19910326 Ver 1_Scoping Comments_19940725

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State of North Carolina
Department of Environment,
Health and Natural Resources
fir,
Division of Water Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary Q E H N 1=?
John N. Morris, Director
Monday, July 25,1994
MEMORANDUM
To: Ms. Lois D. Cashell, Secretary
Federal Energy Regulatory Commission
From: John Morris, Director
Subject: Lake Gaston Water Withdrawal Environmental Impact Statement Scoping
Lake Gaston and Roanoke Rapids Project (FERC No. 2009-003)
The Division of Water Resources appreciates the opportunity to provide scoping comments for
the Lake Gaston Water Withdrawal Environmental Impact Statement. We commend FERC in
deciding to do the long overdue comprehensive analysis of this proposed withdrawal from Lake
Gaston.
The proposed intake and pipeline will impact the flows of the Roanoke River, the operation
of John H. Kerr Reservoir, Lake Gaston, Roanoke Rapids Lake, and existing and potential future
uses of this water. The magnitude of these impacts has never been fully quantified. A
comprehensive multi-disciplinary evaluation is needed for the Roanoke River-Albemarle Sound
system.
We feel strongly that this evaluation must not be rushed and must be done with an open
approach. This proposed withdrawal has generated much misunderstanding and, at times,
misinformation. FERC needs to establish the methods and procedures by which the necessary
analysis will be done and provide all interested parties an opportunity to comment on these
procedures. Then, models and data collected in development of the EIS to evaluate impacts must
be available for review by all interested parties. Development of a common database is a critical
starting point. All analyses done need to be working with the same information.
We look forward to working with your staff to conduct an evaluation of the impacts of this
proposed withdrawal and pipeline.
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
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Division of Water Resources
State of North Carolina Department of Environment, Health, and Natural Resources
Lake Gaston Water Withdrawal Environmental Impact Statement Scoping Comments
Lake Gaston and Roanoke Rapids Project (FERC No. 2009-003)
CONTENTS
SCOPING/EIS PROCESS .... .. .. .. . . ....... .. .... . .. . . . . . ... 3
CONSUMPTIVE WATER USE AND PROJECT NEED . . . . . . . . . . . . . . . . . . . . 3
Consumptive Water Use in the Roanoke River Basin . . . . . . . . . . . . . . . . . . . . 3
Water Demand in the Virginia Beach Area . . . . . . . . . . . . . . . . . . . . . . . . . . 5
ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Desalination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Aquifer Storage and Recovery . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . 7
Conservation and Water Management . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Other Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
COMPREHENSIVE ANALYSIS OF CUMULATIVE IMPACTS . . . . . . . . . . . . . . . 13
Minimum Releases . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . 13
Upstream Impacts : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Secondary Impacts . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 14
OTHERISSUES .........................................16
Aquatic Weed Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 16
Effects On Water Intakes .......... ..... • • • • • • • ..... .. 16
Effects On Weed Control Activities . . . . . . . . . . . . . . . . . . . . . . . . . 17
General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Socio-economic and Environmental Justice / Equity : . . . . . . . . . . . . . . . . . . . . 17
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
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SCOPING/EIS PROCESS
As FERC points out in its FEA, a great deal of uncertainty exists throughout the past
analyses conducted, including even the validity and interpretation of seemingly straightforward
data. To remedy this, the Division of Water Resources recommends that FERC follow a two-
stage evaluation process. During the first stage of its evaluation, FERC should establish the
methods and procedures by which the necessary analyses will be done and provide all interested
parties an opportunity to comment on these procedures. FERC could then refine its approaches
as necessary to ensure the greatest possible acceptance of its findings. The second stage of this
process would be the actual data collection and analysis needed to prepare the EIS. The
Division of Water Resources also insists that any models developed be fully "transparent," i.e.,
all aspects of the models, including data, operating assumptions, and output, be available for
review by interested parties. This strategy will make the outcome of the EIS less disputable by
both advocates and opponents of the pipeline project.
