Lisa Sulka Mayor Ted Huffman Mayor Pro Tempore Anthony Barrett Town Manager

Council Members Fred Hamilton Karen Lavery Larry Toomer Sandra Lunceford Town Clerk

April 22, 2014 Mr. Brian Flewelling, Chairman Natural Resources Committee Beaufort County Council P.O. Drawer 1228 Beaufort, SC 29901 Dear Chairman Flewelling: We are contacting you on behalf of the May River Watershed Action Plan Advisory Committee (WAPAC) to express our collective concern over the unintended impacts of the proposed Bluffton Gateway Project Development Agreement language, included as follows:
XI. H. Stormwater Management Plan. The Southern Connector Road shall be dedicated
and accepted as a County Road as provided in this Article XI. Accordingly, the Southern Connector Road shall not be included in calculations for the effective impervious area for the stormwater management plan prepared for the permitting and the Development of the Property contemplated in this Agreement (the "Stormwater Management Plan"). Furthermore, so long as the Stormwater Management Plan meets the nutrient degradation and detention requirements of the ZDSO, as determined by the County engineer, the goal to achieve a maximum of ten percent {10%) overall effective impervious area ratio shall be increased to twenty percent (20%).

While the purview of the WAPAC is specific to the May River watershed, the Committee feels strongly that the proposed language sets a dangerous precedent for future Beaufort County development which may negatively impact our sensitive waterways, including the May River. We respectfully request that the existing Article H. be amended back to its original content which states the development will meet the County's existing stormwater ordinance. We accept the County stormwater engineer recommendation that the site will meet the intent of the current ordinance; the issue is the language itself. Both the County and Town have been committed to protecting our outstanding natural resources and waterways to the best of our ability over the past fifteen years. Not only have we invested numerous monetary resources to that end, but we've entered into a mutual Intergovernmental Agreement (December 18, 2009) which states that we, Beaufort County and Town of Bluffton, agree to "Formulate a partnership to protect Southern Beaufort County Watersheds and other outstanding Natural Resources" and further to, "Implement coordinated requirements for controlling stormwater volume from new, approved and built development," and "Coordinate land management activities and regulations to reduce actual and effective impervious surface in our watersheds." Again,

Theodore D. Washington Municipal Building 20 Bridge Street

P.O. Box 386

Bluffton, South Carolina 29910 Fax (843) 757-6720

Telephone (843) 706-4500

www. townofbluffton.sc.gov

including language which allows an effective impervious ratio of 20% does not support our combined efforts. A specific concern for the May River watershed is the extension of roadways to allow access to the site. The developer proposes to transfer ownership of the connector roads from the south (extension of Red Cedar) and the west (extension from Sheridan Park) to the County, thereby excluding these roadways from their stormwater calculations and plans. Assuming the County accepts ownership, the County is then obligated to develop stormwater capture and treatment as the owners of these roads. Additionally, as stormwater is conveyed from the site, the Town has concerns that the flow could adversely impact work previously accomplished to re-establish the historic flow patterns from Bluffton Park/Verdier Cove back to the Colleton River. The Town has invested significant resources, monetary and staff time, to correct this issue and prevent impacts to the May River. Again, we respectfully request the Natural Resources Committee carefully consider the widespread impacts of the proposed development agreement language as it is currently written and the unintended consequences that can be borne by both the Town and County as we work together to protect and restore our waterways. Thank you again for your consideration.

Pro Tempore Vice Chairman, WAPAC cc: ufort Co nty Council n Council Blu May River Watershed Action Plan Advisory Committee Mr. Gary Kubic, County Administrator Mr. Anthony W. Barrett, Town Manager

Theodore D. Washington Municipal Building 20 Bridge Street

P.O. Box 386

Bluffton, South Carolina 29910 Fax (843) 757-6720

Telephone (843) 706-4500

www.townofbluffton.sc.gov

Lisa Sulka Mayor Ted Huffman Mayor Pro Tempore Anthony Barrett Town Manager April 22, 2014 Mr. D. Paul Sommerville, Chairman Beaufort County Council P.O. Drawer 1228 Beaufort, SC 29901 Dear Chairman Sommerville:

Council Members Fred Hamilton Karen Lavery Larry Toomer Sandra Lunceford Town Clerk

I am writing to you to express concern over the proposed Bluffton Gateway Project Development Agreement language and the unintended impacts for the sensitive waterways in the greater Bluffton region. In discussing this project with members of the May River Watershed Action Plan Advisory Committee (WAPAC) and County Councilman Vaux, there are two major points of discussion. First, the requested Development Agreement language allowing for a 20% effective impervious area ratio sets us back over 15 years in our combined efforts to protect our waterways. Both the County and Town have based their development standards on not only existing scientific research, but also as an outcome of our own substantial investment in water quality studies. Allowing the proposed language opens the door for all future development to request a similar, or potentially greater, waiver, effectively negating all our efforts. Second, there are several unanswered technical questions dealing with the management of the proposed stormwater Best Management Practices (BMPs), including long-term operation and maintenance of the BMPs and stormwater impacts due to the extended roadways. I respectfully request that you not place this item on County Council's agenda for third and final reading until such time as the above issues have been appropriately addressed. Thank you again for your consideration. Sincerely,

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Lisa Sulka, Mayor Town of Bluffton cc: Beaufort County Council Bluffton Town Council Mr. Gary Kubic, County Administrator
Theodore D. Washington Municipal Building 20 Bridge Street

Mr. Anthony W. Barrett, Town Manager May River WAPAC

P.O. Box 386

Bluffton, South Carolina 29910 Fax (843) 757-6720

Telephone {843) 706-4500

www.townofbluffton.sc.gov