20230343 Ver 1_More Info Received_20230416

TERRAIN
o ENVIRONMENTAL
CONSULTING
April 16, 2023
US Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
Attention: Mr. Brad Shaver
Subject: Incomplete Application Response
SAW-2022-02693
Gladiolus Road Site
New Hanover County, NC
Dear Mr. Shaver:
Terrain Environmental Consulting, PLLC (Terrain) appreciates your comments
regarding the Nationwide Permit application for the Gladiolus Road Site. Our
responses to those comments are below.
1. Avoidance and Minimization
Comment:
• What exactly makes up the maintenance access for stormwater pond, is
this a conversion impact along the run of a buried utility or is this a filled
road? If this is more than a conversion impact can this road be set within
the secondary street yard buffer? If this is not practicable could the
access be set along the top of the wetland impact C, affecting only the
top of the drain not further down the drain?
Response:
• The maintenance access will be a permanent gravel road. This road has
been moved from Impact C to Impact B which results in Impact B
increasing from 0.03 acres to 0.04 acres, and Impact C decreasing from
0.08 acres to 0.02 acres. This is also discussed below in the Revised
Wetland Impacts Discussion.
Comment:
• Could retaining walls be utilized around wetland impact B to eliminate
this impact all together?
Response:
• This impact cannot be avoided as it provides for the necessary
turnaround for delivery trucks as required by Tractor Supply. The turning
radius for this road impact is for a WB65 truck with a turning radius of 52
feet. The road is at the minimum size to allow for these trucks to safely
turn. The shape of the wetland in that area was taken into consideration

Terrain Environmental Consulting Project 22-028-WS April 16, 2023
Gladiolus Road Site Incomplete Application Response
to provide the turning radius. An alternative, T-head turnaround would
result in more impact. To reduce this impact, an extended curb (18-inch
vertical concrete curb) has been proposed for a portion of the impact
instead of a fill slope. Since the stormwater access road has been
relocated to this impact, the overall impact amount at this location
increases but the deepened curb helps to minimize that increase.
Comment:
• Is there any level of development that would be permitted near or around
the OHE areas? If so, could there be opportunities for more avoidance.
Response:
• Development is not permitted within the OHE. New Hanover County
requires a secondary street yard buffer along the north side of the OHE.
A condition of the property rezoning was that no work would occur within
the buffer as is currently proposed. Thus, there is no room to move the
development south.
2. Secondary Impacts, taken from NW 39, "(4) (i) A description of the proposed
activity; the activity's purpose; direct and indirect adverse environmental effects
the activity would cause."
Comment:
What measures are being designed to eliminate secondary impacts
associated with wetland impact D? Currently, impact D eliminates the
wetland from flowing NW, if the wetlands to remain west of impact D flow
or could flow a different direction please show the flow path and how it
will be maintained. If the wetland is isolated, it would be secondary
impact that would need to be tabulated as an impact.
Response:
• The wetland within impact D does not appear to flow to the northwest.
The northern edge of that wetland is within the property boundary and
there is no offsite connection to the northwest. This feature does connect
to the roadside ditches along Castle Hayne Road and Gladiolus Road
which eventually flow into Ness Creek, nearby to the southwest. A copy
of the topographic survey, provided by Paramounte Engineering, with
delineated wetland features shown has been included along with flow
arrows for the ditches based on ditch bottom elevations. Ditch bottom
elevations along Gladiolus Road in the southeast corner are at 31 feet
while in the southwest corner elevations are at 30 feet. Ditch bottom
elevations along Castle Hayne Road in the northwest corner are at 34
feet while in the southwest corner elevations are at 30 feet. These
elevations indicate surface drainage through the ditches is toward the
southwest corner of the property where a culvert is present allowing flow
2

Terrain Environmental Consulting Project 22-028-WS April 16, 2023
Gladiolus Road Site Incomplete Application Response
to continue south toward Ness Creek. This survey also shows the north
terminus of this wetland and it being located entirely within the project
property with no offsite connection north. Thus, the remaining wetland
outside impact D is not severed from its downstream surface water
connection and no secondary impacts are resulting from the proposed
wetland impact D. These ditch connections are vital to keeping impacts
below 0.5 acres, and we would gladly meet you onsite to view them.
Comment:
If wetland impact C must remain, what measures will be taken to
connect the remaining wetlands to downstream waters?
Response:
• As mentioned above, the maintenance access road has been moved to
Impact B. A culvert has been included to allow flow between the
remaining wetland areas on either side of the road.
3. Sketch
Comment:
• Please provide a cross section drawing of each different impact. It's
expected that each impact will be a different elevation therefore please
provide a cross section of the building footprint and loading dock into the
wetland A, driveway access area into wetland B, access for stormwater
into wetland C, and parking area into wetland D. The cross section will
show the proposed slope, whether it be through a retaining wall or filled
slope with vegetative stabilization. There should be no slopes tying into
the wetland shallower than 3:1.
Response:
Cross -sections have been provided for each of the impacts. All fill slopes
at wetland impact areas are 3:1.
4. Mitigation
Comment:
• Please provide the reservation letter from the mitigation bank you propose
to use. This provides the confidence the bank has the type of credits
available for the proposed action.
Response:
• A copy of the wetland mitigation reservation letter was provided to you
via email on March 13, 2023. Acknowledgement of receipt was provided
by you via email on March 14, 2023. However, the new site plans result
3

