HomeMy WebLinkAbout20090136 Ver 2_401 Application_20100210KCI
ASSOCIATES OF NC
ENGINEERS • SCIENTISTS • SURVEYORS • CONSTRUCTION MANAGERS
Landmark Center 11, Suite 220 4601 Six Forks Road Raleigh, NC 27609 (919) 783-9214 (919) 783-9266 Fax
Date: February 19, 2010
Company:
NCDWQ
401 Oversight & Express
Permitting
2321 Crabtree Blvd.,
Suite 250
Raleigh, NC 27604
Contact: Amy Chapman
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FEB 1 90 2Ci0
CDs mo WATER OUALITy
Job Number 12082306A
Project: Dunn Creek Greenway
DWQ Project # 2009-0136 V a
Wake County
Subject: Modified PCN Notification
Number of Items
Description
5 j Modified PCN Notification with Revised Buffer Impacts
? In accordance with your request ? For your use/files
® For your review ? Please call when ready
® For processing ? Please return to this office
? Plans reviewed and accepted ® Approval requested
? Plans reviewed and accepted as noted ? Conference requested
? For revision by you at your convenience
Comments: Amy, Dave and I look forward to meeting with you to discuss the project
modifications. If you have any questions, please contact me at 919-278-2517 or by cell (919)
210-5481. Thanks, Steven
- V,4Ay
Steven F. Stokes, LSS
Senior Soil Scientist
cc: Susan Simpson
Files
KCI ASSOCIATES OF NORTH CAROLINA, P.A.
www.kci.com
Employee-Owned Since 1988
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Office Use Only:
Corps action ID no.
DWQ project no.
Form Version 1.3 Dec 10 2008
Pre-Construction Notification (PCN) Form
A. Applicant Information
1. Processing
1 a. Type(s) of approval sought from the
Corps: Buffers
El Section 404 Permit El Section 10 Permit
1 b. Specify Nationwide Permit (NWP) number: or General Permit (GP) number:
1c. Has the NWP or GP number been verified by the Corps? ? Yes ? No
1 d. Type(s) of approval sought from the DWQ (check all that apply):
? 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit
? 401 Water Quality Certification - Express X Riparian Buffer Authorization
1 e. Is this notification solely for the record
because written approval is not required? For the record only for DWQ 401
Certification:
X Yes ? No For the record only for Corps Permit:
X Yes ? No
1f. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation
of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu
fee program. ? Yes X No
1 g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h
below. ? Yes X No
1h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes X No
2. Project Information
2a. Name of project: Dunn Creek Greenway
2b. County: Wake
2c. Nearest municipality / town: Wake Forest LC5 V V/ L9
2d. Subdivision name: Heritage
2e. NCDOT only, T.I.P. or state
project no:
DENR- 4
3. Owner Information "MILANDS" AND STORMWATER BRANCH
3a. Name(s) on Recorded Deed: Town of Wake Forest
3b. Deed Book and Page No. DB 10537, Page 709
3c. Responsible Party (for LLC if
applicable): Susan Simpson
3d. Street address: 401 Elm Avenue
3e. City, state, zip: Wake Forest, NC 27587
3f. Telephone no.: (919) 554-6182
3g. Fax no.: (919) 556-2063
3h. Email address: ssimpson@wakeforestnc.gov
Page 1 of 11
PCN Form - Version 1.3 December 10, 2008 Version
4. Applicant Information (if different from owner)
4a. Applicant is: ? Agent ? Other, specify:
4b. Name:
4c. Business name
(if applicable):
4d. Street address:
4e. City, state, zip:
4f. Telephone no.:
4g. Fax no.:
4h. Email address:
5. Agent/Consultant Information (if applicable)
5a. Name: Steven F. Stokes
5b. Business name
(if applicable): KCI Associates of North Carolina, P.A.
5c. Street address: Landmark Center II, Suite 220, 4601 Six Forks Road
5d. City, state, zip: Raleigh, NC 27609
5e. Telephone no.: (919) 278-2517
5f. Fax no.: (919) 783-9266
5g. Email address: sstokes@kci.com
Page 2 of 11
B. Project Information and Prior Project History
1. Property Identification
1840-64-7176, 1840-63-7946, 1840-72-1919,1840-62-
1a. Property identification no. (tax PIN or parcel ID): 8697, 1840-44-8440, 1840-76-1672, 1840-75-2348,
1840-75-7997
1 b. Site coordinates (in decimal degrees): Latitude: 35.956194 Longitude: -78.503056
(DD.DDDDDD) (-DD.DDDDDD)
1 c. Property size: 5.0 acres = 30' x 7348'
2. Surface Waters
2a. Name of nearest body of water (stream, river, etc.) to Smith Creek
proposed project:
2b. Water Quality Classification of nearest receiving water: C:NSW, Smith Creek
2c. River basin: Neuse
3. Project Description
3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this
application:
Greenway will generally follow existing 30' sewer easement in 100-yr floodplain (Managed herbaceous cover & forested
Land-Bottomland). Downstream section of site is heavily developed and the upstream is being developed (as observed
by recent infrastructure installation).
