20180349 Ver 1_More Info Received_20180516

Homewood, Sue
From: Brad Luckey <[e-mail]>
Sent: Wednesday, May 16, 2018 9:33 AM
To: Bailey, David E CIV USARMY CESAW (US); Homewood, Sue
Subject: RE: [External] RE: Request for additional information; RE: Twin Lakes PCN, Alamance
County; SAW -2018-00284
Attachments: 17-111 Storm Runoff Chart.pdf, 17-111 CF101 - Comment Response Exhibit.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spam.<mailto:[e-mail]>
Good Morning David and Sue,
On behalf of the applicant, please find the below applicant responses to the Division's request for additional
information. Please let me know if you require additional information. Thank you for your assistance.
DWR Comment #1: It has been stated that the road alignment is dependent upon the stormwater management pond
location. Please provide an analysis of other stormwater control measures which could be located elsewhere on the
property and/or may require a smaller footprint within the current location and therefore may allow for realignment of
the proposed road.
Applicant Response: The only location that an alternate stormwater pond could be located is north of the maintenance
facility parking lot (see attached exhibit). The red polygon is an approximation of the size of an alternate stormwater
pond. It is evident that there is insufficient space to site an alternate pond here. In addition to insufficient space, the
elevations in this area are too high for the majority of the parking lot to drain to this location. There are other
stormwater devices that would require a smaller footprint such as bio -cells, sand filters, and proprietary devices,
however all of these alternatives are more expensive to build and maintain, and would be cost prohibitive for the
project. The stormwater pond will provide an added benefit as compared to the alternatives by the attenuation of peak
discharge rates from the site through the range of storms. This is not a design requirement for the pond, however is an
inherent benefit of a pond (see attached chart).
DWR Comment #2: It is noted that the existing road cannot be rerouted around the north side of the stormwater pond
because it is not possible to achieve the minimum curve of radius required. Please indicate why this standard is
necessary as the proposal indicates that this is a maintenance facility rather than as a public road.
Applicant Response: Although the proposed road is private and will be used as an entrance for the maintenance facility,
it will also be used as an additional entrance for the Twin Lakes West Campus area. The road will be used by the same
vehicle types as public roads, therefore the minimum geometric standards that are typically associated with public roads
must be adhered to for safety reasons. The geometric elements include centerline curve radii, profile slopes and cross
slopes. The majority of the drivers on this road will be elderly drivers, which makes the safety aspects of the design even
more important. Another reason that the road cannot be rerouted to the north side of the pond is that there is
insufficient space between the pond and the stream buffer. Even if the geometric design requirements were not a
factor, the road construction would have a significantly greater impact on the stream buffer compared to what is
currently proposed. The existing road would need to be elevated above the 100 -year base flood elevation, and would
need to be widened to accommodate 2 -way traffic. Additionally, the existing culvert crosses the road alignment at a
skew. The combination of these factors would likely result in a greater total stream impact, including the prior impact,
than the proposed realignment, given that the existing culvert will be removed.
1

Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
www.pilotenviro.com
[e-mail]
-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (US)[mai Ito: David. [e-mail]]
Sent: Monday, May 7, 2018 11:11 AM
To: Brad Luckey <[e-mail]>
Cc: Homewood, Sue <[e-mail]>
Subject: RE: [External] RE: Request for additional information; RE: Twin Lakes PCN, Alamance County; SAW -2018-00284
Brad,
Thanks for your email. The Corps shares NCDWR's concerns as submitted by Sue Homewood this morning (below). We
will await the response to these questions prior to rendering our determination of whether or not the project meets the
terms and conditions of NWP 14.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail]
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey is
located at: http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0
Thank you for taking the time to visit this site and complete the survey.
-----Original Message -----
From: Brad Luckey [mailto:[e-mail]]
Sent: Monday, May 7, 2018 10:02 AM
To: Homewood, Sue <[e-mail]>
Cc: Bailey, David E CIV USARMY CESAW (US)<[e-mail]>
Subject: [Non-DoD Source] Re: [External] RE: Request for additional information; RE: Twin Lakes PCN, Alamance County;
SAW -2018-00284
David -do you have additional concerns outside of the below?

