20220972 Ver 1_More Info Received_20221212

Baker, Caroline D
From:
Chris Huysman <[e-mail]>
Sent:
Monday, December 12, 2022 2:03 PM
To:
Dailey, Samantha J CIV USARMY CESAW (USA); Homewood, Sue
Subject:
[External] SAW-2022-00367 Ammons Property / DWR 20220972
Attachments:
221212 ammons cover letterhead.pdf, 2022.12.08.Ammons Wetlands Impact
Exhibit.pdf, 221212_USACE Impact Table Finalized by phase.xlsx; 221212 ammons
cover letterhead.docx
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Sam and Sue -
Attached please find additional information that you have requested. Do not hesitate to call me with any questions.
Have a great holiday season and we can catch up in the new year on this one.
Attached are revised impact drawings, a cover letter (word and pdf) and an excel impact table.
Thanks
Chris Huysman
336.406.0906
170 Dew Drop Road
Sparta, NC 28675
[e-mail]
[e-mail]
wetlands-waters.com
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WETLANDS
ly4ysa: WATERS? INC.
December 12, 2022
Sam Dailey
Chief, Charlotte Regulatory Field Office
U.S. Army Corps of Engineers, Wilmington District
8430 University Executive Park Drive, Suite 615
Charlotte, NC 28262
RE: Action ID: SAW-2022-00367
Ammons Property (residential subdivision)
Ms. Dailey,
The purpose of this correspondence is to respond to your October 24, 2022 request for additional
information for the processing of the Department of the Army for the Ammons Property (residential
subdivision). For ease of reference, we have included the requested information in this letter; it is
indented and in bold.
We drafted a separate email response to the NC Division of Water Resources on November 28, 2022 to
respond to their requests for additional information dated September 29, 2022. This document included
supplemental information and plans that were requested as part of their review.
Attached are revised site plans and impact tables that quantify the currently proposed impacts.
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.
i. Specifically, please add to the alternatives analysis provided in your
Individual Permit application (June 30, 2022) and with revisions
received on September 6, 2022:
a. Site selection criteria: Please provide specific, measurable
criteria for your On -Site and Off -Site alternatives analysis.
Your permit application evaluated contiguous acreage
available, zoning, and utilities. These are not sufficient criteria
to determine the least environmentally damaging practical
alternative. Please also include stream impacts, wetland
impacts, threatened/endangered species, historic properties,
minimum size (acreage) requirement, property available for
purchase, and any other applicable criteria. This information
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
should be outlined in a table for comparison with each
alternative analysis.
Below is a table that supports a determination that the proposed impacts are the least environmentally
damaging practical alternative available to the developer at the time the project commenced. The Veridia
site, refenced in the following table, was contemplated for development by Brookfield in December 2020
and initially reviewed by Wetlands and Waters, Inc. in January 2021. Brookfield declined to move
forward with this project based on anticipated environmental impacts, infrastructure availability, and
financial returns.
Table 1.
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Preferred
468
120
75.34
12.3K
74%
3
428
1.61
Yes
Yes
1
Alternative
Alternative
468
120
75.34
12.3K
74%
3
428
0.48
Yes
Yes
1
1
Veridia*
1092
150
13
58K
75%
25
3500
2.5
Yes
No
4
Off -Site
* The Veridia project started to receive local approvals circa 2009 and was issued USACE AID# 2010-
01907. Brookfield and their consultants investigated the development of the site using different
development concepts that would reduce impacts to streams and wetlands. Percent usable land assumes
streams to have 50-foot regulated buffers on each side of them where they are outside of the 100-year
floodplain. All values are estimates based on then available public information.
b. Off -site alternatives: Please explore Off -Site alternatives in
accordance with the above referenced criteria. Correlating
maps/design drawings should be provided for each off -site
alternative. If Off -Site alternatives are not practicable, please
provide a detailed explanation as to why.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
See Table 1. for an analysis of an off -site alternative to the project. Brookfield specializes in creating
developments that have a minimum of 1500 dwelling units and a minimal impact on the environment
while achieving market appropriate financial returns. Generally speaking, these unit counts are only
achievable on tracts with usable acreage in excess of 300 acres. The estimated mitigation stream
mitigation for the Veridia project was in the range of 3.25 to 5 million dollars at the time of due diligence
m 2021. The analysis shows that the Veridia project was not a practicable project for this developer
based on information that was available at the time of their due diligence.
c. On -site alternatives: Please provide quantitative data that
supports your On -Site alternatives configurations, including
design drawings. For example, your On -site Alternative 1
states: "On -site alternative 1 proposed an equivalent amount
of road and sewer impacts, but eliminated wetland impacts for
residential unit construction. The applicant determined that this
alternative was not economically practicable and would result
in a non -viable project, therefore this alternative was
eliminated from consideration." This information is not
sufficient to evaluate as an alternative.
Elimination of Lot Fill -
The following images are excerpts from the proposed site plan. The red lines illustrate approximate
changes in the road configuration and the lots shown in pink represent lots that are likely lost due to street
setbacks and grading requirements, were these wetlands to be avoided.
The following tables list the projected total financial impact for each of the lot areas. The total revenue
generated by the proposed fills, less the mitigation, is $2.7M.
Impact G-1
Product Type #of lots Revenue
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 27 $ 1,776,000.00
Cost of Mitigation
$ (178,000.00) I �_
Total Financial Impact $ 1,598,000,00
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS
IMPACT G1

