20201897 Ver 1_More Info Received_20210601

ADDITIONAL INFORMATION RESPONSE > EWP-20000
creating experiences through experience 1 of 4
June 1, 2021

Mr. Lyle Phillips
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587

Ms. Stephanie Goss
NC Division of Water Resources
401 & Buffer Permitting Branch
512 N. Salisbury St.
Archdale Bldg. 9th Floor
Raleigh, NC 27604

RE: Nationwide Permit 39/GC 4263
Project Athens Area 4
Raleigh, Wake County, North Carolina
EWP-20000

Dear Mr. Phillips and Ms. Goss:

Additional information requested by Lyle Phillips with the USACE.
1) The Corps considers proposed/previous impacts for this project as cumulative when considering Nationwide
Permit (NWP) thresholds. Per NWP 39 regional condition 28, the use of more than one nationwide permit
(NWP) for a single and complete project is authorized, subject to restrictions. One restriction is if one or more
of the NWPs used to authorize the single and complete project has specified acreage limits, the acreage loss
of waters of the United States authorized by those NWPs cannot exceed their respective specified acreage
limits.
a. Project Athens - Area 4 Parking Lot proposes to discharge fill (resulting in loss) within 0.11 acres of
potentially jurisdictional waters. A previous authorization under Department of Army NWP 42 (SAW-
2015-01028) to facilitate the expansion of recreation facilities within the Heritage Village complex at
the North Carolina State Fairgrounds resulted in a loss of 0.49 acres of waters. Cumulatively the total
single and complete non-linear project would result in a loss of 0.60 acres of waters, exceeding the
0.5 acre threshold authorized by NWP 39 (2021) and NWP 42 (2012).
b. You may apply for the proposed project via the Standard Permit process. Or, as an alternative, you
may further avoid or minimize impacts proposed to show that cumulative impacts fit within the NWP
impact thresholds.

As discussed in several communications with Lyle Phillips and Jean Gibby of the USACE, the overall project
purpose provided in the application did not include adequate detail to evaluate the project’s independence.
Although the site will be used for State Fair parking, it represents a fraction of the site’s overall use.

The State of North Carolina owns property at the intersection of Edwards Mill Road and Reedy Creek Road
hereinafter referred to as Area 2. This property has been used for construction equipment and supply
staging, emergency response staging, tenet parking and State Fair parking and has the potential to provide
ADDITIONAL INFORMATION RESPONSE > EWP-20000
creating experiences through experience 2 of 4
approximately 5,000 parking spaces. The State proposes to sell Area 2 to Bandwidth for the software
company’s campus. There are no areas under Clean Water Act jurisdiction within the development area of
Area 2. Most of the site will be used for Bandwidth’s campus, but a portion of the property will be
dedicated to State Fair parking with grass cover and no other uses permitted.

Project Athens Area 4 is located on the north side of Chapel Hill Road east of Edwards Mill Road and owned
by the State. It is proposed as a replacement site for Area 2. The proposed development of Area 4 has been
designed to accommodate and improve the function of the site for emergency response and construction
equipment and supply staging, which will be discussed in detail in the responses to Item 2 below. Due to the
density of development in Raleigh, there are very few places with the necessary access to accommodate
wide loads and space necessary for construction staging. Raleigh is an important location for emergency
response staging for other areas of the state because it is not under an emergency declaration when ice
storms, flooding and landslides affect the western part of the state and more often when hurricanes affect
the eastern part of the state. The State Fairgrounds have scheduled events year-round that require parking
for attendees and workers, concessions, and accommodations for event workers that precludes the use of
these parking areas for construction staging and emergency response.

Area 4 will also be used to provide State Fair parking, but tenant space for parking and equipment storage
and emergency response are uses for most of each year. Further, if State Fair parking were the only purpose
for Area 4, the State would pursue a temporary lease instead of development of the proposed project.

2) Per Regional Condition 23 (a) and (b) the activity must be design and constructed to avoid and minimize
adverse effects, both temporary and permanent, to waters of the United States to the maximum extent
practicable at the project site (i.e., on site). Mitigation in all its forms (avoiding, minimizing, rectifying,
reducing, or compensating for resource losses) will be required to the extent necessary to ensure that the
individual and cumulative adverse environmental effect are no more than minimal.
a. Given that the Mt. Vernon Road access achieves the project purpose and does not result in impacts
to waters please explain further the need for the Mt. Vernon Road access to be limited to bus traffic
only.

