Loading...
HomeMy WebLinkAboutNCS000517_APPLICATION_20120313STORMWATER DIVISION CODING SHEET MS4 PERMITS PERMIT NO. CS o 5- DOC TYPE ❑FINAL PERMIT ❑- REPORT. /�FINUAL Lw APPLICATION ❑ COMPLIANCE 0 OTHER DOC DATE ❑ � 6 1a- YYYYMMDD Quible Quible & Associates, RC, ENGINEE%NG • ENVIRONMENTAL SQENCES • PLANNING • SURVEYING SINCE 1959 March 9, 2012 Mr. Bradley Bennett Stormwater Permitting Unit NC Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699 RE: The Fund for Sandy Point North Carolina, LLC NPDES Permit No. NCS000517 Permit Renewal Dear Mr. Bennett: P.O. Drawer 870 Kitty Hawk, NC 27949 Phone:252-261-3300 Fax: 252-261-1260 Web', quible,com QVM@RDW[Rp MAR 1 3 2012 DENR -!WATER DUALITY WETLANDS AND STORMMYATER BRANCH On behalf of The Fund for Sandy Point North Carolina, LLC ("FSP"), we request renewal of Permit No. NCS000517 (the "Permit"). The Permit was issued to FSP for the Sandy Point Development project (the "Project"), effective June 15, 2006, and was scheduled to expire on June 14, 2011. FSP failed to seek renewal of the Permit in advance of its 2011 expiration solely because we believed that the scheduled expiration date was extended by the General Assembly (Session Laws 2009-406 and 2010-177, the "Permit Extension Act of 2009" and the 2010 amendment thereof). We appreciate the distinction you have pointed out — the subject Permit, though issued by the state, is a federal permit — and your courtesy in respect to the subject expiration and our desire for prompt renewal. There are no proposed changes or modifications to the Permit. FSP intends to move forward with the Project when economic conditions permit. The widely acknowledged economic recession has negatively affected real estate development and, of course, has retarded FSP's progress. The Project's erosion control plan, which incorporates numerous BMPs used to minimize pollutants in stormwater runoff from construction activities, will be implemented and maintained in accordance with the NCDENR erosion control permit until construction is complete. Upon completion of site construction and occupation, FSP will develop and implement an illicit discharge detection and elimination program for the separate storm sewer system in accordance with the NPDES permit requirements. While development activity has been in abeyance, again, due to the ongoing recession, FSP has undertaken the following activities on the Project: ■ Constructed a 1,400-linear-foot mitigation breakwater associated with submerged aquatic vegetation ("SAW) mitigation; ■ Established a riparian wetlands shoreline buffer; Mr. Bradley Bennett Page 2 March 9, 2012 ■ Constructed two hydraulic spoil disposal areas; ■ Excavated permitted boat channels 1, 2 and 3; ■ Constructed six jetties to protect the aforesaid channels; and • Installed channel markers. And of course, FSP is continuing to prosecute required SAV mitigation, which it expects to complete in 2013. There is no new impervious cover on the Project at this time, and no stormwater management infrastructure exists. The Project scope has not changed from that which was permitted. All existing conditions and proposed development activities, as presented in the 2005 application package and set forth in the Permit, are extant, unchanged today, provided only that the development timeline has been pushed forward. The developer/owner is the same as per the Permit, although the mailing address has changed: Sam Young, President The Fund for Sandy Point North Carolina, LLC P.O. Box 789 Edenton, North Carolina 27932 Mobile Tel. (252) 562-3812 Deed Restrictions/Restrictive Covenants The natural Albemarle Sound shoreline of the permitted Property is protected by restrictive covenants, which prohibit the construction of piers, docks, jetties, channels, bulkheads, boat ramps or other such waterfront facilities, save in those locations specifically permitted. Such preservation is intended to guard against additional impacts to adjacent shallow water habitat. FSP has also agreed to preserve Section 404 freshwater wetlands (243 acres), which have been delineated and confirmed by USACE, through permanent restrictive covenants. Copies of these recorded instruments are available upon request. Public Education and Outreach FSP and Quible have developed an informational presentation describing the Project's permitted stormwater management system. Even though the associated infrastructure has not been constructed, our presentation has been given to a NC State University student group, which has shared the information within its community and published materials respecting the Project, and to the NC Clean Water Management Trust Fund Innovation Committee. In addition, students from Elizabeth City State University have contributed to the US Army Corps of Engineers mandated compensatory mitigation program which includes SAV enhancement and monitoring. Students have used their experience and the data collected to develop oral and poster presentations for their peers. As development begins, FSP will maintain its public education program and expand outreach education respecting water quality. Such activities will include public Mr. Bradley Bennett March 9, 2012 Page 3 stakeholder meetings, workshops, informational and instructional signage, web based newsletters and data reports, brochures and, importantly, the promotion of natural resources through public access to the Sound and riparian lands. Development Projections It is not possible to predict when development will commence. However, once physical development does commence, it is anticipated that population growth will conform to the pattern (elapsed time) presented in our original NPDES application. The land use projection also remains the same, that is, as described in our original NPDES application, and includes the following: LAND USE ACRES PERCENT Residential 441 47.4% Commercial 49 5.3% Industrial 0 0% Open Space 440 47.3% Water Quality Monitoring Permit No. NCS000517 specifies development of a "Water Quality/Hydraulic Assessment and Monitoring Plan" that includes quarterly baseline sampling beginning one year prior to initiation of the development. The baseline sampling began in 2009 and includes two surface water sample stations in the Sound and two groundwater sampling stations (permanent shallow monitoring wells) on the west side of Sandy Point. After excavation of the west side harbor, water quality samples will also be collected at two locations in the harbor. The quarterly sampling is conducted by Quible and analyzed by Quible and Envirochem Inc. A summary of the quarterly baseline sampling to date is enclosed. Detailed lab data and analysis reports from each sampling event are kept on file with Quible. Complete copies are available upon request. Once the west side harbor has been excavated, two additional sampling stations within the west side harbor will be included, per the approved monitoring plan. Other State, Federal and Local Permits Permit Issue Date Expiration Date 1 Federal USACE Individual Permit 10/11/2007 12/31/2013 2 CAMA Major 3/12/2007 12/31/2013 3 401 Water Quality Certification 9/14/2006 upon exp. of 404 or CAMA Permit 4 SESCP (West Side) 7/27/2006 No Expiration 5 Nigh Density SW Permit {West Side) 4/18/2006 6/1/2020 6 General SW (Clear and Grade for Spoil Retention Areas) 12/22/2008 No Expiration 7 SESCP(East Side Dredge Spoil 1 Location) 10/23/2008 No Expiration 8 Chowan Co. SUP 2/17/2009 1/1/2013 9 Wastewater Treatment Permit 3/31/2006 3/31/2015 10 404 Wetlands Jurisdictional Determination 12/3/2009 12/3/2014 Mr. Bradley Bennett March 9, 2012 Page 4 Annual Reporting Annual reports in respect to the Permit have been completed and submitted to NCDWQ in a digital format since 2008 and through 2011. Copies of the submitted reports are available upon request. We appreciated your continued assistance with respect to the Sandy Point Project. If you have questions regarding our request for renewal of Permit No. NCS000517, please contact me at (252) 261-3300. Sincerely, a;?, DC4 w Brian D. Rubino, P.G., V.P. Quible & Associates, PC CC: Sam Young, President The Fund for Sandy Point North Carolina, LLC P.O. Box 789 Edenton, North Carolina 27932 Mobile Tel. (252) 562-3812 Email: sam@dpz.com Steve Levitas, Kilpatrick Stockton, LLP 3737 Glenwood Ave, Suite 400 Raleigh, NC 27612 Mike Randall Stormwater Permitting Unit NC Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699 Derek Dail Quible & Associates, P.C. P.O. Drawer 870 Kitty Hawk, NC 27949 u i State of North Carolina Department of Environment & Natural Resources Division of Water Quality OFFIC USE ONLY Date Rec'd D D to Fee Paid Permit Number apd NPDES STORMWATER PERMIT APPLICATION FOIiJM, This application form is for use by public bodies seeking NPDES stormwater permit coverage for Regulated Public Entities (RPE) pursuant to Title 15A North Carolina Administrative Code 2H .0126. A complete application package includes this form and three copies of the narrative documentation required in Section X of this form. This application form, completed in accordance with Instructions for completing NPDES Small MS4 Stormwater Permit Application (SWU-270) and the accompanying narrative documentation, completed in accordance with Instructions for Preparing the Comprehensive StormwaterManagement Program Report (SWU Z68) are both required for the application package to be considered a complete application submittal. Incomplete application submittals may be returned to the applicant. APPLICANT STATUS INFORMATION a. Name of Public Entity The Fund for Sandy Point North Carolina, LLC ("FSP"), a North Carolina Seeking Permit Coverage limited liability company FSP is not a Public Entity but is seeking NPDES stormwater permit coverage in accordance with Senate Bill 732, General Assembly of North Carolina Session 2003 Ratified July 2004). b. Ownership Status (federal, FSP is a private, for -profit land development company state or local c. Type of Public Entity (city, FSP is a private entity that will Operate as a Small MS4 Local Entity town, county, prison, school, etc. d. Federal Standard Industrial SIC 65529901 — 65529902, Subdividers & Developers, Residential / Classification Code Commercial e. County(s) Chowan f. Jurisdictional Area (square 1.45 Square Miles miles g. Population 2005 — 2006: 0 2008: Estimated 300 Permanent 2010: Estimated 500 2016: Estimated 1,500 2021: Estimated 2,500 2005 — 2006: 0 2008: Estimated 100 Seasonal (if available) 2010: Estimated 200 2016: Estimated 500 2021: Estimated 800 h. Ten-year Growth Rate N/A to a new community. See projected population growth, above. i. Located on Indian Lands? ❑ Yes ®Na 11. RPE / MS4 SYSTEM INFORMATION a. Storm Sewer Service Area 0.94 Square Miles (square miles b. River Basin(s) Pasquotank c. Number of Primary Receiving 3 Streams 1 NPDES RPE Stormwater Permit Application d. Estimated percentage of jurisdictional area containing the following four land use activities: • Residential 47.4% • Commercial 5.3% • Industrial 0% • open Space 47.3% Total = 100% e. Are there significant water quality issues listed in the attached application report? ❑ Yes ® No III. EXISTING LOCAL WATER QUALITY PROGRAMS a. Local Nutrient Sensitive Waters Strategy ❑ Yes ® No b. Local Water Supply Watershed Program ❑ Yes ® No c. Delegated Erosion and Sediment Control Program ❑ Yes ® No d. CAMA Land Use Plan ® Yes ❑ No IV. CO -PERMIT APPLICATION STATUS INFORMATION (Complete this section only if co -permitting) a. Do you intend to co -permit with Yes ®No a permitted Phase I enti ? b. If so, provide the name and permit number of that entity: • Name of Phase I MS4 • NPDES Permit Number c. Do you intend to co -permit Yes No with another Phase II entity? d. If so, provide the name(s) of the entity: e. Have legal agreements been finalized between the co- ❑ Yes ❑ No N/A ermittees? V. RELIANCE ON ANOTHER ENTITY TO SATISFY ONE OR MORE OF YOUR PERMIT OBLIGATIONS (If more than one, attach additional sheets) a. Do you intend that another entity perform one or more of our permit obligations? ❑ Yes ® No b. If yes, identify each entity and the element they will be implementing • Name of Entity • Element they will implement • Contact Person • Contact Address • Contact Telephone Number c. Are legal agreements in place to establish responsibilities? ❑Yes ❑ No N/A VI. DELEGATION OF AUTHORITY (OPTIONAL) Page 2 SWU-264-103102 t NPDES RPE Stormwater Permit Application The signing official may delegate permit implementation authority to an appropriate staff member. This delegation must name a specific person and position and include documentation of the delegation action through board action. a. Name of person to which permit authority N/A has been delegated b. Title/position of person above c. Documentation of board action delegating permit authority to this person/position must be _provided in the attached application report. VII. SIGNING OFFICIAL'S STATEMENT Please see the application instructions to determine who has signatory authority for this permit application. If authority for the NPDES stormwater permit has been appropriately delegated through board action and documented in this permit application, the person/position listed in Section VI above may sign the official statement below. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. lam aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Signature Name Sam Title President, The Fund for Sandy Point h Carolina, LLC Street Address 1023 SW 25Avenue PO Box City Miami State Florida Zip 33135 Telephone 305-644-1023 Fax 305-644-1021 E-Mail Sam@dpz.com VIII. MS4 CONTACT INFORMATION Provide the following information for the person/position that will be responsible for day to day implementation and oversight of the stormwater program. a. Name of Contact Person Sam Young* b. Title President, The Fund for Sandy Point North Carolina, LLC c. Street Address 1023 SW 251Avenue d. PO Box Page 3 SWU-264-103102 r NPDES RPE Stormwater Permit Application e. City Miami f. State Florida g. Zip 33135 h. Telephone Number 305-644-1023 i. Fax Number 305-644-1021 j. E-Mail Address Sam@dpz.com * Upon receipt of permits necessary to commence development, Mr. Young will take up residence in Chowan County and, ultimately, will be a resident of the Sandy Point community. IX. PERMITS AND CONSTRUCTION APPROVALS List permits or construction approvals received or applied for under the following programs. Include contact name if different than the person listed in Item VIII. If further space needed, attach additional sheets. a. RCRA Hazardous Waste N/A Management Program N/A b. UIC program under SDWA c. NPDES Wastewater Discharge N/A Permit Number d. Prevention of Significant N/A Deterioration (PSD) Program N/A e. Non Attainment Program f. National Emission Standards for N/A Hazardous Pollutants (NESHAPS) reconstruction approval g. Ocean dumping permits under the N/A Marine Protection Research and Sanctuaries Act h. Dredge or fill permits under Yes section 404 of CWA X. NARRATIVE APPLICATION SUPPLEMENT: STORMWATER MANAGEMENT PROGRAM REPORT Attach three copies of a comprehensive report detailing the proposed stormwater management program for the five-year permit term. The report shall be formatted in accordance with the Table of Contents shown below. The required narrative information for each section is provided in the Instructions for Preparing the Comprehensive Stormwater Management Program Report (SWU-268). The report must be assembled in the following order, bound with tabs identifying each section by name, and include a Table of Contents with page numbers for each entry. TABLE OF CONTENTS Page 4 SWU-264-103102 NPDES RPE Stormwater Permit Application 1. STORM SEWER SYSTEM INFORMATION 1.1. Population Served 1.2. Growth Rate 1.3. Jurisdictional and MS4 Service Areas 1.4. MS4 Conveyance System 1.5. Land Use Composition Estimates 1.6. Estimate Methodology 1.7. TMDL Identification 2. RECEIVING STREAMS 3. EXISTING WATER QUALITY PROGRAMS 3.1. Local Programs 3.2. State programs 4. PERMITTING INFORMATION 4.1. Responsible Party Contact List 4.2. Organizational Chart 4.3. Signing Official 4.4. Duly Authorized Representative 5. Co -Permitting Information (if applicable) 5.1. Co-Permittees 5.2. Legal Agreements 5.3. Responsible Parties 6. Reliance on Other Government Entity 6.1. Name of Entity 6.2. Measure Implemented 6.3. Contact Information 6.4. Legal Agreements 7. STORMWATER MANAGEMENT PROGRAM 7.1. Public Education and Outreach on Storm Water Impacts 7.2. Public Involvement and Participation 7.3. Illicit Discharge Detection and Elimination 7.4. Construction Site Stormwater Runoff Control 7.5. Post -Construction Storm Water Management in New Development and Redevelopment 7.6. Pollution Prevention/Good Housekeeping for Municipal Operations Page 5 SWU-264-103102 APPENDIX A: NARRATIVE APPLICATION SUPPLEMENT: STORMWATER MANAGEMENT PROGRAM REPORT Stormwater Management Program Narrative TABLE OF CONTENTS 1. STORM SEWER SYSTEM INFORMATION 1.1. Population Served 1.2. Growth Rate 1.3. Jurisdictional and MS4 Service Areas 1.4. MS4 Conveyance System 1.5. Land Use Composition Estimates 1.6. Estimate Methodology 1.7. TMDL Identification 2. RECEIVING STREAMS 3. EXISTING WATER QUALITY PROGRAMS 3.1. Local Programs 3.2. State programs 4. PERMITTING INFORMATION 4.1. Responsible Party Contact List 4.2. Organizational Chart 4.3. Signing Official 4.4. Duly Authorized Representative S. Co -Permitting Information (if applicable) 5.1. Co-Permittees 5.2. Legal Agreements 5.3. Responsible Parties 6. Reliance on Other Government Entity 6.1. Name of Entity 6.2. Measure Implemented 6.3. Contact Information 6.4. Legal Agreements 7. STORMWATER MANAGEMENT PROGRAM 7.1. Public Education and Outreach on Storm Water Impacts 7.2. Public Involvement and Participation 7.3. Illicit Discharge Detection and Elimination 7.4. Construction Site Stormwater Runoff Control 7.5. Post -Construction Storm Water Management in New Development and Redevelopment 7.6. Pollution Prevention/Good Housekeeping for Municipal Operations 1. Storrs Sewer System information 1.1. Population Served: Sandy Point is a planned New Urban Waterfront community that is being developed pursuant to the New Urban Waterfront pilot program established by Senate Bill 732, General Assembly of North Carolina, Session 2003 (Ratified July 2004), and that is presently seeking permits from state and federal regulatory authorities. When built out (over fifteen or more years), the Sandy Point community will be comprised of 1,600f dwelling units and will have a population on the order of 3,300, some 75% of whom are expected to be permanent residents. The 3,300-person population figure is an estimate based upon the intended (second home and retirement) market for the development of Sandy Point. At year 2010, it is projected that Sandy Point's population will be approximately 700 people and include 500 permanent residents and 200 seasonal residents. 1.2. Growth Rate: Since Sandy Point is currently an undeveloped parcel of land, there is no growth rate to report. 1.3. Jurisdictional and MS4 Service Areas: The jurisdictional area of Sandy Point will be comprised of 930 acres (currently undeveloped), which equates to approximately 1.45 square miles. 1.4. MS4 Conveyance 5 stem: The Sandy Point jurisdictional area currently consists of a combination of managed timberland and farmland. Within the managed timber areas, there are no discernable stormwater conveyances outside of natural drainage swales and wetland impoundments. Existing farmland is currently drained via man-made ditches, which cross the site in a loose grid pattern and discharge directly to the Albemarle Sound or;to adjoining wetland areas. Existing farm ditches have been historically maintained via backhoe excavation as deemed necessary to provide drainage of upland field areas. Upon the development of Sandy Point, the farm ditches will be removed and replaced with a managed stormwater conveyance system consisting of!shallow swales and minimal storm sewer. The Sandy Point stormwater management system is designed to treat and dispose of water in a de -centralized manner throughout the development. Within the entire development, runoff will be captured in the vicinity of its source and impounded through the implementation of roadside bio-retention swales and integrated road - base (subsurface) infiltration trench systems. For normal rainfall events, the captured runoff is infiltrated in -place, therefore requiring no conveyance of stormwater to downstream areas. For larger rainfall events, stormwater overflows the local impoundments and is conveyed via shallow roadside swales and subsurface storm sewer to central bio-retention areas and/or wet ponds, which provide additional impoundment and infiltration. The planned maintenance of these systems is described in detail in Appendix J of "Sandy Point Phase One Stormwater Design and Narrative." The "Sandy Point Phase One Stormwater Design and Narrative" is enclosed with this application and hereby made a part of the application. 1.5. Land Use Composition Estimates: LAND USE ACRES PERCENT Residential 441. 47.4% Commercial 49 5.3% Industrial 0 0% Open Space 440 47.3% 1.6. Estimate Methodology: Residential and Commercial development are currently estimated to be 90% and 10%, respectively, of the total platted development indicated on the preliminary plat. The area to be developed is comprised of approximately 490 acres, which represents 53.7% of the land use for the Sandy Point site. Residential and commercial development is expected to comprise 47.4% and 5.3%, respectively, of the entire jurisdictional area. There are no proposed industrial activities in Sandy Point. r•n Utilizing the preliminary plat, Open Space is calculated by subtracting the proposed platted commercial and residential areas. Open Space includes allocated green space, common areas (not streets), parks, athletic fields, water bodies (ponds and harbors), and wetlands that are not contained within platted lots. These areas were calculated to be approximately 440 acres, which represents 47.3% of the land use for the Sandy Point site. 1.7. TMDL Identification: Currently there are no TMDLs listed in the Pasquotank River Basin 2. Receiving Streams Sandy Point is located in the Pasquotank River Basin, and the Sandy Point jurisdictional area drains in its entirety to the Albemarle Sound. The Sandy Point stormwater management system is designed such that stormwater runoff is captured, impounded, and infiltrated throughout the development. This approach results in a system which captures, treats, and infiltrates the vast majority of storms as well as the vast majority of runoff from all storm events (for example; the system captures, treats, and infiltrates, on average, 6" of runoff from a 6.8" rainfall event). In a flood situation, the systems provide emergency overflow via overflow structures, storm sewer, and level dispersion device. Emergency overflow for the systems will occur at the upland harbor and in two