20070279 Ver 1_More Info Received_20070410

tLMG
LAND MANAGEMENT GROUP INC.
Environmental Consultants
April 4, 2007 , � 3
APR 1 0 2007
TO: Ms. Kim Garvey
U.S. Army Corps of Engineers DEN, vvA�=►�U'6AL1 F,r
rPns4 �1 srr , vaTar:r
P.O. Box 1890
Wilmington,NC 28402-1890
RE: Additional Information for St. James Safe Storage;Action ID#2007899-010
Brunswick County,NC
Dear Kim:
We received Tom Farrell's letter dated March 12,2007 in which he requested additional project
information for the St. James Safe Storage NWP 39 application.Tom recently told us that this project has
been turned over to you. Below is a response to each of his comments.
1. The applicant needs to address avoidance and minimization for this project.It appears that there
is sufficient room on site to avoid the larger part of the wetland impact by either adjusting the
building locations or reducing the size of at least one of the buildings.
Buildings 1 and 2 were offset from the back of the property a certain distance in order to allow an
adequate turning radius for tractor trailer moving vans.Please see the enclosed figure provided by the
applicant's engineer. These large trucks will not be able to maneuver between Buildings 3 and 4,so it
is essential to maintain this radius between Buildings 1 and 2.Please note that the applicant has already
revised the site plan several times in order to reduce wetland impacts. He originally planned to have
120,000 square feet of storage space, but reduced this to 86,000 square feet in order to meet DOT
requirements. This has already diminished the project value significantly due to the fixed overhead
costs associated with office, staff and land expenses.The proposed building sizes are needed in order
to make this project economically feasible.
2. Mitigation through EEP for wetland impacts usually is at a ratio of no less than 2:1. Please
consider adding an upland buffer or other significant increase in preservation protection that
may justify a reduction of the mitigation ratio.
The applicant agrees to buy into the EEP for the restoration of 0.75 acre of non-riparian wetlands.
3. On March 9,we received comments from North Carolina Division of Wildlife regardingprotected
species. The Division has asked us to coordinate with the applicant to seek an agreement to
relocate any Menus flytrap plants that may be on the site.In addition, the Division asked that all
the remaining wetlands on site be preserved. Please notify us as to the applicant's intention to
comply with this request.
Prior to any construction,the wetland area near the front of the site will be evaluated for the presence
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of Venus flytraps. If any are observed in the proposed impact area,they will be relocated to adjacent
undisturbed wetlands by a qualified professional. The applicant does not want to preserve the
remaining wetlands in this area because these wetlands are located in the front of his property and he
will need to periodically cut back the vegetation here in order to maintain good visibility and create an
aesthetically pleasing frontage.
4. The parcel under review is shown on the survey as lot 29.Is the lot under single ownership or has
this lot been subdivided since the delineation was done?The original delineation involved only a
portion of the 1 S-acre site. The remainder of the property has not been delineated and appears to
include uplands. Our regulations require that we review an application to consider all
jurisdictional impacts that are likely to occur on the applicant's parcel. This is to prevent
piecemealing of projects. Accordingly, a delineation for the rest of the site should be included
with the application.In addition, any anticipated wetland impacts need to be reviewed under the
present application.
The tract has not been subdivided.The applicant has plans only to develop the property as depicted on
the site plan.As determined during the original delineation by LMG,there may be upland areas located
along the northern property line,to the rear of the property. Accessing these potential uplands would
entail the disturbance of wetlands,which the applicant does not plan to do. However,he does plan to
occasionally cut vegetation within these wetlands in accordance with regulatory guidelines.Because of
this,he does not want to place these areas in preservation. The applicant is agreeable to adjusting the
ratios of payment to EEP to make up for the lack of preservation.
I hope this response adequately addresses your comments.Please contact me if you have any other
questions. Thank you for your assistance with this project.
Sincerely, `am Q
Willis
Encl.
C: Mr. Jay Cole, St. James Safe Storage, LLC
Ms. Noelle Lutheran,DWQ
Mr. Ian McMillan, DWQ
Mr. Kent Harrell,Norris Kuske&Tunstall

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MiCtIAEL UNDERWOOD and A550CIATM PA V / A 1/ _ :'
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MWINCTON,NC 284 3
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