20201177 Ver 1_RESPONSE TO COE SAW-2020-01307_20201008

Strickland, Bev
From: lagnocco, Michael <[e-mail]>
Sent: Thursday, October 8, 2020 3:51 PM
To: Roden Reynolds, Bryan K CIV (US)
Cc: Johnson, Alan; Kotheimer, Joshua L.; 4020717
Subject: [External] RE: SAW-2020-01307_Unity Classical Academy - Response to Notice of
Incomplete Pre -Construction Notification
Attachments: SAW-2020-01307 Response to Notice of Incomplete PCN.pdf, SAW-2020-01307
Stream Relocation Plan.pdf, SAW-2020-01307 Stream Relocation Plan Exhibits_20_
1008.pdf, Unity Classical Charter School DMS CAT03ESA Acceptance.pdf; USFWS_
20-398_(survey results) Unity Classical Academy -Mecklenburg Co.pdf
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hey Bryan - hope you're doing well; attached is a consolidated response to your comments received SEP 16, 2020; 1
trust that based on our subsequent conversation that we've adequately addressed your comments; please see the
attached file entitled SAW-2020-01307 Response to Notice of Incomplete PCN; In summary, the compensatory mitigation
plan now consists of a payment to NCDMS as well as the on -site stream relocation plan; we've provided a commitment
letter from NCDMS as well as a stand-alone stream relocation plan that includes a planting plan, monitoring plan, and
success criteria; we're also providing confirmation of concurrence on T&E issues from FWS; please let me know if you
have any comments on what we're providing; we appreciate your ongoing attention to this project.
DWR #20201177
Hey Alan - hope you are also doing well; I also trust that the revised grading plan associated with the stream relocation
plan has addressed your previous concerns regarding the originally proposed change in elevation at the confluence with
the existing stream - the grading plan/relocated stream profile was revised to include a nearly at -grade confluence with
the existing channel; in addition, the stream relocation plan includes the following statement- "An underdrain will be
installed along the portion of the stream being impacted to help minimize the risk associated with ground water
degrading the sub surface under the proposed site improvements" - this has been added to address your previous
comment regarding the 170 If section of stream to be filled.
Michael A. lagnocco, PWS
KsT:Vra
100
k
STV Engineers, Inc.
michael.iagnoccoa-stvinc.com
Office: [phone] Mobile: [phone]
Direct: [phone]
Please consider the environment before printing this e-mail

From: Roden Reynolds, Bryan K CIV (US) <Bryan.K.Roden [e-mail]>
Sent: Wednesday, September 16, 2020 4:10 PM
To: Iagnocco, Michael <[e-mail]>
Cc: Johnson, Alan <[e-mail]>; [e-mail]
Subject: SAW-2020-01307_Unity Classical Academy (Notice of Incomplete Pre -Construction Notification)
Importance: High
Mr. Iagnocco,
On September 10, 2020, we received the Pre -Construction Notification you submitted on behalf of Performance Charter
School Development, LLC on a property located in Mecklenburg County, North Carolina. I have completed my initial
review of the report and I have determined that it is incomplete. The following information is necessary before I will
issue a determination:
a. The project proposes permanent stream impacts (i.e. 170 linear feet) which result in the loss of waters
occurring within the HUC 103. Any loss of waters, in this HUC specifically, have been and will likely continue
to require compensatory mitigation. This watershed is highly urban and has a long history of intensive land
uses which has resulted in long-term degradation to aquatic resources. In addition, there are currently no
private mitigation banks or in -lieu fee sites with credits available to offset losses of aquatic function from
private development in this watershed. Therefore, stream credits are purchased through the Expanded
Service Area which generally result in the doubling of the determined compensatory mitigation. For
example, impacting 170 linear feet of a medium quality stream would result in a compensatory mitigation
ratio of 1.75:1; but would be doubled to 3.25:1 for HUC 103. The PCN proposed onsite stream restoration
which has potential to reduce or eliminate the double requirement for this HUC but onsite stream
restoration will not negate compensatory mitigation entirely. Therefore, please provide a Compensatory
Mitigation Plan for the 170 linear feet of stream impacts.
b. The PCN lacked confirmation from NCDMS for the purchase of compensatory mitigation credits to offset the
permanent loss of waters from the project. Therefore, please include a Compensatory Mitigation
Reservation Letter from NCDMS for the permanent stream impacts in the revised PCN.
c. The PCN contained a letter from USFWS (dated August 19, 2020) which stated "Service records show historic
occurrences for the federally endangered Schweinitz's sunflower in the project vicinity and suitable habitat
may be present within the action area for this species. Suitable habitat may also occur onsite for the
federally endangered Michaux's sumac and smooth coneflower. To ensure that these species are not
inadvertently lost and to inform a prudent effect determination form the appropriate action agency,
targeted botanical surveys should be conducted during the optimal window where project -mediated
impacts may alter its suitable habitats within the action area." Based on this letter, the Corps will initial
consultation with USFWS for the previously mentioned species and will not be able to make an effects
determination until the USFWS has the recommended information for them to make their determination.
