20181041 Ver 1_Mitigation Information_20180824

Strickland, Bev
From: Brad Luckey <[e-mail]>
Sent: Friday, August 24, 2018 6:40 PM
To: [e-mail]
Cc: Homewood, Sue; Eric Dischinger; Bob Dischinger
Subject: [External] RE: Request for Additional Information: Cambridge Park s/d, Mebane,
Alamance County; SAW -2017-02329
Attachments: EEP Credit Reservation Letter_7.17.18.pdf, Local Bank -No Credits l.pdf
David,
Please find the attached applicant response to requested information, including Item 2 from previous request. Based on
this information, it is our opinion that the conditions of the NWP 29 have been met for the proposed project and
request processing of the NWP 29 Verification for the proposed project. However, if you have additional request for
additional information then please let us know. Thank you for your assistance with this project.
USACE Comment 1: For item #4, please briefly describe where the proposed force main and waterline are coming from,
outside of the confines of the Cambridge Park development. It appears that both of these facilities are proposed rather
than existing, so we have to account for any potential impacts to aquatic resources. Will these facilities be installed
within road shoulder along their entire length? Will impacts be avoided by some other measure?
Applicant Response: The proposed sewer line and water lines outside of the proposed Cambridge Park site are being
designed by others. However, it is the applicant's understanding that the proposed water line will connect from existing
infrastructure near the intersection of Old Hillsborough Road and Jones Road and enter the site from Jones Road. The
proposed water line will be located within the Jones Road ROW/road shoulder with the exception of connecting to
existing infrastructure just north of Old Hillsborough Road. The applicant is not aware of impacts to WoUS associated
with the proposed water line outside of the Cambridge Park project area.
The proposed sewer line connects to existing infrastructure north of Melville Commerce Parkway. The proposed sewer
line will be a proposed gravity line north of NC Highway 119 to its connection to existing infrastructure north of Melville
Commerce Parkway. The sewer line will be a force main located within the road ROW/shoulder of Turner Drive south of
NC Highway 119 to the Cambridge Park property and proposed pump station. The applicant is not aware of impacts to
WoUS associated with the proposed sewer line outside of the Cambridge Park project area.
USACE Comment #2: Thank you for your detailed information regarding project phasing, including design level of each
phase. Although it appears as though Phase 1A has independent utility and could potentially be permitted ahead of
future phases, due to the high potential for future phases of the Cambridge Park development to include cumulative
stream impacts greater than the typical compensatory mitigation threshold (NWP Regional Condition 3.2), the Corps has
determined that the stream impacts currently proposed for Phase 1A will also require compensatory mitigation(per
NWP General Condition 23(d) and Regional Condition 3.2). Please update Section D.2 of the PCN accordingly, including
any relevant compensatory mitigation acceptance letters
Applicant Response: The applicant proposes mitigation at a 2:1 ratio for the unavoidable 92 linear feet of net loss of
stream from culvert fill proposed in Phase IA. Please find the attached credit reservation letter from DMS that confirms
availability of necessary credits and email correspondence from private mitigation bank that confirms credits are not

available within the site HUCfrom aprivate bank. Mitigation isnot proposed for unavoidable permanent stream
impacts from rip -rap energy dissipation or temporary impacts to streams associated with de -watering and utility line
Sincerely,
Brad�2y S.Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
P0Box 128
Kernersville, NC 27285
From: Bailey, David E CIV USARMY CESAW (US) [maiIto:[e-mail]]
Sent: Wednesday, August ZZ,ZU1O7:Z4AM
To: Brad Luckey xb|uckey@pi|otenviro.com>
Cc: Homewood, Sue ([e-mail])[e-mail]';Eric 0schinger
xeric@|dequityzom>;Bob 0schingerxrsd@evans'engzom>
Subject: RE: Request for Additional Information: Cambridge Park s/d, Mebane, Alamance County; SAW -2017-02329
Thanks Brad. I have reviewed the information you sent in response to our requestfor additional information dated
8/9/2018. As you note, resolution of item #2 is still pending.
Otherwise, your responses have satisfied our requests for item #s I and 3-7 with the following clarification:
For item #4, please briefly describe where the proposed force main and waterline are coming from, outside of the
confines of the Cambridge Park development. It appears that both of these facilities are proposed rather than existing,
so we have to account for any potential impacts to aquatic resources. Will these facilities be installed within road
shoulder along their entire length? Will impacts be avoided by some other measure?
_
David E.Bailey, PWS
Regulatory Project Manager
USArmy Corps otEngineers
CE -SAW -KG -K
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Fax: [phone]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at:
Thank you for taking the time to visit this site and complete the survey.
From: Brad Luckey
Sent: Monday, August 13,ZU1O4:SUPM
To: Bailey, David ECIV U3ARMYCE3AVV(U3)
Cc: Homewood, Sue �Eric0schinger

