NCS000400_Email RE Jamestown MS4 Permit Public Comments_20240609 (2)

Georgoulias, Bethany
From: Susan Dickenson <[e-mail]>
Sent: Sunday, June 9, 2024 10:33 PM
To: Lawyer, Mike; Reed, Isaiah L
Cc: Butler, Kathlene; McCabe, Janet
Subject: [External] Jamestown NC NPDES MS4 permit NCS000400
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Misters Reed and Lawyer:
Please look very closely at the insulting simplicity of the "MEASURABLE GOALS" in the town
manager's Stormwater Management Plan.
This is serious business. At least seventeen different PFAS analytes have now been detected in the
Town of Jamestown's drinking water, some in the double-digit PPT range:
https://themamestowner9.com/water-quality-mamestown-nc/pfas-test-results-round-4/
1 ,4-Dioxane has been contaminating our MAIN DRINKING WATER SUPPLY SOURCE - DEEP
RIVER - for decades: https://themamestowner9.com/water-quality-mamestown-nc/1-4-dioxane-i22-
years
/
If I simply scroll through the plan pages and randomly stop, this stuff appears in the "Measurable
Goals" column B: "Identify staff and contractors that apply landscape chemicals" ... "Require staff and
that apply chemicals to attend training class and/or be certified in chemical application" ... "Develop a
written xyz plan" ... "Add hotline number to any new stormwater education pages" ... "Review website
annually for broken links" ...
Seriously? Measurable goals? These are 12th-grade basic entry-level job descriptions. Surely you
see the absurdity in this document.
And then I come across this - "Post link to DEQ Iaserfiche for easy public access to annual reports" -
and I shake my head in disbelief. Half the town of Jamestown now knows how to use the DEQ
Iaserfiche.
We had NO CHOICE but to learn how to use the DEQ Laserfiche system because over the past two
years our town manager, town staff and town council have REFUSED to: (1) fulfill our public
information FOIA requests unless we agree to pay a large sum for unknown final amounts to be
arbitrarily determined by the town manager at his whim, pleasure and convenience, and (2) answer
our questions and address water issues in public meetings - if it concerns water, we are forced to
come to an hour long in-person meeting at Town Hall with the town manager and whomever else he
chooses to waste taxpayer-funded employee time on.
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He is grossly out of touch with the residents of this town, knows NOTHING about stormwater,
wastewater, permits and water quality, and is wasting our badly needed infrastructure funds on
window dressing, trucks, sound systems and playground nonsense.
It's almost comical considering he charges residents thousands of dollars for access to their own
Public Records: https://themamestowner9.com/public-records/public-information-the-rising-cost-of-foia-
request/
and
https://themamestowner9.com/local-government/nc-open-government-coalition-to-oamestown-public-
records-are-the-property-of-the-people/
Even the NCDEQ won't respond to our FOIA requests: https://themamestowner9.com/public-
records/foia-public-records-requests-ignored/
It's SO bad, in fact, that we residents had to build OUR OWN PUBLIC RECORDS database:
https://themamestowner9.com/public-records/mamestowner-research-notes/
Here's where I posted a quick way to access the Laserfiche library using the community mapping tool
- so you can tell the town manager to cross that "MEASURABLE GOAL" off his list because it's
already been DONE: https://themamestowner9.com/public-records/ncdeg-community-mapping-system/
Further, the NCDEQ's "Public Notice" system has gotten dramatically worse in the two years I've
been using it. It's obvious the Division of Water Resources does NOT want Public Comments. The
nonexistent "Public Notice" for this permit renewal is a good example. It was not posted publicly
anywhere. We found it by accident during a random search in the edoc Laserfiche files. Also, the links
appear to be purposely set up so that they're not "links" - the user has to manually type that LONG list
of characters in the URL to pull up the SWMP. Surely the NCDEQ can do better than this.
