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November 27,2017

llr. Zachary Crouch, P.E.Davis, Bowen & Friedel, Inc.1 Park Ave.Milford, DE 19963

RE: PLUS review 2017-10-04; OA Vantage Point

Dear Zachary,

Thank you for meeting with State agency planners on October 25,2017 to discuss theOA Vantage Point project. According to the information received, you are seeking review of arezoning of 16.45 acres from R-2 to Community Facilities/Limited Commercial in anticipationof a site plan for a 175 unit assisted living facility and 59,000 square feet of commercial space inLewes.

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 are

the 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 alsonote that as the City of Lewes has governing authority over this land the developers willneed to comply with any and all regulations/restrictions set forth by the City.

Stratesies for State Policies and SpendinsThis project is located in Investment Levels 1 according to the Strategies þr State Policiesand Spendizg. Investment Level 1 reflects areas that are already developed in an urban orsuburban fashion, where infrastructure is existing or readily available, and where futureredevelopment or infill projects are expected and encouraged by State policy.

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

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

PLUS review 2017-10-04Page2 of 17

Code Requirements/Agency Permitting Requirements

Department of Transportation - Contact Bill Brockenbroueh 760-2109

Because the site fronts on roads that are part of the Federal Aid Primary Road System, itis subject to outdoor advertising regulations found in CFR 23 $13 | and 17 Del. C. $1101-1120. Accordingly, the applicant should expect the following requirements:

o No new billboards, variable message boards, or electronic changing message

sign(s) anywhere on or off either frontage road. Any such structure or fixtureshall be 660 feet away, i.e., any closest by*ay right-oÊway edge.

o No ofÊpremises advertising on the property for others within 660 feet of eitherSavannah or Kings Highway, e.g., displaying on-site the bank/financial institutionfunding the project or the contractor building the project.

o Along Kings Highway, the applicant would not be permitted to advertise or directinformation about themselves on other private property.

The site access on Kings Highway (US Route 9) and Savannah Road (Business Route 9)must be designed in accordance with DeIDOT's Development Coordination Manual,which is available athttp ://www.deldot. gov/Business/subdivisions/index. shtml?dc:changes.

a Pursuant to Section P.3 of the Manual, a Pre-Submittal Meeting is required before plansare submitted for review. The form needed to request the meeting and guidance on whatwill be covered there and how to prepare for it is located athttps://www.deldot.goviBusiness/subdivisions/pdfs/Meeting_Request_Form.pdfl08022017.

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.

a Section 1.2 of the Manual provides DeIDOT's general policy on the location ofentrances, with additional, detailed criteria provided in subsequent chapters and sectionsThe site entrances should be located to meet the spacing criteria in Figure I.2.1-a as

nearly as possible, subject to the need to provide adequate auxiliary turning lanes.

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 endsper hour in any hour of the day. From the PLUS application, DeIDOT see that the total

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daily trips are estimated at2,678 vehicle trip ends per day. Therefore, DeIDOT willrequire a TIS and may require off-site improvements as a result.

As necessary, in accordance with Section 3.2.5 and Figure 3.2.5-aof the Manual,DeIDOT will require dedication of right-of-way along the site's frontage on KingsHighway and Savannah Road. By this regulation, this dedication is to provide aminimum of 40 feet of righfof-way from the physical centerline of Kings Highway and40 feet of right-of-way from the physical centerline of Savannah Road. The followingright-of-way dedication note is required, "An X-foot wide right-of-way is herebydedicated to the State of Delaware, as per this plat."

In accordance with Section 3.2.5.1.2 of the Manual, DeIDOT will require theestablishment of a l5-foot wide permanent easement across the property frontage onKings Highway and Savannah Road. 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 lS-foot widepermanent easement is hereby established for the State of Delaware, as per thisplat."

Referring 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 entrances within 450 feet of the Kings Highway entranceand within 300 feet of the Savannah Road entrance.

o Notes identifying the type of off-site improvements, agreements (signal, letter)contributions and when the off-site improvements are warranted.

