20210448 Ver 1_More Info Received_20210708

kimley-horn.com 200 South Tryon Street, Suite 200, Charlotte, NC 28202 704-333-5131

July 8, 2021

Ms. Donna Hood
NC Dept. of Environmental Quality
Division of Water Resources
Transportation Permitting Branch
610 E. Center Ave.
Mooresville, NC 28115

RE: NCDWR #20210448 - Response to Incomplete Application Notification
City of Gastonia - Gateway 85 - Aberdeen Blvd Ext and Lineberger Rd Realignment
Gaston County, North Carolina

Dear Ms. Hood,

On behalf of our client, the City of Gastonia, Kimley-Horn is submitting the attached additional information
for the above referenced Project per the North Carolina Department of Environmental Quality, Division of
Water Resources Incomplete Application Notification dated June 13, 2021.

Below is an outline of the NCDWR comments with a brief narrative addressing each item. The NCDWR
comments with Kimley-Horn response and explanation are as follows:

1. Provide verification of Army Corps of Engineers (ACOE) selection of Nationwide Permit 14
See attached email correspondence from the ACOE.
2. Provide ACOE approved purpose and need statement and logical termini determination
See attached email correspondence from the ACOE.
3. Provide Indirect and Cumulative Impact study for the development of the currently forested
400 acres to ensure future development will not contravene water quality with coming
development of the Northpointe
A formal Indirect and Cumulative Impact study report was not prepared for this project;
however, extensive justification, avoidance and minimization, and cumulative impact
analyses have been considered for both the private industrial park as well as the privately
funded, future public City of Gastonia roadway project. The final version of the Individual
Permit narrative for the private industrial park is included for reference. Here is additional
justification for the privately funded, future public proposed roadway project:

The proposed public ROW will cut through to facilitate public traffic. Historically this project
has been named the “Lineberger Connector” and has been part of Gastonia and Lowell’s
long-range transportation plans. The public ROW will extend Aberdeen and relocate/realign
Lineberger up to Lowell Road. Currently, to get from Lineberger to Aberdeen, the travel
takes approximately 8 minutes and requires traffic to cut through a residential neighborhood
via a grade-separated, single-vehicle tunnel under the Norfolk Southern Rail line or drive out
to Cox Road and then back into Aberdeen. Additionally, the shortest path from Lowell Road
to the I-85 Interchange is through the residential neighborhood. Cut-through traffic poses a
great risk to folks in the residential community. The proposed project will significantly reduce
drive times and cut-through traffic, which will greatly improve the safety of the residents. The
stub at the end of Aberdeen Extension is required to provide public ROW access to the
private residences along the eastern side of the existing Lineberger Road. Following the
construction of the Gastonia Logistics Park Building 3002, those homeowners will be routed
through realigned Lineberger Road, to the Aberdeen extension and east to their homes.
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kimley-horn.com 200 South Tryon Street, Suite 200, Charlotte, NC 28202 704-333-5131

This is a more recent article for the roadway project. The roadway has gone through many
iterations, but the purpose remains the same:

https://www.gastongazette.com/news/20200225/lineberger-connector-making-fourth-push-
for-funding

Here is the Gaston-Cleveland-Lincoln Metropolitan Planning Organization’s 2045
Comprehensive Transportation Plan for Streets and Highways as referenced in the IP
document. This was last updated in 2018:

