20180152 Ver 2_Cover Letter for Savaan Subdivision_20180420

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March 20, 2018

US Army Corps of Engineers NC Division of Water Resources
Raleigh Regulatory Office 401 & Buffer Permitting Unit
Attn: Ms. Tasha Alexander Attn: Ms. Stephanie Goss
3331 Heritage Trade Drive 512 N. Salisbury Street
Suite 105 Raleigh, NC 27604
Wake Forest, NC 27587

Re: Savaan Subdivision (Ferrell Farm)
Revised Request for NWP 29 & GC 4139, and Riparian Buffer Impact Approval
Sage Project # 2017.28
DWR #18-0152
SAW-2015-00557

On behalf of Ashton Woods Homes (applicant) and Arroyo Capital I, LLC (owner) please find
attached a revised application and supplemental information requesting written concurrence from
the US Army Corps of Engineers (USACE) and North Carolina Division of Water Resources
(NCDWR) that the activities associated with the proposed residential development may proceed
under Nationwide Permit (NWP) 29 and the associated General Certification (GC) 4139. The
associated site plan has previously been submitted to both the USACE and NCDWR. Although
the overall site plan has not changed, the Town of Cary’s latest review has required that the
headwalls, previously proposed to minimize impacts resulting from the road crossing, be
removed. The NCDWR issued approval (DWR #18-0152) based on the previous site plan. All
other impacts remain the same as the previous request. After discussing the revision with Ms.
Stephanie Goss of NCDWR, she determined that a revised and new application should be
submitted. We ask that the NCDWR approval be updated to include the increase in wetland and
buffer impacts and that the USACE replace the previous request with this one. Please find
attached a complete application and supplemental information.

Project Summary and Purpose
The overall project is a single-family residential subdivision with residential streets and utilities
that will connect to existing adjacent roads and utilities in the area. The Project is located western
Wake County approximately 3/10 mile west of the Davis Drive and Morrisville Carpenter Road
intersection in Cary, Wake County, NC. The purpose of the proposed project is to construct a
residential subdivision and associated utilities to meet the demand for housing in this part of Wake
County.

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Project Detail
The overall project is a single-family residential subdivision that consists of 158-detached
residential lots and 140 condo/ townhome units. Residential streets will connect to existing
adjacent roads in the area. Several connections to existing adjacent sewers are to be constructed
in the southern portion of the Property. An existing sewer located along the eastern property line
is proposed to be removed and relocated slightly. An existing RCP approximately 75 linear feet
(LF) will be removed. The pipe is located at the end of drained pond. Upstream of the pipe
removal, a precast double barrel box culvert (2) 6’x10’ measuring 106 LF with headwalls and an
outlet riprap dissipater basin will be installed upstream of the existing RCP. The proposed impacts
will result from road construction, wetland fill, and temporary impacts associated with stream
dewatering and culvert placement. Heavy equipment typically used for utility installation projects
(e.g. back hoes, bull-dozers, etc) will be utilized.

No recorded federally listed species are located on the project site or within a 1-mile radius
according to the NC Natural Heritage Data Base (2017).

The project is located within the eastern portion of the Carpenter Historic District (WA0787), a
National Register (NR) Boundary, which occupies a late 19th-early 20th century farm crossroads
district. The portion of the proposed development within the Historic District has historically been
used for agriculture and pasture (i.e. regularly plowed) and contains The C.F. Ferrell House
(WA0742). The C.F. Ferrell House is located along the southern property boundary of the tract
adjacent to Morrisville-Carpenter Road. According to the SHPO website, the status of the C.F.
Ferrell House is Surveyed Only (SO) and Center point of a National Register historic district
(NRHD). The house was built circa 1900 and is a one-story frame dwelling.

As part of the rezoning approval process, the Town of Cary Council and Planning Department
requested that the C.F. Ferrell House be preserved. The Town of Cary would allow preservation
/ relocation to be completed either on-site or off-site. No other structures were deemed historically
relevant and are not slated for preservation.

To best preserve the house in its contextual environment Ashton Woods and David Ferrell
(homeowner) determined that the home should remain on-site. The location chosen is
approximately 900’ southeast of its current location and will provide an ideal setting for the
relocation.

The home will be set within a conservation easement area of approximately 1.3 acres. 0.97 acres
of that space is set aside for stream and wetland buffers and reforestation areas. These areas
are restricted and no development is allowed (see attached Draft Site Plan and Ferrell House
Exhibit).

The home will be restored to as near its original structure as is feasible. This includes the removal
of structural additions and the replacement or rehab of windows, roof, siding, and front porch to
more closely resemble the original structure. The interior rehab will include fireplace rehab and
reclaiming the original flooring as much as possible. The landscape planting will also see a rehab
which includes planting that more closely resembles the style and period of the house (see
attached draft rehab agreement).

