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HomeMy WebLinkAbout19870095 Ver 1_COMPLETE FILE_19841223IN REPLY REFER TO Regulatory Branch . DEPARTMENT OF THE ARMY. WILMINGTON DISTRICT, CORPS OF ENGINEERS P.O. BOX 1890 WILMINGTON, NORTH CAROLINA 28492-1890 March 5, 4,987 SUBJECT: File No. SAWC087-N-010-0073 pp f1 " ?;'1? i Mr. M. F. Fox, Chief Engineer Federal Paper Board Company, Inc. Post Office Box 338 Bolton, North Carolina 28423 Dear Mr. Fox: Reference your application for a Department of the Army Section 404 permit to place fill material in pocosin wetlands between the Shallotte and Lockwoods Folly River Basins (Driving Creek) to provide sufficient ditch drainage for forestry management in two tracts totaling 1,567 acres off N.C. Highway 211 in Brunswick County approximately 18 miles south of Bolton, North Carolina. The public review for your proposal has been completed and I must deny your request for permit authorization. I reviewed and evaluated the impacts of this application, as well as the stated views of Federal and non-Federal agencies and the concerned public, and I determined that the issuance of the requested permit was not in the overall public interest. My decision to deny this permit was also based on my evaluation of the probable impacts, including cumulative impacts, of the proposed work. The benefits, which reasonably could be expected to accrue from the proposal, were balanced against reasonably foreseeable detriments. My decision to not authorize the proposal was determined by the outcome of this general balancing process. My decision reflects the national concern for both protection and utilization of important resources. In reaching this decision, I considered the comments of other agencies and their advice regarding important environmental resources that would be adversely impacted by the project. Those comments were previously furnished to you. Recommendations that the permit be denied were received from the U.S. Fish and Wildlife -2- . Service, the National Marine Fishery Service, the U.S. Environmental Protection Agency, and the North Carolina Department of Natural Resources and Community Development. I concur with the assessments of these agencies regarding the significant adverse impacts that would occur if the requested work were accomplished. I also considered the public and private benefits of the proposed project. I agree that certain economic benefits would be realized by the Federal Paper Board Company, but I have determined that there are reasonable alternatives available to you that would achieve the purposes for which the work would be conducted. The proposed work is not. in accordance with the overall interests of the public as reflected in the comments of State and local agencies and the general public. There would be significant adverse environmental effects related to the work. Denial of this permit application is consonant with national policy, statutes, and administrative directives. On balance, the total public interest would best be served by the denial of a Department of the Army permit. Thank you for your close coordination with my staff on this and other permit matters. I regret that this decision was not more favorable to you. Mr. Ernest Jahnke of my staff is available to answer any questions you may have or to assist you with your future plans that may involve lands within the Corps of Engineers' regulatory jurisdiction. He may be reached at telephone (919) 343-4467. BY AUTHORITY OF THE SECRETARY OF THE ARMY: Paul Woodbury Colonel, Corps of Engineers District Engineer -3- Copies Furnished (without enclosures): Mr. John Parker Division of Coastal Management North Carolina Department of Natural Resources and Community Development Post Office Box 27687 Raleigh, North Carolina 27611-7687 Mr. Charles Jones Morehead City Regional Office North Carolina Division of Coastal Management Post Office Box 769 Morehead City, North Carolina 28557 Ms. L. K. (Mike) Gantt U.S. Fish and Wildlife Service Post Office Box 25039 Raleigh, North Carolina 27611-5039 Mr. C. Robert Stroud Wilmington Regional Office North Carolina Division of Coastal Management 7225 Wrightsville Avenue Wilmington, North Carolina 28403 Mr. Randy Cheek National Marine Fisheries Service Habitat Conservation Division Pivers Island Beaufort, North Carolina 28516 Mr. William L. Kruczynski, Chief Wetlands Section Region IV Marine and Estuarine Branch U.S. Environmental Protection Agency 345 Courtland Street Atlanta, Georgia 30365 ^M- William Mills ater Quality Section Division of Environmental Management North Carolina Department of Natural Resources and Community Development Post Office Box 27687 Raleigh, North Carolina 27611 V . .• v v.a sTATF ,? •? Ol?w'pV• State of North Carolina Department of Natural Resources and Community Development Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor R. Paul Wilms S. Thomas Rhodes, Secretary Director March 4, 1987 Mr. M.F. Fox, Chief Forester Federal Paperboard Company, Inc. P.O. Box 338 Bolton, NC 28423 Subject: Certification Pursuant to Section 401 of the Federal Clean Water Act, Proposed Drainage Ditches Federal Paperboard Company, Inc. Tributaries to Driving Branch Brunswick County Dear Mr. Fox: Attached hereto are two (2) copies of Certification No. 2034 issued to Federal Paperboard CoaT>any, Inc. dated March 4, 1987. If we can be of further assistance, do not hesitate to contact us. Sincerely yours, Original Signed By William C. Mills For R. Paul Wilms cc: Wilmington District Corps of Engineers Wilmington Regional Office Mr. William Mills Mr. David Owens Pollution Prevention Pays P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer NORTH CAROLINA Brunswick County CERTIFICATION THIS CERTIFICATION is issued in conformity with the requirements of Section 401 Public Laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of Environmental Management Regulations in 15 NCAC 2H, Section .0500 to Federal Paperboard Company, Inc. pursuant to an application filed on the 13th day of November, 1986 to excavate ditches to provide drainage for forestry management. The Application provides adequate assurance that the discharge of fill material into a wetlands area adjacent to the waters of Driving Creek in conjunction with the proposed drainage project in Brunswick County will not result in a violation of applicable Water Quality Standards and discharge guidelines. Therefore, the State of North Carolina certifies that this activity will not violate Sections 301, 302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in accordance with the application and conditions hereinafter set forth. Condition(s) of Certification: 1. That the activity be conducted in such a manner as to prevent significant increase in turbidity outside the area of construction or construction related discharge (increases such that the turbidity in the Stream is 50 NTU's or less are not considered significant). 