20080580 Ver 2_401 Application_20101222

I I"I" III') II"I I'lll'IIII'I'I II'I FAST LANE PICKUP DATE PICKUP TIME
31844 SAME DAY DRIVER # OF PIECES WEIGHT'
BILL TO SHIF PER RECEIVER 3RD PARTY
NEXT DAY CAR VAN ROUND TRIP CHARGES
FROM S & EC TO
COMPANY NAME
------ ?- ---------_-------
11010 RAVEN RIDGE ROAD STREET ADDRESS
RALEIGH, NC 27614
846-5900
PROJECT
SIGNATURE
_
CITY- - - -1- - STS -ZIP
CONTACT NAME
PHONE #
I NT
TIME. -- -

o8-o5go
Environmental Consultants, PA
Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
December 22, 2010
S&EC Project # 10998.W2
To: N.C. Division of Water Quality
401 Oversight and Express Permits Unit
Attn: Ian McMillan
512 North Salisbury St., 9°i Floor
Raleigh, NC 27604
From: Nicole Thomson
Soil & Environmental Consultants, P.A.
11010 Raven Ridge Road
Raleigh, NC 27614
Re: Buckhorn Place, Wake County, NC
1
9ci(.1
V.ETL", ;Oni;N STOf? OUALI ER°yCN
On behalf of the owner, Buffaloe Forest, LLC, please find attached a complete application and supplemental information requesting
AFTER-THE-FACT Neuse River Riparian Buffer Authorization from the N.C. Division of Water Quality (DWQ) for the
activities proposed below. Please contact me at [phone] if you have any questions or require additional information.
PROJECT SUMMARY
Project Name Buckhorn Place
Project Type Residential Development
Owner / Applicant Buffaloe Forest, LLC
County Wake
Nearest Town Raleigh
Waterbod Name UT to Neuse River
Basin / Sub-basin 03-03-02
Index Number 27-(22.5)
Class C; NSW
USGS Cataloging Unit 03020201
IMPACT SUMMARY
Stream Impact (acres): 0
Wetland Impact (acres): 0
Open Water Impact (acres): 0
Total Impact to Waters of the U.S. (acres) 0
Total Stream Impact (linear feet): 0
Total Neuse River Riparian Buffer Impact (sq. ft.) 33,194 sq. ft. (18,818 sq. ft. Zone I & 14,376 sq. ft. Zone 2)
Attachments:
Pre-construction Notification (PCN) Application Fonn
USGS Topographic Site Vicinity Map
NRCS Soil Survey Site Vicinity Map
Agent Authorization Form
DWQ Buffer Determination (NBRRO 05-346)
404 Verification (AID 2008-01195)
401 Water Quality Certification (DWQ No. 08-0580)
JD Verification Letters
DWQ NOV (NOV-2010-PC-1084)
Impact Map Detail
Planting Plan Details
cc: Mr. Pablo Reiter, Buffaloe Forest, LLC, 6404 Falls of Neuse Rd, Suite 103, Raleigh, NC 27615
Mr. Morgan Bryan, The Bryan Group, Inc. 447 Houses Mill Rd, Newton Grove, NC 28366
Mr. Steve Levitas, Kilpatrick Stockton, LLP, 3737 Glenwood Ave., Raleigh, NC 2612
Charlotte Office: Greensboro Office:
236 LePhillip Court, Suite C 3817-E Lawndale Drive
Concord, NC 28025 Greensboro, NC 27455
Phone: [phone] Phone: [phone]
Fax: [phone] Fax: [phone]
WAIF
o -c
Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.3 Dec 10 2008
Pre-Construction Notification (PCN) Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the
Corps:
El Section 404 Permit ? Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number: or General Permit (GP) number:
1c. Has the NWP or GP number been verified by the Corps? ? Yes ? No
1d. Type(s) of approval sought from the DWQ (check all that apply):
? 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit
? 401 Water Quality Certification - Express ® Riparian Buffer Authorization
1 e. Is this notification solely for the record
because written approval is not required? For the record only for DWQ 401
Certification:
? Yes ? No For the record only for Corps Permit:

? Yes ? No
1f. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu
fee program. ? Yes ® No
1 g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below. ? Yes ® No
1 h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes ® No
2. Project Information
2a. Name of project: Buckhorn Place
2b. County: Wake `j r3"Zk?-
2c. Nearest municipality / town: Raleigh !
2d. Subdivision name: Buckhorn Place DE 9, n ? .t
2e. NCDOT only, T.I.P. or state
project no:
N/A DENR- WATER QUAUTY
3. Owner Information
3a. Name(s) on Recorded Deed: Buffaloe Forest LLC
3b. Deed Book and Page No. 11787/1460
3c. Responsible Party (for LLC if
applicable): Mr. Pablo Reiter
3d. Street address: 6404 Falls of Neuse Rd., Suite 103
3e. City, state, zip: Raleigh, NC 27615
3f. Telephone no.: 919-792-3746
3g. Fax no.: N/A
3h. Email address: N/A
Page 1 of 12
PCN Form - Version 1.3 December 10, 2008 Version
4. Applicant Information (if different from owner)
4a. Applicant is: ? Agent ® Other, specify: Applicant is Owner as listed on the Agent
Authorization; please copy agent (S&EC) on all correspondence
4b. Name: Mr. Pablo Reiter
4c. Business name
(if applicable): Buffaloe Forest LLC
4d. Street address: 6404 Falls of Neuse Rd., Suite 103
4e. City, state, zip: Raleigh, NC 27615
4f. Telephone no.: 919-792-3746
4g. Fax no.: N/A
4h. Email address: N/A
5. Agent/Consultant Information (if applicable)
5a. Name: Nicole J. Thomson
5b. Business name
(if applicable): Soil & Environmental Consultants, PA
5c. Street address: 11010 Raven Ridge Road
5d. City, state, zip: Raleigh, NC 27614
5e. Telephone no.: [phone]
5f. Fax no.: [phone]
5g. Email address: [e-mail]
Page 2 of 12
B. Project Information and Prior Project History
1. Property Identification
1a. Property identification no. (tax PIN or parcel ID): 1746505680
1 b. Site coordinates (in decimal degrees): Latitude: 35.8383 Longitude: - 78.5093
(DD.DDDDDD) (-DD.DDDDDD)
1 c. Property size: +/- 129 acres
2. Surface Waters
2a. Name of nearest body of water (stream, river, etc.) to Neuse River
proposed project:
2b. Water Quality Classification of nearest receiving water: 03-04-02; 27-(22.5); C; NSW
2c. River basin: Neuse River (USGS Cataloging Unit 030020201)
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
The subject property is currently under construction. Phase 1 of the development has been cleared and
infrastructure has been installed. The remaining phases of the development are currently forested. The
surrounding land use is residential.
3b. List the total estimated acreage of all existing wetlands on the property:
+/-2
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
+/-1,446
3d. Explain the purpose of the proposed project:
The purpose of the proposed project is to construct the Buckhorn Place residential development to provide
additional housing for the area.
3e. Describe the overall project in detail, including the type of equipment to be used:
The proposed development will be for a residential subdivision with typical roads and utilities. Heavy equipment
necessary for road and home construction as well as utility installation will be used.
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property /
®Yes ? No ? Unknown
project (including all prior phases) in the past?
Comments:
4b. If the Corps made the jurisdictional determination, what type
? Preliminary ®Final
of determination was made?
4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: Skelly & Loy, LLP
Name (if known): Jay Keller Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
The USACE issued the 404 and Jurisdictional Determination for the project on May 7, 2008 (see attached AID 2008-
01195). The validity of this JD was further confirmed in the September 29, 2010 email correspondence between Mr.
Steve Levitas and Mr. Justin McCorcle (see attached). Mr. Mike Horan issued a Neuse River Riparian Buffer
determination letter on January 6, 2006 (see attached).
Page 3 of 12
PCN Form - Version 1.3 December 10, 2008 Version
B. Project Information and Prior Project History
5. Project History
5a. Have permits or certifications been requested or obtained for ® Yes ? No ? Unknown
this project (including all prior phases) in the past?
5b. If yes, explain in detail according to "help file" instructions.
On May 7, 2008 and August 5, 2008, the USACE and NC DWQ, respectively, authorized impacts to 0.0977 acres of
wetland impact (0.0947 acres permanent impact and 0.003 acres temporary impact), 110 linear feet of permanent
important/perennial stream channel and 11,785 square feet of riparian buffer impact (7,180 square feet of Zone 1 and
4,605 square feet of Zone 2). On July 22, 2010, the NC DWQ Raleigh Regional Office (RRO) issued a letter relating to
their June 2010 site inspection. This was followed by an August 30`h Notice of Violation letter which cited unpermitted
riparian buffer impacts related to Sediment Pond 1. Follow up site visits by NC DWQ RRO staff in September and
October resulted in an October 12`h Notice of Continuing Violation, Notice of Intent to Enforce letter related to the original
Riparian Buffer violations in addition to subsequent sediment violations. A site meeting with Mr. Danny Smith and Ms.
Lauren Witherspoon in October 2010 was held to discuss the violations on-site and appropriate remediation requirements
which lead to the submittal of this "After-the-fact" Riparian Buffer Impact request. This application is solely to request
after-the-fact Authorization of the Neuse River Riparian Buffer impacts.
6. Future Project Plans
6a. Is this a phased project? ® Yes ? No
6b. If yes, explain.
This project has always been shown as a phased development. Phase I is currently under construction. The initial permit
application submitted in 2008 clearly shows the Phase lines on the overall impact map. All proposed impacts were
requested within the original permit application. Further, a stormwater management plan for the entire subdivision was
developed in accordance with the requirements that were in place at the time of the application submittal.
Page 4 of 12
C. Proposed Impacts Inventory
1. Impacts Summary
1a. Which sections were completed below for your project (check all that apply):
? Wetlands ? Streams - tributaries ® Buffers
? Open Waters ? Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a. 2b. 2c. 2d. 2e. 2f.
Wetland impact Type of jurisdiction
number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact
Permanent (P) or (if known) DWQ - non-404, other) (acres)
Temporary T
W1 ? P ? T ? Yes ? Corps
? No ? DWQ
W2 ? P ? T ? Yes ? Corps
? No ? DWQ
W3 ? P ? T ? Yes ? Corps
? No ? DWQ
W4 ? P ? T ? Yes ? Corps
? No ? DWQ
W5 ? P ? T ? Yes ? Corps
? No ? DWQ
W6 ? P ? T ? Yes ? Corps
? No ? DWQ
2g. Total wetland impacts
2h. Comments:
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a. 3b. 3c. 3d. 3e. 3f. 3g.
Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact
number - (PER) or (Corps - 404, 10 stream length
Permanent (P) or intermittent DWQ - non-404, width (linear
Temporary (T) (INT)? other) (feet) feet)
S1 ? P ? T ? PER ? Corps
? INT ? DWQ
S2 ? P ? T ? PER ? Corps
? INT ? DWQ
S3 ? P ? T ? PER ? Corps
? INT ? DWQ
S4 ? P ? T ? PER ? Corps
? INT ? DWQ
S5 ? P ? T ? PER ? Corps
? INT ? DWQ
S6 ? P ? T ? PER ? Corps
? INT ? DWQ
3h. Total stream and tributary impacts
3i. Comments:
Page 5 of 12
PCN Form - Version 1.3 December 10, 2008 Version
4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individual) list all open water impacts below.
4a. 4b. 4c. 4d. 4e.
Open water Name of waterbody
impact number - (if applicable) Type of impact Waterbody type Area of impact (acres)
Permanent (P) or
Temporary T
01 ?P?T
02 ?P?T
03 ?P?T
04 ?P?T
0. Total open water impacts
4g. Comments:
5. Pond or Lake Construction
If and or lake construction proposed, then complete the chart below.
5a. 5b. 5c. 5d. 5e.

Pond ID
Proposed use or purpose Wetland Impacts (acres) Stream Impacts (feet) Upland

b (acres)
num
er of pond
Flooded Filled Excavated Flooded Filled Excavated Flooded
P1
P2
5f. Total
5g. Comments:
5h. Is a dam high hazard permit required?
? Yes ? No if yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If an impacts require mitigation, then you MUST fill out Section D of this form.
6a.
® Neuse ? Tar-Pamlico ? Other:
Project is in which protected basin? ? Catawba ? Randleman
6b. 6c. 6d. 6e. 6f. 6g.
Buffer impact
number - Reason for impact Buffer Zone 1 impact Zone 2 impact
Permanent (P) or Stream name mitigation (square feet) (square feet)
Temporary T required?
B1 ®P ? T Sediment/Stormwater UT to Neuse ? Yes 18
818 14
376
Pond River ® No , ,
B2 ?P?T ?Yes
? No
B3 ?P?T ?Yes
? No
6h. Total buffer impacts 18,818 14,376
6i. Comments: A new riparian buffer will be re-established around the sediment pond when it is converted from an erosion
Page 6 of 12
I control device to a permanent stormwater management device (see attached proposed planting plan).
Page 7 of 12
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
The riparian buffer violation was not done with malice or forethought. The applicant's previous consultant delineated the
subject site and stated they received agency concurrence of the location, nature and origin points of streams and
wetlands on the property. Further, the previous consultant provided a DWQ Neuse Buffer determination letter to support
what features were subject to the Neuse Riparian Buffer Rules. Based upon those documents, the applicant submitted a
Preconstruction Notification (PCN) which included a complete site plan that noted the locations of all jurisdictional
features and riparian buffers and requested USACE and NC DWQ approval for unavoidable impacts to the same. The
current location of Sediment Basin 1 (the violation area) was not shown to be an impact because at the time of submittal
of the PCN and supplemental information, it was not believed to be an impact. Subsequent site visits and discussions
with NC DWQ RRO staff resulted in the Neuse Riparian Buffer limits being extended further upstream than where
originally thought to be. Therefore, Sediment Basin 1 is now located within the riparian buffer and the impacts have been
accounted for accordingly. Further, a permanent stormwater device is proposed to be located where Sediment Basin 1
currently is (previously approved by NC DWQ staff in August 2008) and the applicant is proposing to re-establish the
riparian buffer around the pond when it is converted from an Erosion and Sedimentation control device to a permanent
Stormwater Management Device (as was required by NC DWQ RRO staff in prior site meetings and discussions).
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
Construction activities for the previously discussed impacts are completed and this application is for after the fact buffer
impact authorization only. Therefore, this question is not relevant at this time.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for ? Yes ® No
impacts to Waters of the U.S. or Waters of the State?
