20231170 Ver 1_More Info Received_20240205

Baker, Caroline D
From:Brad Luckey <[e-mail]>
Sent:Monday, February 5, 2024 2:39 PM
To:Homewood, Sue
Cc:Jeff White; Hopper, Christopher D CIV USARMY CESAW (USA)
Subject:RE: \[External\] RE: Request for Additional Information for McConnell Rd-McConnell
Ridge Residential Development - Guilford County - DWR# 20231170
Attachments:6869.2_McConnell Rd_PCN_2.5.24.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Good A?ernoon Sue,

Please find a?achments and below responses to Division RFI on 12/4/23. Please let me know if you require addi?onal
informa?on to process, thanks.

NCDWR 1: Explana?on of why the water line cannot be installed within the roadway shoulder at the stream crossings as
shown in areas adjacent to the stream crossings.

Applicant Response: The water line can not be installed within the road shoulder or suspended from the bridge because
it would not be allowed by NCDOT or the City of Greensboro, who are responsible for maintenance of the exis?ng
bridges and the proposed water line respec?vely.

NCDWR 2: Explana?on of why the water line cannot be installed by methods that would not require disturbance to the
stream (bore/drill).

Applicant Response: The line is proposed to be open/cut backfill based upon the presence of bedrock in geotechnical
borings and visual observa?ons.

NCDWR 3: Not withstanding the answers to the ques?ons 1 and 2 above, please review the stream impact length shown
and confirm that the length provided is in the direc?on of flow, it appears that the stream impact length may be
reported as the width of the channel.

Applicant Response: Please find a?ached updated PCN, impact drawings for water line and stream impact table with
accurate proposed impact quan??es. There were no other changes to proposed impacts or the remainder of previously
provided permit applica?on.

NCDWR 4: Not withstanding the answers to the ques?ons 1 and 2 above, the Division has significant concerns regarding
open cut installa?on methods in large stream systems. It is staff’s experience that open cut installa?on 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 construc?on details, including proposed dewatering methodology, expecta?on
of encountering rock and methodology for removal of rock, expected construc?on ?meline, and addi?onal measures
proposed to ensure water quality protec?on during construc?on.

Applicant Response: See a?ached detailed 1 and construc?on sequence. The water lines will be installed in phases
across the streams by using temporary stream diversions and pumps that dewater to s?lling bags. Rock that is
encountered in the stream bed will be removed with excavator/air hammer. Blas?ng is not proposed. Is an?cipated
that crossings will be installed within weeks of beginning construc?on. During proposed construc?on, in-stream
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installa?on ac?vi?es, including temporary diversions, will not be installed when forecasted rain or high flow rain events
may occur.

NCDWR 5: Not withstanding the answers to the ques?ons 1 and 2 above, it is the Division’s experience that erosion
control programs and/or u?lity maintenance requirements will not approve vegeta?ve restora?on of disturbed channels
of this size. Please review the proposed stream restora?on detail and ensure that it will meet other
requirements. Please revise restora?on details as necessary.

Applicant Response: See a?ached detail 2. The applicant will stabilize temporarily disturbed stream banks above the
ordinary high water mark with rip-rap in the area of the permanent maintenance easement.

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: Monday, December 4, 2023 8:30 AM
To: Brad Luckey <[e-mail]>; Hopper, Christopher D CIV USARMY CESAW (USA)
<[e-mail]>
Cc: Jeff White <[e-mail]>; Munzer, Olivia <[e-mail]>
Subject: RE: \[External\] RE: Request for Additional Information for McConnell Rd-McConnell Ridge Residential
Development - Guilford County - DWR# 20231170

Brad,

Thank you for the response to the previous ques?ons. Upon review of the updated informa?on, I again require
addi?onal informa?on on the items noted below. Please submit a complete response within 30 days of receipt of this
applica?on. Please note that the applica?on will be considered “on hold” un?l submi?al of a complete response.

