20040868 Ver 1_Complete File_20040526

ESP Associates, P.A.
engineering • surveying planning
March 16, 2005
Mr. Alan Johnson
North Carolina Division of Water Quality
Mooresville Regional Office
6100 East Center St., Suite 301
Mooresville, North Carolina 28115
j ICES
J
y -
MAR 17 2005

RE: Withdrawal of Section 401 Water Quality Certification Request for
Arbor Oaks Subdivision in Cabarrus County, North Carolina
DWQ # 04-0868 MAR 2 Z 2005
Dear Mr. Johnson:
L)ENR.
DSAN STQ TER Bkq'CH
Please find enclosed with this letter the following items: kq'CH
1) A letter from the NC Division of Water Quality (NCDWQ) dated June 9, 2004;
2) A letter from the NCDWQ dated February 9, 2005;
3) Survey Map depicting the impact area that was field reviewed, approved, and
permitted by the US Army Corp of Engineers (USACE) in October 2004;
4) Photograph pages depicting the impacts and existing systems; and,
5) US Army Corp of Engineers Nationwide Permit for the Arbor Oaks impacts
approved and dated October 26, 2004.
The purpose of this letter is to provide you with information concerning jurisdictional
impacts and to formally withdraw our request for a Section 401 Water Quality
Certification concerning the above-mentioned project. Following the receipt of your
letter (dated February 9, 2005), ESP personnel visited the site on February 26, 2005
to verify and document the existing impacts. The site was visually inspected for
existing conditions information; however, because the site has been delineated,
surveyed and verified in the past, a jurisdictional delineation was not conducted.
General site conditions, impact area, and photographs were documented according to
information previously recorded for the property. Simonini Builders has completed
their portion of the work for the proposed project and impacts total approximately 75
feet of stream for an existing road crossing.
961 Trinity Road, Raleigh, NC 27607, [phone] Fax [phone]
www.espassociates.com
Mr. Alan Johnson
16 March 2005
As you may recall, this project involved an after-the-fact permit submitted in June
2004 and contained approximately 75 linear feet of stream. At the time additional
proposed impacts to the streams were anticipated. In October 2004 the USACE
visited the site, verified the delineation, and authorized the use of nationwide permit
#39 for 250 linear feet of stream impacts and 0.04 acre of wetland impacts. In
addition, because of the habitat and water quality conditions with the on-site systems,
the USACE did not propose the need for mitigation to these impacts (the majority of
the streams were labeled unimportant). However, after further investigations as well
as design alterations for the proposed development were completed, the final impacts
for the development were limited to the initial 75 feet of stream.
Again, our objective is to formally withdraw our request for a Section 401 Water
Quality Certification concerning the above-mentioned project. Existing impacts
remain at 75 linear feet of stream and are permitted by the USACE for 250 linear
feet. Additional impacts may occur but are not currently proposed and it is
understood that these impacts will be added to the existing impacts for a total anc
complete project. If any additional impacts do occur, they will not exceed 150 feet of
stream and/or 0.1 acre of wetland and NCDWQ will be notified and updated for their
records. Please contact me if you have any questions or need further information.
Thank you for your continued assistance with this project.
Sincerely,
ESP Associates, P.A.

Adam V McIntyre
Natural Resources Department Manager
Cc: Randol Tilghman, Simonini Builders
Enclosures
Page:
CADocuments and SettingstamcintyrelDesktop\Submittal Letter for Arbor Oaks 3-15-0S.doc 2/2
av "'
O ?
wnuam u. moss ir., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 9, 2004
Cabarrus County
DWQ # 04-0868
Mr. Randol Tilghman
Simonini Builders R E C E I V E
817 E Morehead St.
Charlotte, NC 2820.2
....E .z nf,n
Subject: Arbor Oaks Subdivision _
S t? AJSQCIAa.S, c)A..
Dear Mr. Tilghman:
On May 26, 2004, the NC Division of Water Quality (DWQ) received your after-the-fact
application for a General 401 Water Quality Certification for the construction of the Arbor Oaks
Subdivision in Cabarrus County.
On June 1, Mr. Alan Johnson with this office spoke with Mr. Sean Connoly with ESP Associates
regarding the subject subdivision. Mr. Connoly informed Mr. Johnson that a road had been
constructed across a stream and other stream impacts were proposed for the subdivision, and that
the aforementioned after-the-fact Preconstruction Nofication form had been submitted to DWQ for the
project.
Based on Mr. Johnson's and Mr. Connoly's above noted conversation, and subsequent telephone
conversations, the impacts shown on the submitted plan do not agree with the impacts that were
previously discussed. The application shows in addition to the stream/road crossing, that permanent
impacts (fill) are proposed to the wetland and stream on lots #20 and #9. These total impacts would
exceed 300 linear feet of stream channel, thereby requiring an individual permit from the Army Corp
of Engineers.
It is Mr. Johnson's understanding that impacts to the stream would be minimized. However, the
application does not reflect this. It is requested that the following information be provided to this
office:
• Linear feet of stream impacts for each lot.
• Wetland impacts and area for each lot.
• Total impacts.
• Identify channels as intermittent, perennial, or ephemeral.
• Proposed method of mitigation (if required).
Until the DWQ receives requested information, this office is requesting (by copy of this letter) that
the Corps of Engineers place this project on hold. Also, this project will be placed on hold for our
processing pursuant to 15A NCAC 2H .0507(h).
N Carolina 7M
o
; atural " ENWR
!?. . Llv??? n of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (htto://112o.enr.state.nc.us ncwedands)
Customer Service it: 1-877-623-6748
Thank you for your prompt attention to this matter. If you have any questions, please contact
Alan Johnson at [phone] or Cyndi Karoly in Raleigh at [phone].
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
cc: Corps of Engineers-Asheville
Cyndi Karoly - Wetlands Unit
Sean Connolly - ESP
File Copy
Central Files

