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Home My WebLink AboutWPO202200037 Correspondence 2022-10-28® Stantec To: John Anderson From: Andrew Tiefenback, PE County of Albemarle, Community 5209 Center Street Development Department Williamsburg, VA 23188 401 McIntire Road, North Wing Charlottesville, VA 22902 File: Innisfree Stream Mitigation Bank Phase Date: October 26, 2022 STN#203443600 Reference: Innisfree Stream Mitigation Bank Phase 2, WPO2022-0037 Albemarle County, Virginia VSMP Permit Plan Review Please find an itemized response to comments received from the County of Albemarle's Community Development Department dated October 3, 2022. For tracking purposes, comments are provided in italics followed by our responses. A. Stormwater Pollution Prevention Plan (SWPPP) The SWPPP content requirements can be found in County Code section 17-405. A SWPPP must contain (1) a PPP, (2) an ESCP, (3) a SWMP, and (4) any TMDL measures necessary. SWPPP 1. Stantec proprietary SWPPP differs from county SWPPP template. Ensure information included with county template appears in SWPPP prepared by Stantec for this project. For example, SWPPPs must include: a. ESC plan sheets corresponding with revised approved VSMP plan sheets. (Sec. 4, county template); Note: ESC SWPPP insert sheets are 11" x 17" reduced -size plan sheets. ESC plan sheets at 11" x 17" are included in Appendix B of the SWPPP. b. A copy of 2019 VAR10 CGP (Sec. 11) A copy of the Construction General Permit is included in Appendix C of the SWPPP C. PPP Exhibit (Sec. 6.A. - 11 " x 17') that identifies initial location of following in relation to project limits: i. Rain gauge ii. Vehicle wash station, with wash waters draining to a depression with no outlet to stream or storm conveyance system iii. Portable sanitary facilities (ports John) iv. Solid waste dumpster, as needed v. On -site Fuel station, as needed vi. Solvent -chemical storage, as needed vii. Concrete or grout washout, as needed me u:1203443600102_correspondencelcountylmem_albemarle_innis(reephasetwo_20221026.docx October 26, 2022 John Anderson Page 2 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review The noted items have been added to the PPP exhibit and is included in Exhibit B of the SWPPP. Items iv, vi, and vii are not needed. d. List named individual responsible for PPP (Sec. 6. E.) Section 1.1 of the SWPPP includes all contact and responsible party information. e. List named individual responsible for VESCH /SWPPP compliance inspections (Sec. 8). Items d./e. not required for plan approval but needed to receive a Grading Permit. Section 1.1 of the SWPPP includes all contact and responsible party information. 2. Stantec Sec. 7.0 Certification: complete /sign /date. Section 7.0 has been completed by the Engineer of Record and will be transferred to the selected contractor at the appropriate time. 3. Incl. ref. to WPO202200037 on SWPPP cover. Water Protection Ordinance application number has been added to SWPPP cover. B. Pollution Prevention Plan (PPP) —see SWPPP item 1.c./d., above The PPP content requirements can be found in County Code section 17-404. The PPP exhibit is included in Exhibit B of the SWPPP. See the responses to comments 1.c — 1.e for further information. C. Stormwater Management Plan (SWMP) VSMP Regulation 9VAC25-670-108 requires the VSMP authority to approve or disapprove a SWMP. This plan is disapproved for reasons listed below. The stormwater management plan content requirements can be found in County Code section 17-403. General a. Orient all plan sheets to landscape view. Comment acknowledged. All plan sheets are in landscape view. me u:1203443600102_correspondencelcountylmem_albemarle_innisfreephasetwo_20221026.docx October 26, 2022 John Anderson Page 3 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review b. Submit floodplain development permit (FDP) application. Allowable activities within floodplain: 18- 30.3.11, table; pre -requisites to floodplain development: 18-30.3.12. Restoration projects (table: flood and water related uses and structures, 2nd item) approved by Albemarle are by -right within floodway or floodway fringe only if they cause no change to the base floodplain elevation or horizontal limits of mapped floodplain. Any change to horizontal limits or base floodplain elevation of a FEMA-mapped floodplain