20091346 Ver 3_Typical SW Wetland BMP_20101008

October 7, 2010
Mr. Ian McMillan, Acting Supervisor
401 Oversight/Express Review Permitting Unit
2321 Crabtree Blvd
Raleigh, North Carolina 27604
11E@[90WR I
ocr s 200
New Hill Place
Little Branch/Oak Creek [030607,18-7-6-1-1, C]
DM - WATER QUALITY
VVLAM)i AND STORMWATER BRANp f
Response to Request for More Information, dated September 29, 2010
Dear Mr. McMillan,
On October 4, 2010 we received your letter requesting additional information dated September 29,
2010 and offer the following responses. We disagree with the USACE interpretation of our delineation
and maintain that our total proposed impacts are to fill or otherwise impact 1.101 acres of
404/wetlands and 4,934 linear feet of stream per USACE & 4,292 linear feet of stream per, in order to
construct the proposed mixed-use development at the site. For clarity your request for additional
information has been restated and our responses are below.
Additional Information Requested (9129110) Responses (10/7/10)
1) Please submit your revised site plans on full plan sheets at a scale of no smaller than 1 "=50' with
topographic contours and the proposed lot layout shown as an overlay on the site plan.
Five copies Enclosed. The site plans incorporate the site layout, contours and impacts into one
document. The same color coding of DWQ and COE impacts are the same as previously
submitted. *note previous submittal was 1"=40'
2) Please submit your master plan as presented to the Town of Holly Springs for the entire site.
Five copies Enclosed. *note NCDENR DWQ has a more current plan, once our impacts are
permitted we will make a resubmittal to the TORS.
3) Please revise your site plan by either removing all stub roads or show all proposed roads through
build-out on the site plan.
The stub road locations are important for our NCDOT approvals. These locations have been
reviewed and approved by that agencv. As we have discussed previously with DW all stub
locations allow for an eventual street network that does not cause further impacts.
4) Please enumerate all impacts on the site plans and in the impact tables include isolated and
non-404 jurisdictional wetlands and streams deemed intermittent by DWQ that are considered
to have 0:1 mitigation requirement by the USACE. Please note that DWQ requires 1:1 mitigation
on all intermittent streams.
Five copies Enclosed. Additional discussion regarding the impacts is noted below:
Impact #1, 2.11,11A.11B, 3.3A & 12 - These are road related impacts for the Thoroughfare
The Thoroughfare is part of the Holly Springs master transportation plan In addition the full
system was approved by NCDOT through their Controlled Access Committee (CAC). The CAC
reviewed all existing and future traffic in the area. In order to adequately provide flow alone
and across NC55, the network of superstreets, thoroughfare and collector street was required
in order to disperse all vehicles. Last, the design speed, horizontal curve requirements,
vertical curve requirements all needed to be taken into account when setting the alignment of
the road and connecting drives. The sideslopes were minimized as much as possible:
however, NCDOT requires a minimum sideslope and limits the use of walls due to
maintenance constraints.
Impact #4.4A - This is a site related impact. For the development to be a reality, a major
anchor is needed. The major anchor reauired specific location and parking layout. The impact
in this area has been minimized to only effect what is needed for the major anchor's
requirements.
Impact #5 - This is a site related impact, although it is also road related. As stated above, the
traffic network works because traffic is dispersed in various directions and not to one point
along NCSS. This impact allows for a spine road to run the length of the development
allowing for this dispersion.
Impact #6 - This is a site related impact. It is near the rear of the main anchor for the
development. The preliminary design called a retaining wall behind the anchor followed by a
sideslope to existing grade. Over the course of permitting discussing with DWQ. the design
has been modified to install a second retaining wall near the impact, thus eliminating it
entirely.
Impact #7 - This is a site related impact. The site layout has been pulled closer to NC55 as the
DWQ permitting process has progressed thus reducing this impact. With that said, a minimum
level of building and parking area are reauired for financial viability of the project.
Impact #8 & 8A -This is a site impact, although it is also road related. As stated above, the
traffic network works because traffic is dispersed in various directions and not to one point
along NC55. This impact allows for the collector road and drive connections to create a spine
road._ This spine road runs the length of the development allowing for this dispersion. We
believe we can reduce this impact by a further 25' with the selected use of retaining walls.
This is in addition to the total listed in the plan sheets.
Impact #9 - This is a site related impact.
Impact #10 - This is a site related impact. It is near the northern end of the site. The anchor at
that end of the site is out of the impact, but the parking is not. The preliminary design called
for mostly parking in the area. Over the course of permitting discussions with DWQ, the
design has been modified to eliminate some of the parking, add retaining walls. This has
reduced the impact.
Impact #13 & #14 - This is a road related impact for the interchange ramp. The Thoroughfare
is part of the Holly Springs master transportation plan. In addition, the full system was
approved by NCDOT through their Controlled Access Committee (CAC). The CAC reviewed all
existing and future traffic in the area. In order to adequately provide flow along and across
NC55, the network of superstreets, thoroughfare and collector street was reauired in order to
disperse all vehicles. The CAC originally reauired an interchange ramp: however. we felt a
superstreet worked better while providing less impact. We worked for over a year with
NCDOT and finally obtained approved approval to install a superstreet. This revision
eliminated the impact of the interchange ramp.
