846 West Fourth St.

Winston-Salem, NC 27101

Telephone : 336-722-4949

November 16, 2015

VIA EMAIL AND U.S. MAIL

Nin Kimmer

Division of Water Resources

1611 Mail Service Center

Raleigh, NC 27699

Re: Yadkin River Water Supply Project Interbasin Transfer

Pump Station, Access Roads and Pipe Corridor

Draft Environmental Impact Statement

Dear Sir,

Yadkin Riverkeeper submits these comments on the proposed Yadkin River Water Supply Project(YRWSP) Interbasin Transfer Draft Environmental Impact Statement. The Yadkin Riverkeeper is a 501c(3) organization whose mission is to protect drinkable, fishable, swimmable water in the Yadkin basin. We are a membership-based organization and have members whose use and enjoyment of the waters of the Yadkin/Pee Dee within the project area are affected by the proposed YRWSP Interbasin Transfer.

YRK supports water from a given hydrologic unit staying within its natural watershed. If we are to have sustainable long-term growth in North Carolina, our communities must exist within the carrying capacity of their natural systems. To reach, as the proposed alternative does, outside of the Rocky River basin in which the majority of the projected growth will fall, creates unnecessary costs and environmental impacts. For this reason, we raise a number of concerns about the preferred Alternative 1A favored by the Draft EIS. While we agree that Union County must “secure a reliable water supply” we disagree that Alternative 1A is the most efficient means of doing so, either in cost to ratepayers or in terms of environmental impact.

  1. Assumptions
  1. Projected Growth in Union County

The Draft is inconsistent in its descriptions of induced growth related to the proposed project. Specifically, the Draft states that the no action alternative would lead to economic stagnation, but then when estimating the impacts of alternatives, the Draft estimates the impacts of growth from the IBT will be “minor” or “insignificant”. If the projected growth cannot occur without one of the action alternatives being chosen, the environmental impacts of that growth must be factored into the “Secondary” and “Cumulative” impact analyses.

If alternatives themselves will dictate growth, a consideration of meaningful alternatives must then consider different patterns of induced growth paired with different potential water sources.

  1. Projected Need for Water

The EIS takes as a given the 28.9 MGD Maximum Monthly Average Projected Water Demand. However, this is not the only reasonable definition of the project’s “Purpose and Need”. Nowhere in the EIS is a different growth path considered, and how the various projects might satisfy a different target. Given that growth rates in Union County have fluctuated widely in the last decade, it is only prudent, when considering the largest capital expenditure Union County faces, to evaluate the alternatives in relation to a range of growth scenarios.

In particular, the stated Purpose and Need, set at 23 MGD, forecloses the possibility of a water supply within the Rocky River subbasin because a withdrawal of that size would, “necessitate a large portion of the total water within the Rocky River be withdrawn at this location[Just above Highway 205].” Draft EIS, p. 276

Given that Alternative 5is, by far, the lowest cost option at almost $50 million cheaper than Preferred Alternative 1A($190 to $239 million), an alternatives analysis is not complete without a study of what level of water could be withdrawn from the Rocky while achieving minimal environmental impacts.

  1. Finding a watershed carrying capacity

Ultimately, the most sustainable long-term supply of water for the area will come from its local ground and surface waters. By reaching outside of this area, Union County puts itself in long-term competition for Yadkin River water with other municipalities and opens itself to the possibility that, as with its current agreement with Anson County, a change in local politics will require additional investment in the future. Indeed, the Draft admits that the Preferred Alternative 1A was selected not because it was the most cost efficient or because it had the least environmental impact but because of the current political environment, “"...Union County held discussions with numerous entities along the Yadkin river regarding partnerships for water supply. Of all those contacted, the Town of Norwood was the only political jurisdiction who expressed a desire to participate in a partnership with mutual benefits for both parties." Draft EIS August 2015, p. 25

  1. Local Impacts

The preferred alternative 1A is not the option with the least environmental impacts either during construction or after. Alternative 1A will impact 551 acres,Alternative 5 will impact only 67. Draft EIS, p. 225 Alternative 5 will impact less than 10% as much land, permanently and during construction compared to 1A. Alternative 5 is the only alternative outside of modifying existing current WTPs that will not impact any current agricultural land. In terms of Significant Natural Heritage Areas Alternative 5 impacts 5.5 acres whileAlternative 1A will impact 7.2 acres of significant Natural Heritage Area.Alternative 5 does not impact any perennial streams,only 1,343 feet of intermittent stream on 3 crossing vs. 11,014 feet of intermittent stream via 20 crossings and 2,848 ft of perennial streams via 11 crossings.

By the majority of environmental impact indicators, then Alternative 1A is not the least environmentally damaging option. The primary area it differs from Alternative 1A is that it would withdraw water from the Rocky River rather than a reservoir on the Yadkin, like Lake Tillery.

The feasibility of re-classification of the Rocky River as a drinking water supply should be more thoroughly investigated in the Draft EIS, in conjunction with looking at whether the Purpose and Need could be met with a conjunction of efficiency measures combined with a smaller Maximum Monthly Average withdrawal.

Before attempting to take clean water from a distant reservoir, the County must come to terms with the impact current growth is having on its own Rocky River, which is impaired for copper, turbidity and biological integrity. Draft EIS, p.281. We would respectfully submit that when local waters are impaired, the long-term solution to them is not to seek water elsewhere but to protect those waters to the point where they are a viable water supply. An assessment of the cost of mitigating the impacts of a low-head dam on the Rocky River are not included in the Draft EIS, nor are any estimate of what stormwater and land conservation measures would be necessary to bring the Rocky into line with state water supply guidelines.

  1. Water Efficiency

The Draft EIS takes 125 gallons per capita per day as its baseline used to project demand upon the municipal water system. By contrast, the United States Geological Survey estimates per capita per day usage at 80-100 a day for the average American. The Draft itself averaged acknowledges that historical data shows per capita usage in Union County, “between 110 to 120 gpcd, with slightly lower values in the most recent years due to ongoing mandatory water restrictions, increased conservation efforts, and more favorable climate conditions (more annual rainfall and slightly lower annual temperature averages).” Draft EIS, P.15 We would urge that those hard-won lower averages be taken as the new norm and that used to estimate, in conjunction with slowing growth, a variety of projected water demand levels by which the project alternatives can then be meaningfully evaluated.

Conclusion

The alternatives proposed do not explore the full extent of options available. Instead of choosing the local, low-cost option of drawing water from the Rocky River in conjunction efforts to reduce per capita usage, the Preferred Alternative is more expensive, more dependent upon politics and more damaging to streams and land across Union County than other available options.

Sincerely,

William M. Scott

Yadkin Riverkeeper