20080525 Ver 1_General Correspondence_20080723

,
5outkern Environmental C3roup) Inc.
5515 South College Road, Suite E • Wilmington, North Carolina 2841 2
910.452.2711 • Fax: [phone]
www.segi.us
July 23, 2008
Regular Mail
Joanne Steenhuis
Division of Water Quality
Isolated Wetland Permit Application
127 Cardinal Drive Ext.
Wilmington, North Carolina 28405
Re: Response to DWQ Letter regarding Request for Information
Dear Ms. Steenhuis:
This letter is in reference to a request for additional information regarding an application we had
submitted to place fill material in a wetland with no significant nexus to navigable waters.
You had requested three items:
1. Avoidance and Minimization of Impacts, including a financial analysis;
2. Information on the stormwater pond and other stormwater features; and
3. The number of stores for the proposed project.
Avoidance and Minimization of Impacts, including a financial analysis
The project has been designed to avoid and minimize impacts where required in order to
accomplish the basic project purpose-develop the property for office and/or retail establishment
development in harmony with development in the area while providing a reasonable return to the
property owner.
The lot is not large for an office and/or retail development, and setbacks from Hwy 17 and
adjacent parcels remove much of the area that can be used for development. Retail and offices
want to be visible from the roadway and have sufficient parking without having to make the
customers and/or employees walk excessive distances from where they park their vehicles. The
proposed project has been designed taking into account of the
1. Spatial and dimensional requirements of the project;
2. The location of existing structural and natural features that might have dictated the
placement or configuration of the proposed project; and
3. The purpose of the project and how the purpose relates to the placement, configuration,
and density of the project.
DWQ,Repsonse - DRAFT [2/4) sr-6i
Specifically, the small lot requires full development to meet the project purpose due to planning
requirements (e.g., setbacks, parking requirements, etc.) and the need in the area for office and/or
retail development as observed by the rapid development of similar proposals in the vicinity.
Frontage on Highway 17 means access to the highway is required, and stormater is, therefore,
directed to the back towards the area where stormwater and other precipitation currently flow
after severe storm events.
As is observed with similarly located properties being developed along that stretch of Hwy. 17,
single-story office complexes and/or retail shopping centers are the "norm." Double-story
developments have additional costs in both assuring and/or creating appropriate sediment below
the development to accommodate and support the additional weight per area and accounting for
the "economic cost" for lost rents/leases, etc. that occur due to the reduced prices paid for both
retail/office leases and/or development space not located on the bottom floor or not locate on
"street level."
At this time, the project has a three-year development plan. The plan includes a basic financial
analysis of expected and incurred costs (See "Financial Analysis" below) that have been or are
expected to be incurred to complete the development of the site to prepare it for development.
Financial Analysis
Sale Price $350,000.00
Purchase Price $140,000.00
Closing Costs $7,500.00
Holding Interest $22,400.00
Permitting $13,000.00
Surveying $7,500.00
Planning $2,500.00
Suitable Sediment Testing $7,500.00
Existing Fill On-Site $18,000.00
Additional Fill Required for Site $40,000.00
Advertising $4,000.00
CPA $2,000.00
Attorney Fees $2,800.00
Real-Estate Commission $35,000.00
Total Cost $302,200.00
DWQ.Repsonse - DRAFT [3/4] SE-6i
The current financial analysis shows the property owner is expected to make a maximum of Forty
Seven Thousand Eight Hundred Dollars on the proposed development just shy of a fourteen
percent profit of the sale price.
Information on the stormwater pond and other stormwater features
The rear of the development is, in fact, planned as the location for the stormwater pond due to the
site's existing drainage that flows west from the current site. However, a finalized stormwater
plan has not been submitted or designed. The client states the stormwater plan will not be
designed until the wetland permit is obtained for several reasons, including:
1. To avoid additional filing fees in case the stormwater plan is changed during the
application review for the wetland permit; and
2. The Client's development time line is to obtain all permits that would be required in an
order that maximizes efficiency, reduces costs, reduces redundant review by state and/or
local agencies, and where one permit may be required prior to initiating the process to
apply for another permitting process.
The Client is aware that a stormwater plan may need to be obtained prior to finalizing the
proposed plans with the local and state government.
The Client asks that the permit be conditioned, as needed, by the DWQ as allowed by regulation.
15 NCAC 2H . 1304(b) states the General Permit may be conditioned, as deemed "necessary to
insure compliance with this Section including written post-discharge notification to the
Division." While applying for other Department of the Environment and Natural Resource
permits may be the application to fill an isolated permit under these rules (See 15A NCAC 02H .
1302(h) of the regulations), obtaining other required permits is not a requirement of obtaining a
valid permit under the rules.
The number of stores for the proposed project
Local regulations require a specific number of parking spaces that is determined by the gross
floor area of the proposed development such that the developer must provide 1 parking space for
every 200 square feet of gross floor area (See Note #5 on the development plan submitted with
the application). The gross floor area proposed is 10,400 square feet, and 52 (10,400 / 200)
parking spaces are proposed. The surveyor and planner have stated that they would not expect
the number of stores to affect the gross floor area.
DWQ.ReFsonse - DRAFT [4/4]
Summary
SEGO
In summary, proposed project has been designed to meet the project purpose of developing the
project site in order to build an office and/or retail shopping complex in the same manner as
those being build in the surrounding areas and to guarantee a viable financial return for the
property owner.
If you have any questions and/or comments, please do not hesitate to contact our office.
Sincerely,
James Taylor