20201374 Ver 1_More Info Received_20210920

Southern Environmental Group, Inc.
5315 South College Road, Suite E, Wilmington, NC 28412
Ph: [phone] · Email: [e-mail]
1

20 September 2021

Via Electronic Mail

US Army Corps of Engineers (USACE)
Wilmington District
Attn: Mr. Brad Shaver
69 Darlington Avenue
Wilmington, NC 29403
[e-mail]

NCDEQ – Division of Water Resources (DWR)
401 & Buffer Permitting Branch
Attn: Mr. Rick Trone
512 N. Salisbury Street, Suite 942-F
Archdale Building
Raleigh, NC 27604
[e-mail]

Re: Response to USACE and DWR request for additional information – 704/706 South Second Street,
Carolina Beach, New Hanover County, USACE AID: SAW-2019-00908; NC DWR Project #20201374
Dear Brad and Rick,
Thank you both, for your review and subsequent request for additional information (RFAI), as well as your input
during our conference call, regarding the application for permanent, wetland impacts, at the above referenced site.
Since that time, SEGi and the Applicant have had discussions with the Town of Carolina Beach (Town) regarding the
proposed project. The outcome of those meetings resulted in the Town specifying the road’s length would need to
extend to the southern property line of 706, and the width would need to be 20’, as if we were connecting to South
Second Street (see Attachment 1). Therefore, the site plan has been revised to reflect these changes (see Attachment
2).
SEGi and the Applicant believe, based on your comments and guidance information, as well as discussions with the
Town of Carolina Beach, are offering the following responses, for your consideration:
USACE RFAI dated 24 June 2021:
1. EPA comments submitted to the USACE via email dated 11 June 2021:
A) The EPA recommends that the applicant further consider off site alternatives to reduce the amount of
wetlands necessary to meet the overall project need. Such alternatives should include reducing the
project size, to fit another currently owned property (one duplex instead of two) or change the project
location (could the project purpose be met elsewhere).
With regard to fitting the project on another currently owned property, the Applicant intends to build single
family structures upon the other lots he currently owns.
As for other off site considerations, SEGi researched 17 additional undeveloped lots, that are available for
acquisition. The price of these lots ranged from $209,000 to $2,500,000. The least expensive lot (i.e., Lot 11)
is located within a private community, wherein duplexes are not permitted, and the most expensive lots (i.e.,
704/706 South Second Street Response to Agencies’ RFAI SEGi
Lots 1 and 17) is either too large (i.e., 3 acres) or is not within walking distance of shops and the beach. Lot’s
6 and 7 are believed to be comprised of wetlands, while the remaining lots are too expensive to make the
project economically viable, once you take into consideration the cost of acquiring the land and construction.
The following is a list estimated costs, for the proposed project:
Land: $20,000
Civil Site Work: $60,000
Permitting: $8,000
Structures: $1,151,500
Mitigation: $94,418
Total: $1,333,918
Constructing the proposed structures, on one of the remaining 15 lots, would cost the Applicant, at the very
least, $60,000 more than the proposed plan. This estimate is based upon the asking price of the least expensive
lot (i.e., $225,000) that meets required criteria. Therefore, moving the project to another location in not
economically feasible. The Avoidance and Minimization document has been updated to include the evaluation
of these lots (see Attachment 3).
The proposed duplexes are to serve as long term rentals for the foreseeable future, but it is the Applicant’s
intention to leave the dwellings to his children, for their use as either permanent residences, vacation homes
or continued rental income. SEGi researched five different rental agencies (i.e., Zillow, Intracoastal Realty,
Bryante Real Estate, Sea Coast Realty, and Rent.com) who list long term rentals, in the Carolina Beach area.
There were four rental units available, within Carolina and Kerr Beaches. Of the four listed, one was a duplex,
and one was a single family house, the others were multi-family residences (i.e., apartments or condos). Based
on SEGi’s research, there is a definite need for housing, in this area.
B) Beyond a more reasonable look at off-site alternatives, the EPA believes additional minimization can be
realized reducing wetland impacts by as much as 50% over the current plan (i.e., building 1 duplex
instead of 2).
The Applicant explored constructing three units, on the one combined lot. However, that would require
rezoning the property to multi-family, which allows for higher density. During a phone conversation with Mr.
Jeremy Hardison, with the Town of Carolina Beach Planning and Zoning Department, it is unlikely rezoning
would be approved, as it would be inconsistent with the Town’s desire to limit high density development, in
the area, which is supported in the Town’s approved 2019 CAMA Land Use Plan, which has the area
designated as single family (see Attachment 4). Additionally, while building only one duplex, instead of two,
would significantly minimize impacts to wetlands, the proposed plan better meets the Applicant’s stated
purpose and need. Therefore, this option was rejected.
C) Finally, the EPA has requested a functional assessment of the wetlands to better explain why the
mitigation offered may be appropriate once avoidance and minimization has been satisfied.
The wetland area to be impacted is mostly comprised of Phragmites australis (see Attachment 5), an exotic,
invasive species that has choked out the naturally occurring, herbaceous vegetation that once was prevalent.
Based on the lack of vegetative diversity and location (i.e., surrounded by development) of the wetland, the
feature’s main function is to provide flood storage. To further demonstrate the functional value of the wetland
to be impacted, SEGi conducted a NC Wetland Assessment Method (WAM) evaluation, which resulted in
having a “Low Functional Value” (see Attachment 6). That being the case, it is of SEGi’s opinion that the
USACE’s required 4:1 mitigation to impact ratio is more than sufficient to offset the loss of function that is
anticipated to take place as a result of the proposed project.
2. As part of the National Environmental Policy Act (NEPA) process and as required by 404(b)(1) guidelines
the project purpose needs to be established. The applicant’s stated purpose disclosed in the Public Notice
was “to construct two residential duplexes, with access road, driveways, and maintenance corridors to meet
local market demand”. The Corps agrees with the EPA and finds this purpose and need statement to be too
704/706 South Second Street Response to Agencies’ RFAI SEGi
restrictive and does not allow for a reasonable range of alternati ves. A better purpose and need statement
would be similar to what the EPA proposed as “ to provide housing to meet market demand”.
The purpose and need statement should be as follows:
The purpose of this project is to provide dwellings, within an area where housing is in high demand.
3. According to the 404 b(1) guidelines for processing a permit request, when the proposed discharge does not
require siting in a special aquatic site or is not water dependent to achieve its basic purpose, practicable
alternatives not involving special aquatic sites are presumed available unless clearly demonstrated
otherwise. The second rebuttable presumption is that practicable alternatives not involving special aquatic
sites are presumed to have less adverse impact on aquatic ecosystems unless clearly demonstrated otherwise.
It is conceded that the project is not water dependent and therefore the need for the alternative analysis. I
have reviewed the information and have generated some additional questions regarding the alternative
analysis.
A. To satisfy the second rebuttable presumption please either redesign the project to further minimize
impacts or explain why additional minimization is not practicable. If no additional avoidance is
deemed practicable, then it seems reasonable to have smaller building footprints for the individual
lots thus increasing minimization.
During the conceptual planning process, the Applicant explored putting either 6 tiny houses, 8 condos, 1
tri-plex, or 4 townhomes on the property. However, these types of development are considered either a
“subdivision” or “multi-family”, under the Town’s development code.
Had the Applicant proposed 6 tiny houses (i.e., “subdivision”), a cul-de-sac or other designed turn-around
would be required. By limiting the proposed development to one duplex per lot, thereby keeping the
development under single family development standards, the Applicant avoided 3,700 SF of wetland
impact (see Attachment 7, for road options).
As discusses previously, any multi-family proposal would require rezoning the property, which is unlikely
