A-9 (2)

NCDENR
North Carolina. Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 16, 2011
MEMORANDUM
To: Marshall Edwards, Project Development and Environmental Analysis, NCDOT
From: Brian Wrenn, Transportation Permitting Unit, Division of Water Quality`V? v
Subject: Comments on the Indirect Land Use Screening Report/Scenario Assessment (A-0009
A/B/C/D) and Cumulative Effects Summary (A-0009 A/B/C/D), Graham County, TIP
Project Number A-0009 A, B, C, D.
This office has reviewed the referenced document dated November 17, 2010. The NC Division of Water
Quality (NCDWQ) is responsible for the issuance of the Section 401 Water Quality Certification for
activities that impact Waters of the U.S., including wetlands. It is our understanding that the project as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters. NCDWQ
offers the following comments based on review of the aforementioned document:
1. It is NCDWQ's opinion that the study area for the referenced document should be expanded to
include additional portions of Cherokee and Swain Counties. Throughout the purpose and need
statement and the document, references are made to the importance of providing efficient access to
medical services, education, and job opportunities. Therefore, it is reasonable to assume that the
proposed project will act as a major commuter route for Graham County and could have indirect
and cumulative effects on surrounding communities such as Murphy, Bryson City and Sylva.
2. In Section 1.4 Notable Features, it is stated that there are no "High Quality Waters (HQWs) within
the ICE Study Area." This statement is incorrect. Several HQWs are located in developable lands
in the study area. In addition, a water supply Critical Area is located on the Cheoah River within a
half mile radius of the Town of Robbinsville's drinking water intake. These classification should be
added to the Notable Features discussion.
3. In Section 3.2 ICE Screening Evaluation Results, the screening factor Market for Development is
rated as low. This factor is based on the number of rezoning cases that occurred in the ICE study
area. Based on the fact that there are few to no land use ordinances in the ICE study area, this factor
could not be rated anything other than low. -An alternate method for determining the Market for 4
Development should be used to accurately reflect the potential impact of this factor.
4. In Section 3.2 ICE Screening Evaluation Results, the screening factor Public Sewer Availability is
fated as moderately low. The discussion in Section 2.2 Water and Sewer Provisions is unclear as to
whether this rating accounts for the planned expansion of the Town of Robbinsville's W WTP. This
discussion should be revised to clarify whether the WWTP expansion is included in the rating.
Transportation Permitting Unit One
1650 Mail Service Center, Raleigh, North Carolina 27699-1650 NOlrthCarO11 na
Location: 2321 Crabtree Blvd., Raleigh, North Carolina 27604 -/? rP+?1//
61rq if
Phone: [phone] FAX: [phone]'x i7
Internet: hnp:l/h2o.enr.slale.muslnmetlandsl.
An Equal Opponunity k Affirmative Action Employer
5. The last two sentences of Section 4.2.1• appear to be contradictory. The total growth effects of the
Build (9.5%) and the No-Build (9.8%) scenarios are provided, and then the No-Build scenario is
described as having lower growth than the Build scenario. This should be corrected.
6. It is unclear how the stated 0.8% increase in impervious surface between the No-Build and Build
scenarios will result in an additional 206 jobs and $4.56 million per year for Graham County. This
is especially difficult to understand considering the lengths that the report goes to in detailing the
few opportunities there are for developable land and attracting commercial and industrial
development. Table 13. states that 195 jobs per year will be accrued as a direct result of the project.
If the A-0009 project is completed by 2020, that means a total of 2,925 non-roadway jobs will have
been created in the design year as a direct result of the project. That is 52% of the employment
forecast for Graham County in 2035. Yet, by 2035 only an additional 584 acres of land in Graham
County will be developed as compared to the No-Build scenario. The economic forecast and the
impervious surface forecast seem contradictory to one another. Please provide additional
explanations on how these forecasts were developed.
NCDWQ appreciates the opportunity to provide comments on your project. Shall you have any questions
or require any additional information, please contact Brian Wrenn at 336-771-4952 or 919-807-6432.
cc: Lori Beckwith, US Army Corps of Engineers, Asheville Field Office
Donnie Brew, Federal Highway Administration
Chris Militscher, Environmental Protection Agency (electronic copy only)
Marla Chambers, NC Wildlife Resources Commission
Mike Parker, NCDWQ Asheville Regional Office
File Copy

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