20221617 Ver 2_Eastfield DWR Response Letter_20231116

2401 Brentwood Rd, Suite 107
Raleigh, NC 27604
P [phone]
Terracon.com

November 16, 2023

Sue Homewood
N.C. Department of Environmental Quality
Division of Water Resources
512 Salisbury Street
1611 Mail Service Center
Raleigh, NC 27699-1611

Re: Eastfield Development
DWR# 20221617 V2

Dear Sue:

The Eastfield team is submitting this letter in response to NCDWR’s letter dated September
22, 2023, to Mr. Kevin Dougherty of Eastfield Associates, LCC. Our team consists of the
developer, Eastfield Associates, Gateway Engineers, Modulus, and Terracon. The purpose of
this correspondence is to provide a response for each comment and provide supporting
documentation. The comments from your letter have been reiterated below, immediately
followed by the team’s response.

The project has been revised to remove the feature in Block O that was identified as a
tributary. The only impact in Block O now consists of a road crossing that will impact 0.027
acre of a jurisdictional ditch. Please refer to the attached Master Wetland Map.

The feature identified in Block E has been added to the plans as a jurisdictional stream with
50-foot buffers on each side. This feature is depicted on the attached Master Wetland Exhibit
and Block E Stream Impact Exhibit. These exhibits also depict the proposed impacts to the
stream channel, which comprises two road crossings to allow full access to the usable land in
Block E as well as several outfalls originating from the required Stormwater Ponds that will
serve Block E. The outfalls have been determined to not result in a loss of stream bed. Any
rip rap that is used will be embedded into the streambed to allow unrestricted flow and
continued aquatic life movement.
Eastfield Development
DWR# 20221617 V2
November 16, 2023

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The stream referenced above in Block E is proposed to be crossed by two separate road
crossings (Impact F and G) to allow access to all portions of the usable land. These crossings
have been designed to minimize impacts to the channel and buffers as much as possible. The
two road crossings will incur 299 linear feet of impact; however, the loss of stream bed is
proposed to be 267 LF. The remaining 32 LF consists of four rip-rap aprons (each 8’ft in
length) that will be embedded into the stream bed placed at each crossing (F & G). Stream
mitigation is being proposed for the 267LF of stream bed loss.

Five small outfalls (A1, A2, E1, E2, E3, E4) are also proposed to encroach into the stream
bank inside Block E to allow discharge from the stormwater ponds in this block. Impacts to
the stream bank are approximately 10 LF for each. No loss will result from these outfalls and
any riprap will be embedded into the streambed, and buffers in Block E are as follows and
correspond to the attached drawing for Block E impacts.

The two road crossings (F & G) will incur Allowable buffer impacts as depicted on the Block E
Stream & Buffer Impact Exhibit (proposed buffer impact table). The portion of the riparian
buffer that was previously affected by the road construction is also depicted on this exhibit
and those pre-existing existing impact amounts are as follows. These pre-existing impacts
appear to be in the category of parallel impacts and buffer mitigation is being proposed as
follows.

Pre-Existing Buffer Impact from Existing Construction Activities Associated with
Providence Blvd.
Description Buffer Impact (sf) Multiplier Mitigation
Required (sf)
Zone 1 Impact 7,700 3 23,100
Zone 2 Impact 8,783 1.5 13,175
TOTAL 16,483 36,275

Mitigation for the unavoidable wetland, stream, and buffer impacts associated with the
Eastfield Development is being provided by a private mitigation bank as well as NCDMS.
Based on the current proposed wetland, stream, and buffer impacts that are unavoidable for
this project, the applicant is proposing the following compensatory mitigation.

Eastfield Development
DWR# 20221617 V2
November 16, 2023

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Impacts Mitigation
3.03 acre of wetland impact SOAs attached that will provide wetland
credits covering up to 3.56 acre of impact
267 linear feet of stream impact Attached SOA covers up to 267 LF of stream
impact
16,483 SF of pre-existing buffer impact Terracon is requesting this SOA as this
impact amount was just determined as this
letter was being drafted and submitted.

The updated Stormwater Management Plan and Report for Block E is provided with this
submittal. Also included with this submittal is the updated Supplement EZ Form and the
revised pages of the SWU-101 Application.

The ICI Analysis, as prepared by Gateway Engineers, is attached with this submittal.

The team is aware that based on the inclusion of this feature as a jurisdictional stream, the
land clearing and ground disturbance that has occurred in Block E has subsequently resulted
in what has now been identified as an unauthorized activity in a Neuse River Riparian Buffer.
The applicant is aware that the riparian buffer that is to remain in Block E must be restored.
Approximately 1.8 acres of this riparian buffer will be regraded to pre-disturbance contours
and will be replanted with native woody vegetation (preferably shrubby vegetation) at a
minimum density of 340 stems per acre. If this is deemed acceptable by NCDWR, Terracon
will provide specific details regarding this restoration activity, including a list of potential
species to be planted along with any requested schematics of the proposed restoration area.
It is understood that the restored riparian buffer must be monitored on an annual basis for a
minimum of five years to ensure successful establishment of the planted vegetation. These
annual monitoring events will be reported to NCDWR until the restored buffer is deemed
successful.

The Eastfield project team greatly appreciates your assistance and guidance on this important
Eastfield Development
DWR# 20221617 V2
November 16, 2023

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project. We have strived to satisfy NCDWR’s concerns to the greatest extent possible and
hope that the information contained herein will allow you to resume your review. Please do
not hesitate to contact us if you have any needs or questions.

Sincerely,
Terracon Consultants, Inc

for
Jeff Harbour, PWS Terri Russ
Senior Scientist Department Manager

Cc: Matthew Martin, USACE
Kevin Dougherty, Eastfield Associates
Mark McDonnell, Adventure Dev.
Matt Phillips, Adventure Dev.
Aric Geda, Modulus
Daniel S. Deiseroth, P.E. The Gateway Enginee rs
Josh Scanlon, P.E., The Gateway Engineers
Ryan Enoch, P.E., The Gateway Engineers

Rhiannon Graham