WETLANDS
ly4ysa: WATERS? INC.
Impact G-2
Product Type #of lots Revenue/Lot Cost/Lot Profit 1
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
Total 14 $ 1,190,000.00
Cost of Mitigation $ (75,000.00)
Total Financial Impact $ 1,115,000.00
The proposed development consists of 1562 lots spread over 6 development phases. Below is a table
depicting the proposed lot release schedule based on development phases and market. These
development phases are not necessarily the same as the mitigation phases due to the lead time necessary
to construct infrastructure prior to selling lots.
Development Phase Total Lots Delivery Date
Phase 1
266
4Q24
Phase 2
244
3Q25
Phase 3
291
1Q26
Phase 4
276
4Q26
Phase 5
253
4Q27
Phase 6
232
3Q28
A total of 41 residential units are currently reflected in the G1 & G2 impact areas. While the loss of
$2.7M in revenue is significant, the real effect to the proforma is in the rate of return. The lots shown in
G1 & G2 are anticipated to be in the 1st and 2nd phase of the project, meaning revenue that was
anticipated to be recognized early and be used to offset the huge amount of upfront infrastructure that has
to be constructed before any lots can be sold.
The upfront infrastructure for phases 1 and 2 includes approximately 3,084 linear feet of 3-lane
Undivided Minor Thoroughfare, 813 LF of 2-Lane Undivided Minor Collector and 6,854 LF of Local
Streets & alleys. If areas G1 and G2 were not impacted then the roadway infrastructure would decrease
by just 232 linear feet of Local Street (380 LF less + 150 LF for new street alignment at G2), with the
entire —3,900 LF of Minor Thoroughfare and Minor Collector still being required per the Town of
Wendell Master Throughfare Plan.
Additionally, the sewer infrastructure improvements remain constant. Approximately 2,348 LF of gravity
sewer outfall and 5,134 LF of sewer forcemain will need to be constructed in order to tie Phases 1 & 2 to
the proposed pump station.
The proposed impacts are necessary in order to quickly generate revenue and ensure a financially viable
project. The development of the project cannot be practically accomplished in a manner that avoids
impacts to these wetlands or results in less impacts to these wetlands as described below.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
The $2.7M in revenue as a critical offset for the estimated $24M in first and second phase infrastructure
costs. Of note, we provide the following estimated costs that need to be offset early in the project:
• $320K- for first phase road and sewer stream, wetland and buffer mitigation
• $100K - $600K (depending on rock) - for sewer boring costs associated with impacts S4 and S6
• $120K- for headwalls at the road crossings to reduce impacts
• $500K for enhanced erosion control measures (double row reenforced silt fence)
• $20K for stormwater management
• $193K- for mitigation for impacts G1 and G2
If we were to lose these 41 lots, the rate of return would drop between 1.5%-2%, which would make the
project financially unfeasible.
Complete Avoidance of Impacts
The applicant provides the following quantitative table for completely avoiding all impacts to streams,
wetlands and buffers for the construction of sewer infrastructure. Estimated costs are based on the
engineer's opinion of the costs to install the utilities based on engineering experience and market
conditions; the costs do not include materials.
Table 3.
Sewer
Estimated Cost
Estimated Length
Total Costs for
Construction
Per Running Foot
of Construction
Installation
Methodology
Horizontal
$400/lf
2040
$816K
Drilling
Conventional
$95/lf.
2040
$193K
Open Trench
Difference
$623K
The applicant provides the following quantitative table for completely avoiding all impacts to streams and
wetlands for the construction of road infrastructure. The cost opinions presented in the table are the costs
associated with the infrastructure that is needed to avoid the impact and does not reflect surface treatment
and incidental earthwork. Note: NC DOT does not typically approve bridged crossings in residential
subdivisions due to maintenance costs and other factors.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
Table 4.
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R1 (72"
$10K
110 feet
$1.1M
$950/lf
$192K
$335K
RCP)
(150.01
R2 (54"
$10K
90 feet
$900K
$725/lf
$188K
$295K
RCP)
(146.31
R3 (12'x6'
$10K
40 feet
$400K
$125K
$266K
$391K
Box
Bridge
$2.4M
Conventional
$1M
Total
Total
The costs to totally avoid impacts to streams and wetlands exceed $3M.
d. Please explain how your preferred alternative is the least
environmentally damaging, practical alternative.
The preferred alternative is the least environmentally damaging practical alternative because:
1. It avoids wetland fills in the 100-year floodplain with the exception of a road crossing to access a
portion of the property that will be constructed entirely in high ground.
2. It avoids wetlands that are adjacent to tributaries thereby reducing the potential for damage to
both wetlands and streams and preserving the integrity of the large riparian areas throughout the
project.
3. It avoids impacts to high quality forested wetlands within the floodplains of minor tributaries
within the site.
4. It limits potentially damaging impacts to water quality through the implementation of stringent
erosion control measures and stormwater controls.
5. It avoids impacts to larger tributaries through the use of horizontal drilling.
B. It is necessary for you to have taken all appropriate and practicable steps to
minimize losses of Waters of the U.S., including wetlands. Please indicate all
that you have done, especially regarding development and modification of
plans and proposed construction techniques, to minimize adverse impacts.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
i. The information provided in your submitted application is not sufficient
to assess if all appropriate and practical steps were taken to avoid and
minimize losses to waters of the U.S. Therefore, please provide
specific and measurable avoidance and minimization measures taken.
Please be sure to discuss impacts to waters of the United States.
The applicant provides the following narrative to demonstrate all the practical steps and proposed permit
special conditions that will avoid and minimize direct and indirect impacts to wetlands and waters,
protected species, and cultural resources.
Endangered Species Special Conditions (proposed)
1. Based on consultation with the U.S. Fish and Wildlife Service pertaining to Section 7 of the
endangered Species Act, the following conditions are required for the Ammons Property
(residential development):
The applicant shall commission protected species surveys 90 days in advance of any construction
in wetlands or waters associated with Impacts R3, S4 and S6. The applicant shall provide the
Corps and the US Fish and Wildlife Service a preliminary statement of the survey's findings
within 24 hours and develop a relocation plan as needed. Impacts to waters of the US at these
locations shall not occur until the US Fish and Wildlife Service issues a biological opinion.
a. The extent of tree removal and grading required for the construction activities must be
minimized by planning and scheduling activities in sequence, as appropriate. Areas where tree
removal is not required and access is not otherwise needed for construction of infrastructure,
buildings, or amenities must be fenced during construction to prohibit vehicle entry. Graded or
disturbed soils must be stabilized with native grasses or mulch covers within 14 days of
completion of the disturbance activity;
b. The contractor must be advised about the presence of sensitive species by providing
information and installing visible and weather-proof signage (see the attached signage with the
heading labeled "NOTICE!") on the silt fence at regular (i.e. at least 300-foot) intervals along
clearing limits adjacent to streams and wetlands shown on the approved delineation map;
C. Access for equipment and vehicles to construct the sewer infrastructure must be limited
to those shown on the attached plansheets. No impacts to wetlands, streams, or other potential
waters of the US are authorized for access other than those specified on the attached plansheets;
d. Stringent erosion control measures must be implemented during construction within
100-feet of the Little River floodplain and the perennial stream channel along the southern
property boundary, including: A double row of silt fence, to ensure that erosion is captured
effectively. Silt fence and other erosion control devices must not include outlets that discharge
closer than 50 feet to the top of bank of any stream. Silt fence outlets for each row of silt fence
must be offset to provide additional retention of water and sediment in the outer row;
e. The discharge outlets from stormwater infrastructure must be designed to avoid stream
buffers, including the dissipator pad or any other structures;
f All mechanized equipment shall be regularly inspected and maintained to prevent
contamination of waters and wetlands from fuels, lubricants, hydraulic fluids, or other toxic
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
materials. In the event of a spill of petroleum products or any other hazardous waste, the
Permittee shall immediately report it to the Corps at
Samantha.J.Daileykusace.army.mil <mailto: Samantha.J.DaileyAusace.army.mil > , U.S. Fish
and Wildlife Service (USFWS) at john_elliskf vs. oovv <mailto John_ellisAfws. oovv> , and N.C.
Division of Water Resources (NCDWR) at [phone] or [phone], and provisions of
the North Carolina Oil Pollution and Hazardous Substances Control Act shall be followed.
Inspections, repairs, cleaning, and/or servicing must be conducted either before the vehicle,
equipment, or machinery is transported into the field or at the work site;
g. All drilling muds, wash -water runoff, and/or other harmful materials must be
appropriately controlled to prevent entry into a waterbody or riparian zone;
h. Vehicles and equipment must be fueled and maintained, and potentially toxic
substances (fuels, paints, solvents, lubricants, etc.) must be stored, within a containment area in
uplands at least 100 feet from the top of bank;
i. Temporary and permanent stabilization measures should include only natural materials
that are expected to degrade over time;
j. Revegetate with native species. Sericea lespedeza is invasive and should not be used for
stabilization or revegetation in regulated wetlands, floodplains or stream buffers. Portions of the
sewer ROW that are not intended for long-term maintenance should be revegetated with native
trees and shrubs;
k. Conduct bi-weekly inspections of all erosion and sedimentation controls adjacent to the
floodplain of Little River floodplain and the perennial stream channel along the southern property
boundary, and in uplands within 100 feet of the riparian zones of all streams. Maintain all
controls as necessary to ensure proper installation and function. In addition to bi-weekly
inspections, within 24-hours of rain events, inspect all of the erosion and sedimentation controls
to ensure the integrity of the devices. Repair and replace sections of controls as needed to
minimize the potential for failure;
1. If erosion and sedimentation controls fail causing sediment or erosion in the floodplain
wetlands or stream buffer of the Little River floodplain and the perennial stream channel along
the southern property boundary, the Corps and Service must be notified within 24 hours to
determine if any remediation is required.
in. Completion of Environmental Inspection Report Form: After each inadvertent release,
the environmental inspector will complete an Environmental Inspection Report Form. This form
will contain information of the date, time, location, duration, and estimated amount of the release,
as well as containment and clean up activities. The environmental inspector will also contact
regulatory and resource agencies no more than 24-hours after clean-up and recovery of the
release.
n. Site Restoration: After the complete installation of the force main, restoration activities
will be implemented according to the project's Storm Water Pollution Prevention Plan (SWPPP)
and Erosion and Sedimentation Control Plan. Tie in pits will be backfilled with a mix of drill
returns and minor excavate material removed during the pipe connection process. Disturbed areas
will be seeded with native vegetation and covered with mulch to prevent further erosion.
Abandoned drill holes will be sealed with either a sand/concrete slurry or a mix of drill returns.
Cultural Resources Special Conditions (proposed)
2. Based on consultation with the NC Department of Natural and Cultural Resources relating
to Section 106 of the National Historic Preservation Act, the following conditions are required for
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
the Ammons Property (residential development):
a. Site 31WA2534, which yielded American Indian artifacts from the Middle Archaic
and Early/Middle Woodland Periods and appears to contain deep deposits with intact
stratigraphy, shall not be impacted by the proposed development.
b. Should ground disturbing activities not shown on the design plan, such as land
clearing or grading for walking trails, be proposed within 500 feet of site 31WA2534, measures
shall be taken to avoid site 3IWA2534 inclusive of a 100-foot buffer. The site and buffer area
shall be marked as an environmentally sensitive area on construction plans and be delineated with
high visibility fencing to avoid accidental encroachment. The site and the buffer are depicted on
the plan coversheet.
Erosion Control — The applicant has committed to stringent erosion control measures that include super
silt fence along the perimeter of the site where it drains directly to the Little River and other tributaries.
Super silt fence is two rows of fence with the closest to the aquatic resource being supported by chain link
fence. Brookfield has a solid reputation with Wake County Erosion Control for the implementation and
management of erosion control devises.
Stormwater Management - The site plan depicts 17 stormwater management ponds located throughout the
site. Each of the basins will discharge outside of the Neuse River Riparian Buffers. Wake County
stormwater rules require protection of riparian buffers, peak flow control and nitrogen control from new
development.
This will be achieved by detaining the 1-inch storm event for 2-5 days and the 1-year, 24-hour storm
event so that the peak flow rate doesn't increase from the pre -development rate. An emergency spillway
will be provided to safely pass runoff from extreme storm events or in the event the outlet structure
becomes clogged. These requirements will be met by utilizing 17 onsite Stormwater Control Measures
that will discharge at non -erosive velocities through the use of energy dissipator pads at each outfall.
Wake County is a delegated authority for stormwater management and the plans will comply with their
applicable standards.
Construction Methods and Considerations -
The applicant commits to using construction mats for work in wetlands associated with the
installation of the sewer infrastructure.
• The applicant commits to using pump arounds to ensure that construction is in the dry.
• The applicant commits to using non-invasive species for stabilization within floodplains,
riparian areas and wetlands.
• The applicant commits to create containment areas for lubricants and fuels at least 100 feet
from the top of stream banks.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
ly4ysa: WATERS? INC.
The applicant will ensure that perimeter erosion control is established prior to starting
clearing and grubbing
The applicant commits to exceeding best management practices for forestry during any
timbering activities on the site.
ii. Please provide an explanation as to why utility Impact S6 cannot be
achieved utilizing horizontal directional drilling.
The applicant has agreed to horizontal drill sewer crossings 4 and 6 at an estimated cost of $256K.
Further, the applicant will commission protected species survey 90 days in advance of the borings to
further limit potential adverse impacts to them. The applicant will provide the Corps and the US Fish and
Wildlife Service a preliminary statement of the survey's findings within 24 hours and develop a
relocation plan if needed.
iii. Please provide additional justification regarding impacts GI and G2
and why these areas cannot be further avoided and minimized.
Please see above section titled "Elimination of Lot Fill" for additional justification regarding impacts G1
and G2.
C.i. I have evaluated the compensatory mitigation plan included in your
application and have determined the details to be generally sufficient
for our evaluation. You are proposing a 2:1 and 1:1 mitigation to impact
ratio for the proposed stream and wetland impacts and would purchase
4.75 wetland mitigation units and 856 stream mitigation units from
Wildlands Holdings III, LLC's Falling Creek UMB, McClenny Acres II
Mitigation Site and Falling Creek Mitigation Site.
The applicant requests that the file specifically reflects that the applicant avoided impacts to over 60 acres
of wetlands and 11,000 linear feet of streams and that they remain in protected open space within the
development.
The applicant proposes the following phased mitigation plan for impacts to wetlands and streams. The
mitigation proposal utilizes the agreed upon ratios but has been revised to reflect the reduction of impacts
that result from boring two of the sewer crossings.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WWETLANDS
, & WATERS, INC.
Table 5.
Payment
Impact ID's
Stream Mitigation
Wetland Mitigation
Wetland
Date
(Impact) / Units
(fill) / Units
Mitigation
2:1
2:1
(conversion)
Phase 1
4/15/2024
G1, RI, S 1,
(191 If) / 382 units
(0.864 ac) / 1.728 units
0.16 units
S3, S5
Phase 2
4/15/2025
G2, R2, S2
(0.56 ac) / 1.12 units
0.29 units
Phase 3
4/15/2026
S7, S8, S9,
0.78 units
S10, S11, S12,
S13
Phase 4
4/15/2027
R3
(237 If) / 474 units
(0.20 ac) / 0.40 units
Totals
856 units
3.248 units
1.23 units
The applicant proposes the following phased mitigation plan for impacts to Neuse River Buffers as
required by the rules.
Table 6.
Payment
Date
Locations with impacts to buffers
by Impact ID
Zone 1 Impacts
Zone 2 Impacts
Phase 1
4/15/2024
R1
13021
7628
Phase 2
4/15/2025
S2 allowable w/o mitigation)
N/A
N/A
Phase 3
4/15/2026
S10, S13 (allowable w/o)
N/A
N/A
Phase 4
4/15/2027
R3
16041
8926
Thank you for your time and consideration and please do not hesitate contact me at
chrishuysmankwetlands-waters.com or 336.406.0906 with any questions or comments that you might
have.
Best regards,
Cc: Sue Homewood
John Ellis
Renee Gledhill Earley
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

