20181609 Ver 1_request for more information_20190305

Strickland, Bev
From: Homewood, Sue
Sent: Tuesday, March 05, 2019 10:03 AM
To: '[e-mail]'
Cc: 'Bailey, David E CIV USARMY CESAW (USA)'
Subject: RE: [External] RE: Request for Additional Information: City of Eden Waterline to SoVA
Mega Park; Rockingham Co.; SAW -2018-02188
Attachments: GC4133.pdf
Briana,
Thank you for uploading your response to David's questions to our electronic file system recently. I have two follow up
questions:
1. The stream impact lengths shown in the most recent table appear to be sufficient for the trench activities but do not
seem to include temporary impacts for dewatering activities that are required. Would you please review whether all
construction activities can take place within the permanent impacts shown on the table or provide an updated table that
includes temporary dewatering impacts.
2. Condition 1.2. of GC4133 (attached) states that utility corridors must be 10' from the top of bank when it runs parallel
to a stream. It appears that Impact Site #7 will not meet this condition. Please provide a justification statement for why
the installation cannot be shifted to avoid this impact. If the Division agrees with the justification we will require that
Stream SC be dewatered during construction activities within 10 feet of the streambank. Please call this out on the
plans and identify the length of temporary dewatering impact on the impact table.
Please let me know if you have any questions or concerns about these comments.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, February 20, 2019 5:11 PM
To: Bill, Briana <[e-mail]>; Terry Shelton <[e-mail]>

Cc: [e-mail]; Shelton, Troy <[e-mail]>; Homewood, Sue
<[e-mail]>; Scott Ehrhardt <[e-mail]>; Barksdale, Leslie
<[e-mail]>
Subject: [External] RE: Request for Additional Information: City of Eden Waterline to SoVA Mega Park; Rockingham Co.;
SAW -2018-02188
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]<maiIto: [e-mail]>
Briana,
Thank you for your response to our request for additional information dated 1/25/2019 (received via email 1/28/2019). 1
have reviewed your responses and find them acceptable with the following caveats:
Regarding your response to our item #2), specifically the following statement about riprap being pushed or keyed into
the bank of the waterbody: "This method is shown on the rip -rap placement detail. Please advise of any outlying
concern."
The rip -rap placement detail on Sheet C22 includes the statement "ROCK DUMPED IN PLACE." This is not the same as
riprap being pushed or keyed into the stream bank. In order to avoid confusion, revise the rip -rap placement detail on
Sheet C22 to clearly show the stream bed line extending across the top of the rip rap, and add the statement that riprap
will be pushed or keyed into the stream bed and bank.
Further, regarding your response to our item #4), the information given is not sufficient to justify that HDD or jack and
bore methods are not practicable for the 6 proposed stream crossings. Also, according to the USFWS letter dated
12/20/2018 (attached), they cannot concur with a determination of "may affect, not likely to adversely affect" for the
Roanoke logperch and James spinymussel given the current trenching proposal, known populations of these species, and
lack of additional information. Based on the USFWS letter, information you provided in your PCN and attachments dated
11/21/2018, and additional information you provided on 1/28/2019, the Corps will not challenge the USFWS
determination. Based on discussions with USFWS, if you can modify/re-design the project to avoid impacts to stream
crossings with suitable habitat for these aquatic species (through trenchless methods or otherwise), including
incorporating steps to reduce the likelihood of indirect impacts listed as items 3-7 in the USFWS letter, the Corps could
justify "no effect" or "may affect, not likely to adversely affect" (via Informal Consultation with USFWS) determinations
for these aquatic species. If you maintain that installation via open trench is the only practicable method to complete
this project in these stream areas (assuming acceptable documentation is provided), Formal Consultation with the
USFWS will be required to satisfy Section 7 of the Endangered Species Act for these aquatic species.
If Formal Consultation with USFWS is required for the aquatic species, please be aware that you will be required to
complete and submit a Biological Assessment for Corps approval. The Corps will initiate Formal Consultation with the
USFWS within 15 days of receipt of an acceptable Biological Assessment. From there, the USFWS has 90 days to
complete its analysis and an additional 45 days in which to formulate their Biological Opinion/Incidental Take Statement
and provide this information to the Corps to complete Formal Consultation. The USFWS can request from the Corps a
60 -day extension to the process without consent from the applicant. Please see the following link for more information
about Endangered Species Consultation, including the outline, contents, and common flaws of a Biological Assessment:
https://www.fws.gov/raleigh/es—consultation.html
I understand that a smooth coneflower survey will be performed in May, and that the effect determination for this
species will depend on the results of that survey. In the meantime, please notify the Corps about your anticipated path
forward for this project with respect to the above referenced aquatic species.
Note that the project will remain on hold until the above plan sheet amendment is made and Section 7 consultation is
complete. 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.
-----Original Message -----
From: Bill, Briana [mailto:[e-mail]]
Sent: Monday, January 28, 2019 1:45 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>
Cc: Matthews, Kathryn <[e-mail]>; Shelton, Troy <[e-mail]>; Homewood, Sue
<[e-mail]>
Subject: [Non-DoD Source] RE: Request for Additional Information: City of Eden Waterline to SoVA Mega Park;
Rockingham Co.; SAW -2018-02188
I'm using Mimecast to share large files with you. Please see the attached instructions.
Mr. Bailey,
Attached is a response letter to your Request for Additional Information for the City of Eden Waterline to SoVA Mega
Park in Rockingham County, North Carolina.
Please do not hesitate to contact me with any questions or comments.
Sincerely,
Briana L. Bill, PWS, PWD

