20100147 Ver 1_Emails_20100409

Chapman, Amy
From: Turney, Doug [[e-mail]]
Sent: Friday, April 09, 2010 2:30 PM
To: Chapman, Amy
Cc: Gyamfi, Joseph; Mcmillan, Ian; Scheller, Roberto; Dumpor, Samir; Mann, Chris; Milligan, Rob;
Tyndall, Dave
Subject: RE: Province at Greenville - SMP Issues
Amy,
The City of Greenville recommended the nutrient offset payment program to us several months ago as it is in their
approved stormwater program and, Lisa Kirby, had previously received 401 review certification from the State for this
very purpose, review of stormwater plans for 401 applications. Their program was subsequently over-ruled by your
office during the review of this application after February 191h
As far as the placement of a BMP in the floodplain, I was not at the SCOPING MEETING, I will have to defer to Rob
Milligan and Chris Mann about the details of that meeting, but at that time we had no intentions of installing a BMP in
the floodplain due to our coordination with the City of Greenville and their nutrient offset program. However, as far as
the proposed wetland filling in with sediment, an extensive and thriving wetland system exists there today, so I am
having a hard time understanding why a proposed wetland could not also be sustained in the floodplain at the same
elevation and farther away from the stream channel, outside of the 50' buffer. I realize that the wetland may
accumulate with debris from time to time and require occasional maintenance, however, the preserved wetland
provides a nice buffer and filter between our proposed wetland and the stream channel to help protect it from sediment
and erosion.
The proposed excavation was not intended to be a hole, the existing wetland is at an elevation of 22.5-24, the proposal
was to remove any ground above an elevation of 24 adjacent to the wetland and not create any permanent pools. The
impacts were also required for construction related activity during site improvements. This excavation requires only
minor cutting in most areas. The proposed wetland would be at an elevation of 22.5 and pond to 24 during a 1-year
event from onsite drainage. The floodplain permit would still only show an elevation of 24 through the wetland so that
the wetland storage volume is not being used for both the stormwater plan and the floodplain permit.
I hope you understand that the client has spent a lot of time and money understanding if this project was viable and key
decisions were made following the SCOPING MEETING and subsequent conversations with DENR and the City of
Greenville. It is now very apparent that we were not given adequate information to make sound decisions regarding the
ability to proceed with this project. A meeting with the client is recommended to understand the overall scope of the
redevelopment project including benefits to the community and East Carolina University, both of which are in support of
this redevelopment.
Thank You
Doug Turney, P.E., LEED AP
Senior Water Resources Engineer
Evans, Mechwart, Hambleton, & Tilton, Inc. (EMH&T)
Engineers, Surveyors, Planners, Scientists
5500 New Albany Road
Columbus, Ohio 43054
614.775,4213 Direct
614.775.4804 Fax
emht.com
From: Chapman, Amy [mailto:[e-mail]]
Sent: Friday, April 09, 2010 12:49 PM
To: Turney, Doug
Cc: Gyamfi, Joseph; Mcmillan, Ian; Scheller, Roberto; Dumpor, Samir
Subject: RE: Province at Greenville - SMP Issues
Doug,
These are the notes I've gotten thus far from the Washington Regional Office from the scoping meeting and subsequent
telephone conference:
"Originally during the scoping meeting they proposed to dig a hole in the flood plain (wetlands)to off-set flood plain
impacts. They were told that Green Mill Creek is a typical urban stream with flashy flows during storm events and highly
erosive banks, which translates to high sediment loading for the subject stream. Construction of any measure within the
flood plain would fill with sediment during the first over the bank event.
A phone conference was held with this Office and EMH&T on February 19, 2010 to clarify that the proposed hole in the
wetland area located on the flood plain was to be constructed to off-set flood plain impacts and NOT to be used for
stormwater treatment.
We were asked about nutrient offset and buying credits and they were referred to the City of Greenville for the
stormwater questions."
I believe that what Joseph has stated in his email below is consistent with the scoping meeting you had with the
Washington Regional Office.
Please let us know if you have any further questions.
-Amy
Amy Chapman
NC Division of Water Quality
401/Wetlands Unit
2321 Crabtree Blvd, Suite 250
Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
*Please note my email address has changed*
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Gyamfi, Joseph
Sent: Friday, April 09, 2010 12:17 PM
To: Mcmillan, Ian; Chapman, Amy
2
Mcmillan, Ian
From: Chapman, Amy
Sent: Friday, April 09, 2010 12:49 PM
To: [e-mail]
Cc: Gyamfi, Joseph; Mcmillan, Ian; Scheller, Roberto; Dumpor, Samir
Subject: RE: Province at Greenville - SMP Issues
Doug,
These are the notes I've gotten thus far from the Washington Regional Office from the scoping meeting and subsequent
telephone conference:
"Originally during the scoping meeting they proposed to dig a hole in the flood plain (wetlands)to off-set flood plain
impacts. They were told that Green Mill Creek is a typical urban stream with flashy flows during storm events and highly
erosive banks, which translates to high sediment loading for the subject stream. Construction of any measure within the
flood plain would fill with sediment during the first over the bank event.
