20090858 Ver 1_Signed UMBI & approval Ltr_20140218

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
EBX -EM, LLC
Attn: Mr. Thomas L. Rinker
909 Capability Drive, Suite 3100
Raleigh, NC 27606
Division of Water Resources
Water Quality Programs
Thomas A. Reeder
Director
February 18, 2014
John E, Skvarla, III
Secretary
DWQ Project # 2009 -0858
Re: Cape Fear Riparian Buffer & Nutrient Umbrella Mitigation Banking Instrument
Dear Mr. Rinker:
On February 17, 2014, the North Carolina Division of Water Resources (DWR) received a signed
Umbrella Mitigation Banking Instrument (UMBI) by Norton Webster on behalf of EBX -EM, LLC
(EBX). The UMBI submitted was a modification to the original UMBI signed and approved on
October 9, 2009. This UMBI was developed to provide EBX with the ability to perform the
following functions in the Jordan Lake Watershed of the Cape Fear River Basin, within the 8 -digit
Hydrologic Unit Code 03030002:
• Improve water quality through the restoration of riparian buffer habitat, the installation of
new stormwater best management practices ( "BMP "), and the renovation of existing
stormwater BMPs.
• To provide mitigation for buffer impacts and development (both existing and proposed)
requiring nutrient offset payments, and to sell any resulting credits to third parties.
On February 17, 2014, Thomas Reeder, on behalf of DWR, approved the UMBI modification.
A copy of the signed UMBI is attached with this letter. Please feel free to contact Katie Merritt at
(919) 807 -6371 if you have any questions regarding this correspondence.
KAH/kym
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Unit
cc: Tommy Cousins — EBX -EM, LLC (via electronic mail)
File Copy -Katie Merritt
401 and Buffer Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699 -1650
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919 - 807 -63001 FAX: 919 - 807 -6494
Internet: www.ncwaterquality.org

AGREEMENT TO ESTABLISH THE CAPE FEAR RIPARIAN BUFFER AND NUTRIENT
MITIGATION BANKING INSTRUMENT PURSUANT TO THE JORDA
SUPPLY NUTRIENT STRATEGY D
UMBRELLA BANKING INSTRUMENT 7 ?0 F,.
HUC 03030002 F FEB I I
I. PREAMBLE
This Riparian Buffer and Nutrient Mitigation Umbrella Banking Instrument, regarding the
establishment, use, operation, and maintenance of the Cape Fear River Basin Riparian Buffer
and Nutrient Mitigation Umbrella Bank (Bank) is made and entered into by and among EBX-
EM, LLC, (EBX -EM), acting as the Bank Sponsor, and the North Carolina Department of
Environment and Natural Resources — Division of Water Resources (DWR).
The purpose of the Bank is to:
Improve water quality through the restoration of riparian buffer habitat, the
installation of new stonnwater best management practices (BMPs), and the
renovation of existing stormwater BMPs within the Jordan Lake Watershed of the
Cape Fear River Basin in the State of North Carolina, United States Geological
Survey (USGS) Hydrologic Unit Code (HUC) 03030002.
2. To provide mitigation for buffer impacts and development (both existing and
proposed) requiring nutrient offset payments within the Jordan Lake Watershed of the
Cape Fear River Basin, and to sell any resulting credits to third parties.
II. AUTHORITIES
The Bank will be used to provide nutrient offset and riparian buffer mitigation in accordance
with the Jordan Water Supply Nutrient Strategy requirements of the following proposed
administrative code sections:
I . 15A NCAC 2B .0264 Agriculture,
2. 15A NCAC 2B .0265 Stonnwater Management for New Development,
3. 15A NCAC 2B .0266 Stonnwater Management for Existing Development,
4. 15A NCAC 2B .0268 Mitigation for Riparian Buffers
5. 15A NCAC 02.0269 Riparian Buffer Mitigation Fees to the NC Ecosystem
Enhancement Program
6. 15A NCAC 2B .0270 Wastewater Discharge Requirements, and
7. 15A NCAC 2B .0271 Stormwater Requirements for State and Federal Entities.
8, 15A NCAC 2B..0273 Options for Offsetting Nutrient Loads
All activities will be consistent with permanent rules for the Jordan Water Supply Nutrient
Strategy approved by the Environmental Management Commission and approved by the
North Carolina Office of Administrative Hearings - Rules Review Commission (RRC) on
October 16, 2008 and November 20, 2008.

