20170073 Ver 1_Corps of Engineer Correspondence_20170331

Burdette, Jennifer a
From: Dooley, Brennan J CIV USARMY CESAD (US) < [e-mail]
Sent: Friday, March 31, 2017 5:53 PM
To: Dana Lutheran
Cc: Mairs, Robb L; Burclette, Jennifer a
Subject: SAW -2013-02417 Request for Additional Information
Attachments: 2013-02417 RAI.pdf
Dana
Please find a copy of our request for additional information for the above
referenced copy. I will be out of the office next week for training but
should have access to my e-mail if you need to contact me.
Regards,
Brennan Dooley
Regulatory Specialist
U.S. Army Corps of Engineers
Wilmington District (SAW)
69 Darlington Avenue
Wilmington, NC 28403
[phone]
"The Wilmington District is committed to providing the highest level of
support to the public. To help us ensure we continue to do so, please
complete the Customer Satisfaction Survey located at:
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Classification: UNCLASSIFIED
Caveats: NONE
1

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403
March 31, 2017
REPLY TO
ATTENTION OF
Regulatory Division
SUBJECT: File No. SAW -2013-02417; Information Request for Proposed Commercial /
Industrial Development (Camp Davis Industrial Park, Inc.) Including Discharge of Fill Material
into waters of the U.S. (WOUS), located at I Bacon Drive, Holly Ridge, Onslow County, North
Carolina.
Camp Davis Industrial Park, Inc.
Attn: Thomas C. Rollins
Post Office Box 38
Holly Ridge, North Carolina 28445
Dear Mr. Rollins and Ms. Lutheran:
This letter is in reference to your Department of the Army (DA) permit application received
January 18, 2017 submitted to the Wilmington District Corps of Engineers (Corps) for the
construction of a commercial development, at I Bacon Drive, in Holly Ridge, Onslow County,
North Carolina.
The DA permit application is insufficient to fully evaluate your proposal. No further
Regulatory action will be taken until the information requested in items 1-4 is provided, this
information is needed before Regulatory can complete the project review process and make a
permit decision.
The proposed impacts must meet the 404(b)(1) guidelines of the Clean Water Act. The
following detailed information will be needed to assist us in fully evaluating the project:
1. Avoidance: Please provide additional information describing why this particular site was
selected for your project. The application references the presence, quantity and quality or
function of wetlands and/or waters of the US, the presence of any federally -listed threatened
or endangered species or their critical habitat, state listed species, or other natural or
regionally important ecosystem resource factors that may be significantly impacted. Please
provide information about these factors for each alternative site considered, including the
preferred site. Discuss these factors in combination with the other factors listed in your
application to describe why each site was not found to be a practicable alternative, and/or the
least environmentally damaging alternative, and describe/justify the geographic scope used to
determine potentially suitable sites.
2. Minimization: Minimization includes alternate site plans and other steps which would
reduce impacts to on-site waters of the United States (WOUS). Please further describe other

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site plans and minimization steps considered to further minimize the impact of your project on
aquatic resources. This includes information regarding alternate site configurations that were
considered such as reducing the size of the associated infrastructure so that more impacts are
avoided, and/or reconfiguring the location of the proposed infrastructure. Specifically, the
economic, public interest, and environmental implications of each alternative site plan should
be provided. The analysis should document that the wetland and surface water area to be
filled is the minimum area required for the project to be practicable. The combined off-site
and on-site alternatives analysis should provide information specific enough to determine if
the project is the least environmentally -damaging, practicable alternative that meets the
project purpose.
3. Compensatory Mitigation: An appropriate compensatory mitigation plan is required to
fully offset unavoidable impacts to WOUS in accordance with 33 CFR 332 - Compensatory
Mitigation for Losses of Aquatic Resources. The application states that preservation of 2.44
acres of wetlands and 0. 12 acre of RPWs / Tributaries is proposed to offset impacts to aquatic
resources. As described in 33 CFR 332.3 (h), preservation may be used to provide
compensatory mitigation for activities authorized by DA permits when all of the following
criteria are met: (i) The resources to be preserved provide important physical, chemical, or
biological functions for the watershed; (ii) The resources to be preserved contribute
significantly to the ecological sustainability of the watershed. In determining the contribution
of those resources to the ecological sustainability of the watershed, the district engineer must
use appropriate quantitative assessment tools, where available; (iii) Preservation is determined
by the district engineer to be appropriate and practicable; (iv) The resources are under threat
of destruction or adverse modifications; and (v) The preserved site will be permanently
protected through an appropriate real estate or other legal instrument (e.g., easement, title
transfer to state resource agency or land trust). Please provide information that shows these
criteria are met for the proposed preservation.
Once the final mitigation proposal is determined by the Corps to be appropriate, the mitigation
plan must contain the elements described at 33 CFR 332.4(c)(2) through (c)(14).
Additionally, please note the preference for purchasing mitigation bank credits to offset
impacts at 33 CFR 332.3(b). If mitigation bank credit purchase is not proposed, the
justification for utilizing other forms of mitigation should be provided. Finally, the
application states that the aquatic resources to be impacted are low quality. Please provide
information in the form of NCWAM / NCSAM to support this conclusion.
4. A water quality certification is required for the project pursuant to Section 401(a)(1) of the
Clean Water Act. A copy of the State's water quality certification should be sent to the Corps
after it has been obtained.
No action will be taken on it until the requested information in items 1-4 has been
received. The Corps requests that the applicant provide the requested information within 30

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days of the date of this letter. If no response is received by then, the application may need to
be withdrawn. Should you have any questions or comments regarding this request for
additional information, please contact Brennan Dooley at the above address, by phone at (910)
251-4694, or by email at brennan. j. dooley2us ace. anny. mil.
Sincerely,
Digitally signed by
DOOLEY.BRENNAN DOOLEY.BREN NANJOH NA 512992613
DN -US, o–U.S. Government, ou–DoD, ou–PKI,
ou–USA, cn–DOOLEY.BRENNANJOHN.] 512992613
JOHN.1 512992613 Date 2017.03.31 17.49 30 -04W�
Brennan Dooley
Regulatory Specialist
Wilmington Field Office
Regulatory Division
Copies Furnished:
Dana Lutheran (Southern Environmental Group) (via email)
Robb Mairs (NCDWR) via email
Jennifer Burdette (NCDWR) via email