NCS000408_OTHER_20120724

STORMWATER DIVISION CODING SHEET
M54 PERMITS
PERMIT NO.
C, So (j O Lf(�
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DOC TYPE
❑FINAL PERMIT
❑ ANNUAL REPORT.
❑ APPLICATION
0 COJVIPLIANCE
�THER
DOC DATE
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YYYYMMDD

(Elty of &Oatn
P 0. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
July 24, 2012
Mr. Chuck Waklid
Director
NC Division of Water Quality
1601 Mail Service Center
Raleigh, N.C. 27699-1601
Subject: Category 4b Demonstration as an alternative management approach to the draft
impervious cover limitation TMDL for Little Alamance Creek
Dear Mr. Waklid:
The City of Graham has investigated pursuing a Category 4b Demonstration for Little Alamance Creek
since my November 30, 2011 letter to former NC DWQ Director Coleen Sullins. While the City still has
reservations about the appropriateness of TMDLs that use impervious cover as a surrogate for water
quality, our investigation has led us to commit to developing a Category 4b Program.
The July 2012 deadline in the original letter for the stakeholders in Little Alamance Creek to commit to
the 4b demonstration was established to allow the municipalities to budget effectively for program
creation. As such the City of Graham has funds in its current budget to begin development of the
Category 4b Program and plans to begin development this month. In keeping with former NC DWQ
guidance, specifically the City's original draft NPDES Stormwater Permit about impaired/TMDL waters,
the City plans to develop its Category 4b program over the next 24 months from the acceptance of this
letter by NC DWQ. Once the program is created the City will submit it to NC DWQ for approval.
We look forward to working with DWQ staff on this important initiative to begin the process of restoring
the biological integrity of Little Alamance Creek. If you or your staff have any questions or need any
additional information please contact our stormwater engineer, Josh Johnson, P.E. at [phone] or
through email at [e-mail].
Respectfully Submitted,
Chris Rollins, City Manager
Cc: Josh Johnson, P.E. Alley, Williams, Carmen, and King _
Michael Layne, P.E. City of Burlington p _
Andy McDaniel, P.E. NCDOT
Kathy Stecker, NC DWQ Planning Section
Mike Randall, NC DWQ Surface Water Protection Section AUG — 3 2012
W Nn - WATE- 66ALITY �r
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(Etty of 6ra 4am
P 0. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] / Fax: [phone]
November 30, 2011
Ms. Coleen Sullins
Director
�R@fgoyL� N
DE C ' 1 2011
NC Division of Water Quality
1601 Mail Service Center 4EWDSANDSrORAWATE �rZWtj
Raleigh, N.C. 27699-1601
Subject: Category 4b Demonstration as an alternative management approach to the draft
impervious cover limitation TMDL for Little Alamance Creek
Dear Ms. Sullins:
Over the last year the City of Graham has consulted with NC DWQ, the City of Burlington,
NCDOT, the League of Municipalities, and other communities around the state on issues with
and alternatives to the proposed impervious Cover TMDL for Little Alamance Creek in
Alamance County. Recently the City was represented at a meeting attended by these groups that
centered on alternative management approaches to biological impairment of streams due to
stormwater. The City of Graham appreciates NC DWQ's willingness to entertain discussions
about alternative management approaches within watersheds that are impaired for biological
integrity as we, and many others, have concerns about TMDLs that use impervious cover as a
surrogate for water quality. These concerns have been previously detailed in both my public
comments and the comments from our stormwater engineer, Josh Johnson of Alley, Williams,
Carmen, and King's comments from January 18, 2011.
The City of Graham is committed to clean water and as such is committed to further
investigating the feasibility of a Category 4b Demonstration as an alternative to impervious
cover limitation TMDLs. Specifically regarding the potential for a 4b Demonstration for Little
Alamance Creek, the City of Graham is committed to working with DWQ, NCDOT, and the City
of Burlington to reach a final decision on pursuing a 4b Demonstration by July 2012. This July
2012 date was discussed during the October 2151 meeting and is based on the municipal
budgetary cycle.
We look forward to working with DWQ staff on this important initiative to begin the process of
restoring the biological integrity of Little Alamance Creek. If you or your staff have any

Ms. Coleen Sutlins Category 4b Demonstration
NC DWQ November 30 2011
questions or need any additional information please contact our stormwater engineer, Josh
Johnson, P.E. at [phone] or through email at josh a,awck.com.
Respectfully Submitted,
Chris Rollins, City Manager
Cc: Josh Johnson, P.E. Alley, Williams, Carmen, and King
Michael Layne, P.E. City of Burlington
Andy McDaniel, P.E. NCDOT
Harold Owen, City Manager City of Burlington
Kathy Stecker, NC DWQ Planning Section
CMike.Randall?NC DWQ Surface Water Protection Section