20181486 Ver 1_Email Corps_DLutheran RE_RAI_20181203

Strickland, Bev
From: Greer, Emily C CIV USARMY CESAW (US) < [e-mail] >
Sent: Monday, January 07, 2019 11:36 AM
To: Mairs, Robb L
Subject: [External] RE: Saratoga Residential Sub. (UNCLASSIFIED)
Attachments: 181203 email Corps_DLutheran RE_RAI.PDF
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CLASSIFICATION: UNCLASSIFIED
They are in receipt of my comments (attached).
-----Original Message -----
From: Mairs, Robb L [mailto:[e-mail]]
Sent: Monday, January 7, 2019 10:50 AM
To: Greer, Emily C CIV USARMY CESAW (US) <[e-mail]>
Subject: [Non-DoD Source] Saratoga Residential Sub.
Hey Pearl,
I was checking in on this one as well.
Thanks,
Nuf
Robb Mairs
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
910 796.7303 office
[e-mail] <mailto:[e-mail]>
1

Blockedhttps://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/401-
wetlands-buffer-permits <Blockedhttps://deq.nc.gov/about/divisions/water-resources/water-resources-
perm its/wastewater-bra nch/401-wetla nds-buffer-perm its>
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
CLASSIFICATION: UNCLASSIFIED

From: Greer, Emily C CIV USARMY CESAW (US)
To: "Dana Lutheran"
Subject: SAW -2018-00195 Saratoga Subdivision NWP - Request for additional information (UNCLASSIFIED)
Date: Monday, December 3, 2018 6:03:00 PM
Attachments: ORM Upload Sheet Consolidated Rapanos 20180522.xlsm
CLASSIFICATION: UNCLASSIFIED
Dana -
Please accept this as official correspondence for the above referenced property. The following information is needed
to complete the application and/or to finalize the application review. The applicant is required to electronically
submit a new application package reflecting the required changes and/or additional information.
1. Please either show all isolated wetlands as non jurisdictional and filled or remove them entirely from the impact
map. Please note that the feature at Impact B is an isolated wetland. Please add the four stream features to the impact
map and account for impacts at Impact A and for Tributary 3 located in the vicinity of Keeneland Court/Lot 37.
2. The site has been delineated and verbal approval of the delineation has been provided. Please reference the
delineation and provide answers to questions 4(f) and 4(g) on the PCN.
3. A road crossing is proposed at Impact I; however, there is no indication that a culvert is being installed at this
location, which is required. Please update drawings to reflect this change.
4. The applicant has proposed to construct Secretariat Run to the eastern project boundary and has stated in the
application that this is not a phased project. Due to the location of jurisdictional resources immediately beyond the
project boundary, the applicant will only be allowed to construct a 12 -foot wide access road beginning at the lot
boundary for Lots 20/21. The access road will not be allowed to continue beyond the driveway. Impacts should be
revised to show no wetland impacts on the north side of the road from the Lot 20/21 boundary.
5. At each road crossing, the applicant has proposed to bury culverts either four or six inches. Per the Wilmington
District's Regional General Condition, culverts must be designed and installed so that destabilization and
headcutting are minimized. Additionally, culverts in wetlands do not have to be buried. Given the elevation changes
from north to south at each crossing, the Corps is concerned that the proposal to bury the culverts will result in
secondary drainage effects and headcutting upslope of the crossing. Please either provide a written explanation as to
why the culverts must be buried that also addresses the Corps' concerns or redesign the crossings with an adequate
size and number of unburied culverts to equalize surface waters.
6. The applicant is proposing to install culverts at Impact H that will discharge into what appears to be a piped ditch
before ultimately discharging south to wetlands abutting Harrison Creek. Drainage for this wetland already exists
just offsite from Impact H. Construction of an additional drain will have secondary drainage effects. Burying the
culvert and piping the ditch increases the likelihood of a drainage effect occurring and could also create headcutting.
Please either provide a written explanation of the purpose and need for this drain that also addresses the Corps'
concerns or remove it from the plans entirely.
7. In a pre -application meeting with the Corps, the applicant stated that language regarding how to access upland
areas on lots with wetlands without a permit will be provided in the HOA restrictive covenants. To ensure the
correct information is being disseminated to future buyers, please provide the language that will be used for the
Corps' review.
8. Please revise impact labels and impact amounts, and update drawings accordingly. Also, please fill out the
attached spreadsheet for project impacts and attach it as a separate document when resubmitting.
9. Please provide a compensatory mitigation credit release letter. Without justification, mitigation for wetland and
perennial stream impacts should be provided at a 2:1 ratio and intermittent stream and conversion impacts should be

provided at a 1:1 ratio. Please note that tree cutting on lots with wetlands with the intent to allow the buyer to
maintain those areas in an herbaceous state is considered a permanent impact and should be accounted for in impact
totals and mitigation provided.
Please provide a new application package reflecting the required changes within 30 days of this correspondence.
Feel free to contact me with any questions regarding this project.
Thank you,
Emily Greer, Regulatory Specialist
Wilmington District - Wilmington Regulatory Field Office
69 Darlington Avenue, Wilmington, NC 28403
910.251.4567 (o)
-----Original Message -----
From: Greer, Emily C CIV USARMY CESAW (US)
Sent: Thursday, November 29, 2018 6:15 PM
To: 'Dana Lutheran' <[e-mail]>
Subject: SAW -2018-00195 Saratoga Subdivision NWP - Incomplete application notification (UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
Dana -
Please accept this as official correspondence for the above referenced property. The following information is needed
to complete the application and/or to finalize the application review. The applicant is required to electronically
submit a new application package reflecting the required changes and/or additional information.
1. The application is incomplete because the applicant's contact information has not been provided. The prospective
permittee's first and last name, address (both physical and electronic are required), and telephone number are
required. Because the consultant is not the applicant, providing the consultant's information in lieu of the applicant's
is not correct. Please reference NWP General Condition 32(b)(1) for the required applicant information.
Please provide this information at your earliest convenience to begin the 45 day permit review process.
Emily Greer, Regulatory Specialist
Wilmington District - Wilmington Regulatory Field Office
69 Darlington Avenue, Wilmington, NC 28403
910.251.4567 (o)
CLASSIFICATION: UNCLASSIFIED
CLASSIFICATION: UNCLASSIFIED