20061862 Ver 1_USACE Correspondence_20070411

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
IN REPLY REFER TO
Regulatory Division
Action ID. SAW-2006-20747-241
Archdale Partners, LLC
Attn: Mr. Todd Schneider
530 Huber Park Court
Weldon Springs, MO 63304
Dear Mr. Schneider:
April 10, 2007 QQ ~ ~ ~ (T/
1~5"
~,... ~~`%" ~~~y;',~~ ,,,E
~°4 . ~a ~ ,.; .
~~`~~ ~ K ~ ~ `1~~1
~1 ~.R(I~,~Pp~~ Agl~~
w~;~-v~~i~~a~~l~
,,~~.nra~~'4~ .

Reference our December 15, 2006, Public Notice for the proposed impacts associated with
the construction of the proposed Shoppes at Bush Hill,.a mixed use development in Archdale,
Guilford and Randolph Counties, North Carolina. Permanent impacts associated with the proposed
project include 1.58 acres of jurisdictional non-riparian wetlands, 0.54-acre of open water pond, 125
linear feet of perennial stream channel, and' 1801inear feet of intermittent stream channel lacking
important aquatic functions. Also included within the application are temporary impacts to 0.01-
acre jurisdictional non riparian wetland, 21 linear feet of perennial stream channel, and 1.93 acres of
open water pond.
After review of your proposal, a letter was received from the North Carolina Wildlife
Resources Commission (NCWRC), which raises concerns regarding the filling of wetlands and
piping of streams, and suggested several measures to further reduce the impact of the proposed
work. Included within these measures are items such as the possible use of bridges, maintaining
forested buffers on streams, proper installation of culverts, sediment and erosion control, protection
of remaining wetlands and streams, and submittal of a compensatory mitigation plan.
Several other letters were received from members of the public which raised specific
concerns with items such as septic/well protection, increased traffic, and the proper control of
stormwater from the proposed project. While the Corps of Engineers does not directly regulate the
control of stormwater, several environmental items under the 404 permit public interest review do
relate to the appropriate management of stormwater. These items include, but are not limited to
flood hazards, floodplain values, shoreline erosion and accretion, and considerations of property
ownership. Included within the permit application was a letter from the Town of Archdale's
Planning Director which stated that the developers of this project would ensure that the neighbors
would be protected from additional stormwater runoff, primarily due to the Randleman Buffers and
the new NPDES Phase 2 requirements.
In addition, the permit application contained information indicating that this project would
include a floodplain impact that requires a permit from Guilford County. In an effort to adequately

address citizen concerns, please provide the point of contact(s) and addresses for individuals
responsible for floodplain development permitting. This information, along with the letter from the
Town of Archdale's Planning Director will be forwarded to the commenting landowners for their
review and consideration.
Avoidance and minimization of aquatic impacts is a required action within the 404
process. Information was included within the application for avoiding/minimizing impacts, but the
following items need additional information or evaluation:
1. Stated within the application was a statement that the City of Archdale requires
the inclusion of a light industrial area which results in an additional aquatic impact. This
impact results from the entrance road and parking area. It appears that this impact could be
avoided by re-routing the roadway or reducing the parking facility. If you determine this
impact to be unavoidable, please provide additional supportive information as justification
for this impact.
.. 2. Several different development plans were submitted to evaluate this project and
'. ~ . , to determine the preferred .alternative. A fair comparison between plans is difficult because
different facilities are represented on each of the plans. For example, the light industrial
complex as discussed in Item #1 above is not found on several of the plans, even though the
application states that this facility is a requirement of the City. Instead, theaters and
additional retail areas are proposed. Also, parking for the Wal-Mart anchor store appears to
be significantly different on two of the plans; i.e. 983 spaces on plan P-1 and 741 spaces on
the overall plan dated September 15, 2006, with no parking numbers available for the
preferred alternative. Please provide alternatives representing the requirements of the
necessary facilities and exhibiting the minimum amount of aquatic impacts.
3. It is common for outparcels and residential components to carry the economic
viability of a mixed use project. This application addresses the economic need for these
items. However, the applicant stated that reducing the overall number of outparcels to
minimize impacts is impossible due to grading and siting requirements of the large retail
anchor stores. Nevertheless, siting for the 2°d anchor store appears to change within some of
the development plans as it is found near the southwestern boundary at an area proposed for
residential on the preferred plan. Therefore, it is assumed that the siting for the other anchor
store could also be slightly altered. This may enable high ground to the northeast of the
proposed Wal-Mart to be used for parking facilities or store siting. As such, the wetland
impacts shown between the two anchor stores could possibly be avoided.
Please provide additional evaluations and/or information pertaining to changes in
layout which might facilitate the ability to reposition or reduce the number of outparcels for
protection of aquatic resources. If grading requirements continue to lead to aquatic impacts
via filling rather than cutting, the applicant will need to submit these requirements for
impact justification.

4. Please confirm that the existing pond will not be an element of the approved
stormwater control plan.
5. As part of the siting criteria for the site selection, distance from an interstate exit
was used to eliminate potential sites. Any site over 2 miles away was deemed unfeasible as
a viable candidate. Please provide supporting documentation for these criteria.
Please note that copies of all letters have been attached for your review and consideration.
If possible, please provide a response to these issues within 60 days. If you have any questions or
concerns, please contact Mr. Monte Matthews at [phone] x30 or at the letterhead address.
Sincerely,
Jean B. Manuele
Chief, Raleigh Regulatory
Field Office
Attachments
cc: with attachments
Cyndi Karoly, DWQ
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
Kimley-Horn and Associates
Attn: Beth Reed
PO Box 33068
Raleigh, North Carolina 27636-3068