R4440 (13)

Little
R Tennessee
Watershed
Association
93 Church Street, Suite 214 • Franklin, NC 28734
OFFICE: 828-369-6402
WEB: www.itwa.org

September 21, 2010
LTWA Needmore Road Public Hearing Statement- TIP project number R4440
My name is Jenny Sanders and I am the Executive Director of the Little Tennessee
Watershed Association (LTWA). I am here to comment on behalf of the Little
Tennessee Watershed Association (LTWA) its Board of Directors and its.
membership (approximately 250) on the.DOT's proposed upgrades to Needmore
Road (SR 1364/SR1114). LTWA is a non-profit conservation organization located
in Franklin, NC that works to protect and restore the health of the waters of the
Little Tennessee River through monitoring, education, habitat restoration and citizen
action.
Since 1990, our staff biologist, Dr. William O. McLamey, has been monitoring the
health of the river and its tributaries through our Biomonitoring Program, conducted
annually. In fact, the program existed even before the organization was founded, and
it is one of the most successful in north America. The body of data collected through
this program is believed to be the largest body of fish-based biomonitoring data for
any similar sized watershed in the world, and was critically important in highlighting
the importance of conserving the Needmore tract years ago.
The Needmore Game Lands were protected specifically because of their outstanding
biodiversity and recreational value and many people in the community felt that these
values were an integral part of our local heritage. We wholeheartedly, agree with the
notion that the Needmore Road needs to serve the people who live along it and the
recreational users of the Game Lands. Spending $13 million of taxpayers' money by
inviting more and faster traffic by people who don't fall into those two categories is
contradictory to the purposes for which the DOT and other agencies invested so
much money and effort a decade ago.
As such, LTWA is in favor of a solution for Needmore Road that deals with safety
and environmental problems that currently exist there, and wishes to participate with
the DOT and the community in defining alternatives which will address both sets of
problems while serving local transportation needs and contributing to the realization
of the: goals for which the Needmore Game Lands was created. .

The mission of the Little Tennessee watershed Association is to protect and restore the health of the waters
of the Little Tennessee River and its tributaries upstream of the Fontana Reservoir
through monitoring, education, habitat protection and citizen action.

LTWA cannot support the DOT's preferred option because:
1. DOT states that the intent of the improvement is to "avoid or minimize adverse
impacts" to this outstanding stretch of river and rich game lands. Increased thru
traffic and the consequences of major road construction through acidic rock will
adversely impact the Needmore Game Lands and will alter the character of this
recreational area which comprises an integral part of our local heritage.
2. It is not consistent with the intent of the $17.5 million of public funds, including $7.5
million of DOT funds, invested to secure the Needmore Game Lands for
recreational use and protection of local heritage.
3. There are more immediate and pressing infrastructure and road repair needs that
should be addressed in our area with such a large expenditure of public dollars.
Needmore is a unique place that deserves a unique approach and the NC DOT's preferred
alternative (alternative E) has been consistently cited as the most invasive, environmentally
damaging and most risky (in terms of cost benefit ratio) alternative by every commenting
agency. This list includes: USEPA, USFWS, NC DENR, NC DWQ, NC EEP, NC NHP
and NC WRC.
We agree and ask that you work cooperatively with the represented agencies on the merger
team to take a more serious look at other less expensive, less invasive alternatives,
particularly Alternatives B (soil binder) and C (pave in place). We also ask that you consider
a suggestion that we have received from many people - designated pulls offs that allow
slower traffic to pull out of the way. With more information and perhaps some
modifications, these may become more affordable, palatable options that better serve the
community.
We feel very strongly that a full Environmental Impact Study and Biological Assessment are
in order to adequately review this proposed project and request that you complete both. I'll
also ask that you please send a copy of these documents to LTWA once they are completed.
Thank you for the opportunity to comment on this project.

Jenny Sanders, Executive Director
Little Tennessee Watershed Association
The mission of the Little Tennessee Watershed Association is to protect and restore the health of the waters
of the Little Tennessee River and its tributaries upstream of the Fontana Reservoir 4WW
through monitoring, education, habitat protection and citizen action. %0.

CC:
Ms. Marla Chambers, Western NCDOT Permit Coordinator, North Carolina Wildlife
Resources Commission, 12275 Swift Road, Oakboro, NC 28129
Mr. Chris Militscher, Environmental Protection Agency, 1313 Alderman Circle, Raleigh,
NC 27603
Mr. Brian Wrenn, North Carolina Division of Water Quality, Central Office, 2321 Crabtree
;Boulevard, Suite 250. Raleigh, NC 27604
Ms. Linda Pearsall, Director, Natural Heritage Program, North Carolina Department of
Environment and Natural Resources, 1601 Mail Service Center, Raleigh, NC 27699-1601
Ms. Lori Beckwith, Asheville Regulatory Field Office, U.S. Army Corps of Engineers, 151
Patton Avenue, Room 208, Asheville, NC 28801-5006
Ms. Marella Buncick, U.S. Fish and Wildlife Service, Asheville Filed Office, 160 Zillicoa
Street Asheville, NC 28801