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ROADWAY IMPACTS
IMPACT#
ZONE 1
ZONE 2
WETLAND
STREAM
RIP RAP
TEMPORARY PUMP-
AROUND
TEMPORARY
WETLAND IMPACTS
S.F.
I AC.
S.F.
AC.
S.F.
AC.
L.F.
S.F.
L.F.
S.F.
L.F.
S.F.
S.F
AC.
R1
13,021
0.30
7,628
0.18
2,398
0.06
191
764
60
1080
59
4747
0
0.00
R2
0
0.00
0
0.00
9,746
0.22
0
0
45 *
540 *
0
0.00
R3
16,041
0.37
8,926
0.211
7,098
0.161
237
23661
85
3060
50
43i291
2,176
0.05
TOTAL
29,062
0.67
16,554
0.381
19,242
0.441
428
31311
190
4680
109
90761
2,176
0.05
SEWER
IMPACTS
IMPACT#
ZONE 1
ZONE 2
WETLAND
STREAM
RIP RAP
TEMPORARY PUMP-
AROUND
TEMPORARY
WETLAND IMPACTS
S.F.
I AC.
S.F.
AC.
S.F.
AC.
L.F.
S.F.
L.F.
S.F.
L.F.
S.F.
S.F
AC.
S1
0
0.00
0
0.00
1,043
0.02
0
0
0
0
0
0 0
0.00
S2
2,929
0.07
1,778
0.04
2,177
0.05
46
228
0
0
0
0 761
0.02
S3
0
0.00
0
0.00
489
0.011
0
01
0
0
0
0 0
0.00
S4
0
0.00
0
0.00
0
0.00
0
01
0
0
0
0 0
0.00
S5
0
0.00
01
0.00
5,057
0.12
0
0
0
0
1 0
0 1,2481
0.03
S6
01
0.00
0
0.00
0
0.00
0
0
0
0
0
0 0
0.00
S7
0
0.00
0
0.00
3,487
0.08
0
0
0
0
0
0 292
0.01
S8
0
0.00
0
0.00
8,549
0.20
0
0
0
0
0
0 2,540
0.06
S9
0
0.00
0
0.00
6,254
0.141
0
0
0
0
0
0 2,254
0.05
S10
2,907
0.07
1,817
2725.66
0
0.00
45
182
0
0
01
0 0
0.00
S11
0
0.001
01
0.00
7,557
0.17
0
0
0
0
0
0 2,4871
0.06
S12
0
0.00
0
0.00
212
0.00
0
0
0
0
0
0 1591
0.00
S13
2,851
0.07
1,636
0.04
0
0.00
41
164
0
0
0
0 0
0.00
TOTAL
8,687
0.20
5,231
2725.74
34,825
0.80
T321
574
0
0
0
0 9,7411
0.22
GENERALIMPACTS
IMPACT#
ZONE 1
ZONE 2
WETLAND
STREAM
RIP RAP
TEMPORARY PUMP-
AROUND
TEMPORARY
WETLAND IMPACTS
S.F.
I AC.
S.F.
AC.
S.F.
AC.
L.F.
S.F.
L.F.
S.F.
L.F.
S.F.
S.F
AC.
G1
0
0.00
0
0.00
34,788
0.80
0
0
0
0
0.00
G2
0
0.00
0
0.00
14,533
0.33
0
0
0
0
0.00
TOTAL
0
0.00
0
0.001
49,320
1.13
0
0
0
0
0 0
0.00
GRANDTOTAL
37,749
0.87
21,785
2726.12
103,387
2.38
560
3704
190
0
4680
109.37
9075.971
11,917
0.27
* Rip Rap outlet protection placed in the wetlands is considered a permanent wetland fill and will be mitigated.
v,NT M&CREED
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
O: 919.233.8091 F: 919.233.8031
Impact Table
Date:
Dec 6 2022
Ammons Property

--0
0
............ ............
...........
Z
...........
..........
IMPACT G1
0.
Al
......... ....
.. ..........
.............
.............
IMPACT PROFILE G1
SEE PROFILE, NEXT .........
.
SHEET C) .......
/M .......
A-
............
. . . . . . . . . . .....
PROPOSED
EXISTING' STORM WA TER
EXISTING WETLAND AREA TO WETLANDS BMP
BE PROTECTED
IMPACT S1
PROPOSED GRA OTY ..........
SEWER OUTFALL ........
PROPOSED CITY OF RALEIGH- EEEEi��
,,SANITARY SEWER EASEMENT��=--
Wetland Impact Map Scale: 1"=60'
*1$-�,NjqKIN4&CREED 77=J=L-.�
1730 Varsity Drive, Suite 500 Impact G1 & S1 0 30 60
Raleigh, North Carolina 27606 Date:
0: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6, 2022

310
310
305
305
i
i
300
300
PROPOSED
ROAD
GRADE
295
4" DEEP 7RENCH
UNDERDRAIN
FOR
295
_
FILL TRENCH WI7H
STONE
290
290
EXIS77NG GRAD£
PROPOSED UNDERDRAIN
285
(LOCA77ON APPROXIMA7E)
�n
-
N
o�
M o
Qf ,
N
��
o1
1lq� r�
N
o��
1�
r�
N
coM �M1 coM1
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ri t N NpM c�
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coN
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N
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lM
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Oqpj
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cis
M r�
pNp
N
�O
c�
pMp
N
1� og
N
�O
ro
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N
9+50 10+00 10+50 11+00 11+50 12+00 12+50 13+00 13+50 14+00 14+50
v,McIQM&CREED
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
0:919.233.8091 F:919.233.8031
Wetland Impact Profile
Impact G1
Ammons Property
Scale: 1"=80'
0 40 80
Date:
Dec 6, 2022