A phone conference was held with this Office and EMN&T on February 19, 2010 to clarify that the proposed hole in the
wetland area located on the flood plain was to be constructed to off-set flood plain impacts and NOT to be used for
stormwater treatment.
We were asked about nutrient offset and buying credits and they were referred to the City of Greenville for the
stormwater questions."
I believe that what Joseph has stated in his email below is consistent with the scoping meeting you had with the
Washington Regional Office.
Please let us know if you have any further questions.
-Amy
Amy Chapman
NC Division of Water Quality
401/Wetlands Unit
2321 Crabtree Blvd, Suite 250
Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
*Please note my email address has changed*
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Gyamfi, Joseph
Sent: Friday, April 09, 2010 12:17 PM
To: Mcmillan, Ian; Chapman, Amy
Cc: [e-mail]
Subject: FW: Province at Greenville - SMP Issues
Doug,
I am not privy to any previous discussions so I'm forwarding your email to Ian and Amy so they can comment on both
emails (my concerns and your response). Thanks.
Joe
From: Turney, Doug [mailto:[e-mail]]
Sent: Friday, April 09, 2010 11:37 AM
To: Gyamfi, Joseph
Cc: Mann, Chris; Milligan, Rob; Schimmoeller, Stacy
Subject: RE: Province at Greenville - SMP Issues
Thanks for your feedback.
We have always proposed impacting the existing wetland as shown in our current application as it was required to make
the project viable for several reasons. The modification we are proposing uses the land we proposed to impact anyway
and place a stormwater wetland in its place. We have been lead to believe all along through our SCOPING MEETING ON
JANUARY 13, 2010 with NC DENR staff, our client, and the City of Greenville, and numerous subsequent conversations
with NC DENR staff that the path we were on was a viable path and that a permit could be obtained with proper
mitigation. It appears a lot of these issues are being re-visited now, including the fact that during our scoping meeting,
the nutrient buy-down option was agreed to by the City of Greenville and NC DENR staff. I need to discuss this issue
with Rob Milligan from our office who is coordinating the permit application. Unfortunately, Rob is out today, but a
conference call early next week may be necessary.
Thanks
Doug Turney, P.E., LEED AP
Senior Water Resources Engineer
Evans, Mechwart, Hambleton, & Tilton, Inc. (EMH&T)
Engineers, Surveyors, Planners, Scientists
5500 New Albany Road
Columbus, Ohio 43054
614.775.4213 Direct
614.775.4804 Fax
emht.com
From: Gyamfi, Joseph [mailto:[e-mail]]
Sent: Friday, April 09, 2010 11:04 AM
To: Turney, Doug
Cc: Mcmillan, Ian; Chapman, Amy; Gyamfi, Joseph
Subject: Province at Greenville - SMP Issues
HI Doug,
I promised you in our conversation yesterday to give you some guidance today:
There are two major issues that will make it difficult for us to permit the proposed stormwater wetland in an existing
wetland -floodplain area.
(1) You would be required to demonstrate to this office that you cannot avoid the impact to the existing wetland.
(2) As you alluded to yesterday, the area could potentially be flooded more than twice a year. We foresee several
issues with maintenance, plant survival, and therefore proper functioning (both TSS and Nutrient Reduction
ability) of the BMP.
In view of the above, we strongly recommend that you avoid siting the constructed stormwater wetland in the wetland
- floodplain area. I think you have two options:
(a) Site a BMP in an area upstream of the wetland-floodplain area (It may mean that your client would forego or
lose one or two lots, but that is because stormwater management was not part of the initial planning); OR
(b) Demonstrate to us that you CANNOT avoid and/or minimize the impact to the wetland, and must site the BMP
in the currently proposed location.
If you decide to go with option (b), I strongly encourage you (or your local rep. who may be involved in the project) and
your client to setup a meeting with us (through Ian) to discuss the avoidance and minimization ..... We'll be
communicating with the City of Greenville as well. I hope this will help you make a better decision for your client and for
the environment. Let me know if you have any questions. Thanks.
Joseph
Joseph Gyamfi, P.E., P.Eng.
Environmental Engineer
NCDENR/DWQ
401/Express Permitting Unit
2321 Crabtree Blvd., Suite 250, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Website: http://h2o.enr.state.nc.us/ncwetiands/index.htmi
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is
addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or
distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and
destroy all copies of the original message. If you are the intended recipient but do not wish to receive
communications through this medium, please so advise the sender immediately.
3