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May 24,2017

Ms. Jeannette SteeleFearn-Clendaniel Architects6LarchAve. Suite 398Wilmington, DE 19804

RE: PLUS Review 2017-04-01; Howard T. Ennis School

Dear Jeannette,

Thank you for meeting with State agency planners on April 26th,2017 to discuss the proposedplans for the Howard T. Ennis School. According to the information received you are seekingreview ofan 80,542 square foot special needs school on 61 acres along Patriots V/ay in SussexCounty.

Please note that changes to the plan, other than those suggested in this letter, could result inadditional comments from the State. Additionally, these comments reflect only issues that arethe responsibility of the agencies represented at the meeting. The developers will also need tocomply with any Federal, State and local regulations regarding this property. We also notethat as New Castle County is the governing authority over this land, the developers willneed to comply with any and all regulations/restrictions set forth by the County.

Strategies for State Policies and SpendingThis project is located in an Out of Play area according to the Strategies for State Policies andSpending. Lands in the Out of Play category are not expected to be the location of privatedevelopment due to public ownership, private conservation, or some other legal and/orenvironmental constraint on development. In this case, the land in question is owned by theState of Delaware as a part of the larger Stockely Campus land holding administered by theDepartment of Health and Social Services. Out of Play lands are expected to continue to be usedand developed for the public purposes for which they were acquired or preserved. As such,school construction on this parcel is considered to be consistent with the Strategies þr StatePolicies and Spending.

'We have received some email correspondence between the Department of Education and the

Department of Health and Social Services that indicates that there is a willingness to consider

122 Martin Luther King jr. Blvd. South - Haslet Armory .Third Floor.Dover, DE 19901

Phone (302)739-3090 . Fax (302) 739-566L. www. stateplanning.delaware.gov

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transfening the property to the Indian River School District for school construction. Should theDistrict, DOE and DHSS decide to pursue school construction on this parcel, the three agenciesmust work with OMB to determine the legal method to transfer the land in accordance with theprovisions of Delaware Code

The Office of State Planning Coordination, the Department of Education, and the Office and

Management and Budget will review this school site as per the process detailed in Title 29, $

7525 of the Delaware Code should the District decide to seek approval of this site. Inanticipation of that process, the District is encouraged to consider the following:

o Utility availability is considered when school sites are reviewed. As discussed at thePLUS meeting, the District should obtain verification from utility providers that there isaccess to sewer and water utilities at this site, and that the capacities are sufficient tosupport this proposed school. Knowing that the District intends to construct an additionalschool nearby on other lands using the same infrastructure networks, the analysis ofcapacity should include all future construction.

Contact David Edgell of the Office of State Planning Coordination to discuss additionalinformation that may be required for the school site review report at such time as theDistrict decides to request approval of this site.

Code Requirements/Asency Permittine RequirementsDepartment of Transportation - Contact Bill Brockenbroush 760-2109

The site access on Patriots Way (Sussex Road 326) and Avenue of Honor (Sussex Road86) must be designed in accordance with DeIDOT's Development ManualA copy of the Manual is available athttp://www.deldot.qov/information/business/subdivisions/changes/index.shtml.

Pursuant to Section P.3 of the Manual, a Pre-Submittal Meeting is required before plansare submitted for review.

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a Section P.5 of the Manual addresses fees that are assessed for the review of developmentproposals. DeIDOT anticipates collecting the Initial Stage Fee when the record plan issubmitted for review and the Construction Stage Fee when construction plans are

submitted for review.

Per Section 2.2.2.1of the Manual, Traffic Impact Studies (TIS) are warranted fordevelopments generating more than 500 vehicle trip ends per day or 50 vehicle trip ends

per hour in any hour of the day. From the PLUS application, the total daily trips are

estimated at 150 vehicle trip ends per day. DeIDOT believes the proposed school willnecessarily generate more than 150 vehicle trip ends per day, but as the number ofstudents expected is not included in the application, DeIDOT cannot presently estimate

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how many trips it will generate. As a point of information, a vehicle trip end is a vehiclearriving or departing, so a vehicle which arrives and then departs creates two vehicle tripends. The site's trip generation should be discussed further at the Pre-Submittal Meetingmentioned above.

On the basis of 150 vehicle trip ends per day, assuming that number is correct, thewarrants for a TIS are not met. Realizingthat school traffic tends to be concentrated atthe beginning and end of the school day, the hourly traffic volumes will also need to beevaluated.

For developments generating less than 2,000 vehicle trip ends per day and less than200vehicle trip ends per hour, if the local government does not require a TIS, Section 2.2.2.2of the Manual provides that DeIDOT may accept an Area Wide Study Fee, calculated bymultiplying the daily trip generation by $10, in lieu of requiring a TIS. Provided that thetraffic volumes do not exceed these numbers, DeIDOT is willing to accept a fee in lieu inthis instance.

