20020730 Ver 4_More Info Received_20230614 (2)

4700 Falls of Neuse Rd #300 ,,,'
Raleigh, NC 27609
moffafi & niahol [phone]
www.moffattnichol.com
November 11, 2022
Division of Coastal Management
400 Commerce Avenue
Morehead City, NC 28557
Attn: Cameron Luck, Assistant Major Permits Coordinator
Subject: Response to Additional Information Request for the CAMA Permit Application
Submittal for NC Department of Cultural Resources at USS Battleship, Living with
Water Project, New Hanover County
Dear Mr. Luck:
In response to an email concerning the referenced project from the NC Division of Water Resources (DWR)
dated October 18, 2022 (enclosed), and a letter from the Division of Coastal Management dated October 19,
2022 (enclosed), we are providing additional information. This letter provides clarifications to address specific
concerns related to the volume of water to be conveyed through the proposed constructed wetland and how
the project has been designed to comply with 15A NCAC 02H .0506 (b)1).
Based on discussions with DWR and Stormwater Services on October 19, 2022, and on behalf of the
Battleship NORTH CAROLINA, we are requesting a Water Quality Certification that defines this
project as a "Re -development" project according to the below statutes and accordingly does not require any
additional Stormwater measures in addition to what was presented in the original application, dated August 9,
2022.
• 15A NCAC 07.0208 (a) (2) (B) — `Development shall comply with State and federal water and air quality rules,
statues and regulations;"
• NCGS 15A NCAC 02H .1001(1)(f) — Post -Construction Stormwater Management: Purpose and
Scope: This section shall not apply to "redevelopment as the term is defined in G.S. 143-214.7(al)."
• NCGS 143-214.7(a1) (2) — `Re -Development — Any land -disturbing activity that does not result in a net increase
in built -upon area that provides greater or equal stormwater control to that of the previous development. "
The following calculations document that (1) the quantity of stormwater is reduced due to a reduction of
impervious footprint on the site post -construction, and (2) the stormwater quality is improved due to a
constructed tidal wetland where no structural BMPs exist in the current baseline condition.
1) Reduction in Impervious Area
As depicted in Figures 1 and 2, the proposed Living with Water project has an overall impervious
reduction from 4.67 acres (existing) to 4.09 acres (proposed). This re -development equates to a 12.4%-, or
0.58-acre reduction of impervious parking lot area. The gravel/"crusher run" parking surfaces (both existing
and proposed) are included as impervious areas.

Summary of impervious areas removed:
• Existing compacted "crusher run" stone to be removed = 108,262 sf
• Existing asphalt pavement to be removed = 95,337 sf
• Total impervious removal = 203,599 sf = 4.67 ac
Summary of impervious areas added:
• Gravel overflow parking area = 19,764 sf
• New asphalt = 133,174 sf
• New concrete walkway = 16,025 sf
• New concrete curb = 9,070 sf
• Total impervious added = 178,033 sf = 4.09 ac
Note: The gravel overflow parking area will incorporate a "porous" gravel design that will qualify as
pervious based on standards. Although this gravel area would qualify as pervious, the design
calculations classify this area as impervious, to be conservative. The gravel design will be
distinguished from the existing crusher run areas.
2) Provides Equal or Better Stormwater Control Than the Previous Development
The existing site does not include stormwater treatment. Much of the runoff generated flows overland
to roadside channels, towards the Battleship, or directly to the Cape Fear River. There are also four drainage
inlets in front of the visitor center that discharge via a pipe towards the Battleship basin (see Figure 1).
The proposed design will include a stormwater treatment wetland (see Figure 3). The wetland will be
planted with typical stormwater wetland vegetation although focusing on plants that are more salt tolerant. It
will include an outlet riser structure with a water quality drawdown orifice, overflow at the top of the riser, and
a trash rack. The outlet pipe will discharge into an energy dissipation pool at the head of the proposed tidal
creek. The wetland will be designed to State standards except for a reduced water quality storage volume. This
wetland is not sized to treat the 1.5-inch water quality storm due to the limited vertical relief on the site. The
site currently floods frequently and will remain at a low elevation even after raising the main parking lot. There
is not enough vertical relief to afford ponding water the typically preferred one foot deep in the stormwater
wetland during the water quality storm, and there is not sufficient space to offset this by increasing the
stormwater wetland footprint. The wetland was sized to be as large as possible considering the vertical and
horizontal constraints at the site. The site can store a 0.6-foot depth in the wetland for water quality treatment.
Below are "Simple Method" calculations demonstrating that this depth stores the runoff volume from
approximately the 0.8-inch storm. Even though this is below the standard for this area of 1.5 inches, many
storms that occur at the site are smaller than 0.8 inches and will be fully detained in the wetland.
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The Simple Method volume calculations are as follows:
• Watershed area = 3.774 ac
• Rainfall depth = 0.8"
• Percent impervious = 100%
• Simple Method Rv = 0.05 + 0.009 (Impervious %) = 0.95
• Simple Method treatment volume = (rainfall depth * Rv * Area)/12
o = (0.8 * 0.95 * 3.774)/12 = 0.239 ac-ft = 10,412 cf
• Simple Method treatment volume = 10,412 cf
• Design water quality storage volume @ 0.6-ft depth = 10,538 cf
(Note: Design water quality storage volume is calculated from the stage -storage relationship based on the
wetland grading design in AutoCAD.)
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C VI C'Tlh l r` Fin Anil ArlU hill CTC•
LEGEND
l EXISTING COMPACTED GRAVEL PARKING/DRIVE
�/ EXISTING ASPHALT REMOVAL
Figure 9. Impervious areas removed duringpr ject construction.

