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HomeMy WebLinkAbout20160571 Ver 1_Staff Comments_20160616Water- Rcsources ENVIRONMENInL OU.OL i 1' PAT MCCRORY � DONALD R. VAN DER VAART ��rcit�n,n� S. JAY ZIMMERMAN l hn�� lur� June I5, 2016 Mr. Randy McCaslin, Deputy City Manager City of High Point 211 S. Hamilton Street High Point, NC ?7260 Subject: Proposed Penny Road Greenway in Guilford County, Federal Aid Project No. TCSP-0710(20), State Project No. 45125.1.1, TIP Project No. EL-5104. Dear Mr. McCaslin: The Division of Water Resources has reviewed your submittal for a 401 Water Quality Certification and Randleman Buffer Rules Authorization for the subject project. Review of your application revealed it lacking necessary information required for making an informed permit decision. The permit application was deficient in the following areas: • Page 1, Section A.ld. of the Pre-Construction Notification (PCN) form indicates that you are only applying for a 401 Water Quality Certification. The project is located in the Randleman Lake watershed and appears to impact protected riparian buffers. The PCN should also indicate that you are applying for a Riparian Buffer Authorization. Please submit a revised page 1 of the PCN. • The drawings submitted with the application do not show the areas of impact to streams, wetlands, or buffers. Although it can be assumed that the impacts correspond with the location of the greenway, there may be additional cleared areas outside of the greenway location for installation and maintenance purposes. Please clearly show the impacts to streams, wetlands, and buffers on the drawings at a scale that is easy to read (no greater than 1 "=50'). • [t is unclear whether there will be a maintenance corridor along either side of the greenway through the buffers. NCDWR will accept 2-foot maintenance corridors on either side of the greenway through buffers. Please indicate the location and width of any maintenance corridors on the drawings. • The temporary culverts shown on the plans do not include specifics on the culvert diameters. Please provide details of the culvert dimensions that demonstrate they are appropriately sized for the respective streams. • Sheet 8 of the drawings appears to shows parallel impacts to Zones 1 and 2. Is it possible to shift the alignment of the greenway to avoid the impacts to Zone 1. If not, please provide a justification for the Zone 1 impacts. • Sheet 9 of the drawings appears to show the asphalt greenway beginning in Zone 1. [s it possible to extend the elevated timber greenway section beyond Zone l? If not, please provide a justification for the Zone ] impacts. • Sheets 13 and 14 of the drawings appear to show a riprap ditch beginning approximately at the elevated timber greenway section and extending down through Zone 2 of the buffers. This is not considered diffuse flow and does not appear to meet the requirements of stormwater treatment to control nitrogen and attenuate flow for new conveyances through the buffers [ 1 SA NCAC 02B .0250(9)]. Please provide justification for this new stormwater conveyance as proposed. Please be aware that if the conveyance is approved as proposed, mitigation will be required for the buffer impacts resulting from the conveyance. Therefore, pursuant to 15A NCAC 2H .0507(a)(5), we will have to place the permit application on hold until we are supplied the necessary information. You have 21 days to respond in writing with the requested information or notification to this office that the information is forthcoming. If, at the end of the 21 days, this office has not received this information in writing, we will assume you are withdrawing your application and it will be returned. Furthermore, until the information is received by the NC Division of Water Resources, we request (by copy of this letter) that the US Army Corps of Engineers place the permit application on hold. If you have any questions or require additional information, please contact Brian Wrenn at 919-707-8792 or brian.wrenn@ncdenr.gov. State of North Carolina ,Environmental Quality I Water Resources 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Phone:919-807-6300 Sincerely, � S. Jay Zimmerman, Dir for Division of Water Resources Electronic copy only distribution: David Bailey, US Army Corps of Engineers, Raleigh Field Office Jerry Parker, Division 7 Environmental Officer File Copy