NCS000400_Email RE Jamestown MS4 Permit Public Comments_20240609

Georgoulias, Bethany
From: Krisdena Foronato <[e-mail]>
Sent: Sunday, June 9, 2024 11:21 PM
To: Lawyer, Mike
Cc: Reed, Isaiah L; [e-mail]; [e-mail]
Subject: [External] DEMLR Stormwater Program, Jamestown NC NPDES MS4 Permit
NCS000400
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June 9, 2024
RE: DEMLR STORMWATER PROGRAM, JAMESTOWN NC NPDES MS4 STORMWATER PERMIT NCS000400
To Whom It May Concern:
Here are my public comments regarding the Town of Jamestown NPDES MS4 Stormwater Permit, NCSO400:
Section 3.5 Total Maximum Daily Loads (TMDLs)
Why is the Town of Jamestown only required to report on Fecal Coliform?
The Town of Jamestown and its extra-territorial jurisdiction is situated on 3 watersheds: Jamestown WS-IV, High Point
WS-IV, and Lower Randleman Lake WS-IV. The Lower Randleman Lake WS-IV is classified as a critically protected
watershed, possessing its own NCGS statute (formerly 15A NCAC 02B .0248, .0249, .0250, and .0252; Currently 15A
NCAC .0295, .0610, .0611, .0612, .0720, .0721, .0722, .0724; Randleman Lake Watershed WS-IV mentioned in .0295,
.0311, .0610, .0612, .0720, .0721, .0722, and .0724; Source: http://reports.oah.state.nc.us/ncac/title%2015a%20-
%20environmental%20guality/chapter%2002%20-
%20environmental%20management/subchapter%20b/subchapter%20b%20rules.pdf) Specifically, the Town of
Jamestown's Comprehensive Stormwater Management Plan is subject to 15A NCAC 02B .0721 (3) and (6), which place
stricter rules on stormwater requirements, riparian buffer, and land development, the latter which has been completely
ignored by the Town of Jamestown when approving the D.R. Horton (the former Johnson Farm, which is currently being
cleared of trees and vegetation), Harvey Road, and other developments in/around Jamestown. The Town is also required
to coordinate with the Piedmont Triad Regional Water Authority (PTRWA). This poses problems as the Town's appointed
PTRWA representative, Rich Glover, a non-resident, formerly of Jamestown Engineering (a.k.a. Town contractor, current
employee of Glover Engineering, who has represented property owners in front of the Town Planning Board and Town
Council (without mentioning his conflicts of interests as a Town of Jamestown contractor and/or PTRWA Board
representative), and currently sits as Chair and Town of Jamestown representative on the PTRWA Board).
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The Town of Jamestown is inhabited by many industrial contaminators, environmental polluters, Superfund sites, and
Brownfields. In the last 2 years Alberdingk Boley has released untreated wastewater containing excessively elevated
levels of 1,4-Dioxane into an "unnamed tributary" feeding into Bull Run, which empties into the Deep River, and travels
downstream to the Randleman Watershed. Considering the PTRWA is requesting $120M for a reverse osmosis water
treatment system, obviously our public drinking water source is contaminated. Yet, when the first Alberdingk spill occurred
between October 27-31, 2022, the Town of Jamestown denied responsibility for handling spill [note GIS and Jamestown
Zoning maps below, showing Alberdingk Boley (gray triangular property) is zoned CZ-IND and within Jamestown's ETJ],
which was estimated to be 16,000 gallons of untreated wastewater, and never notified the public regarding health and
safety concerns. Had it not been for a concerned citizen noticing a milky white substance in a nearby retention pond, this
spill would have gone unnoticed. It was other concerned citizens who had to point out to Town staff that Town of
Jamestown was responsible, although Alberdingk Boley resides in Guilford County, it falls into the Town of Jamestown
planning jurisdiction. For the second spill on November 8, 2023, the Town of Jamestown responded, notified a small, local
newspaper ("Jamestown News") of the spill after Town of Jamestown Town Council Elections took place. A former
Councilman, John Capes, the spill was cleaned up in a few hours. We have questioned the timing of the notification
(which still does not meet state requirements), the length of cleanup, and whether or not Alberdingk spill occurred before
and/or during the elections. A Jamestown resident has a pending FOIA for information regarding the November 8, 2023
spill, and her request is still pending. Knowing this, I urge the EPA and NCDEQ to expand the TMDL requirements for the
Town of Jamestown, at a minimum to include those contaminants produced by and/or found on/in/around these
properties and businesses.