CONSUMPTIVE WATER USE AND PROJECT NEED
The Division of Water Resources concurs with FERC's decision to update population and
water consumption figures in order to more fully evaluate the cumulative and socioeconomic
impacts for the proposed pipeline project. This work is needed for the entire Roanoke River
Basin, along with a reevaluation of the need for a 60 mgd water supply project for the Virginia
Beach area.
Consumptive Water Use in the Roanoke River Basin
Consumptive water use in the Roanoke River Basin, as in all basins, will change over time.
In order to address the differences in water availability between current and future situations, a
model with an adequate database should be developed. The output of this model will affect all
considerations of future environmental and socioeconomic evaluations of conditions in the
Roanoke River Basin.
An appropriate database for the model would include detailed information on water use past,
present, and future. This water use information should be addressed by category. These
categories would include public water supplies, independent domestic users, thermal electric
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power generation facilities, other industrial operations (such as paper products, textiles,
chemicals, etc.), agricultural and turf irrigation, and water for livestock.
For understanding the effects of consumptive use, determining seasonal variations is
important. Consumptive uses for each category should be determined by collecting raw data and
making appropriate determinations for each category or sub-category. These consumptive uses
should be determined and tabulated so that losses can be evaluated on a seasonal basis.
Forecasting to the year 2030 and possibly beyond should be developed for each category.
The forecasts should use reasonable and realistic evaluations based on good judgment and
available information. If detailed forecasts are not available, reasonable estimates must be
developed. For instance, although forecasts for future electric production needs may not be
available for long- range planning, population forecasts and industrial estimates are usually
available and power requirements must be shown to meet these needs. Relevant plans that
should be considered when making forecasts include local and regional economic development
plans and land use plans.
Population projections should be based on historical trends and adjusted for known or
anticipated changes that would affect future population growth. Future populations under
several different assumption scenarios should be projected to get a range of possible values.
Population estimates should compare favorably to US Census Bureau information. Historical
per-capita water use should be compared to accepted standards and deviations should be
explained.
The model should include withdrawals including source type (surface, ground, or purchase)
and discharges (with estimates of ground water and storm water infiltration) for each significant
user. Available hydrologic records for streams, lakes, and estuaries in the Albemarle Sound
should be used. The hydrologic system, including streamflows, lake levels, consumptive uses,
and the changes that take place over time when used in an appropriately designed model should
provide answers to the questions of water availability in the future. The model results will yield
an essential element for most environmental and economic evaluations to be done in the
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Roanoke River Basin. Further, any database and model developed must be open for review by
all interested parties.
The Division of Water Resources is in the process of updating its 1991 Draft Roanoke River
Basin Water Use Investigation, which is referenced extensively in the FEA. The FEA fails to
identify this report as a draft report subject to revision. Final water use information from our
investigation will be provided to FERC as soon as available.
Regarding Virginia Beach's estimates of water consumption in the Roanoke River Basin, the
FEA blindly states that the National Weather Service and the U.S. Geological Survey favorably
reviewed these estimates, including their water demand forecasts. These data and reviews need
to be open for public comment.
Water Demand in the Virginia Beach Area
As with basinwide water consumption estimates, projection of water needs in the Virginia
Beach area has seen considerable debate and controversy. The Division of Water Resources
urges FERC to conduct its own open and thorough estimate of population growth and water use
to evaluate the need for a project of this magnitude. This effort should not rely upon outdated
information or old economic projections and must avoid data from agencies with a conflict of
interest.
Water demand estimates in the Virginia Beach area should be based on realistic growth
scenarios, including the effect of the recent slowdowns in growth and ongoing military
downsizing. The regional 2030 demand deficit of 60 mgd that Virginia Beach claims should
also be carefully evaluated in light of recent developments with Chesapeake's water system. In
the past, Chesapeake's Northwest River supply was not considered to provide a reliable yield,
and was therefore not counted. Chesapeake's planned RO treatment of surface water from the
Northwest River in combination with brackish ground water will now provide a 10 mgd reliable
yield. This should automatically reduce the regional demand deficit by 10 mgd.