Sent from my iPhone
On May 7, 2018, at 9:55 AM, Homewood, Sue <[e-mail] <mailto:[e-mail]> >
wrote:
Brad,
With regards to the response to USACE and DWR questions #1 below, please provide the following additional
information:
1. It has been stated that the road alignment is dependent upon the stormwater management pond location.
Please provide an analysis of other stormwater control measures which could be located elsewhere on the property
and/or may require a smaller footprint within the current location and therefore may allow for realignment of the
proposed road.
2. It is noted that the existing road cannot be rerouted around the north side of the stormwater pond because it
is not possible to achieve the minimum curve of radius required. Please indicate why this standard is necessary as the
proposal indicates that this is a maintenance facility rather than as a public road.
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office
Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. [e-mail]<mailto:[e-mail]>
450 W. Hanes Mill Rd, Suite 300

Winston Salem NC 27105
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
-----Original Message -----
From: Brad Luckey [mailto:[e-mail]]
Sent: Thursday, April 19, 2018 5:41 PM
To: Bailey, David E CIV USARMY CESAW (US) <[e-mail]
<mailto: David. [e-mail]> >; Homewood, Sue <[e-mail]
<mailto:[e-mail]> >
Cc: Michael Brame <[e-mail] <mailto:[e-mail]> >;
rwelborn @twin lakescomm.org <maiIto: rwelborn @twin lakescomm.org> ; Neal Tucker <[e-mail]
<mailto:[e-mail]> >
Subject: [External] RE: Request for additional information; RE: Twin Lakes PCN, Alamance County; SAW -2018-00284
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an
attachment to Report Spam.<mailto:[e-mail] <mailto:[e-mail]> >
Good Afternoon David and Sue,
Thank you for the USACE request for additional information on March 30, 2018 and the DWR request for additional
information on March 27, 2018. The purpose of this email is to provide the requested information to process the NWP
and 401 verifications. Please let me know if this not sufficient address your concerns. Thank you for your assistance.
USACE Comment # 1: Although section D.1a of the PCN does provide some information as to why the proposed
road was not designed within (at least a portion of) the existing driveway stream crossing footprint, the reasoning given
does not justify why the proposed crossing couldn't be designed to incorporate at least a portion of the existing stream
crossing footprint. It appears that the access road alignment could be re -designed to use the existing stream crossing
footprint and still fit the project purpose listed in section B.3d of the PCN. Please update the PCN and plans to
incorporate the existing stream crossing footprint to further minimize impacts to waters of the US (per NWP General

Conditions 23(a) and (b). Or, provide additional justification for the current design, addressing the practicability of using
the existing crossing to further minimize impacts to waters of the US. Please note that the future park area shown on
the Overall Site Plan does not appear to be essential to the project purpose.
NCDEQ-DWR Comment # 1: Can you expand in further detail on why the existing road can't be used. I don't
understand the statement in the PCN "due to current road alignment and necessary proposed site development". It
would help to see the existing road and culvert shown on the overall site plan. If they can't use the road can they
propose culvert removal and restoration of that road?
Applicant Response: The updated attached drawings shows the location of the existing culvert. As shown, the
existing road extends through the proposed stormwater pond and proposed Phase II park. The proposed stormwater
pond, which is required by the City of Burlington and the Town of Elon, is located in the only place where it will fit on the
site. The existing road cannot be re-routed around the south side of the stormwater pond due to there being
insufficient space between the pond cut slope and the Church Street right-of-way. If sufficient space was available then
the access road would tie into the entrance driveway outside of the security gate, which would leave this campus
entrance unsecured, which is unacceptable to the Owner and occupant safety. Additionally, NCDOT would not allow a
driveway connection to the main drive that close to Church Street (less than 100 feet) for safety reasons. The existing
road cannot be rerouted around the north side of the stormwater pond because it is not possible to achieve the
minimum curve radius required (150 feet) on the road and avoid the stormwater pond while maintaining use of the
existing culvert location. Deviating from the existing road alignment a sufficient amount to avoid the stormwater pond
will pull the road away from the existing culvert such that it completely misses the culvert, resulting in possibly greater
stream impact due to the new alignment crossing the stream at a skew.
USACE Comment #2: The proposed wetland crossing would bisect a relatively small wetland area, and the Corps is
concerned about secondary and cumulative impacts to this resource. Please provide the acreages of each wetland unit
that would remain if this design was authorized. How would hydrology be maintained in each wetland unit? If these
wetland areas cannot be reasonably expected to maintain their functional quality following construction of this design,
you must provide additional compensatory mitigation for this loss of wetland function.
Applicant Response: During design of the crossing, it was determined that two wetland polygons which total 316 SF
would remain un -impacted by fill for the proposed road crossing. Therefore, the applicant elected to consider the 316
SF of wetlands "as take" and incorporated the 316 into their proposed permanent impact amount and mitigation
proposal.
USACE Comment #3: As discussed previously, a search in our database has revealed no previous permits on the
Twin Lakes property. However, the Corps field verified a wetland/stream delineation (performed by S&ME) on the
property on 2/19/2004 (Action ID: SAW -2004-20375; see attached). Based on the information in this file, as well as an
aerial photo search, the existing driveway stream crossing was constructed between 2004 and 2008, and apparently
without obtaining written verification from the Corps. Per this information, it appears that this road crossing resulted in
approximately 60 linear feet of stream impacts and 0.09 acre of wetland impacts. Please note that the Corps will
consider these impacts cumulative when evaluating Nationwide Permit and compensatory mitigation thresholds.

