20231170 Ver 1_More Info Requested_20231204

Baker, Caroline D
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Brad,
Homewood, Sue
Monday, December 4, 2023 8:30 AM
Brad Luckey; Hopper, Christopher D CIV USARMY CESAW (USA)
Jeff White; Munzer, Olivia
RE: [External] RE: Request for Additional Information for McConnell Rd -McConnell
Ridge Residential Development - Guilford County - DWR# 20231170
Follow up
Flagged
Thank you for the response to the previous questions. Upon review of the updated information, I again 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.
With regards to the two added water line crossings please provide:
1. Explanation of why the waterline cannot be installed within the roadway shoulder at the stream crossings as
shown in areas adjacent to the stream crossings.
2. Explanation of why the water line cannot be installed by methods that would not require disturbance to the
stream (bore/drill).
3. Not withstanding the answers to the questions 1 and 2 above, please review the stream impact length shown
and confirm that the length provided is in the direction of flow, it appears that the stream impact length may be
reported as the width of the channel.
4. Not withstanding the answers to the questions 1 and 2 above, the Division has significant concerns regarding
open cut installation methods in large stream systems. It is staff's experience that open cut installation methods
within large streams are extremely difficult to construct and maintain in a manner that ensures compliance with
water quality standards. Please provide very specific construction details, including proposed dewatering
methodology, expectation of encountering rock and methodology for removal of rock, expected construction
timeline, and additional measures proposed to ensure water quality protection during construction.
5. Not withstanding the answers to the questions 1 and 2 above, it is the Division's experience that erosion control
programs and/or utility maintenance requirements will not approve vegetative restoration of disturbed channels
of this size. Please review the proposed stream restoration detail and ensure that it will meet other
requirements. Please revise restoration details as necessary.
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: Tuesday, November 21, 2023 4:25 PM
To: Homewood, Sue <[e-mail]>; Hopper, Christopher D CIV USARMY CESAW (USA)
<[e-mail]>
Cc: Jeff White <[e-mail]>
Subject: [External] RE: Request for Additional Information for McConnell Rd -McConnell Ridge Residential Development -
Guilford County - DWR# 20231170
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 and Chris,
Please find attached updated PCN and responses to information below. Please note that 2 water line crossings (1 of
Little Alamance Creek and 1 of Beaver Creek) have been delineated by Pilot and incorporated into the PCN. Additionally,
Pilot also delineated a limited area of right of way along McConnell Road associated with the widening of McConnell
Road to add turn lanes. It was determined after Civil design that the proposed widening within this area would not
result in additional impact to streams or wetlands. Let me know of any concerns, thanks.
NCDWR 1: The plan sheet labeled Overall McConnell Ridge Stream Impacts does not appear to include all jurisdictional
features. Specifically, wetland DWE does not appear to be shown and lot/fill development appears to be proposed
which may impact this feature. Please provide an overall development plan sheet showing current and future proposed
development with all jurisdictional features shown. The Division understands that future development areas are
conceptual in nature.
Applicant Response: Please see attached Overall Drawing (Evans Sheet 1 of 9) in updated PCN. There are no future
anticipated impacts to waters outside of this application.
NCDWR 2: Please provide a stream restoration detail for the areas of temporary stream disturbance for open cut sewer
line installation.
Applicant Response: Please see attached restoration details for the proposed restoration of temporary disturbance from
the sewer lines (Evans Sheet 9 of 9) and water lines (Gannett Fleming Sheets 2/3 of 3).
NCDWR 3: 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 stream SC
as all surface flow to this stream appears to be routed to a SCM which would discharge into Stream DSA. Please either,
include indirect impacts to this stream 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 the stream, or provide a
monitoring plan that will document existing conditions and post construction conditions stream DSA.
Applicant Response: The applicant has designed the site to return approximately 30% of the pre -construction drainage
area to the unimpacted origin of Stream SC following construction. Initial designs were approximately 10-15% of the
pre -construction drainage aera, however, the applicant updated their stormwater management plan to discharge roof
leaders and backyards in the vicinity of the unimpacted origin of Stream SC to obtain the 30% post construction drainage
area. It should be noted that not all 70% of the drainage area that is being redirected to SCM contains impervious
surfaces. Yards, landscaped areas and other pervious aeras, which make up a considerable percentage of the removed

drainage area, will continue to provide hydration from groundwater recharge to the unimpacted origin of Stream
SC. Based on the amount of post construction drainage area and lack of all of removed drainage area being from
impervious surfaces, it is our opinion that Stream SC will continue to function as an intermittent stream channel.
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 10:30 AM
To: Brad Luckey <[e-mail]>; *[e-mail]
Cc: David. [e-mail]; Homer, Seren M <[e-mail]>
Subject: Request for Additional Information for McConnell Rd -McConnell Ridge Residential Development - Guilford
County - DWR# 20231170
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 sheet labeled Overall McConnell Ridge Stream Impacts does not appear to include all jurisdictional
features. Specifically, wetland DWE does not appear to be shown and lot/fill development appears to be
proposed which may impact this feature. Please provide an overall development plan sheet showing current
and future proposed development with all jurisdictional features shown. The Division understands that future
development areas are conceptual in nature.
2. Please provide a stream restoration detail for the areas of temporary stream disturbance for open cut sewer line
installation.
3. 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 stream SC as all surface flow to this stream appears to be routed to a SCM which would discharge
into Stream DSA. Please either, include indirect impacts to this stream 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 the stream, or provide a monitoring plan that will document existing conditions
and post construction conditions stream DSA.
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.