20090157 Ver 1_More Info Letter_20090512

SEGO
Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, North Carolina 28412
910.452.2711 (office) • 910.452.2899 (fax)
Date: 07 May 2009
To: Mr. Ian McMillan
Of: DWQ
Attached you will find:*
Mq y ??
A
SEGi Project #: 04-202.01St'' iry
1 " O + 5 'J Client Name: Mr. William H. Smith
DWQ Project #: 09-0157
Transmittal Letter
? Proposal ? Sketch(es) ? Permit ? Signed Wetland Map ? Photo(s)
? JD Package ? Report(s) ? Plans ? Information Request ® Other
Copies Dated Description
5 05/07/09 Response letter to the DWQ's request for additional information
These are being delivered:
*If noted items are NOT attached, please contact our office.
? For your Review/Comment ® For your Records ? Returned for Correction(s)
? Corrected and Returned ? For your Signature ? As Requested
? Other:
By: ® Hand Delivery ? Fed-Ex ? UPS ? Regular Mail ? Other
Notes:
Ian:
Attached are five copies of SEGi's response package to the DWQ's request for additional information. Please review the attached
documentation and let me know if you will need anything further in order to continue with the processing of this permit, or if you have any
questions or concerns with the information provided. Thank you for your time and consideration.
Signature and (Typed) Name:
4w?a?LD40-
Amanda L. Kolb
Date: 05/07/09
Soutkern Environmental 6rou D
P
5515 Soutk College Road, Suite F - Wilmington, Nortk Carolina 28+12-
910-+52-2711 - Fax. [phone]
www.segws
07 May 2009
United States Postal Service
N.C. Division of Water Quality
Wilmington Regional Office
Attn: Mr. Chad Coburn
127 Cardinal Drive Extension
Wilmington, NC 28405
Re: 421 Truck Stop Expansion Project
Wilmington, New Hanover County
Response to Additional Information Request
DWQ Project #: 09-0157
[e-mail]
[SEGi Project #: 04-202.011
Dear Mr. Coburn:
This letter is in reference to the proposed expansion of an existing truck stop facility, located at
1610 US Highway 421 North in Wilmington, New Hanover County, North Carolina. Southern
Environmental Group, Inc. (SEGi) has been retained by Mr. William H. Smith, the Applicant, to
address concerns listed within a letter received from the Division of Water Quality (DWQ), dated
16Apri12009. Please see below:
This site was previously permitted for 0.21 acres of 404 impacts but as indicated
in the application packet, considerably more impacts were constructed than
approved. Provide an accurate description of the cumulative impacts to
jurisdictional waters for this site. This includes impacts previously permitted
under section 404 of the Clean Water Act and proposed impacts for the present
expansion.
Based off information that was obtained from a file review at the United
States Army Corps of Engineer's office, it appears that approximately one
acre of wetlands was erroneously filled by the Worlsey Company in 1991.
The Worsley Company was issued a cease and desist letter, to which they did
not adhere. Subsequently, the Corps sought legal recourse against the
Worsley Company. The case was presented to the United State District
Court for the Eastern District of North Carolina Wilmington Division (Case
No. 93-15-CIV-7-F). A Consent Order and Judgment was issued, which,
among other conditions, required the Worsley Company restore 0.11 acre of
the impacted wetlands on the subject parcel.
21s 5EGi
The file review, unfortunately, did not provide a concrete, overall impact
tabulation of fill the Worsley Company placed on-site. It is SEGN assertion,
based on the information available, that the overall impact acreage
associated with the Worsley Company's filling of the subject parcel totaled
approximately 0.89 acre of fill (the approximate 1 acre of unauthorized fill,
minus the 0.11 acre the Worsley Company was required to restore, totals
approximately 0.89 acre of overall fill at the site).
The proposed expansion will require the filling of 0.72 acre of wetlands.
Combining the previous fill acreage with the proposed fill acreage provides
an approximate cumulative impact total of 1.61 acres of fill.
You do not appear to have avoided and minimized to the greatest extent
practicable. Please explain why buildings and/or parking areas may not be
eliminated, reduced in size, or reconfigured to reduce wetland impacts. Also,
provide additional information as to the alternative off sites looked at and detail
the criteria reviewed and why other sites were deemed unsuitable for this project.
Please refer to the previously submitted Attachment 2, Pages 12 - 14 of the
"Supplemental Documentation", the section entitled "Alternatives", for
discussions on alternative designs and options that were considered during
the design phase of this project (an additional copy of the submitted
Attachment 2 has been included in this response package as Attachment A).
Alternative designs that were considered, and rejected, include: the "no
action" alternative (also considered avoidance); the "other project designs"
alternative; the "other project locations" alternative; and, minimization.
These alternatives are further discussed in Attachment A.
Eliminating the proposed parking area would essentially negate the purpose
of this project, which is to expand an existing facility. The expansion of the
parking area is necessary to accommodate the influx in traffic associated
with the completion of the Isabelle Holmes Bridge and increased use of the
truck stop facility by patrons. In addition, the proposed parking area will
supplement those parking spots that will be lost by the inclusion of an
additional fuel canopy and fuel cells.
Reducing the size of the proposed parking area in not a viable option, as the
proposed parking area must be of adequate size to accommodate tractor-
trailers, as well as compact vehicles.
A reconfiguration of the proposed parking area is not feasible, for the same
reason a reduction in size of the parking area is not possible - one must take
V5
SEGO
into account the size and length of the vehicles that will be utilizing this
facility, as well as the turning radii of tractor-trailers. A reconfiguration of
the proposed layout would not allow for as many additional parking spaces
for tractor-trailers as the current configuration.
As far as acquisitioning an adjacent property, please refer to Attachment B
of this document, titled "Adjacent Properties". Utilizing New Hanover
County's GIS system, SEGi obtained GIS information on the subject parcel,
and subsequently overlayed the "wetland" layer. The attached will
demonstrate that, outside of the uplands on which the convenience store was
constructed, there are no uplands in the general vicinity of the subject
parcel. As is evident on Attachment B, there are no areas in the immediate
vicinity on which the Applicant could construct a parking area for his truck
stop, that would result in less impacts than what is currently proposed.
