20060922 Ver 2_More Info Received_20070205

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January 30, 2007
' ~ Div-sbh} of?~Vater Quality
401 Wetlands Certification Unit
2321 Crabtree Boulevard, Suite 250
Raleigh, North Carolina 27604
Attention: John Dorney

Reference: Request for Additional Information
Airport Road Retail Shopping Center
Buncombe County, NC
DWQ Project # 06-0922
Dear Mr. Dorney,
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This letter is intended to provide additional information requested by your office
in a letter dated January 16, 2007 regarding the project referenced above.
Waste Treatment Facilities
Stormwater
• The project will utilize awetlands-type retention basin and will be designed in
strict accordance with the requirements of Buncombe County and NC DENR.
Attached is a memo from Freeland and Kauffinan, Inc. summarizing the Storm
Water Management Design.
Wastewater
• The site will tie into existing sewer lines, so all wastewater will be treated by the
Metropolitan Sewerage District of Buncombe County, NC.
Mitigation Plan
An onsite mitigation meeting took place October 11, 2006 with NCDENR,
USACE, FWS, and NCWRC. Based on discussions regarding the proposed mitigation
plan, we revised the plan to eliminate the priority 2 stream restoration in favor of stream
enhancement and spot stabilization, due to the lack of buffer available. We have revised
the wetland mitigation by eliminating the onsite wetland creation in favor of utilizing the
Ecosystem Enhancement Program (EEP). A complete revised on-site mitigation plan is
included for your review. Monitoring reports will be submitted to both the USACOE and
NC DWQ for review.
Avoidance and Minimization
Included in Appendix A are five site layouts. The first layout is the original site
plan submitted in the permit application, dated May 8, 2006. The second layout is the
P.O. Box 3744 Greenville, South Carolina 29608 [phone] Fax [phone]

first alternative explored, previously referred to as Alternative 1. This layout was
originally submitted August 11, 2007. The third layout is the second layout that was
explored, previously referred to as Alternative 2. This layout was originally submitted
October 24, 2006. The fourth layout is the one requested in your letter dated January 16,
2007, in which the store is relocated and reoriented to the NE. Finally, the fifth layout is
of the current proposed site plan. Each layout is addressed below individually:
Layout 1-Original Site Plan:
The original site plan submitted involved impacting 1.93 acres of Waters of the
US for commercial development. The plan called for approximately 110,000 to 120,000
c.y. of imported clean fill material, due to the significant difference in elevation between
Airport Road and the site. The site plan included a retaining wall along the northern
portion of the proposed development in order to avoid impacts to "Stream 1 ".
Layout 2 -Alternative 1:
In the first alternative layout, the use of two retaining walls did allow for an
overall reduction of wetland impacts by a total of 0.37 acres, however, due to the
relocation of the stormwater detention basin, the alternate site layout also impacts 742
linear feet of stream. The stormwater management needs to be located at a lower
elevation than the developed area. Therefore, the logical locations for the ponds are at the
lowest points on the property. If the area behind the western retaining wall was utilized
for a detention pond, it would still be necessary for a second pond in order to meet the
detention requirements for the site. Storm drain would have to be punched through the
retaining wall and be routed to the proposed pond. In order to install the storm drain, a
fair amount of wetlands would still have to be impacted. Thus impacts would exist on
the stream as well as the western wetland area "D". The configuration of the ponds on
the alternative layout shows the least amount of impact possible.
Due to the required grading, the retaining wall near the western property
boundary would incur a significant increase in cost when compared to the northern
retaining wall. The overall cost of both retaining walls for the alternate site layout is
approximately $1.8 million dollars, while the cost of the northern retaining wall by itself
is $260,000. From a strictly economic standpoint, the $1.5 million (592% increase in
cost) is not viable for the scope of the project and represents a dramatic increase in
overall cost.
Layout 3 -Alternative 2:
This alternative involves rotating the building so that the side is oriented toward
Airport Road and utilizing the out lots as satellite parking with a span over Wetland "E".
As you can see from the site plan, the re-orientation of the building and the spanning of
Wetland "E" does not allow for adequate parking or access to the front of the building.
Commercial centers are required by law to provide a certain number of handicapped
parking spaces with easy access to the front of the store for patrons with disabilities. In
addition, extensive retaining walls would be necessary, along with the span for Wetland
Area "E". This layout would not be feasible due to the lack of adequate parking, lack of
adequate access to the front of the store and additional costs associated with abridge/span
and the multiple retaining walls needed to avoid impact to "Wetland Area E". Based on