1
30' NEUSE RIVER RIPARIAN
BUFFER ZONE 1 (TYP)
\ \ 1-120' NEUSE RIVER RIPARIAN
\ BUFFER ZONE 2 (TYP)
\
EXISTING WETLAND AREA TO
\ BE PROTECTED
.........
EXISTING . . . _ _{0 . . . . . . WETLANDS . . . . .
. \
i
IMPA C T G2
7-
4
,MCKN4&CREED
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
0:919.233.8091 F:919.233.8031
Wetland Impact Map
Impact G2
Ammons Property
Scale: 1"=50'
0 25 50
Date:
Dec 6, 2022

275
275
270
°
°
270
265
265
260
PROPOSED
GRADE
260
255
24' DEEP
UNDERDRAIN
RLL TRENCH
TRENCH FOR
WITH STONE
255
250
EXISTING
GRADE-125Q
245
PROPOSED
(LOCATION
UNDERDRAIN
APPROXIMATE)
245
c�
�
r
$N o
N
M r�
O�jl c�
N N
P r�
�Mjj
N N
0
pp o3
N N
t in
N
h
N N
Ion�
O�
N
't t
03
N
M o
N
Mf in
Mf �n
o
O co
�!1 00
9+50 10+00 10+50 11 +00 11 +50 12+00 12+50 13+00 13+50
v,McIQM&CREED
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
0:919.233.8091 F:919.233.8031
Wetland Impact Profile
Impact G2
Ammons Property
Scale: 1"=80'
0 40 80
Date:
Dec 6, 2022

T

0
Q
0
F
270
265
I
PROPOSED
FORCE MAIN
PROPOSED
�
I
GRADE
STANDARD
WINGWALL
MITERED
FOR J. 1
FILL SLOPE
260
3. 1
STANDARD
MITERED
WINGWALL
FOR J. 1
3: 1
FILL
SLOPE
I
255
250
UPSTREAM
0, � LP
60 '-7
-1
1
72"RPC�7.7�
IN
VER T=251.82
/milli
DOWNSTREAM-1
INVERT=250. 08
EXISTING
GRADE
245
KEYED-lN RIPRAP
OUTLET PROTECTION
PLACED AT 36" DEPTH
I I
FABRIC UNDERLAYMENT
240
I�
0
�n CN I�
O)
N N
0
00 0
M 0
0 0
P.-0
to 0
00 0
00 0
Ln 0
0
0
0
0
n
cG o
n n
N N N
(V o
c0 n
N N
o
co n
N N
o
co n
(V N
o
co n
(V N
M o
Lo
N N
0
N
0
N
9+50 10+00 10+50 11 +00 11 +50 12+00 12+50 13
v,McIQMCREED
1730 Varsity Drive, Suite 500
Wetland Impact Profile
Impact R1
Scale: 1"=50'
0 25 50
Raleigh, North Carolina 27606
O: 919.233.8091 F: 919.233.8031
Date:
Dec 6 2022
Ammons Property

\ PROPOSED SEWER
FORCE MAIN
PROPOSED CITY OF RALEIGH / / / ♦ /
SANITARY SEWER EASEMENT /
FM / / .
/ i EXISTING
RIPRAP OUTLET PROTECTION / / / / 'WETLANDS
i
Ile
-V . . . . . . . . ...
IMPACT-
--IF1111W.
/. J
j
.
. . . . . .11+.
. . .. 1p p
30' NEUSE RIVER RIPARIAN
vt BUFFER ZONE 1 (TYP)
54" RCP 20' NEUSE RIVER RIPARIAN
STORM PIPE BUFFER ZONE 2 (TYP)
v,MCIQM&CREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact R2 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

285
280
Q*j
0
0
275
PROPOSED
GRADE
270
J. 1
STANDARD
WINGWALL
3. 1
MITERED
FOR J. 1
FILL SLOPE
265
STANDARD
MITERED
WINGWALL
FOR J.-1
FILL SLOPE
260
RC
, 7.5
q
45
UPSTREAM
IN
IiERT=260.68
255
EXISTING
GRADE
DOWNSTREAM
INVERT=257. 98
KEYED —IN RIPRAP
OUTLET PROTECTION
PLACED AT 36" DEPTH
250
FABRIC UNDERLAYMENT
00 0 00 N O [-- * o
O 00 � c0 00 1­ � o
O
� 0-)
0-)
I- co
O) N
00 r-)
I�- 0-)
�0
n co
0-)
r0
00
O
oO
0'L6
(_0
(7),O
(0 Ln
(7),O (7),6 00'06 cod
r- Ln r- Ln(0 Ln(0 Ln
1__'
O Ln
r� r-:�
N L
N Ln
N
N
N N
N N
N N N N N N N N
N N
N N
N N
N
9+50 10+00 10+50 11 +00 11 +50 12+00 12+50 13
Wetland Impact Profile
Scale: 1"=50'
v,McIQM&CREED
Impact R2
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

DISSIPATIONOR SILT SAC
IMPERVIOUS DIKE'
(TEMPORARY,
EXISTING
BE PROTECTED p'I •.
IP
AN
•-• •-• -'
� mot► r /� /�� i�/�i�
L lNOF
I
KIImpact Map Scale: 1"=50'
Wetlan'
North•
Ammons• Dec

r
c�+
0
0
z
250
250
245
PROPOSED
245
GRADE
240 STANDARD
NGAL-
7ER£D�FORW 3L 1
RLL SLOPE
240
1
3: 1
STANDARD
W/NGWALL
•
MITERED FOR J..1
FILL SLOPE
235
235
0&56 LF
12' 8' BOX
CU VET
® 0.60%
230
UPSTREAM
230
INVERT-231.94
EXISTING
ROCK
OUTCROPPING
NEE
EX577NG
GRADE
DOWNSTREAM
225
INVERT-230.69
225
KEYED —IN RIPRAP
7�
OUTLET PR07EC77ON
PLACED AT 36" DEPTH
_17
_7
220
UND£RLAYM£NTpp
1
220
01
�s
00
N
�mp
��
N c\1
��
�p `�°�
�aD
�pFABRIC
rip
o
°gym
r o
�M
0
o
pp o
01
c\1
c\1
01
N
N
01
N
01
N
9+50 10+00 10+50 11+00 11+50 12+00 12+50 13+00 13+50 14+00 14+50
v,McIQM&CREED
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
0:919.233.8091 F:919.233.8031
Wetland Impact Profile
Impact R3
Ammons Property
Scale: 1"=80'
0 40 80
Date:
Dec 6, 2022

I '
1
1 I �
1
PROPOSED GRA VI T
1 SEWER OUTFALL
I I \
1 /
I EXISTING STREAM . — _
I � CENTERLI�-�
1 �- �...... ..
Y
EXISTING
WETLANDS /
^
II
-PROPOSED CITY OF RALEIGH�
SANITARY SEWER EASEMENT
EXISTING WETLAND AREA TO
BE PROTECTED
............. . . . 5' TEMPORARY
J \ CONSTRUCTION
TEMPORARY EASEMENT
WETLAND IMPACT
IMPACT S2 . . . . . . . . . . . . . .
o _ EXISTING WETLAND AREA TO �.
I - \ BE PROTECTED
*N. . . . . . . ... . . . . . . .
PROPOSED CITY OF RALEIGH . . . . . . . . .
SANITARY SEWER EASEMENT .% ' ' ' ' ' ' ' ' '
♦.' . . . . . . . . . . . . . . .
II...I................. ......... :
30' NEUSE Rl VER RIPARIAN ` . . .
/ l BUFFER ZONE 1 (TYP) . . . `.. . . . . . .
/ PROPOSED 20' NEUSE RIVER RIPARIAN �
STORM WATER BUFFER ZONE 2 (TYP)
BMP
......;
,. ....... . ..... ..... .., -
/ y -
/.' .. .'\.... ....... i
.........................
$,MCIQM&CREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S2 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

290 290
285
285
Ca
280
QN
Q�
z z
280
z
QQN
�N
N
275
i
EXISTING
GRADE
275
�
I01I/
i
270
I
'
270
_ SEWER TO HAVE A
MINIMUM 3' OF COVER
ALONG LENGTH OF
265
BUFFER CROSSING
265
12" SEWER
260
260
255
255
M (0 00 to I- to
O 0; ai O cV Yi
N
N N N N N N
9+50 10+00 10+50 11 +00 11 +50 12+00 12+50
Wetland Impact Profile
Scale: 1"=50'
v,McIQM&CREED
Impact S2
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

PROPOSED (RANTY
SEWER 0U7F4LL
% EXISTING WEILAND AREA TO
EXISTING
............... ........ ...... .. ............
...............
. . . . . . . . . . . . . . . ..... . . . . . . . . . . . . . .
BUFFER ZONE 1 (TYP)
NlqKIM&CREED Wetland Impact Map Scale: 1"=50'
Raleigh, North Carolina 27606 Date:

EXISTING EMBANKMENT
l / PROPOSED CITY OF RALEIGH,
� SANITARY SEWER EASEMENT
PROPOSED SEWER \ \
FORCE MAIN \ \ PROPOSED BORE PIT
\ \ \
PROPOSED GRAVITY SEWER - \ \
I OUTFALL INSTALLED VIA BORE % . . .
AND JACK
EXISTING
POND EXISTING STREAM \
/ CENTERLI E/ .
�.... �:
�� \
.. ..
/. /. . .o. ... ... _ -
EXISTING WETLAND AREA TO �. o. . . . . . — _ — _ . .
BE PROTECTED . �. .//// ^ . . \ .
EXISTING
/.... '. :... ........�......
/ / ♦� /\ EXISTING WETLAND AREA TO
. . . . . BE PROTECTED
N.
PROPOSED RECEIVING PIT �
♦' \ \ 0� ED CITY OF RALEIGH' ` . . . .
\ . .
SANITARY SEWER EASEMENT S\ �. . . .
r/' V . .. . .
. .
PROPOSED GRA 0TY
SEWER OUTFALL \
30' NEUSE RIVER RIPARIAN .
\ BUFFER ZONE 1 (TYP) \ \
\\\\ NN\\\1\\ \ \ \ \
PROPOSED 20' NEUSE RIVER RIPARIAN
STORM WA TER\
BMP BUFFER ZONE 2 (TYP) \ \ \ \
\ \ \ \\
v,MCIQMCREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S4 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

Qj
Qj
245
w m
m
J J
DO DO
J
DO
J
QO
240
I
k W k W
�
k W
I
I k W
EXISTING
Q
Q o
GRADE
235
I
I
230
SEWER TO HAVE A
MINIMUM 3' OF COVER
225
ALONG LENGTH OF
BUFFER CROSSING
BORE
PlT 11
220
4
12" SEWER
215
RECEI KING PIT
SEWER MAIN TO BE INSTALLED
WA BORE AND JACK AND TO
BE PLACED WITHIN STEEL
ENCASEMENT PIPE
210
M 0 0 C� C� 0 0 N N
N M cV cV w- � (V cV to to
to to to to
N N N N N N N N N N
9+50 10+00 10+50 11 +00 11 +50 12+00 12+50 13
Wetland Impact Profile
Scale: 1"=50'
v,McIQMCREED
Impact S4
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

PROPOSED SEWER
_ FORCE MAIN \ \
M
TEMPORARY \
WETLAND IMPACT
i
EXISTING WETLAND AREA TO
. . . . . .� I BE PROTECTED
EXISTING WETLAND AREA TO
BE PROTECTED
\
........... ......./ ...
�.. . . . . . ...
\. ...... ......
IMPACT S5 PROPOSED CITY
. . . . . . . . . . . . . . . . . . . . EXISTING \ OF RALEIGH
WETLANDS ... / SANITARY SEWER
\ 20' NEUSE RIVER RIPARIAN � � � � EASEMENT
BUFFER ZONE 2 (TYP) . . . . . . . . \ .I /
....... .............................
30' NEUSE RIVER RIPARIAN
BUFFER ZONE 1 (TYP) .. . . . . . . . . . .
... ... ... ... ... ... / $
�. PROPOSED GRA CITY \ \
SEWER O)UTFALL
EXISTING STREAM . ... . . ... . . ... . . ... . .. .
CENTERLINE _ . . . . . . . . . . . . . . . . . . . EXISTING WETLAND AREA TO
. .. . y.� . BE PROTECTED .
/. �.... .. /.. .............
. . . . . . . . . . . . . . . . . . . .
�....................`.. �.......................
v Wetland Impact Map Scale: 1"=50'
v,MgIQM&CREED
1730 Varsity Drive, Suite 500 Impact S5 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022 Ei

...................................
v,MpQMCREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S6 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

240
`I m
m
240
z
z
I
I
z
z
I
I
235
W W
W
W
W
235
EA7S7ING
GRAD£
230
I
I
230
I
I
I
I
/
I
I /
225
I
225
i
220
A
F
220
EWER
-MINIMUM
ALONG
TO
3'
LENGTH
HVE
OFA
ACOVER
BUFFER
CROSSING
BORE
PIT
215
215
RECEINNG
PIT
12" SEWER
SEWER MAIN TO
VIA BORE AND
BE PLACED
BE INSTALLED
JACK AND
WITHIN
TO
STEEL
210
210
ENCASEMENT
PIPE
205
205
200
200
O �qby �UNp1 � N� O O O O M O 1� N d0 �7aOj �p
N N N N N N N 9
N N N N
9+50 10+00 10+50 11+00 11+50 12+00 12+50 13+00 13+50 14+00 14+50
Wetland Impact Profile
Scale: 1"=80'
v,McIQM&CREED
Impact S6
0 40 80
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

/ PROPOSED
STORM WA TER
BMP
TT/ I PROPOSED GRAOTY / c'S /
I I / SEWER OUTFALL
/ PROPOSED CITY OF RALEIGH.
SANITARY SEWER EASEMENT-
/.
i
. . . . . . . . .
% ..
. . . . . . . . . . . . . . . . . . . . . . . . . .
I ( EXISTING WETLAND AREA TO
BE PROTECTED . . . . . . . . . . . .
. . . . . . . . IMPACT S7
/ \ TEMPORARY ...
/ TEMPORARY 5' \ WETLAND IMPACT
CONSTRUCTION EASEMENT / \ .
\. . . . . . EXISTING \.
WETLANDS'
..............
/..............
................ ....
/..
i. . .
20' NEUSE RIVER RIPARIAN . . . . . . . . . . . �. . .
BUFFER ZONE 2 (TYP)
. .........................I.....
ij JO' NEUSE RIVER RIPARIAN
i%. . . BUFFER ZONE 1 (TYP) . . . . . . . . . . . . . . . I
s/ ,..............;_ - ._.................
............... / ...... �......._ . _ .
/. .. .. .. .. .. .�.. .. .. . ��.�. .
.................................-....�..
i
v,MqQM&CREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S7 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022 ih

PROPOSED GRAOTY
SEWER 0V7F4LL
� / /
PROPOSED CITY OF RALEIGH
.'SANITARY SEWER EASEMENT
EXISTING WEILAND AREA TO WETLANDS
S TORM WA TER
BMP
. .: - - - .. .. .. -..-\ .................... *'o ...........
4$�MCKEN4&CREED Wetland Impact Map Scale: 1"=50'
Raleigh, North Carolina 27606 Date:

/I
PROPOSETORM WA D
BMP
/ PROPOSED GRAVITY
/EXISTING WETLAND AREA TO I — — — _ SEWER OUTFALL
BE PROTECTED _ —
/ .............. 1
TEMPORARY 5' /. . . . . . . . .
CONSTRUCTION EASEMENT . . . . . ` / T_ _ _ _
✓ ...........
PROPOSED CITY OF RALEIGH
. . . . . . . . . . . . . . . . . : . . . . SANITARY SEWER EASEMENT '
....... ......— .................... ......
. �
.0� * . .. . . . . . . . . .TEMPORARY
. . . . . . . . . . . . . . WETLAND IMPACT. .
. . . . . . . . . . . . . . . . . . . ..- y . .
o+oo EXISTING IMPA C T 59 �_ . .
j WETLANDS
. /...........................► .. .. � ...... .. .
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.1-01 . . . _ . . 20' NEUSE RIVER RIPARIAN
. . . . . . . — BUFFER ZONE 2 (TYP)
. . . . . . . . . EXISTING STREAM ,
_CE_NTERLINE — — — 30' NEUSE RIVER RIPARIAN
BUFFER ZONE 1 (TYP)
v,MCIQM&CREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S9 0 25 so
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

EXISTING STREAM /
` CENTERLINE
% �..
EXISTING WETLAND AREA TO
BE PROTECTED
`
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CONSTRUCTION EASEMENT
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/A \ /
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/.___
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EXISTING ` ;. . . . . . . . . SANITARY SEWER EASEMENT%
. . . . . . . . . . .WETLANDS ♦ .IMPACT S 10 ...
. . . .'' ..... --r. . . �. . . . . . . . .. . . . .
/................... ............
20' NEUSE RIVER RIPARIAN
. . . . .. . . . . . . . . . . . . . . .. . BUFFER ZONE 2 (TYP) /
.................... ....
. . : . : . : . : . . . . . 30' NEUSE RIVER RIPARIAN
BUFFER ZONE 1 (TYP)
. . . . . . EXISTING STREAM /
CENTERLINE
v,MgIQM&CREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S10 0 25 50
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

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Scale: 1"=50'
v,McIQM&CREED
Impact S10
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

PROPOSED
STORM WATER —
BMP
PROPOSED GRAW
SEWER OUTFALL
/ :�
EXISTING WETLAND AREA TO PROPOSED CITY OF RALEIGH
BE PROTECTED SANITARY SEWER EASEMENT'
v,MCIQMCREED
Wetland Impact Map Scale: 1"=50'
1730 Varsity Drive, Suite 500 Impact S11 0 25 50
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

