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HomeMy WebLinkAbout20160216 Ver 1_Rebuttal to PN Comments_20160609Burdette, Jennifer a From: Greer, Emily C SAW < Emily.C.Greer@usace.army.mil > Sent: Thursday, June 09, 2016 8:53 AM To: Gerald Pottern; Ellis, John W.; Kevin Lugo Cc: Burdette, Jennifer a Subject: Rebuttal to Hope Mills Dam Public Notice Comments Attachments: e9June2016 SAW -2010-01336 Position Letter.pdf Gerald - Please see the attached position letter for the Hope Mills Dam Project. I have requested a 30 -day turn -around to receive your rebuttal; however, you may provide your response sooner. Feel free to contact me with any questions. Emily Greer Regulatory Specialist Wilmington District- Regulatory Field Office 69 Darlington Ave Wilmington, NC 28403 910.251.4567 (o) Op TSO STATES OEC¢ DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS Wilmington Regulatory Field Office 69 Darlington Avenue Wilmington, North Carolina 28403 June 9, 2016 Regulatory Division Action ID. SAW -2010-01366 Mr. John Ellis, Town Manager Town of Hope Mills 5770 Rockfish Road Hope Mills, North Carolina 28348 Dear Mr. Ellis: We received your application for Department of the Army (DA) authorization to place fill material in approximately 0.89 -acre of jurisdictional wetlands in order to construct a new dam on Rockfish Creek located in the northeast quadrant of the intersection between Lakeview Drive and Main Street in Hope Mills, Cumberland County, North Carolina. Subsequently, re -damming the creek will impact approximately 4.72 acres of existing open water, 11,400 linear feet of streambed, and 23.70 acres of established wetlands. During the Public Notice period, this office received comments from two individuals who expressed concern about the proposed project. Their comments are summarized below and concern property rights and accessibility of the lake for public use by all local citizens. In addition, comments were received from the following government agencies. ■ US Fish and Wildlife Service ■ National Marine Fisheries Service ■ NC Wildlife Resources Commission ■ NC Division of Water Resources A copy of all agency comment letters are attached. Our administrative process provides you the opportunity to propose a resolution and/or rebut any and all objections before a final decision is made; however, additional information is needed prior to a final permit decision on your proposed project. The following comments and requests for information must be addressed in your rebuttal to comments: 1. Avoidance and Minimization: It appears that further avoidance and minimization of 1 impacts to jurisdictional features could be made with alternative site designs that would impound less water. Please see comment 95 for further discussion. 2. Site Development Plan: Please address NMFS's concern of including provisions for diadromous fish passage in the dam design. The applicant states in the application under "Reason(s) for Discharge" that the proposed dam will impound 120 acres; however, under "Potential Impacts to Open Waters, Streams, and Wetlands" the applicant states that 115 acres will be impounded. Also, the provided maps do not seem to coincide with the stated flooded acreage. Please clarify the acreage of impoundment and supply the appropriate mapping to reflect the correct(ed) acreage. 3. Secondary Effects/Flooding/Properiy Rights: Because there is a potential for upstream effects beyond the projected pool area as a result of impounding Little Rockfish Creek, the applicant will need to contact the City of Fayetteville and its Public Works department to ensure that the proposed project (@ 105') will not adversely affect structures, waters, properties, etc. located on or near Rockfish Creek or its tributaries that could potentially be affected by the project. Please provide documentation from the City stating whether potential adverse effects may or may not occur. Be aware that public notice information may need to be disseminated based on the response of the City of Fayetteville and/or their Public Works department if the Corps determines any abutting landowners in the Fayetteville area need to be informed about the project; however, the standard 30 -days of public review will not be reinstituted. There are private landowners upstream of the dam site that will be impacted by flooding after dam construction. To date, the Town has not legally acquired or otherwise compensated these landowners for the condemnation of their property. Please be aware that the permit will be issued with Special Conditions that prevent the applicant from starting construction of the new dam until compensation to these individuals has been accomplished. Please address the comment from NMFS that raises the concern that a smaller dam may not provide sufficient flood storage capacity or alleviate flood risk for downstream communities. The applicant must provide an explanation that addresses NMFS'S