20240524 Ver 1_More Info Received_20240426

-0 WithersRavenel
.. Our People. Your Success.
April 26, 2024
US Army Corps of Engineers
Wilmington Regulatory Field Office
Mr. Gary Beecher
69 Darlington Avenue
Wilmington, NC 28403
Re: Pender County K-8 School - PCN Application Review Comments Response
Hampstead, Pender County
USACE AID: SAW-2023-01398
WR Project #23-0576
Dear Mr. Beecher,
This letter is in response to the PCN Application Review Comments email dated April 11, 2024
requesting additional information for the PCN application submitted by WithersRavenel (WR) on
April 4, 2024. Below are the items addressed in the PCN Application Review Comments email and
our responses:
USACE PCN Application Review Comments email (4/11/2024):
1) It appears that the NE Cape Fear Umbrella Bank - Holly Shelter has credits available. The
Corps requires that projects first to through available Mitigation Banks for credits
WR contacted the NE Cape Fear Umbrella Mitigation Bank regarding available
mitigation credits. Please see the attached Credit Reservation Letter.
2) RCW Slopes: The project (or part of it) appears to be within an RCW Slopes agreement area.
Please fill out the RCW Slopes Agreement for this project.
A Red -Cockaded Woodpecker (RCW) Effects Determination Key has been completed
and has been attached. The RCW Effects Determination Key results in a result of "No
Effect" determination. The mixed hardwood/pine and pine forest communities within
the review area were not considered potential RCW nesting habitat. The pine forest
(1) community was too young and the canopy too closed to be considered potential
foraging/nesting habitat. The pine forest (2) community was also not considered
potential RCW foraging/nesting habitat due to the community being extremely small
(approximately 2-acres) in size which is too small to be considered potential
foraging/nesting habitat. A review of aerial photography determined that there are no
large areas of mature pine forest within 0.5 miles of the review area sufficient to be
considered suitable RCW nesting habitat. Therefore, the review area was not
considered potential RCW foraging habitat. Please see the attached Vegetative
Communities Exhibit and RCW Effects Determination Key.
115 MacKenan Drive I Cary, NC 27511
t: 919.469.3340 1 www.withersravenel.com I License No. F-1479
Asheville I Cary I Charlotte I Greensboro I Pittsboro I Raleigh I Southern Pines I Wilmington

Pender County K-8 School :: W i t h e Fs Rave n e l
PCN Application Review Comments Email Response ❑urPeople. Your Success -
Hampstead, Pender County
3) Wetland Impacts 1 and 4: It appears that a modest redesign of these two wetland impacts can
be avoided.
In a meeting between the USACE and WR on April 24, 2024, it was discussed that there
are two primary reasons for the site design making avoidance of impacts W1 and W4
unavoidable.
The layout of the internal roads and parking areas are designed to maintain the flow of
traffic to accommodate drop-offs and pick-ups of students. The proposed school is
designed for 2,000 or more students and is designed to provide for future expansion.
Additionally, NCDOT requires ±7,000 linear feet of queue space within the site.
Furthermore, the design of the internal road network allows passenger cars to stay
within the west side of the site while buses travel on the east side of the site to prevent
comingling of passenger/bus travel.
The site design needs to accommodate a large number of parking spaces for staff and
visitors, ±7,000 If of internal road for queuing of drop-off/pick-up traffic, as well as an
SCM on the southern end of the proposed parking areas and the goal is to use natural
drainage throughout the site (vegetated swales). This stormwater design does result in
the need for additional grading to accommodate the preferred stormwater design,
which is necessary because the entire site must be raised approximately 5-6, to ensure
proper drainage.
Shifting the locations of the roads to avoid/minimize impacts at Impacts W1 and W4
would result in the loss of parking, loss of total length of vehicular queuing, and would
encroach into space for the SCM. There is very little room to adjust the site design to
avoid impact W1 due to the need to maintain separation between the drive and parking
as well as separation between parking areas and the school. The areas between the
passenger vehicle road and Wetland 6 will be used to return to existing grade and the
space between the parking and the drive will be used for a drainage swale.
Because reduction in parking, total length of vehicular queuing or SCM is not an option,
the only alternative would be to shift the entire design further south to avoid Impact
W4. This shift would result in encroachment into Wetland 5. Wetland 5 is a much
larger, more significant wetland system than Wetland 1. Wetland 1 has been
historically ditched and timbered and has an overall lower functional value than
Wetland 5. Additionally, the impacts to Wetland 5 resulting from shifting the entire
site south to avoid Impact W1 would result in significantly more permanent wetland
impacts than the currently proposed 0.108 acres for Impact W1 and would increase
the total wetland impacts to over 0.50 acres, resulting in the need for an Individual
Permit.
The proposed project as designed represents avoidance and minimization of wetlands
impacts to the maximum extent practicable while maintaining a feasible project design
that functions as required.
Page 2 of 3