2. That the spoil be stabilized to minimize erosion. violations of any condition herein set forth shall result in revocation of this Certification. This Certification shall become null and void unless the above conditions are made conditions of the Federal Permit. This the 4th day of March, 1987. DIVISION OF ENVIRONMENTAL MANAGEMENT original Signed BY William C. Mills For R. Paul Wilms, Director WQC# 2034 ,.a SrATP ,? > State of North Carolina Department of Natural Resources and Community Development Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor R. Paul Wilms S. Thomas Rhodes, Secretary Director March 4, 1987 Mr. M.F. Fox, Chief Forester Federal Paperboard Company, Inc. P.O. Box 338 Bolton, NC 28423 Subject: Certification Pursuant to Section 401 of the Federal Clean Water Act, Proposed Drainage Ditches Federal Paperboard Company, Inc. Tributaries to Driving Branch Brunswick County Dear Mr. Fox: Attached hereto are two (2) copies of Certification No. 2034 issued to Federal Paperboard Company, Inc. dated March 4, 1987. If we can be of further assistance, do not hesitate to contact us. Sincerely yours, Orilftal Signed By William C. Mills For R. Paul Wilms cc: Wilmington District Corps of Engineers Wilmington Regional Office Mr. William Mills Mr. David Owens Pollution Prevention Pays P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer t, NORTH CAROLINA Brunswick County CERTIFICATION THIS CERTIFICATION is issued in conformity with the requirements of Section 401 Public laws 92-500 and 95-217 of the United States and subject to the North Carolina Division of Environmental Management Regulations in 15 NCAC 2H, Section .0500 to Federal Paperboard Company, Inc. pursuant to an application filed on the 13th day of November, 1986 to excavate ditches to provide drainage for forestry management. The Application provides adequate assurance that the discharge of fill material into a wetlands area adjacent to the waters of Driving Creek in conjunction with the proposed drainage project in Brunswick County will not result in a violation of applicable water Quality Standards and discharge guidelines. Therefore, the State of North Carolina certifies that this activity will not violate Sections 301, 302, 303, 306, 307 of PL 92-500 and PL 95-217 if conducted in accordance with the application and conditions hereinafter set forth. Condition(s) of Certification: 1. That the activity be conducted in such a manner as to prevent significant increase in turbidity outside the area of construction or construction related discharge (increases such that the turbidity in the Stream is 50 NTU's or less are not considered significant). 2. That the spoil be stabilized to minimize erosion. Violations of any condition herein set forth shall result in revocation of this Certification. This Certification shall become null and void unless the above conditions are made conditions of the Federal Permit. This the 4th day of March, 1987. DIVISION OF ENVIRONMENTAL MANAGEMENT Original Signed BY William C. Mills For R. Paul Wilms, Director WQC# 2034 IMPORTANT gA.V To Date Time WHILE YOU WERE OUT of s Phone AR E `, NUMBE 7-91 "' "`TELEPHONED PLEASE CALL CALLED TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU URGENT . RETURNED YOUR CALL PMA sage A1q h?, Signed N. C. Dept. of Natural Resources and Community Development i DIVISION OF ENVIRONMENTAL MANAGEMENT February 6, 1987 MEMORANDUM To: Bill Mills Operations Branch From: David H. Cotton QP/ Wilmington Regional Office Through:' A. Preston Howard, Jr. Wilmington Regional Office Subject: Regional Office Review & Recommendations Application for Permit for Excavation and/or Fill Federal Paperboard Company, Inc. Brunswick County The applicant is proposing to dig approximately 175,000 linear feet of drainage ditch to drain approximately 1560 acres of pocosin wetland. The proposal includes placing the excavated soil adjacent to the ditch within the wetlands. The project has been reveiwed to determine impacts to water quality. The following comment is offerred: 1. That the project will require a 401 Certification for the placement of the spoils. The Certification should include the following conditions: a. That the work be done in such a way as to prevent excess levels of turbidity, greater than 50 NTUs,.in the receiving stream. b. That the spoil be stabilized to prevent erosion. 2. This office feels that the project will not adversely affect water quality. During the course of review DEM received a letter from Marvin and Lucy Evans, from Ash, NC. They expressed concerns about the additive effect of wetlands drainage on low lying land downstream. During a site visit I was able to view the extent of flooding currently taking place along Juniper Creek and its tributaries. The areas visited were approximately 12 to 2 miles from the convergence of Juniper Creek and the Waccamaw River. There was extensive flooding adjacent to Juniper Creek and its tributaries. While waters in the southeast region are abnormally high the waters in this vicinity are at a higher flood stage than in other areas. It is recommended that prior to adding additional drainage to the Juniper Creek system that Federal Paperboard address the possibility of additional drainage increasing the flooding problems downstream of the project. DHC:APH:bc cc: DCM - Steve Benton WiRO, CF ?tED 4s , W UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Ftir?Ct??s REGION IV 000RTLAND STREET JAN 2 3 1987 AIL ANTA, GEORGIA 30365 4WID-IEB/LP Colonel Paul W. Woodbury District Engineer U.S. Army Corps of Engineers, Wilmington P.O. Box 1890 Wilmington, North Carolina 28402-1890 ATTENTION: Mr. Ernie Jahnke SUBJECT: Federal Paper Board Company, Inc. (Public Notice No. 86-N-010-0073) Dear Colonel Woodbury: JAN1987 R, E Div. oz ,r ,:s9 Mgt i c t ...:,eyi y : r. C. ,1A I LK' L.ii` 6c.`0,. This is in response to the subject public notice concerning a proposal to place excavated material in pocosin wetlands eighteen miles south of Bolton, Brunswick County, North Carolina. The purpose of the subject project is to provide sufficient ditch drainage for forestry management in two sites totaling 1,567 acres. The sites will be primarily reforested with loblolly pine. The proposed ditches are to be excavated to -5 ft. depths with 1.5 ft. bottom widths and 1:1 side slopes. Excavated material is to be placed adjacent to the ditches which will be spaced approximately 660 ft. apart. Approximately 17,490 linear ft. of ditching is planned. The applicant has recently contributed 1,872 acres of pocosin wetlands to the North Carolina Nature Conservancy as mitigation for the proposed project. Pocosin wetlands perform valuable functions in aquatic systems including: fish and wildlife habitat values, water quality services, and vital stonmwater retention capabilities. It is clear that the fill activity will eliminate or highly degrade a valuable aquatic resource and will result in unacceptable adverse environmental impacts. Consequently, it is our opinion that the proposed project is contrary to the Section 404 Guidelines and should be denied. Sincerely yours, Jack E. Ravan Regional Administrator cc: See enclosed cc: Mike Gantt, Field Supervisor U.S. Fish and Wildlife Service Raliegh, NC R. Paul Wilms, Director NC Division of Environmental Management Preston Pate, Chief Field Supervisor NC office of Coastal Management W. Donald Baker NC Wildlife Resources Commission John