20200705 Ver 1_More Info Received_20200818

Strickland, Bev
From:
Tyson Kurtz <[e-mail]>
Sent:
Tuesday, August 18, 2020 8:25 AM
To:
Homewood, Sue
Cc:
Fuemmeler, Amanda J CIV (US)
Subject:
FW: [External] RE: ASU Child Care PCN AID 2020-00959 Request for additional
information
Follow Up Flag:
Follow up
Flag Status:
Flagged
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Sue and Amanda,
I wanted to follow up and say the proposed impacts to streams and wetlands have not changed. The stormwater
treatment will not result in additional impacts to aquatic resources.
-Tyson
From: Tyson Kurtz
Sent: Tuesday, August 18, 2020 7:41 AM
To: 'Homewood, Sue' <[e-mail]>; Fuemmeler, Amanda J CIV (US) <[e-mail]>
Cc: Clement Riddle <[e-mail]>
Subject: RE: [External] RE: ASU Child Care PCN AID 2020-00959 Request for additional information
Sue,
The engineer is working on a revised plan to incorporate stormwater treatment, likely near the lower parking area.
When we have the updated plan we will be sure to pass it on to you.
Thank you,
Tyson
From: Homewood, Sue <[e-mail]>
Sent: Monday, August 17, 2020 8:58 PM
To: Tyson Kurtz <[e-mail]>; Fuemmeler, Amanda J CIV (US) <[e-mail]>
Cc: Clement Riddle <[e-mail]>
Subject: RE: [External] RE: ASU Child Care PCN AID 2020-00959 Request for additional information
Tyson,
Have the project plans/drawings changed in any way? Has stormwater been resolved?
Thanks
1

Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
From: Tyson Kurtz <[e-mail]>
Sent: Monday, August 17, 2020 1:41 PM
To: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Clement Riddle <[e-mail]>
Subject: [External] RE: ASU Child Care PCN AID 2020-00959 Request for additional information
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Amanda,
Please see the responses to your request for additional information below. The project was on a temporary hold
while the university worked out zoning requirements with Boone.
1. Please provide information as to why a second access/road crossing is needed for the facilities expansion and will
this crossing/area provide parking as well. It is also unclear from the plans the need to fill the entire length of the
stream channel versus just have a more narrow road crossing with retaining walls. Please discuss if retaining
walls could be used which would minimize impacts to the stream channel.
A. The secondary access/road crossing is needed for the facilities expansion and will provide parking. The
expansion needs to be placed adjacent to the existing building (explained under question 2A), the proposed
location would be built on the existing upper parking area. This would create a loss of about 10 parking
spaces close to the front doors while simultaneously increasing the need for proximal parking spaces.
Available parking close to the front doors is required for families with infants. Expanding the existing lower
parking lot and incorporating parking spaces in the new drive loop/second access road is the most efficient
option. The existing upper parking area is already abutting the stream; therefore, new parking in front of the
buildings would have to be pushed northward, over top of the stream. The drive loop/secondary access
would allow for ease of daily children drop-off and pick-up. The drive loop/secondary access would also
allow for fire truck access to both buildings.
B. The engineer investigated an alternative that would reduce stream impacts to less than 149 linear feet and
the results did not provide a benefit to the overall project cost or stream quality. A spanning arch pipe
structure could avoid 90 feet of stream bed at a cost of approximately $83,700 without considering
additional costs to the existing stormwater system and logistics of construction. If a 90 feet long arch pipe
was used, the remaining 59 feet of stream in the impact area would still need to be placed into a culvert.
C. The use of retaining walls to minimize impacts to the stream channel is not considered a practicable option
with the grade of the stream valley and location of the stream bed adjacent to a potential vertical wall
foundation. Even with retaining walls, it is not possible to create a stable slope inside the drive loop or on

the upslope side of the road crossing that would avoid impacting the stream channel. Examples of retaining
walls of this nature have been shown to be very unstable, limit access for maintenance, and create a danger
to young children, for which the facility is designed.
2. Also please address why other portions of the parcel that are currently open/not developed could not be used for
the facility which have existing pipes/culverts and would not require much if any additional stream piping.
A. Building the Child Development Expansion adjacent to the existing building allows for students from both
buildings to share the playground and facilitates resource sharing for faculty and students. The grade
difference and distance between the existing building and the lower field area (alternate location in
question) would require children crossing traffic and parking areas, which is a safety hazard.
B. Construction of the building along the southwest side of the existing building requires less grading and
clearing when compared to other sides of the existing building that have enough space. The proposed
location is mostly clear of trees and is partially at grade.
C. The location of underground and overhead utilities in lower field make the alternative building location less
suitable and more expensive than the proposed location.
D. Limited space on the lower field (alternate location) would require the new building to be situated close to
Poplar Grove Road. Having a childcare facility that close to the road raises issues of noise and safety for
child.
Attached is the NC Stream Assessment Method (NCSAM) that was conducted for reach of S2 where impacts have been
proposed. The overall functional score for this reach is medium. Detractors of functional value include altered riparian
structure, width, and lack of woody vegetation; alterations to the banks that reduce streamside area interaction;
impervious surfaces within the streamside area that accelerate runoff, and degraded stream shading. A mitigation ratio
of 1.5:1 is requested based upon the medium functional rating generating by NCSAM.
Thank You,
Tyson Kurtz
G-ear\oLer
32 Clayton Street
Asheville, NC 28801
Office: 828-698-9800
Mobile: [phone]
tyson(cDcwenv.com
WWW.CWENV.COM
From: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Sent: Wednesday, June 24, 2020 5:11 PM
To: Tyson Kurtz <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Clement Riddle <[e-mail]>
Subject: ASU Child Care PCN AID 2020-00959 Request for additional information
Tyson,
Thanks for meeting out the other day. As discussed, I had several questions relating to avoidance and minimization
efforts on the design that was included in the PCN which I've outlined below. Also we discussed mitigation requirements
in relation to past impacts which just on this parcel alone appear to be at least 200-300 linear feet of perennial stream
channel that has been culverted at some point in the past. So with that said, any additional stream impacts at this point
would trigger mitigation and a mitigation plan should be submitted with the PCN that adequately offsets impacts.
Mitigation ratios typically start at 2:1 unless you conduct NCSAM and depending on the results, potentially a reduced

ratio can be applied. With regards to avoid/minimization, please provide additional information/ clarification on the
following to continue the review of this application:
1. Please provide information as to why a second access/road crossing is needed for the facilities expansion and
will this crossing/area provide parking as well. It is also unclear from the plans the need to fill the entire length
of the stream channel versus just have a more narrow road crossing with retaining walls. Please discuss if
retaining walls could be used which would minimize impacts to the stream channel.
2. Also please address why other portions of the parcel that are currently open/not developed could not be used
for the facility which have existing pipes/culverts and would not require much if any additional stream piping.
Once I receive this information, I will review and provide follow up questions/comments as needed. Feel free to give me
a call with any questions, thanks.
Amanda Jones
Regulatory Specialist
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980 ext. 4225