20120887 Ver 2_More Info Received_20130502

LMG
LAND MANAGEMENT GROUP nic.
Environmental Consultants
April 26', 2013
TO: Ms. Emily Greer
U.S. Army Corps of Engineers
2407 West Fifth Street
Washington, NC 27889
1a,- og8*1 V2.
FILE COPY
RE: Individual Permit Application; Response to Comments
Epiphany School of Global Studies Expansion; New Bern, NC
Action ID# SAW- 2009 -00906
DWQ Project No. 12 -0887 v2
Dear Ms. Greer:
2013
Thank you for your comments received during the Public Notice for the Epiphany School of
Global Studies Expansion project located in New Bern, NC. In addition to the ACOE, comments were
received from the NC Division of Marine Fisheries, NC Wildlife Resources Commission, NC Division
of Water Quality, and an adjacent property owner. Below is a response to each of these comments.
ACOE
1. Please provide data to support the statement that there would be greater impacts to wetlands on
other sites identified in your alternatives analysis.
LMG does not have permission from landowners to ground truth the limits of wetlands on these
alternate sites. As stated in the project narrative, the assertion that significant wetlands and/or stream
exist on these sites is based on aerial photographs and soils maps (Figures 5 -7). The NRCS Soils
Survey for Craven County has mapped Alternate Site #1 as Arapahoe fine sandy loam, which is very
poorly drained soils. It is found on broad flats and in depressions on stream terraces. Typically, the
surface layer is black fine sandy loam 16 inches thick. Furthermore, the topographic map for this site
shows a blue line feature (Lawson's Creek) that runs through the middle of the site. This feature is
visible on the aerial photograph (Figure 6). The NRCS Soils Survey has mapped Alternate Site #2 as
Masontown mucky fine sandy loam and Muckalee sand loam, which are very poorly drained soils and
is mainly in depressions on the broad floodplains (Figure 7). The USGS topographic map (New Bern
quadrangle) also shows a blue -line feature running through it. Enclosed is a topographic map of both
of these sites.
2. Please provide information regarding avoidance and minimization of impacts to wetlands and
RPWs as it relates to the project layout. This should also include alternative project layouts that
avoid or minimize impacts.
Once the specific project location was determined, several site plans were evaluated. Many iterations
were developed that moved the fields in various positions, but only the preferred project fits both
fields. The applicant also evaluated the potential of constructing only one field within the tract. It
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appears a football field could be constructed with under 0.5 acre of wetland impacts. However,
students would still need to utilize the County's baseball /softball fields. This alternative does not
satisfy the applicant's overall goal of providing a full range of recreational opportunities on site for its
students. Therefore, this alternative was not considered feasible.
The applicant also evaluated the possibility of overlapping the baseball and football fields (Alternative
B enclosed). This alternative attempts to avoid approximately one acre of wetlands located in the
center of the tract. However, it is unworkable. It would be impossible to maintain the baseball infield,
the most difficult portion of the field to establish and the most expensive to maintain while it is
contained in the track and sideline area of the football field. This also creates a problem with finished
grades on both fields and it is impractical for safe play. Additionally, the bases of the baseball infield
are typically supported by a clay foundation since they receive a great deal of traffic. It would not be
safe for football players to have sections of their field underlain with a hard clay foundation.
The final alternative that was considered (Alternative C enclosed) swapped the location of the baseball
and football fields and would reduce wetland impacts by approximately 0.4 acre. It would require a
shortening of the baseball centerfield, which is impractical with modern high school hitting distances.
In as much as track and baseball seasons coincide at the high school level, it could easily create a
safety issue for the runners if both teams have an event on the same day. In addition, it encroaches on
the sewer lift station area. Construction activity in this area risks a sewage spill into the adjacent
ditches, which should be avoided in any way possible. It is also possible that spectators at the outfield
fence could create damage to the area as well. The location of the bleachers, in addition to being
inconvenient for spectators, may interfere with the proposed plan to split the drainage outfall from the
facility between the (2) crossing pipes under HWY 70 to avoid any chance of overwhelming the
drainage outfall capacity.
