20051457 Ver 1_Public Comments_20090115

EPA comments on Cleveland Co P&N statement
Subject: EPA comments on Cleveland Co P&N statement
From: [e-mail]
Date: Thu, 15 Jan 2009 10:41:46 -0500
To: "Pugh, Robin" <[e-mail]>
CC: "[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]>, "Jones, Amanda D SAW" <[e-mail]>,
"O'Quinn, Barney" <Barney.0'[e-mail]>, "Britt. Setzer@ncmail. net"
<[e-mail]>, "[e-mail]" <[e-mail]>,
"[e-mail]" <[e-mail]>, "[e-mail]"
<Cyndi. Karoly@ncmai 1. net>, Manager- <David.Dear@C levelandCounty.com>,
"[e-mail]" <[e-mail]>, "[e-mail]"
<fred.tarver@ncmai 1. net>, "[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]>, "[e-mail]" <[e-mail]>, "Wicker,
Henry M JR SAW" <Henry.M.Wicker. [e-mail]>, "[e-mail]"
<[e-mail]>, "James. [e-mail]: " <[e-mail]:>,
"smtp-Mead, Jim" <[e-mail]>, "[e-mail]"
<[e-mail]>, "[e-mail]"
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"[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]. nc.us>, "renee.gledhi11-earl [e-mail]" <[e-mail]>,
"Rick. Howell@cityofshelby. com " <Rick. Howell @cityofshelby. com>, "[e-mail]"
<[e-mail]>, ron mccollum <[e-mail]>, "[e-mail]"
<Tom. Reeder@ncmail. net>, "[e-mail]" <[e-mail]>,
[e-mail], [e-mail]
Henry, Robin, et al,
I have reviewed the draft Purpose and Need (P&N) for the First
Broad River Reservoir (FBRR) and am providing some initial comments in
preparation for our meeting next week. I have not yet had the
opportunity to review the alternatives analysis that was sent out
yesterday. EPA has provided numerous written and oral comments for this
project and our comments have always stressed the need for a strong
water conservation/reuse component for use in determining the projected
water demand and in developing the alternatives analysis. Although the
first objective listed in the project objectives section of the P&N
section is to "develop an effective and efficient water supply system"
there was little information in this section as to how the use of water
efficiency measures was a component in projecting future water needs.
Last week, I forwarded a draft paper to the FBRR project development
team outlining EPA Region 4 guidelines that any applicant for a
reservoir project in the Southeast will be required to utilize in
developing water demand projections and alternatives analysis. Water
efficiency measures have been shown to provide substantial and
documented savings in water and money, and should not be dismissed as
impractical and /or insignificant. The use of these measures are even
more important in light of the current drought being experienced in the
Southeast. EPA Region 4 places a very high priority on applying these
measures in determining P&N and evaluating the alternatives analysis for
reservoir projects, and recommends the applicant and the COE rigorously
apply them in the development of the FBRR EIS. The discussion below is
a follow up to the draft Region 4 paper and provides more information on
efficiency measures we will expect to see addressed in the water needs
projection and alternatives analysis for the FBRR.
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EPA comments on Cleveland Co P&N statement
We believe water efficiency measures can and should be central to
water supply planning. In comparison, large reservoirs can be very
costly in both money and environmental impacts (and mitigation for
environmental impacts), and lose very large amounts of water through
evaporation. Water conservation measures should not be a policy enacted
only in times of drought. The following discussion elaborates on some
of the measures outlined in the EPA Region 4 drought measures guidelines
paper:
Stop leaks: Aged and broken pipes and valves can be responsible for
huge quantities of water loss in water supply systems in the U.S. It is
not clear from the P&N document if the Cleveland County Sanitary
District (CCSD) utilizes a leak detection/repair program. Table 15
contains water loss information that shows an average of 17% unaccounted
water loss per year for years 2003-2007, but there was not a discussion
of a water loss detection and repair program. The P&N section should
contain a detailed discussion of what measures CCSD is using to
determine unaccounted for losses of water and what type of leak
detection and repair measures are being utilized. Although water
losses may be 20% or higher in water supply systems across the country,
we believe with advances in technologies and expertise, these losses
should be able to be reduced to less than 10%. Leesburg, VA was able to
reduce their loss from 33 to 6% and is working on further reductions.
