20051533 Ver 2_Complete File_20051018

Environmental Consultants, PA
Road • Raleigh, North Carolina 27614 • Phone: [phone] • Fax: [phone]
October 18, 2005
NCDENR-DWQ
Attn: Ms. Cyndi Karoly
.Z t}C?5
2321 Crabtree Blvd ?Jt 1.
Parkview Building «;,:; ,tv
Raleigh, NC 27604 ?40slukMIN
RE: Buffer Compliance Only (No Check Fee Required For Application)
Hyundai of Cary (Revision to previous Approved Plan, DWQ# 20051533)
Cary, Wake County, North Carolina
S&EC Project #: 9320.W1
Dear Ms. Karoly:
On behalf of Topaz Moon LLC, we are notifying DWQ of a revision to the previous
approved plan that complies with the Neuse Buffer Rules for impacts associated with
proposed stormwater utility lines. A Pre-construction Notification Application (PCN) is
attached, which includes an agent authorization form. The revision is for DWQ files only
and we do not believe that a new approval is needed since the only change involves
omitting a previously approved impact.
On 1/17/05, S&EC conducted a site evaluation of the tract. We determined that two
streams on-site are subject to the buffer rules. The project engineer (Piedmont Land
Design) has designed the stormwater outlet that impacts buffers in accordance with the
10/10/01 DWQ guidance document posted on your website. The previous buffer
approval was for 507 sq. ft. of buffer impact, the Zone 2 impacts have been removed so
that the actual impacts will be 352 sq. ft. This change is because the Town of Cary
previously required a level spreader following the stormwater wetland. After the
engineer brought it to the Towns' attention that the level spreader was not a DWQ
requirement the Town removed their requirement.
The purpose of this project is to construct a commercial project that will meet the demand
for car sales in the area. No wetland or stream impacts are proposed. Previously DWQ
approved 352 sq. ft. of impacts to Zone 1 of the Neuse Buffers for a stormwater outlet,
this impact will still occur. The site is approximately 8.5 acres in size and is located
north of Hwy 1, south of Hwy 64, east of MacKenan Road, and south of Old Raleigh
Charlotte Office: Greensboro Office:
236 LePhillip Court, Suite C 3817-E Lawndale Drive
Concord, NC 28025 Greensboro, NC 27455
Phone: [phone] Phone: [phone]
Fax: [phone] Fax: [phone]
October 18, 2005
S&EC Project #: 9320.W1
Page 2 of 2
Road. Grading in Zone 2 shown on plans for fill slopes will be re-vegetated and are
therefore exempt activities (these are not a part of this request but are shown for clarity).
Please refer to the attached map for the project's location on a USGS topographic
quadrangle.
Buffer Impacts
The applicant proposes a stormwater utility line that will impact a total of 352 sq. ft. of
Zone 1 of the Neuse Buffers. Because there are no stream or wetland impacts associated
with the proposed utility lines, only Buffer Compliance is required for this activity.
Similar projects designed in accordance with the 10/10/01 guidance have been routinely
approved by DWQ.
NC-DWQ's current policy requires written concurrence for stream impacts of greater or
equal to 150 linear feet of stream length per project. There are no wetland impacts and no
stream impacts proposed, however, we require buffer compliance for the project to cover
352 sq. ft. of impacts to Zone 1 of the Neuse Buffers. Because there are no impacts to
stream channels and no wetland impacts are proposed, we do not believe that wetland nor
stream mitigation should be required by NC-DWQ. Because this project does not
require 401 certification, we do not believe this project requires a DWQ approved
stormwater plan. Details adequate to show that the Neuse Buffer rules are being
complied with are included. We do not believe it is necessary for DWQ to re-approve
this plan since they only change is to remove the Town of Cary level spreader from the
stormwater wetland discharge. However, we do believe it is prudent for us to provide
DWQ with the revised plan for their files. Accordingly we do not believe it is necessary
for DWQ to reissue an approval letter and we plan to move forward with construction per
the previously approved plans, less the level spreader which followed the stormwater
wetland.