An Area Wide Study Fee, when accepted, is set aside for use in funding future trafficstudies in the same county as the subject development. Payment of the Fee does notrelieve the payer of responsibility for off-site improvements where DeIDOT has

identified a need for improvements. While none are identified at this time, some could beidentified in the plan review process.

Payment of the Fee does not relieve the payer of the need to provide a Traffic OperationalAnalysis (TOA) if DeIDOT determines in the plan review process that a TOA is neededto address a concern about the proposed site entrance. Per Section 2.3.2 of the Manual,the threshold for considering the need for a TOA is 200 vehicle trip ends per day, so ifthe 150 vehicle trip ends per day estimate on the PLUS application is accurate, DeIDOTwill not require a TOA.

Section 3.2.4.2 of the Manual addresses the placement of right-of-way monuments(markers) along the roads on which a property fronts, in this case Patriots Way andAvenue of Honor. Monuments sufficient to re-establish the permanent rights-of-wayafter the dedication discussed below should be shown on the plan and provided in thefield in accordance with this section.

As necessary, in accordance with Section 3.2.5 and Figure 3.2.5-a of the Manual,DeIDOT will require dedication of right-oÊway along the site's frontage on Patriots Wayand Avenue of Honor. By this regulation, this dedication is to provide a minimum of 40feet of right-of-way from the physical centerline on Patriots Way and 30 feet of right-of-way from the physical centerline on Avenue of Honor. The following right-of-waydedication note is required, "An X-foot wide right-of-way is hereby dedicated to theState of Delaware, as per this plat."

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In accordance with Section 3.2.5.I.2 of the Manual, DeIDOT will require theestablishment of a 15-foot wide permanent easement across the property frontage onPatriots Way and Avenue of Honor. The location of the easement shall be outside thelimits of the ultimate right-of-way. The easement area can be used as part of the openspace calculation for the site. The following note is required, "A l.S-foot widepermanent easement is hereby established for the State of Delaware, as per thisplat."

In accordance with Section 3.4 of the Manual, a record plan shall be prepared prior toissuing "Letter of No Objection". The following information will be required for the"Letter of No Objection" review:

Initial Stage Fee Calculation FormInitial Stage Review FeeGate-Keeping Checklist * Site PlanDesign Checklist - Record PlanSight Distance SpreadsheetOwners and Engineers' name and e-mail addressRecord PlanConceptual Entrance PlanSubmission of the Area-Wide Study Fee

Refening to Section 3.4.2.1of the Manual, the following items, among other things, arerequired on the Record Plan:

o A Traffic Generation Diagram. See Figure 3.4.2-a for the required format andcontent.

o Depiction of all existing features within 600 feet of the proposed entrance, as perFigure 3.4.2-b.

o Notes identif ing the type of off-site improvements, agreements (signal, letter)contributions and when the off-site improvements are warranted. PresentlyDeIDOT does not anticipate requiring any off-site improvements.

Section 3.5 of the Manual provides DoIDOT's requirements with regard to connectivityThe requirements in Sections 3.5.1 through 3.5.3 shall be followed for all developmentprojects having access to state roads or proposing DeIDOT maintained public road forsubdivisions.

Section 3.5.4.2 of the Manual addresses requirements for shared-use paths and sidewalksin terms of the Investment Areas identified in the Strateeies for State Policies andSpending. According to the Strategies, the subject land is Out of Play and therefore notin any of the four Investment Areas. Section 3.5.4.2 of the Manual does not explicitly

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address Out of Play areas but based on an examination of the surrounding areas, DeIDOTfinds it aþpropriate to treat the subject land as being in Investment Level4. For projectsin Level 4 Investment Areas, installation of paths or sidewalks along the frontage onState-maintained roads is at the discretion of DeIDOT's Subdivision Engineer if theproject does not abut an existing facility. The need for a path or sidewalk should beaddressed at the Pre-Submittal Meeting mentioned above.

Section 3.5.5 of the Manual addresses DeIDOT's requirements for connectivity to transit.In accordance with this section, specific requirements relating to transit may be identifiedby DeIDOT or the Delaware Transit Corporation in the plan review process.

In accordance with Section 3.8 of the Manual, storm water facilities, excluding filterstrips and bioswales, shall be located a minimum of 20 feet from the ultimate State right-of-way along Patriots Way and Avenue of Honor. It appears that the plan presented doesnot meet this requirement.