3b. List the total estimated acreage of all existing wetlands on the property:
KCI delineated 0.37 acres of jurisdictional wetlands within the project corridor.
3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property:
6858.95 Linear Feet
3d. Explain the purpose of the proposed project:
The Dunn Creek Greenway is a part of the Town of Wake Forest Open Space & Greenway Plan (adopted 2002) and a
planned connector to the Mountains-to-Sea Trail-a spur to the East Coast Greenway. It begins where the Smith Creek
Greenway ends at the Soccer Fields and runs north approx. 1 mi. to the NC 98 Byp. and existing pedestrian culvert. The
paved 10-ft wide greenway will have 2' wide gravel shoulders for asphalt protection. The high capacity 10' wide greenway
will provide for multipurpose use (i.e., pedestrians, bicyclists, in-line skaters, wheelchairs, etc.) and two-way directional
traffic, per AASHTO standards. In addition, the maintenance of greenways affects the desired width of the paved surface
as well as the width of its bridges. A 10' wide trail and bridges allows for maintenance and emergency vehicles to enter
the facilities without destroying the edges of the pavement. Emergency vehicles are 9' wide and need 10' trails and
bridges with 2' shoulder for safe passage. The design is also intended to be consistent with all other greenways within
Wake County.
3e. Describe the overall project in detail, including the type of equipment to be used:
The Dunn Creek Greenway will tie into the Smith Creek Greenway at the soccer fields on the east side of Dunn Creek. An
existing 30' sewer easement and greenway easement has been dedicated for the greenway by the Town, NCEEP and
private landowners. Based on field investigation we shifted the greenway away from both Dunn Creek and Spring Branch,
which required contacting private landowners and asking for more land to avoid the Neuse buffers as much as possible.
Four bridge crossings are needed along the route. The bridges will span the creek and the bridge abutments will not
impact §404 or 401 streams. The wetlands were delineated and will be avoided. In many areas the greenway will change
to a boardwalk to allow for diffuse flow. The paved surfaces will be designed at grade to allow diffuse flow. Construction
will occur within a dedicated 30' easement. Track trucks and D6 bulldozers will be used for grading to minimize the
footprint. Cranes will be used to position the pre-fabricated 40' to 70' bridges on the abutments.
Page 3 of 11
PCN Form - Version 1.3 December 10, 2008 Version
Project Information and Prior Project History
4. Jurisdictional Determinations
4a. Have jurisdictional wetland or stream determinations by the
Corps or State been requested or obtained for this property / X Yes ? No ? Unknown
project (including all prior phases) in the past?
Comments: Requested COE concurrence
4b. If the Corps made the jurisdictional determination, what type
? Preliminary ? Final
of determination was made?
4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: KCI Associates of NC
Name (if known): Steven F. Stokes, LSS Other:
4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation.
5. Project History
5a. Have permits or certifications been requested or obtained for X Yes ? No ? Unknown
this project (including all prior phases) in the past?
5b. If yes, explain in detail according to "help file" instructions.
The impervious surface impacts were previously permitted on May 26, 2009. However the fill associated with the
impervious surface at each approach to each of the four bridges was not. This modified permit is requesting additional
buffer impacts to zone 1 of 4827.62 sq ft and zone 2 of 9137.96 sq ft.
6. Future Project Plans
6a. Is this a phased project? ? Yes X No
6b. If yes, explain.
This greenway connects to Smith Creek Greenway downstream and the pedestrian culvert upstream under NC 98
Bypass. This greenway trail is expected to continue north of NC 98 Bypass and eventually connect with the Town Center.
Page 4 of 11
C. Proposed Impacts Inventory
1. Impacts Summary
1 a. Which sections were completed below for your project (check all that apply):
? Wetlands ? Streams - tributaries X Buffers
? Open Waters ? Pond Construction
2. Wetland Impacts
If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted.
2a. 2b. 2c. 2d. 2e. 2f.
Wetland impact Type of jurisdiction
number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact
Permanent (P) or (if known) DWQ - non-404, other) (acres)
Temporary T
W1 ? P ? T ? Yes ? Corps
? No ? DWQ
W2 ? P ? T ? Yes ? Corps
? No ? DWQ
W3 ? P ? T ? Yes ? Corps
? No ? DWQ
W4 ? P ? T ? Yes ? Corps
? No ? DWQ
W5 ? P ? T ? Yes ? Corps
? No ? DWQ
W6 ? P ? T ? Yes ? Corps
? No ? DWQ
2g. Total wetland impacts
2h. Comments: No impacts
3. Stream Impacts
If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this
question for all stream sites impacted.
3a. 3b. 3c. 3d. 3e. 3f. 3g.
Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact
number - (PER) or (Corps - 404, 10 stream length
Permanent (P) or intermittent DWQ - non-404, width (linear
Temporary (T) (INT)? other) (feet) feet)
S1 ? P ? T ? PER ? Corps
? INT ? DWQ
S2 ? P ? T ? PER ? Corps
? INT ? DWQ
S3 ? P ? T ? PER ? Corps
? INT ? DWQ
S4 ? P ? T ? PER ? Corps
? INT ? DWQ
S5 ? P ? T ? PER ? Corps
? INT ? DWQ
S6 ? P ? T ? PER ? Corps
? INT ? DWQ
3h. Total stream and tributary impacts
3i. Comments: No temporary or permanent impacts from installing the bridges.
Page 5 of 11
PCN Form -Version 1.3 December 10, 2008 Version
4. Open Water Impacts
If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of
the U.S. then individual) list all open water impacts below.
4a. 4b. 4c. 4d. 4e.
Open water Name of waterbody
impact number - (if applicable) Type of impact Waterbody type Area of impact (acres)
Permanent (P) or
Temporary T
01 ?P?T
02 ?P?T
03 ?P?T
04 ?P?T
4f. Total open water impacts
4g. Comments: No impacts
5. Pond or Lake Construction
If and or lake construction proposed, then complete the chart below.
5a. 5b. 5c. 5d. 5e.
Wetland Impacts (acres) Stream Impacts (feet) Upland
Pond ID Proposed use or purpose (acres)
number of pond
Flooded Filled Excavated Flooded Filled Excavated Flooded
P1
P2
5f. Total
5g. Comments: No impacts
5h. Is a dam high hazard permit required?
? Yes X No If yes, permit ID no:
5i. Expected pond surface area (acres):
5j. Size of pond watershed (acres):
5k. Method of construction:
6. Buffer Impacts (for DWQ)
If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts
below. If an impacts require mitigation, then you MUST fill out Section D of this form.
6a. XNeuse ? Tar-Pamlico
? Other:
Project is in which protected basin? ? Catawba ? Randleman
6b. 6c. 6d. 6e. 6f. 6g.
Buffer impact
number - Reason Buffer Zone 1 impact Zone 2 impact
Permanent (P) or for Stream name mitigation (square feet) (square feet)
Temporary T impact required.
131 ?P?T ?Yes
? No
B2 ?P?T ?Yes
? No
B3 ?P?T ?Yes
? No
6h. Total buffer impacts 9878.18 16029.17
6i. Comments: See attached page for riparian buffer impacts.
Page 6 of 11
6. Previously Approved Impervious Surface Buffer Impacts (for DWQ)
6b. Buffer impact # Reason Stream name Buffer Zone 1 Zone 2
Permanent (P) or for mitigation impact impact
Temporary (T) impact required square ft square ft
61 X(P) greenway UT-1 to Smith Creek No 782.67 413.51
B2 X(P) greenway UT-2 to Smith Creek No - 600.61
B3 X(P) greenway UT-3 to Smith Creek No - 632.43
B4 X(P) greenway UT-4 to Smith Creek No 41.85 1009.08
B5 X(P) greenway UT-5 to Smith Creek No 174.39 1937.00
B6 X(P) greenway UT-6 to Smith Creek No - 89.12
B7 X(P) greenway UT-7 to Smith Creek No - 253.32
B8 X(P) greenway UT-8 to Smith Creek No 955.12 580.50
B9 X(P) greenway UT-9 to Smith Creek No 874.00 -
B10 X(P) greenway UT-10 to Smith Creek No - 185.12
1311 X(P) greenway UT-11 to Smith Creek No 313.11 935.67
B12 X(P) greenway UT-12 to Smith Creek No 1656.10 254.85
6h. Total Buffer Impacts
4797.24 6891.21
X confirms the impact is permanent (P)
6. Modified Buffer Impacts (for DWQ)
6b. Buffer impact # Reason Stream name Buffer Zone 1 Zone 2
Permanent (P) or for mitigation impact impact
Temporary (T) impact required square ft square ft
B1 X(P) greenway UT-1 to Smith Creek No 1643.98 1676.70
B2 X(P) greenway UT-2 to Smith Creek No - 790.99
B3 X(P) greenway UT-3 to Smith Creek No - 885.40
B4 X(P) greenway UT-4 to Smith Creek No 90.75 1363.10
B5 X(P) greenway UT-5 to Smith Creek No 297.72 2411.59
B6 X(P) greenway UT-6 to Smith Creek No - 89.12
B7 X(P) greenway UT-7 to Smith Creek No - 428.49
B8 X(P) greenway UT-8 to Smith Creek No 2346.00 2867.81
B9 X(P) greenway UT-9 to Smith Creek No 1660.17 2963.70
B10 X(P) greenway UT-10 to Smith Creek No - 259.60
B11 X(P) greenway UT-11 to Smith Creek No 410.22 1133.01
B12 X(P) greenway UT-12 to Smith Creek No 3429.34 1159.66
6h. Total Buffer Impa cts 9878.18 16029.17
X confirms the impact is permanent (P)
Total Impervious Surface and Fill Impacts 9878.18 16029.17
Total Previous Impervious Surface Impacts 5050.56 6891.21
Difference 4827.62 9137.96
D. Impact Justification and Mitigation
1. Avoidance and Minimization
1a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project.
Dunn Creek Greenway was originally planned to follow a dedicated easement owned by the Town of Wake Forest. The
proposed greenway starts at the downstream section where it ties into the existing Smith Creek Greenway at the Soccer
Fields then heads north to its terminus at the pedestrian culvert under NC 98 Bypass. The greenway crosses Dunn Creek
three times and Spring Branch once as it generally follows the 30' sewer line/easement. The greenway was shifted
outside of the dedicated easement in places to avoid impacts to Zone 1 and minimize impacts to Zone 2. Wetlands were
completely avoided. In several areas boardwalks are being specified in order to prevent concentrated flow in areas along
the greenway. Additionally, the greenway will be installed at grade to avoid ponding of surface water.
1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques.
The greenway was moved away from the streams where possible to avoid sedimentation and erosion control issues
related to construction and bank full storm events. Pre-constructed bridges were specified to minimize stream impacts
during construction and bridge abutments were placed outside of the stream to avoid all impacts within the normal flow
path. The bridges were angled at crossings to be between 75 degrees 105 degrees and mature hardwood trees were
spared where possible.
2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State
2a. Does the project require Compensatory Mitigation for ? Yes X No
impacts to Waters of the U.S. or Waters of the State?
2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps
? Mitigation bank
2c. If yes, which mitigation option will be used for this
El Payment to in-lieu fee program
project?
? Permittee Responsible Mitigation
3. Complete if Using a Mitigation Bank
3a. Name of Mitigation Bank:
3b. Credits Purchased (attach receipt and letter) Type Quantity
3c. Comments:
4. Complete if Making a Payment to In-lieu Fee Program
4a. Approval letter from in-lieu fee program is attached. ? Yes
4b. Stream mitigation requested: linear feet
4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold
4d. Buffer mitigation requested (DWQ only): square feet
4e. Riparian wetland mitigation requested: acres
4f. Non-riparian wetland mitigation requested: acres
4g. Coastal (tidal) wetland mitigation requested: acres
4h. Comments:
5. Complete if Using a Permittee Responsible Mitigation Plan
Page 7 of 11
PCN Form - Version 1.3 December 10, 2008 Version
5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ
6a. Will the project result in an impact within a protected riparian buffer that requires
buffer mitigation? ? Yes X No
6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the
amount of mitigation required.
Zone 6c.
Reason for impact 6d.
Total impact
(square feet)
Multiplier 6e.
Required mitigation
(square feet)
Zone 1 3 (2 for Catawba)
Zone 2 1.5
6f. Total buffer mitigation required:
6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank,
permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund).
6h. Comments: Greenways are Allowable without mitigation per 15A NCAC 026. 0233 (6).
Page 8 of 11
E. Stormwater Management and Diffuse Flow Plan (required by DWQ)
1. Diffuse Flow Plan
1 a. Does the project include or is it adjacent to protected riparian buffers identified X Yes ? No
within one of the NC Riparian Buffer Protection Rules?
1 b. If yes, then is a diffuse flow plan included? If no, explain why.
Comments: We are setting the grade for the greenway in alignment with existing ? Yes X No
topography.
2. Stormwater Management Plan
2a. What is the overall percent imperviousness of this project? 3.4%
2b. Does this project require a Stormwater Management Plan? ? Yes X No
2c. If this project DOES NOT require a Stormwater Management Plan, explain why: The percent impervious surface is less
than 24%.
2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan:
? Certified Local Government
2e. Who will be responsible for the review of the Stormwater Management Plan? ? DWQ Stormwater Program
? DWQ 401 Unit
3. Certified Local Government Stormwater Review
3a. In which local government's jurisdiction is this project?
? Phase II
3b. Which of the following locally-implemented stormwater management programs ? NSW
? USMP
apply (check all that apply): ? Water Supply Watershed
? Other:
3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes ? No
attached?
4. DWQ Stormwater Program Review
? Coastal counties
E] HQW
4a. Which of the following state-implemented stormwater management programs apply ? ORW
(check all that apply):
? Session Law 2006-246
? Other:
4b. Has the approved Stormwater Management Plan with proof of approval been
attached? ? Yes X No
5. DWQ 401 Unit Stormwater Review
5a. Does the Stormwater Management Plan meet the appropriate requirements? ? Yes ? No
5b. Have all of the 401 Unit submittal requirements been met? ? Yes ? No
Page 9 of 11
PCN Form - Version 1.3 December 10, 2008 Version
F. Supplementary Information
1. Environmental Documentation (DWQ Requirement)
1 a. Does the project involve an expenditure of public (federal/state/local) funds or the ® Yes ? No
use of public (federal/state) land?
1 b. If you answered "yes" to the above, does the project require preparation of an
environmental document pursuant to the requirements of the National or State ? Yes ® No
(North Carolina) Environmental Policy Act (NEPA/SEPA)?
1c. If you answered "yes" to the above, has the document review been finalized by the
State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval
letter.) ? Yes ® No
Comments: Per Melba McGee since no wetlands or streams will be impacted the
project is below the minimum threshold.
2. Violations (DWQ Requirement)
2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated
Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ® No
or Riparian Buffer Rules (15A NCAC 2B .0200)?
2b. Is this an after-the-fact permit application? ? Yes ® No
2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s):
3. Cumulative Impacts (DWQ Requirement)
3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No
additional development, which could impact nearby downstream water quality?
3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the
most recent DWQ policy. If you answered "no," provide a short narrative description.
Upstream of NC 98 Bypass is moderately developed. Also, greenways are generally a nature-based amenity resulting
from residential development, not an instigator of development.
4. Sewage Disposal (DWQ Requirement)
4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from
the proposed project, or available capacity of the subject facility.
None generated
Page 10 of 11
PCN Form - Version 1.3 December 10, 2008 Version
5. Endangered Species and Designated Critical Habitat (Corps Requirement)
5a. Will this project occur in or near an area with federally protected species or ? Yes ® No
habitat?
5b. Have you checked with the USFWS concerning Endangered Species Act ® Yes ? No
impacts?
® Raleigh
5c. If yes, indicate the USFWS Field Office you have contacted.
? Asheville
5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical
Habitat?
Natural Heritage Program
6. Essential Fish Habitat (Corps Requirement)
6a. Will this project occur in or near an area designated as essential fish habitat? ? Yes ® No
6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat?
Ron Sechler, National Marine Fisheries Services said he knows the area and that there is no essential fish habitat
impaired by the project (2-9-09). Additionally, previous construction of sewer piping by City of Raleigh.
7. Historic or Prehistoric Cultural Resources (Corps Requirement)
7a. Will this project occur in or near an area that the state, federal or tribal
governments have designated as having historic or cultural preservation ? Yes ® No
status (e.g., National Historic Trust designation or properties significant in
North Carolina history and archaeology)?
7b. What data sources did you use to determine whether your site would impact historic or archeological resources?
Even though the greenway is not impacting wetlands a request was sent to NC Cultural and Historic Resources. Delores
Hall State Archeologist stated a survey was conducted along the sewer easement when the sewer was installed and
nothing was found. An email correspondence is attached. I have not heard from Historic Resources but there are no
structures in the floodplain nor in view of the greenway.
8. Flood Zone Designation (Corps Requirement)
8a. Will this project occur in a FEMA-designated 100-year floodplain? ® Yes ? No
8b. If yes, explain how project meets FEMA requirements: No change to water surface profile.
8c. What source(s) did you use to make the floodplain determination? Firm Map # 3720-1840-OOJ effective May 2, 2006
Steven F. Stokes 2-19-2010
Applicant/Agent's Printed Name Applicant/Agent's Signature Date
(Agent's signature is valid only if an authorization letter from the applicant
is provided.)
Page 11 of 11