Senior Environmental Scientist
Dewberry
551 Piney Forest Road
Danville, Virginia 24540
434.549.8494 (Direct)
540.484.3851 (Mobile)
434.797.4341 (Fax)
Blockedwww.dewberry.com <Blockedhttp://www.dewberry.com/>
From: Bailey, David E CIV USARMY CESAW (US) [mai Ito: David. [e-mail]]
Sent: Thursday, December 20, 2018 3:01 PM
To: Terry Shelton <[e-mail]>; Ehrhardt, Scott <[e-mail]>; Barksdale, Leslie
<[e-mail]>
Cc: Bill, Briana <[e-mail]>; Beverly O'Dell <[e-mail]>; Michael Dougherty
<[e-mail]>; Homewood, Sue <[e-mail]>; Matthews, Kathryn
<[e-mail]>
Subject: RE: Request for Additional Information: City of Eden Waterline to SoVA Mega Park; Rockingham Co.; SAW -2018-
02188
This message originated from outside your organization
0
Please see the attached letter I received this afternoon from USFWS regarding this project. Note that they cannot concur
with proposed determinations for Roanoke logperch, James spinymussel, or smooth coneflower. Please provide
information concerning how you plan to address the concerns listed in the letter, and include that information in your
response to my Request for Additional Information submitted to you by email earlier today. 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: [e-mail] <mailto: David. [e-mail]>
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.

-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (US)
Sent: Thursday, December 20, 2018 2:03 PM
To: 'Terry Shelton' <[e-mail] <mailto:[e-mail]> >; 'Scott Ehrhardt' <[e-mail]
<mailto:[e-mail]»;'Barksdale, Leslie' <[e-mail]
<mailto:[e-mail]> >
Cc: 'Bill, Briana'<[e-mail] <mailto:[e-mail]> >; Beverly O'Dell <[e-mail]
<mailto:[e-mail]> >; Michael Dougherty <[e-mail] <mailto:[e-mail]> >;
'Homewood, Sue'<[e-mail] <mailto:[e-mail]> >
Subject: Request for Additional Information: City of Eden Waterline to SoVA Mega Park; Rockingham Co.; SAW -2018-
02188
0
Thank you for your PCN and attached information, dated 11/21/2018, for the above referenced project. I have reviewed
the information and need clarification before proceeding with verifying the use of Nationwide Permit (NWP) 12
(Blockedhttp://www.saw.usace.army.miI/Portals/59/docs/regulatory/regdocs/NWP2012/NWP12_3-23.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) Project plans require additional details:
a. Currently wetland areas are not clearly visible on the plan sheets. Add all wetland boundaries to the plans and label
them according to the delineation documentation provided by Dewberry on 8/24/2018. 1 recommend that a different
color be used on the plan sheets for wetland lines (such as green?). Show and label the wetland boundaries on the
profile drawings as well;
b. Clearly label all streams on the plan sheets according to the delineation documentation provided by Dewberry on
8/24/2018. 1 recommend that a different color be used on the plan sheets for stream lines (such as blue?). Show and
label the streams on the profile drawings as well;
c. Currently there is no way to match up itemized impacts listed in the PCN with the plans. As such, add Impact Site
labels to the plans, and add corresponding labels to Section D. of the PCN for clarity purposes:
i. Impact Site 1: Wetlands WD and WE
ii. Impact Site 2: Stream SH;
iii. Impact Site 3: Wetlands WC (2 areas);
iv. Impact Site 4: Streams SF and SG, Wetland WB;
v. Impact Site 5: Stream SE;
vi. Impact Site 6: Streams SC and SD;
vii. Impact Site 7: Streams SA and SB, Wetland WA;

