20191760 Ver 1_Please_DocuSign_C-5621_On-Hold_Response_20200430

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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
Roy COOPER
GOVERNOR
April 21, 2020
S. Daniel Smith
Director
NC Division of Water Resources
512 North Salisbury Street
Raleigh, NC 27699
J. ERIC BOYETTE
SECRETARY
Subject: Second Request for Additional Information for Proposed Improvements to Highway 21
Mecklenburg County, C-5621, BIMS No. 20191760
Dear Mr. Smith,
The North Carolina Department of Transportation (NCDOT) is in receipt of your second request for
additional information dated March 31, 2020 for the above referenced project and would like to
offer the following responses to the cited deficiencies:
Inadequate response for avoidance and minimization:
Avoidance and Minimization of stream impacts at Sites 2A and 3 at the southern roundabout:
The location of the southern roundabout had several constraints (outlined below) resulting in the
current location as shown. The southern roundabout is acting as a U-turn for vehicles traveling
eastbound on Catawba Avenue desiring to turn left at the Catawba Avenue/US 21/Holiday Lane
intersection to travel northbound on Holiday Lane therefore a recommended distance of —800-ft
from the main intersection was used to place the roundabout. Considerations of the driveways on
the west side of US 21 as well as access concerns were evaluated for several locations for the
southern roundabout along US 21 north and south of the proposed southern roundabout location.
The proposed location at -Y4- (the driveway to Lucky Dog Bark and Brew) was selected to meet
the spacing requirements for the U-turn location as well as to minimize the impacts to the
Environmental Justice (EJ) Smithville community since there is a break in the houses along S. Hill
Street (parallel road to the east of US 21) here. Driveways are not recommended inclose
proximity to roundabouts and therefore the driveway was designed to act as a "leg" of the proposed
southern roundabout. The existing grade of the -Y4- driveway is the controlling factor to the
placement of the roundabout as the driveway is sloping down toward US 21 at an 8.5% grade. The
distance the roundabout is shown from the existing edge of US 21 at the driveway was needed in
order to get down to the roundabout elevation while also being able to maintain US 21 traffic
during construction.
The roundabout was sized based on the largest design vehicle (WB-67) expected to utilize it daily.
Shifting the roundabout to the west would require that some if not all of the parcels along US 21 in
Mailing Address: Telephone: [phone] Location:
NC DEPARTMENT OF TRANSPORTATION Fax:[phone] OTH HIGHWAY DIVISION
DIVISION OF HIGHWAYS Customer Service: 1-877-368-4968 716 W. MAIN STREET
716 W. MAIN STREET ALBEMARLE, NC 28001
ALBEMARLE, NC 28001 Website: ncdot.gov

that location to be a total take. The Town of Cornelius is currently working to revitalize this area
and removing local businesses would be detrimental to that directive. Shifting the roundabout to
the east would require additional total takes along S. Hill Street in the EJ Smithville community.
Permit Site 3 has been modified by relocating the stream channel for 92 feet rather than directing
flow to a closed pipe system as originally proposed. Impacts to jurisdictional features have been
minimized as much as practical given the site constraints referenced.
Hazardous spill basin was not included in the plans:
We are providing a response to the HSB requirements specifically with regard to requirements
based on project scope and functional classification. We have further evaluated the feasibility of
a basin at this site by investigating highway volume, traffic type, accident potential, receiving
water quality and feasibility of construction and have determined a Hazardous Spill Basin (HSB)
is not required as outlined in Appendix O in the "NCDOT Guidelines for Drainage Studies and
Hydraulic Design 2016".
Roadway classification:
Currently Holiday Lane is classified as a Local road per the NCDOT Functional Classification
GIS map shown below and after the construction of the C-5621 project, Holiday Lane will be
classified as a collector. Due to this classification, the requirement for a HSB at the location of
the northern roundabout (Holiday Lane intersection with Sterling Bay Ln East and West) has
been analyzed on a site by site basis per Appendix O in the "NCDOT Guidelines for Drainage
Studies and Hydraulic Design 2016". More detailed site -specific information related to the
determination of why a HSB was not proposed is outlined below.

Home 9 NCDOT Functional Class
0 Details I 8& Basemap
Q About []°-- Content It Legend
Legend
NCDOT Functiona I Clan
Functional Class
— Interstate
Other Freeway
— Other Principal Arterial
Minor Arterial
Major Collector
M i nor Collector
— Local
Project Purpose:
C-5621 is designated as a project to improve mobility and safety in the area, not to increase
capacity, and is therefore not considered a major project for NCDOT.
Safety: Roundabouts are considered a great improvement for safety as compared to traditional
signalized and unsignalized intersections. Removing the existing conflict points at the northern
point of Holiday Lane with Sterling Bay Lane East and Sterling Bay Lane West reduces the

