20220239 Ver 1_More Info Received_20220314

Strickland, Bev
From: Bob Zarzecki <[e-mail]>
Sent: Monday, March 14, 2022 6:32 PM
To: Norton, April R CIV USARMY CESAW (USA)
Cc: Cohn, Colleen M
Subject: [External] RE: Request for Additional Information (Kinsley Subdivision)
SAW-2018-01484
Importance: High
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April:
Please consider this additional information / responses from the project engineer provided below to
your questions 1 & 2.
Comment 1
Given the nature of this stream and the proposed development, complete avoidance cannot be
obtained and significant minimization has already occurred for Impact 1 throughout the design and
permitting process.
The length of this buffered stream is approximately 800 linear feet. The small pocket of isolated
wet/ands, Wet/and 9, extends this stream corridor an additional 40 feet to a total length of 840 feet.
We are only crossing this stream at one point, and at additional expense to the project we have
pushed that crossing as far to the east as possible in order to minimize the impacts.
To avoid any impacts to the wet/ands and buffer in this area would require us to shift this road and
SCM 11 an additional 160 feet to the east. As we will explain below that is prohibitive.
There was significant minimization to Impact 1 during the conceptual design phase of Kinsley. Earlier
conceptual plans intended to cross the stream further to the west, near the headwater of the existing
pond. This alignment produced additional lots and a more efficient layout, however out of concern for
minimization of the wet/and and buffer impacts we pushed the street as far to the east as we could
justify.
In Urban Zoning Districts such as the Kinsley Planned Unit Development, the Wake Forest Unified
Development Ordinance sets a maximum block length of 400 feet in Section 6.5. C. We have arranged
to allow a longer block length than allowed by the UDO of approximately 700 feet on the street to the
north and approximately 600 feet on the street to the south. We felt that the Town had been very
understanding of the environmental considerations in allowing this deviation from the Town standards.
Pushing this street further east is prohibitively negative to the economics of the plan, damages the
continuity of the street pattern and block rhythm, and causes an unjustifiable violation of the Towns
Unified Development Ordinance.
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We were actually pretty proud of our avoidance and minimization efforts project wide by producing
over 720 new homes with such a relatively small total impact.
Comment 2
Kinsley Greenways are internal development greenways and not depicted on the Towns greenway
plans.
The greenways within Kinsley are more an extension of the typical sidewalks and pedestrian corridors
of urban areas. The Kinsley greenways serve as a pedestrian connection from the western side of the
existing pond, across the dam, Impacts 18 and 20, and back to the proposed multi -use path along a
proposed public street. The greenway then resumes with no additional impacts between the stream
and the back of several proposed homes, before it pops back out to become a multiuse path along
Lake Forest Drive which does not have a sidewalk. After crossing N. Main Street, the multi -use paths
continue along N. Main and the internal Boulevard to the main recreational amenity which is for the
private use of the residents.
There is a second greenway, Impact 10, that serves as a mid -block pedestrian connection between
sidewalks along two proposed public streets. We were able to get this approved through the Town
rather than to install a public street crossing of Stream Feature A as would typically be required by the
Town UDO. This is a further example of minimization that would be easy to overlook and was not
mentioned in Item 1 above.
None of the Kinsley Greenways will connect directly to Town greenways.
There are however some opportunities for pedestrian connection to other existing facilities. The
Kinsley greenway north of the existing pond will tie to a proposed street with sidewalk, that will tie to
an existing public street with sidewalk, that continues on to provide access to an existing Town
greenway trail along Richland Creek.
There are a/so some existing Town of Wake Forest greenway trails east of the site, but there will be no
future connection to those trails due to the existing railroad tracks that are due to be a part of the
future high speed rail network. As depicted on the Towns comprehensive greenway plans, there is a
future greenway corridor planned along Harris Road that would potentially continue east across the
railroad tracks, but this is south of the existing Heather Grove and Edgeford Park subdivisions south of
Kinsley, again with no planned direct connection between Kinsley and this future potential trail that
may never get built.
Tommy Craven
Priest, Craven & Associates, Inc.
Land Use Consultants
Planners/Landscape Designers/Engineers/Surveyors
919 781-0300
Thank you for keeping providing notification of the FWS and SHPO consultations. We're not
anticipating any issues and happy to assist in this in anyway.
Sincerely,
BOB ZARZECKI
Wetlands Department Manager/Principal
Soil & Environmental Consultants, PA
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From: Norton, April R CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, March 7, 2022 12:18 PM
To: Bob Zarzecki <[e-mail]>
Cc: Cohn, Colleen M <[e-mail]>
Subject: Request for Additional Information (Kinsley Subdivision) SAW-2018-01484
Dear Bob Zarzecki,
Thank you for your Preconstruction Notification and attached information, dated 2/9/2022, for the above referenced
project. I have reviewed the information and need clarification before proceeding with verifying the use of Nationwide
Permit (NWP) 29 (https://saw-reg.usace.army.mil/NWP2021/NWP29.pdf).
Please submit the requested information below (via e-mail is fine) within 30 days of receipt of this Notification,
otherwise we may deny verification of the use of the Nationwide Permit or consider your application withdrawn and
close the file:
1) Impact #1 for the proposed project indicates the need to place fill material in Stream B and Wetland 9 due
to a road crossing and a stormwater control measure. The need for such access is not disputed, however you
have not demonstrated avoidance and minimization to the maximum extent practicable as required by NWP
General Conditions 23(a) and (b). For example, it appears that such impacts may be avoided and/or
minimized by possibly realigning the road and/or lots. Please provide additional information regarding
Impact #1, including updates to the PCN/plans, as necessary.
2) Please provide additional information regarding the proposed greenway construction. Specifically, please
indicate if the proposed greenway would connect to the existing greenway near the property boundary
which appears to be a part of the Town of Wake Forest Comprehensive Transportation Plan, see the below
depiction.
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Legend
Mufti -Use Paths
Status
Completed
_ _ _ _ Linder Construction
G re eriways
Status
Completed
.. Under Construction
ate
rea
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New Light
Falls Lake State Nasentree Club
Recreation Area
Bayleaf
3) Given the proximity of this project to known populations of several threatened/endangered species, as well
as potentially suitable habitat for these species occurring the project action area, we will initiate informal
consultation with the US Fish and Wildlife Service (USFWS). Please note that the Corps cannot verify the use
of an NWP until Section 7 consultation is complete.
4) Given that the proposed project activities occur within a near potentially historical properties, I have
initiated informal consultation with the State Historic Preservation Office; they require up to 30 days to
respond to our coordination request. Please note that the Corps cannot verify the use of any NWP until
consultation pertaining to Section 106 of the National Historic Preservation Act is complete.
Please let me know if you have any questions.
Sincerely,
April Norton
April R. Norton
Regulatory Division
US Army Corps of Engineers
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone]
Fax: [phone]
Email: [e-mail]
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