Therefore, please conduct the USFWS recommended targeted botanical surveys where project -mediated
impacts may alter suitable habitat for Schweinitz's sunflower, Michaux's sumac, and smooth coneflower
during the optimal survey window and provide this survey and results to the USFWS.
d. The PCN lacked a Stream Restoration Plan which includes sufficient detail to analyze the proposed onsite
stream enhancement activities. A Stream Restoration Plan would include but not limited to: 1) a narrative
write-up on the approach for the site; 2). Post -construction monitoring activities; 3). Success criteria; 4).
Planting lists and timing; 5). Etc. As stated in Nationwide Permit 27, "The NWP authorizes the relocation of
non -tidal waters, including non -tidal wetlands and streams, on the project site provided there are net
increases in aquatic resources functions and services"; however, the Corps is concerned that the proposed
stream restorations activities would not provide aquatic uplift from the current conditions onsite (i.e.,

Stream A is rated as medium by NCSAM). In Bulletin Drawing Sheet 1, Stream A goes from a meandering,
sinuous channel to a straightened channel (170 linear feet) and the slight bend in the "new portion of
stream (245 linear feet)" with boulder cross vanes. In order to demonstrate aquatic uplift from the stream
restoration activities, NCSAM would need to be conducted on the new stream (415 linear feet) to determine
its quality (i.e., this evaluation of stream quality would likely need to be conducted multiple times for
multiple years during post construction monitoring activities). Since the existing Stream A rated at medium
quality, the new stream would need to rate at medium to high quality to demonstrate aquatic uplift. Based
on the current proposal, the Corps is not confident the stream would rate at medium or high because nearly
half of the new stream in a straight line ditch, there would be no to a very limited wooded buffer, loss of
sinuosity, etc.
PLEASE NOTE:
The Corps is unable to make an effects determination, meet the requirements of the Endangered Species Act,
and move forward with the NWP authorization until the issue (i.e., target surveys during the optimal survey
window) with the USFWS is resolved. Please ensure the Corps is CC'd on any email transactions between the
applicant/agent and the USFWS.
The current rate schedules for a linear foot of stream channel is $558.81. This project could have a
compensatory mitigation bill ranging from $166,245.98 (170 linear feet at 1.75:1) to $308,742.53 (170 linear feet
at 3.25:1). This information can be found at the following link (https://deg.nc.gov/about/divisions/mitigation-
services/dms-customers/fee-schedules)
Please provide the information requested above in ONE consolidated response within 30-days of the date of this
correspondence. If you do not respond within 30-days, the request will be administratively canceled. Please
contact me via telephone or e-mail if you have any questions. You may also consider withdrawing your current
PCN which would allow you additional time to satisfy all the above additional information requests. A revised
PCN can be resubmitted at a later date which addresses all these issues.
Thanks,
Bryan Roden -Reynolds, PWS
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Charlotte Regulatory Field Office
8430 University Executive Park Drive
Charlotte, NC 28262
Office: [phone]
Redesigned and rebuilt: visit our new website at www.stvinc.com
The information contained in this electronic message is intended only for the use of the individual or entity to
which it is addressed and may contain information that is privileged, confidential and exempt from disclosure
under applicable law. If the reader of this message is not the intended recipient, you are informed that any
dissemination, copying or disclosure of the material contained herein, in whole or in part, is strictly prohibited.
If you have received this transmission in error, please notify STV and purge this message.

SAW-2020-01307
Unity Classical Academy
Response to Notice of Incomplete PCN
The following information and attachments are provided in response to the comments
STV received in an email dated September 16, 2020 to the Pre -Construction Notification
we submitted on behalf of Performance Charter School Development, LLC on a property
located in Mecklenburg County, North Carolina. The Corps comments are labeled a.
through d. below:
The project proposes permanent stream impacts (i.e. 170 linear feet) which result in
the loss of waters occurring within the HUC 103. Any loss of waters, in this HUC
specifically, have been and will likely continue to require compensatory mitigation.
