20220972 Ver 1_More Info Received_20220929 (2)

Baker, Caroline D
From: Chris Huysman <[e-mail]>
Sent: Thursday, September 29, 2022 11:23 AM
To: Homewood, Sue; Perry Isner
Cc: [e-mail]; Dailey, Samantha J CIV
USARMY CESAW (US); Cohn, Colleen M; Matzen, Tanya
Subject: [External] Re: Request for Additional Information for Ammons Project - Wake County
- DWR#20220972
Attachments: Impacts G1 G2 - Alternatives Analysis 9.28.22 (1).pdf
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Sue -
Please see below for our initial responses to your September 2, 2022 letter requesting additional information.
We have included your text in italics and our response immediately follows.
Please do not hesitate to contact us if you have any questions.
1. A review of the project cannot be completed until the completion of a 30-day public notice as
issued by the US Army Corps of Engineers. If the U.S. Army Corps of Engineers 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.
We understand the Division's statement and that more comments may be forthcoming.
2. Please provide evidence of USACE verifications of the wetland and steams as shown on the
overall plan sheet.
I will be forwarding a May 4, 2022 email delineation concurrence from Lyle Phillips. Wetlands are depicted in green,
perennial streams are depicted with a dash and 3 dots, and intermittent streams are depicted with a dash and 1 dot.
3. In order to adequately assess DWR stream mitigation requirements for the proposed project,
please provide indication of intermittent/perennial stream determinations for all stream
features and provide DWR stream forms to support the determinations.
See above.

4. The proposed overall plan sheet does not appear to match the buffer determination issued
by DWR March 4, 2022:
a. Stream H does not appear on the proposed plan sheet,
b. Please verify that the start points of Streams AA and Z have been accurately surveyed
and shown on the plan sheets as they appear shorter than shown on the DWR buffer
approval map;
c. Stream A above the confluence of Stream F, as shown on the approved map from
buffer determination letter (shown below circled in blue) does not appear on the
proposed plan sheet.
The approved buffer determination has been relied upon for the preparation of the application.
a. Feature H was determined to extend approximately 15 feet from Stream A. The feature will be depicted on all
forthcoming maps and impact will be assigned accordingly. The feature is entirely in the first 30 feet of the Neuse River
Buffer and buffer limits will be adjusted accordingly.
b. The start points for all streams were field located using high accuracy GPS. Maps included in the DWR approval are
distorted.
c. Thes feature was reviewed during the field evaluation and it was determined that much of it is not subject to the
Neuse River Buffer Rules. Stream forms were completed along this feature and were included in the request and should
be part of the record. It is worthy to note that the soil survey depicts more stream segments and longer stream lengths
than are actually present on the ground.
5. The application states that proposed project will require permanent and temporary impacts
to Waters of the US and Waters of the State, however the impact information provided does
not clearly indicate which impacts are proposed as permanent and which are proposed as
temporary. Please provide a detailed breakdown of temporary and permanent impacts for
each proposed impact area.
The tables and drawings in the Public Notice depict both permanent and temporary impacts; they have been updated
since the date of the application that you reviewed.
6. Please provide proposed impact drawings that include grading limits for roadways so that
culvert lengths and buffer impact areas can be sufficiently reviewed. In addition, it appears
that buffer impacts are not proposed outside of the culvert/road fill, however it is the
Division's experience that dewatering activities and installation of riprap aprons require
additional buffer clearing. Please ensure that all buffer impacts are appropriately indicated
on the plans.
The applicant takes this comment as advisory.
7. It appears that buffers that are shown on the impact sheets may have been determined from
the existing stream centerline. Pursuant to 15A NCAC 028.0714(8)(0) the Zone 1 buffer
begins at the most landward limit of top of bank. Please provide clarification or updated
impact sheets and an updated impact table accordingly.

