HomeMy WebLinkAboutRE [External] RE Springdale Driving Range Extension Update (2)1
Winston, Joey
From:Preston Gregg <PRengineering@outlook.com>
Sent:Monday, July 3, 2023 12:00 AM
To:Winston, Joey
Cc:Davidson, Landon; Davis, Brooke A CIV USARMY CESAW (USA); Jason Miller
Subject:RE: [External] RE: Springdale Driving Range Extension Update
Attachments:SPRINGDALE - PCN STREAM IMPACT TABLE 7-2-23.pdf
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Hi Joey,
Thank you for the response. I have updated the PCN in the attached to reflect the below correspondence. Please let me
know if you need anything further to proceed with processing this request. Thank you,
Preston Gregg, PE
Principal
(828) 400‐9353
From: Winston, Joey <joey.winston@deq.nc.gov>
Sent: Friday, June 30, 2023 9:59 AM
To: Preston Gregg <PRengineering@outlook.com>
Cc: Davidson, Landon <landon.davidson@deq.nc.gov>; Davis, Brooke A CIV USARMY CESAW (USA)
<Brooke.A.Davis@usace.army.mil>; Jason Miller <jasonmiller.mail@gmail.com>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
Hi Preston,
Due to the unique circumstances with this project, such as the impacts from Tropical Storm Fred, impacts that occurred
prior to current regulations, and discussions with the Corps about restoring the pond, along with the Corps’ decision not
to require mitigation, the Division will not include the proposed impacts to the stream within the extents of the former
pond in calculations for the mitigation threshold. This decision is based on the unique circumstances of this project and
should not be referenced in future projects.
A calculation of the proposed amount of impact, in linear feet and matching the jurisdictional determination agreed to
by the Corps, will need to be provided for the Division to issue a water quality certification that authorizes all impacts
proposed for the project. The most recent revision submitted to the Division does not include a calculation of stream
impact for the stream within the extents of the former pond and such number has not been provided when requested in
subsequent discussions. Per 15A NCAC 02H .0502(a) and 40 CFR 121.5(b), the location and dimensions of impact must
be included in the request for certification. Please provide this measurement so that the Division can proceed with your
application.
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Please let me know if you have any questions.
Thanks,
Joey
Joey Winston
Environmental Specialist II, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (828) 296‐4685 | Cell: (828) 785‐9171
NEW: joey.winston@deq.nc.gov
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th.
Employee email addresses may look different, but email performance will not be impacted.
From: Davidson, Landon <landon.davidson@deq.nc.gov>
Sent: Monday, June 26, 2023 11:26 AM
To: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Preston Gregg
<PRengineering@outlook.com>
Cc: Jason Miller <jasonmiller.mail@gmail.com>; Winston, Joey <joey.winston@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
Thank you Brooke for the follow‐up, much appreciated.
Landon
G. Landon Davidson, P.G., CPM (he/him/his)
Regional Supervisor – Asheville Regional Office
Water Quality Regional Operations
Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, NC 28778
North Carolina Department of Environmental Quality
Office: (828)296‐4680 | Mobile: (828)230‐4057
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th.
Employee email addresses may look different, but email performance will not be impacted.
My new email address beginning the week of May 15th will be: landon.davidson@deq.nc.gov
NC DEQ Permit Directory
Public record information: website
3
From: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>
Sent: Monday, June 26, 2023 10:01 AM
To: Davidson, Landon <landon.davidson@deq.nc.gov>; Preston Gregg <PRengineering@outlook.com>
Cc: Jason Miller <jasonmiller.mail@gmail.com>; Winston, Joey <joey.winston@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
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Hi Landon,
Per our conversation, we unfortunately do not have documentation other than verbal, which coincides with my
conversation with David Brown this morning. I am justifying the pond/straightened section of channel through the
historic pond bottom as still being a part of the “emergency” provision of 24 months in our Nationwide
Permits. Therefore, we are not requiring mitigation under the Section 404 permit.
Hope this makes sense.
Let me know if you need further explanation.