ot WA
r
O 'C
FE8 - 9 2005
Michael F. Easiey, Qovemor
WIRIAm Q. Raw Jr. Setxeiary
Nanh caroling tk7mmnentorEnvitonmentand Nuturul Reramos
Alan W. Klimek P.12 Dimiar
Olvision of Watcr Quality
February 4, 2005
Cabarrus County
DWQ # 04-0868
CERTIFIED MAIL
Return Receipt Requested
Mr. Randol Tilghman
SimoninI Builders
817 E Morehead St.
Charlotte, NC 28202
Subject Arbor Oaks Subdivision
Dear Mr. Tilghman:
On May 26, 2004, the NC Division of Water Quality (DWQ) received your application for a
General 401 Water Quality Certification for the construction of the Arbor Oaks Subdivision In
Cabarrus County.
On June 1, Mr. Alan Johnson with this office spoke with Mr. Sean Connoly with ESP Associates
regarding the project. Mr. Connoly informed Mr. Johnson that a road had been constructed across
a stream and other stream impacts were proposed for the subdivision. He also advised that an
after-the-fact Preconstruction Nofication form had been submitted to DWQ for the project.
Subsequently, Mr. Johnson conducted an inspection at the site, and on June 8, 2004,'the project
was placed on hold awaiting submittal of modifications to the original plan. As of this date no plan
has been submitted, nor has there been any further communication.
If we do not hear from you within 15 days of receipt of this letter we will, assume you no longer
want to pursue the project and will withdraw the application from consideration. If you' have any
questions, please contact Mr. Johnson at [phone] or Ms. Cyndi Karoly in Raleigh at (919)
733-9721.
Sincerely,
D. Rex Gleason, P. E.
Surface Water Protection
Regional Supervisor
cc: Corps of Engineers-Asheville
Cyndl Karoly - Wetlands Unit
ESP Associates ?}??Utt lt1l
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North Carolina Oivislon of Waw Quality 6100 Eau Ccntcr St.. Sul u; 301 Moor=vl11c. NC 28l l S rhonc (!04) 663.1699 Custamcr Scrvlcc
Intemat: h2canretatammus FAX [phone] t-877.03.6748
An Equal Opponunll/Aelmt7Uvo AWon Emplopor-50% Racyclod110% Post WamorPopor
Arbor Oaks
Subdivision
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Wetland Delineation Date:
Survey Map (NTS) 10-7-04
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Photo 1: The upstream culvert impacts to the existing stream.
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Photo 2: The downstream culvert impacts to the existing stream.

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Photo 3: Standing downstream of the culvert crossing looking upstream.
Photo 4: Standing upstream of the culvert crossing looking upstream towards the
transition of intermittent/perennial

U.S. ARMY CORPS OF ENGINEERS
WILMINGTON DISTRICT
Action ID. 200430778 County: Cabarrus USGS Quad: Kannapolis
GENERAL PERMIT (REGIONAL AND NATIONWIDE) VERIFICATION
Property Owner / Authorized Agent: Mr.. Randol Tilghman
Address: Simonini Builders
817 E. Morehead Street
Charlotte. NC 28202
Telephone No.: 704-358-9940
Size and location of property (water body, road name/number, town, etc.): The project site is located on
the north side of Odell School Road past Untz Road west of Concord Cabarrus County North
Carolina.
Description of projects area and activity: This permit authorizes the installation of cuiverts and
placement of fill associated with the development of Arbor Oaks subdivision Permanent impacts to
stream channels and wetlands authorized by this permit are 0.04 acre of wetlands and 250 linear
feet of stream channel associated with a road crossing and lot fill
Applicable Law: ® Section 404 (Clean Water Act, 33 USC 1344)
? Section 10 (Rivers and Harbors Act, 33 USC 403)
Authorization: Regional General Permit Number:
Nationwide Permit Number: 39
Your work is authorized by the above referenced permit provided it is accomplished in strict accordance with the
attached Nationwide conditions and your submitted plans. Any violation of the attached conditions or deviation
from your submitted plans may subject the permittee to a stop work order, a restoration order and/or appropriate
legal action.
This verification will remain valid until the expiration date identified below unless the nationwide authorization
is modified, suspended or revoked. If, prior to the expiration date identified below, the nationwide permit
authorization is reissued and/or modified, this verification will remain valid until the expiration date identified
below, provided it complies with all requirements of the modified nationwide permit. If the nationwide permit
authorization expires or is suspended, revoked, or is modified, such that the activity would no longer comply with
the terms and conditions of the nationwide permit, activities which have commenced (i.e., are under construction) or
are under contract to commence in reliance upon the nationwide permit, will remain authorized provided the activity
is completed within twelve months of the date of the nationwide permit's expiration, modification or revocation,
unless discretionary authoray has beer. exercised on a case-by-case basis to modify, suspend or revoke the
authorization.
Activities subject to Section 404 (as indicated above) may also require an individual Section 401 Water Quality
Certification. You should contact the NC Division of Water Quality (telephone [phone]) to determine
Section 401 requirements.
For activities occurring within the twenty coastal counties subject to regulation under the Coastal Area
Management Act (CAMA), prior to beginning work you must contact the N.C. Division of Coastal Management.
This Department of the Army verification does not relieve the permittee of the responsibility to obtain any other
required Federal, State or local approvals/permits.
If there are any questions regarding this verification, any of the conditions of the Permit, or the Corps of
Engineers regulatory program, please contact Amanda D. Jones at 828-271-7980 x231.