2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps
? Mitigation bank
2c. If yes, which mitigation option will be used for this
El Payment to in-lieu fee program
project?
? Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter) Type Quantity
3c. Comments:
4. Complete if Making a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached. ? Yes
4b. Stream mitigation requested: linear feet
4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold
4d. Buffer mitigation requested (DWQ only): square feet
4e. Riparian wetland mitigation requested: acres
4f. Non-riparian wetland mitigation requested: acres
4g. Coastal (tidal) wetland mitigation requested: acres
4h. Comments:
Page 8 of 12
PCN Form - Version 1.3 December 10, 2008 Version
5. Complete if Using a Permittee Responsible Mitigation Plan
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation? ? Yes ® No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.

Zone 6c.
Reason for impact 6d.
Total impact
(square feet)
Multiplier 6e.
Required mitigation
(square feet)
Zone 1 3 (2 for Catawba)
Zone 2 1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund).
6h. Comments:
Page 9 of 12
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1 a. Does the project include or is it adjacent to protected riparian buffers identified within ® Yes ? No
one of the NC Riparian Buffer Protection Rules?
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
Comments: There are no changes to the diffuse flow plan that was approved in 2008,
therefore, no plan has been provided. This is an After the Fact Riparian Buffer ? Yes ® No
Authorization request for the Sediment Basin that was inadvertently constructed within
the Neuse Buffer.
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? >24% %
2b. Does this project require a Stormwater Management Plan? ? Yes ® No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why: The applicant is only seeking a Neuse
River Riparian Buffer Authorization Certificate which does not require a Stormwater Management Plan. It is also
important to note that the Stormwater Management Plan proposed for this project was approved by NC DWQ in 2008.
No changes have been proposed to that approved plan.
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
? Certified Local Government
2e. Who will be responsible for the review of the Stormwater Management Plan? ? DWQ Stormwater Program
? DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a. In which local government's jurisdiction is this project?
? Phase II
3b. Which of the following locally-implemented stormwater management programs apply ? NSW
? USMP
(check all that apply): ? Water Supply Watershed
? Other:
3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ? No
attached?
4. DWQ Stormwater Program Review
? Coastal counties

4a. Which of the following state-implemented stormwater management programs apply ? HQW
? ORW
(check all that apply): ? Session Law 2006-246
? Other:
4b. Has the approved Stormwater Management Plan with proof of approval been
attached? ? Yes ? No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No
5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No
Page 10 of 12
PCN Form - Version 1.3 December 10, 2008 Version
F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1 a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No
use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State ? Yes ? No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.) ? Yes ? No
Comments:
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ® Yes ? No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after-the-fact permit application? ® Yes ? No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): The impacts that
occurred at the site were inadvertent and were not knowingly or willfully done. The current location of Sediment Basin 1 (the
violation area) was not shown to be an impact because at the time of submittal of the PCN and supplemental information, it
was not believed to be an impact. The applicant is therefore applying for the Neuse River Riparian Buffer impacts associated
with Sediment Basin 1.
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
We have reviewed the "DRAFT Internal Policy, Cumulative impacts and the 401 Water Quality Certification and Isolated
Wetland Programs" document prepared by the NC Division of Water Quality on April 10, 2004, version 2.1. The draft
states that most residential subdivisions are unlikely to cause cumulative impacts. This residential project does not meet
any of the three criteria of private projects that can clearly result in cumulative impacts. This development is relatively
small in nature, has no commercial component associated with it, is within a primarily residentially developed landscape
and therefore, the utility infrastructure (i.e. water and electricity) are already in place to service the proposed
development. This residential development will not affect regional growth patterns. We anticipate that you will advise us
if a qualitative or quantitative impact analysis is required.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
The project will tie into an existing sewage treatment facility in the area. The City of Raleigh will ensure that its capacity is
not exceeded.
Page 11 of 12
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or F1 Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act ? Yes ® No
impacts?
5c. If yes, indicate the USFWS Field Office you have contacted. [:1 Raleigh
? Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
As this project is only requesting Neuse River Buffer Riparian Authorization, this question is not relevant at this time.
Further, this project was previously approved in 2008 by both the USACE and NC DWQ. This was not an issue then, nor
is it anticipated to be an issue now.
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
As this project is only requesting Neuse River Buffer Riparian Authorization, this question is not relevant at this time.
Further, this project was previously approved in 2008 by both the USACE and NC DWQ. This was not an issue then, nor is it
anticipated to be an issue now.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation ? Yes ® No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
As this project is only requesting Neuse River Buffer Riparian Authorization, this question is not relevant at this time.
Further, this project was previously approved in 2008 by both the USACE and NC DWQ. This was not an issue then, nor
is it anticipated to be an issue now.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain? ? Yes ® No
8b. If yes, explain how project meets FEMA requirements:
8c. What source(s) did you use to make the floodplain determination? As this project is only requesting Neuse River Buffer
Riparian Authorization, this question is not relevant at this time. Further, this project was previously approved in 2008 by
both the USACE and NC DWQ. This was not an issue then, nor is it anticipated to be an issue now.
Nicole J. Thomson - 12/22/10
Applicant/Agent's Printed Name pplica gen s ature Date
(Agent's signature is valid onl orization letter from the applicant
is provided.
Page 12 of 12
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Environmental Consultants, PA
Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
Address' y----fa-lk- C A- --i_J S e t2 s' to?
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The Department of the Army
U.S. Anny Corps of Engineers. Wilmington District
P.O. Box 1890
Wilmington. NC 28402
Attn:
Field Office:.,
Re: Wetlands Related Consulting and Pcrmitting
To Whom It May Concern:
1. the current roe owner, hereby designate and authorize Soil & Environmental Consultants. PA to act in my
behalf as my agent in the processing of permit applications, to t", ish upon request Supplemental information in
support ofapplications, etc. from this day forward. T'he ___2.`,day of ?C? V J{
This notification supersedes any previous correspondence concerning the agent for this project.
NOTICE: This authorization, for liability and professional courtesy reasons, is valid only for government
officials to enter the property when accompanied by S&EC staff. You should call S&EC to arrange a site
meeting prior 'ling the site.
Print Property N ner's Name Property Owner's Signature
cc: - Ms. C'yndi Karoly cc: Mrs. Nicole Thomson
NCDENR - DWQ Soil & Environmental Consultants, PA
2321 Crabtree Boulevard
Raleigh. NC 27604
Charlotte Office: Greensboro Office:
236 LePhillip Court. Suite C 3817-E Lawndale Drive
Concord. NC 28025 Greensboro, NC 27455
Phone: [phone] Phone: [phone]
Fax [phone] Fax: [phone]
AGENT AUTHORIZATION FORM
All Blanks To Be Filled In By The Current Landowner

A
vV
A ,I micnaw r. kasiey, uovernor.

