20050949 Ver 1_Other Agency Comments_20050624

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OF June 22, 2005
Regulatory Division
Action ID No. 200520934
Mr. John Shallcross, Jr.
Partner's Equity Group
Post Office Box 1089
Smithfield, North Carolina 27577
Dear Mr. Shallcross:
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JUN 2 4 2005
DENR - WAiER QUALITY
WETLANDS AND STORMWATER BRANCH
Reference is made to your preconstruction notification application dated May 19, 2005,
for Department of the Army (DA) nationwide permit authorization for proposed impacts totaling
1.9 acres of wetland associated with the development of lots 18 and 19 at Partner's Equity Group
Subdivision. The property drains to an unnamed tributary of Polecat Branch, in the Neuse River
Basin, and is located on the west side of SR 2398 (Industrial Park Road), approximately 0.5 mile
north of NC Highway 70 Business, immediately north of Interstate 95, in Johnston County, North
Carolina.
Nationwide Permit 39 conditions states that "the discharge does not cause the loss of
greater than %z -acre of non -tidal waters of the U.S." Furthermore, in calculating the total loss of
waters of the U.S. for the subdivision, we consider the cumulative effect of past permit
authorizations associated with the development. Our records indicate that previous
authorizations associated with the development (Corps Action ID numbers 199400569 and
199708043) have resulted in an aggregate loss of 1.24 acres of wetlands. Accordingly, all future
development activities associated with the development that result in a loss of waters of the U.S.
will require individual DA permit authorization (application enclosed).
If you choose to pursue individual permit authorization for the proposed activities, please
note that the DA and the U.S. Environmental Protection Agency (EPA) signed a memorandum of
agreement (MOA) on February 6, 1990 that established procedures to determine the type and
level of mitigation necessary to comply with the Clean Water Act Section 404(b)(1) Guidelines.
This MOA provides for first, avoiding impacts to waters and wetlands through the selection of
the least damaging, practical alternative; second, taking appropriate and practical steps to
minimize impacts on waters and wetlands; and finally, compensating for any remaining
unavoidable impacts to the extent appropriate and practical. To enable us to process your
application in full compliance with this MOA, we request that you provide the following
additional information when you submit your individual permit application:
Printed on 0 Recycled Paper

a. Permits for work within wetlands or other special aquatic sites are available only if the
proposed work is the least environmentally damaging, practicable alternative. Please furnish
information regarding any other alternatives, including upland alternatives, to the work for which
you have applied and provide justification that your selected plan is the least damaging to water
or wetland areas. Specifically, we need information regarding alternative sites that would result
in reduced impacts to wetlands. This includes the use of any other lots within the subdivision
that have not been developed, as well as off-site alternatives that would result in reduced
impacts. Aerial photographs dated April 5, 2005, that were submitted with your permit
application show that several high -ground lots within the subdivision have not been developed.
Information should be submitted with your permit application that specifically explains why
these lots cannot be used for the proposed development activities.
b. It is necessary for you to have taken all appropriate and practical steps to minimize
wetland losses. Your application specifically stated that a detailed site plan has not been
prepared for the subject lots, and requested that a permit be issued with a condition requiring
final site plan and mitigation plan approval prior to construction. Please note that in order to
allow us to review the proposed impacts, a site development plan must accompany the permit
application. Regulations state that an application will be determined to be complete when
sufficient information is received to issue a public notice, including "a plan and elevation
drawing showing the general and specific site location and character of all proposed activities,
including the size relationship of the proposed structures to the size of the impacted waterway"
[See 33 CFR 325.1(d) and 325.3(a)]. The development plan must show the location of all
required impacts, including the building foundations, parking areas, stormwater management
facilities (if required), etc. Additionally, you should indicate all that you have done, especially
regarding development and modification of plans and proposed construction techniques, to
minimize adverse impacts. Such information would include an evaluation of alternative designs,
including the use of retaining walls to reduce the reach of fill slopes into wetland areas.
c. The MOA requires that appropriate and practical mitigation will be required for all
unavoidable adverse impacts remaining after all appropriate and practical minimization has been
employed. Your application does not specify the amount of proposed mitigation (in acres), or the
specific type of mitigation, however you do suggest several mitigation alternatives, including
payment into the North Carolina Ecosystem Enhancement Program (NCEEP), off-site
restoration/creation, or on-site activities including wetland detention basins. Please note that the
Corps does not generally consider the creation of wetlands within basins constructed to provide
stormwater retention as mitigation. Please provide additional information that specifies the type
and amount of mitigation that is proposed. If you choose to pay into NCEEP, please provide
verification from NCEEP that they are willing to accept payment for the proposed mitigation.
2