This watershed is highly urban and has a long history of intensive land uses which
has resulted in long-term degradation to aquatic resources. In addition, there are
currently no private mitigation banks or in -lieu fee sites with credits available to
offset losses of aquatic function from private development in this watershed.
Therefore, stream credits are purchased through the Expanded Service Area which
generally result in the doubling of the determined compensatory mitigation. For
example, impacting 170 linear feet of a medium quality stream would result in a
compensatory mitigation ratio of 1.75:1; but would be doubled to 3.25:1 for HUC
103. The PCN proposed onsite stream restoration which has potential to reduce or
eliminate the double requirement for this HUC but onsite stream restoration will
not negate compensatory mitigation entirely. Therefore, please provide a
Compensatory Mitigation Plan for the 170 linear feet of stream impacts.
Response:
The compensatory mitigation plan for permanent impacts to 170 if of intermittent
stream on -site has been revised to consist of an on -site stream relocation plan
detailed below as well as a payment made to the NCDMS.
The PCN lacked confirmation from NCDMS for the purchase of compensatory
mitigation credits to offset the permanent loss of waters from the project.
Therefore, please include a Compensatory Mitigation Reservation Letter from
NCDMS for the permanent stream impacts in the revised PCN.
Response:
The Compensatory Mitigation Reservation Letter from NCDMS is attached; the
applicant is offering a payment of 1.75:1 based on Stream A rating medium
quality according to NCSAM and taking into consideration the stream relocation
plan.
c. The PCN contained a letter from USFWS (dated August 19, 2020) which stated
"Service records show historic occurrences for the federally endangered
Schweinitz's sunflower in the project vicinity and suitable habitat may be present
within the action area for this species.
900 WEST TRADE STREET, SUITE 715
PROVIDING QUALITY SERVICE SINCE 1912 1 CHARLOTTE, NORTH CAROLINA 28202-1144
[phone] FAX:[phone]

Suitable habitat may also occur onsite for the federally endangered Michaux's
sumac and smooth coneflower. To ensure that these species are not inadvertently
lost and to inform a prudent effect determination form the appropriate action
agency, targeted botanical surveys should be conducted during the optimal window
where project -mediated impacts may alter its suitable habitats within the action
area." Based on this letter, the Corps will initial consultation with USFWS for the
previously mentioned species and will not be able to make an effects determination
until the USFWS has the recommended information for them to make their
determination. Therefore, please conduct the USFWS recommended targeted
botanical surveys where project -mediated impacts may alter suitable habitat for
Schweinitz's sunflower, Michaux's sumac, and smooth coneflower during the
optimal survey window and provide this survey and results to the USFWS.
Response:
The targeted botanical surveys were completed on August 26, 2020, within the
optimal survey window for Schweinitz's sunflower, Michaux's sumac, and
smooth coneflower. Plant by plant surveys were completed on the subject
property within areas of appropriate habitat. The findings of the surveys,
including biological conclusions, were included as an attachment in the
Supplemental Information section of the ePCN submittal. Subsequent to this
comment, STV forwarded the findings of our botanical surveys as well as the
copy of the PCN to Byron Hempstead with the USFWS on September 24, 2020.
The Service's response dated September 30, 2020 provides concurrence with the
MANLAA determination from the Corps; see attached.
d. The PCN lacked a Stream Restoration Plan which includes sufficient detail to analyze
the proposed onsite stream enhancement activities. A Stream Restoration Plan
would include but not limited to: 1) a narrative write-up on the approach for the
site; 2). Post -construction monitoring activities; 3). Success criteria; 4). Planting lists
and timing; 5). Etc. As stated in Nationwide Permit 27, "The NWP authorizes the
relocation of non -tidal waters, including non -tidal wetlands and streams, on the
project site provided there are net increases in aquatic resources functions and
services"; however, the Corps is concerned that the proposed stream restorations
activities would not provide aquatic uplift from the current conditions onsite (i.e.,
Stream A is rated as medium by NCSAM). In Bulletin Drawing Sheet 1, Stream A goes
from a meandering, sinuous channel to a straightened channel (170 linear feet) and
the slight bend in the "new portion of stream (245 linear feet)" with boulder cross
vanes. In order to demonstrate aquatic uplift from the stream restoration activities,
NCSAM would need to be conducted on the new stream (415 linear feet) to
determine its quality (i.e., this evaluation of stream quality would likely need to be
conducted multiple times for multiple years during post construction monitoring
activities). Since the existing Stream A rated at medium quality, the new stream
would need to rate at medium to high quality to demonstrate aquatic uplift. Based
on the current proposal, the Corps is not confident the stream would rate at
medium or high because nearly half of the new stream in a straight line ditch, there
would be no to a very limited wooded buffer, loss of sinuosity, etc.