to be approved, due to the Town’s desire to limit density, in this area, and it being inconsistent with the
Town’s approved 2019 CAMA Land Use Plan.
As for impacts associated with lot development, the size of the structures is in harmony with those that
have recently been constructed, in the immediate area. Please keep in mind, each unit is only 17.5’wide,
which requires the structures be longer and taller, in order to achieve the square footage needed to provide
at least 4 bedrooms, pre unit. The proposed structures are at the max height (i.e., 50’) allowed under this
zoning and area. However, the Applicant was able to incorporate retaining walls, along each side of the
driveways, and redesigned the structures, by moving the storage closets and stairs, toward the center of
the dwellings, thereby allowing the fill to terminate at the end of the structures. These efforts have reduced
Area B wetland impact by approximately 1,625 SF (0.04 AC) and RPW impacts by 160 SF (0.004 AC).
Please see Attachment 2, for the revised site plan.
In summary and as a result of keeping the development single-family and modifying the building design,
the Applicant minimized wetland impacts by 5,455 SF (0.13 AC), for the overall project.
B. The Corps is disagreeing with the applicant’s stated purpose and need for the NEPA analysis and
therefore contends the stated purpose offered by the EPA is better used to explore the full range of
alternatives required. By placing one building per lot, it’s conceivable that impacts may be
minimized further and still meet the purpose of the project. There are numerous lots nearby that
have single family residences and therefore one residence per lot would appear to meet local market
demand. If you disagree with this assessment, you will need to demonstrate why a smaller building
footprint would not be practicable.
See responses to 1B and 3A.
C. Also, another aspect of the current design could be altered to minimize wetland impacts through the
shared driveway. The current plan calls for separated drives that isolate a small section of wetlands
704/706 South Second Street Response to Agencies’ RFAI SEGi
between the drives. This separation does not isolate the wetlands and cause them to be non-
jurisdictional, but it’s been this office’s experience the wetlands will be impacted, and functions
reduced being surrounded by impervious surfaces. The Corps encourages the revised plans to design
a shared drive along the shared property lines eliminating the current wetland separation.
The Applicant explored a shared driveway, but wetland impacts were about the same as the proposed plan
(see Attachment 8). Additionally, due to the fact that the proposed structures are duplexes, on two separate
lots, one shared driveway would not be practicable, as it would create liability issues. Lastly, the main
function of the wetland is the storage of flood water, it is of SEGi’s opinion that the segregated wetlands
will provide that same function after the project has been completed. Therefore, this option was rejected.
4. As proposed in the public notice, alternate ideas were formulated to provide on -site permittee responsible
mitigation but were not finalized at that time our public notice was issued. Please follow up on the current
and final mitigation plan once the avoidance and minimization of the wetlands has been resolved.
The Applicant has exhausted his search for properties that are for sale and within close proximity to the project, to
offset the proposed impacts. Therefore, mitigation will be fulfilled through payment to the Lower Cape Fear
Umbrella Mitigation Bank (LCFUMB) (see Attachment 9).
NC DWR RFAI Via Email Dated 24 June 2021:
1. Please clarify if the ditch depicted on the plans is considered Waters of the U.S. and/or Waters of the State.
If the ditch has been determined to be Waters of the U.S. and/or Waters of the State, please enumerate all
impacts. If the ditch was determined to NOT be waters of the U.S. and/or Waters of the State, please provide
appropriate documentation [15A NCAC 02H .0502(c)].
The relatively permanent water (RPW) is a manmade ditch through wetlands. The impacts have been separated
out from the wetland impacts (see Attachment 2).
2. Please provide more details regarding avoidance and minimization of road, driveway, and culvert impacts
for this project [15A NCAC 02H .0506(b)(1)].1. This Office believes that the access road can be moved or
reconfigured to minimize the impacts to wetlands. Please revise the plans to minimize the impacts or provide
a detailed explanation of why this plan for the activity cannot be practically accomplished, reduced, or
reconfigured to better minimize disturbance to wetlands. For example, please explain why the access road
cannot be located on the opposite side of the ditch.
The Applicant would prefer to have the road on the west side of the ditch. However, the Town would not approve
this plan. SEGi spoke with Mr. Hardison, on 19 July 2021, who stated the access road would need to be in line
with the existing Lake Drive, to which the access road will connect. While speaking with Mr. Hardison, SEGi
inquired about constructing a “driveway”, on the west side of the ditch, to access the lots, but Mr. Hardison stated
the “driveway” could not cut across the Town’s right of way and must connect to a road in front of the lot.
Therefore, these options are not practicable.
3. You indicated that the option of a shared driveway for both units was explored. Please explain why this
option is not feasible.
Please see response to the USACE’s RFAI 3C above.
4. Please clarify what existing surface road the proposed access road will tie into.
The proposed road bed will be an extension of Lake Drive. The site plan has been updated to depict where the
proposed road bed will tie into the existing road bed (see Attachment 2).
5. Please provide a detailed engineering plan, profile view, and cross-section of all proposed culverts. These
drawings must include details regarding stream/ditch alignment in relation to pipe alignment, pipe slope,
pipe burial, and dissipater pads [15A NCAC 02H .0502(c) & .0502(a)(9)].
The project is not to that stage yet. SEGi is relying upon the Town of Carolina Beach to determine the size of the
pipe(s). However, the existing crossing, to the north and downstream of the project, contains 2 – 24” reinforced
concrete pipe (RCP). Therefore, the site plan has been revised to reflect the change from single pipes to double
704/706 South Second Street Response to Agencies’ RFAI SEGi
24” RCP (see Attachment 5). The pipe will be installed at existing grade. Topography in this area is flat, thus there
is no pipe slope and dissipater pads are not required.
6. Mitigation is required for losses of equal to or greater than 300 linear feet of perennial stream and equal to
or greater than 1/10 acre of wetlands. Please provide a mitigation plan that conforms to the requirements
of 15A NCAC 02H .0506(c). You have proposed on-site mitigation, please provide a complete detailed
mitigation plan (including full sized plans and detail sheets) for this project. The mitigation plan may be
proposed in Phases to correspond with the construction Phases. Please provide a notarized copy of the draft
deed notification, covenants, preservation (if required by the Corps) or restrictions that, at a minimum,
notify future lot owners that there are wetlands on the property, which are protected by the NC Division of
Water Resources and the US Army Corps of Engineers. If you plan on preserving the remaining wetlands
on the tract, please provide the draft language that will accomplish preservation.
See response to USACE’s RFAI #4 above. While preservation is not being proposed any longer, the Applicant
intends to record the attached deed notification (Attachment 10), at the New Hanover County Register of Deeds.
This should, in perpetuity, ensure future owners are aware of the presence of wetlands, within the property limits,
thereby minimizing the potential for unauthorized impacts to the wetlands taking place. The deed notification will
be recorded prior to commencing with construction.
It is our hope the information found within and attached to this correspondence will address the agencies’ concerns
and the permits will be processed without delay. However, should either of you have further questions or concerns,
please call me at 910.228.1841.
Thank you both, again, for your time and assistance with this project. We look forward to hearing from you.
Sincerely,

Dana A. Lutheran
SEGI Regulatory Specialist

Attachments (10)

cc: Ms. Holley Snider – [e-mail]

704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 1

Town of Carolina Beach Correspondence

From: Jason Wade <[e-mail]>
Sent: Monday, September 13, 2021 6:00 PM
To: A. Dana Lutheran Wetlands <[e-mail]>
Subject: Fw: South 2nd Street

See below, let me know if you need anything further.

