20231242 Ver 1_Updated Impacts_20231110

Baker, Caroline D
From: Kate Hefner <[e-mail]>
Sent: Friday, November 10, 2023 10:06 AM
To: Bailey, David E CIV USARMY CESAW (USA); Thomas, Zachary T
Cc: Chris Raughley; Robert Rudloff, Amanda Johnson; Lauren Norris -Heflin
Subject: [External] RE: Request for Additional Information: SAW-2021-01965 (Cambria / New
Bethel Road /Garner / Wake County / residential)
Attachments: 2023.11.10_Cambria RAI Response Package_FINAL (reduced).pdf
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.
Dave/Zach,
Good morning!
Attached is the Request for Additional Information (RAI) response package for the Cambria site. Please let me know if
you have any questions or need anything else for your review.
Thanks, and have a great weekend!
Kate Hefner, WPIT, ISA-CA (she/her)
Environmental Scientist 11
,06
Tit CANS GROUP
LNGUACERMG. 14ESIGN i 7ECHNINOGY
TIMMONS GROUP I www.timmons.com
5410 Trinity Rd, Suite 102 1 Raleigh, INC 27607
Office: 919.866.4953 1 Cell: 828.455.4636
Kate. [e-mail]
Your Vision Achieved Through Ours
To send me files greater than 20MB click here.
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, October 6, 2023 11:56 AM
To: Kate Hefner <[e-mail]>; Chris Raughley <[e-mail]>
Cc: Thomas, Zachary T <[e-mail]>
Subject: Request for Additional Information: SAW-2021-01965 (Cambria / New Bethel Road /Garner / Wake County /
residential)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
0
1

Thank you for your PCN, dated 9/8/2023, for the above referenced project. I have reviewed the information and need
clarification before proceeding with verifying the use of Nationwide Permits (NWPs) 29 (https://saw-
reg.usace.army.mil/NWP2021/NWP29.pdf) and 18 (https://saw-reg.usace.army.mil/NWP2021/NWP-18.pdf). Please
submit the requested information below (via e-mail is fine) within 30 days of receipt of this Notification, otherwise we
may deny verification of the use of the Nationwide Permit or consider your application withdrawn and close the file:
1) Note that a Preliminary Jurisdictional Determination (PJD) was issued for this project to the requestor (Soil &
Environmental Consultants) on 3/22/2023. Although the delineation map included in your PCN package appears
to match the map included with the PJD, the project plans do not appear to show feature LW1 (wetland), and
feature W5 (wetland) does not appear to extend as far updrainage (south) on the project plans as it does on the
delineation map. Please ensure that all features and their delineated extents appear on the plan set and report
any proposed impacts accordingly on the PCN.
2) Given the relatively steep slopes (>3%) of the proposed culverts at Impacts 1 and 6, we are concerned that these
features would be subject to headcutting above the proposed culvert if the invert is buried 1 foot as proposed.
Note also that, in this case, NWP Regional Condition B.9.a does not require culvert invert burial, based on the
proposed culvert slopes and size of the proposed pipes (<72"). Please confirm with NCDWR regarding whether
or not culvert burial is required/advisable in this situation. If burial of the culvert pipe is not advised, please
redesign accordingly and update the PCN and applicable plansheets.
3) Specific to Impact 5:
a. The multiple -culvert design appears to comply with the portion of NWP 29 Regional Condition B.9.c
requiring that the high flow culvert be designed to only receive flows above bankfull. However, the low -
flow culvert proposed is 12-feet wide, which appears to be wider than the width of the existing stream
bed as reported in PCN Section C.3. This does not appear to comply with Regional Condition B.9.b or the
portion of NWP 29 Regional Condition B.9.c that states "The width, height, and gradient of a proposed
culvert shall be such as to pass the average historical low flow and spring flow without adversely altering
flow velocity." To this end, the Regional Condition states "If the width of the culvert is wider than the
stream channel, the culvert shall include multiple boxes/pipes, baffles, benches and/or sills to maintain
the natural width of the stream channel. If multiple culverts/pipes/barrels are used, low flows shall be
accommodated in one culvert/pipe and additional culverts/pipes shall be installed such that they receive
only flows above bankfull." Please redesign this crossing to meet this condition.
b. Project plans indicate that this culvert outlet is oriented such that the stream would exit the culvert(s)
aimed at the stream bank. It is reasonable to expect severe bank erosion in this area during high flows.
i. Please re -design the culvert(s) to align with the downstream stream banks to avoid indirect
impacts of erosion and sediment loading into the stream. If slight re -alignment of the stream
channel are necessary at either end of the culvert, please include proposed cross sections of the
stream re -alignment, include the stream impact footprint and the proposed channel alignment
on the plans, and itemize the length of stream impacted as a permanent impact on the PCN.
ii. If redesign of the culvert is not practicable (available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of overall project purposes),
specifically state why, and show how the project is designed to prevent this foreseeable erosion
while also complying with Regional Condition B.9.c through profile/cross-section views, etc.
c. Please provide a detail of the tie-in between the outlet of the high -flow culvert and the existing stream
channel, ensuring that this tie-in does not widen the existing stream channel beyond the existing width
and also does not result in erosion or headcutting. Constructed floodplain benches are often used for
this purpose and have been shown to be effective on many NCDOT projects. An example is attached for
reference.
4) Based on proposed/assumed grading, the project appears to eliminate the majority of the drainage
areas/hydrology source for Wetlands W6 and W9:
a. Please provide justification that hydrologic input will be maintained to these waters. Common designs
include routing approximately equivalent surface water/runoff area to these locations, altering locations
of stormwater outlets, usage of French drains and under -drains where appropriate, etc. Please also
update applicable plansheets to clearly show such measures/details;

