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HomeMy WebLinkAbout20240435 Ver 1_20240435 Ver 1_Calebs Creek Add Info Response_20241022TO: Sue Homewood, NCDEQ Krysta Stygar — USACE FROM: Jeff Harbour — Terracon Charles Pearman - SEH Kenton Brose, PE — SEH CC: BOMA North Carolina, LLC Turner Perrow Jr. PE — SEH Samantha Dailey — USACE DATE: October 22, 2024 RE: RE: Request for Additional Information Caleb's Creek Subdivision NCDWR: 20240435 USACE ID: SAW-2015-01697 The Division previously requested additional information for the purpose of Impact T34 shown on Exhibit 5. The response submitted on September 20, 2024, indicates that impact T34 is "caused by the fill associated with the roadway crossing, not general development fill". Please further clarify this statement since what appears to be the roadway fill line (highlighted in image below) (Image not included in response draft) on Exhibit 5 only represents a small portion of the Impact T34. The line referenced by the Division is an easement line for dry utilities not a roadway fill line. Exhibit 5 has been updated to show proposed contours associated with the crossing. The impact to T34 has been reduced in this submittal from 100 LF to 47 LF but does extend beyond the Right -of -Way due to grading to install culverts and achieve required roadway elevation. Exhibit 5 and the table on Exhibit 3C have been updated to reflect the smaller impact. IMPORTANT NOTE: STREAM IMPACT T34 HAS BEEN REDUCED FROM 100 LF TO 47 LF 2. The Division previously requested information regarding the purpose of Impact W4. The response submitted on September 20, 2024, indicates that impact W4 is "necessary for a crossing required to access PA-106 and is required by Town ordinance." This statement is insufficient to justify the impacts to the wetlands. Pursuant to 15A NCAC 02H .01305(b) "In assessing whether the proposed activity will comply with water quality standards, the Division shall evaluate if the proposed activity: (1) has avoided and minimized impacts to surface water and wetlands....". If the locations or widths of roads are dictated by local government requirements or transportation plans, then the avoidance and minimization analysis must be based on traffic analysis or planned roadway infrastructure layouts. DWR understands that many local governments require developers to design and construct roadways identified on the transportation plans, however DWR will evaluate the justifications for location and widths of these roads as if they were being proposed/designed by the local government. A statement that the location or design is required by the local government will not be considered a sufficient avoidance and minimization justification. Engineers I Architects I Planners I Scientists ShortElliott Hendrickson Inc., 400 Locust Avenue, Suite 2, Charlottesville, VA 22902-4858 434.202.3780 888.908.8166 fax I sehinc.com SEH is 100%employee-owned Affirmative Action —Equal Opportunity Employer Memorandum October 22, 2024 Page 2 The location of the crossing was determined based on the narrowest portion of the wetlands W43. Width of the crossing was determined by the minimum allowed roadway permitted by the Town. These decisions were made to minimize the impacts to the wetlands in that area. Exhibit 3M and 3N have been updated to show the crossing in a location that will have the least amount of impact. The temporary impact occurring at this location has been reduced from 0.55 ac to 0.22 acre by shifting to a narrower wetland crossing location. IMPORTANT NOTE: IMPACT W4 (TEMP) HAS BEEN REDUCED FROM 0.55 AC TO 0.22 AC The Division previously requested information regarding the possible indirect impacts to features that have the potential to cause a violation of water quality standards. The response submitted on September 20, 2024, indicates that an SCM will be located adjacent to features T10 and W12 that will provide hydrology to these features to prevent indirect impacts. It