20240684 Ver 1_USACE More Info Request_20240614 (5)

Baker, Caroline D
From: Homer, Seren M
Sent: Wednesday, July 10, 2024 4:01 PM
To: Homewood, Sue
Subject: FW: [External] Request for Additional Information: SAW-2021-00677 / 238 Ritters Lake
Road / Greensboro / Guilford County / commercial
Seren Homer (she/her)
Environmental Specialist II, Division of Water Resources
North Carolina Department of Environmental Quality
Winston-Salem Regional Office
Office: [phone] 1 Cell: [phone]
[e-mail]
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Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Meyer, Laura J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, June 14, 2024 2:39 PM
To: [e-mail]
Cc: Brad Luckey <[e-mail]>; Homer, Seren M <[e-mail]>
Subject: [External] Request for Additional Information: SAW-2021-00677 / 238 Ritters Lake Road / Greensboro / Guilford
County / commercial
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ALCON,
Thank you for your Pre -construction notifications (PCNs) for the proposed 238 Ritters Lake Road in Greensboro, Guilford
County, NC Project (SAW-2021-00677), received on May 9, 2024.
The following information is required to complete our evaluation, confirm compliance with one or more General or
Regional Conditions, and/or complete consultation with another federal/state agency to verify the use of the
Nationwide Permit (NWP) 39 (Commercial and Institutional Developments):
1. Per General Condition 15, the activity must be a single and complete project.
a. For non -linear projects, the term "single and complete project" is defined in 33 CFR 330.2(i) as "the total
project proposed or accomplished by one owner/developer or partnership or other association of
owners/developers."
i. With the submittal of the Project J PCN, located within the same property parcel boundaries as
the 238 Ritters Lake Road project and has not been subdivided at this time according to Guilford
County, impacts proposed for the two projects will be considered a single and complete project

unless further justification can be provided. Current cumulative impacts to potential waters of
the US (WOUS) for the 238 Ritters Lake Road and Project J single and complete project include a
total loss of 0.3922 acre of wetlands and 0.0074 acre (52 linear feet) of stream channel.
Please note that single and complete projects are evaluated cumulatively with respect to
compensatory mitigation and Nationwide Permit thresholds.
b. A project is considered to have "independent utility if it would be constructed absent the construction of
other projects in the project area. Portions of a multi -phase project that depend upon other phases of
the project do not have independent utility. Phases of a project that would be constructed even if the
other phases were not built can be considered as separate single and complete projects with
independent utility."
Please provide updated plans for the 238 Ritters Lake Road and Project J projects to include all
infrastructure (utilities, stormwater, etc.) for the 238 Ritters Lake Road and Project J submitted
PCNs. These plans are necessary to evaluate whether the two projects have independent utility
from each other.
2. Based on the proposed grading and re-routing of drainage into stormwater ponds, the project appears to
eliminate the drainage area/hydrology source for a portion of Wetland WD. Based on LiDAR, the current surface
area draining to the head of Wetland WD appears to be approximately 4 acres.
a. Please provide justification that sufficient hydrologic input will be maintained to these wetlands.
Common designs include routing approximately equivalent surface water/runoff area to these locations,
altering locations of stormwater outlets, usage of French drains where appropriate, etc.
b. If maintenance of wetland hydrology is unable to be justified, 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 upon aquatic function (e.g., North Carolina Wetland Assessment Method [NCWAM]).
c. A monitoring plan (typically including groundwater monitoring wells and visual observations for a period
of 5 years post -construction) to document maintenance of wetland 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
wetland hydrology.
3. The November 3, 2021, Detailed Schweinitz's Sunflower Survey is noted within the submitted PCN; however, as
the survey was conducted over three years ago, the survey is no longer valid according to the U.S. Fish & Wildlife
Service (Service) (North Carolina's federally threatened, endangered, and at -risk plant species I U.S. Fish &
Wildlife Service (fws.gov). Due to the potential habitat identified in the 2021 survey report, the Corps requests
an updated survey be conducted for Schweinitz's sunflower, during the optimal survey window (late August —
October). Following the survey, please provide the survey report to the Corps (copy also the Service) for review.
Of course, if you do not believe that any suitable habitat exists in the Action Area for these species, please
provide a justification so that the Corps is able to evaluate the potential for a No Effect determination.
4. Additional information has come forward regarding the potentially Determined Eligible historic resources on the
property. We are considering the information concerning 106 consultations with SHPO with our regulatory
archaeologist. As soon as additional information is identified, the Corps will inform the applicant regarding
requirements for consultation pursuant to the Section 106 of the National Historic Preservation Act (NHPA).
5. Please note that responses to the questions above may prompt additional information requests to allow full
evaluation of the proposed project.
Please provide the requested information within 30 days (July 12, 2024), or your application will be administratively
withdrawn. To clarify, if the requested information is submitted after the 30-day timeframe, you will not be required to

re -submit an entirely new PCN (unless otherwise specified). We will continue to review and/or process your permit
application upon receipt of the requested information.
Sincerely,
Laura
Laura J. Meyer, PWS
Regulatory Specialist
U.S. Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Phone: [phone]
Email: [e-mail]
rrs.usace.army.mil
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