20190459 Ver 1_Other_20190611

Strickland, Bev
From: Johnson, Alan
Sent: Tuesday, June 11, 2019 4:23 PM
To: Shaeffer, David Leigh (Dave) CIV USARMY CESAW (USA)
Subject: patterson road
Given your email, just received, I thought I would pass along. Some thoughts/comments are similar.
Oppose to the waiver:
1) In the pre -app meeting it was apparent that this was the site determined to be what was desired. It was stated
to meet the Huntersville "sub -market". What that means was not clarified. If this is for businesses located and
servicing Huntersville submarket? What is the service area that this is to accommodate. It the development is
in reality to meet the Charlotte region, then location in Huntersville is not as important.
2) The purpose/needs to is accommodate 10K to 400k sq ft. The more common need stated is 10K— 100K sq ft
which can be accommodated easily w/o the need to impact the stream.
3) No building on the site plan exceeds 270K sq ft.
4) Of the numerous sites of similar purpose this is the largest development proposed: 714K sq ft. The next closest
is 659K sq ft.
5) The comment that the other buildings for similar developments are smaller (less sq ft), because lot the
dimension or the lot (a building constraint). It is our position that impacts to stream are a more important
constraint and something that should be protected and recognized. A good lot configuration, should not mean
impacting streams is a foregone conclusion and do not need to be avoided. The stream on this site cuts off the
lot (i.e. a lot dimension constraint).
6) No reasonable explanation was provided to explain why the impact was needed to the stream, other than to be
a viable operation. This is a general statement, that can be attributed to any development/building project.
7) Upon build out, the site will be 60%-70% impervious. That will have a major impact on the receiving stream
from the discharge of the SW system.
8) Also the headwater of the stream will be paved over, potentially reducing recharge of the stream and affecting
aquatic habitat. It is suggested that a study be conducted to determine the impact on water quality prior to the
approval of any impacts.
9) The construction of a new sewer line to service the site, will encourage additional growth and potential impacts
to wetlands and streams along the sewer corridor.
10) These project types have become common and there is concern that waivers are expected. Waivers should be
for exceptions, not because the building is just too big for the available land.
11) Based on similar sites, it is often noted that anecdotally, the stream ranking is medium. This stream evaluation
showed high and medium indicators for a majority of the items yet yielded an overall LOW score. Part of this
could be due to the evaluation of stream stability. Head cuts were mentioned as an instability, yet the
slopes/banks of the stream were relatively stable. Head cuts are an indication of past instability and it was
noted in the application of the historic land use at the site. However evaluating past impacts and not the
current system can provide the wrong stream evaluation. The question is, is the stream currently unstable. The
photos indicate otherwise. There was no observed heavy sediment load leaving the site. Good stream habitat
was stated, yet low aquatic life tolerance. There appears to be some conflicting information, that might need to
be addressed.
12) The stream ID form scored a 26.5. Midway between the 19 and 30 point. The form was completed in August,
usually the droughty time of year, yet there was base flow. Given that information, the stream should be
determined to be perennial (at least in terms of mitigation). As they stated in the application, historic land use
has had an impact on the channel, thus affecting the natural parameters evaluated

Thanks,
Alan
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DMiloo of Wxter Rcsourccs
Alan D Johnson — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.

DWR
DM on of Wmer Resources