Terrain Environmental Consulting Project 22-028-WS April 16, 2023
Gladiolus Road Site Incomplete Application Response
in less impact. A new mitigation request was sent to the mitigation bank
and the new reservation letter has been included.
REVISED WETLAND IMPACT TABLE AND DISCUSSION
The wetland polygons in the PJD Package and impacts identified in the Pre -
Construction Notification were based on wetland boundary flag data collected using
hand-held, sub -meter accurate, non -survey grade GPS equipment. Subsequent to
submission of the PCN, the project surveyor located our wetland boundary flagging
which resulted in small changes to the wetland polygons and wetland impacts, along
with some site design changes discussed below. Table 1 below provides a summary
of those changes.
TABLE 1 — REVISED WETLAND IMPACTS
Impact Area
Original Impact
New Impact
Impact Change
Impact A
0.27 ac
0.28 ac
0.01 ac
Impact B
0.03 ac
0.04 ac
0.01 ac
Impact C
0.08 ac
0.02 ac
- 0.06 ac
Impact D
0.11 ac
0.11 ac
None
Original Impact Total
0.49 ac
New Impact Total
0.45 ac
Net Impact Change
-0.04 ac
The increase at Impact A is due to the surveying of the field flags and not due to any
site plan changes. The increase at Impact B is due to relocating the stormwater
maintenance access road from Impact C to Impact B. The wetland at the new road
crossing is narrower than it was at the originally proposed crossing, resulting in less
impact. Also as discussed above, an extended curb has been partially incorporated at
Impact B instead of a fill slope to help further reduce impacts. A culvert has also been
placed under the newly positioned stormwater access road to allow for hydrologic
connection between the wetland sections on either side of the road. Impact B also
now includes a stormwater pipe beneath the access road, taking stormwater runoff
from the built -upon area to stormwater pond. This allows for two activities to occur
within the same impact footprint thus avoiding an additional impact for the stormwater
pipe. Impact C has been reduced by moving the stormwater access road to a location
where the wetland crossing is narrower and by incorporating an extended curb. The
reduction is very small (0.004 acres) and rounding the impact to two decimal places
shows no change. No change is proposed for Impact D. The revisions made in
response to your comments and by moving the stormwater access road have resulted
in a net decrease in the total wetland impacts from 0.49 acres to 0.45 acres.
rd

Terrain Environmental Consulting Project 22-028-WS April 16, 2023
Gladiolus Road Site Incomplete Application Response
CLOSING
If you have any questions, require additional information, or wish to schedule a site
meeting to review the ditch connections discussed above, please do not hesitate to
contact me.
Sincerely,
(�41
Paul Masten, LSS, PWS
President/Owner
Attachments
Wetland Impact Map
Topographic Survey with ditch flow arrows
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NORTH
SITE DATA:
PROJECT NAME:
TRACTOR SUPPLY COMPANY
SITE ADDRESS:
3400 CASTLE HAYNE RD.
CASTLE HAYNE, NC 28429
DEVELOPER:
CASTLE HAYNE
DEVELOPMENT GROUP, LLC.
120 MARKET SQUARE: 2ND FLOOR
PINEHURST, NC 28374
PARCEL ID:
R02500-002-009-003 0.77 ACRES
R02500-002-021-000 1.66 ACRES
R02500-002-022-000 1.71 ACRES
R02500-002-020-000 1.73 ACRES
R02500-002-009-000 5.72 ACRES
PROPOSED PROJECT AREA:
+/- 11.52 ACRES
PROPERTY OWNER:
ASHTON & AVERY, LLC
201 MARSHFIELD DR.
WILMINGTON, NC 28411
EXISTING ZONING:
R-20
PROPOSED ZONING:
CONDITIONAL REZONING B-2
COMP. PLAN PLACE TYPE:
COMMUNITY MIXED USE
JURISDICTION:
NEW HANOVER COUNTY
PROPOSED USE:
RETAIL / COMMERCIAL
(TYPE OF DEVELOPMENT)
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