Thanks,

Jason Wade, PE
(Owner / Principal Engineer)
A Structural Guy
701 Carolina Beach Ave S
Carolina Beach, NC 28428
[phone]
www.AStructuralGuy.com

----- Forwarded Message -----
From: Jeremy Hardison <[e-mail] >
To: Jason Wade <[e-mail] >; Ed Parvin <[e-mail] >
Sent: Monday, September 13, 2021, 03:06:21 PM EDT
Subject: RE: South 2nd Street

Hi Jason,

I will be glad to speak with DWR on this if needed. Below are the requirements and attached is
the petition for street improvements. The process and requirements are described in the
application. Let me know if you have any questions.
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 2

Revised Proposed Site Plan

Lake Drive 13.75' road bed70' South Second Street ROW 704 & 706 South Second Street Wetland Impact Map (8/26/21) Wetland Impact A = 2115 SF Wetland Impact B =12,910 SF -------------------------------------- RPW (Ditch) Impact 1 = 80 SF RPW (Ditch) Impact 2 = 80 SF -------------------------------------- Total Wetland Impacts = 15,025 SF Total RPW Impacts = 160 SF Total Impacts = 16,185 SF/0.35 AC Wetland Impact Area A4' wide ditch WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck20'20'8' x 35' Deck7.5'7.5'7.5'7.5'758'x 35'Deck20'20'8'x 35'Deck Wetland Impact Area BCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-00020'20'Proposed wetland impactProposed RPW impact RPW Impact 1 2 - 24" x 20' RCP RPW Impact 2 2 - 24" x 20' RCPStorageStorageStairsStairs 706 South Second Street 35' x 87' Two Story Duplex 704 South Second Street 35' x 87' Two Story DuplexP1P2P3P4P2P1P3P4P#Parking SpaceProject LimitELimit Wetland FillA2A1Proposed 105' x 13.75' South Second Street Extension 34' Profile Drawing100'~14' Wetland fill limit RPW Impact2-24" x 20' RCP
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 3

Revised Avoidance & Minimization Document

SSouthern Environmental Group, Inc.
5315 South College Road, Suite E · Wilmington, North Carolina 28412
910.452.2711 · Fax: [phone] · [e-mail]
www.segi.us

Attachment 1
704 & 706 South Second Street
Avoidance and Minimization

Prepared for:

Mr. Jason Wade
206 Greenville Ave.
Carolina Beach, NC 28428

Prepared by:

Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, NC 28412
910.452.2711

Date:

26 April 2021
Revised 16 September 2021
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
2

Table of Contents
Section Title Page
I. Alternative Analysis 3
A. Off-Site Alternatives 3
B. On-Site Alternatives 4
II. Appendices 5
A. Option A – Preferred Plan 6
B. Option B Site Plan 7
C. Option C Site Plan 8

704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
3

I. Alternative Analysis:
Alternatives that are practicable are those that are available and capable of being undertaken, after considering cost,
logistics and existing technology.
Comprehensive off-site and on-site alternatives analysis has been conducted, as part of the Individual Permit process.
Section 404(b)(1) guidelines were relied upon, to perform the analysis. When evaluating off-site alternatives,
considerations, such as the presence, quantity and quality or functional value of wetlands and/or other waters of the
U.S.; the presence of any federally-listed Threatened and/or Endangered Species (TE) or their Critical Habitat (CH);
state listed Threatened and/or Endangered Species (STE), or other natural or regionally important resource factors that
may be significantly impacted, were not explored, as this area is densely developed and, to SEGi’s knowledge, there
are no known T&E, STE or CH, within this area of Carolina Beach.
A. Off-site Alternatives
Current New Hanover County Zoning Maps, historical aerial photography, topographic and soils maps, and available
current land use records, were used, to best determine if any of the alternative sites met some or all of the following
criteria:
1. Be located within the incorporated area of Carolina Beach;
2. Provides sufficient buildable area for two, residential duplexes (i.e., from 0.20-0.40 acre);
3. Available sewer and water connection;
4. Zoned residential;
5. Close to schools;
6. Close to shopping centers;
7. Close to beach access; and
8. Available for acquisition.
The figure below illustrates the nine sites, that were evaluated, as part of the Off-site Alternative Analysis. Only sites
5 – 9 met the size criterion.
Figure 1. Alternative Site Map

`

The table, on the following page, summarizes Sites 5-9, for practicability.