statement that recent dam failures have resulted in `a significant economic impact because of a loss of homes and property' to the downstream communities. In addition, the applicant will need to address the known potential flooding effects on approximately 24 mobile homes that are located upstream in the Parkway Mobile Home Park, and which the Town identified. These potential flooding effects on private property are a result of the change in the floodplain for a lake elevation to 105' compared to 104'. Please note that any DA permit authorized for this project will be based on consideration of the above concerns, as well as other issues related to the public interest (and sub -parts to the Section 404(b)(1) Guidelines) such as safety, floodplain management, property ownership, and general environmental concerns. All appropriate permits from local and state government agencies with respect to surface water/stormwater management, and water quality, must be obtained prior to any dam construction. Comments received from the public notice(s), as well as authorizations from the State and local governments will be considered in our analysis of the 2 direct, secondary, and cumulative effects of the proposed project on the environment. Additionally, all information received regarding this project, as well as any proposed changes, may warrant further public involvement, to include additional public notice and public meeting. 4. Purpose and Need: Understanding that the applicant's stated purpose for the proposed project is to dam Little Rockfish Creek in order to provide recreational opportunity to the local community and to meet current dam safety requirements, please provide a justified purpose and need for constructing the dam to impound water to an elevation of 105 feet compared to 104 feet. The response should include data supporting the stated `historical' lake levels presented throughout the permit application and what public benefits justify why this elevation should be maintained with the construction of a new dam. Including a discussion of the recreational opportunities the proposed dam construction will provide for residents that do not reside on the lake itself is essential. This is because the proposed elevation seems to only satisfy the request of the very small number of lakeside residents currently living on the lake; however, no recreational benefit to the rest of the community was discussed in the application. For instance, it appears that the Town currently has approximately 600-800 linear feet of usable shoreline for public use, an approximately 60 -foot long fishing pier, and a single -use boat ramp (i.e., only one motorized boat can launch at a time). Additionally, previous Town policies required a fee of all non -lakeside residents to utilize the boat ramp. How much usable shoreline will accessible with the proposed lake elevation? Does the applicant have intensions of improving the public use space or otherwise expanding it? Based on the stated proposed purpose and need, the limited public use area appears to be inadequate for such a large lake and again begs the applicant to provide a sufficient justification for the need of a lake elevation of 105'. 5. Alternatives: The lack of an Alternatives Analysis discussion does not meet the requirements of the Section 404(b)(1) Guidelines and is insufficient in providing information that can be used to make an informed decision to identify the Least Environmentally Damaging Practicable Alternative (LEDPA). Please provide an analysis that presents a No Build/No Action Alternative, offsite alternatives, and an analysis of onsite iterations of the site development plan. A summary of the process for analyzing alternatives is provided below for your convenience. Because this is a water -dependent project, with the potential for conflict regarding resource use, the applicant should provide a brief narrative supporting that there are no less environmentally damaging practicable alternatives, including alternative locations or designs, available, considering costs, existing technology, and logistics, in order to accomplish the project purpose and need. However, a comparison between the No Action Alternative and the Proposed Onsite Alternatives is required. Please note that the No Action Alternative should address comments from the NMFS and USFWS regarding the removal of the failed dam and the corresponding restoration of Little Rockfish Creek and its riparian zone. 7. Water Quality: Please provide a summary describing soil and erosion control measures to be used during demolition and construction and address how sediment accumulation and a minimum flow will be maintained after project completion (see comments by DWR and WRC). 3 8. Temporary Wetland Impacts: Please clarify what the temporary wetland/stream impacts are versus the permanent impacts if temporary fills are necessary for the proposed demolition and the construction phases. Please be aware that all temporary fills or disturbance must be restored upon project completion (i.e. removal of all access roads). 