With regards to the two added water line crossings please provide:
1. Explana?on of why the water line cannot be installed within the roadway shoulder at the stream crossings as
shown in areas adjacent to the stream crossings.
2. Explana?on 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 ques?ons 1 and 2 above, please review the stream impact length shown
and confirm that the length provided is in the direc?on 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 ques?ons 1 and 2 above, the Division has significant concerns regarding
open cut installa?on methods in large stream systems. It is staff’s experience that open cut installa?on 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 construc?on details, including proposed dewatering
methodology, expecta?on of encountering rock and methodology for removal of rock, expected construc?on
?meline, and addi?onal measures proposed to ensure water quality protec?on during construc?on.
5. Not withstanding the answers to the ques?ons 1 and 2 above, it is the Division’s experience that erosion control
programs and/or u?lity maintenance requirements will not approve vegeta?ve restora?on of disturbed channels
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of this size. Please review the proposed stream restora?on detail and ensure that it will meet other
requirements. Please revise restora?on 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 A?ernoon Sue and Chris,

Please find a?ached updated PCN and responses to informa?on below. Please note that 2 water line crossings (1 of
Li?le Alamance Creek and 1 of Beaver Creek) have been delineated by Pilot and incorporated into the PCN. Addi?onally,
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 a?er Civil design that the proposed widening within this area would not
result in addi?onal 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 jurisdic?onal
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 jurisdic?onal features shown. The Division understands that future development areas are
conceptual in nature.

Applicant Response: Please see a?ached Overall Drawing (Evans Sheet 1 of 9) in updated PCN. There are no future
an?cipated impacts to waters outside of this applica?on.

NCDWR 2: Please provide a stream restora?on detail for the areas of temporary stream disturbance for open cut sewer
line installa?on.

Applicant Response: Please see a?ached restora?on details for the proposed restora?on of temporary disturbance from
the sewer lines (Evans Sheet 9 of 9) and water lines (Ganne? Fleming Sheets 2/3 of 3).

NCDWR 3: Pursuant to 15A NCAC 02H.0506(b) “a 401 Water Quality Cer?fica?on may only be issued upon determining
that the proposed ac?vity will comply with state water quality standards which includes designated uses, numeric
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criteria, narra?ve criteria and the state’s an?degrada?on policy, as defined in rules of 15A NCAC 02B .0200… In assessing
whether the proposed ac?vity will comply with water quality standards, the Division shall evaluate if the proposed
ac?vity: (2) would cause or contribute to a viola?on of water quality standards; (3) would result in secondary or
cumula?ve impacts that cause or contribute to, or will cause or contribute to, a viola?on of water quality
standards. Based on the current proposed plan the Division believes there is poten?al 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 mi?ga?on as appropriate, provide hydrologic
calcula?ons to document that surface flow will con?nue to support the exis?ng func?on of the stream, or provide a
monitoring plan that will document exis?ng condi?ons and post construc?on condi?ons stream DSA.

Applicant Response: The applicant has designed the site to return approximately 30% of the pre-construc?on drainage
area to the unimpacted origin of Stream SC following construc?on. Ini?al designs were approximately 10-15% of the
pre-construc?on 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 construc?on 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 con?nue to provide hydra?on from groundwater recharge to the unimpacted origin of Stream
SC. Based on the amount of post construc?on drainage area and lack of all of removed drainage area being from
impervious surfaces, it is our opinion that Stream SC will con?nue to func?on as an intermi?ent 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: [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
addi?onal informa?on on the items noted below. Please submit a complete response within 30 days of receipt of this
applica?on. Please note that the applica?on will be considered “on hold” un?l submi?al of a complete response.

1. The plan sheet labeled Overall McConnell Ridge Stream Impacts does not appear to include all jurisdic?onal
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 jurisdic?onal features shown. The Division understands that future
development areas are conceptual in nature.
2. Please provide a stream restora?on detail for the areas of temporary stream disturbance for open cut sewer line
installa?on.
3. Pursuant to 15A NCAC 02H.0506(b) “a 401 Water Quality Cer?fica?on may only be issued upon determining that
the proposed ac?vity will comply with state water quality standards which includes designated uses, numeric
criteria, narra?ve criteria and the state’s an?degrada?on policy, as defined in rules of 15A NCAC 02B .0200… In
4

assessing whether the proposed ac?vity will comply with water quality standards, the Division shall evaluate if
the proposed ac?vity: (2) would cause or contribute to a viola?on of water quality standards; (3) would result in
secondary or cumula?ve impacts that cause or contribute to, or will cause or contribute to, a viola?on of water
quality standards. Based on the current proposed plan the Division believes there is poten?al 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
mi?ga?on as appropriate, provide hydrologic calcula?ons to document that surface flow will con?nue to
support the exis?ng func?on of the stream, or provide a monitoring plan that will document exis?ng condi?ons
and post construc?on condi?ons 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.
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