20200933 Ver 1_More Info Received_20201021

kimley-horn.com 421 Fayetteville Street, Suite 600, Raleigh, NC 27601 919 677 2000

October 20, 2020

Ms. Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
NC Division of Water Resources
512 N Salisbury Street
Raleigh, NC 27604
RE: Bloodworth Street Sewer – Chavis Park Conservation Easement
City of Raleigh, Wake County, North Carolina
NCDWR Supplemental Information Request

Dear Ms. Merritt,

On behalf of our client, the City of Raleigh, Kimley-Horn is submitting the below supplemental
information for the above referenced project in response to the NC Department of Environmental
Quality (NCDEQ) and NC Division of Water Resources (NCDWR) supplemental information request
received on September 29, 2020. The project proposes to construct approximately 2,010 linear feet
(LF) of 8- to 24-inch sanitary gravity sewer owned and maintained by the City of Raleigh. Of these
2,010 LF of sewer improvements, 132 LF are proposed within the Chavis Park Conservation Easement.
The proposed project would perpendicularly cross a portion of the Conservation Easement outside of
the existing sanitary sewer maintenance easement. In addition, the proposed project will result in
impacts to the Neuse River riparian buffer zones associated with Chavis Branch and an UT to Chavis
Branch regulated by NCDWR. No 404/401 stream or wetland impacts will result from the proposed
project as an aerial crossing with footers located outside of the top of bank will be installed at the
crossing. Impacts to the riparian buffer zones are located both within and outside of the Conservation
Easement. A Buffer Authorization request for the project was submitted to NCDWR on May 18, 2020
and is currently on hold pending the below information related to the conservation easement impacts.

Below is an outline of the information requested by the NCDEQ Stewardship Program and NCDWR in
order to complete the easement modification and buffer authorization request for the proposed project.
The NCDEQ and NCDWR requests with Kimley-Horn responses and explanations are as follows:

1) A detailed planting plan for restoration of easement areas upon completion of construction.
• See attached updated plan sheets (Sheets 5 and 14) including a detailed planting plan for
Chavis Park conservation easement areas. A full plan set can be provided upon request,
but due to file size, was left off of this submittal.

2) An asset map from DMS showing where the buffer assets are located.
• See attached DMS map provided by NCDEQ on September 29, 2020.
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kimley-horn.com 421 Fayetteville Street, Suite 600, Raleigh, NC 27601 919 677 2000

3) An exact amount of buffer replacement credits (after applying the 3:1 ratio) that will be
purchased by City of Raleigh.
• The proposed project will permanently impact approximately 1,353 square feet of
previously released riparian buffer credits within the Conservation Easement. Additionally,
the loss of these buffer credits will result in indirect impacts to approximately 14 linear feet
of previously released stream credits. The City proposes to mitigate for these impacts at a
3:1 ratio by purchasing riparian buffer credits and stream credits through the NCDMS In-
Lieu Fee program. The City will purchase 4,059 buffer replacement credits and 42 stream
replacement credits through NCDMS (see attached NCDMS Acceptance Letter).

The temporarily impacted areas within the conservation easement will be restored to pre-
existing contours, reseeded, and replanted with native trees and shrubs; therefore, no
compensatory mitigation is proposed for these areas.

4) A specific statement from City of Raleigh to purchase directly from DMS and not any other
provider.
• The City of Raleigh will purchase the above-mentioned buffer and stream replacement
credits directly from DMS prior to construction of the proposed Bloodworth Street Sewer
Replacement project.

5) A commitment that City of Raleigh will apply for the appropriate Buffer Authorization or Variance
from the DWR prior to any activities within the riparian buffer.
• A Buffer Authorization request for the project was submitted to NCDWR on May 18, 2020.
On August 21, 2020, the NCDWR determined that the buffer authorization application was
incomplete and could not be processed until a copy of the final approval from the NCDEQ
Stewardship and the IRT along with the final proposed alignment regarding the impacts to
the Conservation Easement associated with this project are received. This supplemental
information is being submitted to satisfy the additional information needed to process the
buffer authorization request currently on hold. The City of Raleigh will not begin
construction within the protected riparian buffer zones until a buffer authorization is
received from NCDWR.

In addition to the above information, the following items have been included with this submittal:
• Revised Plan Sheets with Planting Plan
• DMS Chavis Branch Mitigation Assets Map
• NCDMS Acceptance Letter

If there is any additional information that you need to assist in the processing of this permit application
package, please do not hesitate to contact me at [phone].

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kimley-horn.com 421 Fayetteville Street, Suite 600, Raleigh, NC 27601 919 677 2000

Sincerely,

Kimley-Horn and Associates, Inc.

William Sullivan

CC – Ed Hajnos (NCDEQ), Todd Tugwell (USACE), Lyle Phillips (USACE), Stephanie Goss
(NCDWR)

Attachments
OF
14
BLOODWORTH STREET SEWER
PREPARED FOR
PUBLIC UTILITIES DEPARTMENT
CITY OF RALEIGH, NORTH CAROLINA
©OF
14
PLAN AND PROFILE
STA 9+94 TO 20+00
5
SECTION VIEW
OF
14
OF
14
BLOODWORTH STREET SEWER
PREPARED FOR
PUBLIC UTILITIES DEPARTMENT
CITY OF RALEIGH, NORTH CAROLINA
©PLANTING PLAN 14
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS,USDA, USGS, AeroGRID, IGN, and the GIS User Community
Legend
Chavis Bloodsworth SMU Impa ct_1_31_20
Chavis Bloodsworth Ea seme nt Imp act_1 _31_2 0
Chavis Bloodsworth Bu ffer Impact_1_31_20
Te mpo rary_Stream_Impacts
Te mpo rary_Buffer_Impacts
Te mpo rary RO W Ea se me nt Impa ct
ChavisBuffe rAssets
WVS_Ea seme nt
Chavis Streams 50 0 5025 Feet
.
Chavis Park DMS ID 87 1_31_20 ROW Impact Analysis Map
Results: Easement Impact Area: 2,623 sq. ft.Stream Mitigation Impact : 19 lf. Buffer Mitigation Impact: 1,921 sq. ft. Temporary Impacts:Buffer: 568 sq. ft. Easement: 663 sq. ft. Stream: 5 lf.

October 21, 2020

Janeen Goodwin, PE
City of Raleigh
PO Box 590
Raleigh, NC 27602 Expiration: April 20, 2021

Project: Bloodworth Street Sewer- Chavis Park easement County: Wake

The NCDEQ Stewardship Program has evaluated your request to impact a conservation easement and, after
consultation with the Inter-agency Review Team, has agreed to allow the temporary impacts to the easement
area contingent upon the acceptance of a mitigation recovery payment by the Division of Mitigation Services.
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for the impact as indicated in the table below.
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 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.
Location Impact Type Impact Quantity
Neuse 03020201

Riparian Buffer 1,353 ft2 @3:1
Warm Stream 14 ft. @3:1

Sincerely,

FOR James B. Stanfill
Asset Management Supervisor

cc: Todd Tugwell, USACE – Raleigh
Ed Hajnos, NCDEQ Stewardship Program
Katie Merritt, NCDWR
William Sullivan, agent