9. Compensatory Mitigation: Taking into consideration that litigation and lack of funding prevented the Town from addressing the most recent dam failure in a timely manner, which would have likely allowed for the application of Nationwide Permit 3: Maintenance in -lieu of a standard permit, and, thus, would likely not require mitigation, the applicant has requested that mitigation, conducted in the traditional sense of restoration, for the proposed project be waived. However, there are opportunities to offset impacts in a non-traditional sense. The Corps would like to review a proposal of mitigative measures that would provide additional benefits for the public as a result of the project. For example, there are educational opportunities for the citizens of Hope Mills regarding area wildlife and plants or the history of the dam and/or lake. Expanded recreational opportunities for all residents would also be favorable in mitigating for impacts (see USFWS comment letter). Please feel free to contact the Corps project manager to discuss other potential opportunities for non-traditional mitigation. Please also address NCDWR's comment regarding their requirements for compensatory mitigation in your response. You may provide all of the information requested above to me via email, on or before July 8, 2016. Thank you for your time and cooperation. Feel free to contact me by email at Emily. c.greergusace, army.mil, or by phone at (910) 251-4567 if you have any further questions concerning the processing your application and coordinating with the review agencies. Sincerely, GREER.EMILY. GREE ally signed GREEllEMILY..by b 85325300 DN: c=US, o=U.S. Government, ou=DoD, ou="l,ou=USA, C.1385325300 cn=G REER.EM ILY.C.1385325300 Date: 2016.06.09 08:46:53 -04'00' Emily Greer Regulatory Specialist Enclosures Cc/Electronically provided: Mr. Gerald Pottern, Robert J. Goldstein and Associates, Inc. Ms. Jennifer Burdette, Division of Water Resources I Raleigh Field Office Post Office Box 33726 ZVJMM Emily Greer U.S. Army Corps of Engineers, Wilmington District Wilmington Regulatory Field Office 69 Darlington Avenue Wilmington, NC 28403 MEMM��� it M-UV-Mff=- J The U.S. Fish and Wildlife Service (Service) has reviewed the project advertised in the above referenced Public Notice. The Service believes the stated purpose of protecting the bridge can bc met with a less damaging alternative than the one proposed and recommends the applicant conduct an alternatives analysis that considers removing the remains of the failed darn. Dam removal would benefit the environment by restoring free flowing stream conditions, restoration of natural floodplain and riparian wetlands and remove any obstacle to the movement of migratory fish. Removing the remains of the failed structure should be much less expensive and the old lake bed could be used as a recreational park (http:,/lwww.americanrivers.org/newsroom/resources/taking-a-second-loo . There may be such as American Rivers which would allow the town to spend its money for other priorities. Dam removal would remove any risk to the town of another expensive dam failure that could result from hurricanes or from sinkholes forming in the lake bottom and also remove liability to the town from accidental drowning that can be associated with dams. It would also remove the environmental risks downstream associated with dam failure such as large uncontrolled release of sediment. Y fie project as proposea is not i defined by the Endangered Species Act of 1973 as amended (ESA). Therefore the requiremen of section 7 (a)(2) of the ESA have been satisfied for this project. Please remember thira obligations under the ESA must be reconsidered if. (1) new information identifies impacts of t action that may affect listed species or critical habitat in a manner not previously considered; (1, this action is modified in a manner that was not considered in this review; or (3) a new species I listed or critical habitat determined that may be affected by the identified action. The Service appreciates the opportunity to review and provide comments on the proposed action. Ef the project moves forward as proposed, to reiterate, the Service believes that removing the remains of the existing darn would be the less damaging alternative to protect the bridge. Should you have any questions regarding the project, please contact Mike Wicker at (919) 856-4520 extension 22. cc: NMFS, Beaufort, NC EPA, Atlanta, GA WRC, Raleigh IQ North Carolina Wildlife Resources Commission Gordon Myers, Executive Director MEMORANDUM TO: Jennifer Burdette, Raleigh Regional Office N.C. Division of Water Resources FROM: Gabriela Garrison �L , 6 Eastern Piedmont Coordinator Habitat Conservation DATE: June 1, 2016 SUBJECT: Pre -Construction Notification for Hope Mills Dam Repair, Cumberland County, North Carolina. Corps Action ID 4.: SAW -2010-01336; DWR Project No.: 20160216. Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as amended), Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e), and North Carolina General Statutes (G.S. 113-131 et seq.). The applicant proposes to impact `open waters', to include a portion of the existing spillway that normally conveys water (0.31 acre), the lower end of the diversion channel above the spillway (0.12 acre) and two shallow pools on either side of the spillway, contiguous with the main channel during high flows (0.46 acre). The purpose of the project is to repair the Hope Mills Dam on Little Rockfish Creek, specifically the spillway which failed in 2008. There will be no stream or wetland impacts as a result of construction. Upon completion, refilling the lake will flood 4.72 acres of semi -impounded channel above the spillway, 8,500 feet of perennial stream, 2,900 feet of tributaries, 16.02 acres of forested wetlands and 7.68 acres of marsh/shrub wetlands. Work will include installing a cofferdam to isolate and dewater the right half of the spillway, followed by demolition and excavation of the right half of the existing spillway. Once this portion of the spillway has been constructed, a cofferdam will be used to isolate and dewater the left half of the existing spillway, followed by dewatering and demolition of the left half of the existing spillway. Once the left half of the spillway has been constructed, a 3rd cofferdam will be installed to isolate and dewater the right half of the new spillway, diverting flow through the drain gate on the left side. After construction on the right half of the new spillway is complete, the drain gate will be closed to allow refilling to occur. There are records for the state -significantly rare, Sandhills spiny crayfish (Cambarus hystricosus) in Little Rockfish Creek, downstream of the proposed site. The Natural Heritage Program Natural Area — Rockfish Creek Corridor — is located downstream of the site. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Page 2 June 1, 2016 Hope Mills Dam Repair Corps Action ID No.: SAW -2010-01336 DWR Project No.: 20160216 Should the permit be issued, the NCWRC offers the following recommendations to minimize impacts to aquatic and terrestrial wildlife resources: 1. The minimum release flow should be maintained during repair activities in order to protect downstream aquatic resources. The applicant should coordinate with the N.C. Division of Water Resources regarding any required minimum flow releases following completion of the dam repairs. 2. A silt curtain or other means to contain sediment should be used to minimize turbidity in Little Rockfish Creek. 3. Concrete is toxic to aquatic life and should not be allowed to come in contact with surface waters until cured. 4. Sediment and erosion control measures should be installed prior to any land -disturbing activity. The use of biodegradable and wildlife -friendly sediment and erosion control devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have loose -weave netting that is made of natural fiber materials with movable joints between the vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh should be avoided as it impedes the movement of terrestrial wildlife species. Excessive silt and sediment loads can have detrimental effects on aquatic resources including destruction of spawning habitat, suffocation of eggs and clogging of gills. Thank you for the opportunity to review and comment on this project. If I can be of further assistance, please contact me at (910) 409-7350 or gabriela.garrison(a),ncwildlife.org. ec: Emily Greer, USACE (Sent via Electronic Mail) UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE Southeast Regional Office 263 13th Avenue South St. Petersburg, Florida 33701.5505 http://sero.nmfs.noaa.gov May 6, 2016 Colonel Kevin P. Landers Sr., Commander U.S. Army Corps of Engineers Wilmington District 69 Darlington Avenue Wilmington, North Carolina 28403-1398 Attention: Emily C. Greer Dear Colonel Landers: F/SER47:KR/pw NOAA's National Marine Fisheries Service (NMFS) has reviewed the public notice for Action ID No. SAW -2010-01336, dated April 7, 2016. The Town of Hope Mills seeks authorization for work that includes demolition of an existing failed dam and construction of a new dam within the waters and associated wetlands of Little Rockfish Creek in Cumberland County. The Wilmington District's initial determination is the proposed project would not affect essential fish habitat (EFH) or associated fisheries managed by South Atlantic Fishery Management Council (SAFMC), the Mid -Atlantic Fishery Management Council (MAFMC), or NMFS. The NMFS agrees the proposed project is not within areas designated EFH, and the NMFS accordingly offers no comments under the authorities of the Magnuson - Stevens Fishery Conservation and Management Act. As the nation's federal