20200009 Ver 1_DWR Response_20200205

Strickland, Bev
From: Meagan Jolly <[e-mail]>
Sent: Wednesday, February 5, 2020 8:49 AM
To: Johnson, Alan
Cc: [e-mail]; Boyle, Mike; David Starkel; Chris Huysman
Subject: [External] Re: SAW 2016-00724, DWR 20-0009
Attachments: 200205_NCDWR response.pdf
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Alan,
Thank you for your comments. Please see attached response, and let us know if you have any other questions
or concerns.
Thanks,
Meagan Jolly
704.681.3479
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On Fri, Jan 17, 2020 at 11:28 AM Johnson, Alan <alanJohnsonkncdenr.gov> wrote:
This appears to be an expansion of an existing parking lot recently permitted in March 2017 for
148 if of stream impact for a stream crossing. Proposed is an additional 208 ft, which would
appear to place you in individual permit territory. This will need to be clarified with the Army
Corps. In addition the impact is for parking spaces. A parking deck would achieve the same
result and avoid additional stream impacts.
A discussion should be provided how filling the headwater of a channel would not have an
adverse effect down gradient given the headwaters is being filled. Should/if the project moves
forward, monitoring down gradient could be required and depending if a loss can be identified,

potential mitigation may be required. A base line for the existing stream flow, biota, etc could
be required. The measurement and timeline for the study can be discussed.
Parking can be increase with the current site with the construction of underground storm bmps,
without the need for additional stream impact. Why is/was this not an option.
Thanks,
Alan
DWR
DkUWm of war Resour-tc;
Alan D Johnson — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.

WETLANDS
ly4y8a, WATERS, INC.
February 5, 2020
Mr. Alan Johnson
N.C. Department of Environmental Quality
Division of Water Resources
610 East Center Avenue, Suite 301
Mooresville, NC 28115
RE: The Parking Spot — Charlotte, NC
SAW-2016-00724; DWR 20-0009
Mecklenburg County, North Carolina
Mr. Johnson,
This letter is provided by Wetlands & Waters, Inc. on behalf of The Parking Spot Charlotte in response to a request
by the N.C. Division of Water Resources (DWR) for more information relating to the above referenced project.
Requests from DWR are italicized, with responses in bold.
This appears to be an expansion of an existingparking lot recently permitted in March 2017 for 148 if of stream
impact fora stream crossing. Proposed is an additional 208 ft, which would appear to place you in individual
permit territory. This will need to be clarified with the Army Corps. In addition the impact is for parking spaces. A
parking deck would achieve the same result and avoid additional stream impacts.
Impacts associated with the proposed project may be eligible for a waiver of the 300 linear foot threshold
established in the Nationwide Permit program. Based on an email received February 3, 2020 from NCWRC
referencing the waiver request outlined in the Pre -Construction notification submitted by W&W on
December 18, 2019, it appears that the Corps has initiated agency coordination for the waiver request.
A parking deck is not a viable onsite alternative for the proposed project. A parking deck is not economically
practical and would require extensive construction work, structural design, and reassessment of stormwater
management on the property, which would substantially disrupt ongoing business operations on the site and
would potentially require prolonged site disturbance due to construction of the structure.
A discussion should be provided how filling the headwater of a channel would not have an adverse effect down
gradient given the headwaters is being filled. Should/if the project moves forward, monitoring down gradient could
be required and depending if a loss can be identified, potential mitigation may be required. A base line for the
existing stream flow, biota, etc could be required. The measurement and timeline for the study can be discussed.
Most of the stream systems onsite intersect with groundwater. Construction of the project will not result in
negative impacts to hydrology of these downstream systems since the project will not impact or reduce
groundwater input. Additionally, the controlled release of treated stormwater runoff from the impervious
surfaces of the site will assist in ensuring there is not removal of hydrology from downstream systems.
Baselines documenting existing conditions of the streams onsite are available. The applicant understands that
future monitoring may be required.
Parking can be increase with the current site with the construction of underground storm burps, without the need for
additional stream impact. Why is/was this not an option.
Underground stormwater BMPs were considered for the project but found to not be viable at this time. The
existing stormwater controls would have to be removed and temporary controls placed elsewhere for the
duration of the construction period for underground stormwater BMPs. While underground stormwater
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTALCONSULTANTS

I WETLANDS
,1. & WATERS9 INC.
BMPs would achieve the same level of treatment and detention as the existing structures once constructed,
there is limited area where temporary stormwater BMPs could be implemented during construction of the
underground BMPs, and the level of treatment and detention achieved with the existing structures would not
be possible with the temporary stormwater BMPs, resulting in a lapse of coverage for the duration of
construction of the underground BMPs. The lapse of detention coverage for the duration of construction
would significantly increase the probability of erosion and scour downstream due to the increased volume of
runoff from the site.
Should you have questions or concerns on the above information, please don't hesitate to contact us.
Best Regards,
Meagan Jolly
704.681.3479
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTALCONSULTANTS