20061203 Ver 2_Western Wake Comment Summary 102507 PDT materials (11-29-07)_20071129

Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at October 25, 2007 PDT Meeting No. 6

Jennifer Haynie - DWQ Construction Grjnts and Loans
1. Identification In the second bullet on Page 2, the last sentence states that

1
WRF Site
Introduction qualitative scoring might also be used. Since no qualitative
Discussion regarding qualitative scoring has been added to the document.
Alternatives
Al analysis for this portion of the screening was discussed, please
remove this sentence.
a. In the second paragraph (Page 8), the different sites considered
for each wastewater management option is described in the
bulletized list. Since no management option number is given, it is
confusing and difficult to figure out how each of the options listed Concur - reference to wastewater management option has been added for each
relate to the options described in the Wastewater Management bullet.
Options document. It might be better to list the sites and the option
number for which these sites were considered. Then, reference the
appropriate option on the other document (or section number when
the EIS is drafted).

2 1. Identification
of WRF Site III.B - Wastewater
b. The fifth sentence of the first paragraph ("Siting a WRF in the
Alternatives Management Option lowest elevation...") states that the reason for selecting sites for the
preferred wastewater management alternative is that the sites are To eliminate the redundancy, the phrase "...because they are located near the
at the bottom of the service area. The bulletized list in the next bottom of the service area for this wastewater management option" has been
paragraph provides the same reasoning for selecting the sites and deleted from the bullet list.
is redundant with the previous paragraph. Please revise these
paragraphs to minimize redundancy.
c. In the bulletized list, please note which option is the preferred
wastewater management option so that the reader will be able to Concur - reference to wastewater management option has been added for each
note which sites make the initial cut based on wastewater bullet, and the selected option has been noted.
management option.
a. When documentation becomes available, please include it with Concur - will include this documentation and citations when received.
appropriate citations.

3 1. Identification
of WRF Site IILC - Shearon Harris
b. The last sentence of the third paragraph (Page 11) discusses a
Alternatives Lake Level communication between Progress Energy and the Town of Holly
Has been added as Attachment 3 to the Identification of WRF Site Alternatives
Springs. Please provide proof of this communication in the document.
appropriate attachment for this document (or appendix in the EIS)
and refer the reader to it.
Once the analysis is complete, please include a map that would
show the sites that were eliminated with shading for the number of
Identification of Water Reclamation reasons (e.g., red for three reasons, orange for two reasons, yellow
4
Facility Site Alternatives
for one reason). This will allow the reader to visually understand This map has been added as Figure 9.
which sites had multiple reasons for being eliminated and would
solidify the rationale for why these sites were eliminated.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at October 25, 2007 PDT Meeting No. 6
CG&L believes that this table should not include information related
to the site minus the 200-foot buffer or the practicable area, as this
1. General level analysis is broad and not detailed. Additionally, including
these two areas appears to be double-counting. Please remove
this information from Site Data and Physical Environment.
We included this data to show the results of scoring several ways. Although the
WRF sites are approximatley 200 acres in size, only 50 to 60 acres will be used
for construction of the WRF facilities. We thought it would be worthwhile to
consider whether the best-scoring sites changed based on consideration of the
entire site vs. the likely area where the facilities would be constructed. For
example, it is possible that a WRF site could have extensive wetlands on the site
but very few wetlands where the facilities would be built. Discussion has been
added to the Qualitative Analysis section.
The full site scoring is shown as the primary methodology, and the site minus
200-ft buffer and practicable area methods are considered as alternative scoring
methodologies. We avoided double-counting by not including the data for each
of three areas on a single table. The three tables are meant to be considered as
three different ways to score the data. Scoring for the full site data shows that
Sites 17, 19, 21/23, and 30 score better than or equal to the Partners' preferred
site. Scoring for the site minus 200-foot buffer and practicable area is provided
for information as alternate ways to view the data. This alternate scoring
reinforces that Sites 19, 21/23, and 30 are the sites that score best.
a. Item Per conversations in previous meetings, please define Site Access,
11. Data Tables Transportation, and Other Services to be either by secondary roads These are defined in Table 3.
#2.a with adequate weight limits or by using bridge weight limits.
In the material provided at the September 2007 PDT meeting, the
list of intermediate criteria presents wetlands and lakes/ponds as
separate criteria. Likewise, perennial and intermittent streams are
b. Items presented as separate criteria. The data table from the October
4 and 5 2007 PDT meeting shows wetlands and lakes/ponds and perennial
2. Part A - and intermittent streams combined. Since the combination of
Physical these features was not discussed with the PDT, please keep them
Environment separate when conducting the data analysis.
a. In conjunction with Comment 11.2.c, please consider
c. Item 4 wetlands and lakes/ponds separately, as these features may be
considered to be two distinct types of Waters of the U.S. by the
U.S. Army Corps of Engineers (USAGE).
When the criteria were originally developed, these were four individual criteria
under the category Wetlands and Waters of the US/State. Based on the analysis
of data, these were condensed to two criteria. See responses below.
In doing the GIS analysis, it was noted that the majority of ponds overlapped with
either hydric soils or NWI information used to identify wetlands. Therefore, these
sites were included as wetlands and were not double counted also as
lakes/ponds. In considering the regulatory significance of ponds, they could be
regulated as wetlands depending on the characteristics such as being located on-
line within an intermittent or perennial stream. If they were upland ponds, they
have little regulatory significance. Since the area of these ponds were typically
small, about 5 acres or less, it was decided to add these to the wetlands as a
worst case measure of wetlands impacts.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at October 25, 2007 PDT Meeting No. 6

For perennial and intermittent streams, Wake County maintains a GIS data layer
for County streams that bases the perennial and intermittent stream type on
USGS blue lines. This information was developed for use with the Neuse River
In conjunction with Comment II.2.c, please consider perennial and buffer requirements developed by DWQ which are identical for intermittent and
2. Part A - intermittent streams separately, as these are two different types of perennial streams. Field studies have indicated that this information is not
5 II. Data Tables Physical
d. Item 5
streams. Depending on which Town's buffer regulations are reliable for differentiating intermittent and perennial streams. While the local
contd
( ) contd
( ) Environment considered, then the buffers for perennial and intermittent streams governments may have additional (in comparison with the Neuse rules) buffer
(contd) may be different. requirements that differ between intermittent and perennial streams, each of the
jurisdictions with potential sites have slightly different requirements. Based on
the problems with the data and that DWQ treats these streams similarly from a
regulatory standpoint, they were combined for the purpose of the intermediate
screening analysis.
On several of the maps, it is clear that the practicable area may be
shifted as needed. While these other areas may not be as
expedient environmentally, the environmental impacts of this
project are so minor that the difference in shifting the Practicable See response to Comment 5, II. 1.
Area may not be significant. To avoid assumptions that the
Practicable Area is the area where the WWRWRF would be built
for each site, please do not show the Practicable Area on any
mapping or include in any calculations.
On the mapping with aerial photography, the contours other than
the 260-foot and 240-foot contours makes the map very busy and Maps have been revised as requested.
6 III. Mapping difficult to read. Please remove these extraneous contours.
The Practicable Area on the maps with aerial photography are hard
to see. If the Practicable Area remains as a criterion, please Maps have been revised as requested.
choose another color besides black for the border.
Some of the maps do not differentiate between perennial and
intermittent streams. Please break out these two types of streams Maps have been revised as requested.
on all of the maps.
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