20141176 Ver 1_401 Application_20141112

CAROLINA 2 0 1 4 1 1 7 6
3040 NC 42 West, Clayton NC 27520
ECOSYSTEINAIS, INC. P 919- 606 -1065 — F 919 -585 -5570
November 10, 2014
Ms Karen Higgins
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699 -1617
RE- Request for Appeal of Stream Origin Determination
Waste Industries - High Point Landfill
Guilford County, North Carolina
Dear Ms. Higgins;
The purpose of this letter is to request an appeal of the City of High Point (City) stream origin
determination on the above referenced site Carolina Ecosystems, Inc. (CEI) requested that the
City perform a stream origin determination at this site under the authority of City Ordinance
#6839/11 -47, which implements the Randleman Lake Water Supply Watershed. Protection and
Maintenance of Existing Riparian Buffers Rule (15A NCAC 02B .0250). The North Carolina
regulation states that "Any disputes over on -site determinations shall be referred to the local
Board of Adjustment or other local appeals process in writing " However, the City ordinance
states that "Any disputes over on -site determinations shall be referred to the Director of the NC
Division of Water Quality in writing " Due to this discrepancy, we are requesting an appeal of
the determination described below, and copying the City on this request in order to comply with
the wording of both regulations.
City personnel visited the site on September 12, 2014 Three stream origin determinations were
made on channels that were field classified by CEI as, at least partially, ephemeral streams.
These determinations on drainages designated as WI -03, WI -08, and WI -11 were documented in
separate letters dated September 12, 2014 (attached)
CEI assessed each of these drainages on August 8, 2013, and revisited the site on February 27,
2014. It is our professional opinion that two of these features, drainages WI -03 and WI -11, are
ephemeral channels (Figure 1). This concurs with the City determination. In addition, it is our
professional opinion that drainage WI -08 should be subject to riparian buffers at the confluence
with WI -03 (shown as a solid line "SA" in Figure 1). The City determined that WI -08 was
subject approximately 400 feet upstream, as shown on the attached map.
It should be noted that the City's field review occurred after a week with heavy rainfall, which
may have influenced the stream origin determination With the benefit of multiple season
reviews of drainage WI -08, it is our professional opinion that the Randleman Lake buffer should
not extend past the stream point shown in Figure 1

Ms. Karen Higgins
November 10, 2014
Page 2 of 2
I would like to schedule a site visit to review the aforementioned stream determination Please
contact me at your earliest convenience at (919) 606 -1065 or phil.may @carolinaeco com.
Sincerely,
Carolina Ecosystems, Inc.
1
Philip May
Senior Environmental Scientist
Attachments
Figure 1. Stream Assessment map
City of High Point Stream Determination Letters
Cc. Sue Homewood — NCDWR Winston -Salem Office
Terry Kuneff, P E. — City of High Point
Stacy Smith, P.E. - Smith Gardner Inc.
David Pepper - Waste Industnes

Engineering Services Department
B. Keith Pugh, P.E., Director
September 12, 2014
Phil May, Senior Scientist
Carolina Ecosystems, Inc
3040 NC Hwy 42 West
Clayton, North Carolina 27520
NORTH CAROLINA'S INTERNAITONAL CITY"
Re: Waste Industries — High Point Landfill — Drainage Feature WI -08
Randleman Rule (15A NCAC 02B 0250) Surface Water and Stream Origin Determination
Dear Mr. May:
Per your request, a site investigation was conducted on the property by the City of High Point Engineering Services
staff on September 12, 2014, to verify if the drainage feature labeled as WI -08 should be classified as surface water
for the purpose of the application of requirements for stream buffers The drainage feature was evaluated using the
most current North Carolina Division of Water Quality Stream Identification Form. The results of the evaluation
indicate that this feature does possess sufficient riparian characteristics to be classified as surface water for the
purpose of application of the requirements of 15A NCAC 02B 0250, Randleman Lake Water Supply Watershed
Protection and Maintenance of Riparian Areas The stream was identified and classified as perennial Stream
buffers will be required for this drainage feature
If you need any additional information, please contact me at (336) 883 -8583.
Sincerely,
Terry A Kuneff, P E, C M
Engineering Services Department
High Point, North Carolina
City of High Point, P O Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax. [phone] Phone [phone] TDD 336 883 8517

Engineering Services Department
B. Keith Pugh, P.E., Director
September 12, 2014
Phil May, Senior Scientist
Carolina Ecosystems, Inc.
3040 NC Hwy 42 West
Clayton, North Carolina 27520
NORTH CAROLINA'S INTERNATIONAL CITY""
Re: Waste Industries — High Point Landfill — Drainage Feature WI -03
Randleman Rule (15A NCAC 02B 0250) Surface Water and Stream Origin Determination
Dear Mr. May:
Per your request, a site investigation was conducted on the property by the City of High Point Engineering Services
staff on September 12, 2014 to verify if the drainage feature labeled as WI -03 should be classified as surface water
for the purpose of the application of requirements for stream buffers The drainage feature was evaluated using the
most current North Carolina Division of Water Quality Stream Identification Form The results of the evaluation
indicate that this feature does not posses sufficient riparian characteristics to be classified as surface water for the
purpose of application of the requirements for stream buffers
If you need any additional information, please contact me at (336) 883 -8583
Sincerely,
Terry A. Kuneff, P 4,FM
Engineering Services Department
High Point, North Carolina
City of High Point, P O Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax [phone] Phone [phone] TDD 336 883 8517

Engineering Services Department
B. Keith Pugh, P.E., Director
September 12, 2014
Phil May, Senior Scientist
Carolina Ecosystems, Inc.
3040 NC Hwy 42 West
Clayton, North Carolina 27520
NORTH CAROLINA'S INTERNATIONAL CITY""
Re: Waste Industries — High Point Landfill — Drainage Feature WI -11
Randleman Rule (15A NCAC 02B 0250) Surface Water and Stream Origin Determination
Dear Mr. May:
Per your request, a site investigation was conducted on the property by the City of High Point Engineering Services
staff on September 12, 2014 to verify if the drainage feature labeled as WI -I I should be classified as surface water
for the purpose of the application of requirements for stream buffers The drainage feature was evaluated using the
most current North Carolina Division of Water Quality Stream Identification Form The results of the evaluation
indicate that this feature does not posses sufficient riparian characteristics to be classified as surface water for the
purpose of application of the requirements for stream buffers
If you need any additional information, please contact me at (336) 883 -8583
Sincerely,
Terry A Kuneff, PIE, C
Engineering Services Department
High Point, North Carolina
City of High Point, P O Box 230, 211 South Hamilton Street, High Point, NC 27261 USA
Fax [phone] Phone [phone] TDD 336 883 8517