20210573 Ver 1_More Info Requested_20220629

From: Snider, Hollev
To: Woioski. Paul A
Cc: Beecher, Gary H CIV USARMY CESAW (USA); Hargrove. Andrew D
Subject: RE: [Non-DoD Source] Re: [External] Re: The Cannon Tract (SAW-2020-01466)
Date: Wednesday, October 26, 2022 1:05:00 PM
Attachments: imaae002.Dna
20210573 Stanley Martin Cannon Homes DENIAL BrunsCo Oct.22.docx
Good afternoon Gentlemen,
Please see that attached draft of the denial letter for the Stanley Martin Cannon Homes Tract (DWR
project #20210573. The letter has been drafted with two receipt dates for the application which is
consistent with the chronology listed below for the project and with the USACE's determination of
permitting pathways. Feel free to call or email me if you have any questions.
Sincerely,
Holley Snider
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
U,_�!EE Q�:!��,
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Snider, Holley
Sent: Tuesday, October 4, 2022 5:45 PM
To: Wojoski, Paul A <[e-mail]>
Cc: Beecher, Gary H CIV USARMY CESAW (USA)<[e-mail]>; Hargrove,
Andrew D <[e-mail]>
Subject: FW: [Non-DoD Source] Re: [External] Re: The Cannon Tract (SAW-2020-01466)
Hey Paul,
Please add the Stanley Martin Cannon Tract (DWR Project #20210573) to our list of projects to
discuss THIS WEEK PLEASEIIIIIIIIIIII Here's a lovely example of how wildly wonky things can go
when the project spans different managers and new rule changes and interpretations. I seem to
recall this project was originally assigned to me, then I found the fine print about 4 acres of isolated
wetlands impacts and reassigned to Rick at the CO because of the mitigation requirements.
3/17/2021 pre -filing meeting request submitted
4/17/2021 pre -filing date completed

10/04/2021 application complete at CO requesting NW14 with 4 acres of isolated wetland impacts
---I believe this was during the time the USACE was told they could not process NW29 requests (see
excerpt below from 04/04/2022)
11/17/2021 RFAI from Rick Trone, per BIMS not in LF
11/18/2021 RFAI from USACE Gary Beecher (email attached -exceeds thresholds for NW)
1/28/2022 add info received impacts below threshold for IP resubmitted as a NW 29 -redesign with
bottomless culverts proposed in intermittent streams
------this project got caught up in the changes to the Rule that required PN for NWs
3/08/2022 Public Notice published
4/04/2022 status update request from Gary..
Holly,
Is this one still under public notice? Checking to see what your stance is on
this one.
I'm trying to figure out were we are at on this one. It originally got stuck
when the Corps stopped issuing the NWP 29, So it came in as a NWP 14.
Now its back to a NWP 29,
Thanks,
Gary
6/20/2022 - isolated wetland determination wetland data sheets provided not NC WAM forms
6/29/2022 — DWR RFAI re: inconsistencies in culvert crossing details but DWR failed to RFAI
re:mitigation for impacts to isolated wetlands greater than one acre.
7/14/2022 — DWR RFAI re: bottomless culvert
8/4/2022 — DAVEY response to RFAI re: inconsistencies in culvert crossing details
8/9/2022 — USACE RFAI re: bottomless culverts
To date no response from the applicant
I hope this is helpful in facilitating our discussion.
Sincerely,
Holley Snider ,������°>•, .. ..><((((°>.• -
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
DE
pRT _
M a� EnaronnNn�al fJa�lily
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Beecher, Gary H CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, August 9, 2022 3:36 PM
To: Williams, Kim <Kim.Williams(@davey.com>; Snider, Holley <holley.sniderCCDncdenr.gov>
Cc: Wojoski, Paul A <Paul.Wojoski(@ncdenr.gov>; Paul Farley <paul.farleyPdavey.com>; Weber,
Adrianna <aweber(@townofleland.com>
Subject: RE: [Non-DoD Source] Re: [External] Re: The Cannon Tract (SAW-2020-01466)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
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Kim,
Below are the impact details that I've gathered about this project from your most recent email.
Stream Impact #1:
74 LF of impact
Stream Impact #2:
60 LF
Stream Crossing #3:
94 LF
Stream Crossing #4:
67 LF
Bottomless Culvert #1 & 2:
"Typical Bottomless Culvert" on plans a geotechnical evaluation will be conducted to determine the
correct size required for this crossing.
Wetland Impact
0.13 acres
A couple of comments/observations and questions:
-What is the total acreage of the stream impacts?
-It looks like each stream will have outlet protection and a rock stabilization apron. I have a difficult
time actually seeing these devices on the plans. (there is a small blurb on what page of the plans, see
attached)
Bottomless Culverts:
While the Corps does not specifically prohibit the use of Bottomless Culverts there are several things
to take into account before they can be accepted into a permit application:
They include:
-How will they be installed

