20070026 Ver 1_More Info Received_20070531

LM G
LAND MANAGEMENT GROUP Irrc.
Environmental Consultants
May 29, 2007 ~ ~ v ~ O `~' ~ D
MAY 3 }~ X007
TO: Mr. Brad Shaver o~ , W~TEa Ou~iTY
U.S. Army Corps of Engineers N~E1lANl~ANDSTClAll~ihTERiRAN(~~
P.O. Box 1890
Wilmington, NC 28402
RE: Additional Information for Individual Permit Application
Surf City Market; Pender County, NC; Barnett Properties LLC & Wilco-Hess LLC
Action ID# 200600589; DWQ #070026; DCM# 20070001
Dear Brad:
Thank you for your letter dated April 17, 2007 in which you provide comments received
during the Public Notice review period for the Surf City Market project. Comments were received
from the Corps, U.S. Fish and Wildlife Service, and NC Wildlife Resources Commission.
Comments from the NC Division of Coastal Management and the NC Division of Water Quality
were received separately. Below is a response to each of these agencies' comments.
U. S. Army Corps of Engineers
1. The alternatives analysis defines specific criteria used to identify potential sites, which includes a
minimum size of thirty acres. However, at least three of the off site alternatives you identified were
less than thirty acres and two sites were not zoned for the desired use. Therefore, there appears to
have only been one site that was thoroughly evaluated as part of the off site alternatives analysis. It
is our understanding that along Highway 17, there are several large parcels advertised for sale,
and it would seem that there would be more than one site which would meet the search criteria. It
appears that the search criteria may be too focused on a small geographic area, or may not have
taken all available parcels into consideration. Please further explore off site alternatives, and
explain more thoroughly your search criteria, and reasons for eliminating off site parcels.
Several off site and on site alternatives were described in the Project Narrative, which was
submitted with the Individual Permit application. The specific criteria listed at the beginning of the
alternatives analysis meant to give a brief synopsis of reasons why the subsequent tracts were not
accepted as the preferred site.
During the site selection process, a geographic boundary limited to the Highway 17 corridor, 10-
miles in each direction of its intersection with Highway 210, was established to define the trade area
that the applicant is attempting to serve. Within this geographic boundary, the two most important
criteria evaluated by the applicant from both an economic and functional standpoint were those sites
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served by water and sewer infrastructure and those sites with established traffic infrastructure.
Primary traffic infrastructure included existing road intersections with Highway 17 and existing
traffic signals. While there may be properties for sale along Highway 17, if they were not within the
immediate access of an intersection they were not considered because lack of traffic infrastructure
would make the sites both economically and functionally unfeasible. Those properties within direct
access to an intersection but did not have access to water and sewer infrastructure were also given
very little consideration. Given the absence of water and sewer infrastructure, commercial
development of this magnitude is a public health risk on a well and septic system. Furthermore, a
self contained wastewater system for a single site is economically unfeasible. The preferred site is
located at a major intersection (Highway 17 and Highway 210) within the trade area and is able to
connect to an existing lift station positioned along Highway 210.
2. The on site alternative analysis explores the two extreme ends of possible wetland impacts. First,
the no impact alternative recognizes that with no wetland impacts, outparcels, office space and up
to two medium sized retail spaces would still be viable. This option however is discounted because
of its low marketability. The property sits at a major cross roads leading to a barrier island beach
community and just miles from the exploding south Pender area along highway 17. The site is also
across the street from a major retail business; it does not appear that marketability would be an
issue. It would seem that the no impact alternative, or something very close to it, would be the. least
environmentally damaging practicable alternative which our process requires us to choose. If you
disagree please provide additional evidence as to why this alternative is not practicable. Such
evidence should include an economic analysis that demonstrates the minimum practicable project.
The `No Wetland Impact Alternative' would contain three small outparcels, up to eighteen small
office units, and two medium-sized retail/commercial buildings. As you noted, this tract is at a
prime location and the applicant would quickly be able to lease andlor sell these units. However, the
income generated from this limited design would not cover the land costs, construction costs, and
long-term costs associated with financing this project over a number of years.
To divide this shopping areas up into smaller, only upland tracts will 1) be inconvenient to the
residents, 2) be bad town planning because of expensive demand for the extension of water and
sewer infrastructure of the Town of Surf City to more isolated areas, 3) cause the ambiance of this
section of US 17 to be one continuous strip mall of small buildings, and 4) deny residents
convenient access to large scale retailers that require large buildings and large parking lots.
3. The other end of the spectrum is the option which discusses more wetland impact with the
additional residential component. In our experience, such an option would be highly unlikely to
receive a permit, and is not a viable demonstration of minimization. In our opinion, the two
alternative options you have provided do not show that you have adequately minimized impacts
onsite. An onsite alternative should be discussed that reduces the size of development on the tract
which would significantly reduce the proposed wetland impact. Additionally, d~erent
configurations of buildings, d~erent traffic flaw patterns, and possible reductions in parking
spaces should each be considered in order to provide adequate minimization.
Based on concerns received from the commenting state and federal agencies, a new site plan has
been developed that reduces wetland impacts (enclosed). Total proposed wetland impacts have been

