20191197 Ver 1_Start of Study Notifications_20180531

Carpenter,Kristi
From:Bailey, David E CIV USARMY CESAW (US)
<[e-mail]>
Sent:Thursday, May 31, 2018 10:13 AM
To:Rebecca Jackson
Cc:Norton, April R; Powers, Tim; Parker, Jerry A
Subject:\[External\] NCDOT Division 7 - Start of Study
Notifications
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Becca,

Thank you for your Start of Study Notification email, dated 1/26/2018, for the following
bridge replacement projects:
Alamance Co. - Bridge No. 164 on SR 1113; Bridge No. 128 on SR 2369; Caswell Co. -
Bridge No. 19 on SR 1771; Bridge No. 108 on SR 1156; Guilford Co. - Bridge No. 52 on SR
1332; Bridge No. 224 on SR 3000; Bridge No. 235 on SR 1005; Bridge No. 240 on SR
3285; Orange Co. - Bridge No. 99 on SR 1723; Rockingham Co. - Bridge No. 23 on SR
2430; Bridge No. 166 on SR 1360.

Please accept my apologies for the delay in my response. Unfortunately it appears that
an incorrect email address was used for my contact information, and I did not receive
the above referenced correspondence until April Norton (NCDWR) forwarded it to me.
Please note that my correct email address is: [e-mail]

Your email requested that my agency provide any information that would be helpful in
evaluating potential environmental impacts of the projects. We have reviewed the
information you submitted, any information in our permitting database, as well as
remotely sensed resources including aerial photography, County Soil Surveys, LiDAR,
and USGS topographic maps. Further, delineations of potentially jurisdictional aquatic
features (i.e. wetlands, streams, open waters) were completed by Ecosystem Planning &
Restoration (EPR) and submitted to the Corps and NCDWR for verification on 4/6/2018;
eight of these sites were reviewed by the Corps and NCDWR in the field.

In general, based upon a review of the above referenced information, the construction
of these projects is likely to impact streams and/or wetlands within the work corridor.
Please be aware that discharges of dredged or fill material into jurisdictional waters of
the United States are subject to our regulatory authority pursuant to Section 404 of the
Clean Water Act, and thus would require Department of the Army (DA) permit
authorization. The type of DA authorization required (i.e., general or individual permit)
will be determined by the location, type, and extent of jurisdictional area impacted by
the project, and by the project design and construction limits. Until additional data is
furnished which details the extent of the construction limits of the proposed projects,
we are unable to provide specific comments concerning DA permit requirements or a
recommendation of alternatives.

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That said, the Corps recommends replacing bridges with bridges to avoid and minimize
impacts to streams. Typically, bridge-to-bridge replacements can be authorized by
Nationwide Permit (NWP) 3 for Maintenance (likely without requiring a PCN). If
accompanied by appropriate justification of avoidance and minimization, replacing
bridges with culverts could potentially be authorized by NWP 14. Projects involving
larger magnitudes of impacts to wetlands or streams may require authorization via NWP
23 (if accompanied by a CE), General Permit (GP 31), or an Individual Permit.

Below I have included pertinent project-specific comments based on completed aquatic
resource delineations and field verifications:

Bridge No. 164 on SR 1113 (Alamance): Stream SB in the northeast quadrant of the
study area runs parallel to SR 1113. We recommend that project design involving any
road realignment, widening, or shoulder improvements occur on the west side of the
existing road to avoid the potential for high magnitudes of stream impacts.

Bridge No. 19 on SR 1771 (Caswell): All four quadrants of the study area have wetlands
in close proximity to the existing road and bridge; this includes a wetland that extends
under the existing bridge on the west side of Lynch Creek. Further, a small stream exists
along the base of the road fill slope in the southeast quadrant of the study area. We
recommend that project design involving any road widening or shoulder improvements
be held to the minimum necessary, as even small adjustments to the existing fill slope
would result in large impacts to wetlands and/or streams.

Bridge No. 52 on SR 1332 (Guilford): Stream SA in the southwest quadrant of the study
area runs parallel to SR 1332. We recommend that project design involving any road
realignment, widening, or shoulder improvements occur on the east side of the existing
road to avoid the potential for high magnitudes of stream impacts.

Bridge No. 224 on SR 3000 (Guilford): Wetlands are prevalent in all quadrants on the
west side of South Buffalo Creek. We recommend that project design involving any road
widening or shoulder improvements be held to the minimum necessary on the west side
of South Buffalo Creek, as even small adjustments to the existing fill slope would result
in large impacts to wetlands.

Bridge No. 235 on SR 1005 (Guilford): Streams SA, SB, and SC occur on the eastern and
western extremes of the study area. We recommend that project design involving any
road realignment, widening, or shoulder improvements occur only in the vicinity of the
existing bridge, in order to avoid impacts to these streams on the outer fringes of the
study area.

Bridge No. 240 on SR 3285 (Guilford): Wetlands are prevalent in both quadrants on the
north side of Little Alamance Creek (Stream SA). We recommend that project design
involving any road widening or shoulder improvements be held to the minimum
necessary on the north side of the existing bridge, as even small adjustments to the
existing fill slope would result in impacts to wetlands.

Bridge No. 23 on SR 2430 (Rockingham): Replacing Bridge 23 itself could likely occur
without requiring DA authorization, if the disturbance limits do not include aquatic
resources. However, if larger interchange improvements are proposed in this area,
impacts to Candy Creek (Stream SA) and/or the Haw River (Stream SC) and adjacent
wetlands are likely. Note that beaver activity in Candy Creek (Stream SA) on the south
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side of SR 2430 has increased the extent of wetlands in this area. Further, the Haw River
(Stream SC) floodplain in the northern extent of the study area includes large areas of
wetlands. As such, any road realignment, widening, or shoulder improvements along the
length of SR 2430 would likely result in large impacts to wetlands. If larger interchange
improvements are proposed (rather than simply replacing the bridge), the project may
benefit from inclusion in the Merger Process.

Bridge No. 166 on SR 1360 (Rockingham): Streams SB on the east side of SR 1360, and
Stream SD and adjacent wetlands in the southwest quadrant of the study area, run
parallel to SR 1360. We recommend that project design involving any road realignment,
widening, or shoulder improvements occur in these areas to avoid the potential for high
magnitudes of stream and wetland impacts.

Hopefully this information is useful. If you have any additional questions please let me
know.

Sincerely,

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.

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