Mt Vernon Road provides access to Mt Vernon Elementary School and includes on-street parking on
both sides of the road as shown in 2020 aerial map below. On-street parking is not compatible with
wide loads that are necessary for heavy equipment and large prefabricated culverts used in
construction. Additionally, traffic from school drop off and pick up is not compatible with
emergency response staging that requires quick mobilization of convoys that sometimes require as
many as 30 power trucks. The unsuitability of Mt Vernon Road requires construction of an access to
Chapel Hill Road that meets the needs of construction staging and emergency response. During the
State Fair, Mt. Vernon Road will be used as an access point for buses to bring fair attendees from
remote parking locations around the City to accommodate the heavy volume of traffic created by
the fair.

ADDITIONAL INFORMATION RESPONSE > EWP-20000
creating experiences through experience 3 of 4

b. Could the Chapel Hill Road access road be moved west of the confluence of S3 and S5 to cross only S3
to reduce stream impacts? It appears an access road could line up with the existing drives located at
35.789279, -78.725372 or 35.789279, -78.725372 meeting DOT requirements, achieving the project
purpose and reducing impacts to waters. Please provide further rationale for the location of the
Chapel Hill Road access road.

Although the property owned by the State is larger than the project area for Area 4, the area
adjacent to Edwards Mill Road and east to the stream that constitutes the eastern boundary of the
site has been allocated to the NC Department of Military and Veterans Affairs (VA) for the proposed
Raleigh State Veterans Home. The allocation agreement and plat are attached. The existing drives
denoted below by red stars on the excerpt from the plat show these driveways are across Chapel
Hill Road from the VA Home site. While different state agencies sometimes cooperate and collocate
their facilities. The VA Home is a retirement home for veterans that is incompatible with
construction and emergency response traffic. The driveway to the east of the proposed crossing
that is not located across from the VA Home site does not have a median cut to allow a full
movement intersection to access the site that is needed to serve the purpose of the project.
Therefore, the access point to Chapel Hill Road is required in the proposed location to provide a full
movement intersection to the site.

ADDITIONAL INFORMATION RESPONSE > EWP-20000
creating experiences through experience 4 of 4

c. In lieu of the Chapel Hill Road access road could an access road connecting the proposed parking lot
to Edwards Mill Road reduce the proposed impacts while still achieving the project purpose?

Most of the area along Edwards Mill Road is occupied by the proposed VA Home site discussed
above. NCDOT would most likely not allow another full movement intersection on Edwards Mill as it
would add additional traffic to the already congested Edwards Mill/Trinity intersection. If allowed,
the bifurcated profile of Edwards Mill Road may prohibit left turn movements and would potentially
impact stormwater devices constructed as part of the Edwards Mill extension.

In addition to the avoidance and minimization measures discuss above, the access road proposed to connect the
project area to the RV park on the State Fairgrounds will be accomplished using a wooden bridge instead of a
culvert. This will eliminate 284 linear feet of temporary and permanent stream impacts. This connection will allow
emergency response workers access to the RV park for accommodations while staged for a response. It will also
provide an access point for trams to carry people from the parking area to the fairgrounds during the State Fair once
a year. The revised impact map showing the bridge crossing and a cross-section is attached. Revised tables for
stream and buffer impacts are also attached.

Additional information requested by Stephanie Goss with DWR.

1. Has a SEPA review been conducted? Can you provide details pertaining to a SEPA review for this project?

As originally proposed the project did exceed the minimum criteria for perennial stream impact. The
threshold was misread as 500 linear feet of permanent loss instead of total impact. I consulted with Lyn
Hardison who explained in the attached email that any project that requires a Water Quality Certification
does not require an environmental assessment. Further, the perennial stream impact has been reduced by
using a bridge instead of a culvert at Impact Area 1 thereby avoiding 284 linear feet of temporary and
permanent stream impacts and changing the total perennial stream impact for the project to 232 linear feet.

If you have any questions about the additional information provided, please do not hesitate to contact me.