reduced from 7.09 acres to 4.58 acres. This is a 35% reduction in wetland impacts. The developer
has reduced the total square footage of the commercial/retail space to approximately 225,000 sq. ft.
The site plan now contains reduced minimum parking requirements. The major retail building
contains five (5) spaces per 1,000 sq. ft. of building. The remaining shopping center has been
reduced to approximately 4.5 spaces per 1,000 sq. ft. of building. Specifically, Retail Building A
located along US 17 has been reduced to two (2) separate 8,000 sq. ft. buildings resulting in a net
square footage loss of 26,350 sq. ft. In addition, Retail Building B has been reduced by
approximately 14,800 sq. ft. The total shopping center thus has been reduced by 41,150 sq. ft. This
reduction in square footage will result in a loss of approximately $650,000 of rental income. With
the addition of two (2) new bridges, the anticipated construction cost has risen by approximately $1
million. The developer is now at a breakeven point for a financially viable project. In order to make
up for the rental income loss, the developer plans to ground lease anticipated outparcels. The
projections show total income from the ground leases to approach $500,000. Returns are considered
minimal for the amount of risk associated with the development of this size.
Please note that the applicant has put a great deal of time and energy into redesigning the site plan
to reduce wetland impacts as much as financially possible. Several draft plans (enclosed) were
developed and discounted because they found additional ways to further reduce impacts. The
proposed site plan represents a breakeven point for a financially viable project.
4. Finally, once the unavoidable wetland impact is established, more discussion needs to be given to
the mitigation. Regulatory policy requires that on-site or near site mitigation should be explored
before off-site alternatives are considered. There needs to be a better attempt to provide mitigation
in the area where the wetland loss will occur. By going to the NC EEP program there is a
guarantee the restoration would occur in the same HUC but no assurance that the restoration will
occur near the site or even east of Highway 17. We suggest that you explore other mitigation
alternatives If no other alternatives are shown to be available, you may be required to mitigate at a
higher ratio to compensate for the expected distance of the mitigation project from the wetlands
impacted by your project.
LMG staff evaluated one potential mitigation site located several miles from the project area, near
the intersection of Highway 17 and Highway 210 W. This site had received a permit to fill wetlands
several years ago. An investigation of this site found very little wetland disturbance and was not
suitable for restoration mitigation. Furthermore, the owners were not interested in selling the tract
for use as preservation mitigation. Therefore, this site cannot be used for potential mitigation for the
project. No other off site mitigation opportunities were identified within Pender or Onslow
Counties.
To mitigate for impacts, both on-site and off-site mitigation is now proposed. The wetland fingers
on site are divided by three historical, filled road crossings leading to an existing residence. The
applicant will remove two of the three road crossings, which will restore the historic flow patterns
in this area. An alternative roadway has been provided to the residence through the parking lot
planned for retail center. This will restore 0.10 acre of wetlands. In addition, the applicant will
preserve all remaining wetlands on the property (16.95 acres) utilizing the Corps' standard language
for preservation. The applicant is currently preparing the draft preservation language. In addition,
the applicant will buy into the EEP to mitigate for the balance of wetland impacts (4.48 acres).