https://gclmpo.org/wp-content/uploads/Chapter-11-Streets-and-Highways-1.pdf

4. Provide stormwater plan review and approval by the locally permitted MS4 entity
See attached.
5. Provide documentation of alternative routes that were studied to ensure the Least
Environmentally Damaging Alternative was chosen; a less environmentally impactful road
location was identified during the review process
See attached.
6. Correct the following on the PCN:
a. Use the most recent version of the PCN form, Version 4.1
The application was submitted through the ePCN portal. Per the USACE
Wilmington District website, the most recent version of the PCN (Version 1.4)
was uploaded as an attachment to the ePCN for reference.
b. Fill out the stormwater section in its entirety (Section E, #2,3,4, and5)
See attached.
c. Public monies are being used for this project, please check the correct box
(Section F 1.a)
Public monies are not being used for this project. The project is privately funded
and will be constructed by the developer as required by the City of Gastonia.
Roadway and utilities will be dedicated to the City following completion of
construction.
d. Provide NEPA/SEPA documentation
NEPA/SEPA is not proposed since public monies are not included.
7. Impacts for Sites 1a and 1b will be cumulative due to their close proximity to each other
This was assumed as part of the original submittal. Cumulative impacts are less than 300lf for
this single and complete project area.
8. If proposed roadway ownership is being assumed by NC DOT, provide written approval of the
design from the NC DOT Hydraulics Unit in Raleigh
Ownership will not be assumed by NCDOT. The City of Gastonia will assume ownership of
the road once dedicated by the private developer.
9. Provide narrative on how utility impacts will be handled
All utilities are within dedicated easements and avoid additional impacts; where utilities cross
streams these impacts are within the ROW and accounted for in the PCN.
10. Provide new copies of pdf pages 38, 39, 40, 55, and 56 which were unreadable
See attached.
11. Provide adequate surface water conveyance at Sta 33+71 on Lineberger Road to maintain
aquatic passage
Please see the Under Drain Detail. The entirety of intermittent stream S8 will be filled by the
development (upstream portion) and the roadway (downstream portion), therefore,
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kimley-horn.com 200 South Tryon Street, Suite 200, Charlotte, NC 28202 704-333-5131

maintaining aquatic passage is not feasible. We are proposing an underdrain to maintain
subsurface/contributing flow to perennial stream S5.

12. Provide a plan detail for bank stabilization which includes Class II riprap
The hydraulic discharge analysis for both culverts at the impact site indicates that the existing
condition versus proposed condition for the bankfull and the 100-year events are nearly
equivalent. Therefore, natural channel design techniques including bank grading and native
riparian vegetation plantings are preferred. We propose to modify the plan to install 25 lf of
Class II riprap along both banks beginning at the outlet of each culvert and extending
downstream in order to maintain stability at the highest energy discharge locations, followed
by natural stabilization throughout the remaining impact site.

The Section 106 process is nearing completion for the on-site development since adverse effects are
proposed by the development only. The proposed roadway project will have no effect on these features.

Additionally, we submitted a response to Mr. Byron Hamstead with the USFWS indicating that the Federal
nexus requiring their review is the USACE 404 Permit. As of the date of this letter, no response has been
received. The on-site development is currently going through an IP process; therefore, all of the
applicable agencies have been notified of development activities.

If you need any additional information to assist in your review of this RFI Response Package, feel free to
contact me at 704-409-1802 or [e-mail].

Sincerely,

Kimley-Horn and Associates, Inc.

Chris Tinklenberg, PWS
Environmental Scientist
1
Tinklenberg, Chris
From:Tinklenberg, Chris
Sent:Thursday, July 8, 2021 12:02 PM
To:Tinklenberg, Chris
Subject:FW: Gastonia Road NWP

From: Roden Reynolds, Bryan K CIV (USA) <[e-mail]>
Sent: Wednesday, June 30, 2021 11:43 AM
To: Tinklenberg, Chris <[e-mail]>
Subject: RE: Gastonia Road NWP

Mr. Tinklenberg,

Please provide the following information to the State:

- The City of Gastonia submitted a PCN with the following permanent and temporary stream and wetland
impacts to extend Aberdenn Boulevard and realign Lineberger Road. These impacts will be issued under
Nationwide Permits 13 and 14.
Nationwide Permit No. Aquatic Resources
Impacted
Duration of Impact Amount of Impact Reason for Impact
14 Stream 3 Permanent 168 linear feet (0.02
acres)
Culvert installation
14 Stream 1 Permanent 127 linear feet (0.02
acres)
Culvert installation
14 Streams 1, 3, and 5 Temporary 90 linear feet Dewatering activities
13 Streams 1 and 3 Permanent 290 linear feet (0.04
acres)
Bank stabilization
activities
14 Stream 5 Permanent 137 linear feet (0.01
acres)
Culvert installation
14 Wetland 11 Permanent 0.06 acre Grading
14 Wetland 11 Temporary 0.01 acre Construction access
14 Stream 8 Permanent 214 linear feet (0.02
acres)
Grading
14 Wetland 6 Permanent 0.02 acres Grading
14 Wetland 6 Temporary 0.01 acres Construction access