Any changes to the proposed Jordan Water Supply Nutrient Strategy legislation that occur
during review by the General Assembly will also be adhered to as pant of this banking
instrument.
II1. ESTABLISHMENT OF BANK PARCEL(S)
A. Each tract of land subject to a conservation easement or restrictive covenants described in
Section III -E ( "Bank Parcel ") to be included in the Bank shall require a Bank Parcel
Development Package (BPDP), including detailed information concerning site location,
existing conditions, proposed buffer restoration activities or stormwater best management
practice (BMP's) activities, monitoring and maintenance plans, financial assurances, and
associated buffer mitigation /nutrient credit calculations (to include credit generation,
service area, and accounting as appropriate for each regulatory authority cited above).
Additional Parcels may be added to the Bank at any time upon approval of the associated
BPDP by the DWR and prior to use of the parcel for mitigation purposes. Please note the
service area for each Bank Parcel will be limited to the affected arm /subwatershed of B.
Everett Jordan Lake (i.e., Upper New Hope, Lower New Hope, or Haw River) in which
the Bank Parcel is located.
B. For each BPDP, EBX -EM agrees to perform all necessary work, in accordance with the
provision of this Banking Instrument, to establish and / or maintain and monitor riparian
buffers or to install and / or renovate stormwater BMPs until it is demonstrated to the
satisfaction of the DWR that the restored property (buffers) or installed / renovated BMPs
comply with all conditions contained herein, or until all credits from that Bank Parcel are
sold, whichever is later but at a minimum of (5) years.
C. EBX -EM will obtain all appropriate environmental documentation, permits, or other
authorizations needed to construct and maintain the Bank Parcel. This Banking
Instrument does not qualify or substitute for such authorization.
D. Financial Assurance Requirements: Following approval of the BPDP, EBX -EM shall
provide a Performance Bond from a surety company that is rated no less than an "A -" as
rated by A.M. Best. The Performance Bond amount shall be 100% of the estimated cost
for implementation of the buffer restoration / stormwater management plan included in
the BPDP, but no less than $150,000.00 in amount. Alternatively, in lieu of posting the
Performance Bond, EBX -EM may elect to construct the project prior to the first credits
release. After completion of the restoration / construction, a Monitoring Bond will be
substituted for the Performance Bond. The sum of said Monitoring Bond shall be for
100% of the estimated cost to implement the monitoring and maintenance plan but no
less than $100,000.00 in amount. The Monitoring Bond shall be in effect for a period of
five years but may be lowered each year based on the adjusted cost to finish the
monitoring.
E. Property Disposition: Prior to the release of any credits, EBX -EM shall acquire a
permanent conservation easement(s) or record restrictive covenants at the county clerk's
office to the deed(s) on all Bank Parcels to provide protection to the restored riparian
buffer and / or stormwater BMPs in perpetuity from activities that would impair their
ability to provide nutrient abatement to waters of the Cape Fear River Basin, including B.
Everett Jordan Lake. The form of the conservation easement or restrictive covenants shall
be consistent with the standards employed by the State of North Carolina in the
protection of restored riparian buffers and / or stormwater BMPs and shall be approved
by the DWR prior to the certification of any credits. EBX -EM shall not grant additional
easements, rights of way, or any other property interest in or to the project areas without
the written consent of the DWR or its designee. In the case of a conservation easement,
iJ

EBX -EM will hold the easement until a qualified holder under N.C. General Statute
( "G.S. ") 121 -34 et seq. and 170(h) of the Internal Revenue Code is identified. The holder
shall be a land trust or stewardship program that will hold and enforce the conservation
easement and the interests in perpetuity. The Sponsor shall choose a land trust or
stewardship program that is accredited by the Land Trust Accreditation Commission
and /or has been approved by DWR prior to the end of the fourth year monitoring period.
