20051071 Ver 2_More Info Received_20070507

4 i 7-A BROAD ST.
P.O. BOX 3496
NEW BERN, NORTH CAROLINA 28564-3496
Certified Mail Receipt No
ROBERT M. CHILES, P.E.
ENGINEERS, CONSULTANTS
MARINE SUP.VEYORS
May 7, 2007
7006 2460 0003 3520 3352

BUSINESS :252-637-4702
FAX: [phone]
officesrobertmchilespe.com
mikerice~aroberfmchilespe.com
Mr. Kyle Barnes
NC DENR; Division of Water Quality
943 ~Nashington Square Mall
Washington, N. C. 27889
Enclosures: (1) Copy, NCDENR DWQ letter dated April 2, 2007, On-site determination for UT to
Deep Branch of Bachelor Creek, DWQ Project WaR0-07-0025.
(2) Courtesy Copy of Robert M. Chiles, PE letter to Mr. Stephan Rynas regarding DCM
20070029, dated May 3, 2007.
Dear Mr. Barnes:
On behalf of our client B/S/H/ Home Appliances Corp. we acknowledge our receipt of your letter
of February 26, 2007 requesting additional information about a DWQ subjectivity determination for the
unnamed tributary adjacent to the project site.
As we discussed with you via telephone, and by your suggestion, we made arrangements to meet
on-site with Mr. Chris Pullinger, Environmental Specialist II, of DWQ, Washington Regional Office. During
our March 13 meeting, Mr. Pullinger conducted ah on-site determination to review the drainage feature
that is adjacent to the northeast corner of the B/S/N/ Logistics Center project site. A copy of Mr.
Pullinaer's determination is provided as enclosure T.
Enclosure 2 is a courtesy copy of our letter to Mr. Stephan Rynas of the Division of Coastal
Management. This courtesy copy is being provided because you were indicated as one of the persons
to whom Mr. Rynas copied his letter which advised us that DCM Stdff determined that our consistency
certification was incomplete.
Should you require additional information or have any questions, please contact us your
convenience.
_Very truly yours,
~Rb,BERT M. CHIL P.E.
'~. "~
~~
Michael L. Rice, P.E.
Cc Ian McMillan, DWQ Oversight/Express Permitting Unit
DWQ Central Office
2321 Crabtree Blvd.
Raleigh, NC 27604
D~. T F Q S- 16'1 t
co, c~:_ i ~sTe~~. ~ ~~~. ~ ~ ~~ ~P .. Acre ~ -~ _ .

417-A BROAD ST.
P.O. BOX 3496
NEW BERN, NORTH CAROLINA 28564-3496
Certified Mail Receipt No
ROBERT M. CHILES, P.E.
ENGINEERS, CONSULTANTS
8
MARINE SURVEYORS
May 3, 2007
7006 2460 0003 3520 3437
Mr. Stephan Rynas, AICP
Federal Consistency Coordinator
NCDENR, DCM
400 Commerce Ave
Morehead City, NC 28557
R.e: DCM # 20070029

BUSINESS :252-637-4702
FAX: [phone]
office,'s?roberimchilespe.com
mikerice~~robertmchilespe.com
Enclosures: (1) 1 original 8~ 21 electronic copies, NCDENR, DCM Consistency Certification for the
B/S/H/ Home Appliances Logistics Center, 300 Executive Parkway, Craven County
Industrial Park, developed by B/S/H/ Home Appliances Corporation 120 Bosch
Blvd., New Bern, NC, prepared by Robert M. Chiles, PE, REVISED May 3, 2007.
Dear Mr. Rynas:
On behalf of our client B/S/H/ Home Appliances Corp, we acknowledge our receipt of your letter
of March 26, 2007 advising that DCM staff has determined that our consistency certification submission
was incomplete. We have revisited :the regulations that are referenced in your letter, reviewed our
previously submitted consistency certification in light of these regulations, and present the following
response for your review.
