20090186 Ver 1_More Info Received_20090505

BUNN ENGINEERING CO., P.C.
CIVIL ENGINEERING, LAND SURVEYING
152 NORTH MAIN STREET MOUNT AIRY. NC 27030
May 4, 2009
Sue Home
N. . ision of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
RE: CRAWFORD VILLAGE - STOKES COUNTY
DANBURY, NORTH CAROLINA
Dear Ms. Homewood:
N C u?-r
MAY 0 5 2009
y -n-Sa.e
Regional Office
336-789-6610 FAX [phone]
This letter is in response to your letter dated April 1, 2009 addressed to Mr. James Turpin
concerning the above project. The letter refers to a project I am not familiar with - "North Fork
Estates" - which causes me to question the contents of the letter.
Mr. Turpin is an officer of Adrien Associates, LLC and the name of his project is "Crawford
Village." We did not apply for a 401 permit nor pay an application fee, because it does not
exceed the threshold limits of disturbance requiring a 401 permit. The drainage areas do not
exceed 24% impervious cover. We sent you a complimentary copy of the 404 Permit application
sent to the U.S. Army Corps of Engineers. The Nationwide 39 Permit was issued on March 17,
2009. We understand that if there is any future development of the site a stormwater
management plan may be required.
Please review the information you used to compile the letter and contact me if you have
questions.
Thank you.
Sincerely,

Eddie H. Bunn, P.E., P.L.S.
jsb
Homewood, Sue
From: Homewood, Sue
Sent: Wednesday, May 06, 2009 12:29 PM
To: '[e-mail]'
Cc: [e-mail]
Subject: RE: crawford Village 09-0186
Eddie,
In addition, here's a link to a public notice that has new language about to go into effect that will help clarify the
Division's interpretations of these regulations:
http://h2o.e nr.state.nc. us/ncwetia nds/documents/publicmemo031209.pdf
see item V
Sue Homewood
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
From: Homewood, Sue
Sent: Wednesday, May 06, 2009 11:42 AM
To: '[e-mail]'
Cc: [e-mail]
Subject: crawford Village 09-0186
Eddie,
It is easier to put this in an email that contains quotes and links. As we discussed, I understand that your application for
this project was a courtesy only application. My hold letter was intended to ensure you were aware that based on what
was submitted, I did not think your project would be built in compliance with the 401 Conditions that become automatic
when the USACE 404 is issued.
The language from the 401 states "For applicants other than DOT a SMP is required ...... for every drainage area that
contains more than 24% impervious area ...Where a pocket of high density exists or drainage areas are hard to delineate,
the Division will use best professional judgment..."
the link to the 401 is here: http://h2o.enr.state.nc.us/ncwetlands/documents/WQC3705.pdf its condition #12.
The stormwater regulations define a drainage area as ""Drainage Area or Watershed" means the entire area contributing surface
runoff to a
single point." that language can be found at this link.
f
httl)://h2o.enr.state.nc.us/admin/rules/2H.1000.pd
based on your drawings, you will have a road, a parking lot, and a drugstore with a curb and gutter system that directs
the stormwater to a single point. This would meet the regulated definition of a "drainage area" regardless of how much
undeveloped land is adjacent. In addition, even if you were to be able to eliminate the single point of discharge, in order
to assure that the project stays as low density we would be required to see documentation that the areas adjacent that
were being used to make a low density calculation were to be protected as undeveloped land, and you clearly stated in
the PCN that the adjacent areas will likely be developed in the future.
If you have more questions, or want to discuss this in more detail it would probably be best if you contact Annette Lucas
directly and she can inform me of your discussions or any of her decisions. Her number is 919-715-3425. At this time,
unless something different is decided by Annette after more review, if this project is constructed as proposed without a
SMP it will be in violation upon occupancy and DWQ will issue a notice of violation and civil penalties.
Sue Homewood
NC DENR Winston-Salem Regional Office
Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.