20200269 Ver 1_Satterfield Farm SD-Response to Corps_20200501

1501 Lakestone Village Lane, Suite 205
Fuquay-Varina, North Carolina 27526
919-669-0329
Mitchell Environmental, P.A.

April 9, 2020

Mr. Christopher Hopper
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587

Re: Satterfield Farm Subdivision
Roxboro, Person County
USACE Action ID: SAW-2019-02271

Mr. Hopper:

This letter is in response to review comments we received regarding proposed
Satterfield Farm Subdivision in Roxboro (Person County), and associated wetland and
stream impacts proposed for this activity. Responses to review comments are provided
below.

US Army Corps of Engineers Comments:
1. At the conclusion of our November 26, 2019 site visit with you, we
requested updated mapping to be provided for our review and
concurrence. Please update the mapping and jurisdictional determination
tables to reflect changes made during the November 26, 2019 site visit to
this property with the USACE.
An updated map and table of all jurisdictional features on the site is attached.

2. Please provide exhibits that show all lots with numbers, at sufficient scale
to demonstrate proximity to adjacent stream and wetland areas and show
the location of headwalls referenced in your application. Where stream or
wetland resources occur within a proposed lot(s), please address how
these features would be protected in the future. For example, other
applicants have used deed notifications, conservation easements, or
eliminating lot placement within jurisdictional features.
All lots are shown on the plan sheets and if you need a summary sheet C-4a lists
each lot.

3. Please provide a graphic scale bar on all future exhibits rather than a text
scale.
Graphic Scale is on all plan sheets and exhibits.

4. How will sewer collection be provided? Please include details of gravity
and forcemain infrastructure, as well as any pumping facilities that may be
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required. Will additional impacts be required for either interior or off-site
and/or other sewer lines?
The entire property will be served by gravity sewer that collects waste and
transfers it to the pump station at the end of Crow Field Street. The pump station
then pumps through a forcemain along Crow Field Street, Lucy Garrett Road,
and Billy Hicks Rd where is dumps into the existing Billy Hicks Pump Station.
See the attached plan sheets.

5. There are seven stub roads, including one aligned to cross a stream toward
Lucy Garrett Road, and two that would intersect one another within a
couple hundred feet. The application states that the project will be built in
phases. Are adjacent parcels included in future development plans? Please
include a discussion of why this number of stub roads are required and
provide detail for questionable locations described above.
The stub roads to adjacent properties you mentioned are required by the City of
Roxboro to meet the road design link/node ratio. These give the adjacent
owners access in the event the decide to develop their property. Most are highly
unlikely but we are required to provide regardless. You will see the planned
phasing on the attached plan sheets.

6. Please provide a discussion and exhibits to illustrate the proposed phasing
plan discussed in your application.
Phase 1 will be the 86 lots along Crowfield Street with the access off Lucy
Garrett Road. Phase 2 requires a connection to US 501 so that will include all
internal property lots and lots along the access road that leads to US 501. The
third phase will be lots in the southwest property corner which will be accessed
by a bottomless culvert to avoid disturbance of important streams.

7. Please provide detailed exhibits with feature and impact numbering that
match other submitted documents.
C-3A is the updated stream and wetland impact map.

8. The USFWS list provided hasn’t been updated since October 2018. Please
review the USFWS IPaC website to obtain a current list of species that may
be impacted by this project. Species proposed for listing are not required
to be addressed, but it is recommended to protect applicants in the event a
species becomes listed during this process.
A USFWS IPaC report is attached, and that report states “There are no critical
habitats at this location.”

9. Consultation with the NCSHPO is requested. Please request their
concurrence with the project via their Environmental Review emailbox at
[e-mail].
We emailed NCSHPO a request for Environmental Review, but we have not
received a response to that request yet. We will send their response to you as
soon as we receive it.

10. Will interior roads be transferred to NCDOT?
No. All streets and utilities will be owned and maintained by the City of Roxboro.

11. No stormwater BMP impacts can be authorized in jurisdictional features
(NWP 29 Regional Condition 4.1.1.).
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The only stormwater BMP impacts were in Phase 2. The subject BMPs have
been repositioned outside of the wetland area.

12. A number of wetland impacts are proposed to accommodate lot fill or lot
and road grading, but no discussion is provided as to how impacts were
minimized or why these impacts are necessary. The location of each
numbered lot (requested above) will assist in review of your avoidance and
minimization discussions. Please clarify each impact requested.
The initial subdivision layout and approval was for 400 homes. Through our
efforts to avoid streams and wetlands we have eliminated 2 of the originally
proposed stream crossings and have reduced the number of home sites to 318
lots. The exact internal layout of phase 2 will likely be tweaked further due to
stormwater requirements and we will likely lose more lots during this process. In
sections where fill slopes enter wetland areas, we have steepened the slopes as
much as possible without losing additional lots and without building unstable
slopes that would lead to erosion.

