20051457 Ver 1_Public Notice Comments_20050802

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July 28, 2005
Mr. David Baker
U.S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
RE: Public Notice and Comment
Conceptual Project: First Broad River Reservoir
Cleveland County, North Carolina
Dear Mr. Baker:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
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Based on a review of the subject notice by the NC Division of Water Quality's Planning Section,
it is recommended that, at a minimum, an Environmental Assessment be prepared. This is based
on concerns for flow impacts on water quality and aquatic life downstream of the dam and on
concerns for water quality within the proposed impoundment.
Based on benthic macroinvertebrate sampling and information presented in the Broad River
Basinwide Water Quality Plan (February 2003), streams in the watershed are marginally
supporting their best-intended use for aquatic life. Riparian areas, minimum stream flows and
nutrients are all important in maintaining and even improving the aquatic habitat in the First
Broad River watershed. Construction of the dam and the resulting downstream flow impacts
would result in further degradation of benthic communities and impairment of the stream.
DWQ recommends that an Environmental Site Assessment be conducted in the proposed project
area. Minimum stream flows should be calculated in order to maintain and improve the overall
aquatic habitat both upstream and downstream of the proposed reservoir. DWQ also
recommends that a nutrient model be created to assess potential inputs into the system, factoring
in the potential land use changes associated with population growth.
Thank you for the opportunity to provide comments on the proposed First Broad River Reservoir,
Lawndale, Cleveland County, North Carolina.
Sincerely,
Alan Clark
Chief, Planning Section
cc: Cyndi Karoly
-- NC Division of Water Quality, Section 4010versight ,,~
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N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina ?7699-1617 (9l9) 733-7015 Customer Service
1-877-623-6748

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July 17, 2005
North Carolina Division of Water Quality
1650 Mail Service Center
Raleigh, North Carolina 27699
Atten: Cyndi Karoly
Re: The new reservoir for Cleveland County
To Who This May Concern:
As a property owner of the proposed site for the reservoir, we would like to
inform you of our support for the building of the dam.
We feel that it would not only be needed for future water needs for the
county, but would it could also be beneficial to the economy of Cleveland
County.
Thank you.
Sincerely,
JUL 1 9 2005
DENR -WATER QUALITY
WETLANDS AND STORNNVATER BRANCH
_ ,
Walter J. auney Betty . Mauney

James M. Lee
138 Charlolais Drive
Lawndale, NC 28090
July 27, 2005
North Carolina Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699-1650
Dear Cindi Karoly:
AUC~ 1 'tq~ih

On behalf of the Heirs of Elizabeth Lee, owners of property on Hams Creek Road,
Cleveland County, North Carolina, we would like to go on record in favor of building the
proposed reservoir by the Cleveland County Sanitary District. We feel this reservoir will
be a huge asset to ow area primarily by providing a stable water source, with additional
benefits of recreation and overall improvement of the desirability of the area. We
received a letter from the US Army Corps of Engineers, so we believe the impoundment
will affect ow property.
Sincer 1 ,
'~_.
es M. Lee
Heir of Elizabeth Lee

To: NC Division of Water Quality
From: Rosa S. Greene
Re: Upper Cleveland County Reservior
I have been a resident of Polkville, NC for 12 years. I work in Shelby which is about 12 miles from my
home. There is no way that I can go to Shelby without crossing a bridge. There is nothing more
frightening than to look down at those rivers and there is no water, you can actually walk across the river
bed. Farmers were coming into our office, Farm Service Agency, needing water sources for their animals.
I do understand that some residents don't want to part with their land but this was a disaster and could have
been much, much worse. This may not happen in my lifetime but this project does need to be approved
and started as soon as possible. Yesterday, the temperature in Shelby was 102 and suppose to be the about
the wine today, it wouldn't take too many days to start drying the rivers up again. I would rather have
water on down the road than a piece of land that probably will never be used for anything.
Please approve the reservoir for our future.
Thank you for your time.
/s/Rosa S. Greene
cc: US Army Corp of Engineers
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Janet Sims
700 Westover Terrace
Shelby, NC 28150
July 21, 200
Cyndi Karoly
NC Division of Water Quality
1650 Mail Service Center
Raleigh, NC 27699
Ms. Karoly:
I am writing with concerns about the proposed Upper Cleveland dam/reservoir. I am
concerned, as I was several years ago, that the short-term and long-term environmental
impact of this project has only been minimally addressed. What effect will this project
have on wildlife, runoff, farmland, development, etc? What kinds of alternatives have
been explored? Are the additional lines from the Broad River (laid during recent
drought) being fully utilized? Finally, in 1997, the feasibility study from the Cleveland
County Sanitary District indicated that there was much opposition to this project. What
has changed?
Please request a public hearing on this matter.
Sincerely, ~ .
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Janet
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"'~'u~S'gH STTQ~LII'y
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JUL 2 ~ 20U5
Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
WETLANDS AND STORMVYA ER BRANCH
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I u.^.: eYY~SPd ±o the hRai.lding of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river becaus a develo mem comes into the
Upper Cleveland that will be forever lost as more and mo P
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition------ see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
~``"~~

Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
NIs. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First B~e aRdl River because of the resulting
environmental damage---- both short-term and long
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition----- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
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Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resuming
environmental damage--- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes into the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition---- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
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JUL 2 6 2005
DENR - WATER gUALITY
WETLANDS AND STDRMYVATER BRANCH

Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I w„, epYoCed tip the lie~iiding of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition------ see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.:-,
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Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition---- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
;~ a ~~e~ ,~~Y ~
ti.G~lJ/1/~/c(~Y~~r~ ~PG'c1U

Cyndi Karoly , , _ ~~
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the res~ilting
environmental damage---- both short-teen and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition----- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.

Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resulting
environmental damage---- i~otii ~'iio ~eiin nd lonb ±Prm.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition----- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
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Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
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Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resulting
environmental damage---- both short-terri~ aria long-tc~:.=.
I am opposed to the building of a dam on this river becmore develo mern comes in to the
Upper Cleveland that will be forever lost as more and P
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition---- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
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,-UL 2 7 2005
Cyndi Karoly IJEiJt~ -WATER QUALITY
North Carolina Division of Water Quality WETUwpSANDSTpRMWATERBRANCH
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
r, µ~;, ~pposPd to the building of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition---- see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
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Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
explored. Hand in hand with this is the issue of whether there is a real need for an
additional water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition------ see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
process.
Ron McCollum
~--
616 Ca ar-Lawndale Rd.
Lawndale, NC 28090
e-mail teweenot cr~yahoo.com
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JUL 2 5 2005
DENR -WATER QUALITY
YVETLANDS AND STORMWATER BRANCH

Cyndi Karoly
North Carolina Division of Water Quality
Raleigh, NC
Ms. Karoly:
I write regarding the proposed damming of the first Broad River in Upper Cleveland
County. I am opposed to the building of a dam or reservoir of any size on this river.
I am opposed to the building of a dam on the First Broad River because of the resulting
environmental damage---- both short-term and long-term.
I am opposed to the building of a dam on this river because of the rich cultural history of
Upper Cleveland that will be forever lost as more and more development comes in to the
area.
I am opposed to this effort because alternatives to the reservoir have not been seriously
expl` ored_Hand in hand with this is tlr~3ue o w ~e er there is a re nee or an
tonal water source in Cleveland County.
I am opposed to this effort because I believe the process has ignored a very loud voice of
opposition------ see the Cleveland County Sanitation District's own Feasibility Study of
1997 (appendix C to note this opposition).
I respectfully request Public Hearings be scheduled to allow for citizen input into this
~~w~~~~g~rb
JUL 2 5 2005
DENR -WATER QUALITY '~
'~/ETi.AMDS AND STORMtMATER BRANCH

