HomeMy WebLinkAbout20230410 Ver 1_Capeton_IP_Response_071923_20230719DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
CAROLI ILIA 3040 NC 42 West, Clayton NC 27520
ECOSYSTEMS P:919-606-1065
July 19, 2023
Ms. Katharine Elks
Wilmington Regulatory Field Office
US Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
RE: April 3, 2023 Request for Additional Information & Public Notice Comments
SAW-2022-00968
Capeton Development
Harnett County, North Carolina
Dear Ms. Elks;
Per your letter from April 3, 2023, we are providing the following additional information for
your review and processing of the Individual Permit for the above -referenced project. Each item
requested is repeated for reference (in italics) followed by the corresponding additional
information. In addition to the items below from your letter, we are also providing responses to
comments received through the public notice process from the NC Division of Water Resources
and Campbell University.
Request for Additional Information
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.
The proposed project is the least damaging practicable alternative for the site that meets the
purpose of the development, which is to provide a mixed -use development with commercial
access (US 421) and river frontage within the proximity of the Town of Lillington for future
pedestrian access. Before evaluating alternatives, several major constraints should be
considered:
- Commercial areas must have access to US-421 and therefore are constrained to the
northern portion of the site.
- Retail and recreational areas associated with river views and access are constrained to the
southern portion of the site, and particularly the central area where views are available
from upland areas without encroachment into the floodplain or increased impacts.
- Ingress and egress points are required for connection to US-421 and to the properties to
the east and west.
- Truck traffic for the primary retail component (i.e. grocery store) must be separated from
the primary residential traffic entrance off US-421.
- Three primary drainages (Dry Creek, Stream SB, and Stream SS) bisect the site.
- Gas pipeline crossings should be minimized to the greatest practicable extent.
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 2 of 8
July 19, 2023
Alternative site designs were evaluated from conceptual depictions through to detailed
evaluation of design and impacts. An intensive effort has been made to address environmental
concerns and minimize impacts to the aquatic environment, including initial walkthrough to
identify major issues and constraints, development of conceptual plans and alternatives that
minimized large-scale impacts, detailed wetland and stream delineation, master planned site
development, and detailed engineering and minimization of impacts. Alternatives provided
below are grouped by general concept, as each alternative has numerous iterations, along with a
determination of their practicability.
Alternative 1: No Action Alternative
If the proposed Capeton master planned community was not implemented, each of the
seven primary parcels that make up the site, ranging in size from 32 to 202 acres, could
be developed "by right", without rezoning or master planning, in a piecemeal approach
by individual developers. The original zoning for the site would have allowed for similar
uses including General Business along US-421 and residential development internal to
the site (up to RS-20). This approach would likely result in the following:
- Each component with US-421 access would likely include commercial
components adjacent to US-421, pushing residential development further into the
site.
- Road crossings would still have been required to provide access to adjacent
parcels, leading to similar impacts, or possibly increased impacts as the timing of
individual delineations and identification of resources on adjacent parcels would
not be coordinated to achieve avoidance and minimization.
- River access and riverfront development would not have been able to be
concentrated in the upland area in the center of the site possibly leading to
additional development in or adjacent to the floodplain.
- The coordinated sewer infrastructure, including new pump station and routing the
Town's wastewater infrastructure through the site, would have been difficult to
achieve without the master planned community.
Overall, the no action alternative would have yielded similar and more likely increased
impacts. Those impacts, assuming development proceeded over time with individual
developers, could have been permitted under individual Nationwide Permits, leading to
cumulative impacts of similar or greater magnitude. In addition, it is reasonable to
assume that at least some of the impacts would possibly have been under typical
compensatory mitigation thresholds which would result in a net loss of function on the
site versus the proposed plan which provides compensation for all proposed impacts.
Alternative 2: Ubland Alternative
Development of the site in uplands with no impacts to CWA resources is not practicable.
As mentioned above, three primary drainages bisect the site, which prevents total
avoidance of impacts. Existing crossings are not sufficiently wide enough (i.e.. one -lane
farm roads), or are too degraded (Dry Creek crossing), to provide permanent connection
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 3 of 8
July 19, 2023
between the three primary component areas of the site (east, central, and west) without
impacts.
As mentioned in Alternative 1, upland development even if practicable would still require
sewer and transportation infrastructure connections between components or parcels if
developed separately, leading to similar or greater impacts.
