20191445 Ver 3_More Info Received_20221011

Staff Review Form
NORTH CAROLINA
Envlronm¢ntcl Qvofiry
Updated September 4, 2020
Staff Review
Does this application have all the attachments needed to accept it into the review process?*
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ID# *
20191445
Version* 3
Is this project a public transportation project?*
Yes
• No
Reviewer List: * Sue Homewood:eads\slhomewood
Select Reviewing Office: *
Winston-Salem Regional Office - [phone]
Does this project require a request for payment to be sent?*
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Project Submittal Form
*
Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: *
For the Record Only (Courtesy Copy)
New Project
Modification/New Project with Existing ID
More Information Response
Other Agency Comments
Pre -Application Submittal
Re-Issuance\Renewal Request
Stream or Buffer Appeal
Pre -Filing Meeting Date Request was submitted on:
6/9/2020
Is this supplemental information that needs to be sent to the Corps?*
Yes No
Project Contact Information
Name:
Philip May
Who is submitting the information?
Email Address: [e-mail]
Project Information
Existing ID #:
20191445
20170001 (no dashes)
Project Name: Serenity Development
Is this a public transportation project?
Yes
No
Existing Version:
3
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
Yes No Unknown
County (ies)
Harnett
Please upload all files that need to be submited.
Click the upload button or drag and drop files here to attach document
Serenity_IP_DWR Comments_101022_Compiled.pdf 8.53MB
Only pdf or kmz files are accepted.
Describe the attachments or
comments:
Supplemental responses to DWR comments (initial responses provided on 9/9/22).

Sign and Submit
By checking the box and signing box below, I certify that:
• I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to the
best of my knowledge and belief.
• I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time.
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Statutes (the "Uniform Electronic Transactions Act");
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Submittal Date: Is filled in automatically.

CARO LI NA 3040 NC 42 West, Clayton NC 27520
EC O SYS T E M S P:919-606-1065 — F:919-585 5570
October 10, 2022
Mr. Paul Wcjoski
NC Division of Water Resources
512 N Salisbury Street
Raleigh, NC 27699-1611
RE: DWR # 2019-14450
Response to 8/10/22 Request for Additional Information
Serenity Development
Harnett County, North Carolina
Dear Mr. Wcjoski;
On behalf of Greenfield Communities, and Withers & Ravenel, please see below and the
attached information in response to your August 10, 2022 Request for Additional Information for
the above referenced project, and as additional information to supplement our September 9, 2022
response. Each individual comment received is in italics below, along with corresponding
response.
1. If the USACE requests a response to any comments received as a result of the Public
Notice, please provide the Division with a copy of your response to the USACE.
A revised alternative site analysis is being provided to the USACE, and NCDWR will be
copied on that response. The only additional comment requiring response is from the
State Historic Preservation Office. Field surveys for potential archaeological resources
are being coordinated with the USACE and SHPO, and will be resolved prior to permit
issuance by the USACE.
2. Please provide an analysis of potential secondary and cumulative impacts as a result of
this development pursuant to the Division's Cumulative Impact Policy.
Previously submitted response on 9/9/22.
3. In order to ensure that the project is appropriately authorized, the Division requires
documentation that the USACE has verified that wetland 23 is Isolated.
A field visit on 10/6/22 confirmed that there is no visible surface or subsurface
connection between this feature and down gradient jurisdictional resources. This visit
was approximately 1 week after the remnants of Hurricane Ian affected the site with 3+
inches of rain. Based on conversations with Liz Hair, USACE, a request for an Approved
Jurisdictional Determination is being submitted for this wetland area. Please coordinate
with the USACE to process this wetland as non-federal jurisdiction.
4. While the Division recognizes that impacts to wetland 24 were inadvertent, as clearly
stated in the application, significant design effort was made to avoid this feature in