- In the PCN submitted to the Corps, the applicant stated the purpose of the project as “The Gateway 85
Project, formerly named The Lineberger Connector Project, is a well-known, previously planned public
connector located within the Gastonia Logistics Center. The connector will provide independent utility to the
residents of Gastonia and Lowell that live and work locally. The connector will decrease travel time for
eastbound/westbound users and eliminate cut-through traffic in adjacent residential communities,
providing safer neighborhoods for these residents. In addition, to time savings for residents who may no
longer need to commute along I-85, other travelers and the freight industry will benefit from the reduced
congestion along the interstate. The Lineberger Connector Project is currently included in the Gaston-
Cleveland-Lincoln Metropolitan Planning Organization’s Comprehensive Transportation Plan and has been
included in the organization’s long-range transportation plan for many years.” At this time the Corps has no
issues with the stated purpose of the project.

Thanks,
2

Bryan Roden-Reynolds, PWS
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
Gastonia Logistics CenterProject Name
Date:
Location
Submitted By
Date Received:
Watershed
New Submittal Revision
Sincerely,
Gaston County Stormwater Control Program
Responsible Party
Address
City, State, Zip
Stormwater Administrator
Gaston County
Soil Erosion and
Sedimentation Control
Program
RE: Letter Of Approval
Joseph D. Alm
Gaston Natural Resources Department
Stormwater Control
GASTON COUNTY
12/02/2020
Aberdeen BLVD & Lineberger RD
Kimberly-Horn and Associates, Inc.
X
Cramerton
11/03/20
Kimberly-Horn and Associates, Inc.
NPD Management, LLC
4825 NW 41st Street, Suite 500
Riverside MO 64510
000000296
Telephone: [phone]
Gaston Natural
Resources Department
1303 Cherryville Hwy
Dallas, NC 28034
Gaston County
Belmont
Bessemer City
Cherryville
Cramerton
Dallas
Dellview
Gastonia
High Shoals
Kings Mountain
Lowell
McAdenville
Mount Holly
Ranlo
Spencer Mountain
Stanley
Mission Statement
"To provide leadership
and conservation
assistance to the
people of Gaston
County to improve and
sustain their soil,
water, air, plant and
wildlife resources."
CC1:
CC2:
www.co.gaston.nc.us/
NaturalResources
attn: NPD Management, LLC
Gaston Natural Resources Department received a complete Stormwater Control Plan for the above
project . Staff review of the plans and specifications determined that the project, as proposed, will
comply with Gaston County's Stormwater Ordinance. The Gaston County
Your Stormwater Permit shall be effective from the date of issuance and shall be subject to the
conditions and limitations as specified therein. Please pay special attention to your Operation and
Maintenance requirements. Failure to establish an adequate system for operation and maintenance of
the stormwater management system will result in future compliance problems.
Section 11, As-built Plans and Specifications, of the Stormwater Ordinance shall be validated at
completion of the project. Note that a Certificate of Compliance or Occupancy will not be issued without
as-built plans or certification of previously submitted plans.
Be advised of the annual inspection report, maintenance agreement/restrictive covenant, and record
easements for access, maintenance, and inspections required under Section 18, Assurance that
Improvements will be Maintained, in Gaston County's Stormwater Ordinance.
If any parts, requirements, or limitations contained in this permit are unacceptable, or you need
additional information concerning this permit, please contact Gaston Natural Resources Stormwater
Division at [phone]. We look forward to working with you throughout this project.
Stormwater Permit number,
This approved plan shall become null and void if no progress is realized on-site within six months after the
date of approval (Section 7.p). If any parts, requirements, or limitations contained in this permit are
unacceptable, or you need additional information concerning this permit, please contact Gaston Natural
Resources Stormwater Division at [phone]. We look forward to working with you throughout this
project.
CONTACT:
is approved.
Alternative Route 1
Alternative Route 2
Alternative Route 3