WORST OF ALL is that the Winston Salem Regional Office Division of Water Resources continues to
downplay and MISREPRESENT the data and facts about the rising levels of 1 ,4-Dioxane in Deep
River, Randleman Lake/Reservoir, and the Upper Cape Fear River Basin:
https://themamestowner9.com/water-quality-mamestown-nc/14-dioxane-levels-increase-mamestown-nc-
water/
In case there's any doubt, here's the 1 ,4-Dioxane water sampling history of Jamestown I put together
for an interested legal expert - it goes back 22 years: https://themamestowner9.com/water-quality-
0amestown-nc/1-4-dioxane-i22-years/
THEREFORE, in submitting this round of Public Comments for the NPDES MS4 two-year-past-due
permit renewal, many of my fellow residents and neighbors feel it is necessary to copy Ms. Butler and
Ms. McCabe at the Environmental Protection Agency. The actions and non-actions of the NCDEQ
and, especially, the Winston Salem Regional Office of the Division of Water Resources, have given
us reason to believe they are complicit in enabling this corrupt and dysfunctional system of water
permitting and lack of oversight in Jamestown and Guilford County.
EPA NEEDS TO STEP IN AND STOP THE STORMWATER SHENANIGANS THAT ARE
DESTROYING JAMESTOWN, GUILFORD COUNTY, THE RANDLEMAN WATERSHED, DEEP
RIVER, AND THE UPPER CAPE FEAR RIVER BASIN.
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Let's continue with more examples, starting with some of our Jamestown residents' first findings in
the Laserfiche files that the town is now so valiantly pushing as a "MEASURABLE GOAL" in its
SWMP.
When Jamestown residents found out about a 1 ,4-Dioxane spike two years ago in the Laserfiche
files, and then found out what 1 ,4-Dioxane is, we alerted fellow Jamestowners with a post on our new
citizens' website, www.thejamestowner9.com and then issued a press release to local media outlets.
I wrote the release, and was ridiculed, dismissed and mocked by the town manager and town council
for doing nothing more than sharing DOCUMENTS from the NCDEQ Laserfiche files:
https://themamestowner9.com/water-quality-mamestown-nc/blogger-responds-to-misleading-press-
release-from-town-of-iamestown/
More recently, two of my Jamestown friends were literally thrown out of Jamestown's public park by
the town manager and park director for bringing Secretary Biser's 1 ,4-Dioxane Health Report and
press release to a public event last month: https://themamestowner9.com/local-
government/jamestowns-matthew-iohnson/
Jamestown's town manager has no desire, no respect for, and no plans to do anything to address
stormwater, wastewater, and contamination issues in Jamestown, as he's made clear over the past
three years: https://themamestowner9.com/public-comments-and-citizen-complaints/iamestown-
residents-stormwater-com plaints/
He REFUSES to incorporate the 2020 Randleman Water Supply Watershed Rules in the town's
ordinances, which has greatly undermined the protections we could have had if a competent manager
had led us through the disastrous 1 ,500-home D.R. Horton development now being built on
undeveloped protected and critical watershed wetlands in Jamestown. See:
https://themamestowner9.com/randleman-watershed-rules/15a-ncac-02b-0721-rand leman-lake-water-
supply-watershed-stormwaterrequirements/
Despite bringing this up at numerous public meetings, the town manager and the town council
ignored the pleas of residents. When I brought this to Sue Homewood's attention at the WSRO DWR
office, she told me that even though everything I read in the actual rules/statute, and even though it is
described as a mandate, Jamestown doesn't have to incorporate the 2020 Randleman Watershed
Rules? What???
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........
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Her statement that the rules currently being used are more stringent simply isn't true, especially with
respect to the D.R. Horton development, which is using the LESS stringent density requirements and
LESS stringent buffer protections, and LESS stringent stream mapping and erosion controls of the old
existing "nutrient strategy" plan for Randleman Lake.
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Here's an example - where the town manager and town council were complicit in allowing D.R.