Therefore, the acquisition of any adjacent property for use as a parking area
is not a viable option. Building on an adjacent parcel would most likely
result in the same amount, if not exceed what is proposed in the current
design, of wetland impacts. Should the Applicant be required to construct
his new parking area on a nearby parcel, he would have to incorporate a
footpath through the wetlands, leading to the truck stop, that could
potentially constitute an additional wetland impact. Without the footpath,
patrons would be required to walk along the shoulder of US Highway 421
North, which could be considered unsafe.
The Applicant's stated project purpose is to expand an existing facility, in
order to accommodate a significant increase in traffic utilizing the NC
Highway 133, US Highway 421 and the US Highway 17 corridor, which
supports the general north/south and east/west flow of traffic through the
region. The construction of a parking area on a different parcel, other than
the proposed subject parcel, would not meet the Applicant's stated purpose
and need.
The design of the project as proposed has not demonstrated that there is no
practical alternative that would avoid or result in less adverse impacts to surface
waters in accordance with NC Administrative Code 15A NCAC 2H .0506.
Specifically, a lack of practical alternatives have not been shown by
demonstrating that, considering the potential for a reduction in size, configuration
or density of the proposed activity and all alternative designs, the basic project
purpose cannot be practically accomplished in a manner which would avoid or
result in less adverse impacts to surface waters. It is strongly recommended that
you select an alternative design that avoids the wetlands or significantly reduces
the impacts on the subject property.
,, SEGO
Again, SEGi requests that the DWQ refer to the previously submitted
Attachment 2 (provided herein as Attachment A), "Supplemental
Documentation," Pages 12-14, entitled "Alternatives". Alternate designs and
locations were discussed in the submitted Supplemental Documentation, and
the reasonings behind the rejection of those options were also addressed.
Some of the options discussed in the previously submitted document include:
attempting to construct a pile-supported parking area; restructuring the
proposed layout for the expansion project; and, the consideration of
additional locations. These alternatives were rejected for a variety of
reasons, therefore, the Applicant suggests that, "There is no reasonable or
prudent alternate design or location for the project that would avoid the losses
to be mitigated."
On a site where the remainder of the property has been verified as being a
wetland, it is impossible to construct the proposed project on the subject
parcel without resulting in a wetland impact. The Applicant has taken every
measure possible to avoid and minimize impacts where practicable.
Minimization has been demonstrated in that the Applicant is proposing to
incorporate a concrete retaining wall as a form of stabilization for the
proposed fill material, thereby eliminating the need for additional wetland
impacts that would have been associated with side slopes. Also, the 0.70 acre
of fill requested is the minimum amount needed in order to accommodate
parking for tractor-trailers. The Applicant is proposing to create nine
parking spaces, each 80 feet in length, as the average length of a tractor-
trailer is somewhere between 70 and 80 feet. In addition, the size of the
requested parking expansion accounts for the large turning radii associated
with tractor-trailers.
The Applicant believes that the proposed project can be considered an
"exceptional development". The Applicant feels the project has been
"sensitively designed to be in harmony with the sites natural features and
natural functions, and provides a balance with the highest and best use of
the property." The Applicant's project, as proposed, minimizes erosion,
runoff and siltation (by the utilization of stormwater BMPs); minimizes
impervious surfaces impacts and protects estuarine resources (as
demonstrated by the Applicant's attempts at avoidance and minimization, as
well as the consideration of other alternatives, and the implementation of the
stormwater BMPs); the project does not interfere with access to or use of
navigable waters; does not require extraordinary public expenditures for
maintenance; there will be no ground absorption of sewage systems, as the
site has its own WWTP; and, no historic, architectural or archaeological
resources will be impacted by this project.
515 SEGO
Include the location of utilities to show that additional wetland impacts will not
be required.
The majority of utilities on-site were installed when the truck stop was
originally constructed in 1991. The proposed expansion of the parking area
will require the installation of an additional power line, which will provide
power to the proposed stormwater pumps. The new conduit will run from
the existing building, underground, to the proposed stormwater structures'
pumps. Additional wetland impacts are not anticipated with the installation
of the power line, as the utility will be installed within the new parking area,
which has already been requested as a wetland impact.
Attachment C, "Utilities Drawing", is attached herein for reference. The
areas highlighted in pink depict the location of the proposed stormwater
pumps and also show the extent that the utilities will infiltrate the new
parking area. As is evident on the attached drawing, no additional wetland
impacts will be associated with the installation of any utilities.
For clarification of the statements mentioned above, please refer to the following documentation
attached to this correspondence:
A. Supplemental Documentation to Individual Permit
B. "Adjacent Properties" (taken from New Hanover County GIS)
C. Utilities Drawing
It is SEGi's sincere hope that the submittal of the responses above, and the documentation
attached, will satisfy the concerns listed within the Division of Water Quality's Request for
Additional Information. If you have any remaining questions or concerns, please feel free to
contact me via telephone at 910.452.2711, or email, at amanda(a,se i.us. Thank you for your
time and consideration with regard to this project.
Sincerely,
_A-Yv\WJD,-_) "
Amanda L. Kolb
Environmental Consultant
Enclosures: (3)
cc: Mr. Ian McMillan (DWQ)
Ms. Emily Hughes (USACE)
Ake ac ?nw?e?n? Al
5outkern Envi'ronmental
Group,
5315 South College Koacljuite E- • Wilmington, 'k4)-
10.-+52-271 North Carolina 28412
1 Fax: [phone]
www.segi.us sr ?kV
y
Supplemental Documentation to the
Individual Permit Application
for the
Truck Stop Expansion
January 22, 2009
Applicant
Mr. William H. Smith
115 Linden Drive
Danville, VA 24551
Agent
Southern Environmental Group, Inc.
5315 South College Road, Suite E
Wilmington, North Carolina 28412
910.452.2711 (Office)
910.452.2899 (Facsimile)
421 Truck 5top IF [2/2 11
sr GO
Section ;
F
?.. v
Page

Location
- 3
Existing Conditions and Project Eistory 1 1 4

Wetland Systems i
7
Project Description 8
Sequence of Events 10
Purpose and Need
,:
10
_. ,1.._..i ..... .{^d i:.-p
...e.+YP? .... .::.. .a.;, :-_ x. .... .av ..5.... w.nz...r-.a.nr-
Alternatives 12
No Action _ . _ . ,
12
Other Project Designs 12
Otfier Project Locations . ?,,., a .z -= ?.., ,+?. ;_?