Response:
The stream relocation plan is attached which includes the grading plan, planting
plan, post -construction monitoring plan and success criteria. The stream
relocation plan is further supplemented by the mitigation payment to the NCDMS
to complete the compensatory mitigation for the 1701f of permanent stream
impact on the site.

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FT. (NAVD)
RIGHT VANE ARM INTERCEPT CONTROL POINT ELEVATION
X4
FT. (NAVD)
POOL CONTROL POINT ELEVATION
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6
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8
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X13
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NOTES:
1. A BOULDER CROSS VANE IS A GRADE CONTROL IN -STREAM STRUCTURE THAT DIRECTS STREAM FLOW AWAY FROM THE STREAM BANKS AND IN TOWARD THE CENTER OF THE CHANNEL.
2. ELEVATION CONTROL POINTS SHALL BE DESIGNATED AT THE UPSTREAM INVERT (CENTER) OF THE CROSS VANE TO ESTABLISH PART OF THE PROFILE. POOL ELEVATION CONTROL POINTS OR EXCAVATION TO A SPECIFIED MAXIMUM
POOL DEPTH SHALL BE DESIGNATED TO ESTABLISH THE REMAINING PROFILE. SURVEY OF CONTROL POINTS SHALL BE REQUIRED TO ESTABLISH ACCURATE CROSS VANE INSTALLATION WITHIN THE TOLERANCE SPECIFIED BY THE
DESIGNER.
3. THE VANE ARM SHALL INTERCEPT THE STREAM BANK AT A HEIGHT EQUAL TO BETWEEN % BANKFULL STAGE AND BANKFULL STAGE. ELEVATION CONTROL POINTS MAY BE ESTABLISHED AT THE LEFT AND RIGHT STREAM BANK/VANE
ARM INTERCEPT POINTS. THE VANE ARM INTERCEPT LOCATION MAY BE OTHERWISE DESCRIBED BY ITS RELATIONSHIP TO BANKFULL STAGE OR BY THE LENGTH AND SLOPE OF THE VANE ARM. BANKFULL IS NOT NECESSARILY THE TOP
OF THE STREAM BANK SLOPE.
4. IF PLANS DESIGNATE THE USE OF MULTIPLE BOULDER CROSS VANES, A TABLE OF ALL STATION LOCATIONS AND CONTROL POINT ELEVATIONS SHALL BE PROVIDED IN THIS DETAIL OR PROVIDED ELSEWHERE IN THE PLANS AND
REFERENCED HEREIN.
5. TYPICAL RIFFLE AND POOL CROSS SECTIONS SHALL BE PROVIDED ELSEWHERE IN THE PLANS TO ESTABLISH THE DIMENSIONS OF THE CHANNEL GRADING INTO WHICH THE BOULDER CROSS VANES ARE TO BE INSTALLED.
6. THE CROSS VANE SHALL BE CONSTRUCTED WITH FLAT -SIDED BOULDERS OF A SIZE (LENGTH, WIDTH, AND DEPTH) AS SPECIFIED BY THE DESIGNER.
7. FILTER FABRIC OF A TYPE AND SIZE SPECIFIED BY THE DESIGNER SHALL BE USED TO SEAL THE GAPS BETWEEN THE BOULDERS AND UNDER THE COARSE BACKFILL MATERIAL. THERE SHALL BE NO FILTER FABRIC VISIBLE IN THE
FINISHED WORK; EDGES SHALL BE FOLDED, TUCKED, OR TRIMMED AS NEEDED.
8. COARSE BACKFILL OF THE BOULDER CROSS VANE SHALL BE OF A TYPE, SIZE, AND GRADATION AS SPECIFIED BY THE DESIGNER. COARSE BACKFILL SHALL BE PLACED TO A THICKNESS EQUAL TO THE DEPTH OF THE HEADER AND
FOOTER BOULDERS AND SHALL EXTEND OUT FROM THE VANE ARMS TO THE STREAM BANK AND UPSTREAM A DISTANCE SPECIFIED BY THE DESIGNER.
