20060711 Ver 1_Email_20160928

Strickland, Bev
From:Burdette, Jennifer a
Sent:Wednesday, September 28, 2016 11:13 AM
To:Randy Miller
Subject:RE: Stream Crossing - Holly Pointe
Randy,

The General Certification that would apply to a NWP 29 for this project requires written approval when
activities meet any one of the thresholds or circumstances listed at the beginning of the GC. It is correct that
the previous temporary impact from the sanitary sewer does not count towards the mitigation threshold that
applies to the proposed permanent impact from road crossing. However, the temporary impact combined with
the proposed permanent impact does apply the threshold for written approval of the GC listed below.

b. Total stream impacts within the project boundaries equal to or greater than 150 linear feet of stream, including
temporary and/or permanent impacts; or

Another circumstance that requires written approval relates to a stormwater plan requirement for high density
projects. When discussing the project previously, I don’t think that I made the appropriate distinction that
“subject to” referred to a stormwater plan as opposed to within the jurisdiction of a certified community’s
stormwater program. Because the project was grandfathered from requirement to have a stormwater
management plan by the Town of Holly Springs is not subject to a certified community’s stormwater program. I
apologize for the delay in my clarification.

d. Any impact associated with a high density project (as defined in Item (A)(iv) of the 401 Stormwater Requirements) that
is not subject to either a state stormwater program (such as, but not limited to, Coastal Counties, HQW, ORW or
state-implemented Phase II NPDES) or a certified community’s stormwater program;

Therefore, the project requires written approval of the 401 WQC due to the proposed road crossing that will
impact the stream.

I understand from my conversation with Chris Allen yesterday that the project also involves a curb and gutter
stormwater system. For a project to qualify as a low density project, it must transport stormwater through
vegetated conveyances and propose less than 24 % impervious area. Therefore, a stormwater management
plan approved by the Division will be required before the GC can be issued since Holly Springs will not be
requiring or reviewing a SW plan. Utilization of bridge or arch culvert that would avoid impact to the stream
channel would not require application for a 401 WQC that triggers the need for a SW management plan. You
may also want consult with Storm-EZ tool for additional flexibility in stormwater treatment at the following link.

http://deq.nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permit-
guidance/stormwater-lid-storm-ez

Thanks,
Jennifer

Jennifer Burdette
401/Buffer Coordinator
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Division of Water Resources - 401 & Buffer Permitting Branch

Department of Environmental Quality
919 807 6364 office
[e-mail]

1617 Mail Service Center
Raleigh, NC 27699-1617
th
(Physical Address: 512 N. Salisbury St, Raleigh, NC 27604 - 9 Flr Archdale Bldg – Room 942F)

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Randy Miller \[mailto:[e-mail]\]
Sent: Wednesday, September 21, 2016 4:37 PM
To: Burdette, Jennifer a <[e-mail]>
Subject: Stream Crossing - Holly Pointe

Jennifer:
As previously discussed, please see courtesy copy of the PCN for the proposed stream crossing associated with Holly

Pointe 2C in Holly Springs.

The Town of Holly Springs has raised concerns, that during the construction of Holly Pointe Phase 1 back in 2005, some
temporary impacts might have occured with the placement of a main 8" sanitary sewer outfall line. A temporary impact
map was completed at that time and submitted. Through discussions with Bob Zarecki at Sand EC, it was my
understanding that these possible temporary impacts for sanitary sewer installation where not subject to be included with

the proposed stream crossing for the new road and culvert. Could you please clarify.

Also, the Town Holly Springs has concerns that a permit maybe required for the roadway crossing and culvert placement
because the Town approved the development plan and did not requiring a stormwater plan for the development. Could

you also please be clarified.

Thank you,

Randall L. Miller, PE
Thompson and Associates, PA
1149 Executive Circle
Suite D-2
Cary, NC 27511
919-465-1566 office
919-465-1585 fax
919-669-5324 cell

[e-mail]

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