Section 3.5 of the Manual provides DeIDOT'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. If an interconnection can be negotiated with the Henlopen Gardenscondominium association, the senior living facility should be connected to its internalstreet system.

Section 3.5.4.2 of the Development Coordination Manual addresses requirements forshared-use paths and sidewalks. For projects in Level I and2Investment Areas,installation of paths or sidewalks along the frontage on State-maintained roads isrequired. The type(s) of facility to be installed should be discussed at the Pre-SubmittalMeeting.

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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 Kings Highway and Savannah Road.

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 entrances and howlong those lanes should be. The worksheet can be found athttp://www.deldot.gov/Business/subdivisions/index.shtml. The conceptual site planappears to show an acceleration lane exiting the site onto Kings Highway. DeIDOT nolonger requires acceleration lanes at site entrances.

There are utilities along both frontages. In accordance with Section 5.14 of the Manual,all existing utilities must be shown on the plan and a utility relocation plan will berequired for any utilities that need to be relocated.

Because the proposed development is to be constructed in the proximity of a road with a

functional classification of principal arterial, freeway or interstate, specifically KingsHighway, the developer will be required to perform a noise analysis in accordance withDeIDOT's Noise Policy, found in Section 3.6 of the Manual and may be required toprovide noise abatement for residents based on that analysis.

Department of Natural Resources and Environmental Control - Contact MichaelTholstrup 735-3352

Executive Summary

Development of this parcel will result in increased impervious surface and new sources ofgreenhouse gas emissions. Opportunities exist to preserve natural resources while reducing theenvironmental impact on-site. As discussed at the PLUS meeting, the Department recommendsreducing the environmental impact on-site through appropriate consideration of the PollutionControl Strategies to protect natural resources and the overall health of the community. Thisincludes waste reduction and resource conservation measures that will also improve long termregional sustainability.

The State of Delaware is threatened by climate change and has a goal of reducing greenhouse gas

emissions by 30 percent by 2030. Appropriate development that provides access to publictransportation, opportunities to walk and bike to shopping and recreation, and that employsenergy efficient building standards are among key strategies to meet these goals. DNRECencourage the use of high performance building standards and consideration of alternativeenergy sources to promote clean sustainable energy and reduce greenhouse gas emissions. Thiscould mean siting the buildings to take advantage of solar and geothermal systems, andlorincluding infrastructure for electric vehicle charging stations (funding assistance may be found atwww.de.gov/cleantransportation). DNREC further recommend an abundant use of native

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vegetation and shade trees throughout the landscape, as well as green infrastructure, wherepracticable, to absorb carbon dioxide, protect water quality and provide relief to residents on hotdays.

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

Water Quality: TMDLso The project is located in the greater Delaware River and Bay drainage area, specifically

within the Broadkill River watershed. In this watershed, the State of Delaware hasdeveloped specific Total Maximum Daily Load (TMDL) pollutant reduction targets fornitrogen, phosphorus, and bacteria (under the auspices of Section 303(d) of the CleanWater Act). A TMDL is the maximum level of pollution allowed for a given pollutantbelow which a "water quality limited waterbody" can assimilate and still meet Statewater quality standards (e.g., dissolved oxygen, nutrients, and bacteria; State of DelawareSurface Water Quality Standards, as amended July 1I,2004) to the extent necessary tosupport use goals such as, swimming, fishing, drinking water and shell fish harvesting.The TMDL for the Broadkill River watershed calls for a 40 percent reduction in nitrogenand phosphorus from baseline conditions. The TMDL also calls for a75 percentreduction in bacteria from baseline conditions.

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) 739-4811for further information conceming compliance requirements or view additionalinformation here : http ://dda. delaware. gov/nutrients/index. shtml

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Water Supplyo Should dewatering points be needed during any phase of construction, a dewatering well

construction 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 construction schedule.Dewatering well permit applications typically take approximately four weeks to process,which allows the necessary time for technical review and advertising.