9. THE INVERT (CENTER) OF THE BOULDER CROSS VANE SHALL BE CONSTRUCTED FIRST, FOLLOWED BY ONE VANE ARM AND THEN THE OTHER VANE ARM. THE FLOODPLAIN SILLS SHALL BE CONSTRUCTED LAST.
10. BOULDER CROSS VANE SHALL BE BUILT TYPICALLY AS FOLLOWS:
A. OVER -EXCAVATE STREAM BED TO A DEPTH EQUAL TO THE TOTAL THICKNESS OF THE HEADER AND FOOTER BOULDERS.
B. PLACE FOOTER BOULDERS. THERE SHALL BE NO GAPS BETWEEN BOULDERS.
C. INSTALL FILTER FABRIC.
D. PLACE COURSE BACKFILL BEHIND THE FOOTER BOULDERS.
E. INSTALL HEADER BOULDERS ON TOP OF AND SET SLIGHTLY BACK FROM THE FOOTER BOULDERS (SUCH THAT PART OF THE HEADER BOULDER IS RESTING ON THE COARSE BACKFILL). HEADER BOULDERS SHALL SPAN
THE SEAMS OF THE FOOTER BOULDERS. THERE SHALL BE NO GAPS BETWEEN BOULDERS. THE SLOPE OF THE VANE ARM IS MEASURED ALONG THE VANE ARM WHICH IS INSTALLED AT AN ANGLE TO THE STREAM BANK AND
PROFILE.
F. PLACE COARSE BACKFILL BEHIND HEADER BOULDERS ENSURING THAT ANY VOIDS BETWEEN THE BOULDERS ARE FILLED.
11. IF ANY EROSION CONTROL MATTING IS SPECIFIED FOR USE IN THE VICINITY OF THE VANE ARM INTERCEPT POINTS AND FLOODPLAIN SILLS ALL MATTING EDGES SHALL BE NEATLY SECURED AROUND THE BOULDERS.

PLANT INFORMATION
TAG
BOTANIC NAME
COMMON NAME
SIZE
BENI
BETULA NIGRA
RIVER BIRCH
2" MIN. EACH CANE
CCRS
CERCIS CANADENSIS 'RISING SUN'
RISING SUN REDBUD
2"
FAGR
FAGUS GRANDIFLORA
AMERICAN BEECH
2"
ILAF
FOSTER HOLLY
ILEX x ATTENUATA'FOSTERI'
8'
JUVI
JUNIPERUS VIRGINIANA
EASTERN RED CEDAR
8'
LIST
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STV moo
SAW-2020-01307; DWR #20201177
Unity Classical Academy
Response to Notice of Incomplete PCN
October 8, 2020
Stream Relocation Plan
Overview
The project will result in the initial loss of 170 linear feet of intermittent Stream A. The
project proposes to mitigate for this impact to 170 linear feet of intermittent Stream A
through a combination of an on -site stream relocation plan supplemented by a mitigation
payment to the NCDMS.
The existing stream is experiencing active channel downcutting and bank failures
throughout its length which also limits the streamside area interaction. The 170 linear
feet of intermittent channel will be relocated along the eastern border of the study area
within the City's required vegetated Zoning Buffer.
The project proposes relocating the 170 linear feet of Stream A and creating an additional
245 linear feet of headwater stream channel for a total of 415 linear feet of functionally
relocated channel; see exhibits prepared by LITTLE entitled Unity Classical Charter
School Stream Relocation, Bulletin Drawings 1 through 10. As indicated in the
drawings, the stream relocation grading plan has been designed to extend above the
current upper elevation of the existing stream allowing any existing groundwater to enter
the new channel. The grading and drainage have been carefully considered to help
maintain as much of the original drainage area as possible that contributed flow to the
intermittent stream. A sand filter will be utilized to treat the impervious run-off that will
be directed toward the upper reaches of the relocated intermittent stream — the sand filter
will be situated immediately north of the Arrival Drive as shown on Bulletin Drawing 1
of 10, entitled Stream Relocation Grading and Location. The drawdown time will help
extend the time stormwater will flow into the relocated portion of the stream as well as
the remainder of the existing stream. Stormwater will also be directed to the relocated
channel from the open field that has been incorporated into the campus immediately
north of the Arrival Drive; see Bulletin Drawing 1 of 10.
Retaining walls have been utilized to help minimize the stream impact and help with the
relocation of the stream; see Bulletin Drawing 9 of 10, Section A, which depicts a cross
section through the two proposed retaining walls. The area available to reconstruct the
stream falls within a Zoning Buffer and is limited in width, which creates some
limitations in terms of being able to construct more significant meanders. The stream
relocation is designed to mimic the sinuosity of the existing stream to the extent
practicable given these spatial constraints.