• Our submission complied with the requirements cf 15 CFR 930.58.
• A brief analysis of 15A NCAC 07M was provided in our submission. The mitigation policy
described in section .0700 is not applicable to the project.
• The statements about the issued 401 water quality certification (05-1071) were provided for
information only.
• The project is not located in an area of environmental concern.
• The project is located in the coastal area, but is not located in the coastal zone.
• The project does not create a coastal effect as defined in 15 CFR 9301 1(g).
The following discussions are presented in corresponding order and in support of the above
statements:
Your letter indicates that "our submission is incomplete for the purposes of consistency review
since it does not meet the requirements of 15 CFP, 930.58." !t specifies that the "submission package did
not meet the requirements of Section 15 CFR 930.58 in that the analysis required by 15 NCAC 07M .0700
was not provided." With a reference to Section .0700 your letter indicates a requirement "that adverse
impacts to coastal lands and waters be mitigated or minimized through proper planning and site
selection" and that adverse impacts to coastal resources must be "mitigated/restored to the extent
feasible." Your letter advises that section .0703 "requires that there be no reasonable or prudent
alternative design or location for the project that would avoid the losses to be mitigated." An example is
provided in your letter for avoiding the proposed wetland impacts altogether. Your letter requests that
we provide an analysis exploring various project alternatives to avoid the impacts and requests that we
address minimization and mitigation for unavoidable impacts. You further request an analysis of why the
adverse unavoidable wetland impacts could not be mitigated on-site considering the size of the parcel
even though the Ecosystem Enhancement Project has agreed to accept an in-lieu payment for the
proposed impacts.
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Rynas 2 of 6 RMC Job ff 2005036
The requirements of 15 CFR 930.58(a)(3) indicate that the applicant shall furnish "an evaluation
that includes a set of findings relating the coastal effects of the proposal and its associated facilities to
the relevant enforceable policies of the [State's] management program" and that "applicants shall
demonstrate that the activity will be consistent with the enforceable policies of the [State's]
management program." By the definitions contained in 1 S CFR 930.1 1(h) and 16 USC 1453(ba), "the term
"enforceable policy" means State policies ... by which a State exerts control over private and public
land and water uses and natural resources in the coastai zone." Page S of our previous submission
includes a statement that "there [are] no reasonably foreseeable effects on any coastal use or resource
resulting from the proposed project." This statement is a quote of the definition of "coastal effect," and
was intended to indicate that the project does not create a coastal effect. The statement follows an
implication that the project site is not in the coastal zone and a statement that "there are no coastal uses
or resources present." Based upon the codified definitions, there are no "enforceable policies" as they
relate to the proposed project because the project is not in the coastal zone. Furthermore, there is no
process by which we could include a set of findings relating the coastal effects to any such relevant
enforceable policies because the project creates no coastal effects according to the definition.
Our previous submission briefly addressed 15A NCAC 07M as it relates to the project and
concluded that the project was consistent with chapter 07M as the project did not efr'ect any of the
areas described in the chapter. In response to your letter's indicated requirements and the requests for
analyses which reference section .0700, we provide. the following expanded discussion of 15A NCAC
07M.0700 as it relates to the proposed. project,
Your letter's paraphrase of the requirements based upon section 15A NCAC 07M.0701 is
incomplete. In whole, section .0701- reads:
(a) It is the policy of North Carolina to require that adverse impacts to coastal lands and waters be
mitigated or minimized through proper planning, site seiectidn, compliance with standards for
development, cnd creation or restoration of cocsta! resources. Coastal ecosystems shall be
protected and maintained as complete and functicnal systems by mitigating the adverse impacts
of development as much as feasible by enhancing, creating, or restoring areas with fhe goal of
improving or maintaining ecosystem function and creal proportion.
(b) The CRC shall apply mitigation requirements as defined in this Section consistent with the goals,
policies and objectives set forth in the Coastal Area Management Act far coastal resource
management and development. Mitigation shall be used to enhance coastal resources and offset
any potential losses occurring from approved and unauthorized development. Proposals to mitigate
losses of coastal resources shall be considered only for those projects shown to be in the public
interest, as defined by the standards in 15A NCAC 7M.0703, and only after all other reasonable
means of avoiding or minimizing such losses have been exhausted.
As with all of 15A NCAC 07M, reference is made by this section to various portions of NCGS 1 i3A
as being the rule's source of authority. All of These statutory references are contained in The Coastal Area
Management Act which begins at NCGS 1 13A-100.
The term "development" is used in four different places in sub-section .0701. Given the references
to NCGS 1 13A and the Coastal Area Management Act, and since a definition is not provided in section
.0700, it can only be assumed that the definition for "development" contained in the Coastal Area
Management Act at NCGS 1 13A-103(5)(a} applies to this section of the administrative code. By that
definition, ""development" means any activity in a duly designated area of environmental concern..."
The numerous references to "coastal resources" and fhe "coastal ecosystem" in section .0701 appear to
support the assumption that this definition is appropriate. As indicated in the "areas of environmental
concern" section our previously submitted consistency certification, beginning on page 6, the proposed
project is not located in an area of environmental concern. Based solely upon this interpretation, the
requirements of Section .0700 are not applicable to the project.
M~~.HANIClJ_ CIVIL, AND M.ARINF tiJGIfJEf'RIfJG
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Rynas 3 of 6
RMC Job # 2005036
As a further evidence to support our interpretation that the mitigation policy of Section .0700 does
not apply, we offer the following additional analysis.
Definitions for the terms "coastal lands and waters" and "coastal resources" as used in .0701 are
not specified, so we looked to the context of the Section .0700 for clarification of these terms. Sub-
section .0703(a) enumerates all of the criteria that a development project must demonstrate in order for
the CRC to approve it for mitigation candidacy. There are four specific criteria itemized in this section.
Your letter quoted the criteria contained in item (1) which states that "there [be] no reasonable or
prudent alternative design or location for the project that would avoid the losses to be mitigated." If this
was the only criteria indicated in the section, and the implications associated with the definition for
"development" are neglected, then Section .0700 could be interpreted as being applicable to this
project; the project does create losses that will require mitigation, so an analysis of alternative designs or
locations would be warranted. However, the language of the introductory statement in .0703(a), "...all
of the following criteria can be met..." implies that it is not a matter of any one of the criteria being
individually applicable to a project, but all of 'the criteria. Continuing to item (2) discloses the
requirement "that the entire project for which the permit is requested is dependant upon being located
within or in close proximity to public trust waters and coastal wetlands." The inclusion of the terms "public
trust waters" and "coastal wetlands" in item (2) appear to be direct references to the defined "public
trust areas" and "coastal wetlands" areas of environmental concern, and as such, provides additional
support for our earlier conclusion that the term "development" carries the definition provided by NCGS
1 13A-103(5)(a). Furthermore, the generaf`ia~nguage of item (2) implies thdt the terms "coastal lands and
waters," and "coastal resources" as used in section .0700 are intended to be consistent with the 15 CFR
930.1 1 and 16USC 1453 definitions for "coastal use or resource," "coastal waters," and "coastal zone"
and/or be defined to relate specifically to the areas of environmental concern alluded to in this item.
Item (2) is not applicable as this project is not within or in close proximity to public trust waters and coastal
wetlands. Item (3) requires that "benefits to the public interest clearly outweigh the long range adverse
effects to the environment" and item (3) (B) requires thafi in the case of privately funded projects, that the
project "provides increased access opportunities available to the general public... or provides
significant economic benefits to the state or community in accord v~~ith the local land use plan." Public
access is enumerated among the examples within the 15 CFR 930.; 1 definition of "coastal uses." The use
of this term in .0703 appears to be an indirect reference to 1 ~A NCAC 07M.0300, the Shorefront Access
Policy. We indicate in the "areas of environmental concern" section of our previously submitted
consistency certification, beginning on page 6, that there are no public rights of access associated with
the project site or the adjacent unnamed tributary. Our previous submission also indicates on page 7, our
determination that there are no public trust areas present, and without this AEC present, there is no
shorefront present to provide public access to. In light of these determinations, item (3) is not applicable
to the project. Item (4J expands upon item (1) and requires that the design incorporate all reasonable
means and measures to lessen the impacts of the project. Taken out of context, items (1) and (4) could
apply to this project. However, items (2) and (3) have no application to this project. Based upon this
review, there is no impetus for submitting the project for mitigation n candidacy per section .0703. By
extension, the mitigation policy of Section .0700 is not applicable to the project.
This project's location in Craven County (a coastal county) and our submission of an application
to the US Army Corps of Engineers (USAGE) for an Individual Permit (IP) related to this project have
initiated this consistency certification process. For this project, as for any project that proposes wetland
impacts, analyses of the avoidance and minimization of the proposed impacts have been provided in
the permit application package submitted to the USAGE. Additionally, duplicate copies of the
application package were provided to the NCDENR Division of Water Quality (DWQ) for their review and
approval as it relates to a corresponding 401 Water Quality Certification (WQC). It is our understanding
that the USAGE and DWQ are the lead permitting agencies in this application scenario. It is also our
understanding (and experience) that if the proposed method of providing mitigation is inappropriate or
as you suggest, undesirable, then these agencies will not hesitate to recommend appropriate mitigation
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Rynas 4 of 6
RMC Job # 2005036
alternatives. Our understanding of the responsibility of your agency as it relates to this project is to
determine if it is consistent with the State's Coastal Management Program.
The second page of your letter begins with a paragraph wherein you explain that the WQC issued
under DWQ Project Number 05-1071 may be used in conjunction with USACE Nationwide Permit No. 39
(NW39). You explain that the proposed action wil! not involve the issuance of a NW39, and conclude
that the WQC may not be valid. To quote the "Existing Facilities" section of our previously submitted
consistency certification, beginning at the bottom of page 3, "Portions of the two larger areas totaling
0.45 acres were previously impacted as part of the first construction phase. Those impacts were issued
Nationwide Permit Number 39 bearing USACE Action Id 20051 1 1 29, and NCDENR 401 approval bearing
DWQ Project #05-1071." These sentences were included in the existing facilities section for your
information only. They are statements of fact concerning the previous issuance of a nationwide permit
and the corresponding water quality certification for an earlier phase of this project. We are fully aware
that the 401 approval was issued solely for the issued NW39, and do not see where we imply that it
applies to the requested IP. In the "Previously Issued Permits" section of our submission on page 9, we
state that the "certification corresponds to the Corps NW39 issued for wetland impacts associated with
phase one construction at the project site." Having reviewed our previously consistency submission it is
apparent, however, That we did not include the fact that we have copied our IP application package to
DWQ for their review. If this contributed to a misunderstanding by your staff, we apologize.
The last portion of your letter challenges our assertion that the proposed project has no coastal
effects. Your letter indicates that "it is a mistaken conclusion that typically results by the fact that the
proposed project is not within an Area of Environmental Concerns." We understand that the absence or
presence of an AEC is not the criteria for determining if a coastal effect occurs. The criteria for that
determination is the definition of "effect oh any coastal use or resource (coastal effect)" found in 15 CFR
930.1 1(g). We can only assume thatyou misinterpreted our analysis of the areas of environmental
concern relative to the project site as being intended to offer supporting information for our
determination that the project does not create a cadstcal effect. This' is not correct. We included the
analysis for two reasons -first, because the sample consistency certification submission provided on the
DCM Federal Consistency website contains a similar analysis; and second, because if the project is
located within any AEC, the consistency process is not applicable and a CAMA permit application
becomes necessary instead. Therefore, the primarypurpose for including the AEC analysis was to confirm
the absence of any AEC and confirm that consistency review is the appropriate process, as opposed to
submission of an application for a CRC permit.
Your letter continues as follows:
Section 1 13A-103 of CAMA defines the "coastal area" (the State's coastal zone) as comprising all
counties that in whole or part are adjacent to, adjoining, intersected by or bound by the Atlantic
Ocean. Craven County is a coastal county and the effect of any proposed project or. the
resources or the uses of those resources in Craven County constitute a "coastal effect" within the
meaning of 15 CFR 930.1 1 (b) and 15 CFR 930.1 1 (g). Coastal resources are those biological and
physical resources located anywhere within the State's coastal zone(coastal area).
North Carolina General Statute (NCGS)113A-103(2) indicates that the term ""coastal area" means
the counties that (in whole or in part) are adjacent to, adjoining, intersected by or bounded by the
Atlantic Ocean ... or any coastal sound." The term "coastal sound" is specifically defined in GS 1 13 A-
103(3). Guided by these terms, the list of "coastal counties" as contained in 15A NCAC 02H.1002(4} was
generated. Craven County is a "coastal county," and by definition, part of the State's "coastal area."
16 USC 1453(1) states that "the term "coastal zone" means the coastal waters (including the lands
therein and thereunder) and the adjacent shorelands (including the waters therein and thereunder),
strongly influenced by each other and in proximity to the shorelines of the several coastal states." It
further states that "the zone extends inland from the shoreline only to the extent necessary to control
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Rynas 5 of b
RMC Job ~ 2005036
shorelands, the uses of which have a direct and significant impact on the coastal waters, and to control
those geographical areas which are likely to be affected by or vulnerable to sea level rise."
We disagree with your parenthetical addition to the definition of "coastal area" which implies
that the coastal area and coastal zone are one and the same. Without question, North Carolina's
portion of the Nation's coastal zone is entirely contained within the State's defined coastal area.
However, given the actual parenthetical inclusion "(in whole or in part)" in the definition of coastal area
as contained in NCGS 1 13A-103(2), the implication is that there are parts of certain counties comprising
the coastal area that are not "adjacent to, adjoining, intersected by or bounded by the Atlantic Ocean
or any coastal sound." To reiterate, "the term "coastal zone" means the coastal waters... and the
adjacent shorelands..., strongly influenced by each other and in proximity to the shorelines of the several
coastal states." If a part of a coastal county is not "adjacent to, adjoining, intersected by or bounded by
the Atlantic Ocean or any coastal sound," it cannot be a coastal water or an adjacent shoreland
strongly influenced by each other or in proximity to the shorelines. Therefore, if the coastal area is
comprised of the coastal counties, and it is possible that a part of a coastal county is not part of the
Nation's coastal zone as indicated above, then it is possible that there are parts of the State's coastal
area that are not located within the coastal zone. The coastal area and coasta! zone are not one and
the same.
The definition of "coastal zone" relies heavily on the presence of "coastal waters", and as
mentioned earlier, 16 USC.1453, more specifically .:i 453(3), defines "coastal waters." In that definition, the
water's primary characteristic is a measurable quantity or percentage of sea water. Similarly, "coastal
sound" as defined in NCGS 1 13 A-103(3) identifies the inland limits of a sound on a tributary river as the
"limits of seawater encrocchment on said river under normal conditions." Therefore, the waters
delineated by our State's "coastal sound" definition are our State's "coastal waters."
As described on page 5 of our previously submitted consistency certification, the project site is
located within a property partially adjoined on the horfheast by an'unnamed tributary to Deep Branch, a
tributary of Bachelor Creek and the Neuse River. According to NCGS 1 13A-103(3) (d), the inland limit of
coastal waters along the Neuse River is located at the Neuse's confluence with Swift Creek, which is
approximately 3.6 miles upstream of the Neuse's confluence with Bachelor Creek. According to 1 SA
NCAC 2B.0315, Bachelor Creek and Deep Branch are classified C Sw NSW, and according to 15A NCAC
2B.0301(i) (1) the same classification is carried by the uhnamed tributary of Deep Branch. As indicated in
15A NCAC 28.021 1, Class C is a fresh water classification, making the Neuse River, at its confluence with
Bachelor Creek, the coastal water nearest to the project site. Measured in a straight line, the project site
is approximately 4.7 miles from the confluence of the Neuse River with Bachelor Creek. Measured along
the runs of the unnamed tributary to Deep Branch that is adjacent to the project site, Deep Branch, and
Bachelor Creek, the project site is approximately 15 miles from the confluence of the Neuse River with
Bachelor Creek. There are no coastal waters at or in close proximity to the project site. This is implied by
the statements on page 5 of our previous consistency submission, which read in part "the tributary does
not meet the definition of a coastal water," and "in the absence of coastal waters..." While we
concede the fact that the project site is in Craven County, and by definition, in the State's coastal area,
we maintain our assertion that the project site is not in the coastal zone.
We also disagree with the assertion than an effect of any proposed project on any resources or
any of their uses within Craven County constitutes a coastal effect. 15 CFR 930.1 1 (b) and (g) and terms
used therein that are defined in 16 USC 1453(1), (10), and (18) quite specifically define what constitutes a
coastal effect. Based upon the definition of 930.1 1 (b), "the phrase "any coastal use or resource" means
any land or water use or natural resource of the coastal zone" (emphasis added). We have addressed
our understanding that there are portions of the coastal area that are not within the coastal zone. We
understand that the project site is not in the coastal zone. Expanding upon that understanding, there are
resources within the coastal area (in this case, the wetlands at the project site) that are not within the
coastal zone. Accordingly, an impact to any resource so located does not constitute a coastal effect by
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Rynas 6 of 6
RMC Job # 2005036
definition. Our previously submitted consistency certification contains a detailed review of these
regulations and while it was not stated strongly, it did conclude that the proposed activity creates no
coastal effects as defined.
Based upon our review of the regulations that are referenced in your letter, and our review of our
previously submitted consistency certification, we respectfully disagree with the determination that our
submission was incomplete. However, in light of the DCM staff's comments and our subsequent review,
we recognize i-hat our certification is not as clear as it should be. Therefore, we have revised it to more
clearly state our position and to include portions of the additional information contained in this letter.
We maintain our position that the proposed activities described in our application to the USACE
for an IP do not create a coastal effect and that they comply with the enforceable policies of North
Carolina's approved management program and will be conducted in a manner consistent with such
program. We reiterate our requests that your office issue a concurrence with our consistency certification
and provide a courtesy copy of your concurrence to Ms. Tracey Wheeler of the US Army Corps of
Engineers, PO Box 1000, Washington NC 27889-1000.
Should you require additional information or have any questions, please contact us at your
convenience.
Very truly yours,
ROBERT M. CHILES, P.E.
~~~
'Michael L. Rice, P.E.
cc:
w/o enclosure
Mr. Doug Huggett, Manager, Major Permits, Division of Coastal Management
Ms. Tere Barrett, District Manager, Division of Coastal Management
Ms. Tracey Wheeler, US Army Corps of Engineers`
Mr. Kyle Barnes, Division of Water Quality
Ms. Maria Tripp, NC Wildlife Resources Commission
Ms. Beth Harmon, NC Ecosystem Enhancement Program
w/enclosure
Mr. Patrick Franke, Director Logistics, B/S/H/ Home Appliances Corporation
Mr. Richard Tucker, P.E., B/5/H/ Home Appliances Corporation
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