Referring to Section 4.3 of the Manual, an entrance plan shall be prepared prior to issuingentrance approval. The following information will be required for Entrance Plan review:

Construction Stage Fee Calculation FormConstruction Review Fee

Gate-Keeping Checklist - Entrance PlanDesign Checklist - Entrance PlanAuxiliary Lane SpreadsheetEntrance PlanPipe/Angle Spreadsheet (If applicable)SV/M Report and Calculations (If applicable)

In accordance with Section 5.2.5.6 of the Manual, a separate turning template plan shallbe provided to verify vehicles can safely enter and exit the site entrance. As per Section5.2.3 of the Manual, the entrance shall be designed for the largest vehicle using theentrance.

In accordance with Section 5.2.9 of the Manual, the Auxiliary Lane Worksheet should beused to determine whether auxiliary lanes are warranted at the site entrance and how longthose lanes should be. The worksheet can be found athttp://www.deldot.gov/information/business/subdivisions/Auxiliary_Lane_V/orksheet.xlsm?030817.

In accordance with Section 5.4 of the Manual, sight distance triangles are required andshall be established in accordance with American Association of State Highway andTransportation Offrcials (AASHTO) standards. A spreadsheet has been developed to

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assist with this task. It can be found athttp://www.deldot.gov/information/business/subdivisions/Intersection-Sight-Distance.xls.

In accordance with Section 5.14 of the Manual, all existing utilities must be shown on theplan and a utility relocation plan will be required for any utilities that need to berelocated.

Section 6.4.3 of the Manual, which pertains to the inspection and acceptance ofcommercial entrances, applies. Construction inspection responsibilities shall be inaccordance with Figure 6.4.3-a. Our preliminary reading of this figure is that the projectrequires Level I inspection and that a construction inspection agreement will not beneeded however, because of the site's relatively short frontage on Avenue of Honor andthe presence of the railroad line at the west end of that frontage, this matter should bediscussed at the Pre-Submittal Meeting mentioned above.

Section 7.7.2 of the Manual addresses the need to provide 20-foot wide drainageeasements for all storm drainage systems, open or closed, that fall outside the existingright-of-way or the drainage/utility easement. In accordance with this section, metes andbounds and total areas need to be shown for any drainage easements. The easementsshould be shown and noted on the record plan.

Department of Natural Resources and Environmental Control - Contact MichaelTholstrup 735-3352Development of this parcel will result in increased impervious surface and new sources ofgreenhouse gas emissions. Opportunities exist to reduce the environmental impact on-sitethrough appropriate use of the Pollution Control Strategies, stormwater management and nature-based infrastructure described below.

The State of Delaware is also threatened by climate change and has a goal of reducinggreenhouse gas emissions by 30 percent by 2030. Appropriate development that provides access

to public transportation, opportunities to walk and bike to school, and that employs energyefficient building standards are among key strategies to meet these goals. DNREC encouragesthe use of high performance building standards and consideration of alternative energy sources topromote clean sustainable energy and reduce greenhouse gas emissions. This could mean sitingthe buildings to take advantage of solar and geothermal systems, and/or including infrastructurefor electric vehicle charging stations. DNREC further recommends an abundant use of nativevegetation and shade trees throughout the landscape, as well as pervious pavement to absorbcarbon dioxide, protect water quality and provide relief to residents on hot days.

The following pages provide information about applicable regulations and detailedrecommendations associated with this project, from various DNREC Divisions. DNREC wouldlike to be a partner in creating appropriate development that protects and highlights the

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environment as a natural amenity of the landscape. The Department has resources and expertisethat are available to help make this areality, often at no expense to the landowner.

\ilater Quality: TMDLs.o This project is located in the hígh nutrient reduction zone of the greater Inland Bays

watershed. In this watershed, Total Maximum Daily Load (TMDL) pollutant reductiontargets call for 85 percent and 65 percent reductions in nitrogen and phosphorus frombaseline conditions, respectively. The TMDL also calls for a 40 percent reduction (17percent for marine waters) in bacteria from baseline conditions. TMDLs have beendeveloped by the State of Delaware under Section 303(d) of the l9T2Federal CleanWater Act, for nutrients and bacteria. A TMDL is the maximum level of pollutionallowed for a given pollutant below which a "water quality limited waterbody" canassimilate and still meet State water quality standards (e.g., dissolved oxygen, nutrients,and bacteria; State of Delaware Surfoce ïlater Quality Standards, as amended July I I,2004) to the extent necessary to support use goals such as, swimming, fishing, drinkingwater and shell fish harvesting. Please view the following web link for furtherinformation on the regulatory requirements and technical analysis involved in thedevelopment of the specific TMDLs:http://www.dnrec.delaware.gov/swc/walPages/WatershedAssessmentTMDls.aspx