, 12

I
Minimization d
12,
Proposed- Compensatory Mitigation 13
Payment to NC EEP 13
Preservation of Remaining On-site Wetlands 16
Adjacent Property Owners 20
Other Authorizations
Figures 21
421 Truck jtop IP [5/21]
Location
5F-G1
The proposed project is located at 1610 US Highway 421 North in Wilmington, New Hanover
County, North Carolina (34.2530°N, -77.9565°W). To access the site, cross over the Isabelle S.
Holmes Bridge (Hwys. 133 & 117) out of Wilmington. Take a right at the first stoplight (US 421
N). Take an immediate right into the parking lot of the subject parcel, the Scotchman #303 Dixie
Boy Truck Stop.
The subject parcel is comprised of approximately 3.15 acres. The wetlands on the subject
property are considered contiguous with the Northeast Cape Fear River, though the site itself
does not abut the waterbody. The eastern property boundary is approximately 520 feet from the
nearest branch of the Northeast Cape Fear River. Ms. Jennifer Frye (former USACE Field
Representative for New Hanover County) visited the site, and verified the wetland line on 31
August 2004 (Action ID Number: SAW-2004-1149-064). The original wetland boundary
survey, provided to the Corps, showed 1.025 acres of wetlands on the property (see Attachment
7). A topographic survey was needed, as the wetland boundary survey provided to the engineer
did not have any topographic shots for the existing site. When the new surveyor created his
topographic survey, he also recalculated the on-site wetlands and determined there were actually
0.91 acre of riparian wetland on the subject parcel (see Attachment 8). It appears that the first
survey referred to an existing 0.115 acre unused stormwater retention feature as wetlands, when
421 Truck jtop IF [4/2 I ]
SEGO
it should not have been accounted for as such. Therefore, the total acreage of jurisdictional
wetlands on the subject parcel was determined to be 0.91 acre (39,856 square feet).
The property to the north and east is owned by Eagle Island LTD. The parcel to the south is
owned by Holmesbridge LLC, and the property to the west of the subject parcel is owned by Mr.
Robert L. Bryden and Ann Stapleton.
Existing Conditions and Project History
A truck stop already exists on the subject parcel and has been in use for approximately 18 years.
The truck stop is owned by Mr. William H. Smith and managed by the Worsley Company (the
Worsley Company is now owned by an affiliate of Sun Capital Partners, Inc., a private
investment firm, and the name "Worsley Company" was retained during that sale). The truck
stop comes complete with a diesel canopy and a fuel canopy, both with their own set of pumps, a
convenience store, an asphalt parking area, truck scales, and attendant features one would expect
at a truck stop. Currently, the undeveloped portion of the property is comprised of 0.91 acres
(39,856 square feet) of freshwater marsh wetlands, with a 0.115 acre existing stormwater
retention feature found near the eastern property boundary.
-7 7
2
r." - `•
-?. . ? ? , ?-; ? ?• _ icy .
Figure 2: Existing conditions at subject parcel. Unused stornnwater retention feature is
visible along the northeastern property boundary.
-1-21 Tru& Stop IP 5/21 ]
'
sr-G,
This site has a somewhat convoluted past. This parcel was once used for the purpose of an old
automobile junkyard, which included old rusting automobiles, old batteries, old tires, etc. The
Worsley Company cleaned up the debris and constructed the existing truck stop on the upland
portion of the property in 1990. According to old court records (see Attachment 20), on 7 April
1987, Mr. Hugh Heine, the USACE New Hanover County Regulator at the time, made a site visit
and discovered 0.13 acre of unauthorized fill material in two areas of the "standing water
swamp" complex. At Mr. Heine's request, the Worsley Company removed the unauthorized fill
material from the wetlands (on or around 28 May 1987).
On 25 August 1987, a 404 permit application was submitted on behalf of the Worsley Company,
by Catlin & Associates of Wilmington, North Carolina. The project was given an Action ID
number of 198700517. The application requested permission to fill 0.21 acre of wetlands on-
site, to allow for an access ramp. The application was retired on 30 November 1987, at the
request of the Worsley Company, due to an insufficient compensatory mitigation offer.
Sometime before 22 September 1988, the Worsley Company retained the services of Mr. Rob
Moul and Land Management Group, to assist in performing a wetland delineation. Mr. Moul
performed the delineation, which was verified by Mr. Heine sometime around 19 January 1989.
Mr. Heine also verified the wetland boundary survey, performed by Brunswick Surveying, Inc.
On 10 September 1991, a mitigation proposal was submitted on behalf of the Worsley Company,
by Mr. Moul. As compensatory mitigation was the single lacking factor in the original
application submittal, the inclusion of this document re-opened the file for the original
application (requesting 0.21 acre of fill). The Corps issued the Worsley Company a 404 permit
on 17 October 1991, to allow for the filling of 0.21 acre of wetlands (see Attachment 19).
Mr. Michael Smith, the Corps' then-enforcement officer, performed a compliance inspection on
04 December 1991, in response to several telephone calls which reported wetland fill at the
subject parcel. Mr. Smith's site visit showed the Worsley Company had filled approximately one
acre of wetlands, well beyond the limits of the approved 0.21 acre request. The Worsley
Company was given a cease and desist letter that day, requiring them to refrain from any work in
waters or wetlands, until the matter got resolved.
A site visit on 1 September 1992 showed that truck scales had been constructed and installed at
the site, and that the unauthorized fill area had been paved. Both of those actions were in direct
violation of the cease and desist order. At that time, the Corps decided to seek legal recourse.
The case was presented to the United States District Court for the Eastern District of North
Carolina Wilmington Division (Case No. 93-15-CIV-7-F). The facts of the case were presented,
and a Consent Order and Judgment was subsequently issued (see Attachment 26).
The Consent Order and Judgment required the Worsley Company to restore 0.11 acre of the
impacted wetlands on the subject parcel. Please note, the Order does allow for future permitting
of the previously impacted area. The Order states: "Nothing herein shall be construed to
421 Truc? `jtop IF [6/21 ] Sr-6 1
prohibit the corporate defendant from applying for a Department of the Army permit to discharge
dredged or fill material into the area after it has completed the restoration work..., or from
discharging dredged or fill material into the area in strict compliance with any subsequently
issued Department of the Army permit. In the event the corporate defendant applies for a
Department of the Army permit to fill the area to be restored, in its review of such permit
application, the Corps shall consider the value of the restored area to be its value prior to the
performance of the work which was the subject of this action" (see Attachment 26).
