20060652 Ver 2_More Info Letter_20070309

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 9, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7006 2150 0005 2459 7254
Mr. John E. Clarke, Assistant Vice President
Wal-Mart Real Estate Business Trust
2001 South East 10~' Street
Bentonville, AR 72712
Subject: Airport Road Retail Shopping Center
Unnamed tributary to French Broad River
DWQ # 06-0922 version 2
Buncombe County
On March 5, 2007, Division of Water Quality staff (Kevin Barnett, Asheville Regional Office and John Dorney,
Raleigh Central Office) conducted a site visit at the proposed Wal-Mart site on Airport Road in Buncombe
County, NC. The purpose of the site visit was to examine the presence and quality of wetlands and streams on
the property, to discuss stream and wetland mitigation and on-site stormwater management as well as
alternative site plans for the property. Present were Dave McHenry with the NC Wildlife Resources
Commission as well as Richard Bates and Laura Belanger with Environmental Permitting Consultants, Inc. The
following issues are listed that need to be addressed in order for us to complete action on the required 401
Water Quality Certification for this project. Until we receive answers for the following issues, this project will
remain on hold as incomplete in accordance with 15A NCAC 2H .0506.
1. Alternate Site Plan -Please see the attached sketch entitled "DWQ Alternative Design, March 5,
2007". The Division believes that this plan (or a slight alteration thereof) is a practical site plan that
minimizes impacts to the large central wetland on the property while allowing construction of the
Wal-Mart, parking equivelant to the proposed plan, an outparcel and possible commercial
development of the southwest corner of the property. We are aware that development of the
southwest corner of the site may require impact of the smaller wetland/stream in that area and are
willing to discuss possible site plans in that regard.
One concern raised by your consultants with regard to this site plan is that Wal-Mart reportedly has a
policy to prevent parking on the side of your stores more than one-half the length of the building.
However, we believe that this policy must be flexible since the new Wal-Mart at RiverBend
Shopping Center in Asheville has parking at least three-quarters down the side of the building. The
amount of parking shown on our alternative plan is about the same amount shown on the applicant
preferred plan but we are not able to measure it precisely. If additional parking is needed on the site,
it may be possible to widen the connection between the larger parking lot and the one shown on the
side of the building in order to have more spaces. If some, small additional wetland fill is needed for
this parking, we are willing to discuss this issue with your consultants.
Nose Carolina
~tura!!y
North Carolina Division of Water Quality 2090 U.S. Highway 70 Swannanoa, NC 28778 Phone [phone] Customer Service
Internet www.ncwaterquality.org FAX [phone]
An Equal OpportunitylAffirmative Action Employer - 50% Recycled110% Post Consumer Paper

Airport Road Retail Shopping Center
Unn~ med tributary to French Broad River
DWQ # 06-0922 version 2 -
Buncombe County
Page 2.
Another concern raised by your consultants is the grading that would be needed on the site and
concerns about balancing cut and fill on the site. Division staff believe that the proposed plan would
minimize the need for extensive site grading and note that the site presently is at the level of Airport
Road. Therefore location of the building and parking lot closer to Airport Road should require less
cut and fill overall.
In summary, we believe that this alternative site plan is practical and would clearly reduce the
amount of wetland fill on the site to less than one acre. If wetland fill is less than one acre, then the
Division will not require compensatory wetland mitigation but we understand that the US Army
Corps of Engineers will still require mitigation for the reduced impacts to the wetlands on the site
(see item three below).
2. Stormwater management -The present plan for stormwater management is to construct a "wetiands-
type retention basin" according to the August 9, 2006 letter from your engineers (Freeland and
Kaufmann, Inc. - Mr. Michael Ranks). According to the description in this memo, you are basically
planning to construct wet detention ponds with littoral shelves as required by DWQ's Stormwater
Design Manual.
3. Compensatory mitigation
a. Stream mitigation -The present plan to restore the hydrology of the channel that flows along
the northern property boundary is acceptable to the Division. We suggest that a fence be
constructed along the property line to help control trash dumping into the stream. In
addition, please be sure that DWQ and the US Army Corps of Engineers are copied on the
mitigation plan and annual reports.
b. Wetland mitigation - As noted above, impacts to wetlands would be much less than one acre
with the proposed alternative site plan. Therefore if this plan is implemented, DWQ will not
require compensatory wetland mitigation. However we understand that the US Army Corps
of Engineers will still require compensatory wetland mitigation. We believe that it may be
possible to provide on-site enhancement of the large, central wetland by directing treated
stormwater to flow at non-erosive velocities into the wetland. From our field visit, the upper
end of the wetland appears to be somewhat drier than expected. We believe that rewetting
this area with the treated stormwater will enhance the hydrology and water quality function
of the wetland and then may serve as adequate compensatory mitigation for the reduced
impact. If the Corps is able to accept this approach as mitigation, then a payment of about
$88,553 to the NC Ecosystem Enhancement Program for mitigation would not be needed.
We have had initial discussions with Tom Walker of the US Army Corps of Engineers
concerning this approach and if you would like to pursue this approach to mitigation, please
have your consultants contact him directly. If we can assist in this discussion, please let us
know as well.
x,

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Airport Road Retail Shopping Center
Unnamed tributary to French Broad River
DWQ # 06-0922 version 2
Buncombe County
Page 3.
In summary, we believe that a revised site plan (as outlined above and shown on the attached sketch plan)
would greatly reduce impacts to the large, central wetland on the site. In addition, direction of treated
stormwater to the remaining wetland will both serve to keep the wetland wet and possibly serve as
compensatory mitigation through enhancing the hydrology and water quality value of the wetland. In order for
DWQ to complete our review of the 401 Water Quality Certification for this project, please give provide a
thorough analysis of this approach to the Division within two weeks of receipt of this letter. If you have any
questions, you can reach John Dorney in Raleigh at 919-733-9646 or Kevin Barnett in Asheville at 828-296-
4657. Thank you in advance for your careful consideration of these matters.
Sincerely yours,
®_
Kevin Barnett, DWQ Asheville Regional Office
' -
~,~ John Dorney, DWQ Raleigh Central Office
Cc: Tom Walker, US Army Corps of Engineers, Asheville Field Office
Dave McHenry, NC Wildlife Resources Commission
Laura Belanger, Environmental Permitting Consultants, Inc., P.O. Box 2346,
Hendersonville, NC 28793
Richard Bates, Environmental Permitting Consultants, Inc., P.O. Box 3744,
Greenville, SC 29608
File copy
John Dorney, DWQ Raleigh Central Office
Central files

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