19970722 Ver 1_Other Agency Comments_19980714

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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 9, 1998
Mr. Reginald R. Sutton
Division of Water Quality
Construction Loans and Grants Section
Post Office Box 29579
Raleigh, North Carolina 27626-0579
Dear Mr. Sutton:
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The U.S. Fish and Wildlife Service and the Department of the Interior have expressed a number
of concerns and reservations about the proposed Eastside Wastewater Treatment Plant (Eastside
WWTP) expansion and upgrade in High Point, Guilford County, (see letters dated August 15,
1997, February 12, 1998, and May 5, 1998) and the proposed Randleman Reservoir in Guilford
and Randolph Counties. A concerned citizen has informed us that recent actions by the City of
High Point may be actively facilitating increased point and nonpoint discharges, stormwater
runoff, wastewater needing treatment, and water supply demands through zoning variances and
changes which encourage or facilitate development in environmentally sensitive areas.
We have repeatedly recommended the City of High Point and other service area governments
investigate and implement nonstructural alternatives as appropriate point and non-point
reduction strategies, regardless of the outcome of the two proposals. Addendum No. 1 to the
Environmental Analysis for the Eastside Wastewater Treatment Plant Expansion and Upgrade,
dated March, 1998, implicitly recognized the value of this approach: "The City of High Point
will adopt watershed protection ordinances for the [proposed] Randleman Lake [reservoir]
watershed," "Expansions of wastewater treatment plants are typically responses to development,
rather than the impetus for it,." and "The local governments affected by the lake [actually, the
proposed reservoir] are working towards watershed protection goals that will ensure the best
possible water quality." (pp. AD 1).
Despite these statements, on June 29, 1998, the City of High Point apparently changed zoning
designations specifically to facilitate high density development of a 100 or more acre tract of
streams, riparian wetlands, and seeps in a low lying area in the Deep River watershed (upstream
of both High Point Lake reservoir and the proposed Randleman Reservoir and in the Eastside
WWTP service area). We are unaware of the rationale for this decision, however, it appears
inconsistent with the statements cited above.

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The zoning change may adversely affect nonstructural protections of existing and proposed
drinking water supply reservoirs and point and nonpoint discharges into the wastewater
treatment stream. The change would also increase demands on the water supply, stormwater
runoff, and wastewater treatment infrastructure in High Point. That, in turn, raises questions
about the (1) purpose and needs and (2) avoidance and minimization efforts described for the
Randleman Reservoir and WWTP expansion proposals.
We strongly recommend that all land and water management actions by the City of High Point
be assessed before any decisions about the proposed Eastside WWTP expansion and upgrade are
made by your agency. All actions regarding zoning, construction permits, property tax
assessments, and infrastructure should be identified and examined from the perspective of
potable water supply, wastewater streams, and point and nonpoint discharges. It is important to
determine whether or not the City of High Point has changed management practices to reflect the
existing and anticipated deficiencies in potable water supply and wastewater treatment capacity.
The recommended assessment will ensure that all efforts to avoid and minimize the adverse
impacts associated with the two proposals have been made before those activities are funded or
permitted.
Thank you for the opportunity to comment on this matter. Please call Kevin Moody of my staff
at [phone] extension 19 if you have any questions or comments.
Sincerely,
ohn M. Hefner
Ecological Services Supervisor
cc:
DWQ, Raleigh, NC (John Dorney)
WRC, Raleigh, NC (Frank McBride)
COE, Wilmington, NC (David Franklin)
COE, Raleigh, NC (John Thomas)
EPA, Wetlands Regulatory Branch, Atlanta, GA (Thomas Welborn)
FWS/R4:KMoody:KM:07/09/98:919/856-4520 extension 19:\hp-zone.wpd
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