In addition to the restoration required on the subject parcel, the Worsely Company was required
to establish 0.44 acre of wetlands on another property that exuded similar habitat and wetland
features. After several property inspections, the ideal location was found. The mitigation
property is located approximately 1/2-mile south of Jackey's Creek, along NC 133 in Brunswick
County (see photograph below). The tract measures approximately 2.1 acres in size. While the
property does not have a physical address, it has a Parcel Identification Number of 05900007.
The property is now, and has been since 1994, owned by the Worsley Company (see Attachment
28).
The final component of the Consent Order and Judgment was the assessment of a civil penalty to
the Worsley Company. The Worsley Company was required to pay $25,000 (twenty-five
thousand dollars) to the US Treasury.
421 Truck jtop IF [7/2 l ]
5r-6I
Previous Corps' Action Identification Numbers associated with this site include 198700517 and
199103305 (see Attachment 19). The previously issued Stormwater Permit number is SW8-
900421 (see Attachment 20).
Research indicates that the requirements associated with the Consent Order and Judgment were
satisfied. As is evident in all of the attached documentation pertaining to the court case, the main
defendant in this trial was the Worsley Company (the lessee), not Mr. Smith (the property owner,
and subsequent Applicant for this individual permit). Mr. Smith did not have any prior
knowledge that the Worsley Company would partake in the unauthorized filling of jurisdictional
wetlands.
Wetland Systems
The wetland type within the project area may have once been classified as freshwater marsh.
Currently, the entire wetland complex is comprised of a monotypic stand of Phragmites
australis, an invasive species that appears to have taken over the entire wetland complex. The
wetland area lacks a canopy and shrub layer.
Freshwater marshes develop in sounds at the mouths of large rivers. These
marshes are semi-permanently to permanently inundated or flooded - these
wetlands develop where standing water is generally present throughout the year,
so that trees cannot become established. Freshwater marshes are common in the
outer coastal plain, and are valuable for storing water and protecting water
quality. Their plants retain and filter sediments, thereby reducing pollutants.
Freshwater marshes stabilize shorelines and prevent bank erosion and siltation.
Freshwater marshes are not generally known for their rare species, though they
do provide habitat for a number of common species. I
Two soil types were mapped within the Soil Survey of New Hanover County, North Carolina
(see Attachment 11). According to the mapped survey, the two types of soil are classified as
Dorovan soils and Urban land:
Dorovan soils are nearly level, poorly drained soils that are found in bays and long, broad
areas of tidal and stream floodplains. These soils are frequently flooded for very long
periods of time. The soils is known to subside if drained and tilled.'-
Urban land is classified as areas where the original soil has been cut, filled graded or
paved so that most of the soil properties have been altered to the extent that the soil series
is not recognized. Areas that fall within the mapped areas of Urban land are primarily
used as shopping centers, factories, buildings, apartments, etc. The soil is covered by
pavement.'
1 A Field Guide to North Carolina Wetlands Department of Environment, Health and Natural Resources Division of
Environmental Management, January 1996.
2 Soil Survey of New Hanover County North Carolina United States Department of Agriculture, April 1977.
421 Truck Stop IF [8/21 ] 5EGi
Mammals that would utilize this area for foraging habitat may include the raccoon and opossum.
The water moccasin may frequent this area, as well as water snakes (Nerodia spp.), and yellow
bellied sliders (Trachemys scripta). Snapping turtles may also be common. Avian species which
may utilize this area include prothonotary warbler (Protonotaria citrea), pileated wood pecker
(Dryocopus pileatus), and barred owl (Stria varia), among other waterfowl.
Project Description
Due to the influx of traffic associated with the widening and refurbishment of the Isabelle S.
Holmes Bridge, the continued work on the Wilmington by-pass, the lack of truck stops in the
vicinity of the project site and the increasing activity at the State Ports facility, truck traffic has
increased steadily along Highway 421 and in New Hanover County. Continued growth in New
Hanover and Brunswick Counties, and the expansion of the State Port, will fuel the increase in
traffic now and in the future. Due to the increase in traffic volume, increase in amount and
movement of freight to and from the Wilmington Ports, and the number of people relocating to
Brunswick and New Hanover Counties, an expansion of this truck stop is necessary and cannot
be completed without impacting wetlands. The Applicant owns the subject property, and there
are no other properties in the immediate vicinity which can be developed with less impacts to
jurisdictional waters.
In addition to enlarging the parking area, the Applicant's current expansion request calls for an
additional fuel canopy and accompanying pumps. The location of the proposed fuel canopy was
chosen so that positive traffic flow within the truck stop parking area would not be inhibited.
This location also ensures that tractor trailers utilizing the new parking area will not have their
turning radii impeded by the new fuel pump's location. The proposed expanded parking area will
replace those parking spots lost in the inclusion of the new fuel pumps and canopy. The
proposed additional fuel pumps and canopy will be located in an upland portion of the subject
property. They have been situated in their proposed location in an effort to protect the wetlands
from possible detrimental environmental effects, such as spills or leaks (see Attachment 3 and 4).
Parking creates a safe haven for cargo, while providing truck drivers with a safe place to rest.
The Federal Motor Carrier Safety Administration has estimated that "driver fatigue is a primary
factor in 4.5 percent of truck-involved fatal crashes and is a secondary factor in an additional
10.5 percent of such crashes."' With the regulations set forth pertaining to the length of time a
truck driver is allowed to be on the road, and the fact that the nearest truck stop to the subject
parcel is located 17.5 miles away in Delco, North Carolina, the expansion of the Scotchman #303
is a necessity. It is imperative that the Applicant be allowed to expand the existing truck stop, to
accommodate the influx of traffic, as well as make the road safer for all drivers. The figure on
the following page shows the distance between the Scotchman #303, and the next closest truck
stop located in Declo.