d. Specify whether the utility corridor would include a permanent maintenance easement where vegetation would be
maintained in an herbaceous state. If so, include zoomed -in details of each stream and/or wetland crossing showing the
footprint of the permanent maintenance and temporary construction corridors. Such details must also show the extent
of temporary impacts (streams and wetlands) and extent of permanent maintenance impacts through wetland areas.
Further, for each applicable crossing, quantify the acreage of wetlands proposed to be converted from forested
wetlands and permanently maintained in an herbaceous state and add those as separate impacts in Section D of the
PCN;
2) Project plans indicate that stream crossings include discharging rip rap. If so, please confirm (including via profile
drawings) that any rip rap placed below the ordinary high water mark will be placed such that the top of the rip rap will
be no higher than the existing stream bed elevation (see NWP 12 Regional Condition 4.1.11). Note that the "Rip -Sap
Placement Detail" on Sheet C22 does not appear to comply with this Regional Condition. Also, since discharged rip rap
would not be removed, the lengths of stream subject to rip rap discharge must be added to the PCN as permanent
impacts;
3) Given the time past from the date of the USFWS Section 7 self -certification letter, as well as the known occurrences of
several aquatic species in Cascade Creek and the Dan River, we have initiated informal consultation with the USFWS.
Please note that the Corps cannot verify the use of a NWP until Section 7 consultation is complete;
4) Given that occurrences of Roanoke logperch are known is Cascade Creek, and occurrences of James spinymussel are
known just downstream in the Dan River, avoidance of impacts to Cascade Creek via HDD or jack and bore methods
seem reasonable. However, the plans note an alternative trenching method through Cascade Creek and the PCN
accounts for temporary impacts to Cascade Creek due to trenching. Please clear up this discrepancy in the plans and
PCN, such that the project would be compliant with NWP 12 Regional Condition 4.1.1. If the Cascade Creek crossing
would be installed via HDD, remove this impact from Section D of the PCN and add a note on this page clearly indicating
that the impact would be avoided in this manner;
5) Provide a plan including any pertinent detail sections for typical wetland impacts via trenching. Such plans should
including dewatering methods, lengths of time that trenches will be open in wetlands, and confirmation that the top 6
to 12 inches of the trench will be backfilled with topsoil from the trench. Per NWP 12 Regional Condition 4.1.9, provide a
specific wetland restoration plan including how grade and contour will be re-established, anti -compaction measures in
soils subject to construction traffic and matting, stabilization methods, and seeding/planting lists and specifications. Be
sure to specify wetland restoration differences in temporary and permanent easement areas. Such details should be
provided as an addendum that can be referenced in permit Special Conditions;
6) Plan sheet -specific comments:
a. Sheet C5: Wetland lines do not appear on the plan sheet (should be Wetlands WD and WE, per comment 1)a above.
The footprint of wetland areas proposed for impact (permanent maintenance as well as temporary construction
corridors) should be clearly shown on a zoom -in of the crossing (should be labeled "Impact Site 1" per comment 1)c.
above. The sheet references "Provide Stream Restoration per Details"; however, this area includes wetlands rather than
streams, and the plan sheet should reference a Wetland Restoration plan (see comment 5 above);
b. Sheet C6: Clearly show and label Stream SH per comment 1)b above. The footprint of the stream proposed for impact
should be clearly shown on a zoom -in of the crossing (should be labeled "Impact Site 2" per comment 1)c. above);
c. Sheet C7: Wetland lines do not appear on the plan sheet (should be Wetland WC [2 segments], per comment 1)a
above). The footprint of wetland areas proposed for impact (permanent maintenance as well as temporary construction
corridors) should be clearly shown on a zoom -in of the crossing (should be labeled "Impact Site 3" per comment 1)c.
above). The sheet should also reference a Wetland Restoration plan (see comment 5 above);

d. Sheet C8: Clearly show and label Streams SF and SG per comment 1)b above. If applicable, the footprint of the stream
proposed for impact should be clearly shown on a zoom -in of the crossing. The plan sheet shows both an HDD plan and
an "Alternative Open -Cut Cascade" option. Please clear up this discrepancy (per comment 4 above). Wetland lines do
not clearly appear on the plan sheet (should be Wetland WB, per comment 1)a above). The footprint of wetland areas
proposed for impact (permanent maintenance as well as temporary construction corridors) should be clearly shown on a
zoom -in of the crossing. The sheet should also reference a Wetland Restoration plan (see comment 5 above); Note that
both the stream and wetland crossing should be labeled "Impact Site 4" per comment 1)c. above;
e. Sheet C10: Clearly show and label Stream SE per comment 1)b above. The footprint of the stream proposed for impact
should be clearly shown on a zoom -in of the crossing (should be labeled "Impact Site 5" per comment 1)c. above);
f. Sheet C14: Clearly show and label Streams SC and SD per comment 1)b above. The plan sheet indicates that the
waterline would be installed essentially within the bank of Stream SC. As such it is reasonable to assume that the
waterline would impact Stream SC itself. Provide information to justify that impacts to Stream SC would be avoided with
the current plan, or quantify proposed impacts and add to the plan/profile sheets and PCN. The footprint of the streams
proposed for impact should be clearly shown on a zoom -in of the crossing (should be labeled "Impact Site 6" per
comment 1)c. above);
g. Sheet C17: Clearly show and label Streams SA and SB per comment 1)b above. The footprint of the streams proposed
for impact should be clearly shown on a zoom -in of the crossing. Wetland lines do not clearly appear on the plan sheet
(should be Wetland WA, per comment 1)a above). The footprint of wetland area proposed for impact (permanent
maintenance as well as temporary construction corridors) should be clearly shown on a zoom -in of the crossing. The
sheet should also reference a Wetland Restoration plan (see comment 5 above); Note that both the streams and
wetland crossing should be labeled "Impact Site 7" per comment 1)c. above.
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: David. [e-mail]<maiIto: David. [e-mail]>
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
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