Potential Contamination Sources exist in the area, and any well permit applications willundergo a detailed review that may increase turnaround time and may require site

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specific conditions/recommendations. In this case, there are two (2) Underground StorageTank sites associated with: l) Adams Oil Company and2) Cape Henlopen High Schoollocated within 1,000 feet of the proposed project. Should you have any questionsconcerning these comments, please contact Rick Rios, at (302) 739-9944.

Sediment and Erosion ControUStormwater Management.o A detailed sediment and stormwater plan will be required prior to any land disturbing

activity taking place on the site. Contact the reviewing agency to schedule a pre-application meeting to discuss the sediment and erosion control and stormwatermanagement components of the plan. The site topography, soils mapping, pre- and post-development runoff, and proposed method(s) and location(s) of stormwater managementshould be brought to the meeting for discussion. The plan review and approval as well as

construction inspection will be coordinated through the Sussex Conservation District.Contact the Sussex Conservation District at (302) 856-7219 for details regardingsubmittal requirements and fees.

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

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

Table 1: Potential Regulatorv RequirementsRequlation Requirements7 DE Admin. Code 1106 -Particulate Emissions fromConstruction and MaterialsHandling

Use dust suppressants and measures toprevent transport of dust off-site frommaterial stockpile, material movement anduse ofunpaved roads.

Use covers on trucks that transport materialto and from site to prevent visibleemissions.

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7 DE Admin. Code ll44 -Control of StationaryGenerator Emissions

Ensure that emissions of nitrogen oxides(NO*), non-methane hydrocarbons(NMHC), particulate matter (PM), sulfurdioxide (SOz), carbon monoxide (CO), andcarbon dioxide (COz) from emergencygenerators meet the emissions limitsestablished. (See section 3.2).

Maintain recordkeeping and reportingrequirements.

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7 DE Admin. Code 1145 -Excessive Idling of HeavyDuty Vehicles

Restrict idling time for trucks and buseshaving a gross vehicle weight of over 8,500pounds to no more than 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/AQM/Paees/AirRe gulations. aspx

Recyclingo Delaware Law (7 Del.C.. $6053) and Regulations (7 Del. Admin. C. $1305) specify that

the 'commercial sector' shall participate in a comprehensive recycling program. As such,all those involved with the planning of the facilities should allocate space for collectionof recyclables that would be typically generated. For example, space for a recyclingdumpster should be provided adjacent to each trash dumpster.

The Universal Recycling Law (7 Del.C.. $6053) and Regulations (7 Del. Admin. C.

S1305) require all waste service providers to provide recycling collection to theirresidential customers including multi-family residential settings. Propertyowners/managers must provide information to residents and help facilitate services.Every trash dumpster should have an adjacent recycling dumpster. Those involved withthe planning of new facilities should allocate space for collection of recyclables.

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For more information or assistance related to recycling requirements, benefits, tools, andassistance please call Don Long, at (302) 739-9403.

State Historic Preservation Offîce - Contact Terrence Burns 736-7404This parcel has no known archaeological sites or National Register-listed property. If anyproject or development proceeds, the developer should be aware of the Unmarked HumanBurials and Human Skeletal Remains Law. Prior to any demolition or ground-disturbingactivities, the developer should hire an archaeological consultant; to examine the parcelfor archaeological resources, including unmarked human burials or human skeletalremains, to avoid those sites or areas.

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Abandoned or unmarked family cemeteries are very common in the State of Delaware.They are usually in rural or open space areas, within or near the boundary, of ahistoricfarm site. Even a marked cemetery can frequently have unmarked graves or burialsoutside of the known boundary line or limit. Disturbing unmarked graves or burialstriggers the Delaware's Unmarked Human Burials and Human Skeletal Remains Law(Del. C. Title 7, Ch. 54), and such remains or discoveries can result in substantial delayswhile the procedures required under this law are carried out. If there is a discovery of anyunmarked graves, burials or a cemetery, it is very costly to have them archaeologicallyexcavated and the burials moved. The Division of Historical &. Cultural Affairsrecommends that owners andlor developers have a qualified archaeological consultantinvestigate their project area, to the full extent, to see if there is any unmarked cemetery,graves, or burial sites. In the event of such a discovery, the Division of Historical &Cultural Affairs also recommends that the plans be re-drawn to leave the full extent of thecemeteries or any burials on its own parcel or in the open space area of the development,with the responsibility for its maintenance lying with the landowner association or

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development. If you would like to see more information, please review the followingwebsites : www.history.delaware.gov/preservation/umhr.shtml andwww.history. delaware.qov/preservation/cemeteries.shtml.

a If there is federal involvement, in the form of licenses, perrnits, 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(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 jeopardize the 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 Offïce - Contact John Rudd 739-4394At 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 Water Requirements :

o Water distribution system capable of delivering at least 1000 gpm for l-hour duration, at20-psi residual pressure is required. Fire hydrants with 800 feet spacing on centers.

o V/here a water distribution system is proposed for a business or a heath care site, theinfrastructure for hre protection water shall be provided, including the size of watermains for fire hydrants and sprinkler systems.

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

installed.o Buildings greater than 10,000 sq. ft., 3-stories or more, over 35 feet, or classified as High

Hazard, 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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Accessibility:o All premises, which the fire department may be called upon to protect in case of fire, and

which are not readily accessible from public roads, shall be provided with suitable gates

and access roads, and fire lanes so that all buildings on the premises are accessible to fireapparatus. This means that the access road to the subdivision from Kings Highway mustbe 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.o Any dead end road more than 300 feet in length shall be provided with a turn-around or

cul-de-sac arranged such that fire apparatus will be able to turn around by making notmore than one backing maneuver. The minimum paved radius of the cul-de-sac shall be38 feet. The dimensions of the cul-de-sac or turn-around shall be shown on the finalplans. Also, please be advised that parking is prohibited in the cul-de-sac or tum around.

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

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

Gas Pipine and System Information:Provide type of fuel proposed, and show locations of bulk containers on plan.(J

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 O{FPA) Construction Typeo Maximum Height of Buildings (including number of stories)o Note indicating if building is 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, even for County Roads

Recom m end ations/Ad d itional Info rmationThis 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 \ryay required) that the applicant will open a dialogue with therelevant agencies to discuss how these suggestions can benefit the project.

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I)enartment of Transnortation - Bill Brockenbroush 7 60-2109Both of the roads on which the site fronts are part of the Historic Lewes Byway, theapplicant should expect the following requirements:

o Byways signs may be required along both roads as part of the plan reviewprocess.

o There is a Kings Highway Master Plan for future roadway and right-of-wayimprovements. Improvements to Kings Highway, from Dartmouth Drive toFreeman Highway, to be designed and built consistent with that Master Plan, arefunded in DeIDOT's Capital Transportation Program for Fiscal Years 2019through 2024 for Preliminary Engineering in Fiscal Years 2023 and2024.Depending on the project schedule, the applicant may be required to undertakepart of the Master Plan construction and/or reserve greater or additional rights-of-way. The Master Plan is available athttos ://www. deldot. sov/Pro s cmpiKHGN MasterPlan 0926l6ftnakx.pdf .

o As part of the plan review process, the applicant may be required to look forcontext sensitive design solutions with regard to their entrance design andlocation and screening of their development from the two frontage roads.

o The applicant may be asked to work with or provide updates to the Lewes BywayCommittee.

To assist in meeting the entrance spacing criteria discussed above, DeIDOT recommendsthat the developer consider combining their access on Savannah Road with NorthAtlantic Drive in Henlopen Gardens to form a single access opposite Donovans Road(Sussex Road 263). Doing so would require the concurrence of the Henlopen GardensHomeowners Association but could result in a better entrance for both properties.

a In accordance with Section 3.5.4.3 of the Manual, DeIDOT recommends that internalwalkways be provided to connect the senior living facility to the medical office buildings,the medical offrce buildings to each other and all three buildings to the pedestrianfacilities along the site frontages.

o Along Savannah Road, the subject development is only 230 feetfrom the Lewes-Georgetown Rail-Trail. If rights-of-,way or easements can be obtained along the frontageof the two intervening properties, extension of the pedestrian facilities that will berequired along the property frontage to connect to the trail would provide a significantamenity.

The applicant should expect a requirement that any substation andlor wastewaterfacilities will be required to have access from an intemal driveway with no direct access

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to Kings Highway or Savannah Road.

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 as of August 1,2015, all new plan submittals and re-submittals,including major, minor and commercial plans, shall now be uploaded via the PDCA(Planning Development Coordination Application) with any review fee paid online viacredit card or electronic check. Guidance on how to do this is available on our website athttp ://www. deldot. gov/Business/subdivisions/index. shtml.

Please be advised that the Standard General Notes have been updated and posted to theDeIDOT website. Please begin using the new versions and look for the revision date ofOctober 11,2017. The notes can be found athttp ://www.deldot. gov/Business/subdivisions/index. shtml

Department of Natural Resources and Environmental Control - Contact MichaelTholstrup 735-3352

Nuisance Waterfowlo Wet ponds created for stormwater management purposes may attract resident Canada

geese and mute swans that will create a nuisance for community residents. Highconcentrations of waterfowl in ponds create water-quality problems, leave droppings onlawn and paved areas and can become aggressive during the nesting season. Shortmanicured lawns surrounding ponds provide attractive habitat for these species.

To deter waterfowl from taking up residence in these ponds, DNREC recommendsplanting the surrounding open space with a mix of native wildflower plantings (to beplanted in accordance with the Sediment and Stormwater Plan approval agencyrequirements). It is best to mow the open space area surrounding the pond only once a

year, either in February or March. If mowing must occur more often, it would be helpfulto leave a minimum buffer of 15-30 feet in width to be mowed annually. This area wouldbe necessary to adequately deter the waterfowl from inhabiting the area (when the viewof the surrounding area from the pond is blocked, geese can't scan for predators and areless likely to reside and nest in the area of the pond). In addition to deterring nuisancewaterfowl, the native wildflower mix will also serve to attract bees, butterflies, and otherpollinators, and reduce run-off.

Additional information on TMDLs and water qualityo In response to concems about the need for reducing nonpoint source nutrient (nitrogen

and phosphorus) and bacterial pollutants to levels sufficient to meet the TMDL reductionrequirements prescribed for waters of the greater Broadkill River watershed, amultifaceted and comprehensive process known as a pollution control strategy (PCS) wasdeveloped. Specifically, a PCS is a combination of best management practices andcontrol technologies that reduce nutrient and bacterial pollutant runoff loading in waters

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of a given watershed to level(s) consistent with the TMDL(s) reduction levels specifiedfor that watershed. The PCS for the Broadkill River watershed consists ofrecommendations from the following three areas: agriculture, stormwater, andwastewater. Although the Pollution Control Strategy (PCS) has been established for theBroadkill watershed, implementation of the TMDL load reduction requirement(s) to aspecific project(s) is hampered by circumstance that the PCSs' strategies are entirelyvoluntary in nature.

Additional information about Broadkill River PCS can be reviewed in the follow weblink: http://www.dnrec.delaware.gov/swc/walPages/WatershedManagementPlans.aspx

In further support of the PCS, the applicant is also strongly urged to reduce nutrient andbacterial pollutants through voluntary commitment to the implementation of thefollowing recommended best management practices :

o Maintain as much of the existing open space as possible in this parcel. DNRECfurther suggest additional native tree, shrub andlor native herbaceous vegetationplantings in available open space, wherever possible.

o Employ green-technology storm water management and a rain gardens, in lieu ofopen-water stormwater management structures, as best management practices tomitigate or reduce nutrient and bacterial pollutant runoff. If open-waterstormwater management is selected (and approved) for use, these structuresshould be minimized to the extent possible while meeting their intended purpose.Based on information provided in the PLUS application, the applicant isproposing at least four (4) stormwater management ponds which, DNRECbelieve, is far in excess of what is necessary and is inconsistent with principles ofgood environmental design. Open-water stormwater ponds are problematicbecause they attract nuisance geese and help create conditions conducive forgrowth of nuisance algae (via nutrients from goose waste and nutrient runoff fromresidential development), while further contributing to the degradation of overallwater quality in the watershed. DNREC strongly recommend that the applicantemploy green-technology stormwater management instead of open-waterstormwater management.