The Inland Bays Pollution Control Strategy (PCS) and the accompanying regulations canbe reviewed athttp.lhegulations.delaware.gov/documentsÀtrovember200Sc.pdf.Background information about the PCS with guidance documents and mapping tools canbe retrieved here:http://www.dnrec.state.de.us/water2000/Sections/V/atershed/ws/ib pcs.htm

A nutrient management plan is required under the Delaware Nutrient Management Law(3 Del.C., Chapter 22) for all persons or entities who apply nutrients to lands or areas ofopen space in excess of 10 acres. This project's open space may exceed this 10-acrethreshold. Please contact the Delaware Nutrient Management Program at (302) 739-48IIfor further information conceming compliance requirements or view additionalinformation here : http ://dda. delaware. sov/nutrients/index. shtml

Water Suppty.o The project information sheets state that an unknown provider will be used to provide

public water for the proposed project. Our records indicate that the project is not locatedin an area where public water service is available. Should an on-site Industrial, Publicwell be needed, a minimum isolation distance of 150 feet is required between the welland any potential source of contamination, such as central sewer lines, septic tank andsewage disposal area, stormwater management pond and at least 150 feet from theoutermost boundaries of the project. The Division of Water Resources will considerapplications for the construction of on-site wells provided the wells can be constructedand located in compliance with all requirements of the current Regulations Governing the

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Construction and Use of Wells. A well construction permit must be obtained prior toconstructing any wells.

a Should dewatering points be needed during any phase of construction, a dewatering wellconstruction permit must be obtained from the Water Supply Section prior to constructionof the well points. In addition, a water allocation permit will be needed if the pumpingrate will exceed 50,000 gallons per day at any time during operation.

All well permit applications must be prepared and signed by licensed water wellcontractors, and only licensed well drillers may construct the wells. Please factor in thenecessary time for processing the well permit applications into the constructionschedule. Dewatering well permit applications typically take four weeks to process,which allows the necessary time for technical review and advertising.

Sediment and Stormwater Management.1. A detailed Sediment and Stormwater Management Plan must be approved by DNREC

Sediment and Stormwater Program prior to beginning construction. The plan mustcomply with the current Delaware Sediment and Stormwater Regulations.

2. A Notice of Intent (NOD for Stormwater Discharges Associated with ConstructionActivity must be submitted along with NOI fee to DNREC Division of WatershedStewardship prior to Sediment and Stormwater Plan approval. Once the constructionactivity is complete, as-builts have been approved, and final stabilization is established onthe site, a Notice of Termination (NOT) may be submitted to terminate permit coveragefor the construction activity.

3. Initially, a Stormwater Assessment Study (SAS) must be completed for the project siteand submitted to DNREC Sediment and Stormwater Program. Once a complete SAS has

been submitted, a project application meeting will be scheduled. At the projectapplication meeting the methods for compliance with the Sediment and StormwaterRegulations will be discussed and submittal requirements, analysis points, and BMPs topursue will be agreed upon.

Air Quality.. The applicant shall comply with all applicable Delaware air quality regulations. Please

note that the following construction phase regulations in Table 1 - Potential RegulatoryRequirements may apply to your project:

Table 1: Potential Regulatory Requirements

Regulation Requirements

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7 DE Admin. Code 1106 -Particulate Emissions fromConstruction and MaterialsHandling

Use dust suppressants and measures to preventtransport of dust off-site from material stockpile,material movement and use of unpaved roads.

Use covers on trucks that transport material to andfrom site to prevent visible emissions.

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7 DE Admin. Code ll4l -Limiting Emissions of VolatileOrganic Compounds fromConsumer and CommercialProducts

Use structurall paint coatings that are low in VolatileOrganic Compounds.Use covers on paint containers when paint containersare not in use.

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7 DE Admin. Code ll44 -Control of Stationary GeneratorEmissions

Ensure that emissions of nitrogen oxides (NO*), non-methane hydrocarbons (NMHC), particulate matter(PM), sulfur dioxide (SOz), carbon monoxide (CO),and carbon dioxide (COz) from emergency generatorsmeet the emissions limits established. (See section3.2).Maintain recordkeeping and reporting requirements.

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7 DE Admin. Code 1145 -Excessive Idling of Heavy DutyVehicles

Restrict idling time for trucks and buses having agross vehicle weight of over 8,500 pounds to no morethan three minutes.