900 WEST TRADE STREET, SUITE 715
PROVIDING QUALITY SERVICE SINCE 1912 I CHARLOTTE, NORTH CAROLINA 28202-1144
[phone] FAX: [phone]

The relocated stream will be graded to incorporate shallow sloped banks to allow for
higher intensity storms to be less channelized and allow greater streamside interaction
which is an improvement over the incised condition of the existing stream. An
underdrain will be installed along the portion of the stream being impacted to help
minimize the risk associated with ground water degrading the sub surface under the
proposed site improvements. Grade breaks comprised of six boulder cross -vanes have
been incorporated into the design of the relocated portion of the intermittent stream. One
of the boulder cross -vanes will be incorporated immediately upstream of the relocated
channel's confluence with the existing channel. The confluence point has been
specifically targeted to occur at a non jurisdictional swale that currently intersects the
existing channel. The locations of these in -stream structures are shown on Bulletin
Drawing 1 of 10 (plan view) as well as in the profile views presented in Bulletin
Drawings 2 thru 5. There is a 1/2-foot drop at each boulder cross -vane structure and then
an approximate 2.5-foot drop in the stream run until the next structure. The relocated
stream has been graded to facilitate a minimal change in elevation at the confluence with
the existing channel.
The six in -stream structures will provide grade control, maintain the thalweg in the center
of the channel, and provide a pool which will help to reduce flow velocities, reduce
stream bank scour and provide additional aquatic habitat; see Bulletin Drawing 6 of 10,
Boulder Cross -Vane Detail. Over time, sediment transport and deposition by the stream
flow will cover the crushed rock with material such as leaf litter and sediments. This
should help the relocated stream channel to mimic the conditions of the existing stream
channel and provide a benthic substrate suitable for macro invertebrates.
Coir fiber matting will be utilized for initial bank stabilization, in order to reduce erosion
and establish seeding faster; see Bulletin Drawing 1. In addition, a native riparian seed
mix will be utilized from the normal water level to one foot beyond the top of bank on
either side of the stream; the riparian see mix developed by the City of Charlotte will be
utilized. Riparian seed mix is typically applied in the fall or spring which should coincide
with the anticipated construction schedule. The relocated stream corridor will be
replanted with woody tree and shrub species following construction; see Bulletin
Drawings 7 and 8 of 10 (Planting Plan).
The combined elements of the grading plan and profile, along with the interception of
existing groundwater and post -construction drainage and planting plan will promote
stream stability, mitigate channel incising, improve streamside area interaction and offer
equal or improved stream function.
Construction will commence with an initial stage of clearing and mass grading and will
not initially include disturbance of the existing intermittent stream. The mass grading
will include the construction of the main BMP located south of existing/preserved
Wetland A, as well as smaller sediment traps and basins to contain erosion associated
with the grading. The second stage will include the grading of the relocated portion of
the stream and will allow for an early planting of this portion of the site to allow a greater

time frame for the plantings to start to become established prior to most of the site
development.
Planting Plan
An overview of the proposed planting plan for the relocated and preserved stream
corridor is presented on Bulletin Drawings 7 and 8, entitled Planting Plan Area A and
Planting Plan Area B, respectively).
Riparian Seed Mix:
• A native riparian seed mix will be utilized from the normal water level to one foot beyond
the top of bank on either side of the stream
• The riparian seed mix developed by the City of Charlotte will be utilized
• The riparian seed mix will be applied in the fall or spring which should coincide with the
anticipated construction schedule
• Seeds should be broadcast by hand or knapsack seeder using the proper seeding rate, and
carefully proportioned to cover the entire area; the seed will be covered with a light layer
of straw mulch following seeding
• Annual rye grass will be utilized to stabilize the area surrounding the tree and shrub
plantings.
Woody Plant Materials:
• After the planting substrate has been prepared, the relocated stream corridor will be
planted with woody species; tree selection will utilize species currently occurring in the
existing stream corridor/watershed and listed on the City's pre -approved planting list
• Planting densities for canopy trees will meet City criteria for buffer zone planting; trees
will be native and non-invasive and/or subject to disease; 12 trees will be planted per 100
If of stream corridor
• Anticipated canopy trees will include sweetgum, American beech, river birch, redbud, and
Eastern red cedar; tree planting sizes are as indicated on the Planting Plan
• Tree plantings will be supplemented with streamside shrub species, including silky
dogwood, ninebark, and witch hazel
• Trees and shrubs would preferably be planted in early to late spring (between April 1 and
June 15), or in the fall (September 15 to October 30).
