20100899 Ver 3_Corps of Engineer Correspondence_20170424

Regulatory Division
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
Action ID: SAW -2010-00061
Mr. Jeff Richardson
County Manager
Cleveland County Government
Post Office Box 1210
Shelby, North Carolina 28151
Dear Mr. Richardson:
April 24, 2017
Please reference the application for an Individual Department of the Army (DA) Permit
submitted on your behalf on February 2, 2018, by Clearwater Environmental Consultants,
Incorporated to discharge fill material into 1,792 linear feet of stream and 0.062 acre of wetlands
associated with the expansion of the Clearwater Paper Shelby tissue manufacturing facility. The
proposed project includes the construction of a 2.5 million square foot building as well as the
installation and/or improvement of surrounding private and municipal utilities. Cleveland County
has elected to be the applicant for the proposed project because the project area is currently
owned by the County and the sewer and water lines will be owned and managed by the County.
The project site is located 0.5 miles southeast of the intersection of West Cabaniss Road and
Farmville Road in Shelby, Cleveland County, North Carolina.
The project was advertised by public notice on February 17, 2017. Comments in response to
the notice were received from the National Marine Fisheries Service, the U.S. Fish and Wildlife
Service (USFWS), the North Carolina Department of Cultural Resource, the North Carolina
Wildlife Resources Commission (NCWRC), the North Carolina Division of Water Resources
(NCDWR), and the U.S. Fish and Wildlife Service (USFWS). These comments are enclosed for
your information. Please provide written responses to the comments submitted by the NCDWR,
the NCWRC, and the USFWS.
In addition to conducting a public interest review which balances the reasonably expected
benefits against the reasonably foreseeable detriments, all Clean Water Act (CWA) Section 404
permits must meet guidelines for the specification of disposal sites for dredged or fill material
under CWA Section 404(b)(1). These comments are being submitted pursuant to the Clean
Water Act Section 404(b)(1) guidelines (40 CFR 230).

-2 -
With respect to the project purpose, its analysis is a critical first step in the Corps permitting
process. The Corps is responsible in all cases for independently defining the project purposes
from both the applicant's and the public's perspective. Initially, the Corps evaluates a project's
"basic purpose" to assess whether the project is water dependent. Once the Corps has determined
the water dependency of the project, it no longer considers the basic project purpose, but
analyses practicable alternatives in light of the "overall project purpose". The overall project
purpose must be specific enough to define the applicant's need, but not so restrictive as to
preclude an analysis of reasonable alternatives.
The basic project purpose stated in the application is to make and convert tissue paper into
usable products for the home and commercial markets. The overall project purpose stated in the
application is to expand tissue paper making and converting capacity to meet market demands. In
considering the overall project purpose, we have determined that this project purpose is too
vague. Accordingly, we have determined that the overall purpose of this project is to expand
tissue paper making and converting capacity to meet the Southeastern United States market
demand.
We have completed our initial review of the application and determined that the following
additional information is necessary to expeditiously complete our permit decision:
1. The application states that Clearwater Paper Corporation was willing to consider sites
other than the proposed project site for the development of the proposed facility.
Multiple siting criteria are discussed in the application. However, the criteria is vague
and cannot reasonably be used to compare offsite alternatives to determine whether
they are reasonable or practicable. For example, the minimum property size
requirement necessary to fulfill the overall project purpose is not clear. In terms of
property availability, it is unclear how close the facility must be to the existing
facility to satisfy the overall project purpose. Additionally, it is not clear how far the
facility needs to be from railways, interstates, existing utilities, and the existing labor
force. In terms of cost efficiency, it is unclear what constitutes a reasonable cost for a
project of similar type, scope, and size. Please revise the siting criteria accordingly.
2. During our onsite pre -application meeting on September 21, 2016, Mr. Brian
Hoaglund of Clearwater Paper Corporation stated that multiple offsite alternatives
within the market area were being considered for the proposed project. However, the
application only discusses using existing offsite facilities already owned by the
applicant and outside of the market area. Please explain the efforts that have been
taken by the Clearwater Paper Corporation to locate other offsite alternatives within
the market area. Please explain whether these alternatives are reasonable or
practicable in light of the siting criteria and the overall project purpose. It may be
helpful to create a map that shows the extent of the market area, the location of the
proposed site, and the location of other similar sites within the market area.
Alternatives that are determined to be reasonable and practicable will be compared
with the applicants preferred alternative to determine the least environmentally
damaging practicable alternative as required by the 404(b)(1) guidelines.