Parker, Permits Coordinator NC office of Coastal Management Randy Cheek, Area Supervisor National Marine Fisheries Service Beaufort, NC J.T. Brawner, Regional-Director National Marine Fisheries Service St. Petersburg, FL 1 Z . DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS P.O. BOX 1890 ?. WILMINGTON, NORTH CAROLINA 28402.1890 January 12, 1987 IN REPLY REFER TO Regulatory Branch Mrs Lucy R. Evans Ash, North Carolina 28420 q u, *a 4 h?, Dear Mrs. Evans: Thank you for furnishing me a copy of your letter'tb ,tV rfn fh Carolina Division of Environmental Management (NCDPI.yt,dat December 9, 1986, regarding the request by Federal CF,?Epmp#'Yj for a Department of the Army permit for construction of drainage ditches near the Green Swamp in Brunswick County, North Carolina. Although your letter was addressed to the NCDEM, from which you may expect a direct answer, many of the points you raised are matters concerning Corps of Engineers' policy and/or past actions and we believe it will be of help to you if we also respond to those points. We are furnishing a copy of our response to the NCDEM for their information. By way of background, you probably are aware that Federal Government authority over wetland activities in your area is a recent occurence. Prior to 1977 the Corps had no authority over the small streams and wetlands in your area. Since then, the jurisdiction of the Corps of Engineers has reached a point that today, we require permits for the placement of dredged or fill material into numerous small streams and wetlands over which we had no authority in the recent past. Regarding your comments about past approvals given to Federal Paper Company, we wish to assure you that Federal Paper Company has received no approvals from the Corps of Engineers which did not require their rigid compliance with all existing laws and regulations. Indeed, their current permit application involves their use of two parcels of land over which we determined jurisdiction a few years ago, and within which they have curtailed their activity since that time. Keep in mind that the Corps of Engineers has authority to regulate only the discharges of dredged or fill material, not the discharges of water or other activities. In this case, the regulated activity for which Federal Paper needs a permit is the "discharge" of the excavated soil from their proposed ditch construction onto the adjoining land which we have determined to -2- be "wetlands" under our jurisdiction. Prior to this time, they have constructed logging roads and cut some of the timber off the land. The Clean Water Act exempts logging roads from the permit requirement and the cutting of trees is not a "discharge" under the law. Federal Paper Company is now interested in completing their work on the property which would involve reforestation, however, a drainage sytem is required to manage the surface water until the new tree seedlings become established. Those field ditches require a Corps permit under our current regulations. The donation of lands is not as insignificant as it may seem. Much of the land contains virgin stands of Southern White Cedar and pocosin forest which comprise a unique and valuable supplement to the lands already held by the Nature Conservancy. Federal Paper Company would not have needed permits to construct roads or to harvest the cedar and other timber if they had chosen not to donate the property, but, of course, that harvesting would have destroyed the unique ecological value of the property. Certainly they may enjoy certain tax credits for such action, but those kinds of tax credits have inspired placement of thousands of acres of special lands into public ownership in North Carolina, which would have otherwise been permanently altered and lost as a natural resource. You are obviously primarily concerned about the need for relief from the periodic flooding of your property and property of others adjacent to the various streams within the Waccamaw River basin in Brunswick County. The Corps of Engineers' involvement in this matter is apparently also a matter of some confusion and we are pleased to have this opportunity to explain our past actions. Two Brunswick County drainage projects have been the subject of our review. First was a request, in mid 1980, from the Brunswick County Department of Water Management and Mosquito Control for a permit to channelize approximately 3-1/2 miles of streambed in Scippio Swamp Creek and place the excavated material in the adjacent swamp wetland. The environmental consequences of such work have long been the cause for strong objections from those State and Federal agencies charged with protection of fish and wildlife resources, and, in this case their objections were especially strong because of our recent experience with similar work in other counties, particularly Burgaw Creek in Pender County. There and elsewhere, we came to the conclusion that the carrying capacity of most small streams could be restored and maintained by simply clearing and snagging the limbs, trees, and J ? -3- other vegetative debris from the streambed. Most importantly, the environmental damage to the wetlands and to the fish and wildlife habitat that is caused by channelization and spoil disposal is avoided. In early 1981, the Brunswick County Commissioners were advised that the Corps of Engineers had gotten agreement from all interested agencies for the clearing and snagging of 10,000 linear feet of Scippio Swamp Creek to proceed. Coincidently, out of the interagency discussions on the Scippio Swamp project, we were successful in developing a general permit for clearing and snagging which eliminates the need for future individual permits for such work by Brunswick County or others. The general permit became effective on October 16, 1980. In 1982, our general permit was incorporated into the national Corps of Engineer regulations and made effective nationwide. To our knowledge, the county has not proceeded with work in Scippio Swamp. Notwithstanding the availability of the nationwide authority, Brunswick County applied in January 1984 for a permit to channelize 2,700 linear feet of Mill Branch. All review agencies recommended denial of the permit and the State of North Carolina determined that the request was inconsistent with the North Carolina Coastal Management Plan. That permit request was denied on April 26, 1984. The Brunswick County authorities have been advised on several occasions that no permit is required for clearing and snagging, and, until that alternative is demonstrated not to be effective, we cannot consider future applications for stream channelization. We are convinced that clearing the stream of blockages of limbs and debris will be effective and that it will provide relief from much of the flooding that is being experienced in the area. Thank you for your interest in the Federal Paper Company permit application. Your views will be given careful consideration. Sincerely Charles. W. Hollis Chief, Regulatory Branch J it -4- Copies Furnished: Mr. Steve Benton Division of Coastal Management North Carolina Department of Natural Resources and Community Development Post Office Box 27687 