20231169 Ver 1_More Info Requested_20231017

Baker, Caroline D
From: Homewood, Sue
Sent: Tuesday, October 17, 2023 9:22 AM
To: Brad Luckey; [e-mail]
Cc: Seneres, David J; Homer, Seren M; Hopper, Christopher D CIV (USA)
Subject: Request for Additional Information for Suits Rd -Providence Pt Residential
Development - Randolph County - DWR# 20231169
Brad,
The above noted project has been reassigned to me to distribute some workload. I have conducted a review and require
additional information on the items noted below. Please submit a complete response within 30 days of receipt of this
application. Please note that the application will be considered "on hold" until submittal of a complete response.
1. The plan sheets provided include wetland and buffer markings which are very difficult to distinguish between
which makes it difficult to see the exact limits of the wetlands which overlap with buffer areas. Please provide
plan sheets that clearly distinguish between wetlands and buffer limits.
2. The culvert profiles for Culvert 2 and Culvert 3 show that multiple culverts are proposed to be installed. Given
the reported width of the stream channels, it appears that this will not comply with the Division's standard
condition (quoted below). In addition, it appears that the culverts are to be installed at the same elevation and
at streambed which also would not comply with the Division's standard condition.
"Culverts shall be designed and installed in such a manner that the original stream profiles are not
altered and allow for aquatic life movement during low flows. The dimension, pattern, and profile of
the stream above and below a pipe or culvert shall not be modified by widening the stream channel or
by reducing the depth of the stream in connection with the construction activity. The width, height, and
gradient of a proposed culvert shall be such as to pass the average historical low flow and spring flow
without adversely altering flow velocity. If the width of the culvert is wider than the stream channel, the
culvert shall include multiple boxes/pipes, baffles, benches and/or sills to maintain the natural width of
the stream channel. If multiple culverts/pipes/barrels are used, low flows shall be accommodated in
one culvert/pipe and additional culverts/pipes shall be installed such that they receive only flows above
bankfull. Placement of culverts and other structures in streams shall be below the elevation of the
streambed by one foot for all culverts with a diameter greater than 48 inches, and 20% of the culvert
diameter for culverts having a diameter less than or equal to 48 inches, to allow low flow passage of
water and aquatic life. If the culvert outlet is submerged within a pool or scour hole and designed to
provide for aquatic passage, then culvert burial into the streambed is not required."
3. The culvert profiles for Culvert 2 and Culvert 3 do not show the keyed in riprap pad. Please provide these details
so that DWR can confirm compliance with 401 conditions.
4. On Sheet CWI 2.5 two buffer impacts are shown within Zone 2, however it appears that in both locations, fill is
proposed into Zone 1 and possibly into streams (see item 1 for inability to identify feature limits clearly). Please
ensure that all proposed impacts are accurately depicted and accounted for on the plan sheets and PCN impact
table.
5. Pursuant to 15A NCAC 02H.0506(b) "a 401 Water Quality Certification may only be issued upon determining that
the proposed activity will comply with state water quality standards which includes designated uses, numeric
criteria, narrative criteria and the state's antidegradation policy, as defined in rules of 15A NCAC 02B .0200... In
assessing whether the proposed activity will comply with water quality standards, the Division shall evaluate if
the proposed activity: (2) would cause or contribute to a violation of water quality standards; (3) would result in
secondary or cumulative impacts that cause or contribute to, or will cause or contribute to, a violation of water
quality standards. Based on the current proposed plan the Division believes there is potential for indirect

impacts to Wetland WK, Wetland WJ and stream ISF as all surface flow to these areas appears to be routed to
SCMs which would discharge at the lower end of the noted features. Please either, include indirect impacts to
these features within the impact table and provide mitigation as appropriate, provide hydrologic calculations to
document that surface flow will continue to support the existing function of these features, or provide a
monitoring plan that will document existing conditions and post construction conditions these features.
Thanks,
Sue Homewood (she/her/hers)
401 & Buffer Permitting Branch
Division of Water Resources
[e-mail] please note my new email address
336 813 1863 mobile
919-707-3679 office
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.