks.)
® Your application did not include a statement explaining how avoidance and minimization for losses of
waters of the U.S. were achieved on the project site. (see remarks)
® Your submitted project plans or maps were insufficient, too large, or not legible (see remarks).
❑ Your application did not include a delineation of affected special aquatic sites, including wetlands, vegetated
shallows, and riffle and pool complexes as required.
❑ You must submit a copy of your application to the NC Wildlife Resources Commission (WRC) since your
proposed work is in a designated trout water county (see remarks section below for the address of your WRC
representative)
® Other (see remarks below).
"Please reference your PCN dated 10/15/2014, received 10/27/2014.
REMARKS:
1. Your cover letter noted "In order for the area to be used as a borrow site... ", which is inconsistent with the
remainder of the PCN and attached documents. Is this a typo, or will the proposed access road be used for
anything other than a residential subdivision?
2. For further avoidance and minimization information, please explain the practicability of accessing the
property off of Field -Homey Road instead of Liberty Road. It appears, based on Figure 5 of the submitted
PCN package, that using this corridor for the access road could completely avoid or significantly minimize
the wetland impact footprint.
3. Please send an updated overall subdivision plat /parcel map showing proposed lot lines as well as the
verified boundaries of waters of the US. This map will enable evaluation of secondary and cumulative
impacts with respect to the requested authorization.
4. Thank you for the detailed wetland impact drawings. Plan Sheet # WL1 -2 shows a small area of wetlands
(0.012 acre) to the east of the proposed crossing that will be disconnected from the remaining wetland. In
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our experience such small areas of wetlands lose the majority of their function due to disconnection from
hydrology sources and/or habitat fragmentation. As such, either include this area of wetlands in the
proposed wetland impact total or justify how this area of wetlands will retain its functions and values.
Please amend the PCN, plans, and compensatory mitigation proposal as appropriate.
5. Furthermore, based on Plan Sheet # WL1 -2 it appears that the remaining 0.183 acre of wetlands on the west
side of the proposed crossing may be indirectly impacted due to separation from its surface /subsurface
hydrology source, thus potentially losing jurisdictional status or being functionally reduced. Please
show /explain how the surface /subsurface hydrology will be retained or include this area of wetlands in the
proposed wetland impact total. Please amend the PCN, plans, and compensatory mitigation proposal as
appropriate.
6. Based on your NCEEP acceptance letter, the type of requested credits (non- riparian) is not appropriate for
the wetland type. As the wetland proposed for impact is a headwater forest wetland based on NCWAM,
the appropriate compensatory mitigation type is Riparian, non - riverine (Riparian for NCEEP purposes).
Please update the NCEEP acceptance letter to reflect this change.
Please submit the above information within 30 days of receipt of this Notification (via e -mail is
fine) or we will consider your application withdrawn and close the file. Please call or email
( Davin .E.Bailey2Ca�usace.army.mil) me if you have any questions.
Date: November 26, 2014 DIgR°Itysi"w
BAILEY. DAVID. a^I EY°— E1379303J36
E.1379283736
Corps Regulatory Official: David E. Bailey Telephone No: 919 -554 -4884, ext. 30
Corps Regulatory Field Office Address: USACE Raleigh Regulatory Field Office, 3331 Heritage Trade Drive,
Suite 105, Wake Forest, NC 27587
Copy furnished:
Sue Homewood, NCDENR -DWR, 450 W. Hanes Mill Road, Suite 300, Winston Salem, NC 27105
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