20191369 Ver 1_Comments to USACE_20191119

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
November 19, 2019
Corps Action ID# SAW-2018-00053
DWR# 20191369
Gaston County
David Shaeffer
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville NC 28801
Subject Project: Gaston County Landfill Expansion
Dear Mr. Shaeffer:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above referenced
property:
1. The applicant's Purpose and Need as stated in the application indicates that "to construct a
landfill on a new site would take a greater amount of time to do than the 2.5 years of remaining
lifespan at the existing landfill". The Division suggests that inadequate planning by Gaston
County Public Works Department should not be considered as a valid purpose and need for the
proposed project. Although it may be not be economically desirable, transportation of waste to
other local or regional landfills is a technologically feasible option which would provide the
County with the proper time to develop a more sufficient alternatives analysis for the proposed
expansion.
2. The applicant proposes 1.5:1 mitigation based on an NCSAM analysis, however the NCSAM
analysis has likely been influenced by prior development activities, therefore the Division
recommends reconsideration of whether the NCSAM evaluation is appropriate in this situation.
3. The Division has requested additional technical information from the applicant and requests
that the USACE also consider the attached letter during the review of the application.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
Noana GwauNn �
919.707.9000

Corps Action ID# SAW-2018-00053
DWR# 20191369
Page 2 of 2
Thank you for your considering the Division's comments during your review of this Individual Permit. If
you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
DocuSigned by:
466ED631098F411...
for Mac Haupt, Acting Supervisor
401 & Buffer Permitting Unit
cc: Kelly Thames, HDR (via email)
Olivia Munzer, NCWRC (via email)
Byron Hamstead, USFWS (via email)
DWR MRO
DWR — Wetlands and Buffer Permitting Branch