Response to Jamestown Public Comments from Isaiah Reed, stormwater program coordinator, NC Dept of Environmental Quality, July2024:
“Jamestown was audited by the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Mineral and Land Resources (DEMLR) on June 7, 2023 to determine compliance with their Municipal Separate Storm Sewer System (MS4) permit. At that time, the program was found to be deficient in meeting all permit requirements. The renewal of their MS4 permit does not constitute an approval of the Town’s past administration of their program. The permit renewal, and creation/approval of the associated Stormwater Management Plan (SWMP) is the first step in the Town’s process to bring their program into compliance with the permit.”
“The measurable goals outlined in the SWMP are a required component which are designed to map out the steps the town will be taking over the next permit cycle to correct their program. While comments and concerns related to the MS4 program in the past are appreciated, the Town has already been found deficient of meeting all permit requirements and the renewal of the MS4 permit is focused only on future implementation of the program.“
This is an image of Reed’s actual response:
Since they weren’t addressed in the “response” document, we’re archiving/sharing excerpts from Jamestown residents’ public comments below:
Jamestown’s stormwater permit is three years late in renewing, and the (required) Stormwater Management Plan submitted with it was incomplete, with minimal “measurable goals:”
Here are more Jamestown residents’ submitted comments:
“The response to BMP#6 in TABLE 13 gives an extremely weak, vague, lazy, “pass the buck” answer – Jamestown says it will “partner” with Stormwater Smart and the Piedmont Triad Regional Council. This organization provides absolutely ZERO services and support to Jamestown. We have documented examples of Jamestown residents writing PTRC for information and answers about our water and stormwater practices, including within my own household, and they’ve received NO response. NOTHING.This is UNACCEPTABLE in a critical watershed such as Jamestown, where a network of water supply streams converge for treatment at the un-permitted and overstressed Eastside Wastewater Plant, before traveling south for five miles to our drinking water treatment plant and reservoir, Randleman Lake, and then continuing south to the Cape Fear River. The water supply streams that all meet up in Jamestown carry wastewater discharge, chemical contaminants and VOCs from industrial facilities, chemical companies, manufacturers, landfills and construction dumps in Greensboro, High Point, and northern Guilford County.”
“…the idea that this town would propose this as a MEASURABLE GOAL (for Public Outreach and Education): “MAINTAIN LEGAL AGREEMENT WITH PIEDMONT TRIAD REGIONAL COUNCIL FOR PUBLIC OUTREACH AND VOLUNTEER OPPORTUNITIES” is an insult. … TABLE 13 of the draft SWMP dated 3/4/2024 references “APPENDIX A” for some kind of memorandum of understanding between the town of Jamestown and the Piedmont Triad Regional Council/Stormwater Smart regarding the number of public information items distributed. APPENDIX A IS NOT ATTACHED TO THE SWMP IN THE PUBLIC FILE. This is a major component of the EPA NPDES MS4 Public Education and Outreach requirement, yet it has been completely left out of the SWMP that is currently posted for review.”
“I am a fisherman. I fished Randleman Lake as soon as the new reservoir opened for such activities in 2005. I was deeply disappointed to hear from the onsite staff there (Randleman Lake/Southwest Park) that I should “never” eat any fish caught from the lake due to the massive amounts of pollution and contamination. NOTHING has changed, except that I stopped fishing at Randleman Lake. How can you allow this water to be served to us as drinking water with SO LITTLE INFORMATION on the testing and contamination? We all know that Piedmont Triad Regional Water Authority (PTRWA) which owns and operates Randleman Reservoir and the Kime treatment plant has been “set up” so that it is exempt from REPORTING AND TESTING WATER QUALITY at the same levels that PUBLIC water treatment facilities and reservoirs are required to do. Obviously you see this as a health hazard to the residents of this community. We all do. It’s VERY hard to miss.”
“Since 2010, all of Jamestown’s drinking water, and much of the surrounding areas here in southern Guilford County and northern Randolph County, comes from PTRWA/Randleman Lake. Nobody in local government ever felt it necessary to INFORM US OF THAT. There is SO MUCH documentation showing that the state of North Carolina KNEW Randleman Lake as a drinking water reservoir was a stupid idea – so stupid that they predicted the day would come that PTRWA/Randleman Reservoir would come begging for money to fix its contaminated drinking water problem – just as it did at Jamestown Town Hall last fall.”
“TABLE 14 in the March 4, 2024 SWMP – the MEASURABLE GOALS are a JOKE: “review for broken links… train staff to answer the phone … add phone number to stationery…” ARE YOU SERIOUS? Did anyone at the North Carolina Department of Environmental Quality even READ THIS??”
“In the first four rounds of the UCMR5 test sampling events, EIGHT PFAS were detected in Jamestown’s drinking water, some of them in double-digit parts per trillion. Our water would NEVER have been tested for PFAS if the federal government hadn’t mandated it. The town has said NOTHING to residents or local communities about these findings. Private Jamestown citizens found the results on the EPA UCMR data website and shared them with residents on a citizens’ website. Doing our OWN research as volunteers on our own free time is the ONLY way we can inform ourselves about what is running through our backyard river and streams, under our homes, shops and schools, and out of our faucets.”