A land trust must be certified under. 501(c) (3) of the Internal Revenue Code and must
have the qualifications outlined in G. S. 105 - 130.24 and G.S. 105 - 151.12
F. Operat onu and Nainf riat,ce Ag oe.a,erits: Prior to the release of any �redit<, EBX -EM
will provide Dk,vR v „lith the neccs ate; operatian and maintenance agreements for the
newly constructed or renovated stormwater BMPs (if applicable). These agreements shall
be consistent with the standards adopted by DWR and shall be approved by the DWR
prior to the certification of any credits.
G. As -Built Reports: EBX -EM will submit an as -built plan and report for each Bank Parcel
within 30 days after cor~,pleting the establishment of the buffer and / or construction or
renovation of stormwater BMPs (if applicable). The as -built report will describe in detail
any deviation from the BPDP. In addition, the as -built report will document the
appropriate aspects of the Bank depending upon the type as follows:
a. Buffer restoration: planting details, invasive species control, monitoring device
locations, vegetation plot locations, photo point locations, surface and
groundwater elevations, as appropriate.
b. Stormwater BMPs: outlet structure information, surface area / volume
.computations, hydrograph routing information, planting details, monitoring
device locations, photo point locations as appropriate.
c. Boundary Survey of easement area
IV. MAINTENANCE AND MONITORING OF BANK PARCEL(S)
A. Operation and Maintenance Provisions: EBX -EM agrees to perform all necessary work to
operate and maintain the Bank Parcel(s) consistent with the operation and maintenance
criteria established in Section III -F of this instrument. EBX -EM shall continue with such
activities until Items J (2) (a) and J (2) (b) of Section VI have been satisfied. Deviation
from the approved BPDP is subject to review and written approval by DWR or its
designee.
B. Monitoring Provisions: EBX -EM shall monitor the Bank Parcel as described in the BPDP
for each Bank Parcel until such time as DWR determines that the success criteria
described below have been met. The monitoring period shall be a minimum of five (5)
years.
Riparian Buffer Restoration
C. Vegetative Success Criteria: Vegetative Success Criteria will be based upon the density
and growth of character tree species. "Character Trees” are defined as planted or
volunteer species identified from a survey of local vegetation on less degraded sections of
the specified stream and from reference literature that details native species. A list of
Character Tree species for each Bank Parcel will be detailed in that Parcel's BPDP.
Vegetative Success Criteria will be based upon guidelines set forth in the Guidelines for
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Riparian Buffer Restoration prepared by the North Carolina Ecosystem Enhancement
Program (or subsequent updated versions of this Guidance in place at the date of
acceptance of a BPDP). Success is defined as the survival of an average density of 320
desirable trees per acre after five (5) years. If vegetative success criteria are not met,
supplemental plantings may be required. Supplemental plantings will be utilized until the
required densities have been achieved after five (5) years. Success criteria of the riparian
buffer restoration and enhancement shall be based on the CVS -EEP Protocol for
Recording Vegetation Level 1 -2 Plot Sampling Only Version 4.0.
D. 'Monitoring- EB -F,M shall subrnit to the DWR an annual inonitoring. report; no
later than Deccmbcr 31 each year for five years afltcr the, first frul, goviing season,
describing the conditions of each Bank Parcel and relating those conditions to the success
criteria. Reports shall be submitted annually and shall contain the following:
1. A U.S. Geological Survey map showing location of the Bank Parcel(s);
2. A detailed narrative summarizing the condition of the Bank Parcel(s) and all regular
iiiaiIiteilaiiic activities;
3. Appropriate topographic survey showing location of sampling plots, permanent photo
points, location of transects, etc.;
4. Monitoring data, including specific vegetative counts and photographs; and
5. A copy of the Bank credit /debit ledger.
E. Contingency Plans /Remedial Actions: In the event the Bank fails to achieve the success
criteria described in this instrument, EBX -EM shall develop necessary contingency plans
in coordination with the DWR or designee and implement appropriate remedial actions
for the Bank. Depending on the degree of remedial actions required, DWR reserves the
authority to extend or re -start the monitoring period as necessary to demonstrate site
success.
If the DWR determines that the Bank is operating at a deficit (i.e., EBX -EM is closing on
sales and transferring credit not yet available), the sale /transfer of credits will
immediately cease, and the DWR, in consultation with EBX -EM, will determine what
remedial actions are necessary to correct the situation.
