20190432 Ver 1_USACE correspondence_20190531

Strickland, Bev
From: Bailey, David E CIV USARMY CESAW (USA) < [e-mail] >
Sent: Friday, May 31, 2019 12:09 PM
To: Mularski, Eric; Homewood, Sue
Cc: Vena, Dave; DePalma, Alicia ([e-mail]); Rogers, Carl
Subject: [External] RE: Request for Additional Information; PNG Pleasant Garden Looping
Project, Guilford Co.; SAW -2018-02075 (UNCLASSIFIED)
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Hi Eric. I apologize for not reviewing your responses more quickly. I admit that I still have to go fully review the revised
information you sent, but I do want to respond regarding item #4, Wetland 8 in particular.
I do understand that this area was already clear cut by others, and this is an issue we see frequently on linear projects. I
tried to state this in my request for additional information but I realize that it was buried in my larger item #4 request:
although Wetland 8 was clear cut by others, we have no reason to believe that this wetland wouldn't otherwise be
allowed to regenerate into a PSS or PFO wetland system. As such, since the PNG project would keep the permanently
maintained corridor as a PEM system, rather than letting the wetland regenerate into a PSS/PFO, we will require
compensatory mitigation at 1:1 for the long-term loss of wetland function directly related to the PNG project.
We see this situation as different than permanently maintained corridor through a wetland within a maintained grass or
pasture area, where the expectation would be that the existing land use (PEM) would continue and would therefore not
typically consider the permanently maintained corridor as a permanent loss of wetland function requiring compensatory
mitigation.
This approach is consistent within our field office for other similar projects. Hopefully this makes sense, but if you have
any further questions please let me know.
-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.
From: Mularski, Eric [mailto:[e-mail]]
Sent: Tuesday, May 7, 2019 2:40 PM
To: Bailey, David E CIV USARMY CESAW (USA) <[e-mail]>; Homewood, Sue
([e-mail]) <[e-mail]>
Cc: Vena, Dave <[e-mail]>; DePalma, Alicia ([e-mail])
<[e-mail]>; Rogers, Carl <[e-mail]>
Subject: [Non-DoD Source] RE: Request for Additional Information; PNG Pleasant Garden Looping Project, Guilford Co.;
SAW -2018-02075 (UNCLASSIFIED)
Dave,
We appreciate the comments to the submitted Pre -Construction Notification for PNG's Pleasant Garden Road Project.
Below are responses to your questions and comments.
1) Per NWP 12 Regional Condition 4.1.1, please explain why the avoidance of direct impacts due to one or more
wetland/stream crossings cannot be avoided by HDD or directional drill methods?
• With the exception of Stream S10, the other 14 streams impacted by the project range between 2' and 5' in
width. Six of these 14 streams are intermittent in nature and will likely not have significant flow during
construction of the project. These streams are proposed for open -cut trenching operations due to their small size,
to reduce the amount of additional clearing within the regulated riparian stream buffer and adjacent forested
wetlands required for HDD, to reduce impacts to affected landowners, and to reduce impacting additional
landowners.
• Stream 10 was evaluated for an HDD crossing; however, preliminary designs of the HDD indicated that impacts to
an adjacent stream (labeled as Stream 5) depicted on Drawing PNG-C-330-0001018 would occur due to
additional workspace to conduct the HDD (stringing area, additional easement, or drill pad area). An HDD would
have resulted in more significant impacts to landowners and potentially fragmented their properties. The current
alignment through this area was chosen to follow existing property lines and reduce impacts to landowners.
• The potential for an inadvertent return during trenchless crossing operations which could result in impacts to the
stream lasting several weeks as opposed to a conventional open -cut crossing which should be completed in 24
hours, or less.
2) Please provide the permanent seeding specs for wetland and stream impact areas.
NC Piedmont Riparian Mix - (ERNMX-307) (20 lbs/acre) NC Piedmont FACW Mix (ERNMX-308) (20 lbs/acre)
Botanical Name
Common Name
% of mix
Botanical Name
Common Name
Sorghastrum nutans
Indiangrass
26
Panicum anceps
Beaked Panicgrass
Panicum anceps
Beaked Panicgrass
25
Elymus virginicus
Virginia Wildrye
Elymus virginicus
Virginia Wildrye
20
Carex vulpinoidea
Fox Sedge
Panicum clandestinum
Deertongue
20
Carex lupulina
Hop Sedge
Chamaecrista fasciculata
Partridge Pea
4
Rhynchospora globularis
Globe Beaksedge
Hibiscus moscheutos
Crimsoneyed Rosemallow
2
Juncus effusus
Soft Rush
Juncus effusus
Soft Rush
1
Hibiscus moscheutos
Crimsoneyed Rosemallow
Juncus tenuis
Path Rush
1
Veronia noveboracensis
New York Ironweed
Vernonia noveboracensis
New York Ironweed
1
Scirpus cyperinus
Woolgrass
3) The plan sheets show an impact to Stream 21 (Stream Impact S8), however this stream does not appear on the
updated delineation map.
Figure 6b has been updated to illustrate Stream 21 also attached is the NCDWR Stream Identification Form.

