20080535 Ver 1_401 Application_20080308

STROUD ENGINEERING, P.A.
107-B Commerce Street
GREENVILLE, NC 27858
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ATTENTIO//NG 1 /,M~'/It11
RE:
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WE ARE SENDING YOU ^ Attached ^ Under separate cover via the following items:
^ Shop drawings ^ Prints ^ Plans ^ Samples ^ Specifications
^ Copy of letter ^ Change order ^ D
COPIES DATE NO. DESCRIPTION
G°~~j ~y~ ~--f ' f ~(~ DENR -WATER QUALITY
"° ~ ! ~9

THESE ARE TRANSMITTED as checked below:
^ For approval
^ For your use
^ As requested
For review and comment
^ FOR BIDS DUE
REMARKS
^ Resubmit copies for approval
^ Submit copies for distribution
^ Return corrected prints
^ PRINTS RETURNED AFTER LOAN TO US
COPY TO ~V11~' IUA-vU ~-el,~ /~Q-~T~
SIGNED:
/f enc/osures are not as noted, kind/y notify us a o ce.
^ Approved as submitted
^ Approved as noted
^ Returned for corrections

r

Office Use Only' Form Version March OS
USACE Action ID No. DWQ No. ~ $ 0 5 3 5
(If any particular item is not applicable to this protect, ptease enter °i~ot Hppucaoie yr ivit-~ .~
I. Processing
1. Check all of the approval(s) requested for this project:
® Section 404 Permit ^ Riparian or Watershed Buffer Rules
^ Section 10 Permit ^ Isolated Wetland Permit from DWQ
® 401 Water Quality Certification ^ Express 401 Water Quality Certification
2. Nationwide, Regional or General Permit Number(s) Requested: NW 18 WQC3705
3. If this notification is solely a courtesy copy because written approval for the 401 Certification
is not required, check here: ^
4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP) is proposed
for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII,
and check here: ^
5. If your project is located in any of North Carolina's twenty coastal counties (listed on~ D
4), and the project is within a North Carolina Division of Coastal Man
Environmental Concern (see the top of page 2 for further details), check h
MAR 2 p 2008
II. Applicant Information
DS PN~ S t~~ ~R ~,v.
1. Owner/Applicant Information
Name: MARINER'S BAY LLC C/O FRANKIE W. PENDERGRAPH~~
Mailing Address: P.O. BOX 19691
RALEIGH NC 27619
Telephone Number: 919-755-0558 Fax Number: 919-754-8663
E-mail Address: fpender raph thepencos com
2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter
must be attached if the Agent has signatory authority for the owner/applicant.)
Name: STROUD ENGINEERING, C/O GINGER TURNER
Company Affiliation: CONSULTING ENGINEER
Mailing Address: 107B COMMERCE STREET
GREENVILLE NC 27858
Telephone Number: 252-756-9352 Fax Number: 252-756-2345
E-mail Address: turner stroudengineer com
Page 5 of 13

III. Project Information
Attach a vicinity map clearly showing the location of the property with respect to local
landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property
boundaries and development plans in relation to surrounding properties. Both the vicinity map
and site plan must include a scale and north arrow. The specific footprints of all buildings,
impervious surfaces, or other facilities must be included. If possible, the maps and plans should
include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property
boundaries outlined. Plan drawings, or other maps maybe included at the applicant's discretion,
so long as the property is clearly defined. For administrative and distribution purposes, the
USACE requires information to be submitted on sheets no larger than 11 by 17-inch format;
however, DWQ may accept paperwork of any size. DWQ prefers full-size construction
drawings rather than a sequential sheet version of the full-size plans. If full-size plans are
reduced to a small scale such that the final version is illegible, the applicant will be informed that
the project has been placed on hold until decipherable maps are provided.
Name of project: MARINER'S BAY
2. T.I.P. Project Number or State Project Number (NCDOT Only): N/A
3. Property Identification Number (Tax PIN): 5395.04.73.5212
4. Location
County: CARTERET Nearest Town: NEWPORT
Subdivision name (include phase/lot number): MARINER'S BAY
Directions to site (include road numbers/names, landmarks, etc.):
FROM THE INTERSECTION OF HWY 70 AND HWY 24 TAKE HWY 24 APPROX. 12.5
MILES TOWARD CAPE CARTERET. PROJECT LOCATED ON SOUTH SIDE OF
HWY 24 BEFORE BEULAH LANE.
5. Site coordinates (For linear projects, such as a road or utility line, attach a sheet that
separately lists the coordinates for each crossing of a distinct waterbody.)
Decimal Degrees (6 digits minimum): 34^42'16" °N 77^0'44" °W
6. Property size (acres): 9.77
7. Name of nearest receiving body of water: GOOSE CREEK
8. River Basin: WHITE OAK
(Note -this must be one of North Carolina's seventeen designated major river basins. The
River Basin map is available at http://h2o.enr.state.nc.us/admin/maps/.)
9. Describe the existing conditions on the site and general land use in the vicinity of the project
at the time of this application: SINGLE FAMILY RESIDENTIAL HOME ONSITE AND
THE GENERAL LAND USE WITHIN THE VICINITY IS RESIDENTIAL AS WELL
Page 6 of 13