requires coordination with FEMA, and an approved CLOMA /LOMA. GIS image below indicates floodplain exists in vicinity of SR 668, an area of proposed project activity - stream restoration, and perhaps elsewhere within project vicinity. FDP application has been submitted along with these plans. c. FDP Application approval is required prior to WPO plan approval. Comment Acknowledged. d. List WP0202200037 as associated with FDP Application. Water Protection Ordinance application number has been listed on the FDP application. e. Include ref. to WPO202200037 on VSMP /WPO plan title sheet. Water Protection Ordinance application number has been added to Sheet 1. f. List Corps permit # lower left corner of title sheet. USACE approval required prior to WPO plan approval. Corps permit number will be provided upon receipt from USACE. 1. On sheet NV001 (Existing conditions) or sheet NS101 (Master summary), label tax map parcel with ownership information: Name, TMP ID, deed bk.-pg. ref. (TMP 01400-00-00-01000). Tax map parcels with ownership information have been added to Sheet NV001 and NS101. 2. All plan sheets a. ShowAabel stream buffers (county GIS). b. Show /label mapped FEMA floodplain. c. Show/label critical slopes (GIS Critical Resources layer). For example: in partial image of project area, purple (1.) indicates stream buffer, tan (2.) indicates critical slopes, horizontal hatching (3.) indicates floodplain. Shading or linework for stream buffers, critical slopes and floodplain must display across plan sheets for review, approval, and construction purposes. Stream buffers, FEMA floodplain, and critical slopes have been added to all plan views and sheet legends. me u:1203443600102_correspondencelcountylmem_albemarle_innisfreephasetwo_20221026.docx October 26, 2022 John Anderson Page 4 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review 4. On sheet NV001, include statements that place project in context of project goals: streambank erosion mitigation, flood control, SWM control/runoff reduction, natural stream restoration, biological enhancement, environmental benefit, streambank stabilization, all of which are intrinsic if not direct stormwater management goals, only in this instance, identical with project land disturbance. Land is disturbed to achieve project outcomes, all of which have direct SWM benefit. The project is not exempt from state stormwater management requirements yet is not evaluated by typical review metrics. Provide narrative statement that speaks to this. Recommend transfer entire text of first 3-p. of Stantec letter d. August 11, 2022 (Innisfree Stream Mitigation Bank Phase 2 — Stormwater and Hydraulic Calculations). If text is copied, revise any reference to `attached' to proper reference to Stantec August 11, 2022 Calculation packet, submitted separately with the Innisfree Stream Mitigation Bank Plan. A narrative covering the above noted items has been added to Sheet NV001. 5. Note: Whatever forest/open space (FOS) acreage is listed in the VaRRM.xis is required to be covered by. platted easement (incl. metes and bounds); deed of easement; and a SWM Maintenance Agreement (FOS easement is an `Other Technique' that meets state SWM regulations). A forest/open space easement plat requires separate application, review and approval. Plat must be recorded prior to WPO plan approval. Application link. Comment acknowledged. Per email correspondence with Albemarle County on October 19, 2022, the existing recorded Restrictive Covenant is sufficient to meet the requirements of the Open Space noted in the VaRRM.xls post -development land cover table. 6. Engineering affirms: Channel flood protection calculations maybe waived in this instance consistent with past precedent and DEQ Guidance Memo 15-2003. [quote: Stantec letter, p. 3] Comment acknowledged. 7. VaRRM.xIs (New development) indicates no phosphorus reduction is required (3.4 Ib. credit) since all post-dev land cover is forest /open space (9.96 Ac) (8/11/22 Stantec, p. 2), with `stream and wetland restoration areas and adjacent vegetated buffers ...protected in perpetuity under the terms of the Mitigation Banking Instrument (MBI). Comment acknowledged. 8. Project may proceed with an approved ESC plan to restore streams and protect wetlands degraded by cattle pasture /access, widening or straightening of channels for flood control, logging, loss of forest (sheet NV002), and installation of multiple ponds and road crossings. Comment acknowledged. 