20081063 Ver 1_More Info Received_20080812

Environmental Consultants, PA
Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
www.SandEC.com
August 12, 2008
S&EC Project # 9239.W3
DWQ No. # 08-1063
Division of Water Quality
Attn: Cyndi Karoly/Ian McMillan/Annette Lucas/Amy Chapman
2321 Crabtree Boulevard
Suite 250
Raleigh, NC 27604
Re: Reply to the Division of Water Quality's 07/11/08 request for additional information
River Towne
Wake County, North Carolina
Dear Ms. Karoly, Mr. McMillan. Ms. Lucas and Ms. Chapman:
2008
?,al
This letter is in response to your letter dated July 11, 2008 which requested additional information for the
proposed River Towne. The following restates your questions/comments and is then followed by our
response.
Additional Information Requested
1. Per the requirements of the Neuse River Riparian Buffer Rule, you must show that
this site meets diffuse flow requirements with a level spreader or other BMP per
Chapter 8 of the BMP Manual (see http://h2o.enr.state.ne.uslsulbmp_forms.htm).
All of the proposed Stormwater Devices for the subject development are stormwater wetlands. Therefore,
per the Neuse River Riparian Buffer Rules "Table of Uses," "New drainage ditches, roadside ditches and
stormwater outfalls provided that a stormwater management facility is installed to control nitrogen and
attenuate flow before the conveyance discharges through the riparian buffer" is an "allowable" activity.
The stormwater wetland meets the criteria of controlling nitrogen as well as attenuating flow prior to the
outfall discharge. As required, we requested a Neuse Buffer Authorization Certificate for the impacts
associated with the stormwater outfalls through the Neuse River Riparian Buffer (see pages 10 through 13
of the original Preconstruction Notification application). We have also included a letter from Mr. Thomas
F. Craven of Priest Craven that details the City of Raleigh Construction Plan Approval process and how it
affects the Stormwater Management Plan (SMP) approval (i.e. City of Raleigh won't approve the SMP
until the applicant has secured both the 404 and 401 Approvals).
2. Please provide narrative discussing adjoining properties in respect to whether "stub
roads" point toward "waters" or buffers.
The original application included both a copy of the NRCS Wake County Soil Survey site vicinity map as
well as a copy of the Knightdale USGS Quadrangle site vicinity map. It can clearly be seen on both maps
that there are streams and/or wetland areas that are off property, however, at this time S&EC cannot
comment on the presence or absence of these features as depicted on the maps as we have no authority to
conduct wetland and stream delineations beyond the proposed project boundaries. Furthermore, per the
attached map provided by Priest Craven & Associates, these "stub roads" at the property lines were
required by the City of Raleigh during the site plan review. The project engineer stated during recent
Charlotte Office:
236 LePhillip Court, Suite C
Concord, NC 28025
Phone: [phone]
Fax: [phone]
Greensboro Office:
3817-E Lawndale Drive
Greensboro, NC 27455
Phone: [phone]
Fax: [phone]
conversations regarding the "stub roads" that "stub road #2 (see attached map), was a condition (i) in the
rezoning case Z-45-06 and enforced during the preliminary site plan review dated 212612008. Stub roads
#7 and #8 were required by the City of Raleigh to serve the 2.5 acre (#7), 4.0 acre (98) as well as #2
serving the 14.0 acre tracts of land south of the large Floodplain associated with Hodges Mill Creek (these
tracts of land are located immediately north of the proposed stub roads). These areas will be challenged to
be served from the north of the floodplain given the topographic and environmental challenges between
them (i.e. crossing the FEMA floodplain, etc.). Road crossings of Hodges Mill Creek and the associated
Floodplain will ultimately be denied, and therefore, to avoid land-locking the parcels (which Raleigh
prohibits) access had to be provided by the adjacent property owner. " There are additional stub roads that
also point "off property" (i.e. #1, #4, #5 and #9) that are also zoning conditions from the preliminary site
plan review (dated 2/15/07) and/or are part of the City of Raleigh's "Thoroughfare Collector Plan" and
therefore, are required to be part of the development. The applicant avoided and minimized stream impacts
on the subject property wherever possible (i.e. streams and associated buffers are at the back of proposed
lots) in an effort to adhere to the requirements of both the 404 and 401 regulations while still meeting the
provisions of the local governing municipality.
3. Please provide documentation from the NCEEP indicating their willingness to
accept your request to purchase buffer credit to mitigate for the proposed buffer
impacts listed in your PCN application per section VIII, No. 2. PCN mitigation for
the buffers does not match NC EEP's acceptance letter. PCN mitigation tables
states Zone 1 = 77,754 square feet, NC EEP letter states 36,279 square feet, and
PCN mitigation table states Zone 2 = 20,140 square feet, NC EEP letter states 8,933
square feet. Please address this discrepancy.
On July 30, 2008, S&EC discussed the above mitigation discrepancy with both Mr. Ian McMillan and Ms.
