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HomeMy WebLinkAbout20081463 Ver 1_More Info Received_20081103uitRexwoods Drive Dewberry" S I2301 Suite 200 Raleigh, NC 27607 October 30, 2008 Ms. Cyndi Karoly Environmental Supervisor II NC Division of Water Quality 401 /Wetlands Unit 1650 Mail Service Center Raleigh, North Carolina 27699-1650 919.881.9939 919.881.9923 fax www.dewberry.com 08- 14 LP 3 Reference: Marine Corps Base Camp Lejeune, Onslow County Install Moving Target on Range G5 - N40085-08B-0049 Dewberry Project No. 50014655 Dear Ms. Karoly: Dewberry & Davis, Inc. (Dewberry) submitted a Pre-Construction Notification (PCN) Application package to your office on September 3, 2008 for the Install Moving Target on Range G-5 project at MCB Camp Lejeune. On October 7, 2008, Dewberry received comments from the Corps of Engineers concerning the 401/404 permit application. We have revised the PCN Application form based on comments from the Corps. Enclosed are five (5) copies of the revised application package, two (2) sets of full size drawings, three (3) sets of drawings reduced to l IX17, and one (1) copy of the response letter to the Corps of Engineers. Please call with any questions regarding this project. Sincerely, Dewberry & Davis, Inc. -?? 40a, 11?d__ Rana Dydula, P.E. Project Engineer Enclosures P:\50014655\Adm\Permits\Wetlands 401 404\2008.10.30 Revised Submittal Letter DWQ.doc MVyp?ERR?ON UENR.vV slog V?E?`Np5 PNU Dewberry & Davis, Inc. 10) ! x,111' I_i? U Vi 1_15 I I ? tip N 0 V 3 2008 UENR - NIATER QUALITY Tyaun? 20 51ORM`AIER t K%Ncti Office Use Only: Form Version March 05 USACE Action ID No. DWQ No. o18- N63 (If any particular item is not applicable to this project, please enter "Not Applicable" or -NSA".) 1. Processing 1. Check all of the approval(s) requested for this project: ® Section 404 Permit ? Riparian or Watershed Buffer Rules ? Section 10 Permit ? Isolated Wetland Permit from DWQ ® 401 Water Quality Certification ? Express 401 Water Quality Certification 2. Nationwide, Regional or General Permit Number(s) Requested 3. If this notification is solely a courtesy copy because written approval for the 401 Certification is not required, check here: ? 4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP) is proposed for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII, and check here: ? 5. If your project is located in any of North Carolina's twenty coastal counties (listed on page 4), and the project is within a North Carolina Division of Coastal Management Area of Environmental Concern (see the top of page 2 for further details), check here: ? If. Applicant Information Owner/Applicant Information Name: Mr. Carl Baker P.E. - Deputy Director of Public Works Mailing Address: Marine Corps Base Camp Lejeune, PSC Box 20004 Camp Lejeune NC 28542 Telephone Number: 910-451-2213 Fax Number: 910-451-3302 E-mail Address: carl.h.bakergusmc.mil 2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter must be attached if the Agent has signatory authority for the owner/applicant.) Name: Rana Dydula, P.E. Company Affiliation: Dewberry & Davis, Inc. Mailing Address: 2301 Rexwoods Drive Suite 200 Raleiah. NC 27607 Telephone Number: 919-881-9939 Fax Number: 919-881-9923 E-mail Address: rd dula ,dewberry.com Page 5 of 13 III. Project Information Attach a vicinity map clearly showing the location of the property with respect to local landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property boundaries and development plans in relation to surrounding properties. Both the vicinity map and site plan must include a scale and north arrow. The specific footprints of all buildings, impervious surfaces, or other facilities must be included. If possible, the maps and plans should include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion, so long as the property is clearly defined. For administrative and distribution purposes, the USACE requires information to be submitted on sheets no larger than 11 by 17-inch format; however, DWQ may accept paperwork of any size. DWQ prefers full-size construction drawings rather than a sequential sheet version of the full-size plans. If full-size plans are reduced to a small scale such that the final version is illegible, the applicant will be informed that the project has been placed on hold until decipherable maps are provided. 1. Name of project: Install Moving Target on Range G-5 - N40085-08-B-0049 2. T.I.P. Project Number or State Project Number (NCDOT Only): 3. Property Identification Number (Tax PIN): unknown 4. Location County: Onslow Nearest Town: Jacksonville Subdivision name (include phase/lot number): Directions to site (include road numbers/names, landmarks, etc.): From intersection of Holcomb Blvd and Leieune Blvd. Turn onto Holcomb Blvd. Turn left onto Sneads Ferry Road. Turn left onto NC Hwy 172. Travel proximately 2.4 miles along NC Hwy 172. Range G-5 is located on the right side of NC Hwy 172. 