Yancey Co. Water Supply Watershed

oI'll v iF9QG S'Arr S i l v"J
6
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John Murphy .
Yancey County
Building Inspection
121 Oak Crest Road
Burnsville, NC 28714
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
June 9, 2008
Coleen H. Sullins, Director
Division of Water Quality
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Subject: Yancey County Watershed Protection Compliance Evaluation -
Dear Mr. Murphy:
JUN 1 1 2008
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Thank you and Gary Benfield for meeting with DWQ staff on April 24, 2008 to discuss Yancey
County's Water Supply Watershed Protection (WSWP) Program. This letter provides a summary
of our discussion and lists program strengths as well as non-compliance issues that must be
addressed by your office.
DWQ's review of the county's program revealed the following:
1. Administrators. John Murphy administers the WSWP program for Yancey County. The
Town of Burnsville administers its own WSWP program.
2. Surface Water Classifications. Yancey County has three water supply watersheds within
its jurisdiction as follows: Cane River WS-II, Bowlens Creek WS-II, and UT at Bowlens
Creek WS-II. There are also several Outstanding Resource Water and High Quality Water
management zones.
3. Watershed Ordinance. Yancey County's watershed protection rules are contained in its
Watershed Protection Ordinance which has been in effect since November 1993. A
review of the county's Watershed Protection Ordinance confirmed that it is complete and
in compliance with the Environmental Management's minimum requirements outlined in
NC Administrative Code 15A NCAC 2B .0200.
4. Website and Mapping. The county has a mapping department and GIS capability. Staff
indicated that their maps show the WSWP boundaries. While not required, DWQ
recommends the county's watershed map include the state's ORW and HQW features
(httv://www.neoliemay.com).
5. Low-Densityvgh-Density Option. Yancey County has a low -density development
ordinance for all its watershed areas. Standards and restrictions for density and built -upon
area are contained in Article 300 of its watershed protection ordinance.
No�SthCamlina
Wetlands and Stormwater Branch 1617 Mail Service Center Raleigh NC 27699-1617 Phone [phone] �/ljtj{C6j�Ijf
Internet: h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
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Yancey County
Page 2 of 2
June 9, 2008
6. 5/70 Provision. Yancey County's watershed protection ordinance includes a 5/70
provision for the WS-H-BW areas. This provision is reserved for non-residential uses.
Applications for this provision are approved as special non-residential intensity allocations
(SNIA). The county's Watershed Administrator approves SNIA projects. Staff indicated
that none of its 5/70 allocation has been used in any watershed. There has been no high -
density development in the county. -
7. Buffer Requirements. Yancey County's watershed ordinance requires 30' vegetative
buffers for development activities along perennial waters shown on USGS topographic
maps. Please be advised that all projects approved under the 5/70 SNIA provision must be
buffered as high -density projects with 100-foot vegetative buffers.
8. Variances. The county's WS variance process is detailed in Section 507 of its watershed
ordinance. Minor variances are reviewed and authorized by the county's watershed
administrator and county commissioners. Major variances are sent to the EMC for review.
Staff indicated that there have been no variances in the WSWP areas, although there have
been variances granted to the flood damage prevention ordinance. Please be advised that
the county must provide DWQ a description of all WSWP variances granted on an annual
basis.
9. Enforcement. Staff indicated that there have been no violations of the watershed
protection ordinance. Staff were able to rectify a violation of the flood prevention
ordinance.
10. Permits. Yancey County does not issue individual :WSWP permits; rather, the county
reviews projects for WSWP compliance when issuing building permits. The county
estimates it has issued approximately 400 building permits, with fewer than 10 in the
WSWP areas. DWQ recognizes that Yancey's Watershed Protection Permit Plan
Checklist is comparable to the watershed checklist in the state's Model Ordinance.
Thank you for your cooperation and assistance in this program evaluation. Your efforts to protect
North Carolina's natural resources are greatly appreciated.' Please feel free to contact me at (919)
733-5083 ext. 530 or Starr Silvis at 828-296-4500 if you have any questions.
Sincerely,
t/zc
Julie Ventaloro
NPS Assistance & Compliance Unit
cc: Starr Silvis, Asheville Regional Office, DWQ
DWQ Central Files

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
July 13, 1998 ' j�i� Lll
�� 5
UUL 2 2 Ig98 I_ i
Mr. Kelly Pipes, Manager
Yancey County
County Courthouse, Room 11
Burnsville, North Carolina 28714
Subject: Minter Supply Water,.shed Protection �.,rd n�nee � "ancey Coup
Dear Mr. Pipes:
This letter is in response to your June 30, 1998 letter requesting an extension, until
September, of the deadline by which Yancey County's water supply watershed
protection ordinance changes must be submitted to the Division of Water Quality. It is
our understanding that the County has recently settled a related lawsuit. It is also our
understanding that the requested extension will allow the County sufficient time to
revise your existing local ordinance to be in compliance with the statewide minimum
water supply watershed protection requirements.
As authorized by the Environmental Management Commission, I am granting Yancey
County an extension of their ordinance amendment submission deadline. The new
submission deadline will be Tuesday, September 1, 1998.
If you have any questions or if you need further assistance with the required
amendments, please call Steve Zoufaly of my staff at 919-733-5083, extension 566.
Thank you for your cooperation and support of the Water Supply Watershed
Protection Program.
Sincerely,
e �
A. Preston Howard, Jr., P.E.
cc: to��Westall111 0 -t � WW61
Alan Lang, ARO DCA
Steve Zoufaly, DWQ
DWQ - Central Files
P.O. BOX 29535, RALEIGH, NORTH CAROLINA 27626-0535
PHONE [phone] FAX [phone]
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State of North Carolina
Department of Environment
and Natural Resources
J Division of Water Quality
l
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 9, 1998
Mr. James K. Pipes, III
County Manager
Yancey County
County Courthouse, Room 11
Burnsville, NC 28714
RE: Water Supply Watershed Protection Ordinance -- Yancey County
Dear Mr. Pipes,
This letter is in response to your March 16, 1998 letter requesting an extension of the
deadline by which Yancey County's water supply watershed protection ordinance changes
must be submitted to the Division of Water Quality. It is our understanding that the
requested extension will allow the County sufficient time to settle a related lawsuit and to
modify the local ordinance to be in compliance with the statewide minimum water supply
watershed protection rules.
In the past, the Environmental Management Commission has authorized extensions of
ordinance deadlines for a period of 120 days. Therefore, I am granting Yancey County an
extension of their ordinance amendment submission deadline. The new submission
deadline will be Friday, July 3, 1998.
If you have any questions or if you need further assistance with the required
amendments, please contact Brent McDonald of my staff at [phone], extension
508. Thank you in advance for your cooperation and support of the Water Supply
Watershed Protection Program.
2Sincerely,
A. Preston Howard, Jr., P.E.
cc: Brent C. McDonald i��
Forrest Westall, ARO DWQ ur `f °� A 2
'c2dan_I.an:a ARQDCA: ,
Plil , ; j i
DWQ -- Central Files _ _ ?; , �z. t 1p ,;EtCT1C;�
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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CEY CoU�%
James K. Pipes III
County Manager
David R. McIntosh, Chairman
Randy 011is, Commissioner
John Renfro, Commissioner
office of tbe Q1.1'.10urttp Manager
33 County Courthouse, Room 11 - Burnsville, NC 28714
PHONE [phone] - FAX [phone] - email: [e-mail]
March 16, 1998
v
Mr. Brent McDonald
Community Planner, DEHNR c:':
P.O. Box 29535
Raleigh, N.C. 27626-0535
Dear Brent:
It is my understanding that the current Yancey County Watershed Protection Ordinance is
not in compliance with the standards set forth by the North Carolina Environmental
Management Commission. Yancey County is currently in litigation with the Yancey
County Property Rights Association over the current Watershed Protection Ordinance.
The County is attempting to resolve this lawsuit prior to its court date in May.
Because of this lawsuit I am requesting that the deadline for submission of a revised
Yancev County Watershed Ordinance be extended until June 30, 1998. This should
allow for ample time to make the necessary changes to the ordinance while allowing the
county to resolve the pending lawsuit.
Thanks for all your cooperation.
f
iPipes
County Manager
CC: Board of Commissioners

