20221179 Ver 1_More Info Requested_20221122

Baker, Caroline D
From: Homewood, Sue
Sent: Tuesday, November 22, 2022 1:49 PM
To: Michael Brame; Ken Chavis; Catherine Carston
Cc: Bailey, David E CIV USARMY CESAW (USA)
Subject: RE: [External] Request for Additional Information: SAW-2020-01862 (Brittway II / 4150
R1 Pleasant Garden Road / Greensboro / Guilford County)
up
Please copy me on your responses to the items requested by the USACE. DWR will consider the application on hold until
receipt of a complete response. Thank you.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, November 22, 2022 12:45 PM
To: Michael Brame <[e-mail]>
Cc: Catherine Carston <[e-mail]>; Ken Chavis <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: [External] Request for Additional Information: SAW-2020-01862 (Brittway II / 4150 R1 Pleasant Garden Road /
Greensboro / Guilford County)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
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Thank you for your additional information, received 10/28/2022, for the above referenced project. I have reviewed the
information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 39
(https://saw-reg.usace.army.mil/NWP2021/NWP39.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Permit or consider your application withdrawn and close the file:

1) Thank you for your responses to items 1) and 4) of our request for additional information. These items are
resolved accordingly.
2) Information provided in your response to item 3) does not adequately address our concerns. Based on
information from the landowner's website (https://www.carroIIindev.com/inventory/brittway-ii-industrial-site/),
as well as the attached brochure, there are future plans for development within this area that the Corps would
consider to be part of the same single and complete project (see NWP General Condition 15) . Unless the
currently proposed project can be justified as having independent utility from the overall Brittway II Industrial
Site, information is needed to justify that all reasonably foreseeable impacts associated with full buildout of the
Brittway II Industrial Site would not cumulatively exceed NWP thresholds. Otherwise the project would require
evaluation as an Individual (i.e. Standard) Permit;
3) In the western half of the property, the wetland delineation shown on the provided "Overall Site Plan" does not
appear to match the delineation shown on the figures provided with the PJD dated 11/23/2021. Please correct
any discrepancies, update the plan sheet(s) accordingly, and/or provide explanations of the differences where
they occur. Importantly:
a. Based on the PJD, the proposed grading appears to impact the narrow portion of Wetland E extending
to the north of Stream A2.
b. Wetlands A-D, G, a large portion of Wetland E, and Streams V, W, and Z are not shown on the "Overall
Site Plan." This is especially problematic given proposed future development noted in item 2) above.
4) Based on proposed grading and re-routing of drainage into stormwater ponds, the project appears to eliminate
the majority of the drainage areas/hydrology source for Wetlands L and M:
a. Please provide justification that hydrologic input will be maintained to these wetlands. Common designs
include routing approximately equivalent surface water/runoff area to these locations, altering locations
of stormwaters outlets, usage of French drains where appropriate, etc;
b. If maintenance of wetland hydrology is unable to be justified, the Corps would consider these areas as
reasonably foreseeable indirect impacts (see NWP General Conditions "District Engineers Decision")
resulting from a loss of hydrology. In such cases compensatory mitigation may be required for indirect
impacts resulting in a loss of hydrology and therefore aquatic function; compensatory mitigation is
typically required at a 1:1 ratio for such indirect impacts (although may be situationally up to 2:1),
depending largely on aquatic function (e.g. NCWAM);
c. A monitoring plan (typically including groundwater monitoring wells and visual observations for a period
of 5 years post -construction) to document maintenance of wetland hydrology may also be proposed for
Corps evaluation and approval; such monitoring plans would also include a contingency plan, typically
including compensatory mitigation, in the event that monitoring does not indicate maintenance of
wetland hydrology.
5) Until item 2) above is resolved, item 5) from our request for additional information pertaining to scope for
compliance with Section 7 of the Endangered Species Act remains unresolved.
6) Item 6) from our request for additional information is ongoing.
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]
Email: David. [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: Michael Brame <[e-mail]>
Sent: Friday, October 28, 2022 2:43 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
<[e-mail]>
Cc: Catherine Carston <[e-mail]>; Ken Chavis <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Request for Additional Information: SAW-2020-01862 (Brittway II /
4150 R1 Pleasant Garden Road / Greensboro / Guilford County)
David and Sue,
Please see our responses in RED below. Thank -you.
Sincerely,
Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenvire.com
[e-mail]
From: Catherine Carston <[e-mail]>
Sent: Wednesday, September 21, 2022 2:20 PM
To: Michael Brame <[e-mail]>
Subject: FW: Request for Additional Information: SAW-2020-01862 (Brittway II / 4150 R1 Pleasant Garden Road /
Greensboro / Guilford County)
Sincerely,
Catherine Carston
336.712.7381 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
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PILOT,
PILOT E N V I F 0 N M E N T. L I N C
From: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Sent: Wednesday, September 21, 2022 12:34 PM
To: Catherine Carston <[e-mail]>
Cc: Homewood, Sue <[e-mail]>