Pender County K-8 School :: Withers Rave n e l
PCN Application Review Comments Email Response ❑urPeople. Your Success.
Hampstead, Pender County
4) Will wetland 2 and 4 still remain hydrologically connected?
Currently, Wetlands 2 and 4 are hydrologically connected via a swale in the right of
way. Both features are tied into feature S1.
Wetlands 2 and 4 will remain hydrologically connected via a 100'x30" RCP culvert as
depicted on the attached impact map sheet 2.02.
Please contact me if you have any questions about the information provided.
Sincerely,
WithersRavenel
Rick Trone Troy Beasley
Environmental Scientist Director of Natural Resources
Attachments:
1) PCN Application Review Comments email
2) NECFUMB Credit Reservation Letter
3) Red -Cockaded Woodpecker Effects Determination Key
4) Vegetative Communities Exhibit
5) Impact Map Sheet 2.02
Page 3 of 3

■■ WithersRavenel
lipp Our People. Your Success.
PCN APPLICATION REVIEW
COMMENTS EMAIL

From:
Beecher, Gary H CIV USARMY CESAW (USA)
To:
Trone, Rick
Cc:
Williams. Kelly
Subject:
[EXTERNAL] Corps PCN Application Review comments for Pender County School K-8 in Pender County, NC (SAW-
2023-01398)
Date:
Thursday, April 11, 2024 11:35:03 AM
Attachments:
image001.pnno
NE Cape Fear Umbrella Mitiaation Bank -Holly Shelter.odf
Red -cockaded Woodpecker NC SLOPES FINAL 02 March 2022.pdf
Site Plan.Ddf
CAUTION: This email originated from outside of WithersRavenel. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Rick,
Please see my PCN Application Review comments Below:
USACE Project ID:
SAW-2023-01398
Application Review Comments:
1. Mitigation:
It appears that the NE Cape Fear Umbrella Bank -Holly Shelter still has credits available. The Corps
requires that projects first go through available Mitigation Banks for credits. (see attached)
2. RCW Slopes:
The project (or part of it) appears to be within an RCW Slopes agreement area. Please fill out the
RCW Slopes Agreement for this project. (Form attached)
3. Wetland Impacts 1 and 4:
It appears that by a modest re -design these 2 wetland impacts can be avoided. (See attached plan
sheet)
4. Will wetland 2 and 4 still remain hydrologically connected?
Thanks for your assistance with this project
Respectfully,
Gary
�a.
Gary Beecher
USACE Wilmington Field Office
Regulatory Project Manager
Office [phone]
gary.h.beecher(@usace.army.mil

■■ WithersRavenel
lipp Our People. Your Success.
N ECFU M B CREDIT
RESERVATION LETTER

