NC0022098_Remission (Decision)_20230403

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ROY COOPER r ' '_,
Governor
ELIZABETH BISER v
Secretary
RICNARD E. ROGERS, JR. •Qa;,;,�i•
Director
NORTH CAROLINA
Environmental Quality
4/3/2023
CERTIFIED MAIL # 7019-1120-0001-4877-5447
Jake Krantz, Owner
Cranbrook Village MHP
Greensboro NC LLC 75
75 W. Towne Ridge Pkwy, Suite 201
Sandy, Utah 84070
Subject: Civil Penalties Decision for Case#MV-2023-0002
Cranbrook Village Mobile Home Park(MHP)
NPDES Permit NC0022098, WWTP, WPCS Grade-I
4309 Old Liberty Place, Greensboro
Guilford County
Mr. Krantz:
The Division of Water Resources (DWR or the Division)has considered your information(received January
30, 2023) submitted in support of your request to remit civil penalties in the subject case. In accordance
with NCGS 143-215.6A(f), the Division has found no cause to remit your initial penalties totaling $396.41
($275.00 plus $121.41 enforcement costs).
If you choose to pay the penalties, the Cranbrook Village WWTP (Cranbrook)please send payment to the
address provided below. Be sure to include the above case number on your check. Please make your check
payable to NCDEQ.
Your outstanding balance of$396.41 is now due and payable. Two options are available to yo
1) You may pay this balance.
If you decide to pay the penalty,please make your check payable to the Department of Environmental
Quality (DEQ) and send payment to:
Attention: Wren Thedford/Bob Sledge
NCDEQ/D WRNS WP S/NPDE S
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Your payment must be submitted within thirty(30) days of this letter in accordance with NCGS §143-
215.6A(f). If not received, your request for penalty remission(with its supporting documents), together
with DWR's recommendations,will be delivered to the North Carolina Environmental Management
Commission's (EMC's) Committee on Civil Penalty Remissions (the Committee) for final agency decision.
OR [option 2]

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2) If you desire to make an oral presentation to the Committee on why your request for remission meets
one or more of the five statutory factors you addressed, you must complete and return the enclosed
form(s)within thirty(30) days of receiving this letter. Please mail completed form(s)to:
Attention: Bob Sledge
NC DEQ/DWR/NPDES
1617 Mail Service Center
Raleigh,NC 27699-161
Your request for an oral presentation and supporting documents will be reviewed by the EMC Chairman
and, if it is determined that there is a compelling reason to require an oral presentation by you, the
Commission will notify you by certified mail of the date, time, and place for your oral presentation.
Otherwise, the final decision on your request for remission will be made by the Committee based on the
written record.
Thank you for your continued cooperation in this matter. If you have questions about this transmittal,please
contact my staff member, Joe R. Corporon, P.G. [e-mail]].
Sincerely,
E -
DocuSigned by:8328B44CE9EB4A1...
for Richard E. Rogers, Jr, Director
Enclosed/attached:
• Civil Penalty Remission Review Summary—signed, Case Number MV-2023-0002
• Request for Oral Presentation
ec: Enforcement File Case Number MV-2023-0002
Winston-Salem Regional Office(WSRO)
Laserfache

