20020672 Ver 3_Attachment 38 - 6-22-10 Wrenn e-mail to Shumate re not agreeing to permit application_20141124

https://mail.nc.gov/owa/?ae=Item&a=Open&t=IPM.Note&id=RgA...H55xhyk6IGAGT595HFAABZIbO%2boESRTIinpRz6alp7AAFTu9WpAAAJ
From: Wrenn, Brian
Sent: Tuesday, June 22, 2010 2:20 PM
To: Shumate, Christy
Cc: Harris, Jennifer; [e-mail]; Lespinasse, Polly; Karoly, Cyndi; Matthews, Matt
Subject: NCTA - Monroe Connector/Bypass (R-3329/R-2559) "corridor" permit application
Christy,
DWQ does not feel that a “corridor” 401 application is appropriate. Although we issue 401s for similar
phased projects, these projects always have at least one section with final design numbers. Our reasons
for not accepting a corridor 401 application are two-fold:
1)This necessitates an additional review period. These projects are large and complex and we feel it is
unnecessary to review an application until final design numbers are provided, especially when no
authorization to construct will be granted in the 401. Furthermore, it is unclear what NCTA will gain by
applying for a “corridor” 401.
2)We will require a mitigation plan to be part of the application. With the large amount of impacts
involved in this project, it is assumed that you will be using EEP for at least a portion of the project. It is
unclear whether a formal acceptance letter will be provided as part of the plan (it will be required by
DWQ). Any mitigation estimates will likely be overinflated based on the method of determining the
preliminary impacts. This will lead to EEP potentially acquiring more mitigation credits than they need.
DOT, DENR, and the Corps have worked hard to reduce and avoid the surplus asset situation experienced
a couple of years ago. We see the corridor 401 as going down the path to surplus assets again.
The Corps has indicated that they will accept the application for a “corridor” permit. Although they
determine the type of permit required and the limits of the project, DWQ has discretion in what is
required for a complete 401 application. Until final design numbers are provided along with a
comprehensive mitigation plan, DWQ will not accept an application from NCTA for a corridor 401. If you
have any questions on this or would like to discuss further, please let me know.
Thanks,
Brian
Brian Wrenn
Transportation Permitting Unit, NCDWQ
2321 Crabtree Bvd., Ste 250
Raleigh, NC 27604
919-733-5715 (phone)
919-733-6893 (fax)
PLEASE NOTE THAT MY EMAIL ADDRESS HAS CHANGED
[e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
https://mail.nc.gov/owa/?ae=Item&a=Open&t=IP...595HFAABZIbO%2boESRTIinpRz6alp7AAFTu9WpAAAJ (1 of 2) [1/18/2011 3:16:26 PM]
Attachment 38
https://mail.nc.gov/owa/?ae=Item&a=Open&t=IPM.Note&id=RgA...H55xhyk6IGAGT595HFAABZIbO%2boESRTIinpRz6alp7AAFTu9WpAAAJ

https://mail.nc.gov/owa/?ae=Item&a=Open&t=IP...595HFAABZIbO%2boESRTIinpRz6alp7AAFTu9WpAAAJ (2 of 2) [1/18/2011 3:16:26 PM]