3 Study of Adequacy of Commercial Truck Parking Facilities Technical Report. Fleger, Stcphen A. ETAL. McLean, Virginia.
March 2002. httg://www.tfhrc.goy/safety/pubs/01158
421 Truck Stop IF [912 1
SF-6i
Fill will be placed into 0.72 acre (31,165 square feet) of wetlands, in order to allow an expansion
of the existing facility. The proposed impact includes the installation of concrete retaining walls
and the discharge of clean fill material behind them. Of the 0.72 acre of fill requested,
approximately 0.70 acre (30,291 square feet) is attributed to the expansion of the parking area,
with the remaining 0.02 acre (874 square feet) being associated with the incorporation of
vegetative filters (as required by Stormwater) and the inclusion of a dumpster pad. The dumpster
is required by Chapter 23, Article V of New Hanover County's Code of Ordinances, which reads:
Every owner, occupant, tenant and lessee using or occupying any
commercial, institutional or industrial building or property shall be
obligated, jointly and severally, to provide adequate containers to hold the
litter generated by operations on the premises. Specifically, and without
limiting the generality of the foregoing, the requirement for such
containers shall apply to shopping centers, supermarkets, convenience
stores, fast-food restaurants, service stations and similar establishments,
and shall likewise apply to commercial establishments, garages, schools,
colleges and churches.
(Code 1978, § 11-74)
The existing, non jurisdictional stormwater retention feature will also be filled, and will be used
as part of the proposed parking area. The Applicant is proposing to utilize silt fencing along the
exterior of the project boundary, in order to prevent extraneous, unaccounted for, after-the-fact
wetland impacts. Fill material is to be brought to the site using heavy machinery (such as: back
hoes, bull dozers and front loaders, among others), in order to incorporate the fill material into
the proposed parking area.
+21 Truck `jtop IF [10/2 11 SEG
In addition to the aforementioned items, the Applicant is proposing to regrade a portion of the
existing site, to eliminate the existing sand filters on-site, and install two larger sand filters,
which will address the increase in impervious surface area on the subject parcel. According to
the engineer, State Stormwater requires vegetative filters, to serve as an off-line bypass, so when
the storage pipes are full, there is an outlet for the water to discharge. The discharged water must
be conveyed through a vegetative filter to assist in pollutant removal. The vegetative filters aide
in removing pollutants from water that is not being conveyed through the sand filters. The
vegetative filters will be raised one to two feet above the existing wetlands and the raised filters
will be planted with grass, to assist in pollutant removal. All proposed impacts associated with
the vegetative filters have been accounted for in this permit request. Overall, 439 cubic yards of
fill material will be required for the parking area expansion.
Due to the increase in traffic volume, increase in amount and movement of freight to and from
the Wilmington Ports, and the number of people relocating to Brunswick and New Hanover
Counties, an expansion of this truck stop is necessary and cannot be completed without
impacting wetlands.
Sequence of events
The proposed schedule for this project is dependent on the issuance of the appropriate
authorizations. Once the permits have been issued, the Applicant would like to begin work
immediately, starting with the installation of sedimentation and erosion control structures. Next,
the Applicant would have the stormwater system installed, followed by the concrete retaining
wall, then discharge the clean earthen fill material, and finally, surface the area with asphalt to
construct the proposed parking and rest areas. Once the parking area has been paved over, the
Applicant will have the additional fuel pumps and canopy installed, and the expansion will be
complete.
Purpose and Need
The Applicant is proposing to fill 0.72 acre of jurisdictional wetlands, to facilitate the expansion
of the existing truck stop. Traffic has increased significantly since the completion of the Isabelle
S. Holmes Bridge. This bridge is one of two river crossings connecting the city of Wilmington
with NC Highway 133, US Highway 421 and the US Highway 17 corridor. This roadway
supports the general north/south and east/west flow of traffic through the region. According to
statistics obtained from Mr. Roger Hawkins, with the North Carolina Department of
Transportation, traffic counts prior to the completion of the bridge are as stated on the table on
the following page:
421 Truck Stop Ir [11/21)
SEGO
Date # of Vehicles Counted Highway of Reference
April 2003 15365 US Hwy 421 N
April 2003 19820 NC Hwy 133 E/W
May 2003 22476 US Hwy 421 S/ NC Hwy 133E
See Attachment 17 to the Supplemental Documentation portion of the application.
Again, according to information received from Mr. Hawkins in 2004, the future projections of
traffic patterns for the year 2020 are as follows:
Date # of Vehicles Counted Highway of Reference
2020 23700 US Hwy 421 N/S
2020 34400 NC Hwy 133 EM
- naucnrneno 16 to We uupptementat vocumentation portion ql tpe application.
According to NC DOT's website, which provided traffic statistics for the year 2007, traffic
counts adjacent to the existing truck stop had an Annual Average Daily Traffic (AADT) of
24,000 vehicles a This AADT has already exceeded the estimate procured by Mr. Hawkins in
2004 (see Attachment 17). The expansion of this facility will allow the Applicant to serve the
increased number of vehicles traversing the corridor daily.
Two important factors that contribute to the demand for truck parking are: the need to comply
with Federal "hours of service" rules; and, the need for drivers to perform non-driving activities,
such as eating or fueling. "Under current hours of service rules, truck drivers ... are generally
permitted to drive up to 10 hours, after 8 consecutive hours off-duty." 3 "These regulations
induce a demand for parking spaces so that drivers who must drive more than 10 hours between
their origin and destination can obtain the required 8 hours of long-tern rest."' The regulations
placed on truck drivers by the Interstate Commerce Commission are strict regarding the amount
of time a driver can drive, and therefore, drivers must be offered flexibility in parking.
The availability of truck parking is becoming a problem with potential safety implications. A
major safety issue, according to truckers, is a "lack of safe, available commercial vehicle parking
on or near Interstates."3 The subject truck stop is adjacent to US Highway 421, NC Highway
133 and the US Highway 17 corridor. This area is a prime location for truck drivers, due to its
close proximity to arterial highway corridors. "An inadequate supply of truck parking spaces can
result in two negative consequences: tired truck drivers may continue to drive because they have
difficulty finding a place to park for rest; and, truck drivers may choose to park at unsafe
locations, such as the shoulder of the road and exit ramps, if they are unable to find available
parking. Both of these consequences generate a safety hazard for the truck driver and for other
drivers using the national highway system."' Due to the influx of traffic in the project vicinity
and the need to service these vehicles, the Applicant proposes to expand his facility.
The proposed impact to jurisdictional waters associated with the proposed expansion of the truck
4 NC DOT Traffic Maps. http://www.ncdot.org/it/img/DataDistributionfTmMcSurveyMaps/
42 1 Truck jtop IF [ 1 2/21 ] 5EGi
stop is the placement of 0.72 acre of clean fill material within 404 wetlands (see Attachment 3).
No coastal wetlands are to be impacted by this project, and, according to a site visit held 15
November 2005 with Mr. Robb Mairs (former New Hanover County Division of Coastal
Management Field Representative), the project is located outside of all Areas of Environmental
Concern (AECs). The Applicant does not anticipate any fish species being impacted due to the
expansion of his truck stop. The fill material will be stabilized via a retaining wall, and the new
area created will be used to incorporate additional parking spaces. The Applicant has proposed
to utilize this area of the project specifically for parking, rather than incorporate the additional
fuel cells in this location. The placement of a fuel canopy and cells adjacent to wetlands has the
potential for detrimental effects on the environment, should a spill or leak ever occur. In
addition, the proposed project design calls for the clustering of the proposed fuel canopy with the
existing fuel canopy, which will provide a general area to pump gasoline, versus a sprawling
layout with fuel canopies scattered throughout the property. Finally, the location of the proposed
fuel canopy was chosen so that positive traffic flow within the truck stop parking area would not
be inhibited. This location also ensures that tractor trailers utilizing the new parking area will not
have their turning radii impeded by the new fuel pump's location.
Alternatives
The Applicant investigated other potential means of expanding the existing truck stop, and has
been unable to find a practicable alternative that would achieve his goal and meet his stated
purpose.
• No action:
The no action alternative is that alternative which does not require filling of 404
jurisdictional wetlands. There is no practicable manner in which this project could be
completed on this site without a permit to discharge fill material into wetlands. On a site
where the remainder of undeveloped land is jurisdictional, the only way a project might
be constructed without DA authorization is to be pile supported. Unfortunately, the
Applicant cannot construct additional parking for tractor-trailers on a pile supported
structure that would not act as a form of fill. According to Section 323.3 Discharges
Requiring Permits, found within the Code of Federal Regulations:
Placement of pilings in waters of the United States constitutes a discharge
of fill material and requires a Section 404 permit when such placement
has or would have the effect of a discharge of fill material. Examples of
such activities that have the effect of a discharge of fill material include,
but are not limited to, the following: Projects where the pilings are so
closely spaced that sedimentation rates would be increased; projects in
which the pilings themselves effectively would replace the bottom of a
waterbody; projects involving the placement of pilings that would reduce
the reach or impair the flow or circulation of waters of the United States;
and projects involving the placement of pilings which would result in the
adverse alteration or elimination of aquatic functions.
421 Truck jtop !P [13/21)
5r-6i
Other project designs:
The only alternate design for this project on-site would be to relocate the new fuel pumps
to the wetland area and move the truck parking area closer the main building. This would
result in pumps being sprawled about the property, instead of being clustering together.
Spreading the fuel pumps and canopy about on the site could potentially be extremely
environmentally damaging, as the ability to locate and contain a spill or leak may be
reduced.
Other project locations:
The proposed project calls for the expansion of an existing facility, thus, construction on
an alternate site would not meet the Applicant's stated purpose and need. In addition,
there are no available properties which could be considered suitable, located within
approximately 2 miles of the subject property, where a fueling facility of this magnitude
could be constructed with less impact to jurisdictional features.
• Minimization:
Minimization was demonstrated in that the Applicant is proposing to utilize a concrete
retaining wall when constructing the parking lot, versus requesting a larger impact to
accommodate fill slope. In addition, the Applicant has designed the proposed expansion
project so that the new fuel pumps are situated within the existing fill pad. This will
assist in reducing the potential that spills or leaks would impact the neighboring wetlands,
should the new pumps have been placed in their alternate location. In an effort to reduce
impacts to jurisdictional features, the majority of the fill requested by the Applicant, 0.70
acre, is necessary to create a safe haven for the trucking fleet, and is the minimum amount
of fill necessary to accommodate parking for tractor-trailers. The Applicant is proposing
to create 80 foot parking spaces, as the overall average length of an eighteen wheeler is
between 70 and 80 feet.' Information obtained from the Truckers Report, concerning the
turning radius of tractor-trailers compared to the minimum road width, can be found on
the table below:'
Maximum Angle Mjnimum Road Width
30° 16'6",
60° 24'6"
90° 2710"
120° 27'0»
150° 35'0"
180° 33+091
Table 1: wit milretn?c6ersreoort comlturning radins for eighteen wheelers shim!
5 The Truckers Report Watts, Kevin R. Big Sandy, Tennessee. 2006. www.thetruckersrenort.com
42 I Truck Stop Ir C 14/2 I
SEGO
The remaining 0.02 acre of requested wetland impact is necessary to create vegetative
filters, as required by State Stormwater standards, and also to incorporate a dumpster pad.
Proposed Compensatory Mitigation
Due to the lack of a mitigation bank within New Hanover County, the immediate vicinity of the
project, or the same drainage basin, compensatory mitigation for wetland impacts associated with
the expansion of the Scotchman #303 is being sought through a combination of mitigation
mechanisms. The Applicant is proposing a combination of payment to the North Carolina
Ecosystem Enhancement Program (NC EEP), and the strict preservation of the remaining on-site
wetlands, as mitigation for the proposed impacts.
. Payment to NC EEP:
Pursuant to the Army Corps of Engineer's new rules regarding Compensatory Mitigation
for Losses of Aquatic Functions, baseline information regarding the impact sites, as well
as the determination of credits, will be the only two of the twelve components of
mitigation discussed with regard to NC EEP:
Baseline Information: The wetlands on-site can be classified as freshwater
marsh wetlands. The wetlands are vegetated with a monotypic stand of
Phragmites australis. Freshwater marshes are semi-permanently to permanently
inundated or flooded, and develop where standing water is generally present
throughout the year, so that trees cannot become established. They are common
in the outer coastal plain, and are valuable for storing water and protecting water
quality. Their plants retain and filter sediments, thereby reducing pollutants.