Sincerely,
MCADAMS

Jennifer Burdette
Sr. Environmental Consultant, Water Resources

cc: Andy Padiak, McAdams
Linda Vasil, McAdams
Spencer Merritt, EastWest Partners

North Carolina
Department of Administration
State Property Office
Roy Cooper, Governor
March 21, 2019
MEMORANDUM
TO: Commissioner Steven W. Troxler
Department of Agriculture and Consumer Services
FROM: Tim Walton[
Director
SUBJECT: Allocation of Property located in Wake County
Machelle Sanders
Secretary
Tim Walton
Director
Attached is your original of the above noted allocation properly executed by all parties.
Thank you.
Attachment
State of North Carolina I State Property Office
116 West Jones Street, Suite 4055 11321 Mail Service Ctr. I Raleigh, NC 27699
919 807 4650 T I Web* http//www.ncspo.com

STATE OF NORTH CAROLINA
DEPARTMENT OF ADMINISTRATION
RoY COOPER MACHELLE SANDERS
GOVERNOR SECRETARY
March 15, 2019
Commissioner Steven W. Troxler
NC Department of Agriculture and Consumer Services
1001 Mail Service Center
Raleigh, North Carolina 27699-1001
Secretary Larry D. Hall
NC Department of Military and Veteran Affairs
4001 Mail Service Center
Raleigh, NC 27699-4001
Re Allocation of Property Located in Wake County to the North Carolina Department of Military and
Veteran Affairs
Dear Commissioner Troxler and Secretary Hall:
Pursuant to an agreement between the North Carolina Department of Agriculture and Consumer Services
and the North Carolina Department of Military and Veteran Affairs, and the authority vested in me by the
North Carolina General Status §143-341(4)(g), the following described property located in Wake County
North Carolina, is allocated to the Department of Military and Veteran Affairs:
That certain property containing approximately t 16 acres at the northeast corner of Edwards Mill
Road and Highway 54, Raleigh, Wake County, as further described in
the attached map to be part of this letter of allocation.
This allocation is made at no cost or consideration to the Department of Military and Veteran Affairs.
Sincerely,
Mache le Sanders
MS
Attachment
CON TED AND AG
TO:
Commissioner Steven W. Tro er
NC Agriculture and Consumer Services
Mailing Address:
NC DEPARTMENT OF ADMINISTRATION
1301 NIA❑ SERVICE CENTER
RALEIGH, NC 27699-1301
Secrete y D. Hall
NC Depafinent of Military and Veteran Affairs
Telephone: [phone]
Fax: [phone]
COURIER #51-01-00
Email: [e-mail]
Website: www.ncadmin nc.aov
Location:
116 WEST JONES STREET
RALEIGH, NORTH CAROLINA