Mr. Paul Wojoski
October 10, 2022
Page 2 of 5
previous submittal. Pursuant to 15A NCAC 02H.01305(b) "In assessing whether the
proposed activity will comply with water quality standards, the Division shall evaluate if
the proposed activity: (1) has avoided and minimized impacts to surface waters and
wetlands...". Please provide further evidence that the current proposal meets this
criteria when prior design indicates this area could be avoided.
Previously submitted response on 9/9/22.
5. Please provide a stream restoration detail and wetland restoration details for all
proposed temporary impact areas.
In addition to the previously submitted response, a stream crossing standard detail for
sewer construction is attached to this submittal. This detail, or an equivalent, will be
included in the final construction plans for the development.
6. In order for the Division to adequately evaluate potential impacts to stream and wetland
functions, please provide detailed plans and profiles for all proposed culverts. These
details should include temporary dewatering details and riprap apron design details,
proposed culvert slopes, culvert burial (if appropriate) and stream width and culvert
diameters.
Previously submitted response on 9/9/22.
7. For all locations where multiple culverts are proposed, the plan sheets must clearly
detail that low flows shall be accomplished in one culvert/pipe and additional
culverts/pipes shall be installed such that they receive only flows above bankfull. Please
provide design details that clearly show floodplain bench construction and/or sills at the
inlet and outlet of the culverts to ensure that the stream is not over -widened on either end
of the culvert. Please also provide a profile view of all stormflow culverts.
Previously submitted response on 9/9/22.
8. The alignment of the culvert outlet at stream impact S17 appears to be directed at a
streambank. Please either provide a revised alignment or provide more detailed
information to clarify or otherwise address the proposed alignment.
Previously submitted response on 9/9/22.
9. The riprap apron proposed at Impact S15 is extensive. Please provide plan and profile
construction details for the riprap outlet apron. The details should clearly show how
natural stream flow and conditions will be maintained within a low flow channel within
the enhanced riprap apron. It is the Division's experience that when excessively wide
riprap aprons are required for velocity control and/or stability that natural stream
function is not maintained and therefore these impacts should be considered as
permanent loss of stream.

Mr. Paul Wojoski Page 3 of 5
October 10, 2022
Previously submitted response on 9/9/22.
10. Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be
issued upon determining that the proposed activity will comply with state water quality
standards which includes designated uses, numeric criteria, narrative criteria and the
state's antidegradation policy, as defined in rules of 15A NCAC 02B.0200... In assessing
whether the proposed activity will comply with water quality standards, the Division
shall evaluate if the proposed activity: (2) would cause or contribute to a violation of
water quality standards; (3) would result in secondary and cumulative impacts that cause
or contribute to, or will cause or contribute to, a violation of water quality standards".
In order for the Division to fully evaluate the potential hydrological impacts on some
stream and wetland features within the project limits, please provide the location of all
outlet structures from the SCMs shown on the proposed plan sheet. In order to avoid
further requests for additional information upon receipt of the response to this item, the
Division strongly encourages that you carefully evaluate the proposed site plan for
locations where existing surface hydrology will be redirected which would have the
potential to remove or reduce the existing functions of a stream andlor wetland. Based on
the current proposed plan the Division believes there is potential for indirect impacts to
some features within the overall project limits.
A drainage area analysis map (SCM Outlet — Sheet No. Q) is attached showing relevant
drainage areas associated with SCMs that redirect a portion of stormwater flow on the
site from natural drainageways. The SCMs chosen for analysis, in coordination with your
office, exclude those associated with the previous permit action, those that have a
significant portion of their contributing drainage from off -site, and those that are located
along the major streams on site (i.e. Hector Creek) which are large systems unlikely to be
affected. Table 1 below summarizes the SCMs analyzed in Sheet No. Q, and provides
the existing natural drainage area and remaining post -construction drainage area at each
location.
The locations adjacent to SCM 9, 12, and 14 were reviewed in the field on October 6,
2022. While no direct evidence of current groundwater recharge was noted, there was
evidence of groundwater and surface water influence in several locations. At SCM 9, the
surrounding uplands adjacent to the wetland boundary exhibited a relatively impervious
clay lens approximately 2 feet below grade, and seasonal high water table evidence
approximately 1 foot below grade. At SCM 14 there was evidence of seasonal high water
table above the jurisdictional wetland elevation in the surrounding uplands, suggesting a
combination of surface and ground water recharge. No evidence of seasonal water table
was noted adjacent to wetlands below the jurisdictional pond near SCM 12, but the
wetland exhibited flow from pond seepage.