Freshwater marshes stabilize shorelines and prevent bank erosion and siltation.
Freshwater marshes are not generally known for their rare species, though they do
provide habitat for a number of common species)
Indicators of hydrology include inundation, and a prevalence of species with an
indicator status that was wetter than facultative. Saturated soil was found at 12
inches below the surface.
Two soil types were mapped within the Soil Survey of New Hanover County,
North Carolina (see Attachment 11). According to the mapped survey, the two
types of soil are classified as Dorovan soils and Urban land:
Dorovan soils are nearly level, poorly drained soils that are found in bays and
long, broad areas of tidal and stream floodplains. These soils are frequently
flooded for very long periods of time. The soils is known to subside if
I A Field Guide to North Carolina Wetlands. Department of Environment, Health and Natural Resources Division of
Environmental Management, January 1996.
421 True: Stop Ir (1 5/21 )
drained and tilled.2
5F-G1
Urban land is classified as areas where the original soil has been cut, filled
graded or paved so that most of the soil properties have been altered to the
extent that the soil series is not recognized. Areas that fall within the mapped
areas of Urban land are primarily used as shopping centers, factories,
buildings, apartments, etc. The soil is covered by pavement.Z
Determination of Credits: Payment to NC EEP is offered at a 2.08:1 ratio, for
riparian wetland impacts (see Attachment 13). This ratio was chosen because the
Corps' guidelines state there should be no net loss of wetlands, and the Applicant
feels that providing a ratio of 2.08:1 will ensure that the "no net loss" guideline is
met. The proposed the ratio should also ofd set the temporal losses which may
occur, due to any time lag between NC EEP agreeing to perform the mitigation,
and the mitigation efforts actually being undertaken. The stormwater
management facilities proposed for the site will filter out pollutants from runoff
and rehydrate the wetlands, thereby off-setting the proposed impacts.
According to NC EEP's website, "EEP facilitates responsible economic development
across North Carolina by offsetting unavoidable damage to the environment. EEP
manages the restoration and enhancement of streams and wetlands statewide in [the] In-
Lieu Fee program. Through which the state contracts with private-sector companies to
perform the needed ofd sets." Payment to NC EEP, in an amount sufficient to off set the
proposed impacts, will assist the Applicant in achieving the "no net loss" of wetlands
policy set forth by the Corps. The freshwater marsh wetland functionality, flood storage
and pollutant removal, will be off-set by the stormwater management facilities. The
Applicant's stormwater plan calls for sand filters and vegetated filters, which will filter
out pollutants from runoff and rehydrate the wetlands. Freshwater marsh wetlands are
not generally known for their rare species, though some common wildlife, such as deer,
fox, raccoon, waterfowl and amphibea have been known to utilize this wetland type. Due
to the fact that this freshwater marsh wetland complex is located adjacent to a highly
traveled roadway, SEGi does not anticipate a significant impact to the habitat value of the
wetland.
Pursuant to the Memorandum of Understanding between NC EEP (a division of NC
DENR) and the USACE, once payment is made to the NC EEP, they are then responsible
for the compensatory mitigation specified within the issued USACE permit, in this case,
compensation to adequately off-set the loss of 0.72 acre riparian wetlands. The Applicant
will be purchasing 1.5 acres of riparian mitigation credit, at a cost of approximately
$89,400 (Eighty Nine Thousand Four Hundred Dollars).
2 Soil Survey of New Hanover County. North Carolina United States Department of Agriculture, April 1977.
421 Truck Stop IF [ 16/21 ]
G 1
5r-,
• Preservation of Remaining On-site Wetlands:
In accordance with the Corps' new Compensatory Mitigation rules, the twelve
components of mitigation will be discussed, with regard to the proposed preservation
area:
Objectives: The Applicant will be preserving the remaining on-site freshwater
marsh wetlands, totaling 0.20 acre (8,881 square feet).
Preservation is a mechanism utilized by the Corps, which protects remaining on-
site wetlands in perpetuity by using appropriate restrictions or covenants. These
restrictions prohibit harmful activities that might otherwise jeopardize the purpose
and function of remaining wetlands. These restrictions include: no filling; no
grading; no construction of walkways, roads, etc.; no activities which may alter
on-site drainage patterns; and, no alteration of vegetation on the property.
Preservation is a necessity in this area, as recent urban impacts within, and
adjacent to, the conservation site increase the need for preserving wetland
functions. The completion of the Isabelle S. Holmes bridge has increased the
traffic flow along that length of US421, which has in turn made the area more
attractive to business owners. Preservation of this land will provide a significant
vital resource protection in the Cape Fear River basin. The preservation easement
will be designed to ensure perpetual protection of the wetlands and will be
binding to the property (see Attachment 12).
Site Selection: As stated in the previous section, recent urban impacts within and
adjacent to the conservation site, as well as the increase in traffic associated with
the completion of the Isabelle Holmes bridge, augment the need for preserving
wetland functions. The preservation area will be located on the subject parcel,
which is adjacent to the Northeast Cape Fear River. Though the site does not abut
the river, it is located extremely close to the waterbody. Any wetland
preservation proposed in close proximity to the river will be advantageous to the
feature because the preserved wetlands will serve a multitude of beneficial
purposes: filtration of pollutants from run-off; fish and wildlife habitats; natural
water quality improvements; flood storage; shoreline erosion protection; and,
reducing potential for flood damage, among other functions.
Site Protection Instrument: Preservation will be accomplished by utilizing the
Model Declaration of Restrictions, found on the Army Corps of Engineer's
website, and recording the document and associated exhibit map with the New
Hanover County Register of Deeds (see Attachments 6 and 12). The Model
Declarations are enforceable by the United States Army Corps of Engineers. The
site protection instrument will run with the subject property and be binding on all
421 Truck Stop IF 11712 1l
SEGO
parties that have, or shall have, any right, title, or interest in the property.
Baseline Information: The wetlands on-site can be classified as freshwater
marsh wetlands. The wetlands are vegetated with a monotypic stand of
Phragmites australis. Freshwater marshes are semi-permanently to permanently
inundated or flooded, and develop where standing water is generally present
throughout the year, so that trees cannot become established. They are common
in the outer coastal plain, and are valuable for storing water and protecting water
quality. Their plants retain and filter sediments, thereby reducing pollutants.
