20170938 Ver 2_More Info Requested_20190328

NORTH CAROLINA
ROY COOPER Environmental Quality
caverna•
MICHAEL S. REGAN
Seuetary
LINDA CULPEPPER
Interim IX"d r
March 28, 2019
CSX Transportation, Inc.
Attn: Mr. Matthew L. Adkins
351 Thornton Street, Ste 125
Lithia Springs, GA 30122
NCDOT Division 4
Attn: Mr. Tony Coggins
509 Ward Boulevard
PO Box 3165
Wilson, NC 27895
DWR # 17-0938v2
Edgecombe/Nash County
Subject: REQUEST FOR ADDITIONAL INFORMATION
Carolina Connector Intermodal Rail Terminal & Line of Road Improvements
Dear Mr. Adkins and Mr. Coggins:
On January 29, 2019, the Division of Water Resources (Division/DWR) received your application
dated January 17, 2019 requesting an Individual Water Quality Certification and Buffer
Authorization from the Division for the subject project. On February 1, 2019 the U. S. Army
Corps of Engineers (USACE) issued a Public Notice for the project that expired on March 3, 2019
and was received by the Division on February 1, 2019. The Division has determined that your
application is incomplete and cannot be processed. The application is on -hold until all of the
following information is received:
1. The application and supporting documents you uploaded to the Divisions online
Laserfishe repository is one file, 4,588 pages in length. Many pages contained rendering
errors making them unreadable. The large size of the file and lack of electronic indexing
causes difficultly in loading and reviewing. Please re -upload the application and
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

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supporting documents, breaking up the file as appropriate to smaller parts/sections that
are legible.
2. Please copy the Division on any response to USACE request for more information sent
March 14, 2019, including any response to address comments received during the
USACE public notice period.
3. The USACE individual permit application page 3 of 3 was not signed by CSX
Transportation, Inc. or the authorized agent. Please provided a signature page.
4. The Division of Water Resources Riparian Buffer Authorization Form was not signed
(page 6 of 6). Please provided a signature page.
5. Please provide a close-up, detailed, plan view of the stream impacts that consist of
culvert installation. Is any rip -rap proposed with culvert installation? Does the impact
table account for temporary impacts associated with the installation? Please list all
temporary impacts separately from permanent impacts.
6. On page ES -2, executive summary of the Environmental Report, bottom paragraph,
277,708 SF of buffer credit is cited as the quantity needed to offset the proposed
impacts. According the application documents 666,162 SF of buffer mitigation is
needed. Please clarify and correct if necessary.
7. Provide a final SEPA approval issued from the State Clearing House. Please be advised
that while work on an environmental document is in progress, no Department of
Environmental Quality (DEQ) agency shall undertake any action which might limit the
choice among alternatives or otherwise prejudice the ultimate decision on the issue.
[15A NCAC 01C.01071
Stormwater Management
8. Has the stormwater management plan been submitted to the Town of Rocky Mount for
approval? If so, please provide a copy of the stormwater design drawings.
9. Please provide information on the stormwater management for the undetained areas.
How much impervious surface is proposed in each undetained area? Where will the
stormwater flow and will vegetative receiving areas will be provided?
Mitigation
The Division has reviewed the Swift Creek Permittee Responsible Mitigation Plan (PRMP) and
has the following general comments regarding the mitigation plan:

Carolina Connector Intermodal Rail Terminal & Line of Road Improvements
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10. Throughout the document, please change Department of Environmental Quality (DEQ)
to Division of Water Resources (DWR).
11. The conservation easement is for both the DWR & USACE but is noted throughout as the
"USACE easement." There is a template that has been approved by the DWR & USACE
for easements. Please use this template for the PRMP.
The Division has reviewed the Swift Creek Permittee Responsible Mitigation Plan (PRMP) and
has the following comments regarding the stream and wetland mitigation plans [15A NCAC
02H .0502(h)]:
12. Instead of labeling and referring to features as "Relatively Permanent Waters (RPW)s,"
label as "stream" or "ditch."
13. Figure 10 "Aquatic Resources Map" shows UT -K1 and UT -K2 as ditches, however, figure
14a shows these features as stream preservation. These features should not be listed as
stream preservation.
14. The Division recommends the ratio for reach B-1 be 10:1.
15. Section 5.1.1- The mitigation credits listed in the first bullet appear to be for the entire
site as proposed in the previous authorization request, not the current credits as shown
in Table 2, please revise.
16. Section 5.8.1.2 - Wetland Hydrology- The Division recommends the wetland hydrology
performance criteria for the Roanoke soils on this site be at least 10%. While the
current October 2016 Mitigation Update lists Roanoke soils as 9-12%, the Inter -agency
Review Team (IRT) has recently revised some of the ranges and the Roanoke soil series
now shows a range of 10-12%. In addition, the success criteria for years 1 and 2 remains
10%, any changes are up to the discretion of the USACE Project Manager and/or the IRT.
17. Figure 8 shows the USGS flow paths for the proposed project. Figure 14a shows the
proposed Mitigation Work Plan. It appears that the supporting hydrology for Tributary
K will remove much of the supporting hydrology that would contribute to Tributary 131.
The Division is concerned that there will not be enough flow to maintain even an
intermittent channel throughout the monitoring period. Please realize that to receive
stream mitigation credit, Tributary B1 must show the appropriate channel features and
flow to earn credit. The Division recommends installing a stream gauge mid -reach on 61
to verify throughout the monitoring period.
18. Figure 17 - The Division recommends adding monitoring gauges, one near station 50+50
(design sheet Al2) and one near station 59+00 (design sheet A13).

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19. Design sheets- it appears the design shows a single thread channel (A01 and A02)
extending well beyond the Intermittent/Perennial point as seen on Figure 10. The
headwater restoration should begin near the bottom of A02 near station 06+00. In
addition, the sheets show a single thread channel. The Division recommends grading a
floodplain valley (very shallow with minimal grading and nearly flat side slopes) with
wood placed in the lowest part of the valley to provide opportunity for bed diversity
formation. The Division believes headwater restoration is the preferred method for
reaches K and Upper A-1, and the development of a single thread would probably not be
likely until near the confluence of A-1 and K. Moreover, a headwater stream method is
preferable for B-2 until the road. Please note comment #15 as it affects reach B-2 as
well.
20. Stream mitigation credit for headwater stream restoration is calculated using valley
length not from a meandering single thread channel.
21. The Division recommends a stream gauge be placed mid reach for reaches B-2, K, and
upper A-1.
22. Please describe what allowances/plans are being considered for the likely confluence of
a stream restoration channel coming from the eventual bank site near stations
49+00/49+50.
23. In the future, the Division would like the design sheets to show the plan view and the
longitudinal profile on the same sheet. Also, the Division prefers to see the longitudinal
profile at a scale that planned bedform diversity can be discernible.
24. The Division recommends the wetland preservation ratio be 7.5:1.
The Division has reviewed the Swift Creek PRMP and has the following comments regarding the
buffer mitigation plan [15A NCAC 02B.0295]:
25. There is reference to "nutrient offsets" in the PRMP. Please note, that nutrient offsets
cannot be generated on this PRMP. This permittee -responsible mitigation (PRM) is to
meet 401/404 and buffer impacts associated with the CSX project noted in the plan.
Remove all reference to nutrient offsets.
26. Table 6 — It appears UT -K1 is supposed to be 1-1 and K-2 is 1-2? See Page 18. Please
verify/correct.
27. Please provide a complete and detailed planting plan.

