Erin Stewart - Aqua Sierra, Inc ATTACHMENT 1.

April 4, 2014
Mr. Justin Bashaw
USACE, Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403 -1343
justin.p.bashawkusace. army. mil
Mr. David Wainwright
North Carolina Division of Water Resources
512 North Salisbury Street
Raleigh, NC 27604
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Re: Concerns regarding the Environmental Assessment (EA)
for A Demonstration Project Showing the Impact of Floating In -Lake Long
Distance Circulators in B /E. Jordan Lake, March 2014
Dear Mr. Bashaw and Mr. David Wainwright,
The following evaluation and comments to the Environmental Assessment (EA) a
Demonstration Proiect Showing the Impact of Floating In -Lake Lona Distance Circulators in
B /E. Jordan Lake are submitted on behalf of Aqua Sierra Inc. (ASI). ASI is a full service
fisheries and water quality consulting firm based in Morrison, Colorado. Established in 1989
and staffed by a multidisciplinary team of biologists and engineers; the team at ASI brings over
135 years of experience in the management and recommendations of aquatic systems.
Although this EA is in regards to North Carolina General Assembly passed Session Law 2013-
360, which mandates that the North Carolina Division of Water Resources (NCDWR) utilize
solar in -lake circulators for a 24 -month demonstration project for the prevention and reduction of
noxious algal blooms and high levels of chlorophyll a due to elevated nutrients in the Haw River
and Morgan Creek Arms of Jordan Lake, it does not include the consideration of any
alternatives that could also solve these problems, such as bottom diffused aeration.
In reviewing the EA, references, and appendices, we found conflicting statements, obscure
wording, a lack of data supporting claims and a language of clear bias in the support of the Solar
Bee technology. The document also raised significant concerns regarding the attractive
nuisance, recreational disturbance, potential interference to wildlife, and high maintenance these
units will present.
We propose that a comprehensive comparison of all available alternatives should be provided.
ASI would like the opportunity to propose bottom diffused aeration as an alternative. Our
proprietary systems are custom designed to mitigate and manage specific problems, such as
dissolved oxygen, as well as, elemental, organic, and chemical pollutants. Representatives from
ASI have been involved in the Jordan Lake aeration proposal process since September 2011 and

submitted an alternative proposal to the WEARS system originally considered in a more
centralized location in the lake.
We believe that both the Corp of Engineers and project shareholders would support that the goal
of an environmental assessment is to provide a full unbiased review of both the short and long-
term, positive and negative effects of a project or program on the environment. In the case of a
multiuse resource, such as Jordan Lake, additional considerations are needed in the assessment
of the treatment benefits /effects, recreational impact, liability created for shareholders, aesthetic
impacts, and other alternatives for solving nutrient related water quality issues. A breakdown of
our concerns and unaddressed items are listed below.
Sincerely,
Erin Stewart
Fisheries Biologist / Field Services Manager
Aqua Sierra Inc.
9094 US Hwy 285 Morrison CO 80465
(303) 697 -5486
erinstewart I gaqua- sierra.com

Aqua Sierra Inc. Concerns regarding the Environmental Assessment (EA)
for A Demonstration Project Showing the Impact of Floating In -Lake Long
Distance Circulators in B /E. Jordan Lake, March 2014
1. Section 1.0 of the Introduction, states:
"The circulators would upwell water from near the bottom of the hypolimnion to the surface (epilimnion) of
the lake."
ASI Comments: The depth of the hypolimnion and epilimnion change on a regular basis since
they are affected by flow, temperature, weather, precipitation, etc. How will it be verified that
the circulators are pulling water from "near the bottom" of the hypolimnion? What will the
depth of the intake tubes be at each location? Will the intake depth affect flow rate? How will
the seasonal change in depth, especially in the Morgan Creek Arm under drought conditions.
2. Section 1.1.2, The Demonstration Project states:
"20 monitoring sites are now located on Jordan Lake. Eleven new stations have been established including
four within the Morgan Creek Arm study area and five within the Haw River Arm study area. One new station
is located in the New Hope Creek arm. These eleven sites have been established to monitor and determine the
effectiveness of this demonstration project and have been monitored monthly since July 2013 in anticipation
of the project."
ASI Comments: This is only 8 months of data for 11 of the 20 monitoring sites. It seems very
difficult to verify the effectiveness of a potential solution when a full 12 months of seasonal data
has not been collected. Ideally multiple years of data would be available in order to accurately
attribute effects of the demonstration.
3. This sections also states:
"Phytoplankton samples would be collected at selected sites chosen by proximity to circulators. Microscopic
analysis would used to determine species composition."
ASI Comments: At what proximity to the units would these samples be collected? The impact
would be much greater the closer you are to the units. The samples should be collected at a
specified distance from the circulators; but not in close proximity of the units in order to get an
accurate evaluation of treatment area. Also, it is important to evaluate the density of the
phytoplankton, not just species composition, which will determine if the population is just
present and /or thriving.
4. Section 2.0, Purpose and Need for the Proposed Action states:
"The biggest water quality concern in Jordan Lake is nutrient loading; specifically relating to nitrogen and
phosphorus. These two nutrients have contributed to excessive chlorophyll a concentrations and noxious algal
blooms."
ASI Comments: The source of the nutrient loading, internal and/or external, within Jordan Lake
needs to be identified. Re- suspension of phosphorous that has been previously locked to the
sediments is a natural occurrence in anoxic conditions. Circulators do not typically keep a high
dissolved oxygen level at the sediment /water interface since intake tubes are not at the bottom of
a water body allowing for anoxic conditions to persist and phosphorous to become re- suspended.

