NCS000399_30 day response_20231003

,ate° --Qyc City of Jacksonville
f Public Services, Engineering Division
PO Box 128 •Jacksonville NC 28541-0128.910 938-5233
September 25, 2023
DEQ-DEMLR Stormwater ProgramwE®
Attn: Mr. Isaiah Reed 202�
1612 Mail Service Center
Raleigh, NC 27699-1612 DM�RStotmwe�Ptog _
RE: NPDES MS4 Permit No. NCS000399
Notice of Deficiency (NOD-2023-PC-0226)
Required NOD Response
Mr. Reed,
The City of Jacksonville acknowledges receipt of the Notice of Deficiency dated August 29,
2023. Please accept this correspondence as our response that is required within 30 calendar
days from the above referenced document. It is our intention to follow the procedures outlined
by the Notice of Deficiency and meet all requirements to ensure full compliance with the NPDES
MS4 Program.
The City of Jacksonville would like to provide clarification on two issues discussed in the audit
report.
1. The audit report states that Dr. Richard Woodruff is the Permit Owner of Record.
a. In accordance with the enclosed NPDES Stormwater Permit Summary report, the
current person legally responsible for the permit is Mr. Ronald F. Massey.
b. According to the enclosed NCDEQ Permit Owner Affiliation Designation Form
provided to my staff by your office, Mr. Massey is a "duly authorized
representative" of the City of Jacksonville which should qualify him as the Permit
Owner of Record.
c. The City of Jacksonville prefers that Mr. Massey remain the permit holder as
recorded. Mr. Massey serves as the designated representative on multiple State
permits including the City's water and wastewater permits. If you have additional
information available that would clarify that this position is not in accordance with
current rules or regulations, please advise.
2. The audit report states that the City of Jacksonville does not have an approved
Stormwater Management Plan.
a. The enclosed NPDES Permit No. NCS000399 does not clarify the proper
procedures required to obtain an approved Stormwater Management Plan. Upon
review of the NCDEQ MS4 website, the instructions provided suggest that a new
permit will not be issued until a SWMP has been approved.
b. The City of Jacksonville provided our Stormwater Management Plan to NCDEQ as
required when renewing our last permit period in 2017 and the City has provided
City Hall,815 New Bridge Street•910 938-52001 JacksonvilleNC.gov

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an updated document each year when submitting our yearly audit report. A new
permit was issued to the City of Jacksonville for the 2018 thru 2023 period. In
addition, the current City of Jacksonville SWMP can be found on the NCDEQ
Laserfiche repository.
To fully comply with the remaining instructions of the Notice of Deficiency, your office will
receive the required documentation within the times stipulated. Should you have any questions
or if I can be of further assistance, please contact Nicholas Lanier, Senior Civil Engineer, at
[phone].
Thank you,
Joshua W. Ray
City Manager
Enclosure: 2018 NPDES MS4 Permit
NPDES Stormwater Permit Summary
NCDEQ Permit Owner Affiliation Designation Form
cc: Nicholas Lanier, Senior Civil Engineer