-3-
3. Please submit a consolidated set of plans that depict, in detail, all proposed impacts to
waters of the United States associated with the proposed project. This includes all
impacts associated with the proposed Clearwater Paper facility as well as the impacts
associated with the required utility improvements and expansions. The plans should
include all temporary and permanent impacts including rock dissipation pads if
applicable and all fills for temporary access and dewatering. The plans should be
sequentially numbered and dated.
4. It appears that land outside of the boundaries of the preliminary jurisdictional
determination issued on January 23, 2017, has been added to the project area. This
land includes but is not limited to the parcel identified as parcel identification number
2528109438. Please revise the waters of the United States delineation to include the
entire project area.
5. We have evaluated the conceptual compensatory mitigation proposal included in the
application. We have determined that, if the permit is issued and credits are purchased
from the North Carolina Division of Mitigation Services, compensatory mitigation at
a ratio of 0.5:1 would be required for the low quality intermittent stream impacts, a
ratio of 2:1 for high quality perennial stream, a ratio of 1.75:1 for medium quality
perennial stream, and a ratio of 0.75:1 for medium quality intermittent stream. Please
revise the mitigation plan accordingly and submit a final mitigation proposal. A final
mitigation plan is required before we can make a decision on the individual permit
application.
6. It appears that outbuildings and/or parking areas located at the northeast corner of the
main building could be moved to the southwest of the main building to avoid or
minimize impacts 3 and 4. Please revise the plans to avoid these impacts or provide a
detailed explanation of why it is not practicable to avoid or minimize these impacts.
The NCDWR has also expressed this concern in their comment letter dated March 9,
2017 (item 3).
Additionally, if an individual DA permit is issued for the proposed project, the Individual DA
Permit issued on June 25, 2015, under the file number SAW -2010-00061 will no longer be valid
because the proposed project would satisfy the purpose of that project.
The information requested above is essential to the expeditious processing of the application; please
submit one consolidate response to all comments by May 31, 2017. If you do not submit this
information within the given timeframe, then the application will be administratively canceled.
Cancellation of the application does not preclude you from reopening the application at a later time,
provided you submit the required information.
If you have any questions regarding these matters, please contact me at [phone] or
David.L. Shaeffer(ausace.army.mil.

ME
Sincerely,
David L. Shaeffer
Project Manager
Charlotte Field Office
Enclosures
cc (via Email):
Brian Hoaglund
Clearwater Paper
Brian.Hoa lg und(cr�,clearwaterpaper.com
Clement Riddle
Clearwater Environmental Consultants, Inc.
clement ewenv.com
Sue Homewood
NC Division of Water Resources
sue.homewood(c�r�,ncdenr. gov
Digitally signed by
SHAEFFER.DAVID.LEIGH.1260750573
DIV: Ko UGovernment, ou=DoD,
ou=PI,ou=SA,
c n=SH AEF F E R. DAV I D.LE IGH.1260750573
Date: 2017.04.2411:07:39 -04'00'

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
March 24, 2017
David Shaeffer
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Wetland Fill for the Expansion of Clearwater Paper Corporation, Shelby, SAW 2010-00061,
Cleveland County, ER 17-0380
Dear Mr. Shaeffer:
We have received a public notice concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
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.reviewgncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
�TvRamona M. Bartos
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 276994617 Telephone/Fax: [phone]-6599

United States Department of the Interior
Mr. David Schaeffer
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
March 20, 2017
USACE Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina, 28801-5006
Dear Ms. Schaeffer:
Subject: Washburn Switch — Clearwater Paper Facility Expansion; Cleveland County, North
Carolina
Log No. 4-2-17-082
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the
Public Notice issued February 17, 2017 whereby you solicit our comments on the proposed
project and initiated informal consultation with this office. We submit the following comments
in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended
(16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321 et seq.); and
section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).
Project Description
According to the information provided, Mr. Jeff Richardson (Cleveland County Manager), is
seeking Department of Army authorization to expand an existing Clearwater Paper Corporation
tissue paper manufacturing facility on approximately 266 acres near Shelby, North Carolina.
The proposed project would result in permanent loss of 1,578 linear feet of stream and 0.03 acre
of wetlands associated with the construction of a paper facility, roadways, railway, and
appurtenant structures. The proposed development would also require several miles of new
construction or the expansion of existing utility lines (water, gravity sewer, force main sewer,
and gas). The proposed utility line construction would result in several temporary stream
impacts totaling 214 linear feet, and several wetlands impacts totaling 0.032 acre.
The Applicant proposes to purchase stream mitigation credits from NCDMS. The proposed
mitigation ratios are 1:1 (for impacts to 263 linear feet) and 2:1 (for impacts to 1315 linear feet).
The NCSAM scores for these streams vary (low, medium and high).
Federally Listed Endangered and Threatened Species
According to Service records, suitable summer roosting habitat may be present in the project
area for the federally threatened northern long-eared bat. However, the final 4(d) rule (effective