W illam G Ross Jr., Secretary
W
3 North Carolina Department of Envlronment and Natural Resources
Alan W. Klimek, P.E. Director
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Colleen N Suilins, Deputy Dlgcta+
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Division of Watef Quality

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NBRROP05)-346
County: NNAe
Skelly & LOY, LI.P
6404 Falls of Neuse Rd.
Ralel J1, NC 27615
wrt: Mr. Keller
BASIN:
_Neuse Riwr. X j Tar-Pamlico
(i 5 A NCA C 2B A233) I (15 A NCAC 2B.0259)
Complaint NOV
Buffer Determination X
_Incident # Appeal Call -
Project Name: Buffalo Road Site
Locatiom"Directions: Located off of Buffalo RoadA0 t x of i'et-C'rossrc?a?is
Subject Strewn: UT to Neusc River
Date of Determination: 11/I.5/05
rTeature - Start Wfer l;nd BUffeY Stream
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1 / 612006
Page 2of2
This oa-,site determination shall expire five (5) years from the date of this letter. Landowners or affected parties
that dispute a determination made by the, DIVQ or Pelegated Lora! Authority that a stoface wirier exists and that
it is subject to the buffer rule may request a determination by the Director. A request fur a determination kv the
Director shall be referred to the Director in writing " Cyndi Karoly, nli'Q Wetlands1401 Unit, 2321 Crabtree
81vel., Ralelgh, NC 27604-•2260. Individuals that dispute a determination by the DWQ or Delegated Local
Authority that "exempts" a surface water front the Otiffer rule may ask, for an ad judicatory hearing. You niu,st
act within 60 days of the date that yotr receive this latter. Applicants are hereby notified that the 60-d4(y stattrtoly
y (&4ludirig downstream and adjacent landowners) is notified of
appeal rune floes not start until the affected pan
this decision. Off IQ recommends that the applicant conduct this notifl ation lrt older to be certain that third
party appeals fire made in a timely manner. ? o asi? for a hearirsg, se ed a rvrittert petition, ?vlrich coil forms to
Chapter 1508 of the North Carolina General Slatu es to the Office of Administrative Hearings, 6714 Mait
Ser•t?tce Center, Ralc+igh, N.C 2 699-6714. This de?ermination is final and binding unless you ask for a heru•irr,l?
within 60 days.
The (owner/future owners) should notify the Di Inn of Water Quality (including ruty other Local, .State, and
Federal Agencies) of this dec s n concerning any ttture correspondences regar?ding the subject properly (stated
above). 77iis project attay require a Section 4G14/4 Permit for the proposed activity..9rry ingttirles should be
directed to the Division of Water Qualllty (Centnd i ce) at (919)-733-1786, and the USArmy Corp of Engineers
y Field Office) at (919)-876-8441.
(Raleigh Regulator
Respectfully,
Mich$el Horan
Environmental Spec. I
CC: Monte Mattliews, US Army Corps of Engineers, Raleigh Regulatory Office
Wetlands/ Stormwater Branch, 2321 Crabtree Blvd, Suite 250, Raleigh, NC 27604
Byron Brady, Wake County Environrnenta! Services, F.U. Box 550, Raleigh, NC 27602
File Copy i
Central Files
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U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action ID. 2008-01195 County: Wake USGS Quad: Raleigh East
GENERAL PERMIT (REGIONAL AND NATIONWIDE) VERIFICATION
Property Owner/ Authorized Agent: Buffaloe Land Developers, LLC E ! E }`
Address: Attn: Pablo Reiteru
6404 Falls of the Neuse Rd, Suite 103 MAY 14 2008
Raleigh, NC 27615
bye Soil Pi Ptr ttwreitr.l lawns ?!t7ryts PA
Telephone No.: 9.19-792-3746
Size and location of property (water body, road name/number, town, etc.): The Buckhorn Place site is approximately
130 acres of land located.in the southeast quadrant of the intersection of Buffaloe Rd and Old Milburnie Rd, in
Raleigh, Wake County, North Carolina.
Description of projects area and activity: This authorization is for permanent impact to .0947 acres of wetland due to
lot fill, 110 linear feet of stream channel with important aquatic function'due to construction of a roadwav and the
permanent conversion of .003 acres of wetland from forested wetland to a herbaceous wetland due to installation of
a utility line and the 20 foot permanently maintained sewer right-of-way easement. The project must be conducted
in accordance with the application and drawings submitted on March 28, 2008.
Applicable Law: ® Section 404 (Clean Water Act, 33 USC 1344)
El Section 10 (Rivers and Harbors Act, 33 USC 403)
Authorization: Regional General Permit Number:
Nationwide Permit Number: 12 and 29
Your work is authorized by the above referenced permit provided it is accomplished in strict accordance with the attached
conditions and your submitted plans. Any violation of the attached conditions or deviation from your submitted plans may subject the
permittee to a stop work order, a restoration order and/or appropriate legal action.
This verification will remain valid until the expiration date identified below unless the nationwide authorization is modified,
suspended or revoked. If, prior to the expiration date identified below, the nationwide permit authorization is reissued and/or
modified, this verification will remain valid until the expiration date identified below, provided it complies with all requirements of
the modified nationwide permit. If the nationwide permit authorization expires or is suspended, revoked, or is modified, such that the
activity would no longer comply with the terms and conditions of the nationwide permit, activities which have commenced (i.e., are
under construction) or are under contract to commence in reliance upon the nationwide permit, will remain authorized provided the
activity is completed within twelve months of the date of the nationwide permit's expiration, modification or revocation, unless
discretionary authority has been exercised on a case-by-case basis to modify, suspend or revoke the authorization.
Activitics subject to Section 404 "as •indicaied above) may also require an individual Section 401 Water Quaiity Certification. You
should contact the NC Division of Water Quality (telephone [phone]) to determine Section 401 requirements.
For activities occurring within the twenty coastal counties subject to regulation under .the Coastal Area Management Act (CAMA),
prior to beginning work you must contact the N.C. Division of Coastal Management.
This Department of the Army verification does not relieve the permittee of the responsibility to obtain any other required Federal,
State or local approvals/permits.
If there are any questions regarding this verification, any of the conditions of-the Permit, or the Corps of Engineers regulatory
program, please contact Andrew Williams at telephone number 919-876-8441 extension 26.
Corps Regulatory Official _Crystal Amschler Date: 05/07/2008
Expiration Date of Verification: 5/07/2010
The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do so,
please complete the attached customer Satisfaction Survey or visit hM://www.saw.usace.army.mil/WETLANDS/index.html to
complete the survey online.
Page I of 3
Determination of Jurisdiction:
? Based on preliminary information, there appear to be waters of the US including wetlands within the above described project area.
This preliminary determination is not an appealable action under the Regulatory Program Administrative Appeal Process
( Reference 33 CFR Part 331).
? There are Navigable Waters of the United States within the above described project area subject to the permit requirements of
Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act. Unless there is a change in the law or our
published regulations, this determination may be relied upon for a period not to exceed five years from the date of this
notification.
® There are waters of the US and/or wetlands within the above described project area subject to the permit requirements of Section
404 of the Clean Water Act (CWA)(33 USC § 1344). Unless there is a change in the law or our published regulations, this
determination may be relied upon for a period not to exceed five years from the date of this notification.
? The jurisdictional areas within the above described project area have been identified under a previous action. Please reference
jurisdictional determination issued . Action ID
Basis of Jurisdictional Determination: Wetlands were determined using the Corps 1987 delineation manual. Streams were
identified utilizing ordinary high water mark as identified in the field
Appeals Information (This information applies only to approved jurisdictional determinations.)
