20161072 Ver 2_More Info Received_20210812

Strickland, Bev
From: Sydni Law <[e-mail]>
Sent: Thursday, August 12, 2021 2:06 PM
To: Cohn, Colleen M
Cc: Goss, Stephanie; Matt Michel
Subject: [External] RE: Leighson Landing
Attachments: Leighson Landing - RAI Response.pdf
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Good afternoon Colleen,
Please find attached our response to the Request for Additional Information regarding the Leighson Landing buffer
authorization application. Please let us know if you have any additional comments or concerns regarding this project.
Best,
Sydni Law, WPIT
Environmental Scientist
TIMMONS GROUP I www.timmons.com
5410 Trinity Rd, Suite 102 I Raleigh, NC 27607
Office: [phone] I Fax: [phone]
Mobile: [phone]
[e-mail]
Your Vision Achieved Through Ours
From: Cohn, Colleen M <[e-mail]>
Sent: Thursday, July 22, 2021 3:37 PM
To: Sydni Law <[e-mail]>
Cc: Goss, Stephanie <[e-mail]>
Subject: Leighson Landing
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Sydni,
I am currently reviewing the application for the above reference project and in order to complete the review process,
some additional information is required:
1. Page 8 of 18 carries the signature of Sydni L. Law. In order for Sydni to sign, the application package requires an
agent authorization letter from the owner. A sample agent authorization letter can be found on the USACE
website. (http://www.saw.usace.army.mil/Portals/59/docs/regulatory/regdocs/Permits/SAMPLE AGENT AUTH
ORIZATION FORM.pdf). [15A NCAC 02H .0502(a)(11)]
1

2. Please provide more details regarding avoidance and minimization of Zones 1 and 2 impacts for this
project. [15A NCAC 02H .0502(b)(1)] This Office believes that the SCM Conveyance labeled on the plans as
Impact 1 can be moved or reconfigured to avoid the impacts to the riparian buffer. The plans included for the
prior Buffer Authorization Application for this project, DWR #16-1072 submitted November 4, 2016, showed the
SCM Conveyance to the north of the SCM Conveyance indicated in the new application. The previous
Authorization Certificate dated November 17, 2016 approved 202 square feet of impacts in Zone 2 compared to
the proposed 51 square feet of impact to Zone 1 and 684 square feet of impact to Zone 2. I have attached a copy
of the 2016 Authorization Certificate for your convenience. Please revise the plans to avoid the impacts or
provide a detailed explanation of why this plan for the activity cannot be practically accomplished, reduced or
reconfigured to avoid impacts to Zone 1.
Thank you in advance.
Colleen Cohn
Environmental Specialist II
Division of Water Resources
Raleigh Regional Office
380o Barrett Drive
Raleigh, NC 27609
Office: 919-791-4258
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2

ENGINEERING | DESIGN | TECHNOLOGY
5410 Trinity Road
Suite 102
Raleigh, NC 27607

P 919.866.4951
F 919.859.5663
www.timmons.com

August 12, 2021

Colleen Cohn
NCDEQ – Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609

Re: Response to Requests for Additional Information
Leighson Landing
USACE AID: SAW-2021-00877
NBRRO #21-133
(Approx. 1.66 acres)
Wake County, North Carolina

Dear Ms. Cohn,
On behalf of Geff Rucker Homes, we are providing a response to the Request for Additional Information
(RAI) email received on July 22, 2021 for Leighson Landing, an approximately 1.66-acre site located south
of Poole Drive and west of Aversboro Road in Garner, Wake County, North Carolina (the Site).
The revised Impact Maps have been attached showing adjustments to Riparian Buffer Impact 1, including
reduction in the Limits of Disturbance (LOD) to reduce the amount of total Zone 2 riparian buffer impacts
from 684-sq.ft. to 374-sq.ft. and eliminate all Zone 1 buffer impacts. Further, Zone 2 buffer impacts have
been called out as temporary (300-sq.ft.) and permanent (74-sq.ft.).
The comments are outlined below in italics and are grouped by impact, with DWR comments in green. Our
response is below each comment.
1. Page 8 of 18 carries the signature of Sydni L. Law. In order for Sydni to sign, the application package
requires an agent authorization letter from the owner. A sample agent authorization letter can be found
on the USACE website.
A copy of the Agent Authorization form dated March 2, 2021 and signed by Geff Rucker,
representative of GFR Properties, LLC, the deeded property owner of the Site is included below.
Per the signed agreement, representatives of Timmons Group are granted permission to act on the
behalf of the signee.
2. Please provide more details regarding avoidance and minimization of Zones 1 and 2 impacts for this
project. [15A NCAC 02H .0502(b)(1)] This Office believes that the SCM Conveyance labeled on the
plans as Impact 1 can be moved or reconfigured to avoid the impacts to the riparian buffer. The plans
included for the prior Buffer Authorization Application for this project, DWR #16-1072 submitted
November 4, 2016, showed the SCM Conveyance to the north of the SCM Conveyance indicated in
the new application. The previous Authorization Certificate dated November 17, 2016 approved 202
square feet of impacts in Zone 2 compared to the proposed 51 square feet of impact to Zone 1 and 684
square feet of impact to Zone 2. I have attached a copy of the 2016 Authorization Certificate for your
convenience. Please revise the plans to avoid the impacts or provide a detailed explanation of why
this plan for the activity cannot be practically accomplished, reduced or reconfigured to avoid impacts
to Zone 1.

Upon further review, due to utility and roadway layout and alignment restrictions, the SCM depicted
in the southwestern corner of the site cannot be moved if the project’s goals are to be realized.
The site plans have been revised to reduce the extent of the project’s LOD, which includes required
silt and tree protection area fencing, within the riparian buffer area to minimize impacts to the
maximum extent practicable (see attached Figure 7 – Wetlands and Waters Impacts Map).
Reduction of the LOD has decreased the proposed Zone 2 buffer impacts from 684-sq.ft. to 374-
sq.ft. and eliminated Zone 1 buffer impacts altogether. Of the 374-sq.ft. of proposed Zone 2 buffer
impacts, 74-sq.ft. are proposed permanent impacts resulting from riprap dissipater pad and
stormwater conveyance installation. The remaining 300-sq.ft. of proposed Zone 2 buffer impacts
will be temporary, with the area being stabilized and revegetated following completion of the work.

Please review the updated Impact Maps and contact Sydni Law at [phone] or
[e-mail] if additional information is required.

Sincerely,
Timmons Group

Sydni Law, WPIT
Environmental Scientist

Matt Michel, PWS, PhD
Senior Environmental Scientist

02 March 21
[phone]
[e-mail]
1418 Aversboro Road, Suite 105
Garner, NC 27529-3981