20180880 Ver 2_ Justification open cut_20200702

Strickland, Bev
From: Jennifer Robertson <)[e-mail]>
Sent: Thursday, July 2, 2020 12:06 PM
To: Johnson, Alan
Subject: [External] RE: stephens creek
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
r [e-mail]
The justification for open cutting the streams is included in the cover letter.
Here is the language from the cover letter.
This permit application is requesting temporary stream impacts at crossings 1, 2, 5, 6, and 8 to open cut the
stream bed as well as for pump arounds to work in the dry. The total linear footage requested at these five
stream crossings is 190 linear feet. The pre-existing stream bed elevation will be restored once
construction is complete. The excavated stream bed material will be side cast along the stream bank and used
to re-establish the pre-existing habitat.
DWR's Goose Creek Buffer rules previously did not allow temporary stream impacts for sewer line construction
therefore all eight stream crossings were presented as trenchless in the 2018 NWP 12 application. As of June
1, 2020, 15 NCAC 02B .0607 Site Specific Water Quality Management Plan For The Goose Creek Watershed
(Yadkin Pee -Dee River Basin): Buffer Types And Management Activities Within Riparian Buffers were
proposed to be revised including the Table of Uses to allow for temporary stream impacts for sewer line
construction. This NWP 12 application is being submitted due to this revision in DWR's buffer rules. All of the
stream crossings would have been proposed for temporary stream impacts in 2018 if these buffer rules had not
prohibited these impacts.
The primary drivers/benefits for shifting from directional boring to open trench stream crossings are that there
is a lower risk of tunnel collapse and associated impacts to the environment as well as worker safety. Boring
under the stream bed carries inherent risk of collapse where the soil between the tunnel and the stream bed
fails and the pressure from the bore tunnel then breaks through the stream bed. Open trenching stream
crossings eliminates this risk. Secondly, shorter construction duration is required for open trenching. Open
trench installation can be performed in a much shorter time frame. This has cost and schedule benefits but
also from an environmental standpoint, the temporary impact areas are disturbed for shorter timeframes and
can be restored sooner. Thirdly, open trenching can be achieved at a lower cost. In addition to the shorter
construction time frames, open trench installation requires less specialized equipment and operators as well as
reduced mobilization costs.
Thank you,
Jennifer L Robertson, President
ATLAS Environmental, Inc.
338 S. Sharon Amity Road, #411
Charlotte, NC 28211
[phone] office
[phone] mobile
www.atiasenvi.com fatlasenvi.coml
Offices in Asheville and Charlotte

RONMENTAL
From: Johnson, Alan <[e-mail]>
Sent: Thursday, July 2, 2020 11:55 AM
To: Jennifer Robertson <jrobe [e-mail]>
Subject: stephens creek
If they have open cut lines proposed through the creek. They should provide an explanation
why they can't jack and bore at least under the stream.
Haven't really review, just came to my mind and passed it alone
Dkkiion of WAter Rv%ourcc%
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.