Attached to this verification is an approved jurisdictional determination. If you are not in agreement with that approved jurisdictional
determination, you can make an administrative appeal under 33 CFR 331. Enclosed you will find a Notification of Appeal Process
(NAP) fact sheet and request for appeal (RFA) form. If you request to appeal this determination you must submit a completed RFA
form to the following address:
District Engineer, Wilmington Regulatory Division
Attn: Crystal Amschler, Regulatory Specialist,
Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
3331 Heritage Trade Dr, Suite 105
Wake Forest, North Carolina 27587
In order for an RFA to be accepted by the Corps, the Corps must determine that it is complete, that it meets the criteria for appeal
under 33 CFR part 331.5, and that it has been received by the District Office within 60 days of the date of the NAP. Should you
decide to submit an RFA form, it must be received at the above address by 7/07/2008.
**It is not necessary to submit an RFA form to the District Office if you do of obj? to the determination in this correspondence.**
Corps Regulatory Official: C stal Amschler
Date 5/7/2008 Expiration Date 5/7 013
SURVEY PLATS, FIELD SKETCH, WETLAND DELINEATION FORMS, PROJECT PLANS, ETC., MUST BE
ATTACHED TO THE FILE COPY OF THIS FORM, IF REQUIRED OR AVAILABLE.
Copy Furnished:
Soil & Environmetnal Consultants
Attn: Nicole Thomson
11010 Raven Ridge Rd
Raleigh, NC 27614
Page 2 of 3
W A r?9P
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August 5, 2008
Coleen H. Sullins, Director
Division of Water Quality
DWQ Project # 08-0580
Wake County
Mr. Pablo Reiter
Buffaloe Land Developers, LLC
6404 Falls of the Neuse Road, Suite 103
Raleigh, NC 27615
Subject Property: Buckhorn Place
Ut to Neuse River [030402, 27-(22.5), C, NSW]
AUG 07 MO
Approval of 401 Water Quality Certification and Authorization Certificate per the Neuse River
Buffer Protection Rules (15A NCAC 2B.0233) with Additional Conditions - REVISED
Dear Mr. Reiter:
You have our approval, in accordance with the attached conditions and those listed below, to place fill
within or otherwise impact 0.0977 acres of 404/wetland (0.0947 acres permanent impact, and 0.0030
acres temporary impact), 110 linear feet of perennial stream, and 7,180 square feet of Zone 1 Neuse River
basin protected riparian buffers and 4,605 square feet of Zone 2 Neuse River basin protected riparian
buffers, as described in your application dated February 28, 2008, and received by the Division of Water
Quality (DWQ) on March 28, 2008, with additional information received by you on July 16, 2008, to
construct the proposed residential development at the site. After reviewing your application, we. have
decided that the impacts are covered by General Water Quality Certification Number(s) 3699 and 3705
(GC3699) and (GC3705). The Certification(s) allows you to use Nationwide Permit(s) NW12 and
NW29, respectively, when issued by the US Army Corps of Engineers (USACE). This Certification
replaces the Certification issued to you on July 31, 2008. In addition, you should obtain or otherwise
comply with any other required federal, state or local permits before you go ahead with your project
including (but not limited to) Erosion and Sediment Control, and Non-discharge regulations. Also, this
approval to proceed with your proposed impacts or to conduct impacts to waters as depicted in
your application shall expire upon expiration of the 404 or CAMA Permit.
This approval is for the purpose and design that you described in your application. If you change your
project, you must notify us and you may be required to send us a new application. If the property is sold,
the new owner must be given a copy of this Certification and approval letter and is thereby responsible for
complying with all conditions. If total fills for this project (now or in the future) exceed one acre of
wetland or 150 linear feet of stream, compensatory mitigation may be required as described in 15A
NCAC 2H.0506 (h). This approval requires you to follow the conditions listed in the attached
certification and any additional conditions listed below.
The Additional Conditions of the Certification are:
1. Impacts Approved
The following impacts are hereby approved as long as all of the other specific and general
conditions of this Certification (or Isolated Wetland Permit) are met. No other impacts are
approved including incidental impacts:
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: htto://h2o.enr.state.nc.us/ncwetlands
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Noce hCarolina
?t"ally
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Buffaloe Land Developers, LLC
Page 2 of 5
August 5, 2008
Type of Impact Amount Approved nits Plan Location or Reference
404/Wetland 0.0977 [(acres) 0.0947 acres permanent
impact, and 0.0030 acres temporary impact] PCN page 4 of 10
Stream - perennial 110 linear feet) PCN page 5 of 10
Buffers Zone 1 7,180 (square ft. PCN pages 8 and 9 of 10
Buffers Zone 2 4,605 (square ft. PCN pages 8 and 9 of 10
2. No Waste, Spoil, Solids, or Fill of Any Kind
No waste, spoil, solids, or fill of any kind shall occur in wetlands, waters, or riparian areas beyond
the footprint of the impacts depicted in the Pre-Construction Notification. All construction
activities, including the design, installation, operation, and maintenance of sediment and erosion
control Best Management Practices, shall be performed so that no violations of state water quality
standards, statutes, or rules occur.
3. Erosion and sediment control practices must be in full compliance with all specifications governing
the proper design, installation. and operation and maintenance of such Best Management Practices in
order to protect surface waters standards:
a. The erosion and sediment control measures for the project must be designed, installed,
operated, and maintained in accordance with the most recent version of the North Carolina
Sediment and Erosion Control Planning and Design Manual.
b. The design, installation, operation, and maintenance of the sediment and erosion control
measures must be such that they equal, or exceed, the requirements specified in the most
recent version of the North Carolina Sediment and Erosion Control Manual. The devices
shall be maintained on all construction sites, borrow sites, and waste pile (spoil) projects,
including contractor-owned or leased borrow pits associated with the project.
c. Sufficient materials required for stabilization and/or repair of erosion control measures and
stormwater routing and treatment shall be on site at all times.
4. Sediment and Erosion Control Measures
Sediment and erosion control measures shall not be placed in wetlands or waters without prior
approval from the Division. If placement of sediment and erosion control devices in wetlands and
waters is unavoidable, design and placement of temporary erosion control measures shall not be
conducted in a manner that may result in dis-equilibrium of wetlands or stream beds or banks,
adjacent to or upstream and down stream of the above structures. All sediment and erosion control
devices shall be removed and the natural grade restored within two (2) months of the date that the
Division of Land Resources or locally delegated program has released the project;
5. Culvert Installation
All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP
measures from the most current version of NCDOT Construction and Maintenance Activities manual
(http://www.ncdot.orgtdoh/operations/BMP manual/downloadBMP Manual.pdf)
such as sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent
excavation in flowing water.
Culverts required for this project shall be installed in such a manner that the original stream
profiles are not altered. Existing stream dimensions (including the cross section dimensions,
pattern, and longitudinal profile) must be maintained above and below locations of each culvert.
Culverts shall be designed and installed to allow for aquatic life movement as well as to prevent
buttaloe Land Uevelopers, LLI;
Page 3 of 5
August 5, 2008
head cutting of the streams. If any of the existing pipes are or become perched, the appropriate
stream grade shall be re-established or, if the pipes installed in a perched manner, the pipes shall
be removed and re-installed correctly.
Culvert(s) shall not be installed in such a manner that will cause aggradation or erosion of the
stream up or down stream of the culvert(s). Existing stream dimensions (including the cross section
dimensions, pattern and longitudinal profile) shall be maintained above and below locations of each
culvert.
Therefore, you must provide plans with adequate details that indicate that the current stability of the
stream will be maintained or enhanced. You must receive written approval from this Office for the
above plans before the culvert(s) is installed. Culvert(s) must be installed according to approved
plans.