Corps Regulatory Official Amanda D. Jones Date: October 26, 2004
Expiration Date of Verification: October 26, 2006
-2-
Determination of Jurisdiction:
? Based on preliminary information, there appear to be waters of the US including wetlands within the above
described project area. This preliminary determination is not an appealable action under the Regulatory
Program Administrative Appeal Process ( Reference 33 CFR Part 331).
? There are Navigable Waters of the United States within the above described project area subject to the permit
requirements of Section 10 of the Rivers and Harbors Act and Section 404 of the Clean Water Act. Unless
there is a change in the law or our published regulations, this determination may be relied upon for a period not
to exceed five years from the date of this notification.
® There are waters of the US and/or wetlands within the above described project area subject to the permit
requirements of Section 404 of the Clean Water Act (CWA)(33 USC § 1344). Unless there is a change in the
law or our published regulations, this determination may be relied upon for a period not to exceed five years
from the date of this notification.
? The jurisdictional areas within the above described project area have been identified under a previous action.
Please reference jurisdictional determination issued _. Action ID
Basis of Jurisdictional Determination: Wetlands exhibit ordinary high water mark. Stream channels are
unnamed tribs to Back Creek which flows into the Rocky River in the Yadkin River Basin.
Corps Regulatory Official: Amanda D. Jones
Date October 26, 2004
SURVEY PLATS, FIELD SKETCH, WETLAND DELINEATION FORMS, PROJECT PLANS, ETC.,
MUST BE ATTACHED TO THE FILE COPY OF THIS FORM, IF REQUIRED OR AVAILABLE.
Copy Furnished:
Joanne Lewis, ESP Associates, PO Box 7030, Charlotte, NC 28241
(j,oLa- )
O?O? W AT ?9QG
r
6 nd:;
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
February 4, 2005
Cabarrus County
DWQ # 04-0868
CERTIFIED MAIL
Return Receipt Requested
Mr. Randol Tilghman
Simonini Builders
817 E Morehead St.
Charlotte, NC 28202
Subject: Arbor Oaks Subdivision
Dear Mr. Tilghman:
?D
FE a
e 8 - 2005
DEhR - WATER QU
SAND STORI, 4 R8TH
On May 26, 2004, the NC Division of Water Quality (DWQ) received your application for a
General 401 Water Quality Certification for the construction of the Arbor Oaks Subdivision in
Cabarrus County.
On June 1, Mr. Alan Johnson with this office spoke with Mr. Sean Connoly with ESP Associates
regarding the project. Mr. Connoly informed Mr. Johnson that a road had been constructed across
a stream and other stream impacts were proposed for the subdivision. He also advised that an
after-the-fact Preconstruction Nofication form had been submitted to DWQ for the project.
Subsequently, Mr. Johnson conducted an inspection at the site, and on June 8, 2004, the project
was placed on hold awaiting submittal of modifications to the original plan. As of this date no plan
has been submitted, nor has there been any further communication.
If we do not hear from you within 15 days of receipt of this letter we will assume you no longer
want to pursue the project and will withdraw the application from consideration. If you have any
questions, please contact Mr. Johnson at [phone] or Ms. Cyndi Karoly in Raleigh at (919)
733-9721.
Sincerely,
D. Rex Gleason, P. E.
Surface Water Protection
Regional Supervisor
cc: Corps of Engineers-Asheville
Cyndi Karoly -Wetlands Unit
ESP Associates Wne Carolina
Jlatura!!y
North Carolina Division of Water Quality 6100 East Center St., Suite 301 Mooresville, NC 28115 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
0? W A rFQG
Mr. Randol Tilghman
Simonini Builders
817 E Morehead St.
Charlotte, NC 28202
Subject: Arbor Oaks Subdivision
Dear Mr. Tilghman:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
?
i October 12, 2004
U? Cabarrus County
DWQ # 04-0868
lv Vv
On May 26, 2004, the NC Division of Water Quality (DWQ) received your application for a
General 401 Water Quality Certification for the construction of the Arbor Oaks Subdivision in
Cabarrus County.
On June 1, Mr. Alan Johnson with this office spoke with Mr. Sean Connoly with ESP Associates
regarding the project. Mr. Connoly informed Mr. Johnson that a road had been constructed across
a stream and other stream impacts were proposed for the subdivision, and that an after-the-fact
Preconstruction Nofication form had been submitted to DWQ for the project.
Following the conversation, Mr. Johnson conducted an inspection at the site. On June 8, 2004
the project was placed on hold awaiting submittal of modifications to the original plan. As of this date
no plan has been submitted, nor has there been any further communication.
If we do not hear from you in writing by November 8, 2004, we will assume you no longer want to
pursue the project and will withdraw it from consideration. After November 8th, if you still want to
pursue the proposed impacts, you will need to resubmit an application along with a new fee.
Thank you for your prompt attention to this matter. If you have any questions, please contact
Alan Johnson at [phone] or Cyndi Karoly in Raleigh at [phone].
Sincerely,
D. Rex Gleason, P. E.
Surface Water Protection
Regional Supervisor
cc: Corps of Engineers-Asheville
Cyndi Karoly - Wetlands Unit
Sean Connoly - ESP
Now
Central Files Now Carolina
North Carolina Division of Water Quality 6100 East Center St., Suite 301 Mooresville, NC 28115 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycledl10% Post Consumer Paper