Page 12 of 15
PCN Form – Version 1.4 January 2009

E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1a. Does the project include or is it adjacent to protected riparian buffers identified
within one of the NC Riparian Buffer Protection Rules? Yes No
1b. If yes, then is a diffuse flow plan included? If no, explain why.
Comments: The project does not include nor is it adjacent to protected riparian
buffers.
Yes No
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? 50%
2b. Does this project require a Stormwater Management Plan? Yes No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why:

2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
Stormwater is mitigated by over detaining within the overall project limits so that the overall development meets the
oridinance requirements. Additionally the site has been design to attenuate post development peak flows to pre-
development rates for the 25YR-24HR storm event, which is excess of the code requirements.
2e. Who will be responsible for the review of the Stormwater Management Plan?
Certified Local Government
DWQ Stormwater Program
DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a. In which local government’s jurisdiction is this project? Gaston County
3b. Which of the following locally-implemented stormwater management programs
apply (check all that apply):
Phase II
NSW
USMP
Water Supply Watershed
Other:
3c. Has the approved Stormwater Management Plan with proof of approval been
attached?
Yes No
4. DWQ Stormwater Program Review
4a. Which of the following state-implemented stormwater management programs apply
(check all that apply): N/A, Certified Local Government Review
Coastal counties
HQW
ORW
Session Law 2006-246
Other:
4b. Has the approved Stormwater Management Plan with proof of approval been
attached? Yes No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? N/A Yes No
5b. Have all of the 401 Unit submittal requirements been met? N/A Yes No
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>>CC DDDDSTA:64+78.68
OFF:37.93'LT
STA:64+80.52
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ABERDEEN BLVD EXTENSIONCULVERT C
72" RCP68' DUKE POWEREASEMENTEXISTING STREAM BUFFER
30' FROM TOP OF BANK EXISTING STREAM BUFFER
30' FROM TOP OF BANK
HEADWALL C1
HEADWALL C0
PROPOSED 30' GENERAL
DRAINAGE AND UTILITY EASEMENT
PROPOSED 30' GENERAL
DRAINAGE AND UTILITY EASEMENTFUTURE GDUEFUTURE GDUEH. Scale:1"=40' | V. Scale: 1"=4'
CULVERT-C
Profile Data
48" RCP
INV:718.34
8" DI
INV:721.53
78 LF OF72" RCP @ 1.68%
CULVERT
BURIED 1-FEET
PROPOSED GRADE
FOR ABERDEEN ROAD
EXISTING
GRADE1.00'TOP OF SILL
ELEV:711.42
TOP OF SILL
ELEV:710.11HEADWALLSTA:-0+04.06ELEV:720.98HEADWALLSTA:0+74.84ELEV:719.66BASE FLOW LINE
3"-4" ABOVE EX. GRADE
HEADWALL
HEADWALL 1.74'5.12'LINEBERGER ROAD EXTENSIONEXISTING STREAM BUFFER
30' FROM TOP OF BANK
EXISTING STREAM BUFFER
30' FROM TOP OF BANK
PROPOSED UNDERDRAIN LOCATION
STA:34+24.94
OFF:55.30'LT
STA:33+71.99
OFF:72.52'RT
INVERT 1' BELOW
EXISTING GRADE
70' PRIVATE ACCESS EASEMENT
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ABERDEEN &LINEBERGER STREAMCROSSINGR502NORTHPREPARED FOR• •GATEWAY 85NORTHPOINT DEVELOPMENT(GASTONIA LOGISTICS CENTER)NORTH
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(H20 LOAD)
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PVMT AREAS
PAVEMENT AREAS UNPAVED AREAS
BACKFILL WITH
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MATERIAL FOR
BACKFILL WITH
COMPACTED GRANULAR
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FUTURE CONNECTION
OR CONTINUATION
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••••• • • • • • • • • •
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TO MEET AASHTO M252
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YARD AREASPAVEMENT AREAS
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