Construction / Renovation of Stormwater BMPs
F. Stormwater BMP Success Criteria: The success of a stormwater BMP will be based upon
the type and its associated design criteria, as approved by DWR at time of submission of
the BPDP. For purposes of this agreement, the design criteria shown in the North
Carolina Division of Water Quality Stormwater Best Management Practices Manual
(October 2007), or as amended / updated, and the approved operation and maintenance
agreement from Section III -F of this agreement shall be the basis for judging the success
of a specific device.
G. Monitoring Reports: EBX -EM shall submit to the DWR an annual monitoring report, no
later than December 31 each year for five years after the initial installation / renovation of
the stormwater BMP, describing the conditions of each Bank Parcel and relating those
conditions to the success / approved design criteria. Reports will be submitted annually
and shall contain the following:
A U.S. Geological Survey map showing location of the Bank Parcel(s);
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2. A detailed narrative summarizing the condition of the Bank Pareel(s) and all regular
maintenance activities;
3. A copy of the Bank credit /debit ledger.
H. Contingency Plans /Remedial Actions: In the event the Bank fails to achieve the success
criteria described in this instrurnent, ERX -EM shall develop .necessary conlingeoacv plans
in coordination with the DWR or designee and implement appropriate remedial actions
for the Bank.
If the DWR detejrnirw.s ilia- the Back is operating at a deiicii. ;i.c., EBX - Filet is st-41ilng or
transferring credit not c, available), the sale /transfer of credits tivill immediat;l, cease,
and the DWR, in consultation with EBX -EM wiil determine what remedial actions are
necessary to correct the situation.
V. OPERATION OF BANK
A. Nutrient Abatement of Restored Riparian Buffer: EBX -EM and DWR agree the pounds
of nitrogen offset per acre of restored riparian buffer shall be tv✓o thousand two hundred
and seventy three pounds per acre (2,273 lbs /acre) and the pounds of phosphorus offset
per acre of restored riparian buffer shall be one hundred forty six and four - tenths pounds
per acre (146.4 lbs /acre), or the amount of nitrogen and phosphorus offset per acre per
DWR policy at the time the BPDP is approved, and shall be applied to riparian buffer -
based nutrient abatement sites across the State of North Carolina.
EBX -EM and DWR ffirther agree that the am- oun_t of n2itrient offset per acre shall be
fixed as part of the approval of each individual Bank Parcel, with the fixed amount not
changing during the development and credit release schedule of each Bank Parcel(s).
Please note nutrient credits sold or transferred from approved Bank Parcels to prospective
purchasers shall account for DWR - approved transport factors between the Bank Parcel
site and the location of the site or development wishing to utilize credits.
B. Nutrient Abatement of Installed / Renovated Stormwater Best Management Practices:
EBX -EM and DWR agree that the pounds of nitrogen and phosphorus available for credit
release from newly renovated or constructed stormwater BMPs shall be based upon the
design calculations / nutrient export calculations submitted to and approved by DWR as
part of the BPDP.
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C. Establishment and Release of Credits: Within thirty (30) days upon submittal of all
appropriate documentation by EBX -EM, and subsequent approval by DWR or its
designee, it is agreed that the mitigation credits associated with this Bank will become
available for sale to a third party in accordance with the following schedules:
Table li - Credit Release Schedule fa: Riparian Buffer and Nutrient Offset Credits (excluding
Stormwater B1YIPs)
Project Milestone
I % Credit
Available for
Task � Fru'ect 11it1. stave Sale
-Sale - --
BPDP Approved by DWR, Conservation Easement Recorded* and Financial
1 Assurance Posted 20*
Installation / Renovation of Stormwater BMP in accordance with approved design
plans completed
Mitigation Site Earthwork, Planting and Installation of Monitoring Devices
3
2
Completed
20
3
Monitoring Financial Assurance Posted and Approval of As -Built Report
10
_ 4
M -ritoring Report #1 : A _pproved by the DWR- -- - _ - -- - - - -- _ - - --
- -__ 10__
5
Monitoring Report #2: Approved by the DWR **
10
6
Re ort #3: A roved b the DWR **
10
:],Won"itornir
ems J (2a) of Section VI in this Instrument has been completed and approved by
O &M Report #5: Approved by the DWR* and final site visit by DWR has been
conducted
7
WR.