O?O? W A T FRpG
. -i
oliiiw?wsllvillw `c
Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
WETLANDS /401 GROUP
Mr. Randol Tilghman
Simonini Builders
817 E Morehead St.
Charlotte, NC 28202
Subject: Arbor Oaks Subdivision
Dear Mr. Tilghman:
JUN 1.5 2004
WATER QUALITY SECTION
June 9, 2004
Cabarrus County
DWQ # 04-0868
On May 26, 2004, the NC Division of Water Quality (DWQ) received your after-the-fact
application for a General 401 Water Quality Certification for the construction of the Arbor Oaks
Subdivision in Cabarrus County.
On June 1, Mr. Alan Johnson with this office spoke with Mr. Sean Connoly with ESP Associates
regarding the subject subdivision. Mr. Connoly informed Mr. Johnson that a road had been
constructed across a stream and other stream impacts were proposed for the subdivision, and that
the aforementioned after-the-fact Preconstruction Nofication form. had been submitted to DWQ for the
project.
Based on Mr. Johnson's and Mr. Connoly's above noted conversation, and subsequent telephone
conversations, the impacts shown on the submitted plan do not agree with the impacts that were
previously discussed. The application shows in addition to the stream/road crossing, that permanent
impacts (fill) are proposed to the wetland and stream on lots #20 and #9. These total impacts would
exceed 300 linear feet of stream channel, thereby requiring an individual permit from the Army Corp
of Engineers.
It is Mr. Johnson's understanding that impacts to the stream would be minimized. However, the
application does not reflect this. It is requested that the following information be provided to this
office:
• Linear feet of stream impacts for each lot.
• Wetland impacts and area for each lot.
• Total impacts.
• Identify channels as intermittent, perennial, or ephemeral.
• Proposed method of mitigation (if required).
Until the DWQ receives requested information, this office is requesting (by copy of this letter) that
the Corps of Engineers place this project on hold. Also, this project will be placed on hold for our
processing pursuant to 15A NCAC 2H .0507(h).
.one
o Carolina
taral
1V. V. LIY1?1 a of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (htto://l12o.enr.state.ne.us/ncwetIands)
Customer Service #: 1-877.623.6748
Thank you for your prompt attention to this matter. If you have any questions, please contact
Alan Johnson at [phone] or Cyndi Karoly in Raleigh at [phone].
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
cc: Corps of Engineers-Asheville
Cyndi Karoly - Wetlands Unit
Sean Connoly - ESP
File Copy
Central Files
wAT
D - _ 'C
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. HIimek, P.E., Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 7, 2004
Cabarrus County
DWQ # 04-0868
Mr. Randol Tilghman
Simonini Builders
817 E Morehead St.
Charlotte, NC 28202
Dear Mr. Tilghman:
On May 26, 2004, the NC Division of Water Quality (DWQ) received your application for a General 401
Water Quality Certification for the construction of the Arbor Oaks Subdivision in Cabarrus County.
On June 1, Mr. Alan Johnson with this office conducted a site inspection at the subject site. It was also
determined that approximately 100 ft. of stream had been impacted due to the installation of a culvert for a
road crossing. Also during the site inspection, aquatic biota was observed in the section of stream (flowing
through lot #20) extending approximately 150 ft. upstream of the road crossing.
Mr. Sean Connoly with ESP Associates, determined during their investigation that the stream (and the
associated spur in lot #9) below the road crossing was perennial. Based on the preconstruction notification
and Mr. Johnson's findings, fill of this stream channel would exceed 300 linear feet of channel and would
require an individual permit from the Army Corp of Engineers.
Subsequent to the above noted comments, Mr. Johnson has spoken with your representatives from ESP
Associates and it is his understanding that modifications have been made to the plan that was submitted to the
DWQ. Until the DWQ receives the updated modifications for the layout of the lots and which shows the stream
impacts, this office is requesting (by copy of this letter) that the Corps of Engineers place this project on hold.
Also, this project will be placed on hold for our processing pursuant to 15A NCAC 2H .0507(h).
Be advised, that from a point approximately 150 ft upstream (lot #20) of the road crossing to the point at
which the stream channel leaves the property (lot #8), that impacts exceeding 150 ft. must be mitigated
through payment to the Ecosystem Enhancement Fund or through other means.
Thank you for your prompt attention to this matter. If you have any questions, please contact Alan
Johnson at [phone] or Cyndi Karoly in Raleigh at [phone].
Sincerely,
cc: Corps of Engineers-Asheville
Cyndi Karoly - Wetlands Unit
Ken Howard - QORE
File Copy
Central Files
Noe Carolina
Naturally
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
NCt)€1' R
N. C. Division of Water Quality, 401 Wetlands Certification Unit,
1650 Mail Service Center, Raleigh, NC 27699-1650 (Mailing Address)
2321 Crabtree Blvd., Raleigh, NC 27604-2260 (Location)
[phone] (phone), 919-733-6893 (fax), (http://h2o.enr.state.nc.us/ncwetlands)
Customer Service #: 1-877-623-6748
Triage Check List
Date: ?? vte Jam" '
To: ? ARO
? FRO
Ef MRO
? RRO
From:
Project Name:
Mike Parker
Ken Averitte
Alan Johnson
Steve Mitchell