as of February 16, 2016), exempts incidental take of northern long-eared bat associated with
activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150
feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on
the information provided, the project (which may require additional tree clearing) would occur at
a location where any incidental take that may result from associated activities is exempt under
the 4(d) rule.
The federally threatened dwarf -flowered heartleaf (Hexastylis naniflora) occurs within the
project area and several occurrences occur in the vicinity of the project. On September 15-16,
2015, approximately 126 individuals of this species were relocated to a location outside of the
proposed impact area. An additional 70 plants were observed at that time and were left in place
as the proposed development configuration would avoid impacts to this area. Service staff
observed the relocation site on September 21, 2016, and found that recent vegetation clearing
along the adjacent overhead powerline right-of-way likely created suboptimal habitat conditions
(i.e. more sunlight exposure and susceptibility to soil drying) for approximately 15-30 plants.
These plants were relocated to adjacent suitable habitat on January 10, 2017.
To further reduce the probability of take, we request that the population left in place
(approximately 70 near proposed entrance road, Jordan Drive) be surrounded by construction
fencing (or some other temporary barrier) during construction and contractors should be
instructed to avoid this sensitive plant area prior to beginning work.
The Service is concerned about the potential direct, indirect, secondary, and cumulative impacts
to dwarf -flowered heartleaf associated with the several miles of proposed utility lines that would
be necessary to support the project. Service records show that this species occurs throughout the
vicinity of the proposed utility lines. This plant grows along shaded bluffs and often north -
facing slopes, boggy areas along streams, and adjacent hillsides and ravines. It often associates
with mountain laurel and/or pawpaw and requires acidic, sandy loam soils. We request that the
Applicant survey for this species where the proposed utility lines may impact its suitable habitat.
Survey results would generate essential information to support an informed, precise action
agency determination.
The Service has record of no other federally protected species or suitable habitat for those
species in the project area.
Mitigation
The Applicant proposes to mitigate for the proposed permanent impacts to Waters of the U.S.
through payment into the NCDMS at a 1:1 and 2:1 ratio. The Service believes that a minimum
2:1 mitigation ratio is appropriate for the proposed impacts with a "medium" NCSAM ranking,
and that a minimum 3:1 mitigation ratio is appropriate for impacts to streams ranked "high".
2

The Service appreciates the opportunity to review this project. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-17-082.
Sincerely,
- - original signed - -
Janet A. Mizzi
Field Supervisor
E.c. Olivia Munzer; NCWRC
Alan Johnson; NCDEQ
Clement Riddle; Clearwater Environmental
3

