20200579 Ver 1_Wilson letter seeking MBI review_20201214

City of Wilson
P. O. Box 10
NORTH C A R O L I N A Wilson, IN Carolina 27894-0010
Stonnwater/Engineering
December 14I 2020
Katie Merritt
Nutrient Offset & Buffer Banking Coordinator
401 & Buffer Permitting Unit, NC DEQ
512 N Salisbury Street, Raleigh, NC 27620
Subject: Whirligig Station Mitigation Banking Instrument
Dear Mrs. Merritt,
The City of Wilson is proud to be one of the first municipalities in North Carolina to pursue establishment of a
mitigation bank, as we consider ourselves a proactive community in working to improve the condition of our
state's water resources. Water quality is and has been a priority for our community over the years as
demonstrated through our financial investment in construction of several SCMs and SCM retrofits that exceed
regulatory requirements of the Neuse River Water Quality Rules and the City's approved Category 4b
Demonstration Plan for Hominy Creek. These proactive practices are supplementary to the enforcement of our
UDO, which requires all new development to meet EPA Stonnwater Phase II community rules in advance of
future designation. Additionally, we have funded several standalone regional SCMs that provide nutrient
reduction treatment of runoff in developed neighborhoods and commercial areas that preceded implementation
of state stormwater requirements.
Our most recent investment has been the hiring of McAdams to assist in the establishment of a mitigation bank
to generate nutrient credits from retrofit SCMs funded solely from our stormwater utility. The revenue from the
mitigation bank would provide continued funding for future water quality projects, while simultaneously
incentivizing economic development of our community in a responsible manner.
We understand that the development of a mitigation bank by a municipality does not have considerable
precedent and requires additional deliberation in bank instrument development. However, at the time of this
letter it has been more than 120 days since the submittal of our draft instrument language and all supporting
documents without any initial guidance or comments from the state or a deadline with which to expect this
information. This continued delay in review of submitted documents is hindering our ability to most effectively
serve our community in continued improvement of our water resources.
P. O. BOX IO * w'ILSON, NORTH CAROLINA 27894-0010 * TELEPHONE [phone]
OPERATIONS CENTER * 1800 HERRING AyENUE * TAX [phone]
EQUAL OPPORTUNITY/AFFIRMATIVEACT/ONEMPLOYER

We all recognize the complexities and delays COVID49 restrictions have caused. With that said, our
development community and planning for future projects is not yet negatively impacted. As such, we request to
receive an expected timeframe for the remaining review of submitted materials. We also request a reasonable
deadline be provided to the City and McAdams for delivery of initial review comments along with an agreed
upon timeline for review periods of all future submittals. It is our goal to work with the state in as expeditious a
manner as is considered responsible in the establishment of this mitigation bank.
Sincerely,
W.T. Bass IV, PE
Public Works Director
P. O. BOX 30 * wILSON, NORTH CAROLINA 27894-0010 * TELEPHONE [phone]
OPERATIONS CENTER * 1800 HERRING AVENUE * FAX [phone]
EQUAL OPPORTUNITY/AFF/RDIATIFEACTIONEMPLOYER