5
No remaining credits will be released until Task 7 has been satisfied
8
Monitoring Report #4: Approved by the DWR **
5
Monitoring Report #5: Approved by the DWR ** and final site visit by DWR has
9
been conducted
10
Total
100%
* For specification, please see Item E of Section III in this Instrument
** DWR Approval provided upon a determination that the site is meeting success criteria contained
within the approved BPDP
Table 2 - Credit Release Schedule for Nutrient Offset Credits - Stormwater BMPs
Task
Project Milestone
% Credit
Available for
Sale
1
BPDP Approved by DWR, Bank Closure Agreement, Drainage and Access
Easements Recorded* and Financial Assurance Posted, and Operation and
Maintenance Agreement Approved by DWR
20*
2
Installation / Renovation of Stormwater BMP in accordance with approved design
plans completed
20
3
Approval of As -Built Package
10
4::
O &M Report #1: Approved by the DWR*
10
5
6
O &M Report #2: Approved by the_DWR *_ _
O &M Report #3: Approved by the DWR*
10
10
7
Items J (2a) of Section VI in this Instrument has been completed and approved by
DWR.
_
5
No remaining credits will be released until Task 7 has been satisfied
8
O &M Report #4: Approved by the DWR*
5
9
O &M Report #5: Approved by the DWR* and final site visit by DWR has been
conducted
10
Total
100%
* For specification, please see Item E of Section III in this Instrument
** DWR Approval provided upon a determination that the site is meeting success criteria contained
within the approved BPDP

D. Projects Eligible to Use the Bank: Projects eligible for utilization of the credits are those
requiring authorization under the requirements of the following administrative code
sections:
1. 15A NCAC 2B .0264 Agriculture,
2. 1514A NCAC 2B.0265 Stonriwater Management for New Development,
3. 15A N(_'A(' 213 .0266 Storm water Management for Existing Development,
4. i 54 1 7i. AC 2B .0268 Mitigation for Riparianz. Ruffs,�rs
5. 1 �''" i2 .0269 Riparian Luffc -r _ 11ifigatzon F NC Ecosystern
F,nbancement Program.
6. 15A NCAC 2B .0270 Wastewater Discharge Requircmcrts, and
7. 15A NCAC 2B .0271 Stormwater Requirements for State and Federal Entities.
8. 15A NCAC 2B..0273 Options for Offsetting Nutrient Loads
E. Procedure for Debiting or Crediting the Bank: EBX -EM shall maintain three (3) credit
ledgers: one accounting for buffer mitigation credits (in square feet), which are generated
by buffer areas of >.50 feet in width; one accounting for nitrogen offset credits, which are
generated from buffer areas up to 200 feet in width and from the installation / renovation
of stormwater BMPs, and the third accounting for Phosphorus release and debits. The
ledgers shall record the area of available buffer credits and pounds of available nutrient
credits for each Bank Parcel and all associated debits and credits. Credits can be
converted and transferred from buffer mitigation to nitrogen offsets, but the opposite
shall not occur. All debits or credits shall be entered into the ledger and notification
provided to DWR or its designee within thirty (30) days of each transaction. All
transactions shall be kept in the ledger. Key documents are the Credit Reservation Letter
confirming the credits are available for transfer and debiting and have been legally
contracted and reserved for a specific project. The final document for verification and
transfer is the Transfer Certificate that is issued to DWR along with the updated credit
ledger after the purchaser's permit application is approved and permittee fully funds the
purchase of credits. This is the final documentation for DWR that verifies the permittee
has met the mitigation requirement. Notification of all credit sales shall be provided to
DWR until all credits that have been released have been sold.
F. Geographical Service Area (GSA): The GSA is the designated area wherein a bank can
reasonably be expected to provide appropriate riparian buffer and /or nutrient offsets for
impacts due to development activities. The GSA for this Bank shall include the Jordan
Lake Watershed of the Cape Fear River Basin Hydrologic Unit Code (HUC) 03030002 in
North Carolina. The GSA for each Bank Parcel will be restricted to the affected
arm /subwatershed of B. Everett Jordan Lake (i.e., Upper New Hope, Lower New Hope,
or Haw River) in which each Bank Parcel is located.
