20231169 Ver 1_More Info Received_20231204 (3)

Baker, Caroline D
From: Brad Luckey <[e-mail]>
Sent: Monday, December 4, 2023 9:52 AM
To: Homewood, Sue;[e-mail]
Cc: Seneres, David J; Homer, Seren M; Hopper, Christopher D CIV (USA)
Subject: RE: [External] RE: Request for Additional Information for Suits Rd -Providence Pt
Residential Development - Randolph County - DWR# 20231169
Attachments: 20231130 Providence Pointe Environmental Exhibits.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
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Good Morning Sue,
I hope you are doing well. I am glad the updated drawing with color and hatching were helpful. Please find the attached
and below applicant responses to the Division request for information dated 11.30.23. Please let me know if you require
additional information to complete your review. Thanks.
NCDWR 1) The response you provided states "Wetland WJ and Stream ISF receive a majority of their existing drainage
area from off -site that would not be impacted by the proposed project. " A review of USGS stream stats (location of
drainage area approximated based on maps provided) indicates that majority of the drainage area to these features is
within the project limits. Please provide a visual representation or other documentation to support the previous
statement as well as the statement that ". Following construction, Wetland WJ and Stream ISF will maintain
approximately 72% and 69% of their pre -construction drainage areas, respectively. "
Applicant Response: Please find attached Stream ISF and Wetland WJ exhibits documenting previously provided
hydrologic calculations.
NCDWR 2) The response you provided states "Wetland WK will maintain approximately 20% of its preconstruction
drainage area. However, of the 80% of preconstruction drainage area that is redirected to SCM 4, approximately 57% of
this area contains pervious surfaces that will contribute to hydrology of Wetland WK through groundwater
discharge." Please provide a visual representation to show the areas that will remain pervious after construction.
Applicant Response: Please find attached Wetland WK/SCM 4 Impervious exhibit documenting previously provided
hydrologic calculations.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]

From: Homewood, Sue <[e-mail]>
Sent: Thursday, November 30, 2023 8:01 AM
To: Brad Luckey <[e-mail]>; [e-mail]
Cc: Seneres, David J <[e-mail]>; Homer, Seren M <[e-mail]>; Hopper, Christopher D
CIV (USA) <[e-mail]>
Subject: RE: [External] RE: Request for Additional Information for Suits Rd -Providence Pt Residential Development -
Randolph County - DWR# 20231169
Hello Brad,
Thank you for the responses provided. The plan sheets with colors and hatching was extremely helpful in completing my
review. After review of the responses I have follow up questions on item number 5. Please provide a response to the
following items. Please note the application will be considered on hold until receipt of a response:
1. The response you provided states "Wetland WJ and Stream ISF receive a majority of their existing drainage area
from off -site that would not be impacted by the proposed project. " A review of USGS stream stats (location of
drainage area approximated based on maps provided) indicates that majority of the drainage area to these
features is within the project limits. Please provide a visual representation or other documentation to support
the previous statement as well as the statement that ". Following construction, Wetland WJ and Stream ISF will
maintain approximately 72% and 69% of their pre -construction drainage areas, respectively. "
StreamStats Report
Region ID:
Workspace ID:
Clicked Point (Latitude, Longitude):
Time:
2. The response you provided states "Wetland WK will maintain approximately 20% of its preconstruction drainage
area. However, of the 80% of preconstruction drainage area that is redirected to SCM 4, approximately 57% of

this area contains pervious surfaces that will contribute to hydrology of Wetland WK through groundwater
discharge." Please provide a visual representation to show the areas that will remain pervious after
construction.
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.
From: Brad Luckey <[e-mail]>
Sent: Wednesday, November 15, 2023 12:55 PM
To: Homewood, Sue <[e-mail]>; [e-mail]
Cc: Seneres, David J <[e-mail]>; Homer, Seren M <[e-mail]>; Hopper, Christopher D
CIV (USA) <[e-mail]>
Subject: [External] RE: Request for Additional Information for Suits Rd -Providence Pt Residential Development -
Randolph County - DWR# 20231169
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good Afternoon Sue,
Please find attachments and below response to Division's request for information. Please let me know if there is
additional information required to process 401. Feel free to give me a call with any concerns. Thanks.
NCDWR 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.
NCDWR 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."
NCDWR 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.
Applicant Response: Please find attached updated PCN and impact drawings. Hatching/coloring has been used to
differentiate wetland from riparian buffer impacts. Culverts have been re -designed to match existing channel width as
closely as possible and to utilize off -set dual culverts for low/high flow passages. Rip -rap that will be keyed into existing
grade of stream bed elevations is shown within the attached stream crossing cross sections and profiles. Note there is a
slight reduction in net loss permanent impact of wetlands for the proposed two road stream/wetland crossings
quantifies previously provided. Otherwise, there have been no changes to proposed stream and wetland impact
quantifies that were previously provided.
NCDWR 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.
Applicant Response: The plans have been updated to incorporate use of a retaining wall in this area. There are no other
additional stream or wetland impacts than those proposed within this application.
NCDWR 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.
Applicant Response: The applicant will obtain stormwater management plan approval from the City of Archdale, a
NCDEQ delegated municipality, prior to impacts occurring. The stormwater management plan requires water from all
impervious surfaces of the project to be treated. The applicant's civil engineer has conducted an extensive hydrologic
analysis for Wetland WJ, Wetland WK and Stream ISF. Wetland WJ and Stream ISF receive a majority of their existing
drainage area from off -site that would not be impacted by the proposed project. Following construction, Wetland WJ
and Stream ISF will maintain approximately 72% and 69% of their pre -construction drainage areas,
respectively. Wetland WK will maintain approximately 20% of its preconstruction drainage area. However, of the 80%
of preconstruction drainage area that is redirected to SCM 4, approximately 57% of this area contains pervious surfaces
that will contribute to hydrology of Wetland WK through groundwater discharge. Based on the amount of recharge back
to the groundwater table and existing maintenance of surface drainage, we do not believe that the proposed
development will cause indirect impacts due to the partial removal of hydrology from Wetland WJ, Wetland WK or
Stream ISF.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)

PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
From: Homewood, Sue <[e-mail]>
Sent: Tuesday, October 17, 2023 9:22 AM
To: Brad Luckey <[e-mail]>; [e-mail]
Cc: Seneres, David J <[e-mail]>; Homer, Seren M <[e-mail]>; Hopper, Christopher D
CIV (USA) <[e-mail]>
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.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.