Alternative 3: Moving road crossings up/down slope
Due to the relatively unique landscape position of this site, many of the drainages begin
with headwater wetland systems that transition to steep valleys with stream channels as
they flow toward the river and its floodplain. Alternative road crossing locations
throughout the site would either be shifted upstream which would generally increase
wetland impacts, or shifted downstream which would generally increase stream impacts
in steeper valleys requiring wider fill slopes. Each proposed crossing location is
addressed below along with the general results of shifting up or downstream — note these
are generalizations based on the location and size of resources and depth or height of
infrastructure crossings. Calculations related to actual potential increases in impacts
would require complete conceptual designs of alternative layouts and crossing locations
that would obviously lead to higher impacts, and therefore that effort has not been
performed at this time.
Crossing
Upstream Shift Impact
Downstream Shift Impact
Dry Creek
Increased wetland
Increased wetland and floodplain
SAB
Increased wetland
N/A (Dry Creek)
SB
Increased wetland & stream
Increased wetland, stream & floodplain
SK
Increased wetland
Increased wetland
SO
No additional impacts
Increased stream & wetland
SP
N/A — off property
Increased stream and wetland
SS
Increased wetland
Increased stream
As can be seen from the chart above, only the shifting of stream SO road crossing
upstream would result in a decrease in impacts. This stream is a ditched feature draining
farmland, with no adjacent wetlands at the crossing location. Avoiding this feature was
considered but deemed impracticable as cul-de-sac roads would not allow proper traffic
circulation for safety and accessibility to the amenities center in the active adult phase of
the project. Lot fill has been avoided for this crossing location to retain current drainage
patterns.
Alternative 4: Commercial Area Reconfiguration
The commercial area along US-421 was considered in different locations and different
configurations. Of the three portions of the site that abut US-421, the central area where
commercial components are proposed provides the most room to allow multiple
entrances for residential and commercial traffic, along with space between CWA
resources to minimize impacts and provide natural buffers between dissimilar land uses.
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 4 of 8
July 19, 2023
An alternative placing the commercial component on the west side of the primary
(central) entrance from US-421 was considered. However, this could result in similar
impacts as the headwater wetland associated with stream SL encroaches into this zone of
the site. In addition, a secondary entrance "behind" the commercial retail area would be
needed just east of Dry Creek and its associated wetlands, which abut US-421 and may
not allow for road improvements such as a truck turn lane without increasing impacts.
Further evaluation of this alternative is ongoing but unlikely to reduce impacts below
those proposed. The configuration presented in this application is most consistent with
conventional retail planning, including location on the right hand side of US-421 during
predominant afternoon traffic and on the east side of the boulevard entrance for
maximum visibility.
Alternative 5: Co -location with Gas Pipeline
From the outset of the development of this project, extensive effort has been focused on
coordination with Piedmont Natural Gas and several alternatives were proposed to co -
locate road and utility crossings with the pipeline, which cuts across the entire site. As
described in the initial permit application, locating a road or utility line within the gas
pipeline is not practicable as it would not be allowed by the gas company. Co -location of
several road crossings, besides the proposed crossing at Dry Creek, were considered.
However the other pipeline crossings were not viable as the existing crossings were not
well -maintained roads but rather mowed easements.
- Stream SK could be crossed at the pipeline but that alignment would yield
increased impacts to wetlands and streams (compared to the two proposed
bottomless culvert crossings upstream) and also require impacts to features to the
west draining to stream SB.
- Streams SO, SR and SS would all have to be crossed at one time, rather than one
crossing of SS upstream (as proposed) and lead to much greater impact to streams
and wetlands on the site.
Utility crossings have been co -located as much as practicable with the pipeline (i.e.
Impact N), but additional co -location is not practicable in the center of the site (i.e.
Impact K) as the sewer line has to gravity drain to the existing or proposed pump stations.
See the next response for discussion of the Dry Creek crossing lack of practicable utility
co -location.
Alternative 6: Impact H Preservation
One alternative considered was avoidance of Impact H (wetland WAP). Placing this in a
greenspace in the center of a developed area would result in the eventual draining of the
wetland, which sits in a relatively flat area that would not have adequate fall to allow
stormwater to be drained toward it from all sides. Raising the site to allow continual feed
of stormwater (treated by SCMs) from all sides would be impracticable from a cost and
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 5 of 8
July 19, 2023
logistics standpoint due to its central location. Therefore, stormwater drainage would
need to be routed away from the wetland, causing long-term degradation and drainage.