Raleigh, North Carolina 27611-7687 Mr. William Mills Water Quality Section Division of Environmental Management J North Carolina Department of Natural Resources and Community Development Post Office Box 27687 Raleigh, North Carolina 27611-7687 Mr. Bob Jamison Wilmington Regional Office North Carolina Department of Natural Resources and Community Development 7225 Wrightsville Avenue Wilmington, North Carolina 28403 Mr. M. F. Fox Federal Paperboard Company Post Office Box 338 Bolton, North Carolina 28423 A. g,j? I #/(,# F!V1PD V Ash) 11C December 9, 1986 North Carolina Dent. Division of Vatural P. u. Box 2y687 Raleigh, NC 2761 Sirs: Green Swamp stradles the Brunswick-Columbus County line. The process of harvesting, and replanting timber would be eased by this drainage. VIA Of Enviornmental Management Resources and Community Development Federal Paper Compny has applied to the Cort of Engineers for a permit to dig five-feet-deep drainage ditches in the Green Swamp to drain an additional 1,_56'/ acres of wetlands, placina the spolls on adjacent wetlands Federal owns. The Federal proposes to make a gift of 1,872 acres in the Green Swamp to the north Carolina Conservancy to appease any organ- izations that may object to the permit, not to mention the tax deduction. Federal gets what they want, the Conservancy gets what it wants all "free"; but it isn't free. Someone has to pay and that "someone" is the adjacent property owners that have no imput in the determination of who gets a permit. For years Federal Paper Com Inny•has been given a "carte Blanc" permit to dig as they deemed necessary in the Green Swamp and surrounding area on Federal owned property with no regard or forethought whatsoever to problems or hazards they created for their neighbors. Federal has turned water on their neighbors creating health hazards by contamination, destroying farm land and vegetation and making bogs of once dry land. In the Exum and Myrtle Head communities the crops and crop- land has been severly damaged. Water supplies have been con- taminated. The land use has been reduced to nil in some areas. The natural habitat of wildlife has been distrubed. The food supply for wildlife has been deminished. Yet not one of the persons or protective organizations has bothered to inspect the impact or even say "don't". The water from ditches dug in this area drain into Alligator Swamp, Reedy Branch and Mill Branch. Alligator Swamp empties into the two branches at the head of the old Evans Bay, which these branches should drain into Juniper Creek and Waccamaw River. Down stream these natural waterways are blocked by wt '" debris and erosion that has built up over the years. Because of the soil type erosion and debris build up easily. This causes flooding of the area, backing excess water onto adjacent property. 't'hese branches have-not been cleaned out since the WPA project in 1933. Other property owners were not consulted' by Federal as to their intentions or possible problems prior to permission and cer- tainly not since. The property owners are tax-payers and that tax money in part is being used to pay for the so-called protective agencies that are supposed to be protecting us, our rights as property owners, and our property and our quality of life from such as Federal Paper. These same agencies grant permits td Federal with no forethought as to consequences to others. Our ancestors came here in the 1700s with a land grant and set- tled the property on which we live. They passed down to us a heritage rich in the quality of life to which we have become accustom. Beginning with the Revolutionary Tar they have fought to help preserve this country and that heritage for their decen- dants. As children of a farming community we developed early a love of the land and our surroundings. We rambled the woods, gathering things for school and 4-H projects, swam in the streams, gathered wild flowers to take home, caught minnows, tadpoles, turtles, crayfish and anything that moved was inspected through- ly. We learned to fish in these streams. Have you ever tickled a Venus Fly Trap that snapped shut; peeped into trumphet plants to see what it had in it's trumphet. We watched tadpoles and fish eggs develope in the spring. These are the memories that substain us as adults watching our worl-i being attached from every possible angle. These are things that are fast disappearing fran our lives because those with "hearsay" knowledge know more about the needs of our area than the people living here. In February, 1984 on behalf of the property owners Brunswick County Water Management applied to the Corp of Engineers for a permit to clean up some of the mess by snagging out Reedy Branch and Mill Branch so once again they flow naturally into Juniper Creek and Zaccamaw River. The application asked for permission, where necessary, to did; to a maximum of five feet depth, (the same depth used by Federal). No request was made for complete drainage of this area, just the excess water was to be drained off. Once this was completed everyone would benofit. We were denied a permit because of the Clear-V,ater Act. CLEAR ',"oA.TFR ! The interpretation of clear water to those interpting means undistrubed water, even if it's over the trees. They are not concerned with quanity of water and most especially drainage projects, but QUALITY. Water is backed up out of it's:natural fresh area, standing stagnant, stinking and covered with mos- quito larvae is not QUALITY. It's not clean. No form of life c_an.live in it and areas usually foraged in winter by wildlife is soggy and rotting. Federal's plans are drainage for conven- ience. We are told Federal Paper Comp-,.ny is exempt from regulations because growing timber is agriculture. Agriculture cannot be applied to farming. Now the beavers have moved in,compounding the problem. Beavers are protected. The enviornmentalist tell us the beavers were here before we were, but we cannot find anyone (native) that had ever seen a live beaver before now. We didn't have enough water in our immediate area before to accommodate beavers. Our property and our way of life are being destroyed by irres- ponsible management programs and laws that change according to who it is. The inconsistency in these areas is appaling. The rules should be applied equally. Permits should be reviewed with first-hand knowledge. Programs should be set up according to the needs of an area. 