5. Site coordinates (For linear projects, such as a road or utility line, attach a sheet that separately lists the coordinates for each crossing of a distinct waterbody.) Decimal Degrees (6 digits minimum): 34° 36' 35" ON 77° 14' 31 °W 6. Property size (acres): 79.4 7. Name of nearest receiving body of water: Intracoastal Waterway 8. River Basin: White Oak (Note - this must be one of North Carolina's seventeen designated major river basins. The River Basin map is available at http:/,!h2o.enr.state.nc.us/admin/maps/.) 9. Describe the existing conditions on the site and general land use in the vicinity of the project at the time of this application: The project site and the land surrounding the project site is vegetated or open natural area with impact berms, target structures, and related, unpaved Page 6 of 13 service roadways The site is undeveloped and will remain undeveloped. All land surrounding the project site is federally-owned and part of MCB Camp Lejeune. 10. Describe the overall project in detail, including the type of equipment to be used: The berm for the target system shall be approximately 515 feet long and 5 feet high with a retaining wall along the back side of the berm. The top of the berm shall be approximately 10 feet wide and side slopes along the front side of the berm will be 3:1. There is sufficient soil stockpiled on site to construct the required berms. The concrete pad shall be approximately 10 feet wide Conventional construction equipment will be used at the site (i.e. track hoes and dump trucks). The Government shall provide the target system on a subsequent contract. 11. Explain the purpose of the proposed work: Purpose of proposed work is to construct two moving target systems. IV. Prior Project History If jurisdictional determinations and/or permits have been requested and/or obtained .for this project (including all prior phases of the same subdivision) in the past, please explain. Include the USACE Action ID Number, DWQ Project Number, application date, and date permits and certifications were issued or withdrawn. Provide photocopies of previously issued permits, certifications or other useful information. Describe previously approved wetland, stream and buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project, list and describe permits issued for prior segments of the same T.I.P. project, along with construction schedules. Wetland delineation was performed under the project title "Golf' Training Area Delineation. The determination is assigned USACE Action ID: SAW-2006- 32511-067. The plat titled "Golf' Training Area Delineation was issued October 23, 2007. V. Future Project Plans Are any future permit requests anticipated for this project? If so, describe the anticipated work, and provide justification for the exclusion of this work from the current application. unknown VI. Proposed Impacts to Waters of the United States/Waters of the State It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to wetlands, open water, and stream channels associated with the project. Each impact must be listed separately in the tables below (e.g., culvert installation should be listed separately from riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts, permanent and temporary, must be listed, and must be labeled and clearly identifiable on an Page 7 of 13 accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial) should be shown on a delineation map, whether or not impacts are proposed to these systems. Wetland and stream evaluation and delineation forms should be included as appropriate. Photographs may be included at the applicant's discretion. If this proposed impact is strictly for wetland or stream mitigation, list and describe the impact in Section VIII below. If additional space is needed for listing or description, please attach a separate sheet. 1. Provide a written description of the proposed impacts: Site B Target will impact 0.07 acres of delineated wetlands The target was located such that impact to the wetlands is minimized and still meets training requirements of MCB Camp Lejeune. 2. Individually list wetland impacts. Types of impacts include, but are not limited to mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams, Qpnnrntely lief imnnctc clue to both ctrueture and flooding. Located within Distance to Area of Wetland Impact Type of Wetland 100-year Nearest Impact Site Number Type of Impact (e.g., forested, marsh, Floodplain Stream (acres) (indicate on map) herbaceous, bog, etc.) ( es/no) (linear feet) Wetland Impact 1 fill coastal yes 1,275 0.07 Total Wetland Impact (acres) 0.07 3. List the total acreage (estimated) of all existing wetlands on the property: 16.1 acres 4. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed, plans and profiles showing the linear footprint for both the original and relocated streams m„ct he included- To calculate acreage- miiltinly length X width. then divide by 43.560. Stream Impact Number (indicate on map) Stream Name Type of Impact Perennial or Intermittent? Average Stream Width Before Impact Impact Length (linear feet) Area of Impact (acres) Total Stream Impact (by length and acreage) NA 5. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic Ocean and any other water of the U.S.). Open water impacts include, but are not limited to fill. excavation. dredging. flooding. drainage. bulkheads. etc. Open Water Impact Site Number (indicate on ma) Name Waterbody applicable) ) (if ap Type of Impact Type of Waterbody (lake, pond, estuary, sound, bay, ocean, etc.) Area of Impact (acres) Total Open Water Impact (acres) NA Page 8 of 13 6 List the cumulative impact to all Waters of the U.S. resulting from the project: Stream Impact (acres): 0 Wetland Impact (acres): 0.07 Open Water Impact (acres): 0 Total Impact to Waters of the U.S. (acres) 0.07 Total Stream Impact (linear feet): 0 7. Isolated Waters Do any isolated waters exist on the property? ? Yes ® No Describe all impacts to isolated waters, and include the type of water (wetland or stream) and the size of the proposed impact (acres or linear feet). Please note that this section only applies to waters that have specifically been determined to be isolated by the USACE. 8. Pond Creation if construction of a pond is proposed, associated wetland and stream impacts should be included above in the wetland and stream impact sections. Also, the proposed pond should be described here and illustrated on any maps included with this application. Pond to be created in (check all that apply): ? uplands ? stream ? wetlands Describe the method of construction (e.g., dam/embankment, excavation, installation of draw-down valve or spillway, etc.): NA Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond, local stormwater requirement, etc.): Current land use in the vicinity of the pond: Size of watershed draining to pond: Expected pond surface area: VII. Impact Justification (Avoidance and Minimization) Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide information related to site constraints such as topography, building ordinances, accessibility, and financial viability of the project. The applicant may attach drawings of alternative, lower-impact site layouts, and explain why these design options were not feasible. Also discuss how impacts were minimized once the desired site plan was developed. If applicable, discuss construction techniques to be followed during construction to reduce impacts. Site B Target was located such that the impact to the wetlands is minimized and still meets training needs of the client. The client gave specific coordinates for the targets based on training needs. Avoidance was considered for Site B Target. The client requested the target be located at the area shown in order to stay within the current SDZ (Surface Danger Zone). VIII. Mitigation DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC Division of Water Quality for projects involving greater than or equal to one acre of impacts to Page 9 of 13 freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial streams. USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide Permits, published in the Federal Register on January 15, 2002, mitigation will be required when necessary to ensure that adverse effects to the aquatic environment are minimal. Factors including size and type of proposed impact and function and relative value of the impacted aquatic resource will be considered in determining acceptability of appropriate and practicable mitigation as proposed. Examples of mitigation that may be appropriate and practicable include, but are not limited to: reducing the size of the project; establishing and maintaining wetland and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of aquatic resource functions and values by creating, restoring, enhancing, or preserving similar functions and values, preferable in the same watershed. If mitigation is required for this project, a copy of the mitigation plan must be attached in order for USACE or DWQ to consider the application complete for processing. Any application lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete. An applicant may also choose to review the current guidelines for stream restoration in DWQ's Draft Technical Guide for Stream Work in North Carolina, available at http://h2o.enr.state.nc.us/ncwetlands/strmgide.htin]. 