the initial lack of feasibility, this alternative was not pursued further with regards to
preliminary engineering plans, stormwater plans, grading, etc.
Layout 4 -Alternative 3:
The third alternative layout looks at rotating the building and relocating it towards
the northeast corner of the property. With this site plan, the northern entrance drive is
significantly shorter, thereby necessitating that the overall finished elevation of the
development be higher in order to keep the drive at an allowable slope. In the proposed
site plan, the drive drops down at a 6% slope over a much longer distance. With this site
plan, the slope would increase to 8% and the finished elevation would rise by 20 feet. By
increasing the finished elevation by 20 feet, the overall amount of imported fill material
required jumps from approximately 110,000 - 120,000 c.y. to somewhere on the order of
400,000 to 500,000 c.y. By using the conservative estimate of $7.50/c.y. provided by the
engineer and using the difference between the estimated 120,000 c.y of fill required for
the proposed project and the estimated 400,000 c.y. of fill required for this layout, the
cost difference would be a minimum of $2.1 million dollars. Clearly, this would be cost-
prohibitive for this project.
In addition to the added cost of fill material, the cost of the retaining walls would
increase dramatically, as they would now be significantly higher. The retaining wall
separating the development from Stream 1 would now be approximately 45 feet tall along
the rear of the store, at least twice as tall as what was originally proposed. As with
Alternative 1, the cost of the retaining walls makes the project non-viable.
Furthermore, because the overall elevation must be raised in this plan, the fill
slopes become much larger along the back of the project. The height of the fill slopes
requires that it be graded out at a 3:1 ratio, rather than transitioning to a 2:1 ratio as in the
proposed site layout. This results in greater overall impact, specifically with the largest
wetland, Wetland C.
In this layout, the outlots have remained as it was not possible, due to the shape of
the property, to place the store any closer to the corner of the property without impacting
the stream. Also, please note that Wal-Mart does not allow parking past the mid-point of
their building when it would be isolated from the main parking field, across major access
and service drives, or when it will be hiddden from view by the building due to safety
considerations. Therefore, it would not be possible to use the outlots as additional
parking in order to reduce the amount of parking elsewhere.
Layout 5 -Revised Site Plan:
The revised site plan reduces the overall impervious surface to approximately
16.7 acres. By pulling back along the northern portion of the proposed development, the
new site plan stays off of stream to avoid impact without the use of a retaining wall.
Eliminating the need for the original retaining wall without increasing impact, the
developer was able to shift the wall to the back of the development and further reduce
impacts to the largest wetland onsite, Wetland C. The result is a reduction of 0.14 acre of
impact. Under the revised site plan, the total proposed impacts to Waters of the US

equals 1.78 acres. Additionally, please note that the outlots do not require stream
impacts.
All in all, the applicant has avoided and minimized impacts to Waters of the US to
the maximum extent practicable. Alternatives were considered thoroughly prior to
submitting the present design and relying on compensatory mitigation. I hope that this
addresses all your comments and concerns regarding this project and we can proceed in a
timely fashion. If you have any questions, please call me at [phone]. Thank you
for your assistance in this matter.
Respectfully,
Laura Belanger
Environmental Permitting Consultants, Inc.
Cc: Tom Walker, USACOE
Mike Ranks, Freeland and Kauffinan, Inc.

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