10. Describe the overall project in detail, including the type of equipment to be
used:CONSTRUCT AN 11 LOT SUBDIVISION WITH MULTIFAMILY UNITS ON THE
WATERFRONT LOTS. INSTALLATION OF UTILITIES AND BUILDING
CONSTRUCTION. BACKHOES AND DOZERS TO BE UTILIZED ON SITE FOR
CONSTRUCTION.
11. Explain the purpose of the proposed work: CONSTRUCT A COMMERCIAL AND
RESIDENTIAL SUBDIVISION WITH PUBLIC WATER AND ONSITE SEWAGE
TREATMENT. DUE TO THE LOCATIONS OF THE WASTE TREATMENT AREAS
THE STRUCTURES ARE REQUIRED TO SET FURTHER OFF THE PROPOSED ROAD
WHICH IS CAUSING THE PROPOSED IMPACTS TO THE TWO WETLAND
FINGERS.
IV. Prior Project History
If jurisdictional determinations and/or permits have been requested and/or obtained for this
project (including all prior phases of the same subdivision) in the past, please explain. Include
the USAGE Action ID Number, DWQ Project Number, application date, and date permits and
certifications were issued or withdrawn. Provide photocopies of previously issued permits,
certifications or other useful information. Describe previously approved wetland, stream and
buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project,
list and describe permits issued for prior segments of the same T.I.P. project, along with
construction schedules. ACTION ID 2006-00211
V. Future Project Plans
Are any future permit requests anticipated for this project? If so, describe the anticipated work,
and provide justification for the exclusion of this work from the current application.
NONE PROPOSED
VI. Proposed Impacts to Waters of the United States/Waters of the State
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
wetlands, open water, and stream channels associated with the project. Each impact must be
listed separately in the tables below (e.g., culvert installation should be listed separately from
riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts,
permanent and temporary, must be listed, and must be labeled and clearly identifiable on an
accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial)
should be shown on a delineation map, whether or not impacts are proposed to these systems.
Wetland and stream evaluation and delineation forms should be included as appropriate.
Photographs maybe included at the applicant's discretion. If this proposed impact is strictly for
wetland or stream mitigation, list and describe the impact in Section VIII below. If additional
space is needed for listing or description, please attach a separate sheet.
Page 7 of 13

1. Provide a written description of the proposed impacts:
PROPOSING TO IMPACT APPROXIMATELY SQUARE FEET OF WETLANDS TO
CONSTRUCT MULTI-FAMILY STRUCTURES. DUE TO THE DEFINED LOCATIONS
OF THE SEPTIC FIELDS LOTS 6 AND 7 WILL REQUIRE THIS FILL TO BUILD ON
THESE LOTS.
2. Individually list wetland impacts. Types of impacts include, but are not limited to
mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams,
separately list impacts due to both structure and flooding.
Wetland Impact
Site Number
(indicate on map)
Type of Impact Type of Wetland
(e.g., forested, marsh,
herbaceous, bog, etc.) Located within
100-year
Floodplain
(yes/no) Distance to
Nearest
Stream
(linear feet) Area of
Impact
(acres)
1 FILLING & GRADING HERBACEOUS YES ~ 230' 0.0216
2 FILLING & GRADING HERBACEOUS YES ~ 230' 0.0474

Total Wetland Impact (acres) 0.069
3. List the total acreage (estimated) of all existing wetlands on the property: 2.29 AC
4. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary
impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam
construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib
walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed,
plans and profiles showing the linear footprint for both the original and relocated streams
must be included. To calculate acreage, multiply length X width, then divide by 43,560.
Stream Impact
Number
(indicate on map)
Stream Name
Type of Impact
Perennial or
Intermittent? Average
Stream Width
Before Impact Impact
Length
(linear feet) Area of
Impact
(acres)
N/A