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likelihood of accidents. Improved safety at this location as noted by FHWA would reduce severe
accidents by 82%.
hLtps:Hsafety.fhwa.dot.gov/provencountermeasures/roundabouts/
The safety at the intersection of Catawba Avenue/US 21/Holiday Lane is also improved due to
redirecting the eastbound and westbound left turn traffic to turn right instead and utilize the
roundabouts. This reduces the unprotected conflict maneuvers which reduces the potential for
crashes to occur.
Constructability Impacts:
Two locations have been evaluated for an HSB to be constructed. Site 1 as shown below is on the
north side of Sterling Bay Lane East and the proposed location of the northern roundabout, while
Site 2 (also shown below) is on the south side of Sterling Bay Lane East and the proposed location
of the northern roundabout.
I!M1.1.` M- I
HSB Site 1 (north of Sterling Bay Lane East and the proposed northern roundabout)
This HSB is shown in a linear pattern due to several site constraints; an existing sanitary sewer
pump station and apartment building located to the west and the existing apartment complex club
house and amenities located to the east. This site is wooded which would require removal of
existing mature trees and vegetation. It is located on top of a previously identified jurisdictional
stream (JS). Another blue line stream approaching from the west crossing under Sterling Bay Lane
West adjoins with this IS prior to out falling into Lake Norman. It is anticipated the blue line
stream will need to be relocated in order to keep the water separated from the proposed HSB.
Stability of the banks would be a concern and additional erosion control measures are likely to be
needed. The conceptual contours for the HSB construction shown above in magenta are a best
guess as a detailed survey has not been conducted at this time. It is unknown if the width required
for the stream relocation and the proposed HSB will physically fit between the existing physical

constraints. This would also have major impacts to this property owner due to the tree buffer being
removed. As shown an extensive amount of right of way would be required in order to construct
and maintain the HSB. This property is currently in condemnation and the property owners will
likely be uncooperative moving forward. The location of the HSB at Site 1 has the potential for
previously rerouted utilities and other existing utilities to be in conflict and therefore has unknown
additional impacts at this time.
HSB Site 2:
HSB Site 2 (south of Sterling Bay Lane East and the proposed northern roundabout)
Please note in this option a preliminary revised closed storm drainage system was evaluated in
order to redirect water flow to the HSB on the south side of Sterling Bay Lane East.
An existing JS has also been identified on the south side of Sterling Bay Lane East, as well as a
linear wetland that would have potential impacts from the construction of the HSB Site 2. The
conceptual contours for the HSB shown above in white are in a rectangular pattern to best match
existing site conditions in this area.
Most of the existing tree buffer in this location would be removed exposing the residents along
Burton Lane (shown to the east of the HSB Site 2 above) to the HSB further impacting homeowners
of a previously identified EJ community. Additional right of way would be required from
homeowners in order to construct and maintain the HSB in this location. Preliminary calculations
have been evaluated revealing that in order to get the rerouted closed storm drainage system to
drain to the HSB the inverts would be at the same elevation as the existing JS. This raises concerns
of exposing the existing water table due to the low elevations required for the HSB.
The location of this HSB would also be in an area where existing and proposed utilities were routed
to avoid additional conflicts with the apartment complex on the north side of Sterling Bay Lane
East. Therefore, construction of the HSB in this location would have unknown additional utility
impacts for the project.

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Public Involvement:
Extensive public outreach has previously been conducted for this project due to the sensitive nature
of the surrounding neighborhoods. With Smithville neighborhood being a historically African
American community, the Title VI Environmental Justice process was implemented. Several small
group meetings have been held specifically with the Smithville community explaining in great
detail all the impacts associated with the C-5621 project as currently designed. Additional impacts
to parcels in either location (HSB Site 1 or HSB Site 2) would require additional public
involvement and engagement for the project.
Due to the reasons listed above, most notably the functional classification of Holiday Lane, the
reduced accident potential and feasibility of construction, we respectively request that the project
move forward without the construction of a hazardous spill basin for the northern roundabout.
Lastly, due to the many constraints analyzed and implemented during the selection of location of
the southern roundabout we also respectfully request the project move forward with the southern
roundabout remaining as proposed.
Additional impacts to jurisdictional areas not included in the plans:
Revised permit plan sheets are attached which include Permit Site 4 for a total of 42 square feet of
permanent wetland impacts that were not identified during the original Preliminary Jurisdictional
Determination field visit conducted by the US Army Corps of Engineers on August 23, 2019.
If you should have any questions or require any additional information related to this response,
please feel free to contact Larry Thompson, Division 10 PDEA Engineer at [phone] or by
email at: [e-mail].
Sincerely,
DocuSigned by:
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Division Engineer
Attachment: C-5621 Revised Permit Plan Sheets
Cc: Monte Matthews, USACE
Amy Chapman, NCDWR
Donna Hood, NCDWR
Sean Epperson, NCDOT
Randy Bowers, NCDOT
Larry Thompson, NCDOT
Joel Howard, NCDOT