't'hose needs should be determined by persons living in the area and those having made on-site inspec- tion of the whole area. Too many times decisions are made by persons and organizations whose only knowledge comes from printed materials or "hearsay". Developers and Federal Paper can dig the wetlands out by the cubic tons for monetary gains. We are told that if we remove one shovel of soil. from a natural run for preservation, we will be hauled into court. To keep this area livable and useful we must have a working drainage'program. Everything must have a little maintenance.. This area is an agriculture community and is zoned so by the county. To maintain it as a beautiful, healthy, workable farm- ing community we must have consistent water drainage program. We are asking that you help put quality back into our community by denying to Federal Paper Company the requested permit and and azy forthcoming request until the present drainage problems created by previous drainage projects of Federal Paper have been corrected. We request also that on-site inspection of the down stream areas be made. Please no more long-distance dictations. Our problems stem from decisions being made by persons and organizations that do not have to live with the decisions. In reality they know not- hing of the people, the history, or geography of the area. •rhey base their opinions on "hearsay" from persons that tell them exactly what those persons want them to know. Please come look for yourselves. Don't send the Corp of engineers. We find them unreasonable and impossible to work with. Thank ix ou A,,(-? e- X0 cc: Brunswick County Plater Management Bolivia, NC NC Tildlife Resources uomission Conservation Division Habitat Management ivU Dept of Soil Gonservation attn: Mr. Bill Auatin ivC Dept. of ivatural Resources attn: Mr. Jamison Wilmington, NC U S Fish and nildlife Mg. Michael uantt US 'Army Corp of Engineers attn. (fir. Ernest cjahnke attn. Mr. Charlie Hollis NC Division coastal management attn: Mr. Steve Benton Enviornmental Protection Agency Dr. Jack Raven Regional Admintstor 345 Cortland St. NE Atlanta, GA 30365 rnviornmental Frotection Agency Mr. Howard Marshall estuary xeaearch Yederal Paper Board Company, INC. Mr. r,. F. rox ('hief Engineer P. 0. Box 338 Bolton, ivC 28423 A: MEMORANDUM TO: Bill Mills FROM: Steve Bentdfi SUBJECT: Consistency Review Project R E C E I V E D NOV 2-4 1986 4VA i tN gUALI i Y SECTIO N OPERATIONS BRANCH The following project proposal is being reviewed for consistency with the North Carolina Coastal Management Program. Identifying No. CoP-PS -Pl) 7-6073 Project: I)PAr-unc,?r- n_CG5/-1 Gr,P?-7zag4v0 R,ev?vsw<c Co Applicant: F?0?2AL?P?d? /A2? Co , l-uC. DEM Reviewer sent to:??? Response date requested: 2/i z./ g Consistency Response Deadline: z9 As f C=:, DEPARTMENT OF THE ARMY Wilmington District, Corps of Engineers Post Office Box 1890 Wilmington, North Carolina 28402-1890 SAWC087-N-010-0073 PUBLIC NOTICE November 13, 1986 THE FEDERAL PAPER BOARD COMPANY, INCORPORATED, represented by MR. M. F. FOX, Chief Engineer, Post Office Box 338, Bolton, North Carolina 28423, has applied for a Department of the Army permit TO PLACE EXCAVATED MATERIAL IN POCOSIN WETLANDS BETWEEN THE SHALLOTTE AND LOCKWOOD FOLLY RIVER BASINS (DRIVING CREEK) TO PROVIDE SUFFICIENT DITCH DRAINAGE FOR FORESTRY MANAGEMENT IN TWO TRACTS TOTALING 1567 ACRES OFF N.C. HIGHWAY 211, APPROXIMATELY 18 MILES SOUTH OF BOLTON, Brunswick County, North Carolina. The following description of the work is taken from data provided by the applicant and from observations made during an onsite visit by a representative of the Corps of Engineers. Plans and information submitted with the application propose ditching in two tracts: the Canady Road Tract (983 acres) and the Richardson Road Tract (584 acres). Ditches are to be spaced approximately 660 feet apart. Excavation by track mounted V-bucket backhoe of 5-foot-deep ditches with 1-1/2-foot bottom widths and 1 to 1 side slopes is typical. Excavated material is to be placed adjacent to ditches. Best management practices are to be followed to minimize sediment impacts on water quality and to prevent alteration of natural surface water movement patterns. Approximately 1780 chains (117,480 linear feet) of ditching is proposed for the Canady Road Tract and approximately 870 chains (57,420 linear feet) of ditching is proposed for the Richardson Road Tract. The purpose of the work is to facilitate reforestation of the tracts with genetically improved strains of loblolly pine and hardwood. With the exception of the placement of the excavated material, all other work associated with the . proposed reforestation are exempt from regulation by 33 CFR Part 323.4. Plans showing the work are included with this public notice. During 1977, the applicant contributed 13,850 acres of prime pocosin, savannah and ridge land to the North Carolina Nature Conservancy (NCNC). As indicated by the cross hatched areas on sheet 1 of 3 of the attached plans, the applicant, as mitigation for the proposed work, is planning to contribute an additional 1872 acres to the NCNC. This acreage is contiguous with the previously donated land and the areas to be managed. It is significant to note that the applicant could have, without regulation, undertaken "normal silvicultural practices" within the NCNC areas, but they have offered the areas in an almost virgin condition. The applicant states that the NCNC is agreeable to receipt of the additional acreage. The applicant has determined that the proposed work is consistent with the North Carolina Coastal Zone Management Plan and has submitted this determination to the North Carolina Division of Coastal Management for their -2- view and concurrence. This proposal shall be reviewed for the applicability of other.actions by North Carolina agencies such as: a. The issuance of a Water Quality Certification under Section 401 of the Clean Water Act by the North Carolina Division of Environmental Management. b. The issuance of a permit to dredge-and/or fill under North Carolina General Statute 113-229 by the North Carolina Division of Coastal Management. c. The issuance of a permit, under the North Carolina Coastal Area Management Act (CAMA) by the North Carolina Division of Coastal Management or their delegates. d. The issuance of an easement to fill or otherwise occupy State-owned submerged land under North Carolina General Statute 143-341(4), 146-6, 146-11, and 146-12 by the North Carolina Department of Administration and the North Carolina Council of State. e. The approval of an Erosion and Sedimentation Control Plan by the Land Quality Section, North Carolina Division of Land Resources, pursuant to the State Sedimentation Pollution Control Act of 1973 (NC G.S. 113 A-50-66). The requested Department of the Army permit will be denied if any required State or local authorization and/or certification is denied. No Department of the Army permit will be issued until a State coordinated viewpoint is received and reviewed by this agency. Recipients of this notice are encouraged to furnish comments on factors of concern represented by the above agencies directly to the respective agency, with a copy furnished to the Corps of Engineers. This application is being considered pursuant to Section 404(b) of the Clean Water Act (33 U.S.C. 1344). Any person may request, in writing within the comment period specified in the notice, that a public hea ring be held to consider this application. Requests for public hearing shall state, with particularity, the reasons for holding a public hearing. The District Engineer has consulted the latest published version of the National Register of Historic Places for the presence or absence of registered properties, or properties listed as being eligible for inclusion therein, and this worksite is not registered property or property listed as being eligible for inclusion in the