1
Site
Location
4
6
7
9
5
3 2 1
8
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
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Table 4. Alternative Site Practicability Analysis
Alternative Sites 5-8: This site meets all of the Applicant’s criteria but, in order to access these sites, either
Birmingham Ave. or Sumter Ave. would need to be installed per NC DOT standards, which would require far more
impacts to wetlands than the Preferred Alternative. Therefore, these sites were rejected.
Alternative Site 9: This site also appears to meet most of the Applicant’s criterion, but it is oddly shaped and due to
building setbacks, the lot would not provide sufficient buildable area, for two residential duplex structures. Therefore,
this site was rejected.
Additional Off-Site Alternatives: SEGi also evaluated 17 additional parcels of land that were for sale and within
the vicinity of the proposed project. However, these sites either did not meet the size criteria (5000 SF or larger),
contained wetlands, were located within a subdivision, where duplexes are not allowed, or were not economically
feasible to acquire. The following is a summary of the findings:
Parcel Address Size (SF) Listing Price ($)
1 202 Carolina Beach Avenue South$ 1.75 million
2 304 Carolina Beach Avenue South$ 6098 799,000
3 406 Birmingham Avenue$ 6098 225,000
4 409 Greenville Avenue$ 6098 229,000
5 1105 Snapper Lane* & *** 4791 229,000
6 1208 Swordfish Lane* & *** 4791 379,000
7 1411 Swordfish Lane*** 4791 379,000
8 209 North Carolina Avenue*** 4791 489,000
9 1304 Mackerel Lane*** 4791 349,000
10 316 Cape Fear Boulevard$ 8712 340,000
11 302 Fern Creek Lane** 7405 209,900
12 604 Raleigh Avenue$ 12,632 315,000
13 1317-1321 St. Joseph Street$ 43,996 650,000
14 809 Tarboro Avenue$ 11,760 269,000
15 1101 Lake Park Boulevard$ 130,680 2.75 million
16 1111 Canal Avenue$ 7840 1.75 million
Practicability
Category Criterion Preferred
Alternative Alternative 5 Alternative 6 Alternative 7 Alternative 8 Alternative 9
Availability Available for
Acquisition
The tract has been
purchased by the
Applicant.
Yes Yes Yes Yes Yes
Logistics Parcel Size
(0.2 - 0.4 AC)
The two lots offer
adequate buildable
area
Yes Yes Yes Yes Yes
Appropriate
Zoning
The property is
zoned residential
and located within
the incorporated
limits of Carolina
Beach.
Yes Yes Yes Yes Yes
Availability of
Utilities
Through the Town
of Carolina Beach
Yes Yes Yes Yes Yes
Adequate
Access
Access off Lake
Drive
Yes No – Failed
Screen
No – Failed
Screen
No – Failed
Screen
Yes
Technology Topography
and Other Site
Conditions for
Development
Wetlands are
present
Wetlands are
present
Wetlands are
present
Wetlands are
present
Wetlands are
present
There are no
wetlands present,
but the site is
oddly shaped and
would not
provide enough
buildable space
Cost Reasonable
Acquisition
Cost
The tract was
purchased at a fair
market value
Unknown Unknown Unknown Unknown Unknown
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
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17 1029 Seabreeze Road, Wilmington**** 8271 225,000
* Mostly comprised of wetlands, ** Lot is within subdivision, ***Too small (Town ordinance requires lots be at least 5,000 SF for duplexes), ****Not within
walking distance of shops and the beach, $ not economically feasible
Proposed Site – The proposed site meets all of the Applicant’s criterion, for development of two residential duplex
structures, with gravel access drive, and would require less impacts than lots 5-8, which are the only sites that meet
the buildable area criterion. Additionally, the Applicant already owns the property and has invested a significant
amount of time and money to vet it. Therefore, the proposed site is the only alternative that was accepted.
B. On-Site Alternatives Analysis
The following alternatives were explored:
Alternative 1 – Utilization of other uplands within the tract to avoid impacts: There are no available uplands to
utilize. Therefore, this alternative was rejected.
Alternative 2 – Minimizing the impact area:
The following strategies, to minimize wetland impacts, were considered during the design phase:
Tactical road alignment;
Minimize road length and width;
Using retaining walls;
Reducing the lot fill;
Shared driveway;
Reducing the number of structures;
Utilization of multi-family structures; and
Seek a variance to encroach into the Town’s building setbacks.
With these strategies in mind, the following alternative site plans were explored:
Option A (Preferred Plan) – (See Appendix A): The project area, in the Preferred Plan, consists of a 125’ x
80’ section South Second Street, where it intersects with Lake Drive, and 2 – 125’ x 50’ lots, that are situated
on the western side of South Second Street. A jurisdictional ditch bisects the project boundary, from south to
north. It is approximately 38’ east of front property line. The project area contains approximately 0.38-acre
of wetlands.
The Preferred Plan incorporates tactical access road placement, by positioning the road as close to ditch, as
possible. Additionally, the Applicant limited the length of the road to 110’, which alleviated the need to
include a cul-de-sac or other turnaround, for emergency vehicles. Lastly, the Applicant incorporated retaining
walls, around the driveways and along the front property lines, reduced the size of the structures from 95’
long to 87’ long, limited the maintenance apron to 5’ at the back of the house, and eliminating 10’ of back
yard area. Cumulatively, these efforts avoided 0.13 acres of wetland impact. The Preferred Plan achieves the
Applicant’s objective and is considered to be the least environmentally damaging, practicable alternative.
Option B – (see Appendix B): This plan consists of a longer access road that would need to provide a cul-de-
sac or other turnaround, to meet the Town’s emergency services requirement, thereby impacting
approximately 0.04 acre more wetlands than the Preferred Plan. Therefore, this option was rejected.
Option C – (See Appendix C): This plan consists of centering the road between the eastern ROW line and
ditch. This option was not practicable, since South Second Street and Lake Drive align close to the existing
ditch. Furthermore, this option requires impacting approximately 0.03 acre more wetlands than the Preferred
Plan. Therefore, this option was rejected.
Option D – (See Appendix D): The Applicant explored incorporating retaining walls into the design of the
project. Retaining walls could be used along the front of the lots, around the driveways and on the eastern
and southern sides of the access road, all of which measures approximately 420 linear feet. The cost of
installing retaining walls is approximately $24.00 per square foot. This cost does not include labor. The cost
of using retaining walls, as illustrated in Appendix D, would cost approximately $20,160, based on
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
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approximately 840 square feet of wall, and would reduce wetland impacts by 355 square feet (0.008 acre),
which is insignificant compared to the cost of installing the walls. Therefore, this option was rejected.
Option E – (See Appendix E): The Applicant explored a shared driveway, but wetland impacts were about the
same as the proposed plan. Additionally, due to the fact that the proposed structures are duplexes, on two
separate lots, one shared driveway would not be practicable, as it would create liability issues. Therefore, this
option was rejected.
Alternative 3 – While some municipalities have ordinances allowing buildings to encroach into the setbacks, for
the purpose of avoiding “natural areas”, Carolina Beach does not. In the last 16 years, SEGi has attempted to obtain
variances, from the Town of Carolina Beach and for this purpose, two times and were rejected each time, based on
the fact that the problem is “not unique to the property”, which is a criterion for variance approval. Therefore, this
option was rejected.
Alternative 4 – Building one duplex instead of two: While this alternative would reduce impacts to wetlands and
meets the Applicant’s stated purpose and need, it underachieves the Applicant’s objective. The proposed plan will
produce four units, which is the maximum number of units that can be constructed on the property, without rezoning,
which is discussed in Alternative 5. As has been demonstrated within this document, the demand for single family
dwellings is very high, in this area. Thus, four units would do more to reduce the demand than would two units.
Therefore, this alternative was rejected.
Alternative 5 – Building condos, tri-plex or townhomes: This alternative would require rezoning the property to
multi-family. However, according to Mr. Jeremy Hardison, with the Town of Carolina Beach Planning and Zoning
Department, it is unlikely rezoning would be approved, as it would not be in line with the Town’s desire to limit high
density development, in the area of the project. Furthermore, Mr. Hardison stated the rezoning would not be
consistent with the Town’s approved 2019 CAMA Land Use Plan, which has the area designated for single-family.
Therefore, this alternative was rejected.
Alternative 6 – Avoiding all impacts to wetlands: The Applicant investigated other potential means for developing
the property without impacting wetlands and has been unable to find a practicable alternative that would achieve his
stated goal. Therefore, this alternative was rejected.
Alternative 7 – Impact all wetlands: While this alternative would allow the Applicant to achieve his stated goal, it
would be more damaging to the environment. Therefore, this alternative was rejected.
Alternative 8 – No Build: Under the no build alternative, residential dwellings would not be built and the current
need for additional housing would not be met. Therefore, this alternative was rejected.