unnamed tributaries to Albemarle Sound. Table 1. Receiving Stream Overview Receiving Stream Name River Basin Water Quality Classification Water Quality Issues Unnamed Tributary to Albemarle Pasquotank SB - Unnamed Tributary to Albemarle Pasquotank SB _ Albemarle Sound Pasquotank SB _ 3. Existing Water Quality Programs 3.1. Nutrient Management Strategy: There is currently no nutrient management strategy or program in - place within the Sandy Point Jurisdictional Area. 3.2. Local Water Supply Watershed Program: There is currently no local water supply watershed management program within the Sandy Point Jurisdictional Area. 3.3 Erosion Control Program: There is currently no local erosion control program in -place within the Sandy Point Jurisdictional Area. 3.4. CAMA Land Use Plan: There is an existing CAMA Land Use Plan for the Sandy Point Jurisdictional Area. The Land Use Plan has been amended to create a New Urban Waterfront designation for the Sandy Point Jurisdictional Area. 4. Permitting Information 4.1. Responsible Party Contact List: The Sandy Point community is being developed by The Fund for Sandy Point North Carolina, LLC, a North Carolina limited liability company ("FSP"), or its successor. FSP is presently pursuing permits for the development of the community. Once permits are obtained, FSP will permanently allocate staff for the development of the Sandy Point community. Until that time, Sam Young, President of FSP, is responsible for the activities of FSP and its permit applications. Page 2 Prog ram Area Title Name Phone # Fax # Administration Public Education Public Involvement Illicit Discharge Construction Runoff Post - Construction Runoff Good Housekeeping * All positions are proposed and responsibilities have yet to be assigned All stormwater programs will ultimately be the responsibility of FSP's Vice President -Community Operations, a position that is expected to be filled in the 2008-2009 time frame, and his or her staff. The VP -Community Operations will have a role not unlike that of a town administrator/manager. He or she will ultimately have several direct -reports; ■ Property Management, which will have responsibility for the operation and maintenance of the stormwater water management system and have sufficient staff for that purpose • Utilities/Engineering, which would include responsibility for wastewater and other utilities • Harbor Master, responsible for harbors and marinas ■ Community Outreach (Education/Entertainment/Recreation), which will have responsibility for regularly interfacing with residents • Transient Housing Until that time, these programs will be the responsibility of the Project Manager, the senior executive charged with supervising physical development, the Marketing Director, the senior executive charged with all third -party communication and media, and other FSP staff as discussed below. ■ Public Education will ultimately be the responsibility of the Vice President -Community Operations and the Community Outreach Director, who will highlight, through brochures, advertising, etc., the robust stormwater regimen adopted at Sandy Point and the importance to the environment of properly maintaining that regimen. These staff members will speak not only to the residents and prospective residents of Sandy Point but also to visitors to Sandy Point and other residents of Chowan County. Until these positions are filled, the Project Manager and FSP's principal Marketing Executive will perform these functions. • Public Involvement will be staffed similarly to public education and will include community events, such as lectures, video presentations, walking tours, etc. • Illicit Discharge prevention and detection will ultimately be the responsibility of the Vice President - Community Operations and the Property Management Director and his or her staff. In the interim, the Project Manager and the consulting engineers who designed the stormwater management system will perform these functions. • Construction Runoff will primarily be the responsibility of the North Carolina Division of land Resources Erosion and Sedimentation Control Plan, but the Property Management Director (and/or staff) and, in the start-up phase the Project Manager, will periodically inspect construction sites to ensure that development activities are being performed in accordance with state law. ~ Page 3 Post -Construction Runoff will ultimately be the responsibility of the Vice President -Community Operations and the Property Management Director. In the interim, the Project Manager and the consulting engineers who designed the stormwater management system will perform these functions. Good Housekeeping will ultimately be the responsibility of the Vice President -Community Operations and the Property Management Director. In the interim, the Project Manager will perform these functions. 4.2. Organizational Chart: As noted above, FSP is not presently staffed. Once permits for development of the Sandy Point community have been issued, however, FSP will employ ten to fifteen individuals who will reside in Chowan County. The development will also contract with third -party consultants and advisors, including engineers and contractors. Please see APPENDIXBfor an organizational chart that reflects the principal positions to be filled during the first five to ten years of the new community's development. 4.3. Signing Official: Sam Young, President of FSP, is the developer of the Sandy Point community. Mr. Young, as the responsible executive officer and a principal of FSP, is authorized to sign for FSP and to take action, as necessary, to ensure FSP's compliance with the rules and regulations promulgated by permitting authorities. 5. Co -Permitting Information: Not Applicable 6. Reliance on other government entity to satisfy one or more permit obligations: Not Applicable 7. Stormwater Management Program Plan FSP will develop, implement, and enforce a stormwater management program (SWMP) that is designed to reduce the discharge of pollutants from Sandy Point to the maximum extent practicable, to protect water quality, and to satisfy the appropriate water quality requirements of the Clean Water Act. The SWMP will be developed in phases and implemented within 5 years from the effective date of the issued NPDES stormwater permit. 7.1. Public Education and Outreach on Storm Water Impacts: FSP will implement a public education program, which will include distribution of educational materials to residents of the Sandy Point community, to prospective residents and to those residing in the vicinity of Sandy Point. The program will educate the public concerning the impact of stormwater discharges on water bodies and provide steps that the public can take to reduce pollutants delivered by stormwater runoff. 7.1.1. BMP Summary Table: See APPENDIX C 7.1.2. Target Audience: The target audience for the Public Education and Outreach activities will be the residents and prospective residents of Sandy Point, visitors to Sandy Point, and those employed at Sandy Point. 7.1.3. Target Pollutant Sources: Public Education and Outreach will focus mainly on both routine and illicit discharges that can be prevented or minimized by practices developed within the residential and commercial sectors. These targeted pollutants include, but are not limited to, trash, floatable debris, sediment, nutrients, household chemicals and used petroleum and automotive waste. 7.1.4. Outreach Program: FSP will communicate with the target audience and will do so through events, brochures, advertising and other means of communication. Such communication will inform the target audience about the stormwater regimen and will instruct the target audience on how to preserve and protect the stormwater system and its efficacy. As the community, for the near term, will be quite small, it is - anticipated that FSP will be able to communicate with the target audience regularly and frequently. Page 4 7.1.5. , Decision Process: Since the Sandy Point Community does not yet exist, all decisions about the structure and content of the stormwater management program are being made by FSP in consultation with its engineers and other contractors and with the benefit of any input obtained from regulatory agencies and other third parties. Once people begin to occupy Sandy Point, FSP will solicit their input concerning the stormwater management program and anticipates that the program will evolve over time based on that input. 7.1.6. Evaluation: The ultimate measure of success of all elements of the stormwater management system will be water quality in surrounding waters, which FSP will monitor as discussed below. However, before the end of this permit cycle, FSP will establish specific numerical goals for this program element and track its performance against those goals. It is premature to do so at this time given where the project is in the development process. 7.2. Public Involvement and Participation: Sandy Point will develop a public involvement program that will allow members of the community to provide input on and participate in the stormwater management program. 7.2.1. BMP Summary Table: See APPENDIX C 7.2.2. Target Audience: The target audience for Public Involvement and Participation programs will be comprised principally of those residing and employed at Sandy Point. However, there will also be communication with those living in the vicinity of Sandy Point. 7.2.3. Participation Program: Upon significant residential and commercial development, the Sandy Point Community will conduct public meetings that will allow the community stakeholders in Sandy Point an opportunity to comment on the Stormwater Management Program. The organization of a community volunteer advisory group and other volunteer program will be promoted. Such groups can assume roles in the Stormwater Management Program such as community education, observatory inspections, and reporting of pollution hazards to ensure a sanitary environment for the community of Sandy Point. 7.2.4. Decision Process: See item 7.1.5 7.2.5. Evaluation: See item 7.1.6 7.3. I_llicit Discharge Detection and Elimination: The Sandy Point community will develop, implement and enforce a program to detect and eliminate illicit discharges. However, it should be noted that given the nature of the Sandy Point community and its stormwater management system, illicit discharges are not expected to be significant or on anything like the scale that might occur in typical urban areas. 7.3.1 BMP Summary Table: See APPENDIX C 7.3.2. Storm Sewer System Map: Sandy Point will not have storm sewers. The "Sandy Point Phase One Stormwater Design and Narrative," which depicts the initial phase of the storm water management system in detail, is enclosed with this application. 7.3.3. Regulatory Mechanism: FSP will place restrictive covenants on all properties sold within Sandy Point that prohibit illicit discharges to the stormwater management system and provide for assessment of corrective action costs and penalties in the event of such discharges. Similar provisions will be incorporated into the rules of the Sandy Point homeowners association. Thus, FSP and the homeowners association will have the authority to take enforcement action in the event of illicit discharges. Page 5 FSP will communicate with the target audience and will do so through events, brochures, advertising and other means of communication. Such communication will inform the target audience about the stormwater regimen and will instruct the target audience on how to preserve and protect the stormwater system and its efficacy. As the community, for the near term, will be quite small, it is anticipated that FSP will be able to communicate with the target audience regularly and frequently. 