9. Project is not exempt from county stream buffer requirements, is an eligible activity which maybe allowed in a stream buffer by program authority as an ecological restoration project (17-604.B.). Project design, goals, and proposed landscaping (replanting stream buffer) should meet requirements for management of stream buffer. Comment acknowledged. Design with community me u:1203443600102_correspondencelcountylmem_albemarle_innisfreephasetwo_20221026.docc October 26, 2022 John Anderson Page 5 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review 10. Stream buffer mitigation (sheet 42): This single sheet provides inadequate detail to evaluate or inspect plan design against riparian buffer requirements. For example: i. Satellite imagery with hatching does not adequately define limits of mitigation plantings; for example: L along stream reach, width, or area (SF) of any particular designated mitigation planting area. Comment acknowledged, see item 10.ii. and 10.iii. below. fi. Calculate /show on individual sheets stream buffer impact and proposed mitigation planting area. It is unclear why not all reaches of restored or realigned or stabilized stream would not receive plantings. Once stream buffer impact is calculated /shown and labeled (so for individual reaches, it is possible to calculate 2:1 offset ratio. If only a 20' width of stream (buffer) is disturbed for a given reach, for example, either side of centerine, ordinance anticipates a 40' width would be re -planted with native species, either side of centerine, per table schedules listed at DCR Riparian Buffers Modification & Mitigation Guidance Manual, Tables A and B, pp. 101 and 102. Per in -person meeting with Albemarle County on October 18, 2022, Stantec has added a table to the Planting Plan (Sheet 42) detailing area (acres) of LOD vs. Mitigation plantings within the GIS mapped Albemarle County Stream Buffer per reach or reach group to clarify plan design against riparian buffer requirements. iii. Once (ft2) stream buffer impact is calculated, provide detailed planting schedule for each reach of stream at 2:1 offset ratio. Please note that even if current land cover at verge of a restored stream is fallow fescue /former pasture, and not forested, the 2:1 mitigation planting requirement applies to these areas, as well,, i.e., mitigation planting requirements apply to any area of disturbance within GIS stream buffer, which are those areas within 100-ft of an intermittent or perennial stream (centerline) in the rural district (areas shaded purple on county GIS). Stantec has added a table to the Planting Plan (Sheet 42) detailing area (acres) of LOD vs. Mitigation plantings within the GIS mapped Albemarle County Stream Buffer per reach or reach group to clarify plan design against riparian buffer requirements. The 2:1 mitigation planting requirement is met for all reaches or reach areas, except for Reach 3F. The Reach 3F stream buffer is wooded, and plantings will occur within the entire LOD available within the stream buffer. iv. No Mitigation plan bond is required, but plant schedules /quantities that meet establishment of buffer vegetation at 17-604. C.S. are required. Comment acknowledged. Plant schedules/quantities detailed on the Planting Plan (Sheet 42) meet the establishment of buffer vegetation at 17-604.C.5. Design with community in mind me u:1203443600102_correspondence\countylmem_albemarle_innisfreephasetwo_20221026.docc October 26, 2022 John Anderson Page 6 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review 11. If VaRRM.x1s post -developed land cover values are revised, please update August 11, 2022 calculations (p. 2, VaRRM.x1s table). Please include ref. to WPO202200037 on Calc. packet. Comment acknowledged. Per correspondence with Albemarle County on October 19, 2022, the existing Restrictive Covenant is sufficient to meet the requirements of the Open Space noted in the VaRRM.xls post -development land cover table. As the table has not been revised, a revised Calc. packet has not been submitted. 