NC Wildlife Resources Commission
1. The NCWRC does not support the filling of wetlands to generate high ground for development
and arty required permit authorization will receive a recommendation for denial unless the project
has significant public bene, fits and all wetlands or aquatic habitat impacts are fully mitigated. To
fully mitigate for wetland impacts, we recommend that the EEP buy-in credits be in the Pender or
Onslow County portion of the Cape Fear River Basin. We also recommend that language
consistent with U. S. Army Corps of Engineers (USAGE) guidelines be used in the conservation
easement for the preservation of remaining wetlands. These prohibit cutting, pruning, mowing, or
burning of vegetation; construction of any kind; use of herbicides; arty land disturbing activities;
dumping or storing of soil, trash, or other waste; and the pasturing, grazing or watering of animals,
or any other agricultural or horticultural purpose within wetlands.
Based on input from town and County officials, the applicant believes that this project is desired by
the residents and governmental entities of Surf City and Pender County. As stated in the Project
Narrative, this project will meet the goals of the Strategic Plan of the Town of Surf City. One of the
stated goals of this plan is to "Improve the availability of business services for residents and
visitors." Currently, there are limited shopping facilities for this growing community and many
residents must travel to Hampstead or even Wilmington to do their shopping. This project will also
create jobs for the community.
The proposed mitigation plan has been modified and now contains both on-site and off-site
mitigation. The applicant proposes to restore 0.10 acre of wetlands on site by removing two road
crossings and will preserve all remaining wetlands on the property (16.95 acres) utilizing the Corps'
standard language for preservation. The applicant is currently preparing the draft preservation
language. In addition, the applicant will buy into the EEP to mitigate for the balance of wetland
impacts (4.48 acres).
2. The applicant has not chosen the least environmentally damaging alternative in the selection of
the preferred alternative stating that it is infeasible to develop the property without wetland
impacts. Additionally, the applicant has not explored another on-site alternative that would impact
less wetland habitat. Retail Building B is located such that some of the highest functioning
wetlands on-site are to be filled. The elimination of Building B would eliminate approximately 3
acres of wetland impact. This would likely require less parking in the adjacent parking lot, further
reducing wetland impacts. We recommend the elimination of Retail Building B and arty required
associated parking from the project.
Based on concerns received from the commenting state and federal agencies, a new site plan has
been developed that reduces wetland impacts to 4.58 acres (enclosed). Retail Building B has been
moved to protect existing wetlands and parking has been reduced. Please see response to Corps
comment #3 for additional information.

US Fish and Wildlife Service
1. As part of the section 7 analysis, the Corps should require information from the applicant
regarding the presence of older pine stands and actual survey results for the RCW in arty stands of
older pines The section 7 determination of the Corps should also address the endangered rough-
leaved loosestrife. At this time, the Service recommends that the applicant provide the Corps with a
statement regarding habitat for RLL on the site. The Venus flytrap is a federal species of concern
and has current occurrence records in the Holly Ridge quad. It is listed as significantly rare in the
state. As a FSC, this plant does not receive the protection of the ESA. As a part of any vegetation
survey, the presence of Venus flytrap should be recorded. If present, this o, ffice should be notified.
There may be opportunities to relocate these plants.
On April 20th, 2007 and May 17, 2007, staff of Land Management Group, Inc. evaluated the Surf
City Market project area for its potential to support federally-listed threatened or endangered
species. Habitat with the potential for supporting listed species was identified by reviewing aerial
photographs, soils maps, and topographic maps of the property and by walking throughout the site.
As stated in the Project Narrative, a search of the North Carolina Natural Heritage Program
database was conducted to identify areas within or around the site that are already known to support
federally-listed species. No rare species were noted within or surrounding the tracts (1/z mile radius).
Most of the site is forested, except for a few small areas that have been previously developed
(Figure 4). These developed areas have been converted into residences and contain several homes
and sheds. A small dirt road cuts through the wetlands located on the southern part of the tract to
provide access to these structures. The wetlands that form the southern and eastern project boundary
contain a very dense assemblage of pond pine (Pimss serotina), loblolly bay (Gordonia lasianthus),
wax myrtle (Myrica cerifera), gallberry (Ilex glabra); and cat briar (Smilax laurifolia). The forested
areas near Highway 17, both uplands and wetlands, have been mowed in previous years and support
a sparse canopy of longleaf pine (P. palustris) and loblolly pine (P. taeda) trees with little or no
shrub layer. The pines trees range in size from 4" diameter at breast height (DBH) to 18" DBH. A
ditch approximately 3' deep runs southeast from Highway 17 between two wetland fingers and may
have some drainage effect on the adjacent wetlands. Uplands located further away from Highway
17 contain younger and thicker stands of longleaf and loblolly pine trees with scattered titi (Cyrilla
racemiflora} and loblolly bay shrubs. Surrounding land use consists of Highway 17 to the
northwest, Highway 210 to the southwest, scattered residential development to the south and
southeast, and undeveloped land to the east.
The red-cockaded woodpecker (RCW) is generally found in old-growth pine forests and prefers
mature longleaf pines with at least a 15" DBH for nesting and foraging. Dense stands (stands that
are primarily hardwood, or that have a dense hardwood understory) are avoided. In mature pine
habitat, sufficient substrate can be provided on SO to 125 acres. Some of the mowed areas adjacent
to Highway 17 contain mature pine trees with little or no shrub layer and could provide appropriate
habitat for the RCW. All large (>12" DBH) pines that were encountered on the tract were inspected
for RCW cavities. No cavities orred-cockaded woodpeckers were observed during the survey.
Both the rough-leaved loosestrife and the Venus flytrap prefer moist habitats that are exposed to