AN EVEN BIGGER QUESTION: How many spills/contamination events have happened and gone undetected/unreported
due to the Town of Jamestown's neglect in failure to report, investigate, and enforce these spills?
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Section 3.6 Endangered and Threatened Species and Critical Habitat
This section lists "[s]ignificant populations of threatened or endangered species and/or critical habitat are identified within
the regulated MS4 urbanized area." However, what this section does not state is Deep River 17-(3.7), WS-IV;CA:*, 2.0
FW Miles, 4136 From Guilford County SR 1334 to dam at Oakdale Cotton Mills, Inc. (Town of Jamestown water supply
intake) appears on the 2024 North Carolina Draft 2024 303(d) List for Benthos (Nar, AL, FW) (IR Category S, Method 83)
and has been on the 303(d) list since 2018. Yet recent testing for the portion of the Deep River that runs through the Town
of Jamestown cannot be found, despite the fact Jamestown WWTP, High Point Eastside WWTP, and Richland Creek
were named as contributors to the contamination of the Deep River in decennial biological, chemical and
macro invertebrates studies performed in early 1970s, 1983,1992/93, and 1994. These studies seem to have disappeared
around/after 2003. In one report, it states, in low flow conditions, the Deep River consists of 74% wastewater. This fact is
very disturbing, considering the Deep River empties into the Randleman Reservoir, which serves as a public drinking
water source for Town of Jamestown, Guilford County, and surrounding area residents. And considering Deep River, Bull
Run, and its "unnamed tributaries" are not being regularly tested through Jamestown, how do we know the status of these
organisms, let alone the health of the area waterways and PTRWA drinking water, which originates in the Randleman
Reservoir?
NORTH CAR LINA DRA
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PARAMETER IRCATEGORY
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[Source: https://edocs.deg.nc.gov/WaterResources/DocView.aspx?dbid=0&id=3170580&cr=1]
Section 3.7 Industrial Facility Discharges
8

The list of 3 permittees (Teknor Apex-North Carolina, Highland Container Incorporated, and North Point Family Limited
Partnerships) seems rather basic and incomplete. At one time, I recall there being approximately 41 NPDES permittees in
the area. They may have not all been in Jamestown, but considering the number of industrial contaminators,
environmental polluters, Superfund and Brownfield sites, I would imagine there are many other permit holders missing
from this list and unaccounted for in the links referenced on application. I would check those properties that are situated in
High Point, Greensboro, and/or Guilford County that are under the Town of Jamestown planning jurisdiction as it appears
local and county government likes to confuse their residents and community members by drawing obscure boundaries
and imaginary lines to abscond form their monitoring and enforcement responsibilities. I would also like to question
whether the permits held are reflective of what is actually being manufactured or contained on the premises, as
Alberdingk Boley, a Germin resin manufacturer, has released untreated wastewater containing 1,4-dioxane into the
waterway, yet they have a Food Warehousing permit.
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Table 3
Pen&ttad Point Kurce Diechargcrs to W Deep River
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1. NC Dept. of Corrections (44 3) NCO0277 V1toWi fit Fork Deep iLk r
2. Florence Elam. School NCO058199 Ul' Lo Fat Fork Deep River
• 7h ee M*s Villa NWIP NCU1505 Bull Run Crook
4. Jnmw town W P NCO023183 SOP River
. AMP Atteraz Yaehts NC0o4 922 Ur to R1c?`+1and Creek
6. HISh Point Easts3de NC0O24210 Richland Creek �
7. Sbdae )d Subdivision NCO026 11 Registers Comm
der Elea. School N O03712 UT bo Mckary Creak
. Fly IrM M000141403 lT!' to Hickory Creek
10. Southern Gcd lfbrd Sr. B.S. NC0038 9 UT to Hickory Creek
11. Southern Elomentitary School NCO038091 U11" to Hickory Nxeck
12. Arablale Elam. School NCOO41017 U? to WAY Cr k
IT 711nd$le Momentary NCOC40894 HIM Creek
14. Wagnner "ccrai`t NCOCC�948 UT to m e y ry � pi
16. Vicks Mfg.. J+CO02792S Long
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17. tin Marietta - Pomona NCO000922 LongBrmammch
18. E.E. Frcem n Rcatdonce NCO051845 Ur to Dccp. Elver
19. Undon Oil C.o. N0002 47 U3' tD Est Pc& Deep River
20. Eurl Xearne ' 0 to RIChland Creek {
+ 21. WNW Cotton Nd 11 NCO002348 Deep River
. Colonial Pipeline M00031046 UT to East Fork Deep RdIver