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FERC should further challenge the need for a 60 mgd project based on the availability of
water from Norfolk. Norfolk can continue to supply a substantial amount of water to Virginia
Beach. Under normal conditions, Norfolk can provide 30 mgd to Virginia Beach, and even
under drought conditions, Norfolk has historically provided 15 mgd. Any water that will
continue to be available from Norfolk should reduce, gallon for gallon, the amount of the
pipeline transfer requested by Virginia Beach. Further, the pipeline will not reduce Virginia
Beach's dependence on the Norfolk system-it will result in an even closer integration of the
Norfolk water system and the Virginia Beach water system. Water from Lake Gaston would be
discharged into Norfolk's storage reservoirs, treated by Norfolk, and distributed through
Norfolk's pipelines to Virginia Beach. Because of this integration, it is imperative that FERC
evaluate the Norfolk and Virginia Beach water systems as a unit to ensure that Virginia Beach
takes full advantage of its most readily available supply before seeking out-of-basin supplies.
An issue related to project size is whether or not any assurances would be granted by
Virginia Beach, if their project is approved, that they will not exceed their project limit and that
additional waters from the Roanoke River Basin will not be sought. As you know, this was of
great concern to the basin residents attending the South Hill scoping meeting.
ALTERNATIVES
The FEA correctly identified that more work is needed to define, describe, and quantify the
alternatives to the Lake Gaston pipeline project as proposed. Few major metropolitan areas limit
all their entire water supply to one source and even fewer rely upon just a single pipeline of this
length. If a problem occurred, or even in performing preventive maintenance, the tap would be
turned off to the users.
In a building block approach to sound water management, new treatment plants come on-line
as the demand warrants them. This makes financial sense, as the citizens only pay for what they.
need at the time. Secondly, it makes sense from a reliability standpoint. Lastly, if the building
block approach were used by a regional water authority, then the maximum advantage would
come from each individual part.
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In the FEA's discussion of need for the project, FERC cites water restriction episodes for
Suffolk, Chesapeake, Norfolk, Virginia Beach, and Portsmouth. Suffolk, Portsmouth, and
Norfolk are not even slated to receive the water from Lake Gaston. Why include their water
restriction episodes? However, this does show that other local water systems have had. shortages
and that they could meet them through other sources. Also from the list, it appears that Franklin
and Isle of Wight have not had water restrictions since 1977. They too have apparently avoided
restrictions through the use of other options than Lake Gaston?
As stated earlier, alternatives to the pipeline need to be reevaluated. The following
comments on the alternatives presented in Section 3.2 of the FEA demonstrate this need.
Desalination
No mention is made of brackish water desalination. No mention is made of Chesapeake's
planned use of desalination to meet their water needs. No reviews or figures are presented that
support claims of expense per 1000 gallons in stages over the planning period. The Division of
Water Resources encourages FERC to visit the Dare County reverse osmosis plant on the North
Carolina Outer Banks. This plant is a model of desalination for Southeastern Virginia.
Aquifer Storage and Recovery
Aquifer Storage And Recovery (ASR) is dismissed out of hand based upon Virginia Beach's
comments that it is experimental technology and will not meet the entire demand. The
opposition to ASR argument was presented during the public hearing in Virginia Beach. One
speaker stated that they looked into ASR over 25 years ago, and found that it did not work, so
FERC does not need to examine the technology. ASR is no longer considered "experimental" in
current literature. The FEA plays down Chesapeake's project that showed all geological aspects
of the ASR project were successful. No supporting documentation was published in reference to
the water quality problems, treatment costs, nor the specific reasons of placing the project on
hold. Large area modeling has yet to be preformed to dismiss ASR as unworkable. No cost
figures are presented, in actuality, no real facts were presented at all in the FEA. An
independent, rigorous and open scientific review of ASR's role for meeting a portion of Virginia
Beach's demand is required. All potential sources, fresh and brackish, must be reviewed and
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compared with all treatment technologies. Discussion should not be limited to vague statements
about other rivers or ground water stresses in the region.
