NCS000400_Response to public comments_20240820

Response to Comments received during the May
M 2024 through June 30, 2024 Public
Comment Period for NCS000400.
Thank you to everyone who submitted comments concerning the NCS000400 renewal process.
Many of the comments received were for similar concerns, so many of the below responses will
apply to multiple comments received.

Part 1
Jamestown was audited by the North Carolina Department of Environmental Quality(NCDEQ)
Division of Energy, Mineral and Land Resources (DEMLR) on June 7, 2023 to determine
compliance with their Municipal Separate Storm Sewer System(MS4)permit. At that time, the
program was found to be deficient in meeting all permit requirements. The renewal of their MS4
permit does not constitute an approval of the Towns past administration of their program. The
permit renewal, and creation/approval of the associated Stormwater Management Plan(SWMP)
is the first step in the Town's process to bring their program into compliance with the permit.
The measurable goals outlined in the SWMP are a required component which are designed to
map out the steps the town will be taking over the next permit cycle to correct their program.
While comments and concerns related to the MS4 program in the past are appreciated, the Town
has already been found deficient of meeting all permit requirements and the renewal of the MS4
permit is focused only on future implementation of the program.
Part 2
As long as a permit renewal application is submitted to NCDEQ at least 180 days prior to permit
expiration, permit coverage under the previous permit continues until renewal. The renewal
application was received on July 6, 2021. Permit expiration occurred on February 19, 2022. As
such, permit coverage continued until permit renewal. Jamestown has not been operating without
permit coverage.
Part 3
All MS4s are required to "Maintain adequate funding and staffing"of their program to maintain
compliance. How the municipalities obtain that funding is not determined by their MS4 permit
and is not incorporated into any permit requirement. This applies to all financial matters to do
with the Town's budget.
Part 4
The compliance audits and reviews conducted by NCDEQ's MS4 Program do not determine
compliance with any approved TMDL or the components and monitoring requirements therein.
However,part 3.8 of the MS4 Permit will be a required component of Jamestown's program and
annual reports moving forward into the next permit cycle. This includes requirements for TMDL
information in the annual report, and an explanation of where/how the program is or may be
better implemented to reflect those requirements.

Part 5
The comments submitted relating to concerns about currently issued industrial stormwater
permits is greatly appreciated. However,NCDEQ is the permit issuing authority concerning
General Industrial Stormwater Permits issued to Industrial facilities, not Jamestown. These
concerns will be forwarded to the appropriate regional office.
Part 6
Comments related to page numbers and formatting are greatly appreciated and will be corrected
through a requirement to modify the stormwater management plan as soon as possible.
Part 7
There was some confusion about the existence of an ETJ for Jamestown. Accordingly, the permit
has been corrected.
Please let me know if you have any questions,
Thank you for your time and for relaying your concerns to the Department.
Isaiah Reed,MS4 Program Coordinator