4) The Corps of Engineers, Wilmington District, Raleigh Regulatory Field Office (Corps) typically requires
compensatory mitigation for permanent conversion of one wetland type to another, including the conversion of
shrub -scrub wetlands - or those that have been recently cleared and would otherwise regenerate as shrub -scrub
or forested wetlands - to herbaceous wetlands. As such, the areas of the following Wetland Impacts within the
proposed permanent maintenance corridor will require compensatory mitigation at a 1:1 ratio unless otherwise
justified based on aquatic function (i.e. NCWAM evaluation): W4, W7, W8, W9, W10 (which appears to be
partially forested?), and W17).
The PCN Section B.2 and B3 Impact tables have been revised for crossings W4, W7, W8, W9, and W10 (see
attached). Crossing W17 - Wetland 8 has already been clear cut by others. See Photograph below taken on
12/5/2018.
5) Typically, permanent discharge of fill material (including rock) into a wetland would warrant compensatory
mitigation at a 2:1 ratio (e.g. Wetland Impact W29).
A revised mitigation calculation includes a 2:1 ratio for permanent fill impacts at crossing W29.
6) Please provide the NCDMS acceptance letters, itemized for each HUC (03030002 and 03030003), showing that
NCDMS can provide the appropriate amount of compensatory mitigation in each HUC.
Please see attached revised NCDMS Acceptance Letter.
7) The SHPO letter indicates that additional items are required for their review. Has an updated letter been
requested following submittal of this additional information?
Yes. Please see attached letter from SHPO dated 1/17/2019.
After your review of our responses, please let us know if your require additional information to process our request.
Thank you,
Eric Mularski, Pws
D 704-973-6878 M 704-806-1521
hdrinc.com/follow-us
From: Bailey, David E CIV USARMY CESAW (USA)[mailto:[e-mail]]
Sent: Friday, April 26, 2019 4:19 PM
To: Mularski, Eric <Eric.Mularski @hdrinc.com>; Vena, Dave <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: Request for Additional Information; PNG Pleasant Garden Looping Project, Guilford Co.; SAW -2018-02075
(UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
Messrs. Clayton and Gonzales,
Thank you for your PCN and attached information, dated and received 4/4/2019, for the above referenced project. I
have reviewed the information and need clarification before proceeding with verifying the use of Nationwide Permit 12
(Blockedhttp://saw-reg.usace.army.mil/NWP2017/2017NWP12.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) Per NWP 12 Regional Condition 4.1.1, please explain why the avoidance of direct impacts due to one or more
wetland/stream crossings cannot be avoided by HDD or directional drill methods?
2) Please provide the permanent seeding specs for wetland and stream impact areas.

3) The plan sheets show an impact to Stream 21 (Stream Impact S8), however this stream does not appear on the
updated delineation map.
4) The Corps of Engineers, Wilmington District, Raleigh Regulatory Field Office (Corps) typically requires
compensatory mitigation for permanent conversion of one wetland type to another, including the conversion of
shrub -scrub wetlands - or those that have been recently cleared and would otherwise regenerate as shrub -scrub
or forested wetlands - to herbaceous wetlands. As such, the areas of the following Wetland Impacts within the
proposed permanent maintenance corridor will require compensatory mitigation at a 1:1 ratio unless otherwise
justified based on aquatic function (i.e. NCWAM evaluation): W4, W7, W8, W9, W10 (which appears to be
partially forested?), and W17).
5) Typically, permanent discharge of fill material (including rock) into a wetland would warrant compensatory
mitigation at a 2:1 ratio (e.g. Wetland Impact W29).
6) Please provide the NCDMS acceptance letters, itemized for each HUC (03030002 and 03030003), showing that
NCDMS can provide the appropriate amount of compensatory mitigation in each HUC.
7) The SHPO letter indicates that additional items are required for their review. Has an updated letter been
requested following submittal of this additional information?
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: 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.
CLASSIFICATION: UNCLASSIFIED
CLASSIFICATION: UNCLASSIFIED