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 11,1997
VM' pumm"e.
4AT_EaxL_T-ipiron
County Manager
Yancey County
Courthouse, Room 11
Burnsville, NC 28714
Re: Water Supply Watershed Protection Ordinance
Dear Mr. Tipton;
The purpose of this letter is to inform you of the status of the water supply watershed
protection ordinance for Yancey County. As you are aware, the Environmental Management
Commission (EMC) revised the Water Supply Watershed Protection Rules in 1995 in order to
clarify certain provisions and add flexibility for local governments administering their water
supply watershed protection programs. Staff of the Division of Water Quality reviewed the
ordinance for compliance under both the 1992 and 1995 versions of the Rules. The corrections
recommended under the 1995 version of the rules are optional, and are noted as such in this
letter. The other corrections listed below are not optional. Once the ordinance is amended and
submitted to the Division of Water Quality, we will recommend approval of the ordinance by
the Environmental Management Commission. In accordance with the Water Supply Watershed
Protection Act (NCGS 143-214.5), the County has 120 days to correct and submit the ordinance to
the Division of Water Quality. The deadline for submission is Friday. November 7,1997. The
additional changes that are necessary in order for the ordinance to meet the minimum
statewide requirements are as follows:
1. If desired, Section 103 (D) may be modified to read as follows,'consistent with the 1995
Rules revisions:
D.
ardinanee, re.9ardless ai N . vthether ar.net-a ve�t6d riot hits been established-, may -be
If a nonconforming lot of record is not contiguous
to anj other lot owned by the same party, then that lot of record shall not be subect to
the development restrictions of this ordinance if it is developed for single-family
residential 1urposes.
Modify Section'302(B)(1)(d):
(d) Non-residential development, excluding: 1)
materialsrde pi �i nta 'Rl. 'J y , - ' `^ ' ^"andfills, and 3} 21 sites
I
for land application ofsludge/ residuals or petroleum contaminated soils. New
,
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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Mr. Earl Tipton
July 11,1997
Page Two
spilland maintained
hazardetts materials are wither used,
All other references to hazardous materials in your water supply watershed protection
ordinance may be eliminated and all other references in the ordinance to "sludge" also
should be changed to "residuals" to be consistent with statewide terminology.
3. Under the 1995 changes to the Rules the 5%/ 70% provision may now be increased to .
10%/70% and it may be applied to all new development and expansions to existing
development. If the County desires to'follow the 1995 Rules revisions, -mend Sections
302(C) and 501(D) as appropriate using language from the Model Ordinance.
If the County chooses to modify the ordinance to raise the provision to 10%/70%, submit
the amount of land available (as of 7/1/93) for development in the watershed areas
where the 10%/ 70% provision is allowed.
4: . • Section 303(C) may be amended to the following, based on the 1995 Rules revisions:
, Title
of to the open space area shall be conveyed to -the an incorporated homeowners
association for management; to a local government for preservation as a park or open
space; or to a conservation organization for preservation in a permanent easement.
Where a property association is not incorporated, a maintenance agreement shall be
filed with the property deeds...
5. Section 304(B) may be amended as follows:
"No new development is allowed in the buffer except that water dependent structures,
other structures such as flag poz les signs and securitylights which result in only
diminutive increases in impervious area, and public works projects..."
6. In Section 501(E), modify the following:
The Watershed Administrator shall keep a record of variances ... and shall submit
this record for each calendar year to the Division of Water Quality on or before
January 1st. of the following year '
Greup' Water QuEdity Seetion, Division of Env ire tal and provide:..,-
a description of each project.receiving a variance and the reasons for granting the
variance...
In July, 1996, the Division of Environmental Management became the Division of Water
Quality. All other references to the Division of Environmental Management and to the
Supervisor of the Classification and Standards Group, Water Quality Section, should
be changed.
7. Add or amend the following definitions in Section 601, consistent with the 1995
revisions to the State Rules:
a) Discharging Landfill. A landfill which discharges treated leachate and
which requires a National Pollution Discharge Elimination System (NPDES)
permit. F