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For a complete listing of all Delaware applicable regulations, please look at our website:http ://www. awm. delaware. gov/AOM/Pages/AirRe gulations. aspxLauren DeVore, (302) 7 39-9437, lauren.devore@,støte.de.us

Tank Management.o If a release of a Regulated Substance occurs at the proposed project site, compliance of 7

Del.C., Chapter 60; 7 Del.C., Chapter 74 and DE Admin. Code 1351, State of DelawareRegulations Governing Underground Storage Tank Systems (the UST Regulations) isrequired.

a Per the UST Regulations: Part E, $ 1. Reporting Requirements: Any indication of aRelease of a Regulated Substance that is discovered by any Person, including but notlimited to environmental consultants, contractors, utility companies, financial institutions,real estate transfer companies, UST Owners or Operators, or Responsible Parties shall bereported within 24 hours to:

o The Department's 24-hour Release Hot Line (800) 662-8802; and

o The DNREC Tank Management Section (302) 395-2500.

If any aboveground storage tanks (ASTs) less than 12,500 gallons are installed, they mustbe registered with the TMS. If any ASTs greater than 12,500 gallons are installed, theyare also subject to installation approval by the DNREC Tank Management Section.

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State Historic Preservation Offïce - Contact Terrence Burns 736-7404o There is no known archaeological site or National Register-listed property on this parcel

The Stockley Center (S-9126), which is across Patriots Way from the parcel, has beendetermined eligible for the National Register of Historic Places.

The Stockley Center Farm Residence Complex (S-9129) was further south, near the newDelaware Memorial Veterans Cemetery, but has been demolished. There should be

sufficient landscaping between the development and Stockley Center (S-9126), to blockadverse noise or visual effects. If any project or development proceeds, be aware of theUnmarked Human Burials and Human Skeletal Remains Law.

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For more information, go to: http://www.dnrec.delaware.gov/tanks/Pages/default.aspx orcontact Ross D. Elliott with further questions at (302) 395-2500, orRo s s. Elliott@.q tate. de. us

Abandoned or unmarked family cemeteries are very common in the State of Delaware.They are usually in rural or open space areas, and sometimes near or within the boundaryof an historic farm site. Even a marked cemetery can frequently have unmarked graves orburials outside of the known boundary line or limit. Disturbing unmarked graves orburials triggers the Delaware's Unmarked Human Burials and Human Skeletal RemainsLaw (Del. C. Title 7, Ch.54), and such remains or discoveries can result in substantialdelays while the procedures required under this law are carried out. If there is a discoveryof any unmarked graves, burials or a cemetery, it is very costly to have themarchaeologically excavated and the burials moved. The Division of Historical &, CulturalAffairs recommends that owners andlor developers have a qualified archaeologicalconsultant investigate their project area, to the full extent, to see if there is any unmarkedcemetery, graves, or burial sites. In the event of such a discovery, the Division ofHistorical & Cultural Affairs also recommends that the plans be re-drawn to leave the fullextent of the cemeteries or any burials on its own parcel or in the open space area of thedevelopment, with the responsibility for its maintenance lying with the landownerassociation or development. If you would like to see more information, please review thefollowing websites: www.history.delaware.gov/preservation/umhr.shtml andwww.history.delaware. gov/preservation/cemeteries. shtml.

Therefore, prior to any demolition or ground-disturbing activities, the developer shouldhire an archaeological consultant, to examine the parcel for archaeological resources andplan to avoid those sites or areas.

If there is federal involvement, in the form of licenses, permits, or funds, the federalagency, often through its client, is responsible for complying with Section 106 of theNational Historic Preservation Act (36 CFR 800) and must consider their project's effectson any known or potential cultural or historic resources. Owners and developers whomay plan to apply for an Army Corps of Engineers permit or for federal funding, such as

HUD or USDA grants, should be aware of the National Historic Preservation Act of 1966

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(as amended). Regulations promulgated for Section 106 of this Act stipulate that noground-disturbing or demolition activities should take place before the Corps or otherinvolved federal agency determines the area of potential effect of the project undertaking.These stipulations are in place to allow for comment from the public, the Delaware StateHistoric Preservation Office, and the Advisory Council for Historic Preservation aboutthe project's effects on historic properties. Furthermore, any preconstruction activitieswithout adherence to these stipulations may jeopardizethe issuance of any permit orfunds. If you need further information or additional details pertaining to the Section 106process and the Advisory Council's role, please review the Advisory Council's website atthe following: www.achp. gov.

Delaware State Fire Marshall's Office - Contact John Rudd 739-4394

At the time of formal submittal, the applicant shall provide; completed application, fee, and threesets of plans depicting the following in accordance with the Delaware State Fire PreventionRegulation (DSFPR):

Fire Protection \ilater Requirements:o Water distribution system capable of delivering at least 1000 gpm for l-hour

duration, at 20-psi residual pressure is required. Fire hydrants with 800 feet spacingon centers.

o Where a water distribution system is proposed for educational sites, the infrastructurefor fire protection water shall be provided, including the size of water mains for firehydrants and sprinkler systems.