-,x ................
. . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . ...................
.........................
%
% EXISTING
EXISTING STREAM WETLANDS . . . . . .
. . . . CENTERLINE . . . . . . . . . . . . . . . . .
. . . . . . . . . . .
. . . . . . . . . . .
/ � . .1
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TEMPORARY 5'
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PROPOSED GRA OTY
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SANITARY SEWER EASEMENT,
— — — — — — —
— — — —
. . . . . . . . . . .
.. . . ... . . ... . . .
TEMPORARY'
WETLAND IMPACT.'.'.'.'.'.
IMPACT S12
......................................
. . . . .
. . . . EXISTING . . . . . . . . .
WETLANDS . . . . . . . .
.. . . . . . . . . . . . .
EXISTING WETLAND
. . . . . . . . . . // . . . . . . . . . .
.....................................
.. . . ... . . . . . . . .
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. . . . . . . . ... . ............
. . . . . . . . . . . . . . . .
BE PROTECTED
............
. . . . . . . . . . . . . . . . . . . .
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. . . . . . .
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*je*Q,*,�NjqKIM&CREED
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Impact S12
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
0: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6, 2022

STORM WA
BMP
EXISTING STREAM
\ CENTERLINE I / . . . 1
i
/. . . EXISTING . .
. . . .WETLANDS. . . �%
. . . . . ./
.............�
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..... .........
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TEMPORARY 5'
/ >> CONSTRUCTION EASEMENT
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S
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BE PROTECTED \ ��
PROPOSED CITY OF RALEIGH
IMPACT S 13 SANITARY SEWER EASEMENT
777-7
EXISTING STREAM
- CENTERLINE _ ♦ `
20' NEUSE RIVER / RIPARIAN, BUFFER ZONE 2 (TYP)
30' NEUSE RIVER RIPARIAN '
BUFFER ZONE 1 (TYP) \
v Wetland Impact Map Scale: 1"=50'
v,MCK1M&CREED
1730 Varsity Drive, Suite 500 Impact S13 0 25 50
Raleigh, North Carolina 27606 Date:
O: 919.233.8091 F: 919.233.8031 Ammons Property Dec 6 2022

275 275
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SEWER TO HAVE A
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255
ALONG LENGTH OF
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250
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245
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240
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Wetland Impact Profile
Scale: 1"=50'
v,McIQMCREED
Impact S13
0 25 50
1730 Varsity Drive, Suite 500
Raleigh, North Carolina 27606
Date:
O: 919.233.8091 F: 919.233.8031
Ammons Property
Dec 6 2022

AMMONS AQUATIC RESOURCE IMPACT TAE
404/401
Project
Phase
Impact #
Aquatic Resource ID
(one feature per line)
Type of Impact
Stream Impact
Permanent (If)
Stream Impact
Temporary (If)
Stream Impact
Riprap (If)
1
R1
Tributary 1
Culvert Road Crossing
191
59
60
1
R1
Wetland 9300
Culvert Road Crossing
x
x
x
1
R1
Wetland 9200
Culvert Road Crossing
x
x
x
1
S1
Wetland 9400
Permanent Conversion
x
x
ONE=
x
1
S3
Wetland 2000
Permanent Conversion
x
x
x
1
S5
Wetland 1000
Permanent Conversion
x
x
x
1
G1
Wetland 9400
Lot Fill
x
x
MEN
x
2
R2
Wetland 5000
Culvert Road Crossing
x
x
MENNEN!
x
2
S2
Tributary 1
Utility Sewer Crossing
x
46
x
2
S2
Wetland 2000
Permanent Conversion
x
x
x
2
S4
Tributary 1
Utility Sewer Horizontal Bore
x
x
x
2
S4
Wetland 1000
Permanent Conversion
x
x
x
2
G2
Wetland 9000
Lot Fill
x
x
x
3
S7
Wetland 6000
Permanent Conversion
x
x
x
3
S8
Wetland 6000
Permanent Conversion
x
x
x
3
S9
Wetland 6000
Permanent Conversion
x
x
x
3
S10
Tributary 2C
Utility Sewer Crossing
x
45
x
3
Sil
Wetland 6000
Permanent Conversion
x
x
x
3
S12
Wetland 3000
Permanent Conversion
x
x
x
3
S13
Tributary 2A
Utility Sewer Crossing
x
41
MENNEN!
x
4
R3
Tributary 2
Culvert Road Crossing
237
50
85
4
R3
Wetland 1000
Culvert Road Crossing
x
x
x
4
S6
Tributary 2
Utility Sewer Horizontal Bore
x
x
x
4
S6
Wetland 1000
Utility Sewer Horizontal Bore
x
x
x
NEW
TOTALS
428
241
145

3LE
Wetland Impact
Permanent (ac-)
Wetland Impact
Temporary (ac-)
Wetland Impact Perm.
Conversion (ac-)
x
x
x
0.06
x
x
0.0041
x
x
x
x
0.02
x
x
0.01
x
x
0.13
0.8
x
x
0.23
x
x
x
x
x
x
x
0.07
x
x
x
x
0.11
0.22
0.33
x
x
x
0.01
0.09
x
0.06
0.25
x
0.05
0.2
x
x
x
x
0.06
0.23
x
0.003
0.01
x
x
x
x
x
x
0.2
0.05
x
x
x
x
x
x
x
lm6241
0343
113
this impact combines the wetland and riprap also
This impact combines the wetland and riprap; so 0.22 acre plus the
CONFIRMED

540 square feet (0.01 acre)

WI WETLANDS
1Ewk & WATERS, 1 NC.
December 12, 2022
Sam Dailey
Chief, Charlotte Regulatory Field Office
U.S. Army Corps of Engineers, Wilmington District
8430 University Executive Park Drive, Suite 615
Charlotte, NC 28262
RE: Action ID: SAW-2022-00367
Ammons Property (residential subdivision)
Ms. Dailey,
The purpose of this correspondence is to respond to your October 24, 2022 request for additional
information for the processing of the Department of the Army for the Ammons Property (residential
subdivision). For ease of reference, we have included the requested information in this letter; it is
indented and in bold.
We drafted a separate email response to the NC Division of Water Resources on November 28, 2022 to
respond to their requests for additional information dated September 29, 2022. This document included
supplemental information and plans that were requested as part of their review.
Attached are revised site plans and impact tables that quantify the currently proposed impacts.
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.
i. Specifically, please add to the alternatives analysis provided in your
Individual Permit application (June 30, 2022) and with revisions
received on September 6, 2022:
a. Site selection criteria: Please provide specific, measurable
criteria for your On -Site and Off -Site alternatives analysis.
Your permit application evaluated contiguous acreage
available, zoning, and utilities. These are not sufficient criteria
to determine the least environmentally damaging practical
alternative. Please also include stream impacts, wetland
impacts, threatened/endangered species, historic properties,
minimum size (acreage) requirement, property available for
purchase, and any other applicable criteria. This information
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WIIWETLANDS
1 & WATERS, INC.
should be outlined in a table for comparison with each
alternative analysis.
Below is a table that supports a determination that the proposed impacts are the least environmentally
damaging practical alternative available to the developer at the time the project commenced. The Veridia
site, refenced in the following table, was contemplated for development by Brookfield in December 2020
and initially reviewed by Wetlands and Waters, Inc. in January 2021. Brookfield declined to move
forward with this project based on anticipated environmental impacts, infrastructure availability, and
financial returns.
Table 1.
C1
0
0
�.
U ..
to
44
O
'CCn
U
r
�
i
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44-
U
ct
.--i
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n
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it
fir"
U
¢
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r"'
r"'
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i-r
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i
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w
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a
a
a
U
U O
Preferred
468
120
75.34
12.3K
74%
3
428
1.61
Yes
Yes
I
Alternative
Alternative
468
120
75.34
12.3K
74%
3
428
0.48
Yes
Yes
I
1
Veridia*
1092
150
13
58K
75%
25
3500
2.5
Yes
No
4
Off -Site
* The Veridia project started to receive local approvals circa 2009 and was issued USACE AID# 2010-
01907. Brookfield and their consultants investigated the development of the site using different
development concepts that would reduce impacts to streams and wetlands. Percent usable land assumes
streams to have 50-foot regulated buffers on each side of them where they are outside of the 100-year
floodplain. All values are estimates based on then available public information.
b. Off -site alternatives: Please explore Off -Site alternatives in
accordance with the above referenced criteria. Correlating
maps/design drawings should be provided for each off -site
alternative. If Off -Site alternatives are not practicable, please
provide a detailed explanation as to why.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