It is difficult to conceive that any form of local treatment would impact external loading.
External loading should be controlled at point source, such as TMDL regulations that are already
put in place for Jordan Lake.
5. Section 3.0, Alternatives Considered states:
"Due to stipulations outlined in Session Law 2013- 360 §14.3A.(a), consideration of installation feasibility, and
likely product efficacy, solar powered in -lake long- distance circulators have been selected as the preferred
action for this demonstration project. "
ASI Comments: We propose that all available alternatives should be fairly weighed and assessed
to provide the shareholders with the best technology to solve the water quality issues in Jordan
Lake responsible for noxious algal blooms. The National Environmental Policy Act of 1969
(NEPA) supports these claims in Sec. 102 [42 USC § 43321 Part B which states that US Public
laws shall be interpreted and administered in accordance with the policies set forth in the Act,
and Federal Government agencies shall:
(B) "identify and develop methods and procedures, in consultation with the Council on Environmental Quality
established by title II of this Act, which will insure that presently unquantified environmental amenities and
values may be given appropriate consideration in decision making along with economic and technical
considerations;" (NEPA, Online)
6. Sec. 102 [42 USC § 43321 Part E states Federal Government agencies shall:
(E) "study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which
involves unresolved conflicts concerning alternative uses of available resources;" (NEPA, Online)
ASI Comments: Bottom diffused aeration is a great alternative to the options presented in the EA
for Jordan Lake. This type of aeration promotes high concentrations of dissolved oxygen
throughout the entire water column allowing phosphorous to be locked to the bottom of a water
body and speed up the nitrification cycle reducing the availability of nitrogen. With high levels
of oxygen throughout the treatment area, greater fish habitat can be achieved increasing the
overall biological carrying capacity of the reservoir. These types of systems do not contain
moving parts in the water, do not impact nesting or migratory patterns of waterfowl, and have
little to no impact on recreational activity. The equipment for the system is located on shore
where maintenance can be performed easily when necessary (typically two to four times per year
maximum) and vandalism can be discouraged through the use of concrete buildings and locks.
Aqua Sierra can propose a bottom diffused aeration system to be used as an alternative to the in-
lake long- distance circulators as completed for the WEARS project previously considered on
Jordan Lake.
Note: Please see attached document, Bear Creek Reservoir Case Study
7. Section 3.1, No Action Alternative states:
"With the no action alternative, it is likely that water quality concerns in Jordan Lake would gradually improve
because the TMDL would remain in place."
ASI Comments: How will the demonstration be able to prove any effects if the "no action"
alternative will also improve water quality over time due to reduction in point source and non -
point sources of total nitrogen and phosphorus inputs? Biological studies typically only change

