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HomeMy WebLinkAbout20090186 Ver 1_Staff Comments_20100224Mcmillan, Ian From: Karoly, Cyndi Sent: Wednesday, February 24, 2010 12:29 PM To: Mcmillan, Ian Subject: FW: Crawford Project in Danbury, NC Attachments: FW: Construction Problems -----Original Message----- From: Lucas, Annette Sent: Monday, November 23, 2009 2:05 PM To: Matthews, Matt; Karoly, Cyndi Subject: FW: Crawford Project in Danbury, NC Matt and Cyndi - Just to be clear, I want to let you know that Option 1 that Steve Tedder has proposed for this project does not meet the current requirements of the GC (nor the future version of the GC either). Of course Sue and I will honor the commitment that Steve has made to this applicant. I just wanted to put in my two cents for future understanding of the program. The huge issue that is being overlooked is that the pharmacy is just one phase of a much larger project. The applicant should not be allowed to call it "low density" based on all the adjacent undeveloped land that he owns and plans to develop later. (That is a policy that both the 401 and SW units currently follow.) If we isolate the pharmacy phase of the project, then it is well over 24% impervious. Thanks, Annette -----Original Message----- From: Wakild, Chuck Sent: Monday, November 23, 2009 1:43 PM To: jmturpin@windstream.net Cc: Tedder, Steve; Matthews, Matt; Sullins, Coleen; Karoly, Cyndi; Lucas, Annette Subject: RE: Crawford Project in Danbury, NC John, I have discussed the stormwater permitting issues you raised in your email with appropriate staff members. As a result our regional supervisor, Steve Tedder, has discussed possible alternatives for your project with your engineer. Steve's email to Eddie Bunn is attached. While too late for your project, we agree that the current general certification lacks clarity about when a stormwater permit may be required even when the low density option is used for an entire project and we are in the process of claifying the certification. I also discussed Sue Homewood's approach with Steve (her supervisor) and reminded him of our intent to provide professional customer service to all DWQ customers. If you have further questions, please let me know. -----Original Message----- From: J. Turpin [mailto:jmturpin@windstream.net] Sent: Wednesday, November 18, 2009 2:50 PM To: Wakild, Chuck 1 Subject: Crawford Project in Danbury, NC Mr. Wakild, we have a project in Danbury, NC that we plan on constructing. I was hoping for an onsite visit with you along with Steve Tedder, Sue Homewood, and our Engineer. Here is a brief description below. In April 2009 Crawford at Danbury was granted from DENR, DOT and Army Corp of Engineers permits for development. Bunn Engineering in Mount Airy had submitted site plans for an eight acre phase 1 development. The site had met all requirements of leaving the "stream" in front undisturbed except for 147 feet and the plan was under 24 percent impervious sedimentation requirement.. As a courtesy, Eddie Bunn sent Sue Homewood, Division of Water Quality in Winston-Salem (336- 771-4964) a copy of the plans just for her info. When received, she called my home many times warning that we were a candidate for a storm water runoff control plan. She never called Eddie but warned me to not begin the project or she would be "shutting it down". Eddie in turn, called to remind her that the property was in compliance. Ms Homewood called me again warning me of the "violation" of the final paragraph of the regulation that "she authored" which stated that even though this property was well within the limits that it was at the DWQ's discretion to stop development. Eddie then called Ms Annette Lucas (919-733-5083 in Raleigh ((401 Wetlands Unit) (Homewood"s boss)) to present her with the site plans and request a visit to the site. She declined an on site visit but agreed to review the plans that were sent to her on 10/23/09. Anyone who views the property can see that a storm water runoff plan shouldn't be required. We got an email from Eddie on 11/09/09 stating that Ms. Lucas is requiring a new application from us to just review what we already submitted and know has passed the test. We are now stuck with having to apply for another permit that we don't need, months of delay and who knows how much more money. Our permits ($50,000.00 cost) that has been granted expires 06/01/2010 and we haven't been able to stick a shovel in the ground. We have a Stokes county business ready to expand and Stokes county contractors ready to start building. We have had two offers to purchase, one of which is still waiting; the second notified us yesterday that time was running out that they were going to have to look elsewhere at less desirable options - that happens to be a Danbury Municipal well and tank site Thanks, John Turpin cell anytime 336-978-1611 2 Mcmillan, Ian From: Karoly, Cyndi Sent: Wednesday, February 24, 2010 12:29 PM To: Mcmillan, Ian Subject: FW: Crawford Project in Danbury, NC Attachments: FW: Construction Problems -----Original Message----- From: Wakild, Chuck Sent: Monday, November 23, 2009 1:43 PM To: jmturpin@windstream.net Cc: Tedder, Steve; Matthews, Matt; Sullins, Coleen; Karoly, Cyndi; Lucas, Annette Subject: RE: Crawford Project in Danbury, NC John, I have discussed the stormwater permitting issues you raised in your email with appropriate staff members. As a result our regional supervisor, Steve Tedder, has discussed possible alternatives for your project with your engineer. Steve's email to Eddie Bunn is attached. While too late for your project, we agree that the current general certification lacks clarity about when a stormwater permit may be required even when the low density option is used for an entire project and we are in the process of claifying the certification. I also discussed Sue Homewood's approach with Steve (her supervisor) and reminded him of our intent to provide professional customer service to all DWQ customers. If you have further questions, please let me know. -----Original Message----- From: J. Turpin [mailto:jmturpin@windstream.net] Sent: Wednesday, November 18, 2009 2:50 PM To: Wakild, Chuck Subject: Crawford Project in Danbury, NC Mr. Wakild, we have a project in Danbury, NC that we plan on constructing. I was hoping for an onsite visit with you along with Steve Tedder, Sue Homewood, and our Engineer. Here is a brief description below. In April 2009 Crawford at Danbury was granted from DENR, DOT and Army Corp of Engineers permits for development. Bunn Engineering in Mount Airy had submitted site plans for an eight acre phase 1 development. The site had met all requirements of leaving the "stream" in front undisturbed except for 147 feet and the plan was under 24 percent impervious sedimentation requirement.. As a courtesy, Eddie Bunn sent Sue Homewood, Division of Water Quality in Winston-Salem (336- 771-4964) a copy of the plans just for her info. When received, she called my home many times warning that we were a candidate for a storm water runoff control plan. She never called Eddie but warned me to not begin the project or she would be "shutting it down". Eddie in turn, called to remind her that the property was in compliance. Ms Homewood called me again warning me of the "violation" of the final paragraph of the regulation that "she authored" which stated that even though this property was well within the limits that it was at the DWQ's discretion to stop development. Eddie then called Ms Annette Lucas (919-733-5083 in Raleigh ((401 Wetlands Unit) (Homewood"s boss)) to present her with the site plans and request a visit to the site. She declined an on site visit but agreed to review the plans that were sent to her on 10/23/09. Anyone who views the property can see that a storm water runoff plan shouldn't be required. We got an email from Eddie on 11/09/09 stating that Ms. Lucas is requiring a new application from us to just review what we already submitted and know has passed the test. We are now stuck with having to apply for another permit that we don't need, months of delay and who knows how much more money. Our permits ($50,000.00 cost) that has been granted expires 06/01/2010 and we haven't been able to stick a shovel in the ground. We have a Stokes county business ready to expand and Stokes county contractors ready to start building. We have had two offers to purchase, one of which is still waiting; the second notified us yesterday that time was running out that they were going to have to look elsewhere at less desirable options - that happens to be a Danbury Municipal well and tank site Thanks, John Turpin cell anytime 