20200694 Ver 1_G.8 Purpose and Need_20200526

FROEHLING & ROBERTSON, INC.
Engineering Stability Since 1881
310 Hubert Street
Raleigh, North Carolina 27603-2302
T 919.828.3441 I F 919.582-0304

Corporate HQ: 3015 Dumbarton Road Richmond, Virginia 23228 T 804.264.2701 F 804.264.1202 www.fandr.com

VIRGINIA • NORTH CAROLINA • SOUTH CAROLINA • MARYLAND • DISTRICT OF COLUMBIA

A Minority-Owned Business

Purpose & Need/Avoidance & Minimization Statement for Proposed Wetland and Stream Impacts
Big Rockfish Creek Outfall Project
Fayetteville, Cumberland County, North Carolina
F&R Project No. 59Y-0128

PURPOSE AND NEED

The proposed project is located in southwest Cumberland County, in and around the southwest
portion of the City of Fayetteville. The proposed project is the installation of a new gravity outfall
consisting of approximately 22,900 linear feet (LF) of 24” sewer pipe and 10,850 LF of 18” sewer pipe
to serve areas annexed by the City of Fayetteville. The Fayetteville Public Works Commission (PWC) is
obligated to provide sewer service to the annexed communities as part of the annexation agreement.
In addition to the outfall, six existing neighborhood lift stations, serving communities along the route
of the outfall but outside of the annexation areas, will be abandoned and re -routed to the outfall.
Abandoning all six lift stations requires an additional 5,650 LF of 12” gravity sewer and 8,600 LF of 8”
gravity sewer line.

Since the project area is currently not served by sewer utilities, there are no existing means to
directly serve the annexation areas. A means of conveying the collected wastewater to existing
outfalls owned by PWC is required. PWC has made providing sewer service to this area a priority in
its Capital Improvement Plan (CIP) to satisfy its legal obligations. The purpose of the proposed project
is to implement PWC’s CIP to provide a means of conveying collected sewerage from areas previously
annexed, protect the environment by providing a means of replacing septic systems in the
annexation areas that will eventually fail, and provide for Fayetteville future growth by installing a
means of collecting sewerage from additional areas beyond those annexed. The outfall also provides
a means of replacing septic systems in the annexation areas as well as within existing incorporated
areas along the outfall corridor. Although septic systems in this area are not known to currently be
failing, septic systems are known to have a limited lifespan before the drain fields become plugged
and need to be replaced to prevent sanitary issues inside residences or spills of raw wastewater onto
residential property. Having a public sewer system in place that property owners can connect to will
help reduce or eliminate the occurrence of these spills.

In addition, the construction of the outfall will allow PWC to eliminate six neighborhood lift stations,
simplifying PWC’s wet weather response procedures, reducing energy consumption, and reducing
the need to visit the sites currently occupied by the lift stations. This Purpose and Need statement
provides general project information and a list of the design aspects utilized to reduce and eliminate
wetland and stream impacts to the maximum extent practicable.

The project site is generally located to the south of King Road, traveling to the south across Camden
Road, and then south and then east to Blackbridge Road. The project area transects many contiguous

Fayetteville PWC 2 Big Rockfish Creek Outfall
F&R Project Number: 59Y-0128 May 2020
parcels and the total review area consisted of approximately 53.94 acres. The project parallels the
east side of Kings Pond on the northern portion, to the south along the east of Stewarts Creek, and
then along the northern side of Upchurches Pond and Rockfish C reek to the eastern terminus at
Blackbridge Road, in the Town of Hope Mills, Cumberland County, North Carolina. The project
transects various land use areas, including residential, undeveloped wooded or cleared land, and
existing utility right of ways.

Emily Greer of the US Army Corps of Engineers (USACE) has been consulted and has indicated that a
Preliminary Jurisdictional Determination (PJD) for the project may be issued along with the Pre-
construction Notification (PCN). The documents for the PJD are supplied with this application.
Features identified during field review are shown on the attached Project Plans, Impact Maps, and
supplemental maps.

AVOIDANCE AND MINIMIZATION

Project construction will result in direct impacts to soils within the boundaries of the project as soil is
temporarily side cast and permanently removed during construction. In wetland areas, upon
completion of installation, side cast soil material will be approximately returned to its original
location to maintain the preconstruction grade elevation. Once grade is reestablished in the
temporary impact areas, the restored areas will be seeded with appropriate native grasses as
referenced in the Temporary and Permanent Seeding Specs published by the North Carolina
Department of Environmental Quality. This reference is included with the PCN and will be included
with the bid package for the job. Soil erosion during construction will be minimized by following a
DEQ-approved Erosion and Sedimentation Control Plan, submitted to the DEQ at least 30 days prior
to construction. A number of steps were taken during the planning stages of this project in an effort
to substantially reduce and, in some cases, eliminate wetland and stream impacts; however, the
alignment design is largely based on utilizing gravity flow for the sewer pipes, for reasons discussed
above. Some of the specific measures and considerations taken to avoid and minimize impacts to
streams and wetlands include:

 Realignment of the sewer location where practical to avoid placing permanent
aboveground features such as vents and manholes in wetlands .
 Natural vegetated buffers being maintained where possible.
 Consideration of practices such as aerial crossings, bore and jack, etc.
 Lay-down and staging areas located outside of wetlan ds and greater than 100’ from
streams
 Limiting areas of disturbance within wetlands where feasible to reduce construction
footprint
 Utilizing super silt fence and other enhanced erosion and sediment control measures to
prevent silt and sediment from entering wetlands.

Fayetteville PWC 3 Big Rockfish Creek Outfall
F&R Project Number: 59Y-0128 May 2020
 Reducing permanent maintenance corridor to 10 ft centered on the pipeline in order to
reestablish as much natural vegetation in the disturbed project area once construction is
complete.

The planning measures listed above have been taken to effectively reduce the amount of wetland
and stream impacts to the greatest extent practicable. To address potential impacts to aquatic
species, the USFWS recommends all practicable measures be taken to avoid adverse impacts,
including sediment and erosion control measures, maintaining natural vegetated buffers on streams
adjacent to the project site. All practicable measures will be taken to avoid adverse impacts to
aquatic species. Examples of these measures include installing silt fence tree protection fencing,
super silt fence, rock check dams, silt sack inlet protection, concrete washouts and temporary gravel
construction entrances. Erosion and sedimentation controls will be installed and maintained
between the construction site and nearby down-gradient surface waters. An erosion and
sedimentation control plan will be submitted to the NC Land Quality Section for approval of a NPDES
Stormwater prior to construction and is pending review and approval.

The US Fish and Wildlife Service has also recommended directional drill methods for stream and
wetland crossings. However, directional drill is not appropriate for this project. The project entails a
long, flat gravity sewer outfall with little elevation difference between the upstream and
downstream portion of the project. Therefore, directional drill of any stream or wetland crossing is
not practical due to the challenges of maintaining grade with horizontal directional drill. Dips or sags
could easily form resulting in significant constructability issues or worse, operability issues if left
unresolved. Horizontal directional drill is compatible with pressure main applications rather than
gravity lines. As recommended, open cut stream crossing methods will be utilized when water levels
are low and stream flow is minimal. Negative impacts to protected aquatic species or aquatic
resources are not anticipated as a result of this project. It is our opinion that these efforts satisfy the
requirement to avoid wetland and stream impacts where possible and reduce impa cts where
necessary to the maximum extent practicable. A scoping letter was completed as part of the BRCO
project and a finding of Not Likely to Adversely Affect was received on February 16, 2018 from the
USFWS.

As recommended by USFWS, natural vegetated buffers on all streams and creeks adjacent to the
project site will be protected to the maximum extent practicable. Locations of the proposed outfall
alignment and permanent easements have been selected in an effort to maintain a buffer distance of
100 feet in most areas adjacent to perennial streams, where practicable. The closest proposed buffer
disturbance along Big Rock Fish Creek is approximately 50 feet from the top of bank; the minimum
proposed buffer disturbance along Stewarts Creek is approximately 75 feet from the top of bank.
Reasonable care will be taken during construction to avoid damage to vegetation not located in the
easements. Trees that are not selected for removal within the proposed alignment and trees located
outside of the project boundary will be protected from unnecessary cutting, breaking or skinning of
roots; skinning and bruising of bark; smothering of trees by stockpiling construction materials or
excavated material within the drip line; excessive foot and vehicular traffic including parking of

Fayetteville PWC 4 Big Rockfish Creek Outfall
F&R Project Number: 59Y-0128 May 2020
vehicles within drip line during construction. Trees and vegetation receiving unintended damage will
be repaired or replaced, when practicable.

SUMMARY

The Purpose of the BRCO project, as described above, is to implement PWC’s CIP to provide a means
of conveying collected sewerage from areas previously annexed, protect the environment by
providing a means of replacing septic systems in the annexation areas that will eventually fail, and
provide for Fayetteville future growth by installing a means of collecting sewerage from additional
areas beyond those required for the areas previously annexed. This PCN submittal addresses the
general and regional conditions of Nationwide Permit 12 and ensures aquatic resources are
protected.

The PWC respectfully requests review and approval of this NWP 12 verification so that bidding and
construction of the project can proceed without delay.

Sincerely,
FROEHLING & ROBERTSON, INC.

Alex D. Aycrigg, MS, PWS
Wetland Scientist