RE: Kings Grant / SAW-2020-00547 / Incomplete Application Notification

Lyle,

The applicant and project engineer have worked diligently in addressing
your concerns and comments. We have provided responses below in red.
Additionally, please see attached updated Impact Exhibits, an updated
PCN application with pdf modifications and a Statement of Availability
letter from Resource Environmental Solutions to cover the additional
compensatory mitigation needed for this project.

Please let us know if any further information is needed to process this
application.

Thank you,

Debbie

Debbie Edwards Shirley

Project Manager-Regulatory Specialist

Soil & Environmental Consultants, PA

919-846-5900 (office)

919-673-8793 (mobile) *currently home based, please use mobile number

P THINK BEFORE YOU PRINT

From: Phillips, George L CIV USARMY CESAW (USA)
<[e-mail]>
Sent: Friday, August 28, 2020 4:17 PM
To: Deborah Shirley <[e-mail]>
Cc: Goss, Stephanie <[e-mail]>
Subject: Kings Grant / SAW-2020-00547 / Incomplete Application
Notification

Debbie,

I have reviewed the PCN for the above referenced project and need the
following questions/comments addressed prior to issuance of the permit
verification.

1. It appears that there are two branches of proposed sewer that
will result in impacts. The sewer line to the west of the proposed SCM
resulting in wetland impact 4 (we believe that you are referring to 3-B)
stubbing at the project boundary and the sewer line extending offsite to

the north resulting in Impact S1 and wetland impact 4. Which sewer line
will service the proposed project and what is the purpose of the other?
Each sewer line should have a purpose and need to justify impacts. The
sewer line extending offsite to the north which includes wetland Impact
#4 and stream impact S1 (#5) will connect to an existing manhole and
will service the proposed development. Impact 3-B is the sewer line
connecting to the west and is a requirement of the Town of Apex. The
project engineer has modified this sanitary sewer crossing to now be
constructed via Jack & Bore construction method therefore avoiding
direct impacts to wetland W3. Please see updated impact exhibits and
updated PCN application.
2. The proposed SCM appears to bifurcate Wetland 3 resulting in a
loss of connection between the up gradient section of Wetland 3 from the
downgradient system. Based on the proposed design it appears the
proposed activities will result in a loss of function for the wetland
area upgradient of the SCM and therefore would require mitigation under
the current design. The project engineer looked at possibly shifting
the SCM to the north however that was not feasible because the sanitary
sewer line needed to remain in place. They also looked at providing a
hydrologic connection on the east side of the wetland to connect the
bifurcated wetland, however because of the elevation of SCM inlet pipe
network this was not feasible. That said, we have identified and
quantified the wetlands to the southeast and have proposed 2:1
mitigation for the indirect impacts. Please see the Statement of
Availability letter from Resource Environmental Solutions to cover the
additional wetland mitigation needed. Also, please reference the
Section E2 within the attached updated PCN application that outlines the
current proposed compensatory mitigation.
3. What is the proposed activity (FES installation) that results in
Temporary Impact #1? Will Wetland 1 continue to function after
construction of the roadway? Wetland 1 will still continue to function
as a wetland post construction. FES is for “Flared End Section”, this
area is identified and quantified for the construction access to install
the FES. Additionally, the proposed 15” RCP pipe that is buried will
provide a hydrologic connection to the northern area of wetland W1.
4. Provide an explanation for the need for the turnaround that
results in additional impacts to Wetland Impact 1? Could the proposed
turnaround be constructed south of its proposed location resulting in
less wetland impacts? The Town of Apex requires a turnaround if there
are any lots in the vicinity of the end of a stub road. A turnaround is
also required for emergency vehicles such as ambulance or fire trucks,
municipality garbage collection services etc. Per the Town of Apex
requirements, the turnaround cannot be shifted to avoid/minimize wetland
impacts because of the proximity of the lots.
5. Can you provide an authorization form from the applicant? You
and I discussed this on September 2, 2020 and you agreed that an Agent
Authorization from the Applicant was not necessary.

Please let me know if you have any questions.

Lyle Phillips

Regulatory Specialist

US Army Corps of Engineers

CE-SAW-RG-R

3331 Heritage Trade Drive, Suite 105

Wake Forest, North Carolina 27587

Phone: [phone], Ext. 25.

Fax: [phone]

Email: [e-mail]
<mailto:[e-mail]>

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