4 W WETLANDS
1 fta & WATERS9 I NC.
See Table 1. for an analysis of an off -site alternative to the project. Brookfield specializes in creating
developments that have a minimum of 1500 dwelling units and a minimal impact on the environment
while achieving market appropriate financial returns. Generally speaking, these unit counts are only
achievable on tracts with usable acreage in excess of 300 acres. The estimated mitigation stream
mitigation for the Veridia project was in the range of 3.25 to 5 million dollars at the time of due diligence
m 2021. The analysis shows that the Veridia project was not a practicable project for this developer
based on information that was available at the time of their due diligence.
c. On -site alternatives: Please provide quantitative data that
supports your On -Site alternatives configurations, including
design drawings. For example, your On -site Alternative 1
states: "On -site alternative 1 proposed an equivalent amount
of road and sewer impacts, but eliminated wetland impacts for
residential unit construction. The applicant determined that this
alternative was not economically practicable and would result
in a non -viable project, therefore this alternative was
eliminated from consideration." This information is not
sufficient to evaluate as an alternative.
Elimination of Lot Fill -
The following images are excerpts from the proposed site plan. The red lines illustrate approximate
changes in the road configuration and the lots shown in pink represent lots that are likely lost due to street
setbacks and grading requirements, were these wetlands to be avoided.
The following tables list the projected total financial impact for each of the lot areas. The total revenue
generated by the proposed fills, less the mitigation, is $2.7M.
Impact G-1
Product Type #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 27
Cost of Mitigation
$ 1,776,000.00
$ (178,000.00)
---
Total Financial Impact $ 1,598,000.00
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
1q4Y8&: W A T E R S 9 1 NC.
Impact G-2
Product Type #of lots Revenue
40' Front Load 7 $ 125,000.00 $ (46,000.00)
45' Front Load 7 $ 143,000.00 $ (52,000.00)
Total 14
Cost of Mitigation
Profit
553,000.00
637,000.00
1,190, 000.00
$ (75,
Total Financial Impact $ 1,115,000.00 `` I IMPACT G2
The proposed development consists of 1562 lots spread over 6 development phases. Below is a table
depicting the proposed lot release schedule based on development phases and market. These
development phases are not necessarily the same as the mitigation phases due to the lead time necessary
to construct infrastructure prior to selling lots.
Development Phase Total Lots Delivery Date
Phase 1
266
4Q24
Phase 2
244
3Q25
Phase 3
291
1Q26
Phase 4
276
4Q26
Phase 5
253
4Q27
Phase 6
232
3Q28
A total of 41 residential units are currently reflected in the G1 & G2 impact areas. While the loss of
$2.7M in revenue is significant, the real effect to the proforma is in the rate of return. The lots shown in
G1 & G2 are anticipated to be in the 1st and 2nd phase of the project, meaning revenue that was
anticipated to be recognized early and be used to offset the huge amount of upfront infrastructure that has
to be constructed before any lots can be sold.
The upfront infrastructure for phases 1 and 2 includes approximately 3,084 linear feet of 3-lane
Undivided Minor Thoroughfare, 813 LF of 2-Lane Undivided Minor Collector and 6,854 LF of Local
Streets & alleys. If areas G1 and G2 were not impacted then the roadway infrastructure would decrease
by just 232 linear feet of Local Street (380 LF less + 150 LF for new street alignment at G2), with the
entire —3,900 LF of Minor Thoroughfare and Minor Collector still being required per the Town of
Wendell Master Throughfare Plan.
Additionally, the sewer infrastructure improvements remain constant. Approximately 2,348 LF of gravity
sewer outfall and 5,134 LF of sewer forcemain will need to be constructed in order to tie Phases 1 & 2 to
the proposed pump station.
The proposed impacts are necessary in order to quickly generate revenue and ensure a financially viable
project. The development of the project can not be practically accomplished in a manner that avoids
impacts to these wetlands or results in less impacts to these wetlands as described below.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WWETLANDS
.�. Sc WATERS9 INC.
The $2.7M in revenue as a critical offset for the estimated $24M in first and second phase infrastructure
costs. Of note, we provide the following estimated costs that need to be offset early in the project:
• $320K- for first phase road and sewer stream, wetland and buffer mitigation
• $100K - $600K (depending on rock) - for sewer boring costs associated with impacts S4 and S6
• $120K- for headwalls at the road crossings to reduce impacts
• $500K for enhanced erosion control measures (double row reenforced silt fence)
• $20K for stormwater management
• $193K- for mitigation for impacts G1 and G2
If we were to lose these 41 lots, the rate of return would drop between 1.5%-2%, which would make the
project financially unfeasible.
Complete Avoidance of Impacts
The applicant provides the following quantitative table for completely avoiding all impacts to streams,
wetlands and buffers for the construction of sewer infrastructure. Estimated costs are based on the
engineer's opinion of the costs to install the utilities based on engineering experience and market
conditions; the costs do not include materials.
Table 3.
Sewer
Estimated Cost
Estimated Length
Total Costs for
Construction
Per Running Foot
of Construction
Installation
Methodology
Horizontal
$400/lf
2040
$816K
Drilling
Conventional
$95/1f
2040
$193K
Open Trench
Difference
$623K
The applicant provides the following quantitative table for completely avoiding all impacts to streams and
wetlands for the construction of road infrastructure. The cost opinions presented in the table are the costs
associated with the infrastructure that is needed to avoid the impact and does not reflect surface treatment
and incidental earthwork Note: NC DOT does not typically approve bridged crossings in residential
subdivisions due to maintenance costs and other factors.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WI WETLANDS
1 & WATERS, 1 NC.
Table 4.
�.~
¢ oo
o
O
U r"'
Q.
...
O
o.
¢
U • t"..
bA o
O
'C
W 0
i
W
O O
U
W
U
W
RI (72"
$10K
110 feet
$1.1M
$950/lf
$192K
$335K
RCP)
(150.0 If)
R2 (54"
$10K
90 feet
$900K
$725/lf
$188K
$295K
RCP)
(146.3 If)
R3 (12'x6'
$10K
40 feet
$400K
$125K
$266K
$391K
Box)
Bridge
$2.4M
Conventional
$1M
Total
Total
The costs to totally avoid impacts to streams and wetlands exceed $3M.
d. Please explain how your preferred alternative is the least
environmentally damaging, practical alternative.
The preferred alternative is the least environmentally damaging practical alternative because:
1. It avoids wetland fills in the 100-year floodplain with the exception of a road crossing to access a
portion of the property that will be constructed entirely in high ground.
2. It avoids wetlands that are adjacent to tributaries thereby reducing the potential for damage to
both wetlands and streams and preserving the integrity of the large riparian areas throughout the
project.
3. It avoids impacts to high quality forested wetlands within the floodplains of minor tributaries
within the site.
4. It limits potentially damaging impacts to water quality through the implementation of stringent
erosion control measures and stormwater controls.
5. It avoids impacts to larger tributaries through the use of horizontal drilling.
B. It is necessary for you to have taken all appropriate and practicable steps to
minimize losses of Waters of the U.S., including wetlands. Please indicate all
that you have done, especially regarding development and modification of
plans and proposed construction techniques, to minimize adverse impacts.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WIIWETLANDS
1 & WATERS, INC.
i. The information provided in your submitted application is not sufficient
to assess if all appropriate and practical steps were taken to avoid and
minimize losses to waters of the U.S. Therefore, please provide
specific and measurable avoidance and minimization measures taken.
Please be sure to discuss impacts to waters of the United States.
The applicant provides the following narrative to demonstrate all the practical steps and proposed permit
special conditions that will avoid and minimize direct and indirect impacts to wetlands and waters,
protected species, and cultural resources.
Endangered Species Special Conditions (proposed)
1. Based on consultation with the U.S. Fish and Wildlife Service pertaining to Section 7 of the
endangered Species Act, the following conditions are required for the Ammons Property
(residential development):
The applicant shall commission protected species surveys 90 days in advance of any construction
in wetlands or waters associated with Impacts R3, S4 and S6. The applicant shall provide the
Corps and the US Fish and Wildlife Service a preliminary statement of the survey's findings
within 24 hours and develop a relocation plan as needed. Impacts to waters of the US at these
locations shall not occur until the US Fish and Wildlife Service issues a biological opinion.
a. The extent of tree removal and grading required for the construction activities must be
minimized by planning and scheduling activities in sequence, as appropriate. Areas where tree
removal is not required and access is not otherwise needed for construction of infrastructure,
buildings, or amenities must be fenced during construction to prohibit vehicle entry. Graded or
disturbed soils must be stabilized with native grasses or mulch covers within 14 days of
completion of the disturbance activity;
b. The contractor must be advised about the presence of sensitive species by providing
information and installing visible and weather-proof signage (see the attached signage with the
heading labeled 'NOTICE!") on the silt fence at regular (i.e. at least 300-foot) intervals along
clearing limits adjacent to streams and wetlands shown on the approved delineation map;
C. Access for equipment and vehicles to construct the sewer infrastructure must be limited
to those shown on the attached plansheets. No impacts to wetlands, streams, or other potential
waters of the US are authorized for access other than those specified on the attached plansheets;
d. Stringent erosion control measures must be implemented during construction within
100-feet of the Little River floodplain and the perennial stream channel along the southern
property boundary, including: A double row of silt fence, to ensure that erosion is captured
effectively. Silt fence and other erosion control devices must not include outlets that discharge
closer than 50 feet to the top of bank of any stream. Silt fence outlets for each row of silt fence
must be offset to provide additional retention of water and sediment in the outer row;
e. The discharge outlets from stormwater infrastructure must be designed to avoid stream
buffers, including the dissipator pad or any other structures;
f. All mechanized equipment shall be regularly inspected and maintained to prevent
contamination of waters and wetlands from fuels, lubricants, hydraulic fluids, or other toxic
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