NORTHEAST CAPE FEAR UMBRELLA MITIGATION BANK
Agent: Davey Resource Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington, INC 28403
Credit Reservation Letter
April 18, 2024
Moseley Architects
Attn. Ashley Dennis
911 North West Street Ste 205
Raleigh NC 27603
Project: Pender County K-8 School (Pender County, NC)
Dear Ashley:
Per the credit request submitted by Rick Trone (agent), the Northeast Cape Fear Umbrella Mitigation Bank (Bank) is
providing preliminary acceptance to supply mitigation credits for proposed impacts to non -riparian wetlands associated
with the Pender County K-8 School project in Pender County, NC (conditional upon receipt of payment as outlined
below). Please refer to the table below depicting the type and quantity of credits requested and reserved for your
project.
Mitigation Type Credit Source Credits Reserved L Fee Per Unit _I Fee
Stream N/A 4 0 $740.09 I $0.00
Non- Riparian Wetland Holly Shelter Bay 0.8 $76,150.13 �I $60,920.10
Riparian Wetland N/A 0.0 I $76,150.13 I $0.00
Total F—$60,920.10
Based upon receipt of the credit request, the Bank will reserve 0.8 non -riparian wetland credits for a period of up to 90
days from the date of this letter. Note that requests to reserve credits beyond 90 days will require a deposit. Please
contact us if you need a reservation to extend beyond the 90-day period.
Upon request for credit transfer, the Bank will issue an invoice in the amount of $60,920.10. Upon receipt of payment,
the Bank will provide an executed Transfer of Credit Certificate for the total amount of credits invoiced and paid for. If
you have any questions or need additional information, please contact me by phone at [phone] or by email
at [e-mail]
Sincerely,
Northeast Cape Fear Umbrella Mitigation Bank
Christian Preziosi
Davey Resource Group, Inc (agent)
Northeast Cape Fear Umbrella Mitigation Bank
c/o Davey Resource Group, Inc.
3805 Wrightsville Avenue, Suite 15
Wilmington NC 28403
1

■■ WithersRavenel
lipp Our People. Your Success.
RED -COCKADED
WOODPECKER EFFECTS
DETERMINATION KEY

RCW SLOPES Manual — North Carolina
March 2022
US Army Corps
of Engineers.
Appendix B — Red -cockaded Woodpecker Effects Determination Key
ORM2 No.: Date
USFWS Reference No. (if applicable):
1) Is the action area' located within the RCW consultation area (see Appendix A and project -specific
results from a project -specific IPaC or internal USACE GIS review)?
a) Yes......................................................................................................................................................go to 2
b) No...................................................................................................................................................No effect'
2) Is the action area' located in the northeastern coastal plain (see Appendix A)?
a) Yes.......................................................................................................................................................go to 3
b) No (the project is located in piedmont, sandhills, or southeastern coastal plain)..................go to 4
3) Is the action area' located in a forested area with pine trees present in northeast North Carolina (e.g.,
high pocosin, Atlantic white cedar, nonriverine swamp forests, pond pine woodland, coastal fringe
evergreen forest, wet successional pine/pine-hardwood forest, or pine plantation or uplands)? If yes,
are the pine trees greater than 30 years of age (if stand age is not readily determined, refer to Table
1 for a description of the minimum dbh of 30-year-old pines associated with each community type).
If the answer to both of these questions is yes, choose Yes below. If the answer to one or both
questions is no, then choose No below.
a) Yes.......................................................................................................................................................go to 8
b) No...................................................................................................................................................No effect'
4) Is the action area' located within suitable RCW foraging or nesting habitat (pine or pine/hardwood
stands in which 50% or more of the dominant trees are pines and the dominant pine trees are 30
years of age or older or >_8-inches dbh')?
a) Yes.......................................................................................................................................................go to 5
b) No...................................................................................................................................................No effect'
5) Will any activity in the action area' remove trees equal to or greater than 8 inches dbh; or will any
activity occur within 200 feet of known RCW cavity trees? If unable to determine the location of a
cavity tree with confidence, contact the USFWS Raleigh Ecological Services Field Office.
a) Yes (to one or both).........................................................................................................................go to 6
b) No.........................................................................................................................................................NLAA3
12

