20161033 Ver 1_Response to request for addtional information_20161122

PANGLER
ENVIRONMENTAL, INC.
Environmental Planning Environmental Permitting Environmental Consulting Environmental Construction Management Expert Testimony
November 22, 2016
Samantha Dailey,
Raleigh Regulatory Field Office
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
RE: Request for Additional Information for Waterstone
Dear Ms. Dailey,
We are confident that our design efforts have resulted in avoiding and minimizing impacts to jurisdictional features to the
greatest extent practicable. The site plan we have proposed represents the best practical alternative that still meets key
project needs of maintaining compliance with local ordinances, DOT regulations, and projected economic viability. In
response your e-mail sent on 11/22/16 concerning the Waterstone (SAW -2016-01345) PCN submittal, we offer the
following remarks.
The Town of Hillsborough requires at least two means of ingress/egress to and from the property. There are two
currently existing median breaks in Waterstone Drive, which makes them the natural locations for the two
entrance roads which are necessary for the project. Furthermore, the Town of Hillsborough requires that one of
the entrances to the property (Street B) must be aligned with the existing signalized intersection for the UNC
Health Care -Hillsborough Campus Hospital located directly across Waterstone Drive. Since the Town has made
the fixed location of Street B a condition of the project, the impact to wetland F (Impact Area D) cannot in any
way be avoided. In order to minimize impacts to wetland F, stream C, and wetland G, lots which were originally
planned to go along the southern portion of Street B were removed from the project.
In order for stormwater pond B to function, grading of the surrounding area was necessary. The location of the
pond was moved to the west from its original location so the pond would not be located within a wetland unit.
Due to local topography, a retaining wall was utilized as part of the grading plan. The retaining wall resulted in
impacts to wetland C (Impact Area Q. Since wetland C would already be impacted as a result of the grading
elements associated with the stormwater pond which is necessary for the project, a lot was planned to occupy a
portion of the area where wetland C is currently located. The impact to wetland C is not for the sake of fitting one
more lot onto the project, but rather for the grading elements associated with the stormwater pond. The lot in this
location was merely an afterthought in the planning process to make efficient use of the project area.
• As discussed earlier, the locations of the entrance roads (Street A and Street B) are fixed due to the existing
configuration of Waterstone Drive and the requirements set by the Town of Hillsborough. The maximum
allowable curvature of Street A was used to minimize impacts to wetland L and tributary L (Impact Area B).
Impacts in this area would be required for the construction of Street A and thus were unavoidable. Since wetland
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L and tributary L were already being impacted by fill slopes for the road, it was determined that the inclusion of
lots in this area would only result in a nominal increase in wetland impacts in addition to those which were
already necessary for the project. The decision to include lots in this area was preferable to placing lots in other
low lying areas of the property which would have resulted in a greater net result of wetland impacts to achieve an
appropriate amount of lots for the project.
A site concept plan from early in the planning process is included as an attachment. The concept plan includes
significant additional impacts to wetland F as well as impacts to wetland G and stream C as the result of lot fill.
Those lots were later removed to minimize wetland impacts. The concept plan also shows impacts to wetlands C,
D, E and stream C as the result of a strormwater pond and lot fill. Road A was later redesigned, stormwater pond
B was later relocated, and lots were later rearranged to minimize wetland impacts. Additionally, the concept plan
shows greater impacts to wetland J as a result of fill for a pool area. The configuration of the area where the pool
was originally planned was later changed to minimize wetland impacts. Despite an overall reduction in the total
amount of lots associated with the project, various considerations were made to design roads, stormwater
management features, amenity locations, and lot locations to avoid and minimize wetland impacts to the greatest
extent practicable.
• There is no surface connection between wetland L and the other features on the subject property. Tributary L
drains into wetland L. Both features are located in a topographic depression with no jurisdictional hydrologic
connection to other features visible on the surface. The planned impacts are in the headwater areas of this
jurisdictional area. As a result, impacts to this area will not result in cumulative impacts to the function of other
areas.
During the contemplation of minimized impacts, several lots were removed from the site plan for the sole purpose of
reducing impacts to jurisdictional features. Lot locations, stormwater locations, and road locations were chosen to
efficiently maximize the use of non -avoidable impacts and uplands.
Sincerely,
Spangler Environmental, Inc.
Tomas Will
Environmental Project Scientist
Attachments: Site Concept Plan Prior to Minimization
69
SPANGLER
ENVIRONMENTAL, INC.