7.1.5. Decision Process: Since the Sandy Point Community does not yet exist, all decisions about the structure and content of the stormwater management program are being made by FSP in consultation with its engineers and other contractors and with the benefit of any input obtained from regulatory agencies and other third parties. Once people begin to occupy Sandy Point, FSP will solicit their input concerning the stormwater management program and anticipates that the program will evolve over time based on that input. 7.1.6. Evaluation: The ultimate measure of success of all elements of the stormwater management system will be water quality in surrounding waters, which FSP will monitor as discussed below. However, before the end of this permit cycle, FSP will establish specific numerical goals for this program element and track its performance against those goals. It is premature to do so at this time given where the project is in the development process. 7.2. Public Involvement and Participation: Sandy Point will develop a public involvement program that will allow members of the community to provide input on and participate in the stormwater management program. 7.2.1. BMP Summary Table: See APPENDIX C 7.2.2. Target Audience: The target audience for Public Involvement and Participation programs will be comprised principally of those residing and employed at Sandy Point. However, there will also be communication with those living in the vicinity of Sandy Point. 7.2.3. Participation Program: Upon significant residential and commercial development, the Sandy Point Community will conduct public meetings that will allow the community stakeholders in Sandy Point an opportunity to comment on the Stormwater Management Program. The organization of a community volunteer advisory group and other volunteer program will be promoted. Such groups can assume roles in the Stormwater Management Program such as community education, observatory inspections, and reporting of pollution hazards to ensure a sanitary environment for the community of Sandy Point. 7.2.4. Decision Process: See item 7.1.5 7.2.5. Evaluation: See item 7.1.6 7.3. Illicit Discharge Detection and Elimination: The Sandy Point community will develop, implement and enforce a program to detect and eliminate illicit discharges. However, it should be noted that given the nature of the Sandy Point community and its stormwater management system, illicit discharges are not expected to be significant or on anything like the scale that might occur in typical urban areas. 7.3.1 BMP Summary Table: See APPENDIX C 7.3.2. Storm Sewer System Map: Sandy Point will not have storm sewers. The "Sandy Point Phase One Stormwater Design and Narrative," which depicts the initial phase of the storm water management system in detail, is enclosed with this application. Page 6 7.3.3. Regulatory Mechanism: FSP will place restrictive covenants on all properties sold within Sandy Point that prohibit illicit discharges to the stormwater management system and provide for assessment of corrective action costs and penalties in the event of such discharges. Similar provisions will be incorporated into the rules of the Sandy Point homeowners association. Thus, FSP and the homeowners association will have the authority to take enforcement action in the event of illicit discharges. 7.3.4. Enforcement: See item 7.3.3 7.3.5. Detection and Elimination: 7.3.5.1. Locating Problem Areas/Illicit Discharges. FSP will regularly inspect the stormwater management system, and its employees will be cross - trained to recognize and report illicit discharges. The public education, outreach and involvement programs will also educate target audiences on detecting and reporting illicit discharges 7.3.5.2. Addressing and Removing/Correcting Illicit Discharges. As noted previously, FSP and the homeowners association will have authority to enforce prohibitions of illicit discharges. 7.3.6. Non Stormwater Discharges: Given the design of the Sandy Point stormwater management system, there is less opportunity for non-stormwater discharges to the system than with a typical urban storm sewer system. The restrictive covenants and homeowoners association rules will prohibit non-stormwater discharges to the system with the exception of enumerated sources under prescribed conditions. At present, the only potential non-stormwater sources identified are landscape and residential lawn watering, which will be required to be done in a manner that does not result in surface runoff, and residential car washing, which is not likely to have a significant impact on the system. 7.3.8. Outreach: The public education and outreach program will inform the general public of hazards associated with illicit discharges and the improper disposal of waste within the community. Information will be distributed via mailing and presented at community meetings and functions. Public involvement will be encouraged. A reporting mechanism for residents to report illicit discharges will be established. 7.3.9. Decision Process: See item 7.1.5 7.3.10. Evaluation: See item 7.1.6 7.4. Construction Site stormwater Runoff Control: FSP intends to rely on the State Erosion and Sediment Control Program and the DWQ General Stormwater Permit for construction activities to meet these requirements. All construction activities at Sandy Point Community fall under the purview of of the North Carolina Division of Land Resources (DLR). Initial construction of the development will be required to comply with an erosion and sedimentation control plan approved by DLR. Future construction which disturbs less than one acre will be required to adhere to the erosion control practices outlined in the Maintenance Specifications as well as the Construction Specifications (both of these documents can be found in the Appendix of the Stormwater Design Narrative). Future construction which disturbs greater than one acre will be required to adhere to the erosion control practices outlined in the Maintenance Specifications and the Construction Specifications and will furthermore be required to obtain a separate Page 7 erosion and sedimentation control plan approval from DLR. FSP restrictive covenants and builder agreements will require compliance, such that FSP, as well as DLR, will have enforcement authority.. 7.5 Post -Construction Stormwater Management in New Development, and Redevelo ment: The Sandy Point stormwater management plan includes extensive structural and non-structural BMPs that are developed to maximize water quality of the surrounding surface waters to the maximum extent practicable upon completion of construction. The Sandy Point site will exceed the low density stormwater management program criteria of no more than two dwellings units per acre. Therefore the entire Sandy Point community's stormwater program will be managed as a high density project. As a high density project, Sandy Point will implement stormwater control measures that: (I) Control and treat the difference in stormwater runoff volume leaving the project site between the pre- and post -development conditions for the 1-year, 24-hour storm. (II) Achieve an 85% average annual removal for Total Suspended Solids. (III) Incorporate General Engineering Design Criteria in accordance with Administrative Code 15A NCAC 2H .1008(c). The proposed post -construction stormwater management system is presented in detail in the enclosed "Sandy Point Phase One Stormwater Design and Narrative." 7.5.1. BMP: Operation and Maintenance: The Sandy Point stormwater management program will include operation and maintenance components that ensure adequate long-term operation of the structural BMPs required by the program. The program will require specified maintenance and investigation schedules. These schedules will vary depending on the conveyance structure. Detailed maintenance requirements and maintenance schedules are presented in appendix J of the enclosed "Sandy Point Phase One Stormwater Design and Narrative." 7.5.2. On -Site Wastewater systems: Sandy Point will be served by a central reclaimed water system that relies on spray irrigation and infiltration in areas remote from the stormwater management system. Wastewater collection will be via gravity sewers flowing to central lift stations which feed sanitary sewer force mains which deliver effluent to the wastewater treatment facility located in the project's northwest extremity. The treatment system will operate as an activated sludge plant with tertiary filtration and UV disinfection to achieve reclaimed water quality effluent with de -nitrification to a total nitrogen concentration of less than 10 mg/I. Following treatment to disinfected tertiary levels at the wastewater plant, the treated effluent would be directed to a storage basin. The storage basin will provide a minimum of 90 days of storage capacity so that the land application system can operate optimally, that is, irrigating the land only when weather conditions permit. That amount of storage will also ensure that the wastewater treatment system will be capable of handling peak flows during certain times of the year and when conditions prevent or limit the land application activities. The storage basin will also be designed to function as an infiltration basin to allow for the treated effluent to exit the basin by infiltration. The proposed storage basin is hydrologically isolated from the stormwater infiltration systems since it is separated from the developed portion of the project by a wetland drain which runs in a southeasterly direction through the site. Land application of the treated wastewater is proposed as the primary form of treated effluent use and disposal, with infiltration (as described above) proposed as an alternative method of disposal. Land application will provide a means for the site to benefit from the advantages of water "reuse," which includes saving or conserving fresh water. The treated wastewater, then, will be applied to the Page 8 land to irrigate crops, open grassed areas, an adjoining golf course and a variety of fruit and nut trees. 7.5.3. BMP Summary Table: See APPENDIX C 7.5.4. Non -Structural BMPs: Non-structural BMPs to be used to maintain water quality within the community include: (I) Maintenance and inspection BMPs of the stormwater conveyance structures to maintain the integrity of the structures and to ensure that they convey the water as designed. Maintenance of stormwater appurtenances is outlined in Appendix J of "Sandy Point Phase One Stormwater Design and Narrative." (II) Education efforts targeting contractors and builders working within the community, as outlined within Appendix J of "Sandy Point Phase One Stormwater Design and Narrative." As dictated by Appendix ), all contractors and builders working within Sandy Point shall be contractually bound to the requirements of Appendix J, "Operation and Maintenance Requirements," which include conducting construction activities within a specific hierarchy of protection, erosion control, and maintenance. (III) Platted land uses are designed to minimize impacts to the 404 wetlands located on the property. The vast majority of these wetlands are designated as unbuildable open space within the community. (IV) Water Quality Monitoring: : FSP plans to monitor water quality within the man-made harbors on the east and west side of the project. Two sample points within each harbor will be selected in coordination with NCDWQ. At least one "baseline" sample location outside of the project, but in the project vicinity will also be selected. Grab samples will be collected and analyzed at all three locations monthly, or 12 times a year. Each sample will be tested to Nitrogen, Phosphorous, Total Suspended Solids, Fecal Coliform, and Chlorides. Sampling protocols and reporting requirements will be developed in coordination with NCDWQ. 7.5.5. Structural BMPs: A variety of structural BMPs are planned for use within the community to minimize stormwater impacts. These BMPs include but are not limited to. (I) Permeable Pavers: Permeable pavers are to be used in the urban water front area on the west side of Sandy Point (west of NC 32), where the building density is highest. The permeable pavers will allow the infiltration of stormwater into the subsurface gravel base below the pavers and, finally, into the underlying soils. (II) Infiltration Swales: Infiltration swales are to be located within the right of way flanking the permeable paver / infiltration trench roadways. These infiltration swales provide storage and infiltration of runoff from surrounding lots. Each infiltration Swale is designed to fill to capacity prior to overflowing in a "stepped" manner to down -gradient swales. Once the capacity of all the individual swale and infiltration trench sections is exceeded, runoff will overflow into bio-retention parks. (III) Bio-retention Parks: The bio-retention parks are centrally located impoundments, which are graded slightly below the surrounding grade. These areas will be landscaped with appropriate native species such that they function as shallow bio-retention/infiltration basins for stormwater overflow. (IV) Wet -detention basins: Wet -detention basins will be used as emergency overflow Page 9 receptors. For a detailed description of the structural BMPs as well as the entire stormwater management system, please see "Sandy Point Phase One Stormwater Design and Narrative," which is enclosed as part of this application. 7.5.6 Regulatory Mechanism: Operation and maintenance of the post -construction stormwater management system will be the responsibility of FSP, whose obligations will be enforceable by the Division pursuant to the permit. As noted, above, FSP and the homeowners association will have authority to enforce restrictions on property owners with respect to the stormwater management system. 7.5.7 Operations and Maintenance: Long-term Operation and Maintenance (O&M) plans for the on -site BMPs are prescribed in Appendix J of "Sandy Point Phase One Stormwater Design and Narrative," which is enclosed as a part of this application. The O&M plan will be reviewed and approved by the regulatory authority to ensure the long-term operation of selected BMPs. 7.5.10. Decision Process: See item 7.1.5 7.5.11. Evaluation: See item 7.1.6 7.6. Pollution Prevention/Good Housekeeping: FSP will develop and implement an operations and maintenance program for its own activities that includes a training component and that has the goal of ensuring that FSP prevents or reduces pollutant runoff to the surrounding surface waters to the maximum extent practicable. 7.6.1. BMP Summary Table: See APPENDIX C 7.6.2. Affected Operations: The following facilities and operations are anticipated to be covered by the Pollution Prevention/Good Housekeeping Program. These anticipated activities would be evaluated and revised to ensure that the programs minimize pollution. Certain activities may be eliminated as a potential source of pollution if it is determined that they do not represent a potential source of pollution. Programs of concern are not limited to the programs listed below. As new potential sources of pollution are discovered, associated programs and facilities will be added to the list and evaluated. Programs: - Maintenance programs associate with the inland harbors - Stormwater conveyance system maintenance - Park and open space maintenance - Solid waste collection procedures - Chemical applications associated with grounds maintenance - Street cleaning/maintenance - Solid waste collection/disposal Facilities: - On -site wastewater treatment plant - Property management maintenance areas 7.6.3. Training: Page 10 Training programs for stormwater personnel and other staff to identify and minimize water pollution due to the affected operations are required per Appendix J of "Sandy Point Phase One Stormwater Design and Narrative." Training programs for the proposed system will be evaluated and modified as necessary. 7.6.4. Maintenance and Inspection: The Property Management Director will have responsibility for inspecting FSP's own operations to ensure their compliance with stormwater management requirements. 7.6.5. Vehicular Operations: FSP will not maintain a significant fleet of vehicles. Any vehicle maintenance or washing will be done at locations remote from the Sandy Point stormwater management system and in a manner to ensure that the activities do not create stormwater runoff problems. 7.6.6. Waste Disposal: Waste disposal from stormwater management maintenance activities is addressed within Appendix J of "Sandy Point Phase One Stormwater Design and Narrative." All solid waste removed from the system shall be dewatered and legally landfilled in accordance with Appendix J. 7.6.7. Flood Management Projects: There are no area flood management projects for the area. The stormwater conveyance system for the Sandy Point community is to be designed to convey the 10-year, 24-hour storm. 7.6.8. Existing Ordinance: There are no current existing ordinances for the proposed community of Sandy Point. 7.6.9. Other Evaluations: N/A 7.6.10. Decision Process: See item 7.1.5 7.6.11. Evaluation: See item 7.1.6 Page 11 APPENDIX C: Provisional Organizational Chart, Development = Primary line of GommunwotiorVRcporting = Secondary the or Wff1mureCal= - OW Me or Team Communicallon 1 Sales Manager 1 I Saes ASsadates I 6uyers1Develope relgull0ers SANDY POINT STAFFING AND REPORTING HIERARCHY DIAGRAM (General Contractor/Architectural Project Manager Model) President. Sard, P.'att eq'udve t eadershW G&mlopment 1 Markatinf; Consentent 1 Vlea Preslderg of Operalions Canstrucdon Protect Manager I General Comragar i I GC Project Manager 1 Trades 6 Other Reid Pelsonrtel Araritectirairl=ngmeerttg Cateultant CftytState Agendesiauad€rnq Department Site Supeftenoant 1 Arctitecturz€ Project Manager 1 Finance Manager 1 1 Aroourkdng Assoda;es I Clerwa€ Staff 1 ` APPENDIX C: BMPs and Measurable Goals 1. BMPs and Measurable Goals For Public Education and Outreach BIUiP iV1 asu�aE3fKGoal YRtHIVFi YR YRReS ff ibi '4 5. Position/,i?arty r+i �, ate,, Establish resident Develop and implement an education and educational campaign to inform outreach program residential property owners on illicit FSP discharges and sources of pollution. Marketing, In near term, outreach will be direct, later Community as there will be so few residents Outreach Establish business Develop and conduct an educational education and campaign to inform businesses on outreach program illicit discharges, reporting improper waste disposal, and actions they can take to minimize them. FSP Project In near term, focus will be on persons Manager, later Community working for FSP and contractors. Outreach Public education Distribute brochures via mailings, in material community central areas and other dissemination heavy trafficked. Include information on steps to reduce pollution sources including the proper disposal of FSP waste materials. Marketing, In near term, educational material later Community can be delivered directly to resident. Outreach Presentation at Present educational information at homeowner homeowners association and other association community meetings. meetings At Sandy Point, there is little difference between "the public' and "the homeowners," because of the size of the planned community. Educational information will be Project Architect / tailored to the residents and Engineer, later residential property owners of Sandy Community Point. Outreach Presentation at Present educational information at business association business association and other meeting community business meetings. Information is to be tailored to the business community of Sandy Point. At Sandy Point, there will be no distinction between business and Project residential users, certainly, for Manager and stormwater purposes. Contractors, In near term, labor is the target later CommunityOutreach audience. Page t APPENDIX C: BMPs and Measurable Goals 1 + 2. 'BMPs and Measurable Goals for Public Involvement and Participation 'BA71P Mi?asur"abf�G" fs +YRx 1� YR RIYJR J 4R5fPy tart Administer a public Conduct public meetings to allow the involvement public an opportunity to comment on program the stormwater management plan. This will not be applicable for the first few years, while the project is in the early stages of construction. Thereafter, a resident committee can be formed that learns about, comments on and teaches others about stormwater system. Community Outreach 3. BMPs and Measurable Goals for Illicit Discharge Detection and Elimination BIvIP I+lleasura6l'e Gc"als YR YR YR, W-41 Y Resp`o si6lle t 2 3 b. Pao rtion/P�rty Develop/implement Develop and implement an illicit illicit discharge discharge detection and elimination detection and Program. Include provisions for elimination program program assessment and evaluation. Program will be developed as residents begin settling at Sandy Point. VP Operations Establish and Develop legal regulatory authority to maintain appropriate prohibit illicit discharges and enforce legal authorities the approved Illicit discharge detection and elimination program. Regulation and enforcement of illicit discharge detection and elimination will be by contract at Sandy Point, enforced by FSP and the homeowners association. VP Operations Develop a storm The location and specifications for sewer and all stormwater conveyances will be conveyance system included in the finalized site plans base map upon the final design and construction of each stormwater Project conveyance. Engineer Page 2 APPENDIX C: BMPs and Measurable Goals I Implement illicit Implement an inspection program to discharge detection detect illicit discharges into the procedures stormwater conveyance system including the emergency overflow floodwaters. Establish procedures for tracing the source of illicit discharges and for removing the sources. Develop procedures for identification of priority areas likely to have illicit discharges. Such programs will be developed over the first five years in cooperation with residents. VP Operations Establish and Establish and maintain water quality maintain water quality monitoring systems and conduct monitoring systems water quality monitoring at the locations and in detail and frequency as specified by the permit. VP Operations Staff training FSP's community staff will be cross- Project trained to recognize and report Manager, later illegal discharges. VP Operations Public education Inform the general public, including residential and commercial inhabitants, of hazards associated with illicit discharges and improper disposal of waste via mailings or other means easily accessible to the community. In near term, communication will direct, but as community is built out, Marketing, there will be greater need for mailing later VP and other such communication tools. Operations Public involvement Establish and publicize a reporting and participation, mechanism for residents to report illicit discharges. In the near term, reporting will concern construction personnel, reporting to the Project Manager; Project later, program will permit residents Manager, later to report to VP -Operations. VP Operations Page 3 ,,APPENDIX C: BMPs and Measurable Goals 4. BMPs and Measurable Goals for Construction Site Runoff Controls BMP Measi�ratile oafs fiY Fi§ Y 3,_ YJOILR—s—p 4� nsif3le itonfPa Implement a The Sandy Point community will program and elect to comply by relying on the NC establish a DENR Division of Land Resources regulatory (DLR) Erosion and Sediment mechanism for Control Program, either as erosion and administered by the DLR or as sediment control delegated by the Sedimentation Control Commission (SCC) to Project another entity with appropriate Manager ... Later, jurisdiction. VP Operations 5. BMPs and Measurable Goals for Post -Construction Site Runoff Controls BMP eastirabl : G a!s YR F YR • YR •Yet sPQKgoly Lpi 1 34 5 itionarty Establish strategies Develop and implement strategies to address that include a combination of stormwater structural and/or non-structural structural and non- BMPs. Establish preconstruction structural BMP review of plans, inspection during construction, and post -construction acceptance procedures. Long-term operation and maintenance plan are to be required as well as scheduled maintenance report to be conducted Project by a qualified professional. Engineer Develop a program Develop and implement a program to to control the ensure the proper maintenance of on - sources of fecal coli site wastewater treatment systems. form Coordinate program with the Chowan County Health Department. Establish and implement a program that Project incorporates a pet waste Engineer, later management program. VP Operations_ Develop a targeted Provide contractors, and builders educational effort working within the community about the program guidance materials about the local Project post -construction requirements. Manager, later VP Operations Page 4 ' 1; APPENDIX C: BMPs and Measurable Goals r ,, L G. BMPs and Measurable Goals for Pollution Prevention/Good Housekeeping B' I? easiar""aGfe Goals YR YRP Y �R Y e Rspo�nsi e, .. k. 1 4 Position/Party Develop an Develop an operation and - operation and maintenance program that has the maintenance ultimate goal of preventing or Project program reducing pollutant runoff. En ineer Inspection and Develop an inventory of all facilities evaluation of and operations within the community facilities and with the potential for generating operations polluted stormwater runoff. Develop inspection and maintenance schedules for potential sources of Project polluted runoff, the stormwater Engineer, later controls, and conveyance systems. VP Operations Trained stormwater All stormwater maintenance staff maintenance Staff must be properly trained to identify and remove pollutants including sediments from the stormwater system. I VP Operations Develop spill Develop spill response practices that response will most practicably minimize the risk procedures of polluting bodies of water. VP Operations Page 5 Sandy Point Stormwater Management Review Summary 18 January 2006 BL Land UElnfrastructU Water re,PA Civil Engineering Ecosystem Engineering Environmental Engineering Environmental Consulting GeoMatiCS Consulting Land Planning Landscape Design r SANDY POINT • STORMWATER MANAGEMEN'r REVIEW SUMMARY Contents 1. Executive Summary ..................................................................... 3 1I. Project Background...................................................................... A. Location and Setting................................................................ 3 B. Development Overview.............................................................. 4 I11. System Review......................................................................... 8 IV. Discussion and Recommendations................................................ ......... A. Infiltration Potential................................................................. S B. Permeable Pavements................................................................ 9 C. Bioretention Areas................................................................. 11 D. Eastern Project Area............................................................... 12 E. Western Project Area............................................................... 12 E. Performance Monitoring............................................................ 13 G. As -Built Survey................................................................... 13 H. Performance Bonds................................................................ 14 V. Conclusions........................................................................... 15 BLUE: Land, Water, Infrastructure Page 2 of 15 SANDY POINT • s,rORMWATER MANAGEMENTRE VIEW SUMMARY Executive Summary The Sandy Point project is located along the northern shore of Albemarle Sound in Chowan County, at the outlet of the Chowan River. The project site is divided by NC Highway 32 which crosses the Albernrie Sound and the site in a generally north by northwesterly orientation. The site is approximately 930 acres and currently primarily comprised of cultivated farm fields, managed timber stands, and various freshwater wetlands. Sandy Point is proposed by the real estate developer (The Fund for Sandy Point North Carolina LLC) as a mixed use project, with a relatively high density urban waterfront subproject in the western portion and a relatively low density residential subproject in the eastern portion. The project is facilitated through legislation adopted by the State of North Carolina (Session Law 2004-117 of the North Carolina General Assembly). Session Law 2004-117 states: `The application for the National Pollutant Discharge Elimination System (NPDES) permitfor stormwater management shall be reviewed by two independent experts approved by the Department. This review shall be conducted at the expense of the applicant. The permit shall require that the permittee establish and maintain water quality monitoring systems and conduct water quality monitoring at the locations and in the detail and frequency specified by the permit." Thomas S Blue PE PLS is one of the two independent experts designated for the project (North Carolina State University being the other). This document summarizes the project National Pollutant Discharge Elimination System stormwater management permit application review by Thomas S Blue PE PLS. Detailed information has been provided by the real estate developer only for Phase I of the project, a relatively high densiIX residential area comprising 26.4�i acres of the 930± acre site. The real estate developer has indicated the independent_experts are _to_review the initial application and not review detailed information for development of the remaining area. As such, the review of Thomas S_Blue PE PLS is generally']imited7t-5 PlJasc. Pof the project as ade uate review of the application is dependent upon detailed information. The comments and concerns presented within this document have previously been related to the real estate developer and associated design consultants. Except as indicated, these comments and concerns were addressed by the design consultants and, as such, will not be elaborated upon. No assessment of impacts from marine development (boats, harbor etc) was requested or undertaken. 11. Project Background A. Location and Setting The Sandy Point project is located along the northern shore of Albemarle Sound in Chowan County, at the outlet of the Chowan River. The center of the site is located approximately 6 miles southeast of downtown Edenton. A golf course is located less than a mile to the west of the project boundary and an airport is located approximately 2 miles to the west of the project boundary. The project site is divided by NC Highway 32 which crosses the Albemale Sound and the site in a generally north by northwesterly orientation. The site is approximately 930 acres and currently primarily comprised of cultivated farm fields, managed timber stands, and various freshwater wetlands. BLUE: Land, Water, Infrastructure Page 3 of 15 SANDY POIN'r • STORMWA'I'ER MANACFMEN"r RFVIFW SUMMARY B. Development Overview Figure 11-1. Phase One Schematic (outlined) with Topographic Relief The real estate developer has stated the project will proceed in phases. Only the first project phase has been delineated. This phase is located within a strip of land on the western edge of site. This phase is proposed as a relatively high density residential area comprising 26.4± acres. Phase I extends generally from NC Highway 94 southward to an area adjoining the western edge of the excavated inland harbor. A 3.1± acre stormwater management measure is also planned to be constructed north of NC Highway 94 during Phase 1. This phase is depicted in Figure II-1. The residential area of Phase I is located on the highest elevations of the site, with the possible exception of a residential area between the adjoining excavated inland harbor and Albemarle Sound. The soils in the Phase I area are mapped as Chapanoke silt loam and Yeopim loam, with Chapanoke comprising most of the area. The slopes in the Phase I area generally in the 0% to 2% range. Average annual high water table in this area is near the surface with probable depths of 0.5 feet to 3.0 feet. Soil infiltrate n limited in this area by fines a . The Phase I area generally presents fewer challenges and less obstacles to implementation of an infiltration focused stnmwater management system than other areas of the proposed Sandy Point development. BLUE: Land, Water, Infrastructure Page 4 of 15 SANDY POINT - STORMWATER MANACEMEN"f REVIEW SUMMARY Figure I1-2. Site Master Plan Schematic with Topographic Relief The site master plan is depicted in Figure II-2 through Figure II-6. The project area to the west of NC Highway 32 is generally proposed as a high density residential community centered on an excavated inland harbor. The project area to the east of NC Highway 32 is generally proposed as a low density residential community with high density residential clusters. The western project area (west of NC Highway 32) is higher than the eastern project area (east of NC Highway 32). The western area is generally at 12 feet above mean sea level. The eastern area is generally at 9 feet above mean sea level. The eastern area is both lower and wetter than the western area (see Figure II-2, Figure [I-4, and Figure [I-6). The real estate developer has indicated that the eastern project area stormwater management system will be similar, but less intensive, than the western project area stormwater management system. Most all lots in the eastern project area are larger than the western eastern project area. It appears there are fewer common areas adjacent to lots in the eastern project area than in the western project area. Approximately 237.6 acres of jurisdictional wetlands are present at the project site (See Figure 11-6). BLUE: Land, Water, Infrastructure Page 5 of I5 .,V A, ANT."', I SANDY POmT • STORMWATER MANACEMENT REVIEW SUMMARY Figure 11-5. Site Master Plan Schematic with NRCS Soil Mapping Units 41 eIF i �?