Alternative 7: Proposed Project
This alternative was detailed in the initial application, and in comparison to the general
alternatives provided above, the proposed project is the least damaging practicable
alternative for a master -planned development on this site. Considering the various
components and functions, impacts have been minimized by using existing road and
utility crossings where practicable, avoiding road crossings in the floodplain. Considering
that there are over 33,000 linear feet of streams (not including the Cape Fear River) and
over 84 acres of wetlands on the site, the permanent loss of Waters of the US proposed
for Capeton comprises approximately 3% of the total length of streams and 4% of the
total acreage of wetlands on the site.
b. It is necessary for you to have taken all appropriate and practicable steps to minimize wetland
losses. Please indicate all that you have done, especially regarding development and
modification of plans and proposed construction techniques, to minimize adverse impacts. In
review of your submitted plans, there were a few items where it appears that further
minimization steps could be implemented. For example, please include information to support
why impacts to W26-W29 could not be further avoided or minimized by shifting the parking lot
footprint and /or ingress/egress routing. Similarly, this information should verify why the road at
W36 can't be shifted or retaining walls be utilized to further reduce impacts. Additionally, please
justify the need for two (2) relatively close sanitary sewer crossings (W12-14 & W15-23) that are
in addition to the road crossing impacting the Dry Creek stream and wetland complex.
Impact avoidance and minimization has been performed throughout the site development process
and it is our contention that the proposed plan has minimized impacts to the greatest practicable
extent given the site constraints and purpose of the project. The specific items requested are
each addressed below.
Impacts W26-W29 are located in the commercial portion of the site adjacent to US-421. The
proposed impacts are based on conceptual plans for the commercial area, as is typical for this
size development, since a retail hub store has not been contracted at this time. The proposed
layout provides a commercial area meeting minimum requirements including:
- Typical square footage of for the retail hub space (i.e. grocery store) of at least 45,000
square feet, which is typical for grocery stores chains in the region.
- Orientation toward the west to provide frontage to the main entrance and parking, and
allow supply traffic to enter from the east and ingress/egress from US-421 while
minimizing conflicts with customer & residential traffic and providing visibility from
US-421
- Minimum parking space requirements for the amount of potential retail space. The
proposed plan meets minimum requirements in the current configuration, but is subject to
change based on the ultimate tenant requirements.
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 6 of 8
July 19, 2023
- Adequate distance between entrances along US-421 that do not impede traffic flow or
create safety issues as determined by NCDOT.
Impact site 26/27 has been minimized through the use of a retaining wall, saving 0.04 acre of
wetland impact. Avoiding this impact would either reduce parking below required standards,
reduce the size of the SCM treating this high impervious area, or require shifting of the
commercial area to the west side of the primary entrance, which would have similar impacts (see
Alternative 4 above).
Impact site 28/29 is unavoidable due to the lack of space between US-421 and the wetland. A
secondary entrance is required to access behind the retail frontage outparcel and provide
unobstructed access to the loading dock area of the retail hub store.
As discussed in our meeting on 5/31/23, further refinements of the design of this commercial
area will be undertaken once the specific retailer has been identified. Any modification in this
area would reduce impacts as compared to those proposed.
Impact W36 has been re-evaluated based on your comment as designs in that section of the
development have been advanced since the permit application. This impact has been eliminated
and removed from the attached updated impact maps.
Impacts W12-14 and W15-23 were required as the sewer connections must tie to the existing
gravity sewer along Dry Creek at existing manholes agreed upon by the Town of Lillington. At
the time of the permit application, combining the two systems could have conflicted with SCMs
treating stormwater on the west side of Dry Creek and the gas pipeline. Since design in this
section of the development has been advanced since that time, the combining of the sewer
infrastructure on the west side of Dry Creek has been determined to be feasible. The revised
impact maps attached have eliminated the upper crossing (W12-14).
c. The MOA requires that appropriate and practicable mitigation will be required for all
unavoidable adverse impacts remaining after all appropriate and practicable minimization has
been employed. Please indicate your plan to mitigate for the projected, unavoidable loss of
waters or wetlands or provide information as to the absence of any such appropriate and
practicable measures. For example, the NC WAM rating sheet for wetland WAP, proposed for
1.515 acres of fill at a 1:1 mitigation ratio, is graded as low but has N/A for many rating
components. Please provide documentation including the assessment paperwork used to obtain
the ranking to support the proposed mitigation ratio.