12. Albemarle offers no review comment on natural stream restoration design /Rosgen Method; design is only evaluated for comparison with ESC-SWM-Mitigation-SWPPP requirements. Comment acknowledged. D. Erosion and Sediment Control Plan (ESCP) Virginia Code §62.1-44.15:55 requires the VESCP authority to approve or disapprove an ESCP. This plan is disapproved for reasons listed, below. The erosion control plan content requirements can be found in County Code section 17-4022. 1. Beginning sheet 30 a. Provide match -lines to orient drawings relative to one another. Match lines have been added to sheets where applicable. See Sheet 4 and Sheet 29 for sheet locations. b. Show/label critical slopes. Critical slopes have been added to the plans and included in sheet legends. c. ShowAabel stream buffers. Stream buffers have been added to the plans and included in sheet legends. d. For any CRS proposed across critical slopes, evaluate alternative construction access that avoids critical slopes. If evaluation indicates no alternative accessway exists across critical slopes (sheet 35, for example, contours 880' to 840), provide plan notes, labels, narrative etc. specifying protective and restorative measures [will] be installed and maintained as deemed necessary to ensure that the development will be consistent with the intent of section 4.2' of chapter 18, Albemarle County ordinance. See county code 18-4.2.6.c. CRS has been revised to avoid critical slopes. me u:1203443600102_correspondencelcountylmem_albemarle_innisfreephasetwo_20221026.docx October 26, 2022 John Anderson Page 7 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WPO2022-0037 Albemarle County, Virginia VSMP Permit Plan Review e. Provide silt fence downslope of CRS, upslope of streams. SF is shown downslope of stockpile areas, only. Provide ESC sequence to coordinate placement of SF with in -stream structure placement, channel realignment, or stream bank stabilization. SF cannot be installed if it interferes with active grading but should be installed upon completion of channel or stream bank work daily where CRS provides access to a stream reach. Silt fence has been added between CRS and streams on Sheets 30-38. The construction sequence on Sheet 41 has been revised to coordinate placement of SF with construction activities. 2. Sheet 36 a. Provide paved construction entrance at intersection with Walnut Level Road. While county ESC inspector may allow VESCH Std. & Spec. 3.02 temporary (stone) construction entrance, Albemarle County Design Standards Manual (ACDSM) specifies a paved wash rack (CE). Include paved construction entrance detail on plans (pg. 8). A paved wash rack has been added at the noted location on Sheet 36. The provided Paved Wash Rack detail has been added to Sheet 40. 3. Sheet 41 a. ESC Narrative, 2nd paragraph: Revise /edit 'the current sheets are preliminary and future design plans will provide more detail.' Preliminary plans cannot be approved. Provide final ESC design for plan approval. These plans are not preliminary. The ESC narrative has been revised for clarity. b. Pre -construction Note 1: Revise /edit 'arrange a pre -construction meeting with Charlotte County and the southside soil and water conservation district,' appropriate to Albemarle County project location. The note has been revised to correct references. Note 3: 'Install Phase V ESC measures. ESC does not appear to be phased. Clarify if ESC measures are phased. Later text indicates Phase 2 is in -channel work. Revise sequence for clarity. The sequence has been revised for clarity. References to ESC phases have been removed. me u:1203443600102_correspondencelcountylmem_albemarle_innisfreephasetwo_20221026.docx October 26, 2022 John Anderson Page 8 of 8 Reference: Innisfree Stream Mitigation Bank Phase 2, WP02022-0037 Albemarle County, Virginia VSMP Permit Plan Review It is our goal that this information is sufficient to satisfy any outstanding comments or concerns regarding the Innisfree Stream Mitigation Bank Phase 2 Project. If more information is required, please contact me. Thank you. Stantec Consulting Services Inc. i Andrew Tiefenback PE Civil Engineer Phone: 757 358 9080 Andrew.tiefenback@stantec.com Attachment: Innisfree Stream Mitigation Bank Phase 2 plans, Stormwater Pollution Prevention Plan, and WPO Application c. Gene Haffey (Stantec), Peter Traverse (Innisfree Stream Mitigation Bank LLC) Design with community in mind me u:1203443600IO2_ommpondencelcountylmem_albemarle_innisfreephasetwo_20221026.doac