20071580 Ver 1_Staff Comments_20080422

DWQ Project #07-1580
Subject: DWQ Project #07-1580
From: "Hal Owen & Associates Inc." <[e-mail]>
Date: Tue, 22 Apr 2008 11:21:06 -0400
To: "Ken Averitte" <[e-mail]>, "Cyndi Karoly" <cyndi. karoly@ncmai 1. net>,
<[e-mail]>, <[e-mail]>, <annette. lucas@ncmai 1. net>
CC: "James cothran" <[e-mail]>, "Kim Judge"
<[e-mail]>
Re: DWQ Project #07-1580
Royal Woods, Laurenwood, Princess Gate Developments
Moore County, NC
Applicant James Cothran, Dominion Development
Ian,
As you recommended the project engineer, Kim Judge, called Annette Lucas to discuss the stormwater
requirements. They discussed the stormwater requirements for HQW and Kim inquired about the
regulation that excludes wetlands from the impervious surface calculation. Annette directed her to
Water Quality Certification 3705 . Kim and I have read the WQC and don't see a calculation method or
reference that says to exclude wetlands from the impervious surface calculation. Condition 12 of the
certification says a Stormwater Management Plan is required if a drainage area is anticipated to have
24% or more impervious surface cover. So I checked the stormwater management regulations (T15A:
02H.1000) and a "drainage area" is defined as "the entire area contributing surface runoff to a single
point". These regs don't say exclude wetlands either. .l also looked in the 2B regs (wetlands and surface
waters) and can't find anything in it.
The only reference I have found for the exclusion of wetlands from the impervious surface area
calculation was an amendment to the coastal stormwater rules (15A NCAC 2H .1005) that was adopted
at the January 2008 meeting of the EMC
http://h2o.enr.state.nc.us/admin/emc/documents/JanuaryO8FinalMinutes.pdf. However, this project is
located in Moore County, which is not a coastal county.
DWQ forwarded a letter requesting additional information about this project on January 7, 2008. Kim
Judge says she communicated with you about the information requested on the maps, which we
forwarded in our response on February 13, 2008 more than 60 days ago. Currently, the impervious
surface calculation (including wetlands area) is 6% which is well below the 24% automatic threshhold in
the WQC. We believe we have met all of the conditions of WQC 3705 and satisfied DWQ's additional
information request from January. We ask that you not delay Mr. Cothran any further and issue the
wetland permit for this project.
Krissina Newcomb
Hal Owen & Associates, Inc.
PO Box 400, Lillington, NC 27546
PH [phone]/ FX 893-3594
www.halowensoil.com
Hal Owen <halowen(&,,earthlink.net>
Hal Owen & Associates, Inc.
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