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Homewood, Sue
From:Jennifer Burdette <burdette@nrconsultnc.com>
Sent:Monday, November 29, 2021 1:58 PM
To:SVC_DENR.publiccomments
Subject:[External] Wetland Rules
Attachments:image002.wmz
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Proposed permanent rule Section .1400 – Discharges to Federally Non‐Jurisdictional Wetlands and Federally Non‐
Jurisdictional Classified Surface Waters provides a permitting system for discharges to this type of wetlands and
classified surface waters in North Carolina. Discharges are defined as deposition of dredge or fill material. Without a
permitting mechanism, discharges into these water resources would violate wetland and water quality standards.
Water quality standards (15A NCAC 02B .0211‐.0225) require maintenance of biological integrity. Biological integrity is
defined for water quality and wetland standards as the ability of an aquatic ecosystem to support and maintain a
balanced and indigenous community of organisms having species composition, diversity, population densities, and
functional organization similar to that of reference conditions. Wetland standards (15A NCAC 02B .0231) require the
maintenance of hydrological conditions necessary to support the biological and physical characteristics naturally present
in wetlands and populations of wetland flora and fauna to protect biological integrity.
Limiting the proposed rules to discharges does not provide a permitting mechanism for other types of impacts that
would violate water quality and wetland standards such as flooding and draining. These standards are important to
protect wetlands and classified surface waters and require permitting mechanisms for all types of impacts to ensure
proper avoidance, minimization and mitigation. Therefore, the rule should be expanded to apply to all types of impacts
that would violate water quality and wetland standards.
Jennifer Burdette
Natural Resource Consultants
10212 Creedmoor Road, Raleigh, NC 27615
burdette@nrconsultnc.com – 919.422.3605
Natural Resource
Consultants