NCS000399_Jacksonville 2021 Annual Report Addendum_20210816

City of Jacksonville
Public Services Department
Water Quality Division
Habitat Protection
Friday, August 6, 2021
PO Box 128 • Jacksonville NC 28541-0128
Central Phone [phone] Fax [phone]
Stormwater Manager Phone [phone]
RECEIVED
AUG 16 2021
North Carolina Department of Environmental Quality DENR-LAND QI�AirITY
Division of Energy, Mineral $ Land Resources Stormwater Program SfORMWA.TER PERINI IHH3
512 N Salisbury Street, 6th Floor
1612 Mail Service Center
Raleigh, NC 27699-1612
Dear Jeanette,
The City of Jacksonville has completed, and submitted, its annual report or the 2020-2021
Stormwater Management Program Assessment (SWMPA).
In doing so, I had concerns about a section within the report and wanted to clarify our answer.
In the Construction Site Stormwater Runoff Control or SW 104190, specifically SW 104200 asks:
"Does the permittee rely on the NCDENR Division of Land Resources (DLR) Erosion and
Sediment Control Program to comply with this minimum measure for private development? (If
No, go to SW 104220). The program does not let you check the "NO" box and go to SW 104220
as instructed, it forces you to list a Root Cause and then a Plan of Action.
There were 54 reasons for the "Root cause" listed as to why the COJ did not rely on NCDENR
for the erosion and sediment program. I did not agree or like any of the 54 reason, but was
forced to pick one. I choose the very last option of "unclear or conflicting federal, state, county
or local requirements". I do not agree with this statement but thought it was the lesser of two
evils. The COJ, nor myself, agree with any of the 54 reasons listed in the "Root Cause".
Our Plan of Action is: we do not rely on NCDENR is the City of Jacksonville has its own
delegated program for Erosion and Sediment Control that follows the NCDENR rules and
regulations, permitting and enforcement. We took over the program because we are on site
regularly and felt we could do a better job.
nicer ,
Pat Donovan -Brandenburg
Stormwater and Soil and Erosion Control Manager
City of Jacksonville
[e-mail]
Jacksonville City Hall • 815 New Bridge Street • 910 938-5200 • www.JacksonvilleNC.gov