NC0043176_Request for waiver of moratoruim_20210322

�►��— north Carolina WilliamP.Elmore Jr.LW. UNN Mayor
Mayor Pro Tem
Dr.David L.Bradham
Council Members
J.Wesley Sills
city o f dunn n n April L.Gaulden
Frank McLean
POST OFFICE BOX 1065 • DUNN,NORTH CAROLINA 28335 Chy Tart
Chuck Tumage
[phone] • FAX[phone]
City Manager
www.dunn-nc.org Steven Neuschafer
March 15, 2021
SENT VIA CERTIFIED MAIL RECEIVED
RETURN RECEIPT REQUESTED MAR 2 2 2021
7019 2970 0001 5819 6199
Dionne Delli-Gatti,Secretary NCDEQ/DWR/NPDES
North Carolina Department of Environmental Quality
N.C. DEQ Administration
1601 Mail Service Center
Raleigh, N.C. 27699-1601
Dear Secretary Delli-Gatti:
On March 5, the City of Dunn received a letter from the NC Department of Environmental Quality
(NCDEQ), stating that the City was going to be placed under a moratorium, prohibiting the
introduction of any additional waste into the City's Wastewater Treatment plant (WWTP). As a
condition of the letter, the City is required to publish a notice of the moratorium in the local
newspaper.
On Friday, March 12, the City was granted a virtual meeting with Mr. Michael Montebello,
Supervisor, Municipal Permitting Unit, Division of Water Resources to discuss the contents of the
letter. Mr. Montebello noted that his office would consider a Special Order by Consent (SOC) if the
City were to apply for one.
Over the past year, the COVID pandemic has placed a true hardship on our rural residents and
businesses. The timing of this moratorium could not be worse, especially delivered without any
warning. The City's interactions with NCDEQ's Fayetteville Regional Office have always been very
positive and the field inspectors have been complementary of how we have continued to work
with our aging infrastructure,while acknowledging our ongoing efforts to improve the conditions.
As of this time, the City has not been given the opportunity to craft a true response to the letter or
have any meaningful dialogue with the NCDEQ. With that in in mind, the following is the City's
perspective:
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Secretary Delli-Gatti,Page 2
The City of Dunn is fully aware that our WWTP experiences sanitary sewer overflows and we work
diligently to minimize each event:
• Invested over $14M in the Dunn sewer system, with the assistance of many funding
organizations.
• Proactively sought and received funding for additional upcoming work: USDA $2.63M; Golden
Leaf$313K; and Local lending$185K.
• An additional$2M is pending for CDBG-I sewer rehabilitation work in low to moderate income
areas.
• Balanced the sewer debt, raising the sewer rates 25% in 2019 and 6% additionally each year
since. This evidence shows that the City understands the need and is willing to take the
necessary steps to fund repairs even without an increase in customer base. The City of Dunn
has not experienced any significant growth in decades, staying just under a population of
10,000.
A moratorium will make it difficult to generate the extensive revenues required to support the
needed repairs to bring the City into compliance. Recent interest in the City from local and national
development firms,in addition to a Regional Economic Alliance soon to be formed with the Towns
of Four Oaks and Benson provides excellent opportunities for growth along the I-95 corridor and
an increase in revenue.
The City of Dunn has strived to improve over the last few years,winning a second All-America City
Award and worked to become a NC Main Street Community. The City is also in the process of
completing a community-wide vision plan in partnership with the Dunn Area Chamber of
Commerce and Dunn Area Tourism Authority.
We are requesting your assistance to waive the moratorium and allow the City to work with the
NCDEQ Regional Office to develop a Special Order by Consent that will produce results in an
agreed upon timeline, thereby providing the City with an ability to fund the needed projects to
bring its sewer system into compliance.
Thank you for your consideration. Please contact me at 919-820-3661 with any questions you may
have.
4", Respectfully yours,
William P. Elmore,Jr.
Mayor
CC: Governor Roy Cooper
Michael Montebello,Supervisor
Municipal Permitting Unit, Division of Water Resources