“1,4 Dioxane is also in the Pretreated Wastewater of in-town chemical/plastics manufacturer Alberdingk Boley, and a number of hosiery, automobile parts and chemical manufacturers in High Point that discharge to Richland Creek/Deep River. We are expected to drink it after it’s “treated” at the rundown Eastside plant and the treatment plant at Randleman.”
“The stormwater education link on the Town of Jamestown’s site ONLY addresses private residents – a ridiculous 3rd-grade primer on how not to stop up sinks, drains and Jamestown’s pipes. There is not a single mention of the REAL problem – the ENORMOUS INDUSTRIAL DISCHARGE FLOW that has been destroying DEEP RIVER for decades. Jamestown residents have uncovered numerous engineering and surveys and groundwater assessments/studies that make it very clear that much of the dumping and abandoned hazardous sites in Jamestown and its extraterritorial jurisdiction along Riverdale Road continue to exist because local government, for nearly 100 years, designated Deep River as the designated water dump for High Point and Greensboro’s furniture, textiles and chemical manufacturing industries because Deep River was “NEVER GOING TO BE A DRINKING WATER SUPPLY” source due to its massive contamination problem.“
“Number 9 in the SWMP “Public Education and Outreach” section discusses a “stormwater hotline.” No such thing exists. Ask a simple question or call Town Hall with a water concern, and you have to play the town manager’s ridiculous game of setting aside an hour to meet with him and whomever else he pulls off the job, at Town Hall. This is a TREMENDOUS waste of taxpayer money. … In addition, the town does NOT have the resources – personnel and knowledge – to manage a system such as this. It’s a major threat to the Upper Cape Fear River and, ultimately, our downstream neighbors.”
August 19, 2024: In an email sent earlier this month, Isaiah Reed, Coordinator of the NPDES MS4 permit program for the NC Department of Environmental Quality, told us that he is working on responses to Jamestown’s Public Comments (about the town’s inability to present and manage a Stormwater Plan), and hopes to have the completed document soon.
Reed said that Jamestown residents brought up a lot of issues that require responses from other divisions within NC DEQ, so those divisions must weigh in on the comments that pertain to their environmental areas before the document can be released.
Reed apologized for the delay and stated quite candidly that he is “working through several tasks and just hasn’t had time to finish it up yet.“
We know this to be true – while searching the state’s stormwater site for info on a different matter, several webinars popped up featuring Reed guiding and advising the many stormwater managers he works with across the state. Given North Carolina’s water infrastructure issues, it should come as no surprise that Reed is a very busy guy. He did, however, did take the time to explain what was going on with Jamestown’s public comments:
“The response to comments document should provide clarity on several issues, but I am mainly wanting to make sure that I clearly cover what parts of the issues described in the comments are applicable to the MS4 program. Sometimes the blanket of the MS4 program is presumed to cover more divisions than it is intended to cover. Again, due to the comments, that is the main goal of the document … I hope this provides some clarity and update on the situation. I am hoping to have the document ready soon. Please let me know if there is anything I can help with in the meantime.”
Coincidentally, a major stormwater event took place the day Reed sent his email: Hurricane Debby blew in from the coast and dumped its torrential rainfall on Jamestown for hours, our second one-in-a-hundred years storm in eight months. Neighborhoods were flooded, the train tracks were underwater, the sewer pipe over Deep River was leaking, and muddy red-brown water carved out more roots, holes and gaps in our stream banks. Jamestown’s existing circa 1980 stormwater culverts, sewer pipes and stream channels are incapable of handling 2024 impervious surfaces, water flow, and storm events.
June 4, 2024: This week, we were surprised to see that the NC DEQ reissued a stormwater /wastewater permit to the Town of Jamestown without posting, responding to, or acknowledging the PUBLIC COMMENTS submitted by the citizens of Jamestown.
We also noticed that the “JAMESTOWN STORMWATER PERMIT” folder in the NC DEQ laserfiche files had been moved (link broken) and modified.
The Stormwater permit (NPDES MS4) was issued at 4:00 a.m. on Monday, July 1, 2024 by Isaiah Reed:
One business day before issuing the Stormwater Permit, Reed said in an email that he had many comments to work through and a “response to comments document” would be posted and made available to the public (us). That did not happen.
The NCDEQ public Laserfiche folder containing the town manager’s permit application, Notice of Violation, on-site audit, self-audit and correspondence were moved to a different location (which broke the links in our posts) and at least one document was removed. Meta data shows the files were moved on March 18, 2024. We have redirected the links and uploaded images of the missing document: an August 18, 2023 letter from Matthew Johnson to Isaiah Reed confirming the timeline and certifying the permit data:
Readers, going forward, please notify the admin in the comments box (beneath every article) if you find any broken links. The Jamestowner archives all documents referenced on our site and can fix it quickly.
About The Author
Unbelievable…I’m speechless.t