Comments:
A- + oV rd
Telephone : (919) :Tj 5__5g7q-

W 1a?9? ?0 f zp_ wG? ,s -r
shott ld 6 c?
ice.

?rQ f(???'? ?t?y c°li'let-

The file attached is being forwarded to your for your evaluation.
Please call if you need assistance.
Stream length impacted
9Stream determination
? Wetland determination and distance to blue-line surface waters on USFW topo maps
,L A Minimization/avoidance issues
? Buffer Rules (Meuse, Tar-Pamlico, Catawba, Randleman)
? Pond fill
10Mitigation Ratios
? Ditching
Are the stream and or wetland mitigation sites available and viable?
? Check drawings for accuracy
? Is the application consistent with pre-application meetings?
? Cumulative impact concern

?or
?bor yaks
F
DWQ#: U -Q86 2
County: Gad r f'`A_?
? WaRO Tom Steffens
? WiRO Noelle Lutheran
? WSRO Daryl Lamb

ESP Associates, P.A.
engineering • surveying • planning
040860
Arbor Oaks Single-Family
Development!
Concord, NC
ACOE Wilmington District
404/401 Permit Acquisition
Pr'j

Prepared By:
ESP Associates, P.A.
PO Box 7030
Charlotte, NC 28241
Phone # [phone]
April 29, 2004
WETLANDS 1401 GROUP

MAY 2 6 2004
r
WATER QUALITY SECTKON ,.

Arbor Oaks Subdivision Master Plan
TABLE OF CONTENTS
Executive Summary
Background and General Information
Purpose and Objectives
Description of the Project
404b Alternative Analysis for Unavoidable Impact
Compensation
Conclusion
Appendices
Application
Adjacent Property Owners
Site Location Map
Wetland Delineation
Arbor Oaks Lot Layout
Wetland Cross Sections
Page Number
2
2
3-5
5-7
7
Page 1 of 10
EXECUTIVE SUMMARY
This project is being reviewed as an After-the Fact permit application. The proposed work consisted
of the placement of 130 cubic yards of material in approximately 0.05 acres of jurisdictional area for
road crossings associated with a high-end residential development.
Sections of this report provide a description and evaluation of specific project impacts to
jurisdictional waters of the State, and ensure that the proposed work did not contravene water quality
standards or change classified uses of Coddle Creek. The assessment also ensures that the proper
sequencing of avoidance, minimization, and appropriate compensation for impacts not feasibly
avoided, has been demonstrated.
Development proposes a single-family residential development on approximately 80-acres adjacent
to Coddle Creek in Cabarrus County, North Carolina outside the city of Concord. The development
will be known as Arbor Oaks Subdivision. This community will provide natural resource
conservation, enhancement, and preservation, while allowing for reasonable single-family
community development.
Proposed impacts on the 80-acre site from the Simonini Development master plan included 0.05
acres of jurisdictional impact, all of which was associated with fill of a jurisdictional ditch. The
applicant proposes to create a 50' vegetated upland buffer along Coddle Creek to act as a filter for
runoff associated with the project. Additionally, the applicant proposes to create a wetland detention
to act as a filter for runoff associated with the development. The buffer and detention pond will act
to replace the minimal water quality benefits associated with the filling of the jurisdictional ditch.
BACKGROUND AND GENERAL INFORMATION
The Simonini Development community is located in Cabarrus County, North Carolina outside the
city of Concord on Odell School Road. The majority of the site consists of land adjacent to a
tributary of Coddle Creek. The area surrounding the proposed Simonini Development community is
utilized for future residential development and contains many existing residential ventures.
The proposed site is located within a critical watershed area (WSI1). Due to this the maximum
allowed impervious area allowed is 20%. The proposed project has an 8.8% impervious area. This
includes roads, driveways, and homes.
The site drains to Coddle Creels through the existing tributaries onsite. The entire tributary flowing
through the Simonini Development tract is currently wooded and provides an excellent riparian
buffer.
Page 2 of 10
The Simonini Development tract is unique to the area due to the onsite tributaries to Coddle Creek
and the existing upland access. Existing vehicle access is from Odell School Road.
The Simonini Development community master plan concept is to design a high-end residential
community, which will result in the creation of a unique neighborhood, complimentary in nature to
the existing adjacent land uses. The design concept was based on an initial consideration of the
environmental conditions of the site and resulted in proposed land uses for the Simonini
Development community that complimented and enhanced these existing conditions as well as
adhered to state and federal regulations. The master plan was developed to facilitate continuity and
control of the initial design's integrity, environmental quality, visual quality, and other aesthetic
aspects of the development.
PURPOSE AND OBJECTIVES
The specific purpose of the Simonini Development master plan is to provide the direction and
requirements necessary to ensure that the development is constructed to the high quality standards
typical of Simonini Development. These standards are developed to facilitate necessary construction
activities while minimizing and avoiding their impact on the natural environment.
DESCRIPTION OF THE PROJECT
Simonini Development proposes to develop 80-acres of land in Cabarrus County off Odell School
Road outside the city of Concord. All areas involved in the project have been delineated for areas
within state and federal jurisdiction as well as reviewed for Threatened and Endangered Species of
Concern. Simonini Development proposes the development of a single-family residential project.
The specific goals of the development are to create a high quality residential real estate project that
enhances the market value of the property; create a high quality alternative in the greater Concord
market; create a world class and high qualityproject offering amenities, services, and products in an
environmentally sensitive and well-planned manner.
BASELINE CONDITION
The jurisdictional areas on-site are the tributaries and adjacent wetlands associated with Coddle
Creek. The hardwood communities, typical of this area, dominate the jurisdictional areas. The
dominant species in the canopy of the wetlands are Acer rubrum, (Red Maple), and Liquidambar
styraciflua (Sweetgum). The sub-canopy is dominated by Ilex Opaca (American Holly), Zenobia
pulverulenta (Fetterbush). Additionally, the jurisdictional area, which was filled, had been impacted
(under-cut) due to the extent of the surrounding development and associated runoff. Therefore, the
water quality benefit associated with the ditch was greatly diminished.
404b ALTERNATIVES ANALYSIS FOR UNAVOIDABLE IMPACTS
Page 3 of 10
The siting of the project is critical to its economic success. The existing pond and onsite streams are
unique factors for the proposed site. The requirement for this development to be successful
economically can be achieved primarily through the single-family residential community proposed
for the site. The natural resources of the proj ect site have been carefully considered in planning and
are primary component for the success of the proposed project. No other sites were found in the area
where such a development could be successfully contemplated. In light of the overall project
purposes, this was the only site available and capable of serving the purposes of the proposed project
when taking costs, logistics, jurisdictional impacts, and existing methods for development into
consideration.
The project as planned avoids impacts on natural resources to the maximum extent practicable.
Avoidance of impacts on jurisdictional areas was also a central effort in the many considerations of
residential development designs. The roads, utility corridors, and other developmental aspects of the
proposed project were all planned after the jurisdictional areas were thoroughly investigated.
Because of the time spent investigating alternatives the applicant was able to limit jurisdictional
impacts to 0.05 acres.
Historic, archeological, and endangered species were investigated for the project and the searches
turned up no significant findings. All environmental and regulatory requirements have been met or
exceeded to the maximum extent possible in the development of the master plan.
The efforts to avoid impacts on the jurisdictional areas and other resources of the Project site
included identifying the resources, mapping them, and developing plans for the uses of the property
that had the least impact. The concept of an estate subdivision plan (2.5+ acre lots) was accepted
over standard single-family subdivision layout (0.2 acre lots) in an effort to reduce impacts to natural
resources. The estate design concept also allowed for the impervious area to be reduced to 8.8%;
below the required 20% for critical watersheds. Research has stated that when a project's
impervious area is below 10%, with a riparian buffer, the project will not cause or contribute to
further degradation of a watershed.
The jurisdictional area was spread over approximately 15 % of the project site and right the through
the middle of the site. Complete avoidance of jurisdictional areas was not possible in spite of a
significant level of effort on the part of the planners and engineers for the project. As impacts from