is unclear that the topography within this location will allow for discharge from the SCM to the top of feature T10. Please clarify this by showing the proposed location of the outlet of the SCM based on planned elevations within the area. If the outlet of the SCM will is not proposed at the top of feature T10, please include the area above the outlet as indirect impacts on update impact tables/maps and adjust the proposed mitigation amounts accordingly. L-Anibit 3F uUU1I UPUQIGU LU J1 IUVV UANDLII ly ILours and proposed stormwater management layout. The proposed stormwater SCM can be constructed at an elevation that will allow discharge to the most upstream end of T10 as shown in the exhibit. The revisions noted in this submittal resulted in a reduction of stream impact by 53 linear feet and temporary wetland impact by .33 acre at Wetland Impact W4 location Calebs Creek Impacts (October 22, 2024) • 895 linear feet of stream loss 0 695 LF of perennial / high intermittent 2:1 mitigation proposed (1,390 LF) 0 40 LF of medium intermittent 1.5:1 mitigation proposed (105 LF) 0 160 LF of low intermittent 1:1 mitigation proposed • 0.49 acre of wetland fill @ 2:1 ratio = 0.98 acre of mitigation • 0.65 acre of conversion @ 1:1 ratio = 0.65 acre of mitigation Attachments: Exhibit 3C Impact Exhibit Exhibit 3F Impact Exhibit Exhibit 3N Impact Exhibit Exhibit 3M Impact Exhibit Exhibit 5 - Utility Crossing (U-2 - Phase 1) � ,s r T6 W5) FUTURE STORMWATER BMP W6 I \ - IMPACT W1: 0.13 AC T8 3C i IMPACT T34: 47 LF, 705 SF r SEE CROSSING EXHIBIT 5 IMPACT T34A: 60 LF, 300 SF W7 SEE CROSSING EXHIBIT 5 T34 ' W8 FUTURE STORMWATER BMP > ` IMPACT W2: 0.06 AC SEE CROSSING EXHIBIT 5 \� ) T33 \ IMPACT W3: 0.11 AC SEE CROSSING EXHIBIT 6 T35 IMPACT T4 40 LF 280 SF I P1 SEE CROSSING EXHIBIT 6 SURFACE WATER IMPACT: 0.17 AC SEE CROSSING EXHIBIT 6 �Z�-*'�// T36 L- GRID BOUNDARY - - - 100 YEAR FLOOD PLAIN _ SURFACE WATER _ IMPACTED SURFACE WATER WETLANDS IMPACTED WETLANDS IMPACTED STREAMS STREAM P1 � I mrmm"w T N 200 0 200 400 scale 100 feet AREA 3C IMPACTS STREAM WETLAND IMPACTED STREAM OR WETLAND NAME IMPACT NAME LENGTH (LF) AREA (SF) AREA (ACRES) PHASE W6 W1 N/A N/A 0.13 1 W8 W2 N/A N/A 0.06 1 W5 W3 N/A N/A 0.11 1 T8 T4 40 280 N/A 1 T34 T34 47 705 N/A 1 T34 T34A 60 300 N/A 1 TOTAL 147 1,285 0.30 CALEB'S CREEK DATE: WETLANDS & STREAMS SEW 10/15/2024 ROAD IMPACT DETAILS L"N"N'"", KERNERSVILLE, FORSYTH COUNTY, NC N IMPACT • EXHIBIT 3 C 200 0 200 400 scale 100 feet A 7 1 -4 ^ C GRID BOUNDARY - - - 100 YEAR FLOOD PLAIN _ SURFACE WATER WETLANDS IMPACTED WETLANDS IMPACTED STREAMS STREAM DATE: A SEH 10/15/2024 •1' f T25 W41' r*1 W47 r - s j T14� r . ' W47 Ir • W52 00 .... ... .... ....... ... - T14 : : :Y - ------------- ----------- ----........ ............ - .... --- TEMPORARY IMPACT FOR PYLON BRIDGE CONSTRUCTION - ........... -.• ...•..•.....•..• 34' IMPACT W4: 0.22 AC :: ■ EXISTING UTILITY EASEMENT ........................ W43 ... ...... . W48.. . .......................... . . . . ir T25 AREA 3M IMPACTS STREAM WETLAND IMPACTED STREAM OR WETLAND NAME IMPACT NAME LENGTH (LF) AREA (SF) AREA (ACRES) PHASE W43 W4 N/A N/A 0.22 2 TOTAL 0.22 CALEB'S CREEK WETLANDS & STREAMS ROAD IMPACT DETAILS KERNERSVILLE, FORSYTH COUNTY, NC N IMPACT EXHIBIT 3 M 200 0 200 400 scale 100 feet .... I T22 W42 �- -_- W43� T25 W46 W41 L................ .. 7 ................ W44 W45) : 1� r \ - W47� ......... /� .. :.':.'..'..'..' l ::. :::::::::. . �® T38 EXISTING UTILITY EASEMENT ------------ t i - % T39D 1 ................... 1 �\ .. \` ......................... ......................... �:: W43 W49 T43 � - - ........ T41 .-.r ... ....... :: �..'..'..'..'..'...'..':.'::: . .'•• •:• / ' TOR o C GRID BOUNDARY - - - 100 YEAR FLOOD PLAIN _ SURFACE WATER WETLANDS IMPACTED WETLANDS IMPACTED STREAMS STREAM CALEB'S CREEK DATE: WETLANDS & STREAMS iEHof 10/15/2024 ROAD IMPACT DETAILS -NIC.z z KERNERSVILLE, FORSYTH COUNTY, NC T42 IMPACT EXHIBIT 3N N 200 0 200 400 scale 100 feet