sunlight. Most wetland areas within the tract are too thickly vegetated to support these species.
However, wetlands and transitional areas located adjacent to Highway 17 have been mowed and
could provide appropriate habitat. During the survey, approximately fifty Venus flytraps were
observed in a small cleared area located along the wetland boundary of the long wetland finger that
leads from Highway 17 to the southern part of the tract. Approximately 100 sundew plants were
also observed in this area. No rough-leaf loosestrife plants were observed on the site.
The site plan has been revised to avoid the wetland area that contains many of these rare
carnivorous plants. The Venus flytrap plants that are located in adjacent uplands that will be
disturbed will be relocated to the wetland area prior to any land disturbance activities.
2. A true alternatives analysis should include a time line on the Town's application for the Rural
Economic Development Center Grant and the extent to which the grant application specified the
shopping center at the US 17/NC 210 intersection. Since the water/sewer connection appears to
have dictated the location of the shopping center and this connection was dependent on the grant, a
meaningful alternatives analysis should focus on the details and timing of this grant. If is
determined that the preferred site was pre-determined by the grant to provide water/sewer service
to that site, then there is no point to an alternatives analysis after the granting of these funds.
According to information obtained from the Town and their engineer, this grant application was
submitted in November of 2006 and acted upon by the Rural Center Board in February of 2007. Of
the development planned for the intersection of Highways 17 and 210, the grant application
specified only the Harris Teeter project. The Surf City project will tie into an existing lift station
located off of Highway 210. The applicant will be financially responsible for upgrading the lift
station and connecting to it. The applicant had no previous knowledge of this grant.
3. There should also be consideration of minimizing wetland impacts by using parking decks rather
than having all parking spaces at grade. The use of just one elevated parking level would reduce
wetland impacts and allow more open ground for the infiltration of stormwater.
Parking decks are not considered feasible for several reasons. Parking decks are significantly more
expensive to build than parking lots at grade. Furthermore, parking decks would negatively impact
the marketability of the shopping center because they reduce the visibility of shops. However, based
on concerns received from the commenting state and federal agencies, a new site plan has been
developed that reduces wetland impacts by reducing the size of several buildings and minimizing
parking spaces (enclosed). Total proposed wetland impacts are now 4.58 acres. Please see response
to Corps comment #3 for additional information.
The applicant's stormwater plan controls the first 1'/2 inches of any rain event to provide for TSS
and other pollutant removal and will discharge cleaner waters to recharge the wetland areas. Please
note that the revised site plan includes a retention pond near the wetlands located off of Highway
17. Treated stormwater will be discharged into these wetlands to ensure continued wetland
hydrology.
4. Finally, the restored wetlands for compensatory should be located in an area where they could
serve to replace the functions and habitat values of those lost. Since the wetlands in the project area

serve as the headwaters of a tidal creek, the restoration wetlands should have the same location in
the landscape. The DA permit should not be issued until the NCEEP has agreed to accept this
mitigation obligation within the geographic restrictions recommended in these comments.
Please see the response to Corps' comment #4.
NC Division of Coastal Mana eg ment
1. A full range of alternatives to the proposed 275, 000 square foot commercial center has
apparently not been considered. The three on-site alternatives presented consist of 1) no wetland
impacts, 2) the proposed project that would result in impacts to approximately 7 acres of wetlands
and 3) a maximum development proposal. While the No Wetland Impact Alternative would be most
consistent with 1 SA NCAC 07M .0700 and 1 SA NCAC 07M .0800 other alternatives could still be
developed for minimizing impacts to wetlands. One such alternative, for example, would be a
proposed project that would be smaller in scope than the proposed project. This alternative would
fit between the No Wetland Impact Alternative and the Proposed Project Alternative.
Based on concerns received from the commenting state and federal agencies, a new site plan has
been developed that reduces wetland impacts to 4.58 acres (enclosed}. Please see response to Corps'
comment #3 for additional information.
Z. Additionally, it appears that the No Wetland Impact Alternative may not have been resourcefully
designed to maximize its development potential within the context of no wetland impacts. For
example the statement is made in the No Wetland Impact Alternative analysis that "Multiple
driveways off of Highway 17 would be needed to provide access to these buildings.... Furthermore,
the multiple driveways off of Highway 17 would make it cumbersome to access the site, creating a
hazardous traffic situation. " A review of Figures 12 and 13 appear to show the same number of
driveways. Also if multiple driveways are needed for a smaller project, why would multiple
driveways for a larger project that generates even more traffic be considered acceptable? We
request that the design of the No Wetland Impact Alternative be reconsidered.
Please see response to Corps' comment #2.
3. The Wetlands Functional Assessment for the proposed project is inadequate. While the functional
assessment notes certain facts, such as 96.7 trees per acres at sample point 1 and that certain areas
are more degraded than other areas, there is no substantive analysis/conclusion that the project site
possesses "high' versus "low" habitat value. Thus it is unknown whether the proposed project
would or would not have a sign cant adverse impact on habitat. We request that the functional
assessment be revised to evaluate the proposed project on habitat values and conclude whether the
proposed project would or would not have a sign cant adverse impact on habitat values.
It was noted in the Wetlands Functional Assessment that the report had limitations and was only
meant to give a general comparison between the wetlands to be impacted and the wetlands to be
preserved. Since that report was prepared, it has been determined that part of the mowed area near
Highway 17 contains Venus flytraps and sundews and has additional ecological significance. The