VI. OTHER PROVISIONS
A. EBX -EM and the landowner will allow, or otherwise provide for, access to the Parcel(s)
by the DWR or other parties authorized by the DWR, as necessary, for the purpose of
inspection and compliance with the terms and conditions of this Banking Instrument and
the conservation easement or restrictive covenants. Inspecting parties shall provide
reasonable notice, of not less than 24 hours, to EBX -EM, prior to inspection of Bank.
7

B. Force Majeure: After the sale of all available credits, EBX -EM will not be responsible for
Bank failure that is attributed to natural catastrophes such as but not limited to flood,
drought, disease, regional pest infestation, etc. that are beyond the control of EBX -EM.
However, while EBX -EM may not have control of such events, if an event occurs before
the final sale of all credits, EBX -EM shall take remedial action to restore the property to
its condition prior to this event, in a manner sufficient to provide adequate mitigation to
cover credits that were sold prior to the oecurrence of the event. Such remedial action
shall be takori by E- TiX -EM only to the extent necessary and appropriate, as determined.
by DWR and EBX-E , to 6,dc-' �() Offsd aotllori' %;CCl 11ii11aC;ts to bilffCl'S i1T to Sr1:�;iy
nutrient offset buy down requirements imposed during land development activities and
satisfied through payment into the affected Bank Parcel.
DWR must concur in writing that a force majeure event has occurred.
C. Validity, Modification, and Termination of the Banking Instrument: This Banking
Instrument will become valid on the date of the last party's signature. This Banking
Instrument may be amended or modified only with written approval of all signatory
parties.
D. Specific Language of Barking L,strrament Shall Be Contrellirg: To the extent tha±
specific language in this document changes, modifies, or deletes terms and conditions
contained in those documents that are incorporated into the Banking Instrument by
reference, and that are not legally binding, the specific language within the Banking
Instrument shall be controlling.
E. Dispute Resolution: Any disputes between the Bank Sponsor and the DWR regarding the
attainment of success criteria and release of credits from a specific site and appropriate
monitoring, maintenance and /or remedial onsite activities shall first be addressed among
the field staff of DWR and MAM field personnel and then, if not resolved, raised to the
level of the individual signatories to the Banking Instrument or their designees.
G. Notices: Unless otherwise provided herein, all notices and other communications which
may be or are required to be given or made by any party to the other in connection
herewith shall be in writing and shall be deemed to have been properly given and
received on the date delivered in person or deposited in the United States mail, registered
or certified, return receipt requested, to the addresses set out below, or at such other
addresses as specified by written notice delivered in accordance herewith.
If to EBX -EM: EBX -EM, LLC
10055 Red Run Boulevard, Suite 130
Owings Mills, MD 21117
Attn: Mr. Thom Rinker
Copy to: EBX -EM
909 Capability Drive, Suite 3100
Raleigh, North Carolina 27606
Attn: Mr, Tommy Cousins

If to DWR: NC Division of Water Resources
Attn: Ms. Katie Merritt, Nutrient Offset Program Coordinator
1650 Mail Service Center
Raleigh, NC 27699 -1650
H. Entire Agreement: This Agreement constitutes the sole and entire agreement among the
par.xes hereto and no i—noelfication of this _Agreement shall be binding unless in writing
and signed by all ,patties 0oretc).
1. Applicable Law: This Agreement shall be construed under the laws of the State of North
Carolina.
J. lank Parcel Closure:
1. Bark Parcel Closure shall be identified as the evert when the Sponsor is relieved of all of its
responsibilities to the Bank Parcel and there are no mitigation credits left to sell.
2. Bank Parcel Closure shall commence only after all of the following events have occurred:
a. Transfer or assign the conservation easement and all of its interests, in perpetuity, to a
land trust or stewardship program as described in Item E of Section III of this
agreement.
b. All five years of monitoring completed and all monitoring reports submitted and
approved by DWR.
c. All credits have been released and debited and updated ledgers showing a zero credit
balance have been submitted and approved by DWR.
EBX -EM, LLC
Name: I is A t, 09J"
Title: 1-e3 v\a,-t,
Date: 1-Z Fe- � '2-01,4
I

NORTH CAROI
NATURAL RES
By:
Name:
Title:
Date:
DEPARTMENT OF ENVIRONMENT AND
CES - DIVISION OF WATER RESOURCES
,
�/ / / -7 / / -/'
10