Post -Construction Monitoring Plan
Monitoring and maintenance efforts for the stream relocation plan will take place over a
three year period commencing following completion of construction, activation of
hydrologic inputs, and planting/seeding.
• Site visits will occur twice a year (minimum)
• Two monitoring stations will be established
• NCSAM forms will be completed during each site visit

• Vegetative plots will be established and monitored; plant species, along with their
estimated relative frequency and percent cover will be documented
• Photo -documentation will be completed; at least one visit each year will occur during the
growing season
• A memorandum of findings will be prepared after each site visit
• An annual report will be prepared to include findings and observations made during the
annual site visits and specifying any needed remedial action
• The annual monitoring report will be provided to the U.S. Army Corps of Engineers and
NCDWR every year for each of the three years.
Determination of Success Criteria
The following success criteria have been established for the stream relocation plan:
• Planted species survivorship: At least 85% of the planted trees and shrubs along the
relocated stream corridor should be established and living by the end of the three year
monitoring period; plantings will meet or exceed an 85 percent survival rate by the end
of the second growing season - if this goal is not met, the site will be re-evaluated and
replanted as necessary (Note: if revegetation is failing due to herbivory, the wildlife
responsible need to be identified and appropriate damage control methods employed.
Possible methods include deer fencing, rabbit fencing, and use of repellents -this pest
control will need to be maintained as necessary throughout the three year monitoring
period
• Native species composition: At least 50% of the plants present should be non -weedy,
native, perennial species; invasive species will not constitute more than 10 percent of
the vegetative/streamside community; if this goal is exceeded, measures will be taken
to eradicate/hand-remove the invasive species
• Stream function: based on NCSAM, the relocated stream will score medium quality or
higher (Note: the lack of a wooded stream corridor may hinder the results of NCSAM
initially, however, its anticipated that the interaction of the stream with the streamside
area will work to offset that evaluation criteria)
• Stream stability: based on observations, the streambanks will be stable with little to no
erosion.
Long -Term Maintenance
It is envisioned that the stream relocation plan will afford an opportunity for an outdoor
classroom for the Unity Classical Academy high school students. It's further anticipated
that the students will `adopt' the stream corridor and provide long-term maintenance
activities, including invasive species removal.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TIM BAUMGARTNER
Director
NORTH CAROLINA
Environmental Quality
September 24, 2020
Brandon Whallon
Performance Charter School Development, LLC
855 W Broad Street, Suite 300
Boise, ID 83702
Project: Unity Classical Charter School
Expiration of Acceptance: 3/24/2021
County: Mecklenburg
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin
Impact Location
8-di it HUC
Impact Type
Impact Quantity
Catawba
03050103
Warm Stream
170
*DMS proposes to utilize the Catawba 03 Expanded Service Area to meet the mitigation requirement.
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The
mitigation will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010.
Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any questions or neec
additional information, please contact [e-mail].
cc: Michael lagnocco, agent
Sincerely,
A_V_V�tA_�
FOR James. B Stanfill
Asset Management Supervisor
NORTH CARCi NA , E Q��
gepartment of EnvironmeMnl quallry
North Carolina Department of Environmental Quality I Division of Mitigation Services
217 W. ]ones Street 1 1652 Mail Service Center I Raleigh, North Carolina 27699-1652
919.707.8976

Uz '
United States Department of the Interior ` EM
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
September 30, 2020
Michael Iagnocco
STV Engineers, Inc.
900 West Trade Street, Suite 715
Charlotte, North Carolina 28202
[e-mail]
Dear Michael Iagnocco:
Subject: Unity Classical Academy; Mecklenburg County, North Carolina Log No. 4-2-20-398
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in your
correspondence and PCN received via email on September 23, 2020, wherein you solicit our
comments regarding project -mediated impacts to federally protected species. We submit the
following comments in accordance with the provisions of the Fish and Wildlife Coordination Act,
as amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321
et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543)
(Act).
Project Description
According to the information provided, the proposed project would entail the construction of a
school facility and appurtenances on approximately 14.2 partially forested acres in Charlotte,
North Carolina. The project area consists of undeveloped mixed pine/hardwood forest, several
residences, maintained lawns, developed open spaces, and transitional habitats. The proposed
project would result in unavoidable impacts (fill) to 170 linear feet of an unnamed tributary stream.