13. Cumulative permanent wetland impacts for this project exceed the 0.1acre
threshold per Nationwide Permit General Condition 23c, and therefore
compensatory mitigation is required. Please submit a compensatory
mitigation plan. The mitigation rule generally prescribes purchasing
wetland credits first through a mitigation bank with wetland credits
available in this 12-digit HUC, or second through the NC Division of
Mitigation Services; please provide a mitigation acceptance letter from
your proposed compensatory mitigation provider. Typically, compensatory
mitigation is required at a 2:1 credit to impact ratio unless otherwise
justified based on evaluation of aquatic function;
Wetland mitigation credits are currently available through multiple private banks
in the HUC. SOA letters from various bankers are attached.

14. Avoidance and minimization discussions state that near perpendicular
crossings were selected to reduce impacts. However, Sheet 2 illustrates a
crossing with significant meanders and straight reaches both above and
below this crossing. Sheet 5 illustrates a crossing that would discharge
from the culvert into an almost 90-degree bend in the stream with no
accommodation provided to protect this feature. Two of the proposed
crossings are less than 200 feet from one another and would both cross
the same stream.
It does not appear the proposal satisfies the minimum requirements of
NWP Conditions 23(a) or 23 (b). Please explain the rationale for each
proposed impact, addressing location selection, avoidance, minimization,
and need for each.
Minimizing stream impacts on this project was a priority in our efforts to get the
overall length of stream loss below 300 feet. We reduced the proposed number
of crossings from 6 in the original design, down to 5 prior to the PCN application
submittal, and now we are down to 3 stream crossings. This is the minimum
number of crossings needed to be able to access the majority of uplands on the
parcel. The 2 crossings that are 200 feet apart (Band Saw Lane and Round Bale
Way) are on a stream segment that is of such low quality and function, that David
Bailey stated mitigation would not be required for impacts on this segment, and
impacts to this stream will not count towards the Nationwide Permit stream
impact threshold. Also please notice the major stream crossing used to access
this area was changed to a bottomless culvert at the southernmost location to
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avoid stream disturbance/impact. The northwest corner we have elected to leave
undeveloped due to the amount of stream impacts required to access only about
10-15 lots. As for installing the road perpendicular to the stream, if you look at
the overall plan you will see that this has been achieved as best as we could
feasibly. There are meandering sections all along these streams and because
each crossing is roughly 100’ wide it’s not feasible to achieve without adversely
effecting other sections of the stream and losing lots or going over the property
line with grade tie-outs. On sheet 2 if you were to slide the crossing far enough
north to avoid this meandering section you could not comply with the Roxboro
standard for road curvature and we would lose all lots north of the road and you
would still not be crossing the stream at a 90 degree angle. On sheet 5 we are
crossing the stream at close to a 90 degree angle and moving either direction
puts you in a meandering section of the stream. The velocity at the pipe
discharge into that creek bend will not be increased by the pipe installation.
There is currently a 24” pipe that was installed there years ago by logging crews
and we will be replacing with a 48” which will handle the 100 year storm.

As for the overall layout we have minimized the stream and wetland disturbance
as much as possible to comply with the Nationwide Permit and Roxboro/NCDOT.
Due to the size of this development there must be 2 entrances to access the lots.
For this reason, we must have 3 crossings to connect the property as a whole.

15. How will streams be protected during construction? Will stream pump
arounds be utilized? If so, where would coffer dams be placed? How will
work area dewatering be accomplished?
See the attached detail sheets. Yes, cofferdams are the typical choice during dry
weather periods. These installations typically take less than 2 days.

16. Seven stream crossings are shown in the impact exhibits. Three stream
crossing plans are provided with no reference to their location. Stream
names A, B, and C used in the PCN impact table do not correspond to any
of the exhibits provided. On the overall exhibit, one crossing is labeled as
being accomplished via bottomless culvert, and three are not discussed.
Riprap aprons are show for two of the three crossings detailed.

Please provide:
a. Detailed exhibits of all culverts, including bottomless arch culvert
crossings proposed. Mitigation for each may be required and
depending on the designs provided, the total length of each may be
counted toward the NWP threshold.
The 8.5x11 exhibits of the 3 pipe installations now match the overall
stream and wetland disturbance map.

The bottomless culvert has not been designed but the intent is to make it
wide enough to completely span the creek. Preliminary estimates are 30
feet wide. Keep in mind all phase 2, 3, and 4 are subject to change
because these are preliminary layouts. Only phase 1 is set in concrete at
this point. Our plan is to stay at or below what is being permitted which is
the 285 feet of stream disturbance. If more stream crossing are needed
we would have to start the process over as an individual permit and we
don’t want to go that route.