Impact #15 - This is a site related impact.
5) Before you conduct impacts to surface waters, the DWQ must receive documentation of the
Town of Holly Springs approval of the stormwater management plan for this project. This
documentation may consist of Either:
• A valid approval letter from the Town of Holly Springs indicating that the proposed
activity has an approved SMP and on copy of the approved SMP, including plan details,
calculations and other supporting information, Or
• A set of stormwater plan details and calculation stamped as "approved" by the Town of
Holly Springs.
You have the option of requesting that the DWQ issue an Individual Permit that is conditional
upon our receipt of the Stormwater Management Plan approved by the Town of Holly Springs.
This condition would state the impacts may not commence until the approved plan has been
received by the DWQ.
Please accept this as our formal reauest for an IP with the aforementioned Condition.
6) Please provide a conceptual stormwater management plan for Phases R-1,R-2,R-3,R-4 and lots 7-
13:
• A depiction of the drainage areas on the site
• An estimation of the percentage impervious associated with each of the drainage areas.
• A calculation of the water quality volume associated with each drainage area.
• A depiction of a proposed BMP (state the type of BMP you plan to use) on the site plan
that is correctly sized based on the water quality volume.
Five copies Enclosed. We have previously shown exhibits to DWQ outlining our proposed
build areas for the residential section. These exhibits also included areas for drainage. The
additional information requested is enclosed and substantiates what has been previously
submitted. Please also note our answer to #8 below.
7) Please provide your updated jurisdictional determination information by locating all isolated or
non-isolated wetlands, streams, and other waters of the State as overlays on the site plan.
Five Copies Enclosed.
8) It is our understanding that no additional impacts to surface waters will occur beyond those
currently requested in your most current application. Is this correct?
Yes this is correct. AS HAS BEEN PREVIOUSLY CONVEYED ON NUMEROUROUS OCCASIONS. NO
FURTHER IMPACTS TO SURFACE WATERS WILL OCCUR BEYOND WHAT WE ARE CURRENTLY
PROPOSING.
Additionally please understand that we have avoided and minimized to the full extent this project will
allow. Again as previously stated no alternative sites exist for this region that have the necessary
infrastructure and retail spacing to enable a mixed use development of this scale. We accept but
respectfully disagree with the USACEJDWQ delineation of our wetlands and streams; as such would like
to note the following: approximately Three Acres of Wetlands exists on this site of which we are only
impacting One Acre; furthermore approximately Thirty Eight Percent of our total stream impacts are due
to the proposed mixed-use development (commercial & residential combined) while the balance is
directly attributed to the Thoroughfare that is needed with or without this project.
Sincerely,
Al Goodrich
A.B. Goodrich Contracting, LLC

David C. George, P.E.
Kite Realty Group
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Future_SWMF_1
Simla Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 1
Drainage Area (SF) = 189383 SF
Drainage Area (AC) = 4.35 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 11442 CF
Future_SWMF_2
Simple Method Water Quality Volume Calc ?latnr
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 2
Drainage Area (SF) = 393901 SF
Drainage Area (AC) = 9.04 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 23798 CF
Future_SW M F_3
Simale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 3
Drainage Area (SF) = 286128 SF
Drainage Area (AC) = 6.57 AC
DA Percent Impervious (%) = 75.00%
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 17287 CF
Future_SWMF_4
imale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =>
SWMF ID = 4
Drainage Area (SF) = 242734 SF
Drainage Area (AC) = 5.57 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 14665 CF
Future_SW MF_5
Simale Method Water Quality Vojlame Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 5
Drainage Area (SF) = 154422 SF
Drainage Area (AC) = 3.55 AC
DA Percent Impervious (%) = 75:00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 9330 CF
Future_SWMF_6
Simple Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 6
Drainage Area (SF) = 109862 SF
Drainage Area (AC) = 2.52 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 6637 CF
Future_SW MF_7
Simple Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 7
Drainage Area (SF) = 142244 SF
Drainage Area (AC) = 3.27 AC
DA Percent Impervious (%) = 75.00%
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 8594 CF
Future_SWMF_8
Simale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 8
Drainage Area (SF) = 148771 SF
Drainage Area (AC) = 3.42 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 8988 CF
Future_SWMF_9
imule Method Water Quality Volume Calmilatnr
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 9
Drainage Area (SF) = 97537 SF
Drainage Area (AC) = 2.24 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 5893 CF
Future_SWMF_10
Simale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 10
Drainage Area (SF) = 102662 SF
Drainage Area (AC) = 2.36 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 6202 CF
Future_SWMF_11
aimale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 11
Drainage Area (SF) = 705976 SF
Drainage Area (AC) = 16.21 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 42653 CF
Future_SWMF_12
Simple Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 12
Drainage Area (SF) = 526447 SF
Drainage Area (AC) = 12.09 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 31806 CF
Future_SWMF_13
Simale Method Water Quality Volume Calculator
(Rf.• NCDENR BMP Design Handbook, April 1999)
Input Parameters =_>
SWMF ID = 13
Drainage Area (SF) = 194984 SF
Drainage Area (AC) = 4.48 AC
DA Percent Impervious (%) = 75.00 %
Rainfall Depth (inches) = 1.00 Inches
Calculated Runoff Volume =_>
Rv = 0.73 (in/in)
R/O Volume = 11780 CF