Horton to misrepresent their DENSITY number - easy to do since they weren't following the
Randleman watershed rules: https://themamestowner9.com/residential-real-estate-developments/d-r-
horton-iamestown-north-carolina/dr-hortons-density-debacle/
The utilities director and planning director attempted to mislead residents regarding the amount of
money it is going to cost the town to build a new sewer system to handle the D.R. Horton
development: https://themamestowner9.com/eastside-wastewater-treatment-plant-mamestown-wwtp-
nc/new-sewer-line-and-manholes-for-dr-horton-development-to-cost-iamestown-1055000-on-top-of-
8000000-for-eastside-repairs/
The NCDEQ is just as bad. In January, a 401 permit for a new development in Jamestown's Deep
River/Randleman watershed was granted by the Winston Salem Regional Office, Division of Water
Resources, citing JORDAN LAKE NUTRIENT RULES instead of the 2020 Randleman Watershed
Rules that were written specifically for projects like this. No mention was made of the buffer,
density, mitigation, vegetative setback, water quality standards and variance requirements in the
Randleman Watershed Rules.
Jamestown residents' public comments pointed out that the developer (Windsor Homes) application
was incomplete with many entries left blank, that several items had incorrect data, and residents
stressed the importance of making sure the developer followed the 2020 Randleman Watershed
Rules including mitigating any and all damage.
In response to Jamestown residents' Public Comments, the Winston office issued a one-paragraph
memo to their file that said our comments weren't "applicable." Not a single word to any of us. We
found the memo by researching the Laserfiche files to see if we could find out what had happened
with the 401 permit.
On January 26th, the Winston Salem Regional Office resubmitted a revised 401 water quality permit
for the Harvey Road development ("Oakdale Forest") referencing the correct watershed rules this
time (Randleman Watershed Rules instead of Jordan Lake, as we pointed out in our Public
Comments). The permit LIMITED IMPACT to perennial streams at 138 linear feet, and limits impact
to wetlands at .028 acres. Which sounded reasonable and in accordance with the protections in the
watershed statutes.
BUT THEN, on February 5th, Jamestown town planner Anna Hawryluk granted a Major
Exception to the developer, Windsor Homes, giving them the right to permanently impact
19,506 SQUARE FEET of the Randleman Lake Watershed — in the fragile BUFFER ZONES (a
stream flows across the property and then downhill to Bull Run and Deep River).
Hawryluk okayed it in a letter that is now part of the Public Record, WITHOUT the "No Practical
Alternative Request" document she references.
In the letter, Hawryluk says she applied a NEW 2020 Randleman Watershed Rule — 15A NCAC 02B
.0724. But she failed to apply the NEW Rule that defines this as a MAJOR EXCEPTION
(IMPACTS greater than one-third of an acre of Riparian buffer) and thus requires: (1) a
complete application package, (2) preliminary findings, and (3) a 30-day public posting of
those findings BEFORE a final decision is made. That would be Randleman Watershed Rule 15A
NCAC 02B .0611 .
More details are here: https://themamestowner9.com/public-comments-and-citizen-
com plaints/oakdale-forest-401-perm it/
The NCDEQ has refused to impose any sort of penalty or even at LEAST reprimand the Town of
Jamestown for never giving any kind of public alerts or information regarding spills and contaminant
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spikes: https://themamestowner9.com/water-quality-mamestown-nc/pfas-1-4-dioxane/pittsboros-
organized-response-to-last-weeks-dioxane-discharge-in-haw-river-is-in-stark-contrast-to-iamestowns-
sloppy-disinterest/
In sum, NO, Jamestown is not able to nor interested in spill response, illicit detection, stormwater
controls, construction runoff controls, water quality, wastewater controls, public information, public
education, public involvement or public participation.
Do NOT give this town any authority over our severely compromised water system. There is not an
entity on earth that is less capable and more ill-suited for this task than the Jamestown town
manager, the people sitting in Jamestown's Town Hall, and the invisible powers at the county and
state level that are pulling their strings.
Susan Dickenson
Jamestown, NC 27282
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