preliminary plans were identified, the proj ect engineers and planners worked with the landowners to
redesign the community layout to minimize and avoid the impacts. The redesign of one area often
led to additional changes that also had impacts. The impacts associated with the project are for
roadway access to proposed lots within the subdivision. It was finally determined that economic
success could be realized if the project was converted to an estate single-family residential
community, thus reducing the number of lots that would need access.
The proj ect has undergone rigorous environmental and economic analysis. The proj ect entails very
low-density development plans far below allowed limits. The total impervious area will be 8.8%
well below the allowable 20%.
Page 4 of 10
However, the process, which lasted more than 9 months, eventually resulted in an avoidance and
minimization of jurisdictional areas to the maximum extent practicable for the single-family
development. The impacts to the jurisdictional areas are consistent with similar projects previously
approved by state and federal agencies.
The proj ect engineers and planners also went through a process of avoiding and minimizing impacts
in developing the plans for roads, infrastructure, and other uses of the property. Significant site
features, such as natural drainage paths, large trees and stands of trees, were also taken into
consideration in the planning efforts to minimize jurisdictional areas impacts. Stormwater
management planning, irrigation planning, and utilities placement were all conducted with the goal
of avoiding identified resources.
The application for the jurisdictional area alterations describes the areas where jurisdictional area
impacts are unavoidable. Practicable alternatives were not available for the alterations sought in the
application. Minimization of impacts has resulted in only 0.05 acres of fill within jurisdictional
ditches. There was only 1-area proposed for impact where the project purposes could not be
accomplished with any practicable alternatives in light of the available resources for the project. In
the process of trying to avoid jurisdictional areas and minimize the fill, many other wetland areas
were being impacted because it was not possible to move the elements of the plans without
encountering other jurisdictional areas. The cost of the planning and redesign to avoid and minimize
the jurisdictional areas is substantial, and additional investment in the effort is not cost effective.
The spatial distribution of the jurisdictional areas creates a diminishing return on additional efforts to
redesign or relocate project improvements.
The area filled for the road crossing will have minimal impact on the associated tributary because the
culverts were adequately sized to handle 10-year stormevent. To ensure the proposed freshwater
impacts are negligible the applicant placed a 36" culvert upstream and a 42" culvert downstream to
maintain natural hydrology and reduce impacts to all natural resources. Furthermore, all culverts
were placed below the fill material and these culverts were placed at the same elevation as the flood
plain to prevent erosion and allow unrestricted aquatic life passage.
Because of the nature of the low-density development, which results in more than 25 % of the
developable area, left in green space, further avoidance was not feasible and would of made the
project economically unsuccessful.
Alternatives for the unavoidable alteration of the jurisdictional areas include not proceeding with the
Project (no action alternative), or reducing the scope of the Project below the point of its being
feasible economically. The siting of the project is crucial to its success, making movement to
another site impracticable. The scope of the investment in the project is significant. Furthermore,
the impacts were kept below the 0.1-acre threshold and were further reduced to 0.05-acres. In light
of the overall project purposes, the factors of cost, natural resources, engineering, and logistics, and
the many months of effort to avoid and minimize the impacts, no practicable alternatives are
identified for the impacts of the jurisdictional areas shown in the application.
Page 5 of 10
COMPENSATION FOR UNAVOIDABLE IMPACTS
The basic compensation offered is the buffering of onsite tributaries to Coddle Creek. The
compensation goes to replacing the minimal water quality benefits lost in filling of the impaired
jurisdictional area, for road crossing. All upland buffers will be preserved by restrictive covenants.
Furthermore the wetland created with the detention system will actually improve water quality
benefits of the jurisdictional area lost.
Proposed compensation includes the creation of a thirty (30) foot riparian buffer along the onsite
tributaries to Coddle Creek. Furthermore, the tributary will be investigated to see ifbankfull benches
should be installed at several key locations.
In order to maintain the integrity of the compensation area the following will be incorporated into the
development covenant and restrictions:
The buffer boundaries will be marked with permanent signs that provide warning that the area is not
to be impacted and whom to contact.
All new owners will be fully informed about buffer limits/uses when property is sold or transferred.
All buffers will be checked annually by Simonini Development staff to ensure integrity.
LAND USE ENHANCEMENT
The following is a summary of prominent measures likely to result from the land use planning effort
that is proposed as part of the compensation package:
Reduce non-point source pollution
Decrease upland surface runoff
Increase sheet flow through substantial upland buffer
Decrease peak storm water discharge rate
Increase infiltration of surface runoff
Decreased depth to groundwater within upland buffer areas
Decrease sediment and contaminants
Enhance opportunity for habitat enhancement
GENERAL ENHANCEMENT/RESTORATION DESIGN CONSIDERATIONS
The average buffer width for the entire tract averages thirty (30) feet in the Master Plan. The
proposed upland buffers should protect the physical and ecological integrity of the stream/wetland
ecosystem.
Page 6 of 10
The upland buffer and proposed bankfull benches should provide the following enhancements to the
wetland/stream complex:
Creation of floodplain wetlands
Provide shade that reduces water temperature within tributaries of Coddle Creek.
Cause deposition of (i.e., filter) sediments and other contaminants from adjacent land use.
Reduce nutrient loads to tributaries of Coddle Creek.
Provide riparian wildlife habitat.
Protect fish habitat.
Maintain aquatic food webs.
Provide a visually appealing greenway.
Provide recreational opportunities.
Dissipate the energy of the stream during bankfull rain events.
Reduce erosion of stream banks and prevent undercutting of the stream.
Except for providing for limited clearing or under brushing according to approved master plan
guidance, where the clearing will be limited to 4" DBH or less, the buffer will be retained and
maintained to the extent feasible, as will woody debris and stumps in the upland buffer. In addition,
to providing habitat and erosion and sediment control, these features should provide seed sources as
well as important vertical diversity. The gradual change from upland buffer edge to stream/wetland
core will soften environmental gradients and minimize any associated effects.
The model conservation easement published by the Corps will be used as a guide for the restrictive
covenants. Use of compensatory compensation is the only practicable alternative for the unavoidable
impacts minimized through the planning process.
CONCLUSION
The placement of fill material in jurisdictional areas may have caused a temporary increase in
turbidity levels in adjacent waterbodies, but ambient conditions should have resumed once the work
was completed. Water quality standards were not be contravened and designated uses were not
changed by the placement of fill material in jurisdictional areas.
The Simonini Development project has successfully avoided or minimized the impacts on site
through a long and careful planning process. Of more than 0.95 acres of jurisdictional area spread
out over more than 15 % of the project site, only 0.05-acres was impacted. The significant
investment in the proj ect includes an effort of more than nine months in redesign of the single-family
