NCS000335_SJAFB Comprehensive Watershed Protection Plan Cover Letter_20151011

Environmental
Quality
October 11, 2015
W. Dean Chastain, P.E.
Environmental Element Chief
4 CES/CEIE
1095 Peterson Ave
SJAFB, NC 27531
Dear Mr. Chastain;
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
The Comprehensive Watershed Protection Plan is approved by the State of North Carolina,
Department of Environmental Quality (DEQ) pursuant the Base's NPDES permit, NCS000335, with
the following changes.
1. The plan refers to Best management Practices (BMP). The state is moving toward the term
Stormwater Control Measure (SCM) to better describe structural stormwater control
measures. Often BMP is used to both describe structural stormwater control measures and
management measures and sometimes the BMP is not the BEST management practice.
2. The North Carolina Department of Environment and Natural Resources (NC DENR) has
been replaced with the Department of Environmental Quality (DEQ) to better describe the
programs administered by the Department.
3. Stormwater activities previously managed by Division of Water Quality (DWQ) have been
moved to the Department of Energy, Mining, and Land Resources Quality (DEMLR).
For items 1-3, the Base can simple acknowledge the terms and agency name changes on a cover sheet,
and attach it to the Comprehensive Watershed Protection Plan in lieu of changing all 400 plus
references to BMPs, DWQ, and DEQ.
4. Include in Comprehensive Watershed Protection Plan the following or similar language
regarding reducing or eliminating stormwater runoff.
The State encourages "volume matching" or "volume reduction" as an alternative to "treating"
stormwater runoff. A development is considered volume matching when the volume of
runoff leaving the site after development matches the volume of runoff before development.
DENR joined engineering consultants, NC State University, the University of North Carolina,
local governments, and the NC Coastal Federation in encouraging and promoting the
volume matching or volume reduction. Eliminating or reducing the volume of stormwater
runoff yields positive economic and environmental benefits and more closely mimic a site's
natural hydrology by disconnecting impervious surface areas and incorporating design
techniques that infiltrate, filter, store, evaporate and detain runoff close to its source. By
incorporating infiltration practices early into the design and construction phase of projects,
Nothing Compares!.
State of North Carolina I Environmental quality
1601 Mail Service CenterRaleigh, North Carolina 27699.1601
919-707-8600

infiltration practices can make efficient use of the surrounding landscape. When designed
appropriately and maintained it has been shown that eliminating or reducing the volume
stormwater runoff can reduce "hard" infrastructure costs, increase lot yields and enhance
water quality protection.
Sites that are designed to reduce or eliminate the volume of stormwater runoff may look
different from conventional sites in that the site typically has more vegetated areas
interspersed with roads, parking lots and buildings. These vegetated areas provide
landscaping for the site while also eliminating or reducing stormwater runoff. Other
stormwater practices may include permeable pavement, infiltration systems, rainwater
harvesting (cisterns), and green roofs. Another excellent SCM to eliminate or reduce
stormwater runoff is bio retention. Disconnected Impervious Surfaces" (DIS) provide
runoff reduction credit for simply sending runoff from built -upon areas to vegetated areas.
Under the State's Stormwater Programs, a development is considered compliant when the
volume of runoff leaving the site after development matches the volume of runoff before
development for a given storm event. When a site does not successfully match pre- and
post -development runoff volumes, than the site is compliant, when at a minimum, the
difference between pre- and post -development runoff in a stormwater control measure is
treated in an approved SCM. Sites can still benefit from using low impact fate stormwater
control measures even though they are not volume matching, in that any reduction in
stormwater runoff will reduce the size of the SCM needed.
5. Include in Comprehensive Watershed Protection Plan the following or similar language:
The Base encourages and promotes the use Stormwater Control Measures (SCM) that
eliminate or reduce stormwater runoff. Strategies that may eliminate or reduce stormwater
runoff include:
• Protecting natural resource areas (e.g., forests, prairies) and critical habitat (e.g.,
conservation corridors, buffer zones, wildlife preserves) from future development.
Protection of significant tracts of critical lands and wildlife habitat will aid in
protecting and improving water quality by increasing infiltration and groundwater
recharge, preventing erosion and contamination of ground water and surface water
resources, and protecting sources of drinking water.
• Buffers and other protective measures tools in place around wetlands, riparian
areas, lakes, rivers, estuaries and floodplains to improve/protect water quality. The
use of these practices will reduce pollutant loads and hydrologic alterations to water
bodies.
• Protecting trees and planting additional trees to enhance the tree canopy.
• Street design standards and engineering practices that encourage streets to be no
wider than is necessary to effectively move traffic, thereby reducing overall
imperviousness.
• Integrating green infrastructure practices as a standard part of construction,
maintenance, and improvement plans. Formally integrate green infrastructure into
standard roadway construction and retrofit practice. Projects to improve or repair
streets provide opportunities to include green infrastructure retrofits as part of
larger project budget, design and construction.

Where feasible, promote use of pervious materials for paving areas, including alleys, streets,
sidewalks, crosswalks, driveways and parking lots.
Require landscaping that help reduce stormwater runoff. Parking lots generate a large
amount of impervious cover. Requiring landscaping reduces stormwater runoff from
parking and can provide additional community benefits by providing shade and, if
appropriately placed, creating natural barriers between pedestrians and cars.
Ensure stormwater management plan reviews take place early in the development review
process. (Incorporate stormwater plan comments and review into the early stages of
development review/site plan review and approval, preferably at pre -application meetings
with developers). Pre -site plan review is an effective tool for discussing with developers
alternative approaches for meeting stormwater requirements. This can ensure that green
infrastructure is incorporated into new projects at early design stages, well before
construction begins.
Allow harvested rain water for non -potable uses, such as irrigation and non -potable interior
uses such as toilet flushing. Stormwater reuse is important for dense, urban areas with
limited spaces for vegetated green infrastructure practices.
The 2014 annual report on post -construction activities provided some information, i.e., Page 24 - as
of 2011 the base reduced the foot print by 69 acres since 2007 and has "credit" of 71.31 acres due
to additional demolition. In future annual reports, for each demolition project and/or added
projects that added impervious areas project, other than routine maintenance and improvement
projects that are under 5,000 s.f., please provide:
• Brief description of project
• Indicate if any state or federal permits were applied for and issued
• Receiving Stream name
• Total Drainage Area
• On -Site Drainage Area (so
• Offsite Drainage Area (so
• Proposed Impervious Area - new (sf)
• Proposed Impervious Area - removed for project
• Description of any BMPs
• Volume of runoff reduced
• Volume of runoff treated
• Total Impervious area for Base (2007)
• Total Impervious area for the Base (current)
• Total Credit for future development
Also in future annual reports, please identify:
• Natural resource areas (e.g., forests, prairies) and critical habitat (e.g., conservation
corridors, buffer zones, wildlife preserves) protected from future development.
• Buffers and other protective measures tools in place around wetlands, riparian areas, lakes,
rivers, estuaries and floodplains to improve/protect water quality.
• Where green infrastructure is being utilized including streets and roads, sidewalks,
crosswalks, driveways, parking lots, and retrofits.
• Where landscaping has reduced the stormwater runoff.
• Where harvested rain water is allowed for non -potable uses, such as irrigation and non -
potable interior uses such as toilet flushing.

If you have any questions, or need additional information concerning this matter, please contact me
at [phone]; or [e-mail].
Sincerely,
Original Signed by Mike Randall
Micheal f. Randall
ec: Samir Dumpor, P.E., Environmental Engineer
Division of Energy, Mineral, and Land Resources
Land Quality Section
Washington Regional Office