Figure 2. Impervious areas proposed to be added during project construction.
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Figure 3. Screen capture of plan sheet C- 103, "Stormwater Plan "from the CAMA major permit submittal.
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3) Construction Methodology and Sequencing
As noted in DWR's comments, the waters of the Cape Fear River in the vicinity of the proposed project are
class SC and are designated as Primary Nursery Areas by the NC Marine Fisheries Commission. Accordingly,
the NC Wildlife Resources Commission (WRC) has requested a moratorium between April 1 — September 30
for activities associated with the proposed living shoreline. Construction methodology and proposed equipment
is discussed in the CAMA permit narrative. These methods and equipment consist of land -based mechanical
equipment with supplemental manual equipment for sensitive areas (i.e., existing coastal marsh). Construction
matting will be used in sensitive wetland areas. As noted in the permit narrative, existing coastal and volunteer
coastal wetlands along the shoreline will be maintained with minimal impact from equipment.
A preliminary construction sequence has been developed and major elements are provided below: The sequence
includes additional environmental protections and measures as requested by the WRC. The following
construction sequence will be included in final design and technical specifications for compliance by the selected
contractor.
Initial site preparation:
1. Contact North Carolina "one call" before performing any excavation.
2. Contact the NCDEMLR land quality section before beginning work to notify them of the start date.
3. Install rock construction entrances.
4. Install floating turbidity barriers, silt fence and inlet protection measures.
5. Install tree protection fencing.
6. Install and maintain an on -site rain gage and logbook for recording rain dates. Complete self -
inspection as required by the erosion control permit.
Tidal marsh, tidal creek, and living shoreline:
7. Construct the tidal marsh, creek, and living shoreline in the cool season months between September
30th and February 1st to avoid and minimize impacts to fisheries.
8. Avoid working in low lying areas while flooded by riverine tidal inundations.
9. Use "mud mats" as needed when working in wet conditions to minimize erosion from equipment
operation.
10. Tidal/river flooding of the tidal marsh, tidal creek and living shoreline areas should normally be non -
erosive, however more intense storm events could result in erosive flows from onsite runoff in the
tidal creek while under construction. If a large storm is anticipated while construction of the tidal creek
is underway, take measures to stabilize the creek, including installing coir matting per the plans.
11. Time construction of the tidal marsh, tidal creek, and living shoreline areas so that they may be
vegetated upon completion as detailed in the planting plan. No areas should be left unvegetated for
long periods of time.

General erosion control requirements during construction:
12. Follow requirements detailed in the erosion control notes section of this plan set.
13. Minimize disturbance within the site outside of areas where construction work has begun.
14. Use geotextile sediment collection bags when pumping to dewater work areas.
Construction completion:
15. Soil stabilization shall be achieved within 7 calendar days after land disturbing activity has ceased,
temporarily or permanently, on all perimeter dikes, swales, ditches, perimeter slopes and all slopes
steeper than 3:1. All other disturbed areas shall be provided temporary or permanent stabilization with
ground cover as soon as practicable but in any event within 14 calendar days from the last land
disturbing activity.
16. Refer to the landscaping/planting plans for stabilization requirements.
17. At construction completion, ensure that the site is free of trash, equipment, and stockpiled materials.
18. Remove all temporary erosion control measures following the completion of construction.
We appreciate the opportunity to provide additional information to DCM and DWR for the Battleship North
Carolina's Living with Water Project. Please let me or Jose Martinez, Senior Civil Engineer
(iosemartinez(a�moffattnichol.com), know if you have any further questions or need additional clarification.
Sincerely,
MOFFATT & NICHOL
Dawn York
Project Manager
Enclosures
DCM Letter
DWR Email
Cc:
Jose Martinez — Moffatt & Nichol
Terry DeMeo — Battleship North Carolina
Chris Vargo — Battleship North Carolina
Holley Snider — DWR
Tara MacPherson - DCM
Kelly Johnson — NC Division of Energy, Mineral and Land Resources, Stormwater Permitting
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ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
BRAXTON DAVIS
Director
NC Department of Cultural Resources
Dawn York
238 Princess Street
Wilmington, NC 28401
NORTH CAROLINA
Environmental Quality
October 19, 2022
SUBJECT: Coastal Area Management Act (CAMA) Permit Application Submittal for NC
Department of Cultural Resources at USS Battleship, in New Hanover County
Dear Ms. York:
This letter is in response to the above referenced CAMA Major Permit application, which was
accepted as complete by the Division's Wilmington office on August 12, 2022. Processing of the
application is ongoing. However, it has been determined that additional information will be
required prior to the Division taking final action on your application. The required item is
summarized below:
1) Comments were received from the NC Wildlife Resources Commission detailing
concerns regarding activities associated with wetland restoration, which request
established measures to minimize sediment input during high water and rain events.
These comments have been included within this email correspondence.
2) In accordance with 15A NCAC 07H.0208(a)(2)(B), it is the policy of this Division that,
prior to taking final action on a project of this nature, a Water Quality Certification for
the proposed development must first be approved by the Division of Water Resources
(DWR).
On October 18, 2021, the DWR placed the project on hold as proposed and requested additional
information. I have provided the state agency comments within the email providing this
notification for your reference.
Therefore, it is necessary that processing of your permit application be placed in abeyance until
such time as the required information is accepted by the resource agencies and final comments
have been provided.
D Q North Carolina Department of Environmental Quality I Division of Coastal Management
NORTH caHOHNA Morehead City Office 1 400 Commerce Avenue I Moorehead City, North Carolina 28557
nawrowm m Enmminbadi duai�h 252,808,2808