Applicant Response: The applicant has updated proposed plans to include removal of the existing culvert and
restoration of the stream banks and bed previously impacted by the existing culvert. The attached overall drawing
includes details of the culvert removal and stream restoration. Following culvert removal, stream banks will be restored
by laying back the banks on a 3:1 or flatter slope, seeding, matting and live staking. Based on the culvert slope (less than
1%), the applicant proposes that grade control structures are not necessarily. The area of the restored stream will tie
directly into grade of the un -impacted portions of the stream.
Due to the fact that the 0.09 acres of wetlands that was impacted by the existing road crossing was previously
located in a drained pond basin and given the amount of fill that has been placed over the wetlands (approximately 10-
12' of fill), it is the opinion of the applicant that it would be difficult to achieve a successful wetland restoration.
Therefore, the applicant proposes to amend their mitigation proposal to mitigate for the 0.09 acres of wetlands that
were previously impacted by the existing road crossing at a 1:1 ratio. Updated response letters from a private bank and
NCDMS that confirm necessary credits are available for purchase are included as attachments.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285
Blockedwww.pilotenviro.com <Blockedhttp://www.pilotenviro.com>
[e-mail] <mailto:[e-mail]>
-----Original Message -----
From: Bailey, David E CIV USARMY CESAW (US) [mai Ito: David. [e-mail]
<mailto: David. [e-mail]> ]
Sent: Friday, March 30, 2018 2:48 PM
To: Brad Luckey <[e-mail] <mailto:[e-mail]> >; [e-mail]
<maiIto: rwelborn @twin lakescomm.org>
Cc: Michael Brame <[e-mail] <mailto:[e-mail]> >; Homewood, Sue
<[e-mail] <mailto:[e-mail]> >

Subject: Request for additional information; RE: Twin Lakes PCN, Alamance County; SAW -2018-00284
on
Thank you for your PCN and attached information, dated and received 3/6/2016, for the above referenced project. I
have reviewed the information and need clarification before proceeding with verifying the use of Nationwide Permit 14
(Blockedhttp://saw-reg.usace.army.mil/NWP2017/2017NWP14.pdf <Blockedhttp://saw-
reg.usace.army.mil/NWP2017/2017NWP14.pdf> ). Please submit the requested information below (via e-mail is fine)
within 30 days of receipt of this Notification, otherwise we may deny verification of the use of the Nationwide Permit or
consider your application withdrawn and close the file:
1) Although section D.1a of the PCN does provide some information as to why the proposed road was not designed
within (at least a portion of) the existing driveway stream crossing footprint, the reasoning given does not justify why
the proposed crossing couldn't be designed to incorporate at least a portion of the existing stream crossing footprint. It
appears that the access road alignment could be re -designed to use the existing stream crossing footprint and still fit the
project purpose listed in section B.3d of the PCN. Please update the PCN and plans to incorporate the existing stream
crossing footprint to further minimize impacts to waters of the US (per NWP General Conditions 23(a) and (b). Or,
provide additional justification for the current design, addressing the practicability of using the existing crossing to
further minimize impacts to waters of the US. Please note that the future park area shown on the Overall Site Plan does
not appear to be essential to the project purpose;
2) The proposed wetland crossing would bisect a relatively small wetland area, and the Corps is concerned about
secondary and cumulative impacts to this resource. Please provide the acreages of each wetland unit that would remain
if this design was authorized. How would hydrology be maintained in each wetland unit? If these wetland areas cannot
be reasonably expected to maintain their functional quality following construction of this design, you must provide
additional compensatory mitigation for this loss of wetland function;
3) As discussed previously, a search in our database has revealed no previous permits on the Twin Lakes property.
However, the Corps field verified a wetland/stream delineation (performed by S&ME) on the property on 2/19/2004
(Action ID: SAW -2004-20375; see attached). Based on the information in this file, as well as an aerial photo search, the
existing driveway stream crossing was constructed between 2004 and 2008, and apparently without obtaining written
verification from the Corps. Per this information, it appears that this road crossing resulted in approximately 60 linear
feet of stream impacts and 0.09 acre of wetland impacts. Please note that the Corps will consider these impacts
cumulative when evaluating Nationwide Permit and compensatory mitigation thresholds.
Please let me know if you have any questions.

-Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE -SAW -RG -R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: David. [e-mail] <mailto: David. [e-mail]>
We would appreciate your feedback on how we are performing our duties. Our automated Customer Service Survey
is located at: Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0
<Blockedhttp://corpsmapu.usace.army.miI/cm_apex/f?p=136:4:0>
Thank you for taking the time to visit this site and complete the survey.
-----Original Message -----
From: Brad Luckey [mailto:[e-mail] <mailto:[e-mail]> ]
Sent: Tuesday, March 6, 2018 1:01 PM
To: Bailey, David E CIV USARMY CESAW (US) <[e-mail]
<mailto: David. [e-mail]> >; Homewood, Sue <[e-mail]
<mailto:[e-mail]> >
Cc: Michael Brame <[e-mail] <mailto:[e-mail]> >
Subject: [Non-DoD Source] Twin Lakes PCN, Alamance County - Electronic Copy

David and Sue,
Please find attached electronic copy of the Twin Lakes PCN. Hard copies and appropriate fees will be mailed today
to both agencies. Please note that I believe we currently have 2-3 mitigation SOAs for the remainder of the Cripple
Creek wetland credits. Other private banks in Haw, 02 HUC do not have credits available. So, in the likely event private
credits are not available for this project, I went ahead and requested full amount of credits from DMS. If they are
available, then it will be a mix and match from Cripple Creek and DMS. Just wanted to bring to your attention since we
currently have at least two PCNs in right now with this type of split mitigation proposals.
Please let me know if you have any questions or concerns. Thank you for your assistance.
Sincerely,
Bradley S. Luckey, PWS
336.708.4997 (c)
336.310.4527 (o)
PO Box 128
Kernersville, NC 27285

Blockedwww.pilotenviro.com <Blockedhttp://www.pilotenviro.com> <Blockedhttp://www.pilotenviro.com/
<Blockedhttp://www.pilotenviro.com/> >
[e-mail] <mailto:[e-mail]> <mailto:[e-mail]
<mailto:[e-mail]> >
10

17-111 Twin Lakes Maintenance Facility
Peak Discharges
(CFS)
Storm Event
Pre-Dev
Post-Dev
Routed
1 Year
1.45
5.12
1.14
2 Year
2.68
7.26
2.10
5 Year
4.88
10.45
4.72
10 Year
6.79
12.98
6.27
25 Year
9.53
16.43
10.40
50 Year
11.76
19.12
13.71
100 Year
14.10
21.83
17.01

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-Z �%// I \ TW: 615, 48
CP CP , I1 / INV 604.79 a / GREENSBORO, 6 27409
CONC. ` / / / ij° [phone]
GRAVEL _B I / S C U CH ST -L ---1--L- - \ \ /w �°'
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-YP.
DRIVE �! a - - ��- - /3 1 - - -� - -/ - - - {6 gee
R W PER DB 3572 PG 807 T/C 634.67 S 1 / / U.S.HIGHWAY °\ 1 R/W
15 RCP OUT �- ; I 50 0 50 100
630. 55 \-RIM 633. �1 / PUBLIC R/W VARI _
TBM INV 625. 051 - ""-' R/W PER PB 75 PG 109 `
SITE BENCHMARK:
TOP OF CATCH INLET R/W
ELEV = 634.67'
North SCALE: 1" = 50'
150
JOB. NO: 17-111
SHEET TITLE:
OVERALL
STORMWATER
MANAGEMENT
PLAN
SCALE: 1 "=50'
SHEET NO.:
CF101
© STIMMEL ASSOCIATES, P.A.