Placement of culverts and other structures in waters, streams, and wetlands must be placed below
the elevation of the streambed by one foot for all culverts with a diameter greater than 48 inches,
and 20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow
low flow passage of water and aquatic life. Design and placement of culverts and other structures
including temporary erosion control measures shall not be conducted in a manner that may result
in dis-equilibrium of wetlands or streambeds or banks, adjacent to or upstream and down stream
of the above structures. The applicant is required to provide evidence that the equilibrium shall be
maintained if requested in writing by DWQ.
The establishment of native, woody vegetation and other soft stream bank stabilization techniques
must be used where practicable instead of rip rap or other bank hardening methods. If rip-rap is
necessary, it shall not be placed in the stream bed, unless specifically approved by the Division of
Water Quality.
Installation of culverts in wetlands must ensure continuity of water movement and be designed to
adequately accommodate high water or flood conditions.
Upon completion of the project, the Applicant shall complete and return the enclosed "Certificate
of Completion" form to notify NCDWQ when all work included in the §401 Certification has
been completed. The responsible party shall complete the attached form and return it to the
401 /Wetlands Unit of the NC Division of Water Quality upon completion of the project. Please
send photographs upstream and downstream of each culvert site to document correct installation
along with the Certificate of Completion form.
6. Diffuse Flow (DWQ Reviewed Plans)
All stormwater shall be directed as diffuse flow at non-erosive velocities through the protected
stream buffers and will not re-concentrate before discharging into the stream as identified within
15A NCAC 213.0233 (5)
In an effort to comply with the diffuse flow provision of the Buffer Rule (15A NCAC 02B
.0233(5)), you have provided the DWQ with level spreader designs received by the DWQ on July
16, 2008. The DWQ believes that if implemented, as per these plans, diffuse flow will be
achieved. However, if diffuse flow as per 15A NCAC 02B .0233(5) is not achieved, then the
DWQ shall be notified and corrective actions to restore diffuse flow shall be taken if necessary to
impede the formation of erosion gullies. At no time shall stormwater from the proposed
development be piped directly through the buffer without prior DWQ written authorization.
Buffaloe Land Developers, LLC
Page 4 of 5
August 5, 2008
The structural stormwater practices as approved by this Office as well as drainage patterns must
be maintained in perpetuity. No changes to the structural stormwater practices shall be made
without written authorization from the Division of Water Quality. Stormwater easements shall be
recorded for a distance of at least 10 feet on each side of all stormwater conveyances on all lots
containing these structures including future access for maintenance. The stormwater easements
shall allow for the ability to maintain the structures, perform corrective actions as described
above and shall provide protection of the structures from potential alternations by future property
owners.
An Operation & Maintenance (O&M) agreement signed by the current landowner must be
approved by the DWQ. This O&M agreement must transfer with the sale of the land or transfer
of responsibility for the stormwater facilities and the DWQ must be notified of every transfer.
Stormwater Management Plan Implementation Procedures (No Further Approval Needed)
• The approved SMP must be constructed and operational before any permanent building or
other structure is occupied at the site. If a development is phased, then the approved SMP for
each future phase must be constructed and operational before any permanent building or other
structure associated with that phase is occupied.
• The approved SMP as well as drainage patterns must be maintained in perpetuity.
• The SMP may not be modified without prior written authorization from the SMP approval
authority. If the SMP falls under another state stormwater program, then a copy of the
approval letter and the modified SMP must be submitted to the 401 Oversight/Express Unit
prior to the commencement of the modifications.
8. Protective Fencing
The outside buffer, wetland or water boundary and along the construction corridor within these
boundaries approved under this authorization shall be clearly marked with orange warning fencing
(or similar high visibility material) for the areas that have been approved to infringe within the
buffer, wetland or water prior to any land disturbing activities;
9. Certificate of Completion
Upon completion of all work approved within the 401 Water Quality Certification or applicable
Buffer Rules, and any subsequent modifications, the applicant is required to return the attached
certificate of completion to the 401 Oversight/Express Review Permitting Unit, North Carolina
Division of Water Quality, 1650 Mail Service Center, Raleigh, NC, 27699-1650.
Violations of any condition herein set forth may result in revocation of this Certification and may result in
criminal and/or civil penalties. The authorization to proceed with your proposed impacts or to conduct
impacts to waters as depicted in your application and as authorized by this Certification, shall expire upon
expiration of the 404 or CAMA Permit.
If you do not accept any of the conditions of this Certification (associated with the approved wetland or
stream impacts), you may ask for an adjudicatory hearing. You must act within 60 days of the date that
you receive this letter. To ask for a hearing, send a written petition, which conforms to Chapter 150B of
the North Carolina General Statutes to the Office of Administrative Hearings, 6714 Mail Service Center,
Raleigh, N.C. 27699-6714. This certification and its conditions are final and binding unless you ask for a
hearing.
Buttaloe Land Developers, LLU
Page 5 of 5
August 5, 2008
Any disputes over determinations regarding this Authorization Certificate (associated with the approved
buffer impacts) shall be referred in writing to the Director for a decision. The Director's decision is
subject to review as provided in Articles 3 and 4 of G.S. 150B.
This letter completes the review of the Division of Water Quality under Section 401 of the Clean Water
Act and the Neuse riparian buffer protection rule as described within 15A NCAC 2B .0233. If you have
any questions, please telephone Cyndi Karoly or Ian McMillan at 919-733-178641,
Si ere6?
Coleen H. Sullins
CHS/ijm
Enclosures: GC3699 and GC3705
Certificate of Completion
cc: USACE Raleigh Regulatory Field Office
Lauren Witherspoon, DWQ Raleigh Regional Office
DLR Raleigh Regional Office
File Copy
Central Files
Nicole Thomson, S&EC, P.A., 11010 Raven Ridge Road, Raleigh, NC 27614
Filename: 080580BuckhomPl ace(W ake)401 _NBR_Revised
KILPATRICK
\ STOCKTON LLP
Attorneys at Law
September 27, 2010
Suite 400 3737 Glenwood Avenue
Raleigh NC 27612
t 919 420 1700 f 919 420 1800
www.KilpatrickStockton.com
Steven J. Levitas
direct dial 919 420 1707
direct fax [phone]
[e-mail]
Justin McCorcle, Esq.
Office of Counsel
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
RE: Buckhorn Place Project
Wake County, NC
General Permit I.D. 2008-01195
Dear Justin:
SEP ? 1U
-_.`'; Soil c f rrirt;,lll:tsr?a' I I +Eti!Rt ?:.`??
I am writing on behalf of our clients Buffaloe Land Developers, LLC (`BLD") and
Buffaloe Forest, LLC (`BF") to follow up on our several phone conversations concerning the
above-referenced project ("Project").
As you know, on March 28, 2008, Soil & Environmental Consultants, P.A.