trustee for the conservation and management of marine, estuarine, and anadromous fishery resources, the NMFS provides the following comments and recommendations pursuant to authorities of the Fish and Wildlife Coordination Act. Description of the Proposed Project The Town proposes to replace a dam that failed in 2010 and drained the 120 -acre Hope Mills Lake. As a result of chronic erosion, the remaining dam infrastructure poses a threat of failure for the nearby Lakeview Road Bridge, an important thoroughfare for the community. The Town proposes to construct a smaller dam that would restore the lake to normal pool elevation, while providing services for flood storage and recreation. The project seeks to reduce the risk and threat of failure for Lakeview Road Bridge by structurally separating the dam from Lakeview Road. The new spillway would be smaller than the existing structure and constructed entirely within the existing footprint of the failed dam. The environmental impacts of construction activities include temporary fill of 0.23 acres of open water for the cofferdam installation and permanent fill of 0.66 acres of open water for construction of the new spillway and foundation. Upon completion and once the lakebed refills, the dam would have impounded water to its historical level of 106 feet in elevation, impacting 4.72 acres of open water, 11,400 linear feet of streambed, and 23.70 acres of wetlands that have established since the 2010 dam failure. According to the public notice, the Wilmington District would waive mitigation requirements for the loss of wetlands and re -flooding the lakebed. Comments on Habitat Conservation The NMFS believes the applicant should consider and present alternatives for dam replacement, including removal of dam infrastructure and restoration of Little Rockfish Creek to re-establish the hydrology, hydraulics, and geomorphic conditions of the stream and riparian areas. Restoration of the stream could be a long-term cost-effective solution for improving water quality and upland watershed issues while providing important fish habitat and unimpeded fish passage. With recent dam failures (2003 and 2010), the NMFS is concerned construction of a smaller dam would not provide the necessary flood storage or reduce the risk of flooding for communities downstream in the watershed of the Cape Fear River. Flooding from the recent failures has resulted in a significant economic impact because of a loss of homes and property. The applicants should provide additional information on engineering, technical specifications, and risk analysis to justify construction of a new dam in a period -of -time when emphasis is placed on dam removal and habitat restoration. The NMFS believes the new spillway should include provisions for diadromous fish passage. The public notice does not include any description or engineering specifications for fish passage systems or monitoring programs for fish passage. The Cape Fear River and Little Rockfish Creek include spawning, foraging, or migration habitat for American shad (Alosa sapidissima), striped bass (Morone saxatilis), and American eel (Anguilla rostrata). The NMFS would be happy to assist the applicant with reviewing designs of fish passage systems and monitoring programs. The NMFS recommends the project design should include measures to reduce construction impacts, including noise disturbance, sediment and toxicant input into streams and rivers, and direct physical injury, which threatens diadromous fish and their habitats. Environmental windows (seasonal restrictions) should be prescribed for the timing of construction activities to protect protected species and fish during sensitive life history phases (e.g., reproduction, migration). Work should not occur during times designated by the North Carolina Wildlife Resources Commission, the U.S. Fish and Wildlife Service, and the NMFS for protection of fish or wildlife resources. Lastly, the NMFS recommends the Wilmington District examine whether loss of freshwater wetlands associated with this project could adversely affect water quality as this habitat filters pollutants and facilitates transport of organic material, and impacts to streams can permanently eliminate habitats used by aquatic organisms. Thank you for the opportunity to provide these comments. Please direct related questions or comments to the attention of Dr. Ken Riley at our Beaufort Field Office, 101 Pivers Island Road, Beaufort, North Carolina 28516-9722, or at (252) 728-8750. cc: COE, Emily.C.Greer@usace.army.mil USFWS, Pete_Benjamin@usfws.gov NCDCM, Doug.Huggett@ncmail.net NCDCM, Gregg.Bodnar@ncdenr.gov EPA, Bowers.Todd@epa.gov SAFMC, Roger.Pugliese@safmc.net F/SER4, David.Dale@noaa.gov F/SER47, Ken.Riley@noaa.gov PA / for Sincerely, 2 ,r CICS' 11& Virginia M. Fay Assistant Regional Administrator Habitat Conservation Division �Y," 11 "J �p Water Resources ENVIRONMENTAL QUALITY Town of Hope Milles