applicant has redesigned the site plan to avoid this wetland area. The revised site plan also reduces
impacts to wetlands located closer to Virginia Creek and the existing road crossings in this area will
be removed to further improve this system.
NC Division of Water Quality
1. Impact Justification (Practical Alternatives and Avoidance & Minimiaation)
In accordance with ISA NCAC 02H .0506©(1)0, a lack of practical alternatives may be shown by
demonstrating that, considering the potential for a reduction in size, configuration or density of the
proposed activity .and all alternative designs the basic project purpose cannot be practically
accomplished in a manner which would avoid or result in less adverse impact to surface waters or
wetlands. DWQ has determined that you have not demonstrated that there is no practical
alternative to filling 7.04 acres of wetlands for the purpose of constructing the proposed
commercial development. Furthermore, it appears that an economically feasible project could be
built at the proposed location with less wetland impacts.
On-site alternatives discussed in the application (one with 10 acres of impacts and a residential
development and one with no impact) do not convey all of the practical alternatives for the site. It
appears that reducing and reconfiguring to office/retail space depicted "Retail B" on the Figure 13
Site Plan will result in a reduction of wetland impacts. Please reevaluate the proposed site plan for
the project and submit additional reasonable alternatives for consideration. Remember to account
for all permanent and temporary impacts associated with utilities.
Based on concerns received from the commenting state and federal agencies, a new site plan has
been developed that reduces wetland impacts to 4.58 acres (enclosed). Please see response to Corps
comment #3 for additional information.
2. Mitigation
The application proposes mitigation with EEP and has not evaluated available sites in the local
area for mitigation purposes. The DWQ concurs with the USACE and would like to see proposals
for local mitigation sites. Please note that DWQ does require a minimum of 1:1 restoration of
creation as part of the mitigation plan. When the USACE and DWQ agree with the mitigation plan,
all proposed conservation language and associated maps must be submitted to this office before a
401 Water Quality Certification can be issued.
Please see the response to Corps' comment #4.
3. NPDES General Stormwater Permit No. NC GOI0000 Monitoring Requirements
Upon approval of an Erosion and Sedimentation Control Plan issued by the Division of Land
Resources (DLR) or a DLR delegated local erosion and sedimentation control program, an NPDES
General stormwater permit (NCG010000) administered by DWQ is automatically issued to the
project. This General permit allows stormwater to be discharged during land disturbing
construction activities as stipulated by conditions in the permit. If your project is covered by this
permit, full compliance with permit conditions including the sedimentation control plan, self-
monitoring, record keeping and reporting requirements are required. Please provide a written

narrative explaining how you intend to comply with this Permit and who will be delegated to
inspect the site and maintain required rain gauge and monitoring reports.
The applicant will include this monitoring in the contractor's scope of work to ensure that it is
completed.
I hope this response adequately addresses all agency comments. Please contact me if you have any
additional questions. Thank you for your assistance with this project.
Sincerely,
Kim Williams
Encl.
C: Mr. Hall Barnett, Barnett Properties LLC
Mr. Steven Williams, Wilco-Hess LLC
Mr. George House
Mr. Hill Rogers
Mr. John Kuske
Mr. Steven Everhart, NCWRC
Mr. Howard Hall, USFWS
Mr. Stephen Rynas, NCDCM
Mr. Ian McMillan, DWQ
Ms. Joanne Steenhuis, DWQ

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