704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
7

Appendix A
Option A - Preferred Plan

Lake Drive 13.75' road bed70' South Second Street ROW 704 & 706 South Second Street Wetland Impact Map (8/26/21) Wetland Impact A = 2115 SF Wetland Impact B =12,910 SF -------------------------------------- RPW (Ditch) Impact 1 = 80 SF RPW (Ditch) Impact 2 = 80 SF -------------------------------------- Total Wetland Impacts = 15,025 SF Total RPW Impacts = 160 SF Total Impacts = 16,185 SF/0.35 AC Wetland Impact Area A4' wide ditch WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck20'20'8' x 35' Deck7.5'7.5'7.5'7.5'758'x 35'Deck20'20'8'x 35'Deck Wetland Impact Area BCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-00020'20'Proposed wetland impactProposed RPW impact RPW Impact 1 2 - 24" x 20' RCP RPW Impact 2 2 - 24" x 20' RCPStorageStorageStairsStairs 706 South Second Street 35' x 87' Two Story Duplex 704 South Second Street 35' x 87' Two Story DuplexP1P2P3P4P2P1P3P4P#Parking SpaceProject LimitELimit Wetland FillA2A1Proposed 105' x 13.75' South Second Street Extension 34' Profile Drawing100'~14' Wetland fill limit RPW Impact2-24" x 20' RCP
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
8

Appendix B
Option B Site Plan

Release Dates0. Issued forSITE PLAN AND WETLANDS IMPACTPERMIT INFO2-BLDG WADE DEVELOPMENT704 S. 2ND STREETCAROLINA BEACH BEACH, NC 28428www.AStructuralGuy.comA Structural Guy(919) 451-0974NEW DESIGNS INSPECTIONS206B GREENVILLE AVE, CAROLINA BEACH NC 28428RENOVATIONSTechnical Review7'12'-800 SFRetaining walls EXISTING LAKE SIDE DRIVE3:1 SLOPE130'-0"100'-0"4' DITCH~120'-0"20' X 48" RCP20' X 48" RCP5' SLOPE5' SLOPE5' SLOPE5' SLOPE3' SLOPE5' SLOPE3' SLOPEWADE, JASON R09010-022-010-000Melissa's Laundry, LLC R09010-0221-001-000COURIE ELI III ETAL R09010-022-005-000COURIE ELI III ETAL R09010-022-004-000R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PWADE, JASON R09010-022-017-000LEGEND LIMIT OF WETLAND IMPACTS AVG. 4' WIDE DITCH (RPW) JURISDICTIONAL WETLANDS DOT ROAD 50'4' DITCH50'70' ROW12/15/20201645 SF1645 SF1645 SF70470610'3' SLOPESCALE 1" = 8'0816PORCHPORCHPORCHPORCH10'86'8'1645 SF14'14'WETLAND IMPACT 17,225 SF / 0.40 AC APPENDIX B OPTION BgRii ll100'-0"4' DITCH50'1645SF1645SF1645SF7047004070606010'3' SLOPEPORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCH10'86'8'1645SF3' SLOPE20' X 48" RCP20' X 48" RCP14'14'NCDOT ROAD DESIGN125'
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
10

Appendix D
Option D Site Plan

Release Dates0. Issued forSITE PLAN AND WETLANDS IMPACTPERMIT INFO2-BLDG WADE DEVELOPMENT704 S. 2ND STREETCAROLINA BEACH BEACH, NC 28428www.AStructuralGuy.comA Structural Guy(919) 451-0974NEW DESIGNS INSPECTIONS206B GREENVILLE AVE, CAROLINA BEACH NC 28428RENOVATIONSTechnical Review7'12'-800 SFRetaining walls EXISTING LAKE SIDE DRIVE3:1 SLOPE130'-0"100'-0"4' DITCH~120'-0"20' X 48" RCP20' X 48" RCP5' SLOPE5' SLOPE5' SLOPE5' SLOPE3' SLOPE5' SLOPE3' SLOPEWADE, JASON R09010-022-010-000Melissa's Laundry, LLC R09010-0221-001-000COURIE ELI III ETAL R09010-022-005-000COURIE ELI III ETAL R09010-022-004-000R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PWADE, JASON R09010-022-017-000LEGEND LIMIT OF WETLAND IMPACTS AVG. 4' WIDE DITCH (RPW) JURISDICTIONAL WETLANDS DOT ROAD 50'4' DITCH50'70' ROW12/15/20201645 SF1645 SF1645 SF70470610'3' SLOPESCALE 1" = 8'0816PORCHPORCHPORCHPORCH10'86'8'1645 SF14'14'WETLAND IMPACT 16,735 SF / 0.39 AC APPENDIX C OPTION C20' ROAD / CENTRALLY POSITIONED112'20'gRii ll100'-0"1645SF1645SF1645SF7047004070606010'3' SLOPORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCH10'86'8'1645SF20' X 48" RCP20' X 48" RCP3' SLO112'14'20'-
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
9

Appendix C
Option C Site Plan

Release Dates0. Issued forSITE PLAN AND WETLANDS IMPACTPERMIT INFO2-BLDG WADE DEVELOPMENT704 S. 2ND STREETCAROLINA BEACH BEACH, NC 28428www.AStructuralGuy.comA Structural Guy(919) 451-0974NEW DESIGNS INSPECTIONS206B GREENVILLE AVE, CAROLINA BEACH NC 28428RENOVATIONSTechnical Review7'12'-800 SFRetaining walls EXISTING LAKE SIDE DRIVE3:1 SLOPE130'-0"100'-0"4' DITCH~120'-0"5' SLOPE5' SLOPE5' SLOPE5' SLOPE3' SLOPE5' SLOPE3' SLOPEWADE, JASON R09010-022-010-000Melissa's Laundry, LLC R09010-0221-001-000COURIE ELI III ETAL R09010-022-005-000COURIE ELI III ETAL R09010-022-004-000R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PWADE, JASON R09010-022-017-000LEGEND AVG. 4' WIDE DITCH (RPW) JURISDICTIONAL WETLANDS ACCESS ROAD4' DITCH70' ROW12/15/20201645 SF1645 SF1645 SF70470610'3' SLOPESCALE 1" = 8'0816PORCHPORCHPORCHPORCH10'86'8'1645 SF14'14'WETLAND IMPACT 15,255 SF / 0.35 AC APPENDIX D OPTION DRETAINING WALLS112'20'3' SLO'L1645SF7047004010'gRii ll1645SF1645SF706060PORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCHPORCH10'86'8'1645SF3' SLO14'112'3'SLO20'20'RETAINING WALLRETAINING WALLRETAINING WALLS14' X 48" RCP14' X 48" RCPRETAINING WALL - 420 LF(2 FT) = 840 SF
704 & 706 S. Second Street Avoidance and Minimization Analysis (Revised) SEGi
11

Appendix E
Option E Site Plan

704 South Second Street 35' x 87' Two Story Duplex 706 South Second Street 35' x 87' Two Story Duplex Lake Drive 13.75' road bed70' South Second Street ROW 704 & 706 South Second Street Shared Drive Wetland Impact A = 2,885 SF Wetland Impact B =12,881 SF -------------------------------------- RPW (Ditch) Impact 1 = 176 SF -------------------------------------- Total Wetland Impacts = 15,766 SF Total RPW Impacts = 176 SF Total Impacts = 15,942 SF/0.37 AC South Second Street Extension (20' x 125') Wetland Impact Area A4' wide ditch WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck8' x 35' Deck Wetland Impact Area BCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-000Proposed wetland impactProposed RPW impact South SecondStreetExtension(20'x 125') 704South SecondStreet 35'x87' Two Story Duplex 706South SecondStreet 35'x 87' Two Story Duplex7.5'7.5'7.5'7.5'758'x 35'Deck8'x 35'DeckRetaining Walls20'20' RPW Impact 1 2 - 24" x 44' RCP4' wide ditchngng" "CPCPh
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 4

