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HomeMy WebLinkAboutAttachment_E4_revisedAVA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Resources Pat McCrory Governor Thomas A. Reeder Director FINDING OF NO SIGNIFICANT IMPACT John E. Skvarla, Ill Secretary ENVIRONMENTAL ASSESSMENT FOR THE CHARLOTIE MECKLENBURG UTILITIES DEPARTMENT MODIFICATION OF INTERBASIN TRANSFER CERTIFICATE Pursuant to the requirements of the Surface Water Transfers Act [G.S. 143-215.221] and the State Environmental Policy Act (G.S. 113A), the Charlotte Mecklenburg Utilities Department (CMUD) has prepared an environmental assessment (EA). This EA has been prepared to support CMUD's request to eliminate Condition 3 from its lnterbasin Transfer (IBT) Certificate, issued by the Environmental Management Commission (EMC) on March 14, 2002 under the provisions of G.S. 143-215.221. The IBT Certificate issued by the EMC allows CMUD to transfer 33 million gallons per day (MGD) from the Catawba River Basin to the Rocky River Basin. Due to concerns that impacts to the Carolina heelsplitter, a federally-listed endangered species, had not been sufficiently evaluated, the EMC created a condition to exclude Goose Creek from the area to be served by the interbasin transfer: Condition 3 of the certificate states: The Goose Creek subbasin in Mecklenburg County is removed from the area to be served by the IBT. A moratorium on the installation of new interbasin transfer water lines (water lines crossing the ridgeline) into Goose Creek subbasin is in effect until the impacts of additional urban growth on the endangered species are fully evaluated. At the time the certificate was issued, it was assumed that Goose Creek Watershed protection measures would be addressed in an environmental study developed for a new wastewater plant under consideration by Union, Cabarrus, and Mecklenburg Counties. The wastewater treatment plant effort has since been abandoned and watershed protection needs within Goose Creek have been addressed through separate local and state level initiatives, most specifically the Town of Mint Hill's 2010 Post- Construction Ordinance (PCO). The Town of Mint Hill's PCO addresses the action items listed in the NC Department of Environment and Natural Resources Site Specific Water Quality Management Plan for the Goose Creek Watershed 15A NCAC 2B .0600-.0609, approved by the EMC in 2008. As stated in 15A NCAC 02B .0601, "The purpose of the actions required by this site-specific management strategy is for the maintenance and recovery of the water quality conditions required to sustain and recover the federally endangered Carolina heelsplitter (Lasmigona decorata) species. Management of the streamside zones to stabilize stream banks and prevent sedimentation are critical measures to restore water quality to sustain and enable recovery of the federally endangered Carolina heelsplitter." Some of the mitigation and protection measures specifically required by the PCO and currently being implemented by the Town of Mint Hill include: 1611 Mail Service Center, Raleigh, North Carolina 27699-1611 Location: 512 N. Salisbury St Raleigh, North Carolina 27604 Phone: 919-707-9000\ FAX: 919-733-3588 Internet: www.ncwater.org An Equal Opportunity \ Affirmative Action Employer E452 Environmental Assessment Finding of No Signifi~ant Impact Charlotte Mecklenburg Utilities Modification of lnterbasin Transfer Certificate I. The control of storm water for projects disturbing 1 acre or more of land • Requires Storm Water Management Permit for new development activities that disturb 1 acre or more and result in increased impervious area. • Controls and treats difference in runoff from pre-to post-development conditions for 1- year, 24-hour storm. • Removes 85% of total suspended solids. • Exceeds runoff volume requirement of EMC rule by requiring that storm water treatment systems be installed to control the volume leaving the project site at post- development for the 1-year, 24-hour storm. • Town of Mint Hill accepts maintenance and operational responsibility so as to preserve and continue a BMP's design functions. II. The control of wastewater discharges and toxicity for streams supporting the Carolina heelsplitter • No new NPDES wastewater discharges or expansions to existing discharges • No new onsite sanitary sewage systems within riparian buffers • No activity that would result in direct or indirect discharge is allowed if it causes toxicity to Carolina heelsplitter • When possible, action shall be taken to reduce ammonia