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: David Shaeffer,
Asheville Regulatory Field Office
United States Army Corps of Engineers
FROM: Olivia Munzer
Western Piedmont Coordinator
Habitat Conservation
DATE: 17 March 2017
SUBJECT: Individual Permit Application for the Clearwater Paper Corporation Facility Expansion,
Cleveland County; USACE Action ID SAW -2010-00061 & SAW -2011-02398, DEQ
Project No. 201008990.
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) and Fish and Wildlife Coordination Act Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661 et seq.).
Clearwater Paper Corporation has submitted and Individual Permit (IP) application for the expansion of
the manufacturing facility and associated infrastructure. The approximately 266 -acre project area is
located north of the United States Highway 74 Shelby Bypass and east of Washburn Switch Road in
Shelby, Cleveland County, North Carolina.
The proposed project would cumulatively impact a total of 1,682 linear feet (If) streams and 0.12 acres of
wetlands, of which 1041f of streams and 0.09 acres of wetlands were impacted during construction of the
existing facility. In -lieu fees for 2,9971f of streams would be paid as mitigation to N.C. Division of
Mitigation Services. The proposed project would impact unnamed tributaries to Bushy Creek, which is a
tributary to the First Broad River in the Broad River basin. Bushy Creek is classified as a Class C stream
by N.C. Division of Water Resources (NCDWR).
We have records for Broad River spiny crayfish (Cambarus spicatus), Carolina foothills crayfish
(Cambarus johni), and seagreen darter (Etheostoma thalassinum) in Bushy Creek. Broad River spiny
crayfish is federal species of concern (FSC) and state species of special concern; Carolina foothills
crayfish is a FSC and state significantly rare (SSR) species; and seagreen darter is a SSR species. As
indicated in the IP application, C1earWater Environmental Consultants, Inc. documented dwarf -flowered
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
17 March 2017
Clearwater Paper Corporation
DEQ Project No. 201008990
heartleaf (Hexastylis naniflora), a federally threatened species, on the property and relocated plants to
areas that would remain unimpacted by the proposed project.
Due to the sensitive resources within the vicinity of the proposed project, we offer the following
recommendations to further minimize impacts to aquatic and terrestrial wildlife resources.
1. Maintain a minimum 100 -foot undisturbed, native, forested buffer along perennial streams, and a
minimum 50 -foot buffer along intermittent streams and wetlands. Maintaining undisturbed,
forested buffers along these areas will minimize impacts to aquatic and terrestrial wildlife
resources, water quality, and aquatic habitat both within and downstream of the project area.
Also, wide riparian buffers are helpful in maintaining stability of stream banks and for treatment
of pollutants associated with urban stormwater.
2. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. Where feasible, trees and
shrubs should be planted around stormwater ponds. This would provide habitat benefits that
offset those functions lost by development, partially restore aquatic habitats, reduce exposure of
the water surface to sunlight to minimize thermal pollution, and provide essential summer and
winter habitats.
3. Where practicable, bridges should be used for all permanent roadway crossings of streams and
associated wetlands to eliminate the need to fill and culvert. If culverts are used, culverts should
be designed to allow passage of aquatic life during low flow or drought conditions. Culverts 48
inches in diameter or larger should be buried one foot into the streambed. Culverts less
than 48 inches in diameter should be buried to a depth equal to or greater than 20% of their size.
If sufficient slope exists, baffle systems are recommended to trap gravel and provide resting areas
for fish and other aquatic organisms. Culverts or pipes should be situated so no channel
realignment or widening is required. Any riprap used should not interfere with aquatic life
movement during low flow.
4. Use non-invasive native species and Low Impact Development (LID) technology in landscaping.
Using LID technology in landscaping will not only help maintain the predevelopment hydrologic
regime, but also enhance the aesthetic and habitat value of the site. LID techniques include
permeable pavement and bioretention areas that can collect stormwater from driveways and
parking areas. Additional alternatives include narrower roads, swales versus curbs/gutters and
permeable surfaces such as turf stone, brick, and cobblestone.
5. Manage non-native, invasive species by pretreating the project site prior to construction,
preventing spread during construction, and control non-native, invasive species throughout the
monitoring period.
6. Re -seed disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures because fescue is invasive and provides little benefit to wildlife. Using native species
instead of ornamentals should reduce the need for water, fertilizers, and pesticides. We also urge
the Clearwater Paper Corporation to incorporate pollinator species into their plantings. Further
information and free technical guidance from NCWRC is available upon request.
7. Sediment and erosion control measures should use advanced methods and 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.

Page 3
17 March 2017
Clearwater Paper Corporation
DEQ Project No. 201008990
Thank you for the opportunity to review and comment on this project. If I can be of further assistance,
please contact me at [phone] or olivia.munzer@a ncwildlife.org.
ec: Karen Higgins, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service
W. Thomas Russ, NCWRC

K; Ira.
Water Resources
Environmental Quality
March 9, 2017
Clearwater Paper Corporation
Attn: Brian Hoaglund
601 W. Riverside Ave
Spokane WA 99201
Subject: REQUEST FOR ADDITIONAL INFORMATION
Clearwater Paper Corporation Cleveland County Facility Expansion
Dear Mr. Hoaglund:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
DWR # 2010-0899 v3
Cleveland County
On February 3, 2017, the Division of Water Resources — Water Quality Programs (Division) received your
application dated January 31, 2017, requesting an Individual Water Quality Certification from the Division
for your 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:
1. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. [15A
NCAC 02H .0502(c)]
Pursuant to 15A NCAC 02H.0506(a) a 401 Water Quality Certification may only be issued upon
determining that existing uses are not removed or degraded by a discharge to classified surface
waters. Based on the information provided in the application and associated documents, all
surface flow from the drainage area to Impact #2 will be replaced with impervious area that is
proposed to be rerouted through a stormwater control measure. The discharge/outlet from the
measure is proposed to be located a significant distance downstream. In addition, all surface flow
from the drainage area to Impact #3 will be replaced with impervious area that is proposed to be
rerouted through a stormwater control measure and the discharge/outlet from the measure will be
directed to another stream. The rerouting of the drainage areas and surface flows has the
potential to remove existing hydrology and therefore remove existing uses within these stream
channels from the impact limits to the proposed stormwater outlet location/confluence with
another stream channel. Please provide a thorough analysis and any additional information relative
to this issue for further review by the Division.
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone: [phone] FAX: [phone]

Clearwater Paper Corporation
DWR# 2010-0899 v3
Request for Additional Information
Page 2 of 3
Please provide more details regarding avoidance and minimization of the impacts for this project.
[15A NCAC 02H .0506(f) and (g)]. This Office believes that the area within the northeast corner of
the development labeled on the plans as parking can be moved or reconfigured uitilizing adjacent
upland on adjacent property to the southwest that was evaluated at early stages within this
proposal in order to avoid or minimize impacts #3 and impacts #4. Please revise the plans to avoid
the impacts or provide a detailed explanation of why this plan for the activity cannot be practically
accomplished, reduced or reconfigured.
4. Please clarify whether the Division of Energy, Mineral and Land Resources will require riprap within
any stream channels or wetlands as part of the Erosion & Sedimentation Control Plan approval. If
riprap is required, please enumerate and clearly label the temporary and permanent impacts on
the site plan and submit a channel restoration detail. Riprap must be located below the stream bed
elevation. [15A NCAC 02H .0506(f) and (g)]
5. For the impacts within the utility corridors, some of the proposed stream crossings are not aligned
as perpendicular crossings. Please re -configure your proposed stream crossings to show it aligned
approximately perpendicular (between 75° and 105°) to the stream or provide justification for any
non -perpendicular crossings. [15A NCAC 02H .0506(b)(2)]
6. Please provide a detailed engineering plan, profile view, and cross-section of all proposed culverts.
These drawings must include details regarding stream alignment in relation to pipe alignment, pipe
slope, pipe burial, and dissipater pad. [15A NCAC 02H .0502(b)]
7. All work must be done "in the dry" to protect downstream water quality, therefore dewatering
methods will be necessary to temporarily dewater the stream channel during pipe installation.
Please provide a construction sequence that details the method of dewatering to be utilized at the
site and the sequence of construction events to be followed to ensure compliance with this
condition. In addition, please ensure that the location of the temporary impacts are shown on the
construction drawings and clearly indicated in a revised impact table. [15A NCAC 02H .0502(b)(3)]
8. Please provide a complete Stormwater Management Plan for this project. A complete SMP shall
include:
Stormwater management shall be provided throughout the entire project area in
accordance with 15A NCAC 02H .1003. For the purposes of 15A NCAC 02H .1003(2)(a),
density thresholds shall be determined in accordance with 15A NCAC 02H .1017
A full-sized plan sheet showing the entire site with its storm drainage system, including
every inlet, outlet and conveyance device. Please show how stormwater management
requirements have been met at every proposed outlet location. [15A NCAC 02H
.0506(b)(5) and (c)(5)]
c. All appropriate stormwater control measure (SCM) supplemental forms and associated
items, that complies with the high density development requirements of 15A NCAC 02H
.1003.

Clearwater Paper Corporation
DWR# 2010-0899 v3
Request for Additional Information
Page 3 of 3
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information
for the proper consideration of the application. If all of the requested information is not received in writing
within 30 calendar days of receipt of this letter, the Division 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 package and the appropriate fee.
Please respond in writing within 30 calendar days of receipt of this letter by sending two copies of all of the
above requested information to my attention at the address below.
Please be aware that you have no authorization under the Water Quality Certification Rules for this activity
and any work done within waters of the state may be a violation of North Carolina General Statutes and
Administrative Code.
Please contact me at 336-776-9693 or Sue. [e-mail] if you have any questions or concerns.
Sincerely,
Sue Homewood
Winston-Salem Regional Office
cc: R. Clement Riddle, Clearwater Environmental Consultants (via email)
David Shaeffer, USACE Charlotte Regulatory Field Office (via email)
DWR MRO 401 files
DWR 401 & Buffer Permitting Unit

(Sent via Electronic Mail)
Colonel Kevin P. Landers, Sr., Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Landers:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Offioe
26313th Avenue South
St. Petersburg, Florida 33701-5505
http:ttsero. n rnfs. noaa.gov
February 23, 2017
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date Comment Due Date
SAW -2013-02417 Camp Davis Industrial February 17, 2017 March 20, 2017
Park In.
SAW -2010-00061 Cleveland County February 17, 2017 March 17, 2017
Government
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical
habitat under the purview of the NMFS, please initiate consultation with the Protected Resources
Division at the letterhead address.
Sincerely,
Pace Wilber for
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division