If you have any questions concerning these matters, please feel free to contact me by telephone
at [phone], or by email at cameron.luck(d),ncdenr. og_v.
Sincerely,
Cameron Luck
Division of Coastal Management
Assistant Major Permits Coordinator
CC:
DCM WiRO
Greg Currey, USACE Wilmington Regulatory Field Office
Holley Snider, DWR WiRO
Tara MacPherson, DCM WiRO
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North Carolina Department of Environmental Quality I Division of Coastal Management
Morehead City Office 1 400 Commerce Avenue I Moorehead City, North Carolina 28557
252,808.2808

York, Dawn
From: Snider, Holley <[e-mail]>
Sent: Tuesday, October 18, 2022 3:00 PM
To: York, Dawn
Cc: MacPherson, Tara; [e-mail]
Subject: RE: [External] RE: USS Battleship North Carolina Plans
Good afternoon Dawn,
During the January 6, 2022 scoping meeting for the Living with Water USS North Carolina Battleship project the DWR
expressed concerns regarding stormwater treatment of the proposed run-off and how downstream waters would be
protected. These concerns were specific the volume of water to be conveyed through the proposed stormwater
wetlands and how the project has been designed to comply with 15A NCAC 02H .0506 (b)(1) which requires the DWR to
evaluate that a project has avoided and minimized impacts to surface waters and wetlands to ensure any remaining surface waters
or wetlands, and any surface waters or wetlands downstream, continue to support existing uses during and after project
completion; The waters of the Cape Fear River in this location are class SC and are designated as Primary Nursery Area by
the Division of Marine Fisheries. The DWR is requesting that the stormwater calculations, including run-off and
treatment volumes and calculations be provided for DWR to complete the review. The DWR also has concerns regarding
the specific construction methodology and sequencing for the creation of the tidal wetland. Will the construction areas
be subject to daily tidal inundation? Will heavy equipment be placed in the wetlands, if so are mats proposed? Please
provide a copy of the narrative for the project. The DWR requests that the information be provided to complete our
review. The application is on hold until all of the information detailed above has been received by our office. Feel free to
call or email me if you have any questions.
Sincerely,
Holley Snider . ,><((((�>•' ' . ..><((((°>. '-
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
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Depr.tm-i al Ennronenenjnl pgallYy
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: York, Dawn <[e-mail]>
Sent: Monday, October 17, 2022 2:36 PM
To: Snider, Holley <[e-mail]>
Cc: MacPherson, Tara <[e-mail]>; [e-mail]
Subject: [External] RE: USS Battleship North Carolina Plans
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Hi Holley, thank you for reaching out about the Battleship's Living with Water project plans. The attached plan set was
the last set submitted to CAMA in August. This should have been part of the documents submitted to the agencies for
review.
Tara/Greg — does this plan set need to be sent to the full group in response to the USACE's agency notification from last
week? I am happy to help in any way.
Thank you!
Dawn
Dawn York
Senior Coastal Planner
Moffatt & Nichol
238 Princess St. I Wilmington, NC 28401
P 910.218.7087 1 C 910.612.1152
From: Snider, Holley <[e-mail]>
Sent: Friday, October 14, 2022 2:10 PM
To: York, Dawn <[e-mail]>
Subject: USS Battleship North Carolina Plans
CAUTION: This email originated from outside of the organization.
Good afternoon Dawn,
It has just come to my attention that we do not have digital copies of the CAMA permit application drawings for the USS
Battleship North Carolina project. Can you please send a copy of the pdfs for our records? Thanks in advance and have
a great weekend.
Sincerely,
Holley Snider'' -
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
e:.x5fD,EQ;
R9wranopt m aw"m m" VYa i
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties