Sunday, June 7, 2009

DHEC double talk

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Shannon,

Thank you for the site inspection reports that you furnished during last Friday’s meeting. After reviewing these reports, I must now admit to being totally confused with respect to DHEC-OCRM’s position regarding SWM ponds at Sun City.

I thought that I understood DHEC-OCRM’s position after DHEC-OCRM's February 20, 2009 letter to Thomas & Hutton (copy to Del Webb Communities). e.g., “Ensure the bottoms of all ponds are excavated to the appropriate elevation…it (Del Webb Phase 5 lagoon maintenance items) does not address all issues for non-compliance…nine phase five ponds were not listed and there is indication that at least ponds 149, 152, 161 and 162 are currently too shallow…some water surfaces may rise due to downstream connectivity but the water surface elevation will not rise if equalization pipes are clogged.”

Then, in the March meeting, and in a following series of emails, we were told repeatedly that “DHEC-OCRM regulates ONLY volume; DHEC-OCRM doesn’t regulate depth, or connecting pipes, or slope, or compaction, or embankments, or trees in embankments, etc.” This position (which seemed at odds with DHEC-OCRM's February 20, 2009 letter) seemed to be verified again at Friday’s meeting when you said repeatedly that "DHEC-OCRM regulates ONLY volume, NOT depth, etc." I came away from the meeting with the distinct understanding that a pond can be one ft. deep, and as long as sufficient storage volume is provided, that you’re OK with the one-ft. depth (and the resulting aquatic growth that can be expected from such a shallow pond).

I thought that I understood this current position until I got home and reviewed Richard’s site inspection reports. As you know, these reports cite problems with depth, slopes, erosion, water level, aquatic growth, etc. Now, I’m more confused than ever.

I bring this to your attention only because I was made to feel like a nitwit at the meeting because I “didn’t get” DHEC-OCRM’s position, which had been stated previously NUMEROUS times, that “DHEC-OCRM regulates ONLY volume, NOT depth.” Having reviewed Richard’s site inspection reports, in light of your statements during Friday’s meeting, and previous meeting and emails, I now feel totally vindicated in my confusion.

Regards,
Ray Koenig

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