. Water Service Co. N00050792 Muddq Creek �
24. Erxon Co. TUDNX195 UT to East Foek Deep River
25. LCP Plastics of N.C. VMS= UT to last Fook Deep River �
A vwtin % netts - Jamestown N 00O0914 UT to Uccp Rfvoeor
7. AsKend Oil mcco 8991 [TT to Eant F k Deep River
28. Phillips Pipellmn ILW3M3 UT to East Fork Deep River
29. Randleman 'i WW P NCO025445 Dew River
30. J.P. S teevveeyns NCO00IC07 Deep River
31. 'I lndty Middle School NCO029637 Mudly Creek I
32. Tex Elaatic AwporatIon MCO03584a UT to Noddy Creek I
13

)
[Source: North Carolina Department of Natural Resources and Community Development, Division of Environmental
Management Water Quality Section (February 1985). Water Quality Evaluation Upper Deep River Cape Fear River Basin
1983 (see attached file)]
Section 3.8 Non-Stormwater Discharges
The Town claims it "utilizes Public Education and Outreach and Pollution Prevention and Good Housekeeping BMPs",
however, take a look at what they have invested their monies into and what little return they are getting:
14

Town Social Media (Facebook, Instagram, X, etc.). They Town does little to promote public outreach and/or pollution
prevention. They cannot even properly notify their residents when health and safety issues arise (i.e., Alberdingk Boley
spills, water/air quality issues, etc.). Due to negative comments, the Town has resorted to making posts and immediately
turning off comments. Per a recent Supreme Court decision, this is "controlling the narrative" (Source: Public officials can
be held liable for blocking critics on social media - SCOTUSblog), yet the Town believes they are above the law.
Public officials can be held liable for blocking critics
on social media...
i-he Supreme Court on Friday ruled that public officials who post
about topics relating to their work on their pe...
- Town Events. The Town hosts a variety of events throughout the year, posing opportunities for public outreach and
education, yet fails to take advantage of these opportunities to do so. Most recently, Katie Gumerson and I were ejected
by Town Manager, Matthew Johnson, and Parks & Recreation Director, Scott Coakley, from a May 3, 2024 Town of
Jamestown Music in the Park event for peacefully protesting and educating Jamestown residents and the community
about the May 1, 2023 press release by NC DEQ regarding North Carolina ranking 3rd in nation and Guilford County
ranking 1st in North Carolina regarding excessive concentrations of 1,4-Dioxane in our drinking water. This is clearly a
violation of our First Amendment rights as well as the PARTF grant obligations (discrimination based on "residency" status
as well as closing the park to public) as Wrenn Miller park was purchased and improved with PARTF grant funds.
- Stormwater Smart. The Town of Jamestown pays a membership fee to this organization to provide stormwater
outreach and education. However, I do not find this organization highly effective as it is basically resharing the Town of
Jamestown posts. Their analytics are questionable as they could not provide definitive numbers regarding Town of
Jamestown outreach. A representative was present for the Town's Stormwater Symposium, but outside of this meeting,
nothing of significance has been done to assist the Town in their education and outreach efforts. For the most recent
Guilford Creek week, they appear as a sponsor on t-shirt, however nothing was promoted in Jamestown to support
festivities.
- Blue Stream Environmental LLC. The Town has contracted with this newly formed (est. 2018) husband-and-wife
company to help manage its stormwater program. In reviewing the owners and employee qualifications, I question
whether or not this inexperienced company is the best fit for the Town of Jamestown. They seem to lack experience (if the
initial submission of NPDES MS4 Stormwater Plan is any indication) and have only hosted a Stormwater Symposium
(held November 21, 2023 from 4:45-5:45pm, prior to Town Council meeting). I attended this meeting and witnessed
maybe a handful of residents in attendance—and that is a generous number—who attended this event. Mind you, the
Town of Jamestown promotes many local events, including Music in the Park, of which Blue Stream Environmental was
absent for the May 3, 2024 kick-off
Note in the Town of Jamestown's list of Non-Stormwater Discharges, the list is not all-inclusive. III-maintained vehicles
(i.e., oil/antifreeze leaks), equipment failures (like the recent pipe encountered at Harvey Rd), contaminated wastewater
discharges (i.e., Alberdingk Boley), and Ieachate from contaminated Superfund and brownfield sites are all missing from
the list.
15

3.8 Non-Stormwater Discharges
While the Town of Jamestown has included an extensive list of non-stormwater discharge sources, Town staff failed to
mention the contaminated soils from neglected storage tanks, Superfund and Brownfield sites located in/around
Jamestown that can and have seeped into waterways and drinking water. Thes sites include: a defunct dry cleaner, a
former print shop (and most recently a furniture reseller), as well as a well-established restaurant along Main Street in the
center of Town; a Brownfield site along Guilford College Rd; and a Superfund site at the edge of Town.
3.9 Target Pollutants and Sources
"The Town is not aware of other significant water quality issues within the permitted MS4 area". This statement is a lie.
For well over 2 years, Jamestown residents and community members have continually brought to light the stormwater
issues occurring with the Town of Jamestown planning jurisdiction. Yet these complaints have fallen on deaf ears or Town
staff has incorrectly advised residents of their inability to help them. For instance, Hickory Hollow residents have incurred
an inundation of stormwater and erosions after the construction of 6316 Hickory Hollow. After bringing it to the attention of
the Town of Jamestown, residents were advised Town staff could not assist with the issue. However, in looking at the
Town zoning map, Hickory Hollow resides in Jamestown ETJ and is the responsibility of the Town of Jamestown to
monitor, enforce and correct. Issues regarding flooding in Forestdale East neighborhood have existed for years, yet the
Town recently patted itself on the back, securing a stormwater grant to correct the problem, crediting former Town
Councilman and current Planning Board member, John Capes and his wife, Vickie, for recently reporting issue. Mind you
the Capes' family has lived in the neighborhood since 2003 and only reported it this year. The issue was never addressed
by Town staff prior to the most recent stormwater permit submission, exemplifying the Town's inexperience to address
and neglect of stormwater issues. Mind you, these issues would not exist had the Town planning staff appropriately
reviewed and enforced Randleman Lake watershed rules, which are found in the NCGS. Currently, D.R. Horton is
clearcutting 500-acres of pristine forest, known as the former Johnson Farm. This land is situated in the Lower
Randleman Lake WS-IV watershed, which is a critical and protected watershed, contains a recognized NPES waterway
and restricts development to low-density development, yet the Town of Jamestown entered into a very pro-developer
development agreement with D.R. Horton, allowing a very damaging high density development with approximately 1500
units to be built on 500 acres. And yet no one—the Town of Jamestown, Guilford County, NC DEQ, or the Army Corp of
Engineers—saw a problem with this agreement. The Town of Jamestown and Guilford County only sees tax revenue.
16

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4.1 Organizational Structure
The Town of Jamestown Organizational Chart shows the Citizens of Jamestown at the top, yet this is far from the truth.
Neither Jamestown residents nor community members have a say in how the Town of Jamestown operates or makes
decisions. Sure, they can write their Town representatives and publicly speak at Town meetings, but the Town charter and
governing documents is setup in a way that Town staff and government officials do not have to respond or address issues
brought by Jamestown residents and community members. Not only does the Town not have to respond, but they also
launch "misinformation" campaigns, trying to discredit factual information supported by documents that are a matter of
public record. And, in controlling the narrative, the Town has resorted to closing comment on any and all social media
posts, preventing their critics from commenting on these posts, a violation of the public's First Amendment rights to free
speech. In reviewing Table 8: Summary of Responsible Parties, there is not a Title VI Liaison listed. That is due to the fact
the Town-appointed staff member, Sharon Apple, retired in January 2023. When I inquired back on May 7, 2024—almost
a year-and-a-half later—it took the Town over 2 weeks to provide me a contact. That is because there was not one. To
date, the Title VI process, complaint form and contact for Title VI Liaison cannot be found on the Town of Jamestown
website.
4.2 Program Funding and Budget
"The Town of Jamestown funds the Stormwater Program through its general fund and starting January 2024, will be
funded, in part, through a new Stormwater Utility Fee."