1. Provide a brief description of the proposed mitigation plan. The description should provide as much information as possible, including, but not limited to: site location (attach directions and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet) of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view, preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a description of the current site conditions and proposed method of construction. Please attach a separate sheet if more space is needed. Mitigation is not proposed for this site. The range is a fully functional range with multiple targets and impact berms. A large impact berm is located just to the south of proposed Site B Target. This area already receives impacts from bullets fired on the range_ 2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at (919) 715-0476 to determine availability, and written approval from the NCEEP indicating that they are will to accept payment for the mitigation must be attached to this form. For additional information regarding the application process for the NCEEP, check the NCEEP website at http://h2o.enr.state.nc.us/wrp/index.htm. If use of the NCEEP is proposed, please check the appropriate box on page five and provide the following information: Amount of stream mitigation requested (linear feet): Amount of buffer mitigation requested (square feet): Amount of Riparian wetland mitigation requested (acres): Amount of Non-riparian wetland mitigation requested (acres): Amount of Coastal wetland mitigation requested (acres): Page 10 of 13 Environmental Documentation (required by DWQ) 1. Does the project involve an expenditure of public (federal/state/local) funds or the use of public (federal/state) land? Yes ® No ? 2. If yes, does the project require preparation of an environmental document pursuant to the requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)? Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA coordinator at (919) 733-5083 to review current thresholds for environmental documentation. Yes ? No 3. If yes, has the document review been finalized by the State Clearinghouse? If so, please attach a copy of the NEPA or SEPA final approval letter. Yes ? No ? IX. Proposed Impacts on Riparian and Watershed Buffers (required by DWQ) It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to required state and local buffers associated with the project. The applicant must also provide justification for these impacts in Section VII above. All proposed impacts must be listed herein, and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ Regional Office may be included as appropriate. Photographs may also be included at the applicant's discretion. 1. Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233 (Meuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 02B .0243 (Catawba) 15A NCAC 2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please identify V Yes ? No 2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers. If buffer mitigation is required calculate the required amount of mitigation by applying the buffer multipliers. I Zone* I Impact I Multiplier I Required (square feed Mitip-ation 1 3 (2 for Catawba) 2 1.5 Total * Zone I extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an additional 20 feet from the edge of Zone 1. 3. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e., Donation of Property, Riparian Buffer Restoration / Enhancement, or Payment into the Riparian Buffer Restoration Fund). Please attach all appropriate information as identified within 15A NCAC 213.0242 or.0244, or.0260. Page I 1 of 13 X. Stormwater (required by DWQ) Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss stormwater controls proposed in order to protect surface waters and wetlands downstream from the property. If percent impervious surface exceeds 20%, please provide calculations demonstrating total proposed impervious level. Project built-upon area is 3.4% of the total 79.4 acre project area. There are currently no permanent stormwater management measures in the area of new construction The site is classified as low density development and stormwater on the site will sheet flow from the berms to the surrounding topography. XI. Sewage Disposal (required by DWQ) Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. NA XII. Violations (required by DWQ) Is this site in violation of DWQ Wetland Rules (15A NCAC 2H.0500) or any Buffer Rules? Yes ? No Is this an after-the-fact permit application? Yes ? No XIII. Cumulative Impacts (required by DWQ) Will this project (based on past and reasonably anticipated future impacts) result in additional development, which could impact nearby downstream water quality? Yes ? No If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent North Carolina Division of Water Quality policy posted on our website at http://h2o.enr.state.nc.us/ncwetlands. If no, please provide a short narrative description: No development or changes in the use of the site are anticipated Page 12 of 13 XIV. Other Circumstances (Optional): It is the applicant's responsibility to submit the application sufficiently in advance of desired construction dates to allow processing time for these permits. However, an applicant may choose to list constraints associated with construction or sequencing that may impose limits on work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and Threatened Species, accessibility problems, or other issues outside of the applicant's control). PLAil ApplicantlAgent's Signature Date (Agent's signature is valid only if an authorization letter from the applicant is provided.) Page 13 of 13 9-0 3JNVH NO 999V 1.007 E Z66'l ' l3JH` i JNIAOW TlViSN1 L 3NO H 6E66 lB9 6l6 HOGIVU o 09LZON'o3mins 1O3 OUd 'ON TOHd 3U L " 3AI 4 SOOOMX?U ' 1 I SI^Ip 8 aaagnnap NOU03S SSOHO 13JHVi O 3ilS 8003'0£'0 L .;?; Aijec " • + ra;a ,, ,, [ • • , cl . 