Thanks,
Brooke
From: Davidson, Landon <landon.davidson@deq.nc.gov>
Sent: Friday, June 23, 2023 3:12 PM
To: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Preston Gregg
<PRengineering@outlook.com>
Cc: Jason Miller <jasonmiller.mail@gmail.com>; Winston, Joey <joey.winston@deq.nc.gov>
Subject: [Non‐DoD Source] RE: [External] RE: Springdale Driving Range Extension Update
Thanks Brooke,
Our primary challenge in being able to move this forward is the lack of documentation on the topic of restoration of the
pond. You reference David and Amy in that decision but Amy has no information on that subject nor documentation. If
this was David’s decision (i.e., USACE) is there any documentation available for review? We’ll be consulting with our
central office 401/mitigation staff on the subject in the coming weeks.
Thanks everyone.
Regards,
G. Landon Davidson, P.G., CPM (he/him/his)
Regional Supervisor – Asheville Regional Office
Water Quality Regional Operations
4
Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, NC 28778
North Carolina Department of Environmental Quality
Office: (828)296‐4680 | Mobile: (828)230‐4057
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th.
Employee email addresses may look different, but email performance will not be impacted.
My new email address beginning the week of May 15th will be: landon.davidson@deq.nc.gov
NC DEQ Permit Directory
Public record information: website
From: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>
Sent: Thursday, June 22, 2023 4:05 PM
To: Preston Gregg <PRengineering@outlook.com>
Cc: Jason Miller <jasonmiller.mail@gmail.com>; Davidson, Landon <landon.davidson@deq.nc.gov>; Winston, Joey
<joey.winston@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
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Hey Preston,
I agreed with what your consultant identified in the delineation report. We are not requiring mitigation for the area that
was considered the old pond (and what you are going to be piping) because you all had discussed with David and Amy
whether or not you should put back the pond since you would be working in this area; at that time it is my
understanding that all decided to leave the channel as it would be less detrimental to the system. If we did not have the
history on this site, I would have considered it as it’s currently functioning as a channel and required mitigation.
Hopefully this makes sense.
Thanks,
Brooke
From: Preston Gregg <PRengineering@outlook.com>
Sent: Thursday, June 22, 2023 3:43 PM
To: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>
Cc: Jason Miller <jasonmiller.mail@gmail.com>
Subject: [Non‐DoD Source] Re: [External] RE: Springdale Driving Range Extension Update
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Hi Brooke,
I can agree with Landon that the red oval circle in the photo is non jurisdictional bc it’s a sediment basin that was
installed for erosion control. However the point to be made is that Jason and I’s understanding from you was that the
impact within the limits of the old pond would be considered an open water impact. This was what you have
communicated to us several times by you. Can you communicate this to Joey and or Landon? Thanks a lot,
Preston
Sent from my iPhone
On Jun 22, 2023, at 2:41 PM, Davis, Brooke A CIV USARMY CESAW (USA)
<Brooke.A.Davis@usace.army.mil> wrote:
Hi Landon,
That is correct concerning the features you identified below. Please let me know if you have any other
questions.
Thanks,
Brooke
From: Davidson, Landon <landon.davidson@deq.nc.gov>
Sent: Thursday, June 22, 2023 2:21 PM
To: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>
Cc: Winston, Joey <joey.winston@deq.nc.gov>; Preston Gregg <PRengineering@outlook.com>
Subject: [Non‐DoD Source] RE: [External] RE: Springdale Driving Range Extension Update
Brooke,
Good afternoon. Unfortunately, there remain some different understandings regarding the types of
impact proposed for this site. As we talked about onsite, DWR defers to the Corps for the determination
of impact amount and feature type. Based on our conversations onsite and the PJD report submitted by
the applicants, DWR understands that the Corps considers the existing stream channel within the
extents of the former pond (green line below) to be a jurisdictional stream impact and the stormwater
feature (red oval below) to be a non‐jurisdictional impact. Can you please confirm whether this is a
correct interpretation and aligns with previous discussions? Our goal is to resolve this issue which will
therein, allow us to determine applicability of our rule, 15A NCAC 02H .0506(c) which requires
mitigation for impacts to 300 linear feet or greater of perennial streams.