("S&EC"), on behalf of BLD, submitted an application for coverage under Nationwide
Permits 12 and 29 for certain impacts to jurisdictional waters and wetlands in connection
with the Project ("Permit Application"). The Permit Application package included the
enclosed figure showing the full proposed development plan for the Project (lot layout, road
network, stormwater management devices, etc.)(the "Site Plan"). A jurisdictional
determination for the project site ("Site"), which is owned by BF, had previously been
submitted to the Corps by Keller Environmental (the "Keller JD"), but had not been
approved by the Corps. The Permit Application identified and sought approval for
jurisdictional impacts based on the Keller JD. S&EC stated in the Permit Application that
"the applicant does not anticipate any impacts to streams or wetlands associated with
stormwater management facilities as proposed stormwater devices are outside of any
jurisdictional areas ...... Permit Application, p.6. Although the Permit Application showed
a pre-existing farm pond ("Farm Pond") on the Site being used as a stormwater management
device, S&EC made the foregoing statement based on its understanding that the Farm Pond
had not been designated as jurisdictional in Keller JD.
US2008 1575836.1
ATLANTA AUGUSTA CHARLOTTE DUBAI NEW YORK RALEIGH STOCKHOLM WASHINGTON WINSTON-SALEM
Justin McCorcle, Esq.
September 27, 2010
Page 2
On May 7, 2008, the U.S. Army Corps of Engineers (the "Corps") authorized the
proposed impacts pursuant to Nationwide Permits 12 and 29 ("Permit"). The Permit
included under the heading "Determination of Jurisdiction" the following statement:
There are waters of the US and/or wetlands within the above described project
area subject to the permit requirements of Section 404 of the Clean Water Act
(CWA)(33 USC § 1344). Unless there is a change in the law or our published
regulations, this determination may be relied upon for a period not to exceed
five years from the dare of this notification.
In recent months, questions have been raised about (i) whether the Keller JD
delineated all jurisdictional features at the Site; and (ii) whether the Keller JD designated the
Farm Pond as jurisdictional. While there may be some room for disagreement today with
respect to features at the Site other than the Farm Pond, I think it is fair to say that the Keller
JD jurisdictional calls as to those features were not clearly erroneous. In any case, the Corps
approved those calls in connection with issuing the Permit and you have agreed that the
Corps will honor those calls (provided that development is not extended to areas that were
previously shown on the Site Plan as undeveloped). Thus, the Corps agrees that any
development impacts that were shown on the Site Plan in areas not designated as
jurisdictional in the Keller JD (other than impacts to the Farm Pond) do not require a permit.
With respect to the Farm Pond, you have indicated, (i) that the Corps believes it is,
and always has been, clearly jurisdictional; and (ii) that the Corps believes the Farm Pond
was designated as jurisdictional in the Keller JD. You have further indicated that under the
circumstances the Corps will not allow impacts to the Farm Pond without a permit.
Although the consequences for the project are significant, my clients are prepared to
accept this decision by the Corps regarding the Farm Pond provided that they receive
confirmation of your commitment that the Corps will otherwise honor the jurisdictional calls
made in the Keller JD and previously approved by the Corps in issuing the Permit and will
therefore not require a permit for development impacts that were shown on the Site Plan in
areas not designated as jurisdictional in the Keller JD. As noted above, we understand that if
BLD or BF proposes to extend development into portions of the Site not shown as developed
on the Site Plan, the Corps would require a new jurisdictional delineation for those areas.
We also understand that there is uncertainty about whether a permit would be issued by the
Corps for the previously proposed impacts to the Farm Pond and we are actively exploring
options for eliminating those impacts.
U52008 1575836. I
Justin McCorcle, Esq.
September 27, 2010
Page 3
Because it is important to the consummation of transactions related to the Project, I
would appreciate it if you would confirm in writing at your earliest convenience that my
understanding of the Corps' position, as described herein, is correct.
Thanks very much for your assistance.
With best wishes,
Sincerely yours,
KILPATRICK STOCKTON LLP
Steven J. Levitas
Enclosure
cc: Pablo Reiter
Morgan Bryan
Kevin Martin
US2008 1575836.1
Buckhorn Place
Nikki Thomson
From: Kevin Martin
Sent: Wednesday, September 29, 2010 11:10 AM
To: Nikki Thomson
Subject: FW: Buckhorn Place
Attachments: McCorcle Letter.PDF
see below
Page 1 of 2
From: McCorcle, Justin P SAW [mailto:[e-mail]]
Sent: Wed 9/29/2010 11:01 AM
To: Levitas, Steve
Cc: Pablo Reiter; [e-mail]; Kevin Martin; Jolly, Samuel K SAW; Manuele, Jean B SAW; Shern,
James F SAW
Subject: Buckhorn Place
Steve, thanks for the letter. If this email will suffice, I can confirm that
your letter, dated Sept 27, 2010, and attached herein, accurately reflects
the Corps' understanding of the situation, and proposed path forward. If you
need anything further, let me know.
Justin P. McCorcle
Assistant District Counsel
U.S. Army Corps of Engineers
Wilmington District
69 Darlington Avenue
Wilmington, NC 28403
[phone] fox: x4044
THIS EMAIL MAY CONTAIN PRIVILEGED INFORMATION; PLEASE CONTACT SENDER BEFORE
RELEASE
-----Original Message-----
From: Levitas, Steve [mailto:SLevitas@kilpatrickstockton_com]
Sent: Tuesday, September 28, 2010 2:00 PM
To: McCorcle, Justin P SAW
Cc: Pablo Reiter: '[e-mail]': Kevin Martin
Subject:
Justin -- This went in the mail to you yesterday. As we have discussed, I
would appreciate getting your confirmatory response at your earliest
convenience. Thanks very much for your help. Steve
<http://www.kil a?trickstockton.com/> <htti??-//www.ki?-qtrickstockton.com/>
Kilpatrick Stockton
LLP<htt ://www.kilpatrickstockton.com/imaqes/sici/kslocio-color tag sia.aif>
9/29/2010
Suckhorn Place
Steve Levitas
Kilpatrick Stockton LLP
Suite 400 13737 Glenwood Avenue I Raleigh, NC 27612
office 919 420 1707 1 cell 919 749 2953 1 fax [phone]
[e-mail] <mailto:[e-mail]>
My Profile
<http://www.kilpatrickstockton.com/en/Who%20We%2OAre/Professionals/L/LevitasS
tevenJ12450.aspx>
Confidentiality Notice:
This communication constitutes an electronic communication within the meaning
of the Electronic Communications Privacy Act, 18 U.S.C. Section 2510, and its
disclosure is strictly limited to the recipient intended by the sender of
this message. This transmission, and any attachments, may contain
confidential attorney-client privileged information and attorney work
product. If you are not the intended recipient, any disclosure, copying,
distribution or use of any of the information contained in or attached to
this transmission is STRICTLY PROHIBITED. Please contact us immediately by
return e-mail or at 404 815 6500, and destroy the original transmission and
its attachments without reading or saving in any manner.
'DISCLAIMER' Per Treasury Department Circular 230: Any U.S. federal tax
advice contained in this communication (including any attachments) is not
intended or written to be used, and cannot be used, for the purpose of (i)
avoiding penalties under the Internal Revenue Code or (ii) promoting,
marketing or recommending to another party any transaction or matter
addressed herein.
