Cassie Gavin - NC Chapter Sierra Club

Wainwright, David
From: Cassie Gavin <cassie.gavin @sierraclub.org>
Sent: Friday, April 04, 2014 12:15 PM
To: Bashaw, Justin P SAW
Subject: [EXTERNAL] NC Chapter Sierra Club's Comment on the Environmental Assessment for
"A Demonstration Project Showing the Impact of Floating In -Lake Long- Distance
Circulators in B.E. Jordan Lake" March 2014.
April 4, 2014
Mr. Justin Bashaw, Biologist
Environmental Resources Section
US Army Corps of Engineers, Wilmington District
69 Darlington Avenue
Wilmington, NC 28403 -1343
Submitted via email to: Justin. p. bashaw(cDusace. army. mil
Re: NC Chapter Sierra Club Comment on the Environmental Assessment (EA) for "A
Demonstration Project Showing the Impact of Floating In -Lake Long- Distance
Circulators in B.E. Jordan Lake" dated March 2014.
Thank you for this opportunity to comment on the Environmental Assessment for the pilot project to
place 36 floating water mixers in Jordan Lake. The NC Chapter of the Sierra Club urges the Army
Corps to not grant a USACE real estate license to the North Carolina Division of Water Resources
(NCDWR) for placement of circulators within the Morgan Creek and Haw River Arms of Jordan Lake.
Jordan Lake needs science -based solutions to control pollution, not water mixers. And we have the
science -based rules that will, based on modeling projections, lead to a cleaner Jordan Lake. The EA
itself notes in Section 3.1 "No Action Alternative" that without the addition of the water mixers, it is
likely that the water quality in Jordan Lake would gradually improve because the TMDL would remain
in place, necessitating nutrient management. But, the EA assumes, incorrectly, that nutrient
management strategies (like the Jordan Lake Rules) would stay in place. The Jordan Lake Rules were
adopted in 2009 in an effort to clean up the lake, a source of drinking water for 300,000 people. Last
year these clean -up rules were delayed for three years by the North Carolina legislature. This was the
third legislative delay of the clean up plan.
Instead of sticking with the science -based plan to prevent pollution, the legislature directed nearly $2
million in taxpayer funds to a lease of 36 floating water mixers. Excessive nutrients, nitrogen and
phosphorus, flow into the lake from stormwater and other sources and contribute to high
concentrations of chlorophyll a and algae. The SolarBee water mixers aim to reduce chlorphyll a, but
cannot, physically, reduce the inflow of nutrient pollution into Jordan Lake. Meanwhile, developers
are getting a three year reprieve from requirements to control their pollution so the nutrient pollution
problem may get worse.
Further, the pilot project described in the EA is unnecessary because this approach has already been
tried and failed in Lake Howell, Cabarrus County, NC. The legislature, DENR and the Corps' EA should
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have examined the Lake Howell example, including the Lake Howell monitoring and testing results
and study conclusion when evaluating the proposed Jordan Lake project.
Lake Howell is a 1,300 -acre reservoir that provides water to the Coddle Creek Water Treatment Plant
and the Kannapolis Water Treatment Plant. The drainage basin for Lake Howell is approximately 47
square miles in parts of Cabarrus, Rowan and Iredell Counties. Lake Howell was constructed in
1992 -1993 by Cabarrus County and originally called the Coddle Creek Reservoir. Cabarrus County
retains ownership of Lake Howell.
It appears that neither the legislature nor DENR reviewed the success rates of SolarBee projects in
other places in North Carolina before directing nearly $2 million in state funds to a lease of the
technology to be used on Jordan Lake. Cabarrus County tried using SolarBee water mixers to improve
water quality in Lake Howell - without success. The apparent lack of comparative research into
previous SolarBee projects calls the whole Jordan Lake project into question. The nearly $2M in
taxpayer funds being dedicated towards the Jordan Lake pilot project could be better used for
conservation projects, such as buffers, to protect clean water in the Jordan Lake watershed.
In 2007, problems were identified with Lake Howell water quality, water supply, taste and odor. The
Cabarrus County Water and Sewer Authority focused on aeration as a possible mitigation technique
for taste and odor problems tied to algal growth, particularly blue -green algae or cyanobacteria.
SolarBee mixing units were chosen as a mitigation measure and a year -long SolarBee pilot project
was done. Cabarrus County leased SolarBee water mixers with the aim to reduce metals, dissolved
oxygen, algae and chlorphyll a and thereby improve overall water quality, taste and odor in Lake
Howell. Cabarrus County worked with the UNC Charlotte Environmental Assistance Office to do
monitoring and testing of the SolarBee project.
In 2010 the final recommendation by UNC Charlotte Environmental Assistance Office was to
discontinue the SolarBee project due to minimal improvements in water quality and to study
developing a nutrient management plan to address problems including chlorophyll a. See Furr, Ray,
and Chad VonCannon, et al. UNCC Environmental Assistance Office, 27 10 2010. Web. 4 Apr 2014.
<eao.uncc.edu /sites /eao.uncc.edu /files /Lake Howell SolarBee Project PosterFINALI0- 27- 10.pdfx
The Jordan Lake Rules are such a nutrient management plan designed for Jordan Lake.
We know what needs to be done to clean up Jordan Lake - implementation of the Jordan Lake Rules.
Ultimately, North Carolina needs to move forward with planned controls on stormwater runoff from
new and existing development, and upgrades to upstream wastewater treatment plants. The Corps
can't make that happen, but it can end the sideshow of floating water mixers on Jordan Lake, and
thereby take away the state's excuse for further delay of the Jordan Lake Rules. Please do not grant
a USACE real estate license to the North Carolina Division of Water Resources (NCDWR) for
placement of circulators within the Morgan Creek and Haw River Arms of Jordan Lake.
Best,
Cassie Gavin, Director of Government Relations
Sierra Club - NC Chapter
cassie.gavin @sierraclub.org
19 W. Hargett Street, Suite 210
Raleigh, NC 27601
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919.833.8467 x 104