'ON 133HS 31111 31dp fj*501 I 0! 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A "P X A " I l`a, \4 •? 2x pl; ?? , 0 r 1 C C -fiver ° 91 w C ;77o 15' 0.00" 77 ° 14' 0.00" 677- 13' 0.00" Jame: BROWNS INLET Location: 034036'25.61"N 077014'23.61"W )ate: 6/8/2008 ;cafe: 1 inch equals 2000 feet Soil Map-Onslow County, North Carolina (Camp Lejeune G-5) USDA Natural Resources Web Soil Survey 2.0 6/8/2008 Conservation Service National Cooperative Soil Survey Page 1 of 3 N Meters A 0 100 200 400 600 Feet 0 500 1,000 2,000 3,000 m c 0 `m U L Z > N c c > > U a) J O C. U) N C OU a m ° ai a) o rn C a O N O d N m m y L . c o . + 3 c N E ° U) Q) 2 ° a) 'D M N 7 c i r ° c N o m E CL CL m u S co O >, ° m E cu ? 1; U O ?o m N w (D w?- f? d EL m m a) m N Z Z 00 LN N U E Q a a) d y o U m Q p r _ ZN a m t ° co 3 Q o O O Z co co a N c 4)< a) a) .C co a)? y O C Ol o a •- Vi •> ? O L 3 ti v°i 3 c 0, 0 w o ?o o- o a m am E m ? a) 0 Co = N m a N WLg E ? n U c o ° m? ma m m . - y > CL Q CL : E.C OC ?J a) ? N N c a) O> N L d 0. 0) c m C 'D 0) C TE a) N v o ` 0) Z m a) E a) a) N - a) a) m - o rn a) c 0-0 7 7 0 y 0 cu O_ >. U) N 0 m O a •0 V N d ?(n m j C 0 >`N a) dm N N N m to a) 6- m O C -0. O ` Q > m L V 7 N Z` cF E `?v ` am tom N o am m rn3 ?n ?a o °) N> - L> °: d E m E ?•-m 058 E o o (n?U t° Hw o? (n(n m O Lo h- °.!= o (D y N a _ ° 0. a V5 C m U m z i ) >1 CL 0) m m y c _O O d O l0 O U) ` Q y N YO O O 0) L = O m O y LL >. o O m w 0 _ N m N m d y y 0: al m N N > O 7 G 0 U) O U y O to g Ix «0 in O J y A m Q Z , a `2 ( LL G 2 m t a v m } } W w . o 2 d m y $ o Ix CL 3 W J d o Q 0 Q G o N a U) y d Q m d "y' y y N 7 N CL 'O . G d CL ° m 0 7 O Q n CL m a o p a 0. N > _ 3 o C7 c > m -? 7 O ° a a ° w > m o a m N o a Q O m lL O 3 O (n N y N y w LL L ° N C U d C >. > - Y O V a >. C d O m O m m C > C_ N C _ Q (n '8 to m U U CJ U' J J (L L7 a) a7 fn to (n to (n m a c ? 0 ® X + g O O 3 + lli o ` y a (A Q V) co M O0-- 0 N (V 00 a) a T Q) Z o (n N 'O a>i (n Z > ? a (n m o a (n o a 0 m > C O m z CD V N •Z N a) 3 C O O U) '- m ?d N 7 m O Z U 8j j Soil Map-Onslow County, North Carolina Camp Lejeune G-5 Map Unit Legend Onslow County, North Carolina (NC133) Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI BaB Baymeade fine sand, 0 to 6 percent slopes 0.2 0.1% Bo Bohicket silty clay loam 24.0 7.3% KuB Kureb fine sand, 1 to 6 percent slopes 0.1 0.0% Ln Leon fine sand 7.6 2.3% NfC Newhan fine sand, dredged, 2 to 10 percent slopes 3.1 0.9% Pa Pactolus fine sand 155.7 47.5% W Water 0.7 0.2% WaB Wando fine sand, 1 to 6 percent slopes 136.6 41.6% Totals for Area of Interest (AOI) 328.0 100.0% USDA Natural Resources Web Soil Survey 2.0 6/8/2008 IiiiiiiiiN I Conservation Service National Cooperative Soil Survey Page 3 of 3 .YK Dewberry a October 30, 2008 Mr. Brad Shaver 2301 Rexwoods Drive 919.881.9939 Suite 200 919.881.9923 tax Raleigh, NC 27607 www.dewberry.com b US Army Corp of Engineers Wilmington Regulatory Field Office PO Box 1890 Wilmington, North Carolina 28402-1890 Reference: Marine Corps Base Camp Lejeune, Onslow County Install Moving Target on Range G5 - N40085-08B-0049 Dewberry Project No. 50014655 Dear Mr. Shaver: On October 7, 2008 Dewberry & Davis, Inc. (Dewberry) received a letter from your office requesting additional information for a PCN application submitted to your office on September 24, 2008. Below are responses to the comments. Comment 1: In order to understand the project and specifically evaluate whether avoidance and minimization has been considered, the Corps needs to view the entire project area including all aspects of the range from access to firing positions to utilities. The current plan only shows the impact area and does not provide a complete picture of the entire G5 moving target range. Based on the current view it is not clear where this wetland system lies on the approved delineation included due to scaling issues. The entire project area should be displayed on the approved delineation at a scale to properly evaluate avoidance and minimization. Response 1: A copy of the entire set of construction drawings is enclosed. The G-5 Range project area is shown on the enclosed drawings. The targets have been located to minimize impacts. Site "A" Target was located such that it does not impact the wetlands. Site "B" Target was located such that the impact to the wetlands is minimized and still meets training needs of the client. The client gave specific coordinates for the targets based on training needs. Avoidance was considered