II WETLANDS
1 & WATERS9 INC.
materials. In the event of a spill of petroleum products or any other hazardous waste, the
Permittee shall immediately report it to the Corps at
[e-mail] <mailto: [e-mail] > , U.S. Fish
and Wildlife Service (USFWS) at [e-mail] <mailto [e-mail]> , and N.C.
Division of Water Resources (NCDWR) at [phone] or [phone], and provisions of
the North Carolina Oil Pollution and Hazardous Substances Control Act shall be followed.
Inspections, repairs, cleaning, and/or servicing must be conducted either before the vehicle,
equipment, or machinery is transported into the field or at the work site;
g. All drilling muds, wash -water runoff, and/or other harmful materials must be
appropriately controlled to prevent entry into a waterbody or riparian zone;
h. Vehicles and equipment must be fueled and maintained, and potentially toxic
substances (fuels, paints, solvents, lubricants, etc.) must be stored, within a containment area in
uplands at least 100 feet from the top of bank;
i. Temporary and permanent stabilization measures should include only natural materials
that are expected to degrade over time;
j. Revegetate with native species. Sericea lespedeza is invasive and should not be used for
stabilization or revegetation in regulated wetlands, floodplains or stream buffers. Portions of the
sewer ROW that are not intended for long-term maintenance should be revegetated with native
trees and shrubs;
k. Conduct bi-weekly inspections of all erosion and sedimentation controls adjacent to the
floodplain of Little River floodplain and the perennial stream channel along the southern property
boundary, and in uplands within 100 feet of the riparian zones of all streams. Maintain all
controls as necessary to ensure proper installation and function. In addition to bi-weekly
inspections, within 24-hours of rain events, inspect all of the erosion and sedimentation controls
to ensure the integrity of the devices. Repair and replace sections of controls as needed to
minimize the potential for failure;
1. If erosion and sedimentation controls fail causing sediment or erosion in the floodplain
wetlands or stream buffer of the Little River floodplain and the perennial stream channel along
the southern property boundary, the Corps and Service must be notified within 24 hours to
determine if any remediation is required.
in. Completion of Environmental Inspection Report Form: After each inadvertent release,
the environmental inspector will complete an Environmental Inspection Report Form. This form
will contain information of the date, time, location, duration, and estimated amount of the release,
as well as containment and clean up activities. The environmental inspector will also contact
regulatory and resource agencies no more than 24-hours after clean-up and recovery of the
release.
n. Site Restoration: After the complete installation of the force main, restoration activities
will be implemented according to the project's Storm Water Pollution Prevention Plan (SWPPP)
and Erosion and Sedimentation Control Plan. Tie in pits will be backfilled with a mix of drill
returns and minor excavate material removed during the pipe connection process. Disturbed areas
will be seeded with native vegetation and covered with mulch to prevent further erosion.
Abandoned drill holes will be sealed with either a sand/concrete slurry or a mix of drill returns.
Cultural Resources Special Conditions (proposed)
2. Based on consultation with the NC Department of Natural and Cultural Resources relating
to Section 106 of the National Historic Preservation Act, the following conditions are required for
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WETLANDS
y WATERS9 INC.
ly4:
the Ammons Property (residential development):
a. Site 31 WA2534, which yielded American Indian artifacts from the Middle Archaic
and Early/Middle Woodland Periods and appears to contain deep deposits with intact
stratigraphy, shall not be impacted by the proposed development.
b. Should ground disturbing activities not shown on the design plan, such as land
clearing or grading for walking trails, be proposed within 500 feet of site 31 WA2534, measures
shall be taken to avoid site 31 WA2534 inclusive of a 100-foot buffer. The site and buffer area
shall be marked as an environmentally sensitive area on construction plans and be delineated with
high visibility fencing to avoid accidental encroachment. The site and the buffer are depicted on
the plan coversheet.
Erosion Control — The applicant has committed to stringent erosion control measures that include super
silt fence along the perimeter of the site where it drains directly to the Little River and other tributaries.
Super silt fence is two rows of fence with the closest to the aquatic resource being supported by chain link
fence. Brookfield has a solid reputation with Wake County Erosion Control for the implementation and
management of erosion control devises.
Stormwater Management - The site plan depicts 17 stormwater management ponds located throughout the
site. Each of the basins will discharge outside of the Neuse River Riparian Buffers. Wake County
stormwater rules require protection of riparian buffers, peak flow control and nitrogen control from new
development.
This will be achieved by detaining the 1-inch storm event for 2-5 days and the 1-year, 24-hour storm
event so that the peak flow rate doesn't increase from the pre -development rate. An emergency spillway
will be provided to safely pass runoff from extreme storm events or in the event the outlet structure
becomes clogged. These requirements will be met by utilizing 17 onsite Stormwater Control Measures
that will discharge at non -erosive velocities through the use of energy dissipator pads at each outfall.
Wake County is a delegated authority for stormwater management and the plans will comply with their
applicable standards.
Construction Methods and Considerations -
The applicant commits to using construction mats for work in wetlands associated with the
installation of the sewer infrastructure.
• The applicant commits to using pump arounds to ensure that construction is in the dry.
• The applicant commits to using non-invasive species for stabilization within floodplains,
riparian areas and wetlands.
• The applicant commits to create containment areas for lubricants and fuels at least 100 feet
from the top of stream banks.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WI WETLANDS
1 & WATERS9 INC.
The applicant will ensure that perimeter erosion control is established prior to starting
clearing and grubbing
The applicant commits to exceeding best management practices for forestry during any
timbering activities on the site.
ii. Please provide an explanation as to why utility Impact S6 cannot be
achieved utilizing horizontal directional drilling.
The applicant has agreed to horizontal drill sewer crossings 4 and 6 at an estimated cost of $256K.
Further, the applicant will commission protected species survey 90 days in advance of the borings to
further limit potential adverse impacts to them. The applicant will provide the Corps and the US Fish and
Wildlife Service a preliminary statement of the survey's findings within 24 hours and develop a
relocation plan if needed.
iii. Please provide additional justification regarding impacts GI and G2
and why these areas cannot be further avoided and minimized.
Please see above section titled "Elimination of Lot Fill" for additional justification regarding impacts G1
and G2.
C.i. I have evaluated the compensatory mitigation plan included in your
application and have determined the details to be generally sufficient
for our evaluation. You are proposing a 2:1 and 1:1 mitigation to impact
ratio for the proposed stream and wetland impacts and would purchase
4.75 wetland mitigation units and 856 stream mitigation units from
Wildlands Holdings III, LLC's Falling Creek UMB, McClenny Acres II
Mitigation Site and Falling Creek Mitigation Site.
The applicant requests that the file specifically reflects that the applicant avoided impacts to over 60 acres
of wetlands and 11,000 linear feet of streams and that they remain in protected open space within the
development.
The applicant proposes the following phased mitigation plan for impacts to wetlands and streams. The
mitigation proposal utilizes the agreed upon ratios but has been revised to reflect the reduction of impacts
that result from boring two of the sewer crossings.
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS

WI WETLANDS
1 & WATERS, 1 NC.
Table 5.
Payment
Impact ID's
Stream Mitigation
Wetland Mitigation
Wetland
Date
(Impact) / Units
(fill) / Units
Mitigation
2:1
2:1
(conversion)
Phase 1
4/15/2024
G1, RI, S1,
(191 II) / 382 units
(0.864 ac) / 1.728 units
0.16 units
S3, S5
Phase 2
4/15/2025
G2, R2, S2
(0.56 ac) / 1.12 units
0.29 units
Phase 3
4/15/2026
S7, S8, S9,
0.78 units
S10, S11, S12,
S13
Phase 4
4/15/2027
R3
(2371I) / 474 units
(0.20 ac) / 0.40 units
Totals
856 units
3.248 units
1.23 units
The applicant proposes the following phased mitigation plan for impacts to Neuse River Buffers as
required by the rules.
Table 6.
Payment
Date
Locations with impacts to buffers
by Impact ID
Zone 1 Impacts
Zone 2 Impacts
Phase 1
4/15/2024
RI
13021
7628
Phase 2
4/15/2025
S2 (allowable w/o mitigation)
N/A
N/A
Phase 3
4/15/2026
S 10, S 13 (allowable w/o)
N/A
N/A
Phase 4
4/15/2027
R3
16041
8926
Thank you for your time and consideration and please do not hesitate contact me at
chrishu. smane wetlands-waters.com or 336.406.0906 with any questions or comments that you might
have.
Best regards,
Cc: Sue Homewood
John Ellis
Renee Gledhill Earley
Wetlands & Waters, Inc.
WETLAND AND ENVIRONMENTAL CONSULTANTS