o Assess nutrient and bacterial pollutant loading at the preliminary project designphase. To this end, the Watershed Assessment Section has developed a

methodology 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 uses; thus providing applicants and governmental entities with quantitativeinformation about the project's impact(s) on baseline water quality. DNRECstrongly encourages the applicant/developer use this protocol to help them designand implement the most effective best management practices. Please contact John

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Martin of the Division of V/atershed Stewardship, at (302) 739-9939 for moreinformation on the protocol.

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;o The emission of greenhouse gases which are associated with climate change, ando The emission of air toxics.

Based on the information provided, the area, power and mobile source emissions, werequantified. Table 2 - Projected Air Quality Emissions represents the potential impact thatOA Vantage Point may have on air quality.

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Table 2: OA Vantage Point - Senior Livins and Medical OffTce ComplexEmissionsAttributableto the OAVantagePoint -SeniorLiving andMedicalOfficeComplex(Tons perYear)

VolatileOrganicCompounds(voc)

NitrogenOxides

Nox)

SulfurDioxide(Soz)

FineParticulateMatter(PMz s)

CarbonDioxide(Coz)

Area sourceemissions

5.4 0.6 0.s 0.6 22.0

Poweremlssl0ns

* 2.1 7.5 {< 1,101.5

Mobileemissions

8.0 8.4 0.2 0.1 5,172.1

Totalemlsslons

13.4 I 1.1 8.2 0.7 6,295.6

(*) Indícates data is not available

Note that emissions associated with the actual construction of the senior living andmedical office complex, including automobile and truck traffìc from working in, ordelivering products to the site, as well as site preparation, earth moving activities, roadpaving and other miscellaneous air emissions, are not reflected in the table above.

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Site-specific recommendations :

o Planting of native shade trees in parking areas to clean the air of localizedpollutants and cut down on energy/cooling costs.

o A walking trail of some kind would be a nice amenity, especially for thosepatients who undergoing rehabilitative care. Ideally, this trail could connect to the1.10 miles Lewes-Georgetown Rail to Trail project and could be marketed as aunique feature.

o Use the minimum amount of parking spaces needed and consider reducing thewidth of parking spaces to limit the amount of impervious cover.

o The use of open grade recycled asphalt pavement (RAP) or selection of a coolpavement, which reduces heat island effects on paved surfaces.

o The inclusion of electric vehicle charging in convenient, public areas.o Use of energy efficient products in construction to lessen the power source

emissions of the project and costs.

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.

Planting of Native Trees: An element that the developer could incorporate is trees. Treescontain several benefits including:

o Significantly reducing automobile emissions including those from pollutants suchas nitrogen oxides (Ì.{Ox), volatile organic compounds (VOCs), and the mostharmful of all, particulate matter (PM) by trapping gases fumes and replenishingthe oxygen into the ambient air;

o Reducing the effects of heat islands by helping to cool asphalt and pavementwhich also lessens the chances of ozone formation;

o Trees create healthy communities by promoting an active living and generatingattractive places to walk and live;

o Trees can prevent flooding and stormwater problems. A typical street tree canintercept anywhere between 400 to 760 gallons of water per day;

o Increasing biodiversity by providing habitat for protected and sensitive species;o Providing shade forparking areas and lessens localized ground-level ozone

formation (a pollutant);o Reducing home and business costs. This includes reducing energy emissions by

cooling during the summer and by providing wind breaks in the winter, wherebyreducing air conditioning needs by up to 30 percent and saving 20 to 50 percenton fuel costs.

