20080680 Ver 1_More Info Received_20080916

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DR. J.H. CARTER III & ASSOCIATES, INC.
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Environmental Consultants
P.O. Box 891 • Southern Pines, N.C. 28388 DENR - WATER QUALITY
[phone] 41 Fax [phone] WETLANDS AND STORMWATER BRANCH
Letter of Transmittal
To: MR. IAN McMILLAN
DIVISION OF WATER QUALITY
401 WETLANDS UNIT
1650 MAIL SERVICE CENTER
RALEIGH, NC 27699-1650
WE ARE SENDING YOU
Attached
Copy of letter
Prints
Date: 9-11-08 Job # 0817
Attn: Ian McMillan
Re: Savannah's Garden permit
Reports Maps
Plans Data
Photos Permit
COPIES DATE # P s DESCRIPTION
5 9-11-08 3 Letter to DWQ with revised impervious calcs for
Savannah's Garden subdivision,
Carthage, Moore County, NC

THESE ARE TRANSMITTED
For approval Approved as noted
X For your use Approved as submitted
As requested Returned for corrections
For review and comment For your information
REMARKS: Ian,
I've enclosed 5 copies of our letter response in this packet.
Please contact me with any questions or concerns.
Thank you.
Jennifer M. Archambault
Wildlife Biologist
COPY Mr. Ken Averitte - DWQ
TO: Ms. Emily Burton - USACE
Mr. Ron Jackson - Quality Built Homes SIGNED: V?:?
If enclosures are not noted, please contact us immediately
Endangered Species Surveys • Environmental Assessments • Land Management • Wetlands Mapping and Permitting
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DR. J.H. CARTER III & ASSOCIATES, INC.
Environmental Consultants
P.O. Box 891 • Southern Pines, N.C. 28388
[phone] • Fax [phone]
II September 2008
Mr. Ian McMillan
401 Oversight/Express Review Permitting Unit
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699-1650
RE: Savannah's Garden subdivision
DWQ Project #08-0680, Moore County
Dear Mr. McMillan:
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This letter is in reference to the after-the-fact permit application for impacts to jurisdictional
wetlands at the Savannah's Garden subdivision in Carthage, Moore County, North Carolina. The
amount of proposed impervious area onsite has been an issue that we have been working to resolve
since receiving your letter, dated 17 June 2008. This task has required collaboration with Mr. Ron
Jackson, Neal Smith Engineering, Inc. (NSE) and Division of Water Quality personnel at the Central
and Fayetteville Regional Offices.
The impervious area calculations we submitted on 8 May 2008 listed a total impervious area of
23.41 %, with 24.20% in Phase I and 19.37% in Phase Il. These figures were calculated using worst
case built-out conditions, including a greater percentage of high impervious dwellings and generous
driveways and sidewalks. After providing these calculations, you responded with the June 17 letter
stating that "DWQ determined that the drainage areas in this project exceed 24% impervious." Despite
communication with DWQ on a few occasions, we never got a clear explanation of how that
determination was made and can only assume that the impervious area of Phase I triggered the
response.
The new proposed impervious area calculations (attached) provided by NSE are based on the
most likely built-out conditions, rather than the worst case scenario. NSE staff conferred with Mr.
Jackson about reasonable revisions to the project design and visited the Savannah's Garden
subdivision to measure existing driveways, sidewalks and dwelling footprints. Driveways and
sidewalks typically measured 500 ft2 per lot, which is 320 ft2 smaller than the proposed calculations
Endangered Species Surveys • Environmental Assessments 9 Land Management • Wetlands Mapping and Permitting
submitted in May. The calculations submitted in May also assumed that many (worst case) of the
proposed lots would be built using a dwelling design that had a larger than average impervious
footprint. After the site visit, NSE determined that a smaller percentage of the built lots than expected
used the largest design. The new calculations use a more realistic average of the expected impervious
area for dwellings, driveways and sidewalks.
The new proposed impervious area for Phase I is 5.05 acres (23.37%). Proposed impervious
area for Phase II is 7.75 acres (18.55%). The total proposed impervious area for the project is
approximately 12.8 acres, or 22.49% of the total project area. See the attached sheet for a full listing
of the calculations. This project, as designed, falls below the 24% impervious threshold that would
require a Stormwater Management Plan, as set forth in GC 3705.
It is imperative that we move forward with this project in a timely manner in order to get this
property into compliance with State and federal wetlands laws and to implement the approved
Wetlands and Stream Restoration Plan by the December 1 deadline. We received the after-the-fact 404
permit (Nationwide Permit No. 29) from the US Army Corps of Engineers on 30 May 2008 (Action ID
SAW-2006-40688-063). Once we receive 401 Certification from your office, we can move forward
with both mitigation and restoration of wetlands at the Savannah's Garden subdivision.
Contact me with any questions regarding this project. You may also contact Mr. Scott
Matthews of NSE directly at [phone] with any questions regarding the impervious area
calculations or project design. Please also coordinate with Mr. Ken Averitte at your DWQ Fayetteville
Regional Office regarding this project. Thank you for your time.
Sincerely,
it
Jennifer M. Archambault
Wildlife Biologist
Enclosures: Revised impervious area calculations
CC: Mr. Ron Jackson, Quality Built Homes, Inc.
Mr. Ken Averitte, NCDWQ Fayetteville Regional Office
Ms. Annette Lucas, NCDWQ Stormwater Branch
Ms. Emily Burton, Wilmington Regulatory Field Office, USACE
Mr. Scott Matthews, Neal Smith Engineering, Inc.

Savannah's Garden - Impervious Area Calculations (Revision)
Wednesday, September 10, 2008
Phase 1
Total 21.63 Acres
Road Area 2.15 Acres
# of Lots 55.00
Avg. lot Coverage 55 lots @ 1,800 SF 99000 SF
Avg. Driveway and Sidewalk 55 lots @ 500 SF 27500 SF
Total Lot Coverage 2.90 Acres
Impervious Area 5.05 Acres
Total Area 21.63 Acres
% Impervious Area 23.37%
Phase 2
Total 41.79 Acres
Road Area 3.00 Acres
# of Lots 90.00
Avg. Dwelling Coverage 90 lots @ 1,800 SF 162000 SF
Avg. Driveway and Sidewalk 90 lots @ 500 SF 45000 SF
Total Lot Coverage 4.75 Acres
Impervious Area 7.75 Acres
Total Area 41.79 Acres
% Impervious Area 18.55%
Project Totals
Total Area 63.42 Acres
Road Area 5.15 Acres
# of Lots 145.00
Phase 1 Lot Coverage 2.90 Acres
Phase 2 Lot Coverage 4.75 Acres
Jurisdictional Wetlands 6.48 Acres
rvious Area
p 12.81 Acres
Eot
a
Proj ect Area 56.94 Acres
22.49%