In response to claims made in the FEA, the authors should contact Chesapeake's consultants
for the project, CH2M Hill. Their published and peer reviewed papers contradict several items
in the FEA. Just one such document is "Aquifer Storage and Recovery in Virginia, An
Innovative Water Supply Alternative", by Ibison, Buchanan, and Dronfield presented in April
1992 to the American Water Resources Association. Three such contradictions are given below:
1) In the FEA it states: "The project has only small-scale application potential and could
only be used to meet a small portion of the need, presuming a project could be designed
that would function." The consultants provide a list of ten other American ASR
operations, including one at 20 MGD and one at 60.MGD average, they showed a
maximum day demand of 15 MGD for the Chesapeake project. Chesapeake proved the
geology is suitable for ASR at one site, how many other sites in the Tidewater area are
suitable for ASR?
2) "The Chesapeake project was abandoned because of aquifer limitations and lack of
technically feasibility." The consultants write in the report summary: "Results from the
ASR test program at Chesapeake demonstrates that aquifer storage and recovery works
successfully in the Western branch Wellfield. " ... "The Chesapeake project, in
combination with two long running ASR projects in New Jersey, suggest that ASR can be
an efficient, cost-effective water supply alternative throughout the Atlantic Coastal
Plain." It is DWR's impression that the ASR project was abandoned because of expense
in treating the seasonal source water. Using other seasonal water sources available in the
region might solve this problem. No figures or justification have been published to
support this position.
3) "Chesapeake discovered that, because of water quality problems, it would be
necessary to treat water before and after it was injected into the storage aquifer, at a
significant increase in cost." The consultants write: "ASR involves injecting treated
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drinking water through recharge wells into a suitable aquifer and recovering the water
through the same wells." [Italics added] They continue in reference to water quality
degradation in the aquifers: "While little mixing of injected water with formation water
was evident, geochemical reactions altered the concentrations of a number of
constituents." ... "Possibly, the geochemical reactions are slowly reversible such that
once a zone has had its initial ion exchange, the treated water injected into that same zone
in the future will not be altered." These questions about ASR should be answered
through further testing of the wellfield.
The Division of Water Resources encourages the FERC to perform their own literature
searches, review the current published literature on ASR, and commission their own independent
investigation of the ASR potential for meeting some of Virginia Beach's water needs. No
mention has been made of using excess spillage from the Norfolk Reservoirs as source water for
ASR. This option seems logical, and should not increase Norfolk's surface water withdrawal
rates over current levels.
The City of Chesapeake continues a progressive and open-minded approach in further efforts
to meet current water needs. Recently, they announced the funding of a Reverse Osmosis (RO)
Treatment Plant. Their latest use of alternatives to Lake Gaston, combines groundwater
withdrawals with surface diversions from their historic site on the Northwest River. This
conjunctive use in concert with RO will provide a reliable and firm 10 MGD. It is worth noting
that the Army Corps review of water demand for the region, considered Chesapeake's reliable
supply at zero mgd, in calculating their call for nearly 60 MGD. This appears to provide
evidence that the Corps estimates are flawed, or just out of date, in light of new technology and
techniques. As evidenced by Chesapeake, other local water systems feel the alternatives are not
only worth extensive tests, they are worth investing in actual full time operations.
To answer questions on what other parts of SE Virginia or NE North Carolina meet ASR
geological criteria, a jointly funded ASR feasibility study by North Carolina, Virginia, the
regional municipal governments, and various agencies of the Federal Government should be
conducted by the United States Geological Survey (USGS). Representatives from the Virginia
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and North Carolina Districts could develop a report outlining localities, in both States, that meet
geologic conditions or requirements for successful ASR. The USGS acts as an independent
agency which provides data and analyses that should be acceptable to all parties.
Conservation and Water Management
These two items should be separate topics. No discussion is given to Virginia Beach's
efforts toward comprehensive and mandatory refit of all existing plumbing fixtures to the "ultra-
low flow" level. With current techniques and equipment, how is the City doing toward
maximum possible conservation? How does Virginia Beach's conservation compare with other
water short regions across the Country? What limiting volumes of water are needed to insure the
City continues reasonable conservation measures in the future?
Little discussion-is given to the details of improved water management for existing or future
sources. The FEA fails to mention a building block approach for development of sources.