Mr. Paul Wojoski
October 10, 2022
Table 1.
Page 4 of 5
SCM
Nearby Wetland
Existing natural
drainage area (acres)
Remaining post -
construction drainage
area (acres)
7
WF - W25
6.06
4.62
9
WR - above W26
4.06
1.09
9
WR - below W26
8.44
2.68
10
WC - W32
22.89
11.42
11
WC - below W33
8.63
6.41
11
WC - above W33
6.82
4.02
12/13
WAX - below W24
4.62
1.55
14
WBJ
4.37
10.71
14
WBU
3.88
12.28
IL Please provide a conceptual construction schedule for all impacts proposed within the
application. Please note that mitigation will be required for ALL impacts unless a
mitigation schedule is requested, reviewed and approved by the Division. Please note
that any 401 issued by the Division will expire upon expiration of the 404 permit.
Greenfield has elected to pursue phased mitigation, as shown below in Table 2 and in the
attached Impact Phases Exhibit. Phases of mitigation are termed "groups" below for
clarification from the Construction Phases. The initial mitigation group would be
implemented immediately upon permit issuance. The groups associated with
Construction Phases 7, 8, and 9 would be implemented after construction plan approvals
for each phase are issued. Documentation of each group of compensatory mitigation
payment will be provided to the USACE and NCDWR prior to construction commencing
in any of the permitted impact areas associated with that group.
Table 2. Mitigation Grouping
Mitigation
Group
Impact Number
Impact Area
Construction
Phase
Miti able Impact
1
W23
E
6A/613
0.18 acre
1
W24
G
3
0.12 acre
Group 1 Total: 0.30 acre of permanent wetland
impact
2
S 12
C
7
0 linear feet
2
S 13
C
7
130 linear feet
2
S 14
D
7
120 linear feet
Group 2 Total: 250 linear feet of permanent stream
impact
3
S 15
F
8
102 linear feet

Mr. Paul Wcjoski
October 10, 2022
Page 5 of 5
Group 3 Total: 102 linear feet of permanent stream
impact
4
S 16
H
9
0 linear feet
4
S17
1
9
158 linear feet
4
S 18
M
9
0 linear feet
4
S 19
M
9
0 linear feet
4
W25*
H
9
0.01 acre
4
W26
I
9
0.04 acre
4
W27
I
9
0.02 acre
4
W28*
J
9
0.07 acre
4
W29
J
9
0.02 acre
4
W30
K
9
0.30 acre
4
W31
L
9
0.05 acre
4
W32*
M
9
0.02 acre
4
W33*
M
9
0.01 acre
Group 4 Total:
158 linear feet of permanent stream impact
0.11 acre of permanent wetland conversion
0.43 acre of permanent wetland impact
*indicates permanent, no loss, impact
In discussion with the USACE, we anticipate the Individual Permit to expire 5 years from
issuance, which based on the current schedule for construction would allow the project to
be completed.
Please contact me at your convenience if you have any questions or require further information.
Sincerely,
Carolina Ecosystems, Inc.
Philip May
Vice President/Senior Environmental Scientist
Cc: Sue Homewood, NCDEQ WSRO
Chad Turlington, NCDEQ FRO
Liz Hair, USACE Wilmington
Matthew Brubaker, Greenfield Communities
Attachment List:
Stream Crossing Detail
SCM Outlet — Sheet No. Q
Impact Phasing Exhibit

TO MATCH
PRE -CONSTRUCTION
STREAM CONTOUR
RIPRAP APRON DETAIL
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