20060646 Ver 1_More Info Received_20060608

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Soil & Environmental Consultants, PA
11010 Raven Ridge Road Raleigh, North Carolina 27614 Phone: [phone] Fax: [phone]
www.SandEC.com
June 8, 2006
S&EC Project #9701.W1
DWQ Project #06-0646
NC Division of Water Quality
401 Oversight and Express Permits Unit
Attn: Ian McMillan / Cyndi Karoly
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604-2260
Re: Response to DWQ Request for additional information
East Nash Development
Nashville, Nash County, NC
Dear Mr. McMillan and Ms. Karoly:
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The purpose of this letter is to provide responses to the DWQ letter dated May 22, 2006, which
requested additional information. Please find below the request made by DWQ followed
immediately by our response.
This Office does not believe that the avoidance and minimization requirement for
this project has been adequately addressed. Please provide more definitive
documentation as to why this project must be located at this proposed location,
and if so, please address why the plans cannot be reconfigured to avoid and
minimize impacts to onsite wetland, stream and protected riparian buffers.
The plans for the proposed development have been reconfigured and shifted further north on the
subject property thereby reducing the overall wetland impact from 1.83 acres down to 0.91
acres, a net reduction of 0.92 acres. The intermittent/unimportant stream that crosses through
the middle of the subject property will be impacted in either scenario. In order to shift the
development and reduce the impacts to wetlands, 3 potential retail areas were removed as well
as the gas station pump island. Furthermore, to the east of the development additional area was
reserved for use as a stormwater management area.
2. Please show all stream impacts including all fill slopes, dissipaters, and bank
stabilization on the site plan.
The stream impacts shown on the site plan call for fill in 8201inear feet of stream, which is all of
the stream length contained on the subject property. All stream impacts have been shown.
Charlotte Office:
236 LePhillip Court, Suite C
Concord, NC 28025
Phone: [phone]
Fax: [phone]
Greensboro Office:
3817-E Lawnc3ale Drive
Greensboro, NC 27455
Phone: [phone]
Fax: [phone]

3. Please show all wetland impacts including fill slopes on the site plan.
On the revised site plan, the heavy bold line for the road crossing of the southwestern finger of
the wetland indicates the maximum extent for the fill slope and resultant permanent wetland
impact for the roadway. On the north end of the wetland, the heavy bold line indicates the
maximum extent for the fill slope and resultant permanent wetland impact for the commercial
development. In both cases, the permanent wetland impact amounts reflect the inclusion of the
impact due to the fill slopes.
4. Please indicate and individually calculate all buffer impacts on the site plan.
In the original application there is a letter (dated February 10, 2006) from Mr. Mike Horan of the
DWQ Raleigh Regional office that determined the stream on the property to not be subject to the
Tar-Pamlico Buffer Rules. Additionally, the stream shown on the site plans does not appear on
the most recent version of the USGS Nashville Quad nor does it appear on the NRCS Soil
Survey map and therefore, per 15A NCAC 2B .0259 (3), this feature is not subject to the Tar-
Pamlico Buffer Rules, which is why no buffers are depicted.
S. Please address indirect and cumulative impacts from the proposed project.
As was stated in the narrative supplied with the original documentation, the current location of
the proposed development is between the Nash County Railroad and US Highway 64 which is a
heavily traveled transportation corridor. Additionally, the surrounding area has existing
commercial development (e.g., Food Lion), as well as some residential and agricultural land.
The projected growth in this area, which is immediately outside of the Nashville city limits, will
naturally generate commercial and residential development to meet the needs and demands of the
populace. The proposed location is ideal due to its proximity to a major interstate (I-95), US
Highway 64 and the City of Raleigh and therefore, due to the growth in the area, a commercial
development of some kind would be planned on the subject property. Additionally, the subject
property has road frontage on US Highway 64 Business and therefore, with the County's zoning
requirements, it is a foregone conclusion that the site would be developed commercially. While
the "DRAFT Internal Policy, Cumulative impacts and the 401 Water Quality Certification and
Isolated Wetland Programs" document prepared by the NC Division of Water Quality on April
10, 2004, version 2.1, does suggest that commercial development can result in cumulative
impacts, this proposed development is small in nature and is within a landscape that is already
commercial in nature. It is not expected that the proposed commercial development will induce
any additional future growth that is not already occurring in this area. Additionally, the
stormwater treatment facilities are being designed to meet DWQ's design standards and
therefore, it is not expected that there will be any resultant downstream water quality
degradation.
2

6. Please indicate the location of the protected buffers (clearly representing Zone 1
and Zone 2) as overlays on the site plan.
Please see response to No. 4.
7. Please locate all isolated or non-isolated wetlands, streams and other waters of
the State as overlays on the site plan.
The subject property does not contain any isolated wetlands, streams or other waters of the State.
The jurisdictional features are as shown on the site maps. Afield meeting. was held with Ms.
Jean Manuele of the USACE at which time the delineation was confirmed. A survey map of the
delineation has been submitted to the USACE but has not yet been signed.
8. Please provide cross section details showing the provisions for aquatic life
passage.
The proposed impacts to the stream on the subject property are due to lot fill to make the
property useable for the commercial development. Since this is a first order stream that
originates in a wetland, it does not seem necessary to provide aquatic life passage provisions
from an intermittent stream to a wetland within a pipe length that spans the distance of
approximately 800 feet.
9. Please provide the location of any proposed stormwater management practices as
required by GC 3402.
As stated in the original application, adequately sized areas have been set aside to be used as
stormwater treatment/detention areas while the stormwater plans are finalized. It was requested
that a conditiona1401 be issued that required a DWQ approved stormwater plan prior to any
permanent structures being constructed.
10. Please provide detail for the stormwater management practices as required by
GC 3402. Please be advised this project will require constructed wetlands for
stormwater management.
Stormwater devices will be designed according to DENR/DWQ's most recent publicly available
version of Stormwater Best Management Practices.
11. Please specify the percent of project imperviousness area based on the estimated
built-out conditions.
It has been assumed that the proposed development would be well above the 30% impervi us
requirement and therefore, a stormwater plan is currently being d vel ed.
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12. Please indicate all stormwater outfalls on the site plan.
Please see response to No. 9
13. Please indicate the diffuse flow provision measures on the site plan, and if
applicable, please submit level spreader worksheets and signed and notarized
Operations and Maintenance agreements.
As stated in the response to item No. 4, this project is not subject to the Tar-Pamlico Buffer
Rules (1 SA NCAC 2B .0259) and therefore the diffuse flow provision requirement does not
apply to this project., however, stormwater will be treated through an approved DWQ stormwater
plan that is currently in development.
If you have any further questions or any additional explanation is needed, please don't hesitate to
call.
Sincerely,
~~~--
Sean Clark
Environmental Specialist
4

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