Raleigh, NC, through a year round leak detection and abatement program,
has been able to reduce their leakage rate to 4.5%. This can represent
huge savings in MGD of water usage. Leak detection and the impact of
potential repairs to the water supply system should be incorporated into
the water demand projections for the FBRR project. There may be money
available for this with the new Administration as part of an
infrastructure repair component of the financial recovery plan. EPA can
provide additional information on this as it becomes available.
Water Price: Water should be priced to encourage conservation. This
means water should be priced to cover what it actually costs to provide
it to the consumer. A two-tier pricing system is recommended. This
would include a flat fee to cover fixed utility costs and a second part
variable fee that would charge higher rates as water consumption
increases to above average levels to discourage waste and encourage
conservation. Correct pricing for water has been estimated to be able
to provide savings of around 15%.
Meter all Users: Generally multi-family units and commercial buildings
charge a flat rate for water. This practice does not encourage users to
conserve water. Individual user water meters should be installed on all
new buildings and incentives should be provided to retrofit old
buildings with individual metering.
Retrofit all Buildings: Large water savings could be realized if all
households and businesses used water efficient appliances and fixtures.
Estimates are this could result in 20% savings. This could be
accomplished in old buildings by mandating updates be made on resale or
establishment of new accounts. Voluntary incentive programs such as
rebates and free audits could also help with retrofitting older
buildings.
Landscape and Irrigation Systems: Large amounts of water usage can be
attributed to landscaping (some estimates have it at 30%).
Municipalities have been able to greatly reduce this use through
measures such as: dedicated irrigation meters for large landscapes with
a significantly higher water rate, moisture/rain sensors for all
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EPA comments on Cleveland Co P&N statement
irrigation systems, free irrigation system audits, use of different
landscape models and plants that use less water.
Smart New Buildings: All new buildings should require the most water
efficient technologies. This should include the appliances and
fixtures, and also dual plumbing systems that allow the use of gray
water and harvested rain water for activities that do not require
drinking-quality water, like toilet flushing or irrigation. Section
4.1.2 of the P&N section discusses future demands from new housing.
These demand projections should be based on the use of efficiency
measures in new housing and businesses and not on historical water usage
data from houses and buildings not incorporating water efficiency
technology and programs.
These are just some of the ways water efficiency measures can
result in large savings in water and costs. Revised water demand
projections for this project should, at a minimum, reflect the
incorporation of these and other measures outlined in the Region 4
drought management guideline paper. The demand projections in the P&N
appear to be based on historical. usage rates and should be updated to
reflect the incorporation of the efficiency measures outlined above.
Section 4.42 (Water Supply Needs) does riot contain any mention of the
incorporation of water efficiency/conservation measures. This should be
a major component in this section. We will be looking for how each of
these measures will impact the water demand projections in the revised
Purpose and Need section. EPA Region 4 considers this a key component
in the evaluation of not only the FBRR project but also all future
reservoir projects in the Southeast.
Along with the incorporation of the efficiency measures, we are
also providing the reminder that any other municipalities, towns, etc
that are used to determine water projection demands should have a signed
service agreement with CCSD. This information should be included in the
P&N section.. We appreciate the opportunity to comment on the draft P&N
section and look forward to being involved with this project as we move
through the EIS development process.
Becky Fox
Wetland Regulatory Section
USEPA
Phone: [phone]
Email: [e-mail]
"Pugh, Robin"
<Robin.Pugh@arca
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"Wicker, Henry M JR SAW"
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3 of 7 1/15/2009 10:42 AM
EPA comments on Cleveland Co P&N statement
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Subject
RE: Cleveland County Water
Agency/stakeholders scoping
meeting January 21, 2009, 10:30
at the NC DENR Mooresville office
(UNCLASSIFIED)
4 of 7 1/15/2009 10:42 AM
EPA comments on Cleveland Co P&N statement
On behalf of Henry Wicker:
As you know, the US Army Corps of Engineers (USACE), Wilmington
District, Regulatory Division is continuing the National Environmental
Policy Act (NEPA) process in developing an Environmental Impact
Statement (EIS) for Cleveland County Water's (CCW) proposal to construct
a 1,300 acre water supply reservo=ir on the First Broad River
approximately 1.4 miles north of the Town of Lawndale, Cleveland County
North Carolina.