<eri.c ldeg.uity earn>; Bob Dischinger <rs_dC _evans-eng.rca >
Subject: [Non-DoD Source] RE: Request for Additional Information: Cambridge Park s/d, Mebane, Alamance County;
SAW-2017-02329
David,
On behalf of the applicant, please find the below response to USACE Request for Additional Information Item #s 1 & 3-
7. As previously discussed, the applicant is evaluating options prior to responding to the USACE Request for Additional
Information of Item #2. Please let me know if you have any questions or require additional information. Thank you for
your assistance.
USACE Comment #1: Please submit a scanned/electronic copy of your PCN package
Applicant Response: Attached. Please note the PCN has been updated to clarify requested information in USACE
Comment #'s 3 &4.
USACE Comment #2: Thank you for your detailed information regarding project phasing, including design level of each
phase. Although it appears as though Phase 1A has independent utility and could potentially be permitted ahead of
future phases, due to the high potential for future phases of the Cambridge Park development to include cumulative
stream impacts greater than the typical compensatory mitigation threshold (NWP Regional Condition 3.2), the Corps has
determined that the stream impacts currently proposed for Phase 1A will also require compensatory mitigation(per
NWP General Condition 23(d) and Regional Condition 3.2). Please update Section D.2 of the PCN accordingly, including
any relevant compensatory mitigation acceptance letters
Applicant Response: The applicant will provide a response under separate cover.
USACE Comment #3: The PCN reports the Impact 1 permanent stream impacts due to the culvert as 92 Lf., whereas the
plansheet states 93 Lf. of permanent stream impacts due to the culvert. Please ensure consistency between the two
and correct as necessary
Applicant Response: Proposed stream impacts are 92LF. The attached PCN has been updated to resolve this
discrepancy.
USACE Comment #4: Please provide a plansheet that clearly shows the overall location of the proposed Force Main and
Sanitary Sewer lines. The provided Overall plansheet is either not to sufficient scale, or has too many competing layers
for these features to be legible. For example, it is difficult to discern where the Force Main is coming from/going to, and
where the sanitary sewer connects with Phase 1A. It would also be helpful to provide a zoomed -in plansheet for the
entirety of Phase 1A.
Applicant Response: Please see attached PCN that includes updated impact exhibits that include a zoomed in plan sheet
for Phase IA and has removed layers to easily identify sanitary sewer connections.
USACE Comment #5: Is the entirety of the sewer line as proposed necessary to accommodate development of Phase 1A,
or could a shorter segment of the sewer line be constructed to service this phase only? That is, we cannot evaluate the
road/lot infrastructure for Phase 1A only while evaluating the sewer infrastructure for the entire built -out Cambridge
Park development.
Applicant Response: The entirety of the proposed sewer line is necessary to accommodate development of Phase
IA. Additionally, the City of Mebane is requiring the sanitary sewer line to be installed past Phase IA to Jones Road that
will provide current and future service to other properties to the northeast of the site.

USACE Comment #6: Is any rip rap proposed to be placed in streams at Impacts 3-5? If so, please revise the PCN to state
that these are permanent impact (though not a loss of waters), and provide a profile view of each of these crossings
showing that the rip rap would be keyed into the stream bed
Applicant Response: Keyed in rip -rap is not proposed. The overall subdivision has been designed to allow for separate
maintenance access points on either side of proposed sewer line stream crossings. Therefore, a permanent easement
using rip -rap in streams for access is not necessary or proposed.
USACE Comment #7: Is any rip rap proposed to be placed in streams at Impacts 3-5? If so, please revise the PCN to state
that these are permanent impact (though not a loss of waters), and provide a profile view of each of these crossings
showing that the rip rap would be keyed into the stream bed
Applicant Response: During the zoning and special use permitting process for Cambridge Park, the City of Mebane
determined that Abington Drive would be required to be designed and constructed as a 'collector' roadway from Jones
Drive to Turner Road. As such, this road would need to be a curb and gutter road, 41' back-to-back within a 60' right-of-
way, with sidewalks along both sides. In addition, 'collector' roads, as opposed to 'local' residential roads, have
significantly more stringent design requirements in regard to horizontal alignments. This is due to the nature of the
'collector' road itself functioning as the main route for emergency services vehicular access into and out of the
subdivision as well as the requirement of handling the larger volumes of traffic in general. Realignment of Abington
Drive along Hardwick Drive would not meet these design requirements; therefore, the second stream crossing for
Abington Drive becomes necessary to fulfill the 'collector' requirements set forth by the City.
Sincerely,
Bradey S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.11r2illotourviiu o.com
blucke lr2illotourviiu o.com
From: Bailey, David E CIV USARMY CESAW (US)[Mr!ilto:Qavi_d.:_E_._Bal_Iey2_( usa e.arrrry:rrril]
Sent: Thursday, August 9, 2018 2:54 PM
To: Brad Luckey <bluckey(e pilotenviro.co >; Eric Dischinger <er .c l_dequity �cq >
Cc: Homewood, Sue (sue home crod(c ncdenr gcrv) <s_ue._homewcacad�c�ncdenr �cav>
Subject: Request for Additional Information: Cambridge Park s/d, Mebane, Alamance County; SAW -2017-02329
Messrs. Dischinger and Luckey,
Thank you for your PCN and attached information, dated 7/19/2018 (received 7/23/2018), for the above referenced
project. I have reviewed the information and need clarification before proceeding with verifying the use of Nationwide
Permits 12 (I Icrekedhtt ://saw reg:usage:army:_m.l_I/NV\lI 2 7/2t1 INV\11 2: df) and 29 (I Icrekedhtt r://saw
reg:usa e:arrny mil/NWP 0 7✓..20.17_N_` .P29 Fadi). 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) Please submit a scanned/electronic copy of your PCN package;
2) Thank you for your detailed information regarding project phasing, including design level of each phase.
Although it appears as though Phase 1A has independent utility and could potentially be permitted ahead of
future phases, due to the high potential for future phases of the Cambridge Park development to include
cumulative stream impacts greater than the typical compensatory mitigation threshold (NWP Regional
Condition 3.2), the Corps has determined that the stream impacts currently proposed for Phase 1A will also
4