Mr. Earl Tipton
July 11,1997
Page Three
b) Existing Development. (The wording in the Rules and Model Ordinance for the
definition of existing development was amended in 1995 to be more consistent
with zoning law. It is advisable but not required for you to amend the
definition of existing development in the County's ordinance as follows:]
... (3) having
an approved site specific or phased development plan as authorized by the
General Statutes (G.S. 153A-344.1)
c) Major Variance. A variance from the minimum statewi 'a water supply
watershed protection rules that results in any one or more of the following:
f2- the relaxation, by a factor of greater than ten (10) percent, of any
management requirement that takes the form of a numerical standard;
d) Minor Variance. A variance that does not qualify
vari-aneefrom the minimum statewide watershed protection rules that results
in a relaxation by a factor of up to ten (10) percent of any management
requirement under the low density option.
e) Nonconforming Lot of Record A lot described by a plat or a deed that was
recorded prior to the effective date of this ordinance (or its amendments) that
does not meet the minimum lot size or other development requirements of this
ordinance.
All other aspects of your ordinance are acceptable and we anticipate an expeditious
final approval from the Environmental Management Commission once the above noted
corrections are made and the ordinance is resubmitted. Although you are not required to update
your ordinance to meet the 1995 revisions to the Water Supply. Watershed Protection Rules, you
may wish to consider these new rules when amending your ordinances to incorporate the
required changes listed above. If you have any questions regarding the Water Supply
Watershed Protection'Program, please contact Lisa Martin at [phone]; ext. 565 at your
convenience. Thank you in advance for your cooperation and support of the Water Supply
Watershed Protection Program.
Sincerely,
C�
A. Preston Howard, Jr., P.E.
cc: Lisa Martin
Forrestry� es �I#i, A,�IZOi�.' �+ ,
an ang, ARO DCA
DWQ Central Files

State of North Carolina
Department of Environment, -
Health and Natural-Resourcf. -
Division of Environmental Managl
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Direc
Mr. Sam Riddle
Route 6, Box 374
Burnsville, NC 28714
Dear Mr. Riddle,
JUL
Hsi � REQ1 UVA
w- ,- -
I enjoyed meeting with you and thank you for your interest in the &@1er Sou plr
WatershePsotection Pro ' T As promised, this letter includes a summary of the issues we
discussed.
The=Water- Supply Watershed Protection Act _was ratified by the North Carolina
General Assembly in June 1989. The Act mandated that the Environmental Management
Commission (EMC) reclassify all surface water supplies in the state and create a set of
minimum statewide standards (known as the Water Supply Watershed Protection Rules) to
protect the classified. water supplies. The Rules, as you know, require all local governments
with land use jurisdiction within surface water supply watersheds to adopt and implement
ordinances which apply the standards to each watershed. The EMC is very pleased with the
near 100 percent compliance rate for local government adoption and implementation of the
ordinances. As with any new law, however, there are misconceptions as to the application of
the law that have a number of landowners across the state concerned about how the Water
Supply Watershed Protection Program will affect them and their property.
The following issues were raised by you at our meeting on June 8th. I hope this helps
to clarify how the Rules affect your property and the property of other Yancey County
landowners.
1. Gifts of Land: Under North Carolina law, G.S. 153A-335 defines the subdivision of
land as all divisions of a tract or parcel of land "...into two or more lots, building sites,
or other divisions for the purpose of sale or building development (whether immediate
or future)...". In a letter from Wilton Ragland, Jr., Associate Attorney General, to
Forrest Ball dated February 19, 1976 and attached for reference, Mr Ragland states
that if the platting and conveyance of tracts of land to the children and/or projected
heirs or legatees is not made for the purpose of selling and/or developing such
property, then the ensuing "division" of land would not be considered a subdivision
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Mr. Sam Riddle
June 27, 1994
Page Two
under state law. Please note that Mr. Ragland's statement is in reference to the
division of a deceased person's land. In a second attached letter from Richard Ducker,
Assistant Director of the Institute of Government, to David Quinn dated October 30,
1986, Mr. Ducker states that the transfer of land to heirs while the owner is still living
may be subject to regulation under subdivision law. Mr. Ducker does conclude,
however, that gift divisions may be unregulated if it is clear that the donor (and, by
implication, the donees) of the lots in this division do not expect the gift lots to be
resold or developed for resale. As to the application of the Water Supply Watershed
Protection Rules, the Rules are currently silent on this issue. It is our intent to address
"gifts of land" by allowing the local government to determine if the division is a
subdivision of land_ under _North Carolina law. If the division of land -does _ not . qualify
as a subdivision, then it is exempt from the local water supply protection regulations.
However, I do feel compelled to mention that, if applicable, it may not exempt the
land from zoning regulations.' If the water supply protection ordinance is enforced
under zoning, then the property would be subject to the regulations.
2. Exemptions for "subsequent owners": The Water Supply Watershed Protection Rules,
under 15A NCAC 2B .0104(r), state that "...a deeded single family lot owned, by an
individual prior to the effective date of the of the water supply ordinance, regardless
of whether a vested right has been established, is not subject to the development
restrictions of these Rules...". Though not stated implicitly in the Rules, .the,
exemption runs with the land and is, thus, applicable to future owners. The exemption
does not dissolve when the land is sold. It is also not necessary for the lot to be
developed. Vacant platted and recorded single family lots are exempt. This
exemption is not applicable for any other use. Commercial, industrial or other land
uses would require an approved subdivision plat or development plan prior to the
effective date of the local ordinance.
3. Lot recombination: Also under 15A NCAC 2B .0104(r), the Rules state that local
governments may require the recombination of single -owner nonconforming lots. The
Model Ordinance, under Section 307(B) states that single -owner nonconforming lots
shall be combined. Since the Model Ordinance is only suggested language, the
provision in the Rules would prevail. Thus, it is the local government's option
whether or not to require lot recombination for single -owner nonconforming lots.
4. Minimum lot size and built -upon area: All new development in WS-II, WS-III and
WS-IV (except for projects which do not require a sedimentation/erosion control plan)
watersheds must meet the requirements of the water supply watershed protection rules.
The project must meet the density or built -upon area requirements as applicable. The
project does not have to meet both density and built -upon area requirements. For
example, in a WS-II watershed outside of the critical area, each lot in a single family
detached development under the low density option would have to meet either the one

dwelling unit per acre density requirement or the 12 percent built -upon area
requirement for the entire project (the 12 percent requirement does not apply to each
lot, as long as the entire development does not exceed 12 percent). Density
requirements (dwelling units per acre) are only applicable to single family detached
low density development, but built -upon area may also be used. For any development
other than single family detached low density development, built -upon area must be
used.
I hope this adequately summarizes the issues raised at our meeting. I would also like
to mention that Division of Environmental Management (DEM) staff has proposed conceptual
rule changes to the FMC's Water Quality Committee. that will clarify these issues_ in the.________-.__ _
Rules and will also add flexibility to the local government administration of the Water Supply
Watershed Protection' Program. Though it is impossible -to estimate at this time how long the
rule -amendment process will take, I will assure you that we are proceeding quickly and hope
to submit. the proposed changes for public review and comment in the near future.
Thank you again for your interest in the Water Supply Watershed Protection Program.
If I can be of further assistance, please do not hesitate to call me at [phone]. You
may also contact Forrest. Westall DEM'-s- Asheville -Region Water Quality Supervisor, at
[phone].
Si cerely,
Lisa Martin
Attachments
cc: Representative Robert Hunter
A. Preston Howard, Jr.
Steve Tedder
,,Forrest Westall ARO =DEiVI '
Alan Lang, ARO DCA
Henry Lancaster
d-9:riddle.let
0

