20150620 Ver 1_More Info Received_20160204

CAROLINA WETLAND SERVICES, INC.
550 E. Westinghouse Blvd.
Charlotte, NC 28273
704-527-1177 (office)
704-527-1133 (fax)
February 3, 2016
Mr. Alan Johnson
Senior Environmental Specialist
401 & Buffer Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
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Subject: Response to Request for Additional Information (DWR # 15-0620)
UNC Charlotte Davis Lake
Charlotte, North Carolina
CWS Project No. 2015-3551
Dear Mr. Johnson:
The UNC Charlotte Davis Lake Site is approximately eight acres in extent and is located immediately
south of University Road on the University of North Carolina — Charlotte (UNC Charlotte) campus.
The purpose of this project includes retrofitting an existing pond into a stormwater control measure
(SCM) facility to treat runoff from on-site impervious areas. On behalf of UNC Charlotte, Dewberry
has subcontracted Carolina Wetland Services, Inc. (CWS) to provide Section 404/401 permitting
services for this project. This letter is in response to your letter, dated January 12, 2016, requesting a
response to comments made by your office, the North Carolina Division of Water Resources
(NCDWR). A copy of your letter is attached for your reference.
1. Please provide more details regarding avoidance and minimization of stream and
wetland impacts for this project. [15A NCAC 02H .0506(0 and (g)]. This Office believes
that the plan for retrofitting the pond into a storm water bmp can be reconfigured to
avoid and minimize the impacts to the stream and wetland. Please revise the plans to
avoid and minimize the impacts or provide a detailed explanation of why this plan for
the activity cannot be practically accomplished, reduced or configured to avoid or better
minimize disturbance to the stream and wetland.
There are no practicable alternatives, other than the proposed design, that would meet all the
project goals. On behalf of UNC Charlotte, Dewberry has conducted a feasibility study,
concluding that other options would be cost prohibitive.
The City of Charlotte currently charges fees to property owners, including UNC Charlotte, to
manage their stormwater. The City offers storm water fee credits to owners that construct their
own stormwater control measures (SCMs). Preliminary analysis indicates it is feasible for
UNC Charlotte to obtain a 100% stormwater fee credit by converting Davis Lake into a
stormwater control measure.
Alternatives included an option of making minor modifications to the existing outlet structure
with no grading of the pond that would result in less than a 100% stormwater fee credit,
resulting in future fees. In addition, this alternative assumes that the future development of the
Phase XIV Residence Hall would need to incorporate stormwater treatment within its project
NORTH CAROLINA ' SOUTH CAROLINA
WWW.CWS-INC.NET

UNC Charlotte Davis Lake t February 3, 2016
Response to Request for Additional Information CWS Project No. 2015-3551
footprint to address the Post -Construction Stormwater Ordinance[ (PCCO) requirements. The
conversion of Davis Lake to a SCM would meet Phase XIV Residence Hall stormwater
treatment requirements and would not necessitate additional stormwater measures.
Dewberry Engineers Inc. researched the possibility of utilizing the existing wetland as the
forebay for water quality treatment in lieu of the traditional open water forebay design.
However, due to the necessary depth requirements, the existing wetland is not deep enough,
shaped appropriately, or large enough to be utilized as a forebay. Therefore, this alternative
was determined to not be practicable as the goal of the retrofit is to provide adequate water
quality treatment. Leaving the wetland in-situ as a forebay would reduce the water quality
treatment functionality of the design and would facilitate increased inputs to the main pond.
The proposed forebay is designed to capture and settle out sediments prior to entering the main
pond and is sized according to the capacity required of the proposed retrofit
Impacts to on-site jurisdictional waters of the U.S. have been reduced to the maximum extent
practicable. Proper sediment and erosion control measures will be applied to minimize
disturbances to downstream waters. No impact to downstream waters is proposed an the
excavation for the stormwater management pond construction will be completed with
equipment operating from upland areas. Removed sediments will be hauled off site. All
disturbed areas will be seeded and matted with natural fiber matting.
CWS believes the proposed design represents the least damaging environmental alternative
while still meeting the goals of the project. The proposed impacts are designed to improve
storm water management and water quality treatment of stormwater runoff.
Thank for you your consideration in this matter. Please do not hesitate to contact us at 704-408-1683,
or through email at [e-mail] should you have any additional questions or comments
regarding this letter.
Sincerely,
Zra- C - 7 �_
Gregg Antemann, PWS
Principal Scientist
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Attachments: Additional Information Request Letter
Kelly amen, WPIT,
Project Manager
' Charlotte Post Construction Stormwater Ordinance,
http.//charmeck org/stormwater/regulations/Documents/PCCO%20Documents/CPCS02014 pdf
2

Water Resources
ENVIRONMENTAL QUALITY
January 12, 2016
UNC Charlotte
Attn: Mr. Philip M. Jones
9201 University City Boulevard
Charlotte, NC 28223
Subject: REQUEST FOR ADDITIONAL INFORMATION
UNC Charlotte Davis Lake Site
Dear Mr. Jones:
PAT MCCRORY
Got -enter
DONALD R. VAN DER VAART
Secrelao
S. JAY ZIMMERMAN
Director
DWR # 15-0620
Mecklenburg County
On June 19, 2015, the Division of Water Resources (Division) received your application dated
June 18, 2015, requesting an Individual Water Quality Certification from the Division for the
subject project. A revised application dated November 12. 2015 was received on November 12,
2015. The Division has determined that your application is incomplete and cannot be processed.
The application Is on -hold until all of the following information is received:
Please provide more details regarding avoidance and minimization of stream and wetland
impacts for this project. [15A NCAC 02H .0506(f) and (g)j
• This Office believes that the plan for retrofitting the pond into a stormwater bmp can
be reconfigured to avoid and minimize the impacts to the stream and wetland. Please
revise the plans to avoid and minimize the impacts or provide a detailed explanation
of why this plan for the activity cannot be practically accomplished, reduced or
reconfigured to avoid or better minimize disturbance to the stream and wetland.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. If all of the requested information is
not received in writing within 30 calendar days of receipt of this letter, the Division will be unable
to approve the application and it will be returned. The return of this project will necessitate
reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please respond in writing within 30 calendar days of receipt of this letter by sending three copies
of all of the above requested information to the 401 & Buffer Permitting Branch, 1617 Mail
Service Center, Raleigh, NC 27699-1617.
State of North Carolina I Environmental Quality IWater Resources
1617 Mail service Center I Raleigh. North Carolina 27699-1617
919 807 6300

UNC Charlotte
DWR# 15-0620
Request for Additional Information
Page 2 of 2
Please be aware that you have no authorization under the Section 401 of the Clean Water Act
for this activity and any work done within waters of the state may be a violation of North
Carolina General Statutes and Administrative Code.
Please contact Alan Johnson at 704-235-2200 or [e-mail] or Jennifer Burdette
at 919-807-6364 or [e-mail] if you have any questions or concerns.
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Gregg Antemann, Carolina Wetland Services, Inc., 550 East Westinghouse Blvd.,
Charlotte, NC 28273
USACE Asheville Regulatory Field Office
DWR MRO 401 file
DWR 401 & Buffer Permitting Branch
I'llename: 150620UNCCDavisLakeSite( Mecklenburg)_401_IC_Hold.docx
I