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NRND Architects, PA3608 University Drive, Suite 204Durham, NC 27707T919.490.1266www.RNDarchitects.comIn Association witha r c h i t e c t sProfessional SealsProject Number:Drawn:Checked:Date:Sheet TitleSheet NumberThese drawings and specifications are instruments of service and assuch remain the property of the architect. Their use is restricted tothe original site for which they were prepared and publication there-of is expressly limited to such use. Re-use, reproduction, orpublication by any method, in whole or in part, is prohibited.Original drawing is 30" x 42". Do not scale contents of this drawing.©2018 RND Architects, PA.Key Plan1560 Wilson Blvd, Suite 200Arlington, VA 22209T: 703.907.2300F: 703.907.2050FAI #37-015SCO ID# 18-18781-02ACALYX Engineers + ConsultantsCivil Engineering6750 Tryon RoadCary, NC 27518T: 919.836.4800Surface 678, PALandscape Architecture215 Morris Street, Suite 150Durham, NC 27701T: 919.419.1199Lynch MykinsStructural Engineering415 Hillsborough StreetRaleigh, NC 27603T: 919.782.1833Edmondson EngineersPlumbing, Electrical,Mechanical, Fire Protection700 Executive Park1920 Hwy. 54, Suite 700Durham, NC 27713T: 919.544.1936Foodesign AssociatesFood Service Design615 South College St., 9th FloorCharlotte, NC 28202T: 704.545.6151005634.00/1811CJRMDA07.29.20195900 Chapel Hill Road, Raleigh, NC 27607Raleigh StateVeterans HomeRevisionsNo.DateDescriptionALL WORK SHALL CONFORM TO NCDOT AND / OR CITY OF RALEIGH STANDARDS AND SPECIFICATIONS.EXISTING CONDITIONS PLANC100ABCDE1E2
GRAPHIC SCALE
0 25 50 100
1 inch = 50 ft.
M:\Projects\EastWestPart\EWP-20000\04-Production\Engineering\Current Drawings\Area 4\Impact Maps\EWP20000-Area4-Impact Maps.dwg, 6/1/2021 11:54:26 AM, Vasil, Linda
MT. VERNON ROAD EVENT PARKING
IMPACT MAPS - AREA 1
5900 CHAPEL HILL ROAD
RALEIGH, NC 27607
PROJECT NO.EWP-20000
FILENAME EWP20000-E1
CHECKED BY JB
DRAWN BY LJV
SCALE 1"=50'
DATE 06. 01. 2021
The John R. McAdams Company, Inc.
www.mcadamsco.com
phone [phone]
fax [phone]
license number: C-0293, C-187
One Glenwood Avenue
Suite 201Raleigh, NC 27603
PLAN INFORMATION
LEGEND:
TEMPORARY STREAM IMPACT
PERMANENT STREAM IMPACT
ZONE 1 BUFFER IMPACT (ROAD)
ZONE 2 BUFFER IMPACT (ROAD)
ZONE 1 BUFFER IMPACT (STORMWATER OUTFALL)
ZONE 2 BUFFER IMPACT (STORMWATER OUTFALL
ZONE 1 TEMPORARY BUFFER IMPACT
ZONE 2 TEMPORARY BUFFER IMPACT
PERMANENT WETLAND IMPACT
TEMPORARY WETLAND IMPACT
EXISTING WETLANDS
M:\Projects\EastWestPart\EWP-20000\04-Production\Engineering\Current Drawings\Area 4\Impact Maps\EWP20000-Area4-Impact Maps.dwg, 6/1/2021 11:55:58 AM, Vasil, Linda
MT. VERNON ROAD EVENT PARKING
CULVERT CROSS SECTION - AREA 1
5900 CHAPEL HILL ROAD
RALEIGH, NC 27607
PROJECT NO.EWP-20000
FILENAME EWP20000-E1
CHECKED BY JB
DRAWN BY LJV
SCALE NTS
DATE 06. 01. 2021
The John R. McAdams Company, Inc.
www.mcadamsco.com
phone [phone]
fax [phone]
license number: C-0293, C-187
One Glenwood Avenue
Suite 201Raleigh, NC 27603
PLAN INFORMATION
3a. Reason for impact 3b. Impact type
(Perm. or Temp.)
3c. Type of impact 2d. S. name 3e. Stream Type 3f. Type of
Jurisdiction
3g. S. width 3h. Impact
length
S5 Rd Crossing - Area 2 Temporary Dewatering S3 Perennial Both 3 51
S6 Rd Crossing - Area 2 Permanent Culvert S3 Perennial Both 3 88
S7 Rd Crossing - Area 2 Permanent Rip Rap Fill S3 Perennial Both 3 28
S8 Rd Crossing - Area 2 Temporary Dewatering S3 Perennial Both 3 65
S9 Rd Crossing - Area 3 Permanent Culvert S5 Intermittent Both 3 83
S10 Rd Crossing - Area 3 Permanent Rip Rap Fill S5 Intermittent Both 3 24
S11 Rd Crossing - Area 3 Temporary Other S5 Intermittent Both 3 15
3i. Total jurisdictional ditch impact in square feet:
0
3i. Total permanent stream impacts:
223
3i. Total temporary stream impacts:
131
3i. Total stream and ditch impacts:
354
3j. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this question for all stream sites
impacted.
"S." will be used in the table below to represent the word "stream".
Other = construction access
Total permanent stream loss in acres: 0.015
Total permanent stream loss in linear feet: 177
6b. Impact Type*(?)6c. Per or Temp *(?)6d. Stream name *6e. Buffer mitigation required? * 6f. Zone 1 impact *6g. Zone 2 impact *
B1 Bridge Crossing - Allowable P S1 No 2,701 1,742
B2 Eliminated
B3 Eliminated
B4 Road Crossing Area 2 - S&EC - Allowable T S3 No 2,237 102
B5 Road Crossing Area 2 - Road - Allowable P S3 No 5,196 3,300
B6 Road Crossing Area 2 - S&EC - Allowable T S3 No 6,812 3.622
B7 Road Crossings Area 3 -Road - Allowable w/Mit P S1 Yes 6,204 7,149
B8 Road Crossing 3 - S&EC - Allowable upon Auth T S1 No 2,925 473
B9 SCM Outlet - Area 4 - Deemed Allowable P S2 No 184 169
B10 SCM Outlet - Area 4 - Deemed Allowable T S2 No 290 269
6h. Total buffer impacts:
Zone 1 Zone 2
Total Temporary impacts: 11,974 579
Zone 1 Zone 2
Total Permanent impacts: 14,101 12,191
Zone 1 Zone 2
Total combined buffer impacts: 26,075 12,770
6i. Comments:
Deeamed Allowable impact are not included in the impact totals because they do not require a buffer authorization.
6. Buffer Impacts (for DWR)
If project will impact a protected riparian buffer, then complete the chart below. Individually list all buffer impacts below.
6a. Project is in which protect basin(s)? *
1
Burdette, Jennifer
From:Hardison, Lyn <[e-mail]>
Sent:Tuesday, April 20, 2021 4:00 PM
To:Burdette, Jennifer
Subject:RE: [External] Project Athens Area 4 (DWR #2020-1897)