Freshwater marshes stabilize shorelines and prevent bank erosion and siltation.
Freshwater marshes are not generally known for their rare species, though they do
provide habitat for a number of common species.'
Indicators of hydrology include inundation, and a prevalence of species with an
indicator status that was wetter than facultative. Saturated soil was found at 12
inches below the surface.
Two soil types were mapped within the Soil Survey of New Hanover County
North Carolina (see Attachment 11). According to the mapped survey, the two
types of soil are classified as Dorovan soils and Urban land:
Dorovan soils are nearly level, poorly drained soils that are found in bays and
long, broad areas of tidal and stream floodplains. These soils are frequently
flooded for very long periods of time. The soils is known to subside if
drained and tilled.'
Urban land is classified as areas where the original soil has been cut, filled
graded or paved so that most of the soil properties have been altered to the
extent that the soil series is not recognized. Areas that fall within the mapped
areas of Urban land are primarily used as shopping centers, factories,
buildings, apartments, etc. The soil is covered by pavement.'
Determination of Credits: The ratio of preservation is limited by the amount of
wetlands available for preservation on the subject parcel. Overall, 0.20 acre of
wetlands will be placed into preservation.
The Applicant owns two additional properties in New Hanover County, located at
7111 and 7113 Wrightsville Avenue. These properties already contain a gas
station and convenience store, and have no visible wetlands to offer as additional
preservation (see Attachment 16).
1 A Field Guide to North Carolina Wetlands Department of Environment, Health and Natural Resources Division of
Environmental Management, January 1996.
2 Soil Survey of New Hanover County North Carolina United States Department of Agriculture, April 1977.
421 Truck cJ' top IF [ 18/21
5r-G,
Therefore, the preservation ratio was determined, and limited, by the amount of
remaining wetlands on-site. The overall preservation ratio proposed for this
project is approximately 0.28:1.
Mitigation Work Plan: The boundaries of the preservation area were
determined by contracting a surveyor to obtain the metes and bounds of the
wetlands to be preserved. As the Applicant is offering preservation, not
restoration, enhancement or establishment, the remaining information requested
in this section is not applicable to the mitigation offer proposed for this project.
Maintenance Plan: A maintenance plan should not be required for preservation,
as the restrictive covenants and associated exhibit map, to be recorded in the New
Hanover County Register of Deeds, should be specific enough with regard to
permissible and prohibited actions within preservation areas, and should ensure
the wetlands remain in their natural condition (see Attachment 12).
Performance Standards: The performance standards have been included in the
model declaration of restrictions. Adherence to the restrictions, covenants and
conditions within the model declaration of restrictions will ensure the
compensatory mitigation area is achieving its objectives.
Monitoring Requirements: Visual inspection of the preservation area should be
sufficient to determine if the components of the restrictive covenants are being
adhered to. The restrictive covenants, to be recorded, allow for the "Corps, its
employees and agents and its successors and assigns, [to] have the right, with
reasonable notice, to enter the Property at reasonable times for the purpose of
inspecting the Property to determine whether the Declarant, Declarant's
representatives, or assigns are complying with the terms, conditions and
restrictions of this Conservation Declaration." The Corps retains the right to
inspect the preservation area, thus, if the restrictions within the preservation
document are not being adhered to, the United States of America has the right to
seek legal ramifications.
Long-term Management Plan: The recordation of the restrictive covenants will
serve as the long-term management plan. According to the restrictions, "This
Declaration is intended to ensure continued compliance with the mitigation
conditions of authorizations issued by the United States of America, US Army
Corps of Engineers, Wilmington District, and therefore may be enforced by the
United States of America. This covenant is to run with the land and shall be
binding on all parties and persons claiming under the Declarant." Once recorded,
the document is binding on all parties claiming under it, thus, deviation from the
restrictions could result in prosecution by the United States of America.
421 Truck Stop IF [ 19/2 1
SF-G+
Adaptive Management Plan: An adaptive management plan should not be
necessary for the proposed preservation area. The Applicant anticipates the
preservation area will succeed, as the methods of protection put into place,
namely, recordation of the restrictions, will ensure perpetual preservation of the
remaining on-site wetlands. If the District Engineer determines that a deficiency
has arisen in the preservation area, then steps will be taken to remediate the
situation, either restoration of the resource or payment to the NC EEP in an
amount sufficient to off-set the deficient preservation area. Remediation, on
behalf of the Applicant, will occur only in the event that man-made activities,
taking place within the property boundaries, cause the decline in function of the
systems being preserved.
Financial Assurances: Financial assurances should not be necessary for the
proposed preservation area. The preservation mechanism, recorded with the New
Hanover County Register of Deeds, should provide a high level of confidence that
the mitigation area will be preserved in perpetuity.
42 ! Truck Stop IF [20/21 ]
Adjacent Property Owners
Sr-6I
The subject parcel does not adjoin a waterbody. The property to the north and east is owned by
Eagle Island LTD. The parcel to the south is owned by Holmesbridge LLC, and the property to
the west of the subject parcel is owned by Mr. Robert L. Bryden and Ann Stapleton.
Eagle Island LTD
3330 River Road
Wilmington, NC 28412
Hohnesbridge LLC
2019 Fairview Road
Raleigh, NC 27608
Robert L. Bryden &
Ann Stapleton
515 North 5'h Street
Wilmington, NC 28401
Other Authorizations
The proposed project will require other permits, as shown below:
i'rOther uthoriz bons F 5 k }_?:"

Type Agency Date Issues (11) or Applied For (A)
401 Water Quality Certification NC Division of Water Quality Applying for concurrently with EP
State Stormwater Permit NC Division of Water Quality Modification being applied for by Coastal Site
Design
County Stormwater Permit New Hanover County Modification being applied for by Coastal Site
Design
Sedimentation & Erosion Control NC DENR Division of Land Modification being applied for by Coastal Site
Resources Design
Wastewater NPDES Permit NC DENR Surface Water Issued: 04 April 2008
N00065307 Protection
42 ! Truck jtop I; (21/2111sr-61
Figures
Figure 1.
Data obtained from Google Maps
Figure 2.
Data obtained from maps.live.com
Figure 3.
Data obtained from Brunswick County GIS
Figure 4.
Data obtained from Google Maps
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