What independent numbers does the FEA rely upon in the discussion of bringing incremental
projects on-line as they are needed? In this manner the customers only pay for current needs, and
projects can take advantage of the most recent technological advancements, unforeseen in the
past. How much additional water is needed if the communities of southeast Virginia worked in
cooperation for the most efficient water management? This idea is not unrealistic, the area
historically came together in forming a regional waste water treatment system. Opposition to
such cooperation was overcome at that time. Proper regional efforts are only a matter of time
for water supply.
In reviewing the regional supply for more efficient water management, the Final Report:
Conjunctive Use Modeling of Ground and Surface Water Southside Hampton Roads. Virginia,
could provide a basis for modeling this alternative. The Personal Computer (PC) version of the
model used in the report, and code, is accessible to FERC. Between the report documentation
and the PC model, FERC should be able to run various simulations, and quantify the regional .
water savings available. The report outlines sources of information, systems schematics, demand
projections, physical characteristics of reservoirs, operating procedures, and ground water
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characteristics, as they were understood in 1987. FERC should update this model to include the
more recently validated alternatives in use in the region, such as Reverse Osmosis and Aquifer
Storage and Recovery.
Other Alternatives
Numerous additional alternatives are presented below that have not been previously
evaluated at all or are variations of existing alternatives. FERC should fully evaluate each of
these alternatives to determine their merit as water supply alternatives for Virginia Beach. In
addition to these additional alternatives, FERC should conduct literature reviews of each of the
alternatives previously reviewed by the Corps(ND) in their 1983 Final EA and FONSI to outline
the current state of the art science, technology, and current economics. The EIS should review
and document the possible use of each alternative and demonstrate pros and cons, since some of
these alternatives have become more viable in recent years..
Return of Flows to Roanoke River Basin- No mention is made in the FEA of returning waste
water flows back to Lake Gaston, through a dual pipeline. This effort would minimize flow
concerns to the Lower Roanoke. It would have the added benefit of increasing volumes for
power generation at the two hydro operations down stream.
Desalination in Conjunction with Existing Wells - The City of Chesapeake found it
economically practical to add a RO unit at the beginning of their water treatment train. What
other water systems in the region might take advantage of this technology to improve their
production? How would this increase the capacity and/or reliability of the regional water
supply?
Well Fields on the Delmarva Peninsula - No discussion has been presented to review the
option of ground water withdrawals from Northampton County, Virginia. Exciting research in
mapping paleo-channels has been conducted by the U.S. Geological Survey. Pump tests further
north in Salisbury, Maryland offer positive indication that the water is available. A list of
references have been included reflecting the amount of geological work done in this area. A
pipeline from this region could take advantage of an existing bridge/tunnel structure and would
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be considerably shorter than the Lake Gaston pipeline. What are the costs per 1000 gallons for
this alternative?
Texasgulf Pipeline - The phosphate mining operation in Aurora, North Carolina pumps over
50 MGD out of the Castle Hayne Aquifer to de-water the mining pits. This water is discharged
into the Pamlico River/Sound a brackish system. Localities just south of the Virginia / North
Carolina State Line are actively pursuing this pipeline. Their hopes are to not only meet North
Carolina needs, but to sell surplus amounts to Southeast Virginia. The FERC could help pursue
feasibility studies underway in Northeastern North Carolina.
Ground Water Withdrawals in Locations West of Suffolk - The FEA did not discuss pumping
in the five county area west of Suffolk, south of Petersburg, and east of Interstate 95. While this
region includes the already heavy pumping at Franklin, Virginia, discussion should be given to
the ground water potential of the region. Special focus could occur in Prince George, Surry, and
Sussex Counties.
Reduced Pipeline Size - Through the use of other alternatives and the building block
approach to water management, Virginia Beach should be able to reduce their additional need to
zero, however, if they still insist upon building a pipeline to Lake Gaston, then the line size (and
costs) should be substantially reduced: An alternate pipe size, such as 20" or 30" should be
included in the economic review of alternatives.
In FERC's conclusions of the Alternatives section (p. 26), it identifies 30 mgd in smaller-
scale alternative water supplies-10 mgd from ground water and 20 mgd from ASR (p. 26).