Town of Carolina Beach Land Use Plan Map

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704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 5

On-site Photos

Ditch to be impacted
Existing road crossing downstream
of proposed project
Proposed wetland impact area
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 6

NC Wetland Assessment Method

Notes on Field Assessment Form (Y/N)
Presence of regulatory considerations (Y/N)
Wetland is intensively managed (Y/N)
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N)
Assessment area is substantially altered by beaver (Y/N)
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N)
Assessment area is on a coastal island (Y/N)
Sub-function Rating Summary
Function Sub-function Metrics
Hydrology Surface Storage and Retention Condition
Sub-Surface Storage and Retention Condition
Water Quality Pathogen Change Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Particulate Change Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Soluble Change Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Physical Change Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Pollution Change Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Habitat Physical Structure Condition
Landscape Patch Structure Condition
Vegetation Composition Condition
Function Rating Summary
Function Metrics/Notes
Hydrology Condition
Water Quality Condition
Condition/Opportunity
Opportunity Presence? (Y/N)
Habitat Conditon
Overall Wetland Rating
Rating
NA
NA
YES
NO
NO
NO
NO
NO
NC WAM Wetland Rating Sheet
Wetland Type
Wetland Site Name 704 & 706 South Second Street
Southern Env. Group., Inc.Non-Tidal Freshwater Marsh
Date
Assessor Name/Organization
7/19/21
Accompanies User Manual Version 4.1
Rating Calculator Version 4.1
LOW
LOW
LOW
NO
LOW
LOW
MEDIUM
Rating
LOW
LOW
NA
NA
NA
NO
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Date
Assessor Name/Organization
Nearest Named Water Body
USGS 8-Digit Catalogue Unit
Yes No
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on last page if evidence of stressors is apparent. Consider departure from reference, if
appropriate, in recent past (for instance, approximately within 10 years). Noteworthy stressors include, but are not limited
to the following.
•
•
•
•
Is the assessment area intensively managed?Yes No
Regulatory Considerations (select all that apply to the assessment area)
Anadromous fish
Federally protected species or State endangered or threatened species
NCDWQ riparian buffer rule in effect
Abuts a Primary Nursery Area (PNA)
Publicly owned property
N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
Abuts a stream with a NCDWQ classification of SA or supplemental classifications of HQW, ORW, or Trout
Designated NCNHP reference community
Abuts a 303(d)-listed stream or a tributary to a 303(d)-listed stream
What type of natural stream is associated with the wetland, if any? (check all that apply)
Blackwater
Brownwater
Tidal (if tidal, check one of the following boxes)Lu Lunar Wind Both
Is the assessment area on a coastal island?Yes No
Is the assessment area's surface water storage capacity or duration substantially altered by beaver?Yes No
Does the assessment area experience overbank flooding during normal rainfall conditions?Yes No
1. Ground Surface Condition/Vegetation Condition – assessment area condition metric
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure
(VS) in the assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable,
then rate the assessment area based on evidence of an effect.
GS
A A Not severely altered
B B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire-plow lanes, skidder tracks, bedding, fill, soil compaction, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing,
less diversity [if appropriate], hydrologic alteration)
2.Surface and Sub-Surface Storage Capacity and Duration – assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub-surface storage capacity and
duration (Sub). Consider both increase and decrease in hydrology. Refer to the current NRCS lateral effect of ditching guidance for
North Carolina hydric soils (see USACE Wilmington District website) for the zone of influence of ditches in hydric soils. A ditch
≤ 1 foot deep is considered to affect surface water only, while a ditch > 1 foot deep is expected to affect both surface and ditch
sub-surface water. Consider tidal flooding regime, if applicable.
Surf
A A Water storage capacity and duration are not altered.
B B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
C C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation
change) (examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3.Water Storage/Surface Relief – assessment area/wetland type condition metric (answer for non-marsh wetlands only)
Check a box in each column for each group below . Select the appropriate storage for the assessment area (AA) and the wetland
type (WT).
AA WT
3a. A A Majority of wetland with depressions able to pond water > 1 foot deep
B B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
C C Majority of wetland with depressions able to pond water 3 to 6 inches deep
D D Depressions able to pond water < 3 inches deep
Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
Latitude/Longitude (deci-degrees)
Habitat/plant community alteration (examples: mowing, clear-cutting, exotics, etc.)
Surface and sub-surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby
Sub
VS
septic tanks, underground storage tanks (USTs), hog lagoons, etc.)
Precipitation within 48 hrs?
Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
34.027, -77.897
NC WAM WETLAND ASSESSMENT FORM
Accompanies User Manual Version 4.1
Southern Env. Group., Inc.
7/19/21Wetland Site Name
Wetland Type
704 & 706 South Second Street
Rating Calculator Version 4.1
Carolina Beach Lake
03030005
Level III Ecoregion
River Basin
Middle Atlantic Coastal Plain
Non-Tidal Freshwater Marsh
Cape Fear
3b. A Evidence that maximum depth of inundation is greater than 2 feet
B Evidence that maximum depth of inundation is between 1 and 2 feet
C Evidence that maximum depth of inundation is less than 1 foot
4.Soil Texture/Structure – assessment area condition metric
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape
feature. Make soil observations within the 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for
regional indicators.
4a. A Sandy soil
B Loamy or clayey soils exhibiting redoximorphic features (concentrations, depletions, or rhizospheres)
C Loamy or clayey soils not exhibiting redoximorphic features
D Loamy or clayey gleyed soil
E Histosol or histic epipedon
4b. A Soil ribbon < 1 inch
B Soil ribbon ≥ 1 inch
4c. A No peat or muck presence
B A peat or muck presence
5. Discharge into Wetland – opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf) and sub-surface pollutants or discharges (Sub).
Examples of sub-surface discharges include presence of nearby septic tank, underground storage tank (UST), etc.
Surf Sub
A A Little or no evidence of pollutants or discharges entering the assessment area
BBNoticeable evidence of pollutants or discharges entering the wetland and stressing, but not overwhelming the
treatment capacity of the assessment area
C C Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area and
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use – opportunity metric
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources
draining to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the
assessment area (5M), and within 2 miles and within the watershed draining to the assessment area (2M). Effective riparian buffers
are considered to be 50 feet wide in the Coastal Plain and Piedmont ecoregions and 30 feet wide in the Blue Ridge Mountains ecoregion.
WS 5M 2M
A A A ≥ 10% impervious surfaces
B B B < 10% impervious surfaces
C C C Confined animal operations (or other local, concentrated source of pollutants)