All urban trees that are selected should be native to Delaware and preferably low VOCemitting trees. Every tree has a different biogenic emissions rate by which they releaseVOC's into our atmosphere. VOC's are a component of smog and when mixed with othergases in the atmosphere (nitrogen oxide or NOx) in the presence of sunlight cancontribute to air pollution risks. As a general reminder, the best trees to plant are thosethat have: 1) a large leaf surface area at maturity, 2) contain leaf characteristics that are

amenable to particle collection from particulate matter (PM) such as those that have hairy

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or sticky leaves and 3) Have high transpiration rates which result in relatively hightemperature reduction.

Energy Efficient Options: 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 as well as third-party certifications and building materials (i.e. LEED,Greenseal, Ecologo). Every percentage of energy efficiency translates into a percentreduction in pollution.

Economic benefits include:o Reduced operating costso Enhanced asset value and profitso Enhanced occupant comfort and healtho Improved air, thermal, and acoustic environments

The Energy Star Program is an excellent way to save on energy costs and reduce airpollution. Some approaches may include architectural devices, energy efficient lighting,vegetation, or solar panels. Such measures can also have the additional benefit ofchanneling or infiltrating storm water. For more about energy efficient options, pleasesee: https://www.energystar.gov/ or https://www.epa.gov/greeningepa/energy-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. DAQ suggests the addition of a walking trail in the development plan toattach to the adjacent Lewes-Georgetown Trail or to encourage multi-modal travelopportunities. Sharrows and striping are the easiest and most cost effective option. Multi-modal travel can significantly reduce mobile source emissions. For every vehicle trip thatis replaced by the use of a sidewalk or bike path, 7 pounds of VOC and 1 1 .5 pounds ofNOx are reduced each year. Another great feature for this development would be theaddition of a bike rack in common areas (such as in front of the clubhouse.)

There is a transit stop conveniently located near this facility (Bus Route 204 Inbound and206 Outbound.) It is suggested that the OA Vantage Point take advantage of thisopportunity by expanding transit services to this subdivision. For further information ontransit availability in your area, please see:

http ://dartfirststate. com/information/routes/index. shtml

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 in common areas such as near the medicalcomplex building if feasible.

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a Facility Beautification: Lastly, the developer is encouraged to beautify the medicalfacility and senior living site with landscaping that would not only make the project moreattractive but also help to clean the air of any pollutants that could be emitted byneighboring sources. This would also reduce its impact on the surrounding communityafter undergoing the construction process while also incorporating a context-sensitivedesign that blends well with the surrounding development and existing land uses.

Should the developer have any more questions or concems, the DNREC Division 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 to contact the DNRECDAQ to discuss any mitigation measures that will be incorporated into the OA VantagePoint, Senior Living and Medical Office complex project. DNREC looks forward toworking together with you on this project to achieve our shared air quality, healthycommunity and quality of life goals.

Additional information on recycling and reducing water useo Materials and resources utilized for new development should be considered, including

regionally available recycled content (i.e. carpet, concrete, countertops, furniture, siding,etc.), rapidly renewable material and certified woods.

Construction Waste Management should include policies which promote efhcientmaterial use and recycling of project debris).

Employ systems and appliances that increase water efficiency and reduce water use.o Low-flow and high-efficiency itemso Waterless urinalso graywater recycling systemso Rainwater catchment

Delaware State tr'ire Marshallts - Contact John Rudd 739-4394Preliminary meetings with fire protection specialists are encouraged prior to formalsubmittal. Please call for appointment. Applications and brochures can be downloadedfrom our website: www.statefiremarshal.delaware.gov technical services link, planreview, applications or brochures.

o The facility may be required to be licensed by the Department of Health and SocialServices (DHSS), specifically the Office of Health Facilities Licensing & Certification(OHFLC). Additionally, the Center for Medicare and Medicaid Services (CMS) mayimpose additional requirements if applicable. Suggest that you contact Corrina Getchellof OHFLC for additional information at (302)283-7220.

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Following receipt of this letter and upon filing 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.

Sincerely,

C. CPDirector, Office of State Planning Coordination

CC: Sussex CountyCity of Lewes