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Re: FW: Property owners want hearing on upper Cleveland reservoir
Subject: Re: FW: Property owners want hearing on upper Cleveland reservoir
From: Cyndi Karoly <[e-mail]>
Date: Fri, OS Aug 2005 15:33:35 -0400
To: [e-mail], Tom Reeder <[e-mail]>, Alan Clark
<[e-mail]>, Alan Johnson <[e-mail]>, Melba McGee
<[e-mail]>, [e-mail], Rex Gleason
<[e-mail]>, Ian McMillan <[e-mail]>, Laurie J Dennison
<[e-mail]>
Elizabeth, et al
The 401 Unit received the Corps' Public Notice for this project on June 30, 2005, a
copy of which is attached. Note that the primary point of the PN is to serve as
notice of a formal 404/401 application. The secondary point is to solicit opinions as
to whether an EIS or EA should be required. This project has been entered in our
database as DWQ project #2005-1457 and you may encounter it under various nicknames
including Cleveland County Reservoir, First Broad River Reservoir, Cleveland County
Sanitary District c/o Butch Smith, Cleveland Dam, or the Uppper Cleveland
Dam/Reservoir. Since that time we've gotten 15 responses to the notice directed or
copied to DWQ and the Corps. These include four separate letters in favor, ten
opposed (nine of which were a form letter), and one from Alan Clark, Chief of DWQ's
Planning Section, directed to the Corps and recommending that an EA be prepared.
Apart from that, the only other file material at this time is a letter from the EPA
recommending an EIS. Once I get some feedback from Alan Johnson in the MRO as to his
technical review of the project, we'll send a collective hold letter from Central
with the following hold items:
1)they didn't pay an application fee,
2)need for a SEPA document (Melba - do you have any info or opinions to share?). Note
that if it's determined that a SEPA or NEPA document is required, we can't even begin
to process the 401 until the project has cleared the State Clearinghouse,
3) technical issues from MRO...
4)others...If there are other issues of which I need to be aware, with this project
already in the permit mill, please advise and I will be sure to include them in our
correspondence with the Corps and the applicant.
Also, for you folks here in Raleigh, I'll be happy to go over the 401 process and
share the file materials with you to help ensure that we all handle this properly.
i.e.- Elizabeth, With respect to the reclassification - that may put the brakes on
this application for a longer time than the SEPA question.
Elizabeth.KountisGncmail.net wrote:
This is the first I've heard about this project. Do you have any more info?
A reclassification may be needed for this proposed water supply.
Subject:
Property owners want hearing on upper Cleveland reservoir
From:
Susan massengale _<susan.massengale~~ncmail.net>
Date:
Thu, 28 Jul 2005 09:56:49 -0400
To:
DWQ Clips <DENR.DWQ Clips.DWQc~ncmail.net>
To:
DWQ Clips <DENR.DWQ C1ips.DWQ~ncmail.net>
1 of 2 8/5/2005 3:34 PM

Re: FW: Property owners want hearing on upper Cleveland reservoir
v
From the Shelby Star
Property owners want hearing on upper Cleveland reservoir
Joy Scott <mailto:Jo~Scottalink.freedom.com~
Star Staff Writer
Joy Scott
scott~link.freedom.com
SHELBY - At least one property owner has requested a public hearing concerning the
reservoir planned for upper Cleveland County, according to David Baker, a project
manager for the U.S. Army Corps of Engineers.
The Corps of Engineers is the agency that will approve or deny the Cleveland
County Sanitary District's request to build the reservoir by damming up part of
the First Broad River.
A date for a public hearing hasn't been set. The Corps would have to review the
person's reasons for asking for the hearing before deciding whether to hold one,
said Baker.
As of Monday the Corps received close to 20 letters, said Baker. Opinions of favor
and opposition are mixed, he said.
There's one day left for people to comment about the reservoir.
The district wants to build the reservoir to prevent a water shortage in case
there's another drought. It would consist of an 83-foot tall dam across the river,
1.4 miles north of Lawndale. A copy of the application, including the map of the
reservoir, can be viewed on the Corps' Web site (see below) and at the Corps'
Asheville office.
Thursday at 5 p.m. is the deadline to make a written request for a public hearing
on the project or to submit written comments to the Corps. The address is U.S.
Army Corp of Engineers, 151 Patton Ave., Room 208, Attn: David Baker, Asheville,
NC 28801-5006.
Anyone wanting to comment on the district's application under Section 401 of the
Clean Water Act should do so in writing to the North Carolina Division of Water
Quality, 1650 Mail Service Center, Raleigh, NC 27699-1650, Attn: Cyndi Karoly, by
July 28.
On the Web:
17601 *-* 7/27/2005 - LN
Content-Type: application/pdf
,First Broad River Reservoir.pdf
Content-Encoding: base64
2 of 2 8/5/2005 3:34 PM

FW: Propexty owners want hearing on upper Cleveland reservoir
Subject: FW: Property owners want hearing on upper Cleveland reservoir
From: [e-mail]
Date: Wed, 3 Aug 2005 08:38:04 -0400
To: [e-mail]
CC: [e-mail]
This is the first I've heard about this project. Do you have any more info?
A reclassification may be needed for this proposed water supply.
Subject: Property owners want hearing on upper Cleveland reservoir
From: Susan massengale <[e-mail]>
Date: Thu, 28 Ju12005 09:56:49 -0400
To: DWQ Clips <[e-mail]>
From the Shelby Star
Property owners want hearing on upper Cleveland reservoir
Joy Scott <mailto:Joy Scot t~?1ink.freedom.com>
Star Staff Writer
Joy Scott
scottClink.freedom.com
SHELBY - At least one property owner has requested a public hearing concerning the
reservoir planned for upper Cleveland County, according to David Baker, a project
manager for the U.S. Army Corps of Engineers.
The Corps of Engineers is the agency that will approve or deny the Cleveland County
Sanitary District's request to build the reservoir by damming up part of the First
Broad River.
A date for a public hearing hasn't been set. The Corps would have to review the
person's reasons for asking for the hearing before deciding whether to hold one, said
Baker.
As of Monday the Corps received close to 20 letters, said Baker. Opinions of favor
and opposition are mixed, he said.
There's one day left for people to comment about the reservoir.
The district wants to build the reservoir to prevent a water shortage in case there's
another drought. It would consist of an 83-foot tall dam across the river, 1.4 miles
north of Lawndale. A copy of the application, including the map of the reservoir, can
be viewed on the Corps' Web site (see below) and at the Corps' Asheville office.
Thursday at 5 p.m. is the deadline to make a written request for a public hearing on
the project or to submit written comments to the Corps. The address is U.S. Army Corp
of Engineers, 151 Patton Ave., Room 208, Attn: David Baker, Asheville, NC 28801-5006.
Anyone wanting to comment on the district's application under Section 401 of the
Clean Water Act should do so in writing to the North Carolina Division of Water
Quality, 1650 Mail Service Center, Raleigh, NC 27699-1650, Attn: Cyndi Karoly, by
July 28.
On the Web:
1 of 2 8/5/2005 2:46 PM

FW: Property owners want hearing on upper Cleveland reservoir
17601 *-* 7/27/2005 - LN

Property owners want hearing on upper Cleveland reservoir.eml Content-Type: message/rfc822
2 of 2 8/5/2005 2:46 PM

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
~"`~ s"'s~ REGION 4
. ~ .
~,~ ~ Sam Nunn Atlanta Federal Center
""~~ ~~ 61 Forsyth Street, S.W.
Atlanta, Georgia 30303 - 8960
August 1, 2005
Colonel Charles R. Alexander
District Engineer _- - -- °~-~.
._-- --~
ATTN: Mr. David Baker ~'"~'
i1.S. Armv Cams ~f F.n~ineers ~ :_ :: -'
151 Patton Avenue ~ ~~ " ' `' ~~
Asheville, NC 28801
,..,
SUBJ: Cleveland County Sanitary District ~'~"~"
First Broad River Reservoir
Action ID: 200330194
Dear Colonel Alexander:
This letter is in reference to the application by Cleveland County Sanitary District
(CCSD) described in the above referenced Public Notice (PN) dated June 28, 2005. The
application is for a proposed regional reservoir located on the First Broad River near the town of
Lawndale, in Cleveland County, North Carolina. The proposed reservoir would have a surface
area of approximately 2,245 acres and would impound 24 miles of river and streams. The
proposed mitigation for the loss of flowing water habitat includes a 100 foot forested buffer
around the lake, preservation of adjacent lands, development of a lake fishery, conservation
easements on tributaries and headwater areas around the reservoir, public access areas to the
lake. The PN also states that other stream restoration opportunities will be pursued. The
Environmental Protection Agency (EPA) has reviewed the project information contained in the
PN and have the following concerns with the proposed project.
The PN is soliciting input as to whether the magnitude of the impacts require the
preparation of an Environmental Assessment or an Environmental Impact Statement (EIS). We
believe the impacts associated with the removal of 24 miles of flowing aquatic habitat should
definitely be addressed through an EIS. This is an extremely large loss of flowing water aquatic
habitat. Due to the magnitude of the proposed impacts and the nature of the project we believe
an EIS level of analysis is needed to adequately evaluate the project. The remainder of this letter
will address some of our major comments with the proposed project.
The purpose and need section of the Preliminary Consultation Package (June 2005) is
open ended as to who will be the long term users of the reservoir. It mentions both Cleveland
County and upstream and downstream counties and the State of South Carolina. We support the
concept of regional reservoirs, versus each entity constructing their own water use reservoir. We
recommend a region wide planning process be performed with all current and potential future
water users to determine best means to use currently available resources and to plan for future