D D D ≥ 20% coverage of pasture
E E E ≥ 20% coverage of agricultural land (regularly plowed land)
F F F ≥ 20% coverage of maintained grass/herb
G G G ≥ 20% coverage of clear-cut land
H H H Little or no opportunity to improve water quality. Lack of opportunity may result from hydrologic alterations
that prevent drainage or overbank flow from affecting the assessment area.
7. Wetland Acting as Vegetated Buffer – assessment area/wetland complex condition metric
7a. Is assessment area within 50 feet of a tributary or other open water?
Yes No If Yes, continue to 7b. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of the wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is weltand? Descriptor E should be selected if ditches effectively bypass the buffer.
A ≥ 50 feet
B From 30 to < 50 feet
C From 15 to < 30 feet
D From 5 to < 15 feet
E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
≤ 15-feet wide > 15-feet wide Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend into the bank of the tributary/open water?
Yes No
7e. Is tributary or other open water sheltered or exposed?
Sheltered – adjacent open water with width < 2500 feet and no regular boat traffic.
Exposed – adjacent open water with width ≥ 2500 feet or regular boat traffic.
8. Wetland Width at the Assessment Area – wetland type/wetland complex metric (evaluate for riparian wetlands only)
Check a box in each column. Select the average width for the wetland type at the assessment area (WT)
and the wetland complex at the assessment areas (WC). See User Manual for WT and WC boundaries.
WT WC
A A ≥ 100 feet
B B From 80 to < 100 feet
C C From 50 to < 80 feet
D D From 40 to < 50 feet
E E From 30 to < 40 feet
F F From 15 to < 30 feet
G G From 5 to < 15 feet
H H < 5 feet
9. Inundation Duration – assessment area condition metric
Answer for assessment area dominant landform.
A Evidence of short-duration inundation (< 7 consecutive days)
B Evidence of saturation, without evidence of inundation
C Evidence of long-duration inundation or very long-duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition – assessment area condition metric
Consider recent deposition only (no plant growth since deposition).
A Sediment deposition is not excessive, but at approximately natural levels.
B Sediment deposition is excessive, but not overwhelming the wetland.
C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size – wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FW) (if applicable, see User
Manual). See the User Manual for boundaries of these evaluation areas. If assessment area is clear-cut, select “K” for the FW column.
WT FW (if applicable)
A A A ≥ 500 acres
B B B From 100 to < 500 acres
C C C From 50 to < 100 acres
D D D From 25 to < 50 acres
E E E From 10 to < 25 acres
F F F From 5 to < 10 acres
G G G From 1 to < 5 acres
HHHFrom 0.5 to < 1 acre
I I I From 0.1 to < 0.5 acre
J J J From 0.01 to < 0.1 acre
KKK< 0.01 acre or assessment area is clear-cut
12. Wetland Intactness – wetland type condition metric (evaluate for Pocosins only)
A Pocosin is the full extent (≥ 90%) of its natural landscape size.
B Pocosin is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas – landscape condition metric
13a.Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contiguous
metric naturally vegetated area and open water (if appropriate). Boundaries are formed by four-lane roads, regularly maintained utility
line corridors the width of a four-lane road or wider, urban landscapes, fields (pasture open and agriculture), or water > 300 feet wide.
A A ≥ 500 acres
B B From 100 to < 500 acres
C C From 50 to < 100 acres
D D From 10 to < 50 acres
E E < 10 acres
F F Wetland type has a poor or no connection to other natural habitats
13b.Evaluate for marshes only.
Yes No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect – wetland type condition metric (skip for all marshes)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificial edges include
non-forested areas ≥ 40 feet wide such as fields, development, roads, regularly maintained utility line corridors and clear-cuts.
Consider the eight main points of the compass.
A No artificial edge within 150 feet in all directions
B No artificial edge within 150 feet in four (4) to seven (7) directions
C An artificial edge occurs within 150 feet in more than four (4) directions or assessment area is clear-cut
15. Vegetative Composition – assessment area condition metric (skip for all marshes and Pine Flat)
A Vegetation is close to reference condition in species present and their proportions. Lower strata composed of appropriate
species, with exotic plants absent or sparse within the assessment area.
Well
WC
Loosely
B Vegetation is different from reference condition in species diversity or proportions, but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or
clearing. It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
C Vegetation severely altered from reference in composition. Expected species are unnaturally absent (planted stands of non-
characteristic species or at least one stratum inappropriately composed of a single species). Exotic species are dominant in
at least one stratum.
16. Vegetative Diversity – assessment area condition metric (evaluate for Non-tidal Freshwater Marsh only)
A Vegetation diversity is high and is composed primarily of native species (<10% cover of exotics).
B Vegetation diversity is low or has > 10% to 50% cover of exotics.
C Vegetation is dominated by exotic species (>50% cover of exotics).
17. Vegetative Structure – assessment area/wetland type condition metric
17a.Is vegetation present?
Yes No If Yes, continue to 17b. If No, skip to Metric 18.
17b.Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non-marsh wetlands.
A ≥ 25% coverage of vegetation
B < 25% coverage of vegetation
17c.Check a box in each column for each stratum. Evaluate this portion of the metric for non-marsh wetlands. Consider structure
in airspace above the assessment area (AA) and the wetland type (WT) separately.
A A Canopy closed, or nearly closed, with natural gaps associated with natural processes
B B Canopy present, but opened more than natural gaps
C C Canopy sparse or absent
A A Dense mid-story/sapling layer
B B Moderate density mid-story/sapling layer
C C Mid-story/sapling layer sparse or absent
A A Dense shrub layer
B B Moderate density shrub layer
C C Shrub layer sparse or absent
A A Dense herb layer
B B Moderate density herb layer
C C Herb layer sparse or absent
18. Snags – wetland type condition metric
A Large snags (more than one) are visible (> 12-inches DBH, or large relative to species present and landscape stability).
BNot A
19. Diameter Class Distribution – wetland type condition metric
A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12-inch DBH.
C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris – wetland type condition metric
Include both natural debris and man-placed natural debris.
A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
BNot A
21. Vegetation/Open Water Dispersion – wetland type/open water condition metric (evaluate for Non-Tidal Freshwater
Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Patterned
areas indicate vegetated areas, while solid white areas indicate open water.
ABCD
AA WT
CanopyMid-StoryShrubHerb
22.Hydrologic Connectivity – assessment area condition metric (evaluate for riparian wetlands only)
Examples of activities that may severely alter hydrologic connectivity include intensive
ditching, fill, sedimentation, channelization, diversion, man-made berms, beaver dams, and stream incision.
A Overbank and overland flow are not severely altered in the assessment area.
B Overbank flow is severely altered in the assessment area.
C Overland flow is severely altered in the assessment area.
D Both overbank and overland flow are severely altered in the assessment area.
Notes
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 7

