20020672 Ver 3_Becker Comment_20150203

FREDERICK $ECKER III
6GO3 SADLER ROAD
WAXHAW. NORTH CAROLINA 28I%3
Amy Chapman
North Carolina Division of Water Resources
Transportation Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Ms. Chapman,
Please accept these comments on the Water Quality Application for the Monroe
ConnectorBypass in Union County, North Carolina.
Speaking for the town of Mineral Springs as mayor, I would point out that our town council on
September 12, 2013 adopted a resolution requesting, in part, that NC�OT "research, consider,
and implement lower-cost alternatives to the Bypass that will provide more cost-effective
solutions to current traffic congestion problems on US-74". Five towns in total, two of them in
the path of the �ypass, have adopted similar resolutions.
In addition, I would add several of my own personal concerns.
NCDWR and NCDOT, while both state agencies, must sometimes take adversarial positions
with each other. And I believe that the potential worsening of water quality in the basins
throughout the project area — AND beyond — has been grossly understated by NCDOT and will
come back to hau�,t the reputation of DWR as well as the health and well-being of Union
County's citizens if this permit is granted and this project goes forward. DWR must act strongly,
conscientiously, and proactively to prevent these environmental disasters before they happen.
I believe that NCDOT has overstated the "no-build" development estimate and understated the
"build" development estimate by using flawed and inelevant data and then looking the other
way. These two estimates bear no resemblance to the actual results of completed bypass-type
divided-highway projects in the Charlotte metropolitan area, where such roads — particularly at
their interchanges -� triggered massive development that would not have taken place had the
roads not been built. I-485 is the prime example.
NCDOT's "no build" analysis of the Bypass, found in Table 14 of the "Quantitative Indirect and
Cumulative Effects Analysis" in the EIS, dated November 2013, contemplates a 15% increase in
developed area (and water-quality-destroying impervious surface) if the Bypass is not built.
These estimates ignore the fact that much of the land near the Bypass's nine proposed

interchanges is already in the hands of "Limited Liability" real estate investment partnerships,
has been for years, and has NOT been developed because there is NO superhighway to serve that
land. I believe, based on twenty-five years of studying development patterns in Union and
Mecklenburg Counties, that much of this land will remain undeveloped, or be developed at very
low intensities, if the �ypass is not built to serve it. NCDOT's "no-build" estimate of plus 15%
by 2030 is ridiculous.
In fact, if the �ypass is not built, much of this land is likely to remain in agriculture, which is a
not-inconsequential factor in Union Cou�iy's economy. According to the North Carolina
Department of Agriculture, Union County is one of the state's leaders in agriculture. In 2012,
Union County ranked 2nd in soybean production, 2nd in wheat production, 3rd in broilers, 3rd in
layers, and 4�' in turkeys. Total agricultural receipts in 2012 were $464,077,235, placing Union
County 3rd in the state of North Carolina. Any perceived economic benefit to Union County from
the Bypass must be weighed against losses in agricultural revenue.
The notion that this $900 million, 19-mile road with nine interchanges would trigger only 2%0
more total development by 2030 if it is built (half of that developed area being the roads
themselves) is even more ridiculous (Table 15). Experience here has proven — over and over u�
that interchanges along roads like the Bypass trigger massive high-density residential
development and sprawling strip-retail development for a mile or more beyond the highway
corridor. Here we have N1NE opportunities for such massive water-quality-destroying sprawl.
And the claim that there will be 0% - that's ZERO PERCENT - additional industrial, office, and
institutional development if the Bypass is built would seem to completely invalidate the
economic development claims of so many of the "�ypass �oosters" both inside and outside
Union County.
This permit application anticipates permanent impacts to 15,495 linear feet of streams in the
corridor. That is nearly three miles of surface water — destroyed forever! And, worse, I believe
that even that number is underestimated because of the lack of consideration of the true effects
on development of these nine interchanges. Finally, worst of all, both Crooked Creek and
�i�chardson Creek — the largest creeks in the project area -- are already both rated "IlVIPAIRED"
by the US EPA. This highway project, rather than S�ROVING these impaired waters, will
massively exacerbate their impairment. Included in the surface watersheds to be impacted is the
water-supply watershed for the City of Monroe and its over 35,000 residents.
I would request that NC�WR not accept NCDOT's development estimates at face value but,
instead, commission an independent study that will reveal the TRUE level of development and
water-quality impact that the Monroe ConnectorBypass will cause. There is no other responsible
course of action! What is the alternative? Approve this permit application, watch an incredible
level of water-quality impai�rrr�ent, including damage to �onroe's drinking-water supply, occur

well before 2030, and then simply say "Oops!"? The best way to improve impaired water quality
is to prevent the impairment in the first place! Any further damage to our county's precious
surface waters could well be ineversible; "later" would be too late to repair that damage, damage
that would be a disastrous consequence of the construction of the Bypass.
�any credible studies have proven that the ConnectorBypass will not significantly improve
travel on US-74 or on any of the nearby two-lane roads, but that much lower-cost irnprovements
to US-74 itself and to various parallel routes would achieve the goal of increasing mobility in the
corridor! Not only would the savings be in the hundreds of millions of dollars, but the reduction
in environmental devastation achieved by building in already-disturbed corridors rather than
stripping out virgin woodlands and productive farmland would be a huge additional benefit! On
the other hand, the construction of the �'ypass with its nine interchanges, and all of the resulting
development, will actually make traffic and congestion much worse, safety much poorer, and
water-quality impacts much more severe.
When I come to these hearings and hear folks make passionate appeals to "build the Bypass" to
"take the trucks o�` the highway" and "make the roads safer for our children", I actually feel sad
- sad that these well-meaning folks have been led by NCDOT to believe that these safety
improvements would result from the Bypass, when, in fact, just the opposite is true.
So, PLEASE... for all the reasons stated, whether water quality itself, public safety, or simply
more effective use of tax dollars... deny the 401 Water Quality Certification for the Monroe
ConnectorBypass!
Thank you.
Sincerely,
��,�m„�� � °� �������,,,, ���w.
Frederick �eck�r III
Copy via email to [e-mail]
Enclosures:
Table 14: Upda.ted 2030 No-Build Land Use
Agricultural Production in Union County, 2012
Table 15: Updated 2030 Build Land Use