Attn: Mr. John W. Ellis 5770 Rockfish Road Hope Mills, NC 28348 Subject: REQUEST FOR ADDITIONAL !NFORIVIATION Hope Mills Dam & Lake Restoration I -6 �-I 11+71 PAT MCCRORY DON'ALD R. VAN DER V'AART' Socrelarr S. JAY ZIMMERMAN On March 2, 2016, the Division of Water Resources (Division) received your application dated January 22, 2016, requesting an individual Water Quality Certification from the Division for the subject project. The Division has determined that your application is incomplete and cannot be processed, The application is on -hold until all of the following information is received-. Mitigation is required for losses of equal to or greater than 1 acre of wetlands. Please provide a mitigation plan that conforms to the reqements of 15A AC 02H 0506(h) for 7.68 acres of marsh and shrub wetlands that will be converted to open water by tht proposed project. Mitigation proposals must provide for the replacement of wetland acres lost at a minimum of 1:1 ratio through restoration or creation unless, the Director 4etermines that the public good would be better served by other types of mitigation. 2. Provide documentation of the normial pool elevation between 105 and 106 feet reported for the lake from 1923 to 2003. Please note that the certification will be conditioned to require a water quality and quantity plan for maintaining and monitoring minimum water release and'meeting dissolved oxygen and temperature water quality standards before the approved impacts may occur. The plan must include the following information and may be submitted prior to issuance of the certification [15A NCAC 02B.0506(3)j- A monitoring plan including locations, frequiency, water quality parameters, and method of measurement. la Ic of N ort I I Ca ro I I na Environmental Quafity � W � (�so ' a er R urycs 1617 M a � I Sc ry ic c Cn tc r � Ra I v i gh, N orl h Ca ro I Ina 2 7 ()99 - 16& 7 919 8()7 6300 Page 2 of 2 Pursuant to Title 15A NCAC 02H .050I2(e), the appl'icant shall furniish all of the above requested information for the proper consiideration of the application. If all of the requested information is not received in writing within 30 calendar days of receipt of this letter, the Diivision will be unable to approve the application and it will be returned. The return of this project will necessitate reapplication to the Division for approval, including a complete application packag&. !mnd the appropriate fee. P lea se respon d 1 n writ ing with i n! 30 ca len da r d ays of recei pt of th is I etter by send i ng th ree copies of all of the above requested information to the 401 & Buffer Permitting Branch, 16 Mail Service Center, Raleigh, NC 27699-1617. 1 Please be aware that you have no authorization under the Section 401 of the Clean Water Act for this activity and any work done within waters of the state may be a violation of North Carolina General Statutes and Administrative Code. concerns. Sincerely, Karen Higgins, Supervisor 401 & Buffer Permitting Branch 174we =-. rlff��* 17MIAM0 ro bffl= �� W414MMMI.- 1WR FRO 401 file wWR 401 & Buffer Permitting Branch file-- Iq I MERE= u STATE �a 4 North Carolina Department of Natural and Cultural Resources State Historic Preservation Office Ramona M. Bartos, Administrator Governor Pat McCrory Office of Archives and History Secretary Susan Klutz Deputy Secretary Kevin Cherry April 29, 2016 Emily Greer Wilmington Regulatory Field Office 69 Darlington Avenue Wilmington, NC 28403 Re: Demolish Dam & Construct Spillway within Project Footprint, Hope Mills, SAW 2010-01336, Cumberland County, ER 16-0632 Dear Ms. Greer: We have received a public notice concerning the above project and offer the following comments. There are no known archaeological sites within the proposed project area. Based on our knowledge of the area, it is unlikely that any archaeological resources that may be eligible for inclusion in the National Register of Historic Places will be affected by the project. We, therefore, recommend that no archaeological investigation be conducted in connection with this project. It appears improvements proposed to the dam and spillway at Hope Mills Lake will not adversely, a� the National Register -listed Hope Mills Historic District (CD0141), as work will be limited to the current footprint of the dam and spillway, may prevent damage to neighboring historic properties, and will protect the Lakeview Road Bridge. Although the staging area for the project lies within the boundaries of the historic district, it appears the worksite will be accessed by a dirt road, which winds from the staging area under the Lakeview Road Bridge to the dam and spillway. The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or environmental.review(a�nc, dcr.�4ov. In all future communication concerning this project, please cite the above referenced tracking number. Sincerely, Ramona M. Bartos Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: (919) 807-6570/807-6599