Amy Chapman. Per previous discussions with Mr. McMillan, proposed Road Crossing #4 (Impact No. 20)
cannot be constructed at this time. As was explained in the original application submittal, this crossing is
being required by the City of Raleigh, even though the applicant's property line is the center line of the
stream. In the original application submittal, we requested that this crossing be denied as the City of
Raleigh will not remove the road requirement from the subdivision approval until and unless the USACE
and the NC DWQ deny the crossing. Therefore, the riparian buffer impact associated with this
"unbuildable" road crossing was not included in the buffer mitigation request submitted to the NC EEP.
This accounts for the discrepancy between the "proposed" buffer impact and what was accepted by the NC
EEP. The amount of buffer mitigation stated both in the application package on page 14, Section X, No. 3
and the NC EEP acceptance letter is the correct amount of buffer mitigation required for the crossings as
proposed for the River Towne project (i.e. 36,279 sq. ft. in Zone 1 and 8,933 sq. ft. in Zone 2). These
buffer mitigation totals exclude Road Crossing #4 (Impact No. 20) as it cannot be built; it did not seem
necessary to request buffer mitigation from the NC EEP for a crossing that could not be approved by either
the USACE or the NC DWQ and therefore, ultimately couldn't be constructed.
4. Please provide correspondence from the City of Raleigh requiring the crossing at
Stream Impact No. 12:
We are assuming that you are actually referring to Stream Impact No. 11 (Road Crossing No. 1) as Impact
No. 12 is a buffer impact only. Impact No. 12 is part of the road widening required by the City of
Raleigh's Comprehensive Plan for Major Thoroughfares which can be accessed through the City of
Raleigh's website (http://www.raleiphnc.goy/portal/server.pt/ ag teway/PTARGS 0 2 108376 0 0 18/CP-
Transportation_ Plan-Text.pdfJ. As with most developments, the municipality requires that the "frontage"
road be widened to provide for additional turn lanes into the proposed development to ease traffic
congestion and safety concerns. .
With respect to Road Crossing No. 1 (Impact No. 11), this crossing connects to Buffaloe Road and serves
as a second entrance. This crossing is required based upon several factors including the zoning condition
(g) in Z-45-06 requiring 2 entrances, NC DOT requiring maximum driveway separation available along a
frontage road while still maintaining the required sight distance at each location and the City of Raleigh's
maximum block length of 1500 linear feet. These locations were field verified and approved by NC DOT.
We do not have correspondence from the City of Raleigh other than what was approved and/or required in
the preliminary subdivision review (i.e. City of Raleigh did not generate a letter).
We anticipate that this documentation, coupled with the above supplied information and explanation will
satisfy any outstanding issues for River Towne. Please let us know if there is anything further that we can
provide you with or do for you in order to assist in expediting the 401 Approval for this project.
Sincerely,
Nicole J. ?Thomson
Regulatory Specialist
Attachments: 5 copies of Response letter
5 copies of letter from Priest Craven
5 copies of Priest Craven response map
PRIEST, CRAvEN& ASSOCIATES, NC.
LAND USE CONSULTANTS
May 22, 2008
NC Division of Water Quality
401 Oversight and Express Permit Unit
Attn : Cyndi Karoly / Ian McMillan
2321 Crabtree Blvd., Suite 250
Raleigh, NC 27604
Re : City of Raleigh Stormwater Management Plan
River Towne Subdivision, Buffaloe Road, Raleigh, Wake County, NC
Dear Ms. Karoly and Mr. McMillan:
The City of Raleigh has reviewed and approved the Preliminary Stormwater Management
Plan that was submitted as part of the Preliminary Subdivision Approval process for the
River Towne Subdivision. A copy is enclosed for reference.
Before the project can proceed to construction, it must go through the City of Raleigh's
Grading Permit and Construction Plan Approval processes. At that time detailed
construction plans and supporting calculations will be presented that confirm compliance
with the following:
1. The approved Preliminary Subdivision Plan and accompanying
Administration Approval;
2. The stormwater regulations of the City of Raleigh;
3. The standards set forth by the most recent version of the NCDENR
Stormwater Best Management Practices manual;
4. The nutrient reduction requirements for the Neuse River Basin and any
accompanying payment to the NC Ecosystem Enhancement Program
(EEP);
5. The conditions of the NCDENR 401 permit that must be issued for the
project;
6. The conditions of the USACE permit which also must be issued for the
project.
We ask that this project proceed with permitting conditioned upon an approval letter for
each phase being provided to your office from the City of Raleigh prior to be
ginning
c ction of that phase.
Thomas F. Craven, PE
Priest, Craven & Associates, Inc.
PLANNERS / LANDSCAPE DESIGNERS / ENGINEERS / SURVEYORS
3803-B Computer Drive, Suite 104, Raleigh, NC 27609 Phone [phone] Fax [phone]
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