20091346 Ver 3_EPA Comments_20101006

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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ATLANTA FEDERAL CENTER
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I 61 FORSYTH STREET
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October 6, 2010
Mr. James Shern
U.S. Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Raleigh, North Carolina 27587
Subject: New Hill Place - Action ID # SAW-2008-00967, Wake County, North Carolina
Dear Mr. Shern:
The applicant, Springs Investors, LLC is proposing to construct New Hill Place, a 227 acre
mixed-use development, in Holly Springs, Wake County, North Carolina. The project will consist of a
commercial shopping center, residential development and associated transportation, parking and
stormwater facilities. The project, as proposed, would impact 1.101 acres of wetlands and 5,256 linear
feet of streams. We have the following comments:
The Environmental Protection Agency (EPA) is concerned about the magnitude of the
proposed impacts for this project, especially almost one mile of impacts to on-site streams. The public
notice does not contain a discussion of strategies to reduce impacts through avoidance and
minimization practices, so we were not able to evaluate to what degree this has been done for this site.
However, looking at the site plan on page six, it appears there remains opportunity for additional
avoidance and minimization. An evaluation of the development plan indicates that a large amount of
the impacts are associated with roadway construction and parking lots. We suggest there may be
opportunity to further reduce impacts through roadway bridging, project reconfiguration and use of a
multi- level parking deck(s). The table at the top of the figure indicates mitigation will be at 1:1 for
intermittent and 2:1 for perennial stream impacts. Will mitigation be through the North Carolina
Ecosystem Enhancement Program? Has the quality of the streams been determined using the
Wilmington District stream quality assessment form?
EPA appreciates the opportunity to review and comment on the New Hill Place proposed
project. As we stated above, we are concerned with the high level of impacts to site streams and the
lack of the current site plans to address areas where there appear to be opportunities for significant
additional avoidance and minimization of project impacts. From the information presented in the
public notice, it appears this may not be the least environmentally damaging practicable alternative.
We will be happy to review any further project modifications. Should you have questions, feel free to
coordinate with Becky Fox of my staff at [phone] or at fox.rebeccaC epa.yov.
Sincerely, ,
v
Jennifer S. Derby
Chief
Wetlands and Marine Regulatory Section
cc: NCDWQ, Raleigh
Internet Address (URL) . http:!lwww.epa.gov
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