20151279 Ver 1_Public Notice Comments_20160111

Strickland, Bev
From:Mary Benson <[e-mail]>
Sent:Monday, January 11, 2016 4:53 PM
To:Jean Gibby
Cc:Higgins, Karen
Subject:Comments for Public Notice Re SAW-2015-01994
Attachments:COMMENT-SAW-2015-01994-Benson.docx
Jean,

I appreciate your assistance this a.m. in clarifying the ACE public notice and comment process. Attached
please find my set of comments regarding the application under consideration - Corps Action ID Number SAW-
2015-01994. Thank you very much.

Mary Ellen Benson
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Comment from Mary Ellen Benson, January 11, 2016
Corps Action ID Number: SAW-2015-01994

COMMENT

Corps Action ID Number: SAW-2015-01994
Comment Deadline: January 20, 2016
Description: Comment regarding the application from Virginia Electric and Power Company seeking
Department of the Army authorization to discharge fill material into waters of the United States,
associated with the construction of a new 115kV and 230kV switching station near Battleboro, in Nash
County, North Carolina.

Date of Comment: January 11, 2016
Commentator: Mary Ellen Benson
Mailing Address: 10 South Dover Street
Lakewood, Colorado 80226
Home phone: [phone]
E-mail Address: [e-mail]
Affiliation: Property Owner of Potentially Impacted Residential Properties Immediately Adjacent to the
Subject Property (Owner of 4821 Crape Myrtle Street, Battleboro, NC 27809, and Co-owner of 4817
Crape Myrtle Street, Battleboro, NC 27809).

Concern #1. Effectiveness of Storm Water Drainage Plan
I am concerned about the effectiveness of the storm water drainage mitigation proposed by
Angler Environmental and its potentially negative impact on local flooding in the incidence of multiple or
prolonged storm events.
Specifically, information provided in the proposal, as it pertains to relocating and restoring the
stream channel, does not disclose the method or calculations used to determine the actual geometry of
the new drainage area after the stream channel is relocated. There is no assurance that the new
drainage area would be sufficient to accommodate the potential run-off volume lost by the filling of the
currently low-lying terrain and relocation of the stream channel; therefore, without further information,
it is not possible to evaluate the hydrological soundness of this proposal.
Additionally, the materials provided do not include any provisions for maintaining the implied
steep grade for the relocated stream channel as indicated in the graphic cross sectional drawing. Such a
steep grade built in fill dirt or other granular materials would seem to be rather unstable without some
type of cement lined walls or some other type of artificial structure to support and maintain the position
of the relocated stream channel and to control bank slumping during high run-off and sediment capture
in the channel during periods of sluggish water flow. Would the proposed substation grade be
vulnerable to erosion along the margin of the relocated stream? Again, not enough information is
provided to convince the reader that sufficient consideration of these hydrological concerns has been
incorporated into the engineering plan.
Also, has the volume of water up-take by the current vegetation within the drainage basin been
figured into the calculations of water-volume holding capacity in the stream relocation plan? One
assumes that, once filling of the targeted low-lying vegetated areas has been completed, the resulting
altered landscape will be barren of vegetation, and the additional water (that has no plants to absorb it)
will need to be accounted for in the storm water management plan.

Concern #2. Potential for Groundwater Impact at Construction Site
I am concerned about the absence of any reference to the depth and seasonal fluctuations of
the water table in the materials provided in the proposal.

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Comment from Mary Ellen Benson, January 11, 2016
Corps Action ID Number: SAW-2015-01994

What is the relationship between surface run-off in this site and the groundwater table? Are
there any springs in the vicinity of the site? Will filling the current wetland and the stream channel and
moving the surface water channel create a dry and stable substrate or will it continue to be water-
saturated and potentially unstable?
Additionally, if there is a contribution of groundwater into the current stream channel, how will
that volume of water change when the stream channel is relocated?

Concern #3. Potential for Slope Failure at Construction Site
I am concerned about the soundness of a construction plan to build a 5.5 acre power switching
station on the slope of a hill that has been retrofitted with fill-dirt placed on top of water-saturated soils
of an historic wetland and stream channel, despite the relocation of the current stream channel.
Specifically, what type of footing will the power station structures have? Will the footing reach
bedrock? If not, how will the structures be secured?
Additionally, can such a pile of unconsolidated material be made stable enough to maintain its
elevation above the relocated stream and the railroad grade? How susceptible will the newly graded
construction site be to erosion?

Concern #4. Potential Impact on Groundwater Quality
If there is any communication between the current wetland and stream channel and the
groundwater, how might the construction materials used in the filling of the low-lying areas and the
materials used in the construction of the substation impact the local groundwater quality?

Concern #5. Negative Impacts to Local Residents
There is no reference in the proposal to providing a buffer around the residential area that is
immediately adjacent to the project property line or to compensate the property owners for potential
loss of enjoyment of wholesome and peaceful occupancy or for loss of value to our property.
Locally, there will be immediate negative impacts due to construction activity such as increased
noise, increased dust (diminution of air quality), increased traffic on neighborhood streets, and
potentially increased safety concerns due to the influx of non-resident persons.
In the long term, the visual and health impacts of the substation and its bordering area
immediately adjacent to the residential properties could have a negative impact on property values.
There is no reassurance as to how visually intrusive such a substation will be, how tall it will be, or how
noisy it will be. Also, I have concerns about the safety of living adjacent to an electrical power facility of
this sort. How safe is it? What level and frequency of monitoring will be maintained to ensure public
safety for local residents?

Concern #6. Historic Building in Northeast Area of Property
I am aware of an old residence in the northeast area of the project property that pre-dates
1950, at least. In local folk lore, it was the home of early residents of the town of Battleboro. It is visible
on Google Earth. Is it of historic importance as to preservation?