SW6231203_Response To Comments_20240813

^PA
Booth & Associates
August 9, 2024
VIA ONLINE LINK& HAND DELIVERY
Jacob Beeker
Stormwater Permitting Engineer
DEMLR Post-Construction Stormwater Program
512 N. Salisbury Street, Office 640E
Raleigh, NC 27604
Phone: [phone]
Email: [e-mail]
Subject: Response to NCDEQ Comments Dated August 2, 2024
Stormwater Project No. SW6231203
Gillespie - B1.9 Solar Utility Station
Cumberland County
Dear Mr. Beeker:
Please find below a point-by-point response to your comments dated August 2, 2024, concerning
Gillespie - B1.9 Solar Utility Station (Stormwater Project No. SW6231203). Please find our
responses below in blue.
1. With regard to the presence of surface waters, per 15A NCAC 02H .1017(10), "Vegetated
setbacks from perennial waterbodies, perennial streams, and intermittent streams shall be
required in accordance with Rule .1003 of this Section and shall be at least 30 feet in
width. Vegetated setbacks from such waters shall be required if the water is shown on
either the most recent version of the soil survey map prepared by the Natural Resources
Conservation Service of the United States Department of Agriculture ... or the most recent
version of the 1:24,000 scale (7.5 minute) quadrangle topographic maps prepared by the
United States Geologic Survey (USGS)."
We use the USGS topographic map to determine if there are surface waters present on-
site. We understand that these maps may not accurately reflect existing site conditions for
all sites which is why relief from the surface water requirements can be allowed when
surface waters are not present in accordance with 15A NCAC 02B .0714(3)(a). The process
for obtaining such relief is outlined in section .0714(4):
When a landowner or other affected party believes that the maps listed in Sub-
Item (3)(a) of this Rule have inaccurately depicted surface waters or the
specific origination point of a stream, or the specific origination point of a
stream is in question or unclear, he or she shall request the Authority to make
an on-site determination. On-site determinations shall be made by Authority
staff that are certified pursuant to G.S. 143-214.25A... On-site determinations
shall expire five years from the date of the determination. Any disputes over
on-site determinations shall be referred to the Director in writing within 60
calendar days of written notification from the Authority. The Director's
determination is subject to review as provided in G.S. 150B.
2300 Rexwoods Drive, Ste. 300 919.851.8770 office
Raleigh, NC 27607 919.859.5918 facsimile
www.booth-assoc.com

Jacob Beeker
August 9, 2024
Page 2
Barring this on-site determination, it is assumed that this surface water is present and
must be accounted for. Please either contact staff from the Fayetteville Regional Office to
make a determination with regard to this surface water or account for this surface water by
showing this surface water on the plans, excluding the surface area from the project area,
and including any necessary vegetated setbacks from said surface water.
It is noted that the surface area of the wetlands shown on the plans is accounted for in the
surface water calculations. That is allowed, if desired, but the surface area of the surface
water in question will still need to be accounted for in the surface water calculations, as
well as being shown on provided plan sheets in addition to providing required vegetated
setbacks in accordance with 15A NCAC 02H .1042(2)(g)(iii), assuming there is no on-site
determination otherwise.
The USGS 7.5-Minute Quadrangle Topographic Map for the site does depict another aquatic
feature that is not captured in the wetland delineation for the site nor in our drawings.
However, while this aquatic feature appears at first glance to be another surface water,
using the layer management tools in the USGS Map, it was determined the aquatic feature
is actually a "Freshwater Emergent Wetland" (which are depicted as blue and not green like
"Freshwater Forested/Shrub Wetlands" are depicted) and not a surface water. NCDEQ
agreed with this determination in an email exchange on August 2, 2024. As such, no
additional surface waters need to be accounted for in the drawings or associated
documentation.
Relevant pictures of these findings are shown below.
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Jacob Beaker
August 9, 2024
Page 3
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Jacob Beeker
August 9, 2024
Page 4
Wetland Features
Freshwater Emergent Wetland
—
Freshwater Forested/Shrub Wetland
2. With regard to the provided vegetated setbacks, per 15A NCAC 02H .1003(4)(a), "The
width of a vegetated setback shall be measured horizontally from the normal pool elevation
of impounded structures, from the top of bank of each side of streams or rivers, and from
the mean high waterline of tidal waters, perpendicular to the shoreline;"
The provided vegetated setbacks do not appear to be located in the proper place. Please
ensure that any require vegetated setbacks are provided and shown on the main set of
plans, as well as being measured from the proper location.
NOTE: If additional surface water is present, please ensure that the required vegetated
setbacks are shown for the additional surface water as well. The minimum width of
vegetated setbacks required is 30 feet.
Booth had shown a 50' wide vegetated setback as measured horizontally from the
proposed disturbance limit to show there was at least a 50' distance or greater between the
disturbance limit and the edge of the surface waters/wetlands. However, we realize this is
incorrect and it has now been updated to show an undisturbed 50' wide wetland/stream
buffer as measured horizontally from the surface waters/wetlands per the requirements of
15A NCAC 02H .1003(4)(a).
3. With regard to BUA accounting, "Existing BUA" refers to BUA that was located within the
project area prior to the rules going into effect in this area (July 1, 2007). From historical
satellite imagery, the only BUA that remains from what was constructed prior to the rules
going into effect is the existing gravel drive shown on Sheet CG100 of the provided plan
set. This gravel drive appears to have an area of roughly 11,686 square feet, which is
considerably less than the 27,709 square feet of Existing BUA listed. It also appears that all
other BUA has been accounted for. The remaining roughly 16,000 square feet of Existing
BUA listed could not be found on the plan sheets, nor could it be located in current satellite
imagery. Please revise package as needed to exclude the roughly 16,000 feet of missing
existing BUA if it is not present or direct the reviewer to this existing BUA if it has been
missed.
Understood, this was an error, and the area has now been properly measured and adjusted
accordingly. The correct Existing BUA area is 11,384 square feet and is shown as such on
the updated page of the State Stormwater Permit Application, on the Supplemental EZ
form, and on the drawings. When making this check, we realized the access road ("on-site
streets") square footage was incorrect and we have adjusted it as well on the
aforementioned documentation (was previously 31,831 square feet and is now 33,656
square feet). The associated impervious area total and impervious area percentage have
been updated to reflect these values.
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Jacob Beeker
August 9, 2024
Page 5
4. Please provide a Response to Comments letter indicating, in a point-by-point manner, how
each of the above comments has been addressed. This item is required per 15A NCAC 02H
.1042(3)(b).
Understood, this document will serve as the Response to Comments letter as required per
15A NCAC 02H .1042(3)(b).
5. Provide PDFs of all revisions, 2 hardcopies of revised plan sheets, 1 hardcopy of other
documents, and a response to comments letter briefly describing how the comments have
been addressed.
Understood, PDFs will be uploaded to https://edocs.deq.nc.gov/Forms/SW-Supplemental-
Upload and hard copies will be hand delivered.
If you have any questions, comments, or concerns, please to not hesitate to contact Laura Harris, by
phone at 919-851-8770 or by email at [e-mail].
Sincerely,
BOOTH & ASSOCIATES, LLC
,L--/„.„.
Laura Harris, P.E.
Project Engineer III - Team Lead
LRH/rea
cc:
Project Number: P.0574167.E.TE.8121
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