Regards,
Landon
6
G. Landon Davidson, P.G., CPM (he/him/his)
Regional Supervisor – Asheville Regional Office
Water Quality Regional Operations
Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, NC 28778
North Carolina Department of Environmental Quality
Office: (828)296‐4680 | Mobile: (828)230‐4057
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June
9th.
Employee email addresses may look different, but email performance will not be
impacted.
My new email address beginning the week of May 15th will be:
landon.davidson@deq.nc.gov
NC DEQ Permit Directory
Public record information: website
7
From: Preston Gregg <PRengineering@outlook.com>
Sent: Wednesday, June 21, 2023 10:52 PM
To: Winston, Joey <joey.winston@deq.nc.gov>
Cc: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Davidson, Landon
<landon.davidson@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
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Hi Joey,
Thanks for the quick reply. Below are our comments:
1. We have updated the PCN Impact Table (see attached). It has been our understanding from the
last two onsite meetings and phone calls with Brooke that the old impoundment that was blown
out by TS Fred would be treated as an open water impact. Brooke please chime in here if I am
incorrect but that has been the understanding from Jason and myself in the conversations that
we have had with you. In good faith and in communication with Brooke’s predecessor,
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Springdale contractors rushed to restore the site post TS Fred and the site was placed back
without the pond.
You are correct, only NOVs issued by USACE and Haywood Co. for this site.
Unfortunately, I do not have written documentation regarding DWR’s position with not placing
the pond back. These conversations / meetings occurred during and after the site was restored
with your predecessor and members from USACE. Everyone’s desire was to see a finished
product that did not include another impoundment. And here we are haha. Thanks,
Preston Gregg, PE
Principal
(828) 400‐9353
From: Winston, Joey <joey.winston@deq.nc.gov>
Sent: Tuesday, June 20, 2023 10:32 AM
To: Preston Gregg <PRengineering@outlook.com>
Cc: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Davidson, Landon
<landon.davidson@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
Hi Preston,
I’m following up with some more comments to hopefully complete what we need.
1. There will need to be some sort of impact included in the PCN Impact Table for the area within
the extents of the former pond. Right now, the PCN Impact Table doesn’t match with the plans
on the amount of proposed impact. The amount of proposed impact always needs to be
included on the PCN Impact Table so that when the certification is issued, it will cover all
impacts that will occur. The type of impact (stream versus open water) is determined by the JD
reviewed by the Corps, and the Corps has determined that the impact within the extents of the
former pond is a stream (green line on graphic below). Also, I’ve been looking through our files
on the project, and I haven’t found some of the documents you’ve referenced in your
comments. I haven’t found an NOV issued by DWR for this location, just other locations on the
property. I also couldn’t find any discussions with DWR about whether the pond should be
restored. Could you provide any files you have on the matter?
9
2. Thanks for the clarification. Since this impact occurred before June 1, 2000, it will not be
included in the mitigation amount.
3. Unfortunately, the need for mitigation hasn’t been resolved. Please see item 1 above for
additional information needed.
Please let me know if you have any questions.
Thanks,
Joey
Joey Winston
Environmental Specialist I, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (828) 296‐4685 | Cell: (828) 785‐9171
NEW: joey.winston@deq.nc.gov
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June
9th.
Employee email addresses may look different, but email performance will not be
impacted.
10
From: Preston Gregg <PRengineering@outlook.com>
Sent: Monday, June 19, 2023 11:46 PM
To: Winston, Joey <joey.winston@deq.nc.gov>
Cc: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Davidson, Landon
<landon.davidson@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
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Hi Joey,
Thank you for looking into this. Below are a few comments to your previous email.
1. The most recent aerial photo shows (taken March of this year) the site after emergency erosion
control work was completed as part of the remedial action plan referenced in the NOVs issued
by DWR, USACE and Haywood Co. Erosion Control Department’s. So the sediment basin shown,
and “new” stream was only placed there temporarily due to the old pond being blown out by
the flood, in addition to; no one (DWR, USACE, Haywood Co.) desired a pond to be placed
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back. It has been our understanding from previous meetings and most current, that all parties
agreed that the old pond was an open water impact only and no mitigation was required;
therefore, this is why no pipe measurement was accounted for within the extents of the former
pond. Below is a screenshot of the site pre TS Fred.