The above comment is indicative of the Town staff and officials ignoring stormwater issues. Dating back to at least the
January 10, 2020 Town Council Budget Retreat and forward, stormwater was brought up numerous times, with the Mayor
and Town Council not prioritizing its importance. Many excuses have come up through the years including: prioritizing
Town's streets over stormwater(1/10/2020 Budget Retreat: https://storage.googleapis.com/dbc-
0city/files/pdf/11020TCRetreatMinutes-1582144213.pdf); bringing in a stormwater expert to explain to residence
importance of stormwater fee (1/22/2021 Special Budget Meeting: https://storage.gooqleapis.com/dbc-
20

0city/files/pdf/12221SpecialBudgetMinutes-1616433791.pdf); the hiring of Blue Stream to handle upcoming stormwater
audit; dedicated Town staff to handle stormwater concerns and the use of stormwater utility fees to offset maintenance
costs (3/25/2022 Special Meeting: https://storage.googleapis.com/dbc-
0city/files/pdf/32522TCSpecial Meeting Minutes FinalApproved-1650476344.pdf); using the proposed storm water utility fee
to offset "some of the deficiencies that could arise from the [stormwater] audit" and concerns business owners would be
unjustly penalized for large parking lots (1/24/2023 Budget Retreat: https://storage.googleapis.com/dbc-
0city/files/pdf/12423TCBudgetRetreatMinutes-1679946660.pdf). It was only in the 1/24/2023 Budget Retreat meeting that
the Town Council begin entertaining the "unfunded state mandate" stormwater utility fee. The stormwater fee was
eventually approved and implemented January, 2024, over 4 years after it was first initially proposed.
4.3 Shared Responsibility
In the implementation of the NPDES MS4 Permit requirements, since the Town of Jamestown is sharing responsibilities,
using minimum control measures, where is the input of and/or agreements with the named entities, Piedmont Regional
Trial Council ("PTRC") Stormwater SMART, Guilford County Soil Erosion Section, and Guilford County Environmental
Health, outlining these "shared" responsibilities. WHO will be responsible for maintaining, monitoring, and enforcing
compliance with these standards?
4.5 Measurable Goals for Program Administration
• BMP #1 Annual Self-Assessment. Having the Town of Jamestown self-assess themselves is inconceivable. Did
you see the initial MS4 Permit application submission? Blue Stream purportedly assisted the Town staff in completing this
initial step.
• BMP #2 Shared Responsibility. Has anyone consulted with the entities outlined in 4.3 to confirm whether they are
in agreement with the items outlined in this MS4 Permit?
• BMP #3 Minimum Control Measures. The Town of Jamestown needs more stringent control measures, considering
they do not even know their own planning jurisdiction and underreported stormwater events in their MS4 application. They
are always trying to the bare minimum, and they fail miserably at that.
• BMP #4 Funding and Staffing. After discussing the stormwater utility fee for four years, the only reason why it was
finally approved was due to MS4 permit requirements. And regarding a dedicated Town staff member to monitor
stormwater permit requirements, what qualifications do they bring to the table to competently perform this function? I
mean the Town Manager is the responsible party on this permit, yet his experience is with planning and development, not
stormwater issues. Shouldn't the person signing this form be the Director of Public Services?
• BMP #5 Permit Renewal Application. After discussing the renewal of the MS4 permit for over 2 years, the Town of
Jamestown failed to file their MS4 permit renewal timely. And based on the draft submitted, Blue Stream and Town staff
did a poor job of properly completing permit application.
Part 5: Public Education and Outreach Program
"The Town of Jamestown will implement a Public Education and Outreach Program..."
So based on the above statement, the Town of Jamestown did not have a Public Education and Outreach Program? How
is that possible?
o BMP #6 Public Outreach
21

■ In the previous draft of the Town of Jamestown MS4 permit application, Town staff claims to
have worked with Stormwater Smart and Piedmont Triad Water Quality Partnership to identify
stormwater impacts of schools, homeowners, and businesses. I questioned this claim in my
previous public comments, as the Town of Jamestown likes to do a lot of lip services without
having the proof to back up what they say.
■ In reviewing the efforts of the Stormwater Smart and Piedmont Triad Water Quality Partnership,
I see very generic posts with little activity related to issues specifically related to the Town of
Jamestown. Many of these organizations charge membership fees for participation, yet where is
the Town's bang for their buck? I question efforts of these organizations because a brief review of
their websites, public engagements, and social media pages indicate their storm water education
efforts are not happening as outlined in their Town of Jamestown contract, essentially wasting
taxpayer money.
o BMP #7 Town-Sponsored Events
■ The Town held a Stormwater Symposium on November 21, 2023. It was held from 4:45-5:45pm
(prior to the regularly scheduled Town Council meeting). Blue Stream Environmental and
Stormwater Smart were present with only a handful of Jamestown residents and community
members in attendance. It was the Town's failed attempt to fulfill their"Public Education and
Outreach Program" due to their pending MS4 Stormwater permit.