Total Stream Impact (by length and acreage)
Page 8 of 13

5. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic
Ocean and any other water of the U.S.). Open water impacts include, but are not limited to
fill, excavation, dredging, flooding, drainage, bulkheads, etc.
Open Water Impact
Site Number
(indicate on map) Name of Waterbody
(if applicable)
Type of Impact Type of Waterbody
(lake, pond, estuary, sound, bay,
ocean, etc.) Ime aot
p
(acres)
N/A

Total Open Water Impact (acres)
6. List the cumulative impact to all Waters of the U.S. resulting from the project:
Stream Impact (acres): 0.000
Wetland Impact (acres): 0.069
Open Water Impact (acres): 0.000
Total Impact to Waters of the U.S. (acres) 0.069
Total Stream Impact (linear feet): 0.000
7. Isolated Waters
Do any isolated waters exist on the property? ^ Yes ®No
Describe all impacts to isolated waters, and include the type of water (wetland or stream) and
the size of the proposed impact (acres or linear feet). Please note that this section only
applies to waters that have specifically been determined to be isolated by the USACE.
8. Pond Creation N/A
If construction of a pond is proposed, associated wetland and stream impacts should be
included above in the wetland and stream impact sections. Also, the proposed pond should
be described here and illustrated on any maps included with this application.
Pond to be created in (check all that apply): ^ uplands ^ stream ^ wetlands
Describe the method of construction (e.g., dam embankment, excavation, installation of
draw-down valve or spillway, etc.):
Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond,
local stormwater requirement, etc.):
Current land use in the vicinity of the pond:
Size of watershed draining to pond: Expected pond surface area:
VII. Impact Justification (Avoidance and Minimization)
Specifically describe measures taken to avoid the proposed impacts. It maybe useful to provide
information related to site constraints such as topography, building ordinances, accessibility, and
financial viability of the project. The applicant may attach drawings of alternative, lower-impact
site layouts, and explain why these design options were not feasible. Also discuss how impacts
Page 9 of 13

were minimized once the desired site plan was developed. If applicable, discuss construction
techniques to be followed during construction to reduce impacts.
VIII. Mitigation
DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC
Division of Water Quality for projects involving greater than or equal to one acre of impacts to
freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial
streams.
USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide
Permits, published in the Federal Register on January 15, 2002, mitigation will be required when
necessary to ensure that adverse effects to the aquatic environment are minimal. Factors
including size and type of proposed impact and function and relative value of the impacted
aquatic resource will be considered in determining acceptability of appropriate and practicable
mitigation as proposed. Examples of mitigation that maybe appropriate and practicable include,
but are not limited to: reducing the size of the project; establishing and maintaining wetland
and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of
aquatic resource functions and values by creating, restoring, enhancing, or preserving similar
functions and values, preferable in the same watershed.
If mitigation is required for this project, a copy of the mitigation plan must be attached in order
for USACE or DWQ to consider the application complete for processing. Any application
lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete.
An applicant may also choose to review the current guidelines for stream restoration in DWQ's
Draft Technical Guide for Stream Work in North Carolina, available at
http://h2o.enr.state.nc.us/ncwetlands/strm~ide.html.
1. Provide a brief description of the proposed mitigation plan. The description should provide
as much information as possible, including, but not limited to: site location (attach directions
and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet)
of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view,
preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a
description of the current site conditions and proposed method of construction. Please attach
a separate sheet if more space is needed.
REMAINING WETLANDS TO BE PLACED WITHIN A CONSERVATION EASEMENT
2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement
Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at
[phone] to determine availability, and written approval from the NCEEP indicating
Page 10 of 13

that they are will to accept payment for the mitigation must be attached to this form. For
additional information regarding the application process for the NCEEP, check the NCEEP
website at http•//h2o enr state.nc.us/wrp/index.htm. If use of the NCEEP is proposed, please
check the appropriate box on page five and provide the following information:
Amount of stream mitigation requested (linear feet):
Amount of buffer mitigation requested (square feet):
Amount of Riparian wetland mitigation requested (acres):
Amount ofNon-riparian wetland mitigation requested (acres):
Amount of Coastal wetland mitigation requested (acres):
IX. Environmental Documentation (required by DWQ)
1. Does the project involve an expenditure of public (federaUstate/local) funds or the use of
public (federaUstate) land? Yes ^ No
2. If yes, does the project require preparation of an environmental document pursuant to the
requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)?
Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA
coordinator at [phone] to review current thresholds for environmental documentation.
Yes ^ No ^
3. If yes, has the document review been finalized by the State Clearinghouse? If so, please
attach a copy of the NEPA or SEPA final approval letter. Yes ^ No ^
X. Proposed Impacts on Riparian and Watershed Buffers (required by DWQ)
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
required state and local buffers associated with the project. The applicant must also provide
justification for these impacts in Section VII above. All proposed impacts must be listed herein,
and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a
map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ
Regional Office may be included as appropriate. Photographs may also be included at the
applicant's discretion.
1. Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233
(Meuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 02B .0243 (Catawba) 15A NCAC
2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please
identify )? Yes ® No ^
2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers.
If buffer mitigation is required calculate the required amount of mitigation by applying the
buffer multipliers.