Fire Protection Features:o All structures over 10,000 Sq. Ft. aggregate will require automatic sprinkler

protection installed.o Buildings greater than 10,000 sqft, 3-stories or more, over 35 feet, or classified as

HighHazard, are required to meet fire lane marking requirementso Show Fire Department Connection location (Must be within 300 feet of fire hydrant),

and detail as shown in the DSFPR.o Show Fire Lanes and Sign Detail as shown in DSFPR

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and which are not readily accessible from public roads, shall be provided withsuitable gates and access roads, and fire lanes so that all buildings on the premises are

accessible to fire apparatus. This means that the access roads to the building must be

constructed so fire department apparatus may negotiate it.o Fire department access shall be provided in such a manner so that fire apparatus will

be able to locate within 100 ft. of the front door.

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o The use of speed bumps or other methods of traffic speed reduction must be tnaccordance with Department of Transportation requirements.

o The local Fire Chief, prior to any submission to our Agency, shall approve in writingthe use of gates that limit fire department access into and out of the development orproperty.

Required Notes:o Provide a note on the final plans submitted for review to read " All fire lanes, fire

hydrants, and fire department connections shall be marked in accordance with theDelaware State Fire Prevention Regulations"

o Proposed Useo Alpha or Numerical Labels for each building/unit for sites with multiple

buildings/unitso Square footage of each structure (Total of all Floors)o National Fire Protection Association (NFPA) Construction Typeo Maximum Height of Buildings (including number of stories)o Note indicating that the building(s) are to be sprinkleredo Name of Water Providero Letter from Water Provider approving the system layouto Provide Lock Box Note (as detailed in DSFPR) if Building is to be sprinkleredo Provide Road Names.

Recommendations/Additional InformationThis section includes a list of site specific suggestions that are intended to enhance the project.These suggestions have been generated by the State Agencies based on their expertise andsubject area knowledge. These suggestions do not represent State code requirements.They are offered here in order to provide proactive ideas to help the applicant enhance the sitedesign, and it is hoped (but in no way required) that the applicant will open a dialogue with therelevant agencies to discuss how these suggestions can benefit the project.

Department of Transportation - Contact Bill Brockenbroush 760-2109o The applicant should expect a requirement that any substation and/or wastewater

facilities will be required to have access from an internal driveway with no direct access

to Patriots'Way or Avenue of Honor.

The applicant should expect a requirement that all PLUS and Technical AdvisoryCommittee (TAC) comments be addressed prior to submitting plans for review.

Please be advised that DeIDOT adopted an update of the Development CoordinationManual effective April 1I,2016. While in most respects, the changes are incremental,they are located throughout the Manual and could have some effect on the entrancedesigns.

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o Effective August 1,2015, all new plan submittals and re-submittals, including major,minor and commercial plans, shall now be uploaded via the PDCA (PlanningDevelopment Coordination Application) with any fees paid online via credit card orelectronic check. The design firm making the submittal must create the project in thePDCA and upload all the required items to allow DeIDOT to start the review process.

Guidance on how to do this is available on our website athttp ://www. deldot. eov/informatiorVbusines s/subdivi sions/.

Be advised that the Standard General Notes have been updated and posted to the DeIDOTwebsite. Please begin using the new versions and look for the revision date of August 3 1,

2016. The notes can be found at

http ://www. deldot. eov/information/busines s/subdivi sions/.

Denartment of Natural Resources and Environmental Control - Contact MichaelTholstrup 735-3352Soils Assessment.

o Based on the soils survey mapping update, the primary soils mapped on this parcel are

Fort Mott-Henlopen complex (FhA & FhB) and Pepperbox-Rosedale complex (PsA).o Fort Mott-Henlopen and Pepperbox-Rosedale are well-drained and moderately

well-drained soil mapping units, respectively.

Fish and Witdlife.o Nuisance Waterfowl: High concentrations of waterfowl in wet ponds create water-quality

problems, leave droppings on lawn and paved areas and can become aggressive duringthe nesting season. To deter waterfowl, DNREC recommends:

o Planting the surrounding open space with a mix of native wildflower plantings (tobe planted in accordance with the Sediment and Stormwater Plan approval agencyrequirements).

o Mowing the open space area surrounding the pond only once ayear, either inFebruary or March. If mowing must occur more often, leave a minimum buffer of15-30 feet in width to be mowed annually. When the view of the surroundingarcafrom the pond is blocked, geese can't scan for predators and are less likely toreside and nest in the area of the pond.