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STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GILFORD ) DEQ Case Number MV-2023-0002
IN THE MATTER OF ASSESSMENT OF
CIVIL PENALTIES AGAINST: ) REQUEST FOR ORAL PRESENTATION
Cranbrook Village Mobil Home Park(MHP) WWTP )
I hereby request to make an oral presentation before the Environmental Management Commission's
Committee on Civil Penalty Remissions in the matter of the case noted above. In making this request, I
assert that I understand all of the following statements:
• This request will be reviewed by the Chairman of the Environmental Management Commission
and may be either granted or denied.
• Making a presentation will require the presence of myself and/or my representative during a
committee meeting held in Raleigh,North Carolina.
• My presentation will be limited to discussion of issues and information submitted in my original
remission request,and because no factual issues are in dispute,my presentation will be limited to
five(5)minutes in length.
The North Carolina State Bar's Authorized Practice of Law Committee has ruled that the appearance in a
representative capacity at quasi-judicial hearings or proceedings is limited to lawyers who are active
members of the bar. Proceedings before the Committee on Remissions are quasi-judicial. You should
consider how you intend to present your case to the Committee in light of the State Bar's opinion and
whether anyone will be speaking in a representative capacity for you or a business or governmental
entity. If you or your representative would like to speak before the Committee, you must complete and
return this form within thirty (30) days of receipt of this letter.
Depending on your status as an individual,corporation,partnership or municipality,the State Bar's Opinion affects
how you may proceed with your oral presentation. See www.ncbar.com/ethics,Authorized Practice Advisory Opinion
2006-1 and 2007 Formal Ethics Opinion 3.
• If you are an individual or business owner and are granted an opportunity to make an oral presentation before the
Committee,then you do not need legal representation before the Committee;however,if you intend on having another
individual speak on your behalf regarding the factual situations,such as an expert,engineer or consultant,then you
must also be present at the meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of
law.
• If you are a corporation,partnership or municipality and are granted an opportunity to make an oral presentation before
the Committee,then your representative must consider the recent State Bar's Opinion and could be considered
practicing law without a license if he or she is not a licensed attorney.Presentation of facts by non-lawyers is
permissible.
If you choose to request an oral presentation,please make sure that signatures on the previously submitted Remission Request
form and this Oral Presentation Request form are: 1)for individuals and business owners,your own signature and 2)for
corporations,partnerships,and municipalities, signed by individuals who would not violate the State Bar's Opinion on the
unauthorized practice of law.
Also, be advised that the Committee on Civil Penalty Remissions may choose not to proceed with hearing your case if the
Committee is informed that a violation of the State Bar occurs.
This the day of ,20
SIGNATURE Printed with TITLE(President,Owner,etc.)

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ADDRESS

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DIVISION OF WATER RESOURCES
CIVIL PENALTY REMISSION FACTORS—Summary and Signature
Case Number: MV-2023-0002 Region: Winston-Salem County: Gilford
Assessed Entity: Cranbrook Village MHP Permit: NCO022098
Facility: Cranbrook Village WWTP
® (a) Whether one or more of the civil penalty assessment factors were wrongly applied to
the detriment of the petitioner:
The Permittee Asserts:
The late or missing Discharge Monitoring Report(DMR) for Cranbrook Village for the
month of June 2022 was for a period prior to Cranbrook Village MHP Greensboro NC, LLC
ownership. All DMR reports for dates prior to June 30,2022, are the obligation of T3T
Cranbrook LLC, a North Carolina limited liability company.
Attachments: 1)Warranty Deed(property Transfer dated 30Jun2O22); and 2)copy of the
issuance of Permit renewal NPDEX NCO022098 issued to T3T Cranbrook,LLC,dba
Cranbrook Village MHP at the time of the violations.
DWR Response:WSRO disagrees that the Permittee is not responsible for the violations
because the new ownership would have signed off on the June 2022 eDMR. Please note that
the ORC did not change during the property transfer.WSRO recommends no remission
because the eDMR was signed by the new ownership Cranbrook Village MHP Greensboro
NC,LLC.
❑ (b) Whether the violator promptly abated continuing environmental damage resulting
from the violation:
Not Asserted:
❑ (c) Whether the violation was inadvertent or a result of an accident:
Not Asserted:
❑ (d) Whether the violator had been assessed civil penalties for any previous violations:
Not Asserted.:
❑ (e) Whether payment of the civil penalty will prevent payment for the remaining
necessary remedial actions:
Not asserted.
NOTE: Blue X indicates factors addressed by the Permittee's written Request for Remission.
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Total Enforcement: $275.00 plus $121.41 costs=$396.41
DECISION(Check One)
Request Denied Y
Full Remission ❑ Retain Enforcement Cost? Yes No❑
Partial Remission ❑
Original Penalty(without Enforcement Costs) $275.00
Remit 0% $0.00
Subtotal $275.00
Retaining Enforcement Costs +$121.41
Total Penalty $396.41
DocuSigned by:
4/3/2023
18328B44CE9EB4Al..
for Richard E. Rogers, Jr. Date
CPA Summary(MV-2023-0002) [assessed 12Jan20231
DWR hereby makes the following Civil Penalty Assessment (CPA) against Cranbrook Village
MHP, Greensboro,NC LLC:
$275.00 for 11 of 11 violations for failure to properly monitor Temperature,water Deg.
Centigrade in violation of Permit No.NC0022098.
$0.0 for 0 of the 1 failures to submit monitoring reports or portions of monitoring reports in
violation of Permit No.NC0022098.
$275.00 TOTAL CIVIL PENALTY
$121.41 Enforcement Costs
$396.41 TOTAL AMOUNT DUE
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