20160299 Ver 1_RE R-2536 Asheboro mitigation site_20170515

Baker, Virginia
From: Williams, Andrew E CIV USARMY CESAW (US) <[e-mail]>
Sent: Monday, May 15, 2017 1:39 PM
To: Underwood, Chris
Cc: Paugh, Leilani Y; Matthews, Monte K CIV USARMY CESAW (US); Baker, Virginia;
Wilson, Travis W.; Williams, Andrew E CIV USARMY CESAW (US)
Subject: RE: R-2536 Asheboro mitigation site
Chris,
I have had some discussions regarding this project with our Mitigation Team and NCDOT Team Lead. I have also
discussed the project with representatives from the North Carolina Division of Water Resources and NC Wildlife
Resources Commission. Below are some thoughts and concerns regarding the current proposal for the Asheboro Bypass
Onsite Mitigation Site SS & SQ proposal.
1. The project, if pursued any further, will need to be reviewed by the entire Merger Team.
2. The proposed project would be considered as a wetland creation project--credits most likely would start at 3:1(for
every 3 acres created, you would receive 1 credit). Other factors would/could be considered (resulting in either more or
less credit) depending upon final design. Meeting minutes from August 5, 2015 between the agencies and NCDOT
indicated that creation could be 2:1/3:1.
3. While the drawings provided on 22 March 2017, show a single stream channel through the site, our understanding is
that the site will be designed so that a braided channel will be allowed to develop within the wetland footprint. The type
and amount of credit for this type of system would need to be determined by the Merger Team.
4. This proposed mitigation site will have a lengthy (over 300 foot) culvert and highway that will bisect it. During the
review of the project itself, NCDOT was not required to bury many of the pipes this length or greater, as it was
determined culverts this length, within these stream systems, would inhibit most aquatic life movement. As such, this
same factor would be considered when making a final determination on any mitigation amounts and will, most likely,
result in less credits.
5. Buffers--the proposed drawings seem to indicate there will be buffers less than 50 feet in some areas. If so, this could
negatively impact credit amounts.
6. Currently, NCDOT has a permit for this project. The proposed and permitted compensatory mitigation for this project
was by payment to the NCDMS In-Lieu Fee program. The 2008 Final Mitigation Rule, established a preference for
mitigation type and location options (§332.3(b)(2)-(b)(6). While the In-Lieu fee option deviates from these options,
during review of the permit application for the Asheboro Bypass (R-2536), the Corps determined that it was the
environmentally preferable option, based on these factors:
a. the NCDMS has an approved instrument dated July 28, 2010.
b. The DMS has been in operation since 2003 and has established a record for providing successful, consolidated
mitigation sites, utilizing watershed plan procedures.
c. As required by the NCDMS instrument, mitigation is constructed and functioning in advance of NCDOT
impacts, resulting in reduced temporal lag and reduced uncertainty over project success.
As such, a component of any proposal, will have to demonstrate why this specific on-site mitigation option is preferable
to the already permitted In-lieu fee option.
7. The project impacts are distributed throughout three (3) different watersheds or 8 digit Hydrologic Unit Codes (HUCs).
They are:
a. Deep River (03030003)
b. Lower Yadkin (03040103)
c. Upper Pee Dee (03040104)
For the R-2536 permit, NCDOT made payment to NCDMS (or has agreed to pay DMS) for the appropriate amount of
credits within each impacted watershed. This proposed mitigation site is located completely within the Deep River
i

watershed. A credit adjustment may be necessary if credits were proposed to be used in adjacent HUCs, even if they
were for the R-2536 project.
8. The predominant type of wetland impacted by R-2536 were forested. This proposed wetlands to be created are scrub-
shrub. The difference in types impacted vs. those used to provide compensatory mitigation, may be a factor in
considering if this is appropriate compensatory mitigation and/or amount of credit required to compensate for the
permitted wetland loss.
Considering these factors/concerns listed above, NCDOT may conclude that, while this site could be a candidate for
some type of stream and/or wetland enhancement, restoration, etc., it may not be an optimal site for project specific,
on-site, compensatory mitigation.
Please let me know if you have any additional questions or concerns.
Andrew Williams
Regulatory Project Manager
U.S. Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
919-554-4884 ex. 26
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: Underwood, Chris [mailto:[e-mail]]
Sent: Thursday, April 27, 2017 12:03 PM
To: Williams, Andrew E CIV USARMY CESAW (US) <[e-mail]>
Cc: Paugh, Leilani Y <[e-mail]>
Subject: [Non-DoD Source] R-2536 Asheboro mitigation site
Hey Any,
I'm glad that I got you on the phone. This is just to follow up on our conversation to make sure that we are on the same
page. From the conversations that you've had with you with your colleagues, you all are comfortable with this concept
and that the main question had to do with credits. You also said that this mitigation would be considered creation and
credited at 4:1. You also foresaw one mod for the mitigation for the permit. You are going to talk to Monte to make sure
that he agrees with what was stated.
So, in your estimation, the consultant can go forward with the site?
Thanks!

Chris Underwood
Environmental Senior Scientist
Project Development and Environmental Analysis
North Carolina Department of Transportation
919 707 6158 office
919 820 1207 mobile
1020 Birch Ridge Drive
1598 Mail Service Center
Raleigh, NC 27610-1598
Email correspondence to and from this address is subject to the
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Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third
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