20180349 Ver 1_USACE Correspondence_20180330

Homewood, Sue
From: Bailey, David E CIV USARMY CESAW (US) <[e-mail]>
Sent: Friday, March 30, 2018 2:48 PM
To: Brad Luckey; [e-mail]
Cc: Michael Brame; Homewood, Sue
Subject: [External] Request for additional information; RE: Twin Lakes PCN, Alamance County;
SAW -2018-00284
Attachments: 2003 Aerial.pdf, 2008 Aerial.pdf, Pages from SAW-2004-203752460384.pdf
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All,
Thank you for your PCN and attached information, dated and received 3/6/2016, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit 14 (http://saw-
reg.usace.army.mil/NWP2017/2017NWPI4.pdf). Please submit the requested information below (via e - mail is fine) within 30
days of receipt of this Notification, otherwise we may deny verification of the use of the Nationwide Permit or consider your
application withdrawn and close the file:
1) Although section D.Ia of the PCN does provide some information as to why the proposed road was not designed within (at
least a portion of) the existing driveway stream crossing footprint, the reasoning given does not justify why the proposed crossing
couldn't be designed to incorporate at least a portion of the existing stream crossing footprint. It appears that the access road
alignment could be re -designed to use the existing stream crossing footprint and still fit the project purpose listed in section B.3d
of the PCN. Please update the PCN and plans to incorporate the existing stream crossing footprint to further minimize impacts to
waters of the US (per NWP General Conditions 23(a) and (b). Or, provide additional justification for the current design,
addressing the practicability of using the existing crossing to further minimize impacts to waters of the US. Please note that the
future park area shown on the Overall Site Plan does not appear to be essential to the project purpose;
2) The proposed wetland crossing would bisect a relatively small wetland area, and the Corps is concerned about secondary and
cumulative impacts to this resource. Please provide the acreages of each wetland unit that would remain if this design was
authorized. How would hydrology be maintained in each wetland unit? If these wetland areas cannot be reasonably expected to
maintain their functional quality following construction of this design, you must provide additional compensatory mitigation for
this loss of wetland function;
3) As discussed previously, a search in our database has revealed no previous permits on the Twin Lakes property. However, the
Corps field verified a wetland/stream delineation (performed by S&ME) on the property on 2/19/2004 (Action ID: SAW -2004-
20375; see attached). Based on the information in this file, as well as an aerial photo search, the existing driveway stream crossing
was constructed between 2004 and 2008, and apparently without obtaining written verification from the Corps. Per this
information, it appears that this road crossing resulted in approximately 60 linear feet of stream impacts and 0.09 acre of wetland
impacts. Please note that the Corps will consider these impacts cumulative when evaluating Nationwide Permit and compensatory
mitigation thresholds.
Please let me know if you have any questions.
-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]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is located at:
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
-----Original Message -----
From: Brad Luckey [mailto:[e-mail]]
Sent: Tuesday, March 6, 2018 1:01 PM
To: Bailey, David E CIV USARMY CESAW (US) <[e-mail]>; Homewood, Sue
<[e-mail]>
Cc: Michael Brame <[e-mail]>
Subject: [Non-DoD Source] Twin Lakes PCN, Alamance County - Electronic Copy
David and Sue,
Please find attached electronic copy of the Twin Lakes PCN. Hard copies and appropriate fees will be mailed today to both
agencies. Please note that I believe we currently have 2-3 mitigation SOAs for the remainder of the Cripple Creek wetland
credits. Other private banks in Haw, 02 HUC do not have credits available. So, in the likely event private credits are not available
for this project, I went ahead and requested full amount of credits from DMS. If they are available, then it will be a mix and
match from Cripple Creek and DMS. Just wanted to bring to your attention since we currently have at least two PCNs in right
now with this type of split mitigation proposals.
Please let me know if you have any questions or concerns. Thank you for your assistance.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com <http://www.pilotenviro.com/>
[e-mail] <mailto:[e-mail]>

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