Register. Consultation of the National Register constitutes the extent of cultural resource. investigations by the District Engineer, and he is otherwise unaware of the presence of such resources. Presently, unknown archeological, scientific, prehistorical, or historical data may be lost or destroyed by work under the requested permit. The District Engineer has determined, based on a review of data furnished by the applicant and onsite observations, that the activity will not affect 4r, ---A -3- species, or their critical habitat, designated as endangered or threatened pursuant to the Endangered Species Act of 1973. The decision whether to issue a permit will be based on an evaluation of the probable impacts, including cumulative impacts, of the proposed activity and its intended use on the public interest. Evaluation of the probable impacts which the proposed activity may have on the public interest requires a careful weighing of all those factors which become relevant in each particular case. The benefits which reasonably may be expected to accrue from the proposal must be balanced against its reasonably foreseeable detriments. The decision whether to authorize a proposal, and if so the conditions under which it will be allowed to occur, are therefore determined by the outcome of the general balancing process. That decision should reflect the national concern for both protection and utilization of important resources. AL1 factors which may be relevant to the proposal must be considered including the cumulative effects thereof. Among those are conservation, economics, aesthetics, general environmental concerns, wetlands, cultural values, fish and wildlife values, flood hazards, flood plain values, land use, navigation, shore erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food and fiber production, mineral needs, considerations of property ownership, and, in general, the needs and welfare of the people. For activities involving the placement of dredged or fill materials in waters of the United States, a permit will be denied if the discharge that would be authorized by such permit would not comply with the Environmental Protection Agencies' 404(b)(1) guidelines. Subject to the preceding sentence and any other applicable guidelines or criteria, a permit will be granted unless the District Engineer determines that it would be contrary to the public interest. Generally, the decision whether to issue this Department of the Army permit will not be made until the North Carolina Division of Environmental Management (DEM) issues, denies, or waives State certification required by Section 401 of the Clean Water Act. The DEM considers whether or not the proposed activity will comply with Sections 301, 302, 306, and 307 of the Clean Water Act. The application and this public notice for the Department of the Army permit serve as application to the DEM for certification. Additional information regarding the Clean Water Act certification may be reviewed at the offices of the Environmental Operations Section, North Carolina Division of Environmental Management, Salisbury Street, Archdale Building, Raleigh, North Carolina. Copies of such materials will be furnished to any person requesting copies upon payment of reproduction costs. The North Carolina Division of Environmental Management plans to take final action in the issuance of the Clean Water Act certification on or after December 23, 1986. All persons desiring to make comments regarding the application for Clean Water Act certification should do so in writing delivered to the North Carolina Division of Environmental Management, Post Office Box 27687, Raleigh, 4r 1* -4- North Carolina 27611-7687, on or before December 17, 1986, Attention: Mr. William Mills. Written comments pertinent to the proposed work, as outlined above, will be received in this office, Attention: Mr. Ernest Jahnke, until 4:15 p.m., December 15, 1986, or telephone (919) 343-4467. Paul W. Woodbury Colonel, Corps of-Engineers District Engineer 4 42 40 0 6 .112 1 • ra I 1 J A - = a . .::-• ' -r te Sh??7" ! OF.3 SCALE 112 INCH- I MILE :? ?? '? 001 y I ?- • I I NATURE CONSERVANCY PURPOSED GIFT \ t_ \• .C , a PURPOSED DRAINAGE , ? ? y ?I 1 I / ? G? - M 20 4 '4 y5 ZVO y . 310 01 5 n5 1da d A O ? n p a i 1 2 O ti ? O A O n a 0 m O ti n O a G c > E = i " m n n • O 2 O L m i ti A > ? ` C 0 r o I ? 0 9 ° ^^ vl = z x ~ H D i ; ' r z a o 4 e ; D 2 2 n 0 e° t P a a N 3 n A 2 a I? ?O H O n 0 n ti n x n ?It U? A On a a 2 H 1 I%*' n ..p sHEF-T'.3D1: 3 ^- At. Regu'lat oryEF ranch DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS P.O. BOX 1890 WILMINGTON, NORTH CAROLINA 28402-1890 November 10, 1984 SUBJECT: File No. SAWC087-N-010-0073 Mr. William Mills Water Quality Section Division of Environmental Management North Carolina Department of Natural Resources and Community Development Post Office Box 27687 Raleigh, North Carolina 27611-7687 Dear Mr. Mills: n'OV 13 1986 Enclosed is the application of the Federal Paper BR QUALITY SECTl' RATIONS BRANC Company, Incorporated, represented by Mr. M. F. Fox, for a Department of the Army permit and a State Water Quality Certification to place excavated material in pocosin wetlands between the Shallotte and Lockwood Folly River basin (Driving Creek) to facilitate reforestation of two tracts off N.C. Highway 211, approximately 18 miles south of Bolton, Brunswick County, North Carolina. Your receipt of this letter verifies your acceptance of a valid request for certification in accordance with Section 325.2(b)(ii) of our administrative regulations. We are considering authorization of the proposed activity pursuant to Section 404 of the Clean Water Act, and we have determined that a water quality certification may be required under the provisions of Section 401 of the same law. A Department of the Army permit will not be granted until the certification has been obtained or waived. In accordance with our administrative regulations, 60 days after receipt of a request for certification is considered a reasonable time for State action. Therefore, if your office has not acted on the request by January 12, 1987, the District Engineer will deem that waiver has occurred. Questions or comments may be addressed to Mr. Ernest Jahnke, telephone (919) 343-4467. Sincerely, h as W. H t thief, Regulatory Branch RECEIVE NOV 13 1° WATER QUP' OPERATIC PIVED b .. ''.yy Enclosure APPLICATION FOR PERMIT TO EXCAVATE ANOJOR FILL WATER ()uALITY CERTIFICATION EASEMENT IN LANDS COVERED BY WATER CAMA PERMIT FOR MAJOR DEVELOPMENT Department of the Array DopwUrrant of AdrMlnbtratlon State of North Carolina tint corps*( nt of e W1101 rlstert OtsMcl IGS 14&12) Departrnont of Natural Rswurcnsod Cornrnunlty Davolopm 33 CFR 21)9.32 rs, (GS 113.229, 143.215.3(x)(1), 143.215.3(c), 113A•112 Please type or print and fill in all blanks. If information is not applicable, so indicate by placMq NIA in blank. 1. Applicant Information A. Name Federal Paper Board Co. I c.