20051457 Ver 1_Emails_20110830

Mcmillan, Ian
From:
Wicker, Henry M JR SAW [ Henry.M.Wicker.JR @usace.army.mil]
Sent:
Tuesday, August 30, 2011 12:16 PM
To:
gwood @lincolncounty.org; James McRight; John. Condrey @rutherfordcountync.gov; Selzer,
Britt; linvillejr @earthlink.net; Karoly, Cyndi; Johnson, Alan; renee .gledhill- earley @ncdenr.gov;
russtown @nccherokee.com; Holder, Michael L; Mead, Jim; Tarver, Fred;
turnerle @dhec.sc.gov; allen_ratzlaff @fws.gov; Bryan_Tompkins @fws.gov;
Fox.Rebecca @epamail.epa.gov; hortonjl @dhec.sc.gov; gormancm @dhec.sc.gov;
kfortner @gbpw.com; Rick.Howell @cityofshelby.com; marilyns @cityofkm.com; Reeder, Tom;
Mcgee, Melba; teweenot @yahoo.com; elammt @hotmail.com; stevek @cityofkm.com;
eporter @cityofkm.com; Goudreau, Chris J.; Mcmillan, Ian; Laycock.Kelly @epamail.epa.gov;
Jones, Amanda D SAW; Jones, Scott SAW; Brian McCrodden; Higgins, Karen;
danny .searcy @rutherfordcountync.gov
Cc:
Pugh, Robin; keith.webb @mcgillengineers.com; O'Quinn, Barney; pam boaze; CCSD
Manager
Subject:
FW: EPA comments prior to 9 -1 stakeholders meeting for FBRR (UNCLASSIFIED)
Attachments:
WE measures letter FBRR 071409 (signed).doc.pdf
Classification: UNCLASSIFIED
Caveats: NONE
Hello Everyone,
Becky Fox requested that I forward this E -mail and attachment to everyone on the agencies,
stakeholder team.
Henry Wicker
- - - -- Original Message---- -
From: Fox.Rebecca @epamail.epa.gov [ mailto :Fox.Rebecca @epamail.epa.gov]
Sent: Tuesday, August 30, 2011 10:19 AM
To: Wicker, Henry M JR SAW
Subject: Fw: EPA comments prior to 9 -1 stakeholders meeting for FBRR
Henry,
Would you mind forwarding this to stakeholders with my letter attachment?
Jennifer is out of the office until later this afternoon and I would like for
it to go out this morning if possible. It won't fly with the pdf file to
some many addressees from my remote access to epamail. Thanks much! b
Becky Fox
Wetlands and Marine Regulatory Section
USEPA
Phone: [phone]
Email: fox.rebecca @epa.gov
- - - -- Forwarded by Rebecca Fox /R4 /USEPA /US on 08/30/2011 10:14 AM - - - --
EPA comments prior to 9 -1 stakeholders meeting for FBRR (Document
link: Rebecca Fox)

Rebecca Fox
to:
Wicker, Henry M JR SAW
08/29/2011
07:21 PM
From Rebecca Fox /R4 /USEPA /US
To: "Wicker, Henry M JR SAW" < Henry .M.Wicker.JR @usace.army.mil>
Henry,
Thanks for sharing the pre meeting preliminary alternatives (AA) report for
the First Broad River Reservoir (FBRR). We are pleased that it currently
appears, at this time, there are alternatives other than the applicant
preferred alternative that would fulfill the LEPDA requirements.
We do have several comments we wanted to address prior to the September 1,
meeting. As you know, we sent the COE a formal letter (signed by the EPA
Region 4 wetlands and coastal branch chief) on duly 16, 2009 addressing
concerns we had about the incorporation of the EPA Region 4 Water Efficiency
Guidelines (WEGs), officially adopted on July 10, 2010.
We never received a response to this letter. Although the preliminary AA
report mentions the WEGs, there is no discussion as to whether they were used
to lower the projected demand. We acknowledge that Cleveland County is a
rural area and has a low demand and we are pleased they have already taken
some measures to conserve water, especially in times of drought but we also
believe their demand could be even lower with the incorporation of more of
the WEGs. We would like to note that we believe the measures in our
guidelines, that are determined to be practicable, should he enacted to he in
N

place at all times and that conservation no longer be viewed as measures to
be mainly enacted during times of drought. This is the new paradigm that is
being adopted across the entire United States.
We do not agree with the report that the alternative for water conservation
should not be carried through the report as a viable alternative. At this
time we are not proposing that water efficiency measures alone will provide
the entire projected water needs for Cleveland County but we would like to
see this alternative carried through as a supplemental alternative that
formally addresses the issues of our 7 -16 -09 letter and what impact these
may have on the projected demands and which alternatives when used in
conjunction with the WE measures would be the LEDPA. We ask that the COE
officially address each concern in our letter in a section of the AA report
and what impact these may have on the water needs. As we stated in our
letter we do not believe statements, such as, Cleveland County Water
(CCW) has no influence over ordinances proposed or passed by the Cleveland
County government are satisfactory when CCW is providing water for Cleveland
County. We are not suggesting that all of the WE measures will be
practicable but we are suggesting that each one is carefully addressed and
responded to. If this needs to be a section prepared by a separate entity
that specializes in this arena, we would fully support that it be handled in
that manner. We are open to suggestions as to how best to do this, but very
strongly request that water efficiency /conservation be carried through the
alternatives analysis and that it seriously addresses each of the concerns
in our 7 -16 -09 letter.
My supervisor (lennifer Derby) will be sending this message with our
7 -09 letter to stakeholder cclist in the morning. I am attaching our
7 -09 letter. Thanks! bf
(See attached file: WE measures letter FBRR 071409 (signed).doc.pdf)
Becky Fox
Wetlands and Marine Regulatory Section
USEPA
Phone: [phone]
Email: fox.rebecca @epa.gov
Classification: UNCLASSIFIED
Caveats: NONE
3

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
W REGION 4
o " ATLANTA FEDERAL CENTER
61 FORSYTH STREET
rq( PRO, ATLANTA, GEORGIA 30303 -8960
July 16, 2009
Mr. Henry Wicker
U.S. Army Corps of Engineers
69 Darlington Avenue
Wilmington, North Carolina 28403
Subject: EPA Comments on the "Consideration of EPA Drought Management Guidelines"
for the "Proposed First Broad River Reservoir" in Cleveland County, North Carolina
Dear Mr. Wicker:
The Environmental Protection Agency (EPA), Region 4, provided comments to the
project review team (PRT), for the proposed First Broad River Reservoir (FBRR) draft Purpose
and Need (P &N) statement on January 15, 2009, to address the compliance of the project with
the Region's draft Drought Management (Water Efficiency) Guidelines as the P &N and
Alternatives are developed for the Environmental Impact Statement (EIS). The U.S. Army
Corps of Engineers (Corps) provided EPA with a response to the request for the incorporation of
the EPA Guidelines concerning water efficiency measures for proposed reservoir projects on
March 24, 2009. We have reviewed the Corps' response and are providing the following
comments to further discuss EPA's position on the use of the Drought Management (Water
Efficiency) Guidelines as they relate to the FBRR project and the Corps' March 24, 2009,
response per our authority under the alternatives analysis in the 404(b) (1) Guidelines
(230.10(a)).
We appreciate the information provided by the Corps in their response but we felt it did
not completely address our concerns. Although the information provided addressed the concerns
in a general manner, stating that certain, measures could be looked into and that other measures
were outside of Cleveland County Water's (CCW) jurisdiction, etc., in many instances we did
not see the measures addressed with the specificity we feel are necessary for an adequate
alternatives analysis under the 404(b)(1) guidelines. Also, for the measures that CCW believed
they might be able to implement, there was no information as to how this might impact the water
demand projections thus minimizing the impacts to waters of the U. S. Some areas where we
would like to see more information provided are discussed below.
• Water Consumption Reduction Goals: We recommend the Sanitary District develop a
CCW Water Plan (if they have not already done so) which expands upon the current
CCW Water Conservation Plan to include the incorporation of the water efficiency (WE)
measures discussed in this and prior EPA correspondence and the Region 4 WE
guidelines. The plan should contain water consumption reduction goals, for example 10
Intemet Address (URL) • http: / /www.epa.gov
Recycled/Recyclable • Printed with Vegetable 011 Based Inks on Recycled Paper (Minimum 301/. Postconsumer)

percent by year 2011 or 15 percent by year 2016. Definite goals are an important
component of the Plan indicating that incorporation of water efficiency measures is an
important priority of the CCW.
Full Cost Pricing: The response does not state if the CCW prices reflect the full cost of
operating and maintaining the water utility. It also states there is a tiered system with a
variable fee that decreases as water consumption goes up rather than increasing so there
is no incentive to encourage water conservation. It has been shown that a tiered system
that charges significantly higher rates for above average water usages and lower rates for
conserving households can be very effective in reducing water consumption. This is also
effective in encouraging water users to replace old fixtures, such as toilets and shower
heads with more water efficient models and higher fees for water can be used for funding
conservation incentives such as toilet rebate programs.
The City of Greensboro, North Carolina adopted a conservation pricing structure in 2000
and in only seven years, average household consumption dropped 22 percent with only a
small increase of one third of a penny /gallon even at the highest rate.1 A paper by the
South Florida Water Management District states conservation pricing can yield 15
percent reduction in water consumption and Greensboro was able to exceed this amount.
The response goes on to state that CCW will reevaluate its rate structure. We believe this
is a measure that could produce significant savings for CCW and an evaluation of what
this could represent in water savings should be provided in the EIS and should be part of
the 404 (b)(1) evaluation in determining a practicable alternative.
Build Smart for the Future: The response states that CCW has limited authority to
require implementation of this measure requiring water efficient technologies in new
buildings because building codes and ordinances are adopted and administered by
Cleveland County government. We believe since CCW is responsible for providing
water to Cleveland County and other local governments and are pursuing the expense of a
new reservoir they should be in a position to strongly influence the local government(s)
supplied by their service to require water efficient measures in their building codes.
More information should be provided in the EIS than "CCW will encourage local
governments within its service area to update ordinances that would support or require
water efficiency technologies." An analysis should be provided as to what could
reasonably be required and what savings this would produce.
Meter All Water Users: The response states that multi - family housing comprises
approximately one percent of CCW's residential customers and therefore this measure
would not likely result in a measurable decrease in water usage. According to the 2000
Census, 8.9 percent of housing units in Cleveland County were in multi -unit structures.
This indicates to us that EPA's earlier statement concerning metering all water users
should be further addressed and may indeed be an opportunity for reduction in water
usage by the incorporation of this WE measure.
2

Retrofit All Buildings: Once again, the response states CCW does not have the authority
to require the retrofitting of old fixtures for property transfers but will consider this for
new customers. Old toilets, showerheads, etc waste a large amount of water. Toilets by
themselves use 26.7 percent of household water.3 Using an older model 3 to 7
gallon/flush toilet consumes between 63 percent and 81 percent more water than the more
water efficient 1.28 gallons /flush models.4 We are not sure what the distinction is
between property transfers and new customers, but we recommend that CCW pursue a
"retrofit on reconnect" ordinance as was passed by Dekalb County, Georgia in 2008
which required all new accounts to first upgrade all their plumbing fixtures to water
efficient varieties. If this was applied to all of Dekalb County homes built before the
1993 federal water efficiency requirements went into effect, Dekalb County would save
around 9 million gallons per day (MGD) or nearly 10 percent of its daily consumption.5
Another option that could be instituted is an ordinance requiring a plumbing retrofit
anytime a construction permit is issued.
The Cobb County, Georgia Water Authority began a voluntary toilet rebate program in
2007 and in a little over a year and using very conservative assumptions, it was roughly
estimated there was about a 65,000 gallons per day (GPD) reduction in water usage. This
was a voluntary program with only an approximate 9 percent participation rate and the
reduction estimate was calculated using very conservative assumptions.b A mandatory
program would obviously produce much greater savings. This program might also
qualify for EPA Drinking Water State Revolving Green Project Reserve set -aside funds
and would provide economic stimulus by providing jobs for plumbers to install retrofitted
toilets.
Concerning the statement that CCW will consider requiring water efficient fixtures with
new customers, we would like to see more information as to how implementing this
requirement could impact water usage.
CCW should also evaluate the benefits of voluntary incentive programs for rebates and
free audits for all customer sectors to evaluate where the most cost effective water
savings can be produced. These measures should be evaluated and information provided
as to what water consumption reductions these measures could produce. The information
provided indicates that CCW has a program to provide water audits and water efficiency
recommendations for business and industry. We recommend extending this program to
residential customers.
Water Loss: We commend CCW for their active leak detection and water loss prevention
program. According to the information provided their unaccounted water loss is now at
17 percent and their water demand projections are actually based on a 14 percent water
loss rate. Although we feel CCW is having good results with their water loss reduction
program, we believe the goal should be to further reduce the water loss below 14 percent.
EPA Region 4's drinking water program believes most water providers should be able to
reduce water loss to at least the accepted industry standard of 10 percent. Raleigh, North
Carolina has a very effective water loss reduction program which has been able to reduce

water loss to 4.5 percent. We encourage CCW to pursue means to further reduce water
loss rates and for that to be reflected in the water demand projections.
As we have stated in previous correspondence with Wilmington District and the PRT, we
believe water efficiency measures can and should be central to water supply planning. In
comparison, large reservoirs can be very costly in both money and environmental impacts (and
mitigation for environmental impacts) and can also lose large amounts of water through
evaporation. The evaluation of the implementation of these measures should be reflected in the
actual water demand projections and should also be an important consideration in the economic
practicability of the alternatives and in the determination of the least environmentally damaging
practicable alternative per the 404(b)(1) Guidelines 230.10 (a). As we have stated previously,
the implementation of these WE measures is being required by EPA Region 4 for all newly
proposed reservoir projects in the Southeast. Many of these measures are also being required by
water planning districts in the Southeastern states. (For example, see the Metropolitan North
Georgia Water District Water Supply and Conservation Plan at
http://w«,w.northp,eorgiawater.com/html/88.htm.) Should you have questions, feel free to
coordinate with Becky Fox of my staff at 828.497.3531 or at foxxebeccanepa. .Qov.
Sincerely,
Thomas C. Welborn
Chief,
Wetlands, Coastal & Oceans Branch
References
1. Williams, Kristine. City of Greensboro. Email communication. September 12, 2008.
Southwest Florida Water Management District. Water Rates: Conserving Water and Protecting
Resources.
3. Mayer, Peter, et. al., Residential End Use of Water, 1999, pp. 107 -108.
4. Mayer, Peter, et. al., USEPA Combined Retrofit Program, March 28, 2005.
5. Rogers, Kurlis. Dekalb County Department of Watershed, Personal Communication, September
5, 2008.
6. Buff, Arthur. USEPA Region 4 Water Sense Coordinator, June 2009.
Buchan, Ed, City of Raleigh - Public Utilities Department, Email communication, September 18,
2008.
4