one variable in order to obtain sound scientific data. When multiple parameters are altered at
one time, it is difficult to determine what the effect of each alternative offers.
8. Section 3.2, Solar Powered In -Lake Long- Distance Circulators states:
"Battery failure could affect circulator performance when battery power is required until replaced.
Additionally, solar panels may need to be cleaned for optimum performance, especially during periods of little
or no rain. However, the units would be inspected for proper operation and any necessary maintenance
performed on a routine basis (at least weekly). It would be possible to clean solar panels at that time as
required."
ASI Comments: The batteries in solar powered systems retain energy for them to operate;
therefore, battery failure will indeed affect circulator performance. Also maintenance on an "at
least weekly" routine basis seems very intensive and costly. What entity is responsible for this
maintenance? What are the associated costs? How will battery failure be detected? How will
pumping capacity be affected over time as the pump motors age? Do they require regular
maintenance or rebuilds to maintain defined function? How will the change in treatment
overtime be handled?
What is the storage capacity of the solar battery units? What is the impact of cloudy, rainy days
which are inherent in this part of the world year around? How will treatment be impacted if the
units are unable to function for extended period of times?
9. Section 3.2, Solar Powered In -Lake Long- Distance Circulators also states:
"In order to meet the objectives of the demonstration project, a total of 24 circulators would be placed in the
Morgan Creek Arm. Circulators placed in the northern portion of the Morgan Creek Arm would need to
operate in shallow water. The deepest part of the Morgan Creek project area is near the mouth, where the
depth is approximately 10 -12 feet and becomes progressively shallower moving upstream, with no apparent
channels (Triangle J Council of Governments, 2013). The Haw River Arm is deeper, and does have a more
defined channel. The deepest parts are near the mouth where depths are about 45 feet deep and are about
35 feet deep in the upper part of the project area."
ASI Comments: How will the differences in depth account for the units upwelling "water from
near the bottom of the hypolimnion" as stated in section 1.0?
"The upper (northern) part of Morgan Creek is shallow and may dry up under extreme drought conditions. As
a result, circulators placed in the upper parts of Morgan Creek Arm would be configured to operate in shallow
water and not suffer failure if operated out of water. Circulators can operate in as little as three feet of water,
and would completely stop circulating water at approximately two -foot depth. "
ASI Comments: What happens if these areas dry up and the units are then isolated? If the motors
are not impacted by running dry, what about the propeller not being able to turn because it is
stuck in the mud? What happens to the intake tube if the water below the unit disappears?
10. Section 3.2, Proposed Action - Demonstration of Solar Powered In -Lake Long -
Distance Circulators states:
"The State of North Carolina is proposing a demonstration project which includes the installation of 36 solar
powered in -lake long- distance circulators in portions of Jordan Lake. These circulators are capable of a direct
flow rate of up to 3,000 gallons per minute (GPM) (401 ft3 per minute) with an induced flow rate of 10,000
GPM (1,337 ft3 per minute)"

ASI Comments: The proposed action states an "up to" volume for treatment. What impacts the
direct flow rate? The Medora website does not specify a unit that has a flow rate of up to
3000gpm. The SB2500 specifications indicate flow rate of 2,500 GPM whereas the SB500
indicates a flow rate of 5000gpm. Are these units special order or made specifically for this
application? Is there additional information that supports the calculations for the flow rate
presented?
a. Session Law 2013 - 360 §14.3A.(a) states: "At a minimum, the in -lake mechanical system
chosen must meet the following criteria:
(1) Floating equipment shall be capable of continuous operation on solar power only during day,
night, and extended overcast conditions 365 days per year. Continuous operation shall be
defined as operating a minimum of ninety -seven percent (97 %) of the total hours during the
course of one year on solar power without reliance on any connection to the alternating
current power grid.
(2) Achieve a total flow rate through the impellers on a continuous basis for 24 hours per day of
72,000 gallons per minute in the Morgan Creek arm and 36,000 gallons per minute in the
Haw River arm."
ASI Comments: The pumping rate should be verified based off the size of the proposed motors,
diameter of propeller and specified pumping rates of the units to be utilized in the demonstration.
The capacity of the batteries should be verified to ensure that the units are capable of 97%
operation in extended periods of clouds, rain or fog. If the units are only capable of pumping
2,500 gpm each this would not meet the minimum criteria stated in Section 2013 -360§ 14.3A.(a).
Since specifications are not provided for the proposed 3000gpm unit, this could not be confirmed
for this demonstration project.
11. This Section also states:
"One potential concern with upwelling water from depth is the potential for anoxic water to be brought to the
surface potentially reducing dissolved oxygen at the surface. There is a possibility that anoxic conditions could
be present, especially in deeper areas of Jordan Lake. However, as previously mentioned, the water would be
drawn up from above the thermocline, where dissolved oxygen levels are relatively higher than those below
the thermocline. Therefore, it is not likely that anoxic water would be brought to the surface from deeper
areas, as this water is typically present below the thermocline. There is a possibility that hypoxic or anoxic
conditions may periodically exist; however, any decrease in dissolved oxygen levels at the surface are
expected to be relatively short lived, lasting no more than a few days. "
ASI Comments: In the introduction it was stated that the water would be pumped from "near the
bottom of the hypolimnion"; however, here it states that "the water would be drawn up from
above the thermocline ". This is a conflicting statement. If the water is pumped from near the
bottom of the hypolimnion, it will likely be anoxic. The depth of the intake tubes at each location
will likely impact the quality of the water being brought to the surface.
12. Section 5.1.6, Water Quality states:
"According to the State, implementation of circulators in the Morgan Creek Arm and Haw River Arms is
expected to improve water quality by enhancing nutrient management strategies already in place. These
strategies include the B. Everett Jordan Reservoir, North Carolina Phase 1 Total Maximum Daily Load (TMDL)
allocations which require reductions from both point and non -point sources of nutrients, the Jordan Lake

Buffer Rules which require riparian zones in the watershed to be protected, stringent storm water collection
and treatment requirements, and Unified Development Ordinance regulations in more developed areas and
portions of the JLNMS. The circulators are expected to improve water quality by decreasing chlorophyll a
concentrations, reducing turbidity, and lowering pH."
ASI Comments: Again, how will the demonstration be able to prove any direct effects since the
TMDL regulations are already in place and having a positive effect on reductions in nutrient
inputs?
13. Section 5.1.11, Aesthetics states:
"A buoy or marker would be used to mark the anchor point and give warning about the circulator. These
would be a highly visible color such as white or bright orange and be able to be seen from shore or from an
appropriate distance away. Other safety features would include Coast Guard approved lighting, and /or
reflective tape or bands, and /or highly visible signage and strobe lights for nighttime visibility. The circulators
would visually affect aesthetics in a manner similar to that of a channel marker (Figure 25). Circulators and
accompanying markers would present a small visual impact from shore or boat, but would not significantly
impact aesthetic resources.
The proposed action would affect the aesthetics of the project areas. Aesthetics would be impacted as the
circulators would be seen floating on the water surface. However, the low profile of the circulators would
make it difficult for them to be seen at a distance. Associated markers and signage may be visible as well. The
no action alternative will not affect aesthetic resources."
ASI Comments: It is stated that the units will be "marked with a highly visible color which would
be able to be seen from shore or appropriate distance away" and then in the next paragraph it
states that "the low profile of the circulators would make it difficult for them to be seen at a
distance." This is also a very contradictory statement. How can the units be well marked with a
highly visible color but difficult to see at a distance? The current view is of an unobstructed
water body that will now be littered with many 16" diameter floating objects with highly visible
color and flashing strobe lights. Objects impeding the unobstructed view will be a significant
impact to the aesthetics of the resource.
14. Section 5.3.2 Fish and Wildlife states:
"Many waterfowl frequent Jordan Lake and may rest, forage, or nest in or near the Lake. These activities
would be precluded in the immediate vicinity of circulators. The velocity of water at the circulator head would
be about 0.2 feet -per- second, which may be too turbulent for waterfowl to rest and possibly paddle in.
However, the velocity of the water leaving the circulator head dissipates with distance. Swimming and
foraging should be able to occur within a short distance of the circulator. Wading birds would be less
impacted. None of the circulators would be placed very close (greater than 100 feet) to shore (Figure 9) and all
would be located in water at least five feet deep, which is too deep for wading birds. It is anticipated that
wading birds would be unaffected by circulators in shallower waters of the project areas. The circulators
would be outfitted with bird deterrent devices to keep birds from resting or roosting on them.
Neither the proposed action nor the no action alternative would have an effect on waterfowl."
ASI Comments: The velocity of water at the circulator head may be too turbulent for waterfowl
and could result in injury or death if a bird entered this area. It is also possible that the flashing
strobe lights will have an impact to bird populations. Currently there are many units on the
market that utilize strobe light technology to deter bird populations from aquatic resources. One
product, Away with Geese claims that a 360° degree flashing strobe is an effective way to drive
geese away by disrupting sleep patterns causing them to relocate. Deta et al, states that light

