20110896 Ver 1_More Info Received_20111031

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Belvedere Property Management LLC
Peter J Tally
Vice President
October 31 2011
Jennifer S Frye
Enforcement Project Manager
Wilmington Regulatory Field Office
U S Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403 1343
RE Action ID No SAW 2011 00624
Dear Ms Frye
This letter follows my letter of October 21, 2011, in which we mchcated our intent to
provide to you by November 1, 2011, plans for mitigation of unavoidable wetlands
impacts to wetlands in connection with the project by Orton Plantation Holdings, LLC
After numerous consultations with our experts and extensive internal evaluations of
alternatives to avoid and minimize wetland impacts, we believe we have formulated a
plan that utilizes in an ecologically beneficial way the on site environmental assets
presented by Orton Plantation and will result in greater wetlands functionality while
supporting our project purpose
We had hoped to meet with you and representatives of the other permitting agencies to
present our plan It was our understanding, based on statements by Ken Jolly at our
meeting on August 3, 2011, with representatives from the Corps of Engineers and the
Division of Water Quality that a preliminary meeting was recommended in advance of
the submittal of documents We concur with Mr Jolly that a preliminary informal
presentation is the most efficient way to proceed, so that we can get the benefit of and
respond to the continents and suggestions of the permitting agencies to ensure a thorough
and complete plan Informed by the feedback from the agencies, we would be in a better
position to assemble a refined final plan for further review by all interested agencies and
members of the public
It is unfortunate that your schedule does not permit your meeting with us at this time We
nevertheless expect to present our plan to the Division of Water Quality and the Division
of Coastal Management We would much prefer to have your participation, as your input
is critical to the project I hope that you might be able to adjust your schedule to
participate, or to timely engage in a separate discussion with our consultants In any
event we anticipate finalizing the plan following our evaluation of and response to
1251 Avenue of the Amencas 17i° Floor
New York NY 10020

comments by the permitting agencies Our plan will be presented by our consultants,
Steve Morrison and Christian Preziosi of Land Management Group and John Dorney of
Atkins
Let me reiterate our gratitude for your patience in this process Please feel free to contact
me if we can make some alternate arrangement to get the benefit of your comments on
our proposed mitigation plan, or you may contact our consultants directly, Steve
Morrison at Land Management Group (910 452 0001) or John Dorney at Atkins North
America Inc (919 431 5260) Of course, if your counsel wishes to discuss regulatory or
legal issues, please have him contact our legal counsel for this project Craig Bromby, at
919 899 3032
ince a yo s,
Peter Tal
Vice President
Orton Plantation Holdings, LLC
c Eric Klein
Craig Bromby
Steve Morrison
John Dorney
Doug Huggett
Ian McMillan
Ken Jolly
78308 000002 EMF US 37758772v1