{ `+`� .q a ui n ■ 'b� T -.d �� w.'ryn �'.- AY �' Fig., � /a �.. .� w.� �. 3�W b d�' ,•'Y`i a �� �i � °'� �+� _Y ;' -a sa"„Ri � , `,�� 1.s,a�i 4#_i RG• C �lii�ii4��� O��Y�!' fit , Figure I1-6. Site Master Plan Schematic with Jurisdictional Wetlands BLUE: Land, Water, Infrastructure Page 7 of 15 SANDY POINT • STORMWATER MANAGEMENT REVIEW SUMMARY IIL System Review The stormwater management system review by Thomas S Blue PE PLS focused on 4 aspects: 1) hydrologic and hydraulic analysis; 2) treatment train configuration; 3) likelihood of success; and 4) overall expected performance. Thomas Blue assessed information provided by the real estate developer and associated design consultants and provided guidance on analysis and design of the project. Thomas Blue directly stated any recommendation was to be taken as such and not as a requirement. The intent was to provide analysis and design guidance while remaining an objective reviewer. The hydrologic and hydraulic analysis of the design consultants was split into two components: 1) a stormwater response simulation facilitated through application of the HEC-HMS modeling system (US Army Corps of Engineers link -node watershed model); and 2) a subsurface recharge response simulation facilitated through application of the Visual MODFLOW modeling system (Waterloo Hydrogeologic implementation of USGS finite difference model). The stormwater infiltration potential and subsurface hydraulic conductivity are the most important parameters in this analysis. As the surface (HEC-HMS) and subsurface (Visual MODFLOW) response models were not directly linked, a "failure analysis" methodology was undertaken to assess the limits of desired system performance. The failure analysis indicated the stormwater management system proposed for Phase I of Sandy Point will function very well if constructed and maintained ace+ The treatment train for Phase I of Sandy Point was well conceived and well proposed. It includes multiple steps in the stormwater flow path, providing system redundancy and a variety of mechanisms for treatment of stormwater. The likelihood of successful inplementation of the proposed stormwater management system depends upon close collaboration of the designer and the contractors during construction operations, enforcement of design parameters, and long term assurance of system functions through inspection and associated maintenance if required). The stormwater management systan is expected to be successfully implemented if relevant entities are informed and educated about the system, the system is constructed as per the design, changes are not made to the system after construction which diminish the system functions, and damage to the system is correctly repaired. This is easily achievable with relatively minor effort and expense if properly addressed. The stormwater management system for Phase I of Sandy Point is integrated into the overall infrastructure of the site. As with any built structure, there are many possibilities for problems and for a wide range of performance outcomes. That having been stated, the stormwater management system proposed for Phase I of Sandy Point is expected to function very well if constructed and maintained according to the design, exceeding applicable regulatory performance requirements. IV. Discussion and Recommendations A. Infiltration Potential The primary factor governing the stormwater management system success is the long term infiltration potential of the ground. This includes any surface proposed to infiltrate stormwater. Permeable pavements and bioretention areas are primary stormwater management components proposed for Sandy Point. Both_Qf the�component_ty e,.c fundamentally dependent upon ground infiltration potential. BLUE: Land, Water, Infrastructure Page 8 of 15 SANDY POINT • STORMWA'rER MANAGEMENT REVIEW SUMMARY B. Permeable Pavements Permeable pavements have the potential to significantly reduce stormwater runoff from traffic surfaces. Permeable pavements are also highly susceptible to surface scaling and pore clogging. Pore clogging, in particular, is difficult to remedy as the pavement system generally must be removed and replaced. Pre ention of surface sealing and pore clogging depends on regular maintenance and prevention of damaging su s ante spil s. etro eu as of s an greases ave a high po en is o seal surfaces ana cog pores. Permeable pavements are high maintenance systems with a high potential for hydraulic failure. Figure IV-1. Coastal North Carolina Permeable Pavement Demonstration Site A demonstration site for permeable pavement is shown in Figure 1V-1. This is a small parking lot with a very low traffic loading (less than 3 vehicles per week, generally single family type vehicles). Two failure types are evident in this photograph. An approximately 100 square feet area has experienced excessive differential settlement relative to other areas of the parking lot. This is most likely due to improper compaction during construction or piping (pore erosion) of base/subbase materials after construction. These are structural failures, not hydraulic failures - though these failures involved a hydraulic mechanism. Hydraulic failures are improper hydraulic functioning of the permeable paver BLUE: Land, Water, Infrastructure Page 9 of 15 SANDY POINT • sTORMWA"rER MANAGEMENT REVIEW SUMMARY system (primarily inadequate infiltration). Evidence of piping with subsequent settlement at the parking lot corner can be seen in the lower right corner of Figure IV-1. A full structural failure is shown in Figure IV-2. This occurred during a single heavy precipitation event less than one week after the Figure IV -I photograph was taken. The piping evident at the parking lot corner in Figure IV -I proceeded during the precipitation event, resulting in this failure. Structural failures due to piping requires adequate energy gradient bebveen the driving water surface and the outlet water surface. Given the relatively flat terrain at Sandy Point this is an unlikely scenario in most locations. Permeable pavement installations adjacent to harbor bulkheads, retaining wa s, and relatively steep Tslopes are potential areas for such failures at Sandy Point. Figure IV-2. Structural Failure of Permeable Pavement Permeable pavement systems cost more to install than conventional pavement systems, cost much more to maintain than conventional pavement systems, and are much more difficult and expensive to repair when damaged than conventional pavement systems. Repair of failed systems generally involves complete removal of the failed area as well as removal of adjacent adequately functioning pavement for tie-in. Repair to permeable pavement may be required even when the system is functioning properly. This occurs when subsurface utilities, such as sanitary sewer collection and potable water supply, below the permeable pavement arc excavated. Conventional pavement can be readily repaired at minimal cost BLUE: Land, Water, Infrastructure Page 10 of 15 SANDY POIN'r • STOR,MWATER MANAGEMENT REVIEW SUMMARY using standard patching procedures when this occurs. When permeable pavement must be patched, issues such as locating and matching paver type, texture, and color arise. Patching the area with asphalt or concrete may occur, defeating the purpose for implementing permeable pavement. Thomas S Blue PE PLS does not recommend the use of permeable pavement in areas where there is a signs scan o entia for surface sealing or ore cloggin .-This includes roadways and parking ots with regular traffic loading exceeding 10 vehicles per day, irrespective of vehicular weight, and also includes areas which are exposed to heavy loadings of fine particles (such as clay, silt, and (lust). Permeable pavements are generally suitable and recommended for dedicated pedestrian pathways. Permeable pavements which incorporate course aggregate or vegetation (eg grass) between pavers is generally recommended over continuous asphalt or concrete material applications. The majority of permeable pavement proposed for Phase I of Sandy Point will require regular maintenance to perform as per the design intent. It is the opinion of Thomas Blue that any stormwater system that requires regular maintenance is almost certain to fail and generally fail on a regular basis. The more dependent a system is upon maintenance the higher the 2robability of such failure. This was related by Thomas Blue to the developer of Sandy Point and relevant associated consultants on several occasions during the stormwatcr management design process. C. Bioretention Areas The bioretention areas are the most important component for success of the Sandy Point Phase I stormwater management system. The bioretention areas proposed for Phase I of Sandy Point appear adequately dcsiEned. The proposed bioretention locations are well distributed across Phase I, dispersing concentrated stormwater recharge in a manner which reduces soil water mounding. Analysis was undertaken by project consultants to assess subsurface hydraulic recharge response relative to expected soil water parameter modifications (localized changes to hydraulic conductivity, soil porosity, and other relevant variables). Native vegetation is proposed throughout Sandy Point, with the exception of grass turf in specific areas (no native grasses form a turf cover). Both native vegetation and turf are proposed for bioretention areas. Zoysia grass and Centipede grass have been recommended wherever turf is to be employed. Zoysia does not require significant chemical application and is tolerant of heavy traffic, but is often susceptible to diseases and is slow growing. Cutting this grass with reel mowers is recommended to reduce disease occurrence. Periodic aeration and thatching may be necessary to maintain a healthy turf cover. Centipede requires very little, if any, chemical application (excesTertilization can kill Centipede). It is very low maintenance, grows well in moderate shade to full sun, and is moderately drought tolerant, but does not tolerate traffic well. Zoysia is proposed by the designers for Phase I of Sandy Point. Zoysia is recommended for high traffic areas. Centipede is recommended for low traffic areas. Establishment of a healthyroot matrix and associated "topsoil" LQrmatil2o is key to developing and maintaining proper infiltration potential. It is recommended that inspection of bioretention areas as well as any associated maintenance focus on these factors. The biorctention areas proposed for Phase I of Sandy Point are not expected to require regular maintenance to perform as per the design intent. Regular maintenance may be required to obtain the visual character desired. BLUE: Land, Water, Infrastructure Page I I of 15 SANDY POINT • STORMWATER MANAGEMENT REVIEW SUMMARY D. Eastern Project Area Conflicting information regarding the eastern project area is presented in Sandy Point development documents. The Sandy Point Charrette Report states, "There will not be any boat docks or piers erected out over Albemarle Sound from the Sandy Point development. Although such docks and piers are a common practice in eastern North Carolina, they are frowned upon by environmental regulators and are, quite, simply, aesthetically unappealing. Boating activity at Sandy Point, then, will be centered on our upland harbors." The current master site plan indicates five piers are proposed for Sandy Point extending from the shoreline approximately 110 feet to 515 feet onto