20180852 Ver 1_More Info Received_20180719

Strickland, Bev
From: Brad Luckey <[e-mail]>
Sent: Thursday, July 19, 2018 4:48 PM
To: [e-mail]; Homewood, Sue
Cc: Michael Brame
Subject: [External] RE: Request for Additional Information - McKnight Mill Estates, Greensboro,
Guilford County; SAW -2017-00625
David and Sue,
On behalf of the applicant, please find the below additional information. If you have additional concerns, then please let
me or Michael know. Thanks.
USACE Comment #1: Your PCN and plans propose a discharge of fill material into 0.209 acre of riparian, non-riverine
wetlands for road crossing and fill for Lots 6-11. Your avoidance and minimization efforts related to the road crossing fill
portion of the proposed impact (i.e. primarily within the existing farm road footprint) is noted. However:
a. You have not demonstrated avoidance and minimization for the proposed wetland impacts related to
Lots 6-11, as required by NWP General Conditions 23(a) and (b). For example, it is not clear that project
viability is dependent on the inclusion of 6 lots, when the overall development proposes 239. Please
provide additional information to this effect. If project plans are changed as a result of this evaluation,
please provide the updated PCN and plan sheets as necessary.
Applicant Response: The applicant designed the four phases of the residential subdivision with an emphasis on
avoidance and minimization for impacts to WoUS. There is approximately 4,474 linear feet of perennial/intermittent
stream channel and approximately 0.703 acres of wetlands located on the site. At this time, the applicant is proposing
no net loss to streams and the only known permanent impact to WoUS as a result of the development is the proposed
0.209 acres of wetland fill. Of the 0.209 acres of wetland fill, approximately one-third of the total wetland fill is
associated with fill from the road crossing. To utilize the existing culvert and install a new culvert within the previously
impacted footprint results in almost the entirety of wetlands located within Lots 10 and 11 to be filled and at least one-
half of the wetlands located on Lot 9 to be filled. Road fill does not impact wetlands located on Lots 7 and 8.
The remaining wetland that will not be filled associated with the road crossing on Lots 7, 8 and part of 9 is provided
hydrology from the off-site pond/wetland system to the north. This surface hydrology from an off-site source will be
routed around the remaining wetland and discharged down -gradient of the culvert. This effectively removes the surface
hydrology from the wetland and would likely lead to indirect impacts that lead to the wetland no longer providing the
function and quality that it currently provides. Therefore, the impact to the remaining wetland could also be permitted
as assumed take in lieu of lot fill.
Preliminary plans for the four-phase residential subdivision included a cumulative total of 239 residential lots. Of which,
199 lots are located within the first 3 phases of the development. Permanent stream impacts are not proposed within
the first 3 phases of the residential subdivision. Other sites in the piedmont of NC that are within attractive residential
locations and markets for proposed development of approximately 200 lots would likely require far greater impact to
WoUS than what is proposed within this application. Furthermore, the overall development of all four phases will result
in at least approximately 4,200 linear feet of stream channel and 0.50 acres of wetlands remaining undisturbed at the
site. Different and more preliminary designs following the stream/wetland delineation included a cumulative total of
approximately 300 residential lots. However, to avoid and minimize impact to streams and wetlands, this was reduced
1

to the proposed 239 lot subdivision. Therefore, it appears that NWP General Condition 23 (a) has been met for the
proposed project and more specifically for the proposed impacts within this application.
In regards to wetland impacts related to Lots 6-11 not meeting NWP General Condition 23(b), the applicant proposed
mitigation at a 2:1 ratio for the 0.209 acres of wetland impacts within the initial permit application. The mitigation
proposal remains unchanged. However, it should be worth noting that the function and the quality of the wetland is
relatively low to moderate at best. The wetland is a down -gradient overflow of an off-site pond. It provides little benefit
for water quality by retention, storage and nutrient uptake/removal. Furthermore, based on numerous site visits
completed by Pilot personnel, the wetland does not exhibit evidence of prolonged or even seasonal inundation and thus
would not provide hydrologic connection for aquatic species between the off-site pond and down -gradient stream. The
wetland has few large tree species and is largely dominated by green briar and sweet gum saplings. While green briar
and sweet gum saplings do provide some wildlife benefits including limited cover and nesting areas for small mammals
and birds, these are minimal benefits compared to typical wooded wetlands in the piedmont that offer more diverse
species and far higher quality foraging and nesting habitat. Therefore, in combination with the above information
specific to mitigation through avoidance, minimization and reduction techniques, a limited technical analysis of quality
and the mitigation proposal at a 2:1 mitigation ratio, it is our opinion that the proposed project does not result in
individual and cumulative adverse impact to the environment that would be considered as something more than
minimal. Thus, it would be our opinion that the requirements of NWP General Condition (b) has been satisfied by the
applicant's proposal.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
From: Michael Brame
Sent: Friday, July 13, 2018 4:41 PM
To: Anthony Lester <[e-mail]>
Cc: Brad Luckey <[e-mail]>
Subject: FW: Request for Additional Information - McKnight Mill Estates, Greensboro, Guilford County; SAW -2017-00625
See below. I will be on vacation next week but Brad is familiar with this one so reach out to him as needed.
Sincerely,
Michael T. Brame
336.708-4620 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
mbrame(@r)ilotenviro.com
From: Bailey, David E CIV USARMY CESAW (US)<[e-mail]>
Sent: Friday, July 13, 2018 4:15 PM
To: Michael Brame <[e-mail]>
Cc: Homewood, Sue ([e-mail]) <[e-mail]>
Subject: Request for Additional Information - McKnight Mill Estates, Greensboro, Guilford County; SAW -2017-00625

Mr. Brame,
Thank you for your PCN and attached information, dated and received 6/19/2018, for the above referenced project. I
have reviewed the information and need clarification before proceeding with verifying the use of Nationwide Permit
(NWP) 29 (http://saw-reg.usace.army.mil/NWP2017/2017NWP29.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) Your PCN and plans propose a discharge of fill material into 0.209 acre of riparian, non-riverine wetlands for
road crossing and fill for Lots 6-11. Your avoidance and minimization efforts related to the road crossing fill
portion of the proposed impact (i.e. primarily within the existing farm road footprint) is noted. However:
a. You have not demonstrated avoidance and minimization for the proposed wetland impacts related to
Lots 6-11, as required by NWP General Conditions 23(a) and (b). For example, it is not clear that project
viability is dependent on the inclusion of 6 lots, when the overall development proposes 239. Please
provide additional information to this effect. If project plans are changed as a result of this evaluation,
please provide the updated PCN and plan sheets as necessary.
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: David. [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.