20190596 Ver 1_Notice of Incomplete App_20190613

Strickland, Bev
From: Jim Spangler <[e-mail]>
Sent: Thursday, June 13, 2019 11:56 AM
To: Johnson, Alan
Cc: Scott Childers; Erica Brizzee; Matt Pannell; David Nelson; Dalton Cook; Maria Polizzi
Subject: RE: [External] FW: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -
Construction Notification)
Attachments: Veronica Springs Culvert Profiles.pdf
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[e-mail]
Hello Alan,
Please see the attached exhibits showing the profiles of the culverts. They are embedded below the exiting grade and
the dissipaters are as well. Substrate will naturally attenuate into the culvert. This will pass aquatic life, per the
standard conditions in the 404 and 401. 1 am not aware of any parameters of the standard conditions in the 401
Certification that are unmet by this design. Again, the Corps has issued the 404 and is satisfied for the purposes of the
Clean Water Act that all appropriate alternatives analysis, avoidance of impacts to the greatest extent practicable, and
minimization of unavoidable impacts have been documented. Based on these design details and the information
submitted previously, there is no indication that the proposed designs would remove or degrade existing uses; therefore
it seems that issuance of a 401 Certification is in order, pursuant to 15A NCAC 02H .0506.
I've included the e-mail addresses of the designers at ESP who have engineered the site and have obtained the local
design approvals from the engineering department, etc. If you have additional concerns related to engineering design,
can you please "Reply All", and specifically identify what aspect(s) of 15A NCAC 02H .0506 are not met by the proposed
design(s)? We are hopeful that this will not be necessary and that the 401 Cert is forthcoming.
Regards,
Jim
James A. (Jim) Spangler, CEI, A.M. ASCE
President
6 SPANGLER
19ENVIRONMF—NTAL, INC.
Celebrating 20 Years of Excellence 11999-2019
919-630-5637 Mobile
919-875-4288 Office
919-875-4287 Fax
4338 Bland Road, Raleigh, NC 27609
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From: Johnson, Alan [mailto:[e-mail]]
Sent: Wednesday, June 12, 2019 2:52 PM

To: Jim Spangler <[e-mail]>
Subject: RE: [External] FW: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
The information regarding nomenclature for stream/wetland identification, was also for future application. This
happens from time to time with various identifiers and then trying to figure out what means what.
However, apparently these two comments below are getting lost in translation. Pipe size and is riprap placed in
streambed embedded?
Impact #1 And #3, a dual culvert may be more appropriate. 102 inches diameter maybe two large to handle base
flow. A base flow culvert and storm surge culvert would be more appropriate. Mickey Mouse design, with the storm
surge located at/near/above OHW.. I appreciate that the town has approved the culvert for their standard (passing a
storm surge), but unfortunately that doesn't address my concern about being oversized (think of spilled milk on a floor),
which can affect aquatic passage.
Riprap outfall should be embedded in channel
From: Jim Spangler<[e-mail]>
Sent: Wednesday, June 12, 2019 2:42 PM
To: Johnson, Alan <[e-mail]>
Cc: Dalton Cook <[e-mail]>; Maria Polizzi <[e-mail]>
Subject: RE: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
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[e-mail]
Hello Alan:
In response to your e-mail:
Table:
The engineer reports that the diagram nomenclature followed their flood -routing. We used the nomenclature in the
PCN form which cannot be altered. The impact drawings (diagram) from the engineer are represented on the PCN
impact table by us as:
Diagram PCN Impact Table
Proposed Impact # 1 Stream S3 (115 LF) = Impact # 1 S1 = 115 (perm) + 20 (temp)
Proposed Impact # 7 Stream S1 (77 LF) = Impact # 5 S5 = 77 (perm) + 28 (temp)
Proposed Impact # 4 Stream S2 (107 LF) = Impact # 3 S3 = 107 (perm) + 33 (temp)
Proposed Impact # 2 Wetland W5 (0.014 AC.) =
Impact # 1 W1 = 0.014 acres
Proposed Impact # 3 Wetland W3 (0.076 AC.) =
Impact # 2 W2 = 0.076 acres
Proposed Impact # 5 Wetland W4 (0.021 AC.) =
Impact # 3 W3 = 0.021 acres
Alternatives, etc.:
Please see the attached correspondence to the Corps of Engineers, and for which you were copied, that addressed the
location of the road, ponds, dam, alternatives, embeddedness, etc.
Please let us know when the 401 Cert is issued on this. If you have any further questions, please let us know.
Thanks!