Page 2 of 2
9/29/2010
10/25/2010 11:17 FAX [phone] TERRAMOR
4
-
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Subs
Govemor Director
0001/004
Dee Freeman
Secretary
October 12, 2010
CERTY>NM MAIL #70081300 000011312852
RETURN RECEIPT REQUESTED
Buffaloe Forest, LLC
Attn: Pablo Reiter
6404 Falls of Neuse Road, Suite 103
----
Subject: NOTICE OF CONTINUING VIOLATION
NOTICE OF INTENT TO ENFORCE
NOV-2010-PC-1084
DWQ Project # 2008-0580
Construction Stormwater General Permit NCGO 10000
Neuse River Riparian Buffer Violations
Other Waste (in-stream sediment) Violation
35.84124 N, -78.50883W
Wake County
Dear I& Reiter:
On September 30, 2010 and October 14, 2010, Lauren Witherspoon from the Raleigh Regional Office of
the Division of Water Quality (DWQ) conducted site inspections at Buckhorn Place, a tract of land
located south of Buffaloe Road and between Old Milburnie Road and Forrestville Road, in Wake County,
North Carolina. The streams on the site are unnamed tributaries to the Neuse River, Class C, Nutrient
--- Sensitive Waters (NSW), in the Neuse River Basin.
Accordingly, the following observations were noted during the DWQ file review and site inspections.
A stormwater general permit (NCGO 10000) is issued upon the approval of an Erosion and Sedimentation
Control Plan. This permit applies to projects that receive a Division of Land Resources (DI,R) (or
designated local program) Erosion and Sedimentation Control Plan Approval Letter for lan disturbance
of 1 acre or greater. Specifically, the general permit (NCGO 10000) authorizes the discharge of
stormwater under the National Pollutant Discharge Elimination System in accordance with Title 15A
NCAC 2H.0100. Buckhom Place has an approved Erosion and Sedimentation Control Plan (issued by
the City of Raleigh) and is therefore covered under the NCGO 10000 permit.
North Carolina Division of Water Quality
service
Internet; www,ncwaterqualily.org
Raleigh Regional Ofrice
1(128 Mail SwAce Center
L;g?
Q
Surface Water Protection Phone [phone] Customer
Raleigh. NC 2709-1828 FAX [phone].823$748
An Equal Opportunhy/AA9nnetive Action Employer - 50% Recy01edH09y Post Consumer Paper
10/25/2010 11:17 FAX [phone] TERRAMOR 9002/004
Buckhorn Place
Page 2
During the September 30, 2010 and October 14, 2010_ site inspections, sediment was observed outside of
the limits of disturbance below Sediment Basin 1. This sediment was observed in approximately 2,000
sgaure feet of Neuse River riparian buffer measuring between 2-9 inches in depth. Diffuse flow was not
being. maintained at this lcoation below the outfall. The stream at this location also contained sediment
deposition for approximately 50 Imear feet measuring between 1-5 inches of depth.
As a result of the site inspection and file review, the following violations, described below, are noted:
Item L Construction Stormwater General Permit (NCG010000)
Conditions
Part H, Section B. No. 12
Projects and their corresponding activities permitted under the previous version of the NC general permit
for construction activities are covered under this general permit. The requirements for these projects are
the same as those previously required in the general permit until the project is completed or terminated.
Part I, Section B. No. 5
If any visible sedimentation is leaving the site or entering a water of the state, corrective on-site action
shall be taken immediately to control the discharge of sediments. Where visible deposition of sediment
has occurred in surface waters or wetlands, the permittee must contact the Division within 24 hours of
becoming aware of the deposition.
Item IL Nense River Riparian Buffer Violations
The Neuse River Basin is subject to the riparian (streamside) buffer rules covered under North Carolina
Title 15A NCAC 02B .0233., The purpose of these rules is to protect and preserve riparian buffers in the
Neuse River Basin that help protect surface water by removing nutrients from overland flow. The North
Carolina buffer rules apply to areas immediately adjacent to surface waters which include intermittent
streams, perennial streams, lakes, ponds, and estuaries.
The protected riparian buffer has two zones: Zone 1 is measured from the stream bank landward for 30
feet. Zone 2 is measured an additional 20 feet landward from the outer edge of zone 1. Both Zone 1 and
Zone 2 consist of a stable vegetated area that is undisturbed except for activities and uses provided for in
item (6) of 15A NCAC 2B.0233 (4).
10/25/2010 11:18 FAX [phone] TERRAMOR Q003/004
Buckhom Place
Page 3
Neuse Buffer - Diffuse Flow -.15A NCAC 02B.0 . 233 (5) (a) & (b) requires that
Diffuse flow of runoff shall be maintained in the riparian buffer by dispersing concentrated flow
and reestablishing vegetation.
(a) Concentrated runoff from new ditches or manmade conveyances shall be converted to diffuse
flow before the runoff enters Zone 2 of the riparian buffer.
(b) Periodic corrective action to restore diffuse flow shall be taken if necessary to
. impede the formation of erosion gullies.
Item IIL Other Waste Cm-stream sediment) Violation
15A NCAC 02B .0211(3)f
Oils; deleterious substances; colored or other wastes: only such amounts as shall not render the waters
injurious republic health, secacidary_reFreation or to aquatic life,?d e-Or?versely-aswt the
palatability of fish, aesthetic quality or impair the waters for any designated uses.
Requested Response
You are directed to respond to this letter in writing to DWQ at the address provided below within 15
days of receipt.
1. Construction Stormwater General Permit (NCGO10000) Requirements -
a. 'Explain in your response why DWQ was not notified of the sediment depostion in the
buffer and stream channel in accordance with our 24 hour reporting requirement.
b. Please provide DWQ with the last 3 months of written records of the daily rainfall
amounts and inspection records of erosion comtol measures.
2. Sediment impacts _ Sediment impacts to the stream and buffer must be removed. As a part of
this plan, you should provide the amount (depth) of material that has been deposited in the buffer
and stream. This information should be depicted on a map you provide. It is recommended that
you use hand labor (buckets, shovels and wheelbarrows) to remove deposited sediment from the
stream and buffer. The sediment should be removed from the stream and buffer, taken to high
ground away from the stream channel (and riparian area) and stabilized. Also, the plan must
address the measures that will be used for temporary stabilization/scdiment control while this
work is under way.
3. Please indicate in your response a detailed schedule with dates explaining when the site will be. in
compliance.
4. Outstanding violations noted in the August 30, 2010 DWQ NOV:
a. DWQ expects that the after-the-fact buffer authorization request for Basin 1 buffer
impacts will be submitted to-DWQ within 45 days of the date of your letter (September
29, 2010) or November 15, 2010.
b. The turbidity issues on the site appear to be a continuing problem with regard to the
properties downstream of Basin 2. If you continue to be in noncompliance with the City
of Raleigh, DWQ will continue to sample the'areas downstream of Basin 2 and will
additionally sample downstream of Basin 1 for stream standards (turbidity) compliance.
10/25/2010 11:19 FAX [phone] TERRAMOR Ia004/004
Buckhorn Place
Page 4
Submit Reauested Items To:
Lauren Witherspoon'
DWQ Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Thank you for your attention to this matter. This office requires that the violations, as described above,
be properly resolved. These violations and any future violations are subject to a civil penalty assessment
of up to $25,000.00 per day for each violation.
Should you have any questions regarding these matters, contact Lauren Witherspoon at (919) 7914200.
Sincerely,
Danny Smith
Regional S sar
Surface Water Protection Section
cc: Raleigh RO - Water Quality
John Hennessy, NPS Assistance and Compliance Oversight Unit
Ian McMillan, 401 Wetlands Permitting Unit, 1650 MSC, Raleigh, NC 27604
USACE Raleigh Regulatory Field Office
Ben Brown - City of Raleigh
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