20190009 Ver 1_More Info Received_20190322

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P I L O T E N V I R d N M E N T A L. I N C
March 22, 2019
U.S. Army Corps of Engineers
Attn: Mr. Bryan Roden -Reynolds
Charlotte Regulatory Office
8430 University Executive Park Drive
Charlotte, North Carolina 28262
North Carolina Division of Water Resources
Attn: Ms. Sue Homewood
Winston Salem Regional Office - 401 Wetlands Unit
450 West Hanes Mill Road
Winston Salem, North Carolina 27105
Reference: Response to NCDEQ-DWR Request for Information
NWP 12 Verification Request SAW -2019--00032
NCDEQ-DWR 401 WQC Request 20190009
Sedge Hollow Residential Subdivision
Sedge Garden Road
Kernersville, Forsyth County, North Carolina
Pilot Project 2066.4
Dear Mr. Roden -Reynolds and Ms. Homewood:
Mr. Greg Garrett with Shugart Enterprises, LLC (Applicant) received a letter dated February 5,
2019 from the North Carolina Department of Environmental Quality — Division of Water
Resources (NCDEQ-DWR) requesting additional information for the above referenced
Nationwide Permit (NWP) 12 Verification and 401 Water Quality Certification (WCQ) request.
The applicant has previously provided response to U.S. Army Corps of Engineers (USCE) and
NCDEQ-DWR requests on January 22, 2019, January 30, 2019 and January 31, 2019.
The purpose of this letter is to address the stated concerns and February 5, 2019 request for
additional information from NCDEQ-DWR. The received request and Applicant responses are
shown below.
NCDEQ-DWR Comment # 1
You have indicated that the City of Winston Salem will not approve either an aerial gravity line
(as proposed) or a pump station. In correspondence with the City the Division has determined
that the City will not accept future responsibility for an aerial gravity line as proposed due to the
PO Box 128, Kernersville, NC 27285

Response to NCDEQ-DWR Request
Pilot 2066.4
March 22, 2019
height of the line, or for a pump station for a private development. The City has indicated that
either option would be allowed as privately built and maintained collection system components.
In order to meet 15A NCAC 02H .0506(f) you must provide further analysis and/or documentation
that "there is a lack of practical alternatives 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 that would avoid or result in less adverse
impacts to surface waters or wetlands." Please note that greater financial profit is not part of
the criteria outlined by this regulation.
Applicant Response
The Applicant has previously provided information related to up front design planning in which
the Applicant attempted to avoid impacts to WoUS by obtaining an easement. The Applicant has
been unsuccessful in obtaining an easement on at least three separate occasions. Other
alternatives evaluated by the Applicant to avoid WoUS would include the installation of a private
pump station and proposed sewer line that would connect to existing sewer infrastructure along
Sedge Garden Road. This is not a practical alternative because the proposed pump station and
line would be privately owned and maintained bythe residential home owners association (HOA).
The HOA is a private entity that is not familiar with pump station maintenance requirements,
sewer line maintenance or repairs. Should a sewer line failure or repair be needed, then the
home owners would be financially and legally responsible for the failure and repair. This
alternative would increase individual landowner liabilities and cost of living.
Another alternative evaluated by the Applicant is a private aerial crossing in similar location as
what has been proposed. This is not a practical alternative due to being privately owned and
maintained by the HOA, similar to the use of the pump station alternative as stated above.
Additionally, the height of the proposed aerial sewer line presents safety and maintenance
concerns that would likely contribute to further complications for the HOA to provide long term
maintenance and if needed repairs.

Response to NCDEQ-DWR Request
Pilot 2066.4
March 22, 2019
The Applicant has evaluated all practical alternatives to avoid impacts to WoUS to provide sewer
services to site. As proposed, the most practical alternative would allow for the City of Winston
Salem to maintain the proposed sewer line to protect the individual liabilities and costs of the
individual landowners of the residential subdivision. Based on the above and previously provided
information, the Applicant requests the NCDEQ-DWR and USACE to make a final permit decision.
If there are questions regarding this information or a need for further information, please contact
us at [phone].
Respectfully submitted,
Bradle .Luckey, PWS
Project Manager
/L./ 7
Michael T. Brame, PWS
Principal