b. If maintenance of stream hydrology is unable to be justified as appropriate, the Corps would consider
these areas as reasonably foreseeable indirect impacts (see NWP General Conditions "District Engineers
Decision") resulting from a loss of hydrology. In such cases compensatory mitigation may be required for
indirect impacts resulting in a loss of hydrology and therefore aquatic function; compensatory mitigation
is typically required at a 1:1 ratio for such indirect impacts (although may be situationally up to 2:1),
depending largely on aquatic function (e.g. NCWAM);
c. A monitoring plan (typically including monitoring devices and visual observations for a period of 5 years
post -construction) to document maintenance of stream hydrology may also be proposed for Corps
evaluation and approval; such monitoring plans would also include a contingency plan, typically
including compensatory mitigation, in the event that monitoring does not indicate maintenance of
stream hydrology.
5) Given the relative proximity of this project to known populations of several threatened/endangered mussel
species, as well as potentially suitable habitat for these species occurring within the project action area, we have
initiated informal consultation with the US Fish and Wildlife Service (USFWS). Please note that the Corps cannot
verify the use of a NWP until Section 7 consultation is complete.
6) Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
It appears that an Individual 401 Water Quality Certification (WQC) is required from the North Carolina Division of Water
Resources (NCDWR) for this project. Please note that the Corps cannot verify the use of any NWP without a valid 401
WQC.
For NCDWR: Within 14 days, please notify me if the certification request does not contain the nine (9) components listed
in Section 121.5(b) of the 2020 Clean Water Act Section 401 Certification Rule; otherwise, we will consider our receipt
date (9/8/2023) as accurate. As specified in the 9/16/2022, Programmatic Agreement (PA) between the USACE and the
NCDWR, the reasonable period of time (RPOT) for DWR to act on a Section 401 certification request is 120 days unless
the RPOT is extended per the terms of this PA. As such, unless we receive an email request for an extension of the RPOT,
the USACE will consider the Section 401 certification for this project to be waived on 1/6/2024.
Please let me know if you have any questions.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Mobile: [phone]
Email: David. [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: https://regulatory.ops.usace.army.mil/customer-service-survey/
Thank you for taking the time to visit this site and complete the survey.
From: RaleighNCREG <[e-mail]>
Sent: Tuesday, September 12, 2023 1:48 PM
To: Kate Hefner <[e-mail]>

Cc: Bailey, David E CIV USARMY CESAW (USA)<[e-mail]>
Subject: SAW-2021-01965 (Walters Buffaloe Assemblage / Cambria / New Bethel Road / Hebron Church Road / Garner /
Wake County / residential)
Good Afternoon,
We have received your Pre -Construction Notification (PCN) NWP request for the above project and forwarded
it to Dave Bailey for further processing.
Thank you,
Josephine Schaffer
From: [e-mail] <[e-mail]>
Sent: Friday, September 8, 2023 2:40 PM
To: RaleighNCREG <[e-mail]>
Cc: SAW-PCN-RG <[e-mail]>
Subject: [Non-DoD Source] PCN - Wake - Non -DOT
A new project has been received on 9/8/2023 2:38 PM for Cambria. The link below will take you to the project folder.
https://edocs.deg.nc.gov/Laserfiche/index.aspx?db=WaterResources#id=2952733;view=browse
This email was automatically generated by Laserfiche workflow. Please do not respond to this email address, as
responses aren't monitored.