20071445 Ver 1_Emails_20071210

2007-1445 WIIm Beach Street Imps
Subject: 2007-1445 WIIm Beach Street Imps
From: Chad Coburn <[e-mail]>
Date: Mon, 10 Dec 2007 15:33:31 -0500
To: Ian McMillan <[e-mail]>
Ian,
I just read over the response to our (and USACE's) hold letters on this project.
They've eliminated the impacts associated with Spot Lane which decreases the impacts
from 1.452 down 0882 acres total.
In reference to their request to use approx 40 acres of coastal wetlands for
preservation, they say that it is possible to obtain a variance from the CRC and
the EMC to impact these wetlands, so therefore it's acceptable for that area to be
used as preservation. They're also stating that on site preservation is not
practicable for this site.
In reference to the SW plan that we requested - the response says that in the past
municipal funded projects haven't been held responsible for SW management from
adjacent properties. They say that this project is confined only to the roadway
construction and improvements. In conversations with Dan Sams of Land Quality here
in the WiRO, this project would qualify as a 'common plan of development'.
Projects under a common plan of development shall be considered as a single project
and shall require stormwater management in accordance with 15A NCAC 2H.1003. If
Land Quality requires an E&SC, then a State SW plan for the entire site will be
required as well.
One landowner "Wilmington Beach Investment Corp" owns approx 108 of the lots within
the development area according to New Hanover County GIS. Per my understanding of
a conversation with Jennifer Frye of USAGE, we need to get S&EC to identify who owns
each lot and show where on the map. Since this one owner has such a large portion
of the lots, wetland impacts not associated with the roadway construction and
improvements need to be considered. Jennifer also seems to have a problem with the
use of coastal wetlands as preservation.
These lots were apparently platted back in 1913. My guess is that this area has
not been developed since then for a reason. The majority of this area is wet and
would probably qualify as 404 wetlands according to Jennifer. She also mentioned
that the wetland map provided with the IP application has never been verified by
the USAGE. She mentioned that from her site visit, she did verify the areas
exclusive to the roadway construction and improvements, but not the lot areas.
Those areas shown on the map are incorrect and would need to be verified in the
future.
I'm unsure what direction I need to move in at this point. Should we ask that the
lot areas get a delineation and a JD to see what impacts may come in future
development of those 108 lots? It seems like a form of passive permitting to allow
those impacts associated with a possible large (108 lot) development.
Chad
1 oft 12/11/2007 10:38 AM

2007-1445 WIIm Beach Street Imps
Chad Coburn
Senior Environmental Specialist
NCDENR
Division of Water Quality
2 of 2 12/11/2007 10:38 AM