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b. Geotechnical survey information to show scour-less bedrock occurs
at the footings of each bottomless arch culvert proposed within 5-
feet of the surface.
As stated above the bottomless culvert has not been designed but when it
is designed it will be 30 +/- feet wide which will extend far beyond the top
of creek bank on both sides. It would have no impact to the stream. This
size is governed by the structural design requirement not the stream
capacity. At this location the 100-year storm would easily pass through
an 84” pipe which Summit had initially designed it to be. However, to
avoid additional disturbance, the developer will be installing the
bottomless culvert which is extreme overkill from a hydraulics standpoint.

c. Cross sectional details of all culvert crossings to illustrate pipe
burials comply with NWP 29 Regional Condition 3.6.1., and riprap
installation that complies with NWP 29 Regional Condition 4.1.6.
Riprap in streams may require mitigation for loss of stream function.
See the detail sheet D-11. The stormwater details show a typical for
greater than 48” and less than 48”. Only 1 is over 48” which requires the 1
foot burial depth.

17. Cumulative permanent stream impacts for this project exceed the 150
linear foot threshold per NWP 29 Regional Condition 3.2, and therefore
compensatory mitigation is required. Please submit a compensatory
mitigation plan. The mitigation rule generally prescribes purchasing stream
credits first through a mitigation bank with stream credits available in this
12-digit HUC, or second through the NC Division of Mitigation Services;
please provide a mitigation acceptance letter from your proposed
compensatory mitigation provider. Typically, compensatory mitigation is
required at a 2:1 credit to impact ratio unless otherwise justified based on
evaluation of aquatic function.
A portion of the required stream mitigation credits are currently available through
a private bank in the HUC. A SOA letter from Wildlands Holdings III, LLC for
their Falling Creek Stream and Wetland Mitigation Bank is attached. Remaining
stream mitigation credits will be provided by NC DMS. An acceptance letter from
DMS is also attached.

Thank you in advance for your time spent reviewing our responses to your review
comments. Do not hesitate to contact me if you have any questions, or if you need any
additional information to continue processing this application. For site engineering
specific questions, feel free to contact Matt Hastings, PE, at [phone] or
[e-mail].

Sincerely,

Scott Mitchell, PE, LSS
Site Number Latitude (decimal
degrees)
Longitude (decimal
degrees)
Estimated amount of aquatic
resource in review area
(acreage and linear feet, if
applicable)
Type of aquatic resource (i.e.,
wetland vs. non-wetland
waters)
Geographic authority to which
the aquatic resource "may be"
subject (i.e., Section 404 or
Section 10/404)
Wetland A2/B2/Z2 36.33673 -78.96818 0.1299 ac.Wetland 404
Wetland C1 36.33617 -78.97831 0.0196 ac.Wetland 404
Wetland C2/D2 36.33241 -78.97427 0.0730 ac.Wetland 404
Wetland D1/E1 36.33644 -78.97691 0.2125 ac.Wetland 404
Wetland E2 36.33235 -78.97114 0.4954 ac.Wetland 404
Wetland F1 36.33542 -78.97123 0.2723 ac.Wetland 404
Wetland F2/G2/J2 36.33727 -78.96862 0.2874 ac.Wetland 404
Wetland G1/H1 36.33486 -78.97149 0.0728 ac.Wetland 404
Wetland S2 36.33621 -78.97395 0.0274 ac.Wetland Isolated / DWR Only
Wetland T2/U2 36.33329 -78.97235 0.0134 ac.Wetland 404
Wetland V2 36.33402 -78.97268 0.0078 ac.Wetland Isolated / DWR Only
Wetland W1/X1 36.33797 -78.96735 0.2747 ac.Wetland 404
Wetland W2 36.33429 -78.97307 0.0471 ac.Wetland Isolated / DWR Only
Wetland X2 36.33595 -78.96888 0.0129 ac.Wetland Isolated / DWR Only
Wetland Y2 36.33607 -78.96959 0.0516 ac.Wetland 404
Wetland Z1 36.33791 -78.96783 0.0096 ac.Wetland Isolated / DWR Only
Stream A 36.33371 -78.97237 4,225 LF Non-Wetland Waters 404
Stream B 36.33547 -78.97344 818 LF Non-Wetland Waters 404
Stream C 36.33499 -78.96866 2,198 LF Non-Wetland Waters 404
Stream D 36.33290 -78.97293 720 LF Non-Wetland Waters 404
Stream E 36.33623 -78.97711 499 LF Non-Wetland Waters 404
Stream F 36.33811 -78.96934 490 LF Non-Wetland Waters 404
Stream G 36.33431 -78.9753 679 LF Non-Wetland Waters 404
Stream H 36.33689 -78.96825 453 LF Non-Wetland Waters 404
Stream I 36.33722 -78.96493 744 LF Non-Wetland Waters 404
Stream Z 36.33410 -78.97221 243 LF Non-Wetland Waters 404
Table of Aquatic Resources in Review Area which "may be" Subject to Regulatory Jurisdiction
Satterfield Farm Subdivision
April 8, 2020