2
needs for the entire region rather than each entity going through this process individually. As
p&rt;of this process and before a reservoir is constructed we believe there is a need for service
agreeients with the various entities that will be users of the reservoir. We have encountered
other regional reservoir projects in the southeast where population projections were made based
on entities who later claimed to not be a part of any agreement and who wanted to construct their
own reservoirs. The application package mentions several other regional sources in the area
(City of Shelby, Kings Mountain, City of Hickory) and then also discusses other counties
(Rutherford, Gaston, Lincoln in North Carolina and Cherokee in South Carolina) that are
serviced by the CCSD. It is not clear, reading through the application information, as to who the
long term users will be and whether there can be any agreements with existing sources. This
whole issue seems rather vague from the information provided, with conflicting and overlapping
service areas. These regional issues should be better defined in the environmental document and
signed service agreements in place as to who will be the actual customers before the purpose and
need can be adequately evaluated.
In evaluating the alternatives presented in the preliminary information, we strongly
support the pump storage alternative over the traditional reservoir on the First Broad River. We
have found the pump storage reservoirs to be an effective alternative to the impoundment of a
river and have supported them in other states in the Southeast. There have been quite a few
regional reservoir projects in the Savannah District with,~everal of them using the pump storage
option. (Since Savannah District has had several projects of this nature in their district it may be
useful to contact them to see what insights they may be able to offer.) EPA has been supportive
of the pump storage projects over the traditional reservoir projects. The environmental impact is
significantly reduced and as the application information states the actual project costs with this
project are $14 million less for the pump storage alternative. We assume this cost does not
include the savings in mitigation which would be significant when one is looking at mitigating
for five miles of stream impact with the pump storage alternative versus 24 miles with the
current applicant preferred alternative. We strongly urge the applicant to consider the pump
storage option over the traditional reservoir option.
We have not seen enough detail on the proposed mitigation to make specific comments.
However, the applicant should understand we view the reservoir as an impact. We do not
believe a buffer around the impact site or an enhanced fishery and preservation of upland areas in
the watershed of the reservoir provide"in kind'replacement of the lost stream functions. Much of
the buffering and prevention of development of the watershed are measures that the applicant
would want to provide to protect the water quality in the water supply reservoir. Stream
restoration, enhancement and preservation activities would be the type of"in kind'replacement
measures we would recommend for mitigation of the flowing water habitat loss.
We also would like to see the encouragement of more water conservation measures. We
understand this is often difficult to get customers to do voluntarily. Passing more of the cost of
providing for water to the CCSD customers may be a useful means to encourage water
conservation.

3
We are enclosing a list of items that were prepared by EPA Region 4 to address reservoir
issues. These are, at a minimum, items we would like to see the applicant address in the
environmental document. We suggest you provide this list to the applicant
EPA appreciates the opportunity to comment on this project. We look forward to
working with you, the applicant and the other resource agencies to ensure this project is able to
provide the citizens serviced by the CCSD with an adequate future water supply at as minimum a
cost to the environment, as possible. If you have any questions regarding these comments,
please contact Becky Fox at [phone] or fox.rebecca@ epa.gov.
Sincerely,
ald J. ik lak, Chief
Wetland e latory Section
cc: USFWS, Asheville
NCDWQ, Raleigh
NCDWQ, Asheville
NCWRC, Kernersville
Enclosure

EPA Section 404 Reservoir Review c~. ~-~9-os>
(Based on Section 404 (b)(1) Guidelines -Factors EPA considers for reservoir projects)
1. Clearly stated project purpose that can be used for an alternatives analysis -includes needs
_ analysis, population projections, service area and design criteria.
2. Full alternatives analysis including:
a. all alternatives to meet project purpose
b. alternatives evaluated should include groundwater, surface water withdrawal without
an impoundment, reuse, combinations water sources, purchase of water, etc.
c. alternative reservoir locations (main stem, small tributary with pump storage, diked
upland lagoon, expansion of existing reservoir)
3. Avoidance -selection of least damaging practicable alternative
4. Minimization
a. reservoir is minimum size necessary for project purpose/need -this includes full
utilization of 75% of reservoir volume
b. water conservation and/or wastewater reuse programs to minimize demand
c. coordination with wastewater/stormwater discharges
d. staging of impoundment and/or withdrawals- fill to levels as needed
e. adjustment to location of dam and pool level for minimal impacts
f. dam designed to reduce downstream flow and water quality impacts, spill ways with
artificial aeration, variable depth penstocks for flexibility of release
g. region wide planning process for maximum efficiency of use including .integration with
wastewater and storm water management programs, regional reservoirs
h. accurate long range planning for best facility and avoidance of need for additional
reservoirs for same applicant or conflicting/overlapping service areas
Full disclosure of all potential impacts
a. accurate description of all wetland, stream and upland habitats to be filled, flooded or
cleared at-maximum (not just average) pool level -include future expansions
b. stream impacts described by stream order and in linear feet
c. description of pre-impoundment flows and water quality -including flow loss due to
increased evaporation from a reservoir (significant for small streams)
d. presence of any 303(d) listed or outstanding resource waters
e. for pump storage reservoirs, need to include stream withdrawal impacts in analysis
f. threatened/endangered species and species of concern, including migratory fishes
g. upstream and downstream discharges and withdrawals, interbasin transfers
h. potential for reservoir eutrophication -may include modeling of nutrients
i. potential for reservoir aquatic weed problems
j. potential for reservoir volume loss due to sedimentation
k. archeological and historical resources
1. presence of waste sites (old dumps, oxidation ponds etc)
m. human impacts -local opposition -relocations and condemnation

-2-
5. Full disclosure of all potential impacts (continued)
n. pre-delineation reductions of jurisdictional areas (i.e. draining of beaver ponds)
o. cumulative impact issues -historical wetland stream loss in watershed
p. impacts of related facilities including treatment plants, distribution lines and storage
facilities -approval under separate nationwide permits is not appropriate if facilities
are dependent on main project
q. expansion of wastewater treatment capacity issues
r. secondary impacts from development made possible by reservoir (additional fills)
s. loss of flood plains and flood storage capacity
t. ror large projects, sophisticated environmental assessment methods should be used
u. for large projects and/or cumulative impacts -environmental impact statement may be
needed - COE prepares or overviews third party preparation
6. Measures to minimize all impacts
a. guaranteed levels of downstream dissolved oxygen, temperature, flow quantity and
periodicity to maintain existing uses
b. dam operation and release plan based on monitoring to simulate natural conditions
c. erosion and sediment control plan during construction -watershed stormwater plan
d. air quality and noise reduction during construction
e. reservoir maintenance plan -includes any maintenance dredging and disposal
f. shoreline buffers/set backs/restrictions on development (with enforcement)
g. fish passage structures if appropriate
- h. relocation of species of concern (i.e. gopher tortoises, fish, mussels, plants)
i. restrictions/guidelines on recreational uses
j. reservoir destratification measures prior to release if needed
k. development and implementation of a watershed management source water
protection plan including measures/ability/willingness to protect reservoir watershed
7. Compensatory mitigation for loss of wetlands and streams
a. reported in acreage for wetlands, linear feet for streams - - -'
b. covers all impacts from maximum pool level
c. stream mitigation can include watershed level actions (buffers, ordinances etc.)
d. mitigation credit for upland buffers around reservoirs generally not acceptable
e. at least 50°Io of compensatory mitigation should be other than preservation
f. mitigation must be described in detail prior to issuance of any permit and strongly
encouraged prior to permit application
g. must use ecologically based success criteria for restoration/enhancement/creation,
generally based on reference site information
h. firm options on acquisition of proposed mitigation areas
i. mitigation site monitoring plans based on measuring ecologically based success criteria
j. permanent protection for mitigation areas (restrictive covenant, conservation easement)
k. downstream flow and stream morphology monitoring with corrective measures