for Site "B" Target. The client requested the target be located at the area shown in order to stay within the current SDZ (Surface Danger Zone). Firing positions are determined by MCB Camp Lejeune. The approved delineation is shown on the drawings. Comment 2: The current plan shows the impact cutting across a wetland finger without any pipes included to reconnect the severed wetland finger. Please indicate why this approach was chosen and explain why a pipe connection is not warranted. Also as necessary in any impact sketches please provide a cross section view of the impact so the Corps can see how this fill slope will intercept the wetland area, more specifically how the slope will be stabilized and whether or not the slope could be steepened further reducing wetland impacts. Dewberry & Davis, Inc. Mr. Brad Shaver October 30, 2008 Page 2 Response 2: The target berm crosses the wetland finger along the high point. The wetlands area in front of the target berm and behind the target berm drains from south-west to north-east according to the topographic survey. Therefore, no piping system is required under the target berm. A typical cross section of the target berm through the wetlands is enclosed. The slope will be stabilized with sod. For stability of the target berm, a maximum slope of 3:1 is recommended. The berm will be impacted by bullets and any slopes steeper than 3:1 may cause erosion of the berm. Revising the side slope from 3:1 to 2:1 would only reduce the wetlands impact from 0.07 acres to 0.06 acres and would increase the potential of erosion of the side slopes. Comment 3: In order to address the avoidance discussion, please give project specifics as to why the berm has to be on the orientation and length requested. In other words, provide enough project specific information to answer the question as to why the berm could not be shortened and thus completely avoiding wetland impact. Response 3: Site "B" Target was located such that the impact to the wetlands is minimized and still meets training needs of the client. The client gave specific coordinates for the targets based on training needs. Avoidance was considered for Site "B" Target. The client requested the target be located at the area shown in order to stay within the current SDZ (Surface Danger Zone). The orientation and location of the target berm was requested by the client. The length is a requirement of the target system. Comment 4: Within the PCN, a statement is made that the wetland system would be considered coastal but it does not fall within the 100 year flood zone, is this true? If a system has coastal characteristics it typically is subject to regular or at least irregular flooding and it would surprise me if it did not fall within the flood zone. Once again with the project area overlaid onto the approved JD it may clarify what type of system this is. Response 4: The target locations were located on FEMA maps. Site A Target is not located within the 100 year flood zone. A portion of Site B Target is located within the 100 year flood zone. The PCN has been updated. Comment 5: On that note if this wetland is either tidal or non-tidal adjacent to tidal wetlands, nationwide 39 cannot be used for that type of impact. If this system falls under the aforementioned category then you would need to utilize nationwide 18. Please note that because this action has impacts into wetlands and thus requires submission of a PCN, compensatory mitigation may be required for wetland impacts especially to high quality systems. At first glance if the impact is within Coastal Wetlands, the highest quality wetlands in this region, either compensatory mitigation would be required or a detailed explanation should be given as to why the impact may be mitigated in another fashion or how the impact will occur to allow for only minimal impacts to the aquatic resource. This should be further explained in section VIII of the PCN. Dewberry Mr. Brad Shaver October 30, 2008 Page 3 Response 5: The PCN has been change to utilize nationwide 18 in lieu of 39. The impact to the wetlands has been minimized to the maximum practical extent. Mitigation is not proposed for this site. The range is a fully functional range with multiple targets and impact berms. A large impact berm is located just to the south of proposed Site "B" Target. This area already receives impacts from bullets fired on the range. Enclosed are two pictures of the area where Site "B" target will be located. Please call with any questions regarding this project. Sincerely, Dewberry & Davis, Inc. Rana Dydula, P.E. Project Engineer Enclosures P:\50014655\Adm\Permits\Wetlands 401 404\2008.10.30 Response Letter to Corps.docx #*q Dewberry" ?M1?? ?. X91 r ?? ??' ?k ?' _i ? 1 ?„+ r a w'y?.? ? s*? ? , t ? n >d M M F ?l ti l? 47, mP+ e N a°N k " 5 w ?q'l :. 1 ?1 P r ?z ? c o A Mal r, b? e A .J ,. "??k cN ' d , yy rle"r. _ qqqP r y? t. ??yy 1 w ?Sx r, l `