20130428 Ver 2_More Info Received - Email_20170412

Homewood, Sue
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Dave,
Randy Forsythe <[e-mail]>
Wednesday, April 12, 2017 9:32 AM
Bailey, David E CIV USARMY CESAW (US)
Homewood, Sue
Re: [Non-DoD Source] West Burlington Univ. Dr. & Church St. Stream Restoration site PCN for
NW39 Road Crossing
Additional information requested by Wilmington District USACOE_4_l2_l7.pdf
See attached for the requested additional supplemental information regarding Purpose and Need, and Avoidance and
Minimization.
Randy Forsythe
HARP
704-231-5678
On 4/7/2017 2:53 PM, Bailey, David E CIV USARMY CESAW (US) wrote:
Thanks for your email, Randy. I left you a voicemail a few minutes ago regarding
any remaining information necessary for permit processing. This email is intended
to put those requests in writing. I heard back earlier this week from Sue Homewood
(NCDWR) regarding her initial review of the PCN and attachments you submitted. She
brought up some issues to be addressed to tie up project purpose and need and
avoidance and minimization to an acceptable level. Note that Sue may send in
additional items to be addressed from her rules, however I have included below the
items needed for the Corps to continue processing the NWP 39 verification:
Purpose and need for the new road needs to be clarified. Based on the information
sent from the City (attached), the culverted crossing in question is to be part of
Hillier Drive, which will serve to provide access for various development lots,
ostensibly for commercial purposes. Hillier Drive will then continue on to connect
with University Drive. Acknowledgement that the preceding is the case does not
jeopardize the purpose and need for this project. Rather it makes more sense than
the idea that this is just a reconstruction of an access driveway for private
property. Feel free to use the attached map to show the full extent of Hillier
Drive (if still the plan). One item working in your favor is that the overall
development of Hillier Drive and the lots shown is unlikely to impact additional
waters of the US (based on remote sensing) with the exception of the crossing
proposed; additional cumulative impacts are therefore not a tremendous concern. Per
the above, please change the o
verall purpose and need in sections B.3d. and 3e. of the PCN.
Avoidance and minimization efforts need to be clarified. One crossing already
exists over the new stream/wetland area, in the footprint of the old earthen berm.
As such, it is reasonable to ask why this existing crossing will not suffice to
provide access to the area south of the new stream/wetland area for development
purposes. Perhaps the answer is related to NCDOT requirements for the Hillier Drive
through road, or site usage requirements for related development? Perhaps the
business proposed for Lot 1 (attached plans) requires multiple access points and
the existing crossing was required to be maintained due to driveway distance from
intersection requirements? In any case, please clarify why it was not practicable
to avoid the proposed impact by using the existing crossing. Please revise the
avoidance and minimization information as documented in section D.1a. accordingly.
Once the items above are addressed we can proceed with permit processing. Please
let me know if you have any questions.
1

-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
Phone: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]
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.
-----Original Message -----
From: Randy Forsythe [mailto:randy [e-mail]]
Sent: Friday, April 07, 2017 12:58 PM
To: Bailey, David E CIV USARMY CESAW (US)
Subject: [Non-DoD Source] West Burlington
site PCN for NW39 Road Crossing
David,
<[e-mail]>
Univ. Dr. & Church St. Stream Restoration
I passed on your estimate regarding action on the PCN for the road
crossing at the stream restoration site on the corner of Univ. Dr. and
Church St in Burlington to the owners and contractors who are currently
trying to order materials and determine a schedule for site work. If
you think this request is likely to be denied or delayed could you give
me a call: 704-231-5678? The project is financially on a thin edge and
further delays could send things into a tail spin.
Randy Forsythe

Additional information requested by Wilmington District USACOE
The applicant's purpose and need for the project: To construct a crossing for a road (Hillier
Drive), as an attendant feature of mixed use commercial development at a location that is
consistent with the design of an ongoing stream restoration project. The road and crossing
were originally included in plans for a stream restoration project authorized pursuant to NWP
27. The Wilmington District recently determined that only a driveway crossing (DOT Class 1) at
the site of a former dam (breached as part of the restoration project) is appropriate under NWP
27. The restoration project is nearing completion. The attendant road must satisfy NCDOT and
City requirements. Consistent with City rezoning and site plan approvals, the road will abut a
residential community (Glenwood Acres) to the east which currently only has ingress/egress by
means of a single lane road that is overtopped between the 25 and 100 year storm event just
upstream from the restored reach. Hillier Drive will provide a backup means of ingress/egress
for residents and for emergency response vehicles during significant flood events.
The location of Hillier Drive's intersections with Hwy 70 and University Drive (major
transportation corridors) are determined by NCDOT and City requirements that prioritize traffic
safety. Due to NCDOT limitations regarding access to both major roadways, the only means of
providing full ingress/egress for the commercial and adjoining residential users of the project is
construction of internal access roads that connect to Hillier Drive because multiple direct
connections of roads to University Drive or Hwy 70 would not be allowed. The construction of
the Hillier Drive, shown on the attached sketch, is located on the zoning boundary between
residential and commercial areas so as to facilitate the collection of traffic from both areas and
direct that traffic to University Drive and Hwy 70 at points determined by NCDOT to be safe and
manageable distances from the intersection of University Drive and Hwy 70. A short 200'
connector between Huffman Lane (the private road access for Glenwood Acres) and Hillier Drive
is still under development.
The proposed crossing is the only practicable crossing that would satisfy the applicant's purpose
and need and comply with NCDOT and City requirements. For example, the existing Class I
crossing, re-established on the old dam, lies too close to the intersection of Hwy 70 and
University Drive, and would not meet road engineering/safety standards for traffic from the
commercial development or residential communities. Even if the location could have been made
consistent with NCDOT requirements (it could not), additional stream impacts would have been
required for this Class I crossing to be upgraded to meet Class 11 standards.
Avoidance and Minimization: The location and design for the road crossing were and continue
to be an integral component of the design of the ongoing stream restoration project. Features
that avoid and minimize impacts include the following:

Y The design includes grade control and riffle zones that have been designed to avoid
aquatic habitat losses immediately upstream and downstream from the crossing.
Y The crossing alignment minimizes the length of stream impacted.
Y The road crossing engineer has carefully adjusted road approaches and crossing designs
to minimize the height of the crossing in order to further minimize length of stream
impacted.
Y The timing for the installation of the crossing has been targeted to coincide with a final
habitat and QA/QC phase of stream restoration so as to avoid all temporary impacts
from the crossing installation, and allow the installation of cobble riffle armor that can
serve as energy dissipation for the downstream culvert invert locations to further
minimize impacts (both temporary and permanent).
Y Excess (flows over the OHWM) have been carefully designed to be displaced out of the
main stem 72" culvert to elevations above the 'Floodprone' stage (2x Bankfull), so as to
eliminate disequilibrium forces (channel instability) on the stream and provide optimum
conditions for maintaining channel sediment within the stream bed, as well as sediment
transport continuity through the main culvert. This strategy avoids aquatic habitat
losses, and minimizes risk of future channel instability that would otherwise be caused
by directing excess flood discharges through the main culvert.

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