-The DOT does not "usually" accept subdivision roads with Bottomless Culverts (in Coastal NC) , does
that mean these roads will always be private roads? We will need specific clearance and approval
from DOT that they are ok with the use of these two Bottomless culverts.
-If they are in the permit, then the permit will be conditioned so that any failure will result in
impacts. This could potentially result in violations of the Clean Water Act and may escalate this
project into an Individual Permit.
-The Corps will not issue this permit before the geotechnical evaluation takes place. All the field
work should have already been done prior to the application being submitted to the Corps and DWR.
Thanks for your assistance with this project
Respectfully,
Gary
US Army Corps;
of Engineers
Wilg7i Mn pis"kf
Gary Beecher
USACE Wilmington Field Office
Regulatory Project Manager
Office [phone]
Cell [phone]
gary.h.beecher(@usace.army.mil
From: Williams, Kim <Kim.Williams(@davey.com>
Sent: Thursday, August 4, 2022 1:26 PM
To: Snider, Holley <holley.snider(a ncdenr.gov>
Cc: Beecher, Gary H CIV USARMY CESAW (USA)<Gary.H.BeecherPusace.army.mil>; Wojoski, Paul A
<Paul.Wojoski(@ncdenr.gov>; Paul Farley <paul.farley(@davey.com>; Weber, Adrianna
<aweber(@townofleland.com>
Subject: [Non-DoD Source] Re: [External] Re: The Cannon Tract (SAW-2020-01466)
Hi Holley

Thanks for your comments. Please see my responses below. Note that the site plan has changed
slightly, but overall impacts remain the same (0.13 acre of wetlands and 295 LF (1,180 sf) of stream.
Attached are the revised drawings and impact table.
Thanks!
Kim
On Wed, Jun 29, 2022 at 12:51 PM Snider, Holley <holley.sniderPncdenr.gov> wrote:
Hey Kim,
I was reviewing this project on Paul's behalf a few questions have arisen:
• The plan view of the project (sheet 1 of 8) shows two (2) bottomless culverts with a "typical
detail" that states "typical layout actual size and location to be determined at time of final
plans". Additional information will need to be provide that supports the use of bottomless
culverts in these locations, including details, length, width, height, etc. for each of the
bottomless culvert crossings. The use of bottomless culverts in the coastal plain, if not
properly designed, and situated on suitable soils, can result in failures that result in impacts
to downstream waters and wetlands.
RESPONSE: Sheet 9 (attached) includes additional details about the two bottomless culverts that
are proposed. Note that a geotechnical assessment will occur in the coming weeks, which will
provide specific recommendations about the structural design.
• The details sheet (5 of 8) for the wetland crossing at Balboa Avenue North states "pipe size
and type to be determined". However, the submitted cross section drawing shows two (2)
24 inch RCPs with rip rap apron. The "standard outlet protection" on the same drawing
calls out different lengths and widths of the outlet protection based on pipe size. This
information will need to be clarified to be sure that wetlands impacts are being accurately
accounted for. When measured the crossing appears to be greater than 100 feet in length
on both sides. As proposed, the roadway and sidewalk are approximately 60 feet in width
and lacks separation between the two. Will slopes be necessary to stabilize the fill in this
location or will the proposed headwall extend the length of the crossing on both sides? The
Town of Leland street standards may require that separation be provided between the
roadway and sidewalk, please clarify.
RESPONSE: The "pipe size and type to be determined" label has been removed. The plan view
and cross section both show a 60' wide impact at the pipe/riprap location. The headwalls are
shown to extend the length of the crossing on both sides. Furthermore, the proposed roadway
and sidewalk layout meets the Town of Leland requirements.
• Stream Crossing #1 at Raystone Drive (Sheet 6 of 8) calls out 42 liner feet of 24 inch RCP
culvert buried 12 inches below grade, should be buried 20% or 4.8 inches. The drawing
indicates "pipe size and type TBD". The impact table indicates 59 linear feet of impact,
please clarify.