Road Option Exhibits

704 South Second Street 35' x 82' Two Story Duplex 706 South Second Street 35' x 82' Two Story Duplex Lake Drive 13.75' road bed Sumter Ave. South Second Street 20' wide road bed80' South Second Street ROW South Second Street Extension Option 2 - T Turning Head Wetland Impact A = 4480 SF Wetland Impact B = 575 SF Wetland Impact C = 12,881 SF -------------------------------------- RPW (Ditch) Impact 1 = 80 SF RPW (Ditch) Impact 2 = 80 SF RPW (Ditch) Impact 3 = 120 SF -------------------------------------- Total Wetland Impacts = 18,965 SF Total RPW Impacts = 280 SF Total Impacts = 19,245 SF/0.44 AC South Second Street Extension 20' road bed South SecondStreet Extension 20'road bed Wetland Impact Area A Wetland Impact Area B4' wide ditch RPW Impact 3 2 - 24" x 30' RCP 20' WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck20'20'8' x 35' Deck 704South SecondStreet 35'x 82' Two Story Duplex 706South SecondStreet 35'x 82' Two Story Duplex7.5'7.5'7.5'7.5'758'x 35'Deck20'20'8'x 35'Deck Wetland Impact Area C RPW Impact 2 2 - 24" x 20' RCP RPW Impact 1 2 - 24" x 20' RCPCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPEOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-00020'20'Proposed wetland impactProposed RPW impact
704 South Second Street 35' x 82' Two Story Duplex 706 South Second Street 35' x 82' Two Story Duplex Lake Drive 13.75' road bed Sumter Ave. South Second Street 20' wide road bed80' South Second Street ROW South Second Street Extension Option 2 - T Turning Head Wetland Impact A = 5,815 SF Wetland Impact B =12,881 SF -------------------------------------- RPW (Ditch) Impact 1 = 80 SF RPW (Ditch) Impact 2 = 80 SF -------------------------------------- Total Wetland Impacts = 18,696 SF Total RPW Impacts = 160 SF Total Impacts = 18,856 SF/0.43 AC South Second Street Extension 20' road bed Wetland Impact Area A4' wide ditch WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck20'20'8' x 35' Deck 706South SecondStreet 35'x 82' Two Story Duplex 704South SecondStreet 35'x 82' Two Story Duplex7.5'7.5'7.5'7.5'758'x 35'Deck20'20'8'x 35'Deck Wetland Impact Area B RPW Impact 2 2 - 24" x 20' RCP RPW Impact 1 2 - 24" x 20' RCPCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPEOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-00020'20'Proposed wetland impactProposed RPW impact South SecondStreet Extension 20'road bed
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 8

Shared Drive Exhibit

704 South Second Street 35' x 87' Two Story Duplex 706 South Second Street 35' x 87' Two Story Duplex Lake Drive 13.75' road bed70' South Second Street ROW 704 & 706 South Second Street Shared Drive Wetland Impact A = 2,885 SF Wetland Impact B =12,881 SF -------------------------------------- RPW (Ditch) Impact 1 = 176 SF -------------------------------------- Total Wetland Impacts = 15,766 SF Total RPW Impacts = 176 SF Total Impacts = 15,942 SF/0.37 AC South Second Street Extension (20' x 125') Wetland Impact Area A4' wide ditch WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266) Approx. Wetland Line1" = 30'20'20'7.5'10'7.5'7.5'7.5'10'8' x 35' Deck8' x 35' Deck Wetland Impact Area BCOURIE ELI III ETAL R09010-022-005-000 WADE, JASON R09010-022-010-000 (THIS PROPERTY TO BE DEVELOPED UNDER SAW-2021-00266)R09010-022-004-001 GLAZIER WOODROW R SAENGDUAN PCOURIE ELI III ETAL R09010-022-004-000EOPExisting 2 - 24" x 20' RCPRetaining WallsMelissa's Laundry, LLC R09010-0221-001-000Proposed wetland impactProposed RPW impact South SecondStreetExtension(20'x 125') 704South SecondStreet 35'x87' Two Story Duplex 706South SecondStreet 35'x 87' Two Story Duplex7.5'7.5'7.5'7.5'758'x 35'Deck8'x 35'DeckRetaining Walls20'20' RPW Impact 1 2 - 24" x 44' RCP4' wide ditchngng" "CPCPh
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 9

Lower Cape Fear UMB Credit Reservation Letter
(An updated reservation letter will be submitted to the agencies upon receipt)

LOWERCAPEFEARUMBRELLAMITIGATIONBANK
STATEMENTOFCREDITAVAILIBILITY
August26,2021
TO:Mr.JasonWade
605GreenvilleAve
CarolinaBeach,NC28428
FROM:LowerCapeFearUmbrellaMitigationBank
c/oL andManagementGroup
3805 WrightsvilleAvenue,Suite15
Wilm ington,NC28403
Project:706SouthSecondStreet,Ca rolinaBeach(NewHanoverCounty,NC)
DearMr.Wade:
Pursuanttotherecentcreditrequestsubmittedonyourbehalf,theLowerCapeFearUmbrellaMitigation
Bank(LCFUMB)isprovidingconfirmationofacceptanc etosupplymitigationcreditsforproposedriparian
wetlandimpactsassociatedwith706SouthSecondStree t,CarolinaBeach(NewHanoverCounty,NC).This
acceptance is conditional upon receipt of payment a s outlined below. Please refer to the table below
depictingthetypeandquantityofcredits requestedandreservedforyourproject.
BaseduponreceiptofyouremailtransmittedonAu gust26,2021,LCFUMBwillreserve1.4riparianwetland
creditsforaperiodofupto90daysfromthedateofthisletter.Notethatrequeststoreservecredits
beyond90dayswillrequireadeposit.Pleasecontactusif youneedareservationtoextendbeyondthe90
dayperiod.
Uponrequestforreceiptofcredittransfer,LCFUMB willissueaninvoiceintheamountof$94,418.88.
Uponreceiptofpayment,LCFUMBwillprovideanexecute dTransferofCreditCertificate.Notethatall
paymentsmustbemadewithcertifiedfunds.Itis theapplicant’sresponsibilitytoensurethatthecredit
typesandamountsrequestedareconsistentwiththe compensatorymitigationrequirementsofthepermit(s)
issued. LCFUMB and/or its agents are not resp onsible for determining the applicant’s mitigation
requirements.Ifyouhaveanyquestionsorneedadditional information,pleasecontactmebyphoneat
(910)4520001orbyemailat [e-mail].
Sincerely,
LandManagementGroup(agentforLCFUMB)
ChristianPreziosi
PrincipalConsultant
MitigationType CreditsReserved FeePerUnit Fee
Stream 0.0 $603.87 $0.00
NonRiparianWetland 0.0 $67,442.06 $0.00
Riparian(Riverine)Wetland 1.4 $67 ,442.06 $94,418.88
TotalFee $94,418.88
704/706 South Second Street Response to Agencies’ RFAI SEGi

Attachment 8

Draft Deed Notification

COMPLIANCE WITH WETLAND & BUFFER REGULATIONS

The following DEED NOTIFICATION shall be recorded in the New Hanover County Registry prior to the
conveyance of the property, referred to as 704 & 706 South Second Street on the attached plan entitled
Property Boundary Survey and prepared by TBD and dated TBD .

“A portion of this lot, as determined by the Wilmington District US Army Corps of Engineers (USACE) under Action
ID# SAW-2019-00908 , contains waters of the U.S., including wetlands, which are subject to the permit
requirements of Section 404 of the Clean Water Act (33 USC 1344). Any placement of dredged or fill material within
these waters without Department of Army authorization may constitute a violation of Section 301 of the Clean Water
Act (33 USC 1311). Prior to any work within the jurisdictional areas, please contact the U. S. Army Corps of Engineers,
Wilmington District Regulatory Division, Wilmington, North Carolina. This covenant is to run with the land and shall
be binding on all Parties and all persons claiming under them.”

Signature

Owner's Name:

Address:

City, State, Zip Code:

Phone Number: ( )

STATE of North Carolina

County

I, , a Notary Public of the State of North Carolina,
County, hereby certify that owner personally appeared before me this day and executed by above certification.

Witness my hand notorial seal, this day of , 20__.

Notary Public

My commission expires: