20230491 Ver 1_RE Old Milburnie Village USACE and NCDWR Response_20230627

Deborah Shirley
From: Deborah Shirley
Sent: Friday, June 23, 2023 11:36 AM
To: Phillips, George L CIV USARMY CESAW (USA); Myers, Joseph M
Cc: Thomas, Zachary T; Brad Whitehurst; John Myers; MMcAuley; Mason Montgomery
Subject: RE: Old Milburne Village / Knightdale / Wake County / SAW-2018-01443 / RFAI / NWP 29_NWP 18
Lyle & Joe:
Please see our responses below to your RFAI dated 4/28/2023 (Corps) & 5/26/2023 (NCDWR), in addition to
attachments provided within link.
1). The proposed activities include the temporary discharge of dredged material within and permanent conversion of
forested wetlands to herbaceous wetlands for sewer installation at Impact Area 1. The need for sewer access for the
proposed subdivision is not disputed; however, it is unclear if the project at this location has demonstrated avoidance
and minimization to the maximum extent practicable as required by NWP General Conditions 23(a) and (b). It appears
that the proposed sewer in this location does not tie to an existing sewer line, nor does it provide a service for an
existing development. Please redesign or provide information to support installation of the sewer line at Impact Area 1.
Response: Impact 1 has been omitted; it will be constructed via Bore & lack. Please see updated PCN application and
Impact exhibits.
2).The proposed activities include the permanent and temporary discharge of fill material within stream channel for
road construction at Impact Area 2. The need for EMS and fire access is not disputed; however, it is unclear if the project
at this location has demonstrated avoidance and minimization to the maximum extent practicable as required by NWP
General Conditions 23(a) and (b). For example it appears that there are two points of access for the proposed
subdivision from Old Crews Road and Old Milburnie Road. Additionally, it appears that the neighborhood to the north
would also have two points of access from the extension of Endwell Drive and the existing connection at Buffaloe Road.
Therefore, it is unclear if the proposed activities in this location are in compliance with GC 23(a) and (b). Please redesign
or provide information to support the road crossing at Impact Area 2.
Response: Per the applicants and Kevin Lewis with the Town of Knightdale: The Old Milburnie Village connection to
Brilliant Drive is a requirement for the following reasons:
1. The Town's Roadway Network Plan includes this connection extending south from Brilliant Drive.
2. According to the Town's Unified Development Ordinance, specifically Section 11.3.E.3, vehicular
connections from adjacent property (street stub -outs) must be utilized. Additionally, new developments
are required to stub streets to the outer perimeter boundaries of the development so as to ensure access
of surrounding properties to a public right-of-way and in accordance with the Roadway Network Plan.
3. Both the connection to Brilliant Drive and Endwell Court were items discussed at length during the public
hearing process for this project. Town Council strongly supported this connection, as reflected in the final
design. I have attached a copy of the staff report presented to Council.
4. These points of connection provide alternative means of access to surrounding roadways for existing
residents of the Brighton Knoll neighborhood, as well as future residents of Old Milburnie Village.
Attachments: httas://sandec.sharefile.com/d-s59fl82596c7746d69414b43203404c8d
-Updated PCN Application
-Updated Combined Impact Exhibits
-Town of Knightdale Roadway Network Plan (i.e. appendix A)
-Town of Knightdale UDO Section 11.3.E.3 (pages 9 & 10 highlighted)

-Town of Knightdale Town Council Staff Report -dated July 21, 2021
We anticipate that this additional information will allow you to continue your review of this project. Please let me know
if you need anything further to continue processing this permit application.
Thank you,
DEBORAH E. SHIRLEY
Project Manager -Regulatory Specialist
Soil & Environmental Consultants, PA
North Quarter Office Park
8412 Falls of Neuse Road, Suite 104
Raleigh, NC 27615
Office [phone]
Direct [phone]
Mobile [phone]
[e-mail]
Visit us at sandec.com
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From: Phillips, George L CIV USARMY CESAW (USA) <[e-mail]>
Sent: Friday, April 28, 2023 3:11 PM
To: Deborah Shirley <[e-mail]>
Cc: Thomas, Zachary T <[e-mail]>
Subject: Old Milburne Village / Knightdale / Wake County / SAW-2018-01443 / RFAI / NWP 29_NWP 18
Hey Debbie,
I have reviewed the PCN for the above referenced project and have the following questions/comments.
1). The proposed activities include the temporary discharge of dredged material within and permanent conversion of
forested wetlands to herbaceous wetlands for sewer installation at Impact Area 1. The need for sewer access for the
proposed subdivision is not disputed; however, it is unclear if the project at this location has demonstrated avoidance
and minimization to the maximum extent practicable as required by NWP General Conditions 23(a) and (b). It appears
that the proposed sewer in this location does not tie to an existing sewer line, nor does it provide a service for an
existing development. Please redesign or provide information to support installation of the sewer line at Impact Area 1.
2).The proposed activities include the permanent and temporary discharge of fill material within stream channel for
road construction at Impact Area 2. The need for EMS and fire access is not disputed; however, it is unclear if the project
at this location has demonstrated avoidance and minimization to the maximum extent practicable as required by NWP
General Conditions 23(a) and (b). For example it appears that there are two points of access for the proposed
subdivision from Old Crews Road and Old Milburnie Road. Additionally, it appears that the neighborhood to the north
would also have two points of access from the extension of Endwell Drive and the existing connection at Buffaloe Road.
Therefore, it is unclear if the proposed activities in this location are in compliance with GC 23(a) and (b). Please redesign
or provide information to support the road crossing at Impact Area 2.

Please submit the above information within 30 days of receipt of this Notification or we may consider your application
withdrawn and close the file. Please email ([e-mail]) me if you have any questions/concerns or
would like to set up at time to discuss.
Lyle Phillips
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone]
Fax: [phone]
Email: [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at https://regulatory.ops.usace.armV.mil/customer-service-survey/. Thank you for taking the time to visit this
site and complete the survey.