RESPONSE: Raystone Drive is Stream Crossing #2. The culvert at Stream Crossing
#2 will be buried 20% of the pipe diameter (4.8 in). The "pipe size and type to be
determined" label has been removed. This crossing has been revised slightly and total
impacts are now 60 LF. Of this, 42 LF is for the culvert and 18 LF is for rip rap. The
amount of rip rap needed is based on the Town of Leland requirements. They require
the road be designed to the 25 year storm.
• Stream crossing #2 at Mulholland Drive calls out 56 linear feet of 24" RCP culvert, the
drawing indicates "pipe size and type TBD". The impacts table indicates this crossing will be
72 linear feet, please clarify.
RESPONSE: Mulholland Drive is Stream Crossing #1. The "pipe size and type to be determined"
label has been removed. This crossing has been revised slightly and total impacts are now 74 LF.
Of this, 56 LF is for the culvert and 18 LF is for rip rap. As noted above, the amount of rip rap
needed is based on the Town of Leland requirements. They require the road be designed to the
25 year storm.
• Stream Crossing #3 at Mulholland Drive (sheet 7 of 8) calls out 88 linear feet 24 inch RCP
culvert, the drawing indicates "pipe size and type TBD". The impacts table indicates this
crossing will be 103 linear feet, please clarify.
RESPONSE: The "pipe size and type to be determined" label has been removed. This crossing
has been revised slightly and total impacts are now 94 LF. Of this, 84 LF is for the culvert and 10
LF is for rip rap. As noted previously, the amount of rip rap proposed is based on the Town of
Leland requirements. They require the road be designed to the 25 year storm.
• Stream Crossing #4 at Balboa Avenue (sheet 8 of 8) calls out 43 linear feet 24 inch RCP
culvert, the drawing indicates "pipe size and type TBD". The cross section show the pipe
located outside of the stream channel. The impacts table indicates this crossing will be 60
linear feet, please clarify. Additionally, the stormwater outlet pipe from the retention pond
appears to directly discharge to the stream and lacks a 50 foot vegetated buffer which is
likely necessary for compliance with the Post -Construction State Stormwater
requirements. The outlets of all of the proposed stormwater control measures have not
been shown on the plan sheets and therefore it is unclear if the outlet structures will
provide measures necessary to ensure that any remaining surface waters or wetlands , and
any surface waters or wetlands downstream continue to support existing uses during and
after project completion.
RESPONSE: The "pipe size and type to be determined" label has been removed. The cross
section drawing has been adjusted to show two 30" culverts within the channel. This crossing
has been revised slightly and total impacts are now 67 LF. Of this, 52 LF are for the culverts and
15 LF is for rip rap. The project engineer has reviewed the NCDEQ Stormwater Design Manual,
Section A-9- Vegetated Setbacks and it is his understanding that the project as designed meets
these stormwater requirements.

