20230124 Ver 1_More Info Received_20230414 (2)

From: dlutheranCalsegi.us
To: "Beecher. Gary H CIV USARMY CESAW (USA)"
Cc: Snider, Holley; Montalvo, Sheri A
Subject: [External] RE: USACE PCN review comments for the PC3 Old Fayetteville Road Tract in Brunswick County, NC
(SAW-2020-01690)
Date: Friday, April 14, 2023 12:45:28 PM
Attachments: image001.pnng
Kendall Cove PCN Attachments Package Revised 4-13-23 Part l.pdf
PC3 DWR Stream Determination Form.Ddf
SNOPES.Ddf
Credit Reservation Kyndall Cove.pdf
Kyndall Cove Proiect Submittal Interim Form 4-14-23.pdf
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Good morning, Gary and Holley.
Please accept this response to both of your RFAls, starting with the Corps' first:
USACE Comments:
-RCW Slopes:
This project will take place in a designated RCW Slopes area. Please complete the attached RCW Slopes agreement
form.
-Flood Maw
There is a New Hanover County Flood map in the package? Please provide a Brunswick County Flood Map that
corresponds to this project location.
My apologies. See attached Kyndall Cove PCN Attachments Package Revised 4-13-23 Part 1, for the corrected table.
The flood map can be found in Part 2 of the package, which was too large to send via email. Therefore, I have
uploaded it electronically, by utilizing the DWR's Project Submittal Interim Form website. Confirmation of the
submittal has been attached.
-404 Wetland Impacts:
Total wetland impacts are listed as 1.44-acres (in the PCN), are the project impacts for wetlands based on the former
NWPR or on formerffs that used the NWPR? These calls are no longer valid, the "NEW" Rule changes the way the
Corps reviews and determines jurisdiction on wetlands. These wetlands may have to be re -verified in the field.
The Corps' jurisdictional determinations on the non -jurisdictional wetlands was conducted utilizing Rapanos
guidelines not the NWPR, which is when the JD was issued. SEGi maintains the features are still non -jurisdictional
under the NEW rules, as they are not within a flood zone and have no significant nexus to a TNW.
-The submitted plan doesn't separate "non jurisdictional wetlands" from Jurisdictional Wetlands. The impacts need
to be better explained.
The plan has been updated to better identify the non -jurisdictional wetland impacts from the jurisdictional impacts.
The tables, in the top left corner of Sheet CWI-1.2, summarize the impacts for each jurisdiction. Additionally, the
impact detail sheets have also been updated to better identify the impacts by jurisdiction. Please see Kyndall Cove
PCN Attachments Package Revised 4-13-23 Part 2, which has bee submitted via the DWR's Project Submittal Interim
Form website. Confirmation of the submittal has been attached.
-Mitigation Requirement:
There's no Mitigation availability letter in the package from LCFUMB stating that they have the required .50 credits.
The credit reservation letter has been attached.

DWR Comments:
-DWR echoes the concerns raised by the USACE regarding the jurisdictional status of the wetlands onsite and the
ability to further avoid and minimize impacts to wetlands onsite.
The applicant has avoided and minimized impacts to the greatest extend practicable. Minimization efforts were
achieved by bridging the stream, thereby avoiding impacting more than 0.05-acre of stream bed, as well as limiting
the number of units, which avoided impacting more than 2.0 acres of wetlands, and by incorporating retaining walls
into the plan, which further minimized wetland impacts by approximately 0.10-acre.
-Additionally the application, maps and impact table do not clearly discern impacts to "non jurisdictional wetlands"
and/or jurisdictional wetlands.
Please see response to USACE's comment above.
-Please provide the stream determination forms for any intermittent or perennial stream on site.
The stream determination form has been attached.
-DWR is placing the project on -hold until additional information is proved that addressees avoidance and
minimization of impacts to wetlands and surface waters.
SEGi is requesting the project be removed from its hold status.
It is my hope that the information found within, attached and submitted electronically, will satisfy the agencies'
request for additional information. However, should either of you have further concerns, please do not hesitate to
call.
If I don't speak with you, I hope you both have a nice weekend.
Dana
Southern Environmental Goup, Inc.
5515 South College }load, Suite If
Wilmington, NC 2841 2
Phone: 910.452.271 1
Mo6ile:910.228.18+1 (Preferred)
www.segws
From: Beecher, Gary H CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, March 2, 2023 1:37 PM
To: Dana A. Lutheran <[e-mail]>
Cc: Snider, Holley <[e-mail]>
Subject: USACE PCN review comments for the PC3 Old Fayetteville Road Tract in Brunswick County,
NC (SAW-2020-01690)
Dana,
Please see my comments below for the PCN Application review for the PC3 Old Fayetteville Road
Tracts in Brunswick County, NC
USACE Project ID:
SAW-2020-01690

KIN Review Comments:
-RCW Slopes:
This project will take place in a designated RCW Slopes area. Please complete the attached RCW
Slopes agreement form.
-Flood Maps:
There is a New Hanover County Flood map in the package? Please provide a Brunswick County Flood
Map that corresponds to this project location.
-404 Wetland Impacts:
Total wetland impacts are listed as 1.44-acres (in the PCN), are the project impacts for wetlands
based on the former NWPR? Or on former JD's that used the NWPR? These calls are no longer valid,
the "NEW" Rule changes the way the Corps reviews and determines jurisdiction on wetlands. These
wetlands may have to be re -verified in the field.
The submitted plan doesn't separate "non -jurisdictional wetlands" from Jurisdictional Wetlands?
The impacts need to be better explained.
-Mitigation Requirement:
There's no Mitigation availability letter in the package from LCFUMB stating that they have the
required .50 credits.
Please contact me if you have any questions about this project or about the USACE Regulatory
Program.
Respectfully,
Gary
U5 Army Corp;
of Eriglrmeers
Wilmington pist+kt
Gary Beecher
USACE Wilmington Field Office
Regulatory Project Manager
Office [phone]
Cell [phone]
gary.h.beecher(@usace.army.mil
Vi rus-free.www. avast. com