o A native wildflower mix will also serve to attract bees, butterflies, and otherpollinators, and reduce run-off, which can contain oil and other pollutants thathomeowners may use on their lawns and driveways. Our program botanist, BillMcAvoy would gladly assist in drafting a list of plants suitable for this site. Billcan be contacted at(302) 735-8668 or William.McAvoy@,state.de.us

Compliance with TMDLs through the Pollution Control Strateg¡r (PCS).. Compliance with the specified TMDL nutrient and bacterial reduction requirements

specified for the Inland Bays watershed can be facilitated by adherence to the strategiesand requirements described in the Inland Bays PCS, and the implementation of thefollowing recommended best management practices :

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o Maintain as much of the existing open space as possible in this parcel. DNRECsuggests additional native tree, shrub and/or native herbaceous vegetationplantings in available open space, wherever possible.

o Calculate post-construction surface imperviousness with all forms of createdsurface imperviousness (e.g., rooftops, driveways, parking lots, sidewalks, open-water storm water management structures, ponds, and roads) included in thecalculation. Omission of any of the above-stated forms of surface imperviousnesswill result in an underestimate of the actual post-development surfaceimperviousness and the associated environmental impacts.

o Employ green-technology storm water management and arain garden(s) (in lieuof open-water management structures) as BMPs to mitigate or reduce nutrient andbacterial pollutant runoff.

o \Mhen compatible with concerns for the protection of excellent recharge areas

and/or well-head protection areas, as determined by a DNREC hydrogeologists,use pervious paving materials instead of conventional paving materials (e.g.,asphalt or concrete) to help reduce the amount of water and pollutant runoffdraining to adjoining streams and wetlands. Pervious pavers are especiallyrecommended for areas designated for parking.

o Assess nutrient and bacterial pollutant loading at the preliminary project designphase. To this end, the Watershed Assessment Section has developed amethodology known as the "Nutrient Load Assessment protocol." The protocol isa tool used to assess changes in nutrient loading (e.g., nitrogen and phosphorus)resulting from the conversion of individual or combined land parcels to a changedland use; thus providing applicants and governmental entities with quantitativeinformation about the project's impact(s) on baseline water quality. DNRECstrongly encourages the applicant/developer to use this protocol to design andimplement the best management practices. Please contact John Martin in theDivision of Watershed Stewardship, at (302) 739-9939, for more information onthe protocol.

Additional information on tank management.. 'When contamination is encountered, PVC pipe materials should be replaced with ductile

steel and nitrile rubber gaskets in the contaminated areas.

Additional information on air quality.o New homes and businesses may emit, or cause to be emitted, additional air contaminants

into Delaware's air, which will negatively impact public health, safety and welfare.These negative impacts are attributable to:

o Emissions that form ozone and fine particulate matter; Sussex County is currentlynonattainment for the 2008 ozone standard.

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o The emission of greenhouse gases which are associated with climate change, and

o The emission of air toxics.

Based on the information provided, emissions for mobile sources were quantified. Table2 - Projected Air Quality Emissions represents the potential impact that the Howard T.Ennis School may have on air quality.

**Note that emissions associated with the actual construction of the new special needsschool, automobile and truck traffic from working in, or delivering products to the site, as

well as site preparation, earth moving activities, road paving and other miscellaneous airemissions, are not reflected in the table above.**DNREC recommendations for this project are as follows:

o Planting of native shade trees to clean the air of localized pollutants and cut downon energy/cooling costs.

o The use of recycled asphalt pavement (RAP), which reduces heat island effects onpaved surfaces.

o Use of energy efficient products in construction to lessen the power sourceemissions of the project and costs.

o Inclusion of bike racks and expansion of the bicycle/pedestrian network throughsidewalks and bike lanes which also promote alternative forms of transportation.

o At least two parking spaces dedicated to alternative fueled vehicle (electricvehicle (EV), hybrid electric vehicle (HEV), low emission vehicle (LEV)) use andcharging

o Beautification and landscaping to generate a context-sensitive design that wouldblend in well with surrounding land uses while also helping to mitigate thepollution potential of the project

Native Delaware Tree Plantings: To offset the impact of the new special needs school,the applicant is encouraged to plant native trees. Trees can significantly reduceautomobile emissions including those from pollutants such as nitrogen oxides (NOx),

Table 2: Projected Air Quality Emissions for Howard T. Ennis School Based onprojected estimate of 150 trips during peak season)

Emissions Attributable toHoward T. Ennis School(Tons per Year)

VolatileOrganicCompounds(voc)

NitrogenOxides(Nox)

SulfurDioxide(sot

FineParticulateMatter(PMzs)

CarbonDioxide(Coz)

Mobile emissions .498 657 * ,1. {.