Finally, in your permit application you state, "In 1997, 2.39 acres of wetlands were
delineated and signed off by the USACE. In 1998, the wetland area was reduced to 1.9 acres
with conditions pertaining to the expansion of storm water ponds." However, all of the plans
submitted in your application still show 2.39 acres of wetlands located on lots 18 and 19. Please
be sure that your application includes maps that depict the new (1998) wetland boundaries, and
provide verification that a Corps representative has approved the change. If necessary, a site
meeting can be scheduled to inspect the site and determine the current extent of jurisdiction
present.
Please be reminded that nationwide permit authorization is not available for your project,
and if your choose to pursue your project further you will need to submit an individual permit
application and address the issues outlined above. Should you have any questions regarding this
letter or your application for DA permit authorization please call me at telephone (919) 876-
8441, extension 26.
Enclosure
Copies Furnished (without enclosures):
Ms. Robin Little
5409 New Rebel Court
Youngsville, NC 27596-8856
Ms. Cyndi Karoly
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Wetland/401 Unit
1650 Mail Service Center
Raleigh, NC 27699-1650
Sincerely,
V 7J.Tugw
To
Regulatory Project Manager,
Raleigh Field Office
3

March 6, 2006
CERTIFIED MAIL — RETURN RECEIPT REQUESTED
Mr. John Shallcross, Jr.
Partner's Equity Group
PO Box 1089
Smithfield, NC 27577
--7 / 011M
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
DWQ#: 2005-0949
Johnston County
Subject: Denial of Request for 401 Water Quality Certification
Residential Fill at Lots 18 & 19 at the Partner's Equity Group Subdivision
Johnston County
Dear Mr. Shallcross:
Your application for a Water Quality Certification under Section 401 of the Federal Clean Water Act was
received on June 1, 2005, with more information received by the DWQ on June 17, 2005, August 8,
2005, November 11, 2005, and January 11, 2005. The activity for which the Certification is requested is
to allow fill in 1.9 acres of wetlands located on Lots 18 & 19 in the Partner's Equity Group Subdivision
located on the west side of SR2398 (Industrial Park Road), approximately 0.5 miles north of NC
Highway 70 Business, immediately north of Interstate 95 in Johnston County, North Carolina. A Water
Quality Certification represents a determination by the Division that the activity, for which the federal
permit or license is being required, is not expected to result in a violation of state water quality standards
for Waters of the State.
After a thorough site inspection of your property and review of your submittals, our staff has determined
that lots (10, 11, 18, & 19), in accordance with 15A NCAC 2H.0500, have Deed Restrictions and
Protective Covenants (Book 1931, Page 654, dated April 12, 2000), which state:
"1....A portion of lots 10, 11, 18 and 19 have been determined to meet the requirements for designation
as a regulatory wetland. Any subsequent fill or alteration of this wetland shall conform to the
requirements of the state wetland rules adopted by the State of North Carolina in force at the time of the
proposed alteration. The intent of this provision is to prevent additional wetland fill, so the property
owner should not assume that a future application for fill would be approved... This covenant is intended
to ensure continued compliance with wetland rules adopted by the State of North Carolina and therefore
benefits may be enforced by the State of North Carolina. This covenant is to run with the land and shall
be binding on all parties and all persons claiming under them."
Noce hCarolina
NaturallY
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Intemet: h2o.encstate.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

