20090136 Ver 1_More Info Received_20090514

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NCDENR Division of Water Quality
Attn: Cyndi Karoly
401 Oversight Express Review Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27604
Subject Property: Dunn Creek Greenway, Wake Forest, NC
UT to Smith Creek [030402, 27-23-(2), C, NSW]
Dear Ms. Karoly:
Thank you very much for your reconsideration of our application and follow up letter of May 4, 2009. We
are pleased to provide you with the additional information requested and sincerely hope that our design is
sound and provides the Division of Water Quality with the confidence necessary for granting a permit for
construction.
While trails are allowed in the buffer, we share the goal of protecting riparian buffers and made choices to
accommodate construction activities associated with the trail in a manner that minimizes the removal of
woody vegetation, the extent of the disturbed area, and the time in which areas remain in a disturbed
state. We would be pleased to take you on a tour of the site to better explain the choices made. Please
also see the attached image with a composite of the proposed trail and photographs taken on May 9, 2009.
Also, please see the attached image showing the request to provide the approximate location of the trail in
relation to the approved Holding Village Master Plan.
It is our hope that you find that the trail is appropriately located and offer the following extended details
describing the five locations referenced in your letter of May 4, 2009.
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401 Elm Avenue • Wake Forest, NC 27587-2932
Phone: [phone] • Fax: [phone] • www.wakeforestnc.gov
[OW1101
Wake Forest
North Carolina
STA 14-15: The trail is located on land owned by the Town of Wake Forest, adjacent to private property. Your
letter requested information to explain why the trail can't be slid further onto Lots 658 and 659 to avoid zone 2 buffer
disturbances in the amount of 600 square feet. However, the Town holds no interest in the privately owned properties
in question. Lot 658 is developed with an occupied single family residence. The homes in this subdivision are generally
being constructed with the rear of the house on the floodplain line. While the fill slopes are relatively gentle in this
area, the slopes get steeper as the trail extends northward.
The proposed trail location is situated as far away from the buffer as possible within the Town's rights-of-way. This was
accomplished with the additional cost of boardwalk sections to clear wet areas at the toe of the slope, rather than
sliding the trail upland on the sewer easement, into the buffer where the extent would be greater in zone I and zone 2.
Please note in the supporting images that the trail is located adjacent to the private property line, rather than
continuing along the sewer easement where the total impact areas would be greater in zone I and zone 2. The images
show that the houses are built on fill slopes and the buffer to the east is higher than the land where the trail is
proposed.
To shift the trail further to the west, the Town would be required to acquire additional rights-of-way to facilitate the
placement of the trail in the back yards of private homeowners. There would be significant opposition from the
homeowners. It would also delay the project and add significantly to the cost of the project, without affording
additional protection to the riparian buffers. Fortunately, as may be seen in the photographs associated with STA 14-
15, the proposed trail location is in a clearing where there is no need for removal of woody vegetation, there is no
additional disturbance to riparian buffers, and construction activities and disturbance are minimized. It is our request
that you find that that the trail is appropriately located.
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2. STA 16-17: As with the previous section, Wake Forest is not in a position to slide the trail to the west onto private
property. As proposed, the trail impacts 632 square feet in zone 2, but does not involve woody vegetation removal
because the proposed trail is located in a clearing between the manholes and the creek on the east side of the trail and
the private property line on the west side of the trail. Also, in this section, boardwalk is added to provide for access
over wet areas to facilitate the trail at the edge of the private property.
Relocation of the trail to the west would require acquisition of additional rights-of-way, placement of the trail in the
back yards of private property owners, removal of the fence from one of the back yards, removal of woody vegetation,
and a cut slope. Therefore, it is our wish that you find that the trail is appropriately located as proposed in that
construction activities minimize the removal of woody vegetation and the extent of the disturbed area.
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3. $TA 21-24: Wake Forest is not able to move the trail west of the available rights-of-way onto private property and
wet areas. The zone I impacts are 174 square feet and the zone 2 impacts are 1937 square feet, but the trail was
designed and located to be as far from the creek and riparian buffers as possible without impacting wet areas. Please
note that the proposed trail is situated in the clearing, west and off center within the greenway and sewer easement to
reduce the extent of buffer impacts. The trail design additionally minimizes impacts with 65 feet of boardwalk, without
drainage structures. Please see the plan composite with picture call outs showing the trail location between wetland
areas and the buffer to the minimize impacts to each to the greatest extent possible. The photograph of the manhole
was taken from the center of the trail and shows the wide clearing and the buffer marker behind the manhole on the
creek side of the sewer easement.
In contrast, if we were required to shift the trail to the west to reduce the square feet in zone I and 2, the plan would
result in additional cost and impacts due to acquisition of rights-of-way (impacting private property owners), mature
hardwood vegetation removal, cut slopes on lot 668, wet areas on the Town lot (where the neighborhood connecting
trail is proposed), longer boardwalks, and possibly drainage structures. If we meander onto the Town lot to reduce
buffer impacts, we also introduce a curve in the trail that reduces safety for cyclists without eliminating buffer impacts.
It is our wish that you find that the trail is appropriately located with construction activities that minimize the removal
of woody vegetation and the extent of the disturbed area based on the existing conditions, competing concerns, and
design accommodations.
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4. STA 30: Wake Forest proposes placement of the trail within existing easements. However, within those easements,
the trail could be shifted to the west to reduce the 250 square feet of area in zone 2. This shift may necessitate the
removal of mature trees, but within the confines of the bridge location and existing easements, we are able to shift the
trail approximately eight feet to the west. Please see the call out photographs to see the location of the trail in relation
to the manhole and the clearing. It is our preference that we be allowed to preserve the existing vegetation with the
trail location as proposed with a finding from DWQ that the trail is appropriately located in the clearing. However, if
you find that the reduction in square feet in zone 2 is balanced by removal of vegetation and construction in the drip
line, we are willing to shift the trail approximately eight feet to the west in the vicinity of STA 30.

5. STA 52: The trail was positioned in relation to STA 52 based on easements we have in ownership and in a manner
that avoids wet areas. As proposed, there are 31 1 square feet in zone I, and 936 square feet in zone 2, but the area is
already cleared as shown in the photographs. The trail design minimizes impacts with the addition of 175 feet of
boardwalk in wet areas and trail construction without drainage structures. The trail, if shifted to the east in this
location would impact more wet areas, require new fill, require woody vegetation removal, increase the length of the
boardwalk, and would be difficult to accomplish without the addition of drainage structures. Wake Forest has obtained
all of the greenway easements we are able to acquire in this area and has shifted the trail to the east as far as is possible
without increasing negative impacts. It is our desire that you find that the trail is appropriately located and that
construction activities minimize the removal of woody vegetation and the limit extent of the disturbed area based on
the existing conditions.

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STA-52-53
Paperwork has been submitted for Stimulus funding for this project. Therefore, completion of this process
is time sensitive. Please let me know of your availability for a site visit at your earliest convenience. We
appreciate your time and efforts to protect the riparian buffers and your assistance in resolving these last
issues.
Sincerely,
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Susan Simpson
Director
Parks and Recreation Department
Town of Wake Forest
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