SW4070701_Add Info_20200210

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Joseph Meliski, PE
55 Broad Street
Asheville, NC 28801
NORTH CAROLINA
Environmental Quality
February 10, 2020
Subject: Request for Additional Information
Stormwater Permit No. SW4070701
Echota IV The Summit at Echota
Watauga County
Dear Mr. Meliski:
The Division of Energy, Mineral and Land Resources (DEMLR), received a Stormwater
Management Permit Application for the subject project on January 7, 2020. A review of that
information has determined that the application is not complete. The following information is
needed to continue the stormwater review:
NOTE: Since having issued my first round of comments in December, I was made aware
that, for Modifications, the Applicant only needs to fill out the Modification Application
for the areas that will be modified/added to the permit, not the previously permitted areas.
I apologize for the confusion on this (The Applicant does have the option to bring
everything that was previously permitted "up-to-date" and have it all on one permit,
similar to what I requested, but this is not required). For this Application, please include
only the area associated with Echota IV by making the following changes:
a. Section IV, 4 — The Total Property Area should match the information shown on
the plans (54.15 ac).
b. Section IV, 7 — The Total Project Area should be calculated as described in the
Application, (54.15 ac — 0 ac. — 0.04 ac. = 54.11 ac).
c. Section IV, 8 — The Project Percent Impervious should be recalculated taking the
above comment into consideration (322,909 sf / 2,356,554 sf = 13.7%).
d. Section IV, 10, Existing BUA — Only include existing BUA located within the
area of Echota IV (0 sf).
e. Section IV, 10, Proposed Impervious Area — Recalculate this value taking the
prior comment into consideration (322,909 sf).
f. Section IV, 10, Total & On -Site Drainage Areas — If the project will meet the
requirements for low -density, the "drainage area" is the entire site (2,356,554 sf).
D EQ North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAROLINA _
o.PaWnamofEnvironmental Quality /� 919.707.9200

g. The Supplement-EZ Form does not need to be re -signed since the Project Area
matches Echota IV, however, please make the following changes on the other
pages of the form:
i. Drainage Area Page, Line 14 — Please remove this item.
h. The O&M Agreement does not need to be re -signed.
2. Original Comment 1 "Please provide a Designer's Certification for the completed
sections, Echota I, II, & III (Section I, 1 b). " I have attached a Designer's Certification
that should be completed and returned. Generally, the Designer Certification is completed
immediately after the construction of the permitted project (Echota III) is complete. A
copy of the Designer's Certification is sent out with the .... Since the Regional Office did
not have it and you did not have it, I have provided a new copy of the certification. Please
do not send this form to the Winston-Salem Regional Office (as it states on the bottom),
but rather to me. I will ensure that it is added to the existing permit file since it is
currently in my possession.
3. Original Comment 2 "As designed, Echota IV does not meet the requirements of a low -
density project (Section I, 2). " There are still aspects of this project that do not meet the
requirements of a low -density project. The way the requirements for low -density
development are worded, for a project to qualify as low -density, it must be designed with
the intent to maximize the amount of disbursed flow and minimize channelization;
whatever cannot practically be disbursed can be transported via vegetated conveyance
with a minimal amount of piping (for roadway/sidewalk crossings, etc...) when
unavoidable. This is distinctly different than designing a project and then trying to
maximize disbursed flow and/or vegetated conveyance. For example, one of the more
egregious instances of this project not meeting the definition of low -density is in the
western -most section of the project where runoff from the parking areas in front of
buildings 2-4 is channelized in the center of the roadway, captured in a catch basin,
conveyed via pipe, and discharged. This could have been designed so that runoff sheet
flows off of the roadway and into a vegetated area/swale. In addition, since this project is
over 12% BUA, it does not qualify as low -density (Since this project is subject to
ORW/HQW rules). Please revise the submission so that the project meets the
requirements for low -density or high -density. If all of the "high -density" aspects of the
project cannot be removed, it is possible to permit the project as a low -density project
with pockets of high -density. Please reach out to me if you would like to pursue this
option.
4. Original Comment 11 "Please provide a copy of the current property deed for the entire
property (Section VI, 10). " The response to comments letter mentioned an attached item
that would show that the LLC's are under the parent company. This item was not
provided in the last submittal. Please provide this item.
5. Original Comment 13 "Buildings 1, 2, 3, & 4 are partially located outside of the property
boundary. " The response to comments letter mentioned an attached item that would
show that the area of land that buildings 1-4 are located on is owned by the same entity.
This item was not provided in the last submittal. Please provide this item. It is noted that
the proposed development area on the map has been adjusted to reflect this.

6. Please provide updated calculations for the swale design since it has changed since the
prior submission. If the side slopes of the swales are steeper than 3:1, please provide
shear stress calculations showing that the swales will remain stable. Please also provide
times of concentration for each drainage area so that the intensities used in the
calculations can be verified.
7. Provide pdfs of all revisions, 2 hardcopies of revised plan sheets, and 1 hardcopy of other
documents. Pdfs must be uploaded using the form at:
hgps://edocs.deq.nc.gov/Forms/SW Project Submittal
Please note that this request for additional information is in response to a preliminary review.
The requested information should be received by this Office prior to March 11, 2020, or
the application will be returned as incomplete. The return of a project will necessitate
resubmittal of all required items, including the application fee. Please reference the State
assigned project number SW4070701 on all correspondence.
If you need additional time to submit the information, please submit your request for a time
extension to the Division at the contact below. The request must indicate the date by which you
expect to submit the required information. The Division is allowed 90 days from the receipt of
a completed application to issue the permit.
The construction of any impervious surfaces, other than a construction entrance under an
approved Sedimentation Erosion Control Plan, is a violation of NCGS 143-215.1 and is subject
to enforcement action pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter please feel free to contact me at
[e-mail] or [phone].
Sincerely,
v- "f
Jim Farkas
Environmental Engineer
Stormwater Program
cc: Winston-Salem Regional Office