Jim
James A. (Jim) Spangler, CEI, A.M. ASCE
President
1619 SPANGLER
ENVlRC' NMENTALt INC.
Celebrating 20 Years of Excellence 11999-2019
919-630-5637 Mobile
919-875-4288 Office
919-875-4287 Fax
4338 Bland Road, Raleigh, NC 27609
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privileged work product. If you have obtained this e-mail by error or you are not the identified recipient, please notify the sender
by calling toll free 1-866-772-6453, then delete this e-mail (and any attachment) from your system. Use of this e-mail (or any
attachment) by any person other than the identified recipient is strictly prohibited.
From: Johnson, Alan[mailto:[e-mail]]
Sent: Tuesday, June 04, 2019 1:14 PM
To: Jim Spangler <[e-mail]>
Subject: RE: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
Please reply to my comments from my email back on May 15th and I can kick this out.
Thanks
From: Jim Spangler <[e-mail]>
Sent: Tuesday, June 04, 2019 12:27 PM
To: Johnson, Alan <[e-mail]>
Cc: [e-mail]; matt. [e-mail]; [e-mail]
Subject: Re: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
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[e-mail]
Mr. Johnson,
The Corps issued the 404 authorization based on the quantities, form of construction, and locations as shown in the
PCN, and the town has reviewed the engineering design for the culverts/stream crossings. CD approval is in process. Just
waiting on you to issue the 401 for the Corps' authorized impacts.
Regards,
Jim
Jim Spangler, CEI, A.M. ASCE
President
Spangler Environmental, Inc.
Sent via mobile device.

-------- Original message --------
From: "Johnson, Alan" <[e-mail]>
Date: 6/4/19 11:48 AM (GMT -05:00)
To: Jim Spangler<[e-mail]>
Subject: FW: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
Following up on the email below. Just checking up on where things are in process on your end.
Thanks
Alan
From: Johnson, Alan
Sent: Wednesday, May 15, 2019 12:10 PM
To: Jim Spangler<[e-mail]>; [e-mail]
Cc: Matt Pannell <[e-mail]>
Subject: RE: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
I just located the submittal. It hadn't made its way down to me from Central Office.
**Off the bat:
The STREAM table doesn't match the site diagram. Please clarify the impact amount. In the future use "stream"
Diagram
Non wetland S1 (77 ft)
Non wetland S2 (107 ft)
Non wetland S3 (115 ft)
Table
S1 ( 115 ft) plus 20 ft
S3 (107 ft) plus 33 ft
S5 (77 ft) plus 28 ft
Wetland 5
Wetland 1
Wetland 3
(at least the)
Wetland 2
Wetland 4
(acres match)
Wetland 3
Impact #1 And #3, a dual culvert may be more appropriate. 102 inches diameter maybe two large to handle base
flow. A base flow culvert and storm surge culvert would be more appropriate. Mickey Mouse design, with the storm
surge located at/near/above OHW..
Make sure the figures match the diagram and table. Impact #1 (on diagram) = S1 or W1 (on the table)
Riprap outfall should be embedded in channel
**Why isn't the existing driveway crossing being utilized? Is this proposed to be restored? The culvert removed and
stream restored? This should be the preferred alternative to avoid stream #1, which won't substantially alter the
development.
4

