20161279 Ver 1_Correspondence_20150205

JOHN
RUNKLE
D.
ATTORNEY AT LAW
2121 DAMASCUS CHURCH ROAD
CHAPEL HILL, N.C. 27516
919-942-o600
[e-mail]
VIA MAIL AND EMAIL
February 2, 2015
Colonel Kevin P. Landers, Sr.
Wilmington District
US Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403
Re: REQUEST FOR ENVIRONMENTAL IMPACT STATEMENT
Chatham Park Development
Chatham County, North Carolina
Dear Colonel Landers:
I am writing you on behalf of Pittsboro Matters, Haw River Assembly, Chatham Citizens
for Effective Communities, Orange/Chatham Group of the Sierra Club, and Rocky River
Heritage Foundation. These are all nonprofit organizations in Chatham County,
representing groups and individuals concerned about the impacts of the massive
Chatham Park development on the natural and environmental resources in Chatham
County including the Haw River, Rocky River and upper Cape Fear River watersheds.
The Chatham Park development will have a direct and negative impact on the B.
Everett Jordan Dam and Lake, constructed by the US Army Corps of Engineers and
operated through a partnership between the US Army Corps of Engineers and the State
of North Carolina.
Of immediate concern is the lack of analysis and concrete information on the massive
residential and commercial development by Chatham Park LLC. On December 8, 2014,

the revised master plan was approved by the Pittsboro Board of Commissioners.' The
development consists of approximately 7,200 acres directly adjacent to the Haw River
and Jordan Lake property, encompassing 22,000 residential units with more than
22,000,000 sq. ft. of commercial and industrial space. Currently rural farm fields and
woodlands will be replaced with urban development and untold miles of roads and other
impervious surfaces.The cumulative impacts on wetlands, streams, buffer zones and
other aspects of water quality will be both significant and negative, and have so far been
largely undisclosed.
As it is being built out and after it is fully constructed, Chatham Park will have significant
direct and cumulative impacts on the already impaired Jordan Lake and the Haw
River.The water supply and wastewater treatment requirements alone will far exceed
available resources and will entail considerable capital outlays; wastewater estimates
for the development are 4.8 MGD. The master plan is exceedingly vague about
drinkingwater supplies and discharge options.
The Chatham watersheds and Jordan Lake are increasingly threatened by local
economic development activities that increase pollution loading from stormwater and
wastewater. Accordingly, a substantial need exists for more information for decision-
making and permitting processes using the type of environmental impact analyzes only
Federal agencies can provide.
WE THEREFORE REQUEST AN EIS focusing on the potential increases on all aspects
of this development, such as effluent discharges and surface runoff of sediments and
nutrients to the waters of the United States, including Jordan Lake. The EIS should
consider the inter -related and interdependent impacts of infrastructure projects such as
the major transportation projects, and water and wastewater projects needed for the
project.
The Chatham Park plan appears to be to piecemeal the entire development into a
series of minor projects; the master plan identifies 27 "small area plans." Apparently, the
strategy is to use a number of general nationwideor regional permits for developing
these small area plans, rather than applying for an individual Section 404 Permit and
the preparation of an EIS examining the whole project. The entire project needs to be
addressed as the impacts of the project are cumulative, rather than split into 27 pieces.
Everything that can be quantified should be quantified, and methods of quantification
should be thoroughly explained. We believe that no permits of any type including
nationwide general permits, can be or should be issued until an EIS for the entire
development has been completed and approved.
Without US Army Corp leadership, decisionmakers and the impacted communities will
never know the direct, indirect, and cumulative impacts from this development project or
their potential alternatives. As such, we would greatly appreciate your support for our
'The revised master plan for the Chatham Park development is available at on the Town of Pittsboro
website. http://pittsboronc.gov/index.asp?Type=B_BASIC&SEC={EF3BFB5C-E314-4A29-97EC-
51274510982A}&DE={84265D4A-AFDF-4989-91 BD-ED17D6C1001 C)

request. Representatives of the organizations signing this letter are available to further
discuss this request with you and your staff, and are ready to supply any additional
information you require.
Please inform us of any action you take on this request.
Sincerely,
John D. Runkle
cc. Andrew Williams, USACE Raleigh Regulatory Field Office
Tony Able, EPA Wetlands Regulatory Section
Jay Zimmerman, NC Division of Water Resources
Elaine Chiosso, Haw River Assembly
Amanda Robertson, Pittsboro Matters
Caroline Siverson, Chatham Citizens for Effective Communities
William M. Causey, Jr., Rocky River Heritage Foundation
Judith Ferster, Orange/Chatham Group of the Sierra Club