Please advise if we need to discuss this further.
Sincerely,
q(J'1Vt;U k-&4
Kevin Martin
President
Attachments:
Pre-construction (PCN) notification form
Site Location Map-USGS
Site Location Map - Soil Survey
Proposed Buffer Impact Maps (Overall, NB#l, and Inset NB#2)
Agent Authorization Form
Stormwater calculations and plan provided by project engineer
Office Use Only: Fonn Version March 05
USACE Action ID No. DWQ No.
(If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A".)
1. Processing
Check all of the approval(s) requested for this project:
? Section 404 Permit ® Riparian or Watershed Buffer Rules
? Section 10 Permit ? Isolated Wetland Permit from DWQ
? 401 Water Quality Certification ? Express 401 Water Quality Certification
2. Nationwide, Regional or General Permit Number(s) Requested: None
3. If this notification is solely a courtesy copy because written approval for the 401 Certification
is not required, check here:
4. If payment into the North Carolina Ecosystem Enhancement Program (NCEEP) is proposed
for mitigation of impacts, attach the acceptance letter from NCEEP, complete section VIII,
and check here: ?
5. If your project is located in any of North Carolina's twenty coastal counties (listed on page
4), and the project is within a North Carolina Di ement Area of
Environmental Concern (see the top of page 2 for fu?
11. Applicant Information IIJJ?? O C T 1 8 M5 J
DENR • WATER QUALITY
Owner/Applicant Information WETLMDsAND STORMWATER BRANCH
Name: Topaz Moon LLC
Mailing Address: Attn: C. David Johnson Jr.
5839 Capital Blvd.
Raleigh, NC 27616
Telephone Number: 919-876-5398 Fax Number:
E-mail Address:
2. Agent/Consultant Information (A signed and dated copy of the Agent Authorization letter
must be attached if the Agent has signatory authority for the owner/applicant.)
Name: Kevin Martin
Company Affiliation: Soil & Environmental Consultants, PA
Mailing Address: 11010 Raven Ridge Road
Raleigh NC 27614
Telephone Number: 919-846-5900 Fax Number: 919-846-9467
E-mail Address:_ KMartinASandEC.com
Pagel of 8
III. Project Information
5.
Attach a vicinity map clearly showing the location of the property with respect to local
landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property
boundaries and development plans in relation to surrounding properties. Both the vicinity map
and site plan must include a scale and north arrow. The specific footprints of all buildings,
impervious surfaces, or other facilities must be included. If possible, the maps and plans should
include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property
boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion,
so long as the property is clearly defined. For administrative and distribution purposes, the
USACE requires information to be submitted on sheets no larger than 11 by 17-inch format;
however, DWQ may accept paperwork of any size. DWQ prefers full-size construction
drawings rather than a sequential sheet version of the full-size plans. If full-size plans are
reduced to a small scale such that the final version is illegible, the applicant will be informed that
the project has been placed on hold until decipherable maps are provided.
1. Name of project: Hyundai of Cary
2. T.I.P. Project Number or State Project Number (NCDOT Only):
Property Identification Number (Tax PIN):
4. Location
County: Wake Nearest Town: Cary
Subdivision name (include phase/lot number):
Directions to site (include road numbers/names, landmarks, etc.):. South of Old Raleigh Rd.
and east of MacKenan Road Cary NC (see attached USGS map)
Site coordinates (For linear projects, such as a road or utility line,
separately lists the coordinates for each crossing of a distinct waterbody.)
Decimal Degrees (6 digits minimum): ON
attach a sheet that
ow
6. Property size (acres): 8.5 acres
7. Name of nearest receiving body of water: Williams Creek
8. River Basin: N
(Note - this must be one of North Carolina's seventeen designated major river basins. The
River Basin map is available at ham://h2o.enr.state.nc.us/admin/maps/.)
9. Describe the existing conditions on the site and general land use in the vicinity of the project
at the time of this application: Undeveloped wooded and cutover woodland and
commercial.
Page 2 of 8
10. Describe the overall project in detail, including the type of equipment to be used:
Construction of an auto dealership utilizing typical construction equipment.