336-978-1611 z Mcmillan, Ian From: Karoly, Cyndi Sent: Wednesday, February 24, 2010 12:29 PM To: Mcmillan, Ian Subject: FW: Crawford Project in Danbury, NC Attachments: FW: Construction Problems -----Original Message----- From: Lucas, Annette Sent: Monday, November 23, 2009 2:05 PM To: Matthews, Matt; Karoly, Cyndi Subject: FW: Crawford Project in Danbury, NC Matt and Cyndi - Just to be clear, I want to let you know that Option 1 that Steve Tedder has proposed for this project does not meet the current requirements of the GC (nor the future version of the GC either). Of course Sue and I will honor the commitment that Steve has made to this applicant. I just wanted to put in my two cents for future understanding of the program. The huge issue that is being overlooked is that the pharmacy is just one phase of a much larger project. The applicant should not be allowed to call it "low density" based on all the adjacent undeveloped land that he owns and plans to develop later. (That is a policy that both the 401 and SW units currently follow.) If we isolate the pharmacy phase of the project, then it is well over 24% impervious. Thanks, Annette -----Original Message----- From: Wakild, Chuck Sent: Monday, November 23, 2009 1:43 PM To: jmturpin@windstream.net Cc: Tedder, Steve; Matthews, Matt; Sullins, Coleen; Karoly, Cyndi; Lucas, Annette Subject: RE: Crawford Project in Danbury, NC John, I have discussed the stormwater permitting issues you raised in your email with appropriate staff members. As a result our regional supervisor, Steve Tedder, has discussed possible alternatives for your project with your engineer. Steve's email to Eddie Bunn is attached. While too late for your project, we agree that the current general certification lacks clarity about when a stormwater permit may be required even when the low density option is used for an entire project and we are in the process of claifying the certification. I also discussed Sue Homewood's approach with Steve (her supervisor) and reminded him of our intent to provide professional customer service to all DWQ customers. If you have further questions, please let me know. -----Original Message----- From: J. Turpin [mailto:jmturpin@windstream.net] Sent: Wednesday, November 18, 2009 2:50 PM To: Wakild, Chuck 1 Subject: Crawford Project in Danbury, NC Mr. Wakild, we have a project in Danbury, NC that we plan on constructing. I was hoping for an onsite visit with you along with Steve Tedder, Sue Homewood, and our Engineer. Here is a brief description below. In April 2009 Crawford at Danbury was granted from DENR, DOT and Army Corp of Engineers permits for development. Bunn Engineering in Mount Airy had submitted site plans for an eight acre phase 1 development. The site had met all requirements of leaving the "stream" in front undisturbed except for 147 feet and the plan was under 24 percent impervious sedimentation requirement.. As a courtesy, Eddie Bunn sent Sue Homewood, Division of Water Quality in Winston-Salem (336- 771-4964) a copy of the plans just for her info. When received, she called my home many times warning that we were a candidate for a storm water runoff control plan. She never called Eddie but warned me to not begin the project or she would be "shutting it down". Eddie in turn, called to remind her that the property was in compliance. Ms Homewood called me again warning me of the "violation" of the final paragraph of the regulation that "she authored" which stated that even though this property was well within the limits that it was at the DWQ's discretion to stop development. Eddie then called Ms Annette Lucas (919-733-5083 in Raleigh ((401 Wetlands Unit) (Homewood"s boss)) to present her with the site plans and request a visit to the site. She declined an on site visit but agreed to review the plans that were sent to her on 10/23/09. Anyone who views the property can see that a storm water runoff plan shouldn't be required. We got an email from Eddie on 11/09/09 stating that Ms. Lucas is requiring a new application from us to just review what we already submitted and know has passed the test. We are now stuck with having to apply for another permit that we don't need, months of delay and who knows how much more money. Our permits ($50,000.00 cost) that has been granted expires 06/01/2010 and we haven't been able