Analysis by Boyle Engineering (Analysis of Alternative Water Supplies for Virginia Beach, June
1992) has shown that raw water sources for a 20 mgd ASR facility are already available from
existing sources-7 mgd from Norfolk Reservoir spills, an additional 6 mgd from Norfolk's
Blackwater River intake, and an additional 7 mgd from Norfolk's Nottoway River intake (Boyle).
Since these supplies utilize existing sources, their cost to implement should be relatively
moderate. These alternative supplies totalling 30 mgd, in combination with Chesapeake's 10
mgd reliable source effectively reduces the demand deficit from 60 mgd to 20 mgd. The FEA
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describes desalination as more economically feasible for a smaller scale project.. A 20 mgd
project should therefore be more economically feasible. This type of scenario is one example of
the conjunctive use alternative involving the development of a variety of smaller scale sources
that the FEA indicates is worth reviewing using updated information on economics and
technology.
COMPREHENSIVE ANALYSIS OF CUMULATIVE IMPACTS
We concur with your decision to update. population and water consumption figures in order
to more fully evaluate the cumulative and socioeconomic impacts for the proposed pipeline
project. The impact analysis is needed for the entire Albemarle Sound Basin, not just the
Roanoke River Basin.
An cumulative impact analysis can not be limited to just the project lands and waters, the
pipeline corridors, and the Lower Roanoke River Basin. A basin-wide approach is needed to
fully evaluate the proposed water. withdrawal impacts.
An impact analysis needs to include a water balance model that is designed to answer such
questions as how changes in consumptive water use will impact water availability in the future;
how changes in water availability and reservoir operations will change flow characteristics,
fisheries, and water quality? A model needs to be developed for the whole basin, since changes
in upstream consumptive water use will impact flows into the Kerr Reservoir. These changes in
inflow will affect Kerr Reservoir, Lake Gaston, and Roanoke Rapids Lake ability meet project
needs such as water supply, power generation, and minimum releases.
Minimum Releases
The work done by the Roanoke River Water Flow Committee and others with the success of
experimental flow regimes show the need for moving from a 51-day striped bass spawning flow
window to a year around the includes examining the needs of species. Based on the work done
by the Roanoke River Flow Committee and the historical trend in FERC relicensing process, it is
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reasonable to assume the current minimum releases will change and will likely be increased. As
minimum flows are increased, this decreases the amount of storage available for other project
purposes such as water supply and reduces operational flexibility.
Therefore, the need for an evaluation of the impacts on instream flows of the lower Roanoke
River is critical. An instream flow study utilizing the Instream Flow Incremental Methodology
(IFIM) must be completed as part of the EIS process to determine the impacts on all aquatic
species of anadromous fish, resident fish, and macroinvertrebrates. The study should include
time series analyses that document the habitat change by species and life stage. The IFIM study,
and all the other evaluation work, should incorporate the existing and projected increases of
consumptive water uses. The lower Roanoke River hydrology has complex spatial and temporal
hydrologic and hydraulic characteristics. Therefore, a 2-D hydrodynamic model will be required
as part of the IFIM study. Also, site-specific habitat suitability indices will need to be developed
for some species. The scope for such a study needs to be a joint effort with the US Fish &
Wildlife Service (Raleigh Field Office and the Cooperative Instream Flow Service Group) and
the North Carolina Department of Environment, Health, and Natural Resources (Division of
Water Resources and Wildlife Resources Commission).
Upstream Impacts:
Upstream Riparian owners in the Basin have expressed concerns that the withdrawal by
Virginia Beach may eventually curtail their water use. These owners and users would like
expressed written assurances that Virginia Beach will guarantee upstream use will not be
reduced if basinwide water use is found to ever exceed the reliable ability of the river to meet the
needs, both in-stream and off-stream. Virginia Beach must agree to reduce their demand to
protect current Riparian reasonable uses or provide redress. Bonds should be established for
this action.
One direct upstream impact that needs careful evaluation is the impact to Philpott Reservoir.