RCW SLOPES Manual — North Carolina
March 2022
6) Is the action area' located in suitable RCW nesting habitat (in the sandhills and piedmont: pine or
pine/hardwood stands that contain pines 60 years in age or older or >_10 inches dbh; in the
southeastern coastal plain: pine or pine/hardwood stands that contain pines >:8 inches dbh, including
but not limited to pine flatwoods, pocosin, pine savannah, upland pine/hardwood)?
a) Yes........................................................................................................................................................go to 9
b) No.........................................................................................................................................................go to 7
7) Does suitable nesting habitat occur within 0.5 miles of suitable foraging habitat that would be
impacted by any activity in the action area'?
a) Yes......................................................................................................................................................go to 9
b) No.........................................................................................................................................................NLAA3
8) Refer to Table 1 in the SLOPES for the northeastern North Carolina habitat type in the action area'.
Are pine trees with a dbh equal to or greater than that shown in Table 1 proposed to be removed in
the action area', or is the action area' within 200 feet of a cavity tree? If the answer to either of these
questions is yes, choose Yes below. If unable to determine the location of a cavity tree with
confidence, then contact the USFWS Raleigh Field Office.
a) Yes......................................................................................................................................................go to 9
b) No.........................................................................................................................................................NLAA3
9) Contact the appropriate USACE representative for a pre -application meeting to determine if a survey
is necessary (for a list of USACE representatives please see the contact list at http://saw-
reg.usace.army.mil/FO/PMList.pdf). Note that project -specific information, such as a delineation of
waters of the U.S., project plans, and details concerning certain activities on disturbances that would
occur in the action area' (e.g. percussive activities, forest management, or similar disturbances), may
be needed for the USACE to determine the action area(s)' of the project. If a survey is required and
agreed to by the applicant, all suitable RCW nesting habitat within 0.5 miles of the action area' should
be surveyed according to USFWS protocol for the presence of RCW cavity trees'. If the applicant is
unwilling or unable to conduct the survey, standard consultation with the USFWS should begin. Such
surveys are conducted by running line transects through stands and visually inspecting all medium-
sized and large pines for evidence of cavity excavation by RCWs. Transects must be spaced so that all
trees are inspected and are run north -south.
Was a survey performed?
a) Yes, a survey was performed, and RCW cavity trees were observed.......................................go to 10
b) Yes, the survey was submitted to the USFWS for concurrence, and the USFWS concurred with the
results (no RCW cavity trees were observed)................................................................................NLAA3
c) No, the USACE determined that a survey was not required and the USFWS
concurred.............................................................................................................................................NLAA3
d) No, a survey was not performed..........................................................................Consultation required'
10) Does the project involve activities or disturbances in the action area' (e.g., percussive activities, forest
management, or similar disturbances) within the 200-foot cavity tree buffer, and/or cause removal or
damage to RCW cavity trees (e.g., via root compaction, soil compaction)? If yes to either or both then
consultation is required.
a) Yes............................................................................................................................Consultation required
b) No......................................................................................................................................................go to 11
13

RCW SLOPES Manual — North Carolina
March 2022
11) Has a foraging habitat analysis (FHA)' been conducted to determine whether enough foraging habitat
would remain for each RCW group post -project? For information on how to conduct an FHA', refer to
the "Procedures for Determining Foraging Habitat Availability" and the Private Land Guidelines.'
a) Yes, the FHA' has been submitted to the USFWS for concurrence' and the USFWS concurred
that adequate amounts of foraging habitat would remain post -project ................................. NLAA3
b) Yes, and review of the FHA' by the USACE along with concurrence from USFWS determined
inadequate amounts of foraging habitat would remain post -project......... Consultation required'
c) No, an FHA' has not been conducted...............................................................Consultation required'
'Action Area means all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved
in the action. Please contact the appropriate USACE representative for any questions as to the action area for the Federal action.
For a list of USACE representatives, please see the contact list at: http://saw-reg.usace.army.mil/FO/PMList.pdf.
2No effect — The proposed project would result in no effect to this species and/or its federally designated critical habitat (if
applicable). Further consultation with the USFWS Raleigh and Asheville Ecological Services field offices is not necessary for the
project as described.
3NLAA—The proposed project may affect but is not likely to adversely affect this species and/or its designated critical habitat (if
applicable). NLAA determinations for projects made pursuant to this key require no further consultation with the USFWS Raleigh
and Asheville Ecological Services field offices, therefore, consultation is considered complete for this species. For General Permits,
submittal of a Pre -Construction Notification to the USACE will be required for all NLAA determinations.
4Follow link to USFWS RCW Recovery Plan, Appendix 4 for additional information on nesting and foraging habitats, and survey
protocol (https://www.fws.gov/rcwrecovery/files/RecoveryPlan/survey protocol.pdf)
-'Consultation required — Contact the USACE to begin this consultation process. For a list of USACE representatives please see the
contact list at http://saw-res.usace.army.mil/FO/PMList.pdf. Further consultation with the USFWS Raleigh and Asheville
Ecological Services field offices is necessary to discern if the activity would result in a "no effect," "not likely to adversely affect,"
or "likely to adversely affect" determination.
6Follow links for additional information on conducting FHA (https://www.fws.gov/rcwrecoverv/matrix.html) and for
determining foraging habitat availability (https://www.fws.gov/ncsandhills/files/fha data collection procedures.pdf).
'Follow link for additional information regarding determination for adequate amount of foraging habitat
(https://www.fws.gov/rcwrecoverv/files/RecovervPlan/private lands guidelines.pdf).
8 FHA — When an FHA is conducted, the USACE must provide the FHA to USFWS for review and concurrence.
Additional Information
14

