20071668 Ver 1_More Info Received_20080205

noch
ngineers,P.A,
Joe E. Godwin Sr., P.E., P.L.S.
Jce E. Godwin Jr., P.E., P.L.S.
Kevin R Allen, P.E.
Jason E. Godwin, A.P.S.S.
January 31, 2008
Consulting Engineers & Surveyors
1403 NC Highway 50 South
Benson, North Carolina 27504
Q~~~od~p
FEB 5 2008
Phone: [phone]
[phone]
Fax: [phone]
Website: www.enochengineers.com
Email: enochengineersQearthlink.net
US Army Corps of Engineers NC Div'=ion of Water Quality
Wilmington Regulatory Field Offic '~~ 2321 Crabtree; Boulevard
P.O. Bog 1890 ~~~~ Suite 250
Wilmington, North Carolina 28402-1890 Raleigh, North Carolina 27604
Atm: Ronnie Smith
Attn: Ian McMillan
Reference: PRACTICABLE ALTERNATIVES ANALYSIS:
AVOIDANCE, MINIMIZATION & COMPENSATION
Action ID No. SAW-2007-00902-043
Lexington Plantation (UT to Reedys Swamp and UT to Rice Patch Branch)
Anderson Creek Township, NC Highway 87
Spout Springs, Harnett County, North Carolina
Enoch Engineers Project No. 3059
On the behalf of notable owner, Mr. Jimmy Pierce, please find the additional information requested January
14, 2008 for the project referenced above. The information provided is in response to the Memorandum of
Agreement (MOA) signed by the US Environmental Protection Agency (EPA) and the Department of the
Army (DA) February 6~ 1990 pertaining to this development's determination of type and level of
compensatory mitigation necessary to comply with the Clean Water Act (CWA) Section 404(b)(1) Guidelines.
Below is a list of requisite project facts related to the permitting process:
PROTECT SUMMARY
Project Name/Description Lexington Plantation/Single, Multi-family
residential
Project Type/Permit Type Residential development/Standard
Individual Permit
Owners A hcant
/ PP Pierce Development, LLC/Jimmy Pierce
Villa e of Lexin on, LLC/ imm Pierce
Cozen Harnett
Nearest Town S out S rin near Cameron
Name of nearest Waterbody (Index No.) Reedys Swamp (18-23-29-2)
Rice Patch Branch 18-23-29-3
NC River Basin Ca e Fear
USGS Basin/HUCODE-8 U er Ca e Fear/03030004
Current Class C
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IMPACT SUMMARY
Stream Im act feet 606
Wetland Im act acres 1.396
O en Water Im act acres 0
Total Im act to Waters of the United States acres 1.396
Total Stream Im act feet 606
Total Tem or Wetland Im act acres 0.561
Total Permanent Wetland Im act acres 0.835
Total Tem o Stream Im act feet 160
Total Permanent Stream Im act feet 446
Total Non-Ri arian Wetland Im act acres 0.507
Total Ri atian Wetland Im act acres 0.889
The MOA described above initially administers avoiding impacts to waters and wetlands through selecting
practicable alternatives; secondly, taking practical actions to reduce impacts on waters and wetlands; and
finally, dete+'++~;ning compensatory mitigation for remaining unavoidable impacts to the most appropriate and
practical extent. Listed below is an outline of additional information requested in quotation with an equivocal
alternatives analysis and/or justification provided in response to encouragingly, complying with the MOA of
February 6~ 1990:
1) "Permits for work within wetlands or other special aquatic sites are available onlq if the proposed work is
the least environmentally damaging, practicable alternative. Please furnish information regarding any
othex alternatives, including upland alternatives, to the work for which you have applied and provide
justification that pour selected plan is the least damaging to water or wetland areas."
a) The sewer utilities for the project are temporary impacts and involve a combination of gravity feed
lines and (1) or more lift stations for sewer displacement Traditionally, sewer utilities ate designed to
receive sewage from higher elevations and transport it through a series of pipes utilizing the down
gradient aspect of the topography. This may resultantly lead to lower lying areas including wetlands
as a means of placement for beneficial use. Sewer utility access is limited to adjacent land which is
unique to impact No.'s 9, 17, 18 and 19.
b) Additionally, directional drilling alternatives for sewer utilities was explored but due to the substrate
materials and topography of the landscape positions in most areas, it is limited as to its practicability
and quality of placement Directional drilling alternatives have been implemented in some areas of
the development The temporary sewer line impacts are the least environmentally damaging
alternative with consideration to location and quality of work done in waters or wetland areas.
c) The wetland crossings by road and culvert for the project are permanent impacts and involve several
sizes of culverts designed to withstand particular storm events with consideration to drainage areas of
the local development. The main objective is to avoid and minimize water and wetland impacts by
these proposed crossings. More particularly, impacts No.'s 10 and 11 are essential to this
development for that the proposed road is an arterial entry to the total project and based on zoning
requirements and minimal lot depths influenced the road's alignment and location. In order to attain
the minimum lot depths required by Harnett County zoning, the proposed arterial split-lane median
was designed for avoidance of further larger impacts of the wetland features. The same concept
applies to impact No. 9 including lot depth requirements.
d) Wetland impacts No.'s 17, 18, and 19 may seem substantial over a small amount of land, but prove
to be a necessity as a result of the location of the upland features (ridges) and the access restriction
from adjacent locations other than the proposed impacts. Thus, these impacts are needed to access
the valuable land on landscape features such as nose slopes, linear ridges, and side slopes in and
between the waters and wetlands present onsite at these locations.
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2) "It is necessary for you to have taken all appropriate and practicable steps to m?nir+~ize wetland losses.
Please indicate all that you have done, especially regarding development and modification of plans and
proposed construction techniques, to minimize adverse impacts."
a) Care will be dedicated to the placement of sewer utilities within the waters and wetlands. Incidental
fall back may be discussed with contractors of the work to minimize its impacts to waters and
wetlands.
b) The permanent wetland crossings by road and culvert have been minimized were practicable using
minimum road width standards, where capable, and lessoning the environmental damage to each
wetland feature. In addition, all culverts have been designed where there is a significant amount of
slope per foot of culvert for passage of aquatic life and continuance of aquatic life cycles.
3) "The MOA requires that appropriate and practicable mitigation will be required for all unavoidable
adverse impacts remaining after all appropriate and practicable minimization has been employed. Please
indicate pour plan to mitigate for the projected, unavoidable loss of waters or wetlands or provide
information as to the absence of any such appropriate and practicable measures."
a) In order to mitigate for the project's unavoidable adverse impacts to waters and wetlands, the owner,
applicant, intends to make payment into the North Carolina Ecosystem Enhancement Program
(NCEEP). The amount to be paid to NCEEP in form of an In-Lieu Fee will be based on a 2:1 ratio
for linear feet and acres of water and wetland impacts, respectively.
b) A notably unique aspect of this local development is the Reedys Swamp Longleaf Forest, a
Significant Natural Heritage of Harnett County. In the future, preservation and conservation of
wetlands and riparian areas may be used as a tool for compensation for waters and wetland loss.
Enoch Engineers appreciates your consideration of this project. Should you have any questions or comments
about this project please contact Jason Godwin at [phone], extension 241.
Respectfully,
Enoch Engineers, PA
Jason Godwin
Project Managex/Natural Resources
cc: jimmy Pierce
Chad T"rl±n~ on
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