X1,
)SED I P
WETLANI
!2 SF 10.076
tO POSED IMPACT #4
NON -WETLAND S2
(1107 LF)
Thanks
alan
r
WF-IFLAND VV4
(925 SF f 0.021 AC.)
-----Original Message -----
From: Jim Spangler<[e-mail]>
Sent: Wednesday, May 15, 2019 10:46 AM
To: [e-mail]; [e-mail]
Cc: Johnson, Alan <[e-mail]>; Matt Pannell <Matt.Pannell @lennar.com>
Subject: [External] FW: SAW-2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
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attachment to [e-mail]<maiIto: [e-mail]>
Hello Scott and Bryan,
We are attempting to get detailed responses together to you for item 1 and 2 below. We have item 1 resolved, and the
engineers are working on the feasibility studies for item 2. We will probably have a follow-up call with Bryan and the
engineering/planning folks to go over any questions Bryan may have after we get the detailed response to him.
However, the discussion below about other comparable projects with different product densities is confusing to us. Is
the point being made here that the Corps feels that the density of the project is not in compliance with 404(b)(1)
Guidelines because it is denser than others that are in the vicinity? Or is the point being made that project density
(number of lots) is not sufficient justification for the applicant's proposal? I agree with you if it's simply the latter, but
the former seems to conflict with the policy that deference is given to an applicant to determine if their project proposal
is economically viable. Can you clarify this for me so that we can provide a complete response?
We are hopeful that this relatively straightforward NWP PCN can get resolved timely.
Thanks,
Jim
James A. (Jim) Spangler, CEI, A.M. ASCE
President

919-630-5637 Mobile
919-875-4288 Office
919-875-4287 Fax
4338 Bland Road, Raleigh, NC 27609
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attorney -privileged work product. If you have obtained this e-mail by error or you are not the identified recipient,
please notify the sender by calling toll free 1-866-772-6453, then delete this e-mail (and any attachment) from your
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-----Original Message -----
From: Dalton Cook
Sent: Wednesday, May 15, 2019 10:10 AM
To: Jim Spangler <[e-mail]>
Subject: FW: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
-----Original Message -----
From: Roden Reynolds, Bryan K CIV (US) [mai Ito:Bryan. K. Roden [e-mail]1]
Sent: Monday, May 06, 2019 3:47 PM
To: Dalton Cook <[e-mail]>
Cc: Johnson, Alan <[e-mail]>
Subject: RE: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
Mr. Cook,
Thank you for the additional information. There is still outstanding issues that need resolved and are as follows:
1). Please provide a copy of the signed and dated NCDMS Acceptance Letter based on the proposed project impacts
in the revised PCN. Permanent impacts which need to be compensatory for and stated in the revised PCN are: 0.111
acres of wetlands, 299 linear feet of stream channel, and 0.01 acre of open waters.
2). Avoidance and Minimization has not clearly be demonstrated for this project. General Condition 23(a) of
Nationwide Permit 29 states "The activity must be designed and constructed to avoid and minimize adverse effects,
both temporary and permanent, to waters of the United States to the maximum extent practicable at the project site."
The term practicable means available and capable of being done after taking into consideration cost, existing
technology, and logistics in light of the overall project purposes (see 40 CFR 230.3(1)). The Corps is concerned that the
applicant has not avoided and minimized impacts to Waters of the United States to the maximum extent practicable as
required by regulation. After further review of the proposed site configuration, it seems one or more of the proposed
wet ponds could be reconfigured/resized and/or moved to a new location with the proposed project boundary to allow
for a different road configuration(s) which would have less impacts to Waters of the United States. These new locations
along with one possible alternative interior road configuration can be found in the attached PDF. This alternative interior
road route would reduce the permanent impacts to streams by 77 linear feet, to wetlands by 0.086 acre, and to open
water by 0.010 acres.
In addition, we compared this proposal to similar residential developments that have received Section 404
discharge permits in Union County (i.e., 5-15 miles radius of the proposed project location) within the last few years. We
looked at proposed project area (in acres) and the number of single family homes/lots per development. Based on the
proposed project area (approximately 86 acres), the applicant is proposing 2.3 single-family/lots per acres as compared