require compensatory mitigation(per NWP General Condition 23(d) and Regional Condition 3.2). Please update
Section D.2 of the PCN accordingly, including any relevant compensatory mitigation acceptance letters;
3) The PCN reports the Impact 1 permanent stream impacts due to the culvert as 92 Lf., whereas the plansheet
states 93 Lf. of permanent stream impacts due to the culvert. Please ensure consistency between the two and
correct as necessary;
4) Please provide a plansheet that clearly shows the overall location of the proposed Force Main and Sanitary
Sewer lines. The provided Overall plansheet is either not to sufficient scale, or has too many competing layers
for these features to be legible. For example, it is difficult to discern where the Force Main is coming from/going
to, and where the sanitary sewer connects with Phase 1A. It would also be helpful to provide a zoomed -in
plansheet for the entirety of Phase 1A;
5) Is the entirety of the sewer line as proposed necessary to accommodate development of Phase 1A, or could a
shorter segment of the sewer line be constructed to service this phase only? That is, we cannot evaluate the
road/lot infrastructure for Phase 1A only while evaluating the sewer infrastructure for the entire built -out
Cambridge Park development;
6) Is any rip rap proposed to be placed in streams at Impacts 3-5? If so, please revise the PCN to state that these
are permanent impact (though not a loss of waters), and provide a profile view of each of these crossings
showing that the rip rap would be keyed into the stream bed;
7) It appears that the stubout for Abington Drive points directly at Stream SG, which would require authorization
upon pursuit of a future phase. Please note that presence of an upland stubout road does not guarantee
authorization of a future proposed stream crossing. For example, it appears as though Hardwick Drive would
provide access to future phases without requiring impacts to aquatic resources.
Please let me know if you have any questions.
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: Q7avi.d_:_E.:_B.ail_ey2_.(�,..u_sa_ce arrny...rnil
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: Blocked_htt. _://...cors a u usa e:ar .Y.:_mil/c_ ....... /...( .p.�_136:4:0
Thank you for taking the time to visit this site and complete the survey.

Mitigation Services
ENVIRONMENTAL QUALITY
July 17, 2018
Eric Dischinger
Desco Mebane Partners, LLC
3625 N. Elm Street, Suite 107-A
Greensboro, NC 27455
ROY COOPER
Governor
MICHAEL S. REGAN
Secretmv
Expiration of Acceptance: 1/17/2019
Project: Cambridge Park County: Alamance
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin
Impact Location
(8 -digit HUC
Impact Type
Impact Quantity
Cape Fear
03030002
Warm Stream
186
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The
mitigation will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and
15A NCAC 02B .0295 as applicable. Thank you for your interest in the DMS in -lieu fee mitigation program.
If you have any questions or need additional information, please contact Kelly Williams at [phone].
cc: Bradley Luckey, agent
SVej,fill
Rment Supervisor
State of North Carolina I Environmental Quality I Mitigation Services
1652 Mail Service Center I Raleigh, NC 27699-1652 1 217 W. Jones Street, Suite 3000
919 707 8976 T

Brad Luckey
From: Tiffani Bylow <[e-mail]>
Sent: Tuesday, July 17, 2018 1:59 PM
To: Brad Luckey
Cc: Tiffani Bylow
Subject: RE: Cambridge Park -Stream Credit Request, HUC 0303002
Hey Brad -
We do not have any stream credits available in the CF02 and will not have any for the next year+.
Thanks!!
Tiffani
Tiffani Bylow I Restoration Systems, LLC
1101 Haynes St. I Suite 2111 Raleigh, NC 27604
p: 919.334.91231 c: 919.754.72781 f: 919.755.9492
www.restorationsystems.com
From: Brad Luckey <[e-mail]>
Sent: Tuesday, July 17, 2018 11:00 AM
To: Tiffani Bylow <tbylow@restoration systems.com>
Subject: Cambridge Park -Stream Credit Request, HUC 0303002
Do you have —186LF of stream credits?
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]