The preferred project (Figure 8) offers the most practical juxtaposition of the proposed fields and the
track. The regulations regarding the size of a high school football field dictate its dimensions. The
recommended sideline areas for bench players, coaches and chain crews insure the safety of all
concerned. This location offers the ability to add additional bleachers at the west end of the field in the
event that visitors and home team spectators need to be separated or if the program flourishes and
additional seating is required.
The placement of the track fits perfectly surrounding the football field for the 440 yards typically seen
at track and field events. It also provides a safe separation between the field assets from spectators and
prevents interference with runners via perimeter fencing. The site will require fill throughout and the
south side will require considerable back slope distances to allow for safe ambulatory grades adjacent
to the facility and the required maintenance practices. With the finished grade at the estimated 15'
above sea level, back slope distances at the south perimeter will approach 20'.
The baseball field is designed at close to minimum feasible distances down the foul lines for high
school baseball due to the use of aluminum bats. The infield dimensions are dictated by regulation and
cannot be changed if they are to comply. Unlike a football field, a baseball field requires an
orientation that keeps the sun from being a hindrance to batters and fielders. This is a safety issue as
well as a fairness issue. The field requires a suitable distance between the actual foul lines and the
spectators to allow for dug outs and warm up areas for relief pitchers. This location also allows for
spectator seating in lawn chairs along the home team foul line. The grading of the field must be
exacting to allow for safe play and drainage. Otherwise, a small amount of rain can result in conditions
that are unplayable or unsafe. The same back slope issues apply to both fields.
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3. Please provide financial information supporting the 'burden' of utilizing the county recreational
facilities versus construction of the proposed project.
Below is a breakdown of costs associated with using off -site facilities for JV and Varsity baseball,
including rental of facilities and transportation. Because of the lack of facilities, girls' softball has been
discontinued for the time being and rental and transportation costs associated with it are not included.
The baseball season lasts approximately 17 weeks with practice daily except day games. Please note
these expenses do not include travel for away games, which would occur whether the proposed project
moves forward or not.
Rent (Craven County Parks and Recreation) $700.00
Rent Batting Cage $2500.00
Van Transportation* (JV Team only) $5891.00
Mileage Expense Reimbursement (Varsity) $2882.00
Total Annual Expense Baseball $11,973.00
*Includes gas, insurance, oil changes, depreciation.
When factoring in land and construction costs, the proposed project would be many times more
expensive than the annual costs of the off -site baseball program. However, the school was able to
secure a benefactor for the expansion, which they do not currently have for the annual off -site sports
program costs. Additionally, the expansion would allow other sports programs to be added to the
school's curriculum, thereby allowing it to better compete with area schools and allowing growth of
their student body.
4. Please provide an explanation as to why this expansion was not considered during the initial
conception of the school or its expansion when their stated goal is to expand to a 300 count student
body with low tuition cost.
The Epiphany School is a private school and any future goals for its growth is based on current
financial supporters. At the time of the initial conception of the school and during the construction of
the Trent Road building, the financial resources to construct additional recreational facilities did not
exist. Additionally, the adjacent parcel was not for sale. Since that time, donors have been established
and the financial means to complete the project are in place.
S. In greater detail, please address the scheduling difficulties for existing sports opportunities as well
as the programs that are 'sorely lacking' under the current circumstances.
With the proposed expansion, the school will alleviate severe scheduling difficulties for existing sports
opportunities of lacrosse and women's and men's soccer. Currently, all of these activities are forced to
share the one existing soccer field. The men's soccer season runs between August and November.
However, the seasons for women's soccer, women's lacrosse, and men's lacrosse all occur between
February and May, which makes scheduling practices and games difficult. If they are allowed to
proceed with the proposed expansion, the football and baseball fields will allow for more frequent and
more equitable practice sessions. It is important to offer equal opportunities for both young women and
young men to enjoy the unique benefits of organized athletics.
Sports programs that are currently lacking include football, track & field (they currently only have a
cross country team), and, as mentioned previously, the girls' softball program has recently been
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discontinued. With additional fields, it is anticipated that softball would begin again. The development
of these additional sports programs is essential to creating a diverse and robust student body.