The compensatory mitigation proposal included in the original application for this project
includes payment to private mitigation banks as described. The proposed ratios were developed
from the NCWAM/SAM ratings (2:1 for High, 1.5:1 for Medium, and 1:1 for Low).
Unfortunately, the current version of the rating forms are creating issues with generating PDFs of
the entire form, therefore only the result sheets were included in the application. The Not
Applicable results are auto -generated from the answers on those forms, which are being provided
via email to you in Microsoft Excel format for full clarity on how they were assessed. If you
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks Page 7 of 8
SAW-2022-00968 July 19, 2023
would like to review the specific areas in the field with the forms and evaluate the mitigation
proposal, we would be happy to coordinate a visit to the site.
Public Notice Comments
NC Division of Water Resources — April 24, 2023
NCDWR commented that the purpose/need limits siting criteria and prematurely disqualifies
other alternatives from a thorough analysis. While it is our contention that Capeton is a rather
unique project, which in and of itself limits alternatives, a more thorough evaluation of other
alternatives is provided below and in the attached Table 1 and Figure 1 to address this concern.
Rather than eliminating alternatives using the criteria described in the IP application, similar
criteria have been ranked in comparison to other areas meeting at least some of these criteria
which are located along the river and within the planning area for connectivity to Lillington
according to their 2020 Bicycle and Pedestrian Master Plan (excerpt attached). Using this larger
area, instead of a 2-mile walking radius from the Town, several sites along the river consisting
primarily of large parcels, without other developments or roads bisecting them, were grouped
together in a comparable range of sizes.
Acreage, river frontage, and US route frontage were evaluated with the largest of each criteria
receiving the highest rank. This reflects the development potential of each area with increased
acreage and US frontage, which increases the value of the land to offset the high cost of river
front properties. Environmental impacts are ranked using approximate footage of NRCS mapped
stream features in each alternative area. Since the stream footage would vary by size of each
area, and artificially inflate larger site impacts, the stream footage was divided by the acreage to
reflect the relative concentration of streams in each alternative. Practicability of acquisition is
evaluated through the number of major parcels involved in each area, which include the larger
parcels comprising each alternative and any medium sized ones that provide significant river or
road frontage. Finally, after ranking the areas, an additional overlay of floodplain constraint
(where the location of the floodplain would prevent development of the area) and adjacent land
use conflicts (the wastewater treatment plant or airport) were applied.
Table 1 presents the results of this analysis. As shown, the proposed project received the highest
overall favorable ranking while being one of the least environmentally damaging practicable
alternatives based on streams/acre. Three of the other top five sites (Alternatives 1, 2 and 4) have
floodplain or land use constraints which would prevent reasonable development of a similar
nature. The only other top 5 area (Alternative 8) is located approximately 3 miles upstream of
the Town, with no commercial frontage capacity, and consists of 12 parcels, making acquisition
problematic.
Campbell University —April 27, 2023
Campbell University expressed some concern regarding the roads being stubbed out on the east
side of Capeton at the west edge of their property. Greenfield has been in communication with
the University, and has committed to providing gates and signage at each of the stub out
DocuSign Envelope ID: E2417055-18DF-47AA-90A3-F93EE7C41625
Ms. Katharine Elks
SAW-2022-00968
Page 8 of 8
July 19, 2023
locations, which are required by the Town as part of the development approval process.
Communication between Greenfield and Campbell University is attached.
We would appreciate your consideration of this information during the review of this permit
application and look forward to your favorable review of this project. Please contact me at your
convenience if you have any questions or require further information.
Sincerely,
Carolina Ecosystems, Inc.
DocuSigned by:
P��p n'Ld1A1
P 1 ip6 yE54E4...
Senior Environmental Scientist
Cc: Sue Homewood, NCDWR Winston-Salem Regional Office
Matthew Brubaker, Greenfield Communities
Attachments:
- Table 1: Alternative Area Comparison
- Figure 1: Alternative Areas
- Town of Lillington Bicycle & Pedestrian Master Plan (Excerpt — page 41)
- Revised Impact Map Set
- Greenfield -Campbell University Email Communication (provided via email)
- NCWAM & SAM Excel Spreadsheets (provided via email)
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