pollution can impact animal navigation, alter competitive or predator -prey interactions and affect
animal physiology. Based on this, these types of lights could affect migratory bird navigation,
eagle feeding activities over the water, vertical migration of zooplankton, and fish behavior.
While species more accustomed to humans and manmade structure (i.e. Seagulls and Double -
Crested Cormorants) may show less intimidation, more sensitive waterfowl and bird species may
avoid stages, feeding, and congregating in the vicinity of the floating circulators. Seagulls and
cormorants on the other hand will likely use the platforms and towers as a perch. Cormorants
lack the protective oil coats on their skin common to other water birds and require a perch on
which to stretch their wings and dry themselves. Where these species congregate and perch, they
also defecate. Due to the prevalence of these species on and around Jordan Lake and the
perceived safety from predation provided by the floating platform, it can be reasonably expected
the WEARS system will act as a perch and catch the birds' defecation. Bird feces are primarily
comprised of highly corrosive uric acid, which will ultimately breakdown and compromise any
surface, equipment, or machinery upon which it sits.
15. Section 5.3.2.3 Fisheries states:
"The fate of juvenile and smaller fish in regards to the circulator intake and impeller is another concern. The
NCWRC has suggested that a one millimeter mesh intake screen be installed to prevent fishes from contacting
the impeller."
ASI Comments: A one millimeter mesh screen will require significant additional maintenance
and will ultimately affect performance of the units. Any organic or inorganic material in the
water column (i.e. algae, plants, zooplankton, fish, debris, etc.) will get sucked into this mesh
restricting water flow up the draft tube of the circulator unit. This screen will likely need to be
cleaned or replaced on a regular basis resulting in possibly reduced efficacy of the units and
intense, regular maintenance.
16. Section 5.3.3 Endangered and Threatened Species states:
"Bald eagles are a common sight on Jordan Lake, and watching them is a popular recreational activity. It is
reported that Jordan Lake is home to the largest population of bald eagles on the east coast (NCDPR). The
NCNHP has records of nesting bald eagles near the Morgan Creek Arm project area since 2011 (Weakley,
2013). The project would not affect bald eagle nests and would have no direct physical impacts on bald eagles.
One of the primary sources of food for bald eagles is fish, which are abundant in waters of Jordan Lake. The
circulators are not anticipated to have a negative effect on fish populations. It is quite possible that circulating
water may have a positive impact on fish populations, as more desirable and edible algae would be available
as food, turbidity is expected to decrease, and water could have higher dissolved oxygen levels. An increase in
fish populations could be a benefit to bald eagles. The impacts of the project on fish populations are discussed
further in Section 5.3.2.3. The proposed action would not affect bald eagle populations."
ASI Comments: Could these floating units deter the eagles from wanting to fish in the areas
where they are located? The multiple units could affect navigation on the water where eagles
would potentially fish. Please refer to comments in number 12.
17. Section 5.3.3 Recreation states:
"The circulators would have a minimal impact on fishing. While boaters would be able to approach the
circulators to fish, anchoring within 100 feet of the circulator would be discouraged as to not entangle the
tether line."

"The proposed action would have minimal impacts on recreational opportunities."
"Although boaters may be inconvenienced by having to navigate around circulators and by not being able to
anchor in the immediate vicinity of the circulators, adequate space would be available for navigation and
anchoring in the project areas while maintaining a safe distance from circulators. Circulators would be
properly marked to alert boaters of their location, during all types of light conditions (day and night). The
proposed action represents a small adverse impact to recreation in the project areas."
ASI Comments: The reduction of water use within 100 feet of each of the solar circulators would
have a significant impact to the available water area utilized for recreational activities, such as
fishing and swimming, as well as limits the navigable water to boats for transportation.
Calculations indicate that this would be a total reduction of approximately 753,600sf in the
Morgan Creek Arm and approximately 376,800sf in the Haw Creek Arm based on the number of
proposed units. Will boaters consider the reduction in available area for fishing and being
"inconvenienced by having to navigate around circulators" a "minimal [impact] to recreational
opportunities "?
18. Section 5.4.6 Safety states:
"A safety concern with the proposed action, deployment of circulators in Jordan Lake, is that they may pose a
navigational safety hazard to boaters. "
"The circulators would pose a safety risk. "
ASI Comments: The proximity of the solar circulators to each other, the alcohol policies
involving boating in the state of North Carolina, and the permissibility of minors to operate both
mechanized and non - mechanized watercraft makes the presence of the floating solar circulators
on the water a significant legal liability to Jordan Lake shareholders. Jordan Lake is an active
recreational resource in close proximity to multiple population centers. The proposed floating
solar circulator systems with protective buoys, strobe lights, solar panels, bird deterrents, will
attract attention. Be it boater traffic commuting across the lake, fishermen or swimmers, the
solar circulator units will plausibly act both as an impediment to recreational traffic and an
attractive oddity to explore.
The floating solar circulating units would act as an "attractive nuisance" and could leave the
shareholders susceptible to litigation and legal liability in the case of an associated accident
especially if involving a minor. The Doctrine of Attractive Nuisance states that the landowner is
liable for leaving a condition or object on their property that attracts and then injures a minor.
Regardless of the unspecified measure that would be taken to ensure boater safety, these units
would remain an attractive nuisance to minors, the public would be susceptible to harm, and the
shareholders left vulnerable to litigation and legal liability in the case of injury or death.
19. Section 5.4.6 Environmental Impact Comparison of Alternatives states:
"A comparison of impacts for solar powered in -lake long- distance circulators (proposed action) and the no
action alternative are presented below. No other alternatives other than in -lake long- distance circulators have
been carried forward for further consideration, as they would not meet the stipulations of Session Law 2013 -
360§14.3A.(a). Various types of in -lake long- distance circulators, including solar powered, AC powered, and
wind powered were considered and discussed in Section 3.0. All alternatives except for the no action
alternative and solar powered in -lake long- distance circulators were dismissed as alternatives for various
reasons and are therefore not included."