Philpott is impacted by changes at Kerr Reservoir. The Corps uses an interchange curve to
balance operations between the two reservoirs. If Kerr is below its interchange curve and
Philpott is above its interchange curve then Kerr reduces power generation and Philpott increases
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generation. Any operational changes at Kerr that would cause it to fall below the interchange
curve more frequently, such as increased water supply demands, reduced inflows caused by
increases in upstream consumptive water, or increases in minimum releases, will cause increased
releases from Philpott.
Secondary Impacts
The extent of the impacts will not be limited to the lower Roanoke River basin -- secondary
impacts to southeast Virginia and northeast North Carolina are inevitable as well.
In Raleigh, Virginia Beach officials said that this water wasn't needed for industrial use,
which means that substantial population growth would account for this increased usage. This
growth and development will likely extend from the municipalities receiving Lake Gaston
waters, throughout southeast Virginia, and even into northeast North Carolina. Development to
accommodate this growth will convert rural, low density land uses to more urban, higher density
settings with more pavement, shopping malls, and subdivisions. This will result in increased
point and non-point source pollution loadings in the ditches, creeks, and rivers in these areas.
How will this increased pollution impact the water quality and aquatic ecosystems of the Dismal
Swamp, Chesapeake Bay, and Albemarle Sound drainage areas? Similarly, how will additional
traffic congestion, from more cars and trucks, affect air quality throughout the region?
The Federal Energy Regulatory Commission's Environmental Impact Study should address
these secondary impacts due to new growth and development resulting from this large Interbasin
Transfer. The dynamics of urban expansion should be quantified. How many new homes are
expected over the planning period? Where will construction concentrate, which other
communities need to plan for growth? Will Virginia, or the City, make infrastructure
improvements to cope with this increased development, such as widening highways (for
example, US 460, US 58, and, US 17) and expanding other utility services?
Along with increased population comes increased needs for electric power. Historically, one
popular source of this power has been thermal co-generation plants in the Roanoke River Basin.
Each new plant adds to the water use demand placed upon the River. Impacts of the Lake
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Gaston withdrawal on existing and future electric power generation within the basin should be
evaluated.
Estimates are needed for all the potential impacts Virginia Beach's pipeline will have on the
State's population, commerce, and environment, so the State can plan for and manage the factors
controlling their future. What are the expected economic impacts in North Carolina? Will
communities in the Lower Roanoke be deprived of water supplies necessary to attract new jobs?
Will there be increases in water and waste water demands and stormwater runoff in the northeast
portion of the State? As the Tidewater population expands, what are the cumulative impacts to
the Outer Banks, from the widening of the US 158 Bridge across Currituck Sound? In
combination, how will these projects impact water quality and the fragile ecosystems in the
Sound? The FERC should clearly spell out the reasonably foreseeable impacts of this project, so
that we may prevent or mitigate any detrimental impacts before physical or economic injury
occurs.
OTHER ISSUES
Aquatic Weed Control
Lake Gaston currently supports expanding populations of three exotic noxious weeds. In
order of their discovery in the lake, these are:
Brazilian elodea (Egeria densa)
Hydrilla (Hvdrilla verticillata)
Eurasian watermilfoil (Mvrionhyllum §Ricatum)
All three of these plants are listed as "noxious aquatic weeds" in Title 15A, Chapter 2,
Subchapter 2G, Section .0600 of the North Carolina Administrative Code and are thus subject to
the provisions of the North Carolina Aquatic Weed Control Act of 1991. (Copy attached)
Hydrilla is also listed as a noxious weed by the federal government.
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With the possible exceptions of water willow and American lotus, native macrophytes in
Lake Gaston constitute a very minor portion of the lakes macrophyte biomass.
All three of the exotic species mentioned above are rapidly expanding their range in Lake
Gaston. The acres of lake bottom occupied by hydrilla doubled between 1992 and 1993. The
1400 acres of hydrilla documented in the lake in the fall of 1993 will likely grow to 2000 acres in
the summer of 1994.