Carolina Connector Intermodal Rail Terminal & Line of Road Improvements
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28. The main goal of buffer mitigation sites is for planted hardwood trees to reach maturity
and establish a protected forested community in perpetuity. However, some of the
proposed activities as noted below contradict that goal and are not in compliance with
buffer mitigation sites regulated under 15A NCAC 02B .0295 (n). Specifically:
a. Prescribed burning is prohibited by DWR within the conservation easement area
and would affect the hardwood species required for planting.
b. Planting long leaf pines does not comply with the performance standards
outlined in 15A NCAC 02B .0295 (n)(2) for buffer mitigation sites.
c. "Active Management' of riparian areas as noted in the document appears to
include management that would not be supported in the buffer mitigation areas
such as burning, pruning, thinning, trails, horses, et cetera. (See Section 5.10
Long -Term Management). It is important to note that the conservation
easement will also restrict activities within it and would prohibit management of
trees, hydrology, et cetera outside of the monitoring years. Examples of this
active management language in the PRMP that is problematic/prohibited
include:
i. "Buffer zones within the USACE area may be burned to allow for mosaic
of plant communities." (page 53)
ii. "...upland areas may be more actively managed relying on disturbance
regimes such as burning, disking, mechanical & chemical treatments..."
(page 53)
iii. "...a network of single tract trails will be installed..." (page 53)
iv. "...educational signage maybe placed in various locations along the
trails." (page 53)
Where are the referenced trails located? Are they inside or outside of
the easement? Please provide more details of the trails. Will trees have
to be removed for their construction? Will the trails be impervious?
d. The placement of a "blue trail" is mentioned in the plan. Comments from the
Division on this blue trail were provided in the previous version of this plan
submitted in 2017. What is the "blue trail"? Please provide a figure showing a
preliminary outline of the trail.

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e. Vernal pools, unless planted with hardwood trees, would not meet performance
standards for buffer mitigation credits. Therefore, vernal pool must be excluded
from the square footage of buffer mitigation.
This plan needs to be revised where it conflicts with, or is non-compliant with, the
expectations of buffer mitigation sites outlined in 15A NCAC 02B .0295.
29. If a headwater stream restoration is conducted, the buffer mitigation area is measured
perpendicular to the length of the valley being restored as noted in 15A NCAC 02B .0295
(0)(2). The figures provided show a sinuous channel. Additionally, to use these areas
for buffer mitigation, they must be compliant will all of 15A NCAC 02B .0295 (0)(2).
Please describe how these streams will meet this rule to generate buffer mitigation.
Note, that preservation areas/forested areas adjacent to coastal headwater stream
restoration sites do not meet this rule. Updated figures and tables are expected with
this change.
30. Headwater streams are not credited until an as -built confirms their construction. Please
account for any buffer mitigation areas being altered based on headwater stream
restoration.
31. Section 5.8 needs to include the DWR in addition to USACE on any alternative mitigation
proposed.
32. Section 5.8.4 — Some of the performance standards for generating buffer mitigation
credit in this section differ from 15A NCAC 02B .0295. Some of the performance
standards are more stringent. Address any language that does not at least comply with
15A NCAC 02B .0295 (n)(2). Additionally, only desirable hardwood species may count
towards the stem/acre requirements for buffer mitigation areas. Overall, the species
listed on page 37 seem acceptable.
33. Monitoring should be done no earlier than Late Summer/Fall (late August is the
earliest).
34. Is the Carolina Vegetation Survey (CVS) protocol being used to monitor the site?
35. Monitoring reports should be submitted to the Division in addition to the USACE since
there is buffer mitigation proposed.

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Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC
27699-1617 OR by submitting all of the above requested information through this link:
https://edocs.deq.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested
on the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this
letter, the Division will be unable to approve the application and it will be returned. The return
of this project will necessitate reapplication to the Division for approval, including a complete
application package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Please contact Paul Wojoski at 919-707-3631 or [e-mail] if you have any
questions or concerns regarding the 401 Water Quality Certification, Mac Haupt at 919-707-
3632 or [e-mail], if you have any questions or concerns regarding the stream or
wetland mitigation comments, or Katie Merritt at 919-707-3637 or [e-mail] if
you have any questions or concerns regarding the buffer mitigation comments.
Sincerely,
Jeff Poupart, Section Chief
Water Quality Permitting Section
cc: Richard Harmon, Wood Environmental and Infrastructure Solutions, Inc. (via
[e-mail])
Samantha Dailey, USACE Raleigh Regulatory Field Office
DWR 401 & Buffer Permitting Branch file
Filename: 170938v2CCXl ntermoda ITerm ina land Lineof Road Improvements_TAR_401_IC_Hold