Albemarle Sound. Two of these five piers are proposed for the eastern project area. The Sandy Point Charrette Report also states, "On both the east and west sides of Sandy Point, then, Albemarle Sound beaches are open for all to enjoy." The current master site plan indicates lots adjoining the Albemarle Sound shoreline are proposed along approximately 73% of the Sound waterfront in the eastern project area. These proposed lots would seem t mote docks over Albemarle Sound (and restrict beaches from being `bpen for all to enjoy"). A significant portion of jurisdictional wetlands are included within eastern project area proposed lots. These wetlands are primarily located along the rear lot boundaries. Lots proposed along Albemarle Sound slope towards the shoreline. Proposed lots with wetlands along their rear boundaries appear to slope towards the wetlands. These situations present stormwater management challenges. Individual stormwater management features will likely need to be located within casements in the rear of the lots. Building setbacks and indwidual lot grading will need to take stormwater management features into consideration. It is recommended that site plans be required for all lot construction. These plans should include detailed grading and landscape features and be prepared by a board certified engineer, landscape architect, or land surveyor licensed to practice in North Carolina. These site plans should be submitted to a third party board certified engineer licensed to practice in North Carolina for review and approval. This engineer should not be associated with the real estate developer or design consultants and should be fully indepndent of any interest in the development. It is recommended that at least two counties should be located between any office of the engineer and Sandy Point (Chowan County). E. Western Project Area As with the eastern project area, conflicting information regarding the western project area is presented in Sandy Point development documents. Lots adjoining the Albemarle Sound shoreline are proposed along approximately 12% of the Sound waterfront in the western project area. Three piers are proposed for the western project area. The Sandy Point Charrette Report states, "And nestled up against the wetlands on the west side of Sandy Point are large, woodland lots thatArther add to the diversity of the housing stock on this side of SR 32. " No large woodland lots arc proposed in this area on the current site master plan. The development character of the remaining western project area outside Phase I is proposed to be very similar in nature to that of Phase I. Extension of the proposed stormwater management system into the remaining western project area is expected to focus on permeable pavements and distributed bioretcntion areas. BLUE: Land, Water, Infrastructure Page 12 of 15 SANDY POINT • s'rORNIWA'rER MANAGEMENTREVIEW SUMMARY G infiltration potential and subsurface rechar =e aloniz the eastern portion of the western ro ect area will likely be lower, possibly significantly lower, than such e detailed ana vsis of soil water moundina an , ral scenaee is recommcnded_inAhisar rta er for P Attention should be given to prevention of pollutant short-circuiting from bioretcntion areas to adjacent surface waters in the proposed residential area between the adjoining excavated inland harbor and Albemarle Sound. The proximity and elevation difference of expected bioretcntion areas to adjacent surface waters is analogous to the situation with the proposed excavated inland harbor relative to proposed bioretention area A30. As with bioretcntion area A30, bottom grades should slope away from surface waters. F. Performance Monitoring The proposed stormwater management system is intended to facilitate infiltration of the entire water volume from the majority of precipitation events. This is a system, then, that is intended to produce surface water discharge only during relatively large and infrequent prcipitation events. To assess the proposed stormwater management system performance, monitoring should focus on subsurface measurements. It is recommended that a series_f monitorini* wells he installed along —_ ^- L14 transects between stormwater management measures and adjacent surface waters. Samples should be taken from wells and the adjacent surface waters at intervals following precipitation events. Samples should be analyzed for nitrogen, phosphorous, two metals representative of urban runoff pollutants, and two hydrocarbons representative of urban runoff pollutants. At least six event sample sets should be obtained and analyzed cac r. It is recommended that at least three precipitation gauges should also be installed across the site. These should be auwmatic recording tippingtippLng bucket type gauges. It is also recommended that at least two _water level recordex., a insl UadAu-ulc uLg the Albemarle Sound water level. Multiple moitoring stations are necessary for data comparison and adequate measurement system redundancy. Those undertaking monitoring for the project should take care to regularly inspect the monitoring equipment. Monitoring equipment is often damaged or fouled by animals and storms. Equipment can also fail for other reasons. Data can only be considered for use when it is known that the recordng equipment was operating properly. G. As -Built Survey It is unfortunately the case that "as -built" or "record" drawings of construction prepared by engineers are often significantly erroneous Discrepancies between these drawings and what actually was constructed in the field can be significant. Observed examples of this include sanitary sewer collection extensions shown with a positive grade on "as -built" drawings while actually constructed with a negative grade; potable water supply mains and associated appurtemnces shown as installed on "as -built" drawings while actually not having been constructed; sanitary sewer collection extensions shown as installed on "as -built" drawings while actually not havig been constructed; and potable water supply mains shown along the design alignment on "as -built" drawings while actually having been constructed more than twenty feet away. An "as -built" is not truly representative of what has been BLUE: Land, Water, infrastructure Page 13 of 15 SANDY POINT • STORMWATER MANAGEMENT REVIEW SUMMARY constructed unless site conditions have been determined by a Feld survey during construction (for subsurface structures) and after construction is fully comocted. It is strongly recommended that an "as -built" map should be prepared from a full topographic survey of the construction area by a board certified land surveyor licensed to practi e in North Carolina. This land surveyor should not be associated with the real estate developer or design consultants and should be fully independent of any interest in the development. It is recommended that at least two counties should be located between any office of the land surveyor and Sandy Point (Chowan County). The "as -built" survey and associated map should include all elements indicated on the construction/design plans as well as other prominent physical surface features, subsurface utilities, vegetation (including all planted stock as well as dense vegetation groupings), drainage features, above ground utilities, as well as legal and regulatory boundaries (lots, zoning, casements, setbacks, wetlands, hazards, etc). The map should include contours at one-half foot intervals and appropriate pot elevations to depict the land surface elevations. Electronic copies of the map should be submitted to the NC Department of Environment & Natural Resource (NCDENR) officials and placed on the NCDENR Division of Water Quality (DWQ) World Wide Web (W3) site for public access (download). Electronic copies of the map should be submitted as Portable Document Format (PDF) and Drawing eXchange Format (DXF) files, both open source formats. All associated field point data should also be submitted in electronic format to NCDENR officials and placed on the NCDENR DWQ W3 site for public access (download). Electronic copies of the field data should be submitted as standard comma delimited ASCII text files (with header line) including point number, casting, northing, elevation, and descriptor (N,X,Y,Z,D) followed by a carriage return (CR) after each point entry. All spatial information should be at State Plane Coordinates (NAD$3ft and NVGD88ft). An accurate "as -built" survey and associated map are critical for performance monitoring and permit enforcement. H. Performance Bonds A significant percentage of residential real estate development projects fail and many of these fail repeatedly under multiple ownerships. This is particularly the case with planned amenity focused communities (eg equestrian communities, golf communitas, lake communities). It is also the case that the individuals inspecting and maintaining site facilities, especially stormwater management systems, often do not have an understanding of the system being inspected and maintained. Key requirements for proper system functioning may be completely unknown to these individuals, especially as staff turnover in these positions is often frequent and stormwater management is generally given much lower priority than other duties. A "wait until broken to fix" approach to stormwater management will almost certainly result in considerable problems with the proposed function of the system. It is strongly recommended that performance bonds be required for all project stormwater management components oft e project. The performance bonds should allow a designated responsible third party (fully independent of any interest in the developmett) to fully implement all necessary maintenance and repairs. Clear provisions for enforcement of performance bond provisions in a timely manner is especially important as is a facility closure clause, BLUE: Land, Water, Infrastructure Page 14 of 15 SANDY POINT • STORMWATER MANAGEMENT REVIEW SUMMARY V. Conclusions The stormwater management system proposed for Phase I of Sandy Point is expected to function very well if constructed and maintained according to the design, exceeding applicable regulatory performance requirements. Beyond the discussion and recommendations presented, Thomas S Blue PE PLS finds no deficit in the system design. Thomas Blue recommends approval of the Phase I stormwater management plan contingent upon compliance with applicable local, state, and federal regulations. It is the opinion of Thomas Blue that detailed engineering review, inspection, certification, monitoring, and enforcement of all development on the site is needed to ensure the project is implemented correctly. This includes all development proposed at the project site, not just limited to Phase I. Phase I is the only portion of the proposed development for which detailed work has been presented for review. The current master site plan conflicts with information provided in the Sandy Point Charrette Report. The Sandy Point Charrette Report may have influenced project public opinion. It is the opinion of Thomas Blue that the public should be notified that conflicting information has been presented by the real estate developer. COPY FROM ELECTRONICALLY TRANSMITTED DOCUMENT This document originally issued and sealed by Thomas S Blue PE (023498) PLS (L-4093) on 2006 January 18. This medium shall not be considered a certified document. BLUE: Land, Water, Infrastructure Page 15 of 15