OFFICE OF COUNTY ATTORNEY
BUNC0M13E COUNTY COURT HOUSE
ROOM AIZ . „
The honorable Rufus L. 'Ed-isten
Attorney General
State of North Carolina
P. 0. Box 629
Raleigh, North Carolina 27602
P. O. SOX 7454
ASHEVILLE. NORTH CAROLINA 28807
February 11, 1976
Dear Mr. Attorney -_ General:
_....._.:' On `behalf of the Board of Com=issioners for the County of
_°Buncombe'I submit the following questions for your opinion concern-
ing Part 2-Article 18 of Chapter 153A; Subdivision Regulations:
1-..(a)-Does -the plating--and--conve-yance-.of---one-=lot-ar---tract -- -----
out of a larger tract.. constitute the development of a*
subdivision:within the meaning of -North Carolina. -Generate...
Statutes Section -153A-335 even though- the plat` -upon which
the conveyance is based .is not to be recorded. in the..
Register of Deeds Office?
(b) Under said definition when a subdivision ordinance is
adopted, does such a plat of one lot or tract need to
be recorded?
(c) Does such a conveyance -of one lot or tract result in
the remaining portion of the larger tract being a sub-
division ;•rithi-i the meaning of said statute, and if so,
does said remaining portion need to be platted and re-
corded?
(d) Does the later conveyance for the entire remaining por-
tion as outlined above constitute a subdivision?
2. Does the platting and conveyance of tracts -of land by
a Grantor to children and/or projected heirs or legatees
constitute a subdivision within the meaning of North
Carolina General Statutes Section 153A-335 irregardless
of whether new street right -of =way.de'dications are *in-
- volved?-- 'May such conveyances be exempted from a subdi-
vision ordinance?

r oruary 11, 1976
3. Does the division of land into parcels. of greater than
ten acres if no street right-of-way.dedication is involved
remain exempted from the subdivision definition in such
statute when one of the lots or parcels is less than ten
acres but the rest are ten acres or more?
4. Is it necessary to plat and record the entire tract(s)
from which,a subdivision required to be platted (within
the.meaning of North Carolina -General Statutes Section
153A-335) is derived?
5. In adopting a subdivision ordinance, are the County Commis-
sioners empowered to adopted different standards for
for different classes of subdivisions when. the -classifi-
cation is based solely on the number of lots?'
6.
-- - =
--Whether. conveyaricesMauiong" family`4members may be: -_exempted_
__by::the-._County_ :Commissioners , from --a::subdivisionordinance?.:::.
. .. - h.+
7. Can_-.-s.eller or subdivider_..=of land a -
p s s -onto the buyer`
any" responsibilities which may be 'imposed upon him
a subdivision ordinance, and' thereby releave. himself -of
such * responsihF:Mties-?—
.Trie :Bd- rd:..of Commissioners -=for the. --County- of Buncombe :has
adopted a'subdivision ordinance that will'become effective'March
31, 1976. They have requested me to urge you to reply to these
questions as soon as possible.
Thanking you in advance for your assistance, I am
Sincerely yours,
Forrest F. Ball
County Attorney
FFB:dw
CC: Board of Commissioners

ram.:
RUFUS L. EOMISTEN
ATTORNEY GENERAL •1
c tztte of nrtl� Luraliila
ceparftitrltf of -�ttstirc
P- O. BOX 252-01
RALEIGH
27611
February, 19, 1976.
1r. Forrest F. ball
Office of - County Attorney ___.___
Buncombe County Court --House (Room 412)
P. O..Box 7454
Asheville, North Carolina 288G7
Dear Mr. Ball:
This letter is in reference to. your inquiries concerning Part-.2j:Article
18 of Chaf:ter 153A, Subdivision Regulations. Your letter of `Febru_ary:11�: 1.
1976 was referred to this office for handling. You -were- informed of':this
referral in a letter from this office. dated February 17, 1976.
In your letter- of February 11, you stated that the Board of Commissioners
for the County of buncombe has adopted a subdivision ordinance that will -
become effective March 31, 1976. Part 2, Article 18 of Chapter 153A does not
crake the adortuion of such a regulation by the County *mandatory. The statute
gives each County wide latitude in deciding what provisions should be placed
in a particular County ordinance. However, the statute does state certain
guidelin-.s which must be complied with once such a regulation is adopted by
a County.
As to question l(a), the answer depends upon the intrepretation of the
question. The statute says that a subdivision cleans all divisions of a tract
or parcel of land into two or more lots, building sites, or other divisions
for the purpose of sale or building develop;. ent . if, in question 1(a), you
are referring to selling a portion of a parent tract, and while doin= so
making a plat of the tract that is being sold, this office is of the"oninion
that such a conveyance wound not constitute the development of a subdivision
within the meaning of G. S. 153A 335. This office is of 'the opinion that .ta
the
statute does not co:tle into play until a tract is divided into two or more rts
riith the intention of selling and/or davalorin. both >rts . This office is
also of the opinion that whether cr not tha conveyance is to be recorded is
-Ummaterial".
-
• _.mil __ _ _ _ _ _ � __
T'

1-1r. Forrest. Ball
Faye Two
February 19,197E
The answer to question a(b) is that the County has the option, in its
subdivision ordinance, to require that such a plat or tract be recorded.
As to question 1(c), it would seem that in order to have a subdivision
within the meaning of the statute, some type of plat would have .to be nude,
whether this plat is recorded or not. Otherwise, it would seem that no
division of the land has been made. As stated in answering question 1(a),.
this office is of the orinicn that the 'statut.e..is_not directed toward a mere
sale of a portion.of a tract -of land®'. ;The statute is.. directed toward
dividing.. _cf. a --tract - of _land: into '!twd" 'Wore 'slices""; :for'.the':Purpose` .:of:
selling''and/or'developin�; each, "slice" := " The;''previous statement -was -intended
to also :serve as an"answer to "question-,l(d).
As to question 2, the answer is no, if the platting and conveyance of
tracts. of land to the children andor-projected heirs or legatees is:.not:;-made
for. the purpv3e ..of selling:=and�or� developing such property:- The'.. 'p3z'tit:ionirio
of.propprty.:in:order-:to'-alr6r`"childr'eii_and/or pro;;ected heirs.or.:;legateesao
receive .their rightful -shares would not appear to oe within the' it eaning of the
statute.
As to question 3, it must be kept in mind that the statute refers to -.
divisions into two or more -parts. It should also be kept in mind that the
division is for the purpose of sale ' and/or building, development. Tracts of
ten acres or more are exemi:t. If one Of the lots is less than ten acres, the
statute would not apply, because the statute applies to a division of land into
two or :core rarcels , with each T:arcel being, less than ten acres. This office
is of the opinion that the statute would cor&into slay if there were two or
more rarcels of less than ten acres, and these two parcels of less than ten
acres were divided for the purpose of sale or building, deve orment.
As to question 4, the statute allows the County to decide whether plats
need to be recorded. The statute does not attempt to determine when a
(articular tract needs to be platted or recorded. The statute leaves the
recording, requirement to the individual County, in its particular subdivision
rem lation. As to platting, the statute requires that once a County has adopted
a subdivision regulation, and once a particular owner subdivides and plats a
tract of land, the plat must be in ccnfor-n nce with the subdivision regulation.
As to question 5, the answer to this question would appear to be yes.
The Counties are given wide latitude in adorting their particular subdivision
ordinances.
- _ - -
..-
}.ii
-
w..::,=mot

ti
Lr. Forrest F. Ball
Fade Thrive
February 19, 1970
As to question 6, it is hoped that this _
answered. However, it would appear that the answer toon hthias slrea_d_ y. been
yes- Again, the Counties are given ear
Provisions "of their mm sutxiivision ordinances. west:ioiz"is
great latitude -iri determiriing.-the`- .
As to question 7, it would apFear that the_'aris:,rer-to: this
no. This 'office. is of the opinion .that the statute is intended:te .Pie`
toward the seller of ro -ert question is.:'_::
F r y and not to the bu er of directed-.'
buyer has -
Purchased the parcel in..questio_n, itwould not----
Gnce :he..'<
der Would be. to the statute_ un .,such PPr;that :- ' - :....
the.
:become:a r�� that uch.:tim - e=f'Wottl
;uselle of rtic e'as:-he'him8
_
- - Par.cel.._,-:....:.. -or :a.;_- ort2.01
� _- ---r_a:-----
.� ular :ce,
With -
�k' z.n -
d re ands - - -
g �I am
Ve tr =
rY..
ftUFUS - - - _
: - -
"L. ) N.
Attorne =Ge ral ,
Wilton E. Ragland
Associate AT.tt,prney General
lIzajr:sk
cc: ir. Roy Trantham

Institute of Government CHAPP BUILDING 14- A
- CHAPEL HILL, N.C.2751a-6059
TELEPHONE [phone]
The Uilte)"sil; r,r _Vorth Crr,olilia at C11(lpel 1-1i1l
October 30, 1986 '
Mr. David H. Quinn
Community Development Planner
Asheville Regional Office
_.-..
""Dep`t`:wofmNatural "Resources & Coiimiunity Development
Post Office --Box 370
Asheville, NC 28802-0370
Dear David:
In your letter of September 25, you asked me to provide you and the
Avery County Planning Board with an opinion letter concerning the
application -of the definition of -the term "subdivision" in G.S. 153A-335
to divisions of land for the purpose of transferring lots to the "heirs"
of the subdivider. That statutory definition provides in part that
"subdivision" means all divisions of a tract or parcel of land "into two
or more lots, building sites, or other divisions for the -purpose of sale
or building development (whether immediate or future) . . For
purposes of this interpretation, you define "the division of land for
heirs" as follows:
The conveyance of a tract or tracts to a grantee who would have
been an heir of the grantor if the grantor had died intestate
immediately prior to the conveyance; or the conveyance of a tract
or tracts for the purpose of dividing lands among tenants in
common, all of whom inherited by intestacy or by will, the land
from a common ancestor.
First, let's consider the division of land among tenants in common
who jointly inherited a tract under the terms of a will or by operation
of the law of intestate succession. Under North Carolina law, a routine
division of this sort apparently falls outside the scope of the
"subdivision" definition. In the 1974 North Carolina Court of Appeals
case of Williamson v. Avant, 21 N.C. App. 211, cert. den. 285 N.C. 596
(1974), the court declared that a conveyance made for -"the purpose of
dividing up the real estate of the late (decedent) among the heirs of
(the decedent)" was not subject to regulation because.it "did not
constitute a division of land for immediate or future sale or
development within the meaning of G.S. 153-266.1 et seq." (The statute
just cited preceded G.S. 153A-335, but includes rather similar
language.) In the Williamson case, the heirs apparently agreed to a

Mr. ,David H. Quinn
Page 2 -
October 30, 1986
voluntary partition of their commonly owned property whereby they all
agreed to exchange deeds dividing their commonly held land into
divisions representing equal shares or interests for each. They also
took the additional step of having a plat prepared indicating the lots
to be distributed. It is not clear whether just one lot was distributed
to each heir, or more than one, nor do we know how long after the
decedent's death the division was made.
If the division of land among tenants in common who are heirs to
the property is conducted within a reasonable time period after the
death and each heir takes title to just one portion of the tract (what
deem to be a "routine" partition of land among heirs), the Williamson
case appears to control and the division may not be regulated under a
subdivision ordinance. -To the-extentj- then, -that your definition --of
"division of land for heirs" includes such a division, it -correctly
defines divisions that are outside the scope of G.S. 153A-335. Note,
however, that the ruling in the Williamson case may reflect the fact
that testamentary and estate -related subdividing constitutes a rather
insignificant portion of total subdivision activity in most
7
jurisdictions, and. the concern for profit that drives most subdivision
and development activity is typically not a major motivation for those
who plan for the distribution of their property after their death. As a
result, if the common owners do not divide their land until some
considerable period of time has elapsed after the decedent's death, or
if the common heirs take the opportunity to plat the land into a number
of lots so that each tenant receives more than one parcel of a size and
shape suited for building sites, then the result is less clear. In such
an instance, a court might find that the division of 1ots;was less a
routine distribution of property growing out of the settlement of an
estate and amounted to more of a formal development plan to sell
building sites, with development activity the primary motivation. Such
activity might well be subject to regulation.
The second kind of division that you ask about involves division
made with an eye to transferring land to heirs while the owner is still
living. We have no case law here in North Carolina on this point. But
what case law comes from other states under subdivision statutes that
are similar to North Carolina's suggests that the courts are unwilling
to conclude that divisions involving "intervivos" transfers of lots to
heirs (made while the owner is still living) are necessarily outside the
scope of regulation. The status of a grantee as a potential heir under
the laws of intestate succession does not necessarily mean that the
division that preceded the transfer to the grantee may not be
regulated. If lots are to be sold to heirs, the statute clearly makes
the division subject to regulation. Even if the division is designed to
enable the owner to make gifts of lots (to heirs or to anyone else), the
division may still be subject to regulation. The Maryland case of Groh

i1r . David 11. Quinn
Page 3
October 30, 1986
v. County Commissioners of Washington County, 245 Md. 441, 226 A.2d 264
(1967) involved the division of a parcel of land so that gifts of
several lots co be used as recreational or picnic areas could be made to
several charitable institutions. The court found that such a division
to be outside the scope of regulation, but only because the grantees
provided assurances that the lots would not be developed. Furthermore,
one court has found that evidence that family members intended to resell
lots given to them was enough to subject the original division to
regulation. The case of Pescosolido v. Smith, 142 Cal. App. 3d 964, 191
Cal. Rptr. 415 (1983) involved the application of a California
subdivision statute similar to ours. In that case, the court found that
a series of gift deeds to each of six children was not exempt from
regulation where there was evidence that each of the children intended
to -resell his -or -her- respective lot to someone else and —that the
subdividers (their parents) were party to the plan.
Insofar as your definition of "division of land for heirs" applies
to "intervivos" transfers of lots, it does not define a class of
transactions that are all beyond the reach of regulation under G.S.
153A-335. The definition is overly broad; a good many of such transfers
will be subject to review. The language of G.S. 153A-335 appears to
allow a cognty with a subdivision ordinance to leave some gift divisions
of land unregulated, but only to the extent that it is clear that the
donor (and, by implication, the donees) of the lots in such divisions do
not expect the gift lots to be resold or developed for resale.
I.hope that this letter serves your purpose. Let me know if it
needs clarification or if you would like to discuss any aspect of what I
have said.
.Sincerely,
Richard D. Ducker
Assistant'Director

State of North Carolina
II T1UMn .Nlit:11( Dci.�arcrnent 00LISiiCC;
RALf EIGH
2 7602d0O2c)
November 12, 1986
David H. Quinn
Department of Natural Resources
and Community Development
Post Office Box 370
Asheville, North Carolina 28802-0370
Dear Mr_ Quinn:
You have asked for elaboration on our response of 8
October 1986 and 15 October 1986 regarding the definition
of subdivision under G.S. 153A-335. Particularly, you
asked whether the definition of subdivision in G.S.:,153A-335
has been "amended" by action of the North Carolina Court of
Appeals in the case of Williamson v. Avant, 21 N.C. App.
211.
It appears from that case that conveyances made for
the purpose of dividing land among heirs without any
immediate or future intent for sale or building development
are excluded from the definition -Of subdivision. In that
case the Court had found as a fact that in 1970 "conveyance
was made for the purpose of dividing up the real estate of
the late T_ D. Alley among his heirs." There was no dispute
as to that finding. The result, however, may have been
different had there been some evidence that the division
was for sale or building development either immediate or
future._ It would appear that the sale does not have to be
exclusively for sale or building development; it might well
be for dividing up the property and for sale or building
development by one or more of the heirs. In such a case
the definition of subdivision would apply.
If I can be of further assistance, please let me know.
Sincerely,
LACY H_ THORNBURG
rne.y GEner
Douglarnt
Joh n
Assisttto ne,

September 10, 1
MEMORANDUM
TO: Regional Supervisors
Regional Water Qua ity Supervisors
FROM: Steve Tedder
P
1
i
Asheville Regional office
Asheville, North Carolina
SUBJECT: Handling waters that do not meet water quality standards
As you are aware, since October 1989 the fecal coliform limit
for Class C waters has been 200/100 milliliters. Now, when use
attainability studies are conducted and waters are found not to
meet the new fecal coliform standard, the data are also showing
that these waters are not meeting the basic water quality
standard for this parameter. As a result, there is a need to
establish a procedure to be followed in these cases that ensures
that pollution mitigation measures will be taken to attain water
quality that meets the State's standards. The proposed steps to
this procedure are as follows:
1) A waterbody.is identified as having high fecal
coliform levels through a reclassification'study or
other water quality investigation.
2) A'regional office staff person is assigned'to the
case to identify the problem and serve as the contact
person for DEM.
3) The source(s) of the problem (1.e. failing septic
systems, stormwater runoff, noncompliant NPDES
discharge(s), animal operations) is(are) identified.
4) The appropriate agency(ies) is(are) contacted and
made aware of the problem. This is an important step
and is utilized to establish the lines of
communication between the other agencies and the DEM
contact person. Other agencies should keep the DEM
contact person informed of any actions taken on the
case and copy them on related correspondence or
studies. The DEM contact person needs to make it
clear to the other agency personnel.that DEM wishes
to be kept informed, in writing, of these types of
developments. All DEM correspondence regarding these
matters should also be copied to Steve Zoufaly for
inclusion in the reclassification files. If the
problem is identified as nonpoint source pollution,

the designated nonpoint source lead agency personnel
should be contacted. It may also be helpful to copy
the appropriate cooperating agency.
5) The DEM contact person should maintain a file on the
case, and when necessary call the involved
agency (ies ) to check on the progress of reined-ial
actions.
6) When remediation has been completed, DEM and other
agencies should be notified. In the case of DEM, we
can proceed to public hearing for the
reclassification if all previous work (e.g. studies,
etc.) have been completed and show that the problem
has been resolved and the water quality standards for
the requested classification have been met.
Attached is a table that .l.ists possible nonpoint sources of
pollution and the appropriate agency (ies)-to.contact -for..that
problem. Contacts for the Division of Soil and Water.
Conservation, the Division of Forest Resources and Land Quality
are attached for reference. If the pollution is. the result of
failing septic tanks or straight pipes, the county health
department should be contacted. -If a noncompliant NPDES
discharge is responsible, appropriate DEM staff should be
notified. Also enclosed is a list of waters that have been shown
through a reclassification study to have fecal coliform levels in
excess of the water.standard.
The intention of this effort is to ensure that documented
action is taken in response to the.. identification of water
quality problems. While it is recognized that limited staff and
resources may influence the determination of the priority given
to particular remedial actions, it is also important that these
projects not be given so low a priority that they are lost or
forgotten, potentially resulting in a worsening of the water
quality problems. If you have any questions or comments
regarding this procedure please feel free to contact'Steve
Zoufaly, Suzanne Keen, Beth McGee or David Harding in the Water
Quality Section Planning Branch ([phone]).
cc: Water Quality Assistant Chiefs
David Sides, Division of Soil and Water Conservation
Harry Layman, Division of Forest Resources
Charles Gardner, Division of Land Resources
William Meyer, Division of Solid Waste Management
John Smith, Department of Agriculture, Food and Drug
Protection
Beth McGee
Steve Zoufaly
M:regions.mem

WATERS THAT DO NOT MEET THE FECAL COLIFORM STANDARD FOR
CLASS B OR CLASS C WATERS
(Based on recent reclassification studies.)
Water Body County Regional Office
Drymans Fork Macon Asheville
tributaries to Cartoo- Macon Asheville
gechaye Creek
ICBalNbuntai.r! Creek __—'-----.--- Yancey --A-s--hevi-1_1.e
Elk River downstream Avery, Watauga Asheville
of Wildcat Creek
Ramah Creek Mecklenburg Mooresville
Clear Creek Mecklenburg, Mooresville
Cabbarus
Scott Creek, Dan River Stokes
North Fork New River Ashe, Watauga
South Fork New River Watauga
UT to Yadkin River - Yadkin
(justice Reynolds Creek)
M: nonb. tbl
Winston-Salem
Winston-Salem, Asheville
Winston-Salem, Asheville
Winston-Salem

NONF'CI I NT
POLLUTION SCIL IPCE' � AND LEAO AGENCIES
RESPONSIBLE FOR REGULATION
LEAD AGEP1I_Y
I:13OPEPATIN6 AGENC:IE'
A! F:ICULTIJFIE
-ar,iIna L-par-at.ior-
of Soil
and Water- Con_er--..atian %OSWC.-I
_ail and Water- C:onservat.ion CIist.r i::t:
Field
P,epre_•erIt•at.i%Jc
-Bear-d of Supervisors.
- Lur bidrb-I
:_gee
attached maP;
LIS❑A-Soil Conser-ti,ation 'Ser-,•:-ice
—❑istrict.I_orrser:ationist.
Agricult.ur-al Extension _,er-•: i _e
-Cc unt.y Extension Agent.
-pe '.i _>de:_
EIil-FIar-t.ment. of
Agriculture
E!Si'C
F'- t--,Ja '=art
ian
oil ar-nd 4lat.er- Isonser•aat.ion Cli_,t.ri:t
1_:ontact.: Fielci Inspec:t.or-
------... ---------------------
URBAN Eli-,•-i_•ion of Envir-onmer-rtAl M.3nageirient
W.at.er QualiL:y Planning: 'SLand•ards .and
Assessment. Unit.
CCIN'_;TPUC:TICIN Eli' ision cif Land Quality
Unrrtact.: EHNP Pegional Office Engineer
01•i-' I TE idA_ TEWATEP
O ISF'0':FIL
-puL1 r y_..ten_ and Di-,,Is.ion of Err,.-ircunmenta1 Pianagement
- sept.ic tank:=., t. ai,q ht. C:ount.i_a Health Clep.yrtmerit or
F ipe-, and Eli,, ision of Enr,'ir-orunent.al Health
pr i,•:-at.e -usLeins
SI ILILI NASTE OISPO SAL ---Cli , i_.ion of 'Sc,L id Waste hlanagement-
I.andt=i I Is::
FFIRES IF''r Eh,.•'i_:ion of Fiira_.t. Pesour-r:es National Forest. Service
C:or Laca.: Eli = tri _t Fore_•ter
t1ININ!_ Eli',aision of Land Resources
Contact: EHNF: Regional Office Engineer

50 ve Off-icc ill 1, ulcigli, which provides spcc uliy.cd
wc.rs, geolog i-sts teCill-liCaj lrj(j leg',11 SIIj)j)o)IA.
i"I'.'ss PX-'I I'll 1111111, to S;IfCL�- of
Ck), lt)il alld scdillic.11i colwoi 111C 11cl(I olficC personnel arc CroSS-Mlillcd
II, .:I -;i::Ind TCsjlolIs'ihlc ()Jvmlioll to illiplelliclit the 111sixxtioll, public c(IlIciltioll
and clifolccinc.nt responsibilities in clan) S;Ilk-[y
Cl,()s MI, C.(),) ( ro! a11(j Ill ijjC I -CC Ja 111❑ [i 011. 1-01-1*LlftlICI
inf*01-flizitio)[I OF oSSISMIICC, C011(lict the 11c.arcst
i
1ormll. le.Id(lu:11 IC-1 S.
Regional Flig lwcf o
I S aIII 1 0 1, F1 C CS li
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.X,(X) H.,111:11 l)II- Ii(Y.'s NwIll Point Blvd. tiuuc II})
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P.Ilclgh, N.C. 2,1fJ i 19) '10 1 -2351
,ill;) 131
1, alcigh Central Officc
Sc, lic.41 Chief, Chic( Fligilmul,
1.1;-I Carolina Ayciwc Sedilncntntion Engincur, Dam
'Nashillgi(xi, N.C. 2-18S9 Safcty FII&CCIr, Mining Spcciahsl
P.O. Box 27687,
JAlcigh, N.C. 21611
I )all sallis. P I. I(>') 'I I :1 4 5'/ 1
250 4101
7
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C. r)qArtn,,�l
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j 'ynxjvj RIX"k,
Nudcn 4
Stc4kcn G. C«,,,,I. Lhi- ;,"H� 14, 10.,
Div1slro on of Land Resources
Land Quality
Section
N.C. Department of Natural ReSOWCOS
and Community Development

Noith CaroFbrest Service
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REGIONS & DISTRICTS
JANUARY, 1987
O REGION I Kinston
REGION II S;Mfnrd
REGION III - Asheville
O DISTRICT I -'Asheville
DISTRICT 2 Lenoir
DISTRICT 3 Rockingham
DISTRICT 4 New Bern
DISTRICT 5 Rocky Mount
AMAM
D6
O DISTRICT
6 Fayetteville
DISTRICT
7 Elizabeth City
DISTRICT
8 Whiteville
DISTRICT
9 Sylva
DISTRICT
10 Lexil-19ton
DISTRICT
I Hillsborough
DISTRICT
12 Mt. Holly
DISI'f:ICT
13 Fairfield
1 '
NORIHAMP '
WARREN lON
HAEIIAR
RANKUN
(DGI•
NASH COMB[
WIESON
�1 -RUNE
W AYNE
TO P111
DB
R-I
A 4IIN W (`
G1ON0" \3
INPlu u��t
H,D(
ff AUI ORI / J
N
IAM'
oco
D13
Anil Rli�
O Goldsboro Forestry Center
O2 Clayton Forestry Ccnlcr
O Morganton Forestry Center
® Flolmes State Forest - Hendersonvil':-
O Gill State: Forest - Crossnore
© Bladen Lakes State Forest - ElizabcLh!.o\,,:n
O Rend(:zvOUS Mountain Statc Forest ['(Irlc 1r
O Tuttle State Forest - Lenoir
0

DISTRICT FORESTS-S
D-1 David Brown
220 Sardis Raod
Asheville, NC 28806
Phone: [phone]
D-2 Donald H. Sdeiller
625 East Boulevard
Lenoir, NC 28645
Phone: [phone]
D-3 Gene C. Barnes
3 1/2 miles North Rockingham ;l Highway
Route 1, Box 422
Rockingham, INC 28379
Phone: [phone]
D-4 Ralph M. Cullom
3850 Highway 17, South
New Bern, NC 28560
Phone: [phone]
D-5 Roy M. Butler, Jr.
Box 249, Airport Road
Rocky Mount, NC 27801
Phone: [phone]
D_-6 Harold G. Grady
221 Airport Road
Fayetteville, NC 28306
Phone: [phone]
D-7 J. Mike Hendricks
Berea Church Road
Route 3, Box 511
Elizabeth City, NC 27909
Phone: [phone]
D - 8 Robert H. Houseman
Route 6
Box 404A
Whiteville, NC 28472
Phone: [phone]
1
D-9 David_R. Hudson
Webster Road
Route 3, Box 182
Sylva, NC 28779
Phone: [phone]
D-10 Victor Owen
Route 16, Box 22
( Hargrave Road)
Le:•:i ngton �:C 27�°
Courier '133
Courier ii104
Courier ;;1031
Courier it"422

D-11 Greg Williams
P. O. Box.907
Phone: [phone]
D-12 Howard C. Williams
Highway 273
Route 1, Box 72-A
M-, . Holly, NC 28120'
Phone: [phone]
D-13 Dan Smith
County Road. 1305, One Blk.
P.O. Box 127
Fairfield, NC 27826
Phone: [phone]
%I

rZ
State of Noah Carolina
Department of Natural Resources and Community Development
Division of Soil and Water Conservation
512 North Salisbury Street - Raleigh, North Carolina 27611
James G. Martin, Governor David W. Sides
William W. Cobey, Jr., Secretary October. 16, 1989 Director
TO: Mr. R. Paul Wilms, Director
Division of Env' en al Management
FROM: David W. Sides
• .1
SUBJECT: Enforcement of Turbidity Standards
When a question arises whether B_Ps are being utilized, the "following
Division Field Rep should be contacted.
FajPB--(�z-}, - -Mooresville Regional Office
L-1 n lL��t Y � rteOK
Counties: Buncombe
Cherokee
Clay
Graham
Haywood
Henderson
Jackson
Macon
Madison
McDowell
Mitchell
Polk
Rutherford
Swain
Transylvania
Yancey
Cabarrus
Cleveland
Davidson
Davie
Gaston
Iredell
Lincoln
Mecklenburg
Rowan
Stanly
Union
OCT
P.O. Pox ?7687, Raleigh, ;Norh CarOlir= 17611-7687 T:!rphor.e 919-733.1302
[dual Op;��-ti:: ;: �• .-.. �uvC Action t. .,;igvC:

I
yr. Paul Wilms
Page 2
October 16, 1989
Gerald Dorsett - `rriins ton -Salem Pegonal Office
Counties: Alexander
Alamance
Alleghany
Caswell
Avery
Chatham
Burke
Guilford
Caldwell
Lee
Catawba
Montgomery
Forsyth
Moore
Ashe
Orange
Stokes
Person
Surry
Randolph
Watauga
Rockingham
Wilkes
Yadkin
Steve Bennett - Raleigh Regional Office (Effective 12-1-89)
Counties: Durham
Bladen
Edgecombe
Anson
Halifax
Columbus
Franklin
Cumberland
Granville
Harnett
Johnston
Hoke
Nash
Richmond
Vance
Robeson
Wake
Sampson
Warren
Pat Hooper - Washington Regional Office
Counties: Camden
Hartford
Chowan
Martin
Currituck
Northampton.
Pasquotank
Hyde
Perquimans
Tyrrell
Beaufort
Washington
Bertie
Pitt
Dare
Gates

A
Mr. Paul Wilms
Page 3
October 16, 1989
Tom Jones -
Counties
Wilmington Regional Office
Pamlico
Brunswick
Carteret
Craven
Dup1in
Greene
Jones
Lenoir
New Hanover
Onsio,.•;
Pender
Wayne
DWS:mw
cc: Ed Church, Jr. w/attachment
Jerry Dorsett "
Steve Bennett "
Pat Hooper "
Tom Jones
Carroll Pierce "
Jim Cummings
Charles Bullock "

NEW RIVER
FISHING CREEK
DISTRICT 2
DISTRICT
SURRY
SIDKI$
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Areas of North Carolina Association of NRCD
Office
Area
Field Rep
Phone
Soil and Water Conservation Districts I,R0
1, 8
f e me.4,
r, t
(704)
663-1699
WSRO
2, 3
Gerald Dorsett
(919)
761-2351
RRO
4, 7
Steve Bennett
(919)
733-2303
WaRO
5
Pat Hooper
(919)
946-6481
141iRO
6
Tom Jones
(919)
256-4161