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Capital Area Preservation met with the Town of Cary and Ashton Woods to provide guidance and
direction with regard to the location and rehabilitation of the house. Ashton Woods will work with
Capital Area Preservation to ensure that the home is returned to its original structural form and
remains in a well-maintained condition. Ashton Woods will grant a conservation easement to
Capital Area Preservation to memorialize this effort and provide further protection to this historic
home and lot (see attached draft easement agreement).

Finally, a plaque will be set in a conspicuous location on the site to provide details and information
relating to the origin, design, and history of the C.F. Ferrell house (see attached draft plaque
rendering).

A scoping letter was sent to NCSHPO in August of 2017, which included the action plan described
above. The NCSHPO requested a preliminary survey. Based on current SHPO guidelines the
survey produced four prehistoric sites and two historic sites, none of which will be recommended
eligible for the NRHP. One of the historic sites was associated with the Ferrell Farm house but
the material appears to be incidentally dispersed. A PDF copy of the report has been submitted
to SHPO and the USACE and a hard copy will be delivered next week.

Project History
Most of the project site has been in pasture and crop production since the early twentieth century.
A riparian buffer determination was made by NCDWR staff on March 12, 2014 and a
determination letter (NBRRO# 15-075) was issued on March 18, 2015. A wetland and stream
delineation was completed by Sage Ecological Services, Inc. in 2017. A site meeting was held
with Ms. Tasha Alexander of the USACE in July 2017.

The northern portion of the Site contains a portion of the Town of Cary’s Airport Boulevard
easement which will connect two existing stubs of the roadway located on either side (east and
west) of the Project. The Airport Boulevard corridor was determined to be a separate project by
the USACE in 2017 based on its inclusion in the Town of Cary’s transportation improvement plan
among other things. The Airport Boulevard corridor permit application was previously submitted
to the USACE and NCDWR under separate cover.

As mentioned above, the Town of Cary’s latest review has required that the headwalls, previously
proposed to minimize impacts resulting from the road crossing, be removed. The NCDWR issued
approval (DWR #18-0152) based on the previous site plan. All other impacts remain the same as
the previous request.

Avoidance and Minimization
The proposed roadway was positioned as a nearly perpendicular crossing in an effort to avoid
additional stream impacts. The location was chosen so as to minimize wetland impacts and avoid
the larger wetland area located slightly downstream. Construction fencing will be used to define
the construction corridor and prevent any accidental additional impacts. Silt fencing will be
installed to provide additional protection from runoff. The culvert site will be dewatered during
construction in accordance with Best Management Practices. The culvert will be buried 12" below
the existing stream bed to allow aquatic passage. Headwalls were originally designed to extend
the length of the crossing in an effort to minimize impacts to wetlands and riparian buffers however
the Town of Cary has since required the engineer to redesign the crossing and remove the
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headwalls.

Project Impacts
Proposed stream and wetland impacts will result from fill and culvert placement required for road
construction. The installation of the road will also result in temporary impacts due to dewatering
and work areas. Overall stream impacts total 126 LF which include 107 LF of permanent perennial
stream impact (culvert) and 19 LF of temporary impacts due to dewatering and culvert
construction. Proposed permanent wetland impacts total 0.395 acre (previously 0.34 acre) as a
result of road fill. No stream or wetland impacts are proposed for the relocated sewer line because
the position of the relocated sewer line is within what is now the piped portion of the stream
through the old pond dam.

The Project is located within the Neuse River Basin. Buffer impacts proposed for the project
include 12, 944 Square Feet (ft2) in Zone 1 (previously 12,836 ft2) and 5,880 ft2 in Zone 2
(previously 4,898 ft2) resulting from the road crossing; 1,462 ft2 in Zone 1 and 1,686 ft2 in Zone 2
for the sewer realignment; 1,037 ft2 in Zone 1 and 361 ft2 in Zone 2 for the sewer removal (all of
which will be revegetated); 158 ft2 in Zone 1 and 745 ft2 in Zone 2 for sewer connection to an
existing line; and 242 ft2 in Zone 2 for a parallel sewer easement.

Mitigation
Permanent stream impacts will total less than 150 linear feet therefore stream mitigation is not
proposed. Wetland impacts exceed 0.1 acre and will be mitigated at a 2:1 ratio. Mitigation is
proposed for buffer impacts at 3:1 (Zone 1) and 1.5:1 (Zone 2) ratio. The project is located in HUC
03020201. Wetland mitigation credits for 0.79 acre (previously 0.68 acre) will be purchased from
the Falling Creek Stream and Wetland Mitigation Bank (see attached Statement of Availability
letter). Riparian Buffer credits for 47,652 ft2 (previously 45,855 ft2) will be purchased from the Old
Savannah Nutrient Offset & Buffer Bank (see attached Statement of Availability letter).
If you have any questions, please call me at [phone].
Sincerely,

Sean Clark, PWS
Sage Ecological Services, Inc.