Monroe Connector/Bypass Drajt Qua»titative Indirect and Cumulative Effecls Analysis Update
Table 14: Updated 2030 No-Build Land Use
Total Residential 97,900 48°�0 13°�"0
LowDensityResidentia! 79,500 40� 12°0
Medium Densiry Residentia! 14,900 7% 1°o
High Density Residential 3,500 2°�n 0°�°0
Commercial 5,600 3°fo 1°�0
IndustriaUOfficeitnstitutional 8,700 4°a°a 1 °��a
Transportation 12,800 6°do 0°r"o
Total Developed 125,000 62% 15%
Agricultural Fields ; 14,600 7°!0 -3°!0
Agricultural Pasture/Hay and Natural Herbaceous 22,900 11% -5°�0
Total Agricultural 37,500 19o�a _80�0
Coniferous Culrivated Plantation 600 0°�0 0°l0
Successional Deciduous Forest 3,000 1°fo -1°do
Piedmont Xeric Pine Forests 600 0°do 0°✓0
Piedmont Dry-Mesic Pine Forests 3,100 2% -1%
Piedmont Xeric Woodlands 2,700 1% ' -1%0
Piedmont Dry-Mesic Oak and Hardwood Forests 11,800 6°fo -2°fa
Piedmont Deciduous Mesic Forest 4,500 2% -1°r°o '
Xeric Pine-Hardwood Woodlands and Forests 1,200 1°/0 0°�0
Dry Mesic Oak Pine Forests 7,000 3°fo I -1%0
Piedmont Mixed Bottomland Forests 1,600 1°fo 0°!0
Piedmont Oak Bottomland and Swamp Forests 1,500 1°�'0 0%
Total Forested 37,700 19°/a -7%
Barren (quarries, strip mines, and gravel pits) 0 0°!0 0%
Banen (bare mck and sand) 100 0% 0°do
Piedmont Submerged Aquatic Vegetation 0 0°/0 0°�0
Piedmont Emergent Vegetation 0 0°60 0°�0
Riverbank Shrublands 100 0% 0°fo
Floodplain Wet Shrublands 0 0°�0 0°!0
Open Water 1,500 1% 0°�0
Total Other 1,800 1% 0%
TOTAL 202,000 100% 0%
Notes: Results have been rounded to the nearest 100 acres and whole oercent. Differences were calculated orior to roundine. Totals mav annear
not to equal the sum of tbe parts because of rounding.
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Monroe Conn��2or/Bypass Draft Quantitative Indirecl and Cumulative Effects Analysis Update
The results of the updated Build Scenario are shown in Table 15. These results are analyzed in the
indirect and cumulative impacts review below. Map 18 shows the 2030 Build Scenario land use
conditions and Map 19 compares the Build Scenario land use conditions to the No-Build Scenario land
use conditions.
Table 15: Updated 2030 Build Land Use
Total Residential 99,700 49°�0 l��o
Low Density Residential 8Q 600 40% Q�
Medium Dertsity Residential I5, 600 8sn 1%
High Density Residential 3, S00 1°� p�
Gommercial 5,900 3% p��a
lndustriaUOfficeflnstitutional 8,800 4°r'o Qo/a
Transportation 13,900 7% 1%
Total Developed 128,200 63% 2%
Agricultural Fields 13,800 7% p�/a
Agriculhual PastureOHay and Natural Herbaceous 21,600 I t% _1�/a
Totai Agricultural 35,500 18% _1% I
Coniferous Cultivated Plantation 600 0°r'o 0°Ao
Successional Deciduous Forest 2,900 1°fo 0°/°0
Piedmont Xeric Pine Forests 600 0°do p��o
Piedmont Dry-Mesic Pine Forests !� 3,000 1°!o p��o
Piedmont Xeric Woodlands 2,600 1°fo 0°!0
Piedmont Dry-Mesic Oak and Hardwood Forests 11,500 6°�o p��o
Piedmont Deciduous Mesic Forest 4,300 2% 0°�0
Xeric Pine-liardwood Woodlands and Forests 1,200 1°!o p%
Dry Mesic Oak Pine Forests 6,800 3% p%
I Piedmont Mixed Bottomland Forests 1,600 1°do 0°!0
Piedmont Oak Bottomland and Swamp Forests 1,500 t°!o p��o
Total Forested 36,500 18% _i%
Barren (quarries, strip mines, and gravel pits) 0 0°!a 0°io
Barren (bare rock and sand) 100 0% p�,�o
Piedmont Submerged Aquatic Vegetation 0 0°do 0°�0
Piedmont Emergent Vegetation 0 0°so O��o '
Riverbank Shrublands 100 0°Ao p��o I
Floodplain Wet Shrublands 0 0°do p��o
Open Water 1,500 t°�e 0°�0
Total Other 1,800 1% p"/o
TOTAL 202,000 100% p%
Notes: Results have been rounded to the neazest 100 acros and whole percent. Differences were calculated prior to rounding. Totals may appear
not to equal the sum of the parts because of rounding.
66