• The application indicates no temporary impacts will be associated with this project. Please
clarify if temporary impacts will be associated with utilities installation and construction.
RESPONSE: Correct- no temporary impacts are proposed for this project.
The DWR has additional questions regarding the proposed development and has determined that
additional information will be necessary to complete the review of your permit application. The
application is on hold until all of the following information has been received by our office.
thank you in advance for your time and attention to this matter. Please feel free to call or email
me if you have any questions or I may be of assistance to you in any way.
Sincerely,
Holley Snider .•, ,������°>•, .. ..><((((°>.
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
N [7T i � i.:hfa0i. i O
YAM N EniMa�mMnlN Gwllryr
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Williams, Kim <Kim.WilliamsPdavey.com>
Sent: Monday, June 20, 2022 12:37 PM
To: Snider, Holley <holley.sniderPncdenr.gov>
Cc: Beecher, Gary H CIV USARMY CESAW (USA) <Gary.H.Beecher(@usace.army.mil>; Wojoski, Paul
A <Paul.WoioskiCcDncdenr.g_ov>; Paul Farley <paul.farleyPdavey.com>
Subject: Re: [External] Re: The Cannon Tract (SAW-2020-01466)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.
Hi Holley
We don't have any written documentation for the site meeting with Robb. Paul Farley met Robb
on site and they reviewed each wetland pocket. Each one was dominated by a mix of pines, bay
species, titi, gallberry, etc and they determined that all of them were pocosin habitat. I'm not sure
if Robb took any notes.
We did prepare a couple of data forms for two of the wetland pockets (NW4 and NW17) that
describe pocosin vegetation (attached). The vegetation in the remaining pockets was similar.

Thanks,
Kim
On Mon, Jun 20, 2022 at 11:58 AM Snider, Holley <holley.snider(@ncdenr.gov> wrote:
Hey Kim,
Paul ad I have been discussing this one. Did Davey or Robb complete the NC WAM and/or
provide written documentation as to how the determination was made for the pocosin
wetland? Thanks in advance.
Sincerely,
Holley Snider' -
Environmental Specialist 11
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
, -r- ��� Q.. Fm
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Williams, Kim <Kim.Williams(@davey.com>
Sent: Monday, June 20, 2022 11:54 AM
To: Snider, Holley <holley.snider(@ncdenr.gov>
Cc: Beecher, Gary H CIV USARMY CESAW (USA) <Gary.H.Beecher(@usace.army.mil>; Wojoski,
Paul A <Paul.WoioskiCcDncdenr.gov>
Subject: Re: [External] Re: The Cannon Tract (SAW-2020-01466)
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Hi Paul
I am checking in again on the status of the 401 WQC for the Cannon Tract. Any update you can
provide would be greatly appreciated!!
Thanks,
Kim
On Mon, Jun 6, 2022 at 6:40 PM Williams, Kim <Kim.Williams(@davey.com> wrote:
Hi Paul and Holley

I wanted to check in with you regarding the status of the Cannon Tract 401 WQC. We
submitted our response to you back in January and are looking forward to getting the permit.
Thanks,
Kim
On Tue, Apr 19, 2022 at 9:20 AM Williams, Kim <Kim.WilliamsCcDdavey.com> wrote:
Thanks Holley!
Paul- can you let me know the status of this application when you get a chance? We
responded to comments back in January and are looking forward to getting the permit.
Thanks,
Kim
On Mon, Apr 18, 2022 at 10:35 AM Snider, Holley <holley.snider(@ncdenr.gov> wrote:
Good morning Kim,
The project has been assigned to Paul Wojoski in the Raleigh office. He has been copied
on this email. Feel free to call or email me if you have any other questions.
Sincerely,
Holley Snider . " ,><((((�>•' ><((((�>.•'_
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Q E
1-1�
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Williams, Kim <Kim.WilliamsCcDdavey.com>
Sent: Tuesday, April 12, 2022 10:32 AM
To: Beecher, Gary H CIV USARMY CESAW (USA)<Gary.H.Beecher(@usace.army.mil>
Cc: Snider, Holley <holley.sniderCcDncdenr.gov>
Subject: [External] Re: The Cannon Tract (SAW-2020-01466)

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Hi Holley
Just wanted to check back in on this one. Are you working on this one, or is it the
Raleigh office?
Thanks!
Kim
On Mon, Apr 4, 2022 at 1:04 PM Beecher, Gary H CIV USARMY CESAW (USA)
<Gary.H.Beecher(@usace.army.mil> wrote:
Holly,
Is this one still under public notice? Checking to see what your stance is on this one.
I'm trying to figure out were we are at on this one. It originally got stuck when the
Corps stopped issuing the NWP 29, So it came in as a NWP 14.
Now its back to a NWP 29,
Thanks,
Gary