20051457 Ver 1_Other Agency Correspondence_20050727

North Carolina
Department of Environment and Natural Resources
Division of Water Resources
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Michael F. Easley, Governor ~
William G. Ross, Jr., Secretary
John Morris, Director u'
July 27, Zoos
MEMORANDUM
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NCDENR
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TO: David Baker, US Army Corps of Engineers
FROM: John Sutherland, Division of Water Reso
RE: Proposed First Broad River Reservoir
Cleveland County Sanitary District
Corps Action ID# 200330194
The North Carolina Division of Water Resources (DWR) has reviewed the public notice
for the reservoir on the First Broad River proposed by the Cleveland County Sanitary
District (CCSD) and has the following scoping comments. Our comments have been
numbered to allow easier reference during future discussions.
DWR's primary interest is the flow regime downstream of the proposed reservoir
and the effects on instream uses of those flows -including aquatic habitat, water
quality, recreation, and channel maintenance and sediment transport. A reservoir
with a surface area of 2,245 acres and a dam height of 83 feet would have a
storage capacity capable of substantially regulating downstream hydrology. The
environmental evaluation for this project should compare the effects of
unregulated versus regulated downstream hydrology.
2. The evaluation of potential hydrologic changes will require the development of a
reservoir model that is capable of simulating various operating alternatives for the
release, withdrawal and storage of water. The applicant and their consultant
should consult with DWR in developing this model.
3. Monthly flow duration curves with overlaid plots of the unregulated versus
proposed flow regime are just one output product needed for review. The Index
of Hydrologic Alteration (IHA) developed by The Nature Conservancy is another
tool that should be employed to compare flow regimes
(http://www.freshwaters.or toolsn.

NCDWR comments on Corps Action ID# 200330194
Proposed First Broad River Reservoir, Page 3
9. Depending on the downstream flow regime, reservoirs have the potential to
reduce the ability of the downstream river reach to support recreational use.
CCSD and their consultants should evaluate existing and potential downstream
recreational use and flows needed to allow use by the appropriate watercraft.
10. A water supply expansion of this magnitude will need to address concerns
regarding not just direct impacts, but also secondary and cumulative impacts.
Environmental documents prepared by CCSD and their consultants will need to
describe how CCSD is prepared to manage growth accompanying the water
supply expansion. Measures to minimize adverse impacts to terrestrial and
aquatic habitats should be described in detail.
Based on the size of the proposed project and the extent of potential impacts, it is our
recommendation that an Environmental Impact Statement (EIS) be prepared. This
document could be used to meet the requirements of both the National and State
Environmental Policy Acts (NEPA and SEPA). It would also provide information
needed to review the various other permits that will be needed for the proposed project in
addition to Section 401 and 404 review, including: Division of Land Resources -Land
Quality Section Dam Safety permit; Division of Environmental Health -Public Water
Supply Section Approval; and potential changes to critical area boundaries for waters
classified for water supply by DWQ.
We appreciate this opportunity to comment and will be glad to discuss our comments
with you, the applicant or their consultants.
cc: Linwood Peele, Tom Fransen, Fred Tarver, and Jim Mead - DWR
Shannon Deaton and Ron Linville, WRC
Darlene Kucken, DWQ
John Ellis, USFWS
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