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volatile organic compounds (VOCs), and the most harmful of all, particulate matter (PM)by trapping gases fumes and replenishing the oxygen into the ambient air. In addition,trees also reduce the effects of heat islands by helping to cool asphalt and pavementwhich also lessens the chances of ozone formation. They also have the added benefit ofcreating an urban tree canopy that provides shade for parking areas as well as reducescooling costs for local businesses and by providing wind breaks in the winter, wherebyreducing air conditioning needs by up to 30 percent and saving 20 to 50 percent on fuelcosts. As a general reminder, the best trees to plant are those that have a large leaf surfacearea at maturity, contain leaf characteristics that are amenable to particle collection fromparticulate matter (PM) such as those that have hairy or sticky leaves and have hightranspiration rates which result in relatively high temperature reduction.

Energy Effrciency: Constructing with only energy efficient products can help yourfacility immensely, not only in terms of environmental sustainability but financially.Energy Star qualified products are up to 30 percent more energy efficient. Savings comefrom building envelope upgrades, high performance windows, controlled air infiltration,upgraded heating and air conditioning systems, tight duct systems and upgraded water-heating equipment. Every percentage of energy efficiency translates into a percentreduction in pollution. The Energy Star Program is an excellent way to save on energycosts and reduce air pollution. Providing shade for parking areas can also be of addedbenefit to this facility. Some approaches may include architectural devices, vegetation, orsolar panels. Providing shade for parking areas helps to reduce heat island impacts, and,by extension, helps to minimize the potential for localized ground-level ozone formation.For more about energy efficient options, please see: https://www.energystar.gov/ orhttps ://www. epa. gov/ greenin gepa/ener gy-efficiency-epa.

Multi-modal travel: A component of improving existing air quality levels is to maximizemulti-modal travel through bike lanes, sidewalks and convenient access to transitopportunities. While the basic site plan submitted for PLUS review did not show a levelof detail to include sidewalks or bike paths, DNREC encourages the addition ofsidewalks and bike lanes in the development plan and adding sharrows where needed toencourage multi-modal travel opportunities. Sharrows and striping are the easiest andmost cost effective option. Multi-modal travel can significantly reduce mobile sourceemissions. For every vehicle trip that is replaced by the use of a sidewalk or bike path,7pounds of VOC and I 1.5 pounds of NOx are reduced each year.

Clean Fuel Measures: This measure helps to reduce localized air pollution by supportingthe use of low emission vehicles. It is recommended that electric vehicle charging bemade available in at least one location if feasible. DNREC would also appreciate at leasttwo (2) parking spaces being designated as ooalternative fuel" parking near the front of theschool and consider installation of electric vehicle charging stations, to better facilitateclean alternative fuel use in transportation.

For a site map of local alternative fueling sites, please visit the Alternative Fuels DataCenter website here : http : //www. afdc. ener gy. gov/locator/stations/.

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a Should the developer have any more questions or concerns, the DNREC Dvision of AirQuality (DAQ) point of contact is Lauren DeVore, and she may be reached at (302) 739-9437 or lauren.devore@state.de.us. The applicant is encouraged contact DAQ to discussthe emission mitigation measures that will be incorporated into the Howard T. EnnisSchool construction project. DNREC looks forward to working together with you on thisproject to achieve our shared air quality, healthy community and quality of life goals.

The District should consider including recycling infrastructure in its site design.a

Delaware State Fire Marshall's Office - Contact John Rudd 739-4394o Preliminary meetings with fire protection specialists are encouraged prior to formal

submittal. Please call for appointment. Applications and brochures can be downloadedfrom our website: www. statefiremarshal.delaware. gov, technical services link, planreview, applications or brochures.

Approval ProcessSchool sites must be approved by the Secretary of Education, the Director of OMB, and theDirector of the Office of State Planning Coordination. The Strategies þr State Policies andSpending, the information contained within this PLUS letter, and other factors will be consideredwhen the Secretary and the two Directors make the determination about whether or not toapprove a school site.

Once the District decides on a school site or sites to pursue for approval, the district must submita letter requesting approval for the site(s) to the Department of Education. The letter should bedirected to the DOE staff responsible for the Capital Program. The letter should contain a taxparcel ID number, PLUS review number, and all relevant information regarding the site and theproposed school.

Following receipt of this letter and upon fïling of an application with the local jurisdiction,the applicant shall provide to the local jurisdiction and the Office of State PlanningCoordination a written response to comments received as a result of the pre-applicationprocess, noting whether comments were incorporated into the project design or not and thereason therefore.

Thank you for the opportunity to review this project. If you have any questions, please contactme at 302-739-3090.

AICPDirector, Office of State Planning Coordination

CC: Sussex CountyJames Pennewell, Department of Education