6 Please provide a statement addressing the adjacent property owner's concerns regarding
additional flooding on their property.
The adjacent landowner submitted pictures of standing water on her property and cited concerns that
the project may exacerbate flooding issues. We attempted to contact her to determine when the pictures
were taken so that we could better understand what type of rainfall event resulted in ponding and how
long this ponding persisted. But we did not receive an answer. It appears that this area is the
elevational low spot for the property owner's subdivision (Trolley Run). A site visit to this area found
drainage swales in the front and side of the lot that empty into the wetlands in the southeast corner of
the project area. This water then flows to the NC DOT drainage way that runs along Highway 70. It is
possible that the NC DOT drainage way needs to be cleaned out or otherwise improved. It is also
possible that ponding only occurs after exceptionally heavy rainfall events, which temporarily
overwhelm the NC DOT drainage way.
The existing school was a redevelopment project and actually decreased impervious cover when it was
constructed compared to the previous development. The proposed expansion would consist mainly of
grassy fields and would create little impervious cover (less than 25% of the site). The project would be
considered low density and would comply with all applicable best management practices. A drainage
plan utilizing grassy swales will be developed. These swales will tie into existing ditches on site, which
will then funnel water off site. The proposed drainage plan will not impede flow from adjacent
properties.
NC Wildlife Resources Commission
We believe further avoidance and minimization could be demonstrated...... The wetland impacts at the
proposed baseball field and football field could be minimized by not filling the area outside the
immediate field area, by constructing only one field, or by relocating the athletic facilities. Our
concerns involve the total amount of wetland fill as well as concern for runoff into Lawson Creek and
standing water after storm events once the vegetation is cleared and impervious surfaces are
increased.
Please see our response to the ACOE comment #2 above.
NC Division of Marine Fisheries
The NCDMF recommends that the applicant further reduce wetland impacts by designing additional
site layout alternatives. These alternatives include multipurpose fields such as combining the football
and baseball fields on the proposed baseball site. By moving the football field, it may be possible to
minimize wetland impacts by avoiding the western portion of the wetlands as well as the water feature
in the middle of the wetlands.
Please see our response to the ACOE comment #2 above.
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NC Division of Water Qualily (401 and Stormwater)
Title 15A NCAC 02H. 0506 requires avoidance and minimization to the maximum extent practical of
all surface water impacts. Combining the existing soccer field and proposed football field together on
the existing soccer field site would greatly reduce proposed wetland impacts. Please revise the plans to
minimize the impacts or provide documentation as to why the existing soccer field and proposed
football field cannot be combined together on the existing soccer field site.
The soccer and football fields cannot be combined for several reasons. First, a high school football
field must be 360 feet in length, which includes a 300 -ft long field and two 30 -ft end zones. The
existing soccer field is only 330 feet in length and there is no room to expand this. Tennis courts are
located just west of the soccer field. Therefore, a football field cannot fit perpendicular to the existing
field. Additionally, a track is proposed around the football field. This track would not fit around the
soccer field and would have to be eliminated. Finally, the seasons of football and men's soccer both
occur in the fall. Scheduling practices for soccer and football would be very difficult.
It appears that the project will trigger at least one of the triggers for Stormwater Management
Permitting.
The proposed percentage of impervious cover from this project would be less than 25% of the site and
would be considered low density. The applicant will contact DWQ's Stormwater Division to determine
what type of approval is necessary to move forward.
We hope this response adequately addresses the agencies' concerns and the applicant can move
forward with permitting. Please note that the contact person with the Epiphany School has changed.
The Interim Headmaster is now Mr. David Wayne. All other contact information is the same. Please
feel free to give me a call if you have any additional questions. Thank you for your assistance with this
project.
Sincerely,
Kim Williams
Encl.
Cc: Mr. David Wayne, Epiphany School of Global Studies
Mr. Bud Stilley, Tarheel Building Systems, Inc.
Ms. Karen Higgins, NC DWQ
Mr. Roberto Scheller, NC DWQ
Mr. Stephen Rynas, NC DCM
Ms. Maria Dunn, NC WRC
Mr. Kevin Hart, NC DMF
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3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403

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