2. It is our understanding that the culvert was installed at (or as close to) the time of the course
opening in 1968. I have edited the Historical Impact Assessment report (page 9 of 23 attached)
to reflect a more defined date.
3. Hopefully 1 & 2 above clear up pipe in question.
Please let us know if you need anything further to complete your review. Thanks again,
12
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Preston Gregg, PE
Principal
(828) 400‐9353
From: Winston, Joey <joey.winston@deq.nc.gov>
Sent: Thursday, June 15, 2023 12:11 PM
To: Preston Gregg <PRengineering@outlook.com>
Cc: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>; Davidson, Landon
<landon.davidson@deq.nc.gov>
Subject: RE: [External] RE: Springdale Driving Range Extension Update
Hi Preston,
I have some questions and need some more information about the revised plans, please let me know if
you have any questions about it.
1. The revised PCN Stream Impact Table doesn’t include the proposed impact for piping the stream
within the extents of the former pond. From my understanding of our meeting last month, the
sediment basin (red circle below) is considered non‐jurisdictional but the stream within the
extents of the former pond (green line below) is considered a jurisdictional stream. The revised
PCN Stream Impact Table includes an impact to Open Water 1 for the sediment basin but
provides no measurement for the stream within the extents of the former pond.
14
2. Impact P in the Historical Impacts Assessment says that it was installed as a Tropical Storm Fred
Replacement. Is there an impact that predates TS Fred and the existing culvert was a
replacement, or was this a new impact after TS Fred? If there was an existing impact, do you
know when it occurred?
3. The impacts detailed in the Historical Impacts Assessment, along with the proposed new
impacts for stream piping, will cause the need for mitigation. The important date is June 1,
2000, after which the Division started requiring mitigation for projects of this type impacting
streams of this classification. All impacts after this date will be counted towards the mitigation
threshold and will require mitigation if the threshold is exceeded. I’ve included a table below
that should help.
Impacts requiring mitigation:
Impact Name Impact Type Feature Type Year Length of
Impact (ft)
Notes
P Culvert UT TS Fred
Replacement
(post August
2021)
30 See question 2
above for date—
may not need
mitigation
S1—Piping
existing stream
Culvert UT Proposed 295 Proposed
S5—Piping
existing stream
Culvert UT Proposed ? Proposed—need
measurement
15
within the
extents of
former pond
(see question 1
above)
Total: 325+S5
Thanks,
Joey
Joey Winston
Environmental Specialist I, Division of Water Resources
North Carolina Department of Environmental Quality
Office: (828) 296‐4685 | Cell: (828) 785‐9171
NEW: joey.winston@deq.nc.gov
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June
9th.
Employee email addresses may look different, but email performance will not be
impacted.
16
From: Davis, Brooke A CIV USARMY CESAW (USA) <Brooke.A.Davis@usace.army.mil>
Sent: Tuesday, June 13, 2023 8:29 AM
To: Preston Gregg <PRengineering@outlook.com>; Winston, Joey <joey.winston@deq.nc.gov>
Subject: [External] RE: Springdale Driving Range Extension Update
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the
Report Message button located on your Outlook menu bar on the Home tab.
Hey Preston,
I have all I need.
Thank you.
Brooke
From: Preston Gregg <PRengineering@outlook.com>
Sent: Friday, June 9, 2023 11:04 AM
To: Winston, Joey <joey.winston@deq.nc.gov>; Davis, Brooke A CIV USARMY CESAW (USA)
<Brooke.A.Davis@usace.army.mil>
Subject: [Non‐DoD Source] Springdale Driving Range Extension Update
Good Morning Joey / Brooke,
Hope all is well. Just checking in on the status of this one? Thanks for your help with it.
Preston Gregg, PE
Principal
(828) 400‐9353
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third
parties by an authorized state official.