20230425 Ver 1_More Info Received_20230622

From: David Brame
To: Stock, N Carmela CIV USARMY CESAS (USA); bford.lomonacoinvestments(alamail.com
Cc: Homer, Seren M; Hooper, Christopher D CIV USARMY CESAW (USA)
Subject: [External] RE: Request for Additional Information RE: Trollingwood Townes (SAW-2022-00799)
Date: Thursday, June 22, 2023 1:36:55 PM
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Carmela,
Good afternoon. I think there may be some confusion with the stream dimensions. The ordinary
high water mark of the channel is at about 4 inches above the stream bed and is approximately 2.5-3
feet wide. The bank -full channel is about 2.5-3 feet above the stream bed and ranges from 5 to 6
feet in width. As a result, the pipe will not alter the cross -sectional area of the natural channel.
Additionally, the proposed pipe will not alter base flow and can still accommodate bank -full events.
A second off -set pipe is not needed to accommodate normal or high flow events and still meets the
necessary engineering requirements. A smaller pipe in this channel, even with a second off -set pipe,
would alter the cross -sectional area of the natural stream and create higher velocities and cause
greater downstream degradation.
Sincerely,
David Brame, PWS
336.708.4617 (c)
336.310.4527 (o)
www.oilotenviro.com
dbrame(@pilotenviro.com
From: Stock, N Carmela CIV USARMY CESAS (USA) <[e-mail]>
Sent: Thursday, June 22, 2023 7:36 AM
To: David Brame <[e-mail]>; [e-mail]
Cc: [e-mail]; Hopper, Christopher D CIV USARMY CESAW (USA)
<[e-mail]>
Subject: RE: Request for Additional Information RE: Trollingwood Townes (SAW-2022-00799)
Good morning, David,
Thanks for your response. I understand, but the layout of the proposed design is not
consistent with NWP Regional Condition #9. Regional Condition #9b states that "bank -full
flows (or less) shall be accommodated through maintenance of the existing bank -full
channel cross sectional area. Additional culverts or culvert barrels at such crossings shall
be allowed only to receive bank -full flows."
In the past, applicants with similar projects have proposed a stream culvert with a diameter
similar to the natural width of the stream and an additional culvert upland of the stream to
accommodate bank -full and high flows, while minimizing the washing out of streambed
downstream during high -flow events. Have additional culverts been considered, and if so,
why were multiple culverts not implemented in the proposed project design?

Please note that given the current plans, future stream degradation is likely. Special
conditions on any verification we issue may include monitoring, a corrective action plan,
and/or mitigation for functional stream loss.
Thanks,
N. Carmela Stock
Biologist
Regulatory Project Manager
U.S. Army Corps of Engineers
SAD Technical Regional Execution Center
100 W. Oglethorpe Ave.
Savannah, GA 31401
Email: Nichelle.C.Stock&usace.army.mil
Telephone: [phone]
To assist us in improving our service to you, please complete the survey found at
https:HreguIatory.ops.usace.army.miI/customer-service-survey /
From: David Brame <dbrame(@12ilotenviro.com>
Sent: Wednesday, June 21, 2023 12:26
To: Stock, N Carmela CIV USARMY CESAS (USA) <Nichelle.C.Stock(@usace.arm)l.mil>;
bford.lomonacoinvestments(@gmail.com
Cc: seren.homer(@deq.nc.gov
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Request for Additional Information RE:
Trollingwood Townes (SAW-2022-00799)
Good afternoon. The culvert is still a 66" pipe. However, it is a round culvert that will maintain flow
during normal and low flow periods. Since the pipe is round, it is smaller at the bottom near the
normal pool level, or approximately 33 inches wide at the normal pool level which is consistent with
the stream width. Hope that makes sense. Please feel free to call if needed.
Thanks,
David Brame, PWS
336.708.4617 (c)
336.310.4527 (o)
www.pilotenviro.com
dbrame(@pilotenviro.com
From: Stock, N Carmela CIV USARMY CESAS (USA) <Nichelle.C.Stock(@usace.army.mil>
Sent: Wednesday, June 21, 2023 11:23 AM
To: David Brame <dbrame(.pilotenviro.com>; bford.lomonacoinvestments(@gmail.com
Cc: seren.homer(@deq.nc.gov
Subject: RE: Request for Additional Information RE: Trollingwood Townes (SAW-2022-00799)
Hi David,

