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HomeMy WebLinkAbout19890057 Ver 1_Complete File_19890101ORIGINAL TO ALAN KLIMEK ? -`` COPY TO DENNIS RAMSE?' M AY 0 9 i 89 State of North Carolina ly- ,;1 aLIIY SECTIO?1. Department of Natural Resources and Community(-DEW I'opn Qll?a(,?4 Wii111ington Regional Office James G. Martin, Governor Bob Jamieson William W Cobey, Jr., Secretary Regional N1ana0 DIVISION OF ENVIRONMENTAL MANAGEMENT May 2, 1989 Ms. Carole Robinson Onslow County Environmental Action Network ?' }fir; ` rt4 Route 1, Box 339B Sneads Ferry, North Carolina 28460 PAY ? 1989 Subject: Wyndham Towers "A TER • TY Onslow County SEC loj? Dear Ms. Robinson: The Wilmington Regional office has reviewed your letter dated April 10, 1989 addressed to Mr. Paul Wilms, Director of the Division of Environmental Management, in regards to Wyndham Towers. As Water Quality Regional Supervisor, "I will attempt to respond to your concerns as they relate to the Wyndham Towers project. The Onslow County Environmental Action Network's concern for the protection of coastal environment is shared by this Division and the Environmental Management Commission. The Stormwater Management Plan for Wyndham Towers was received by the Wilmington Regional Office on November 16, 1988. On December 19, 1988, a Determination of Compliance was issued by this office certifying that the Plan complied with the Stormwater Regulations set forth in Title 15 NCAC 2H. 1003(a)(2). Mr. Jim Kennedy, Environmental Scientist of the North Carolina Coastal Federation, did bring a concern to the attention of the Division that warranted a reevaluation of the Stormwater Management Plan. Mr. Kennedy's concern was the procedure the Division utilized in calculating the overall project density. The Wyndham Towers project was perhaps the first project reviewed by the Division where two stream classifications, SB and SA waters, influenced the density requirements of the Stormwater Management Plan. The Division recognized that densities should be calculated based upon drainage areas and their respective stream classification. Based upon this determination, the Division rescinded the Determination of Compliance on March 16, 1989. 7225 Wrightwille Avenue, Wilmington, N.C. 28403-3696 • Telephone 919-2564161 An Equal Opportunity Affirmative Action Employer S Ms. Carole Robinson May 2, 1989 Page Two The Stormwater Management Plan was revised and resubmitted to the Division on March 17, 1989. Following a careful review of the Plan, a Certification of Compliance was issued April li, 1989. All densities with respect to stream classification, SB and SA waters, and the areas within close proximity to waters nominated for Outstanding Resource Waters (ORW) comply with Title 15 NCAC 2H. 1000 et. seq. Non-Discharge Permit No. WQ0000990 was issued January 31, 1989 to North Topsail Water and Sewer, Inc. to serve the Wyndham Towers project. The collection sewers and lift station were reviewed by the Permits and Engineering Unit and the proposed design was found to be in accordance with Title 15 NCAC 2H. 0200 et. seq. The Wilmington Regional Office recommended approval of the Non-Discharge Permit on January 4, 1989 baset? upon the compliance status and remaining hydraulic capacity of North Topsail Water and Sewer's wastewater treatment and disposal facility. The Wilmington Regional office received the LAMA application for the Wyndham Towers project on December 19, 1988. On February 14, 1989, the Division requested that the Developer, Century 21 By the Sea, provide an alternate proposal which would eliminate or reduce wetland filling or provide an explanation of why such reductions were not possible. On April 3, 1989 the Division received plans indicating no wetland filling, draining or crossings. Following a careful review, the Wilmington Regional Office recommended approval of the CAMA Permit to the Operations Branch in the Central Office. On April 25, 1989, the Division of Environmental Management stated no objections to the Wyndham Towers project in a memorandum to the Division of Coastal Management. Although the Onslow County Land Use Plan may have more or less stringent requirements than the Division's rules, our requirements would govern the conclusions we reach. The preceding areas of involvement between the Division of Environmental Management and the Wyndham Towers project have been reviewed and approved in accordance with current rules and regulations of the Environmental Management Commission. In conclusion, let me reemphasize that the Division of Environmental Management does share your concerns, and we will continue to exercise our statutory and regulatory authority to protect the waters of the State. N. S. l.aL'U_LU tCU1J.L11SU11 May 2, 1989 Page Three If you have any questions concerning this matter, please contact me at 919/256-4161. Sincerely, Donald Safrit i ' Water Quality Regional Supervisor DS:trw cc: Paul Wilms Steve Tedder WiRO, CF Please Copy Need _L- Copies Copies To: yeyti/S Original: ???? El Return to. ? File under: Post-it'" copy request pad 7670 a r DIVISION OF ENVIRONMENTAL MANAGEMENT Water Quality Section April 25, 1989 M E M O R A N D U M TO: John Parker FROM: Bill Mills SUBJECT: Application for CAMA Permit The Towers/Century 21 By the Sea Onslow County The Subject application has been reviewed for water quality impacts and the following comments are offered: a. The proposed project will not require a 401 Water Quality Certification. b. The proposed project should be conducted in such a way as to not cause turbidity outside of the immediate construction area to exceed 25 NTU. C. The revised stormwater plan was approved on April 11, 1989. (copy attached) We have no objection to the proposed project. BM/dbp cc: Preston Howard MEMORANDUM DIVISION OF ENVIRONMENTAL MANAGE14ENT Date: April 6, 1989 To: Bill Mills Operations Branch From: James H. Gregson S--tic. Wilmington Regional Office Through: Donald Safric ee -' Wilmington Regional Office f1 D Subject: Regional Office Review and Recommendations Application for Permit for Excavation and/or Fill Project # The Towers/Century 21 by the Sea/Dennis K. Mercer Onslow County PROJECT DESCRIPTION: The applicants propose to construct two 15 story condominium buildings. ADJACENT WATER BODY: Atlantic Ocean/Stump Sound CLASSIFICATION: SB/SA The project has been reviewed to determine impacts to water quality. The following comments have been provided. 1. As per the attatched letter dated March 31, 1989 from Dennis K. Mercer, no wetland filling, draining or crossings are proposed. 1. The project will not require a 401 Water Quality certification. 3. The proposed project should be done in such a way as to not cause the turbidity outside the immediate construction are to exceed 25 NTU. 4. The stormwater management plan approved on December 19, 1988 was rescinded. No problem is foreseen in the new plans submitted. This office has no objection to the project as proposed. JHG:trw cc: DCM - James L. Mercer WiRO, CF y 1 r ' BY THE SEA Box 3000 North Topsail Shores Sncads Ferry, North Carolina 28160 (919) 328-0302 March 31, 1989 Mr. Jim Gregson Division of Environmental Management NCDNRCD 7225 Wrightsville Ave. Wilmington, NC 28403-3696 Re: Wyndham Towers wetlands Dear Mr. Gregson; ,: '? APR `;fi!-•ir.?tc;n f'egi;:n?'1 r-?trt?a Wyndham Towers condominium project, developed by Century 21 By The Sea by John N. Starling, will not contain any wetland filling, no wetland dredging, no wetland crossings nor any other type of land disturbing activity in any type of wetlands, including Corps "404", CAMA Coastal Wetlands, and "401 Permit" wetlands. Sincerely, Dennis K. Mercer, Landscape Architect 9ifector of Planning, Design & Development incl. 3 maps t? r v Each Office Is Independently Owned And Operated Please type or print. Carefully describe all an- ticipated development activities, including construc- tion, excavation, filling, paving, land clearing, and stormwater control. If the requested information is not relevant to your project, write N/A (not ap- plicable). Items 1-4 and 8-9 must be completed for all projects. d. Describe the planned use of the project. Residential development 4 LAND AND WATER ° CHARACTERISTICS' 1 APPLICANT a. b. a. Name Century 21 By The Sea c, Address Box 3000 N. Topsail Shores City Sneads Ferry State NC d. Zip 28460 Payphone 919-328-0302 Landowner or Authorized agent e. b. Project name (if any) The Towers . f. c. If the applicant is not the landowner, also give the owner's name and address. g. a {. 2 LOCATION -OF PROPOSED f >;- PROJECT .`' r . h. a. Street address or secondary road number i. . NC 210 b. City, town, community, or landmark c. County Onslow d. Is proposed work within city limits or planning jurisdiction? Onslow County Planning e. Name of body of water nearest project Alligator Bay/Stump Sound/Atlantic Ocean 3 DESCRIPTION AND, PLANNED USE OF PROPOSED.-PROJECT ' , Size of entire tract 12. 2.3 -acres Size of individual lot(s) _12.23 acres Elevation of tract above mean sea level or Na- tional Geodetic Vertical Datum ayg. 88.5 Soil type(s) and texture(s) of tract Sand to Vegetation on tractmvrtle,,yaupon-yurra beachgrass ma shelder.live oak.sea oats Man-made features now on tractol d abandoned roads (NC 210 & SR 1568) & over poles What is the CAMA Land Use Plan Classifica- tion of the site? (Consult the local land use plan.) High Density Conservation XR Transitional Developed Community Rural Other How is the tract zoned by local government? Exist, R-20 & B-2, proposed CU-R-8 How are adjacent waters classified? SA Has a professional archaeological survey been carried out for the tract? No If so, by whom? `UPLAND DEVELOPMENT "; '' Complete this section if the project includes any upland development. a. Type and number of buildings, facilities, or structures proposed (2) 52 unit, 15 story residential condominiums = 104 until b. a. Describe all development activities you propose c. (for example, building a home, motel, marina, bulkhead, or pier). Construct (2) 15 story condominium d. buildings with 52 units/b ildin_g and parking and site -amenities e. If you plan to build a marina, also complete and attach Form DCM-MP-2. b. Is the proposed activity maintenance of an ex- isting project, new work, or both? New construction c. Will the project be for community, private, or commercial use? Private Residential ?n ?i Number of lots or parcels 1 parcel Density (Give the number of residential units and the units per acre.) 104 units/12, 23 acr. = 8.78 units/acre Size of area to be graded or disturbed approx. If the proposed project will disturb more than one acre of land, the Division of Land Resources must receive an erosion and sedimen- tation control plan at least 30 days before land disturbing activity begins. If applicable, has a sedimentation and erosion control plan been submitted to the Division of Land Resources? Yes Give the percentage of the tract within 75 feet of mean high water to be covered by im- permeable surfaces, such as pavement, buildings, or rooftops. Approx. 1.27 cp . road g. List the materials, such as marl, paver stone, asphalt, or concrete, to be used for paved surfaces. Asphalt, concrete and _turfstone h. If applicable, has a stormwater management plan been submitted to the Division of En- vironmental Management? YEs i. Describe proposed sewage disposal and/or waste water treatment facilities. Sewer service furnished by North Topsail Water and Sewer. Inc. j. Have these facilities received state or local approval? Yes k. Describe existing treatment facilities. N. Topsail Water & Seer, Inc. sewage treatment plant and spray fields, NC 210. Sneads Ferry. NC 28460 1. Describe location and type of discharges to waters of the state (for example surface runoff, sanitary wastewater, industrial/commercial effluent, or "wash down"). Pool discharge & sto mwat ono into 404 wetlands per D.E.M. regiln ions m. Water supply source Onsl ow County n. If the project is oceanfront development, describe the steps that will be taken to main- tain established public beach accessways or pro- vide new access. Public a ss to be mitaged in area. o. If the project is on the oceanfront, what will be the elevation above mean sea level of the first habitable floor? Approx. 22.5 16 EXCAVATIC TAND :FILL' 3 , LNl'OL?1Vlt7?` I;ROt?! d a. Describe below the purpose of proposed excava- tion or fill activities (excluding bulkheads, which are covered in Section 7). • Length Width Depth Access channel (MLW) or (NWL) Boat basin Other (break- water, pier, boat ramp, rock jetty) Fill placed in wetland or below Upland fill areas NA NA NA +' . NA SSA NA NA NA NA 160' 40' No b. Amount of material to be excavated from below water level in cubic yards None c. Type of material NA d. Does the area to be excavated include marsh- land, swamps, or other wetlands? Na e. High ground excavation, in cubic yards None f. Dimensions of spoil disposal area NA g. Location of spoil disposal area NA Ii. Do you claim title to the disposal area? NA If not, attach a letter granting permission from the owner. i. Will a disposal area be available for future maintenance?/ NA If so, where? j. Does the disposal area include any marshland, swamoland,'or water areas? No k. Will the fill material be placed below mean high water? No 1. Amount of fill in -cubic yards Approx, 370 cy m. Type of fill material" sandy-Loam n. Source of fill material TG1 and o. Will fill material be placed on marsh or other wetlands? Yes, Wetlands not marsh p. Dimensions of the wetland to be filled 40' x 190' q. How will excavated or fill material be kept on site and erosion controlled? Berms, Silt Fences and staged construction r. What type of construction equipment will be used (for example, dragline, backhoe, or hydraulic dredge)? None for excavation, bulldozer for fill s. Will wetlands be crossed in transporting equip-. ment to the project site? No If yes, explain the steps that will be taken to lessen en- vironmental impacts. 7 SHORELINE STABILIA`I`IOI a. Length of bulkhead or riprap None b. Average distance waterward of mean high water or normal water level NA c. Shoreline erosion during preceding 12 months, in feet 2.0 feet/year average d. Type of bulkhead material None e. Amount of fill, in cubic yards, to be placed below mean high water None -? r'Tnf iiiI material NA ;d 1 8 ADDITION' '.-'INFORMATION; In addition to the completed application form, the following items must be submitted: yr? A copy of the deed (with state application only) or other instrument under which the applicant claims title to the affected property. If the applicant is not claiming to be the owner of said property, then for- ward a copy of the deed or other instrument under which the owner claims title, plus written permis- sion from the owner to carry out the project. An accurate work plat (including plan view and cross sectional drawings) drawn to scale in black ink on 8 V2 x 11 white paper. (Refer to Coastal Resources Commission Rule 7J.0203 for a detailed description.) Please note that original drawings arc preferred and only high quality copies will be accepted. Blue-line prints or other larger plats are acceptable only if 16 high quality copies are provided by the applicant. (Contact the U.S. Army Corps of Engineers regard- ing that agency's use of larger drawings.) A site or location map is a part of plat requirements and it must be sufficiently detailed to guide agency per- sonnel unfamiliar with the area to the site. Include county road (SR) numbers, landmarks, and the like. A stormwater management plan, if applicable, that may have been developed in consultation with the Division of Environmental Management. A list of the names and complete addresses of the adjacent waterfront (riparian) landowners. These individuals have 30 days in which to submit com- ments on the proposed project to the Division of Coastal Management. The applicant must advise the adjacent landowners of this opportunity by sen- ding a copy of the permit application to them by registered or certified mail. This notification is re- quirYed by G.S. 113-229(d). Name ?F. Roger Page Address P.O. Box 15047 Winston-Salem, NC 27113 Name Address Name _ Address A list of previous state or federal permits issued for work on the project tract. Include permit numbers, permittee, and issuing dates. None 77Z 7 A check for $100 made payable to the Depart- ment of Natural Resources and Community Development to cover the costs of processing the application. A signed AEC hazard notice for projects in ocean- front and inlet areas. A statement on the use of public funds. If the project involves the expenditure of public funds, at- tach a statement documenting compliance with the North Carolina Environmental Policy Act (N.C.G.S. 113A-1 to 10). VA, Any permit issued in response to this application will allow only the development described in the application. The project will be subject to condi- tions and restrictions contained in the permit. I certify that to the best of my knowledge, the pro- posed activity complies with the State of North Carolina's approved Coastal Management Program and will be conducted in a manner consistent with such program. I further certify that I am authorized to grant, and do in fact, grant permission to representatives of state and federal review agencies to enter on the aforementioned lands in connection with evaluating information related to this permit ap- plication and follow-up monitoring of project. 9 This, Usthc Ifilh day ct Oct ber or Authoriz Send e completed application mat ria s to the Dtrisfon of Coastal Management Offi nearest you and the U.S. Army Corps of Engineers. See the map on the inside front cover for the appropriate DCM office and addresses and phone number. DIVISION OF COASTAL MANAGEMENT *Lat:34129124"N FIELD INVESTIGATION REPORT Long:7702513411W 1. APPLICANT'S NAME The Towers/Century-21 By-The-Sea/Dennis K. Mercer 2. LOCATION OF PROJECT SITE West Onslow Beach, Atlantic Ocean, at intersection of Hwy. 210 & 1568, Onslow County; *SEE 1984 AERIAL PHOTOS, STRIP #25, FRAME 4274 @ P-16; 1978 AERIAL PHOTOS, STRIP 422, FRAME #103 @ C-11 3. INVESTIGATION TYPE: DREDGE & FILL 4. INVESTIGATIVE PROCEDURE: (A) DATES OF SITE VISIT 10-28-88 (B) WAS APPLICANT PRESENT YES NO 5. PROCESSING PROCEDURE: APPLICATION RECEIVED November 18, 1988 OFFICE Morehead City Onslow County 6. SITE DESCRIPTION: (A) LOCAL LAND USE PLAN 1986 Update Transition - High LAND CLASSIFICATION FROM LUP Density/Conservation DEVELOPMENT CONSTRAINTS IDENTIFIED IN LUP SEE CAMA SECTION (B) AEC(S) INVOLVED: OCEAN HAZARD X ESTUARINE SHORELINE COASTAL WETLANDS X PUBLIC TRUST WATERS ESTUARINE WATERS OTHER (C) WATER DEPENDENT: YES NO X (CONDOMINIUM) (D) INTENDED USE: PUBLIC PRIVATE COMMERCIAL X (E) TYPE OF WASTE WATER TREATMENT: EXISTING NONE PLANNED North Topsail Water & Sewer Service, Inc. (F) TYPE OF STRUCTURES: EXISTING NONE PLANNED twin 15 story condo buildings; 52 units each plus amenities DCM Ocean Erosion (G) ESTIMATED ANNUAL RATE OF EROSION 2' SOURCE Rate Maps 7. HABITAT DESCRIPTION: (A) VEGETATED WETLANDS Section 404 giant cordgrass salt meadow hay salt bushes (B) NON-VEGETATED WETLANDS: NONE (C) OTHER: highground - beach l.u,uuu sq.=z cut & grade 6.4 ac. (D) TOTAL AREA DISTURBED: Approximatelv 6.5 ac. out of 12.2 ac. AREA DREDGED FILLED OTHER CAMA X (ONLY) 12-7-88 * USGS 7.5 MIN TOPO 'SPICER BAY' N.C. PP. 1971 FIELD INVi IGATION REPORT - THE TOWERS/CENTURY-21 BY-THE-SEA/ DENNIS K. MERCER, ONSLOW COUNTY PAGE 42 8. PROJI. ? SUMMARY: The applicant proposes to construct two 15 stor}? -.ondominium buildings, with 52 units each, plus parking lots _th tennis courts, swimming pools, and other amen:i -es. 9. NARRI- =VE DESCRIPTION: The 12 acre project site is located on P7e:_ Onslow Beach, just south of the Highway 210 Bridge, over :--ump Sound, and in Alligator Bay, at the intersection of SR 1568 leading to North Topsail Island. The property averac-?2s 800' deep from Hwy. 210 to the Atlantic Ocean where the sl-.oreline length equals 6001. There are several noteworthy physical features to the property. A series of frontal dunes, backed by a ridge of primary dunes, occupies the first 120' nearest the beach. The interior of the property is relatively flat, altered by the o_.d abandoned roadbed to Hwy. 210 and some pre-construction grading activities. On the north side of the property, adjacent to Hwy. 210 and SR 1568, there are two eXtinct pockets of Section 404 wetlands flagged by the corps of Engineers Field Representative. The marsh pocket that adjoins SR 1568 has also been designated a Coastal Wetlands Area of Environmental Concern by the Division of Coastal Management. The onsite field inspection revealed that concrete culvert pipe under SR 1568 communicates abnormally high tidal waters from Alligator Bay to this other,ise isolated marsh area. The 'SA' surface waters of Stump Sound and Alligator Bay are part of the recently G c?,it outstanding resource waters by the Division of no?c.nafed Envir-_ nmental Management. The E_:plicant, Century-21 By-The-Sea, is represented by the corps ate President, Mr. John N. Starling, Jr., and the Land: ape Architect, Mr. Dennis K. Mercer. The project has been amed "The Towers", and for the most part, development on t?. west side of the property will mirror its twin on the east ide. The project plans show that all construction, exce; for a pair of pedestrian accessways, will be located land. rd of the CAMA 120' Ocean Erodible recession line. This osition also puts the development landward of the prim y dune line with maximum elevations of 22' and 23'. In c = to protect and enhance the integrity of the dune line three areas of repair have been identified. Over the yea: pedestrian and vehicular traffic have worn pathways in dunes which make the dune line more susceptible to W_ erosion, and possible wave overwash during storm co; ions. The three areas will be filled with similar match existing contours, and the slopes will be FIELD INVESTIGATION REPORT - THE TOWERS/CENTURY-21 BY-THE-SEA/ DENNIS K. MERCER, ONSLOW COUNTY PAGE #3 planted with beach grass. Landward of the CAMA 120' recession line is the 100 year storm recession line equal to an additional 140' which compliments the total 260' of the Ocean Erodible Area of Environmental Concern. It is in this 140' area that the developers plan to locate the twin towers with parking garages. Each of the 15 story condominium buildings will measure about 120' long x 60' wide with a footprint value of 7,200 sq. ft. On the south side of the buildings, construction will include extensive terraces or patios that will connect pedestrian traffic with the main swimming pool and the structural accessways leading to the open beach. Forward of the proposed terrace, the developers will cut and grade a pair of stormwater retention ponds labeled on the workplat drawing as Basin A'and B. On the north side of the twin towers, a series of driveways will connect the open parking lots and covered garages with the main entrances to the buildings. A pair of croquet lawns and fountains will provide green space as visitors arrive at the main gate located on Hwy. 210. Each of the partially enclosed parking garages will measure about 200' long x 100' wide with a combined footprint value of about 40,000 sq. ft. The total surface area of the outdoor parking lots will equal approximately 2 acres. Adjacent to Hwy. 210 there is a long finger of Section 404 wetlands averaging about 150' wide. In order to gain access to the oceanfront property, this marsh area must be bridged. The deeded dimensions of the property preclude access from an alternate direction. According to the project design, 2400 sq. ft. of wetlands will be filled in connecting the bridge abutment to the rotary driveway. The proposed one-lane bridge will measure about 30' wide x 120' long. Another finger of 1404' wetlands measuring about 190' long x 40' wide must be filled in order to complete the main driveway. These wetland areas are dominated by salt bushes, waxed myrtles, bay trees, salt meadow hay and giant cordgrass. The wetlands are elevated and near the upper limits of their living space. The developers Sedimentation and Erosion Control Plan calls for two additional retention ponds shown as Basins C and D next to the proposed entrance road. These ponds will be shaped from the highground adjacent to the wetlands flagged by the COE. 10. ANTICIPATED IMPACTS: The proposed project will enhance the stability of the frontal and primary dune line by restoring the three scoured pathways leading across the sensitive 120' FIELD INVESTIGATION REPORT - THE TOWERS/CENTURY-21 BY-THE-SEA/ DENNIS K. MERCER, ONSLOW COUNTY PAGE #4 Ocean Erodible AEC. Landward of this first recession line, the project will intensify with the construction of two condominium buildings, parking lots, garages and patios. This will generate an impervious surface area of approximately 30% of the total 12.2 acres. However, only 6.5 acres of actual land disturbance can be anticipated. The land disturbance will include four sizeable stormwater retention ponds, two of which could be sprigged with plant species conducive to the 1404' environment. This could increase the nutrient uptake capabilities of the retention ponds, and also, add a replacement value to the bio-mass for those wetlands loss in the road construction. A calculated 7,600 sq. ft. of 1404' type wetlands dominated by salt bushes and waxed myrtles, will be displaced by the entrance road. The proposed bridge crossing will involve the additional loss of some 2400 sq. ft. of '404' wetlands where the abutments meets the highground. The actual 30' wide bridge crossing the 120' pocket marsh should have no significant impact on the ecology of this closed system. LAMA REVIEW: The 1986 Updated Land Use Plan for Onslow County was consulted in the review of The Towers project. The Land Classification Map has designated the project site, along with the majority of West Onslow Beach, as 'Transition' with a sub-classification of 'High Density'. The definition found on Page 494,of the LUP indicates that these areas are experiencing rapid growth and are serviced by municipal water and sewer services. The Ocean Hazard AEC within the 260' jurisdictional boundary is generically classified as 'Conservation'. Proposed construction in these conservation areas appear to be compatible with the CAMA Use Standards. In addition, no development constraints were identified in the review of this Land Use Plan, and therefore, the project appears to be consistent with the goals and objectives of that document. PREPARED BY: JAMES L. MERCER DATE: DECEMBER 15, 1988 ' y f .: ? ttf.JyyV,, k, •k r'?'tY??Y?ky ?7,}l J j } r rr onII`l?4{?f r t•!{t_ \ ,!{'•.r l? , ?r - 111 f"? I •I ?. 4(r'? r- r- L- 1 I is I? II - fill" ?? 1= I' I? I! C II i1 I! r ? ? I. 1 1 I 1= If IE ?: ! ?? ?,?, 4?}. °',??.?C`J?+, +??`?'d??.\?•4 A1V III ?k „ J. II Co ou n o N ,?, U V) C'I ' M S co" N i?N N wowoQ u 1-x-4 i+S OO M M ? o >r E 1 !r v '? you_ + O p y U `v E-y ? . .D p v . z ?v corn z o .2 C) I o ?, Q ?• i i E vn a u v ? 1T II ? t •I "?• ?1 1 . AIL I rl I 1? 1, • II I 1/.1 ?0 I ? trf 4h I, ,,, tt JOPP r S ? f ' V) o E Z 3 N w s 1b 0 E w i ?C> 00 ?00 U o ? \ ? y s o ? o mo ? 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II 10 ` II I ' ? -?; I '? t ? ` f= ! ? tr u u 18 a I: ?r y ! _ SS (? ? K i¦ is ?: 1 i S ?-. ?_• - if ~li ?i J= I; (_ - 1= !f l- !? : 1 1 s . k°?k ? ?r titt ? a ? { ?_f ? ?.-..? c. ? 1ti .:,Yl r "? ?•;, r.S V. r 2n { 1 1 Y } }' ?vl`3J ;? ? J (? {tr i.1 r}yt" / y r 11 1 '° ! F --.? a MW Y ilk: } yt `!t. ¢r Y t Y d ?:Y% ? ? i {YI r• `1? f !1 ??? 1 } 9t i^j 1 II 1 1 1W }? y 1' % 1 r R ja- li?ij Tt L' Nil 147x- _ ..1 - •.1, ??? #?? -.? i ?' s Ili }r? •. t ' ylt :. BY THE SEA Box 3000 North Topsail Shores Sneads Ferry, North Carolina 28460 (919) 328-0302 March 31, 1989 James L. Mercer, Field Representative III N.C. Dept. of Nat. Resources & Community Dev. Office of Coastal Management Marine Fisheries Building, Room 106 P.O. Box 769, 3411 Arendall Street Morehead City, NC 28557 Re: Proposed "Wyndham Towers" Condominiums C.A.M.A. Major Permit Dear Jim; d •; 11 APR 0 5 U ?G.?i ?rr?r r s rr r r r----- -••-- ApR A 21959 t V Llv SEC, Oll r OPERATION, ,•?•. am re-submitting Minor revisions of the abovementioned plan. In the previous revision dated March 17th, 1989, the most important change was the addition of 3.58 acres of oceanfront land 200 feet wide. The Total Project area is now at 17.86 acres with the same as original 104 units. The density has decreased from 7.28 unitstacre to 5.82 units/acre. The total Built-Upon Area of the entire project calculates at ±18.95%; the Built-Upon Area for the watershed draining to "SA" waters is +24.95%; and the Built-Upon Area for the watershed within 575' of Nominated Outstanding Resource Waters calculates at ±19.4%. According to our previous revision date March 171h, and consistant with today's revision, no wetlands crossing will be made, no wetlands filling will be done; and no wetland dredging will be done. All the changes enclosed herein reflect the final plans of changes that were requested by DEM Water Quality Section for the Stormwater Permit from a field meeting that took place on the site on March 301h, 1989. Plans submitted to DEM are identical to both the Master Site Plan and Topographic Plan that I am sending you. I am enclosing Twenty (20) copies each of the "Master Site Plan" and "Topographic Plan" for your use. Let me know if you need anything else. Thanks Jim. Sincerely, ?,_i Dennis K. Mercer, Landscape Architect Director of Planning & Design _... .. I _ - ? • _J /1_.....I.-A MEMORANDUM : TO : , JOHIT _ PARKER FROM: JAMES L. MERCE SUBJECT: MINOR MODIFICATI - CAMA PERMIT REQUEST - CENTURY 21 BY-THE-SEA - PROPOSED "WYNDHAM TOWERS" CONDOMINIUMS, ONSLOW COUNTY DATE: APRIL 10, 1989 Mr. Dennis Mercer has generated a final set of revised drawings, labeled 1L1' and 'L41, dated March 30, 1989. Although Mr. Mercer's cover letter is self-explanatory, it is important to note that the revised plans focus on DEM's stormwater concerns relative to the 575' ORW designation. The revisions are consistent with other most recent project changes submitted by Century 21 where the proposed project involves no wetlands crossing, no filling, and no dredging. These latest blueline drawings should be reviewed by the appropriate agencies and also used for distribution should a permit be issued. JLM/dh Enclosures cc: Charles S. Jones Cliff Winefordner, COE t NOTICE OF FILING OF APPLICATION FOR CAMA MAJOR DEVELOPMENT PERMIT AND WATER QUALITY CERTIFICATION The Department of Natural Resources and Community L' eve iopment hereby yivt--s pu:)iic 1tJi il.c by :'•CGS 113A-119(b) and 143-215 3(a)(1)(c) that The Towers/Century 21 By-The-Sea, of Onslow Ccwnty, filed a revised application on February 3, 1989, for a permit from the Division of Coastal Management to develop in an Area of Environmental Concern and for certification from the Division of Environmental Management that a discharge of fill material in project wetlands will not violate applicable water quality standards. According to said application, the applicant has revised his --- --permit application in order to relocate the entrance way for the condominium complex to a newly acquired tract of land immediately adjacent to the proposed condominiums site at the Hwy. 210 and SR 1568 intersection, Topsail Island, Onslow County. A copy of the entire application and additional information may be examined (or copies furnished upon request and payment of reproduction costs) during normal business hours at the office of Jim Mercer, Division of Coastal Management, located in the Division of Marine Fisheries Building, Morehead City, N.C., 919/725-7021, at--%:/or the office of L reston Howard, Div` .-,ioi. of Environmental Management, NRCD Regional Field Office, Wilmington, N.C., 919/256-4161. The Division of Environmental Management proposes to take final action on this water quality certification on or before March 24, 1989. The issuance of the CAMA Major Development permit and the Section 401 Certification may deviate from this projected date depending upon the nature of the comments submitted and subsequent hearings that may result. All persons desiring to make comments should do so in writing to Dr. George Everett, Director, Division of Coastal Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to March 14, 1989 for consideration in the CAMA permit decision, and to Mr. Bill Mills, Division of Environmental Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to March 14, 1989 for consideration in the water quality certification decision. Later comments on the CAMA application will be accepted and considered up to the time of permit decision. Project modifications may occur based on review and comment by the public and state and federal agencies. Notice of the permit decision in this matter will be provided upon request. PUBLISHED ON: Monday, February 27, 1989 NOTICE OF FILING OF APPLICATION FOR CAMA MAJOR DEVELOPMENT PERMIT AND WATER QUALITY CERTIFICATION The Department of Natural Resources and Community Development h:.reby gives public notice as required by NCGS 113A-li9(b) and 143-215 3(a)(1)(c) that The Towers/Century 21 By-The-Sea/Dennis K. Mercer, of Onslow County, filed an application.on November 18, 1988, for a permit from the Division of Coastal Management to develop in an Area of Environmental Concern and for certification from the Division of Environmental Management that a discharge of fill material in project wetlands will not violate applicable water quality standards. According to said application, the applicant is proposing to construct two 15-story condominium buildings with 52 units each, plus parking lots, tennis courts, swimming pools and other amenities at West Onslow Beach, at the Hwy. 210 and SR 1568 intersection, Onslow County. A copy of the entire application and additional information may be examined (or copies furnished upon request and payment of reproduction costs) during normal business hours at the office of Jim Mercer, Division of Coastal Management, located in the Division of Marine Fisheries Building, Morehead City, N.C., 919/726-7021, and/or the office of Preston Howard, Division of Environmental Management, NRCD Regional Field Office, Wi1:-.ington, N.C., 919/256-4161. The Division of Environmental Management proposes to take final action on this water quality certification on or before February 4, 1989. The issuance of the LAMA Major Development permit and the Section 401 Certification may deviate from this projected date depending upon the nature of the comments submitted and subsequent hearings that may result. All persons desiring to make comments should do so in writing to Mr. David Owens, Director, Division of Coastal Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to January 24, 1989 for consideration in the LAMA permit decision, and to Mr. Bill Mills, Division of Environmental Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to January 24, 1989 for consideration in the water quality certification decision. Later comments on the CAMA application will be accepted and considered up to the time of permit decision. Project modifications may occur based on review and comment by the public and state and federal agencies. Notice of the permit decision in this matter will be provided upon request. PUBLISHED ON: Monday, January 9, 1989 _a r? f •., v State of North Carolina Department of Natural Resources and Community Development Wilmington Regional Office James G. Martin, Governor Bob Jamieson William W Cobey, Jr., Secretary Regional Nlana,,er DIVISION OF ENVIRONMENTAL MANAGEMENT February 14, 1989 Mr. Dennis K. Mercer Century 21 By the Sea Box 3000, N. Topsail Shores Sneads Ferry, NC 28460 Subject: Proposed Wetland Fill The Towers Onslow County Dear Mr. Mercer: The Wilmington Regional Office received your CAMA application on December 19, 1988. A preliminary review indicates that a 401 Water Quality Certification will be required from our division due to the proposed wetland fill. A 401 certification is required prior to issuance of a LAMA or 404 permit. Because of the many essential functions wetlands provide, including purification of surface and groundwater, any loss of wetlands as the result of filling activities is viewed by this office as degradation of water quality, and potentially, a loss of these essential functions wetlands provide. Your project, as proposed, will result in the loss of wetland areas. As a result, this office is requesting the following additional information. be submitted within 30 days upon receipt of this letter: an alternate proposal that will eliminate or reduce the proposed fill in wetland areas; or submit an explanation of why such reductions are not possible and what mitigating factors we should consider to insure no net loss of wetlands within the project area. ItiECEIVED FFR 2 ?. 13089 t'??jFp"'-?? QUALITY SECTION 7225 Wrightn?illc rlvcnue, V'iimin;;on, N.C. 28403-3696 • 'Telephone,)'- {II NS 9?,ar! 1., F. I ( L.n, nim n Alft"'no"". A, rU , F'-l....... v P• r • _ Mr. Dennis K. Mercer Page 2 Until this office receives your response, your proposal for a 401 Certification will be considered incomplete. Should you have any questions concerning this matter, please contact Jim Gregson, Donald Safrit or me at (919) 256-4161. Sincerely, A. Preston Howard, Jr., P.E. Regional Supervisor APH:JG:cwc cc: Bill Mills Chuck Wakild Jim Herstine Charles Hollis John Parker WiRO, CF n ALBERTO J. QUAYAT 1 WILD CAT COVE WAYNESBORO VA 22900 March 21,1989 Mr. Bill Mills Division of Environmental Management P.O.Box 27687 Raleigh NC 27611 Dear Mr. Mills, (703)942-3445 t"I AR _? 8 i'?P'9 t`MAtir Re.-Twin Towers, West Onslow Beach, Onslow County NC Ifollow my letter of March 10,1989 with the following com- ments on the Re.project. DRAINAGE.- I enclose map of property showing impervious surfaces in light brown and wetlands in light blue. A plain vue at this map makes it quite evident that the im- pervious surfaces ar considerably more that the 25% claimed by the applicant. I suggest that as a metter of fact every single statement by the applicant should be verified and double checked. It looks to me the applicant has erroneously included as part of the pervious surfaces the wetlands within the property. These lands are the habitat of extensive flora and fauna and should not be allowed to be the sewage tank of the contamina- ted runoff that will kill wildlife. Those that do not know or do not want to know should be remembered that nature placed these wetlands to balance the ecological system and assure its existence. FILL.- The property present soil-undeveloped-may have the proper perviousness?ut since the applicant intents to add substantial fill such fill may not,in all likelyhood,have the properties of the existing soil and therefore the claimed perviousness becomes unsubstantiated and untrue. Accepted professional practice suggests that prior to a fill operation all organic matter should be removed,that is,all existing vegetatiom. Vegetation covered by fill will turn into rotten material that will cave in and structurally en- danger whatever is above it and constitute a life hazard. r -2- Twin Towers Pest Onslow Beach Onslow County ne GENERAL CONSIDERATIONS.-The purpose of your office is to assure the environment is protected.You do not deal with the safety of people. The function of Onslow County is to examine and approve building drawings,inspect and approve construction as it progresses and upon completion isscc.!:!'the final certificate of occupancy. Included in the above is the enforcement of the North Carolina Building Code and other applicable building regulations. Past experience indicates that inspection by county officials at the beach is lax at best if it does exist at all. In the presentation/brochure to the county planning board and the board of commissioners the applicant does not submit enough information on fire exits nor the all important rise/ tread ratio in the exit stairs. Not a single word is mentioned about the type of structural frame,exterior walls construction or materialsato be used that in case of fire may be smoke ge- nerating andvtremendous damger to the elderly most probably living in these buildings. Of particular concern should be the mechanics of-h6 evacuation process in an emergency. With thousands of living units in Rt.210 and SR 1568 the vehicular traffic at tnis road junction will be monumental. It will be impossible for everybody to leave the beach to save their lives,thousands will be trapped and very many will drown. No exception will be elderly in this project trying to reach their cars in bottlenecked park- ing lots and try to merge into the traffic from the northern part of the island. And let alone the vehicles coming from Rt 210 also trying to reach the highrise bridge and out. The state has no jurisdiction on safety. It is left to the county,with an absolete and unrealistic emergency planning that basically tellsthe people leave on time,reach high land when the county does not even have its: own topographic map and the instructions cannot be read with a magnifying glass. This overpopulated and overburdened island is left in 'he hands of greedy developers and functionally illiterate idiots that make up the local government. The hope of people is on you. I strongly recommend this pro- ject be rejected. Please keep me posted on forthcoming hearings. Sincerely Encl. map C C' ?5rr'sr2 ?I J<L5; ARCHITECT NY LIC. No. 13063 NC LIC. No. 3243 ?I L Q I° a u ° pw? ??uL d xII,Q:I ?, 11 . `? Q V 3 4 3 r j : =ALL la r II. ( /. 4J%0 J Il Y15 ?.;? 1,?? l?r\'l?,ll 1 -EFi `` [' ?iV R'?.? {^-?---- ?CI IIU • 1. /J ? tV= 1 ? 2 < I ?j??)t u r 1 .1 • I C u ? ? ? ? ?i I. S ? 1m I- ly Q ,?11 . •J? ?Av .9 ? fir;-- `cf ?vl •v? Esc - - --- ? ' Y 1 ' ,I In 1 J rp t • h- )) ? :1 i = ? '- ? I _ . ._ _? _ -i r fvl ?P lr S( j'i -? ¦ raq,uts 9/ I ? ??. "I _ Sll/,n X-1 _ j I 1 1 z ?Itiairn? ` / _ l ? vNla Igid • _. , I ?,.-r _ ., _ 4 {_ ..ma'r' I . _ `1• ' ?/6/r? ? ? - •r" ? r, -rte ? ?iti ',{.JYn.J ; .f v 0 gala 1 .r •'..•{ 1',•9/71 vJ ?14 y?u ?`? //?}y-?.... ? ??.? ? ; , ? //-l I - l+.?1 ay _ v I " ' f (l,nYr a.•F rrl?N•"11/LO d afivY I . riati/ a-n-a ara• u,vs tea' 10 1• r+'-? r J,_.•r..a 1 J , .?. Ys p)f t 'll ?7N09 O ? vo -0 4 ? S •' ' ,••., y11 f _ iwfY manna I "? ' 00 O,V,4 rran was G i ? e QQ c 0.1 it f ."o 4 I i . I sfalYV rnn/1 0„ •. ?i ALBERTO J. QUAYAT 1 WILD CAT COVE WAYMSSORO VA 22940 -?c2vt5?a72?.eC2 ?2? MAR ATER s<'?}t; Y C) T ?c? l? I I El I L,- r-2 Q?L?- ?-L -TL c? o -i v?Lz - I ARCHITECT LIC. No. 13063 t?C U0. No. 3243 i s. . Alberto J. Quayat 1 Wild Cat Cove Waynesboro, VA 22980 1. 00 2, Legal Notices NOTICE OF FILING OF APPLICATION FOR CAMA MAJOR DEVELOPMENT PERMIT AND WATER QUALITY CERTIFICATION The Department of Natural Resources and Community Development herey gives public notice as required by NCGS 113A-119(b) and 143.215 3(a) (1) (c) that The Towers/Century 21 By-The-Sea, of Onslow County, filed a revised application on February 3, 1989, for a permit from the Division of Coastal Management to develop in an Area of Environmental Concern and for certification from the Di- vision of Environmental Man- agement that a discharge of fill material in project wetlands will not violate applicaple water quality standards. According to said application, the applicant has revised his permit application in order to relocate the entrance way for the condominium complex to a newly acquired tract of land immedi- ately adjacent to the proposed condominiums site at the Hwy 210 and SR 1568 intersection, Topsail Island, Onslow County. n A copy of the entire application and additional information may be examined (or copies furnished upon request and payment of reproduction costs) during nor- mal business hours at the office of Jim Mercer, Division of Coastal Management, located in the Divi- sion of Marine Fisheries Building, Morehead City, N.C., 919/726- 7021, and/or the office of Preston Howard, Division of Environ- mental Management, NRCD Regional Field Office, Wilming- ton, N.C., 919/256.4161. The Division of Environmental Management proposes to take final action on this water quality certification on or before March 24, 1989. The issuance of the CAMA Major Development per- mit and the Section 401 Certifica- tion may deviate from. this pro- jected date depending upon the nature of the comments submit- ted and subsequent nearings that may result. All persons desiring to make comments should do so in writing to Dr. George Everett, Director, Division of Coastal Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to March 14, 1989 for consideration in the CAMA per- mit decision, and to Mr. Bill Mills, Division of Environmental Management, P.O. Box 27687, Raleigh, N.C., 27611, prior to March 14, 1989 for consideration in the water quality certification decision. Later comments on the CAMA application will be ac- cepted and considered up to the time of permit decision. Project modifications may occur based on review and comment by the public and state and federal agencies. Notice of the, permit decision in this matter will be provided upon request. Feb. 27, 1989 J I ?tp,?S 27? C 2- VE - ST-C i NORTH CAROLINA COASTAL FEDERATION 1832 J Bell Lane (Ocean) • NEWPORT, NORTH CAROLINA 28570 • (919) 393-8185 February 17, 1989 Charles Hollis U.S.'Army Corps of Engineers P.O.'Box 1890 Wilmington, North Carolina 28402 Re: Towers Condominium Project on Topsail Island, Onslow County No. CESAW-CO-89-067-0135 Dear Mr. Hollis: The Towers condominium project on Topsail Island proposes to fill the upper section of recognized 404 wetlands. According to the CAMA permit application, the wetland loss would be for constructing the entrance road. This loss of wetlands is completely unnecessary since the entrance road can easily be moved to avoid the wetlands. Since a clear alternative exists, the proposed loss of wetlands violates the EPA 404(b)(1) guidelines. The Coastal Federation strongly supports denial of a 404 permit for any wetland fill for this project. By copy of this letter we are requesting that DEM deny the water quality certification as a violation of the antidegradation regulation. Sincerely, Jim Kennedy Environmental Scientist cc: Bill Mills Ir pl.. F. B 2 J I %'6"i kP'l('f E it QUA L1]' SLU 10II NORTH CAROLINA COASTAL FEDERATION 832 J Bell Lane (Ocean) • NEWPORT, NORTH CAROLINA 28570 • (919) 393-8185 February 17, 1989 Dr. George Everett, Director Division of Coastal Management P.O. Box 27687 Raleigh, North Carolina 27611 Re: The Towers High Rise Project on Topsail Island, Onslow County Dear George: The Coastal Federation submits these initial comments on the proposed project. Stormwater The building site drains to Alligator Bay in Stump Sound. These waters are some of the most valuable, productive waters in the State. They are (a) Class SA waters open for shellfishing, (b) primary nursery areas, and (c) nominated by the EMC as Outstanding Resource Waters. Two creeks from the sound come under the road through culverts and onto the project site. DEM staff in Wilmington have confirmed that these are salt water creeks. Since they are salt water tributaries, they carry the SA classification and presumably the ORW nomination. These creeks have considerable open water and salt marsh on the project site. The permit applicant has attempted to meet the low density option (25 percent built upon) for stormwater control, which would comply with the requirements for sites draining to nominated ORW waters as well as to SA waters. We believe compliance with the low density option is the appropriate action for this site. As shown in the attached submittal to DEM, the project is claimed to be 24.95 percent built upon; however, we believe this calculation is incorrect. The application incorrectly includes areas that drain to the ocean in calculating percent built upon. The 25 percent criteria applies to areas that drain to shellfish and nominated ORW waters. Areas which drain to other waters have different criteria and must be excluded from the calculation -- that is true whether the other areas have greater than 25 percent built upon or are vacant. Dr. George Everett -February 17, 1989 Page 2. Likewise, the application incorrectly includes the creeks and salt marsh in the calculation. The built upon criteria apply to lands draining to SA waters of the State. The waters of the State clearly cannot be considered as potentially buildable area in making this calculation. Based on a rough estimate from the blue print, I believe the proposed project has more like 50 to 60 percent built upon.area if properly calculated. It should be noted that the DEM stormwater form strongly invites the kind of mistake made in this application, so it might be useful if you encouraged DEM to develop a more clear form. Obviously, if the plan is modified to include engineered stormwater controls or some other proposed solution to the stormwater issue, that would be a significant modification that should have new plans and public notice. Land Use Plan The Division of Coastal Management has responsibility for oversight of the local land use plans. The CRC must approve the land use plans and the Division must assure that CAMA permits comply with the land use plans. In some cases the local government may consider a project to comply with the land use plan, but the Division in its oversight role determines that the project does not comply with the approved plan and the intent of CRC guidelines for land use planning. This happened recently with the Broad Reach marina permit. The proposed Towers project is also inconsistent with the County land use plan. The buildings would be in the federal. flood insurance zone and ocean hazard AEC, which are both classified as "Conservation" in the 1986 Onslow County Land Use Plan (page 95). The CAMA field investigation report notes that the buildings would be in the conservation classification. The approved land use plan states (page 93) that only low density residential development is allowed in the Conservation classification. In addition, the proposed project is clearly inconsistent with the State guidelines for the conservation land use classification. Two 15 story high rise buildings on a 12 acre site is not development "in an extremely limited and cautious fashion" (15 NCAC 7B .0204(d)(5)). As in the Broad Reach case, the State should force the county to abide by the land use plan and require formal change, with public participation and CRC approval, if the county wants to deviate from the recently approved plan. Dr..George Everett 'February 17, 1989 Page 3. Wetlands The proposed entrance driveway would require filling the upper section of a 404 wetland just oceanward of the guardhouse. Since the applicant clearly has the alternative of simply moving the entrance road out of the wetland, this plan does not comply with the EPA 404(b)(1) guidelines for filling. Wetlands are waters of the State (15 NCAC 2H .0125(h)). Removing the use of wetlands (i.e., filling) is inconsistent with the antidegradation requirement and therefore a violation of water quality standards and CAMA rule 7H .0601, unless the filling is in accordance with the intent of the Clean Water Act as specified in the 404(b)(1) guidelines. According to the CAMA field investigation report, the affected wetlands are dominated by salt bushes, salt meadow hay and giant cordgrass, among others. There is no explanation for why the proposed fill area is not recognized as coastal wetlands or marsh under CAMA jurisdiction -- which would also require that the road be moved out of the wetland. If the wetland is not considered as CAMA wetlands or marsh, please send me an explanation. Since relocating the entrance road is a proposed solution to a problem that makes the project otherwise not permitable and will likely alter the critical percent built upon, such a modification should be considered a significant change that requires a new set of plans and public notice. Thank you for carefully considering these comments. Sincerely, Jim Kennedy Environmental Scientist s- TORTH CAROLINA COASTAL FEDERATION 832 J Bell Lane (Ocean) • NEWPORT, NORTH CAROLINA 28570 • (919) 393-8185 February 17, 1989 Charles Hollis U.S. Army Corps of Engineers P.O. Box 1890 Wilmington, North Carolina 28402 Re: Towers Condominium Project on Topsail Island, Onslow County No. CESAW-CO-89-067-0135 Dear Mr. Hollis: The Towers condominium project on Topsail Island proposes to fill the upper section of recognized 404 wetlands. According to the CAMA permit application, the wetland loss would be for constructing the entrance road. This loss of wetlands is completely unnecessary since the entrance road can easily be moved to avoid the wetlands. Since a clear alternative exists, the proposed loss of wetlands violates the EPA 404(b)(1) guidelines. The Coastal Federation strongly supports denial of a 404 permit for any wetland fill for this project. By copy of this letter we are requesting that DEM deny the water quality certification as a violation of the antidegradation regulation. Sincerely, Jim Kennedy Environmental Scientist cc: Bill Mills R E C V FEB 2 2. I m WATER QUALITY SECTIOrd OPERA hONS pjl N,pJCH l NORTH CAROLINA COASTAL FEDERATION 832 J Bell Lane (Ocean) • NEWPORT, NORTH CAROLINA 28570 • (919) 393-8185 February 17, 1989 Dr. George Everett, Director Division of Coastal Management P.O. Box 276B7 Raleigh, North Carolina 27611 Re: The Towers High Rise Project on Topsail Island, Onslow County Dear George: The Coastal Federation submits these initial comments on the proposed project. tormwater The building site drains to Alligator Bay in Stump Sound. These waters are some of the most valuable, productive waters in the State. They are (a) Class SA waters open for shellfishing, (b) primary nursery areas, and (c) nominated by the EMC as Outstanding Resource Waters. Two creeks from the sound come under the road through culverts and onto the project site. DEM staff in Wilmington have confirmed that these are salt water creeks. Since they are salt water tributaries, they carry the SA classification and presumably the ORW nomination. These creeks have considerable open water and salt marsh on the project site. The permit applicant has attempted to meet the low density option (25 percent built upon) for stormwater control, which would comply with the requirements for sites draining to nominated ORW waters as well as to SA waters. We believe compliance with the low density option is the appropriate action for this site. As shown in the attached submittal to DEM, the project is claimed to be 24.95 percent built upon; however, we believe this calculation is incorrect. The application incorrectly includes areas that drain to the ocean in calculating percent built upon. The 25 percent criteria applies to areas that drain to shellfish and nominated ORW waters. Areas which drain to other waters have different criteria and must be excluded from the calculation -- that is true whether the other areas have greater than 25 percent built upon or are vacant. 1 Dr.,George Everett February 17, 1989 Page 2. Likewise, the application incorrectly includes the creeks and salt marsh in the calculation. The built upon criteria apply to lands draining to SA waters of the State. The waters of the State clearly cannot be considered as potentially buildable area in making this calculation. Based on a rough estimate from the blue print, I believe the proposed project has more like 50 to 60 percent built upon area if properly calculated. It should be noted that the DEN stormwater form strongly invites the kind of mistake made in this application, so it might be useful if you encouraged DEN to develop a more clear form. Obviously, if the plan is modified to include engineered stormwater controls or some other proposed solution to the stormwater issue, that would be a significant modification that should have new plans and public notice. Land Use Plan The Division of Coastal Management has responsibility for oversight of the local land use plans. The CRC must approve the land use plans and the Division must assure that CANA permits comply with the land use plans. In some cases the local government may consider a project to comply with the land use plan, but the Division in its oversight role determines that the project does not comply with the approved plan and the intent of CRC guidelines for land use planning. This happened recently with the Broad Reach marina permit. The proposed Towers project is also inconsistent with the County land use plan. The buildings would be in the federal. flood insurance zone and ocean hazard AEC, which are both classified as "Conservation" in the 1986 Onslow County Land Use Plan (page 95). The CAMA field investigation report notes that the buildings would be in the conservation classification. The approved land use plan states (page 93) that only low density residential development is allowed in the Conservation classification. In addition, the proposed project is clearly inconsistent with the State guidelines for the conservation land use classification. Two 15 story high rise buildings on a 12 acre site is not development "in an extremely limited and cautious fashion" (15 NCAC 7B .0204(d)(5)). As in the Broad Reach case, the State should force the county to abide by the land use plan and require formal change, with public participation and CRC approval, if the county wants to deviate from the recently approved plan. Dr.-George Everett February 17, 1989 Page 3. Wetlands The proposed entrance driveway would require filling the upper section of a 404 wetland just oceanward of the guardhouse. Since the applicant clearly has the alternative of simply moving the entrance road out of the wetland, this plan does not comply with the EPA 404(b)(1) guidelines for filling. Wetlands are waters of the State (15 NCAC 2H .0125(h)). Removing the use of wetlands (i.e., filling) is inconsistent with the antidegradation requirement and therefore a violation of water quality standards and CAMA rule 7H .0601, unless the filling is in accordance with the intent of the Clean Water Act as specified in the 404(b)(1) guidelines. According to the CAMA field investigation report, the affected wetlands are dominated by salt bushes, salt meadow hay and giant cordgrass, among others. There is no explanation for why the proposed fill area is not recognized as coastal wetlands or marsh under CAMA jurisdiction -- which would also require that the road be moved out of the wetland. If the wetland is not considered as CAMA wetlands or marsh, please send me an explanation. Since relocating the entrance road is a proposed solution to a problem that makes the project otherwise not permitable and will likely alter the critical percent built upon, such a modification should be considered a significant change that requires a new set of plans and public notice. Thank you for carefully considering these comments. Sincerely, J ? Jim Kennedy Environmental Scientist lily f14, t S!'?I{{,' C Y C it, L , If L?1 rl `L\ ?. { tati 41 <! t l?'` ' I d .? Bd J `r i e +, 3 :..U ZAA ':",? ?'? ? ,?"?.",?7 '_ •;?? ??' ?f F'71 : ,l 7, rd F 7; ?," y 1 (S . 11? 1{ L;? ? -'sit ?" !, ' ? •,--?t r•' ` 1-la+'!! ? ?I? ' ? ' •11? ' ?I ?.? i 111! i i J I.?i t ', li"11. , r r L ?? ,' _ 1 f r 'i , i j ?? '} f1 Nz " Il I? ,) ` t' 111111 ti "!I ' li•i ;? : !? I' !? .: rl' 13 ?!ia 'I? .9 °i9 ai rt ? t 1 ? u; Oil ' 1 t j J 111 .. _ ' L- J? 3 I? ; 1 is i ? ila . {la t ? 7 _ 7 d (! ? ? ?? rte, tr l r *? ? l - ??`J9 '• ? L? = 4? 1 R I !' ` ??? 11 t! tl?_ 11Id it I -, t - jll ? +k 1 ? tit' ?t _{` ?, Fi •7• y j I ?1 j[ P i} P ' ?, Submittal Form for Projects Using Density Limits titrnwate? ?' • "' fll) ` Control 1 1 5 11 PROJECT DATA ri ?? 5 19 8U Name of Project: 11 The -(QV rERS "Ro D LE f r ?H,07 Location (County, Township/Municipality, Address): ? t-Fine lVliersz f`1G210 ?' ?R IsGa V?ESf )y1S(ow Bedell, r15(ow CD 1 !G Applicant Name: ,ENTUKY ?2-1 F3Y THF_ SEA Mailing Address: t3OY 3000 . TO SF.(L -,(-{ORES sN?Abs FERRY c_- 2846o Phone No.: q ? - 32 e? - 0 34 2 Submittal Date: Dec_ 1+ , 1??8 oHiAlkizUcA Brief Description (include map and appropriate drawings): z) s sf o r sz U vi t- u' la i a s LuxurLA esic?evr}-i 1 ?o U ?s if o 2,z3 0_te5 n ??`J G2?0 ?, SR (SZf7 D 1Klet5?? i Water Body Receiving Stormwater Runoff: Name of Water Body: f vVA So Li ltd vii N1L)Sk Pot5-'? 2,Alli a-/-Ur , Classification of Water Body: ?SSV?M ) Sh 1 Total Area of Proposed Project (acres): 2,23 c, 0111 State/Federal Permits and Approvals Required: (Check Appropriate Blanks) X =9-f5 CAMA Major X Sedimendation and Erosion Control 404 Permit X DEM/DHS Sewage Disposal X Other (specify) : k ?? De• a? (nsvnc? CALCULATION OF BUILT-UPON AREA (Built-upon area means that portion of an individual development that is covered by impervious or partially pervious cover including buildings, pavement, recreation facilities, etc. but not including decking.) a) Built-upon area: ?3, DE? 7Nc , C132,°12C? S -? b) Total project area: 12.23 ?? C ??z?-73? s•F.} % built-upon = built-upon / total project area * 100 % built-upon area = 24.5 % If the water body receiving stormwater runoff is classified as SA, is the % built-upon area < 250? Yes ? No If the water body receiving stormwater runoff is classified other than SA, is the % built-upon area < 30%? Yes ? No STORMWATER COLLECTION SYSTEM Is the only kind of stormwater collection system grass swales? Yes ? No (Grassed-line swales should have a side slope of 3:1 (H:V) or less.) f : +NIA . BUFFER AREA Is the built-upon area at least 30 feet from mean high water of all surface waters? Yes ? No If no, please provide a detailed description. (Note: Only boat ramps, public roads, public bridges and walkways to water related facilities are allowed within.30 feet of mean high water if the project is intended to meet stormwater control requirements through density limits.) DEED RESTRICTIONS AND PROTECTIVE COVENANTS Do the deed restrictions and protective covenants ensure that subdivisions maintain the development consistent with the plans and specifications approved by the division and include the State as a beneficiary of the restrictions? Yes ? No (Include a copy of the restrictions and covenants with this form.) CERTIFICATION I, [D?fhV1*is {?, Me-rc-i?--r , certify that the information included on this submittal form is correct, that the project will be constructed in conformance with this information, and that to the best of my knowledge, the proposed project complies with the requriement of 15 NCAC 2H.1003 (b). rl?o" gnature-Owner or Ae_nt Date GF_!KTuFK`f 2I 5'r -THE SEA G Fix 3D00 ?A -ro PSAIL SHORES Address If agent, please list owner's name and address below: -Jo k V1 N . st-n l ? vt ? T?J r. , 0 w 6?vrf vrjz? -?2 t DIVISION OF ENVIRONMENTAL MANAGEMENT SIGN-OFF Regional office ??- 15 Date Individual EvaluatingForms/Plant Date Regional Water- Quality Supervisor cc: Applican?_-/Region/Mills/CF ?-- 3 ? rD O ?- :D 3 Sir. O a) r X rt r z M to O N -1 1 'J rr Q' 0 7 CO z v a, n IL P. rr 0 l< r a N V Qr r z H x n z m o ? N ?n oco o ;o ?? = r D Z H a m 11/? 0 Z O r Z n (X) Z V 14 14 O Ei D- Y-, S"Usl?inF J1I) CHARLOTTE C. LEVINE, M.D. ROUTE #2, BOX 436 SNEAD'S FERRY, NC 28460 USA TEL: (919) 327-3615 190-19 DMill i IVISion of Eril':licrrlrrlenti?l i'li?ri5gerrletlt r :. : loigh , -N.?=. ?7? 11 JAN 3 ii89 flVA EIR QUALITY SECT1011 OPERATION' P,3ANI(T 1'• G T C ,,iv el a r S ? r' + '-1 1 1 ^- 1 , i -? - - u 1 1.-• .-. n i ,? ! i II 1 ?iil l •llllt_:i 7 I _'. t rrv v?lull? t 1rJtir" f!T I?-.;tlltl'.j.r t_vt.ril?t_ Ni r(luctr to dUild 10,4 ut lis t?_?11 'i?Yl 1•JT ;'ll-=•?tJ ij l` ? vi lvrl 1171,_•x'.= il{ VUl i'D Tor iod_al re Ziide-nt3. 1 I i JI I ?rII I ?11?1 1 I tJ 1 I sh 1r. =U II p at ti e nt s te. II n-N3 tint 'InI . nd • eribuiIdinQ ?li r+r•7 :-?CGC r- I1f, T 1_r11d7's 1 r ? )_/11_I ta,? _!_ r ti -_,.-"j run ing JY `l,;iiter to !-.'p U-1:2 --211 1l !m, JrOl_ •y ridJ 1 . ':. 'Ji TV +_-l i,4 it . • _ - .J _ u 1 L• i 1J it ,l tl t? i• t .? r.-. -I n :l n 1 1 {•{ ?{!7 tI I-UK I1 t:• _ i .l. i I lv s' JI V I •I41!•!J-? 1-I. I e ?JT ?i 14 pr-?JN -•:.•LU )1 &ji 7p N,;-t ?IT 411 I]ccot-no iJt?'J 1 (vi .j i?iJt IiiJ •J ' 17 ? i't tci .J 1 1_; u _ t ir If 4 tn rl o ; rl - 1 7 see J1'(Tth th 'Jlo,,1, rlcjtlitiil p -i t ---n' i•,ratpr +F.r••1r lr, t-. tr,? ; - JI II JII I! J 41 tll Vi_I ?1I Iiv ?'UIIJ L'Vi The oil IJ11'J )jijs dripping horn tr o-S-e Lcir-S T"'lot e"Qct]14 hat f );Ji._ en , r , ii?t .11 C _•t r:L . „jol? iCdr- 1 t_i rl c: i?. I t , ,,ere i s e1-10U ,il ruz.,W r a,7d kti on n nigh'r'rii 1.4 to rrcl;o i t d-,y°rousl_' Slippery just after o r i:-in belin-S. ±11i7t IlILI ` 1!_ Ill C'• (1;_rt - , 1110 I. LtJIll i•*i •-i +i, r] -J~ .: lily-te J ?? e thie r 171IiG over D - 'D i 1 '_4 tl -u 1-1 ?I l(IG uliJ, _•11?? 1(1)11 ?'u ''° , i • Ldr 1' - -VI ov? llly t Ilr tIq L.tid iThe tn--Jr iShe '. There i ;,w JPf l er l`•Lr ?- :? - fs?i.T .} arcs r7 .7r .'s .7 vs ?+rl r'?r ?r??i ?. F.-.?.? = ra ter. •- - LIl1- i JrJn tt- ?: L L i. JJL-JI i-? ?J i7 if L+?.l i7 i? js -.'-? iJt YJt1r11iJ to !'1 r1 ii x!•11 mm, c '-I t111Ji !J V'J d I!UII?JI IJ J)1 ?-,j,-J 'i lrt 11 brfin-q. A`,1 e--JId U, the 1•'i- i?tble ill cr0_copic. i3cct_,illlilu*ed Le:url'= to' Ssl-d i I i 1 ,-,.,,- 1iI tr(e dp_n 4rijteof I e 210 ;Jr id ;r. 1 0 11 _Il ldd.i rY i?*'d Il lid =3 tiiiJt trim fir-, (? 1 •-ie r. f _. r- ? - y} -.1 n.,-J 411':Illii_•JI Jlid 11 iT I1t IJJL•?Ip;,iv U'_LIIbrl? Tom. Z, ?Dr `~r ?II'J 11\ tli!J 1111.;11 i"1 IU'?tr tL! ' i!d =r-':!e y+ t'riG ,y ,t ;.r :• i•1, ?I if DTI d? rdI lily trn?r n 'JI J i?-1 aL 14 tr•Jlint LII .•'JJ Iv 0 1r :_i Vtrl ?dfie s. o t11 ?!e sj) rn.? i 1c 1 . • v' --,kJv Ii7 {i?L' ?'i _It_i`, ut th i,,I. ri)' end UT ' 1 j ?1r"ld e;d `r'irTIi i7ttract riiore t?n (iirlit 1'= + t-t.itllrriJ>?r_- TI-ict-ejsin?' 1'111 L. L-Uil !ollrit [y trleir IeCijl IilIj I- ?711 ln`;- i iq Lhe °I't7tN.t tyi_ti7ht!j1 for St -.11 fi_i.h. J!(tld 1;'1J Jtv Mr'tli r11J 1'S tOnS O l}t/11f1 U.?! o it i?a/ III r 1Sj,e? •i1jiVL d1iaf---0j a? •?j?Ir hT)_h p0'= =ri :ddltionul tnrNi;t t0 in>11111 I ''j`I'uirt u' =fJll+? '-,t3 GG11 Gt1[tt; v t• t(-+ • e t, +, C i - I( o-lr; ;nr.q ) I dr alili? t r =iT T1 i L:•_t.rltl? fi7-J 11Ut dal•'eili i_.d i7ri•y JdJLiit,_IIIIJI Y111 I1 t d?' •-`) 51t it' l l . I adJitiJrlU1 JJIiJ 'lI1jJi J Ilrlic rl'11if 11 V4 d_11_rdYj\4dJ !dl'.f'_1 ?ILr-J lid d_1IdJ r-rlJilllolid. Ullr 17ndTTll is ok.,er Jutdenedf Ind rec,-=lina i' not Urldet =.er lous GOIi •i% i i7i_iUrl. /i QCIIUin? eff'0t t lit I Liie 'Ji r-t r1 dC'17v1? ?irt _ iii i7?: Q lender' rlirl role in i9ntiriJ p?=, tiIrlp , I t'iJ •8"Tr1 ? burden, I cii .1l )i qo y lone l '1 E- vt/! J y V .j e ?' 1? wi t to u 1'I ni IIr t;r( rriar.irlq their prCdpo ,oi3 rnot-'= dC-d?eptOrdl,fY to .o_ _.; 1!1ir „ill be t47xpd I- !11.:I d_f1t_ailti `i'i'i it C' )]i'_p'J ii71 r i iliti,?y f ? CHARLOTTE C. LEVINE, M.D. ROUTE #2, BOX 436 SNEAD'S FERRY, NC 28460 USA TEL: (919)327-3615 The fire arrd rescue people are trult, .;t,pprehensive about handling erneroencies there. This is a geographic =:red ,.,,here inspection of such, buildings has never been done. Who is qualified to inspect? Even if self contained fire sprinVers systet-n:are provided, ;,+ho ,^rill train the local firemen in their use? We have no equipment to reach above a fe%y floors. The last large building had i'vater in its s%,.,it-nt-nirig peal but the fire trucks had no dccess to the pooi. Serious itwolvenient of the firemen at the planning level must occur. i understand that it lids not. The offshore isiar,u;_ ,ar _ ,arrrUs for„ r.:-sc.r. s at a, not high rises. Getting pooh}e out of Such br-rlldirig:s and off the island in bad weather is a big CariC?rn. The stiei'et- at D1?CGh SCiioOl ?Vauld be sorely stressed by an additional 300 personas. Are the developers considering that tiffany of these units +ill be inhabited by retirees ;,iihose physical self EnAfficiencu might be Compromisoo? Fifteen stories and a povier failure can ne life threatening. Finally, there is nothing anyone can d to trill:e a nlgn rise "beautiful" to people r,+no truly lore the Uninter-'_r Od vista of the sunrise ratifier than a big city skyline. This Xquisite and fragile coast `;Pill be gone. The `t,+ay of life of the fishermen +il} be gone. There %,t ll be nothing unique left. An earl ior survey of local apinion c}earl y established that the ?arlence, granted by the county conirhissioners to permit this high density building, 'YVolrld not have been granted if the people wiUA n tern miles of the project had been permitted to 'dote upon it. Sincerely, CG/ ?. chal otte C. 1 C''1Ilie it ?' !, ?? ? ? . t ? -_ N ?-??" ?? ? a ? ;. --- ? ? . ?? ? ?; °G ? ' ? I? i t3 ? , ?IE t ? _ P ?;?_ ?- r ''?, _?a ... - E Rt. 1 _`ox 3301E Sneads Ferry, - 28 60 January 19, 1989 1'r. rill Tills Division of Environmental I:ana,ement .C . Lox 27637 Raleigh, :C 27611 Dear :r. Lills : ?,e are writin- to urge you to deny the issuance of the CAI'.l- per alt and section 401 certification in re tard to the application of The Towers/Century 21 Ey-the-Sea/Dennis K. i'ercer of Cnslow County. The excavation, fill, construction and eventual occupancy of these structures will seriously effect the water quality of Stump Sound, an area under consideration for CR',J desi-nation as an outstandins fish habitat and fishery. The construction of The Towers is not co i;patibl,., with the increased envi ron ontal protection of OR". This application should be at least delayed until action on idCAC proposal for CFti'.'O'-A C overlay, specifically under section .&502 a. U: b. as noted in Evan z-runson' s I'e.morandum dated Sept. G, 1S'38 is finalized. Is a further con ent, proposed Towers deve congestion and deter emergency. the increased density resulting- from tills lo_r)ment will additionally ir_lpact traffic safe evacuation in the event of a coastal Large numbers of the public are deeply concerned o-,rer many aspects of tl.is project. We call upon you to act in the public interest in t ai s matter. Sincerely yours, Keith c Carole Robinson JAN 2 a X969 V,IAIER QUALITY SECiIP (,PERA'fIQNa M3ANCH 1 i? C3 qq U CL's Q p>0 a! Cl) zmc) m x o?c. x?xw W C i! Ly r-? i3 C? U 0 r N r? .H f? r? U .--! ?q (") N •? 5 -+ lam- U ? y c 01 ;.: r-1 O O _V, •r'1 •ri ? : 1. ) • 7 U r-I r, •r•I c3 Rt 1, Box 184 Sneads Ferry, N.C. 28460 Jan 18, 1989 I..r. Bill Nills Division of Environmental b'.anaF-ea:ent 1-0 Box 27687 Raleigh, ii.C. 27611 Dear Sir: These comments are in opposition to the Towers/Century 21 By-The-Sea/ Dennis K. Mercer development proposed for West Onslow Beach, Onslow County. Without recourse to narrow, technical objections, I oppose this develop- ment on the broad, general issues of coastal,area management. Whereas the State has legislated protection for fragile coastal areas, and Onslow County's Land Use Plan has rubber-stamped those standards, each new development of this nature augments the surge toward total high density/ high rise usage of this, the most fragile area of the entire county. The couhty Land Use Plan boringly reiterates statements to the effect that it is county policy to implement State and Federal land use programs. Accordingly, this proposed development is a clear-cut challenge to the State: (1) Does this twin high rise development conform to the tenets of Coastal Area Management? (2) And if so, can the same be said for the next, and the next, and the next similar development that surely will be proposed for West Onslow Beach? Although the current county Land Use Plan asserts that, "Ocean Beaches and Shore Lines . . . must be preserved to the greatest extent feasible ." (P• 32,33), the record of variances, re-zoning, and construction permits granted since 1979 by Onslow County clearly indicates just the opposite is happening. Just what sort of Coastal Area Management is going on here in Onslow? Is the State powerless, or just disinclined, to intercede? Is not this an opportune occasion to reassert the aspirations of Coastal Area Management? Sincerely, D. A. Clemente E I VE D ' JAN 2 11a89 MATER QUALITY SECTION' OPERATIONS BRANCH v ./ Cz n1 I"?? f^ ^? I?1 N ray V / W r-i r-i 0.? w c3 w F; c: r-4 c,S a w 0 S4 a w S C O •rf L7 a A r- co n N A O PQ O P4 H H I-D Ll- N U w ri ro F2?i ±71„' °. '`;-.;, ;•1111.._.:'1 p. L`-lt,c?r. 7hl S1,:2 :1:? 2rrv ?)R) 60 _ir. Hill ? ill3 n Box 27637 R,71vi; 11) I:.C. ?"'511 IT u,",1•-- i! 139 Peru .'r. B? fore you 1 3 :crnit rE.'Q'.]L3t fro 7, 1 :1" i/CCntur;y' 21 B; -Th: S-c.7, Their request s1wild bt: denied. This (nYlc::.' r cumty Plu:nni' UO-lyd h,,IL; 1 !: ?,• ll is ta' h": [l .i Cu.'nl{J;, t:) th- Cm nt- of Jth. .:},, -j J'_-,X ..[1'.. .. ,...,a..?:??. .i .31,. [:..r i.Vi1..1C ,2" _,t:?{ ?.a., "?i.l.. c.: i. ?)??.C.;. ?u ?). ?.... ? , ?. _ .. ..? 1, _ r., ,. tal;l 1;e o ct to cn J t.- ct :' :3: 1< ucil u. .., . . stu" " D ! Vic! . C aC , 7:..t.uu,,Calk i _, :C :1 Of C ... _ ' "m ..)I-JlSIs.-I of n.?J1.. tit-:! 11 t. r-'- 7:'.11:10 T' of 1111 C 3 pllcataicn : ho ild no "J 1i1C!?': ±aU 2,, Ct t11':i t' th.-- 1-';7/1;" rl :i 1C'!? Unlt`.z,) <V, i ?[" lots) P_, 1 rcc"C'lLlo[731 .:10113 L"G!_7 '..?? t•1C au L.aI1i; r.JJl:. CIllJ:iii3t i a.3 T.c::: ar, TJIi%+ CuucC C_ 11:7 JGC to :Iii c cr,;r1U1 -. ciltall' ir3yllc Tl-, .:311 t;j .;t t<t7-'s ;1111 3:11'21,x' c:Laln_zh to .3 le`.-A. that 1-- c. !;.,1Cya',., :nd LUL?11 ? [1. C C"c'AzAbl , i'le+ i l'.:.' thi: ..'pf'i11C<ltion Clc::.2 "Crutit:`T art,-', ?:Op.' fillly nu ;fill C: L, t11C: fisctIz t11Jt 1-,h;1! pcrl?:lt r !n!1CC:3t S11C;:z1! t'_' `1 hnn'!,. ycii f cr you l- t;tCnticn Z. r1 C1 1.n t:hi,, ,;,tT tt,( T', S?ncilz•cl? ic;1r..? E is 2 7 " ?n?t .` i- d 7 ' 2 ?O Ln ^JcJO O y0 Lz' •rl O t rH-l ul U Sti L7 ? 'J ? ¢? •i.? Ly 'J ? f,Y ??3 CD -0 c? • r? :J ?A L! F ?co +-) ct r-( C? •i C U .r{ ri 14- C`- C n r-I rl U J i •r{ P p :n CJ Ty •ri r--l r? W ti C? n C r it r? ca ti-