to stick a shovel in the ground. We have a Stokes county business ready to expand and Stokes county contractors ready to start building. We have had two offers to purchase, one of which is still waiting; the second notified us yesterday that time was running out that they were going to have to look elsewhere at less desirable options - that happens to be a Danbury Municipal well and tank site Thanks, John Turpin cell anytime 336-978-1611 2 Mcmillan, Ian From: Karoly, Cyndi Sent: Wednesday, February 24, 2010 12:29 PM To: Mcmillan, Ian Subject: FW: crawford Village 09-0186 From: Homewood, Sue Sent: Thursday, November 19, 2009 12:28 PM To: Lucas, Annette; Karoly, Cyndi Cc: Tedder, Steve Subject: FW: crawford Village 09-0186 Fyi - here's an old string of emails that were between some phone conversations about this project that's rearing its head now. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Homewood, Sue Sent: Friday, June 05, 2009 1:35 PM To: Lucas, Annette Cc: Karoly, Cyndi Subject: RE: crawford Village 09-0186 Hi Cyndi, I hate being a pest about this but I'm afraid I'm going to have to do enforcement when they build without doing an SIVIP and I want my ducks in a row by warning them by letter that their analysis is wrong. Have you had a chance to come up with some language for this? Thank you very much. Please note my new email address Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 1 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lucas, Annette Sent: Tuesday, May 26, 2009 11:27 AM To: Homewood, Sue Cc: Karoly, Cyndi Subject: RE: crawford Village 09-0186 Sue, Cyndi has the file and she's working on language for a response that you can cut/paste into a second hold letter - thanks Cyndi! AZ From: Homewood, Sue Sent: Friday, May 22, 2009 2:26 PM To: Lucas, Annette Cc: Strickland, Bev Subject: RE: crawford Village 09-0186 documents attached, this is all I have. I'm copying Bev so she'll include in laserfische (Bev, documents only please, not the emails between Annette and myself) since I don't know how to upload *yet*. The only drawing we have is the one they submitted with the original application. I can't make any more progress with them. Thanks for your help. Happy long weekend. Please note my new email address Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lucas, Annette Sent: Friday, May 22, 2009 1:54 PM To: Homewood, Sue Subject: RE: crawford Village 09-0186 Sue, Sorry I let this slip - thanks for the reminder. I just checked laserfiche and the file and the more recent submittal is not there. Can you scan and either email or put in laserfiche? Spreadsheet attached. Z From: Homewood, Sue Sent: Friday, May 22, 2009 10:34 AM 2 To: Lucas, Annette Subject: RE: crawford Village 09-0186 Hey Annette, Have you had a chance to look this over? Thanks. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lucas, Annette Sent: Monday, May 11, 2009 1:03 PM To: Homewood, Sue Subject: RE: crawford Village 09-0186 So do you want us to provide feedback at this point re the high/low density issue based on the plan sheet we have? If so, let me know what you're timeframe is please. Thanks, Z From: Homewood, Sue Sent: Monday, May 11, 2009 1:00 PM To: Lucas, Annette Subject: RE: crawford Village 09-0186 they submitted a courtesy copy a month ago, I told them it didn't meet the 401 requirements, specifically stormwater and they are responding that it does. so there is a small plan sheet in laserfische or the file, that at least will show you the layout and their analysis. thanks. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Lucas, Annette Sent: Monday, May 11, 2009 12:58 PM To: Homewood, Sue Subject: RE: crawford Village 09-0186 No problem . Can't get into BUS right now - has it already been submitted? 3 From: Homewood, Sue [mailto:sue.homewood@ncdenr.gov] Sent: Friday, May 08, 2009 3:07 PM To: annette.lucas@ncmail.net Subject: FW: crawford Village 09-0186 I would appreciate if you and Cyndi would look at this project in very specific detail. If we believe he needs an SMP as I thought, I would like to send the owner another formal letter stating that so when I go to enforce penalties we have that as documentation. If you agree with his analysis just let me know. Thanks. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Eddie H. Bunn [mailto:civil@bunnengineering.com] Sent: Thursday, May 07, 2009 3:25 PM To: Homewood, Sue Cc: Annette Lucas; sandra turpin; Anthony Thomas Subject: Re: crawford Village 09-0186 Sue, I have developed the site plans using the same rules you are referring to. We do not exceed the threshold limits requiring stormwater management. Even with the official definition of "drainage area" our coverage for this project is still less than 24%. Therefore we have met all the conditions that apply to this development. Please don't apply the proposed rules stated in the March 12 2009 memo. The regulations that are adopted must be interpreted as they are written. Thank You Eddie ----- Original Message ----- From: Homewood, Sue To: Eddie H. Bunn Sent: Wednesday, May 06, 2009 3:12 PM Subject: RE: crawford Village 09-0186 The NW39 standard conditions states that it is not valid without a corresponding 401: http://www.saw.usace.army.mil/WETLANDS/`NWP2007/PDF-SAW-NWP2007/NWP39 6-07.0df see items 21 and 23. Our corresponding 401 is the GC 43705 which explains when a written authorization is necessary and when it isn't within the first introductory paragraphs. In this specific case the language can be found on page 2 of the GC, immediately above the Condition #1: the link to the GC is: http://h2o.enr.state.nc.us/ncwetlands/documents/WQC3705.pdf (sorry, it's a pdf so it won't let me cut and paste the text) Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Eddie H. Bunn [mailto:civil@bunnengineering.com] Sent: Wednesday, May 06, 2009 1:00 PM To: Homewood, Sue Subject: Re: crawford Village 09-0186 Dear Sue, Let's sort this e-mail out one item at a time. What do you mean by "automatic when a USACE 404 is issued" Please refer me to the regulation. Thank You Eddie ----- Original Message ----- From: Homewood. Sue To: civil(d.bunnengineerinq com Cc: annette.lucasa().ncmail.net Sent: Wednesday, May 06, 2009 11:42 AM Subject: crawford Village 09-0186 Eddie, It is easier to put this in an email that contains quotes and links. As we discussed, I understand that your application for this project was a courtesy only application. My hold letter was intended to ensure you were aware that based on what was submitted, I did not think your project would be built in compliance with the 401 Conditions that become automatic when the USACE 404 is issued. The language from the 401 states "For applicants other than DOT a SMP is required ...... for every drainage area that contains more than 24% impervious area ...Where a pocket of high density exists or drainage areas are hard to delineate, the Division will use best professional judgment..." the link to the 401 is here: http://h2o.enr.state.nc.us/ncwetlands/documents/WQC3705.pdf its condition #12. The stormwater regulations define a drainage area as ""Drainage Area or Watershed" means the entire area contributing surface runoff to a single point." that language can be found at this link. http://h2o.enr.state.nc.us/admin/rules/2H.1000.pdf based on your drawings, you will have a road, a parking lot, and a drugstore with a curb and gutter system that directs the stormwater to a single point. This would meet the regulated definition of a "drainage area" regardless of how much undeveloped land is adjacent. In addition, even if you were to be able to eliminate the single point of discharge, in order to assure that the project stays as low density we would be required to see documentation that the areas adjacent that were being used to make a low density calculation were to be protected as undeveloped land, and you clearly stated in the PCN that the adjacent areas will likely be developed in the future. If you have more questions, or want to discuss this in more detail it would probably be best if you contact Annette Lucas directly and she can inform me of your discussions or any of her decisions. Her number is 919-715-3425. At this time, unless something different is decided by Annette after more review, if this project is constructed as proposed without a SMP it will be in violation upon occupancy and DWQ will issue a notice of violation and civil penalties. Sue Homewood NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4964 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. Mcmillan, Ian From: Karoly, Cyndi Sent: Wednesday, February 24, 2010 12:30 PM To: Mcmillan, Ian Subject: FW: Construction Problems -----Original Message----- From: Wakild, Chuck Sent: Wednesday, November 18, 2009 9:25 AM To: Matthews, Matt; Karoly, Cyndi; Lucas, Annette; Homewood, Sue; Tedder, Steve Subject: FW: Construction Problems Matt - please review and let's discuss asap. Thanks. -----Original Message----- From: Biser, Elizabeth Sent: Wednesday, November 18, 2009 9:21 AM To: Wakild, Chuck Subject: FW: Construction Problems Chuck, Please see the email chain below. Rep. Holloway will be giving me a call about this issue sometime this week. Can you see what you can find out about it and let me know? Thanks, Elizabeth -----Original Message----- From: Jeffrey Hudson (Research) [mailto:Jeffrey.Hudson@ncleg.net] Sent: Wednesday, November 18, 2009 9:02 AM To: Biser, Elizabeth Subject: FW: Construction Problems Elizabeth, Below is the request I mentioned to you yesterday. I've given Representative Holloway your office number. He will give you a call later this week. Thanks, Jeff Jeff Hudson Principal Attorney Research Division North Carolina General Assembly (919) 733-2578 -----Original Message----- From: Bryan Holloway [mailto:brholloway@windstream.net] Sent: Tuesday, November 17, 2009 12:44 PM To: Jeffrey Hudson (Research) Subject: FW: Construction Problems Jeffrey, Here is the e-mail that goes along with my message. Thanks, Rep. Bryan Holloway -----Original Message----- From: J. Turpin [mailto:jmturpin@windstream.net] Sent: Wednesday, November 11, 2009 4:08 PM To: brholloway@windstream.net; Don.East@ncleg.net Subject: Construction Problems Don and Bryan, attached is a problem we are having with the Division of Water Quality. Do you have any suggestions to help resolve this issue. To build this one building they are going to require a sediment pond that has to be monitored everytime it rains literally. The storm water run off plan is only required on projects over 24% impervious surfaces. This land is directly across from the government center in Danbury. In April 2009 Crawford at Danbury was granted from DENR, DOT and Army Corp of Engineers permits for development. Bunn Engineering in Mount Airy had submitted site plans for an eight acre phase 1 development. The site had met all requirements of leaving the "stream" in front undisturbed except for 147 feet and the plan was under 24 percent impervious sedimentation requirement.. As a courtesy, Eddie Bunn sent Sue Homewood, Division of Water Quality in Winston-Salem (336- 771-4964) a copy of the plans just for her info. When received, she called my home many times warning that we were a candidate for a storm water runoff control plan. She never called Eddie but warned me to not begin the project or she would be "shutting it down". Eddie in turn, called to remind her that the property was in compliance. Ms Homewood called me again warning me of the "violation" of the final paragraph of the regulation that "she authored" which stated that even though this property was well within the limits that it was at the DWQ's discretion to stop development. Eddie then called Ms Annette Lucas (919-733-5083 in Raleigh ((401 Wetlands Unit) (Homewood"s boss)) to present her with the site plans and request a visit to the site. She declined an on site visit but agreed to review the plans that were sent to her on 10/23/09. Anyone who views the property can see that a storm water runoff plan shouldn't be required. We got an email from Eddie on 11/09/09 stating that Ms. Lucas is requiring a new application from us to just review what we already submitted and know has passed the test. We are now stuck with having to apply for another permit that we don't need, months of delay and who knows how much more money. Our permits ($50,000.00 cost) that has been granted expires 06/01/2010 and we haven't been able to stick a shovel in the ground. We have a Stokes county business ready to expand and Stokes county contractors ready to start building. We have had two offers to purchase, one of which is still waiting; the second notified us yesterday that time was running out that they were going to have to look elsewhere at less desirable options - that happens to be a Danbury Municipal well and tank site. Rome is burning while these people are dancing. Can you help me with this insanity? Thanks, John Turpin Site plan 2 http://www.crawfordnc.com/maps/T080806 C-4.pdf