• U, F. x Last First Middle B. Address P. O. Box 338 • Street, P. O. Box or Route Bolton NC 28423 State Zip Code Phone Cav or Town IL L,oeatlon of Proposed Project: A. County Brunswick B. 1. City, town, community or landmark Adiacent to Highway 211 18 mil 2. Is proposed work within city limih? Yes No X C. Creek, river, sound or bay upon which project is located or nearest named body of water to project Driving Creek 111. Description of Project (See attachment) A. 1. Maintenance of existing project 2. New work B. Purpose of excavation or fill .?wrdth depth 1. Access channel length- 2. Boat basin length- width depth 3. Fill area length .?.??width depth Other length _.__width depth C. 1. Bulkhead length Average distance waterward of MHW (shoreline) 2. Type of bulkhead construction (material) D. Excavated material (total for project) 1. Cubic yards 2. Type of material - E. Fill material to be placed below MHW (see also VI A) 1. Cubic yards 2. Type of material IV. Land Type, Disposal Area, and Construction Equipment: (See attaclnent) A. Does the area to be excavated include any marshland, swamps or other wetland? Yes No B. Does the dispnsal area include env marshland, swamps or other wetland' Yes No C. Disposal Area 1. Location 2. Do you claim title in disposal area! D. Fill material snuwce if Irll is to be trussed in E. How will excavated material be entrapped and erosion controlled' F. Type of equipment to he used G. Will marshland he crossed to transporting equipment to project site' If yes, explain v. immaiiid lk+ d Praiea Anse ( 1 (See attacYmlent) A. 1. Prkits 2 C ciil 3. No rsing Dev*icmetent Of Indutarial 4. Other IL 1. Lot si:els) 2. Elavatlcn of lot(s) above n%an high waor - 3. Soil type and tLxture 4. Type of building facilities or structures S. Sewage disposal and/or waste water t;eatmeni A. Existir,.! - Planned 8. Describe 6. Land Classifieatinn (circle can.) DEVELOPED TRAkisi nuN. t. COMMUNITY RURAL CONSERVATION OTHER ----_.-~ (See CAMA Local Land Use Plan Synopsis) VI. Pertaining to Fill and Water Quality. A. Does the proposed orniect :rvolve the placement of fill materia?s below mean'++gh water? Yes__..?No X IL 1. Will any runoff or discharge enter adjacent waters as a result of project activity or planned use of the area following project completions Yes X No_ 2. Type of dixharge Runoff Driving creek just prior to confluence with Muddv Branch 3. Location of disc VIC rrowt rate of shoreline erosion Iif known): VUL List permit numbers and issue dates of previous Department of Army Corps of Engineers or State permits for . work In project area, if applicable: N /A UL Lw4th of time required to complete project: X to addition to the completed application form, the following items must be provided: A. Attach & Copy of the dead (with State application only) or other instrument under which applicant •• claims title to the affected property. OR if applicant is not claiming to be the owner of said property, then forward a copy of the deed or other instrument under which the owner claim. title plus written permission from the owner to carry out the proiect on his land. 8. Attach an accurate work plat drawn to scale on SY, X 11" white paper (see instruction booklet for details). Note: Original drawings preferred • only h,gh quality copies accepted. C. A copy of the aopl+cauon and plat must be served uoon adiacent riparian landowners by tegistered or certified mail or by publication (G.S. 113.224 (d))Enter date served D. List names and complete addresses of the riparian landowners with property adjoining applicant's. Such owners have 30 d.vs in which to submit comments to agencies listed below. XI. Certification requirement: I certify that to the best of my knowledge, the proposed activity complies with the State of North Carolinak approved coastal management protram and will be conducted in a manner consistent with such program. X11. Any permit issued pursuant to this aoolication will allow only the development described in this appli cation and plat. Applicants should therefore describe in the aoalication and plat all anticipated devel- opment activities, including construction, excavation, filling, and land clearing. DATE 9 rc 7 4 Aoolicant's Signature DAF42 SEE REVERSE SIDE FOR MAILI04G INSTRUCTIONS r { PLEASE BE SURE THAT: - Bolt coot" am coor*WW -All blanks are tWo d In You haw sfgtned bout e0011110 if you have any questlom pig esll Yew rKfenaf flOW O f m Mail 2112 COPY to: District Engineer Wilmington District Corps of Engineers P. O. Box 1890 Wilmington, N. C 28402 (Note: attach Corps transmittal letter) Phone: 919/343.4631 AND Mail one copy to your regiona, field office as indicated on tre map below: From north side of Pandko River oe Still NW: tsesT1e i. Washington Regional Offbe c? Department of Natural Resotivim and ConvmWAy Ds+eaie0annlst 1502 North Market Street "WK Washington, N. G 27889 Phone 919/946-6481 eE,.ufoc?' ?. -'foe c"vew Frnm south side of Pimlico River to Pender0mlNr COtstltY Mnb: 0-vision of Marine Fisheries Department of Natural Resources and Community Oewioptso tt P O. Box 759 Morehead City, N. C. 28557 Phone 919172.6•7021 aftowswKtC For PerWer, New Hanover and Brunswick Lounties- Wilmington Regional Office Department of Natural Resources and Community Development 7225 Wriehtsville Avenue Wilmintton. N. C. 28403 Project Description General The purpose of this applicaton is to seek U. S. Army corps of Engineers approval for discharge of excavated materials onto lands of Federal Paper Board Co., Inc., pursuant to construction of drainage ditches for forestry use. The specific tracts of land in question (described below) were designated as jurisdictional adjacent wetlands requiring permits for drainage ditch construction by Mr. Charles Hollis in letters to Mr. M. F. Fox and Mr. John Alsup dated November 9, 1983, and June 18, 1985, respectively. The information requested by Mr. Hollis for processing a permit for discharge of excavated material is provided in this attachment. The land management objective of the proposed discharge of excavated material is to facilitate reforestation of the tracts with genetically improved strains of loblolly pine and hardwood. The land has been held for the purpose of timber production for nearly a century. It was purchased by Federal Paper Board, Inc. from Waccamaw Lumber Co. in 1937. The excavation involves construction of primary (field) drainage ditches that will discharge to the collector drainage system that has been in place for some years. All other practices associated with the reforestation effort (including access road construction) are normal silvicultural practices for the region and thus are exempt from all permit requirements in accordance with 33 CFR Part 323.4. The paper titled "Normal Silvicultural Practices for . Eastern North Carolina" that was submitted to the Wilmington District, Corps of Engineers, by The North Carolina Forestry Association describes those practices in detail. During 1977 Federal Paper Board Company, Inc. contributed 13,850 acres of prime pocosin, savannah and ridge land to the North Carolina Nature Conservancy. Much of this land is in its virgin state. As noted on the cross hatched areas of the location sketch, the company is proposing to contribute an additional 1872 acres adjoining the existing gift on both sides of highway 211. The Nature Conservancy is very interested in receiving