Thanks for the clarifications. Could you update the drawing provided with your last email to
reflect the narrower width of the RCP (33"), as you mentioned below, instead of the 66"
RCP indicated in drawings?
I have copied Seren on this email as well.
Thanks!
N. Carmela Stock
Biologist
Regulatory Project Manager
U.S. Army Corps of Engineers
SAD Technical Regional Execution Center
100 W. Oglethorpe Ave.
Savannah, GA 31401
Email: Nichelle.C.Stock&usace.army.mil
Telephone: [phone]
To assist us in improving our service to you, please complete the survey found at
https://regulato[y.ol2s.usace.army.mil/customer-service-survey(
From: David Brame <dbrame(@pilotenviro.com>
Sent: Friday, June 9, 2023 15:47
To: Stock, N Carmela CIV USARMY CESAS (USA) <Nichelle.C.Stock(@usace.army.mil>;
bford.lomonacoinvestments(@gmail.com
Subject: [URL Verdict: Neutral][Non-DoD Source] RE: Request for Additional Information RE:
Trollingwood Townes (SAW-2022-00799)
Carmela,
Please see the below responses to your comments in red and the attached revised drawing. Feel
free to give me a call if you have any questions and I will be glad to discuss. I hope you have a nice
weekend.
Sincerely,
David Brame, PWS
336.708.4617 (c)
336.310.4527 (o)
www.pilotenviro.com
dbrame(@pilotenviro.com
From: Stock, N Carmela CIV USARMY CESAS (USA) <Nichelle.C.Stock(@usace.army.mil>
Sent: Monday, May 22, 2023 10:32 AM
To: David Brame <dbrame(@pilotenviro.com>; bford.lomonacoinvestments(@gmail.com
Subject: Request for Additional Information RE: Trollingwood Townes (SAW-2022-00799)
David,
Brian,

This is in reference to your permit application for the proposed Trollingwood Townes
Project (SAW-2022-00799). Upon review, your permit application is considered incomplete.
In order for us to determine if the permit application is Federally complete and to continue
evaluating the proposed project, please provide the following information:
1. The proposed culvert is documented in the PCN to be larger (66 inches) than the
average stream width (30 inches). Are there boxes/pipes, baffles, benches, and or
sills included the culvert design to maintain the natural width of the stream channel,
which would allow for aquatic life movement during low flows, as required by
Regional Condition #9c of Nationwide Permit #29? Since the culvert exceeds 2.5%
slope, the culvert has been reconfigured so that it is no longer proposed to be buried.
Additionally, the culvert is round. At normal pool level, approximately 4", the width of
the culvert is approximately 33 inches across, is consistent with the natural stream
channel width and will support aquatic live movement during low flows. No other
culvert modifications are proposed. A new culvert cross section is attached.
2. The project plans indicated the permanent placement of riprap at the end of the
culvert; this would be considered an additional impact. What is the proposed length
and width of the riprap apron? The area of riprap impact was included in the overall
impact amount because it overlaps a small area of realigned stream that was
considered in our calculations as a permanent loss that counts towards the
compensatory mitigation threshold. Should it not have been an overlapping impact
that was accounted for in the reported impact amount, we would have separated it
out as a separate impact.
In addition to the requested information above, please see the following regarding your
application:
1. An Individual Water Quality Certification is required since the proposed project would
result in over 150 feet of stream impacts. Have you initiated a pre -filing meeting
request with the North Carolina Division of Water Resources (NCDWR)? Yes, pre -
filing was initiated with the NCDWR on September 27, 2022.
2. Can you please confirm that the proposed work is not part of a phased project? The
proposed project is not part of a phased project. No additional phases or impacts are
planned or anticipated.
3. In the Culvert 1 Cross Section (Sheet C2) it looks like the culvert would be buried.
Please note that culvert burial is NOT required when the slope of the culvert exceeds
2.50% (Regional Condition #9a of Nationwide Permit #29). The culvert design has
been revised so that it is no longer buried (attached).
Please reference our file number in any future correspondence pertaining to this project. If
you do not submit the required information to determine the project Federally complete
within 30 days from the date of this e-mail, we will assume that you no longer wish to
pursue this permit and your application will be withdrawn.
Thanks!
N. Carmela Stock

Biologist
Regulatory Project Manager
U.S. Army Corps of Engineers
SAD Technical Regional Execution Center
100 W. Oglethorpe Ave.
Savannah, GA 31401
Email: Nichelle.C.Stockausace.army.mil
Telephone: [phone]
To assist us in improving our service to you, please complete the survey found at
https://regulatory.ol2s.usace.army.mil/customer-service-survey