Subject: Request for Additional Information: SAW-2020-01862 (Brittway II / 4150 R1 Pleasant Garden Road / Greensboro
/ Guilford County)
0
Thank you for your PCN, dated 8/29/2022, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permit (NWP) 39 (https://saw-
reg.usace.army.mil/NWP2021/NWP39.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:
1) Based on a file review, there are a older Corps actions in the vicinity of this project area; one of these was for the
property immediately to the west of this site: Action ID: SAW-2002-20166. The Corps reviewed a delineation for
this site and issued a JD (signed survey) on 12/3/2002. Although our files do not show that any permit was
verified/issued for the development that has taken place on this site, it is clear based on aerial photos that the
area was developed between 2003 and 2006 (East Elsmley Drive, Bantiff Way, Scounton Way, Fernhurst Way,
Chesham Dr, and Elton Way and associated businesses); these activities resulted in the filling of one wetland and
one stream. The wetland area in question was 1,382 s.f. and the stream reach was approximately 220 Lf. (660
s.f. if you estimate a 3-foot wide channel). Although the Corps is unlikely to enforce the apparent unauthorized
activity in this case, we would consider the total 2,042 s.f. of impacts to waters of the US as cumulative with any
future proposed impacts on the Brittway II site as these developments appear to be part of the same single and
complete project, both require access via East Elmsley Drive, and have/had the same general ownership. The
applicant acknowledges that the project will be considered single and complete with the previous project and
that impacts will be considered cumulative in regards to mitigation and permitting thresholds.
2) Please provide a plan view of the full development infrastructure (buildings, roads, utilities, stormwater, etc.)
overlaid on the verified stream and wetland delineation approved by the Corps (PJD issued 11/23/2021). This
plan is necessary to accurately evaluate avoidance and minimization measures (per NWP General Condition
23(A) and (B)) and potential indirect impacts (see NWP General Conditions "District Engineers Decision") for the
cumulative project; A revised plan view has been completed and is attached.
3) The purpose and need for the proposed project is construct an industrial/commercial facility. In order to
consider your proposal single and complete for the purposes of permitting, the project plans must show all of
the infrastructure required to facilitate construction and operation of the proposed project purpose. Although
the Elmsley Drive Extension plans show the detailed proposed stream/wetland crossing for site access, this plan
shows a hammerhead approximately 400 feet east of the crossing with no attachment/tie-in to any
industrial/commercial facility. Meanwhile, the Proposed Site Plan shows a building with future expansions that
may impact Wetland H, and the Brittway Conceptual Layout shows and apparent full development build -out
with proposed buildings, related infrastructure, and outparcels that would impact substantial portions of
Wetland D, G, K, N, O, and P, and Streams D2, H2, 12, J2, and Z. The attached plan has been revised to address
these comncerns.
The Corps will consider all proposed/foreseeable impacts for this development as cumulative when considering
Nationwide Permit (NWP) thresholds. Based on your proposed impacts as well as the conceptual plans for
apparent future phases, the cumulative project would not fit within acreage thresholds for NWP 39. You may
apply for the entirety of this cumulative development via the Individual Permit process. Or, as an alternative,
you may further avoid or minimize impacts proposed and/or amend the conceptual design to show that full
build out of this development would fit within the NWP impact thresholds. The initial plan that was submitted
was conceptual. The plan has been revised and is included as an attachment.
4) The length of rip rap proposed within (-49 Lf.) and along (extends >20 feet on each side of the channel) Stream
A2 appears to remove aquatic function from this reach of the resource. Given that proposed stream loss
exceeds the compensatory mitigation threshold for streams, this reduction in aquatic function appears to
warrant additional compensatory mitigation; a 1:1 credit to impact ratio appears appropriate unless otherwise
justified based on evaluation of aquatic function. Additional mitigation for the proposed impacts is
necessary. Pilot has been informed that alternate designs have been considered and could not be designed to

avoid the impacts due to engineering constraints. Pilot has included a response letter from the NCDEQ-DWR
indicating that the additional credits are available.
5) Please note that for any increases in project scope per item 3) above, our scope for compliance with Section 7 of
the Endangered Species Act would likely increase as well. As such, please ensure that documentation is included
to enable the Corps to ensure compliance with NWP General Condition 18 upon any changes in project
plans. There is no increase in project scope as the impacts shown on the earlier plan have been removed from
the attached revised site plan.
6) It appears that an Individual 401 Water Quality Certification (WQC) is required from the North Carolina Division
of Water Resources (NCDWR) for this project; please note that the Corps cannot verify the use of any NWP
without a valid 401 WQC.
For NCDWR: After review of the submitted PCN for the above referenced project, and NWP 39 Water Quality
General Certification No. 4276, dated 1211812020 (https.-Z saw-
reg.usace.army.mil/NWP2021/NWP39 StateWQC.pdf), it appears an Individual 401 Water Quality Certification
(WQC) is required from the NCDWR for the proposed activities. The PCN received by our office appears to provide
the 9 required elements for an individual WQC and constitutes the Corps initial receipt of the WQC application
(note that this may not hold if project plans change based on the times above). The reasonable period of time
(RPOT) for you to act on this WQC request will begin is 120 calendar days from the date of the complete WQC
request. Unless NCDWR is granted a time review extension, the date upon which a waiver of the WQC will occur
if you do not act on the certification is 1212712022. Understood.
7) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project. Understood.
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]
Email: David. [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: RaleighNCREG <[e-mail]>
Sent: Monday, August 29, 2022 1:45 PM
To: Catherine Carston <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Subject: SAW-2020-01862 (Brittway II / 4150 R1 Pleasant Garden Road / Greensboro / Guilford County)
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: Catherine Carston <[e-mail]>
Sent: Monday, August 29, 2022 12:19 PM
To: RaleighNCREG <[e-mail]>
Cc: Michael Brame <[e-mail]>
Subject: [URL Verdict: Neutral][Non-DoD Source] Pilot Project 7589 - Brittway Elmsley Drive Extension PCN Submittal
Please find the attached PCN for the Brittway Elmsley Drive Extension (Corps Action ID: SAW-2020-01864). Please let me
know if you have any questions or need anything further to complete your review. Thank you and have a great day.
Sincerely,
Catherine Carston
336.712.7381 (c)
336.310.4527 (o)��
Po Box 128 PILOT-
Kernersville, NC 27285 °"°T ENV1R0NMENT°`''"`
www.pilotenviro.com
ccarston(@oilotenviro.com