residential development as well as the infrastructure and other project components specifically to
avoid and minimize jurisdictional area impacts. The time spent in redesign determined that the
project could meet its goals as an estate subdivision and return reduce impervious area to 8.8%, thus
creating no impact to the Coddle Creek watershed. The 404(b)(1) Guidelines requirements are met
by the project, as demonstrated by the significant investment in design and avoidance. The project
site is uniquely suited to the project because of residential zoning, the proximity, the existence of a
Page 7 of 10
pond, and direct access to tributaries to Coddle Creek. No practicable alternatives remain to further
minimize or avoid the unavoidable impacts of the proposed projects. Upland riparian buffer and
bankfull benches are proposed as the only remaining practicable alternative for the unavoidable
impacts.
Previous sections of this assessment have provided a description and evaluation of specific project
impacts to jurisdictional waters of the State, and provided recommendations and modifications, when
necessary, to ensure that the proposed work will not contravene water quality standards or change
classified uses of Coddle Creek. The above assessment also ensures that the proper sequencing of
avoidance, minimization, and appropriate compensation for impacts not feasibly avoided, has been
demonstrated.
Though the application is an after the fact permit request it has been successfully demonstrated that
environmental concerns were addressed early in the planning process and that water quality was
protected through out the hole process by the use of BMPs during the filling process. Additionally,
the applicant was aware that pollutants present in fill material could have been released if the
material erodes during storm events and enters adjacent waters or jurisdictional areas. Therefore, the
use of only clean fill material, free of pollutant, was used to prevent water quality degradation from
contamination from such pollutants.
Page 8 of 10
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT ( OMB APPROVAL NO. 0710-0003
(33 CFR 3251 Expires December 31, 2004
The Public burden for this collection of information is sestimated to average 10 hours per response, although the majority of applications should require
5 hours or less. This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of
information, including suggestions for reducing this burden, to Department of Defense, Washington Headquarters Service Directorate of Information
Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington, VA 22202-4302; and to the Office of Management and Budget,
Paperwork Reduction Project (0710-0003), Washington, DC 20503. Respondents should be aware that notwithstanding any other provision of law,
no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control
number, Please DO NOT RETURN your form to either of those addresses. Completed applications must be submitted to the District Engineer having
jurisdiction over the location of the proposed activity.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection , Research and
Sanctuaries Act, 33 USC 1413, Section 103. Principal Purpose: Information provided on this form will be used in evaluating the application.for a
permit. Routine Uses: This information may be shared with the Department of Justice and other federal, state, and local government agencies.
Submission of requested information is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit
be issued.
One set of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this
application (see sample drawings and instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed
activity. An application that is not completed in full will be returned.
1. APPLICATION NO. 12. FIELD OFFICE CODE 13. DATE RECEIVED 4. DATE APPLICATION COMPLETED
/ITFMS RFI nW TA Rc crr r cn Rv nvor rrnern
5. APPLICANT'S NAME 8. AUTHORIZED AGENT'S NAME AND TITLE (an agent is not required)
Simonini Builders, Randol Tilghman Sean Connolly, ESP Associates,PA
6. APPLICANT'S ADDRESS 9. AGENT'S ADDRESS
817 E. Morehead St. PO Box 7030
Charlotte, NC Charlotte, NC 28241
7.. APPLICANT'S PHONE NOS. W/AREA CODE 10. AGENT'S PHONE NOS. W/AREA CODE
a. Residence a. Residence
b. Business 704 358-9940 E b. Business 803 600-8514
11. STATEMENT OF AUTHORIZATION
I hereby authorize, M. Sean Connolly, ESP Associates to act in my behalf as my agent in the processing of this application and to
furnish, upon request, supplemental information in support of this permit application.
APPLICANT'S SIGNATURE DATE
NAME, LOCATION AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE (seeinstrucrions.
Arbor Oaks
13. NAME OF WATERBODY. IF KNOWN (ifaodicabm 14. PROJECT STREET ADDRESS m.pp/icaeie)
Coddle Creek 1240 Odell School Road
15. LOCATION OF PROJECT
Cabarrus NC
Concord, NC
COUNTY STATE
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN, (seeinstruotionm)
n/a
17. DIRECTIONS TO THE SITE
SEE ATTACHED MAP
NG OR 4345, Jul 7 EDITION OF FEB 94 IS OBSOLETE. (Proponent: CECW-OR)
18. Nature of Activity (Description of project, include all fearwes)
The proposed work consisted of the placement of 130 cubic yards of material in approximately
0.05 acres (150 linear ft.) of jurisdictional stream for road crossings associated with a
high-end residential development. Further, the project consists of the proposed placement of
fill material in approximately 300 linear feet of degraded intermittent stream to facilitate
the development of three single family residential homes on three separate platted lots.
Total stream impact for the nroiect is 450 linear feet.
19. Project Purpose (Describe rho reason or purpose of the project, see instructions)
The Simonini Development community master plan concept is to design a high-end residential
community, which will result in the creation of a unique neighborhood, complimentary in
nature to the existing adjacent land uses.
USE BLOCKS 20-22 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
To authorize two existing road crossings associated with a high-end residential development
and to allow for the development of three lots within the proposed 20 lot subdivision.
21. Type(s) of Material Being Discharged and the Amount of Each Tvoe in Cubic Yards
750 cubic yards of earthen fill material
22. Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
0.12 acres
23. Is Any Portion of the Work Already Complete? Yes = No IF YES. DESCRIBE THE COMPLETED WORK
The existing road infrastructure has been completed resulting in the fill or shading of 150
linear feet of stream.
24. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (If more than can be entered here,
please attach a supplemental list).
See Attached
25. List of Other Certifications or Approvals/Denials Received from other Federal, State or Local Agencies for Work Described in This Application.
AGENCY TYPE APPROVAL' IDENTIFICATION NUMBER DATE APPLIED DATE APPROVFD nATF nr=tiiFn
Would include but is not restricted to zoning, building and flood plain permits
26. Application is hereby ade or a permit or permits to authorize the work described in this application. I certify that the information in this
appiication is comp) a d accurate. I further certify that I possess the authority to undertake th work cribed herein or am acting as the
duly a iz g t the applicant.
/o'y
SIGN RE OF APPLICANT DATE SIGNATURE OF AGENT DATE
The application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or
fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or
fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
APPENDIX II
ADJACENT PROPERTY
OWNERS
Page 10 of 10
Adjacent Property Owners
1. Unica U B O
1201 Odell School Road
Concord, NC 28027
2. Irvin James
1204 Larkhall Court
Cary, NC 27511
3. Julian McDowell
8637 Davidson Hwy
Concord, NC 28027
4. KSIN Properties, LLC
817 E Morehead Street, Suite 100
Charlotte, NC 28202
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? For approval
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? For review and comment
? Approved as submitted
? Approved as noted
? Returned for corrections
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? FORBIDS DUE ? PRINTS RETURNED AFTER LOAN TO US
REMARKS
COPY TO
SIGNED: -5eA-?AA) 0&wmgLj,?2,
if enclosures are not as noted, kindly notify us at once.