this gift, part of which is a diversified savannah area containing as many as 50 species per square meter. The remaining area is in pocosin or Southern White Cedar organic flats. The North Carolina Nature Conservancy (North Carolina Field Representative Frederick W. Annan, Chapel Hill, NC) is aware of Federal's development plans for the areas adjoining them and has their support. Tract Descriptions The land for which this project is proposed consists of two tracts that will be referred to as the Canady Road and Richardson Road tracts. Both tracts are located in Brunswick County, near state highway 211 about 18 miles south of Bolton, NC. The attached vicinity map and tract maps show the locations of the two tracts of land and the road and drainage systems in the area. As noted on the tract maps, the Canady Road tract contains 983 acres and the Richardson Road tract contains 584 acres. t • Topography and Soils The Richardson Road and Canady Road tracts are elements of a large pocosin located on the interstream divide between the Shallotte River and Folly River basins to the south and Waccamaw River basin to the north. Relief-is low, averaging about three feet per mile. The soils on both tracts formed from parent materials of unconsolidated marine sediments and are poorly drained (Brunswick County Soil Survey Field Sheets, dated 1-82). The soils on the Canady Road tract are a complex mixture of organic and mineral soil series. About half of the area of the tract is Croatan muck. The Croatan Series has an organic surface that typically ranges from 16-35 inches in thickness overlying dark sandy loam. The mineral soils occupying the remainder of the tract are predominately very poorly drained mineral soils with a dark surface. The mapped series are Torhunta mucky fine sandy loam, Pantego mucky loam, and Woodington fine sandy loam. Several small areas that rise slightly above the flat terrain consist of Foreston loamy fine sand. The mineral surface of the Foreston series is yellowish-red in color due to a higher clay content and slightly elevated position relative to the other mineral soil series. The soils on the Richardson Road tract are predominately mineral with only a small inclusion of Croatan muck. The mineral soil is mapped mainly as the Torhunta series with some very small areas of Woodington and Foreston series. Vegetation The vegetation on the Canady Road tract is predominately high pocosin. The relatively tall pocosin shrub layer of gallberry, fetterbush, red bay, etc., predominates in some areas with low densities of pond pine and Atlantic white cedar present in the overstory. Some sections of the tract support stands of pond pine or mixed stands of pond pine and cedar of varying tree size and density that have a dense pocosin shrub understory. Some small sections of pond pine and cedar stands have sufficient wood volume to support a harvest operation. A few cypress and red maple are present. The vegetation of the Richardson Road tract is predominantly low pocosin. A dense shrub layer that averages about 6-7 feet in height has a scattered admixture of young pond pine trees and some older pond pines that are obvious fire survivors. The character of this vegetation indicates that it is the resultant of a very intense wildfire in the recent past. A few young cypress and an occasional older cypress tree are present in some areas. Drainage System As indicated in an earlier section, the roads and associated collector canals (that provide spoil for the roads) surrounding these tracts have already been constructed. The excavation activity needed for this project is to construct the primary or field ditches that are denoted by dotted lines on the tract maps. The primary ditches will be spaced 10 chains (660 ft.) apart and will be 5 ft. deep with a 1.5 ft. bottom width and 1:1 side slope. Such ditches are dug with a track mounted V-bucket backhoe. Best management practices will be followed during construction to minimize sediment impacts on water quality and to prevent alteration of natural surface water movement patterns. Both tracts are located north of the water divide that separates the Waccamaw River Basin to the north from the Shallotte River and Holly River Basins to the south. Thus outflow.from these tracts enters the headwaters of the Waccamaw River. The outflow from the Canady Road tract enters a collector canal that discharges to the channel of Driving Creek just prior to its confluence with Muddy Branch (see tract map and vicinity map). The outflow from the Richardson Road tract enters the secondary canal along Clyde Ellis Road, then enters a large outfall canal on the west side of state highway 211 that flows northward and then westward to discharge to the channel of Driving Creek near its confluence with Muddy Branch. Note that the flow of Driving Creek does not flow its historical channel west of state highway 211 but enters the large canal that flows northward and then westward. It is surmised that the large canal on the west side of the highway was constructed at least in part to provide spoil for construction activity on the highway. It is not known when the diversion of Driving Creek occurred nor who directed its accomplishment. Reforestation Activity As noted earlier, the reforestaton practices to be utilized in this project are long-established normal silvicultural practices for poorly drained soils in this region. Merchantable timber will be harvested with standard mechanical equipment to include feller-bunchers, skidders, and loaders. Site preparation will vary with conditions on the tracts. Large stumps and residual unmerchantable trees larger than 6 inches dbh will be sheared. The entire area of each tract will then be chopped, burned, and bedded. Seedlings will be planted by hand. Alternatives There are no viable upland alternatives for the proposed project. The pocosin land owned by Federal Paper Board, Inc. is an essential element in the raw material plan for the manufacturing facility at Riegelwood. A dependable supply of wood at reasonable cost is critical to the economic operation of such a large pulp and paper mill. Maximizing the wood production from company owned land that lies in close proximity to the mill is a critical strategy in the raw material plan. The intensive silviculture practiced on company-owned timberlands is the only cost-effective way to realize the high potential productivity of these lands. Al' 111 y ? I • r5 ?? • ?• ! 1 ? 0 _-_ ? ....! ? ?.?- I.Al 1 0 1 T J I .' K 1 ;. 1 10 14 L y i I ? nll ?, , ••? 1 'X 1f • ' • r y y C r e o ro - - ti y,, a' n c? 2 i m I _ o i ?p q0 .1t `I NATURE CONSERVANCY GIFT N0.2 90 i i i ,i f v \ \ y NATURE CONSERVANCY \ \ \ \ / GIFT NO. 2 \ n 'T NATURE CONSERVANCY 20 15 10 5 0 CHAINS 20 40 - PROPOSED BACKHOE DITCH ROADS -. -.-. - SECONDARY CANALS RICHARDSON ROAD TRACT FEDERAL PAPER BOARD COMPANY, INC. BOLTON, NORTH CAROLINA BEATTY LOOP SCALE 1 a 20 Ch01e5 ACRES 584 COUNTY YW? DRAWN BY DATE NO. ?MQKATOKq 54f14 fs? ProAe,1y hne W ' N S PO 16. CHAINS 20 00 Cm N - - - - PROPOSED BACKHOE DITCH o "ca ROADS ?c -, -.- • - SECONDARY CANALS y CANADY ROAD TRACT 1 MARSHALL HOOKS ROAD LATTAY HAYNES ROAD 1 1 r