John Shallcross, Jr.
Page 2 of 2
March 6, 2006
"..2. In order to comply with the 401 Certification and the associated storm water management plan
approved on February 11, 1998 (DWQ#970656) the following applies:
As much as reasonably practical a diversion of a portion of the storm water from lots 10, 11, 12 and 17
shall be made into the wetland areas either on the lot or in the wetlands on lots 18 and 19. "
As provided by 15A NCAC 2H .05 06, our review must determine whether a proposed project will
removed or degrade the existing uses of a wetland. In accordance with these rules, the Division has
determined that the placement of fill into the above -referenced wetlands will degrade or totally removed
existing wetland functions and is therefore not an approvable project under 15A NCAC 211 .0506. This
conclusion is based on our determination that you have failed to demonstrate sufficient purpose and need
for this fill, as well as on our review of the permit history for this development. Therefore, I am hereby
notifying you that in accordance with 15A NCAC 211 .0507(e), your application for a 401 Water
Quality Certification is hereby denied.
If you wish to appeal this decision, you have the right to an adjudicatory hearing upon written request
within sixty (60) days of your receipt of this denial. To ask for a hearing, send a written petition, which
conforms to Chapter 150B of the North Carolina General Statutes to the Office of Administrative
Hearings, P.O. Box 27447, Raleigh, N.C. 27611-7447. This denial is final and binding unless you ask for
a hearing.
Should you have information that you believe may alter our decision, we are available to discuss this
matter further. Please direct such information, or questions regarding this denial, to Mr. Ian McMillan at
919-715-4631, Ms. Cyndi Karoly at 919-733-9721, or Mr. Eric Kulz at our Raleigh Regional Office at
919-791-4200.
Sincerely,
Alan W. Klimek, P.E.
AWKlasc
cc: Eric Kulz, DWQ, RRO
Todd Tugwell, US Army Corps of Engineers, Raleigh Regulatory Field Office
File copy
Central files
Robin Little, 5409 New Rebel Court, Youngsville, NC 27596
Rebecca Fox, US Environmental Protection Agency — Region IV
20050949Shallcross(Johnston)DENIAL

4
August 2, 2005
Mr. Todd Tugwell, Regulatory Field Officer
t�°'``''
Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
6508 Falls of the Neuse Road, Suite 120
Raleigh, NC 27615
Subject: Individual Permit Application and requested additional information
for lots 18 and 19 of Partners Equity Group Subdivision, Industrial
Park Road, Smithfield, Johnston County. (Reference USACE Action ID
Number 200520934 and DWQ Project # 05-0949.)
Dear Mr. Tugwell:
Enclosed are the required Individual Permit application forms with attendant
justification on minimization, avoidance and compensatory mitigation. The
proposed project will impact 2.4 acres of non-riverine wetlands located on lots
18 and 19 of the Partners Equity Group subdivision.
Avoidance
We find ourselves caught in a "Catch 22" situation, as the prospective buyer
requires regulatory authorization prior to preparing and submitting engineered
site plans and of course prior to purchase of the subject lots. The buyer does
not want to incur the costs associated with submitting specific site design
plans and storm water design plans without knowing that the subject lots can be
approved for use. The site plan will result in 80% impervious area, from
parking lot and building footprints. The remaining 20% of ground surface could
contain most of the wetland area. Generally, on could assume that total
avoidance of the small wetland area in question will not be feasible or
practicable on these lots. When the original Nationwide 26 was issued, Mr.
Shallcross proceeded to develop the property, without clearly understanding the
difficulties this would cause. The Nationwide 26 should have been issued for
the entire impacts, once he had demonstrated avoidance and minimization, and
provided adequate mitigation. Even with the total cumulative impacts
considered, the impacts still would have been permissible under Nationwide 26 in
1994.

