20021769 Ver 3_Other Agency Comments_20070507

af`~ f o a- -'~ ~ 9 v3
Michael F. Easley, Governor
O~OF W AT ~9QG
~ y William G. Ross Jr., Secretary
~ f North Carolina Department of Environment and Natural Resources
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Alan W. Klimek, P. E. Director
r Division of Water Quality
May 1, 2007
To: Melba McGee, NCDENR ~ ~ . ~; ~A" f ?. ~;
A
From: Hannah Stallings, NCDENR/Division of Water Quality MAY' Z00(
Subject: Moore County -Southern Pines Raw Water Storage Reservoir 'IEiR~, - e^~-r,~i~=p ~?'-~Ai.i i Y
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DWQ#13829, DENR#07-0319
The Division of Water Quality has reviewed the subject project and has the following concerns.
1. Both Horse Creek and Drowning Creek are WS-II, HQW. The latest biological assessment
of this area indicates that it is supporting the High Quality Water (HQW) designation. Both
creeks received an Excellent macroinvertebrate bioclassification (2006 sampling). These
waters are unique must continue to be protected.
2. The unnamed tributary that will be dammed and the new emergency reservoir fall under the
WS-II, HQW classification. However this area may also need to be classified as CA (Critical
Area; normal classification for most drinking water intakes). Although DWR is the lead
agent on this project, coordination with DEH for classification purposes is recommended.
3. The town should provide more detailed maps to make a better assessment.
4. Is there an existing dam serving the town? If so, this is not seen on the map.
5. If there is an existing dam, will it be removed and how will impacts be minimized?
6. Where is the new dam to be located?
7. Since a dam is required to develop the reservoir, it is assumed that the reservoir is actually
inline with the unnamed tributary as opposed to offstream. This detail is impossible to
discern from the map available.
8. If the reservoir is inline with the unnamed tributary to Horse Creek, than a minimum release
flow must be established to maintain the Excellent bioclassification rating of these HQWs
below this impoundment.
9. The mitigation credits quoted do not appear to cover the impacts of this project. How were
these credits obtained?
10. Is the town proposing to use the 8 acres of high quality forested wetlands as mitigation? If so,
what agency approved this proposal?
11. The 401 permit application process for this project is not complete. The town has been
notified that it must first complete the SEPA process prior to submitting an application.
Also, flooding must be listed as an impact of this project. Although the 401 Unit will not
require mitigation for the flooded portions, it will require mitigative action for the
dam/spillway and other areas that will be filled.

12. This project is described as a 52.43-acre project. It is difficult to determine from the map if
this is the size of the reservoir or the project which includes the reservoir and protected buffer
area. Also, the impacts described do not seem to address a full 52.43-acre of disturbance. It
appears that this project could result in major negative environmental impacts to HQWs.
Therefore, it is recommended that an EIS be prepared for this project.
13. If this project is approved, the town should be required to have water restriction ordinances in
place that would go into effect prior to utilizing an emergency water supply reservoir.
Please contact me at 733-5083, ext. 555, if I can be of any additional help in resolving these
issues. Thank you.
Cc: Cyndi Karoly