SWA000230_More Information Received_20240105 (7)

MORRIS & RITCHIE ASSOCIATES OF NC, PC L . + _
■ -ff •
AN AFFILIATE OF MORRIS&RITCHIE ASSOCIATES, INC.WHICH
PROVIDES ENGINEERING,ARCHITECTURE, PLANNING, SURVEYING&
LANDSCAPE ARCHITECTURE THROUGHOUT THE MID-ATLANTIC REGION
Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
225 Green Street, Suite 714
Fayetteville,NC 28301
Subject: Middle Point Project(SWA00230)
MRA Project: 21814
State Stormwater Response to Comments
Dear Jim Farkas:
We have received your review comments for the above referenced project dated November 1,2023,
and made the changes as requested. Please find the updated plan set and response to comments
letter enclosed. The review comments are listed below and have been addressed as follows:
1. As designed, the proposed project will not meet all of the requirements for a low-density
project upon completion:
a. 15A NCAC 02H.1003(1)(d)(i) — This project is shown as draining to three
separate receiving waters,please provide documentation showing that each
portion of the project (the portion draining to Hickory Branch, the portion
draining to Barbeque Creek, and the portion draining to the Upper Little River) is
below the maximum allowable percent BUA for a low-density project or redesign
as needed to meet the high-density requirements. Please also clarify which portion
of the project drains directly to the Upper Little River (Surface waters listed in
Part E4 of the Application are surface waters that the project directly drains to).
Please revise as needed.
No portion of the site is draining directly into the Upper Little River. The receiving waters
are Hickory Branch and Barbecue Creek, and Part E4 of the application has been revised
accordingly. Surface water labels and BUA Calculations have been added to sheet CLOB.
530 Hinton Pond Road, Suite 104, Knightdale, NC 27545 [phone] www.mragta.com
Abingdon,MD ♦ Baltimore,MD ♦ Laurel,MD ♦ Towson,MD ♦ Georgetown,DE ♦ New Castle,DE ♦ Leesburg,VA ♦ Raleigh,NC
[phone] [phone] [phone] [phone] [phone] [phone] [phone] [phone]

DEMLR
Re: Middle Point(SWA00230): Response to Comments Letter
December 28, 2023
Page 2 of 4
b. 15A NCAC 02H.1003(1)(d)(ii)—Per the plans, a total of 92.00 ac (about 45% of
the entire property area) is designated as passive open space and this open space
is primarily concentrated in two portions of the project area (the northern portion
of the site and the eastern portion of the site near the entrance to the subdivision).
This would result in the BUA for the site being concentrated in the remaining
project area and possibly being considered as a high-density pocket. If the BUA
was more uniformly spread out throughout the project or the land use was more
uniform throughout the project area, this would not be an issue for this site. Please
also specify which portions of the project area are being considered as "surface
water area" (2,422,535 sf per Part E5 of the Application) as this value seems
larger than the actual surface water area for this project.
Surface water labels and BUA Calculations have been added to sheet C1.OB, and Part E5 of
the application has been revised accordingly.
c. 15A NCAC 02H.1003(2)(b) — The proposed design does not maximize dispersed
flow through vegetated areas/minimize the channelization of flow. There is a
difference between designing a project to maximize dispersed flow through
vegetated areas and designing a project and then maximizing dispersed flow
through vegetated areas. Most all of the runofffrom the project is channelized and
conveyed via curb &gutter,pipe network, and/or vegetated conveyance. A low-
density project would be designed so that most, if not all of the runoff from
proposed BUA is allowed to sheet flow across vegetated areas as dispersed flow.
Plunge pools have been added at the ultimate discharge points to encourage dispersed flow.
See Sheets C4.0-C4.9.
d. 15A NCAC 02H.1003(2)(c)— This project proposes an excessive amount of non-
vegetated conveyances. Runs of pipe that are parallel to roadways (such as the
piping from Al-49-> AI-48, AI-40-> AI-38, A2-31 -> A2-30, etc...) can be
avoided by utilizing roadside ditches and piping of runoff down steep slopes can be
avoided by changing how the site is graded(it is noted that there are some steep
areas of this project site, however there are also some artificially steep areas of
this project site that could avoid piping the runoff down the steep slopes by
grading the site differently). Please revise as needed.
Grading and Storm Drainage has been revised to remove the parallel runs of pipe to the
greatest extent possible. See sheets C4.0-C4.9.
e. 15A NCAC 02H.1003(2)(d)(v)— The minimum required downstream length of
vegetated area from a curb outlet system is 100 feet. There are a number of
instances where this minimum length does not appear to be provided(downstream
ofA2-1, A2-22,etc...) Please ensure that this minimum flow length is provided.
Grading and Storm Drainage for all swales have been revised to meet the minimum
downstream length of 100'.In addition,drainage swale dimensions have been added on sheets
C4.10-C4.12.

DEMLR
Re: Middle Point(SWA00230): Response to Comments Letter
December 28, 2023
Page 3 of 4
2. As designed, this project will not meet 15A NCAC 02H.1003(4)(b) upon completion. The
vegetated setbacks from surface waters must be maintained in a vegetated state and riprap
is not vegetation. The riprap aprons located downstream of swales B-A, B-B, B-D, B-E, C-
G, etc... and inlets A3-2 &A3-3, A3-5 &A3-6, etc... are located within the vegetated
setback. Please revise as needed.
Grading and Storm Drainage has been revised to remove the rip rap aprons from impacting
the stream buffers. See sheets C4.0-C4.9.
3. As designed, this project will not meet 15A NCAC 02H.1003(4)(e) upon completion.
Inlets A3-2 &A3-3 discharge untreated stormwater runoff in a manner that it is not
released at the edge of the setback and allowed to flow through the setback(i.e., it is
released within the setback and short circuits it). Please revise as needed.
Grading and Storm Drainage for pipes A3-2 and A3-3 have beed revised to discharge prior
to reaching the stream setback.
4. Please correct the following issues with the Application:
a. Part D4—Please include the name of the signing official on the "Signing Official
& Title"line. Please also provide a phone number and email address at which we
can contact the property owner.
The name and phone number of the signing official in Part D4 has been added. Please see the
revised application.
b. Part E2—Per the plans, a vegetated setback of 30 ft appears to be provided form
surface waters (whereas this part of the application indicates 50). Please revise as
needed.
The vegetated setback shall be 30 feet. The application has been revised accordingly.
c. Part E4 &E5—See earlier comments, revise if needed.
Parts E4 and E5 have been revised accordingly per previous comments.
d. Part F8—Lloyd Enterprises, LP is a partnership. Please provide a copy of the
Certificate of Assumed Name for Lloyd Enterprises, LP.
Per Part F8, The Certificate of Assumed Name is needed for the applicant. Lloyd
Enterprises is not the applicant,DR Horton is.

DEMLR
Re: Middle Point(SWA00230): Response to Comments Letter
December 28, 2023
Page 4 of 4
Sincerely,
Morris &Ritchie Associates of NC, PC
Edgar Rodriguez-Diaz
Directl984-200-2103
[e-mail]