ASI Comments: Since this EA does not consider other alternatives, it appears to be in conflict
with the NEPA Act of 1969.
20. Section 6.5 Executive Order 13186 (Protection of Migratory Birds) states:
"Neither the proposed action nor the no action alternative would have a significant impact on migratory birds.
ASI Comments: The potential impact to migratory birds by the flashing strobe lights on the units
needs to be considered. Please see comment number 12.
21. Section 13.0 Finding of this Environmental Assessment states:
"The proposed action would not significantly impact the quality of the human environment: therefore an
Environmental Impact Statement would not be required. If this opinion is upheld following circulation and
review of this EA, a Finding of No Significant Impacts (FONSI) would be signed and circulated."
ASI Comments: We do not agree that this proposed action will not significantly impact the
quality of the human environment. We propose that an Environmental Impact Statement be
provided prior to the demonstration project. As previously stated the potential for harm is
apparent and should be considered to limit liability and litigation of the Jordan Lake
shareholders.
22. Appendix A (Scoping Comments Received) contains a letter from NCWRC regarding
request for an alternatives analysis including bottom diffused aeration. The letter
states:
"We are concerned about direct impacts of the aeration system on aquatic resources and recreational
boating. The EA should include an alternatives analysis that evaluates other alternatives (e.g. bottom diffuser)
to the proposed surface aeration system..."
ASI Comments: This specific concern was not addressed in the EA. There are also other
concerns that were listed in the letter that were neglected and should be addressed.
Aqua Sierra Inc. Contributors
William J. Logan, MS, President
Kendra L. Holmes, VP of Operations /Senior Fisheries Biologist
Erin Stewart, Fisheries Biologist

References
Away with Geese Website
Online: http:// www. birdcontrolsupplies .com/geesecontrol3.htm
Deta P., I Elberthagen, M. Klussmann. Light Pollution and the Impacts on Biodiversity, Species
and Their Habitats. Secretariat of the Convention on the Conservation of Migratory Species of
Wild Animals. 2007.
Online: http: / /www.starlight2007.net/pdf /proceedings /P_Deda.pdf
Doctrine of Attractive Nuisance Definition:
Online: http:/ /legal- dictionary.thefreedictionary.com /attractive +nuisance +doctrine
The National Environmental Policy Act of 1969, (NEPA) as amended
(Pub. L. 91 -190, 42 U.S.C. 4321 -4347, January 1, 1970, as amended by Pub. L. 94 -52, July 3,
1975, Pub. L. 94 -83, August 9, 1975, and Pub. L. 97 -258, § 4(b), Sept. 13, 1982)
Online: http: / /ceq.hss.doe. og v /nepa/re sg /nepa /nepaegia.htm
Medora Website
Online: http: / /lakes.medoraco.com /lakes /product - information
Turchick, Peter A. Supplemental Environmental Impact Statements: How Significant Should
New Information Be ?, 2 Pace Envtl. L. Rev. 298 (1985)
Online: http:// digitalcommons .pace.edu/pelr /vol2 /iss2 /6