SWA000190_Response Letter to Comments_20230405

Civil - Geotechnical - Surveying
Attn: Jim Farkas
512 N. Salisbury Street, Office 640M
Raleigh, NC 27604
Re: Fairview Fire and Rescue in Monroe, Union County
Response to NCDEQ Stormwater Comments dated 3/29/2023
Enclosed, please find
1. Two (2) Sets of Plans @ 24" X 36" (signed and sealed)
2. One (1) Site Report
3. One (1) Existing Storm Exhibit
From the attached site report, you will see there is evidence of an existing storm network.
This network approximately has 635 LF of storm pipe on site. Our proposed design has 526
LF of storm pipe. This site should be deemed a redevelopment as it has no net increase of
BUA and it has greater stormwater control than it did previously. Therefore, with this
definition of redevelopment, the site should be exempt from needing a stormwater permit
per 15 NCAC 02H .1001(1)(f).
In addition, please refer to the flowing responses to comments:
1. As designed, this project will not meet the requirements to be considered a low -
density project. Per 15A NCAC 02H .1003(2)@, "stormwater that cannot be released
as dispersed flow shall be transported by vegetated conveyances." This does rule
does allow a minimal amount of piping for culverts under driveways/roads (such as
the proposed pipe located underneath the driveway entrance on US 601), and in
certain cases, erosion protection, however the roof drains discharging to and being
transported via pipe network are not allowed for low -density projects. Roof drains
are expected to be allowed to sheet flow from the downspout (ideally this dispersed
flow would be directed to a vegetated receiving area per 15A NCAC 02H .1003(2)(b),
but it can also be directed to a vegetated conveyance). Please either revise the
design to remove the piping network or redesign the project to meet the high -
density requirements.
Response: This comment is invalid as we are applying for the redevelopment
exemption.
2. Removing the proposed pipe network would make this project meet the definition of
redevelopment (since there is no net increase in BUA and greater or equal

stormwater control will be provided from the existing conditions) and redevelopment
projects are not subject to the State post -construction program in accordance with
15A NCAC 02H .1001(1)(f). If you demonstrate that the project meets the definition
of redevelopment, we can issue you a letter confirming that this project meets the
definition of redevelopment and stating that no permit is required from our office for
the proposed project.
Response: A site report has been conducted to show the amount of existing storm
pipe on site. This report shows that there is less storm proposed than there is
existing. This site also has no net increase of BUA. Since these two criteria have
been met, this meets the requirements for redevelopment.
Please upload the electronic files for this project to the following link:
httgs://edocs.deg.nc.gov/Forms/SW-Supplemental-Upload. Typically, an email is
sent from our office once the project is accepted for review instructing you to do this,
however it appears as though we never sent this email. We apologize for the
oversight and inconvenience.
Response: The files will be uploaded to the online portal.
4. Provide PDFs of all revisions, 2 hard copies of revised plan sheets, 1 hard copy of
other documents and a response to comments letter briefly describing how the
comments have been addressed. Pdfs uploaded to the link in the prior comment.
Hard copies to be mailed or delivered.
Response: Hard copies and digital copies will be submitted appropriately.
Please contact me if you have any questions or concerns.
Very Respectfully,
Garrett Kraus, EI
Engineering Intern
980-777-3266
[e-mail]
CEOI
Civil - Ceotechnical- Surveying