to achieve 0.5 mg/L or less of total ammonia. Ill. The establishment and maintenance of riparian buffers • Exceeds EMC requirement by requiring buffers on all intermittent and perennial streams as well as ponds, lakes, and reservoirs based on NC DWQ's Identification Methods for the Origins of Intermittent and Perennial Streams. • Requires undisturbed riparian buffers within 200 feet of waterbodies within the 100- year floodplain and 100 feet of waterbodies not within the 100-yr floodplain. • Direct discharges of runoff to streams are not allowed. IV. Other requirements • Sewer lines and associated structures must be a minimum of 50 feet from jurisdictional wetlands associated with the floodplain. • Undisturbed Open Space is required for new development. The Division of Water Resources has determined that the analysis of the potential environmental impacts set forth in the EA and mitigative measures set forth in the PCO support a Finding of No Significant Impact such that preparation of an environmental impact statement will not be required. This decision is based upon the requirements of 15A NCAC 2B .0600-.0609, information in the attached EA, and review by governmental agencies. This FONSI completes the environmental review record, which is available for inspection and comment for 30 days at the State Clearinghouse. . \ 1--/Jq//'2, ~ Page 2 of2 E453 FOR LEAD STATE AGENCY USE ONLY Conclusion Statement (Must be completed and signed by responsible state agency and submitted with the EA document to the State Clearinghouse.) Select th_7"opriate statement below: --l,L._ After preparation/review of this EA, the responsible state agency has concluded there is a Finding ofNo Significant Impact (FONSI) and will not be preparing an Environmental Impact Statement (EIS). (Attach any additional information regarding this conclusion that you deem important to this finding.) ____ The agency has completed this EA and is hereby submitting it for review and comment. After a consideration of the comments received, the agency will proceed with a FONSI or prepare anEIS. liJL b frvR /J;:i<J R ''•••d -~d_a~ Agency / Submission Instructions Note to non-state agency document preparer: Documents completed for state agencies must first be sent to the appropriate agency for approval and completion of the Conclusion Statement prior to State Clearinghouse submission. Contact the appropriate agency for its submission procedures. Documents prepared for the N.C. Department of Environment and Natural Resources will be subject to departmental review prior to submission to the State Clearinghouse. An EA should not exceed 25 pages in length, excluding exhibit materials. Sixteen (16) copies of this document with the cover letter and Conclusion Statement should be submitted to the State Clearinghouse, N.C. Department of Administration, Room 51 06c, 116 West Jones Street, Raleigh, North Carolina 27603. Mailed copies need to be sent to State Clearinghouse, 1301 Mail Service Center, Raleigh, N.C. 27 699-1301. For the review schedule and submission deadline dates, call the State Clearinghouse at (919) 807-2324. 8 E454 E455 E456 E457 E458 E459 E460 E461 E462 E463 E464 E465 E466 E467 E468 E469 E470 E471 E472 E473 E474 E475 E476 E477 E478 MEETING SUMMARY Update: Environmental Assessment for the Addition of the Goose Creek Watershed to CMUD's 2002 IBT Certificate Mark Cantrell/USFWS John Fridell/USFWS Alan Ratzcliff/USFWS Shari Bryant/WRC (phone) Ron Weathers/CMUD Barry Shearin/CMUD Rusty Rozzelle/Mecklenburg County Bill Kreutzberger/CH2M HILL Jaime Robinson/CH2M HILL NC Division of Water Resources file PREPARED BY: CH2M HILL DATE: February 4, 2013 The purpose of this meeting was to discuss Charlotte-Mecklenburg Utilities Department’s (CMUD) preparation of an environmental document to remove the condition in their IBT Certificate limiting transfer of water to the Goose Creek watershed within Mecklenburg County. 1) Who: Introductions and Roles and Responsibilities Overview Note: Shari Bryant joined us by conference call 2) Where: Review of Mapping a) Goose Creek Watershed boundaries within Mecklenburg County and the Town of Mint Hill i) Discussion regarding private individual wells in the watershed. Mark asked if they are low yield or if other water quality problems are present. Yields are sufficient. Some residents complain of brown water but this is not a health concern. Another concern is that private water providers are more expensive than public utilities b) Development patterns in the watershed i) Mark asked what land use changes are expected in the watershed. The Bridges shopping mall, on hold for a while, seems to be ready to move forward. Some commercial development is expected around the mall; most development in the watershed should be residential. Zoning currently reflects a majority of residential land uses. ii) Barry stated that developers are asking CMUD if service is available in the watershed. iii) Shari asked about the presence of CMUD water and sewer service. Right now public sewer is not available. A private collection system run by Aqua pumps wastewater out of the basin before discharge. 