Effects On Water Intakes
Unscreened intakes will entrain the neutrally buoyant fragments of noxious weeds, especially
hydrilla. Plant fragments and propagules such as hydrilla turions will survive passage through
the pipeline and become established in receiving water bodies. Plant fragments will be most
abundant in late fall (especially hydrilla) and least abundant in the transition period between
winter and spring. While static surface levels in lakes may aid the establishment of submersed
macrophytes, fluctuations in surface level do not preclude establishment. Both Kerr Reservoir
and Roanoke Rapids Lake in the Roanoke chain are infested with hydrilla despite having rather
wide fluctuations in surface level.
Intake screens fine enough to exclude plant fragments and propagules will be very
susceptible to biofouling. Plant fragments will impinge on screens unless water velocity at the
screen face is much lower than 1 ft1s.
Future weed control in Lake Gaston will require the use of several techniques in concert.
Periodic de-watering of the lakes littoral zone to a depth that may exceed 10 feet will likely be
one of those techniques. Water quality may deteriorate at low water levels. Erosion of the
exposed lake bottom will likely increase the suspended sediment load entering the system.
Effects On Weed Control Activities
As long as there are weed problems in Lake Gaston, there will be considerable public
pressure to control them. The presence of water supply intakes in Lake Gaston has the potential
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to limit weed control options. Timing and placement of herbicide treatments and the depth and
frequency of drawdowns are the options most at risk.
General
Information on the history of weed problems and control efforts in Lake Gaston and other
water bodies is available in the files of the North Carolina Division of Water Resources.
Assessments of the aquatic plant distributions in Lake Gaston are compiled each winter
following fall surveys.
Socio-economic and Environmental Justice / Equity:
Page 36, Table 5-2, Socioeconomic Characteristics of the Project Area - Add figures on
racial breakdown of the population to support discussion of environmental justice impact issues.
Figures should be presented on out of Basin project recipients and those experiencing a loss of
natural resources in the Basin.
Mr. Michael Berrett, of the Hampton Roads Chamber of Commerce, claimed that SE
Virginia's competitors have exploited the Federal process to their economic competitive
advantage. This shows a perceived competition between the Roanoke River Basin and Virginia
Beach for business advantage. This was echoed by Barry Bishop, Exec. of the Greater Norfolk
Economic Development Commission, who stated that Virginia economic growth and
development was at stake, and Hampton Roads is the principle engine for such regional
development. He noted that the needs of a major metropolitan area, far outweigh the needs of
the Roanoke River (Basin population and fish).
REFERENCES
Page 5, Item 2.3.1, Regulatory Framework
This page discusses previous reviews and findings by the Army Corps of Engineers. In
reference to this, it should be pointed out that this work was based upon outdated science and
information.
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Page 11, Item 2.3.3, Previous Studies Included by Reference
This list should include: the Roanoke and Chowan Basin Water Supply Plans, the
Environmental Assessments (EA) for the Clover, Mecklenburg, and Roanoke Valley Projects (I
and II) thermal power plants, and the Dan River Basin Study (by NC DWR). Other data could
come from the NC Local Water Supply Plans, Virginia water use data, published city and county
plans and both States maintain lists of current thermal power plants. The Roanoke River Water
Flow Committee Reports, the Striped Bass Management Board Report, and Public Water
Supplies of North Carolina by the United States Geological Survey all should be included as
well.
Page 47, Item 5.4.7 Existing Water Consumption and Uses in the Roanoke River Basin. The
EA draws upon the North Carolina Division of Water Resources' Draft Roanoke River Basin
Water Use Investigation, June 1991, without noting the DRAFT status. This report had not been
made final as of the publishing of FERC's EA. All original copies of the document were clearly
marked DRAFT on the cover. The reference occurs on page 5-7, or the seventh page of section
five, not on pages five through seven as reported in the EA. In Table 5-9, the word "natural" has
been added after the category of evaporation, this has been added and did not occur in the
DRAFT report. Evaporation was included in the DRAFT to'quantify the impact man-made
structures had on the natural condition. The DRAFT report stated: "Building a dam on a river
backs water up and forms a larger surface area than the river had originally. Therefore, as a
direct result of the action, evaporation losses increase." This condition is not the natural
situation, and should not be reported as such. Copies of the DRAFT report cover and references
are attached.
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