20071568 Ver 1_Other Agency Comments_20071010 (2)

U.. i F
DEPARTMENT OF THE ARMY O 'l - 1 S to
WILMINGTON DISTRICT, CORPS OF ENGINEERS
PO BOX 1890
WILMINGTON NC 28402-1890
October 2, 2007
Regulatory Division
Action ID No. SAW-2007-03168-065
Mr. Jesse (Lee) Bunch, III
6405 Purple Martin Court
Wilmington, North Carolina 28411
Dear Mr. Bunch:
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OCT 1 G 2007
pENl7 -WATER QUALITY
WE1tAND9 A~VD 5TQ!tMa"!A~R 9RANGH
On September 17, 2007, this Office received a request from your Authorized Agent, Keller
Environmental, for verification to utilize Nationwide Permit 18 for the discharge of fill material
into 0.10 acres of jurisdictional wetlands adjacent to Myrtle Grove Sound, to facilitate the
development of an additional single-family residence located at 110 Virginia Avenue, in
Carolina Beach, New Hanover County, North Carolina.
Upon review of your application, this Office has determined that your application is
incomplete and we cannot process your request until we receive the following information:
Your request must include a delineation of jurisdictional wetlands, to include
all of the required information per the Corps' 1987 Wetland Delineation
Manual.
2. In accordance with General Condition 20 of the Nationwide Permits (Federal
Register Vol. 72, No. 47, March 12, 2007), it is incumbent upon the applicant
to avoid or minimize adverse impacts to Waters of the United States to the
maximum extent practicable at the project location; moreover, your application
does not adequately justify the purpose and need for the project. If the overall
goal of the project is an economic return on an investment, please provide an
economic analysis that takes into account the original investment cost for the
entire parcel and the existing structure with and without potential upgrades.
Your analysis should include all alternative uses for this property, to include
Conservation Easements for tax credit purposes or selling the land in fee simple
to a local land trust or similar entity for preservation purposes.
If property development can be justified, we believe that there may be less
environmentally damaging practicable alternatives to the proposal submitted
with your PCN application. These alternatives include, but are not limited to,
reducing the footprint of the structure(s), reducing the width of the driveway

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access, constructing all, or a portion of the structure(s) on pilings, and/or
requesting a variance from the Town of Carolina Beach's setback requirements.
Please investigate these options and include your findings as part of an
alternatives analysis.
4. Your application did not include any documentation that you have approached
the Town of Carolina Beach with any alternative site designs although your
application states that the Town has denied your request. Please include any
and all correspondence with the Town that demonstrates that your project is
compliant with local requirements and adheres to their Land Use Plan.
5. Finally, please be aware that our records indicate that a Federal Species of
Concern, coastal beaksedge (Rhynchospora pleiantha) may be present at the
project location. The State of North Carolina has also listed this species as
Threatened. We recommend that you contact Ms. Maria Dunn of the North
Carolina Wildlife Resources Commission at mara.dunn(cuncwldlife.ory to
discuss any protection that they may require for this species.
Please submit the above-mentioned information within 30 days of receipt of this letter or we
will consider your application withdrawn and close the file.
Please be aware that if, upon review of any additional information, we determine that the
activity would result in more than minimal individual or cumulative adverse environmental
effects or maybe contrary to the public interest, we will notify you that your project does not
qualify for authorization under the NWP and instruct you on the procedures for authorization
under an Individual Permit.
If you have any questions regarding these matters, please contact me at [phone].
Sincerely,
Jennifer S. Frye, Project Manager
Wilmington Regulatory Field Office
Copy Furnished:
Mr. Jay Keller
Keller Environmental
7921 Haymarket Lane
Raleigh, North Carolina 27615
Mr. Chad Coburn
Division of Water Quality
N.C. Department of Environment
and Natural Resources
127 Cardinal Drive Extension
Wilmington, North Carolina 28405

t
Mr. Ian McMillan
Division of Water Quality
C. Department of Environment
and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Mr. Tim Owens, Town Manager
Town of Carolina Beach
1121 North Lake Park Boulevard
Carolina Beach, North Carolina 28428
Mr. Steven Harrell, Director
Planning and Development
Town of Carolina Beach
1121 North Lake Park Boulevard
Carolina Beach, North Carolina 28428
Mayor Bill Clark
Town of Carolina Beach
1121 North Lake Park Boulevard
Carolina Beach, North Carolina 28428
Ms. Maria Dunn
Wildlife Resources Commission
N.C. Department of Environment
and Natural Resources
943 Washington Square Mall
Washington, North Carolina 27889
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