Zone* Impact
(s uare feet)
Multiplier Required
Mitigation
1 3 (2 for Catawba)
Page 11 of 13

* Zone 1 extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an
additional 20 feet from the edge of Zone 1.
If buffer mitigation is required, please discuss what
Donation of Property, Riparian Buffer Restoration /
Riparian Buffer Restoration Fund). Please attach all
within 15A NCAC 2B .0242 or .0244, or .0260.
XI. Stormwater (required by DWQ)
Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss
Stormwater controls proposed in order to protect surface waters and wetlands downstream from
the property. If percent impervious surface exceeds 20%, please provide calculations
demonstrating total proposed impervious level.
THE PROPOSED IMPERVIOUS FOR THIS SITE IS 102.710SF WHICH COMPRISES
24.13% OF THE TRACT. SEE ATTACHED CALCULATIONS.
XII. Sewage Disposal (required by DWQ)
Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of
wastewater generated from the proposed project, or available capacity of the subject facility.
EACH LOT WILL HAVE INDIVIDUAL SEPTIC SYSTEM WITH ONSITE DISPOSAL
XIII. Violations (required by DWQ)
Is this site in violation of DWQ Wetland Rules (15A NCAC 2H .0500) or any Buffer Rules?
Yes ^ No
Is this an after-the-fact permit application? Yes ^ No
XIV. Cumulative Impacts (required by DWQ)
Will this project (based on past and reasonably anticipated future impacts) result in additional
development, which could impact nearby downstream water quality? Yes ^ No
If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with
the most recent North Carolina Division of Water Quality policy posted on our website at
http://h2o.enr.state.nc.us/ncwetlands. If no, please provide a short narrative description:
type of mitigation is proposed (i.e.,
Enhancement, or Payment into the
appropriate information as identified
Page 12 of 13

XV. Other Circumstances (Optional):
It is the applicant's responsibility to submit the application sufficiently in advance of desired
construction dates to allow processing time for these permits. However, an applicant may
choose to list constraints associated with construction or sequencing that may impose limits on
work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and
Threatened Species, accessibility problems, or other issues outside of the applicant's control).
D
~ ~pplica~t/ gent's Signature / Date
(Agent's signature is valid only if an authorization letter from the applicant is provided.)
Page 13 of 13

Narrative
Mariner's Bay
February 28, 2008
Owner:
Mariner's Bay, LLC
c% Franlde Pendergraph
P.O. Bog 19691
Raleigh, NC 27619-19691
919-755-0558
Engineer: Ronald D. Cullipher
Stroud Engineering, P.A.
151-A Hwy 24
Morehead City, NC 28557
[phone]
A. Description of Project
Maziner's Bay is proposed as an eleven-lot Low Density Subdivision, comprising of five commercial lots and
six multi-family lots, located at 4785 Highway 24, Newport (P.I.N. 5395.04.73.5212), Newport, Carteret County,
which currently houses a single family residence on 9.77 acres. The site has been evaluated by the Army Corps of
Engineers and a Notification of Jurisdictional Wetlands has been received dated November 23, 2005 and the plat
sign by the Corps on March 4, 2008. Less than a tenth of a acre is proposed as being filled on this tract due to the
location of the suitable soils for wastewater treatment. These treatment locations have dictated the location of the
proposed road as well as the pazking and building locations. To construct on lots six and seven, portions of two
wetland fingers are being proposed to be filled and a copy of the application is attached with this submittal. This
tract is comprised of approximately 2.29 acres of wetlands or 23.45% of the tract. A representative from the
Division of Coastal Management has evaluated the site and approved the delineation of the mean/normal high
water tine and coastal wetlands as shown on the plat. The subdivision proposes individual on-site waste treatment
and West Carteret Water Corporation has agreed to provide the project with water.
The proposed improvements are to construct a private road, multi-family dwellings on the six waterfront lots
and commercial development on the lots fronting Highway 24. The land disturbance totals approximately acres.
B. Stormwater Information
This proposed Low Density Residential and Commercial Subdivision is located within the White Oak River
Basin and is being submitted under the Coastal State Stormwater Rules. The site presently drains south to Goose
Creek and is classified as SA-HQW with a stream index of 20-36-4. The impervious total for the entire project
area is to not exceed 25%per the Coastal State Stormw•ater Rules. The proposed impervious totals 24.13%of the
total tract area above mean high water. The total impervious areas calculated are based on the reduced tract area of
utilizing the 100' strip for the useable wetlands, which is the most restrictive method. The method of treating
stormtivater is by sheet flow (no collection system), roadway ditches and swales, as well as added treatment within
the surraunding.vetland areas. It is our opinion based on the size and layout of the lots in this subdivision that
"high pockets of density" should not become an issue.
C. Erosion and Sedimentation Control Measures
The following measures are proposed for the site. If it becomes evident that additional erosion and
sedimentation control measures are needed, they shall be installed immediately. It is intended that all
grading and excavation activities within a certain area will be protected as soon as that activity is
complete.
1. Sediment Fence -Sediment fence will be utilized as necessary in locations as shown on plans or
as deemed necessary by the engineer to insure that off-site sedimentation is controlled.
Pile: t'M1632lnarrative.doc