CAUTION: This email is NOT from McAdams. DO NOT click links or open attachments unless you verify the sender and content.
Bingo!!!!!

An EA will not be required for any project that needs a WQC.



From: Burdette, Jennifer [mailto:[e-mail]]
Sent: Tuesday, April 20, 2021 3:56 PM
To: Hardison, Lyn <[e-mail]>
Subject: RE: [External] Project Athens Area 4 (DWR #2020-1897)

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Lyn,

Doing well. Would love to catch up with you sometime. I know that you guys are crazy busy. Boy, do I know what you
mean.

I believe the land target (45 acres of State land) and funds (30 million) are triggered. Still no EA required because we will
be below minimum criteria and are applying for a 401 WQC?

Jennifer

Jennifer Burdette | Sr. Environmental Consultant, Water Resources

McAdams
2905 Meridian Parkway, Durham, NC 27713
office 919. 361. 5000 x137 | direct 919.287.0743 | cell 919.422.3605 | [e-mail]
www.mcadamsco.com | linkedin | twitter | instagram | join our team

creating experiences through experience

From: Hardison, Lyn <[e-mail]>
Sent: Tuesday, April 20, 2021 3:47 PM
To: Burdette, Jennifer <[e-mail]>
Subject: RE: [External] Project Athens Area 4 (DWR #2020-1897)

2
CAUTION: This email is NOT from McAdams. DO NOT click links or open attachments unless you verify the sender and content.
Hi Jennifer,

How are you? It’s so good to hear from you. All is good in my world…its groundhog day every day.

So, per SEPA, if the development does not exceed $10,000,000 expenditure or permanent land disturbance of greater
than 10 acres of State deeded land, an Environmental Document is not required. The minimum criteria will only be
relevant if the funds or land targets are triggered. Also most of DWR-new 401 projects would not trigger an EA anyway.

I hope this answers your questions.

Take care,

Lyn

From: Burdette, Jennifer [mailto:[e-mail]]
Sent: Tuesday, April 20, 2021 2:40 PM
To: Hardison, Lyn <[e-mail]>
Subject: [External] Project Athens Area 4 (DWR #2020-1897)

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Hi Lyn,

I hope you are doing well. Once again, I have a SEPA question for you.

The Dept of Ag is constructing two additional parking lots (Area 2 & 4) for the State Fair. Area 2 does not involve stream
impacts. Access roads for Area 4 require three stream crossings. Am I correct that, regardless of the cost, a SEPA
document isn’t required if the perennial channel disturbance does not exceed 500 linear feet and the wetland
disturbance does not exceed 1 acre?

We have submitted a PCN application with 516 LF of perennial stream impact because I misread the rules and thought it
was 500 LF of perennial channel loss. We are able to tighten up our pump around plan to get the impacts below 500 LF,
but wanted to make sure that I was interpreting the document requirements correctly. Your assistance is always most
appreciated!

Best Regards,
Jennifer

Jennifer Burdette | Sr. Environmental Consultant, Water Resources

McAdams
2905 Meridian Parkway, Durham, NC 27713
office 919. 361. 5000 x137 | direct 919.287.0743 | cell 919.422.3605 | [e-mail]
www.mcadamsco.com | linkedin | twitter | instagram | join our team

creating experiences through experience