■ During the May 3, 2024 Town of Jamestown Music in the Park, there were zero vendors
promoting stormwater education. This event is a perfect time to educate Jamestown residents
and community members regarding water quality and stormwater issues.
o BMP #8 Town Stormwater Website
■ The Town has a Stormwater website? I mean they did have a page on the Town of Jamestown
website; however, it is considerably basic and fulfilled a requirement. Currently, browsing the
Town of Jamestown website, I cannot find anything regarding Stormwater Education or Outreach
on the Town of Jamestown website.
o BMP #9 Stormwater Hotline
■ So where on the Town of Jamestown website does one find the Stormwater Hotline? The
information previously existed, but now it has disappeared. What happens when a citizen
encounters a stormwater issue after hours?Who do they call?
o I would also recommend having this information easily identified on the Town of Jamestown website as
well as having the Stormwater Hotline staffed 24/7.
Part 6: Public Involvement and Participation Program
o BMP #10 Town Stormwater Website/BMP #11 Stormwater Hotline: See comments in Part 5 above.
o BMP #12 Volunteer Opportunities. "Provide public involvement and participation activities locally or
through partnership with Stormwater Smart at PTRC."
■ Note: The only "volunteer" opportunities with the Town of Jamestown involves Boards and
Committees. And the Town is rather selective regarding who they choose to be seated on a
Board or Committee. For instance, several qualified Jamestown residents who applied for
Planning Board seats have been overlooked and/or completely ignored. It was only after public
outcry that many of these individuals *finally* received a rejection letter from the Town Planning
22

Director, several months after applications were submitted and seats were filled. More recently,
an ousted former Town Council member, John Capes, was recently appointed to a Planning
Board seat.
■ The Town does hold a litter sweep twice/year but picking up trash is the least of Jamestown
residents' and community member's worries when it comes to stormwater issues. Many times the
Town defaults to "not our problem" regarding issues related to NC DOT owned streets within
Town limits.
■ In the most recent Guilford Creek week campaign (June 2-8, 2024), the Town of Jamestown (1)
Was not listed as a sponsor nor (2) Did the Town of Jamestown advertise, promote encourage, or
partake in any activities related to addressing the issues pertaining to the Deep River, Bull Run,
or other"unnamed" tributaries.
Part 7: Illicit Discharge Detection and Elimination Program
o BMP #13 MS4 Map
■ I question the validity of the Town of Jamestown MS4 map, as many WOTUS are not indicated.
One WOTUS in particular runs through the 500-acre D.R. Horton-owned property (a.k.a. the
former"Johnson Farm"), which resides on the Lower Randleman WS-IV, which is a critical and
protected watershed with its own NCGS restricting development to low-density, yet is currently
approved by the Town of Jamestown, with property currently being clear-cutted and slated for
high-density development. Another high-density development, 4718 Harvey, also located within
the Lower Randleman WS-IV, was also approved. How does this board for stormwater
management? There are many other unidentified WOTUS which end up being labeled "unnamed"
tributaries to avoid monitoring and detection.
■ The flooding in Forestdale East neighborhood has gone on for years, and the Town just
announce they secured a $769,000 Golden LEAF Foundation grant and credited former
Councilman and current Planning Board member, John Capes, and his wife Vickie, for reporting
the problem? I am sorry this problem existed back in 2020. One has to question the Town's
motives bringing this issue to light now? The Grants Administrator was only recently hired per
5/10/2023 Jamestown News article (Source: Two new faces at Town Hall). This responsibility
was previously delegated to Planning Director Ana Hawryluk.
Two new faces at Town Hall
Carol Brooks
There is a lot going on in Jamestown these days and much more
planned for the future. To help keep up with the p...
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■ A recent "water and sewer" issue with Potent Potables and Southern Roots, originating around
May 7, 2024, resulted in the Southern Roots property being dug up. The fact that the property
had a deteriorated and leaking tank removed, with soil remediation taken place, however, the soil
underneath the building is presumed contaminated, yet the NC DEQ did not seem to be bothered
with enforcing the clause regarding monitoring and reporting future construction on the property.