2. Seeding -All disturbed areas will be seeded within 14 days following construction in accordance
with the seeding schedule shown on the plans.
3. Stone Construciion Entrance -Stone construction entrance will be used to reduce transport of
sediment off site.
4. Temporary Sediment Traps -Sediment traps will be constructed as shown on plans and serve to
trap sediment and prevent from the sediment moving off=site.
Maiuntenance Plan
1. All erosion and sediment control measures shall be checked for stability and effective operations
following every runoff producing rainfall event or at least once per week. Repairs required shall
be completed immediately to the dimension and functions indicated on the plans.
2. Sediment shall be removed form behind the sediment fencing when it becomes 0.5 feet deep at the
fence. The fence shall be replaced or repaired as necessary to maintain a barrier.
3. All seeded areas shall be fertilized, seeded and mulched within IS days of disturbance. Disturbed
areas shall be fertilized, reseeded and mulched as necessary according to the Contract documents
to establish and maintain a dense vegetative cover.
D. Coastal Stormwater Regulations
The North Carolina Division of Environrr-ental Management implemented coastal Stormwater
regulations in coastal counties on January 1, 1988. These regulations are detailed in 15 NCAC
2H.1000 Stormwater Management. These rules allow for a development to be considered under
various options. This project is submitted for approval consideration under Section .1003(d}(I} low
density development.
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File: PM1632/narrative.doc

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1 N10.45'30'e B1B Il PG 64 er GATE QESCRfPIA78
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~~ 1 IP 'BUFFER NEpOR1.ILNC 789470 In accordance with Title 15 A NCAC 2H ,0500, the following DEED
R6s I DEN71 u
~ ` IONE B-1 NOTIFICATION shall be recorded in the Carteret County Registry prior to the
1 1 1 conveyance of lots. Said Deed Notification shall apply to name of subdivision, lot
~ '1 numbers in Carteret County, North Carolina as shown on the plans titled CONSERVATION EASEMENT MAP
~~ ~ Mariner's Bav prepared by Stroud Engineering. P.A. dated March 17.2008.
~ ~~ "A portion of this lot has been determined to meet the requirements for
~~ MARINERS BAY
~ designation as a wetland, stream or protected stream buffer, Any subsequent fill WHITE OAK TWSP.. CARTERET COUNTY. NORTH CAROLINA
or alteration of this area shall conform to the requirements of the state rules
' ES I GNED:
ado ted b the State of North Carolina in force at the time of the ro osed
P Y p p CLIENT: MAR INER
s BAY. LLC
C/0 FRANKIE PENDERGRAPH
RDC
alteration. The intent of this provision is to prevent additional wetland, stream or DDRESS: P.O. 80X 19691 DRAWN:
buffer filling or draining
so the property owner should not assume that a future RALEIGH, NC 27619-19691 GYT
,
application for filling or draining would be approved
The property owner shall PHDNE: 919-755-0558 CHECKED:
. RDC
report the name of the subdivision in any application pertaining to said rules. aPPROVEO:
ted
This covenant is intended to ensure continued com
liance with all rules ado 3 STROUD ENGINEERING, P.A.
p
p
W RDC
by the State of North Carolina and therefore the State of North Carolina may ~ MOREHEAO
C TY?N.C. 28557 DATE:
enforce benefits. This covenant is to run with the land and shall be binding on all 125212477479 3/11/08
SHEET 3 OF 3 Parties and all persons claiming under them" ------------- scALE:
"
~
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