■■ WithersRavenel
lipp Our People. Your Success.
VEGETATIVE
COMMUNITIES EXHIBIT

it
■ t-
� GRAPHIC SCALE
y 2�� 0 200 400
+ 1 inch = 400 ft.
i• REVIEW AREA �r 4
fn f>
!01 > • i
,. 0t '+i
- o k� _ - ►
jp
VA
IL
Ir
4 Y4
IP
ar
...' tV4
1
jV
7 t
Jr-
lial• �'
- 'A yyam�-- � i
pb
LEGEND: %Jpa'�,'
EARLY SUCCESSIONAL -� — +
0 -
MIXED HARDWOOD/PINE FOREST 0 PINE FOREST (1) '' - ,,;� .. .:y;d r.
. - ' � :.� �� , ,' ��°� . �` ,...�-�` -� ; � • 'may,. � ` f ��'�?' ,
,4 PINE FOREST (2) ., � i ., 4 �a'., �rr`�: �" �' 4.*:•r,.w� 6
- f ti. ti �•.T s 'T ti .-.�y'�+ `' `,��.�--t•!yr'r ��+'�L�� 1t
. ''r-f 1- i' ?� �: :k .s„ f •fir- � ,_ ..�.. ,�� _ #'� ; _ •�`-�� - ,`���'�' �iT}� - ■+. �.. r
N� WithersRavenel
°-,By r- J-�4W PENDER CO. K-8 SCHOOL VEGETATIVE COMMUNITIES EXHIBIT 53No.
cn.�kPd By log, no_ Engineers Planners Surveyors
ac 23-0e76 HAMPSTEAD PENDER COUNTY NORTH CAROLINA

■■ WithersRavenel
lipp Our People. Your Success.
I M PACT MAP SHEET
2.02

— ru —
x x
f
IMPACT W3
PERMANENT WETLAND
ROAD CONSTRUCTION >
(5211 SF, 0.120) AC I
r
M Ix
�XJ
_ X�X
� X
X 9+50
X
WETLAND 2
arm
i a
WETLAND 4/
i
I M PACT LE
TEMPORARY NON -WETLAND WATERS
PERMANENT NON -WETLAND WATERS
(NO FUNCTIONAL LOSS)
PERMANENT NON -WETLAND WATERS
(FUNCTIONAL LOSS)
TEMPORARY WETLANDS
CULVERT
Ln jPROFILE VIEW
GRAPHIC SCALE
1" = 50' HORZ.
1" = 5' VERT.
50
45
40
35
9+50
c
100
NCDOT WING WALL
50
PROPOSED GRADE
r30" NCDOT WING WALL
1 I
30" RCP
EXISTING GRADE
9" RIPRAP W/
GEOTEXTILE
FABRIC
—
10+00 10+50 11+00
40
35
11+50
PRELIMINARY
NOT APPROVED FOR
CONSTRUCTION
�N
W� 1E
s
0 15 30
SCALE: 1 inch = 30 ft. —
Initial Plan Date03/22/2024
Revi,i—
WR lob No. DATE
23-0576 03/22/2024
DRN: WR DGN: WR CKD: WR
IMPACT W3
2.02