There is a WOTUS located behind the property less than a few hundred from the work area (soil
dug up and trenched) to repair"sewer issue". A Townhouse community resides on the same
street and a school is less than 1,000 ft from where work was performed.
o BMP #14 Maintain Legal Authority
■ The Town has failed in its obligation to monitor and report illicit discharges, especially when it
came to the Alberdingk Boley spills on October 27-31, 2022 (16,000 gallons untreated
wastewater containing excessive levels of 1,4-Dioxane) and November 8, 2023 (6,000 gallons of
untreated wastewater—a Jamestown resident's FOIA request for report remains unfulfilled). The
first spill, the Town denied responsibility for handling, although, per their zoning map, Alberdingk
Boley lies in the Town of Jamestown's ETJ and planning jurisdiction. The Town failed to notify the
public of the spill via county-wide news agencies, as required by state laws. The second spill was
announced by a now former Councilman, John Capes, who is not an authorized Town publicist, a
day after the November 7, 2023 Town Council elections. The spill was reported by the Town of
Jamestown to a very local newspaper, a.k.a. Jamestown News, with an extremely limited
readership, which was once again, not in compliance with state laws. None of this was mentioned
in the draft MS4 Stormwater permit. I question how many other incidents have occurred and went
undetected/unreported.
■ The Town's failure to properly handle and address soil erosion and stormwater issues
demonstrates they should not retain legal authority on these matters.
o BMP #15 Written IDDE Plan
■ Why is the Town referencing the 2016 SWMP? Shouldn't there be a more recent plan?
o BMP #16 Outfall Dry Weather Screening
■ When was the last time this task was performed? I would recommend requesting
documentation from the Town of Jamestown supporting that these screenings are being
performed regularly and timely.
■ When was the last time the Bull Run/Deep River outfalls have been inspected and tested to
ensure illicit discharges have not taken place? Were these waterways ever tested after the two
previous Alberdingk Boley spills in 2022 and 2023? Testing water at the source is irrelevant when
contaminants have already entered the waterway and traveled downstream.
o BMP #17 IDDE Program Evaluation
■ So, once "violators" are identified, then what? What actions have the Town of Jamestown taken
against industrial contaminators like Alberdingk Boley?
o BMP #18 IDDE Tracking
■ So, where is the information regarding the Alberdingk Boley spills?
■ What about the erosion and stormwater issue caused by the new construction in Hickory
Hollow?
■ Regarding staff training, which Town staff are currently qualified to handle stormwater
management and issues?
o BMP #19 Town Stormwater Website/BMP #20 Stormwater Hotline
■ These topics are redundant. Refer to comments made in Part 5. Both are currently non-existent
on the Town website.
Part 8: Construction Site Runoff and Control Program
If the Town of Jamestown contracts with Guilford County Soil Erosion Control Program, who is maintaining and monitoring
construction sites and other properties?When the issue regarding the soil erosion and stormwater issue occurred, the
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Town of Jamestown denied any authority over addressing the issue. Town staff did not refer complainant to Guilford
County nor offered to assist in resolving matter.
■ BMP #22 Municipal Staff Training
o I would request records showing Town staff is properly qualified and trained to handle soil erosion
and stormwater issues.
■ BMP #23 Stormwater Hotline
o Again, redundant. See comments made in Part 5.
■ BMP #24 Maintain Legal Authority
o Another redundant topic. See comments made in Part 7.
o Regarding water quality, the Town has been aware of issues regarding water quality for well over 2
years, yet they do not address or completely ignore these complaints, even when public records
confirm concerns. Several Jamestown and ETJ residents have had their water tested through an NC
DEQ verified laboratory, and the Town still deems these results "misinformation".
Part 9: Post-Construction Site Runoff Control Program
As stated previously in Section 3.5 above, the Town of Jamestown fails to inform NC DEQ that the Town resides on 3
different watersheds: Jamestown WS-IV, High Point WS-IV, and Lower Randleman Lake WS-IV. The Lower Randleman
Lake WS-IV is classified as a critically protected watershed, possessing its own NCGS statute (formerly 15A NCAC 02B
.0248, .0249, .0250, and .0252; Currently 15A NCAC .0295, .0610, .0611, .0612, .0720, .0721, .0722, .0724; Randleman
Lake Watershed WS-IV mentioned in .0295, .0311, .0610, .0612, .0720, .0721, .0722, and .0724; Source:
http://reports.oah.state.nc.us/ncac/title%2015a%20-%20environmental%20guaIity/chapter%2002%20-
%20environmental%20 manage ment/subchapter%20b/subchapter%20b%20rules.pdf) Specifically, the Town of
Jamestown's Comprehensive Stormwater Management Plan is subject to 15A NCAC 02B .0721 (3) and (6), which place
stricter rules on stormwater requirements, riparian buffer, and land development, the latter which has been completely
ignored by the Town of Jamestown when approving the D.R. Horton (the former Johnson Farm), 4718 Harvey Road, and
other developments in/around Jamestown. The Town is also required to coordinate with the Piedmont Triad Regional
Water Authority (PTRWA). This poses problems as the Town's appointed PTRWA representative, Rich Glover, a non-
resident, formerly of Jamestown Engineering (a.k.a. Town contractor, current employee of Glover Engineering, who has
represented property owners in front of the Town Planning Board and Town Council (without mentioning his conflicts of
interests as a Town of Jamestown contractor and/or PTRWA Board representative), and currently sits as Chair and Town
of Jamestown representative on the PTRWA Board).