The project engineer and surveyor has utilized high resolution GIS Lidar to determine the maximum top of bank. The
buffer widths that are shown are in excess of the actual ordinary high water mark. The tops of banks will be field
surveyed and impacts further quantified at the time of the project approval.
8. The application states that the applicant determined that avoidance of the general fill for
residential lot construction was not practicable. Please provide specific details as to how this evaluation was
determined. Given the size of the development it is not clear that the loss of a small percentage of lots would render the
project financial unviable. A detailed analysis should be provided for each impact area individually, as well as the total
to avoid both impact areas. Please note that any financial evaluation provided should include the cost of mitigation for
the proposed wetland impacts. Please provide conceptual plan sheets with impacts areas and estimated amounts for
On -site Alternatives 1 and 2,
The financial impact of avoiding general fill is approximately 2.7 million dollars based on the attached summary.
9. The profile of Culvert Impact R1 and R3 do not indicate that the culverts will be buried at the
inlet and outlet to ensure aquatic passage. Please clarify why or provide a revised profile
drawing for the impact.
The drawings in the Public Notice show the burial of the culvert at the inlets and outlets.
10. The inlet alignment of the culvert at impact R3 appears to be at an extreme angle with the
natural channel. The Division has significant concerns about the proposed alignment causing
the upstream channel to become unstable. Please realign the culvert or otherwise address
impacts that would be expected to occur upstream of the current alignment.
The project engineer is not concerned that the upstream channel will become anymore unstable and will seal the
drawings at the time of the construction. The crossing is located proximate to a natural rock outcrop and the existing
upstream conditions are incised approximately 4 to 5 feet. The proposed culvert will be acting as grade control that
replicates the existing conditions.
11. The riprap apron proposed at Impact R3 is extensive. It is the Division's experience that
when excessively long 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 and included in mitigation amounts. Please revise the
application materials accordingly.
The project engineer has determined that proposed rip rap is necessary to stabilize the channel based on sound
engineering principles for the drainage area. Further, the rip rap is needed to comply with stabilization requirements
for erosion control. All rip rap will be underlain with geosynthetic fabric and be pressed into the channel
bed. Appropriately constructed dissipaters are not considered a loss under the applicable definitions of the US Army
Corps of Engineers regulations.
12. Please specify the width of the sewerline construction corridor and the width of the
proposed permanent maintenance corridor for all sewerline impact areas. For any areas with
a construction corridor greater than 40 feet or a permanent maintenance corridor greater
than 30 feet please provide justification for the proposed widths.

All sewer impacts, but for S4, S5, and S6, will have construction corridors that are less than 40 feet and maintenance
corridors less than 30 feet. A detailed typical and justification will be provided for those not meeting this
requirement. In part, City of Raleigh and NC DWR rules dictate that the sewers pass 3 feet under the channel bed and
this results in significantly deep construction based on the length of the outfall. Deep construction results in wider
construction corridors particularly where soils are saturated.
13. Impact S2 is a proposed sewerline crossing that does not appear to connect to anything.
Please provide additional information as to the purpose of this crossing location.
The site plans included in the Public Notice depict the proposed build out for the project. Impact S2 is required to serve
residential units. All impacts are necessary to meet the applicant's objectives.
14. 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 or cumulative impacts that cause or contribute to, or will cause or
contribute to, a violation of water quality standards," Based on the information provided
with the application, the Division believes there is potential for indirect impacts to the
following features within the overall project limits:
a. The large wetland adjacent to a SCM in the vicinity of impacts S2 & S3,
b. The wetland and stream adjacent to and below impact R2;
c. The stream above 510,
d. The stream above S13
The following comments are provided for consideration -
a. The basins are situated in high ground that is elevated above the wetlands. The existing wetland hydrology is
groundwater driven. The SCM areas have been preliminarily evaluated and there is no groundwater within the
separation distance between the bottom of the SCM and the high water table that is required by state law. This
separation supports our position that there is no potential for a quantifiable indirect impact.
b. The wetland and stream complex extends beyond the project area along the natural valley. The drainage area at the
proposed crossing is greater than 20 acres and there will be no indirect impact upstream of crossing R2.
The stream upstream of impact S10 will not be impacted by the proposed work. The groundwater driven system will
remain intact.
d. The stream and wetland complex located upstream of impact S13 will remain intact and will not be impacted by the
proposed crossing. The system is groundwater driven and the hydrology will not be impacted.
On Wed, Sep 7, 2022 at 4:45 PM Homewood, Sue <[e-mail]> wrote:

Please see attached. Hard copies will not be sent unless requested.
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
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Chris Huysman
336.406.0906
170 Dew Drop Road
Sparta, NC 28675
[e-mail]
[e-mail]
wetlands-waters.com
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Impact G-1
Prod uctType #of lots Revenue/Lot Cost/Lot Profit
40' Front Load 10 $ 125,000.00 $ (46,000.00) $ 790,000.00
20' Townhome 17 $ 80,000.00 $ (22,000.00) $ 986,000.00
Total $ 1,776,000.00
Cost of Mitigation $ (178,000.00)
Total Financial Impact $ 1,598,000.00

Impact G-2
Prod uctType #of lots Revenue/Lot Cost/Lot Profit
40' Front Load 7 $ 125,000.00 $ (46,000.00) $ 553,000.00
45' Front Load 7 $ 143,000.00 $ (52,000.00) $ 637,000.00
Tota 1 $ 1,190,000.00
Cost of Mitigation
$ (75, 000.00)
Total Financial Impact $ 1,115,000.00
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