Page 2.
Alternative Sites
The subject property (approximately 45 acres) does have several undeveloped
upland lots, but they have been sold or optioned to other developers. The
subject lots (18 and 19) are prime development property as they have road
frontage on the existing service road. The other lots do not have the visibility
that commercial businesses prefer for exposure to traffic on Industrial Park
Road. Immediate access to the I95 interchange and exits, and exposure to the
traffic to and from the existing Outlet Malls and other existing retail stores
is an obvious asset to the subject lots with road frontage on the service road.
There are no other available properties with this unique combination of proximal
location and high visibility road frontage. In 1994, there may have been other
potential properties, but the Smithfield tax records do not show past ownership
records. Any other alternative sites in this area, within similar distances
from the I95 interchange, would have the same issues with wetland avoidance.
Study of the USDA Soil Survey for Johnston County shows extensive areas of
hydric soils in this area, which may not all be jurisdictional wetlands, but
which illustrates the lack of available upland sites. (Exhibit A.)
Alternative sites may have been available in 1994 when the subject site was
developed. None of them would have had the road frontage or exposure provided
by the specific location of the subject property. Since the wetlands on the
subject site are common in this area, it would have been difficult to find an
alternate property that did not have similar potential wetland impacts. The
area is predominantly wet flats with Rains or Grantham hydric soils, which may
or may not have adequate hydrology to be called jurisdictional wetlands.
Examination of a 1994 aerial photograph (Exhibit B.) shows significantly less
development in the project vicinity than the 2005 aerial photograph, as would be
expected. (Exhibit C.) However, significant impacts to wetland areas have
occurred in this area over time. The functions and values associated with wet
flats which are somewhat isolated by roads and adjacent development are marginal
at best. They provide minimal storm water detention, sediment detention,
wildlife habitat or aesthetic value or water quality improvement or protection
functions. The real need in this area, with the amount of developed,
impermeable area in place, is for storm water treatment and wet detention
basins.
Road Placement
When Mr. Shallcross initially developed the property, he was required by the
town of Smithfield and by the North Carolina Department of Transportation to
build on a specific road alignment, in order to provide safe ingress and egress
to and from his property. He was required to place the new road in a specific
location, and to build a loop or "U" shaped road in order to provide two
entrances or exits so that traffic from the subject property would be less
concentrated at those entry points. There was really only one way to
efficiently configure the lots around the required road layout. This did not
provide optimal avoidance options for the wetland area located on lots 18 and
19. It was then not practicable nor was it feasible to configure the lots so as
to avoid the wetland, without significant financial loss by Mr. Shallcross.

Page 3.
Mitigation
Conceptual mitigation is proposed for on-site or off-site mitigation, or
provided via the Ecosystem Enhancement Program (EEP) with payment of in -lieu
fees. (In lieu fee mitigation review has been initiated with EEP. Approval
letter to follow.) There is currently a stream restoration project initiated by
EEP on Buffalo Creek, adjacent to the subject property. As an extension of the
immediate water shed for that project, it is our opinion that a coordinated
effort to address storm water treatment and storm water detention needs on this
and other nearby properties would accomplish more for the water shed in terms of
water quality improvement than this isolated wetland ever could.
By copy of this letter we also submit this Individual Permit application to the
Division of Water Quality (DWQ) for review and certification. We have included
two paper copies for each agency office. If more copies are needed, please
contact me at [phone].
We appreciate your attention in this matter. If you have any questions or need
any additional information, do not hesitate to contact Ms. Robin Little at (919)
418-7645 or Mr. John Shallcross at [phone]. We look forward to a timely
and productive resolution to this matter.
Sincerely,
�k�vs�6
Robin M. Little
Cc: Ms. Cyndi Karoly
Mr. John Shallcross, Jr.

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