3) What & When: Review of CMU’s IBT Certificate, EMC Plan for Goose Creek Watershed, and Town of Mint Hill Ordinance These documents and how they were developed were discussed. a) 2002 IBT Certificate b) 2009 EMC Site Specific Water Quality Plan for Goose Creek Watershed Plan endorsed c) 2010 EMC Delegation of Authority to Implement Site Specific Water Quality Plan to Mecklenburg County ATTENDEES: COPY TO: E479 d) 2010 Town of Mint Hill updated post construction ordinance i) The ordinance is available at: ftp://ftp1.co.mecklenburg.nc.us/WaterQuality/PCO%20Ordinances/MintHillPCOFinal.pdf ii) Zoning and future land use mapping (as of August 2011) are available at: http://www.minthill.com/documents/7/Zoning-2011-08-24x36.PDF http://www.minthill.com/documents/7/2010%20CLUP%20Map%20-%20Adopted.PDF iii) In the review of Table 7 which compares the 2009 EMC Plan and the 2010 development ordinance, Mark asked what if anything in the ordinance went above and beyond that outlined in the 2009 plan. -More control of peak runoff -Local administration of PCO (by Mecklenburg County, not the Town of Mint Hill) has its benefits (a) BMP inspection and maintenance program is stronger than anything the state could do with its limited resources. Stormwater fee funding supports the program (consistent funding source). (b) BMPs inspected a minimum of every 5 years (more often in recent years) and maintenance is conducted (c) PCO is tied into the NPDES Phase II stormwater permit for the Town, so any change to the PCO would have to go back to the state for approval. This is unique to Mecklenburg County. (d) Discussion regarding lessons learned from BMP maintenance program. Rusty stated that LID measures such as rain gardens tend to be clogged by fine particles and need maintenance. Something to watch in Goose Creek watershed as similar BMPs would be used in the watershed as development occurs. iv) Review of buffer program Rusty stated that mapping of streams that would qualify for buffers has been conducted using NC Division of Water Quality methodology so that the County is not reliant on developers to do their own mapping. v) John asked about floodplain protection in the watershed. Mecklenburg County has a strong program and has fairly recently updated mapping. Below is a link to the program and a map is being provided for reference. http://charmeck.org/stormwater/StormWaterAgencies/Pages/FloodplainMapping.aspx vi) Brief review of septic tank inspection program in the watershed. vii) John asked about variances to the PCO. Rusty stated that the variances are verbatim wording of the EMC Site Specific Plan. viii) Rusty mentioned the Creek ReLeaf program in the County and how the goal was to restore buffers. He hopes to expand the program into the Goose Creek watershed. http://charmeck.org/stormwater/VolunteerGetInvolved/Pages/CreekReLeafProgram.aspx 4) Why: Provide CMUD & Town of Mint Hill with ability to plan and make service decisions a) The Town of Mint Hill has met the intent of the Site Specific Water Quality Plan by implementing and enforcing its updated development ordinance. i) John asked about forestry activities in the watershed. Rusty was not aware of any specifically in the watershed. E480 ii) One component of the Plan is limiting ammonia. Rusty stated that ammonia is being monitored at the monitoring stations in the watershed and that no exceedences had been recorded to date. He stated how BMPs can reduce ammonia. iii) John mentioned how USFWS had requests for the Site Specific Plan that were not incorporated into the final document. These include: (a) Limiting water line construction through buffers (b) Limiting land development activities within the floodplain (c) Limiting water line construction through floodplains and stream crossings by boring lines beginning outside the floodplain (d) Believes 1 acre of development is too large of a trigger for ordinance enforcement b) Now mitigation is in place within the watershed, a key concern when Condition 3 was written into the IBT Certificate. c) Development plans within the watershed emerging with water needs met by private utility service or wells. i) Mark asked if any “where” information is available regarding where future water lines would go. While development patterns cannot be predicted, it is assumed that over time water lines would be extended down all the major roads in the watershed. 5) Other Discussion Discussion of the American eel. USFWS hopes that American eel can return to Goose Creek. It is a good host fish for mussels and USFWS would like to see it listed for protection. E481 Stand Alone Water and Wasterwater Stand Alone Wastewater System Stand Alone Water and Wasterwater Sources: Esri, DeLorme, NAVTEQ, TomTom, Intermap, iPC, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), and the GIS User Community Goose Creek Watershed Goose Creek Watershed Private Systems FEMA 100 year Floodplain Water Mains Distribution HydrantService Transmission 0 0.75 1.5 2.25 30.375 Miles I Mecklenburg County, NC Goose Creek Watershed E482 APPENDIX 3 Agency Comments Environmental Assessment - Addition of the Goose Creek Watershed to IBT Certificate Comment Author Comment Response EA Section 1 Natural Heritage Program, Andrea Leslie Applaud Mint Hill for enacting the Post-Construction Storm Water Ordinance but there will be more certainty of protecting the Carolina heelsplitter and other sensitive species if buffers are strengthened to (1) 200 feet on perennial streams and 100 feet on intermittent streams, (2) minimize the variances allowed from the buffer protection regulations, especially those allowing utility lines within the buffer and utility crossings over streams, and (3) widen the undisturbed buffer width for forestry activities and ensure that developers cannot use the forestry exemption to clear riparian vegetation before development.No action necessary.Sect 6.2 Remain concerned that SCI associated with higher density development could result in further degradation and possible extirpation of listed species in the Goose Creek watershed. Mitigation proposed aligns with Site Specific Water Quality Managment Plan. See Table Sect 6 Correction: Atlantic pigtoe is described in the EA as state threatened, but it is state endangered. As is Carolina creekshell. Correction made.Sect 3.3.3 See most recent description of Goose Creek Aquatic Habitat in the Union County Inventory. Reference added. Note that this project pertains only to the Mecklenburg County portion of the Goose Creek watershed. Sect 3.3.3 Referenced support of more detailed stormwater protection measures described in Wildlife Resources Commission comments See Comment 2.Sect 6.2 2 Wildlife Resources Commission, Shari Bryant WRC continues to remain concerned, as they commented during the review period for the Site Specific Plan in 2008, that some of the measures in the Site Specific Plan are not sufficient to protect the Carolina heelsplitter. We acknowledge this history associated with the Site Specific Plan. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.Sect 6.1, 6.2 More protective if developments that exceed a 6% built-upon area required control of stormwater than the current 10% built-upon area. At 6%, at minimum stormwater controls should treat 2-year, 24-hr storm or bankful event and provide adequate infiltration of stormwater. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.Sect 6.2 It is unclear whether removal of Condition 3 would allow not only water lines, but sewer lines as well. Significant concerns regarding the addition of sewer because significantly higher density development could occur than with water lines only. The focus of this EA is on the removal of Condition 3 which only addresses water service. Condition 3 does not limit sewer lines. General 100-year floodplain: Utility infrastructure should be kept out of the buffers and 100-year floodplain. No new fill or development in the 100-year floodplain. To the extent practical, CMUD's water utility infrastructure, if installed, would be kept ouf of the buffers and 100-year floodplain. Mecklenburg County has in place a strong flooplain protection program and fill and/or development within the 100-year floodplain are strictly limited. Sect 6.3 Page 1 of 4 E483 If condition 3 is removed, please understand that WRC will revisit issues concerning SCI on any future water or sewer projects in the watershed. We acknowledge that any future water or sewer line projects would be independently permitted. General 3 Division of Water Quality , Hannah Headrick SCI will negatively affect water quality. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.Sect 4 Yet to be proven if PCO will protect water quality. Existing water quality data have not shown improvements. As a result of the economic downturn, little development has occurred in the Town of Mint Hill since the Post Construction Ordinance was adopted. Mecklenburg County will continue its monitoring program and continue annual reporting.Sect 6.2 DWQ prefers that CMUD provide annual monitoring reports to show what it has been doing towards meeting the PCO plan goals. Include annual reports for past few years as part of document. Mecklenburg County conducts monitoring within the watershed. Annual reporting is conducted as part of the Goose Creek Fecal Coliform Recovery Program and data is included in Appendix A-1. Other water quality data are located in Appendix A-2, Mecklenburg County Water Quality Data.Sect 6.2 Document does not speak much to the rest of the Goose Creek watershed outside of Mint Hill that will experience growth because of increased water availability. This project is specific to the service area of CMUD and is entirely within Mecklenburg County. The entire Goose Creek watershed within Mecklenburg County is within the planning jurisdiction of the Town of Mint Hill. Figure 2 depicts these boundaries. This project does not include the portion of the watershed within Union County.General 4 Division of Water Quality Removal of Condition 3 is not a prudent course of action considering there is endangered species in the watershed. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.General Mooresville Regional Office 5 Aquifer Protection Section No Comment No action necessary. Mooresville Regional Office 6 U.S. Fish and Wildlife Service, Brian Cole The EA concludes that the effects of increased growth and development made possible by removal of Condition 3 will not be significant to the Carolina heelsplitter. We cannot agree with this conclusion. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.General Brian Cole Provided summary of recent surveys for the Carolina heelsplitter to document population decline and habitat degradation. USFWS conclusion: As a result of aquatic habitat degradation in the watershed, this population of Carolina heelsplitter is rapidly declining and is likely to become extirpated in the near future without implementation of adequate measures to prevent further aquatic habitat degradation and to restore the species' habitat. By inclusion of these comments in the complete final EA document, these survey results are acknowledged.Sect 3.3.3 Page 2 of 4 E484 We do not believe the Site Specific Plan (and hence the PCO) goes far enough to be protective of the Carolina heelsplitter. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.Sect 6 Land disturbance: We belive that requirements of the PCO should apply to any new clearing activity regardless of the size or type of disturbance (current rules apply for disturbances greater than or equal to 1 acre). Recommended requirements include (1) measures designed to replicate and maintain the pre-construction hydrograph and (2) measures to promote infiltration. Any stormwater measures should include a monitoring and maintenance plan. The Town of Mint Hill's Post Construction Ordinance is consistent with the Site Specific Plan regarding the 1-acre trigger and includes references to its Storm Water Design Manual, which includes requirements for operation and maintence of BMPs. The Town of Mint Hill accepts maintence responsibility following a 2- year warranty period. See Table 7. Sect 6.2 Buffers: We continue to recommend the requirement for maintenance or establishment and protection of undisturbed, forested buffers on each side of streams that are naturally vegetated that extend a minimum of 200 feet from the top of the banks of all perennial streams and a minimum of 100 feet from the top of the banks of all intermittent streams, or the full extent of the 100-year floodplain, whichever is greater. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules and exceeds the buffer delineation language of the Site Specific Plan. This results in better definition of intermittent streams in particular. See Table 7.Sect 6.2 Buffers: Disturbances which require maintained, cleared rights-of-way such as ditches or utility lines should not occur within the buffers. To the extent practical, CMUD's water utility infrastructure, if installed, would be kept ouf of the buffers and 100-year floodplain. Mecklenburg County has in place a strong flooplain protection program and fill and/or development within the 100-year floodplain are strictly limited. Sect 6.2 Buffers: The PCO should encourage the reestablishment of riparian buffers in areas where they are currently lacking and require the establishment of riparian buffers when changes in land uses occur. While not described in the Post Construction Ordinance, Mecklenburg County has begun a small buffer restoration program, planting trees within the defined buffers which currently are not forested. Public education programs regarding the benefits of buffers are also in place. Sect 6.2 Buffers: Too much potential for variances within the buffers. Recommend that no fill, no new impervious surfaces, or no creation of semi-pervious surfaces be allowed within the floodplain or the buffers and that the buffers remain undisturbed. Potentially allowable activities with the buffer are reviewed by the Storm Water Administrator and do require mitigation if approved. The Division of Water Quality has the authority to challenge a decision for a period of 30 days after issuance. Variance requests require a multi-level approval process including the Storm Water Administrator (Mecklenburg County), the Storm Water Advisory Committee, and the Director of the Division of Water Quality who then presents it to the Environmental Management Commission. The Environmental Management Commission ultimately makes a decision on a variance request, which is consistent with their rule-making process for the Site Specific Plan. Sect 6.2 Buffers: Variances should require mitigative measures. We would be happy to meet with or discuss buffer concerns in more detail. Section 305C(11) of the Post Construction Ordinance details the mitigation requirements for stream buffer impacts. Sect 6.2 Page 3 of 4 E485 Ammonia toxicity: Based on currently available information, we believe the achievement of 0.5 milligrams per liter or less of total ammonia on a chronic basis is reasonably likely to prevent death, harm, or injury to the Carolina heelsplitter. We recommend that the PCO outline measures that must be taken to ensure "toxicity to the Carolina heelsplitter" is likely to be prevented (instead of more after-the-fact as currently written). This should include monitoring and enforcement plans. Ammonia is monitored as part of Mecklenburg County's water quality monitoring program. The Post Construction Ordinance meets the requirements of the Site Specific Plan. We also recognize that ammonia toxicity is less likely to originate from stormwater sources and that it is an important component of Mecklenburg County's overall water quality monitoring program in the watershed. Point sources, the most likely source of elevated ammonia, are directly regulated by the Division of Water Quality.Sect 6.2 Forestry activities within buffers: Site Specific Plan allows for forestry activities including removing trees within the buffers. It is unclear if the PCO allows the same. This is inappropriate within the Goose Creek watershed and should include rules that do not permit forestry exemptions to be used for clearing prior to development activities. The Post Construction Ordinance includes language regarding vegetation management under Section 305(C)(9). Forestry activities including removing trees is generally not permitted. For example, removal of individual trees which are in danger of causing damage to dwellings, other structures or human life is permitted. Pruning is also permitted. Sect 6.2 We continue to note the need for a restoration component in (or to compliment) the PCO so that existing poor water quality is remediated. Mecklenburg County is currently in the planning stages of a significant restoration project within the watershed, partially within current County-owned property, as part of the County's Watershed Management Plan implementation.Sect 6.2 We believe that removal of Condition 3 will contribute to already degraded conditions and further compromised habitat in the Goose Creek system. The Site Specific Plan was adopted by the Environmental Management Commission, after consideration of input through a formal rule-making process, for the purposes of maintenance and recovery of the water quality conditions required to sustain and recover the Carolina heelsplitter species. The Town of Mint Hill's Post Construction Ordinance meets the requirements of the Plan included in EMC rules. See Table 7.General Page 4 of 4 E486