■ BMP #25 Standard Reporting. I question the self-assessment portion of this standard reporting. I would also question
the Town of Jamestown's definition of low-density, as the D.R. Horton property resides on a Class IV watershed with its
own statute dictating low density development, yet the Town approved a PUD development agreement that allows for high
density development (approximately 1500 units on 500 acres). I would also recommend the NC DEQ request examples of
these reports for review to ensure the Town is fulfilling their post-construction obligations.
Part 10: Pollution Prevention and Good Housekeeping Programs
■ BMP #26 Pollution Prevention and Good Housekeeping (PPGH) Plan
o Do you mean to tell me the Town of Jamestown does not already have these plans in place?
■ BMP #27 Staff Training
o Require Town of Jamestown staff to enroll into a state authorized training program and maintain
necessary certifications
■ BMP #28 Spill Response Procedures
o Again, require Town of Jamestown staff to enroll into a state authorized training program and maintain
necessary certifications.
■ BMP #29 MS4 Operation & Maintenance Plan
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■ BMP #30 Maintenance SCM Operation & Maintenance (O&M) Plant
■ BMP #31 Applicator Training & Certification
o Again, require Town of Jamestown staff to enroll into a state authorized training program and maintain
necessary certifications.
CONCLUSION
If the failure to submit the MS4 Stormwater permit timely is any indication, the Town of Jamestown does not appear to
take its stormwater compliance seriously. The first draft of the MS4 Stormwater permit demonstrates the Town is
inexperienced and ill-equipped to manage its own SWMP—this was even after hiring Blue Stream Environmental to assist
Town staff with completing MS4 Stormwater permit application! The Town's lack of concern extends to not properly
maintaining records, not following state-mandated public notification processes, failure to uphold obligations to monitor,
maintain and enforce stormwater requirements, failure to perform adequate public education and outreach events,
absence of stormwater education materials and hotline on its website, allowing high-density developments in critical and
protected watersheds (against NCGS)... the list goes on and on.
How can NC DEQ consider and approve the Town of Jamestown MS4 Stormwater permit when the file is incomplete and
lacking pertinent information, like the 2022 and 2023 Alberdingk Boley spills? The Town has jeopardized the health and
safety of Jamestown residents and community members at risk by failing to properly notify the public of the Alberdingk
Boley spills. The `unnamed tributary' is a WOTUS, which eventually travels downstream to PTRWA's Randleman
Reservoir, which serves as a public drinking source for Guilford County and surrounding communities.
The Town cannot even provide accurate information to citizens regarding reporting violations and/or take responsibility for
enforcing compliance.
Not only has the Town entered into a very damaging and expensive development agreement with D.R. Horton, but they
are also allowing high density developments to be built on critical and protected watersheds with NCGS dictating low
density development! The clear cutting of pristine forests replaced by more impervious surfaces is sure to wreak havoc on
the watershed. But that remains to be seen. By the time it rears its ugly head, it will be too little, too late—and the
responsibility will fall on the taxpayers to fix.
I have grave concerns—how can the Town of Jamestown continue on this trajectory? The lack of care the Town of
Jamestown has towards its stormwater obligations abounds. Who is going to step in and ensure the Town of Jamestown
is complying with their MS4 Stormwater permit? I highly recommend if this permit is approved, NC DEQ needs to perform
random inspections of Town documents and records to ensure the Town of Jamestown is meeting their obligations. We
cannot allow yet another 5 years to pass without holding the Town of Jamestown accountable for monitoring and
enforcement of current Town of Jamestown SWMP obligations. I would also recommend someone qualified—other than
the current Town Manager—be in charge of managing the Town of Jamestown stormwater program.
Thank you for this opportunity to publicly comment on this matter.
Regards,
KrC, P.via M. 2eew
Krisdena M. Reeser
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