to 0.8 to 1.9 single-family homes/lots for the another permitted projects in the area. Also, the applicant is proposing at
least double the amount of permanent impacts to Waters of the United States compared to the other sites as well. This
would suggest that redesigning the site configuration/interior roads of the development would be practicable and
reasonable since other developments have been constructed with less homes/lots per acre with less impacts.
Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at
http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
-----Original Message -----
From: Dalton Cook [mailto:[e-mail]]
Sent: Wednesday, May 1, 2019 4:32 PM
To: Roden Reynolds, Bryan K CIV (US) <[e-mail]>
Cc: Johnson, Alan <[e-mail]>
Subject: [Non-DoD Source] RE: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
Bryan,
Please see the attached revised impact maps and PCN and the answers to your questions below:
A. Matt Pannell, [phone], [e-mail]
B. The project is a proposed single-family residential subdivision development that includes 200 single family
residential lots, an amenity center, and associated infrastructure.
C. The revised plans and PCN show the proposed temporary impacts. Yes, these areas will be temporarily dewatered
and will use pump-arounds set up to be continuous flow of the streams.
D. The design has been revised to eliminate the impacts to wetlands due to the stormwater outfall riprap apron.
E. The proposed road network was approved by the City of Monroe to meet their requirements of connectivity to
provide adequate access for fire and emergency services, as well as dual -access provided for residents in developments
exceeding 150 lots/units. The culvert lengths have been minimized to the greatest extent possible based on the required
roadway cross section, including necessary utility easements. Utilities have been designed to be within the proposed
roadway to further limit impacts to the stream adjacent to roadway crossings.
Please let me know if you have any additional comments or questions.
Thanks,

Dalton Cook
Environmental Project Scientist
Spangler Environmental, Inc.
Blockedwww.SpanglerEnvironmental.com
Raleigh Office 919-875-4288
4338 Bland Road
Raleigh, NC 27609
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the sender by return e-mail.
-----Original Message -----
From: Roden Reynolds, Bryan K CIV (US) [mai Ito:Bryan. K. Roden [e-mail]1]
Sent: Tuesday, April 23, 2019 1:20 PM
To: Dalton Cook <[e-mail]>
Cc: Johnson, Alan <[e-mail]>
Subject: SAW- 2018-02066_Secrest Short Cut (Notice of Incomplete Pre -Construction Notification)
Importance: High
Mr. Cook
On April 22, 2019, we received the request for jurisdictional determination you submitted on behalf of Lennar Carolinas,
LLC on a property located in Union County, North Carolina. I have completed my initial review of the report and I have
determined that it is incomplete. The following information is necessary before I will issue a determination:
a. Please provide the following information for the applicant (Lennar Carolinas, LLC):
- Point of Contact (Full first and last name)
- Telephone number
- Email address
b. Provide additional, specific details about the proposed residential subdivision:
- Type of subdivision (i.e., single-family, multi -family, etc.)
- Number of home lots
c. There are no temporary impacts for the entire proposed project area. How do you plan to work in the streams for
culvert placement. Will these areas be temporarily dewatered and pump-arounds set up to be continuous flow of the
streams?
d. As stated in Regional Condition 4.1.1. of Nationwide Permit 29 states "discharges in perennial streams, intermittent
streams, and wetlands for stormwater management facilities are prohibited under this permit." Therefore, the proposed
impacts to Wetland W1(0.013 acres) associated with the "wet pond"/stormwater management will not be authorized
under a Nationwide Permit 29. Therefore, a new conceptual design layout will need to be developed with a new site
layout.

e. Avoidance and Minimization strategies/concepts need to be more flushed out and presented. As currently presented
you are within 1 foot of stream impacts results in an individual permit. If changes were needed this would result in a halt
in construction until the project when through the Individual Permitting process.
Please provide the information requested above in ONE consolidated response within 30 -days of the date of this
correspondence. If you do not respond within 30 -days, the request will be administratively canceled. Please contact me
via telephone or e-mail if you have any questions.
Thanks,
Bryan Roden -Reynolds, WPIT
Regulatory Project Manager
U.S. Army Corps of Engineers
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we
continue to do so, please complete the Customer Satisfaction Survey located at
Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
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