20171630 Ver 1_More Info Received_20180530

Strickland, Bev
From: Chris Hopper <[e-mail]>
Sent: Wednesday, May 30, 2018 2:51 PM
To: Elliott, William A CIV USARMY CESAW (US); Homewood, Sue
Cc: Chris Hopper
Subject: RE: RE: [Non-DoD Source] FW: [EXTERNAL] Davie/Forsyth County Agent
Authorization (UNCLASSIFIED)
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Ms. Homewood and Mr. Elliot:
The requested information and resulting project updates have been uploaded to the link below per your request. Mr.
Elliot, the same information has been posted to:
https://drive.google.com/open?id=IoAltd9HJeP3aEWTugfhAeuY5zVbNuyag for your access. The PJD signature page you
requested will be sent via separate email.
A summary of your comments and responses in order of receipt follows. Thank you both once again - please don't
hesitate to call or respond to request additional information.
Ms. Sue Homewood, NCDWR
Comments Received
December 28, 2017
Comment:
Condition 1.2 in the attached GC4133 states that the construction corridor cannot be closer than 10 feet to the top of
bank when the sewer line is parallel to the stream. Exceptions require written approval. Based on the plans provided
(granted, the scale is small) there appears to be a significant number of locations throughout the project where this will
be the case. I need confirmation of exactly where this will be the case and what extra measures will be taken to protect
the stream/stream bank from adjacent excavation activities (not just erosion control but also stability in the bank where
excavation is so close). I also need to see these areas specifically called out on the plans, or if some areas are to be
avoided by narrowing up the construction corridor, those areas should clearly be identified/called out on the plans. I am
very specifically concerned about Branch 4A, it appears much of the actual sewer line is right on top of the streambank.
Response:
Several the proposed sewers will require construction corridors within 10 -feet of stream channels. Each is discussed in
the revised cover letter using stations to describe location. It is worth noting the banks shown on these plans are
surveyor -identified tops of bank (i.e. the morphological transition from floodplain to downward slope, above the
regulatory top -of -bank). Because of this, proximities are overstated. Constraints the design team needed to balance
included steep slopes, existing structures and septic fields, adjacent aquatic resources, and location relative to
anticipated future cross -stream connections. Contractors would utilize trench boxes in these reaches to shore up trench
walls, and work would be limited to low flow periods when no precipitation is in the immediate forecast. We attempted
to address these issues in the location -by -location discussions now incorporated into the attached cover letter. Impact
tables have also been updated to reflect newly minimized impacts.
Comment:

At station 46+00 it appears that there's a bore pit immediately adjacent to a stream/wetland complex. This concerns me
as it could cause draining of the stream/wetland and/or significant construction complications. Can you look into this
and provide more details/construction sequence that is specific to this area.
Response:
Engineers extended the length of this jack -and -bore crossing to extend below these features.
Comment:
There are some areas where the crossings appear that they may not meet the "near -perpendicular" requirement as
noted in Condition 1.3 of the GC4133. Can you confirm any crossings that specifically won't meet this requirement?
Response:
Several stream crossings have been revised after realignments occurred, improving the angles of crossing. Two revised
crossings that don't satisfy this requirement occur along Sewer Outfall 1 between 2+40 and 2+60, and Sewer Branch 2A
Station 19+00. Each area is discussed in the revised cover letter.
Comment:
The construction corridor cannot be greater than 40' in width but I can't confirm based on the scale provided that this is
the case, if you could just make sure that's the case please.
Response:
Sewer construction corridors across wetlands would not exceed 40 -feet. Full- size plan sets have been saved to PDF
format and are attached to the revised application to ease review of these areas.
Comment:
The plan sheets call out a permanent easement of 15' within some of the jurisdictional areas, but not all of them. I just
want to make sure the owner understands that regardless of whether it's noted on the plans, the permanent easement
may only be 20' across streams and within wetlands per the GC, however if you calculated permanent wetland impacts
based on a 15' easement then that is what they will be limited to in the future.
Response:
The owner is aware of the allowances and commitment being. Minimization of compensatory mitigation for conversion
of forested wetlands was a motivation to keep some crossings as narrow as possible.
Comment:
A few of the stream crossings shown on the plans specifically call out dewatering activities, but not all of them do. Is this
an oversight, or a scaling issue that I can't see the notes, or is there something else being proposed?
Response:
Each stream crossing is discussed in the revised cover letter. Aerial crossings are included in the project as proposed and
no cofferdam and pump -around is included at these locations.
Comment:
Your stream impact table notes that the impacts to S9, second to the last row on the table is 178 feet. I can't match this
up to the project plans to see what is going on in this area. Is the pump around specific to where the stream is parallel
to the corridor? Could you provide a new impact table that gives each impact area a specific designation and then use
the stream number as a separate column, or provide Station numbers where the impact areas are to occur. It is hard to
call out specific areas of the project when Stream S9 is noted 6 different times and the plans don't have any
identification on them to indicate what impact # they are.
Response:

The referenced 178 -foot length was a construction corridor overlap. No actual impact to the stream would occur here.
Impact tables were updated to include CEI Figure, and MESCO Plan Sheet references, and each is discussed by location
as identified by station numbers in the revised cover letter.
Mr. William Elliot, USACE
Comments Received 02 February 2018
Comment:
Yes, I have to follow the same guidelines. USACE has an agreement with DOT but not with Wilkes County. If the county
has exercised their right to eminent domain then this is different than having the authority to eminent domain.
Response:
Understood, thank you for the consideration. If the county must exercise its eminent domain authority over these
properties for the USACE to proceed with a Preliminary JD and permit, please advise and we will inform our client.
Comment:
Also Forsyth County is typed in on the Agent authorization form.
Response:
This was an oversight. The protections offered have been declined and the error in County name occurring in that
section is moot and would not be utilized. We believe the remaining paragraphs, authorizing CEI to interact with the
USACE on this project remain in effect.
Comment:
Page 10 has not been signed
Response:
Page 10 of the revised application is signed.
Comment:
Sec D. page 3 of the JD request must be signed.
Response:
Section D. page 3 has been signed and is being sent via separate email for your use.
Chris Hopper
CAROLINA ECOSYSTEMS INC.
[phone]
www.carolinaeco.com
Hi Chris,
I'm reviewing the subject project and have a few questions/concerns:
Condition 1.2 in the attached GC4133 states that the construction corridor cannot be closer than 10 feet to the top of
bank when the sewer line is parallel to the stream. Exceptions require written approval. Based on the plans provided
(granted, the scale is small) there appears to be a significant number of locations throughout the project where this will
be the case. I need confirmation of exactly where this will be the case and what extra measures will be taken to protect
the stream/stream bank from adjacent excavation activities (not just erosion control but also stability in the bank where
excavation is so close). I also need to see these areas specifically called out on the plans, or if some areas are to be

avoided by narrowing up the construction corridor, those areas should clearly be identified/called out on the plans. I am
very specifically concerned about Branch 4A, it appears much of the actual sewer line is right on top of the streambank.
At station 46+00 it appears that there's a bore pit immediately adjacent to a stream/wetland complex. This concerns
me as it could cause draining of the stream/wetland and/or significant construction complications. Can you look into
this and provide more details/construction sequence that is specific to this area.
There are some areas where the crossings appear that they may not meet the "near -perpendicular" requirement as
noted in Condition 1.3 of the GC4133. Can you confirm any crossings that specifically won't meet this requirement.
The construction corridor cannot be greater than 40' in width but I can't confirm based on the scale provided that this is
the case, if you could just make sure that's the case please.
The plan sheets call out a permanent easement of 15' within some of the jurisdictional areas, but not all of them. I just
want to make sure the owner understands that regardless of whether it's noted on the plans, the permanent easement
may only be 20' across streams and within wetlands per the GC, however if you calculated permanent wetland impacts
based on a 15' easement then that is what they will be limited to in the future.
A few of the stream crossings shown on the plans specifically call out dewatering activities, but not all of them do. Is this
an oversight, or a scaling issue that I can't see the notes, or is there something else being proposed?
Your stream impact table notes that the impacts to S9, second to the last row on the table is 178 feet. I can't match this
up to the project plans to see what is going on in this area. Is the pump around specific to where the stream is parallel
to the corridor? Could you provide a new impact table that gives each impact area a specific designation and then use
the stream number as a separate column, or provide Station numbers where the impact areas are to occur. It is hard to
call out specific areas of the project when Stream S9 is noted 6 different times and the plans don't have any
identification on them to indicate what impact # they are.
It may be that larger scale drawings would help me. You can send those electronically by using this link, the project
number is 20171630 version 1 and you'd select "more information response" on the form.
I apologize if some of this information is present on the plans and I just can't see or find it.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
-----Original Message-----

From: Elliott, William A CIV USARMY CESAW (US) [mailto:[e-mail]]
Sent: Wednesday, February 7, 2018 12:06 PM
To: Chris Hopper <[e-mail]>
Subject: RE: RE: [Non-DoD Source] FW: [EXTERNAL] Davie/Forsyth County Agent Authorization (UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
1. Yes, I have to follow the same guidelines. USACE has an agreement with DOT but not with Wilkes County. If the
county has exercised their right to eminent domain then this is different than having the authority to eminent domain.
2. Also Forsyth County is typed in on the Agent authorization form.
3. Page 10 has not been signed
4. Sec D. page 3 of the JD request must be signed.
At this time I am putting your application on hold until these issues are resolved.