We acknowledge the numerous proposed impact avoidance, minimization, and mitigation
measures detailed in the information provided and we appreciate your efforts to improve
ecological stream function described in Section E.2.b of the PCN.
Federally Protected Species
According to Service records, suitable summer roosting habitat may be present in the project area
for the federally threatened northern long-eared bat (Myotis septentrionalis). However, the final
4(d) rule, (effective as of February 16, 2016) exempts incidental take of northern long-eared bat
associated with activities that occur greater than 0.25 miles from a known hibernation site, and
greater than 150 feet from a known, occupied maternity roost during the pup season (June 1 — July
31). Based on the information provided, the project would occur at a location where any incidental
take that may result from associated activities is exempt under the 4(d) rule. Although not
required, we encourage the Applicant to avoid any associated tree clearing activities during
the maternity roosting season from May 15 — August 15.

Service records show historic occurrences for the federally endangered Schweinitz's sunflower
(Helianthus schweinitzii) in the project vicinity and suitable habitat may be present within the
action areal for this species and also the federally endangered Michaux's sumac (Rhus michauxii)
and smooth coneflower (Echinacea laevigata). However, targeted botanical surveys conducted
during optimal survey windows did not detect evidence for these species at that time.
Due to the presence of suitable habitat, but lack of onsite evidence for these species, we believe the
probability for project -mediated loss of these plants is insignificant and discountable. Therefore,
we would concur with a "may affect, not likely to adversely affect" determination from the federal
action agency, and we require no further information at this time.
Please be aware that obligations under section 7 of the Endangered Species Act must be
reconsidered if. (1) new information reveals impacts of this identified action that may affect listed
species or critical habitat in a manner not previously considered, (2) this action is subsequently
modified in a manner that was not considered in this review, or (3) a new species is listed or
critical habitat is determined that may be affected by the identified action.
In addition to the voluntary recommendations provided in our previous correspondence dated
August 19, 2020, we offer the following general recommendations for the Applicant's
consideration:
Pollinator Habitat
Pollinators, such as most bees, some birds and bats, or other insects, including moths and
butterflies, play a crucial role in the reproduction of flowering plants and in the production of most
fruits and vegetables. Declines in wild pollinators are a result of loss, degradation, and
fragmentation of habitat and disease; while declines in honey bees has also been linked to disease.
The rusty -patched bumble bee (Bombus affinis) historically occurred in North Carolina's Mountain
and Piedmont provinces. Although not required, we encourage the Applicant to consider our
recommendations below to benefit the rusty -patched bumble bee and other pollinators. Moreover,
the creation and maintenance of pollinator habitats at this site may increase the value of the project
for the school and community it serves, and help reduce the spread of invasive exotic plants.
Please consider the following:
1. Sow native seed mixes in disturbed areas or in designated pollinator areas with plants
that bloom throughout the entire growing season.
2. Taller growing pollinator plant species should be planted around the periphery of the
site and anywhere on the site where mowing can be restricted during the summer
months. Taller plants, left un-mowed during the summer, would provide benefits to
pollinators, habitat to ground nesting/feeding birds, and cover for small mammals.
3. Low growing/groundcover native species should be planted in areas that need to be
maintained. This would provide benefits to pollinators while also minimizing the
1 Pursuant to 50 CFR §402.02, the Action Area includes all areas to be affected directly or indirectly by the Federal
action and not merely the immediate area involved in the action. Moreover, the Effects of the Action are all
consequences to listed species or critical habitat that are caused by the proposed action, including the consequences of
other activities that are caused by the proposed action. A consequence is caused by the proposed action if it would not
occur but for the proposed action and it is reasonably certain to occur. Effects of the action may occur later in time
and may include consequences occurring outside the immediate area involved in the action (see also 50 CFR §402.17)
2

amount of maintenance such as mowing and herbicide treatment. Milk weed species are
an important host plant for monarch butterflies.
4. Avoid mowing of flowering plants. Designated pollinator areas show be mow only 50%
of the plant height, but no lower than 8 inches.
5. Avoid mowing outside the active season for rusty -patched bumble bee and other
pollinators (April 15 — October 15).
6. Leave slash piles, mulch piles, or loose dirt piles along woodland edges. These areas
provide nesting habitats and/or nest materials for some pollinators.
7. Avoid the use of pesticides and specifically neonicotinoids.
8. Additional information regarding plant species, seed mixes, and pollinator habitat
requirements can be provided upon request.
The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at byron—[e-mail], if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-20-398.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
3