20061427 Ver 2_More Info Letter_20080418

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MS Consultants, Inc.
336-B Carriage Street
Sanford, NC 27330
Subject Property
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
April 18, 2008
DWQ Project # 06-1427; Ver. 2
Lee County
City of Sanford -Sanitary Sewer Improvement
Ut to Little Buffalo Creek [030611, 17-42, C]
REQUEST FOR MORE INFORMATION
Dear Sir or Madam:
On Apri13, 2008, the Division of Water Quality (DWQ) received your application dated April 1, 2008 to
temporarily impact 0.064 acres of 404/wetland, temporarily impact 45 linear feet of perennial stream, and
temporarily impact 234 linear feet of intermittent stream to construct sanitary sewer line improvements at
the site. The DWQ has determined that your application was incomplete and/or provided inaccurate
information as discussed below. The DWQ will require additional information in order to process your
application to impact protected wetland, streams and/or buffers on the subject property. Therefore, unless
we receive the additional information requested below, we will place this project on hold as incomplete
until we receive this additional information, and if we do not receive the following information your
project will be returned as incomplete . Please provide the following information so that we may continue
to review your project.
Additional Information Requested:
1. As you probably know, DWQ's rules require that we certify that the project will not result in
"cumulative impacts, based on past or reasonably anticipated future impacts, that cause or will
cause a violation of downstream water quality standards" NCAC 2H .0506(b)(4). As stated in
your cover letter, installation of this water line project is "to install additional infrastructure,
specifically sanitary sewer piping, to support the growth of the Sanford, NC area". With respect
to cumulative impacts, the Preconstruction Notification (PCN -Section XIV, of the March 2005
version) form for the project asks,
"Will this project (based on past and reasonably anticipated future impacts) result in additional
development which could impact nearby downstream water quality? Yes or 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/documents/InterimInternalPolicyCumulativeImpact.doc
Although, you answered "No" in Section X1V Cumulative Impacts, since has cited above, some
of the project involves supplying sanitary sewer to areas currently not served, there may be
additional wetland and stream impacts in order to develop adjacent undeveloped parcels and the
401 Oversight/Express Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone] /Internet: http://h2o.enr.state.nc.us/ncwetlands
None Carolina
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An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

City of Sanford
Page. 2 of 2
April 18, 2008
stormwater from these developments have the may cause a violation of downstream water quality
standards.
Therefore, we will place this project on hold for incomplete information until the cumulative
impacts of this project are adequately addressed. Alternatively, one way to address this concern
is to have the City of Sanford commit to requiring on-site stormwater management measures
(such as level spreaders, bioretention or constructed wetlands) for the additional development
when adjacent parcels within the utility corridor are developed. However, the Division is open to
other approaches that would give us the assurance that downstream water quality would be
protected from the cumulative impacts of this project.
Please submit this information within 30 calendar days of the date of this letter. If we do not receive this
requested information within 30 calendar days of the date of this letter, your project will be returned and
you will need to reapply with a new application and a new fee.
This letter only addresses the application review and does not authorize any impacts to wetlands, waters
or protected buffers. Please be aware that any impacts requested within your application are not
authorized (at this time) by the DWQ. Please call Ms. Cyndi Karoly or Mr. Ian Mc plan at 919-733-
1786 if you have any questions regarding or would like to set up a meeting to disc[, this matter.

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Sincerely,
Cyndi Karoly, Supervisor
401 Oversight/Express Review Permits Unit
cc: Lauren Witherspoon, DWQ Raleigh Regional .Office
USACE Raleigh Regulatory Field Office
File Copy
Central Files
Christina Breen, ECS Carolinas, LLP, 9001 Glenwood Avenue, Raleigh, NC 27617-7505
Filename: 061427 V er2COSanfordSewerlmprovement(Lee)On_Ho Id