The USACE scheduled the first agency and stakeholder meeting on January
21, 2009, at the North Carolina Department of Environment and Natural
Resources (NCDENR) Mooresville office from 10:30 a.m.to 1:00 p.m. The
NCDENR Mooresville Regional Office is located at 610 East Center Avenue
in Mooresville. Directions are provided on the following website:
http://www.enr.state.nc.us/reaionaloffices/offices/mrowhere.html
At the meeting, as well as future agency and stakeholder meetings,
participants will be able to provide scoping comments on draft review
documentation for the EIS. The agenda for the January 21 meeting is
attached. Prior to the meeting, please review the agenda and the
attached agency stakeholder letter which outlines the scoping meeting
format.
The draft Alternatives Analysis, prepared by McGill Associates, is also
provided for your review prior to the meeting. Because of the large
size of the file, the report is not attached to this email, but is
available on the ARCADIS ftp site. To download the report, go to
http://filetransfer.arcadis-us.com, (Copy this address into your web
browser.) Provide the following (case sensitive) user name and password
- Username: arcadisftp Password: Tr4nsf3R. Then click "Login." Select
"From ARCADIS" then the "Cleveland County Water" folder. The
alternatives report is located in that folder. We will provide hard
copies of the reports at the meeting.
The draft purpose and need statement was provided to you by email on
January 7, 2009. The report is also available on the ARCADIS ftp site.
These are the two documents/issues that will be presented at the January
7 meeting.
Please contact Robin Pugh if you have problems accessing the reports on
the ftp site.
We look forward to seeing you on the 21st.
Robin Pugh, AICP
ARCADIS
801 Corporate Center Drive, Suite 300
Raleigh, NC 27607
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
From: Wicker, Henry M JR SAW
[mailto:[e-mail]]
Sent: Friday, December 19, 2008 10:20 AM
To: gwood@lincolncount_y.orq; [e-mail];
[e-mail]; Britt [e-mail];
[e-mail] [e-mail];
[e-mail]; [e-mail];
[e-mail]; [e-mail];
------------------------------- -
[e-mail]; smtp-Mead, L I Jim; [e-mail];
-. T
[e-mail]; allen ratzlaff@fws_gov; Bryan [e-mail];
Fox.Rebecca@epamail_epa.gov; hortonjlPdhec.sc`qov; [e-mail];
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EPA comments on Cleveland Co P&N statement
[e-mail]; Manager-; [e-mail];
[e-mail]; [e-mail]; [e-mail];
ron mccollum
Cc: Pugh, Robin; O'Quinn, Barney; [e-mail];
[e-mail]; [e-mail]; Jones, Amanda D SAW
Subject: Cleveland County Water Agency/stakeholders scoping meeting
January 21, 2009, 10:30 at the NC DENR Mooresville office
(UNCLASSIFIED).
Classification: UNCLASSIFIED
Caveats: NONE
Hello everyone,
The Wilmington District US Army Corps of Engineers, Regulatory
Division is continuing the National Environmental Policy Act (NEPA)
process in developing an Environmental Impact Statement (EIS) for
Cleveland County Water's proposal to construct a water supply reservoir
in the First Broad River basin near Lawndale in Cleveland County, North
Carolina.
We will be having an Agency/stakeholders scoping meeting to get
comments on revised draft documents on January 21, 2009, 10:30 at the NC
DENR Mooresville office. We will send out the copies of the
documentation on January 7 to provide you two weeks to review the
documentation (revised Purpose and Need Statement, Alternatives
Analysis, and Service Area). If can't make the meeting on January 21,
you will still have the opportunity to send your comments to me by
February 4.
The purpose of this E-mail was to give you enough time to pencil
the meeting date on your calendars if you wanted to attend. We will
send out more information about the meeting on January 7.
Let me know if you have any questions.
Henry
Henry Wicker
Project Manager
USACE Wimington District
Post Office Box 1890
Wilmington, NC 28402
Fax [phone]
[phone]
Classification: UNCLASSIFIED
Caveats: NONE
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EPA comments on Cleveland Co P&N statement
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