11. Explain the purpose of the proposed work: Allow utilization of uplands for an automobile
dealership which complies with local and state stormwater ordinances.
IV. Prior Project History
If jurisdictional determinations and/or permits have been requested and/or obtained for this
project (including all prior phases of the same subdivision) in the past, please explain. Include
the USACE Action ID Number, DWQ Project Number, application date, and date permits and
certifications were issued or withdrawn. Provide photocopies of previously issued permits,
certifications or other useful information. Describe previously approved wetland, stream and
buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT project,
list and describe permits issued for prior segments of the same T.I.P. project, along with
construction schedules. A buffer approval was issued on 9/13/05 (DWQ# 20051533), however
at that time the Town of Cary required a level spreader after the stormwater wetland because
they did not understand that it was not required by DWQ policy. The Town now understands
DWQ's policy.
V. Future Project Plans
Are any future permit requests anticipated for this project? If so, describe the anticipated work,
and provide justification for the exclusion of this work from the current application.
None anticipated.
VI. Proposed Impacts to Waters of the United States/Waters of the State
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
wetlands, open water, and stream channels associated with the project. Each impact must be
listed separately in the tables below (e.g., culvert installation should be listed separately from
riprap dissipater pads). Be sure to indicate if an impact is temporary. All proposed impacts,
permanent and temporary, must be listed, and must be labeled and clearly identifiable on an
accompanying site plan. All wetlands and waters, and all streams (intermittent and perennial)
should be shown on a delineation map, whether or not impacts are proposed to these systems.
Wetland and stream evaluation and delineation forms should be included as appropriate.
Photographs may be included at the applicant's discretion. If this proposed impact is strictly for
wetland or stream mitigation, list and describe the impact in Section VIII below. If additional
space is needed for listing or description, please attach a separate sheet.
1. Provide a written description of the proposed impacts: Impacts to buffers are required for a
stormwater treatment facility outlet.
Page 3 of 8
2. Individually list wetland impacts. Types of impacts include, but are not limited to
mechanized clearing, grading, fill, excavation, flooding, ditching/drainage, etc. For dams,
separately list impacts due to both structure and flooding.
Wetland Impact
Site Number
(indicate on map)
Type of Impact Type of Wetland
(e.g., forested, marsh,
herbaceous, bog, etc.) Located within
100-year
Floodplain
(yes/no) Distance to
Nearest
Stream
(linear feet) Area of
Impact
(acres)

Total Wetland Impact (acres) None
3. List the total acreage (estimated) of all existing wetlands on the property: Unknown
4. Individually list all intermittent and perennial stream impacts. Be sure to identify temporary
impacts. Stream impacts include, but are not limited to placement of fill or culverts, dam
construction, flooding, relocation, stabilization activities (e.g., cement walls, rip-rap, crib
walls, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is proposed,
plans and profiles showing the linear footprint for both the original and relocated streams
must be included. To calculate acreage, multi ly length X width, then divide by 43,560.
Stream Impact
Number
(indicate on ma)
Stream Name
Type of Impact Perennial or
Intermittent? Average
Stream Width
Before Impact Impact
Length
(linear feet) Area of
Impact
(acres)

Total Stream Impact (by length and acreage) None None
5. Individually list all open water impacts (including lakes, ponds, estuaries, sounds, Atlantic
Ocean and any other water of the U.S.). Open water impacts include, but are not limited to
fill, excavation, dredging, flooding, drainage, bulkheads, etc.
Open Water Impact
Site Number
(indicate on ma) Name of Waterbody
(if applicable)
Type of Impact Type of Waterbody
(lake, pond, estuary, sound, bay,
ocean, etc.) Area of
Impact
(acres)

Total Open Water Impact (acres) None
Page 4 of 8
6. List the cumulative impact to all Waters of the U.S. resulting from the project:
Stream Impact (acres): 0
Wetland Impact (acres): 0
Open Water Impact (acres): 0
Total Impact to Waters of the U.S. (acres) 0
Total Stream Impact (linear feet): 0
7. Isolated Waters
Do any isolated waters exist on the property? ? Yes ® No
Describe all impacts to isolated waters, and include the type of water (wetland or stream) and
the size of the proposed impact (acres or linear feet). Please note that this section only
applies to waters that have specifically been determined to be isolated by the USACE.
8. Pond Creation
If construction of a pond is proposed, associated wetland and stream impacts should be
included above in the wetland and stream impact sections. Also, the proposed pond should
be described here and illustrated on any maps included with this application.
Pond to be created in (check all that apply): ? uplands ? stream ? wetlands
Describe the method of construction (e.g., dam/embankment, excavation, installation of
draw-down valve or spillway, etc.):
Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond,
local stormwater requirement, etc.):
Current land use in the vicinity of the pond:
Size of watershed draining to pond: Expected pond surface area:
VII. Impact Justification (Avoidance and Minimization)
Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide
information related to site constraints such as topography, building ordinances, accessibility, and
financial viability of the project. The applicant may attach drawings of alternative, lower-impact
site layouts, and explain why these design options were not feasible. Also discuss how impacts
were minimized once the desired site plan was developed. If applicable, discuss construction
techniques to be followed during construction to reduce impacts. Impacts to buffers for the
outlet are the only proposed project impacts. All others are avoided or exempt activities
VIII. Mitigation
DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC
Division of Water Quality for projects involving greater than or equal to one acre of impacts to
freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial
streams.
Page 5 of 8
USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide
Permits, published in the Federal Register on January 15, 2002, mitigation will be required when
necessary to ensure that adverse effects to the aquatic environment are minimal. Factors
including size and type of proposed impact and function and relative value of the impacted
aquatic resource will be considered in determining acceptability of appropriate and practicable
mitigation as proposed. Examples of mitigation that may be appropriate and practicable include,
but are not limited to: reducing the size of the project; establishing and maintaining wetland
and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of
aquatic resource functions and values by creating, restoring, enhancing, or preserving similar
functions and values, preferable in the same watershed.
If mitigation is required for this project, a copy of the mitigation plan must be attached in order
for USACE or DWQ to consider the application complete for processing. Any application
lacking a required mitigation plan or NCEEP concurrence shall be placed on hold as incomplete.
An applicant may also choose to review the current guidelines for stream restoration in DWQ's
Draft Technical Guide for Stream Work in North Carolina, available at
http://h2o.enr.state.nc.us/ncwetiands/stnngide.html.
1. Provide a brief description of the proposed mitigation plan. The description should provide
as much information as possible, including, but not limited to: site location (attach directions
and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet)
of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view,
preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a
description of the current site conditions and proposed method of construction. Please attach
a separate sheet if more space is needed.
No mitigation should be required.
2. Mitigation may also be made by payment into the North Carolina Ecosystem Enhancement
Program (NCEEP). Please note it is the applicant's responsibility to contact the NCEEP at
[phone] to determine availability, and written approval from the NCEEP indicating
that- they are will to accept payment for the mitigation must be attached to this form. For
additional information regarding the application process for the NCEEP, check the NCEEP
website at http://h2o.enr.state.nc.us/wrp/index.htm. If use of the NCEEP is proposed, please
check the appropriate box on page five and provide the following information:
Amount of stream mitigation requested (linear feet): 0
Amount of buffer mitigation requested (square feet): 0
Amount of Riparian wetland mitigation requested (acres): 0
Amount of Non-riparian wetland mitigation requested (acres): 0
Amount of Coastal wetland mitigation requested (acres): 0
Page 6 of 8
IX.
X.
Environmental Documentation (required by DWQ)
1. Does the project involve an expenditure of public (federal/state/local) funds or the use of
public (federal/state) land? Yes ? No
2. If yes, does the project require preparation of an environmental document pursuant to the
requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)?
Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA
coordinator at [phone] to review current thresholds for environmental documentation.
Yes ? No ?
3. If yes, has the document review been finalized by the State Clearinghouse? If so, please
attach a copy of the NEPA or SEPA final approval letter. Yes ? No ?
Proposed Impacts on Riparian and Watershed Buffers (required by DWQ)
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
required state and local buffers associated with the project. The applicant must also provide
justification for these impacts in Section VII above. All proposed impacts must be listed herein,
and must be clearly identifiable on the accompanying site plan. All buffers must be shown on a
map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ
Regional Office may be included as appropriate. Photographs may also be included at the
applicant's discretion.
1. Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233
(Neuse), 15A NCAC 213.0259 (Tar-Pamlico), 15A NCAC 0213.0243 (Catawba) 15A NCAC
2B .0250 (Randleman Rules and Water Supply Buffer Requirements), or other (please
identify )? Yes ® No ?
2. If "yes", identify the square feet and acreage of impact to each zone of the riparian buffers.
If buffer mitigation is required calculate the required amount of mitigation by applying the
buffer multipliers.
Zone* Impact
(square feet) Multiplier Required
Mitigation
1 352 3 (2 for Catawba) 0
2 0 1.5 0
Total 352 0
* Zone 1 extends out 30 feet perpendicular from the top of the near bank of channel; Zone 2 extends an
additional 20 feet from the edge of Zone 1.
3. If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e.,
Donation of Property, Riparian Buffer Restoration / Enhancement, or Payment into the
Riparian Buffer Restoration Fund). Please attach all appropriate information as identified
within 15A NCAC 2B .0242 or .0244, or .0260. None required
Page 7 of 8
XI. Stormwater (required by DWQ)
Describe impervious acreage (existing and proposed) versus total acreage on the site. Discuss
stormwater controls proposed in order to protect surface waters and wetlands downstream from
the property. If percent impervious surface exceeds 20%, please provide calculations
demonstrating total proposed impervious level. Please see attached plans by Piedmont Land
Design.
XII. Sewage Disposal (required by DWQ)
Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of
wastewater generated from the proposed project, or available capacity of the subject facility.
Municipal.
XIII. Violations (required by DWQ)
Is this site in violation of DWQ Wetland Rules (15A NCAC 2H .0500) or any Buffer Rules?
Yes ? No
Is this an after-the-fact permit application? Yes ? No
XIV. Cumulative Impacts (required by DWQ)
Will this project (based on past and reasonably anticipated future impacts) result in additional
development, which could impact nearby downstream water quality? Yes ? No
If yes, please submit a qualitative or quantitative cumulative impact analysis in accordance with
the most recent North Carolina Division of Water Quality policy posted on our website at
http://h2o.enr.state.nc.us/ncwetlands. If no, please provide a short narrative description:
XV. Other Circumstances (Optional):
It is the applicant's responsibility to submit the application sufficiently in advance of desired
construction dates to allow processing time for these permits. However, an applicant may
choose to list constraints associated with construction or sequencing that may impose limits on
work schedules (e.g., draw-down schedules for lakes, dates associated with Endangered and
Threatened Species, accessibility problems, or other issues outside of the applicant's control).
The project engineer has prepared the design consistent with DWQ Draft Stormwater BMP
desian criteria.
(Agent's signature is valid only if an authorization letter from the applicant is provided.)
Page 8 of 8
08/09/2005 09:47 9198457703 PIEDMONT LAND DESIGN
.I
AGENT AUTHORIZATION FORM
All Blanks To Be ked In By The Current Landowner
Name: -Topaz Moon,
Owner'.
Address: 5839 Capital Boulevard
-Raleigh, North Carolina 27616
Phone: ,(919) 876 -
Project Name/ Description: _Hyundai of Cry
Date. _August 6, 2005
The Department of the Army
U.S. Army Corps of Engineers, Wfmingtdn! District
P.O. Box 1890
S&EC Project # 9320.W1
Wilmington, NC 28402
Attn: `Todd Tugwe
Field Office: Raleigh
Re. Wetlands Related Consulting and Pe7m. tting
To Whom It May Concern:
1, the current RroRgW owner, hereby desj?nlate and authorize Soil & Environmental Consultants, PA to
act in my behalf as my agent in the processing of permit applications, to furnish upon r uest
supplemental information in support of applications, etc. from this day forward. The day of
This notification supersedes any previous correspondence concerning the agent for this project
NOTICE: This authorization, for liabI14 and professional courtesy reasons, is valid only for
goverment officials to eater the prope w
rtyhen accompanied by S&EC staff. You should call S&EC
to arrange a site meeting prior to visitingl the site.
_C. David Johnson, Jr.
Print Property Owner's Name
cc: Ms. Cyndi Karoly
NCDENR - DWQ
2321 Crabtree Boulevard
Raleigh, NC 27604
PAGE 03/03
rte. 4
cc: )GIr. Kevin Martin
Soil & Environmental Consultants, PA
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Cary, Wake County, NC [phone] • [phone]
Wake County Soil Survey Web Page: www.SandEC.com
Sheet 66
08/09/2005 09:47 9198457703 PIEDMONT LAND DESIGN PAGE 02/03
DWQ Project
DIVISION OF WATER QUALITY -
I. PROJECT INFORMATION (please complete
Project Name : yJMA&gJ/ OA-
Contact Person: J/,?CW_ 121541091g
For projects with multiple basins, specify which basi
Permanent Pool Elevation 347.
Temporary Pool Elevation 34
Permanent Pool Surface Area
Drainage Area
Impervious Area
Forebay Surface Area
Marsh 0"-9" Surface Area
Marsh 9"-18" Surface Area
Micro Pool Surface Area
Temporary Pool Volume
SA/DA used
Diameter of Orifice
II. REQUIRED ITEMS CHECKLIST
sq. ft. (water surface area at permanent pool elevation)
ac. (on-site and off-site drainage to the basin)
ac. (on-site and off-site drainage to the basin)
sq. ft. (at permanent pool elevation approximately 15%)"
sq, ft. (at permanent pool elevation approximately 35%)"
sq, ft. (at permanent pool elevation approximately 350/9)"
sq. ft. (at permanent pool elevation approximately 15%)`
cu. ft. (volume detained on top of the permanent pool)
(surface area to drainage area ratio)* 62.77 126Q
?+D)
in. (draw down orifice diameter)
Initial in the space provided to indicate the following : deisign requirements have been met and supporting documentation is attached, ff a
requirement has not been met, attach an explane of why. At a minimum, a complete stormwater management plan submittal includes
a worksheet for each BMP, design calculations, pas and specifications showing all BMPs and outlet structure details, a detailed
drainage plan and a fully executed operation and mt!r enance agreement. An incomplete submittal package will result In a request for
additional information and will substantially delay final review and approval of the project
lip r" The temporary pool controls
The basin side slopes are no
A planting plan for the marsh
Vegetation above the permar
An emergency drain is provid
The temporary pool draws do
Sediment storage is provided
r A sediment disposal area is p
??? j' Access is provided for mainte
'r A site specific, signed and nol
A The drainage area (including
j' Access is provided for mainte
???' plan details for the wetland ar
_Plan details for the inlet and o
- A site specific operation and main)
httpJ/h2o.ehnr.state.nc.t
" Pocket Wetlands have different design parameters
Stormwater BMP Manual, Ap611999.10% open wate
NDED DETENTION (and POCKET*) WETLAND WORKSHEET
following information):
Phone Number: (7M) 6 5- 7C=16
worksheet applies to:
ft. (elevation of the orifice invert out)
ft (elevation of the outlet structure invert In)
off from the 1 Inch rain.
eper than 3:1.
as with plant species and densities is provided,
pool elevation is specified.
to drain the basin,
in 2 to 5 days,
he permanent pool,
idad. &PA•Si TX' 417 !S^344 044 147
ad operation and maintenance agreement is provided.
offshe area) is delineated on a site plan.
t are provided,
nce agreement, signed and notarized by the responsible party Is provided (see
cwetiands/oandm.doc).
are only assumed to remove 35% TSS - See pp. 19 and 20 of the NC DENR
„ J% high marsh, 40% low mars,
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